Fourth Joint U.S./EU Conference on Occupational Safety and Health
14-16 September 2005, Orlando, Florida

Global Management of Chemicals

Background
The challenge of managing chemical hazards in the workplace has led to the development of multiple approaches worldwide. Many strategies have been effective in controlling exposures for specific chemicals and their applications. Yet the quantity and volume of chemicals produced, transported, and used globally require continuing efforts to ensure the safety and health of workers who handle chemicals. Because no single strategy has been universally accepted or proven entirely effective for addressing all possible chemical exposures or scenarios, the challenge persists and expands with complicating factors. Such factors include increasing global commerce and international transport of chemicals, the development of new and unclassified chemicals, existing chemicals with insufficient hazard and exposure data, and limited resources for developing and updating occupational exposure limits. Consequently, a combination of existing and innovative approaches to management of chemicals first identified and discussed at the previous joint conference (Lemnos, Greece, 2003) were further explored. The working group focused on four specific subtopic areas pertaining to chemical management practices:

  • Implementation of the Globally Harmonised System (GHS) of Classification and Labelling of Chemicals
  • Control banding
  • Accuracy of safety data sheets, and
  • Results of a pilot project assessing two chemicals according to principles of the GHS and control banding.

In addition, a fifth subtopic area was dedicated to discussion of nanotechnology and general issues regarding chemical management. Rapid expansion in the area of nanotechnology continues to pose a challenge for assessing potential human health effects. In the course of discussions, the relevance of these topics to small and medium enterprises (SMEs) became apparent. The significance of the proposed European legislation on trade in chemical substances, known as REACH (Registration, Evaluation and Authorisation of Chemicals), was also noted, especially as it relates to the GHS. Just as the EU, the U.S., and other countries become increasingly linked in a global economy, so too do the chemical management issues and proposed solutions.

Summary and Recommendations
Chemical exposures in both European and American workplaces continue to be a significant issue of concern. Exploration of innovative ways to improve worker protection remains a priority for all of us. Our discussions, and our collaboration on the pilot project between the two meetings, have provided a useful forum for information exchange and increased knowledge of each other’s approaches. Given identical data sets, the independent classification of single chemicals was found to result in general agreement. However, there were differences which resulted with the application of the methodology to mixtures.

Our working group believes that global management of chemicals should continue to be an area of collaboration. We have identified areas for further work, as well as volunteers to accomplish the work, and recommend that this subject be included on the agenda for the next joint conference.

In particular, the discussions of the working group produced the following recommendations:

  • The pilot project should be expanded
    • to explore application of the GHS to mixtures, reflecting the reality that packaged chemical products as well as workplace exposures rarely are limited to a single chemical, and
    • to include SMEs evaluating chemicals without being provided an initial data set.
  • Investigation and sharing of control banding approaches should continue, especially as different countries recognize and assess the potential utility of these voluntary control-focused strategies as practical risk management tools for chemical safety guidance.
  • A sample of established training programs for people working with chemicals should be examined with regard to their scope and criteria for assessing their effectiveness.

Subtopics for the next conference would include these areas of work, as well as progress on nanotechnology and an exchange of information on respiratory protective equipment. In the context of these subtopics, possible areas for further discussion also include comparison of health surveillance data sources for the U.S. and EU relating to chemical exposures and the status of REACH.

Information Sharing and Collaboration
The pilot project exploring the application of both GHS classification and control banding principles for selected chemicals proved to be effective for identifying potential differences in interpretation. The exercise helped to demonstrate that multiple factors can impact the outcome of hazard classifications, particularly the availability of complete and accessible data for all evaluators. This clearly indicates the need for development of appropriate guidance and tools to ensure consistent results with the application of the GHS, especially for use in SMEs. To capture and communicate the experience of the working group on this effort, the U.S. and EU chair have proposed to draft a white paper describing the process and outcomes of the project for submission to the U.N. Subcommittee of Experts on the GHS.

An additional effort to build upon the value of the collaboration involves developing a memorandum of understanding among agencies in the EU (U.K. HSE and Germany BAuA) and the U.S. (OSHA and NIOSH). The memorandum will promote research collaboration and the exchange of information about control banding.

Additional Considerations
Delegates of the working group identified additional chemical management issues of continuing importance. One of these issues included developing better strategies for preparing and assuring the quality of safety data sheets. The availability of the international chemical safety cards (numbering approximately 1400) developed by the International Programme for Chemical Safety was noted as a possible resource. It was also recognized that the consistency and quality of safety data sheets will improve with the implementation of the GHS.