OSHA Revises Hazard Communication Standard – One Year Later (TRN Update)

safety-blog-OHSA-HAZARDCOMM2013

From Cliff Gerbick, CSP (The Reserves Network Director of Safety)

It has been approximately one year since the  Occupational Safety and Health Administration (OSHA) revised the Hazard Communication Standard (29 CFR 1910.1200) to align it with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS).  Now that employers have had an opportunity to familiarize themselves with the changes they should be well prepared for the upcoming requirements that are going into effect in 2013.

By December 1, 2013, all employers must train all of their employees on the new requirements of 29 CFR 1910.1200.  The main items in which employees must be trained are the Safety Data Sheet (SDS) format and the pictograms that OSHA will be utilizing to identify hazards.  Additional items are required further down the line but December 1, 2013 is the first in a series of deadlines that both manufacturers and employers must meet to be in compliance with the new standard.

For further reading on 29 CFR 1910.1200 and GHS, please visit: (LINK: osha.gov)

Cliff Gerbick is the Director of Safety for The Reserves Network, a provider of “Total Staffing Solutions” in the office, industrial, professional and technical markets. To contact Cliff, email cgerbick@TRNstaffing.com.

Visit the The Reserves Network’s website at www.TRNstaffing.com.

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OSHA Revises Hazard Communication Standard (TRN Safety Alert)

From Cliff Gerbick, ASP (The Reserves Network Director of Safety)

The Occupational Safety and Health Administration (OSHA) has revised its Hazard Communication Standard (29 CFR 1910.1200) to align it with the United Nations global chemical labeling system. In a process that began decades ago, OSHA has at last published the final rule that will update the current standard to mirror the Globally Harmonized System of Classification and Labeling of Chemicals (GHS).

The updates to the standard will provide chemical manufacturers a proscribed format for identifying the hazards associated with chemicals. Currently, OSHA requires all employers to maintain Material Safety Data Sheets (MSDS) for all hazardous chemicals in the workplace.

While this requirement will not change, the format in which MSDS are organized will be standardized and must contain the information in the following order:

Section 1. Identification
Section 2. Hazard(s) identification
Section 3. Composition/information on ingredients
Section 4. First-Aid measures
Section 5. Fire-fighting measures
Section 6. Accidental release measures
Section 7. Handling and storage
Section 8. Exposure controls/personal protection
Section 9. Physical and chemical properties
Section 10. Stability and reactivity
Section 11. Toxicological information
Section 12. Ecological information
Section 13. Disposal considerations
Section 14. Transport information
Section 15. Regulatory information
Section 16. Other information, including date of preparation or last revision

In addition, OSHA is phasing out the use of MSDS and will now use the term Safety Data Sheet (SDS).

The other big change to the current standard is the standardized use of pictograms to identify the hazards associated with chemicals. There are nine pictograms used in the GHS and OSHA will adopt eight of them.  The ninth pictogram is in regards to environmental effects and since OSHA does not have jurisdiction overall environmental issues, it will not be used. The pictograms are:

HCS Pictograms and Hazards

Health Hazard

Flame

Exclamation Mark

• Carcinogen
• Mutagenicity
• Reproductive Toxicity
• Respiratory Sensitizer
• Target Organ Toxicity
• Aspiration Toxicity
• Flammables
• Pyrophorics
• Self-Heating
• Emits Flammable Gas
• Self-Reactives
• Organic Peroxides
• Irritant (skin and eye)
• Skin Sensitizer
• Acute Toxicity (harmful)
• Narcotic Effects
• Respiratory Tract Irritant
• Hazardous to Ozone Layer
(Non Mandatory)

Gas Cylinder

Corrosion

Exploding Bomb

• Gases under Pressure • Skin Corrosion/ burns
• Eye Damage
• Corrosive to Metals
• Explosives
• Self-Reactives
• Organic Peroxides

Flame over Circle

Environment
(Non Mandatory)

Skull and Crossbones

• Oxidizers • Aquatic Toxicity • Acute Toxicity (fatal or toxic)

OSHA has developed a timeline for all employers to be in compliance with the standard, culminating in 2016. The first deadline in the timeline, December 1, 2013, requires employers to train all employees on the new label elements (pictograms) and SDS format.

Other deadlines are as follows:

Effective Completion Date

Requirement(s)

Who

December 1, 2013 Train employees on the new label elements and safety data sheet (SDS) format. Employers
June 1, 2015

December 1, 2015

Compliance with all modified provisions of this final rule, except:
The Distributor shall not ship containers labeled by the chemical manufacturer or importer unless it is a GHS label.
Chemical manufacturers, importers, distributors and employers
June 1, 2016 Update alternative workplace labeling and hazard communication program as necessary, and provide additional employee training for newly identified physical or health hazards. Employers
Transition period to the Effective Completion Dates noted above. May comply with either 29 CFR 1910.1200 (the final standard), or the current standard, or both. Chemical manufacturers, importers, distributors and employers

OSHA estimates the revised standard will prevent an estimated 585 injuries and illnesses annually. It will reduce trade barriers and result in estimated annualized benefits in productivity improvements for American businesses that regularly handle, store and use hazardous chemicals, as well as cost savings of $32.2 million for American businesses that periodically update safety data sheets and labels for chemicals covered under the standard.

Cliff Gerbick is the Director of Safety for The Reserves Network, a provider of “Total Staffing Solutions” in the office, industrial, professional and technical markets. To contact Cliff, email cgerbick@trnstaffing.com.

OSHA Respiratory Protection Awareness (TRN Safety Alert)

From Cliff Gerbick, ASP (The Reserves Network Director of Safety)

The Occupational Safety and Health Administration (OSHA) has published a series of videos which will help employers understand the OSHA Respiratory Protection Standard (29 CFR 1910.134). The videos, available in both English and Spanish, provide information that employers can use to determine their individual needs as required by the standard.

As always, employers are required to, when possible, eliminate hazards through Engineering Controls and Administrative/ Work Practice Controls. In the event the hazard cannot be eliminated or controlled through those methods, the videos walk employers through the steps they need to take to protect their employees from respiratory hazards.

The videos cover the following topics:

  • Respirator Protection in General Industry
  • Respirator Protection in Construction
  • Respirator Types
  • Respirator Fit Testing
  • Maintenance and Care of Respirators
  • Medical Evaluations for Workers Who Use Respirators
  • Respiratory Training Requirements
  • Voluntary Use of Respirators

Videos can be accessed by clicking here!

For more information from OSHA on this video catalog click here!

Cliff Gerbick is the Director of Safety for The Reserves Network, a provider of “Total Staffing Solutions” in the office, industrial, professional and technical markets. To contact Cliff, email cgerbick@trnstaffing.com.

OSHA’s Top 10 Violations of Fiscal Year 2011 (TRN Safety Alert)

From Cliff Gerbick, ASP (The Reserves Network Director of Safety)

OSHA has released its annual list of the top 10 workplace violations for fiscal year 2011 (October 1, 2010 – September 30, 2011). Annually the list contains mostly the same standards, only switching positions, and this year is no exception.

The Top 10 Citations for FY 2011 are…

1. Fall Protection – General Requirements
Standard 1926.501
Total Violations: 7,129

Top Sections Cited

1926.501(b)(13) – Fall protection requirements for residential construction.
1926.501(b)(1) – Requires fall protection for walking/working surfaces 6 feet or higher.
1926.501(b)(10) – Fall protection requirements for roofing activities on low-slope roofs.

2. Scaffolding – General Requirements
Standard 1926.451
Total Violations: 7,069

Top Sections Cited
1926.451(g)(1) – Fall protection on scaffolds higher than 10 feet above a lower level.
1926.451(b)(1) – Requires each platform on all working levels to be fully planked or decked between the front uprights and the guardrail supports.
1926.451(e)(1) – Access requirements when platforms are more than 2 feet above or below a point of access; prohibits use of crossbars as an access means.

3. Hazard Communication
Standard 1910.1200
Total Violations: 6,538

Top Sections Cited
1910.1200(e)(1) – Requires a written Hazard Communication program.
1910.1200(h)(1) – Requires informing employees of hazardous chemicals, and training employees on protections form the hazards.
1910.1200(f)(5) – Requirements for labels on hazardous chemicals.
1910.1200(g)(1) – Contains requirements for Material Safety Data Sheets.
1910.1200(g)(8) – Requirements to maintain copies of Material Safety Data Sheets that are easily accessible to employees.

4. Respiratory Protection
Standard 1910.134
Total Violations: 3,944

Top Sections Cited
1910.134(c)(1) – Requires the employer to develop a written respiratory protection program.
1910.134(e)(1) – Sets the minimum requirements for the medical evaluation required to determine if an employee is fit to use a respirator.
1910.134(c)(2) – Requirements for voluntary use of respirators.
1910.134(f) – Requires fit testing and specifies the types of fit testing allowed, procedures for fit testing and how the results must be uses.

5. Lockout/Tagout
Standard 1910.147
Total Violations: 3,639

Top Sections Cited
1910.147(c)(4) – Requirements in energy control procedures.
1910.147(c)(6) – Requirements to periodically inspect the energy control procedures.
1910.147(c)(7) – Training and communication requirements.
1910.147(c)(1) – Energy control program requirements.
1910.147(d)(4) – Requirements for the application of Lockout/Tagout devices.

6. Electrical – Wiring Methods
Standard 1910.305
Total Violations: 3,584

Top Sections Cited
1910.305(g)(1) – Concerns the use of flexible cords and cables.
1910.305(b)(1) – Requirements for conductors entering boxes, cabinets and fittings.
1910.305(g)(2) – Covers identification, splices and termination.
1910.305(b)(2) – Requirements on covers and canopies.
1910.305(a)(1) – Requirements for temporary wiring.

7. Powered Industrial Trucks
Standard 1910.178
Total Violations: 3,432

Top Sections Cited
1910.178(l)(1) – Safe operation of industrial trucks.
1910.178(l)(4) – Refresher training and evaluation requirements.
1910.178(l)(6) – Employer shall certify that each operator has been trained and evaluated as required.
1910.178(p)(1) – Requires industrial trucks in need of repair to be taken out of service until restored to safe operating condition.
1910.178(q)(7) – Requirements for examining industrial trucks before they are placed into service.

8. Ladders
Standard 1926.1053
Total Violations: 3,244

Top Sections Cited
1926.1053(b)(1) – Requires ladder side rails to extend at least 3 feet above an upper landing surface, or be secured at its top to a rigid support.
1926.1053(b)(4) – Use of ladders is restricted to only the purpose for which they were designed.
1926.1053(b)(13) – Prohibits using the top or top step of a stepladder as a setup.
1926.1053(b)(16) – Requires defective ladders to be marked with a “Do Not Use” notification and withdrawn from service until repaired.
1926.1053(b)(22) – Prohibits an employee from carrying any object that may cause the employee to lose balance and fall.

9. Electrical – General Requirements
Standard 1910.303
Total Violations: 2,863

Top Sections Cited
1910.303(b)(2) – Requires listed or labeled equipment to be installed and used in accordance with the instructions included in the listing or labeling.
1910.303(g)(1) – Sufficient access and working space is required for all electric equipment to allow safe operation and maintenance of the equipment.
1910.303(g)(2) – Guarding live parts.
1910.303(b)(1) – Requires electrical equipment to be free from recognized hazards likely to cause death of serious physical harm.

10. Machine Guarding – General Requirements
Standard 1910.212
Total Violations: 2,728

Top Sections Cited
1910.212(a)(1) – Requirements for guarding to protect employees in the machine area from hazards.
1910.212(a)(3) – Requirement concerning the point of operation guarding.
1910.212(b) – Requires the secure anchoring of machinery for machines at a fixed location.
1910.212(a)(5) – Specifies requirements for guarding blades.
1910.212(a)(2) – General requirements for the location of a machine guard.

Cliff Gerbick is the Director of Safety for The Reserves Network, a provider of “Total Staffing Solutions” in the office, industrial, professional and technical markets. To contact Cliff, email cgerbick@trnstaffing.com.

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