Globalization of an Industrial Hygiene Program at a Multinational Specialty Chemical Company

Transcription

1 Globalization of an Industrial Hygiene Program at a Multinational Specialty Chemical Company Richard Hirsh, CIH Rohm and Haas Company AIHCE, May 2006 rhirsh@rohmhaas.com (510) Copyright Rohm and Haas Company 2006, All Rights Reserved

2 Objectives Background on Rohm and Haas Company Review Global IH Compliance Program (Standards and Audits) Review Workplace Exposure Assessment and Control Strategy Review Resources and Support Safety Journey and Performance Metrics

3 Rohm and Haas Company Specialty Chemicals + Morton Salt 10 Business Units ~ $8B/year in sales 125 Manufacturing, Mining, Research, and Warehouse Facilities in 27 Countries 16,000+ Employees HQ - Philadelphia 12 OSHA VPP Star sites

4 Rohm and Haas Company Primary Businesses / Products Coatings architectural, automotive, powder Adhesives and Sealants Plastics Additives Performance Chemicals water treatment resins Monomers Consumer and Industrial Specialties household products, detergents, personal care Electronic Materials printed wiring board, photo resist, wafer polishing Advanced Materials laser applications Morton Salt Agrofresh

5 EHS Compliance Program Global EHS Policy We will conduct audits to assist management in assuring compliance with the environmental, health and safety laws, regulations, policies and standards applicable to the company s s operations and products. We will audit our performance and the Board of Directors and EHS Council will monitor our commitment and progress.

6 Hazard Communication IH Standards Workplace Exposure Assessment and Control Workplace Exposure Limits Hearing Conservation and Noise Control Respiratory Protection Sanitation Illumination Ergonomics (Draft) Chemical Specific Standards: Asbestos, Chloromethylation of Ion Exchange Resins, Cyanotic Agents, Formaldehyde, Lead

7 Other Key IH Related EHS Standards Corporate EHS Audits EHS Principles and Personnel Management of Change EHS Management System for Manufacturing Process Safety Management Emergency Medical Response

8 EHS 100: EHS Principles and Personnel Standard EHS Site Policy EHS Manager(s) responsibilities EHS Training requirements and schedule for new EHS managers Attendance at recognized conferences/meetings to ensure functional excellence EHS goals & performance targets Responsible Care Code Coordinator designation Site EHS professional availability for one EHS audit per year Leadership Competencies, Job Responsibilities and Technical Competencies of EHS personnel.

9 Rohm and Haas EHS Audits Audits conducted ~ every 3 years for Company Owned Facilities (WW) External Service Provider audits also done globally

10 Types of Findings ( Exceptions ) Government Corporate Management Open From Previous Repeat Programs of Merit

11 Follow Up Semi-annual follow up and tracking of all open items for each facility (Access data base) Quarterly compliance meetings with manufacturing managers and EHS business directors Quarterly summary reports to business managers and periodic reports to senior managers. Raise issues to the appropriate senior business manager for any audit finding that does not have timely closure.

12 Global Audit Program Challenges EHS Management Systems Standard Implementation Integrating External Service Provider Audits

13 Quarterly IH Monitoring Report Issued to Regional and Business EHS Directors and Manufacturing Managers Summarizes Worldwide Site Monitoring Activity % of target plan completed # of samples collected # and % results above exposure limits Data sorted by region and business Reviewed during quarterly compliance meetings: % Exposure Monitoring Plan Target Completed by site and by business Over-exposures and site corrective action plans

14 Workplace Exposure Assessment and Control Hazard Communication Hearing Conservation Engineering Controls Exposure Monitoring Epidemiology Exposure Assessment Administrative Controls Personal Protective Equipment Medical Surveillance Hazardous Materials Management Work Practice Controls

15 Exposure Assessment Strategy Health Hazard Review Committee Workplace Exposure Monitoring Manual Employee Exposure Monitoring System Job Exposure Profile (JEP) System Fundamentals of IH Training Program Workplace Exposure Assessment and Control Standard New Web-based EASy database

16 Site Expectations IH Coordinator Role and Site Responsibilities Written Exposure Assessment and Control Program Qualitative Exposure Assessment process Annual Routine Exposure Monitoring Plan and Program Monitoring Equipment Statistical Analysis of Datasets Control Strategy Periodic Reassessment

17 Exposure Assessment Model Start Basic Characterization Exposure Assessment Acceptable Exposure Uncertain Exposure Unacceptable Exposure Reassessment Further Information Gathering Control

18 Current Strategy Systematic data-based statistical approach to review workplace exposures Results in a more efficient and effective IH program Identification of unacceptable exposures Better prioritize control efforts and expenditures Improve baseline data for setting standards and risk assessment

19 Multi-faceted Implementation Approach Self-Assessments for New Acquisitions Web-based Solutions/Tools Training Phased in Roll-out of Strategy Teleconferences - Review New Tools Surrogate sampling guidelines Exploring mathematical modeling approaches

20 Asia Pacific Regional IH Training in Thailand 2004

21 Multi-faceted Implementation Approach Corp. IH Surveys Outside consultants Leveraging of regional IH resources EHS Audits Ongoing Technical Assistance

22 Future Challenges/Ideas Integrate new approaches: Control Banding, Surrogate Sampling, Mathematical Modeling, and Bayesian statistical analysis Leverage exposure data Finalize comprehensive EASy Exposure Assessment database Improve prioritization process for establishing exposure limits and sampling and analytical methods Address EHS position turnover issues Improve import/export flow of equipment/ppe into countries and access/cost of laboratory analysis

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24 Safety Beliefs We embraced 5 fundamental safety beliefs as the foundation for our behaviors and practices: The health and safety of people is valued above all else. All occupational injuries and illnesses can be prevented. Excellence in safety is compatible with excellence in other business parameters. Safety must be made an integral part of everything we do. Good safety is a result of the attitudes and beliefs of people.

25 Safety Management System and Principles There are 6 overarching principles in our management system that must be in place for safety excellence. Vision, Commitment and Leadership at all levels Line Ownership of Safety Involvement of All in Safety Activities Training Competent EHS Support Organization Comprehensive Safety Systems and Practices

26 Participation Tool Kits Activities and tools for employee involvement. Increasing the number of employees involved and the depth of their involvement is the key. There are 12 participation tools or opportunities suggested: Training Incident Investigation Inspections Audits/Compliance Assessment Audits Operating Procedures and Task Instructions Hazard Identification and Management of Change Review Empowered Safety Teams Safety Meetings Behavior Safety Sampling Personal Protective Equipment Housekeeping Ergonomics

27 Metrics and Performance Indexing Results Based -two simple metrics required - Number of OII cases - Days since last OII Activity Based Recommended metrics - Safety Performance Indexing - Safety Journey Scorecard

28 Metrics and Performance Indexing Examples of Possible Progress Measures # or % behavior-based safety samples completed % employees doing inspections # near misses or hazards reported Off job injury rate # tool box safety meetings % EHS actions items completed % employees completing required training % EHS management system in place % Job Safety Analysis updated

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