Safetip #33: Key Questions to Identify Chemicals to Substitute
OSHA Has Developed a Step-by-Step Toolkit for Chemical Substitution
Chemical exposures in U.S. workplaces are responsible for many occupational illnesses and fatalities. To reduce the risk of illness and death due to chemical exposure and protect workers, OSHA recommends the reduction or elimination of chemical hazards at the source through informed substitution.
To help companies transition to safer chemicals, OSHA has developed a step-by-step toolkit that provides information, methods, tools and guidance on using informed substitution in the workplace. The first step consists of forming a team to develop a plan to transition to safer chemicals.
Examine the Current Uses of Chemicals
As part of the second step of the toolkit, “Inventory & Prioritize”, organizations should identify target chemicals for informed substitution, by determining how the chemicals are used in the workplace and the hazards associated with each chemical. OSHA provides the following key questions to help identify chemicals that should be substituted:
For each chemical, consider:
- Where is the chemical being used?
- What function does the chemical perform?
- Is the chemical necessary in the process or product? Could the chemical be eliminated without adversely affecting product or process performance?
- What are the hazards associated with the chemical and how could its use harm workers?
- How are workers potentially exposed to the chemical (i.e. during manufacturing of the chemical or product, when using a product containing chemicals, when applying the chemical in a service industry, or during chemical disposal)?
To identify priorities, consider:
- What hazards should be eliminated or reduced first?
- What uses of chemicals are of greatest concern?
- What potential chemical exposures to workers are of greatest concern?
- Could a chemical or process change help improve workplace safety and health?
- Are the identified priorities consistent with the work plan for transitioning to safer chemicals?
After going through the key questions, hazardous chemicals should be prioritized for substitution. OSHA mentions the following criteria that can be used for the prioritization: hazard, exposure, risk, regulation potential, established company policies, interests of relevant stakeholders, and substitution potential. Every single chemical does not have to be substituted immediately. Rather, the work plan should reflect the priorities, and the transition to safer chemicals can be gradual, in order to make an efficient use of limited resources.
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For additional information on product stewardship solutions that can help you manage chemicals as part of your work plan for transitioning to safer chemicals, download Verdantix’s report Smart Innovators: Product Stewardship Solutions.