It just doesn’t seem possible that the new OSHA standard, known as HazCom2012, has been in full swing for over 4 years now. Of course, the time taken to get everything in place regarding it is still fresh in many people’s memories. I can still remember choosing to work on Memorial Day weekend to help some customers meet the June 1, 2015 deadline. Just as a reminder, that transition was to Revision 3 of the Globally Harmonized System of Classification and Labeling of Chemicals (UNSCEGHS) or Purple Book and the direct section of the Code of Federal Regulations (CFR) that was updated is Title 29 1910.1200. Given that the UN just released Revision 8, the US is a bit behind some other parts of the world.
Don’t worry though, OSHA is already in the process of preparing another update to the standard. However, this will take time given the process involved with updating the CFR. The process was supposed to start in the Fall of 2014 with a Notice of Proposed Rulemaking (NPRM) for an update to Revision 7 of the Purple Book. That didn’t happen and the date moved to Spring of 2018. Again, the process stalled. OSHA is now looking to publish the NPRM this month – December 2019.
This notice of proposed rulemaking, whenever it is published, is supposed to update the OSHA standard to Continue Reading…
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…
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.
Fall Protection – General Requirements (1926.501): 6,010 violations
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
Bevacizumab for female developmental effect with CAS 216974-75-3
Here’s the thing. I am a TV junkie. A huge amount of my time has been dedicated to researching new shows, setting them up on my DVR, and watching said shows. One that has my attention right now is “The Rookie” starring Nathan Fillion. In the show, he is a 40-year old rookie cop in Los Angeles. It has my attention for multiple reasons aside from the obvious. The main REGULATORY one is the fact that every officer on the show wears a body camera. It got me to thinking … surely those body cameras come with rechargeable batteries. If so, what happens when in the course of the show, one of those cameras is damaged? My brain then jumped to what about workers who wear battery powered devices.
Believe it or not, OSHA recently published in their newsletter an article called, “Preventing Fire and/or Explosion Injury from Small and Wearable Lithium Battery Powered Devices”. You can find the article at https://www.osha.gov/dts/shib/shib011819.html.
In this article, they do a good job describing batteries and cells as well as how they work. There is also a lengthy section on lithium battery hazards including what can cause enough damage to create fire and explosion risks. These include such things as physical impacts, usage/storing at temperatures too high or too low and failure to follow the manufacturer’s instructions.
The main part of my job is to train companies, workers, handlers, and the like on how to manage hazardous materials or hazardous chemicals safely. This can be done under the umbrella of the transport regulations of 49CFR, IATA, and IMDG, or under the OSHA HazCom standard. However, not everyone is going to take one of my courses. Sad, but true.
Granted all of those folks do their jobs well and use marks, labels, placards, and safety data sheets to convey information about their products to other users. But it begs the question, how is the general public made aware of the “other” dangers or poisons out there? Think about the laundry pod scare recently to make my point.
Back in 1962, the first-ever National Poison Prevention Week was announced. In 2019, the week will be from March 17-23. Supported directly by the American Association of Poison Control Centers (AAPCC), the goal is to promote safety tips and the emergency services provided by the Poison Control Centers in the US.
To emphasize just how important Poison Control Centers are, take a look at some numbers from 2016 taken directly from the AAPCC website at www.aapcc.org.
There were 2,700,000 cases managed by the centers.
Someone called the centers every 14 minutes.
Over $1,800,000,000 saved in medicals costs.
For this year’s event, people are encouraged to use the hashtags #NPPW19, #PreventPoison, and #PoisonHelp. Continue Reading…
It is the end of October. This is the signal for many exciting things. First, autumn is well under way; no more temperatures in the high 90’s. Second, pumpkin spice everything is available. My personal favorite though is plain old pumpkin pie. Finally, OSHA publishes their list of top ten most-cited standards for the previous fiscal year. This is always announced at the National Safety Council’s Congress and Expo. The timing fits with OSHA’s fiscal year that runs from October 1 through September 30. So, without further delay….
Most-Cited OSHA Standards for Fiscal Year 2018
Fall Protection – General Requirements: Standard 1926.501 with 7,720 violations
Hazard Communications: Standard 1910.1200 with 4,552 violations
Scaffolds/Scaffolding: Standard 1926.451 with 3,336 violations
Respiratory Protection: Standard 1910.134 with 3,118 violations
Lockout/Tagout: Standard 1910.147 with 2,944 violations
Ladders: Standard 1926.1053 with 2,812 violations
Powered Industrial Trucks: Standard 1910.178 with 2,294 violations
Fall Protection: Training requirements: Standard 1926.503 with 1,982 violations
Machine Guarding: Standard 1910.212 with 1,972 violations
Personal Protective Equipment and Lifesaving Equipment – Eye and Face Protection: Standard 1926.102 with 1,536 violations
Here are some things I notice about this year’s list. First of all, the top five are the exact same ones and in the exact same order as last year, and all the way back to fiscal year 2014. The next four on the list are the same as well. The only difference is the order of them going back through Continue Reading…
Chemical data and information are an integral part of my work. Data is needed for a shipper of hazardous materials or dangerous goods. It is needed for an author of Safety Data Sheets (SDS). It may also be needed for OSHA workplace labeling. Sometimes you need several websites or resources open all at once to gather the needed data.
As such, OSHA has created a tool that you may find helpful. It is called the “OSHA Occupational Chemical Database”. The link for it is https://www.osha.gov/chemicaldata/. It is a compilation of data from several agencies and organizations put into one online resource. The first paragraph on the site calls this “OSHA’s premier one-stop shop for occupational chemical information”. For chemicals found on the website, there is information on some or all of the following topics:
Exposure limits – OSHA, NIOSH, ACGIH
Additional Resources and Literature References
The site is searchable mainly by chemical name, CAS number or alphabetically. There is even a feature that will allow you to search for chemicals under certain topics. The site allows you to group chemicals by Permissible Exposure Limits (PEL), Carcinogenic classification and Immediately Dangerous to Life and Health hazards (IDLH). That aside, once you have found your chemical, this site provides a variety of information. Simply click on the link listed Continue Reading…
At this time of year all the regulatory updates start. Every time a notation comes across my desk or email I can’t help but think about a famous line in the movie “Sixteen Candles”. That particular line is “What’s happening hot stuff?” Click here to see the actual movie clip. One of these days, I want a presentation to start with this. It would sure break the ice on some rather detailed subject matter.
Having prepared you for thinking about what’s happening or changing, we have to start at the UN level specifically. Much of this information comes from a presentation by Duane Pfund at the Pipeline and Hazardous Materials Safety Administration. We need to focus on is what changed from the 2015 – 2016 biennium. That biennium gave us Revision 20 of the UN Model Recommendations for the Transport of Dangerous Goods. Revision 20 is what will drive the changes starting in January 2019.
What’s Happening or Changing for 2019?
Class 8 Corrosive Materials:
A new alternative method for classifying these mixtures is being introduced. It revolves around using the GHS Purple Book bridging principles and calculation methods. Note that flammable gases and explosives are on the list for this same concept in the current biennium.
Variation packaging cushioning material, excepted quantity packaging, UN packaging testing, distributor deadlines for WHMIS 2015, Mexico GHS, and compatibility
Welcome back to the Regulatory Helpdesk where we answer your dangerous goods & hazmat questions. We’re here to help you become independent with – and understand the whys and hows – of the regulations.
Variation Packaging (4GV) Cushioning Material
Q. Can I substitute a different cushioning material in a variation box?
A. In general: “No.” When a UN-standardized package is specified. The various regulations (49 CFR, IATA DGR, IMDG Code, and TDGR), or the standards referenced within them, restrict the user to assembling the package according to the manufacturer’s instructions. These instructions are based on the components used in the submitted test/design reports on which the approval is based. 49 CFR §178.601(g)(4)(iv) even goes to the point of specifically requiring the same type of cushioning as was used in the submission.
Excepted Quantity Packaging
Q. Is it always necessary for the shipper to have performance test results on packaging used to ship “excepted quantities”?
A. This depends on the mode or jurisdiction of transport. 49 CFR [§173.4a(f)], IATA DGR (§2.6.6) and IMDG Code (§3.5.3) all require that the shipper ensure that testing has been done and documented. This doesn’t need to be externally certified or approved. TDGR [§1.17.1(3)] does not require specific testing, only that packaging is “… designed, constructed, filled, Continue Reading…