OSHA Carcinogen
OSHA Celebrates World Cancer Day?

We all have reminders on our calendars for such things as holidays, birthdays, and appointments. As I looked forward to February for some planning purposes, the date of February 4th popped up as World Cancer Day. Is this a day to celebrate cancer? Does that even make sense when most of us upon hearing that word have some pretty strong negative reactions and emotions? This sent me on a path of fact checking. The purpose of World Cancer Day as established by the Union of International Cancer Control (UICC) is to raise awareness of cancer and to encourage its prevention, detection, and treatment. So, this day is similar to Earth Day or World AIDS Day then.

Since I work in the Regulatory World, I thought this would be an opportune time to talk about cancer in the realm of Hazard Communication. For many cancer is part of the acronym CMR which stands for materials that are carcinogenic, mutagenic or toxic to reproduction. In OSHA HazCom 2012, Appendix A Subsection 6 covers the definition, classification criteria, and cut-off values for carcinogens. Are those pieces of information really enough to classify all of your products? Granted the regulation points out in A.6.2.5.2 some factors to consider, but those exact particular factors can be hard to find in many full length cancer studies.

To make things a bit easier, OSHA has allowed for Continue Reading…

Did You Miss the First GHS Deadline? It’s Not Too Late!

OHSA implemented GHS as part of its Hazard Communication System (29 CR 1910.1200) back in March of 2012. The full conversion is not until June 2016, but there is a phase in process that you should already be aware of. The first deadline set by OHSA was December 1, 2013. This was sort of a basic-training for employees to learn what information is on GHS labels, SDS sheets and how to recognize the new pictograms. Imagine opening the back of a truck, ready to unload its contents into your facility and you see these strange labels on your drums. These are MY drums aren’t they? They have strange looking labels on them, with familiar but slightly different pictograms, along with a few new ones. You reach for the MSDS to see just what the heck you are looking at, only to find something called a SDS. Hey, what happened to the “M”? Wow, there is a lot of information on this SDS. Quit looking for the “M” and Behold! The future.

Learning a new language can sometime s be difficult, but understanding GHS is not. The first training deadline was just a fair warning, saying “Hey! I’m here, and this is what I look like. Oh, and by the way, you are going be seeing a lot more of my kind in the future” That’s right. Did I mention, it the law? Yes, this short introductory training is required. This Continue Reading…

HMIS and NFPA: Do They Still Work?

Now that OSHA has revised the Hazard Communication Standard to align with GHS, the question many employers, chemical manufacturers, distributors and end users have is: Will I be able to continue to use my NFPA and HMIS labeling systems?

The answer is yes . . . But they may cause confusion. The question becomes not whether you can, but whether you should.

First, let’s look at the old standard’s requirements. In the old standard (pre-HazCom 2012), labels (and labeltext) on shipped containers and workplace labels were performance based. That means OSHA didn’t say exactly what had to appear on the labels. Instead, it said what effect the labels had to achieve; OSHA’s goal: to successfully transmit hazard information to the end user.

Many companies adopted either the NFPA or HMIS system for workplace labeling. Both systems are simple and effective. A criteria was established to identify the health, physical, reactivity and personal protective equipment that was required. A numerical system from 0-4 identified the hazard from lowest (0) to worst (4).

Simple right? Well it was until HazCom 2012 adopted the GHS recommendations and added health and physical criteria and categories. Now, a chemical that was previously a number “1” meaning it had a low hazard, is now a “4” meaning it has a low hazard.

What’s an employer to do? If you have used a number based Continue Reading…