Navigating safety and environmental regulatory requirements can be overwhelming, especially for manufacturers involved in cleaning and surface prep who must also achieve throughput, minimize rework, and control costs. Understanding safety requires education, experience, and street-smarts. What do you do if you are thrown into the safety arena? Following a safety “check list” is not enough.
Jim Unmack, Certified Industrial Hygienist, is an iconic safety professional. Since the late 1950s, he has witnessed the evolution of safety and environmental standards and practices. Jim retired from the U.S. Air Force. He was with the State of California Division of Occupational Safety and Health (Cal/OSHA). Jim has advised major aerospace companies on issues of worker safety and compliance. His projects include surface prep and surface finishing. His holistic, common-sense perspective is informed by the diversity of his career. Jim Unmack and Barb Kanegsberg have been friends and colleagues for at least 40 years. Barb has often picked Jim’s brain for ways to solve thorny production and environmental problems. In this article, Jim and Barb reflect on regulatory changes and practical ideas to navigate manufacturing and regulatory complexity.
Jim: The Environmental Protection Agency started in 1970; and I started before there was an EPA. The safeguards we need to put in place to protect workers have always been an issue. While there wasn’t much centralized help when I began my career, even before the EPA, we had a pretty good handle on exposure guidelines. Exposure guidelines are related to tolerance levels, to how much exposure there could be before we saw adverse effects. However, exposure guidelines did not have the force of law.
Barb: Those “good old days” weren’t always so good! On perhaps 2 to 3 occasions, a boss tried to force me to use a chemical that studies indicated to be toxic or explosive. With guidelines that did not have the force of law, I had to stand up for myself. I think employees have to educate themselves about the risks of any chemical or process; and they have to take responsibility for their well-being.
Jim: Fifty to sixty years ago, far higher exposure levels were considered acceptable than would be considered a tolerable exposure level even twenty years ago. The tolerance limits keep inching downward. Back in the day, It was simpler to express exposure; and it was easier to follow the guidelines. Now we look at a material or chemical in terms of all the ways it might impact human health. It results in a much lower exposure limit. We have better ways of identifying an effect when exposure occurs. This gives us much better ways of defining exposure limits. We are much more specific in our approach. In the past we might have controlled worker exposure to chrome; now we are specific to hexavalent chrome, Cr6+. It is easier to manage exposure to trivalent chrome, Cr3+ ; and some people like that finish.
Barb: Doesn’t trivalent have challenges? Should Cr6+ have a place in the world?
Jim: Definitely. Cr3+ is favored, in part because the TLV is higher than that of Cr6+. Even though it has a lower inhalation hazard, it certainly does not mean it is completely safe; you don’t want to breathe or ingest it. In addition, Cr6+ is still used for a reason; It has a function. Cr6+ has important performance properties; and there are important economic issues in moving away from Cr6+.
Barb: How about thermal spray as an alternative?
Jim: Thermal spray is replacing electroplating. However, adopting thermal spray brings with it a whole different set of challenges to protect the workers. And who knows? There may be other technologies that replace both thermal spray and electroplating.
Barb: I agree that technology improvements may obviate the need to use Cr6+. However, I don’t totally agree with you. Thermal spray can be an effective alternative. However, workers cannot do thermal spray without appropriate protection; and environmental controls are necessary. Over the years, I have become increasingly concerned about managing and balancing worker safety, product performance, environmental safety, and economic issues. Every process change brings tumult; and I think we all have to ask ourselves what we mean by making things “better.” I think forcing manufacturers to move processes away from established technology, either through bans or very costly processes controls, may be a losing battle for everyone. The current regulatory restrictions, particularly the bans on Cr6+ in California, are ruinous to many businesses. Also, I think safe or supposedly safer alternatives can lull people into a false sense of security. I run into people, including some safety professionals, who are concerned only with stopping you from using chemicals on official regulatory lists or lists of “chemicals of concern.” They don’t worry about chemicals with unestablished exposure limits, or where there isn’t much data.
Jim: Using a chemical with an unestablished safety level can be interpreted in two ways. One interpretation is that you don’t have to worry about it. Another is that you have to worry about it a lot. My response is to set up processes so as to stay as low as reasonably achievable. You may want to compare your new chemical with a similar one that has similar properties and that has known control guidelines. That at least gives you some place to start. However, interpreting toxicity or safety of a chemical based only on structural similarities can be misleading.
Barb: I’ve been in the position of being thrown into managing manufacturing changes and complying with safety and environmental issues. I’ve often asked you for advice. What is someone just starting out supposed to do if they can’t call you in a panic?
Jim: I always advocate for a designated safety person. However, you have to be educated enough to spot and resolve the problems. The role of safety person is usually an additional duty for someone. While he or she becomes a point of contact, they can be overwhelmed with other job requirements and don’t have time to do justice to the job.
Barb: As someone who has been there, I strongly urge letting management know the magnitude of the problem.
Jim: That’s right, someone in management has to put forth the time and resources. If you are fortunate, someone in management will realize that the function of safety officer is essential. They may designate you or someone else and provide enough time, personnel resources, and funding to accomplish the task.
Barb: What if you are thrown into a thorny performance, safety, and environmental problem? What if you are told you are the designated person who is ordered to solve the problem? What if you are thrown into a situation where the decision impacts a large group of people and the fate of a business? Where do you go for information?
Jim: The best bet is to find a trade group; meet others who have similar positions and face issues. Ask how they learned their job. If people in your industry who are not safety professionals tell you to find a safety professional, find them. Your insurance company can often help. The agent who services your account may not know all the ins and outs of your profession, but they can often point you in the direction of the right person.
Barb: The fire department can be a resource because they often inspect facilities. Even though an individual inspector may not know all the properties of every chemical, they often have ties with other agencies. We now have many sources of information including on-line webinars, chats, and assorted postings. In some ways it becomes difficult to understand actual requirements. Some “experts” are sales reps or others with vested interest in a product or service. They may ignore regulatory requirements in the interest of selling a product that is under “regulatory duress.” They may claim a chemical is banned in the interest of selling one that is supposedly safer. Question the claims. Do you really need to switch chemicals? Is there really a ban? Does the substitute really perform well? Are there safety concerns with the substitute?
Jim: We need to be cautious about substitutes. They may bring properties that have not been anticipated, requiring other measures to keep it safe. One example is when the substitute is flammable.
Barb: Another is when the substitute impacts the environment. What about performance issues? An ineffective substitute can pose product safety problems. Issues of systems safety and impact on the patient can be major threats.
Jim: It’s important to be proactive, to find a mentor or even a few mentors that you can talk with informally. You don’t want to wait until you fail an OSHA inspection. Unfortunately, way too often, companies wait till something goes wrong. They wait until there is an accident or until they fail a safety inspection. That’s too late!
Barb: Agreed! Manufacturers face what I think of as safety and regulatory “microclimates.” If you are an engineer tasked with chemical substitution or process change, you can’t ignore safety and environmental problems. As an engineer, my father-in-law became aware of a safety hazard in a production line. He wrote memos. I don’t think anyone paid attention to them. There was a catastrophic explosion. It affected him for the rest of his life. If you see a problem, you have to point it out and be a bit of a troublemaker. Speak up! Safety has to become part of you as an individual before it is part of the corporate culture. I think safety professionals have to be cognizant of information that comes in.
Jim: Also, you cannot ignore information that comes in from someone who is not a safety professional. Lots of people can provide information that something is wrong; it might be something you missed. If someone has a startup company and there are only two people in your company, you don’t have the problems of managing the concerns and safety of a large group.
Barb: Sometimes, even very small companies ought to involve a safety professional. I’ve seen small startup companies, with maybe 2 to 3 employees. The owner may start to use chemicals and equipment for cleaning and other surface prep. They may be operating without the needed permits and inspection. Just because you can purchase equipment, it doesn’t mean you are set up to operate it legally or safely.
Jim: Sometimes it helps to have a safety professional outside of your group, someone who may be outside of the company or, in larger concerns, part of the company.
Barb: While I’m not an Industrial Hygienist, I have sat in on your courses. You teach two concepts. The first is the correct answer to an exam question. The second, more involved concept, is what you need to know to do the job of a safety professional. Can you talk about that?
Jim: The people who design the exam ask a finite number of questions. Those exam questions have a role in showing where you need to learn more. However, the questions may not test your knowledge over a broad range; they are not complete. That’s the difference between book learning and on the job learning.
Barb: So, if you are looking for a safety professional, you need to find one who is either experienced or is willing to observe and learn. I have a problem with people who do safety audits and only use a check list.
Jim: A check list is a reminder of the areas to look at and key areas you need to pay attention to. However, the check list can’t really go into depth. An airline pilot has a check list of perhaps a few dozen items. If you take someone off the streets not trained as a commercial pilot and they just look at the check list, you would not want that person to be the pilot on your flight. By the same token, you would not want to be a passenger where the pilot did not go through the check list.
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