Originally posted 28 October 2018
One of the most frequent and erroneous statements we hear from clients is that they do not have designated substances in their chemical collections. I thought the same about products used in my own home until I looked a bit closer at some of the ingredients contained in some infrequently used products. This is because many common adhesives, foaming agents, paints and varnishes contain isocyanates and/or other designated substances. I have seen brake cleaner that contains benzene, as another example.
How Do I Figure Out If I Have Designated Substances?
To determine if products contain designated substances, consult the products’ WHMIS 2015 safety data sheet (SDS). Section 3 of an SDS will list the ingredients of the product and Section 15 will list even traces of ingredients that pose special hazards. While there are 11 listed designated substances in Ontario Regulation 490, Table 1, there are many different forms of these substances. For example, there are 8 types of isocyanates that are listed as hazardous in the table and must be searched for in your product ingredient list.
Why Is This Important?
Designated substances are categorized under a special regulation because they are judged to be especially hazardous. As a result, employers are required to take actions to protect employees from exposure to these substances. Take isocyanates as an example. They are highly reactive chemicals that are often found in foams, building insulating material, polyurethane products, paints, elastomers and varnishes. They are severe irritants and have been linked to skin inflammation, allergic reactions, asthma attacks and even death by the Centers for Disease Control and Prevention.
How do I Manage Designated Substances in My Workplace?
Once you have confirmed that your product contains designated substances, you need to determine if the designated substance can pose a risk to employees. For example, many products like sealing compounds can contain silica but these products are pastes that dry to hard substances. According to O. Reg 490, Table 1, silica is harmful as a respirable fraction (inhaled as a dust). This is what the “(R)” means. As a result, the silica in these products would not be harmful to employees in their intended use.
Once you understand that the product could be harmful to workers, you must decide if the product is necessary to your workplace. If not, eliminate it or substitute it with a less hazardous product. If it is deemed necessary, you must perform an assessment to determine if the health of employees can be adversely affected through the use or loss of containment of this product in the workplace. A great reference for this assessment is the Workbook for Designated Substances Assessment by the Ontario Workplace Safety and Prevention Services (WSPS). This workbook will help you walk through how the product is used, identify the activities that pose the highest risk and how to reduce or eliminate the risk. While there is no obligation to have a written assessment if the conclusion reached is that exposure is not possible, it is prudent to keep a record of this assessment to avoid re-work resulting from workplace personnel changes.
Properly maintaining designated substances can be very expensive for employers and can result in stringent requirements for employee health monitoring. Why add this expense and risk unnecessarily? Eliminate these products from your workplace where possible.
How Can SDS RiskAssist Help?
The challenge with managing designated substances is knowing that you have them. It can take hours, days or weeks to search through SDSs, depending on the number of products you manage. SDS RiskAssist uses proprietary software to read your SDSs and find all the designated substance ingredients as well as many other hazards. This knowledge is presented through a user-friendly interface to allow employers and workers to search by product, ingredient, hazard or location. It also allows employers to “tag” information to chemical summaries, such as chemical-specific directives, so that employees get the same safe-handling instructions across your organization.
Once you have knowledge of a hazard, decisions can be very easy. For example, I eliminated the spray foams and isocyanate-containing adhesives from my home for the time being. Should I have cause to use them in the future, I will use them with added ventilation, a proper respirator and ensure other family members are away from the home for a safe period of time.
Contact us if you would like to learn about easier ways to identify designated substances and other hazards in your chemical collection.