Originally Published February 12, 2019
Implementing an effective chemical management system is difficult. Over a 3-year period we spoke with hundreds of people about workplace chemicals and identified 4 obstacles to improving chemical safety.
The Bystander Effect
The bystander effect says that in a group setting which calls for action to address a problem most of us will assume that someone else is better equipped to act then we are. We see this play out with respect to the three groups involved with WHMIS – suppliers, employers and workers.
Suppliers create the SDSs. To many of us they are the experts. But as we read more and more SDSs we saw they are the expert in their product not in how you use it. The majority of data sheets provide generic information not specific, actionable guidance. They say something like “Wear appropriate gloves”. Similarly, employers often assume that workers have read the data sheets, are aware of the hazards and if they had concerns they would ask. But one only needs to look at the dust covered WHMIS binder to know that this assumption is false.
An Information Tsunami
WHMIS is a tsunami of information. Our research suggests that the average organization uses 140 products which produce over 1,600 pages of information. It would take the average person 30 minutes to read one data sheet. And they would only retain 60% of what they read. So yes make the sheets available, but that doesn’t mean people will read them, understand them and take the appropriate action.
WHMIS in Isolation
Too often people do not connect the hazards from WHMIS to the expectations of hazard control found in other regulations. Ontario’s Occupational Health and Safety (OHSA) act contains broad safety laws. The 30 regulations under OSHA contain the specific actions that must be followed. WHMIS describes how hazard information must be shared. Requirements regarding exposure control for these hazards is found in either sector specific regulations such as the Industrial Regulations or hazard specific regulations such as Designated Substances.
For example, the Industrial regulations state “where a worker is exposed to a potential hazard of injury to the eye due to contact with a biological or chemical substance, an eyewash fountain shall be provided”. Yet during a Chemical Handling Blitz MOL inspectors found that 20% of facilities did not meet this requirement.
Ontario’s WHMIS regulation contains 36 actions for employers. Think of it as your WHMIS to-do-list. As with most to-do-lists only the item at the top of the list gets done – update your safety data sheets. The items lower down the list never even get started. The result is a large number of safety data sheets in a binder, but employers have not determined how to handle hazardous products safely and workers are unware of the hazards and the safe handling practices.
An effective chemical management system will overcome these obstacles to make the employer the owner of the process, manage the volume of information contained within WHMIS, link to other regulations and ensure workers are given clear, simple instructions on how to handle chemicals safely.
This is the third of six blogs that talk about Chemical Risk Management and how any organization can make dramatic improvements in chemical safety with the same or less effort than you are spending today complying with WHMIS. These blogs will cover the following topics:
3. Obstacles to Chemical Risk Management
If you have any questions on this blog or the series, please contact me directly at firstname.lastname@example.org