Posts filed under ‘EHS Policy’
While working and benchmarking with a wide variety of companies, I hear a range of interpretations of what constitutes an “ergonomics program.” Unfortunately, the term is being used to describe a mix of approaches (in addition to ergonomics) to managing musculoskeletal disorders (MSDs).
Several leading organizations are in the process of evaluating and changing their programs to simplify, improve focus and improve efficiencies in addressing and preventing MSDs. Currently, there are five general, but very different, approaches used to manage MSDs. Companies use a few, some, or all of these to reduce losses resulting from these types of injuries.
1. Change the Work and Workplace: This approach focuses on the design of new jobs, or changes to existing workstations, tools and equipment to better fit the population doing the work. This is occupational ergonomics, which has been defined by the National Institute for Occupational Safety and Health (NIOSH) as “The science of fitting workplace conditions and job demands to the capabilities of the working population. Ergonomics is an approach or solution to deal with a number of problems – among them are work-related musculoskeletal disorders.”
The most effective workplace changes are engineering controls, which are adjustments and changes in the physical workplace to ensure that the reaches, forces and distances are within the acceptable limits of the workforce. This means designing the workplace to fit people, from the fifth-percentile female to the ninety-fifth-percentile male, to prevent exposure to MSD risk factors for most workers. Engineering controls have been proven to be effective and efficient through research and benchmarking studies.
A secondary level of control is administrative controls, or changes to the administration of work, like job rotation, rest breaks and slowed pace. Unfortunately, administrative controls do not reduce or eliminate the presence of MSD risk factors; they just reduce the exposure time. They can also create additional work and challenges for managers and supervisors as they shift people between work task assignments.
Both of these types of controls are best supported by ergonomists, engineers, and professionals qualified in ergonomics.
2. Change the Capability of the Person: This approach is based on trying to change the capabilities, fitness and stamina of the individual doing the work. This is an element of fitness and wellness programs, and includes stretching, exercise and conditioning. The focus is on changing the individual employee and is dependent upon the willingness and participation of people, as well as their existing physical condition.
Although some organizations mandate stretching before and during work, many find it a challenge to get people to participate in stretching and wellness programs. In addition, company-mandated stretching programs have not been proven to be effective in preventing MSDs.
Unfortunately, employers have limited influence on the personal health and wellness of their employees, and have no control over pre-existing conditions. This approach is typically supported by fitness trainers/specialists, physical therapists and occupational therapists.
3. Change how the Person Performs the Task: This approach is based on getting people to behave differently in hopes of reducing exposure to MSD risk factors. This is behavioral modification, and may include behavior-based safety programs, training and awareness campaigns, and use of body mechanics. This requires people to change their perceptions of work and risk, and change how they perform work (consistently throughout the day, week and their careers).
Even when behaviors do change, they rarely have a significant impact on preventing exposure to MSD risk factors. Managers have expressed their frustrations on “getting people to use safe working practices.” This approach is typically supported by behavioral safety professionals/programs, training and fitness trainers.
4. Fit the Person to the Task: In this approach, the focus is on the individual employee (or candidate), measuring their physical abilities (strength, reach, range of motion), and matching their individual capabilities to the demands of work tasks. This is accomplished by conducting a Functional Job Analysis and Pre-Work Screening to match the results to Functional Job Descriptions.
It requires an investment in performing tests on each employee and the time to match them to the physical demands of a task. This practice was in favor in the 1960’s through the early 1980’s but appears to be waning. It is our experience that 15 to 30 percent of U.S. companies still practice this approach. Companies in which manual material handling and field tasks are common typically have these programs in place.
Physical therapists can provide valid test methods to help match the capabilities of an individual to the physical requirements of a task.
5. Fix the Person: When people experience an MSD or sprain/strain injury, they must be diagnosed and treated, and then managed in their return to work. This is medical management, a reactive program to reduce the losses due to injuries that have already occurred. The need for good medical management is totally dependent on the exposure to MSD risk factors in the workplace and the effectiveness of the ergonomics, fitness and job placement programs in place. A medical management program is best supported by health care providers (nurses and doctors) qualified in occupational health.
So, how does your organization manage MSDs?
What approach or approaches do you use?
What has worked for you and what hasn’t?
What changes have you made to improve management of MSDs?
On March 26, the Occupational Safety and Health Administration (OSHA) published its updated Hazard Communication Standard (HCS). The new rule, which applies to all hazardous chemicals, has been harmonized the Global Harmonization System (GHS) and will affect all companies that make, transport or use hazardous materials. Mark Duvall, Principal at Beveridge & Diamond P.C., has been following the HCS since it was a proposal in the early 1980s. We caught up with him this week to learn more about the updated rule and to understand its potential impact.
What’s the genesis of this latest HCS update?
OSHA adopted the HCS in 1983 and since then they’ve made a number of adjustments to it. They made the latest round of changes for two reasons. The first is because the GHS is out there and the United States wants to harmonize its hazardous communications with those of other countries for the promotion of international trade. The second is that the agency believed that GHS would represent a clear improvement in the hazardous communication standard and thus help protect employee safety.
What is the GHS?
In 1992 the United Nations Conference on Environment and Development issued a mandate to develop a globally harmonized chemical classification and labeling system. It adopted the GHS in 2003. The standard was intended to create a common system for hazard communications. At the time, the lack of consistency across countries was a burden to international trade.
The GHS applies to hazardous chemicals. It doesn’t apply to articles, or products that have a fixed shape, which are not intended to release a chemical. There are also exemptions for certain kinds of chemicals that are subject to detailed regulation in specialized areas. So drugs, toy additives and pesticide residues in food ‘at the point of intake’ are not covered by GHS. It does, however, apply to worker exposure and transportation of drugs, food additives and pesticide residues in food.
It’s important to note that the GHS is a hazard-based system designed for trade; it’s not a risk-based system. Each company in the supply chain must consider its own risk and exposure conditions and decide on risk abatement measures.
How does OSHA’s rule compare to the GHS?
Let’s begin by talking about the three main elements to the GHS:
1. The classification system: The GHS has identified physical hazards, chemical hazards and environmental hazards, and classified them by defining them and defining different categories within each hazard class with objective criteria. Once a classification for a chemical component has been determined, you then need to classify the mixture to which it belongs. Under the old OSHA standard, there was a pretty simple rule for determining the hazards of a mixture. The mixture was determined to have all the health hazards present if they had it at .1 percent or greater, with no regard to dilution. And that ran into a problem with acute toxicity for example if you took something that was acutely toxic at 100 percent and dilute it down to 5 percent, it might not qualify as acutely toxic anymore. What GHS does is it provides guidance on how to calculate the hazards of a mixture depending on the particular hazard categories of the various components and their proportions in the mixture. And there are different approaches for different kinds of hazards. It’s more complicated, but it’s generally regarded as a more accurate system than the old OSHA system.
2. Labeling: Under the GHS there are multiple things that must appear on the label: the product name, the company’s name address and phone number, the standardized hazard statement, a pictogram and a precautionary statement. Under the old OSHA standard, you could express a hazard using any statement you wanted. Under GHS, there is a prescribed hazard statement assigned to each hazard category. There’s also a requirement for a pictogram, or a symbol conveying a visual idea of the hazard. A precautionary statement is what you should do in response to this hazard information (e.g. first aid instructions, personal protective equipment). And finally, there’s a requirement for a signal word. One is ‘Danger,’ the other is ‘Caution’. This is all different from the old OSHA rule, which required only the name and address, the name of the product and “appropriate hazard warnings” (which led to very different descriptions of the hazards for the same product).
3. Safety Data Sheets: A safety data sheet is a written compilation of information about the hazards of that product. In industrial chemicals, there is a list of data elements that have to show up. Under the old OSHA standard there was no required format for that. Now, under GHS and now under OSHA, there’s a prescribed format for the disclosure on the safety data sheets. GHS does not use the term ‘material safety data sheet’, and OSHA is adopting that language so MSDSs will now be called Safety Data Sheets (SDS). There’s a standard format and there’s also specific information that has to be included in each section.
What are some of the differences between the GHS and the updated HCS?
OSHA has not completely taken GHS. There’s a whole set of environmental hazards that are classified in GHS, which are not included in the new OSHA rule because the agency doesn’t have statutory jurisdiction. However, OSHA does require companies to include the section heading for environmental hazards; the hope is to encourage voluntarily disclosure of that information.
OSHA also adds some requirements that focus on the workplace where chemicals are present and where there is exposure potential. It requires training, it requires a written hazard communication program and it requires labeling of containers and chemicals in the workplace. Because GHS focuses on trade, it doesn’t really address the occupational exposure aspect.
The OSHA rule also differs from GHS in its classification requirements. Under the old OSHA standard, you simply had to indicate that something was acutely toxic. Now, under the harmonized rule have to classify the hazard of acute toxicity and put it into one of several buckets. Rather than adopt all five GHS categories, OSHA omitted the lowest toxicity level because it concluded that it wasn’t appropriate to in a worker protection context.
When does the new OSHA rule go into effect?
The rule goes into effect on May 25, 2012 but compliance will take place in stages:
- Dec. 1, 2013: Deadline for training employees on the new label elements. Companies will start transitioning to GHS and they need to train employees to understand the new label warnings, particularly the pictograms.
- June 1, 2015: Classification, labeling and the SDS requirements. This is the same date that the European version of the GHS goes fully into effect. Distributors, however, may continue to ship products with the old labels until December 1, 2015.
- June 1, 2016: The other workplace requirements take effect. These include requirements for hazard communication program and training on newly identified hazards. Between now and then, companies can comply with old rule, new rule or with both.
Mark Duvall is a Principal with Beveridge & Diamond, P.C. in Washington, DC, where he heads the law firm’s chemicals practice, as well as its FDA and OSHA practices. He will share his advice during NAEM’s upcoming webinar, “Preparing for the OSHA’s Globally Harmonized Hazard Communication Standard” on April 24.
This week NAEM’s Upper Midwest Local Networking Group met to discuss regional water management challenges and to explore best practices from around the world. We caught up with speaker David Crisman, Principal of EHS Management Associate LLC, to learn about his research on water management approaches in Australia.
GT: Why did you begin research water management approaches in Australia?
DC: In the case of Australia, what has been the most fascinating to me is the Murray-Darling River Basin. It’s 14 percent of the country area-wide, six percent of the water that falls on Australia falls in the basin. It’s something like half of all the agriculture comes from the basin. Just to give you an idea, 44 percent of the water consumed in Australia goes to agriculture, so you’ve got fairly substantial land area, not so big of an input (because the only input is rain) and a huge water take. And now even in a good year less than half of the water makes it to the ocean. So it’s like our Colorado River.
In Australia, the individual states control resources, so the federal government said, “Wait a second. We’ve got three major states drawing water and as the federal government, we need to say what is the environmental water needed just so it makes it to the ocean so we have aquatic habitat, we have tourism, we have those benefits that we don’t normally think about, rather than throwing it on a rice field.
I thought this was a really good example to look at because as industry people, we don’t think of water coming in; our requirements are always on the water going out. And in the industry, I used to work in (specialty chemicals), water quality was important. If you start taking too much water out of this area, you start having saline problems, you start having acidification problems. Even if I had a plant in this area, you could be saying, “Is it drinkable?” but also, “Is it even useful in a manufacturing setting?” We don’t think of the upstream side. We think of the wastewater side.
So I was really trying to get into that particular issue by taking a look at Murray Darling. I think the cutting-edge thought was what they came up with, which was to create a water market. They said, “The Basin has a finite amount of water and we’ve got to balance this whole water usage and it doesn’t matter if you’re taking it from a well or you’re taking it directly from the river, we’ve got to figure out that balance. It’s a commodity, there’s going to be years it’s in surplus, years that it’s deficient, so how do we, as Australia, buy water to lower the allocation within the Basin so there’s enough water for fish, for flow and all those other things?”
It’s a good technical problem.
GT: What are some of the guidelines of the water market Australia established?
DC: There’s permanent trades that going on – I can actually sell you my rights as a property owner—and there are allocation trades—I can sell you my annual take because it’s low this year. So if the tomato farmer decides it’s more worth his while to sell his allocation this year, he can give it to the guy who owns the vineyard. So what is the value of water? There are also regulations in place to ensure that the way you use the water on your land doesn’t impact others. So the legal framework is critical, too.
GT: How can those lessons be applied to water management in the Upper Midwest region?
DC: Everything has a yin and a yang. So the fact that we have constant supply is really great. We may never think about water coming into a facility, but when we turn the tap, we will have water. The negative is ‘Have I really been thinking of the cost?’ And will that price for water increase? And will it become a variable cost for me? Meaning that one year I will pay x, but two years later it may be 5x or something more. For businesses, it’s probably easier to plan on price than to deal with a disruption. So that’s probably an overall positive.
The next thing is quality. If I can get to a consistent quality grade it’s going to mean less disruption, less upset for my manufacturing process. But that again boils down to price. And then you start to see intangible benefits and impacts. People can’t come to work because their neighborhood is on fire. If you can have consistent supply, you can perhaps deal with drought situations. And of course there are lifestyle impacts in Australia because if you look up Australian water restrictions online you’ll see pages of instructions of when you can water your lawn, do your laundry. That’s at a more personal level but it could reach industry as well.
GT: How close do you think we are to seeing some of the approaches being used in Australia to be applied to the U.S.?
DC: It’s hard to say because it sometimes seems like if we want to focus on an issue, we need to have a crisis. Last year we were dealing with too much water. I think the question of quantity has to be driven by a drought. And certainly the Texas situation if it continues may end up pushing a lot of buttons because those Great Lakes look awfully tempting.
David Crisman is the Principal at EHS Management Associate. As the former EHS Director for a global, specialty chemical company, he is well-aware of the challenges facing today’s EHS managers. He continues to study trends to deal with water supply and quality issues throughout the world.
To learn more about NAEM’s Upper Midwest Local Networking Group, please visit http://www.naem.org/?LNG_Upper_Midwest
At this year’s NAEM Forum in Tucson, several speakers and participants made the point that a strong environment, health and safety (EHS) culture is a prerequisite to achieving and sustaining a high-level of EHS performance, and EHS managers are better served by focusing on building an EHS culture than focusing strictly on outcomes. Building a culture that values EHS is difficult and takes years, so it’s important to have a clear vision of what a strong EHS culture looks like. Here are my thoughts on the core characteristics of a strong EHS culture.
- Top management is involved and visibly supportive: Senior managers include EHS in enterprise goals, metrics, and operations reviews. They engage in safety-related activities, such as safety walks and self-audits, and set a clear and consistent tone through their actions that EHS is a core value.
- All levels of management are accountable: EHS comprises a significant portion of performance evaluations for managers and supervisors. Managers and supervisors are expected to create a safe work environment for their associates, and ensure the people under their supervision tend to their EHS responsibilities with the same rigor as they do quality, productivity and schedule.
- EHS is integrated into core business processes: The EHS program is made operational through the enterprise business management system and standard operating procedures. In enterprises where EHS is well-integrated, EHS doesn’t require special attention or management exhortations. It is simply how business is done.
- EHS is communicated effectively and frequently: EHS requirements are understood by all associates. New associates receive EHS training appropriate to their jobs as part of orientation. Management realizes that the importance of EHS must constantly be reinforced to achieve and maintain a high-level of performance.
- Doing the right thing is innate: Associates have a high-level of EHS awareness, receive sufficient and continuous EHS training and are given the tools to ensure effective EHS management. Associates do the right thing and do things right, even when nobody is watching.
- Associates are motivated: People find intrinsic value in high EHS performance. They understand its contribution to the success of the enterprise and take pride in doing their part.
What characteristics do you think are essential for a strong EHS culture?