Step 6: Pilot the Alternative
Plan the technical and organizational changes needed on a smaller, pilot scale, before fully implementing the alternative. This step will help you test and evaluate the change in order to identify successes and failures and recognize long-term impacts or problems.
- Does the alternative perform well?
- Does the alternative change working conditions?
- What training do workers need to safely and effectively use the alternative?
- Are there any unforeseen effects or trade-offs of using the alternative?
- Is there a secure supply of the alternative?
- How could the alternative be implemented on a larger scale?
Before shifting completely to a safer alternative, it is important to apply the change on a smaller scale, especially if you are making a complex change. For some alternatives, you may need to conduct a field testing program to make sure the preferred alternative meets your performance expectations and product quality requirements, and that any unforeseen changes in use patterns or exposure are identified. Performance and quality can be affected in the process itself, as well as in any related upstream or downstream processes.
To get the best results, it is important to involve the workers who will be impacted by the change. You should discuss when and how to make the change and ensure that workers are trained and feel comfortable working with the alternative chemical, product, or process before the testing begins.
During the pilot or field testing of the alternatives, consult and involve workers to assess the performance, cost, and health and safety impacts on the work environment. It is also important to identify and evaluate any potential unexpected problems that occur, including any shift in risks or new hazards presented by the alternative (e.g., ergonomic, noise, vibration, environmental impacts, fumes and gases formed in the process). You may also consider developing a job hazard analysis [PDF*] to describe the changes and identify hazards involved with shifting to a safer alternative. To ensure that the alternative is not negatively impacting workers, you should consult your OSHA 300 logs to identify any unexpected injuries or illnesses that may be associated with the use of the alternative. Modifications to the choice of chemical, process or work practice alternatives may be necessary as a result of this pilot testing.
Pollution Prevention-Occupational Safety and Health Work Site Assessment (P2OSH)
Researchers from the University of Massachusetts, Lowell, developed the P2OSH strategy for identifying, implementing, and evaluating pilots of safer alternatives. A key component of this strategy is a work site assessment survey that can be used before and after piloting a safer alternative to collect information on the work environment, the materials used in the process, the potential impact of changing materials on the safety and health of affected workers, the workers’ perceptions of the pilot, and the direct costs associated with the pilot. The results of this survey can be used to compare worksite changes, evaluate the technical function of the alternative, and determine whether a full scale implementation of an alternative is appropriate or what changes are needed to better protect the health and safety of workers.
Accessibility Assistance: Contact OSHA's Directorate of Standards and Guidance at (202) 693-1950 for assistance accessing DOC, EPS, GIF, MP4, PDF, PPT or XLS documents.
*These files are provided for downloading.