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.

Common Misconceptions Regarding Powered Industrial Truck Training (TRN Safety Alert)

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

One of the many frequent misconceptions regarding Powered Industrial Trucks (PIT) has to do with operator training. OSHA requires business to train, observe and certify all PIT operators. With that said, it needs to be restated that businesses must train, observe and certify all PIT operators and not rely on the training from an employee’s previous employer. Here are some of the reasons operators must be certified internally.

1. Forklift Certifications do not transfer from one company to another.

Each company is required to develop and implement a Powered Industrial Truck (PIT) Written Program. PIT is an OSHA term for forklifts, powered pallet jacks, etc. The Program must outline: How that company will oversee the usage of PIT’s; the maintenance of PIT’s; and also provide training and certification of operators. OSHA does not state that companies must use the same program, only that companies must develop a program that covers certain items. Therefore, if an employee was Forklift Certified at ABC Company, it does not certify them at any other company because all companies should have written programs specific to their needs. As a result, when a company hires an employee who was certified at ABC Company, it does not make them certified at the new company.

2. OSHA has specific requirements for training.

OSHA has outlined in the Powered Industrial Truck Standard (CFR 1910.178) which topics need to be covered in the classroom portion of the training.

Highlights of the truck-related requirements are:

• Operating instructions, warnings and precautions for the types of truck the operator will be authorized to operate
• Truck controls and instrumentation (IE: Where they are located, what they do and how they work)
• Fork and attachment adaptation, operation and use limitations
• Vehicle capacity

Some workplace-related requirements include:

• Surface conditions where the vehicle will operate
• Pedestrian traffic in areas where the vehicles will operate
• Ramps and other sloped surfaces that could affect the vehicle’s stability and performance
• Other unique or potentially hazardous environmental conditions in the workplace that could affect safe operation

These topic requirements are specific to each individual employer, and one of the primary reasons PIT certifications do not transfer from company-to-company.

3. Trainers have to be knowledgeable on the subject matter.

Since the training topics and requirements are so specific, the trainer needs to have first-hand knowledge of both the Powered Industrial Truck and the operational environment of the PIT. Typically this is information that is only known by employees of the company, therefore third parties would not be sufficient trainers unless they knew all of the ins and outs of the company they are training for.

4. Trainers must observe the operator in regular working environment.

Another training requirement is that instructors must observe and evaluate the operator’s performance in the workplace. Most safety and health professionals know that they must observe PIT operators during their initial certification process, but they should also be continuously observing operators in order to make sure they are following all rules and procedures after they have been certified. This ensures that the operator was not only operating the PIT correctly during the certification phase, but has continued to operate it safety thereafter.

There is a lot of time, knowledge and detail required in providing OSHA compliant training – particularly Forklift Certification. Make sure that you are following all of the requirements of CFR 1910.178 to give your employees all of the knowledge and skills to operate a Powered Industrial Truck safely in your facility.

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 Issues New National Emphasis Program (TRN Safety Alert)

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

The Occupational Safety and Health Administration (OSHA) has issued a new National Emphasis Program (NEP) for chemical facilities. The NEP is focused on protecting workings from the risks associated with catastrophic releases of highly hazardous chemicals.

The new NEP replaces a 2009 pilot Chemical Facility National Emphasis Program which covered certain regions across the United States. The new program is a nationwide program that establishes updated polices and procedures for inspecting workplaces that are covered under OSHA’s Process Safety Management (PSM) standard. The PSM standard covers employees who have threshold quantities of highly hazardous chemicals in their workplaces. The purpose of the new NEP is to give inspectors better tools to conduct inspections of facilities that are likely to have highly hazardous chemicals in quantities covered by OSHA.

For further information on the National Emphasis Program and Process Safety Management, please visit www.osha.gov.

For information on additional OSHA National Emphasis Programs, please (Click Here for OSHA Programs)

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.