Stronger on paper than in practice – does chemical safety have a blind spot problem?

The story

After decades of regulatory progress, chemical safety should be one of the most mature areas of workplace safety. Yet chemical safety data continues to trend in the wrong direction — including an unprecedented number of on-the-job deaths due to chemical incidents over the last year.

The evidence

• The last 11 months saw 36 workplace fatalities due to chemical incidents — “the highest number ever investigated by the US Chemical Safety and Hazard Investigation Board (CSB) in a comparable timeframe” since the CSB became operational in 1998.
• Industrial accidents involving chemical releases increased from 83 in 2021 to 131 in 2025, while accidents involving injuries or fatalities rose from 60 to 89 during the same period — according to reports filed with the CSB.
• In the US alone, workers suffer more than 190,000 illnesses and 50,000 deaths annually related to chemical exposures. [OSHA]
• Nearly 37,000 workers were denied access to required chemical safety information over a five-year period because employers failed to comply with Hazard Communication (HazCom) requirements. Missing or outdated Safety Data Sheets (SDSs) remain one of OSHA’s most common chemical safety violations.
• Since leaving the EU in 2021, the UK has adopted only 2 harmful chemical restrictions, while the EU has implemented 13, including a wide-reaching ban on intentionally added microplastics.

The regulatory picture

On paper, chemical safety is heavily regulated.

• OSHA’s Hazard Communication Standard requires employers to identify hazardous chemicals, maintain Safety Data Sheets (SDSs), label containers, train workers, and communicate risk.
• That is reinforced by OSHA’s Process Safety Management standard for highly hazardous chemicals, EPA’s Risk Management Program for accidental releases, and DOT and EPA requirements for transport, storage, and disposal.

Together, these regulations are designed to ensure workers understand the chemicals they work with, the hazards they present, and how to handle them safely. But regulation alone does not keep information current or readily available.

The debate over what happens next is intensifying. The current US administration has proposed reversing several newer EPA Risk Management Program requirements, including:

• Mandatory third-party audits after serious chemical incidents
• Evaluations of safer technologies and alternatives
• Worker protections, including the authority to stop work in hazardous situations

It has also proposed eliminating funding for the Chemical Safety and Hazard Investigation Board (CSB), the independent agency that investigates major industrial chemical accidents and issues safety recommendations.

Supporters argue that the CSB is redundant to OSHA and the EPA, and that many existing requirements from these agencies duplicate internal safety practices already common across industry.

Many business leaders and industry associations argue that organisations already have extensive chemical safety programmes and strong business incentives to prevent chemical incidents. Serious accidents carry significant costs through operational disruption, legal liability, insurance claims, workforce impacts, and reputational damage. Rather than expanding prescriptive regulation, they want organisations to tailor chemical safety programmes to their own operations while remaining accountable for outcomes.

Critics counter that many exposure limits already lag the science, and that loosening requirements could widen the gap between what is documented and what workers are protected from. Developing or updating chemical exposure standards often takes years, as agencies navigate rulemaking, legal review, public comment periods, and competing stakeholder interests.

The chemical safety blind spots

The regulatory guidance is extensive, and the objective here is straightforward: workers should always know what chemicals they’re working with, what hazards those chemicals present, and how to protect themselves.

Moreover, most organisations have spent decades building comprehensive chemical safety programmes. Yet, in practice, several blind spots present challenges and risks to consistently protecting workers:

Chemical inventories evolve and safety information isn’t static

Chemical safety is a moving target — and the pace of that change keeps accelerating. New chemicals are introduced, suppliers change formulations, products are substituted and inventories shift as operations evolve. Every change can affect labeling, employee training, emergency response procedures, and regulatory documentation.

At the same time, manufacturers regularly update Safety Data Sheets when hazard classifications change, or new toxicological information becomes available. Academics and policy reviews (such as the UK REACH work programmes) point out that when a single hazardous chemical is restricted, industries frequently swap it for an unregulated chemical with a near-identical hazard profile.

Yet, maintenance of chemical safety information is often part of a periodic compliance exercise, rather than the continuous practice needed to ensure that information is accurate and up to date. Without help from technology and software, that can rapidly become unmanageable.

Making safety information practically accessible at the point of work

To be useful, chemical safety information needs to be immediately available and easy to access right at the point of work — on production floors, maintenance sites, laboratories, or construction sites. But too often, chemical information remains stored in paper binders, filing cabinets, or disconnected systems. That accessibility gap shows up in enforcement data: nearly 37,000 workers were denied access to required chemical safety information over a five-year period, while missing or outdated Safety Data Sheets remain among OSHA’s most frequently cited Hazard Communication violations.

Managing complex chemical safety in decentralised work environments

Many organisations manage hundreds — or even thousands — of chemicals across multiple facilities, business units and geographic locations. This creates two equally important challenges: Safety and compliance leaders often struggle to gain a single, reliable view of inventories, Safety Data Sheets, and compliance activities across the enterprise. At the same time, workers at every location don’t always have consistent access to the same current procedures, hazard information, and emergency guidance.

That decentralised, highly manual chemical management creates a fragmented data problem: organisations lose the opportunity to connect that information and identify patterns across their operations. Correlating chemical data with incidents, near misses, engineering controls, or worker exposures can help identify higher-risk facilities, suppliers, or processes — before those risks contribute to a serious event.

Overreliance on behavior-dependent safety measures

Many chemical safety programmes rely heavily on administrative controls: written procedures, employee training, signage, safe work practices, and personal protective equipment (PPE). These measures are important, but they depend on workers following procedures every time.

OSHA’s Hierarchy of Controls places these behavior-dependent measures below more effective approaches such as eliminating hazards altogether, substituting safer chemicals or implementing engineering controls that remove or isolate hazards. Organisations that rely primarily on procedures and PPE may reduce risk, but they also increase their dependence on consistent human performance in environments where mistakes, fatigue, and changing conditions are inevitable.

Extreme weather changes chemical risks

Many chemical safety programmes were developed around historical operating conditions — and extreme weather increasingly challenges those assumptions. Extreme heat can increase evaporation rates, accelerate chemical reactions, and elevate worker exposure, while extreme cold can affect chemical stability, equipment performance, and storage conditions. Severe storms may disrupt power, ventilation, or containment systems, and flooding can damage storage areas and release hazardous materials into surrounding environments. Chemical safety programmes need to evolve to account for these changing environmental conditions that fall outside routine operating assumptions.

Emerging best practices

1. Shift from periodic compliance to continuous chemical management. Leading organisations increasingly treat chemical safety as a living operational process rather than a collection of annual compliance activities. Inventories, documentation, and hazard information are maintained continuously as chemicals, suppliers, and facilities change.

2. Conduct regular chemical inventories. Regular chemical inventories help organisations identify outdated or unnecessary products, evaluate opportunities to substitute less-hazardous alternative and reduce the overall volume of hazardous chemicals on site. Alongside improving worker safety, many organisations find these efforts also reduce procurement, storage, and disposal costs while simplifying ongoing compliance.

REAL-WORLD SAVINGS:

After conducting a comprehensive chemical inventory, Norway’s Porsgrunn Municipality realized approximately NOK 500,000 (£41,000) in cost savings by eliminating or substituting more than 1,000 chemical products, ultimately reducing its hazardous chemical inventory by 16%.

3. Connect chemical safety data to find correlational insights: Centralising chemical inventories, Safety Data Sheets, and hazard information creates a single source of truth for compliance — but it also creates the foundation for richer, cross-functional analysis. Organisations can begin connecting chemical information with incidents, near misses, inspections, and other operational data to identify trends, target interventions, and move from visibility toward an even more valuable proactive approach to risk management.

4. Bring chemical safety information to the point of work. Digital access to current Safety Data Sheets and emergency procedures helps ensure workers can find the information they need right when they need it — where work is actually performed.

5. Design controls that don’t depend solely on behavior. Organisations are increasingly evaluating hazards through OSHA’s Hierarchy of Controls, prioritising opportunities to eliminate, substitute, or engineer out risks before relying on administrative controls like training and PPE that depend on compliant worker behaviors.

6. Prepare for dynamic risk, not just regulatory compliance. Chemical safety programmes are expanding beyond compliance checklists to account for changing supplier information, evolving regulations, distributed workforces, and increasingly unpredictable environmental conditions. The organisations making the greatest progress are building systems that help them adapt as chemical risks evolve.

See what modern chemical safety looks like

EcoOnline is helping leading organisations use digital chemical management to:

• Maintain a single, always-current source of truth for Safety Data Sheets and chemical inventories
• Automatically receive updated SDSs as manufacturers publish new information
• Give every worker immediate access to chemical safety information at the point of work
• Improve visibility across facilities while simplifying compliance and audit readiness
• Reduce administrative effort while strengthening day-to-day chemical risk management

The title

One of the challenges with chemical safety information is making sure that when you’ve got updates to that information, that it actually gets through to who it needs to get through to, which is, you know, people on the ground. And getting a new SDS is obviously important in that process, but having that document available doesn’t necessarily mean that frontline workers are gonna know what’s changed in it, how that affects them, how it affects the risk assessments and controls associated with it. So if I were to give a few tips, I’d remember when sourcing a new SDS, remember that you’ve got the right to be provided with the most recent and up to date version from your supplier. And then you wanna go in and you’re gonna wanna look at what’s changed. Consider whether that has an impact on your risk assessments, your controls, and the information that you’re giving out to your colleagues. And that’s where solutions like chemical manager and SiPo can really help. They’re gonna electronically bring all that information together and support the process of keeping your chemical health and safety assessments all up to date, ready for your workers to access.

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Join the live debate — Chemical safety: Solved on paper, unsolved in practice?

Chemical safety has been regulated for decades. Yet serious incidents continue, exposing a gap between compliance and worker protection.

This live debate asks whether organisations have become better at documenting chemical risk than managing it, and who should be responsible for closing the gap.

Thursday, 17 September | 10AM EDT / 3PM BST