ICC Top 10 List
OSHA’s Top 10 Most-Cited Standards for 2017

Young female Industrial Worker

Top 10 OSHA Violations 2017

At the end of September every year several things happen. It is the official start of autumn. All of the children are back in school. Pumpkin spice everything is available. OSHA publishes their list of top ten most-cited standards. These are 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 2017

  1. Fall Protection – Standard 1926.501 with 6,072 violations
  2. Hazard Communications – Standard 1910.1200 with 6,072 violations
  3. Scaffolding- Standard 2936.451 with 3,288 violations
  4. Respiratory Protection – Standard 1910.134 with 3,097 violations
  5. Lockout/Tagout – Standard 1910.147 with 2,877 violations
  6. Ladders – Standard 1926.1053 with 2,241 violations
  7. Powered Industrial Trucks – Standard 1910.178 with 2,162 violations
  8. Machine Guarding – Standard 1910.212 with 1,933 violations
  9. Fall Protection: Training requirements – Standard 1926.503 with 1,523 violations
  10. Electrical Wiring Methods – Standard 1910.305 with 1,405 violations

Here are some things I notice about this year’s list. First of all, four of top ten are related. By this I mean, items 1, 3, 6 and 9 are related to falling.  Next, take note that the top five violations are the exact same and in the same order as the past four fiscal years. Almost every other standard listed for 2017 is also on the 2016, 2015, 2014 and 2013 lists. The only Continue Reading…

Safety
OSHA, Emergency Exits, & Procedures

Neon Green Exit Sign

School Days, Fire Drills

One of my earliest memories from elementary school was deeply concentrating on my school work at my desk (at least some of the time), when suddenly being startled by a loud alarm. My classmates and I would jump up in excitement as we all meshed together in a quiet single file line, and our teacher would lead us out of the nearest exit into a parking lot on a nice Spring day. We would stand outside quietly until the principal would walk outside and give us a quick wave of her hand, and to our dismay we would all march back into school with our heads down to pick up right where we left off in the rest of the day’s school work.

In hindsight, the fun and excitement of a fire drill as a child was in actuality a well thought out systematic process designed to help students and staff become aware of how to exit the building in the quickest, easiest, and safest way possible. The importance of these emergency procedures are not only important in our childhood school days, they should also play an essential role in the workplace. In fact, OSHA clearly defines what is expected when exiting a building during an emergency.

Exit Routes

Under most circumstances, a workplace must have at least 2 exit routes depending on the number of Continue Reading…

World Hepatitis Day Logo
World Hepatitis Day

Eliminate Hepatitis Banner

Are your Signs Accurate?

Since 2010, World Hepatitis Day is observed on July 28th. The goal is to raise awareness of hepatitis as well as the prevention and treatment of the disease. According to the World Health Organization (WHO), an estimated 1.34 million people died globally from this disease in 2015. In comparison, numbers that high match those caused by tuberculosis, malaria, and HIV/AIDS. According to the World Hepatitis Day website, “Currently, 90% of people living with hepatitis B and 80% living with hepatitis C are not aware of their status.” We all need to be educated. This is not a disease found in just one country or in one particular ethnicity. Here is the chance to educate ourselves. Check out the website dedicated to the even this year at http://www.worldhepatitisday.org/en/about-us

Hepatitis is the inflammation of liver tissue. It is most commonly caused by a virus and there are five main ones commonly referred to as Types A, B, C, D and E. Types A and E are usually short-term (acute) diseases. Types B, C, and D are likely to become chronic. Note that Type E is very dangerous for pregnant women.

Listed below are some key facts about each type of Hepatitis taken from the WHO website. For more information visit http://www.who.int/hepatitis/en/

Key Facts of Hepatitis Types

  • Type A – transmitted through ingestion of contaminated food and water or through direct contact Continue Reading…
Safety Data Sheets (SDS)
Consumer Chemical Products and GHS SDS Requirements

Consumer chemical bottles

Do My Products Need a SDS?

Determining which of your consumer chemical products would require a GHS Safety Data Sheet (SDS), can sometimes be difficult and confusing. Which products actually do need to have compliant SDS, can differ depending on which country/region you are in, and how the product is being used.

Canada

In Canada, chemical products that are labeled, packaged, and sold at retail outlets as consumer products, are regulated by the Canadian Consumer Product Safety Act (CCPSA), and the Consumer Chemicals and Containers Regulations 2001 (CCCR 2001). Examples of ‘retail’ outlets are stores such as Canadian Tire, Home Depot, Rona, and corner gas stations that anyone off the street can walk into and buy chemical products in, etc.

Chemical products, which are intended for use in worksites and not sold at retail outlets, on the other hand, are regulated by the Hazardous Products Act (HPA) and Hazardous Products Regulations (HPR, or “WHMIS 2015“). It is the HPA and HPR (WHMIS 2015), where GHS SDS requirements are found, while the CCPSA and CCCR 2001 do not currently contain any SDS requirements at all.

In the HPA, in Part II, Section 12(j) and Schedule 1, CCPSA consumer products are actually excluded from the application of the HPA’s requirements.

What does this exclusion mean?

Keep in mind that the CCPSA and CCCR 2001 do not contain any SDS requirements, while the HPA and HPR Continue Reading…

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 Continue Reading…

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 Continue Reading…
GHS
GHS in North America and Europe – Where Are We Now?

Isn’t everyone using GHS for SDS’s and labels?

The answer to that is yes, and also no.

The European Union (EU)

In the EU, REACH [Regulation (EC) No. 1907/2006 concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals] and GHS regulations [Regulation (EC) No. 1272/2008 on classification, labelling and packaging of substances and mixtures, or the ‘CLP’] have already been implemented for many years. Most phases of the EU’s implementation plan have already been completed. There is one last remaining date that has not yet passed, however, with respect to SDS’s and labels.

SDS’s and labels for pure substances are required to fully compliant with REACH and the CLP. The last transition date for pure substance SDS’s was completed on December 1, 2012. Any SDS and label for a pure substance after that date, had to be fully compliant with REACH and CLP regulations, and display only GHS information.

SDS’s and labels for mixtures, for products placed on the market in the EU for the first time after June 1, 2015, are also required to be fully compliant with REACH and the CLP, and display only GHS information.

Mixture SDS’s and labels, only for products already placed on the market in the EU for the first time before June 1, 2015, however, may still show old system EU information. These SDS’s and labels for mixtures, may still display the EU’s old system Continue Reading…

Frequently Asked Questions
FAQ – GHS Symbols on SDS in Canada and the United States

Frequently Asked SDS Symbols Questions

How many times have you thought you understood a requirement, only to second guess yourself about whether you got that right or not? It could be something relatively straight forward, or something a bit more complicated. Everyone has these moments occasionally, especially with the implementation of GHS around the world. At ICC, two of the questions that seem to pop up from time to time, revolve around symbols on SDSs.

Do GHS pictograms have to appear on an SDS?

The answer: No. The ‘pictogram,’ specifically, doesn’t have to appear. This answer, in part, boils down to terminology.

In both Canada, under WHMIS 2015 Hazardous Products Regulations (HPR) requirements, and in the United States, under Hazcom 2012 requirements, Section 2 of an SDS is required to list the label ‘information elements’ that are applicable to the product. Hazard ‘symbols’ being one of the required ‘information elements’.

In both the United States and in Canada, ‘pictogram’ is defined as a “symbolalong with other “elements, such as a border or background color”. So a complete GHS ‘pictogram’ is actually two part; a graphic symbol on the inside, and a frame surrounding it. Both countries include an allowance only to show a ‘symbol’ (ie. not a ‘pictogram’), or, just the name of the symbol, on the SDS [Hazcom 2012, Appendix D, Table D.1, Item 2(b); WHMIS 2015 Hazardous Continue Reading…

OSHA
New OSHA Concentration Range FAQ

Validation

Oprah Winfrey once said, “I’ve talked to nearly 30,000 people on this show, and all 30,000 had one thing in common. They all wanted validation.” Validation is receiving feedback from others that what you do and say matters. It is an acknowledgment of your actions, deeds and accomplishments. To be a healthy person we need to receive positive validation and be able to give it to ourselves. So is it possible for a company to receive validation? I believe so and here’s why.

In one of OSHA’s recent Frequently Asked Questions (FAQ’s) postings a question regarding the use of ranges on Safety Data Sheets was added. To see the full FAQ and the answer, please click here. The specific question asked is: When may chemical manufactures/importers use concentration ranges rather than an exact percentage composition in Section 3 of the SDS, and how does this apply to trade secrets? Let’s take a closer look at OSHA’s answer. There are several parts to it and each deserves some attention.

Part 1 – Exact Percentage versus Concentration Range Clarification

The answer starts by clarifying the language used in Appendix D under Section 3. In the actual Appendix it states, “The chemical name and concentration (exact percentage) or concentration ranges of all ingredients which are classified as health hazards” must be disclosed in Section 3. However, in the FAQ answer the statement reads as “the chemical Continue Reading…

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 Continue Reading…