|US - EU Cooperation on Workplace Safety and Health|
|Topic 1 : Chemicals at the workplace
Global Management of Chemicals
17 October 2003
Occupational exposure to chemicals remains a key occupational safety and health issue on both sides of the Atlantic. Such chemicals pose the potential for both adverse health effects and safety hazards. Our group discussed three subtopics: procedures for setting occupational exposure limits (OELs), the Globally Harmonised System of Classification and Labelling of Chemicals; and risk assessment and risk management at the enterprise level, including control banding. The working group recognizes that there are other means to protect workers and prevent injuries and illnesses that could not be dealt with during our discussions. While we divided the discussion into these topic areas, it soon became clear that they are not discrete and need to be addressed in the context of an integrated approach.
A similar approach to dealing with chemical hazards has evolved in our countries. Occupational exposure limits are established, and employers are expected to comply with those limits to control hazards and prevent hazardous effects. Compliance is established by measuring exposure levels in the workplace.
This approach has been successful in some respects. Workplace conditions have improved where exposure limits have been established and compliance is accomplished.
However, the approach is very limited in scope. No country has more than a few hundred occupational exposure limits while workers are exposed to thousands of chemicals.
Furthermore, it is a particularly difficult approach for small and medium enterprises (SMEs) to implement. They don’t have the means to measure, or the knowledge necessary to implement the appropriate controls.
Other supplementary requirements, such as risk assessment in the workplace in the EU, have also been difficult for SMEs to implement.
Our countries have also established rules to classify chemical hazards and provide information to users with labels and safety data sheets. This helps to supplement the chemical-specific regulations by giving employers and employees information upon which to make decisions about protective measures. Our systems in this regard are similar, but not the same. This creates potential differences in levels of protection, risk of confusion for users, and possible barriers to trade.
Based on our discussions, the group came to the following conclusions:
Information should be provided on the EU/US joint web page on the Globally Harmonised System of Classification and Labelling of Chemicals and on the concept of control banding, to help increase awareness about these two initiatives. The group believes that countr+ies should consider adoption of the GHS to provide a harmonized infrastructure upon which to build other chemical safety programs. While the EU and the US have hazard classification and labeling systems, adoption of the harmonized approach will provide benefits to industry, labor, and government in areas related to protection and trade. In addition, the group believes that participation in the March 2004 international conference on control banding would also lead to further information and experience exchanges that can build our knowledge base on the topic. It may also be an opportunity for some members of the work group to meet and continue our discussions.
The EU and the US should form an informal, tripartite working group to do a phased pilot project related to the global approach to management of chemicals. This tripartite group may need input from independent scientific experts. The group believes the benefits of this are significant. The project would be a practical demonstration of the use of new and innovative tools and approaches to advance joint consideration of chemical hazards. It will give us a better idea of the possibilities of future cooperation to review jointly the health effects of chemicals that may later be used by each country to establish OELs; how that data can be used to classify the hazards under the GHS; and illustrate the use of the GHS classifications to lead an employer to appropriate controls. This project provides an opportunity to leverage the limited resources we all have to address such issues.
The joint working group will choose two high production volume chemicals for the pilot. Consideration will be given to OELs that may be lacking supporting scientific data or need updating.
Data regarding the two chemicals will be assembled, shared, and evaluated by experts on both sides of the Atlantic to develop a joint health and physical hazard assessment.
When the data are evaluated, the working group will then classify the hazards according to the GHS criteria. This will provide examples of how the criteria are applied that will help others understand the GHS as well.
Upon completion of the classification, the label elements and SDS information that would be required under the GHS will be developed.
The joint working group will then consider how the two classified chemicals would be treated in a control banding approach as compared to the OEL or another approach. Control measures appropriate to reduce exposures to acceptable levels will be identified, and a control banding guide will be developed for them. This will illustrate how GHS information can be used to select controls, even in the absence of an OEL.
An evaluation of the experiences and process of this collaboration will be developed by the working group.
The results of this collaboration should be shared at the next EU/US conference. The results may be used to frame future discussions on the analysis of health effects in support of the OEL setting process. It is suggested that Global Management of Chemicals should be on the program again next time to continue working together on these issues.
It is the objective of the working group to deliver the project utilizing existing staff resources, web forum, email, videoconferences, etc.