Some of the many reasons for managing hazardous materials follow:
The best reason depends upon your prospective. Sometimes, its just the right thing to do.
No. The regulating agencies have no authority to force companies to "manage" either their hazardous materials or wastes. The agencies can merely enact regulations governing specific actions. For example, an agency can regulate how to dispose of a material, but cannot impose controls on a company that would stop the usage of such material.
And Yes. The EU REACH (Registration, Evaluation, Authorization and Restriction of Chemicals) Regulation places a burden on the manufacturer to prove that certain chemicals were never included in a product or came in contact with a product.
The Committee Review Module is an excellent tool to document the management steps that were taken to insure that products where safe from even incidental exposure to certain hazardous chemicals.
Automotive and heavy equipment manufacturers have had paper review processes in place for decades. Recently, more and more companies have recognized the need to become more proactive with regulatory compliance and are implementing review processes. In addition, they recognize the need to have their hazardous material professionals directly involved in the day-to-day decisions on the use and disposal of hazardous materials.
The module provides a systematic approach to the management of hazardous materials. If realized to its full capability, the module can be used to evaluate materials before they are ever purchased. Materials which will present significant hazards to employees or which will be difficult to dispose of, can be kept out of the facility. When hazardous materials are allowed into the facility, their use can be limited to approved usages (or "Requests"). Once materials have been "approved" for usage, an "SOP" (Standard Operating Procedure for their safe use and disposal) can be established. By integrating these documents and MSDS/SDSs into a company's standard business practice, safety of employees and proper disposal of materials can be better ensured.
MSDS/SDSs are written by the manufacturer for multiple customers; they cannot address customer-specific situations. Typically, MSDS/SDSs provide a disclaimer which states, in some form, that it is your responsibility to determine safe conditions of a material's use. Therefore, the hazMIN® SOP is available so that you can provide facility-specific safe-use and disposal information. The "SOP" can specify the exact make and model of an OSHA-approved respirator to be used. The MSDS/SDS cannot. The "SOP" can state the explicit instructions for disposing of wastes in accordance with the facility's waste permits. The MSDS cannot. The "SOP" can outline usage instructions to minimize employee chemical exposure. The MSDS/SDS cannot.
Your company will benefit in many ways.
First, the Request can document how each hazardous material was utilized and the potential exposure to your employees. Such documentation may be invaluable in workers' compensation claims.
Second, these records could be crucial in determining what chemicals are entering various waste streams from the facility.
Third, the Request can document that a material was evaluated. This would give employees the assurance that the material has been determined to be safe for their use as trained by the SOP for their facility.
No. hazMIN® is very flexible. You may require Requests only for your most hazardous materials. However, if you have Requests for everything, hazMIN® Environmental Reports can be run against the Request numbers. If you have identified the maximum and average storage and usage at each location, the Requests may provide adequate accuracy for environmental reporting.
The Request may be submitted on the computer by the staff or foreperson responsible for a work area. The SOP may be created and maintained by the hazardous material professionals within the facility or corporation. These processes are fairly easy due to the many tools, within hazMIN®, that minimize the actual keystrokes necessary to enter this information.
Hazardous material professionals would include all of the personnel that you need to involve in making decisions on the use and disposal of hazardous material. Typically, this includes the Environmental Coordinator, Industrial Hygienist, Nurse, Safety Officer, Transportation Specialist, Storage Specialist, and Fire Safety Specialist. In larger facilities, the responsibilities may be delegated to more individuals. In smaller facilities, all of the responsibilities may be delegated to one individual. hazMIN® is flexible enough to allow either extreme.