Implementing Hazard Substitution for Safer Work Environments

Importance and Benefits

In the hierarchy of controls, replacing a hazard with a less harmful substitute is the second-best option when hazard elimination isn’t possible. Although it doesn’t eradicate the threat, this mechanism still addresses the root cause of the problem and will help organizations across industries gain the following:

• Improves worker health and safety – Maintaining a safer work environment protects employees from danger, increasing their morale and productivity. It directly benefits companies because happy workers get to contribute more.
• Drives environmental protection initiatives – According to the Environmental Protection Agency’s (EPA) Guide for Industrial Waste Management, industrial activities contribute significantly to environmental contamination in the United States. Companies that utilize substitution for controlling hazards can effectively reduce their ecological footprint.
• Increases cost savings – Substitution as a hazard control method means saving money from hospitalization due to accidents, environmental clean-ups, and costly litigations from regulatory breaches. Funds earmarked for those expenses can go straight to improving the operations.
• Enhances corporate reputation and market advantage – By prioritizing safety and sustainability through hazard elimination and substitution, companies become more attractive to potential investors and partners. They also gain a competitive edge among eco-conscious consumers.
• Promotes future-proofing – Regulations around hazardous substances are becoming more stringent, driven by a growing public awareness of environmental and health risks. Organizations that proactively adopt safer materials are better positioned to adapt to future regulatory changes, minimizing operational disruptions.

Criteria for Selecting Safer Hazard Alternatives

Transitioning to safer alternatives is challenging for various reasons. To help organizations ease the process, they can consider the following criteria to successfully replace the hazard for the welfare of their employees, the environment, and the general public.

Toxicity and Health Impact

Since the primary goal of hazard substitution is to reduce harm, the alternative should have a significantly lower toxicity level than the original substance used. One of the most common hazard substitution examples in manufacturing is replacing chemical hazards, such as cancer-causing benzene with water-based solvents.

Considerations:

• Examine short and long-term health effects, especially for known carcinogens, mutagens, and endocrine disruptors.
• Evaluate the substitute’s risk through inhalation, ingestion, or dermal contact and determine ways to control them.
• Ascertain that the replacement has lower Occupational Exposure Limits (OELs), making it safer for workers over time.

Environmental Impacts

The chosen alternative should minimize negative impacts on ecosystems, air, water, and soil quality. Companies using chlorofluorocarbons (CFCs) for aerosol sprays and refrigerants should switch to hydrofluoroolefins (HFOs) because of their lower global warming potential.

Considerations:

• Prioritize biodegradability or the ability to break down naturally without accumulating harmful environmental residues.
• Assess the replacement’s ecotoxicity, particularly to aquatic and wildlife.
• Evaluate the Global Warming Potential (GWP), particularly for chemicals with greenhouse gas emissions.

Performance and Functionality

The alternative must meet the functional and operational requirements of the process or product without compromising quality. For example, workers in the healthcare industry have differing opinions about the comfort of nitrile gloves. However, these are a better alternative than latex ones because nitriles are allergen-free, protein-resistant, and more impervious to chemicals.

Considerations:

• Ensure the substitute’s efficiency to prevent issues like wastage or the need for higher quantities.
• Ascertain compatibility with existing processes, equipment, and other materials in the system.
• Evaluate durability to prevent frequent replacement.

Cost and Feasibility

Transitioning to safer alternatives should be economically viable. If costs aren’t calculated accurately, the company may experience disruptions in the future. For instance, some textile makers now prefer natural and biodegradable dyes over cheaper ones despite the cost. Aside from the growing demand for safety and sustainability, businesses that still use hazardous dyes spend more for protection against heavy metals like lead, chromium, and cadmium.

Considerations:

• Apart from the direct cost (initial purchase price), assess the indirect costs of the alternative, especially those spent on handling, disposal, and additional safety measures required.
• Consider long-term savings from cutting expenses, such as reduced regulatory burdens, lower insurance premiums, lesser need for protective gear or equipment, and fewer health-related costs, to name a few.

Regulatory Compliance

Finally, the substitutes must comply with national and international regulations governing hazardous substances and their use. For example, the European Union’s REACH (Registration, Evaluation, Authorization, and Restriction of Chemicals) regulation has banned phthalates in plastics, asbestos in construction, and Polybrominated Diphenyl Ethers (PBDEs) in flame retardants. Companies planning to replace these should review the rules to see if their chosen alternative isn’t included in the prohibition or restriction.

Considerations:

• Verify the approval of the alternative by reviewing the specific restrictions and prohibitions of different agencies.
• Ascertain that the replacement isn’t on a watch list for future restrictions or bans, which would require another substitution later.

How to Implement Hazard Substitution

How to Implement Hazard Substitution

Implementing any hazard control measure requires careful planning and execution. Following the right steps in substitution is crucial to ensure that the chosen alternatives are safer and that the transition is smooth. Here are the key steps:

Step 1: Conduct a thorough hazard assessment.

The team assigned to execute the change (e.g., Environment, Health, and Safety (EHS) department, Research and Development (R&D), process engineers, compliance officers, and procurement managers) should start by assessing the risk of the identified hazard. The substances are usually flagged based on the following:

• Toxicity
• Flammability
• Reactivity
• Environmental impact

Step 2: Research and evaluate the alternatives.

Use databases and regulatory guidelines, such as the European Chemicals Agency’s (ECHA) Substitution Support Portal or GreenScreen to identify less harmful alternatives. Once potential substitutes are found, they should undergo rigorous evaluation based on the criteria previously discussed.

Step 3: Pilot test before full implementation.

Before fully replacing a hazardous material, conduct trial runs to ensure the substitute integrates smoothly into the existing system, preventing unintended consequences. After the successful testing, incorporate the alternative into the production or operational process. Make sure to also carry out the following:

• Targeted employee training
• Updating of Safety Data Sheets (SDS)
• Documentation for regulatory compliance

Step 4: Monitor and review the process.

Continuous monitoring ensures the new material remains effective and safe over time. Designated teams should expect new risks and be ready to make the necessary adjustments to the process. Gathering employee feedback and conducting follow-up inspections can help monitor performance, health, and safety impacts.