EHS Programs: Competing Priorities or Burgeoning Opportunities?
Ramon A. Thomas, CIH, CHMM
Ramon A. Thomas, CIH, CHMM, Director Industrial and Occupational Health, Conrail, Inc., Philadelphia, PA 19103, (215)209-2436, www.Conrail.com
83rd Annual International Conference Proceedings - 1998
Abstract. The skill of balancing what sometimes appear to be "competing priorities" of environmental and occupational health requirements in such areas as asbestos, lead, etc. is often simply a matter of being informed and willing to take a leadership role in the process. The informed purchasing professional can be an asset when he/she ensures that the concerns of all sides are addressed BEFORE any actions are taken.
We have come to expect friction between production operations and governmental programs, however, during the course of implementing some Environmental Protection Agency (EPA ) and Occupational Safety and Health Administration (OSHA) programs, environmental and occupational health requirements sometimes appear to be aligned against each other. Because these programs often involve the use of outside contractors, the purchasing manager may be able to seize an opportunity to play a key mediation/leadership role in their implementation.
EPA is generally charged with protecting the public from exposures to hazardous substances while OSHA is charged with protecting the health of workers. EPA emission standards are often significantly lower than OSHA exposure standards because EPA assumes a continuous insult (a 24-hour exposure to the general public) whereas OSHA assumes an 8-hour daily exposure for 40 hours per week over a 40 year working lifetime.
Similarly, the environmental department's priority is protection of the environment while the occupational health department's priority is the protection of employee health. A degree of isolation and polarization amongst the Environmental, Health and Safety subgroups (EHS ) can still exist in spite of the high degree of cross-functionality that seems so commonplace in many professional histories. This polarization is more likely to manifest itself as an underlying sense of confusion than as an overt systemic breakdown.
If your organization has distinct EHS subgroups/departments, they may be fairly oblivious to each others' interests regarding a particular subject or each may assume that the other has been informed regarding the plans for a particular subject and has quietly given its nod of approval to proceed as planned.
The ideas that may arise when one brings a variety of disciplines to bear on an issue can go a long way towards avoiding future problems and program deficits. For instance:
EPA's Asbestos Worker Protection Rule (40 CFR 763) parallels OSHA medical surveillance, exposure assessment, work practices and recordkeeping requirements. Some degree of duplication may creep into your organization if the environmental group attempts to comply with this EPA rule without communicating to the medical and/or safety group.
Legally, lead-free solder contains 0.2% lead and lead-free pipes and fittings contain 8% lead. How would these concentrations translate into exposures for a builder's plumber?
Drinking water standards may be interpreted as an occupational health concern OR as an environmental concern depending on the organization. Likewise, Emergency Planning and Community Right-to-Know (EPCRA) may be confused with Employee Right-to-Know (Hazard Communication). These can cause confusion when it comes to which group will implement the programs.
EPA added regulations that explicitly address monitoring and recordkeeping facilities which fabricate asbestos. To what extent does this monitoring mirror exposure surveillance activities already conducted by medical or safety groups? Should the results of such monitoring be added to employee medical records? How should it be recorded? What are the quality control requirements? Should situational narratives be recorded with the analytical/observational results?
Businesses which are involved in asbestos milling, manufacturing, and fabricating now must monitor for visible emissions for at least 15 seconds at least once a day (during daylight hours), and inspect air cleaning devices at least once a week. To what extent would this information be beneficial to the overall exposure picture for the organization?
Use of hazardous waste contracts implies that employees will be generating and handling hazardous wastes in bulk and transfer quantities. Potential liability beyond waste transport extends to in-house employees and possibly contract employees under mutli-employer worksite rules.
These are multi-discipline, joint-responsibility issues yet, it is not readily apparent that they require multi-disciplinary implementation and resolution. An independent third party mediator would prove beneficial as a catalyst to bring the multi-discipline aspects of these issues to the forefront and get them reconciled. This offers you, the purchasing manager, an opportunity to assert a certain amount of leadership in the EHS process.
A meeting initiated by EHS will probably be reactive; in response to some project, purchase or program. You, the purchasing manager, will need to use questions to turn this reactive meeting into a proactive one. Let's assume an environmental manager approaches you with a request for proposal to provide inspection and labeling of asbestos containing materials. Appropriate questions might be, "What affect will this have on hazard communication training efforts?", "What affect will this have on access to the affected areas?" These questions will provide opportunities to suggest that comments be solicited from the groups that control hazard communication and facility operations. This can then be parlayed into a planning meeting.
Get the parties together rather than simply requesting that they make comments. Plan at least two meetings with prior notice of objectives. Be explicit; parties should be prepared to discuss their requirements and concerns candidly for the program under discussion.
Avoid constructing, or implying, a permanent committee or team. Make it clear that the meeting will have one objective and that a strong, good faith initial effort will help to ensure that the entire issue is wrapped up in two to three meetings. Clearly state what is needed from each party. Each should review their individual programs (if they've developed them) and the relevant regulations and/or standards prior to the meeting and summarize their priorities, objectives and requirements.
These groups develop programs in order to facilitate compliance to government regulations. The product of your meeting should not, however, be a program but, rather, a one to two page consensus flow diagram that distills the individual groups' priorities, objectives and requirements.
This flow diagram should be composed in such a manner that it serves as a reminder for those who know the processes; design it as a comprehensive reminder for yourselves. It should be fairly high level. A subsequent reference section or appendix should be included which is, in essence, a duplicate of the flow chart, however, it should have low-level instructions. Users of these processes will often remember most of the procedures. The subsequent, section gives them a quick reference.