A chlorine dioxide molecule. Image via Wikimedia.
Businesses engaged in chlorine gas handling already have a range of different measures and best practices in place to ensure safe operation. This is an important part of environmental sustainability. It is also key to responsible operation. It is up to facility owners to make sure that their staff remains safe in the workplace, and that the general public and local environment are protected.
But regulations and best practices do not remain static. They grow and evolve to meet the developing needs of businesses and the wider community. With this in mind, what do you need to know in order to stay compliant? Let’s take a look at some of the latest regulatory changes that you need to be aware of when approaching chlorine gas safety in 2021 and beyond.
Regulatory compliance when handling chlorine
The handling of chlorine falls under the Toxic Substances Control Act (TSCA) 1976. This act provided the Environmental Protection Agency (EPA) with regulatory authority over the handling of chemical substances that carry an “unreasonable risk of injury to health or the environment.”
This act is now 45 years old, but it has been updated in recent years to reflect changes to industries in the USA. The most recent amendment came in June of 2016, with the passing of the Frank R. Lautenberg Chemical Safety for the 21st Century Act. As well as ensuring that Sherwood valves and other pieces of infrastructure are well-maintained, businesses must do the following:
- Conduct an evaluation of chemicals used and submit this report to the EPA.
- Follow risk-based safety standards imposed by the relevant acts.
- Identify any unreasonable risks and then take steps to eliminate these.
The EPA provides a detailed factsheet on reasonable applications of chlorine gas and the potential dangers. Applications include cleaning and disinfecting, water treatment and chemical processes, as well as bleaching of wood pulp. Facilities engaged with the production of chlorine gas for industrial applications also fall under this designation.
Under the act, the EPA will also assess risks that chlorine gas poses to workers. This means conducting audits on chemical exposures in the workplace, as well as environmental exposures. Under the terms of the act, the EPA will pay extra attention to workers who are at the greatest risk of exposure, or to particularly “susceptible subpopulation[s].”
This means:
“A group of individuals within the general population identified by the Administrator who, due to either great susceptibility or greater exposure, may be at greater risk than the general population of adverse health effects from exposure to a chemical substance or mixture, such as infants, children, pregnant women, workers, or the elderly.”
Industries using chlorine or other hazardous chemicals must be willing to submit to assessment by government agencies under the guidance of the EPA. Proving that your business has the necessary infrastructure in place to properly handle chlorine or other gases is key to ongoing compliance under the act.
Adopt the hierarchy of controls during chlorine gas handling
The CDC’s National Institute for Occupational Safety and Health (NIOSH) recommends a hierarchy of controls for businesses dealing with hazardous materials, including chlorine gas handling.
The hierarchy is designed to show businesses how to order their controls from most to least effective. All of the different levels of control should be implemented, but businesses should build their strategy on a solid foundation of the most effective measures.
The hierarchy is as follows:
- Most effective control: Elimination
Elimination involves actively removing the hazard. In the example of chlorine gas handling, businesses should consider where they need to utilize this gas for a specific application. They can then eliminate any non-essential uses of the gas to reduce the chances of exposure. You will certainly need to use chlorine for many industrial applications, but this step is designed to reduce unnecessary usage.
- Substitution
Substitution is the second most effective control. This tier refers to the substitution — or replacement — of the hazardous substance with something else. Consider how you are utilizing chlorine gas. Is there any instance in which a safer gas could be used instead?
- Engineering controls
The middle control on the hierarchy of effectiveness, engineering controls involve isolating personnel from hazards. What protective measures can you put in place to separate human teams from hazardous substances like chlorine gas? Can risky processes be automated to reduce the chances of exposure? Ensuring that infrastructure such as chlorine valves and pipework, as well as other industrial gas valves and equipment pieces, are well-maintained and fully functioning is also an important part of engineering control.
- Administrative controls
Administrative controls are the second least effective tier in the hierarchy. This involves changing the way in which people work and adopting safe working practices that work to lower the risk your personnel face in the field.
- Least Effective: Personal protective equipment
The least effective control is personal protective equipment, or PPE. This is equipment that is delivered to workers who may be in direct contact with chlorine gas.
Again, it’s important to understand the hierarchy of controls properly. While PPE is designated as the least effective, this does not mean you can forget about PPE for staff who may be handling chlorine gas. Instead, it means that businesses need to do more to protect their employees in the field.
Fostering a positive and comprehensive culture of safety in the workplace is the most effective means of staying compliant when handling chlorine, and protecting your staff and the general public. Prevention of hazards is always the best policy.
Proper chlorine gas handling requires a comprehensive and collaborative approach
Remember that the EPA is not out to penalize businesses. Instead, they seek to create a safer situation for workers, the local community, and the broader environment. As such, they provide a range of different resources designed to help facilities reach the right standards of compliance, and they welcome a collaborative approach in reaching these standards.
A comprehensive approach is also important. As we have seen, authorities advocate a preventative stance when it comes to handling toxic substances such as chlorine, supported by more responsive measures such as PPE. Moving forward through 2021 and beyond, working closely with the EPA and implementing holistic controls across your entire facility is the best course of action in staying compliant, sustainable, and responsible.