OSHA HazCom 2012
OSHA Stance on Wearable Lithium Batteries

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.

As to ways to prevent injuries Continue Reading…

Skull and Cross Bones
National Poison Prevention Week

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…

ICC Top 10 List
OSHA’s Top Ten Most-Cited Standards for 2018

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

  1. Fall Protection – General Requirements: Standard 1926.501 with 7,720 violations
  2. Hazard Communications: Standard 1910.1200 with 4,552 violations
  3. Scaffolds/Scaffolding: Standard 1926.451 with 3,336 violations
  4. Respiratory Protection: Standard 1910.134 with 3,118 violations
  5. Lockout/Tagout: Standard 1910.147 with 2,944 violations
  6. Ladders: Standard 1926.1053 with 2,812 violations
  7. Powered Industrial Trucks: Standard 1910.178 with 2,294 violations
  8. Fall Protection: Training requirements: Standard 1926.503 with 1,982 violations
  9. Machine Guarding: Standard 1910.212 with 1,972 violations
  10. 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…

Web address monitor icon
OSHA’s Website on Workplace Chemicals
Laptop on wood table

New Tools for Chemical Data

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:

  • Physical/Chemical properties
  • Synonyms
  • Exposure limits – OSHA, NIOSH, ACGIH
  • NFPA ratings
  • Sampling information
  • 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…

United Nations Logo
2018 United Nations Regulatory Updates
Palais des Nations in Geneva

What’s New at the UN for Transport?

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.
  • Dangerous Goods in Articles:
ICC's Regulatory Helpdesk
Regulatory Helpdesk: June 4

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…
2018 Safe + Sound Week
2018 OSHA Safe + Sound Week

2018 Safe + Sound Week

OSHA Safe + Sound Week Set for August 2018

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 August 13-19 has been designated as Nationwide Safe + Sound Week for 2018. The week is presented by the Occupational Safety and Health Administration (OSHA), National Safety Council, American Industrial Hygiene Association (AIHA), and the National Institute for Occupational Safety and Health (NIOSH) just to name a few. The goal is to “raise awareness and understanding of the value of safety and health programs“. All business and companies are encouraged to participate because “safe workplaces are sound business“.

The Core Elements of Safe + Sound Week

The focus of the week is on three core elements. It covers management leadership, worker participation and find and fix hazards.

  • 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…
ICC's Regulatory Helpdesk
Regulatory Helpdesk: April 2

How to determine if a product is regulated, SAPT on a SDS, Shipping a drone, and using a UN package

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.

Is my product regulated?

Q. I have 2 products I distribute to various stores to sell. The SDS files say my product is not regulated under DOT and TDG in Section 14. Since this is sold as a consumer product, doesn’t that mean it is regulated for IATA should I ship it via air? (the SDS were emailed to me)
A. Nothing in your SDS files leads me to believe either one would meet any of the 9 hazard classes in IATA. This is further confirmed by neither SDS classifying the products for DOT and TDG. Basically, what you have are containers of non-regulated liquids.  There is no need for UN Specification packaging or paperwork for IATA or any other transport regulation.

SAPT on my SDS

A. Since the addition of UN numbers for polymerizing substances, we’ve been told we must include the Self-Accelerated Polymerization Temperature (SAPT) on our SDS documents in Section 9. Is this a new requirement?
Q. There is no requirement in OSHA HazCom 2012 to include that particular data point in Section 9. All of the Continue Reading…
Regulatory Helpdesk: February 12

Lithium Batteries, Placards, and SDS in the Workplace

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.

Lithium Batteries (Air)

Q. For PI 967 in IATA is the weight limit the weight of the equipment and battery inside of it or just the battery.
A. For all battery packing instructions in IATA it is always the weight of the battery itself.

Lithium Batteries (IMDG)

Q. Do “excepted” batteries require segregation from limited quantity packages under IMDG?
A. Under IMDG §3.4.4.2 it tells you that segregation requirements in Chapters 7.2 – 7.7 plus any information on Stowage in column 16b of the table do not apply to goods in limited quantity packages. Lithium ion batteries do not yet need segregation under IMDG either. It is only IATA that has implemented segregation this year as part of the packing instructions for shippers. IATA has also added batteries to the segregation table for operators, but it isn’t mandatory until next year and only applies to those in Section 1A and 1B not Section II.

Placards (TDG)

Q. Customer asked if his Class 8 material (UN 1830) needed to have a UN number on the placard if shipping 1 liter per package and 7 per tote for a total of 17 Liters for the shipment in Canada. Continue Reading…
PHMSA
PHMSA & OSHA Make a Video Together – an Oxymoron?

Warehouse with chemicals

PHMSA vs OSHA

George Carlin will always be a favorite comedian for people of a certain age. One of his best-known bits is on oxymorons. An oxymoron, is basically a set of contradictory terms that work together. While not the greatest of explanations, let’s have George give you some examples to make the point.

This concept came to mind on the heels of the DOT’s Pipeline and Hazardous Materials Safety Administration (PHMSA) and the DOL’s Occupational Safety and Health Administration’s (OSHA) joint video on labeling. Those two organizations are just that, 2 different organizations, yet they released a joint video? It sounded like a setup to a bad joke. Turns out I was wrong.

The video does a great job of explaining the focus of each organization and goes a long way to clearing the air. There are references to the regulations used by each, but not a lot of time is spent on “regulatory language” or the details of either one. 

Comparing PHMSA vs OSHA

Here is my version of the comparisons between the two and how closely the align based on the video.

PHMSA OSHA Take Away
Regulates hazardous materials in transport Regulates hazardous chemicals in the workplace Both want people to be safe.
Uses the Hazardous Materials Regulation Uses the Hazard Communication Standard Both have a set of “rules”.
Defines Hazardous Material as those that pose an unreasonable risk to health, safety and property when transported in commerce Defines Hazardous Chemical as Continue Reading…