Safe Holiday Decorating

Holiday Safety

December means festivity and cheer for many. Many offices, including ours, enjoy bringing the festivities to work by decorating our offices, cubicles, and other office areas.

Safety is always important, festive occasions included. Safety+Health suggest the following to help prevent injuries while celebrating on the job. (Safety+Health Magazine)

Safe decorating

  • Don’t stand on a chair to hang decorations. Use a stepladder, and make sure to read and follow the instructions and warnings on the label. And never hang decorations from fire sprinklers – they can prevent the sprinklers from operating properly. OSHA regulations state that stacked materials should never be closer than 18 inches below fire sprinklers.
  • Planning to string decorative lights or other electrical items in your workspace? The Electrical Safety Foundation International, a nonprofit organization, states that workers should:
    • Be sure that all electrical items are certified by a nationally recognized independent testing lab.
    • Inspect all lights, decoration and extension cords for damage before using.
    • Avoid overloading electrical outlets with too many decorations or electrical devices – they can overheat and cause a fire.
    • Never try to make a three-prong plug fit into a two-prong outlet.
    • Turn off all indoor and outdoor electrical decorations before leaving.

ICC Compliance Center offers a variety of safety courses to train employees on the hazards in the workplace. Visit our website and view our safety courses for more information

From our ICC family to yours, have a safe and happy holiday season.

Safe Winter Driving

As the weather gets colder and inevitable snow and ice arrive, it is time to think about winter driving, and the challenges it brings.

According to the Federal Highway Administration, more than 24% of accidents are cold-weather related.

AAA (http://exchange.aaa.com/safety/roadway-safety/winter-driving-tips/#.WDMTHrIrLRY) recommends the following for driving in snow:

  • Accelerate and decelerate slowly. Applying the gas slowly to accelerate is the best method for regaining traction and avoiding skids. Don’t try to get moving in a hurry. And take time to slow down for a stoplight. Remember: It takes longer to slow down on icy roads.
  • Drive slowly. Everything takes longer on snow-covered roads. Accelerating, stopping, turning – nothing happens as quickly as on dry pavement. Give yourself time to maneuver by driving slowly.
  • The normal dry pavement following distance of three to four seconds should be increased to eight to ten seconds. This increased margin of safety will provide the longer distance needed if you have to stop.
  • Know your brakes. If you have anti-lock brakes (ABS) and need to slow down quickly, press hard on the pedal-it’s normal for the pedal to vibrate a bit when the ABS is activated. In cars without ABS, use “threshold” breaking, keeping your heel on the floorboard and using the ball of your foot to apply firm, steady pressure on the brake pedal.
  • Don’t stop if you can avoid it. There’s a big difference in the amount of inertia it takes to start moving from a full stop versus how much it takes to get moving while still rolling. If you can slow down enough to keep rolling until a traffic light changes, do it.
  • Don’t power up hills. Applying extra gas on snow-covered roads just starts your wheels spinning. Try to get a little inertia going before you reach the hill and let that inertia carry you to the top. As you reach the crest of the hill, reduce your speed and proceed down hill as slowly as possible.
  • Don’t stop going up a hill. There’s nothing worse than trying to get moving up a hill on an icy road. Get some inertia going on a flat roadway before you take on the hill.
  • Stay home. If you really don’t have to go out, don’t. Even if you can drive well in the snow, not everyone else can. Don’t tempt fate: If you don’t have somewhere you have to be, watch the snow from indoors.

ICC Compliance Center cares about our employees and customers. Stay safe this winter season.

Shipping a Gift? Ask Yourself, is it Dangerous Goods?

This weekend, my husband and I decided it was time to do some clean up and sell some things on e-Bay. We did the usual photo and description, and posted a few odd items. When we came to the last item, a PS3 controller, my husband stopped and said, “I am going to have to ship this as dangerous goods.”

It got me thinking, how many people would know that? I wonder how many lithium batteries are mailed or shipped by average people, never thinking that they are doing something wrong and potentially very dangerous. Even scarier, is the thought that my family could be on that same plane.

As the holiday season approaches, people everywhere will be sending gifts to loved ones around the world. What many people still do not realize, is that innocent gifts like game controllers, lap-top computers, cell phones, and tablets are dangerous goods.

The definition of “dangerous goods” varies slightly from regulation to regulation, but basics means  articles or materials capable of posing significant risk to people, health, property, or the environment  when transported. Examples include: perfumes, paints, aerosol cans, and anything with a lithium battery including power tools, computers, and cameras.

Dangerous goods need to be packaged and labeled in accordance with the regulations. You also need to be a trained person to ship them.

Before you wrap that gift, contact the post office or the shipping company and ask them if it is considered dangerous goods. If it is, the best solution might be to seek a local packaging and crating company to assist. ICC Compliance Center has a list of “Repackers” around the USA and Canada that can be found here: http://www.thecompliancecenter.com/partners/.

Since not everyone is privileged enough to be in the dangerous goods industry, as dangerous goods professionals, we need to do our part in to educate and protect others, so all families can have a safe holiday season. Help me educate others by sharing this on your social media pages.

OSHA & PHMSA Working Together

OSHA & PHMSA Issue Joint Guidance Memorandum

The Occupational Safety and Health Administration and the U.S. Department of Transportation (DOT) Pipeline and Hazardous Materials Safety Administration (PHMSA) issued a joint guidance memorandum that is intended to provide clarity on the applicability and relationship between, DOT’s labeling requirements under the HMR and OSHA’s labeling requirements for bulk shipments under the HCS 2012.

PHMSA’s hazardous materials regulations require labeling of hazardous materials in transportation, while OSHA requires labeling on containers in the workplace.

When OSHA released its Hazcom 2012 (29 CFR Part 1910.1200) revisions, Appendix C.2.3.3 stated that “If a label has a DOT transport pictogram, the corresponding HCS pictogram shall not appear.” The Hazardous Materials Regulations state “No person may offer for transportation and no carrier may transport a package bearing any marking or label which by its color, design, or shape could be confused with or conflict with a label prescribed by this part” (49 CFR Part 172.401(b)).

This raised many questions with stakeholders, and shortly thereafter, OSHA published a brief that stated that PHMSA does not view the pictograms as a conflict, and both may appear. OSHA continues on in the brief to state they intend on revising C.2.3.3, but in the meantime, they will allow both to appear. This new guidance document further confirms this position.

The Joint Guidance Memorandum can be found at https://www.osha.gov/dsg/hazcom/joint_phmsa_memo_09192016.html


ICC is your source for compliant DOT/OSHA or TDG/WHMIS labeling requirements. Contact us to find out how we can help.

OSHA
The Top 10 – OSHA Violations 2016

Top 10s

When you think “Top 10” you might think about David Letterman’s top 10 lists. These lists are perhaps his greatest legacy from his run on the “The Late Show” (see 5 Top 10 Lists from David Letterman)

Unfortunately, this blog is not about those top 10 lists, but rather something far more serious, OSHA’s Top 10 violations.

This list is comprised of nearly 32,000 inspections of workplaces by federal OSHA staff. The top 3 violations remain the same as the last three years. They include: fall protection, hazard communication and scaffolds.

The complete Top 10 OSHA violations list includes:

  1. Fall protection
  2. Hazard communication
  3. Scaffolds
  4. Respiratory protection
  5. Lockout/tagout
  6. Powered industrial trucks
  7. Ladders
  8. Machine guarding
  9. Electrical wiring
  10. Electrical, general requirements

According to the Department of Labor’s Occupational Safety and Health Administration (OSHA), there are more than 4500 worker deaths and approximately 3 million workers injured every year. Many of the deaths are associated with fall, poor scaffolding and forklift operations. (https://blog.dol.gov/2016/10/18/top-10-osha-citations-of-2016-a-starting-point-for-workplace-safety/)

Prevention

What is astonishing is that so many of the deaths and injuries are preventable. Employers and employees must take safety seriously. Unlike David Letterman’s Top 10, there is nothing funny about workers dying or being injured.

OSHA has recently released new recommendations for safety and health programs that will help prevent injuries and deaths, reduce costs, improve compliance, and engage workers. This recommendation can be found here: https://www.osha.gov/shpguidelines/.

Training

Training is vital. Ensure workers are trained, and have understood the training. Repeat the training as often as needed to reinforce the concepts and remind the worker that safety on the job is essential.

Contact ICC for more information on training courses available. We can assist employers with their employee training requirements. Most courses are available online, and many segments take less than 30 minutes. Everyone can spare 30 minutes to ensure that each and every day, they leave work the same way they arrived.

At ICC our motto is “See something, say something”. Remember that safety is everyone’s concern.

Lithium
Samsung Galaxy Note 7 BANNED

Don’t Bring Your Note 7 with You on a Plane

More bad news for Samsung Galaxy Note 7 owners. Not only do you have to worry about them catching on fire, but now, you can’t even bring them with you when you travel by air.

The U.S. Department of Transportation (DOT), with the Federal Aviation Administration (FAA) and the Pipeline and Hazardous Materials Safety Administration (PHMSA), announced it is issuing an emergency order to ban all Samsung Galaxy Note7 smartphone devices from air transportation in the United States.

This emergency order bans all Samsung Galaxy Note 7 devices from “being on their person, in carry-on baggage or in checked baggage on flights to, from or within the USA.

The emergency order can be found here:
https://s3.amazonaws.com/public-inspection.federalregister.gov/2016-25322.pdf

In September, Samsung announced the recall of over 1.9 million Galaxy Note7 devices. The Consumer Product Safety  Commission says that Samsung received 96 reports of lithium batteries overheating, including 13 burns and 47 reports of property damage. The CPSC recall notice can be found here: https://www.cpsc.gov/Recalls/2017/Samsung-Expands-Recall-of-Galaxy-Note7-Smartphones-Based-on-Additional-Incidents-with-Replacement-Phones


If you need to ship lithium ion or metal batteries by themselves, packed in equipment or  contained in equipment contact ICC for training and supplies to ensure that they are transported safely.

Environmental Update
EPA Aligns 40 CFR Part 370 with OSHA Hazcom 2012

The Environmental Protection Agency (EPA) issued a final technical amendment to 40 CFR Part 370, in June 2016 which aligns the hazardous chemical reporting regulations to the changes in the Occupational Safety and Health Administration’s (OSHA) Hazcom 2012.

These changes have a compliance date of January 1, 2018, and affect reporting under the Emergency Planning and Community Right-to-Know Act (EPCRA), sections 311 and 312.

Section 311 of EPCRA requires facilities to submit a SDS or a list of hazardous chemicals grouped by categories of physical and health hazards. Section 312 of EPCRA requires facilities to submit an emergency and hazardous chemical inventory form yearly by March 1.

Prior to the change in 2012, the hazard communication regulations (OSHA) were performance oriented, and did not specify the language/description or format that the company had to use. Once the hazard communication regulations were updated, stakeholders requested that EPA align the wording to be consistent with the new OSHA Hazcom 2012 regulations.

Some of the changes in 40 CFR Part 370 include:

  • Technical terms have been updated (i.e., Material Safety Data Sheet to Safety Data Sheet)
  • The definition of Hazard Category has been updated
  • The “Five categories” (Fire/Sudden release of pressure/Reactive/Immediate acute and Delayed-chronic) have been changed to match the physical and health hazards outlined the Hazcom 2012
  • The Tier I and Tier II inventory forms are modified
  • Tier 2 Submit, the software will be updated, and EPA is providing flexibility for states to modify their software by January 2018

Look for these changes to be found in Section 15 of your Safety Data Sheets in the near future.

Contact ICC Compliance Center for more information, or if you need help updating your SDSs.

Single Packaging
Change Notice: BX-19SP & BX-21SP

In an effort to continuously improve the quality and performance of our UN packaging, we occasionally must make changes to the specifications and usage instructions. This notice is to inform you that the following changes have been made to BX-19SP and BX-21SP.

  1. The clear tape required for closure of this packaging has changed from 3M #305 48mm wide clear tape to 3M #375 48mm wide clear tape. This change to a stronger tape caused the box to perform better in drop tests, resulting in a more secure packaging.

BX-19SP – USA

BX-19SP – Canada

BX-21SP

If you have any questions or concerns, please contact our customer relations center in the US at 888-442-9628 or in Canada at 888-977-4834.

Thank you,
Karrie Ishmael
Regulatory Manager

OSHA Safety
What to do When the Inspector Comes Knocking

Is anyone really ready for a surprise visit from a hazmat inspector? The quick answer is no, but there are things that you can do to prepare in anticipation of a visit.

Federal law requires that you allow an inspector access to records, property, reports, and other information relevant to shipping hazardous materials/dangerous goods. Unlike the crime show Law and Order, a search warrant is not required; you may not deny an inspector access to a regulated facility, impose conditions on the entry, or limit the inspector’s right to gather information or evidence.

Inspector’s will visit for a variety of reasons, but often include:

  • Complaints
  • Observations
  • High-risk commodities (explosives, bulk shipments)
  • Incidents
  • Prior issues
  • Proximity to another company being inspected

Preparing for the inevitable

  • Develop a plan and designate staff with defined roles
  • Ensure the designate knows what to say, and when to seek assistance from upper management
  • Conduct internal audits and institute corrective actions
  • Have commonly requested items in a centralized location

What are commonly request documents?

  • List of hazmat employees
  • Employee training records
  • Shipping papers
  • Standard operating procedures (SOPs)
  • Special permits and interpretations

What do you do when it is show time?

  • Ask the inspector to identify him/herself and the purpose of the visit
  • Escort them to a quiet area where they can review documents
  • Do not volunteer information, wait for them to ask
  • Be polite, courteous and helpful. Never become rude or argumentative
  • Take notes on what is discussed and who is spoken to
  • Explain company polices (i.e., they must take brief safety training before entering the facility, they must wear safety glasses in a specific area, the supervisor must be present when…)
  • Document the inspector’s information and get a business card, if available
  • Do NOT sign anything except the Exit Brief

The Exit Brief

The Exit Brief will document the visit and any infractions that were found. Signing this document is not an admission of guilt, but rather acknowledging receipt of the document.

Most common violations

  • Failure to train
  • Improper training recordkeeping
  • Undeclared shipments
  • Improper packaging
  • Improper closures
  • Improper testing
  • Labels and marks not properly applied
  • Unauthorized Emergency Response number

After the inspection

  • Follow up with information/documents that may have been requested
  • Verify the probable violation, and take corrective actions
  • Document any actions and/or training
  • Seek assistance by industry experts on areas that you may not understand
  • Reply within timeframes indicated on the documents received
  • Ask for an extension when needed

Being prepared for the inspector before they arrive will save time, cost, and frustration. Always do your best to comply with the regulations, and revisit internal procedures regularly to ensure they are being followed. Ensure that you stay up-to-date with the changes in the regulations, and ensure all employees are trained accordingly.


Need help? Ask us about our auditing and training services. We can help ensure you and your employees are prepared just in case the inspector comes knocking.

Lockout Tagout
What Does Oct 17, 2016 Mean to You?

October 17, 2017 is the deadline for Transport Canada’s Air Cargo Security (ACS) Program.

What is the ASC program?

It is a cargo security program that:

  • meets the highest aviation security standards;
  • reduces risks to the safety and security of the travelling public; and
  • keeps goods moving in and out of Canada efficiently.

Business must apply to participate in the program in order to screen, store, transport, tender or accept secured air cargo.

Companies must choose a category that best suits their role in the supply chain. These categories include:

  • Known Consignor – originates air cargo that has been made secure through a screening process applied at the time of packing.
  • Certified Agent – stores, transports and/or accepts cargo that an authorized Air Cargo Security Program participant has screened and made secure.
  • Regulated Agent – screens cargo on behalf of others to make it secure and subsequently stores and/or transports the secure cargo.
  • Account Consignor – originates cargo and has it screened by an authorized participant in the Air Cargo Security Program to make it secure.
  • Authorized Cargo Administrator – directs the movement of secure cargo without coming into contact with it (i.e., provides logistics services without screening, storing and/or transporting the secure cargo).

Participants must submit an application to Transport Canada which will be vetted, followed by an inspection and ongoing oversight.

It should be noted that this program is completely voluntary.

Initially, the program will be for passenger freight only, but is expected to expand to cargo freight in 2017/2018.

Starting on October 17, 2016, shippers should expect delays with passenger aircraft shipments. “Overnight” shipments may not be delivered the next day.

ICC Compliance Center is your source for supplies relating to air cargo security including security signs, security seals and tamper evident tape.