Working with Newer Chemicals
  Barbara Kanegsberg
  The choice of chemistry, be it a single molecule or a blend, is often driven
      by environmental requirements. Given the plethora of environmental regulatory
      mandates, employee safety can all too easily be pushed to the back burner.
  Toxicologists in Utah recently reported exposure of workers to high levels
        of n-propyl bromide (nPB, 1-bromopropane). SQRC has reviewed information
        obtained from OSHA, and we have spoken with some of the researchers involved.
        According
        to the OSHA report, the manufacturing process involved spraying an adhesive
        that contains nPB onto foam as part of the production of foam cushions
        for furniture. Three employees were seen by emergency room doctors, hospitalized,
        and diagnosed with bromide toxicity. At least some employees appeared
          to be
        exposed to high levels of the adhesive over a period of years.
  
What changes could be made to make the process safer? The statements
          in the OSHA report strongly suggest the need for improved worker safety
          and
          for improved
          worker education. Rather than presenting a negative case-study or rather
          than attempting to second-guess what might have been done, the episode
          is more productively
          used as the inspiration for positive, common-sense, and relatively simple
          reminders about the basics of chemical handling. While in this instance
          the problem was
          exposure to exceedingly high levels of nPB, the bottom line is that any
          chemical, particularly any aggressive (or effective) chemical, chemical
          blend, or chemical
          process, has the potential for worker exposure problems. 
  
Chemical Management Reminders
    A written safety and health program is essential, but it is not sufficient.
            To be of value, the safety program must actually be implemented. 
  In the course of our own site visits, we occasionally see pro-forma, “canned” hazardous
            communication programs. There they are, in impressive bound notebooks,
            taking up space on the shelf. Most of us in the manufacturing world
            are pre-occupied
            with production issues, quality issues, cost containment, lean manufacturing,
            and environmental regulatory concerns. Books of MSDS and lofty tomes
            of written verbiage are of no value if the appropriate ways of working
            with both the
            chemical and the process are not communicated in a compelling and
            effective manner. 
  
Information about pertinent health/safety policies and procedures need
              to be provided to employees in a manner that is clear, definitive, and
              understandable.
  All employees have to be educated in managing not just hazardous materials
              but also the total process. Aside from worker safety, such communication
              makes sense in terms of product quality. If your management tends to
              move safety
              concerns to the back burner, you might remind him or her that safety,
              process consistency, and product quality can be treated as a single issue.
              Unsafe
              practices tend to reflect poorly controlled processes and a high reject
              rate. When employees
              are asked to perform a manufacturing process, an employer interested
              in making a profit teaches employees to achieve a technically correct
              product.
              It is
              imperative that employees are also taught to achieve the appropriate
              safety, chemical handling, and environmental aspects of the process.
  
The hazards of the workplace must be clearly and compellingly communicated
                to workers. For most of us, information about chemical hazards does not
                inherently make for fascinating reading or a compelling lecture. The
                challenge is to make
                chemical handling information compelling and memorable.
  
I suspect that we have all seen incorrect chemical handling and poor process management; and this is by no means restricted to supposedly unsophisticated or uneducated workers. Engineers, academics, even rocket scientists have been known to store bottles of toxic, flammable, and reactive chemicals in their offices. Some anonymous colleagues like to store their MSDS book in the refrigerator, presumably to dampen even the mere description of reactivity of incompatible chemicals. This is amusing, unless someone has to find emergency chemical information quickly.
  Further, we have the additional challenge of communicating
                    hazards to workers where English comprehension is very limited
                    and where
                    workers are simply
                    not comfortable speaking English. In our inspirational example,
                    the employees
                    using
                    nPB had Hispanic surnames; and it is our unofficial understanding
                    that they were all immigrants. The OSHA report does not indicate
                    the language
                    of the
                    worker safety program. I have long been in favor of having
                    MSDS and safety related programs appropriately translated.
                    Over the
                    years,
                    I have unfortunately
                    heard supervisors say: “Let ‘em learn English, like my grandpa
                    did.” Desirable as this may be for the overall cohesiveness
                    of the Nation, it is vital to communicate important health,
                    safety, and
                    technical
                    information
                    within the comfort level of the workers. 
  
Speaking of comfort level, the most successful safety programs I have seen involve multi-media communication, and with good reason. For one thing, we learn differently. Some of us do better with lectures or demonstrations than with the written text. For another thing, semi-literacy is a reality; I have had to educate workers who were functionally illiterate. Humor helps, a lot. Employees who block out the “red-asphalt” approach to safety training will often remember safety procedures that are presented in a humorous manner.
  The bottom line is that employees must understand both
                        the technical aspects of the job and the safety aspects
                        of the
                        job. If you
                        hired them, you have
                        to teach them. If you hired those MIT grads who are convinced
                        the laws of physics
                        don’t apply to them, either re-educate them, or hire
                        different MIT people. If you hired a group of assemblers
                        from a remote
                        South-sea island
                        who speak
                        only an obscure dialect of an unknown language, either
                        learn that language or find a good translator; and get
                        that safety
                        program
                        across to them.
    • Just as acceptance criteria and a daily maintenance program for
    equipment are important, it is imperative to have initial safety training
          for new employees and to schedule regular safety meetings. 
  Most successful companies would not purchase production equipment without
                          making sure that it is built to specification, that
          it performs properly, and that
                          it is maintained properly. This involves initial acceptance
          criteria, ongoing maintenance, and ongoing performance criteria. In
          a similar manner, there
                          is a well-established confluence of safety, environmental,
          and
              quality issues (Kanegsberg, Kanegsberg, and Unmack). Effective
          production means more than
                          training workers in performance, worker safety, and
          environmental issues. Because
                          processes are increasingly complex, training by rote
          is not enough, we must educate workers both initially and on an on-going
          basis.
                Unfortunately, some
                          of the same companies that would never consider running
          equipment
                and processes without both acceptance and maintenance criteria
          consider that “on the
                          job” or “on the spot” safety training
                          is a reasonable approach. Bad idea!
  
Training is only one aspect; because people are complex (have many variables), you have to actually observe your work force. As is the practice in many companies, the company with the nPB exposure issues had an ongoing drug testing program, both prescreening and random testing. A drug testing program may be useful in some instances; and such a program might be considered quantifiable and easier to manage. As a chemist who at one time designed clinical laboratory tests, including drug tests, it is my opinion that, while such testing may have value in some situations, it cannot replace observation, and communication with employees.
  If production equipment began to malfunction in a
                              manner not covered in the Preventive Maintenance
                              program or
                              if the process
                              changed
                              in a manner
                              not
                              covered by normal monitoring, management would
          very likely take action. In an analogous
                              sense, employees may be sober; they may use no
          illicit drugs. However, ongoing observation of employee behavior
                              and communication
                              with
                              employees might prompt
                              suspicions concerning overexposure to industrial
                              chemicals. For example, higher than expected lost
                              workdays or
                              a drop in productivity
                              during
                              exposure to a
                              chemical could be a warning sign. It is important
                              to take immediate action if an employee appears
          to be
                              intoxicated or starts to
                              behave haphazardly,
                              or complains that he or she is “high.” The “high” could
                              very well be attributable to chemicals in the workplace (or perhaps coming
                              from a neighboring workplace); the “high” may
                              not be from a recreational drug.
  
Perhaps more importantly, we do not want to reach the point of overexposure. Controlling and minimizing exposure to all industrial chemicals is essential to worker safety. In addition, in our experience, reducing chemical loss improves the bottom line and the steps leading to appropriate chemical control tend to go hand in hand with a higher quality product.
    In setting up and controlling any industrial process
                                  involving chemicals, it is important to evaluate
                                  the process on a case
                                  by case basis.
  I personally cast a jaundiced eye on uncontrolled,
                                  highly emissive uses of any chemical; I prefer
                                  to see solvent
                                  containment that is protective
                                  of both
                                  employees and the environment. In managing
                                  the containment of any solvent for any process,
                                  it
                                  is important to
                                  consider and coordinate the technical,
                                  environmental,
                                  and safety aspects.
  In designing process controls, it is important
                                    to consider not just the single employee
          but any potential negative
                                    impact of a control on others
                                    in the workplace.
                                    For example, where exhaust fans are employed,
                                    they have to be placed effectively. Placing
                                    fans in
                                    a tandem manner
                                    can
                                    have the undesired effect
                                    of pushing
                                    vapor-laden exhaust air away from one employee
                                    into the breathing zone of other employees. 
  
Then there is the matter of respiratory protection. Engineering controls (where emissions from the process are minimized) are far preferable to employee respiratory protection. However, where respiratory protection is provided, it has to be appropriate to the chemical under consideration. Employees have to understand when it is required, and they have to be trained in how to use it. In some cases, additional personnel monitoring is required. Simply providing the equipment is not adequate. Further, in a number of instances, we have seen workers incorrectly assume that nuisance odor masks will provide protection from chemical vapors.
    How do we know what constitutes a high
                                        exposure? We don’t
                                        always know. Monitor all chemicals and
                                        blends, understand what you are using,
                                        how your
                                        process works, and minimize exposure. 
  Some people, even some safety professionals,
                                        take issue with air sampling when the
                                        exposure level
                                        has not been
                                        firmly
                                        set. We do
                                        not agree with
                                        this attitude,
                                        particularly because new chemicals and
                                        chemical blends are continuously being
                                        introduced.
                                        For many if not
                                        most chemicals
                                        and chemical
                                        blends, inhalation studies have not been
                                        performed. Other safety professionals
                                        and some enforcement
                                        people agree with this more prudent approach,
                                        citing Section 5 or what is
                                        commonly termed the “general duty clause” of the venerable Public Law 91-596.
                                        This section alludes to workplaces that are “free from recognized hazards.” I
                                        think we have to “recognize” that
                                        all industrial chemicals pose potential
                                        hazards, depending
                                        on how they
                                        are used.
  As with many halogenated solvents, exposure
                                          studies using animals and cell-culture
                                          (in vitro) studies
                                          are being
                                          conducted on nPB. While agencies
                                          debate an
                                          appropriate exposure limit for nPB,
          it would seem reasonable to minimize worker
                                          exposure,
                                          and to document both by analytical
          techniques, by process design, and by employee education
                                          that
                                          such exposure
                                          has been minimized. 
  To reiterate, it would seem unreasonable
                                          to avoid the concept of Section 5 by
                                          adopting process chemicals
                                          or chemical blends
                                          where the worker exposure
                                          profile is not well understood.
  Further the prudent employer, when
                                            adopting a new mixture to be used
          repeatedly and
                                            in an emissive
                                            manner, would
                                            do well to analyze the level
                                            of all major
                                            components of a mixture. There is
          a plethora of new chemicals on the market,
                                            and we
                                            know very little
                                            about
                                            the synergistic
                                            or antagonistic
                                            behavior
                                            of mixtures (This means that, for
          a mixture of two chemicals, one plus
                                            one could
                                            add up to greater than or less than
                                            two in terms
                                            of
                                            reactivity,
                                            cleaning ability, performance, or
          health impact.) So even if exposure studies
                                            have been
                                            conducted for the pure (neat) chemicals,
                                            it is very likely that exposure studies
                                            have not been done for every blend
                                            of those chemicals.
  A few concluding thoughts
  Let’s recap the major points.
1. A written safety and health program is essential, but it is not sufficient. To be of value, the safety program must actually be implemented.
2. Information about pertinent health/safety policies and procedures need to be provided to employees in a manner that is clear, definitive, and understandable.
3. Just as acceptance criteria and a daily maintenance program for equipment are important, it is imperative to have initial safety training for new employees and to schedule regular safety meetings.
4. In setting up and controlling any industrial process involving chemicals, it is important to evaluate the process on a case by case basis.
5. How do we know what constitutes a high exposure? We don’t always know. Monitor all chemicals and blends, understand what you are using, how your process works, and minimize exposure.
Environmental regulatory requirements and community environmental justice issues are often greater immediate drivers than are employee safety issues, in part because the inspections may be more frequent and fines may be very high.
  Workers, assemblers,
                                                          technicians are the valuable
                                                          assets of
                                                      a company. While “zero
                                                      risk” is impossible,
                                                      given the availability of
                                                      engineering controls and
                                                      of well-contained
                                                      process equipment, there
                                                      is no reason to compromise
                                                      worker
                                                      safety. If you extract the
                                                      essence
                                                      of the five safety reminders,
                                                      what emerges is:
  
Understand the process (including the chemicals)
Understand your workforce
Educate your workforce.
These concepts should be familiar to those concerned with enhancing the competitive edge. Indeed, when you implement an employee safety program, you also enhance process control, product quality, and lean manufacturing.
    References:
  File #305400616, obtained
                                                              from the Utah Labor
                                                              Commission, Occupational
                                                              Safety
                                                              and Health
                                                              Division, through
  a GRAMA request. 
  Kanegsberg, B., E.
                                                              Kanegsberg, and
          J. Unmack, “Safety, Environmental,
                                                              and Contamination Control,” A2C2
                                                              Magazine, March, 2004.
  Public Law 91-596,
                                                                Occupational
          Safety and Health Act
                                                                of 1970, section
                                                                5, “Duties.”