OF SAFETY ENGINEERS
1800 East Oakton Street
Des Plaines, Illinois 60018-2187
April 5, 2004
Acting Assistant Secretary of Labor
Occupational Safety and Health Administration
U.S. Department of Labor
200 Constitution Avenue, NW
Washington, DC 20210
RE: Reactive Chemical Hazards
Dear Mr. Snare:
The American Society of Safety Engineers (ASSE), on behalf of its 30,000 member safety, health and environmental (SH+E) professionals is concerned that this nation has not adequately addressed the issue of reactive chemicals and that the time has come to develop a consensus plan to address reactive chemicals that can be advanced by the Occupational Safety and Health Administration (OSHA).
ASSE supports OSHA's recent efforts to advance the understanding of reactive chemical hazards. The availability of resources from OSHA and the continued development of guidance documents on the issue are important, as is OSHA's making available on its web site the Center for Chemical Process Safety's Essential Practices for Managing Chemical Reactivity Hazards .
Despite these positive efforts, ASSE's members continue to feel a sense of risk that not enough is being done to ensure that all employers take full and active responsibility for properly controlling processes using reactive chemicals and to ensure their employees understand the risks posed by reactive chemicals.
Given the significant risk that reactive chemicals pose, ASSE's members believe OSHA should employ additional and specific advocacy tools to encourage every employer to take full and active responsibility for ensuring that management systems are in place and that their employees understand the risks posed by reactive chemicals.
OSHA needs to convey a clear statement of employer responsibility in its communications and activities related to reactive chemicals. That message must reiterate in unambiguous terms the following principles :
• Users of chemicals have the responsibility to assure that reactivity hazards are reviewed prior to use of a new or altered chemical or process is initiated, including waste handling and disposal.
• The review, including any systems and process safety analytical techniques employed, must be documented and made available for employee review.
• The review must include material safety data sheets, manufacturer data sheets, if available, and recognized references on chemical reactivity hazards. Consensus among industry stakeholders would determine which widely applicable references would be required
• Following the reviews, the employer must document the identified potential reactivity hazards and control measures.
• The employer must document the control measure(s) selected and implemented. In some cases, redundant systems may be appropriate if the hazard and risk warrant.
• Should an employer observe a reactivity hazard or potentially hazardous reaction that has not been previously reported, the employer must log that information into a designated national database on chemical reactivity.
• The employer must ensure that those who perform systems safety analytical techniques or other reactive chemical hazard evaluations are trained in the techniques employed. Managers and workers require training on the hazards of the chemicals used and control measures that are being employed.
The best way to ensure a national commitment to addressing reactive chemical risks is through OSHA. ASSE hopes that OSHA can provide that leadership.
As always, ASSE's members stand ready to work with OSHA to advance occupational safety and health. Cooperative efforts among OSHA's stakeholders concerned with reactive chemical hazards can help in better protecting workers from reactive chemical risks. We look forward to your response.
Gene Barfield, CSP
cc: Carolyn Merritt
U.S. Chemical Safety and Hazard Investigation Board
Stephen L. Johnson
Environmental Protection Agency
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