Safety Tidbit #2.16 – A Little Bit on Hazardous Chemical Labeling

Safety Tidbit #2.16 – A Little Bit on Hazardous Chemical Labeling

Sources:           OSHA Hazard Communication Standard

                        OSHA’s Hazard Communication Webpage

In almost every workplace that I visit, I find unlabeled containers of hazardous materials. OSHA’s Hazard Communication Standard requires the employer to label, tag or mark each container of hazardous chemicals in the workplace. [1910.1200(f)(6)] They don’t care how big or small the container, it has to labeled, tagged or marked. Also, OSHA prohibits the employer from defacing or removing any labels and if they do they must immediately relabel it. [1910.1200(f)(9)]

However, two exemptions that come into play, first, if the hazardous chemicals are transferred from a labeled container, and are intended only for the immediate use of the employee who performs the transfer. [1910.1200(f)(8)] Make sure it’s for immediate use, though. If the container is left somewhere then you are out of compliance, or, if more than one person is around the chemical, then you need to label the container. Second, and this one is a bit longer, the employer may use signs, placards, process sheets, batch tickets, operating procedures, or other such written materials instead of affixing labels to individual stationary process containers. So long as the alternative method identifies the containers to which it is applicable and conveys the same information as the label. [1910.1200(f)(7)] The employer must ensure the written materials are “readily accessible” to the employees in their work area throughout each work shift. The proof is in the pudding for this part, reality, can the employee explain what the hazards are in the container? If so, then you’re golden! If not, label it.

So what is required to be on the label? Well you’re not going to like this but here goes:

•       Product identifier

•       Signal word

•       Hazard statement(s)

•       Pictogram(s)

•       Precautionary statement(s) and,

•       Name, address, and telephone number of the chemical manufacturer, importer, or another responsible party

Furthermore, the employer shall ensure that workplace labels or other forms of warning are legible, in English, and prominently displayed on the container, or readily available in the work area throughout each work shift. Employers having employees who speak other languages may add the information in their language to the material presented, as long as the information is presented in English as well. [1910.1200(f)(10)]

Lastly, chemical manufacturers, importers, distributors, or employers who become newly aware of any significant information regarding the hazards of a chemical shall revise the labels. The revision must be done within six months of becoming aware of the new information. [1910.1200(f)(11)]

Hope this was helpful and thanks for reading my Safety Tidbits ~ Bryan

Safety Tidbit #2.15 - Tuberculosis and PPD

Safety Tidbit #2.15 – Tuberculosis and PPD

Source:            OSHA Safety and Health Topics Page - Tuberculosis

                        OSHA Instruction – Enforcement Procedures and Scheduling for Occupational Exposure to Tuberculosis

In 2010, a total of 11,182 tuberculosis (TB) cases were reported in the United States. If you work in one of the following types of facilities you are at risk of Tuberculosis exposure: Inpatient Medical Facilities, Outpatient settings, or some other nontraditional facility.

·      Inpatient settings include: Patient rooms, emergency departments, intensive care units, surgical units, laboratories, laboratory procedure areas, bronchoscopy suites, sputum induction or inhalation/respiratory therapy rooms, autopsy suites, and embalming rooms.

·      Outpatient settings include: TB treatment facilities, medical offices, ambulatory-care settings, dialysis units, and dental-care settings.

·      Nontraditional facility-based settings include: Emergency medical service (EMS) facilities, medical settings in correctional facilities, long-term care settings (e.g., hospices, skilled nursing facilities), drug treatment centers, and homeless shelters.

These facilities must have a TB Exposure Control Plan. One important part of the TB Exposure Control Plan is Medical surveillance and the need for periodic screening (e.g., Purified Protein Derivative (PPD) or TB Skin Test (TST) or blood analysis for M. tuberculosis (BAMT)). The periodicity of screening is based on the risk potential for disease transmission (low, medium or ongoing).

In low risk settings, annual screening is not necessary; however, if an exposure to a person with, or specimen containing, TB occurs, the employer should provide screening and update the risk assessment in accord with the 2005 CDC Guidelines

In medium risk settings, screening should be provided at least every year. In setting where there is the potential for ongoing transmission, workers should be tested every 8-10 weeks until a determination is made that there is no more an ongoing transmission potential. At which point, the classification moves to medium and annual screening is accomplished.

Training of employees with exposure potential is required so they understand the risks posed of undiagnosed individuals and the control procedures to be followed. Since most of the facilities with TB exposure potential already fall under OSHA’s Bloodborne Pathogens standard incorporating TB Exposure Control into the required annual BBP training is convenient.   

Hope this was helpful and thanks for reading my Safety Tidbits ~ Bryan

Safety Tidbit #2.14 - Steel-toed shoes Yes or No?

Safety Tidbit #2.14 – Steel-toed shoes Yes or No?

Source:            OSHA 29CFR1910.136 Foot Protection

                        OSHA 29CFR1910.132 Personal Protective Equipment

The Bureau of Labor Statistics reported 5% of all recordable injuries were related to the feet and I am sure all of you fielded the question: “Does OSHA require steel-toed shoes for my workplace?” And the answer being “yes” and “no.”  However, to really answer the question, we need to take a step back. OSHA requires the employer to assess the workplace to determine if hazards are present, or are likely to be present, which necessitate the use of personal protective equipment (PPE). [1910.132(d)(1)] Furthermore, the employer must certify, in writing, that the assessment has been performed and note the date and the workplace evaluated. [1910.132(d)(2)] Meaning the employer followed a systematic procedure which includes intentional thinking about the hazard and how to minimize its effect on the worker.  In this case through the use of the last line of defense or personal protective equipment.  Note: I’m not going to discuss actually reducing or getting rid of the hazard using any one of the other control measures in the Hierarchy of Control toolbox.

So back to the client’s question: Does OSHA require steel-toes shoes in my workplace?  Well there are approximately 18.2 million businesses in the United States.  So OSHA won’t actually say if steel-toed shoes are required in your particular workplace also they don’t prescribe personal protective equipment necessary based on type of workplace again because of potential variability. However, they do say that when working in areas where there is a danger of foot injuries or rolling objects, or objects piercing the sole the employer shall ensure that each affected employee uses protective footwear [1910.136(a)].

So when you assessed the workplace and the operations performed in the workplace and you identified the potential for your employees to injure their feet, your answer is “yes” and you need to require some sort of protective footwear.  Furthermore, if, upon closer inspection, you identified that the danger to your employees’ feet involved crushing possibly by a rollover or from dropping items on their feet then you need to require steel-toed shoes. Actually, more correctly you need to require shoes meeting the American National Standards Institute (ANSI) American National Standard for Personal Protection—Protective Footwear ANSI Z41-1999 and ASTM F2413-05 Standard Specification for Performance Requirements for Protective Footwear.

Last note, make sure you check your employees’ shoes periodically to ensure they are in good repair and will work in accordance with the ANSI and ASTM specifications as designed by the manufacturer.  You are responsible to train your employees on proper use and care of their personal protective equipment.

Hope this was helpful and thanks for reading my Safety Tidbits ~ Bryan