Hazardous Materials management in government facilities is so challenging that U.S. government dollars have been allocated to the creation of a fictional character named Hazardous Matt to help industry recognize when the shipment of materials is hazardous. Despite the many clever ways to identify hazmat, (see Do you know the L-TRIC) hazardous material management is a sector where specific knowledge is required to satisfy specific industry needs. Government facilities face significant challenges due to some unique factors such as:
- Size (acres) According to Wikipedia, Federal lands total 640 million acres.
- Size (people) According to the Office of Personnel Management, the federal workforce is composed of an estimated 2.1 million civilian workers. Keeping 2.1 million workers safe is a big responsibility.
- EPA ID numbers – Due to the uniqueness of government operations, it is not uncommon for one facility to have multiple EPA ID numbers.
- Federal Departments- Each department has different practices. Department of Defense, Department of Energy, Department of Justice, Department of Veterans Affairs, they all have different policies, different practices and different operational risks.
- Divisions – Even the same department can have different divisions and therefore different practices. Take the Department of Defense for instance. The Army, Navy, Air Force, Marine Corps, Coast Guard and NASA must comply with all federal regulations including executive orders. They get guidance from programs like the Navy’s CHRIMP Program, but overall, the chemical lifestyle cycle is the same for all departments and divisions from procurement to disposal.
Common Ground
Even though there are significant challenges, all of these federal entities and subdivisions are obligated to protect their workers. Policy, procedure, and partnerships with safety advocates are designed to protect the safety and health of workers during construction of new research facilities, the recommissioning a submarine or performing maintenance on an aircraft.
The common ground for all of these operations is the life cycle of hazardous materials. Once the need for a material is identified, it must be purchased either through a local supplier or through a procurement system. Safety Data Sheets must be located and obtained either from the manufacturer or through a service that can search, find and retrieve the SDS. Next, they must map their facility by knowing who is using what chemical and where. It’s important to note that each department has specific needs and may need some advice on creating similar exposure groups to track chemical usage. This will create efficiencies when distributing hazmat, as it makes sense to have a point of issue near where the work will take place, just like it makes since to put a pharmacy, where medications can be dispensed in a hospital. Those locations may also be the points where hazardous waste is generated and can be identified as hazardous waste collection area. Hazardous waste management is a process all in itself, but for simplicity of the life cycle, we know it must be collected, stored and disposed of properly. Proper management of chemicals in the workplace is the shared interest between government agencies and departments and the common ground they share.
Divergence
Where different agencies ideals differ is on how to achieve this goal of protecting their workers. Many government institutions have created their own home-grown software technologies to manage these arduous and diverse processes. This has been an acceptable practice for decades but with cyber security becoming a top priority over the past several years, home-grown and in-house managed software product cannot easily maintain the level of cyber security scrutiny required. Additionally, it is often the case to have one expert who can fix all database issues or run a report, but when that person is unavailable temporarily or permanently (vacation or retirement, for example), the system fails, and the process breaks down.
Convergence
The best option for government agencies to meet their Hazmat operations is an enterprise software solution. The core of this is a unified central database that gives access to all functions, areas and units that need to be looking at chemical inventory. The process can start with authorization to bring the chemical on site. Specific departments can review the request and either approve or deny the request. If approved, the chemical can be purchased locally or ordered through the procurement system. When the chemical is received on site, it can be matched to the request, ensuring it goes to the right person and activity. Inventory levels can be tracked; the material is transferred or issued to the person that will use the chemical much like receiving a prescription at a pharmacy. The process that the chemical will be used in can also be tracked, and industrial hygienists, toxicologists and air emissions personnel will benefit from available data from these activities. If only a portion of the chemical is used, the remainder can be turned back into storage locations for others to use, or it can be transferred to waste management for disposal. Experts agree that there is significant cost and process savings in an efficient approach where leftover chemicals can be utilized rather than disposed of. Tracking chemicals from delivery to usage and disposal using Chemical Safety’s Environmental Management Systems (EMS) software allows any agency to manage the chemical life cycle while addressing any unique requirements for a specific department.
Disposal
Since EPA and DOT regulations establish the requirements for management of waste from generation to disposal, there is common ground on what needs to be done, but how to achieve compliance is another point of divergence between departments.
Unfortunately, hazardous waste doesn’t come packaged with a GHS label and an relative SDS. Instead, waste is collected and sorted with a waste identification and testing process and creation of waste profiles. Often, waste is collected in areas where it is generated; for example sand blasting waste is stored near the process, paint wastes are stored near the paint booth and laboratories have small waste storage areas in the lab. These areas are identified as waste collection areas and have restrictions on amounts and times. Once those sites are full, a disposal contractor can schedule a pickup and take the waste away with a hazardous waste manifest. Chemical Safety’s hazardous waste software has all the features needed to track waste from generation through to disposal including automatically generating labels, manifests and related regulatory reports.
Reporting
And just when you think the process is complete, it’s time to report on all of the above processes! With Chemical Safety’s EMS software, all of the data gathered in the process are available for reporting. Preconfigured reporting is available for federal, state and local reporting as well as robust ad hoc reporting functionality that allows custom report creation. The Federal Waste Biennial report is a good example of a difficult report to produce accurately that the EMS technology simplifies dramatically. With technology, actions taken are automated and can ensure that information is correct, current, and readily available. This makes meeting a reporting deadline a simple step, operations are improved, and efficiencies are increased.
Summary
Chemical management within government is not mission impossible! Even though government facilities face significant challenges due to some unique factors of their operations, they do share common ground in that they are all trying to achieve efficient and effective chemical life cycle management and regulatory compliance. If your agency is still operating on a home-grown or in-house system, it is time to pursue a more secure and coherent system that will bring convergence to your operations. Connect with us at Chemical Safety for a demonstration of our EMS software or visit us at www.chemicalsafety.com.
