Most safety professionals are aware of the “Hierarchy of Controls: 1) Elimination/Substitution, 2) Engineering Controls, 3) Administrative Controls, and 4) PPE. Most safety professionals also know this basic principle of industrial safety is often times very difficult to get management buy-in; especially when a safety professional is bold enough to mention eliminating a hazardous chemical for a lesser hazardous chemical! Let us not forget, this was one of the driving factors for how OSHA wrote the PSM standard and EPA wrote their RMP rule (e.g. the list of HHC/EHS with thresholds). In the past 10 years there has been much discussion around “Inherently Safer Technology”, or IST, due to the Department of Homeland Security’s Chemical Facility Anti-terrorism Standards (CFATS). There has been MUCH push back regarding IST, with most claiming it would have serious impacts to businesses. Here is a PERFECT example of IST being implemented. Was it easy? I imagine not, but the safety payback is IMMESAURABLE!
Perfect example of using the “Elimination/Substitution” in the hierarchy of controls as well as IST