Many government regulations for chemical safety identify the need for a risk assessment as part of the decision-making process for managing potential hazards. However, EPA’s hazardous waste determination is the only risk assessment process that is well defined by the regulators, but this determination has proven to be problematic in many settings. That is why we have RCRA Subpart K and all the differing versions of state, universal, and electronic waste requirements.
One reason most chemical safety regulations are vague is confusion over what constitutes a “risk assessment.” Safety science research has shown that a “risk assessment” is not an objective process with reproducible results. This research shows that when practitioners of similar training and experience separately conduct a risk assessment of similar hazard scenarios, the results detail significant variations from case to case. See the “Safety of Work” podcast episode 63 at safetyofwork.com for further discussion of this challenge.
So why is there such emphasis on risk assessments in chemical safety?
From a safety management point of view, there are three key reasons to conduct documented risk assessments:
1. To move beyond chemists’ intuition about the hazards of their work, solidly identifying opportunities to improve the reliability and safety of their chemical processes and to prepare for unexpected occurrences within those processes.
2. To support the development of a partnership between the lab team as a group and support staff, such as facility managers and EHS professionals.
3. To be a good neighbor. There are many stakeholders involved in even the simplest chemical operation, thus necessitating documented, reliable information about the risks associated with the chemistry being conducted.
- Funders and upper management expect that best safety practices will be followed in working with hazardous chemicals.
- Facility and EHS staff need detailed information about chemical hazards to do their jobs safely and productively.
- Emergency responders need to identify worse-case scenarios in a HAZMAT response.
- The public will be affected by the environmental health and safety aspects of chemical research and production.
The process of conducting and documenting a chemical risk assessment can follow many paths, but whether you are developing a Standard Operating Procedure, conducting a ‘What If’ analysis, or using a checklist approach to risk assessment, there are ways to improve the standard risk assessment. These opportunities will be explored in next month’s blog entry.
Dwight Eisenhower observed that “Plans are worthless, but planning is everything”. This sentiment applies to risk assessments as well – it is the process itself that adds value to the work being done. For this reason, “risk assessment” should be thought of as a verb, not a noun. This is particularly true in chemistry-intense settings, where risks change as the work being conducted evolves. Chemical risks cannot be professionally managed by intuition because this quality is not transferable, scalable, transparent, or sustainable. Science aspires to be all of these.
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Ralph Stuart, CIH, CCHO is the Environmental Safety Manager at Keene State College in Keene, NH. He has over 30 years of experience in addressing Indoor Air Quality concerns and optimizing laboratory ventilation for safe energy conservation. He is the past chair of the American Chemical Society’s Committee on Chemical Safety.