Do You Approve? A Process for Reviewing New Chemical Requests David Campos, MPH, CIH, CHMM Raytheon Missile Systems Industrial Hygienist

Why Do We Need to Review Chemical Approvals? Worksite Analysis & Hazard Prevention Compliance Health/Safety Compliance Hazard Communication Process assessment Environmental Compliance What are you bringing in? Excess amounts of potential pollutants? Gateway for capturing chemicals of concern It’s The Right Thing to Do 11/7/2018

Why do we need to approve? The Hierarchy of Control Important for eliminating problems before they begin Opportunity for more control 11/7/2018

An example: What Chemical would you approve An example: What Chemical would you approve? Do you have a method for review? Chemical A Chemical B 11/7/2018

An example: What Chemical would you approve? How about now? Chemical A Stripper/Polymer Remover Contains dimethylacetamide (ACGIH-TLV 10 ppm) Chemical B Primer Contains strontium chromate (ACGIH-TLV 0.5 µg/m3) Contains crystalline silica (ACGIH-TLV 25 µg/m3) 11/7/2018

An example: What Chemical would you approve? How about now??? Chemical A Stripper/Polymer Remover Contains dimethylacetamide (TLV 10 ppm) Available in 1 gallon container Chemical B Primer Contains strontium chromate (TLV 0.5 µg/m3) Contains crystalline silica (TLV 25 µg/m3) Available in 1 pint kit 11/7/2018

Navigating Through a New Request The 5 W’s (plus an H) of chemical requests Who? What? Where? When? Why? How? http://www.thinkstockphotos.com/image/stock-illustration-5w-strategic-who-what-where-when-why/470749119/popup?sq=5 why's/f=CPIHVX/s=DynamicRank 11/7/2018

Who is Requesting the Material? Who is the end user of the material and what is their skill-set or knowledge base? Does the individual(s) thoroughly understand the risks and risk mitigations involved with using the material? Ongoing production work vs. Research & Development. What is the expected risk involved with the process and what are the opportunities for removing risk in repetitive processes. Be wary of seasoned professionals or “experts” “I’ve been doing this for years!” 11/7/2018

What is the material being requested? One of the most potentially complicated and important questions you can ask (M)SDS Chemical components HFR Vapor Pressure (Volatility) Products of decomposition (ties in with the “How”) Size/Quantity/Packaging of the request Is this a chemical that is associated with an OSHA Substance Specific Standard? Acrylonitrile, Asbestos, Benzene, Cadmium, Chromium VI, Formaldehyde, Lead, MDA, Methylene Chloride, 11/7/2018

Where will the material be used? Under what conditions is the expected use of the material? Important to understand the impact to the surrounding area and employees. Have area employees been properly trained to use the chemicals? Any new requirements trigged by the new chemical? What controls are available in the area? Availably of local exhaust of other engineering controls Is the required PPE Stocked in the area? Paint shop vs. Factory Floor vs. Office Cubicle http://www.thinkstockphotos.com/image/stock-photo-blue-car-in-spray-booth/509915957/popup?sq=paint booth/f=CPIHVX/p=2/s=DynamicRank http://www.thinkstockphotos.com/image/stock-photo-overview-of-a-factory-at-work/82659728/popup?sq=production line/f=CPIHVX/s=DynamicRank 11/7/2018

When will the material be used? Usually this question is mostly about logistics “This is a high priority, critical request!” How long until the product is on site Lead time for implementing any controls http://www.thinkstockphotos.com/image/stock-photo-action-required/483186101/popup?sq=immediate action required/f=CPIHVX/s=DynamicRank 11/7/2018

Why is this material needed? What is the reason for bringing the material onsite? Is the material being purchased due to a requirement in the process, or is this simply the preference of the end user? Opens up options for substitution is the material used only as a preference, i.e. “the good stuff” The specific material may be needed to meet certain specifications that cannot be met by a substitution. 11/7/2018

How is the material going to be used? Knowing the application method of the material may determine if you grant approval. Brush-on vs. Airbrush vs. Spraying Is it applied through a closed system or is there significant chance of exposure? If the material will be heated, it may be important to determine if there is a potential for products of decomposition http://www.thinkstockphotos.com/image/stock-photo-top-coat-painting-for-finishing-work-piece/499134216/popup?sq=spray gun/f=CPIHVX/s=DynamicRank 11/7/2018

Tips for rejecting a request Speak with the end-user before rejecting – don’t surprise them. Have your justification prepared, be able to articulate why you are refusing the request. Try to come to an alternate solution when rejecting a request. Is there a substitution? Is there a different size or application available that could be approved? Explain what would be needed to make the chemical “acceptable for use” Above all – Be Courteous! 11/7/2018

Resources for chemical substitution ACGIH Threshold Limit Value Booklet Information on allowable exposure limits and health effects American Chemical Society Green Chemistry Institute EPA Design for the Environment Alternatives Assessment Product Manufacturers New technologies New formulations Variety of packaging or pre-mixing 11/7/2018

After approval Certain chemicals may be approved pending some kind of action, e.g. development of a Job Hazard Analysis, use of local exhaust, additional control. IH Monitoring may be needed for new processes that are not fully understood. Qualitative Risk Assessments, Quantitative sampling Some chemicals will require sampling per OSHA requirements, e.g. lead, CrVI Follow-up air monitoring may be required to ensure that the site remains in compliance 11/7/2018

Example #1 Led-Plate Antiseize Thread Compound From the MSDS: 1 lb brush-top can Used in an Research and Development Lab Process calls for an “anti-seize” to be used From the MSDS: 11/7/2018

Example #2 Methylene Chloride/Dichloromethane, >=99.9% 4-liter glass bottle Used in an Research and Development Lab From the SDS: 11/7/2018

Example #2 Continued Methylene Chloride/Dichloromethane, >=99.9% ACGIH TLV = 50 ppm based on COHb-emia, CNS impair Did you consider OSHA Requirements per 1910.1052, Methylene Chloride? 1910.1052(d) Exposure monitoring. 1910.1052(d)(1) Characterization of employee exposure. 1910.1052(d)(1)(i) Where MC is present in the workplace, the employer shall determine each employee's exposure by either: 1910.1052(d)(1)(i)(A) Taking a personal breathing zone air sample of each employee's exposure; or 1910.1052(d)(1)(i)(B) Taking personal breathing zone air samples that are representative of each employee's exposure. 11/7/2018

Example #3: Back to our original scenario – any differences in your approach? Chemical A Stripper/Polymer Remover Contains dimethylacetamide (TLV 10 ppm) Available in 1 gallon container Chemical B Primer Contains strontium chromate (TLV 0.5 µg/m3) Contains crystalline silica (TLV 25 µg/m3) Available in 1 pint kit 11/7/2018

In Summary Ongoing worksite analysis is dependent on a robust chemical approval system. A systematic approach, such as a 5 why’s process, can help an approver fully evaluate a new chemical, and help them become more confident in that role. Any Questions??? 11/7/2018