OSHA
OSHA Workplace Safety During the Holidays

There are numerous holidays in the months of November and December.  Just a quick look at Wikipedia confirmed at least 47 holidays for Christian, Secular, Hindi and Buddhist celebrations.  Each has its own traditions, decorations and food.  Given that large number, OSHA has some advice to keep workplaces safe during this time of year.  Don’t think this doesn’t apply to you and quit reading.  Think about the increase risks for personnel in warehouses and offices, on transportation teams, retail workers, etc.  E-Commerce is at an all time high which adds another layer to this busy season.

In the most recent Quick Takes Newsletter, there is a link to multiple resources which can be used for worker safety.  The link to reach those resources is https://www.osha.gov/holidaysafety.html.  I browsed through a few of the topics and here are just a few of the highlights.

  • Warehouse Safety Pocket Guide.  There are 10 OSHA standards that could apply to workers in a warehouse.  The standards include hazard communication, electrical safety, personal protective equipment (PPE) and forklifts.  There are also the hazards associated with loading docks, conveyors and charging stations to consider.  This guide provides a nice overview of the possible hazards and solutions for workers in the warehouse.
  • Safety Practices Once Tractor Trailer Drivers Arrive at a Destination.  While just a short 1-page resource, the information is a nice reminder not only for Continue Reading…
Air Canada Cargo – Section II Lithium Batteries Transport Document

It’s really no surprise that something new has come up with shipping lithium batteries again. Frankly speaking, these days it’s easier to ship a radioactive shipment on a passenger aircraft then a cell phone. Of course, I am referring to the process of shipping when I make this statement. Crazy isn’t it?

Effective Jan 2, 2020, anyone shipping any of the following:

  • Lithium-Ion batteries packed with equipment – UN3481 Section II PI966
  • Lithium-ion batteries contained in equipment – UN3481 Section II PI 967
  • Lithium metal batteries packed with equipment – UN3091 Section II PI 969
  • Lithium metal batteries contained in equipment – UN3091 Section II PI 970

With Air Canada cargo must complete and sign Lithium Batteries – Section II – Shipper’s Transport Document. The contents of the document include:

  • certifying shipment doesn’t include forbidden lithium battery shipments such as defective/damage batteries;
  • verifying the watt-hour for lithium-ion batteries meet Section II requirements;
  • verifying lithium metal content for lithium metal batteries meet Section II requirements;
  • airway bill includes the statement, if applicable;
  • lithium battery mark is on the package(s), if applicable; and 
  • shipper’s declaration statement. 

This document reinforces the fact that any person preparing or offering Section II lithium batteries must receive adequate instruction (IATA section 1.6). Basically, have some sort of dangerous goods training before you can ship lithium batteries. 

Up here in Canada we are limited to dangerous goods Continue Reading…

What is an Overpack?

Every few days one of our customers will call our Regulatory Helpline with questions about overpacks. Given the complexity of them, it is time to set the record straight. The focus for this blog will be the IATA Dangerous Goods Regulations as they seem to give a clearer picture, in my opinion, than those of 49CFR for US ground, IMDG for international vessel, and TDG Canadian ground regulations.

To start, let’s look at a few definitions. These are found in IATA’s Appendix A. Some of these may seem silly on the surface, but they are needed to drive the point home about overpacks. These definitions will all pertain to non-radioactive shipments.

  • Packaging: One or more receptacles and any other components or materials necessary for the receptacles to perform their containment and other safety functions and to ensure compliance with the minimum packing requirements of these Regulations. 
  • Package: The complete product of the packing operation consisting of the packaging and contents prepared for transport
  • Overpack: An enclosure used by a single shipper to contain one or more packages and to form one handling unit for convenience of handling and stowage. Dangerous goods packages contained in the overpack must be properly packed, marked, labelled and in proper condition as required by these Regulations. Note: Shrink-wrap or banding may be considered an overpack. 

What is all of that in reality? Packagings are the pieces and parts that Continue Reading…

ICC Top 10 List
2019 Top Ten OSHA Violations

Top Ten lists are often the topic of very enjoyable discussions. Whether its movies, music, sports teams, or restaurants. However some top ten lists aren’t based on entertainment value and taste, some are based on more serious topics. As the year comes to a close, the National Safety Council and the Occupational Safety and Health Administration announced the preliminary Top 10 most frequently cited workplace safety violations for the 2019 fiscal year.

Once again, Fall Protection – General Requirements is OSHA’s most frequently cited standard in the most cited violations of 2019. This makes nine years in a row that Fall Protections has topped this list. Although there is some good news with that as the number of citations for fall protection was 7,720 last year and dropped down to 6,010 for the 2019 fiscal year. The rest of the preliminary list of OSHA’s Top 10 violations for the fiscal year 2019 also remained mostly the same from last year, with only one minor change. Lockout/Tagout, which was ranked No. 5 in 2018, is now No. 4, switching places with Respiratory Protection. Below is the 2019 most cited violations per OSHA.

  1. Fall Protection – General Requirements (1926.501): 6,010 violations
  2. Hazard Communication (1910.1200): 3,671
  3. Scaffolding (1926.451): 2,813
  4. Lockout/Tagout (1910.147): 2,606
  5. Respiratory Protection (1910.134): 2,450
  6. Ladders (1926.1053): 2,345
  7. Powered Industrial Trucks (1910.178): 2,093
  8. Fall Protection – Training Requirements (1926.503): 1,773
  9. Machine Guarding (1910.212): 1,743
  10. Personal Protective and Lifesaving Equipment – Eye Continue Reading…
Graduation Cap
Training … the necessary evil of TDG – Part 3

Hello everyone. I’m back with the subject of TDG training. In my last blog, we made it clear who has responsibility for a list of the most important elements. We used the sections of the Canadian TDG Regulations for each part stating the implications of the various stakeholders.

Now, in order to fully understand what TDG requires as training, we will discuss what is the normal duration for a TDG training that would provide you with adequate skills and especially training applicable to your responsibilities.

It should be noted that the primary purpose of Part 6 of the TDG (article 6.2) is to ensure that the person has a solid knowledge of all of the topics listed in paragraphs (a) to (m) that relate directly to the person’s duties and to the dangerous goods the person is expected to handle, offer for transport or transport.

It is important to clarify here that Transport Canada does not define clearly or exactly what training should contain. TDG leaves much room for the interpretation of what constitutes appropriate training, and it remains the responsibility of the company to establish this.

For this reason, we will be discussing a training standard in the industry and it is equally important to believe that if a training facility declares that it is certified by the government or any other departmental entity that this is completely false. Continue Reading…

Safety
Staying Safe this Fall

If you have followed my blogs for any length of time you know that both my husband and I work in safety fields.  This means we drive our friends a bit nuts when we are together about staying safe.  They, in turn, humor us by attempting to do things safely when we are around.  It is a system that works well for us all.  Recently while together the conversation moved to the change in seasons.  Many look forward to a lessening of the heat and humidity in St. Louis while others lament the loss of daylight and snow.

That conversation got me to thinking.  Are there things that we, as normal, everyday people, should do to stay safe this fall? After some research on the websites for Centers for Disease Control and Prevention (CDC), National Safety Council (NSC), and National Fire Protection Association (NFPA), it turns out there are things that should be done during the fall to stay safe.  Below is a compilation of suggestions for your consideration.

Fall Safety Tips

  • Practice Safe Driving.  At this time of year, it is dark or twilight when people go to work and come home.  This is also an active time for many animals.  People are generally more active as well with the cooler weather.  Do not drive after you have been drinking at say a Halloween party.
  • Furnace readiness.  If needed Continue Reading…
Graduation Cap
Training … the necessary evil of TDG – Part 2

Hello everyone and welcome back! In my last blog, we made it clear who needs to be trained by using the definitions available to us in the Canadian TDG Regulations. Now, let’s try to properly interpret what TDG requires as training. It should be noted that the primary purpose of TDG regulations is the safety of dangerous goods in transport and to achieve an acceptable level of safety, it is, of course, essential that the persons managing dangerous goods in transport have adequate competency. To do this, in Part 6 of the TDG, the Regulations clearly state that any person who handles, offers for transport, or transports dangerous goods must have appropriate training and hold a training certificate. To fully understand what constitutes appropriate training, we must refer to article 6.2 and this article states that a person must have a solid knowledge of all the listed topics as well as the dangerous goods that he is called to handle, transport or offer for transport.

Let’s try to understand these topics that are specified and for each of the points, I will name who is responsible under the TDG.

  • Classification from Part 2 of the TDG. What does classification mean? This consists of defining whether your product meets the characteristics of a dangerous good included in one or more of the 9 hazard classes.
    Person responsible for this Continue Reading…
Environmental Update
Proposition 65 List Update for 2019

Here is one more blog in support of knowing it is autumn even though the weather may not feel like it.  The Office of Environmental Health and Hazard Assessment (OEHHA) in California just published a revised list.  If you aren’t familiar with the OEHHA, you likely do know about California’s Proposition 65 list.  As per usual, the list has changed a few times over the course of the year. 

To refresh your memory, the Safe Drinking Water and Toxic Enforcement Act of 1986 is the official name for California’s Proposition 65.  The list has to be revised and republished at least once per year.  California’s Office of Environmental Health Hazard Assessment (OEHHA) is the agency responsible for the implementation.  Chemicals are added or removed from the list when some other “authoritative body” makes a determination regarding a substances ability to cause cancer, birth defects, or other reproductive harm.

Shown below are all of the new substances that were added and or removed by month. They are listed by name, type of toxicity, and Chemical Abstracts Service Registry Number (CAS).  Now would be a good time to see not only if you are up to date on the new required “warnings” but if any of your products or substances were added to the new list.

Proposition 65 – Additions and Deletions

March 2019

Recalled Macbook Pro Laptops – Prohibited on US Flights

If you were planning on watching your favorite movie or a TV show on your Macbook Pro on your next flight well instead you may need to take a book.

Following Apple’s recall in June 2019 for certain 15-inch Macbook Pro laptops sold between September 2015 to February 2017, the US Federal Aviation Administration (FAA) has announced that effectively immediately these laptops are prohibited on all US commercial fights.  This isn’t a new regulation but rather a reminder of already existing regulations which bans recalled lithium batteries and lithium battery powered devices for air carriers.  These Macbook pros contain lithium batteries which may overheat and pose a fire safety risk. This restriction applies to both carry-on and checked in luggage.

Ensure you check your Macbook Pro model to confirm you are not in the recall group.

For more information, visit ICC Compliance Center’s website or call one of our Regulatory Specialists today! USA: 888-442-9628 | Canada: 888-977-4834

Taking Part in the BC Provincial CVSA Challenge

In June of this year, I was invited to participate in the Commercial Vehicle Safety and Enforcement (CVSE) Inspectors Commercial Vehicle Safety Alliance (CVSA) Challenge in Surrey, BC, Canada as a judge. I know it doesn’t sound fun but honestly, it was awesome.

The challenge was over a 3-day period and the competitors were seven (7) very qualified CVSE inspectors from all over BC to test their skills and knowledge. The winner from this competition would go on to compete in the North American Inspectors Championship (NAIC) in Pittsburgh, PA, USA. The NAIC includes the best of the best inspectors from Canada, the United States and Mexico competing for the title of Grand Champion. This is some serious stuff and of course, comes with bragging rights!

For the provincial competition, the competitors first have to write a series of qualifying exams, which advances them to the provincial competition. This year’s competition consisted of driver interview, dangerous goods cargo tank inspection, coach bus inspection, and dangerous goods packaging inspection. 

I came in as a judge for the dangerous goods inspections. We provided some of the dangerous goods packaging with “compliance issues”. That was fun for me. I got to make dangerous goods stuff incorrect on purpose for once. 

A few incompliance issues that I added: 

  • put primary and subsidiary hazard labels on opposite sides of the package, 
  • left out the telephone number on Continue Reading…