When asked to elaborate on their chemical management programs, colleges and universities refer to policies and procedures. The policies promote safety and prevent adverse employee health problems associated with exposure to and use1 of hazardous materials. Hazardous materials in a university setting includes not only chemicals, but also radioactive material and biological agents in the workplace. For policies to be effective, they must be backed by procedures that provide for the orderly implementation of established policies. Universities will typically reference the Occupational Safety and Health Administration (OSHA) Hazard Communication Standard as the guide to assure every effort is made to reduce the incidence of illness and/or injury caused by working with and use of hazardous materials.
A university policy is a rule that has been officially sanctioned by the administrators of the university and usually has university wide applicability. Policies, programs, and procedures often go together to articulate a hazardous materials management solution to inform employees of the hazards they may be exposed in the workplace and of the protective measures available.
Hazardous Situations at a University
Administrators know that universities are inherently at risk because they work with so many types of chemicals and hazards; yet hazard communication seems complex because the distribution and use of chemicals is constantly changing. Chemicals are present on campus in laboratories, fabrication shops, auto repair and art departments, just to name a few. Universities that are partnering with industry often have tenants, contractors or partners on site and must distribute the policies and procedures to those entities. The more chemicals that are on-site, the greater risk for a hazard communication violation. A written Hazard Communication plan is the backbone of the program but this plan is often out of date, incomplete or sometimes nonexistent. If you are creating or updating your written hazard communication plan, see six steps to a successful written hazcom plan.
The challenge begins when chemicals are acquired and brought on campus. The process starts out by requiring individuals to fill out a chemical request form online. That form may get passed around through multiple departments for review and approval from department heads and managers. Whether this process is done via email or .pdf in the shared drive, there is a potential for failure. If approved by safety and health, it often still requires sign off by other managers and procurement. Overall, the process takes a long time as it happens across multiple systems and getting it signed off can take days to weeks. And we haven’t even talked about training, handling, storage, distribution, or disposal.
However robust the program, policies and procedures that live in a shared drive or a documents control system become stagnant statements. This drive becomes the management system that is bogged down with internal references to each extensive document. A major pain point for most chemical managers is getting people to follow the hundreds of procedures and instructions that exist as forms and documents. Managers are compelled to create “Desk Top Guides” or something of the sort to help their employees, faculty and students understand how to implement these complex procedures. Even if you are following the best practices for getting employees, contractors or tenants to follow procedures like writing them down, educating them on why they are in place, making them easily accessible and even reward them for following the procedure, it is still difficult to get them to comply. Administrators attempt to motivate people into compliance by explaining that OSHA violations can be in excess of $13,000 per day per violation, but that doesn’t resonate with them when the job or project is time sensitive.
Implementation of Procedures
Simple items like maintaining a written hazard communication program, labeling and closing containers, maintaining an accurate chemical inventory and getting up to date SDS from manufacturers will help avoid violations.
Safety Data Sheet entry is shunned by every department, as nobody wants to spend time manually entering Safety Data Sheets; nor should they: when auto-indexing of safety data sheets is functionality that is available through Chemical Safety’s enterprise SDS software offering. If you are still attempting to maintain Safety Data Sheets in a paper binder, you are likely at risk of a violation. Accessible and accurate SDS information is key to avoiding hazard communication violations and the only way to ensure you have the most up to date SDS is to monitor it along with the new or continued purchase of the material.
Creating a Unified Database
No matter the size of an operation, the flow of information regarding chemical management and hazard communication must be uninterrupted. The university setting is particularly predisposed to disruption since the involved parties are situated in multiple locations, under different departments and multiple administrations. Creating and maintaining a unified database that contains all phases of chemical life cycle management and operations in one system; from procurement to inventory through tracking and disposal, Quick access to reliable data is necessary for efficient and effective management. Chemical Safety’s modularized software offering addresses and creates the unified database that allows an organization to have full visibility and the ability to retrieve the analytics that can help make better business decisions. Reach out to Chemical Safety for a full demonstration of our Environmental Management Systems (EMS).