It is widely recognized that the most effective method to eliminate or reduce adverse health and safety outcomes in the workplace is to eliminate hazards at the source, before applying other, less effective forms of protection. This industrial hygiene principle, known as the hierarchy of controls, has been well-studied, widely accepted and prominently incorporated into practice by businesses and industrial hygiene professionals throughout the world.
In chemical management, this hierarchy guides employers and workers to eliminate or reduce hazardous chemicals at the source by substituting them with safer alternatives. Unlike traditional engineering controls, administrative controls, work practice controls, or personal protective equipment, these strategies can completely eliminate exposure to hazardous chemicals, reduce the potential for chemical accidents, reduce disposal costs, and remove concerns regarding worker compliance and equipment maintenance.
Eliminating or reducing chemical hazards at the source, when coupled with a thoughtful, systematic evaluation of alternatives and the adoption of safer chemicals, materials, products and processes, can provide substantial benefits to both workers and businesses.
Improve worker health and safety: In the United States, it is estimated that chemicals are the cause of more than 190,000 illnesses and 50,000 deaths suffered annually by workers.1 These numbers are likely an underestimate due to long latency periods between chemical exposures and the onset of disease, unrecognized relationships between illnesses and chemicals, and other factors. Replacing known hazardous chemicals with safer alternatives could help reduce these numbers.
Reduce costs: Using hazardous chemicals in the workplace results in substantial direct, indirect, and liability costs to businesses and society.2 Step 4 of the toolkit outlines these in detail. Transitioning to safer alternatives can reduce these costs, as well as improve other important measures of success, such as performance efficiency, industry leadership and corporate stewardship. A 2008 study by the American Industrial Hygiene Association demonstrated that making process improvements designed to reduce or eliminate workers’ exposures to hazardous chemicals resulted in greater savings and other benefits than implementing controls further down the hierarchy (i.e., engineering controls, administrative and work practice controls, and PPE).3
Reduce potential for regrettable substitutions: Hazardous chemicals have the potential to be replaced with substitute chemicals or redesigned products or processes that may pose new and potentially greater hazards to workers. Implementing a process of informed substitution – which examines the hazard, performance, and cost of all options – can protect workers and identify replacements that are unlikely to cause more problems or be a target of future regulatory efforts.
Achieve compliance with laws and regulations: Although federal, state, and local legislation in the U.S. has been in place for many years to regulate chemicals (e.g., OSHA’s Occupational Safety and Health Act of 1970, EPA’s Toxic Substances Control Act of 1976), in recent years new international, federal, and state regulations are now requiring manufacturers, importers, and distributors to disclose more information about chemicals throughout the supply chain (e.g., REACH), avoid certain chemicals (e.g., Restriction of Hazardous Substances Directive (RoHS), Maine Kids Safer Products Law), and implement safer chemicals where feasible (e.g., EU Chemical Agents Directive, EU Carcinogens and Mutagens Directive). Additional laws and regulations restricting hazardous chemical use or emissions are also on the horizon. The cost of not complying with existing laws or preparing for future efforts can be substantial. For example, as a result of a European Union law restricting certain chemicals in electronics, 29% of 200 U.S. firms surveyed incurred lost or delayed sales into the European Union costing an average of nearly $2 million per firm.4 Taking a proactive approach by transitioning to safer alternatives can not only help businesses remain compliant with laws and regulations, but also remain competitive in a global marketplace.
Create safer products for consumers and the environment: Transitioning to safer chemicals in the workplace can also contribute to creating products that are less hazardous for consumers and for the environment. This gives businesses the opportunity to brand their company with a new, green and innovative image.
1 This number is derived using the methodology from “Green Chemistry in California: A Framework for Leadership in Chemicals Policy and Innovation,” (http://coeh.berkeley.edu/docs/news/06_wilson_policy.pdf *(PDF)) to estimate illness and deaths attributable to workplace chemical exposures.
2 For more information about the costs associated with workplace injuries and illnesses, see OSHA’s Safety and Health Topics Page on the Business Case for Safety and Health: https://www.osha.gov/dcsp/products/topics/businesscase/
3 American Industrial Hygiene Association. (2008). Demonstrating the business value of industrial hygiene: Methods and findings from the value of the industrial hygiene profession study. Retrieved from: http://www.aiha.org/votp_new/pdf/votp_report.pdf *(PDF)
4 University of Massachusetts, Lowell. (2010). CLEAN TECH: An agenda for a healthy economy. Retrieved from: http://www.sustainableproduction.org/downloads/CleanTechLongFinal2-10_000.pdf *(PDF)
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