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.
- 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…
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 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 “symbol” along 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…
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 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…
When you think “Top 10” you might think about David Letterman’s top 10 lists. These lists are perhaps his greatest legacy from his run on the “The Late Show” (see 5 Top 10 Lists from David Letterman)
Unfortunately, this blog is not about those top 10 lists, but rather something far more serious, OSHA’s Top 10 violations.
This list is comprised of nearly 32,000 inspections of workplaces by federal OSHA staff. The top 3 violations remain the same as the last three years. They include: fall protection, hazard communication and scaffolds.
The complete Top 10 OSHA violations list includes:
- Fall protection
- Hazard communication
- Respiratory protection
- Powered industrial trucks
- Machine guarding
- Electrical wiring
- Electrical, general requirements
According to the Department of Labor’s Occupational Safety and Health Administration (OSHA), there are more than 4500 worker deaths and approximately 3 million workers injured every year. Many of the deaths are associated with fall, poor scaffolding and forklift operations. (https://blog.dol.gov/2016/10/18/top-10-osha-citations-of-2016-a-starting-point-for-workplace-safety/)
What is astonishing is that so many of the deaths and injuries are preventable. Employers and employees must take safety seriously. Unlike David Letterman’s Top 10, there is nothing funny about workers dying or being injured.
OSHA has recently released new recommendations for safety and health programs that will help prevent injuries and deaths, reduce costs, improve compliance, and engage workers. This recommendation can be found here: https://www.osha.gov/shpguidelines/.
Training is vital. Ensure workers are trained, and Continue Reading…
The Environmental Protection Agency (EPA) issued a final technical amendment to 40 CFR Part 370, in June 2016 which aligns the hazardous chemical reporting regulations to the changes in the Occupational Safety and Health Administration’s (OSHA) Hazcom 2012.
These changes have a compliance date of January 1, 2018, and affect reporting under the Emergency Planning and Community Right-to-Know Act (EPCRA), sections 311 and 312.
Section 311 of EPCRA requires facilities to submit a SDS or a list of hazardous chemicals grouped by categories of physical and health hazards. Section 312 of EPCRA requires facilities to submit an emergency and hazardous chemical inventory form yearly by March 1.
Prior to the change in 2012, the hazard communication regulations (OSHA) were performance oriented, and did not specify the language/description or format that the company had to use. Once the hazard communication regulations were updated, stakeholders requested that EPA align the wording to be consistent with the new OSHA Hazcom 2012 regulations.
Some of the changes in 40 CFR Part 370 include:
- Technical terms have been updated (i.e., Material Safety Data Sheet to Safety Data Sheet)
- The definition of Hazard Category has been updated
- The “Five categories” (Fire/Sudden release of pressure/Reactive/Immediate acute and Delayed-chronic) have been changed to match the physical and health hazards outlined the Hazcom 2012
- The Tier I and Tier II inventory forms are modified
- Tier 2 Submit, the software will be updated, and EPA is Continue Reading…
Is anyone really ready for a surprise visit from a hazmat inspector? The quick answer is no, but there are things that you can do to prepare in anticipation of a visit.
Federal law requires that you allow an inspector access to records, property, reports, and other information relevant to shipping hazardous materials/dangerous goods. Unlike the crime show Law and Order, a search warrant is not required; you may not deny an inspector access to a regulated facility, impose conditions on the entry, or limit the inspector’s right to gather information or evidence.
Inspector’s will visit for a variety of reasons, but often include:
- High-risk commodities (explosives, bulk shipments)
- Prior issues
- Proximity to another company being inspected
Preparing for the inevitable
- Develop a plan and designate staff with defined roles
- Ensure the designate knows what to say, and when to seek assistance from upper management
- Conduct internal audits and institute corrective actions
- Have commonly requested items in a centralized location
What are commonly request documents?
- List of hazmat employees
- Employee training records
- Shipping papers
- Standard operating procedures (SOPs)
- Special permits and interpretations
What do you do when it is show time?
- Ask the inspector to identify him/herself and the purpose of the visit
- Escort them to a quiet area where they can review documents
- Do not volunteer information, wait for them to ask
- Be polite, courteous and helpful. Continue Reading…
My husband is a rocker. He loves heavy metal music and listens to it often. There is no better channel for him than “Hair Nation” on Sirius XM radio. Having grown up with him, I know he has attended every concert available including Bon Jovi, Ratt, Metallica, Poison, and the like. One of his best memories is seeing Motorhead perform while we were living in Austria. To this day he still goes to concerts, but now the bands include Disturbed and Breaking Benjamin. What is interesting is his approach to going to concerts now as compared to when he was younger. You guessed it. The biggest change is the use of ear plugs.
I’m not sure if this change is due to getting older or the fact that being in a safety role he now realizes how damaging the level of music at these concerts is to his hearing. (You can insert your own joke about men or women having “selective” hearing here.)
Hear and Now – Noise Safety Challenge
In a recent press release OSHA indicated that every year 22 million workers risk losing their hearing due to workplace noise hazards. The estimated worker’s compensation costs for this disability is around $242 million. This is too high! Employers warn of hearing hazards in the workplace and often require workers to wear hearing protection. In a Continue Reading…
Being a Home Owner Working in Safety
A part of being a homeowner is maintaining the structure and surrounding area. We do this to keep the city and neighbors happy, but also to keep the house in good working order. If you look around your neighborhood, yards are mowed and houses are painted. You will even see the occasional furniture delivery or roofer in the area. Another part of home ownership is keeping the inside up to date. After all indoor plumbing is nice and there is always the chance that the house will be sold in the future.
Our home is currently 16 years old and we’ve been in it for 8 years. It has not been updated much beyond some interior paint and a new roof thanks to St. Louis hail storms. We decided to update a bathroom. Easy enough given how small they are, right? It turns out we needed to gut the bathroom down to the studs since it was covered in wallpaper. During the demolition there was a ton of dust generated. Now that new drywall is up it has to be “mudded and sanded” which created even more dust. What was fascinating was the fact none of the folks working wore masks or respirators during any of this. Remember I work in safety so this bothered me greatly and sent me on a hunt Continue Reading…