OSHA Labeling
Fainting is an OSHA Recordable?

Fainting, or syncope in medical terms, is when someone loses consciousness for a short period of time usually caused by an insufficient supply of oxygen to the brain. In movies and television though, we are lead to believe that fainting can occur for a variety of non-medical reasons mainly emotional ones. One example is where a female character meets a monster for the first time and is so overcome with fear that she faints. For effect, she usually faints into the arms of the monster. Soap Operas are notorious for the next example. There are many scenes where the lead character is presented with horrible news and as a result faints due to the extreme emotion the news triggers. Another one used quite often by the entertainment industry is when a character faints at the sight of blood. Take a look here at Dr. Sheldon Cooper from “The Big Bang Theory” passing out from cutting his thumb.

What is interesting about that clip is Dr. Amy Farrah Fowler would have to list this as a recordable case on the OSHA Log of Work-related Injuries and Illnesses. In November of 2015 OSHA posted in a Letter of Interpretation that fainting at the sight of blood is a recordable event. The scenario as outlined in the letter involves a worker scratching his finger on a clamp. As a co-worker began Continue Reading…

OSHA Flammable
“Light My Fire” – Calculating Flash Points for Flammable Liquids

One of the most common tests for determining hazard classification is the flash point. This humble piece of physical information is defined in various ways in various regulations, but generally is the lowest temperature at which the vapours from a flammable liquid will ignite near the surface of the liquid, or in a test vessel. This can be critical for safety, because this temperature will be the lowest possible for the liquid to cause a flash fire if released or spilled. If the material can be handled and transported at temperatures lower than the flash point, the fire risk will be much smaller.

The flash point has become the standard test for classifying flammable liquids. It’s used by the U.S. OSHA (Occupational Health and Safety Act) and HMR (Hazardous Materials Regulations) classification systems, as well as Canada’s WHMIS (Workplace Hazardous Materials Information System) and TDG (Transportation of Dangerous Goods Regulations).

Obtaining a flash point on a new product is usually easy enough. Many laboratories, particularly those that deal with petrochemicals, can perform the test for a reasonable charge. If your company has too many products to make outsourcing practicable, a flash point tester itself is comparatively low cost (as scientific apparatus goes), and a trained person can obtain data quickly and efficiently. However, both of these options do cost money. Wouldn’t it be nice if there were a Continue Reading…

OSHA Labeling
Disney, Dwarfs and Workplace Labels

It was recently announced that Disney was re-releasing the classic animated movie “Snow White and the Seven Dwarfs”. The commercial started with the dwarfs singing their classic song “Heigh-Ho”. In this tune, the cute characters of Dopey, Bashful, Sneezy, Happy, Grumpy, Sleepy and Doc all sing about coming home from working all day digging in the mine. To remember these characters, watch and listen here.

As the scene starts, I can’t help but notice there are no OSHA workplace labels anywhere. In the new OSHA Hazard Communications Standard 1910.1200 there isn’t much guidance on how to handle workplace labeling. The regulation states “the employer shall ensure that each container of hazardous chemicals in the workplace is labeled, tagged or marked”. The regulation goes on to say use the same information that is found on the shipped containers or use a “Product identifier and words, pictures, symbols, or combination thereof, which provide at least general information regarding the hazards of the chemicals, and which, in conjunction with the other information immediately available to employees under the hazard communication program, will provide employees with the specific information regarding the physical and health hazards of the hazardous chemical.”

Many Employers may feel overwhelmed trying to figure out what to have in a workplace after reading the regulation. Let us help. We offer the GHS Workplace Labels (Orange System).

Orange System GHS Workplace Labels Available Continue Reading…

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…

OSHA Flammable
OSHA Tanker Labeling HazCom 2012 – “Everything Old is New Again”

Clarification provided by OSHA’s Inspection Procedure, Directive CPL 02-02-079 in July 2015, is filtering through the regulated community and causing some concern.

The directive essentially confirms that HazCom 2012 labeling applies to “… a tank truck, rail car or similar vehicle…” comprising the container for a hazardous chemical when it is not immediately unloaded at the destination.

Hazard Communication is Key

The intent is presumably to ensure that workers potentially exposed to hazardous chemicals will be able to identify the risks, particularly if they are not familiar with DOT markings – or if the substance is a hazardous chemical under OSHA, despite not being a hazardous material under DOT.

The wording of 29 CFR1910.1200(c) is light on definitions of “container” (“…storage tank or the like that contains a hazardous chemical…”); and “shipped container” in (f)(1) et al is not actually defined in the regulation itself.

However, “Shipped Container” is defined in part X.C.21 of the CPL directive, i.e. “… means any container leaving the workplace, whether through normal shipping routes or physically handed to another person.”

Consequently OSHA expects that rail or highway tankers as “shipped containers” will, in addition to 49 CFR – required safety marks, include the HazCom 2012 “… labeling information … either posted on the outside of the vehicle or attached to the accompanying shipping papers …”

Sending a copy separately from the vehicle is not allowed.

Custom Tank Labels Continue Reading…

HAZCOM 2012
More Hazard Communication Issues

An inquiry was made by the American Coatings Association, which they asked OSHA to clearly outline the import of materials and the export of materials in sealed containers for the Hazard Communication Standard (HCS). The Occupational Safety & Health Administration (OSHA) responded with a Letter of Interpretation (LOI) on November 23rd, 2015 which further clarified the responsibilities of US companies when importing or exporting materials that require attention under the 29 CFR 1910.1200

In regard to import OSHA’s guidance in the LOI states the responsibility falls on the importers to assure compliant labeling when the material becomes under their control. Once in their control, importers must follow the requirements of 29 CFR 1910.1200(b)(4) where applicable. Importers must also assure compliance with HCS 2012 prior to shipping within the United States. In this LOI, OSHA encourages the review of their CPL-02-02-079 Section X.F.2h compliance directive which entails information for materials packaged for shipment prior to June 1st, 2015.

OSHA’s guidance for export in this LOI for sealed containers is that if prepared for direct shipment outside the US and are inside a USDOT approved shipping container, the manufacturer can label the container for the destination country. A HCS compliant label must be affixed to the outside package or be attached to the shipping papers as well. The container would also have to be labeled according the appropriate regulation for Continue Reading…

ICC Compliance Center
The Story of ICC

One thing that amazes me after 25 years in business is the fact that (even long time) customers do not understand the spectrum of products, services, and training we offer. After hearing yet another customer say, “we did not know you did that” I was inspired to tell you this story.

Once upon a time, not so long ago there was a train wreck, not unlike Lac Megantic disaster of late. A man who owned a printing company was inspired to start another company and together with his partners started to print products that related to shipping dangerous goods.

With the onset of the Transportation of Dangerous Goods Regulations (1985), released by Transport Canada, the company was kept busy producing placards, hazard class labels, signage, and other transportation supplies.

Within a few short years Health Canada introduced WHMIS (1988), where supplier and workplace labels were in high demand. In addition WHMIS introduced Material Safety Data Sheets (MSDS), and with that, the introduction of a new arm of the company. Training was also introduced not only for transportation, but workplace safety as well.

In 1991, The IATA Dangerous Goods regulations, and 49 CFR (remember HM-181?) introduced something new called UN Performance Packaging, or commonly called “POP Packaging” at the time. ICC Compliance Center was one of the first companies to introduce packaging and educate companies on its use.

Bring on the new Continue Reading…

Right to Know
Has Right to Know Gone Too Far?

Right to know regulations are great for employees. They help educate the employees to understand all of the hazards they may be exposed to. OSHA’s philosophy behind their hazard communication standard is based around the “right to know” concept. One key to the system is the training of employees to not only know about a hazard, but to understand the hazard. Some states have implemented individual right to know requirements to provide information to workers above and beyond the federal level.

One state in particular has gone way beyond and branched the right to know into the consumer sector. Yes, I’m talking about California and their Prop 65 legislation. According to the California Office of Environmental Health Hazard Assessment (OEHHA) website (click here), Proposition 65, the Safe Drinking Water and Toxic Enforcement Act of 1986, was enacted as a ballot initiative in November 1986. The proposition was intended to protect California citizens and the State’s drinking water sources from chemicals known to cause cancer, birth defects, or other reproductive harm, and to inform citizens about exposures to such chemicals.

The list of chemicals covered by Prop 65 can be found on OEHHA’s website (click here). Note that they specify coverage to citizens, not just workers. This means that Prop 65 applies everywhere in California, not just workplaces where employees are trained to understand what the information really means. Continue Reading…

Top 10 2015 OSHA Violations Released

Not Just Numbers, But Lives

Once again we find ourselves upon the time of year where OSHA releases the preliminary numbers for the top 10 violations for their calendar year. Remember OSHA’s fiscal year runs October 1 to September 30, this is why these are only preliminary numbers. At the 2015 National Safety Council Congress & Expo held in Atlanta, GA in September OSHA released this information. Data is still being collected and finalized.

The preliminary numbers show that there has been little movement in the top 10 over the past year. This data will be updated and the numbers will change over the next few months. This is what has been released as of September.

Top 10 2015 OSHA Violations

  1. Fall Protection (1926.501) – 6,721
  2. Hazard Communication (1910.1200) – 5,192
  3. Scaffolding (1926.451) – 4,295
  4. Respiratory Protection (1910.134) – 3,305
  5. Control of hazardous energy (Lockout/Tagout) (1910.147) – 3,002
  6. Powered Industrial Trucks (1910.178) – 2,760
  7. Ladders (1926.1053) – 2,489
  8. Electrical – Wiring Methods (1910.305) – 2,404
  9. Machine Guarding (1910.212) – 2,295
  10. Electrical – General Requirements (1910.303) – 1,973

Based on OSHA’s top 10 list from last year, 2014, we can see the power industrial truck violations moved down a spot to the 6th leading violation from the 5th last year. Control of hazardous energy, most commonly referred to as Lockout/Tagout (LOTO) has actually moved up a spot to the 5th leading violation this year up from the 6th spot last year. Continue Reading…

OSHA
OSHA, Newspapers, and Pictures

Before the age of television, cell phones and the internet, news was conveyed via newspapers. In 1911, Arthur Brisbane, a reporter and editor in New York City, used the expression “use a picture. It’s worth a thousand words.” Today, that phrase has been adjusted and is more commonly known as “a picture is worth a thousand words.”

Keep this quote in mind for the next few seconds. Close to my home is a gas station that sustained some damage from a recent summer storm. The awning over the gas tanks had collapsed and was being replaced. As my husband and I drove past the station, I took the following picture.

Fall Prevention

Now my husband and I both work in the safety field, so you can imagine the conversation we had after seeing this. The comment that struck me most was “I’d rather terminate a person for working at elevation without fall protection than have to tell their family that they died.” Think about that statement. It is powerful, honest and true.

For the past few years one of the top ten OSHA violations is in the area of Fall Protection. In 2014, it was the number one violation. Per OSHA 1926.501, Employers must design the workplace in such a way as to keep Employees from falling. Falling can be from overhead platforms, elevated work stations or even into holes.  In fact, the regulation Continue Reading…