Every organization that handles hazardous chemicals is different. They vary in the type of chemical used, the reasons they use the chemical, the number of people who handle the chemicals and the resources they have available to mitigate the hazards associated with chemical use. But what management of manufacturers, schools, hospitals and service companies have in common is the responsibility to protect the people who handle the chemicals.
What the Occupational Health and Safety Act Says
In Ontario the Occupational Health and Safety Act identifies 3 groups of people who have responsibilities with respect to chemical handling. Their roles according to the act are summarized below:
Employers who must –
- provide information, instruction and supervision to a worker to protect the health or safety of the worker;
- acquaint a worker or a person in authority over a worker with any hazard in the work and in the handling, storage, use, disposal and transport of any chemical agent;
- take every precaution reasonable in the circumstances for the protection of a worker.
Supervisors who must ensure every worker –
- works in the manner and with the protective devices, measures and procedures required by the Act and any of the 25 regulations under the act that apply to their organization;
- uses or wears the equipment, protective devices or clothing that the worker’s employer requires to be used or worn.
Workers who shall –
- work in compliance with the provisions of the Act and its regulations;
- use or wear the equipment, protective devices or clothing that the worker’s employer requires to be used or worn.
What Does This Mean in My Organization?
As a Manager with the authority to hire and fire employees and with control over a budget you are the Employer. This requires that you establish and a detailed and functioning safety system that does more than handout safety rules and collect signatures on “boilerplate” training documents. Being a part of management means you cannot assume that everything is working correctly – you must have feedback on the status of your safety system.
It does not mean you are the expert. You most likely will have Technical Advisors – H&S professionals, Engineers or Consultants who provide the detailed knowledge and judgement required to make decisions about the safe use, handling and storage of chemicals. Until your advisors are clear about what they want, they can’t get others in the organization to follow. Their decisions become the company standard that must be communicated throughout the organization.
A Supervisor is not a manager. A Supervisor is in daily contact with employees to provide instruction and guidance and is responsible for their work and actions. They know the regulations but are not the experts and need to be provided with additional information on company standards and the specific safety precautions chemical handlers must take. They are the group who can ensure that the work instructions developed make complex processes feel simple but they cannot follow up on activities if they themselves are not clear on the requirements.
Chemical Handlers are the people (workers, students, contractors) who come in contact with the chemicals. They do not possess the technical understanding or skill of the experts. They are usually given access to vast, inconsistent or ambiguous chemical information (your binder of SDSs) – which they don’t read! If confronted with a task that is not clear or for which there is no supervisory follow-up they will develop their own methods. Without a good system for handling chemicals safely they are at risk.
Management is Responsible
The goal of your safety system is to ensure that the Chemical Handlers have easy access to information, in a timely fashion and in a form that is easily understood. However, the ultimate responsibility for handling chemicals safely rests with management. They have a legal requirement, an ethical responsibility and most important the access to the resources needed to ensure the organization has up to date information, a clear understanding of the hazards, a process to assess and mitigate risk, tools to communicate broadly and finally they have the ability to ask the questions that ensures the system is effective.
Please feel free to contact us if you have questions regarding chemical management.