A question was posted on Linkedin in regards to how to handle mandatory information requirements regarding MSDS when the general workforce may not understand them. It was asserted that there was a disconnect between the language of the documents and the education level of the workers using them.

Safetec Account Manager, Trevor Wichmann, answered:

I agree, Lynn. There is a disconnect - especially considering that there is not a standardized MSDS format and that they are typically authored with a focus of meeting compliance requirements rather than ease-of-use.

As previously mentioned, it is critical to educate users at their comprehension level with a training (and refresher) program (i.e. how to locate the appropriate MSDS for the specific manufacturer's product they are working with, how to read the MSDS, what the specific safety precautions/potential hazards are of the products/chemicals they may be working with directly, etc.).

Depending on internal resources, developing a training program can be accomplished by creating a part/full-time internal position or hiring out (i.e. consultants, safety-specific training organizations, etc.) and a trainer should not only be highly knowledgeable, but capable of translating a scientific document to any audience.

Another critical piece is to establish a pervasive, simple way to access the MSDSs. This can be accomplished via a paper-based or computer-based MSDS management system and depends on the specific MSDS collection characteristics (i.e number of documents, churn, etc.), internal access points, and company resources. The collection should be well organized, regularly maintained, and easy to search, so that when someone needs an MSDS because they can just accidentally drank a quart of paint they can find the exact one they need very quickly.

For example, we help our customers by providing web-based access to a company's specific MSDS collection. Users have access to the original MSDS document as well as information that we've captured that is presented in a standard, simplified format. In addition, company-specific common names can be associated to an MSDS, so that users can search for and identify a product by what they call it (i.e. 01295 Havoline Formula 3 SAE 5W-30 might simply be "forklift oil" to them).

It looks like the CSB will, grudgingly, increase investigations into industrial chemical accidents. It also seems that the EPA will enter into the picture to oversee the effort.

Of course, this will depend of funding but the end result may require more chemical reporting on behalf of the facility.

Here is a quote from the story written by Jeff Johnson of Chemical & Engineering News:

"The Chemical Safety & Hazard Investigation Board (CSB) should quintuple its chemical accident investigations, Government Accountability Office auditors say in a new report. GAO notes that the board—an independent agency charged with investigating industrial chemical accidents—last year identified some 31 fatal accidents warranting a full investigation but examined only six of them."

Release date: 07/24/2008
Contact Information: Mary Simms, 415-947-4270 simms.mary@epa.gov

(7/24/08) SAN FRANCISCO – The U.S. Environmental Protection Agency has waived penalties against the Swiss American Sausage Company, a subsidiary of Hormel Food Corporation, located in Lathrop, Calif., after the facility voluntarily reported federal Clean Air Act Risk Management Program violations.

“The EPA is pleased with the responsible action taken by the Swiss American Sausage Company -- it’s the responsibility of all companies to do the required reporting," said Keith Takata, Superfund Division director in the EPA’s Pacific Southwest region. "It’s critical that facilities using chemicals follow our chemical accident prevention rules to protect the health and safety of area residents, emergency response personnel, and the environment."

The San Joaquin County-based food storage and distribution facility voluntarily disclosed to the EPA that it had not submitted a risk management plan, as required by the Clean Air Act. Swiss American Sausage self-disclosed the violations in accordance with EPA’s Incentives for Self-Policing: Discovery, Disclosure, Correction and Prevention of Violations Policy, commonly referred to as the ‘audit policy.’ The EPA has the discretion to eliminate penalties if it determines that a respondent has satisfied certain conditions set forth in the audit policy.

Federal regulations require all facilities using hazardous substances above specified thresholds to develop chemical risk management plans. Risk management plans help prevent chemical releases and prompt detection and response when chemical releases do occur. At this facility, at least 16,000 pounds of anhydrous ammonia used in the refrigeration system mandated a risk management plan.
The EPA may reduce penalties up to 100 percent for violations that are voluntarily discovered, promptly disclosed to the agency and quickly corrected. Swiss American Sausage very quickly corrected and self-disclosed its violation.

A risk management plan must include an assessment of the potential effects of an accidental release, history of accidents over the past five years and employee training. The plan must also include an emergency response program that outlines procedures for informing the public and response agencies, such as the police and fire departments, in the event of an accident.

The risk management program requires an emergency response strategy, evaluation of a worst case and probable case chemical release, and a prevention program that includes operator training, a review of the hazards associated with using toxic or flammable substances, operating procedures and equipment maintenance.

Labels: chemical approval, chemical compliance, chemical compliance manager, chemical inventory, chemical management, EPA, inspections, Reports, workflow

Release date: 08/01/2008

Contact Information: Dave Ryan, (202) 564-4355 / ryan.dave@epa.gov

(Washington, D.C. – August 1, 2008) EPA is launching an interim policy that offers incentives to new owners who correct environmental violations at recently-acquired regulated facilities. Under the interim policy, new owners may receive lower penalties than long-time owners.

“This is an opportunity for new owners to make a ‘clean start’ by correcting environmental problems that began under the previous owner’s watch,” said Granta Y. Nakayama, assistant administrator of EPA’s Office of Enforcement and Compliance Assurance. “This can lead to big gains for the public and the environment.”

Under the current EPA Audit Policy, the Agency offers reduced penalties to companies that self-audit their facilities, promptly disclose and correct any violations discovered, and take steps to prevent future violations. Under the interim policy announced today, an owner who acquires a new facility may get additional penalty reductions from disclosing an even greater range of violations.

EPA encourages companies with newly acquired facilities to examine compliance of their new facilities, correct environmental problems that began before acquisition, make changes to ensure they stay in compliance, and reduce pollutants going forward.

Since 1995, more than 3,500 companies at nearly 10,000 facilities have used the audit policy to disclose and resolve violations, most of which involved recordkeeping and reporting. With the incentives announced today, EPA hopes to encourage new owners to disclose violations that, once corrected, will yield significant environmental benefit and direct pollution reductions.

The new interim policy will be in effect immediately and EPA will accept public comment until October 30, 2008. The policy may change in light of these comments.

Labels: chemical compliance, chemical compliance manager, chemical inventory, chemical management, EPA, material safety data sheets, MSDS, penalties, Reports

You never know when they will come knocking! If your ducks are scattered you had better get them in a row beforehand or it could mean violations and possible fines.

There are steps you can take to be ready if you do get inspected. Loren Faulkner has written a good article on the topic. Below is an exerpt:

Why would OSHA conduct an inspection?

Somebody has made a complaint about worksite safety or health--perhaps a current or former employee, or perhaps even a resident from the community who is worried about hazardous materials or some other safety or health hazard that could affect the area surrounding your company.

A fatality has occurred in your facility.

It's a regularly scheduled inspection. This is most likely if you are in a high-hazard industry. Thousands of high-hazard worksites are targeted for unannounced, comprehensive safety and health inspections every year.

It's a follow-up visit, perhaps to determine if prior violations have been corrected.

What are inspectors looking for? Inspectors are looking for violations of OSHA standards.

8 Top Violations

The exact kind of violations depends on the nature of your operations and the particular hazards of your workplace. However, you and your employees should be aware that last year's list of the most-often-cited OSHA violations for general industry featured safety and health problems related to:

Machine guarding
Lockout/tagout
Ladders and scaffolding
Hazardous chemicals
Respiratory protection
Fall protection
Electrical safety
Powered industrial trucks

For the rest of the article click here

Labels: chemical compliance, chemical compliance manager, chemical inventory, chemical management, citations, osha, penalties

Safetec has added a new chemical list to the regulatory database: Substances of Very High Concern. This list is provided by the ECHA (European Chemicals Agency) as part of the overall REACH initiative. This is just a proposed list and is likely to be changed over time.

Substances of very high concern are defined in Article 57 of Regulation (EC) No 1907/2006 (“the REACH Regulation”) and include substances which are:

Carcinogenic, Mutagenic or toxic to Reproduction (CMR), meeting the criteria for classification in category 1 or 2 in accordance with Directive 67/548/EEC,

Persistent, Bioaccumulative and Toxic (PBT) or very Persistent and very Bioaccumulative (vPvB) according to the criteria in Annex XIII of the REACH Regulation, and/or

Identified, on a case-by-case basis, from scientific evidence as causing probable serious effects to human health or the environment of an equivalent level of concern as those above (e.g. endocrine disrupters)

Safetec’s technology supports the regulations and requirements of today’s primary international regulatory agencies, including:

U.S. – OSHA, Hazard Communication Standard

Canada – Health Canada - WHMIS

EU – Commission Regulation (EC) No 2001/58, REACH

Australia – ASCC - WorkSafe

UN – Globally Harmonized System (GHS)

Labels: chemical compliance, chemical management, internationalization, material safety data sheets, MSDS, reach

CCM V8 now supports MSDS Classification searching from the standard MSDS Search page. We have also added viewing and editing for MSDS Classifications. Look for this and other features in the CCM next release in a few weeks!

Utilizing receipts for tracking usage is a great way to simplify the inventory process because received quantities can be tracked at the time they are received instead of manually incrementing a running total in an inventory which occurs every month or so.

The one downside of receipts is that it is common to miss some receipts as they come in. The new MSDS Inventory / Receipt Comparison report allows balancing inventory values against receipt values. This report can help identify missing receipts by pointing out where the increase in inventory quantity is greater than the received amount.

Another report was also added but it is a NRF customer specific report called Chemical Inventory Quantities (Pounds) Style R1.

Look for both of these reports in the next release. These reports both appear in the Special Inventory Reports dropdown in the Inventory Reports menu.

Labels: chemical compliance manager, chemical inventory, chemical management

July 1, 2008
Surfing for Safety
By Laura Walter

From standards and training to products and blogs, the Internet resources available to the safety community are growing, changing and becoming more sophisticated.
The Internet has done a lot more than provide alternative ways to shop, date, communicate or read the news: it also has a big impact on the safety industry and the tools available to EHS professionals.

These days, you can train your employees, determine the best PPE for the job, take care of recordkeeping and MSDS management and learn about safety regulations without leaving your desk. All you need is a computer, an Internet connection and the determination to stay focused in the face of all those online distractions.

Occupational Hazards takes a look at just some of the online offerings within the safety community to help you surf for the best information.

Into the Depths
Andrea Okun, the deputy director of the education and information division for the National Institute for Occupational Safety and Health (NIOSH), says the NIOSH site (http://www.cdc.gov/niosh
) contains a broad range of safety resources arranged into topic pages and program-based sectors. At first glance, visitors may not comprehend just how much information is on the site.

“If you look at our Web site, I’m not sure you know how deep it is, how much information is really there,” Okun says.

The NIOSH site logs more than 22,000 hits a day, with the ergonomics and stress-at-work pages racking up the most hits. The NIOSH Pocket Guide, the Spanish site and firefighter and state fatality reports also are among the most commonly accessed pages. Okun adds that the NIOSHTIC-2 bibliographic database, which provides access to all NIOSH documents, publications, articles, grant reports and other products, is one of the site’s key tools (http://www2a.cdc.gov/nioshtic-2/default.asp).

NIOSH manages to avoid information overload on the site through communication and organization. Okun points out that NIOSH staff are committed to making sure the site is organized in the best way to be accessible for site visitors. She says NIOSH conducts regular user assessments and makes adjustments as necessary.

“We really do want to know what works and doesn’t work. That’s very important to us,” Okun explains. “We think of ourselves as a service to provide this information and provide it in the most useful way possible.”
Like NIOSH, OSHA’s site (http://www.osha.gov) offers a wealth of health and safety information. The site contains over 400,000 pages of agency, program and technical information, as well as records on 3.6 million inspections. The site logs more than 8 million visitor sessions per month and exceeded 1 billion hits during FY 2007.

According to OSHA, the site’s most popular resources include regulations, inspection searches, publications and safety and health topics. Training resources and classes, Federal Register notices, eTools and recordkeeping forms also are heavy hitters.

“The A-Z index is the best place to start,” advised an OSHA representative. A keyword search and an advanced search option also help make the site’s resources easily accessible. Safety and health topic pages, meanwhile, consolidate the site’s information by arranging data by type of hazard or injury.

Associations
Safety associations also must have a strong online presence to provide their members and visitors with the best information possible. According to an American Industrial Hygiene Association (AIHA) representative, the AIHA site (http://www.aiha.org) is tailored for various audiences, including members, nonmembers, EHS professionals and general consumers.

The AIHA site contains a members-only section, job search, marketplace, scientific journal, member magazine, consultants search, membership directory and salary calculator. The OEHS Library Central, which is AIHA’s comprehensive, digital library of knowledge, information and research for occupational and environmental health and safety professionals, also is a popular part of the site.

E-commerce Marketing Manager Jon Schwerman of the American Society of Safety Engineers (ASSE) says this association site, http://www.asse.org, stands out from the pack by offering visitors the best and most relevant industry news.

“From a safety perspective, we try to cover the most important, current news,” Schwerman says. “We’re trying to get the most important, the most salient information out immediately.”

Schwerman points out that the site contains two main sections: professional development and ASSE membership area information. The newsroom and members-only sections also are popular parts of the site, which sees approximately 125,000 unique visitors every month.

In addition, ASSE currently is developing the Body of Knowledge, which Schwerman describes as a wiki-based tool for the safety and health community to discuss what defines various disciplines within the industry. While Schwerman says other associations’ Web-based tools are more comparable to libraries, the Body of Knowledge will be interactive. The tool will be launched in phases, with the first phase introduced roughly within a year.

Schwerman added that it’s key for site visitors to have a voice. “We’re letting the customer decide what should be on the site,” he says. “I think that bodes well for the future of our navigation, our content and ultimately, getting more members to join and realize we are a huge resource for them.”

Virtual Training
Gone are the days when safety professionals had to rely only on in-classroom training to ensure their workers complied with health and safety regulations. Today, online training can supplement or replace some types of classroom training, providing a convenient alternative without losing valuable on-the-job time.

“The big difference is that you learn at your own pace and your own speed,” says Justus Heuer, the direct channel manager for OSHACampus.com. He adds that the content of online training is consistent, and that companies can create a course that offers the same message across various jobsites.

While Heuer acknowledges that classroom training has its own value, particularly for some older workers, he says the future of safety training likely lies in online form.

“I really see e-learning becoming more and more the way training’s going to be developed,” he says. “I think you’re going to find a lot of advancements in online training and the quality of the product.”

Troy Hackwart, developer for Adaptive Training Systems (ATS), doesn’t believe that safety should be competitive. That’s why ATS (http://www.adaptive trainingsystems.com) is focused on creating an online safety community based on sharing, not competition.

Hackwart explains that most companies are challenged not by securing course information, but rather by finding an accessible, affordable way to distribute that information to their employees. That’s where ATS comes in, to set up the technology and help companies understand how to use the delivery methods. Some companies even share their course materials with ATS for other clients’ use.

“We’re trying to create a community where we share so people don’t have to reinvent the wheel over and over again,” says Hackwart.

Jonathan Jacobi, a subject matter expert for online safety training provider PureSafety (http://www.puresafety.com), points out that online training allows safety professionals to direct their attention to other, more pressing matters, like prevention.

“The more efficient they can be with safety, the more time that saves the organization,” Jacobi explains.
Online training, however, doesn’t need to be a cold or anonymous process. Jacobi points out that PureSafety uses the experience and knowledge of their own safety professionals to design and deliver course content. PureSafety employs full-time, on-staff safety professionals with industry experience to make sure the most relevant points are emphasized.

“So we’re going to cover all the compliance requirements, but we’re going to make it real-world with people who have real-world experience,” Jacobi says.

Product Info Online
Finding the right safety products or equipment is easier than ever with interactive Web sites. Best Glove’s Web site (http://www.best glove.com), for example, helps customers select the right hand protection with only the click of a mouse.

According to Marketing Manager Gil LeVerne, the site’s “Is the Best Glove for Me?” section is a useful tool for people who are new to an industry or who could use a quick study of hand protection. Visitors can search through the company’s offerings by selecting a particular application, hazard or chemical. The resulting matches include a chart detailing the level of cut, chemical, abrasion or puncture resistance, as well as a price-level indicator.

Best Glove’s chemical resistance guide, or ChemRest, is a dedicated Web portal containing all the information required to select an appropriate chemical-resistant glove for multiple hazardous applications. ChemRest includes data from more than 9,000 tests, including rankings of the most to least effective protection for a particular chemical. Users can search by the type of chemical, CAS number or glove style.

In the future, the company plans to include brief application videos so visitors can see how a glove performs, as well as a password-protected crossover chart. “Our industry is very much following the web development,” LeVerne says. “Everyone’s trying to become more Web-savvy.”

And in addition to featuring an interactive glove selection guide at http://www.progradegloves.com, Ansell offers the Ansell U Challenge, an online safety game, at http://www .vantagegloves.com. Players choose from a variety of gloves with different ratings for dexterity, grip and abrasion and puncture resistance and then attempt to stamp out as many pieces of metal as they can without incurring injuries.

But glove manufacturers don’t have the corner on online PPE resources. Howard Leight by Sperian offers an online hearing protection selector (http://www.howardleight.com/selector) to allow users to select the desired exposure level, type of product, style and features. Visitors enter for their required product specifications and are provided with a comparison chart of the products that meet their needs.

Web-based solutions also can help companies manage gas monitor systems, like Industrial Scientific’s iNet (http://indsci.com/products/inet.aspx), which remotely monitors a company’s instrument fleet via the Internet and automatically handles necessary service requirements.

The system provides weekly instrument status reports covering calibrations, sensors, bump test warning/status, secure off-site data storage, installation, continuous gas cylinder pressure monitoring and more. By using a Web-based system like iNet, a company can eliminate gas managing tasks that are cost-intensive and time consuming.

The Safety Blogosphere
David Michaels is a professor and associate chairman in the department of environmental and occupational health at the George Washington University School of Public Health and Health Services and author of the book Doubt Is Their Product. He also is a contributor to The Pump Handle, a blog touted as “the water cooler for the public health crowd.”

The Pump Handle (http://thepump handle.wordpress.com) readership includes professionals, activists, students, reporters and policy makers, among others. More than a dozen contributors weigh in on occupational safety and health topics, which can range from how OSHA has addressed the recent surge in crane-related deaths to chemical laws or diacetyl.

“It’s an opportunity for the safety and health community to discuss a lot of these issues,” Michaels says. “It creates a conversation.”

The Pump Handle receives approximately 500 hits per day and serves as a sounding board for those concerned with occupational safety. It also contains links to articles and documents and provides a forum for readers to comment on the information.

Other blogs of note include the Weekly Toll, http://weeklytoll.blogspot .com, which recounts workplace fatalities that occur throughout the country and comments on legislation and other pertinent topics. OSHA Underground, http://oshaunder ground.blogspot.com, posts news items and legislation involving OSHA and considers how the agency might be more effective. Finally, archived entries of Confined Space, a blog that focused on worker safety issues from 2005-2007, still are available at http://spewingforth.blogspot.com.

Paper Dump
Besides managing gas monitoring systems or providing an easier way to scope out PPE options, Web-based programs can help keep track of records or material safety data sheets (MSDSs). Duane Burkett, chief operating officer at Safetec (http://www.safetec.net), says online MSDS management allows employees to access MSDSs faster, stay up-to-date on required documents and avoid piles of paper.

"Trying to use paper and going through binders is a cumbersome process,"

Burkett says.

"With an electronic system, you instantly check the entire database."

The online system is backed up by Safetec’s 24-hour hotline, which allows workers or managers to access MSDSs even if the Internet is on the fritz. Companies also can use Safetec’s collection of MSDSs if they are missing an appropriate document.

Replacing all that paper with online methods might be good for a safety professional’s piece of mind – and for the environment. But even more, these online resources help people connect and communicate about safety topics, access otherwise hard-to-find documents and stay up to date on regulations and safety issues.

According to ASSE’s Schwerman, the goal is to strive for a user-centered Web experience and to fully explore all that online resources can offer the industry. That means always learning, trying new things and experimenting with Web-based solutions. After all, if you remain static in the ever-changing online world, you just might get left behind.

Sidebar: OH Online
When you’re searching for news, trends and products relating to occupational safety and health, there’s no need to go farther than OccupationalHazards.com. Here’s a snapshot of what the site offers.

News Items – News items are posted to the site daily to keep you up to date on the latest events, studies, legislation, trends, industry tips and more.

Safety Zones – Take a look at the left side of the site to find Safety Zones that organize information into roughly 4 dozen categories such as construction safety, hand protection, OSHA compliance and safety management. Each section offers category-specific news, articles, featured suppliers and products, making it a snap to find what you need.

Digital Issues – Are you in a rush to reference something in Occupational Hazards but can’t locate your copy of the magazine? You can still read the current issue, as well as archived back issues, online. Just click on the “Digital Issue” icon at the top of the page and select an issue.

Safety WebExpo – In May, Occupational Hazards hosted the Safety WebExpo and Conference, offering all the resources you’d find at a trade show without the stress or expense of travel. You can still take a peek at the archived webcasts, visit virtual booths, download literature and more at http://www.occupationalhazards.com/webexpo.

Webcasts – The site regularly hosts new webcasts for the site, with recent editions focusing on arc flash, fire-resistant clothing, green chemicals and chemicals policy, workplace gas hazards and public safety at major venues.

Podcasts – Listen in as Occupational Hazards editors interview industry leaders and experts about topics like ergonomics and the aging work force, OSHA 10-hour training, sleep deprivation’s effects on safety and more. Listen at your desk or download the podcast and take this portable safety content with you wherever you go.
Products and Suppliers – The site’s Safety Storefront provides information on suppliers, as well as product spotlights and a supplier directory to simplify your search for the best safety equipment and products.

e-Newsletters – Occupational Hazards produces weekly and monthly e-newsletters offering the latest news, best practices and analyses in occupational safety and health, construction safety, ergonomics, industrial hygiene and safety solutions. View archived newsletters at http://www.occupationalhazards.com/NewsletterArchive.

SafetyLive TV – Tune in to this section to watch product demonstrations, company video programs and reports from industry trade shows.

The Future
The Web is an ever-changing and growing world, and OccupationalHazards.com is no different. We have some big plans in store for the site in the future, including design changes and a new content focus to provide readers with the latest and most relevant health and safety information. Be sure to check back often and stay up to date with OH.

Labels: chemical compliance, chemical inventory, material safety data sheets, MSDS, msds approval

OSHA Process Management Safety - Highly Hazardous Chemicals, Toxics and Reactives