EHS and the Procurement Connection

By Adam Levesque, MBA, CSP

Safety Management Consultant, MEMIC

What types of chemicals or raw materials should you ensure receive adequate hazard controls prior to arriving at your facility? How would you respond if you were asked by senior leadership why employees were not protected adequately, why a hazard which caused an injury was not recognized or why a chemical was not stored properly? EHS professionals can often be caught in these situations if they don’t utilize proactive safety management strategies. This is where implementing a chemical and raw material procurement approval program is essential from a safety management system perspective and an essential business practice. Assessing your establishment’s willingness and readiness for such a program is a great first step. Given the green light, it’s time to move forward.

As EHS professionals we work closely with every aspect of our organizations, and whether you’re working in a healthcare, construction or manufacturing, acquiring raw materials is unavoidable. A program to pre-screen and approve incoming raw materials can improve business efficiency and effectiveness and can be quantified over time. The implementation will also improve operational compliance, reduce risk associated with missed reporting obligations, improve employee and environmental safety, strengthen brand image, enhance supply chain knowledge and ultimately foster a more sustainable supply chain vision.

A chemical and raw material approval program is not difficult to facilitate and can be done with minimal resources. OSHA’s hazard communication standard requires you manage chemical hazards by knowing and understanding the chemicals at your facility. Integrating compliance objectives into the procurement department acquisition process is a great way to ensure that when any new or substituted chemical are introduced, there is time to ensure that proper controls are in place prior to the materials arriving on-site. Additionally, there are also risks associated with environmental reporting and recordkeeping which include waste determination/disposal, DOT compliance, air emissions, EPCRA, etc., all of which must be managed.

Defining clear program parameters is crucial to ensure that your procurement department knows what materials need approval. A strong program will require that all purchased raw materials be submitted for review through the approval process. Tracking all raw materials will provide the opportunity for a complete assessment of regulatory, employee and environmental risk.

Here is a list of best practices to consider when developing a chemical and raw material approval program:

• Define the purpose of the program, include business and EHS benefit.
• Define the program parameters, what materials require approval.
• Define internal responsibilities, who is responsible for what. (Process flow diagrams work well.)
• Develop a written program, senior leadership support is a must.
• Develop an approval form, make it easy for submitters to provide the data required.
  • Consider defining limitations or advanced approvals for high hazard chemical purchases, i.e. chemicals with an HMIS health rating of 3 or greater must receive director/senior management signoff.
• Train affected employees, identify program participants and communicate expectations clearly.
• Define an internal control process, audit the system periodically to ensure that it is working how it is intended.

These are just a few ways in which a chemical and raw material approval process can help move your organization to the next level and influence safety culture in the support areas of the organization. When communicating to leadership during pre-implementation, stress that the intent of the program is not to place limitations on the organization, but to better assist in keeping employees safe and to manage internal and external risk. As EHS professionals, we don’t want to respond after an accident with reasons why a hazard or associated risk was not identified, we need to implement controls which prevent hazardous conditions from becoming present in the first place.

Adam Levesque, MBA, CSP earned his Bachelor’s Degree in Applied Safety Sciences from Keene State College in New Hampshire and also earned a Masters of Business Administration (MBA) with a concentration in Environmental Compliance and Sustainability from Southern New Hampshire University. He is a Board Certified Safety Professional (CSP) and is always looking for new opportunities to grow his knowledgebase that will assist him in providing services that lead to a sustainable safe and healthy workplace environment. Mr. Levesque has over ten years of experience as a safety professional. He has spent most of his time working in the manufacturing industry developing and overseeing safety management systems. Mr. Levesque comes to MEMIC after working for multiple manufacturing companies with facilities across the world. He was in charge of managing a team of safety professionals and responsible for developing, integrating and aligning safety best practices across manufacturing facilities globally.