'Banding' together for HazCom can help small companies

Answered by Robert A. Ernst, associate editor, J.J. Keller & Associates, Neenah, WI.

Control banding involves a universal, globally "harmonized" approach to chemical hazard communication in the workplace. The wide variety of national laws regarding workplace hazard communication, or the lack of these laws, has resulted in a variety of hazard labeling and printed safety information.

In an ever-shrinking global market these laws, along with natural language barriers, lead to reduced protection for workers and have created additional barriers to trade, especially for small- and medium-sized companies. It is precisely in these companies that growth in the use of hazardous chemicals is greatest, and where access to hazard control information and expertise is most needed.

Control banding is intended to help smaller businesses by providing an easy-to-understand, practical approach to controlling hazardous exposures at work. It is not possible to assign specific exposure limits to every chemical in use. Therefore, control banding seeks to protect worker health by focusing on exposure controls.

It is possible to determine the broad hazard group to which a chemical belongs and, on that basis, determine the necessary level of control, or "control band." The greater the potential for harm, the greater the degree of control needed to manage the situation and make the risk "acceptable."

Also, many chemicals do not have occupational exposure limits, and many small employers tend to rely on industry customs and past practice to manage risk. Control banding allows an employer to consult a reference chart, see the best controls for a given chemical, and adopt them without doing costly risk assessments.

With control banding, a chemical is assigned to a control band using four pieces of information:

The system then:

• Identifies the control band (control approach)
• Produces advice on controlling risk from the chemical used in the specified task
• Provides written guidance and documentation as a result of the assessment

Control banding is not currently appropriate for many situations, including "hot" processes, open spray applications, gases and pesticides. These situations involve more complex exposures requiring additional considerations not yet fully addressed by current control banding strategies. In addition, control banding does not yet cover safety hazards, environmental issues or ergonomic issues.

OSHA already has taken this control measure-based approach with regard to asbestos and lead in construction settings and is considering it for abrasive blasting and silica. NIOSH researchers are investigating the potential applications and utility of control banding to address occupational safety and health challenges in the United States.