7 Steps of a Best Practices Hazard Analysis for Regulatory Compliance
Is ammonium nitrate a safe chemical or an unsafe chemical? That’s a tough question to answer, and it sets us up for a debate on whether chemical safety is an intrinsic or extrinsic value. As is the answer to many of life’s questions – it depends. A chemical’s safety depends on how we use it and how we move and store it. It depends on the toxicity of the chemical itself and the health and environmental harm it could cause.
The townspeople of West, TX, where the recent fertilizer plant explosion occurred, may answer that ammonium nitrate is not safe. However, as forensic investigation is revealing, the chemical handling procedures were not ideal at the plant. Many other plants continue to use this chemical without exploding, so some might answer that ammonium nitrate is safe if handled properly.
If you’re looking at a chemical, how do you decide whether to use it in your facility? Several regulatory agencies have rules about this and that chemical. We can get you on the right track with our helpful hazards analysis checklist that consolidates rules from the NFPA, ANSI, CGA, OSHA and certain EPA regulations:
7 Steps of a Hazards Analysis
1) Evaluate hazards that could put employees at risk, and make sure to consider all activities from receipt to disposal. What could be a low-risk chemical for one procedure may be high-risk in another activity.
2) In your hazards analysis, consider the design of new facilities or modifications of existing facilities or equipment. Maybe your most efficient safety or pollution prevention option is to modify the infrastructure a tad here and there.
3) Don’t forget about the hazards operations and procedures. The way we handle hazardous materials is part of the solution to accident prevention and regulatory compliance.
4) Take a look at the equipment, products and services that are selected or purchased. Sometimes hazards walk right in the door, invitation in hand, so every material and worker that enters a facility should be included in your hazards analysis.
5) Write it down and send it in – make sure you have documentation of your hazards analysis. It’s hard work, and you should get credit for doing it! Also be sure to have the document approved by the appropriate safety official.
6) Announce the hazards present in a work area before employees begin work. This is part of creating a safe workplace and saving lives.
7) Are you ready for an earthquake? Or any natural or human-made events that could lead to a loss of control of hazardous materials? Consider your hazardous processes and what will become of them if something big happens.
This checklist summarizes several of the key pieces of legislation regarding chemical inventory management. It is available along with other helpful checklists, in the ChemSW best practices white paper “How to Survive a Chemical Management Audit.”
ChemSW loves safety, and we offer several software solutions to manage chemical inventory in a compliant, safe and efficient way. Please visit our site to find out how we can help you today.