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I have seen no less than 20 emails inviting me to webinars that will help me get my house in order for all the changes coming with the OSHA Hazard Communication Standard this year. From the tone of these emails, it would seem like the sky is falling! You know what? The sky is not falling … although there is work to be done to implement the changes. OSHA has published the final rule updating the Hazard Communications Standard as of today 3/20/12. Do you have hazardous chemicals in your workplace? If you think the answer is no, are you sure? Let’s start with a definition! OSHA defines a hazardous chemical as one that presents either a physical or a health hazard. Many common and readily available products such as paints, cleaners, and other materials found in the workplace meet this definition. In fact, last year OSHA issued over 6,300 violations to companies that failed to comply with this standard. Learn more about your Right-to-Know! For a project health and safety administrator, it is vital to be able to communicate with your team members and with outside resources. How do you keep tabs on who is where and what is happening? How do you find if something has gone wrong or someone needs help? As the Field Safety Manager for a 300-mile electric power transmission power line construction project, one of my first tasks was to address the question “How do you make communication possible across 275 miles of relatively unpopulated, harsh mountainous territory”? Specifically, I had to meet OSHA’s requirements for communication: 29 CFR 1926.35 “Employee Emergency Action Plans” and 29 CFR 1926.50 “Medical Services and First Aid”. In fact, these are the reasons that OSHA implemented the Standards listed above – life and death situations may depend upon it! Are you shipping products that may be hazardous? Do you even know how to find out? Is your training up-to-date with the Refresher courses mandated by the DOT and FAA? Have you considered the cascade of repercussions that shipping one package incorrectly could cause for your company or fellow workers? Only trained persons are permitted to be involved with the transportation of hazardous materials. It is what makes the process work safely…for everyone! Understand more about DOT and IATA training today – to protect yourself and the public. With the start of each new year, Emilcott faces regulatory submission deadlines reporting data from the past year including Submission of the EPA Community Right to Know (CRTK) Survey due March 1 and EPA Toxics Release Inventory (TRI) due July 1. Just like Christmas shopping, the compilation and reporting process is less stressful and yields better results if I begin early and develop a strategy with deadlines in mind. As such, here is my personal January first kick-off list that should make the time-consuming process of CRTK and TRI reporting easier to handle. As a facility, are you tracking your toxic chemicals and filing the appropriate NJ PPA documentation? Facilities must account for their use of toxic chemicals and, where feasible, reduce their use. Toxic pollution that cannot be reduced should be recycled, and pollution that cannot be recycled should be disposed of in an environmentally safe manner. Guest blogger, Charles Peruffo, reviews the requirements and process of filing under the New Jersey Pollution Prevention Act. Both OSHA and the EPA seemed to have recently awoken from their regulatory slumber. OSHA has announced its first major rulemaking during the Obama administration with a proposed change to the agency’s Hazard Communication (HazCom) Standard. The existing OSHA HazCom Standard provides workers with the right to know the hazards and identities of the chemicals they are exposed to while working, as well as the measures they can take to protect themselves. This standard was originally Top Ten Things You Need to Know about the Chemical Hygiene Standard 1. The OSHA Standard for regulating safety in research and development laboratories is: Occupational Exposure to Hazardous Chemicals in Laboratories (29 CFR 1910.1450). The standard does not apply to production or QA/QC labs (see definition in #9). 2. The employer must develop and maintain a Chemical Hygiene Plan for each lab 3. The employer must designate a Chemical Hygiene Officer (an individual or group of individuals responsible for OSHA has unveiled its latest National Emphasis Program (NEP), the Process Safety Management (PSM) Covered Chemical Facilities National Emphasis Program. This program targets workplaces that could potentially release highly hazardous chemicals by evaluating their compliance of the PSM standard (29 CFR 1910.119). The only NAICS that has been excluded is 32411 (Petroleum refineries), which has been covered by the Petroleum Refinery Process Safety Management NEP. The PSM Covered Chemical Facilities NEP will be used for programmed inspections at |
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