Safety
National Forklift Safety Day – June 13

Forklift

Forklift Safety

There’s an old joke out there about what happens when you play a country song backwards. According to the joke you get your girl, dog, and truck back. Rascal Flatts even did a song about it. It is a pretty good tune. Take a listen here.

So, how does a song about getting a truck back relate to forklifts and forklift safety? Well, by definition a forklift is a powered industrial truck. Since the joke and song talks about trucks you can see the connection. Forklifts are used to lift, move, and place various materials weighing anywhere from a few thousand pounds up to 90 tons. These powered industrial trucks must comply with OSHA standard 29CFR 1910.178. You can access a copy of the standard at this link.

National Forklift Safety Day

In 2016, accidents and incidents involving powered industrial trucks were listed in the top ten OSHA violations. To stress the safe use of the vehicles, need for operator training, education of non-users the Industrial Truck Association (ITA) has set aside Tuesday, June 13 as National Forklift Safety Day. This is the fourth year for such an event. Having a written standard, good safety policies and regulations surrounding the safe use of these machines isn’t enough. It requires every day awareness and commitment from drivers, managers, and other personnel in the areas with these trucks to stay safe.

If you are in the Washington, DC area check out the free activities ITA has planned.

  • Monday, June 12 from 3 to 5 p.m.: Education session for ITA members and invited quests
  • Tuesday, June 13 morning: Speakers from industry and government, including elected officials
  • Tuesday, June 13 afternoon: ITA members will visit their congressional representatives to convey our message about the critical importance of workplace safety and discuss how elected officials can help to support that

For information regarding your area, contact your local forklift dealer. 

A few ideas from other locations include the following:

  • Safety pledge signings
  • Open houses and plant tours
  • Safety demonstrations / Safety Awareness classes
  • “Train the Trainer” classes
  • Operator training sessions

If there is any way ICC Compliance Center can help make your National Forklift Safety Day a success, contact us. We are here to help.

PHMSA Penalties Increase

Chemical Drums Disposal

Enforcement of Hazardous Materials Program Procedures

Many have heard the phrase, “money makes the world go around”. The phrase was made popular by the stage and film show “Cabaret”. In fact, that phrase is the name of one of the songs in the show. For a snippet of the song featuring Liza Minnelli, listen here.

What does this phrase have to do with the US transport regulations you may ask? It comes down to a particular section of 49 CFR. In Subpart D of Part 107 Hazardous Materials Program Procedures is a section entitled “Enforcement”. Within that subpart are the possible penalties a company could be assessed for violations to the requirements of 49 CFR. In particular, take a look at Sections §107.329 regarding the maximum civil penalties which could be assessed to a company.

Maximum Penalties Increase

Here’s where things get tricky. Anyone working with these regulations is familiar with the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015.  Quite a mouthful, I know. This act basically requires federal agencies to adjust civil penalties each year to account for inflation. The Pipeline and Hazardous Materials Safety Administration (PHMSA) is a federal agency. As such, on April 19, 2017, those penalties increased. Per the announcement:

The maximum civil penalty for a knowing violation is now $78,376, except that the maximum civil penalty is $182,877 for a violation that results in death, serious illness, or severe injury to any person or substantial destruction of property.

Also, there was an increase to the minimum penalty for violations related to training. The new value is now $471. To see the full ruling in PDF form, go here. These new penalties are effective immediately.

Why is this tricky? If you have the hardbound/paper copy of the regulations published in March of 2017 – it won’t have these increased penalties in it. If you use the electronic Code of Federal Regulations the changes are there.

So, take note! Things change fast in this world and you have to stay aware. For help with all of your regulatory needs including training contact ICC Compliance Center today.

Safety
OSHA Safe + Sound Week

Safe + Sound Week 2017

Safe + Sound Week is June 12 – 18

Back in the 14th century, sailing ships were a primary means of trading goods. To protect goods on these vessels they were insured against loss or damage.  The best news for the insurance companies was to receive word that the ship had returned “safe and sound”. The word “safe” was an indication of all crew members were accounted for without injury. The word “sound” told the company the ship had not suffered any serious damage. Since then we continue to use the phrase in our daily life.

The week of June 12-18 has been designated as the inaugural Nationwide Safe + Sound Week. The week is presented by Occupational Safety and Health Administration (OSHA), National Safety Council, American Industrial Hygiene Association (AIHA), American Society of Safety Engineers, the National Institute for Occupational Safety and Health just to name a few. The goal is to “raise awareness and understanding of the value of safety and health programs”. All businesses and companies are encouraged to participate.

The focus of the week is on three core elements. It covers management leadership, worker participation and find and fix hazards. Here is a brief overview of each taken from the OSHA website.

Core Elements:

  • Management leadership is a demonstrated commitment at the highest levels of an organization to safety and health. It means that business owners, executives, managers, and supervisors make safety and health a core organizational value, establish goals, provide resources, and set a good example. Because managers and workers take their cues from leadership, it’s important that all leaders throughout an organization show a visible commitment to safety and health.
  • Worker participation is meaningfully engaging workers at all levels in establishing, implementing, evaluating, and improving safety and health in the workplace. This means workers understand they are a valuable partner in making their workplace safer and are encouraged and able to communicate with management about hazards on the job. Workers are the experts when it comes to the tasks they do and the tools and equipment they use, which makes them a key resource for knowledge and innovative ideas that can improve safety and health.
  • Finding and fixing hazards is a proactive, ongoing process to identify and control sources of potential injuries or illnesses. This means establishing {systemic} procedures to collect and review information about known or potential hazards in the workplace, investigating the root cause of those hazards, and prioritizing hazard controls. Identifying and correcting these hazards before someone gets hurt ensures that workers go home to their families safe and sound after every shift.

Participate in Safe + Sound Week

To prepare your location to participate in the week it is a simple process.

  1. Step 1:  Select or plan activities under each of the elements shown above.
  2. Step 2:  Plan and promote your events
  3. Step 3:  Recognize participation. The website (here) under each element lists a few activities. You just have to click on each topic and decide.

Make the effort to make this week a success for your company. Good business involves keeping workers safe. Use this week to bring new life to your existing safety and health programs or get yours started. If there is anything ICC Compliance Center can do for you to help keep your workers safe, give us a call today.

Airplane Icon
FAA Short Audit Answers

Cargo loading on aircraft

Common Errors When Shipping by Air

At a recent training, the group hosting invited someone from the Federal Aviation Administration (FAA) to come and speak. Throughout the brief discussion, the speaker mentioned things she sees most often while doing site audits. Listed below are a few of the main items. See if you can guess what the officer sees during audits that is not accurate.

  1. Retention of Shipping Papers: In IATA, the retention of documentation is found in Section 8.0.2.2. According to this section the declaration of dangerous goods “must” be maintained for a minimum of 3 months. There are no state or operator variations attached to this section which may be why people get caught. In United States’ variation USG-01 it clearly tells shippers the document must be maintained by not less than 2 years.
    • Error Found: Only 3 months’ worth of documentation can be produced during an audit.
  2. Use of Technical Names: Entries in the blue pages listed with a star (*) symbol tells the shipper a technical name is needed.  Section 4.1.2.1(d) outlines how to determine the name, the number or names, and the type of names allowed. “The technical name must be a recognized chemical or biological name or other name currently used in scientific and technical handbooks, texts and journals. Trade names must not be used.
    • Error Found: The trade name or retail name is listed on the packages and shipping papers.
  3. Classification: The same 9 hazard classes are used in all transport regulations. The classification of materials into those hazard classes is also the same. However, there are some items that are country specific.
    • Error Found: The shipper tried to put an ORM-D package on an air shipment.
    • Error Found: A shipper packaged, marked and labeled a bulk package as Combustible under the DOT regulations and then attempted to send it via air where it is not regulated.
  4. Training Records: There is a very clear listing of what records of training should include. This information is in Section 1.5.5. It includes the employee’s name, the completion month, the name and address of the organization providing the training and some evidence that a test was completed satisfactorily.
    • Error Found: The certificate shown to the auditor had no indication of being tested.
    • Error Found: There was no address for the training organization.
  5. Emergency Response Phone Number: Another country specific requirement found in the state variations for the US is specifics for the emergency response telephone number. In USG-12 is the statement, “… the number must be monitored at all times… .”
    • Error Found: The emergency response number was disconnected and no longer in service.

These are just a few of the incidents noticed by the FAA inspector. The speaker mentioned her team does checks at all times of the day and night. This is not to “catch” you but to ensure hazardous materials/dangerous goods are being properly handled for transport. Interestingly enough, if your site completes a DOT Form 5800.1, a visit from the FAA is likely.

The point is, review your location and process. Just because you haven’t had a visit in a while or had a package refused doesn’t mean you are in the clear. ICC Compliance Centers offers a variety of auditing services. Contact us today to see how we can help you prepare for your next “visit” from the FAA.

OSHA Safety
Compliance Language

Current Dangerous Goods Regulations

Terminology in Regulatory Manuals

Language, as defined by the Merriam-Webster dictionary, is the formal system of words or signs that people use to express thoughts and feelings. Learning a new language is often a complex undertaking. It is also a time that lends itself to funny stories. While living in Austria for a few years taking German lessons was part of our visa process. We were encouraged to practice often. On one of my first attempts was to buy a certain pretzel. Somehow my request came out as asking for the “slow one” rather than the “long one”. My husband told a co-worker he “believed” he was a pencil. While neither request caused harm, it was confusing to the German speakers who heard us. I mention this because the language of transport regulations can be confusing as well until you have a good handle on the language used in them.

Let’s take a look at two simple words. We will compare their “everyday” usage with how they are used for transporting hazardous materials or dangerous goods. The two words will be “should” and “may”.

Word #1: Should

In normal usage, this word indicates certain obligations or expectations. Take for example the statement, “John should be ready by now.” By using the word “should” in the sentence, the expectation is that John is ready or prepared for whatever situation he finds himself. In transport, this word takes on some slightly different meanings depending on the regulation.

  • 49 CFR – US Ground: Per 171.9, the word “should” is used in a recommendatory sense. Meaning the shipper is not required to do what is listed in the regulation. It is encouraged or recommended, but it is not enforceable.
  • International Air Transport Association (IATA): Per Section 1.3.1.3, the word “should” is a preferred requirement. This means the section is not binding for a shipper, but there is a suggestion to follow whatever is listed.
  • International Maritime Dangerous Goods Code (IMDG): It is in the Forward that we find this definition. For “should” again the word is used in a recommendatory sense. Items in the Code with this word are not required, only recommended.
  • Transportation of Dangerous Goods (TDG) – Canada Ground: Oddly enough, this term is not defined in Section 1.3 of the regulations.

Word #2: May

This word is used for possibilities or options even permission when used in daily language. An example here is the statement, “John may be ready by now.” In this case, the statement conveys the possibility that John might be ready, but again there is the option that he is not. Again, for transport, there are different meanings.

  • 49 CFR – US Ground: Per 171.9, the word “may” is used in a permissive sense. Meaning the shipper is not required to do what is listed in the regulation.  The item is simply allowed or permitted.
  • International Air Transport Association (IATA): Per Section 1.3.1.3, the word “may” is listed as a preferred requirement and not binding for a shipper. Again, as a preferred requirement there is the suggestion to follow whatever is listed but no requirement to do so.
  • International Maritime Dangerous Goods Code (IMDG): Again it is in the Forward that we find “may”. Here “may” is used to indicate optional provisions. Items in the Code with this word have no preferred or recommended parts. The shipper can choose to either do what is listed or not.
  • Transportation of Dangerous Goods (TDG) – Canada Ground: In Section 1.3, the word “may” is listed as permissive. This aligns with the US Ground requirements and indicates things that are allowed or permitted.

Be sure to know the language of the regulation you are following before attempting to make a shipment of a dangerous goods or hazardous materials using it. You may be “believing” something that is not actually true or required by the regulation. For all of your transport needs, contact ICC Compliance Center today.

Placarding
Correct Usage of a Dangerous Placard?

Placards on a truck

An Interesting Combination

A recent training class took me to Iowa. Since it is so close to me, I decided to drive there rather than play the airport game. During the drive an old favorite song of mine came on the radio. The song is by Don Henley and called “The Boys of Summer”. In that song is the following lyric: “Out on the road today / I saw a Deadhead sticker on a Cadillac / A little voice inside my head said / “Don’t look back, you can never look back.” Take a listen:

What’s funny is shortly after hearing that song I passed an 18-wheeler truck. On the back and side of the truck was a “Dangerous” placard and a “Class 5.2” placard. A picture of each is shown here. In a very simplistic sense, placards are big hazard labels, roughly 9.84 inches on each side. They are placed on vehicles to warn people about the hazardous materials on or in that vehicle.

Hazard Class 5.2 Placard
Hazard Class 5.2 Placard
Dangerous Placard
Dangerous Placard

The 49 CFR has some unique rules for placarding, but what was on that truck struck me as interesting. I’ve never seen those things together before.  It is usually 1 or the other. Being a safety nerd I checked my regulations when settled in my hotel room. Placarding information is found in Section 172.500 of the 49 CFR. Here are some specifics for placarding vehicles.

Basic Rules of Placarding:

  1. All bulk packagings or vehicles transporting bulk packagings must be placarded on each side and end.
  2. For non-bulk packages, there are two tables to consult. Both can be found in 172.504.
  • If your material is a hazard class listed on Table 1, then it must be placarded following the same rule as bulk packagings.
  • If your package is a hazard class listed on Table 2, the rules are different. You only have to placard for the hazards on Table 2 when the vehicle contains more than 1001 pounds aggregate gross weight of materials on that table.

Table 1

Category of material (Hazard class or division number and additional description as appropriate) Placard name Placard design section reference §
1.1 EXPLOSIVES 1.1 172.522
1.2 EXPLOSIVES 1.2 172.522
1.3 EXPLOSIVES 1.3 172.522
2.3 POISON GAS 172.540
4.3 DANGEROUS WHEN WET 172.548
5.2 (Organic peroxide, Type B, liquid or solid, temperature controlled) ORGANIC PEROXIDE 172.552
6.1 (material poisonous by inhalation (see §171.8 of this subchapter)) POISON INHALATION HAZARD 172.555
7 (Radioactive Yellow III label only) RADIOACTIVE1 172.556

Table 2

Category of material (Hazard class or division number and additional description as appropriate) Placard name Placard design section reference §
1.4 EXPLOSIVE 1.4 172.523
1.5 EXPLOSIVE 1.5 172.524
1.6 EXPLOSIVE 1.6 172.525
2.1 FLAMMABLE GAS 172.532
2.2 NON-FLAMMABLE GAS 172.528
3 FLAMMABLE 172.542
Combustible Liquid COMBUSTIBLE 172.544
4.1 FLAMMABLE SOLID 172.546
4.2 SPONTANEOUSLY COMBUSTIBLE 172.547
5.1 OXIDIZER 172.550
5.2 (Other than organic peroxide, Type B, liquid or solid, temperature controlled) ORGANIC PEROXIDE 172.552
6.1 (other than material poisonous by inhalation) POISON 172.554
6.2 (None)  
8 CORROSIVE 172.558
9 Class 9 (see §172.504(f)(9)) 172.560
ORM-D (None)  

Here is an example of how Table 2 works. A truck has 4.1 Flammable Solids and 4.2 Spontaneously Combustible materials in non-bulk packages on it.  Together those materials add to over 1001 pounds. You would have to use placards on both sides and ends for both Class 4.1 and 4.2.

Using the Dangerous Placard:

In 172.504(b) the Dangerous placard is discussed. A transport vehicle hauling non-bulk packages with two or more categories listed on Table 2 may be placarded with a DANGEROUS placard instead of the separate placarding specified for each of the materials in Table 2. So, using the previous example, instead of using 4.1 and 4.2 placards, you can replace them with the single Dangerous placard. This saves space on the trucks and money because fewer placards are required. The drawback is the loss of clarity of the hazards in the vehicle.

Why Are Dangerous and Class 5.2 Placards Being Used?

Let’s go back to the truck I passed. It had both a Dangerous placard and a Class 5.2 placard. Is this correct? By following the rules above we can reason out the following. There is a container of Class 5.2 material on the truck. It doesn’t matter what size the package is because either rule requires Class 5.2 materials to be placarded. It could be a bulk package which would follow the basic rule. It could also be a non-bulk package. Since Class 5.2 is on Table 1 a placard would still be needed. Note, the Dangerous placard cannot be used for bulk packages or Table 1 materials. That means the Dangerous placard is there for another reason. There must be some combination of materials from Table 2 whose total weight exceeds the 1001-pound cutoff. Again, following the rules, this is the only reason why that placard would be there. While this isn’t the most helpful information, at least we have an idea of just how hazardous the load is.

For all of your placarding needs call ICC Compliance Center today.

Lithium
Lithium Batteries Section 1B & IATA Shipper’s Declaration

Lithium Batteries, Laptop battery

Lithium Batteries on IATA Shipper’s Declaration

One of my favorite cartoons growing up was “Scooby Doo”. Nothing made me laugh more than when Scooby would say, “Ruh roh, Raggy” when he was trying to say, “Uh oh, Shaggy”. This was usually in situations where things had gone terribly wrong. I had one of those moments recently and it was in regards to lithium batteries.

In one of my recent training classes, we were digging into the IATA Shipper’s Declaration and how to complete it. Anyone that handles these knows there are lots of things to include. As the discussion moved to the “Nature and Quantity of Goods” section, we were cruising. Everyone understood the process and how great IATA is about explaining what goes where. The examples in Chapter 8 are awesome!

The “Ruh roh” moment came as we were discussing the inclusion of the Packing Instruction number. Most of us are familiar with the first part of that step. It tells us that for all of our shipments, we add the number of the Packing Instruction we followed for said shipment. In Section 8.1.6.9.3 of IATA, it says the following:

Step 8. Number of Packing Instruction or Limited Quantity Packing Instruction (with its “Y” prefix) (Columns G, I or K). For lithium batteries prepared in accordance with Section IB of Packing Instruction 965 or Packing Instruction 968 the letters “IB” must be added following the packing instruction number.

And I would have gotten away with it too, if it weren’t for you meddling kids… (Not Really)

What I failed to read was the rest of the paragraph. It clearly states that for shipments of lithium batteries prepared under Section 1B, you have to include the letters “IB” after the Packing Instruction number. There is even an additional note in this section. It says if you can’t fit the letters “IB” in the column with the Packing Instruction number that it is ok to put it in the authorizations column.

This information is not found in the Packing Instructions themselves. Neither PI965 nor PI968 mention of this requirement to include the letters “IB” on the declarations.

Needless to say, after class that day I made a note to update all of our training materials on batteries to include this information.

For all of your lithium battery needs, contact ICC Compliance Center today. We have updated classes for both webinars and public courses, new handling marks, and new class 9 labels ready for you.

Lithium
Lithium Battery Worlds Collide

One of my favorite episodes of the show Seinfeld is the one where worlds collide. In the episode Elaine asks George’s girlfriend Susan to a show. On the surface this seems harmless. According to Kramer, this is a bad thing because when George’s “sanctuary world” and his “girlfriend world” collide there will be an explosion.

I had a case of my worlds colliding over the holidays. Let’s see what the results were. The attached pictures are from a leaf blower my husband received as a Christmas gift. It is a nice gift that will help us with yard work in the future. The description on the box says it comes with a charger for the included 40 volt, 2.0 ampere-hour rechargeable lithium-ion battery. On the back was the Lithium battery handling information. I didn’t pay much attention to it due to being in a cookie coma from the holidays.

Lithium battery label on box

Upon arrival home and while unloading the car, my husband noticed the information on the box and pointed it out to me. He then asks, “Should this be on here?” Needless to say, once we were fully unpacked I grabbed my regulations just to see.

Using the information on the box let’s review some points for shipping Lithium-ion batteries. Bear in mind this was purchased at a store where it was on the shelf. I have no way of knowing if it was shipped in this box.

  • Step 1: Is this lithium-ion battery is “contained in equipment” or “packed with equipment”?
    • Answer: The battery was not inserted into the blower but in a separate box beside it. This means it would have been “packed with equipment”.
  • Step 2: What is the watt-hour rating?
    • Answer: This was easy enough since the box said the battery had a 2 ampere-hour capacity and a voltage of 40 volts.  Using the following formula:

Watt-hours = Ah (ampere-hours) x V (voltage)
Watt-hours = 2 Ah.  X 40 volts
Watt=hours = 80 watt-hours

  • Step 3: What would be the proper identification number, shipping name, hazard class, and packing group (ISHP) if this had been shipped?
    • Answer: Since the manufacturer is within the US, I looked at the US ground regulations, 49 CFR. It is a Lithium-ion battery that was packed with equipment. Using the Hazardous Materials Table (HMT) that tells me the proper ISHP would be UN3481 // Lithium-ion batteries packed with equipment // Class 9 // no packing group.
  • Step 4: What sort of packaging requirements are there?
    • Answer: Again the HMT gave me that information in column 8. Luckily for UN3481 the packaging information is all found in Section 173.185. The only Special Provisions listed in the table are for air shipments. Much of this section didn’t apply to my query because I wasn’t shipping this. However, this section is also where all of the marking, labelling, exceptions/exemptions and hazard communication information is found.
  • Step 5: Where does the leaf blower fit and why was that particular safety information used?
    • Answer: This goes back to the information from Step 2. The watt-hour rating of 80 put me into Section 173.185(c) for exceptions. In that section is where the hazard communication information is found. In that was the proof I needed to say, “It is ok for this information to be on this box.” The box only has 1 lithium battery and the box is using the “handling marking” shown in paragraph (c)(3)(ii). The regulation says the following:

(3) Hazard communication. Except for a package containing button cell batteries installed in equipment (including circuit boards), or no more than four lithium cells or two lithium batteries installed in the equipment:

(i) For transportation by highway, rail and vessel, the outer package must be marked with the information in the following paragraphs (c)(3)(i)(A) to (D), or the handling marking in paragraph (c)(3)(ii) of this section:

(A) An indication that the package contains “Lithium metal” and/or “Lithium ion” cells or batteries, as appropriate, or alternatively, the word “batteries” may be used for packages containing cells;

(B) An indication that the package is to be handled with care and that a flammable hazard exists if the package is damaged;

(C) An indication that special procedures must be followed in the event the package is damaged, to include inspection and repacking if necessary;

(D) A telephone number for additional information.

(ii) For transportation by air, the outer package must be marked with the following handling marking, which is durable, legible, and displayed on a background of contrasting color:

Old lithium battery label

So there it is the results of my worlds colliding. There were no explosions, tidal waves, or earthquakes. There were no deaths from licking cheap envelopes, which is a reference to Susan’s fate. It was just an exercise of taking ICC Compliance Center’s “7 Steps to Compliance” idea and making them work for me. Of course, my head may explode when HM215-N is finalized and the information in this section of 49 CFR changes.

As always, ICC Compliance Center is here for all of your hazard communication and lithium battery needs. Call us today for lithium battery training, new class 9 labels or new handling marks, and new lithium battery shipping materials. We have it all.

Services
Inspector Issue

Gaining Regulatory Knowledge

Many of us have heard the phrase, “a little knowledge is a dangerous thing” at some point in conversation with people. What’s interesting is the phrase was originally “A little learning is a dangerous thing“. It comes from Alexander Pope’s poem called “An Essay on Criticism“. This phase can be applicable when you work in an area with ever-changing regulations. The key is to get more knowledge.

A prime example can be found in a September 2016 newsletter from Responsible Distribution Canada (RDC). This group was formerly called the Canadian Association of Chemical Distributors. In Volume 6 Issue 37 is the headline “Issue being reported with some WHMIS 2015 Inspectors RE: MSDS vs SDS“. In the article, RDC was contacted by a paint manufacturer. The manufacturer indicated that a Health Canada inspector was on the job site causing problems. At issue is the following:

“The HC inspector apparently said the paint manufacturer’s MSDS sheet was not acceptable because a “Safety Data Sheet” should now be supplied instead of a “Material Safety Data Sheet”. The inspector added that this change became effective in 2015 and said that the word “Material” should not be mentioned on the technical sheets.”

According to the manufacturer they have yet to convert to WHMIS 2015. In this case it is the inspector in error and a classic case of a little knowledge being dangerous.

Why?

Let’s discuss why. Canada aligned the Workplace Hazardous Materials Information System (WHMIS) with the Globally Harmonized System of Classification and Labelling of Chemicals (GHS) in February 2015. This is why it is called WHMIS 2015. A part of the new regulation is to move from using the term “material safety data sheets” to just “safety data sheets”. There is a multi-year transition plan or phase in period in place before the new regulation goes into full effect. Here is where the inspector gets in trouble. It is during Phase 1 of the phase in plan that the terminology shifts. The dates for Phase 1 are February 11, 2015 to May 31, 2017. Since the paint manufacturer has yet to convert to WHMIS 2015, they still have time as allowed under Phase 1. They are in the right.

The inspector is aware of the changes in WHMIS 2015 which is great but also qualifies as a “little bit of learning”. Where he is “dangerous” is the fact that he was not aware of the time periods involved with the phase in of the new regulations. He was trying to force a regulatory change that is not yet mandatory. Had the inspector been more familiar with the new regulations this issue would not have happened.

Another part of Pope’s poem is the phrase, “To err is human, to forgive divine“. While this is a lovely sentiment, in the world of business and compliance it just isn’t possible. For a link to the complete RDC newsletter, click here.

Don’t be a “danger” to your business. Get trained beyond “a little bit of learning”. ICC Compliance Center offers a full range of courses including WHMIS 2015. Call us today for compliance audits and the multiple courses and learning platforms we offer.

Environmental Update
Chemical Spill Cooperation

Atchison, Kansas Chemical Spill

A little less than a month ago a small town near Kansas City, Kansas got a nasty surprise. According to local news reports a chemical spill at MGP Ingredients in Atchison caused quite stir around 8:00 in the morning.

The Kansas City Star reported the spill resulted in a mixing of Sodium Hypochlorite and Sulfuric Acid. The reaction of the two chemicals created a thick fog that covered much of downtown and areas north and west of there. Several areas were told to evacuate while others were told to “shelter in place” with doors and windows shut. Click here to view a video taken by drone of the chemical plume. By 11:00 am officials reported the spill under control and people were allowed back into their homes and business. The Environmental Protection Agency (EPA) sent personnel to assist in the investigation.

Thanks to a good communication between MPG Ingredients, the City of Atchison and the local Fire/Emergency crews there were no serious injuries reported. Those caught in the fog, roughly 34 townspeople, had respiratory issues including coughing and difficulty breathing. At the time the article was written, there was no word on the number of affected MGP employees.

The key take away from this story is the communication element. It took less than 3 hours for this spill to be handled and for folks to be safely back at home, school or work. If MGP Ingredients had not reported the spill promptly, then the number of injuries would be higher. If local officials had not responded as quickly as they did by using the radio and social media, then the number of injuries would be much higher. If the local fire crew had not known what was needed to help the fog dissipate, then the number of injuries would be much higher.

There are always those that complain about updating hazard communication plans, workplace labels, safety data sheets, and evacuation plans. For those my response is simple. Here is the reason we do this. Here is why they are needed. Given the scope of the cloud and the area it covered, consider how many people were at risk. Had things been handled differently a much worse outcome is a definite.

As always, ICC Compliance Center is here to help you with all of your regulatory needs. For more information on our supplies and services visit our website: http://www.thecompliancecenter.com.