Go to the Puck
Dealing with H&S and environmental regulations in the wood treating industry would be a lot easier if we got ahead of the game.
by Sean Capstick and Shamini Samuel
While watching a hockey game with his father, a young Wayne Gretzky is said to have asked, "Why don't they just skate to where the puck's going to be?" Sometimes it seems that regulations on chemicals used in wood preserving are changing at the blinding speed of a hockey game. Yet even as Wayne Gretzky became the "Great One" for his ability to recognize patterns in the on-ice action and predict where they would lead - so he could get there first - members of the industry can deal proactively to regulation if they wish.
This is important because in many cases, responding to tightening restrictions on chemical use requires changes in processes and products, entailing capital spending. Installing a new kiln or other large piece of equipment is a multiyear process, and it is important to be more like Gretzky than one of the lesser players. Look ahead to make sure your capital investment and other plans are able to meet the changing regulatory picture.
New Regulations
Several major types of changes are affecting the use of chemicals in the wood-preserving industry. Many of these are due to a growing understanding - and concern - about the effects of the chemicals commonly used. These changes show up in three main areas:
- Health & Safety: We see increases in the numbers of chemicals coming under scrutiny and therefore regulation, and decreases in the allowable Occupational Exposure Limit (OEL) of many compounds. There is also an increase in employee awareness about potential workplace hazards. Part of this increase comes through the wide range of on-line resources - of variable accuracy and completeness - that employees use. Organized labour representatives are another source of information. To retain employees, particularly those highly educated and skilled, companies need to be sure that they deal with employee issues effectively and communicate their willingness to build a safe workplace.
- Environmental: Again, as understanding grows about the shortand long-term effects of various chemicals on the external environment, we see an increased range of regulation and decreasing allowable emissions. Limits for ammonia are decreasing, for example, and copper, chromium and arsenic are coming under increasing scrutiny.
- Market: Consumer-protection authorities are taking a closer look at the effects on users of some wood preservation chemicals. Green treated lumber, for example, is coming under increased scrutiny. Consumers are voting with their wallets, concerned about safety reports on some products. While some reports may be inaccurate, unjustified and exaggerated, marketplace demand is still changing rapidly.
What has some industry members feeling they're in the midst of a particularly tough penalty kill is the fact that chemical regulations have both health and safety and environmental aspects. It is important to ensure that dealing with the H&S side, for example through improved ventilation of the workplace, does not cause difficulties on the environmental side, through emissions that exceed regulatory limits. Likewise, the filters used to capture chemicals, in Respiratory Protective Equipment (RPE) and in scrubber systems, need to be disposed of in an environmentally sound manner.
On the plus side, the game is also changing through technological improvements. These include better RPE and equipment for controlling chemical emissions both in the workplace and the environment. There are also better information technology tools to track measurement data. This software alerts management to potential problems through tracking trends, and can also help reassure regulators that the operation is acting in a responsible manner.
Getting Ahead of the Game
As with talented hockey players, there are clear advance signs regarding changes in the wood-preserving chemicals picture. In many cases, issues about chemicals are first developed through US institutions, including the Environmental Protection Agency and the Conference of Governmental Industrial Hygienists. In Canada, US issues may be picked up by federal or provincial regulatory bodies, to develop locally applicable standards. This means that the US trade media and online resources is a good indicator of what may take place in Canada.
Many regulatory authorities publish schedules of which compounds are being regulated more closely, and what the expected limitations will be over time. Company managers need to stay abreast of the trends, as these have implications for capital spending, training and the products they can sell. Some of these resources are online. They can get support from in-house professional staff, or consultants specializing in these areas. One of the benefits of having either competent inhouse staff or consultants is obtaining accurate information on how the company can meet regulatory requirements. Paying proper attention to these matters pays off in smooth operations, without regulator- imposed delays, allowing managers to pay attention to production priorities.
Sean Capstick, P. Eng., is a senior air quality specialist in the Mississauga office of Golder Associates Ltd., and can be reached at (905) 567-4444; scapstick@golder.com. Shamini Samuel is a project manager/senior occupational hygienist in the Calgary office of Golder Associates Ltd., and can be reached at (403) 299-5600; shamini_samuel@golder.com.
