SOP! Yeah, You Know Me!

SOPs have always been part of my working life. Do you know what a SOP is? SOP refers to a Standard Operating Procedure. It is a written step-by-step procedure used in many facets of business to describe the process in order to complete the tasks involved. SOPs are found throughout many work environments from the office to manufacturing. They are always being changed based on modifications to the task, to help increase efficiency, and to improve processes.

When there is a lack of SOPs in place it can lead to confusion in the process(es) leaving more room for error. This can also lead to slow or delayed response times. This is just what the DOT has experienced with the process for approving special permits. This had led them to update the 49 CFR establishing an improved standard for the approval of special permits. This will be effective November 9, 2015 under a final rule of HM-233E.

Have you ever submitted documentation to apply for a special permit through the DOT? If you have, you know that the changes in the final rule were needed.

I needed help, and like many of you, probably never had submitted an application before. It was evident from the beginning that this process needed some TLC. Multiple calls were needed before, during and after the request was submitted, tracking numbers were not available and Continue Reading…

OSHA Safety
Inspection Directive for Compliance Officers for the Hazcom Standard

OSHA released a directive, CLP-02-02-079, it is to give guidance to compliance officers when enforcing the Hazard Communication standard (HCS 2012).

These instructions establish policies and procedures to assist Compliance Safety and Health Officers (CSHO) on how to ensure consistent enforcement of the HCS. It outlines the standard to encompass the revised hazard classification of chemicals, standardizing label elements for containers of hazardous chemicals, and the specified format and required sections for safety data sheets (SDS). It explains how the revised standard is to be enforced during its transition period and after the standard is fully implemented on June 1, 2016.

It should be noted that this instruction is a Federal Program change and State Plans are required to establish enforcement policies and procedures which are at least as effective. State plans will have up to 60 days to submit a notice of intent stating if their State Plan will adopt or already has in place inspection procedures that are identical to or different from the federal program. State adoption of said plans should be accomplished within 6 months.

The contents of the CLP-02-02-079 breaks down the HCS 1910.1200 and its individual sections. As OSHA goes through each section they provide examples for the officers to help give clarity for certain situations. When reading through this document, I found that it actually cleared up some gray area for me Continue Reading…

OSHA Safety
Stand-Down for What?

Updated injury and incident reports from OSHA

From Jan 1 to Dec 31, 2014 there were 5589 ladder incidents reported that have resulted in injury and even death according to OSHA. 14 incidents additionally reported for ladder hooks, 90 more for ladder jack scaffold and another 8840 incidents including death under fall protection. These numbers really just scratch the surface. There are many incidents that appear under other categories that involve ladders and falls. Fall incidents within the past month are presented in the table below. More information is available on OSHA’s website (http://www.osha.gov).

Date of Incident Preliminary Description of Incident Fatality or Catastrophe Inspection #
3/3/2015 Worker cleaning window killed in fall. Fatality 1044021
3/2/2015 Worker killed in fall through gap between jet and jet bridge. Fatality N/a
2/25/2015 Worker on stilts hanging drywall killed in fall. Fatality 1043899
2/24/2015 Worker killed in fall from manlift. Fatality 1042122
2/24/2015 Worker welding on steel decking killed in fall. Fatality 1042893
2/23/2015 Worker killed in fall on portable stairs. Fatality 102416049
2/22/2015 Worker on snow-covered roof killed in fall through skylight. Fatality 1042748
2/21/2015 Worker died after falling on showroom floor. Fatality 1042262
2/19/2015 Worker killed in fall from top of boat. Fatality 1041497
2/18/2015 Worker killed in fall from roof. Fatality 963192
2/18/2015 Worker killed in fall from flatbed trailer. Fatality 100367473
2/18/2015 Worker on roof killed in fall through skylight. Fatality 1041220
2/17/2015 Worker slipped and suffered fatal fall on ice. Fatality 1041590
2/17/2015 Worker clearing power lines from tree killed in fall from bucket lift. Fatality 1040571
2/16/2015 Worker fatally engulfed by gravel after falling into silo during cleaning operations. Fatality 1041096
2/12/2015 Worker killed in fall from ladder. Fatality N/a
2/12/2015 Worker killed in fall from ladder. Fatality N/a
2/10/2015 Worker killed in fall from steel structure. Fatality 1040413
2/10/2015 Worker killed in fall from Continue Reading…
Transport Canada Correction & Clarification

Hot off the press:
Expected ERAP Rail Tanker Correction

As expected, the Dec. 31/14 TDG amendment was corrected in today’s Canada Gazette II to specify that rail ERAP requirements apply to rail tank cars only.*

You can read the correction here:
http://www.gazette.gc.ca/rp-pr/p2/2015/2015-01-28/html/erratum-eng.php

No signature- clarification

Also the FAQ section of the TDG website has been revised to clarify that July’s addition of Consignor’s Certification (TDGR 3.6.1, mandatory July 1, 2015) does not require an actual signature (see answer to the second question under “Documentation…). **

http://www.tc.gc.ca/eng/tdg/faq-319.htm#a4_0

*We still expect an amendment to clarify the intent regarding inapplicability to road transport-see author’s Blog of January 13th:
http://regulatory.blog/2015/01/13/tdg-more-on-sor2014-306/

** Ironically what took the Author a few hundred words or so to “unofficially interpret” in a Blog last October, was accomplished by Transport Canada in the phrase “…(not signature)…” in the FAQ!

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Transport Canada Proposes Passenger Aircraft Cargo Security Enhancements

New proposal to increase aircraft cargo security

Transport Canada has, in an effort to improve safety on passenger aircraft, proposed additions to the Canadian Aviation Security Regulations under Part 4.85 of the Aeronautics Act to streamline screening of cargo for “threat items” (Canada Gazette Part I, November 1, 2014). Threat items include “any … good that could pose a threat to aviation security” in addition to explosives, incendiary devices and their components, when shipped as cargo without being documented on a waybill, shipper’s declaration, etc. Presumably dangerous goods would be prime candidates for threat items.

As well as the addition of “threat items” to the section 3 definitions, the new Part 11 on “Air Cargo” includes the proposed detailed provisions for the improved security programs in new sections 668 to 686.

These changes would provide for “known consignors” (shippers) &/or “certified agents” (cargo/warehouse/trucking third parties), to undertake formal security activities in screening or maintaining the chain of custody of cargo destined for transport on passenger aircraft. This would supplement the current program activities undertaken by the air carrier or regulated agent (approved participant).

Participation in the program by shippers (to facilitate efficient shipment) and agents (as a value-added service) will be voluntary, but those who choose to do so will be held to the stringent prescribed requirements under penalties that will range from $3000 to $5000 for individuals and $10000-$25000 Continue Reading…

TDGR Amendment 12 – Expected July 2, 2014

Updated Safety Marks

Reliable sources have indicated that the December 2012 proposal to overhaul placarding and other safety markings is expected to be published in the Canada Gazette Part II on Wednesday, July 2, 2014.

This amendment is intended to improve the harmonization between the marking requirements in the Canadian TDGR (Transportation of Dangerous Goods Regulations) and the various current international (UN Recommendations, 49CFR, ICAO, and IMDG) regulations.

Significant Changes

Although not an exhaustive list, significant changes, based on the original Gazette I notice, include: introduction of defined “overpacks” and their markings, implications in the LQ (“Limited Quantity”) provisions, etc.; phasing out of the older Class 5.2, LQ, Marine Pollutant, Fumigation marks in favor of the international versions; relaxation of the need to remove safety marks while any quantity of DG remain; completely re-working the Part 4.15 placarding requirements, including severely restricting the use of the “Danger” placard (e.g. only for loads of “small means of containment”), limiting the 500 kg exemption options; allowing the use of 2 placards or 4 labels (with UN #s) on IBC (“intermediate bulk containers”) totes; adding a requirement to mark “toxic-inhalation hazard” on Special Provision 23 DG packages; and other changes.

Word has it that the amendment will take effect July 14, although (again based on the original proposal) there may be transitional provisions for some aspects.

ICC is always up to date with current workplace Continue Reading…

Ontario Ministry of Labour Initiates February Safety Blitz

The Ontario Ministry of Labour (MOL) has announced that it will be conducting a blitz program of inspections targeting Ontario workplaces, concentrating on materials handling. The blitz will last throughout the month of February.

“Materials handling” includes common actions such as lifting, setting down, carrying, pushing or pulling materials. (Note that this is not restricted to hazardous materials; materials such as brick, stone and earth would also be covered.) The main concern of the Ministry is that improper handling of materials can result in musculoskeletal disorders (MSDs). MSDs cover damage to soft tissues, such as muscles, tendons, ligaments, nerves and other parts of the body that might be strained, torn, irritated or otherwise damaged.

The stakes are high – the Ministry estimates that more than 40 per cent of Workplace Safety and Insurance Board (WSIB) claims, as well as lost time due to injuries, are caused by MSDs. Therefore, inspectors (sometimes accompanied by ergonomists) will be visiting Ontario workplaces to ensure that workers are able to minimize these risks.

The blitz will concentrate on the following types of workplaces:
• construction;
• healthcare;
• mining; and
• industrial establishments.

Typical areas that an inspector will look at include:
• Safe procedures for moving and storage of materials.
• Appropriate employee training in safe handling.
• Housekeeping in materials handling areas.
• Safety of egress and exit points.
• Ladder safety.
• Maintenance of equipment used for materials handling.

The blitz is Continue Reading…

Mexico First NAFTA Member to Adopt GHS

On June 4, 2011, Mexico became the first NAFTA member to adopt the GHS as a basis for national health and safety regulations, by proclaiming a new Mexican standard, NMX-R-019-SCFI-2011.

This standard will be based on the Purple Book (Globally Harmonized System of Classification and Labelling of Chemicals), published by the United Nations. However, unlike the changes planned for the United States and Canada, this standard is voluntary. It will allow use of the GHS to be in compliance with the existing standard NOM-018-STPS-2000, which covers classification, labeling and safety data sheets. Suppliers may, however, choose to remain in compliance with the existing standard, without updating to GHS.

Unfortunately, there has not yet been an English translation of this new standard published. Further information (in Spanish) can be found at:

http://dof.gob.mx/nota_detalle.php?codigo=5166277&fecha=04/11/2010

If you have any questions regarding this issue, please contact ICC The Compliance Center Inc at 1-888-442-9628 (USA) or 1-888-977-4834 (Canada).

Get Ready for IATA DGR 2012!

The International Air Transport Association (IATA), has recently published a summary of changes that will be seen in the 2012 edition of the IATA Dangerous Goods Regulations (DGR).
 
Some rather extensive changes to aspects such as packaging have been introduced this year in the DGR 52nd edition. The changes for the 53rd edition, that will take effect January 1, 2012 will be more limited, and are designed in most cases to refine or simplify requirements, rather than create new ones or change requirements significantly.
 
The expected changes include:
 

  • Provisions for limited quantity packaging will be consolidated in section 2.7.5, moving some information from its current location section 5.0.
  • Special provision A44 has been revised to clarify compatibility and packing group requirements for chemical and first aid kits.
  • Special provision A802 has been created, to require that entries to the List of Dangerous Goods without packing groups, but with a requirement for UN specification packaging, must use packaging rated at least to the Packing Group II level.
  • Special Provision A803 will require that all corrosives in Class 8, Packing Group III be packed in packaging that meets at least Packing Group II standards.(except for limited quantities).
  • Special Provision A804 will reaffirm that Gallium and Mercury must be shipped in packaging that meets Packing Group I standards.
  • Special Provision A805 will clarify that Dry ice may be packed directly into an overpack without an intervening packaging.
  • For Continue Reading…
More Changes for FedEx Users

FedEx implemented computer generated shipping papers that had to be generated using an approved error checking software.

Additional changes for FedEx Ground will become effective Aug. 1, 2011. All shipments will require all hazardous materials paperwork to be completed and submitted electronically using a FedEx® electronic shipping solution, a FedEx-recognized hazardous materials vendor software application, a FedEx® Compatible Solutions Program application or a custom solution that has the ability to transmit hazardous materials shipping information electronically. For more information on these new requirements visit http://www.fedex.com/us/hazardous-materials/current-requirements/index.html.

ICC The Compliance Center offers a simple solution in DG Office. This software allows you to complete forms electronically and submit to FedEx per their requirements.

Sign up for a free demo by visiting our website at:

http://www.thecompliancecenter.com/services/dgoffice.htm.