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

Safety Tidbit #2.13 - Lockout Devices

Safety Tidbit #2.13 – Lockout Devices

Source:            29CFR1910.147

                        OSHA Safety and Health Topics Page – Control of Hazardous Energy

Without getting into specific exemptions, OSHA’s Lockout-tagout standard covers the servicing and maintenance of machines and equipment in which the unexpected energization or start-up of the machines or equipment, or release of stored energy, could harm employees. I had a question recently about storage of the locks. My client wished to know when not in use, if it was okay to store the lockout devices with their keys still in. I didn’t see any reason why not and told them I would be more worried about losing the keys when not is service.

So a quick rundown about lockout devices from OSHA’s Lockout-Tagout Standard:

·      First all items necessary to secure a piece of equipment must be provided by the employer. [1910.147(c)(5)(i)]

·      Lockout devices and tagout devices shall be singularly identified; shall be the only devices(s) used for controlling energy; shall not be used for other purposes; and shall meet the following requirements:

o   Durable. [1910.147(c)(5)(ii)(A)]

§  Lockout and tagout devices shall be capable of withstanding the environment to which they are exposed for the maximum period of time that exposure is expected. [1910.147(c)(5)(ii)(A)(1)]

§  Tagout devices shall be constructed and printed so that exposure to weather conditions or wet and damp locations will not cause the tag to deteriorate or the message on the tag to become illegible. [[1910.147(c)(5)(ii)(A)(2)]

§  Tags shall not deteriorate when used in corrosive environments such as areas where acid and alkali chemicals are handled and stored. [[1910.147(c)(5)(ii)(A)(3)]

o   Standardized. Lockout and tagout devices shall be standardized within the facility in at least one of the following criteria: Color; shape; or size; and additionally, in the case of tagout devices, print and format shall be standardized. [[1910.147(c)(5)(ii)(B)]

o   Substantial - Lockout devices shall be substantial enough to prevent removal without the use of excessive force or unusual techniques, such as with the use of bolt cutters or other metal cutting tools. [1910.147(c)((5)(ii)(C)(1)]

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

Safety Tidbit #2.12 - Eyewashes - Revisited

Safety Tidbit #2.12 – Eyewashes - Revisited

Source:              OSHA Factsheet 3818-07/2015 Health Effects from Contaminated Water in Eyewash Stations

                        OSHA Safety and Health Topics Page – Eye and Face Protection

                        OSHA Eye and Face Protection eTool

So how many times have you inspected a worksite and told them they needed to install an eyewash?  According to OSHA [1910.151(c)], where the eyes or body of any person may be exposed to injurious corrosive materials, suitable facilities for quick drenching or flushing of the eyes and body shall be provided within the work area for immediate emergency use. Most of this standard makes sense since it comes from the ANSI Z358.1 consensus standard for emergency eyewashes and showers.  However, there are a few points that clients typically ask about when complying with the standard.

First, when is an eyewash necessary? We can understand injurious corrosive materials (I have heard it also referred to as- eye damaging chemicals). The easiest way is just to take a look at the Safety Data Sheet. 

Second, how much water must be provided? ANSI defines suitable facilities as capable of producing 0.4 gallons per minute of water for 15 minutes.  Therefore, the quick drench bottles are not sufficient since mathematically 0.4 GPM for 15 minutes yields approximately 7 gallons of water.  Also, the water must be tepid (60-100 degrees Fahrenheit) since we don’t want to boil or freeze their eyes.

However, I find most questions come from the part about the eyewash location “within the work is for immediate emergency use.”  Rule of thumb has always been if there is a wall, you must go through a door or have other obstacles the placement is no longer accessible for immediate emergency use. However, I received a call from a client that asked how far can it be from the work area.  ANSI specifies 10 seconds or 55 feet, so the old rule of thumb is still accurate. Their argument is that the average person can walk 55 feet in 10 seconds (Boy, I hope so).  Ultimately remember, if there are any obstacles in the workplace you are right back to square one and all bets are off.  Don't forget to think about the state of mind of the injured worker during the emergency is 55 feet too far? 

Lastly, site assessment.  Prior to installing the eyewash, be aware that water and electricity do not mix well together. So, keep an eye out for panel boxes and outlets (e.g. 36 inches from electrical panels).  Also, if installing the eyewash on an exterior wall, protect it from temperature fluxes such as freezing in the winter.

Now that you have determined where to put up your eyewash and have properly installed it you must maintain it.  The eyewash requires periodic draining and refilling (if self-contained) or flushing based on the manufacturer’s requirements to remove sediment and keep pathogens from thriving. Be sure to keep track of this maintenance.

Lastly, is training. You need to identify the eyewash to workers and they know how to get to it in an emergency. Also, teach them how to activate it and know when it is no longer serviceable. A periodic drill or exercise may reinforce how important it is to know how to get to it. Furthermore, my hope is that if a worker gets something in their eyes that a fellow worker will lend a hand and help get them to safety.

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

http://safety-tidbits.blogspot.com/

Safety Tidbit #2.11 – OSHA 300 – What Gets Recorded

Safety Tidbit #2.11 – OSHA 300 – What Gets Recorded

Source:              OSHA Recordkeeping Webpage

So, you now have more than 10 employees and you were told that you must keep an OSHA log. Probably, your first question was – “What is an OSHA log?” Well, an OSHA log is the OSHA 300 log or the log of workplace injuries and illnesses. So now, your second logical question is, and where I wish to spend a little time in this week’s Safety Tidbit, “What injuries and illnesses must be recorded on this log?”

Let’s start with the easy ones are

1. Any work-related fatality;

2. Any work-related injury or illness that

a. results in loss of consciousness,

b. day away from work,

c. restricted work, or

d. transfer to another job;

3. Any work-related diagnosed case of cancer, chronic irreversible diseases, fractured or cracked bones or teeth, and punctured eardrums.

Now the not so easy one is

Any work-related injury or illness requiring medical treatment beyond first aid.

Which begs the question - How does OSHA define first aid, right? Well, OSHA has an answer and it’s a bit lengthy (imagine that). If a workplace injury or illness results in any of the following it is considered first aid:

·       Using a non-prescription medication at nonprescription strength (for medications available in both prescription and non-prescription form, a recommendation by a physician or other licensed health care professional to use a non-prescription medication at prescription strength is considered medical treatment for recordkeeping purposes);

·       Administering tetanus immunizations (other immunizations, such as Hepatitis B vaccine or rabies vaccine, are considered medical treatment); Cleaning, flushing or soaking wounds on the surface of the skin

·       Using wound coverings such as bandages, Band-Aids™, gauze pads, etc.; or using butterfly bandages or Steri-Strips™ (other wound closing devices such as sutures, staples, etc., are considered medical treatment);

·       Using hot or cold therapy;

·       Using any non-rigid means of support, such as elastic bandages, wraps, non-rigid back belts, etc. (devices with rigid stays or other systems designed to immobilize parts of the body are considered medical treatment for recordkeeping purposes);

·       Using temporary immobilization devices while transporting an accident victim (e.g., splints, slings, neck collars, back boards, etc.). Drilling of a fingernail or toenail to relieve pressure, or draining fluid from a blister;

·       Using eye patches;

·       Removing foreign bodies from the eye using only irrigation or a cotton swab;

·       Removing splinters or foreign material from areas other than the eye by irrigation, tweezers, cotton swabs or other simple means;

·       Using finger guards;

·       Using massages (physical therapy or chiropractic treatment are considered medical treatment for recordkeeping purposes); or

·       Drinking fluids for relief of heat stress.

Bottom line, if you can’t take care of it yourself, you probably should be putting it on your OSHA 300 Log. Oh, and if this wasn’t confusing enough, there are also special recording criteria for work-related cases involving: needlesticks and sharps injuries; medical removal; hearing loss; and tuberculosis.

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

Safety Tidbit #2.10 –What’s in a Name - Safety Data Sheets

Safety Tidbit #2.10 –What’s in a Name - Safety Data Sheets

Source:            OSHA Instruction (CPL 02-02-079) Inspection Procedures for the Hazard Communication Standard (HCS 2012)

So what makes a good Safety Data Sheet? But just as importantly, what are the responsibilities of the employer with respect to the safety data sheet? I wish to take on one very small part of the pie called Hazard Communication.

I think everyone knows that the employer shall have a Safety Data Sheet (SDS) for each product in use at their site.  Many went through the arduous process of replacing their Material Safety Data Sheets (MSDSs) for SDSs as manufacturers and distributors made them available.  That was the ideal way.  However, many employers also diligently tracked down the manufacturers and distributors to request SDSs.  However, the “new” HazCom standard (HCS 2012) has been out for a little while now and I’m starting to see companies reverting back to their old habits – namely, not updating their SDSs. Unfortunately, once the employer had the correct SDS they once again put them in their SDS Book and placed the book on the shelf for all to have access.  Done – end of story – or is it…

What happens when the employer buys a new brand of the same product? Or the manufacturer changes the product or what if the manufacturer itself changes names. The named party on the SDS must be the same as the named party for the label. If there is a different company name on the SDS versus the label, the company that changed the name is responsible for both. Bottom line, the named party (manufacturer/distributer) must be the same between the label and the SDS two names need to be the same. For instance:

1. If the employer is maintaining one SDS for a particular chemical but uses that same chemical from a different manufacturer or importer without obtaining/maintaining the SDS from the new manufacturer or importer, the employer is not compliant.

2. If the SDS received from the manufacturer, importer or distributor has a different responsible party name than that on the product label, the employer must make a documented good faith effort to receive the appropriate SDS or they are not compliant.

3. Interestingly if you encounter a situation where the manufacturer, importer or distributor is providing SDSs that list a different responsible party than that on the label, referral procedures outlined in Appendix G of OSHA Enforcement Instruction must be followed.

So be wary, in today’s ever-changing business climate of company mergers and new start-ups, names can change and your client may find that their SDSs are no longer accurate. Rule of thumb – at least annually the employer should review their Hazard Communication Program which includes reviewing all of their hazardous materials and the respective SDSs.  However, reviewing the SDS for accuracy each time the client receives a new shipment allows for a proper hazard assessment and also ensures compliance with the law.

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