OSHA Changes Hazard Communication Standard to Match GHS

[tweetmeme](from OSHA website)

New changes to the Occupational Safety and Health Administration’s (OSHA) Hazard Communication Standard are bringing the United States into alignment with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS).

Major changes to the Hazard Communication Standard:

  • Hazard classification: Chemical manufacturers and importers are required to determine the hazards of the chemicals they produce or import. Hazard classification under the new, updated standard provides specific criteria to address health and physical hazards as well as classification of chemical mixtures.
  • Labels: Chemical manufacturers and importers must provide a label that includes a signal word, pictogram, hazard statement, and precautionary statement for each hazard class and category.
  • Safety Data Sheets: The new format requires 16 specific sections, ensuring consistency in presentation of important protection information.
  • Information and training: To facilitate understanding of the new system, the new standard requires that workers be trained by December 1, 2013 on the new label elements and safety data sheet format, in addition to the current training requirements.

Changes from the Proposed to the Final Rule: OSHA reviewed the record and revised the Final Rule in response to the comments submitted. Major changes include:

  • Maintaining the disclosure of exposure limits (Threshold Limit Values [TLVs]) established by the American Conference of Governmental Industrial
  • Hygienists (ACGIH) and carcinogen status from nationally and internationally recognized lists of carcinogens on the safety data sheets;
  • Clarification that the borders of pictograms must be red on the label;
  • Flexibility regarding the required precautionary and hazard statements to allow label preparers to consolidate and/or eliminate inappropriate or redundant statements; and
  • Longer deadlines for full implementation of the standard (see the chart below):

What you need to do and when:

  • Chemical users: Continue to update safety data sheets when new ones become available, provide training on the new label elements and update hazard communication programs if new hazards are identified.
  • Chemical Producers: Review hazard information for all chemicals produced or imported, classify chemicals according to the new classification criteria, and update labels and safety data sheets.
Effective Completion Date Requirement(s) Who
December 1, 2013 Train employees on the new label elements and SDS format. Employers
June 1, 2015*December 1, 2015 Comply with all modified provisions of this final rule, except:Distributors may ship products labeled by manufacturers under the old system until December 1, 2015. 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 Comply with either 29 CFR 1910.1200 (this final standard), or the current standard, or both. All chemical manufacturers, importers, distributors and employers

* This date coincides with the European Union implementation date for classification of mixtures.

During the transition period to the effective completion dates noted in the standard, chemical manufacturers, importers, distributors and employers may comply with either 29 CFR 1910.1200 (the final standard), the current standard or both.

The final rule revising the standard is available at http://s.dol.gov/P1*.

Career Success Means Being Fully Engaged!

[tweetmeme]I have spent a lot of time and energy developing this blog.  My aim is now as it has always been, to deliver a voice of encouragement and to be resource for folks looking to help keep themselves or others safe in the workplace.  I have often utilized humor or tried to highlight some slightly off-center topics to engage my readers.  But just the other day I was at lunch with a friend and we were talking about our careers, family, NCAA tournament…the usual.  I guess at some moment I must have seemed down, because my friend asked me if I was happy?  I instinctively said “sure”.  He then asked me, “Why do you do it?”  “Why do you invest so much energy into your work….I mean what is your motivation?  What are you passionate about?”

I thought for sure my friend was having a mid-life crisis or worse he thought I might be having a crisis.  I left that lunch not really answering the question, at least not to myself.  Oh, I replied the usual answers we all give, family and relationships, etc.  But later after more reflection I came to the unexpected conclusion that it wasn’t just my family and personal relationships that drive me, but that I absolutely love what I do and I hold a strong conviction that environmental, health and safety is one of the most important, challenging, and respectable professions available.  I started to write down some of the challenges that I haven’t been able to fully solve or overcome within EHS.   Just that simple act of writing them down in front of me:  there they were staring at me still fighting with me.  Well that got my competitive juices flowing and I immediately wanted more than ever to meet these challenges and solve them once and for all.

As a EHS professional, or any professional, if you want to succeed in something you are not fully engaged in you are doomed to fail.  I realized that my friend must have sensed that I haven’t been as fully engaged as I usually am and he decided to challenge me on it.   So in turn I am challenging you!  What are you passionate about?  If you want to be happy you need to make sure you are getting something from your career choice beyond the paycheck.  Whether its personal growth, working to a common purpose, or being part of a larger process you need to take time to celebrate the successes you have and repeat them when you can.  Being engaged in your work means having fun and being enthusiastic about it.  It is not acceptable to simply be satisfied with your job if you really want to succeed and be happy.

Whenever possible, do something that really charges you up.  If having face-to-face time with the front line employees leave you with a feeling of accomplishment, make time in your schedule to do more of that.  If training employees on hazard awareness helps you feel like you are making a difference, then try to do more of that.  Don’t mistake this with only doing the things that are easy or fun, but definitely make time for them.

Quick Tips for Happy Engaged People

  • Remember the most important skill you will ever have or learn will come from a true desire to help others.
  • Find intrinsic enjoyment in your work;  if you can’t, maybe you need a change.
  • Invest the time and resources to stay current in your industry.
  • Your relationships with management and labor have the biggest impact on your success.  Nurture those relationships!
  • Top performance requires time to rest.  Don’t beat yourself up for downtime.  Rest and relaxation helps recharge your batteries.
  • Show genuine gratitude to your support team.  This includes anyone who has a hand in your success.

Easy Steps for a Successful Accident Investigation

[tweetmeme]Some companies use the term “Circle of Prevention” when following the Plan, Do, Check, Act model for their safety and heath programs. As safety is really a continuing process of improvement, the OSHA standards should only be the beginning. They may help identify many of the general hazards of general business and construction, but you and your employees should be working together to identify on-the-job hazards unique to your industry and your work areas, using formal and informal safety audits and hazard analysis.

Whether through reading OSHA standards, consulting other guidelines or making your own observations, the circumstances of the hazards in your organization must be analyzed, the problem diagnosed, a plan of action developed, and then effective corrective action taken to minimize the risks.

But for whatever reason, somehow, even with your excellent safety and health program in place, an accident happens. Now what? After all the initial work is done including securing the scene and caring for the employee, you need to conduct a thorough accident investigation in order to help prevent similar accidents from happening in the future.

How your investigation is conducted will determine in large part how useful it will be.

When to start an Accident Investigation

You must act quickly as memories get fuzzy and initial perceptions may change, other employees start talking and with that the ‘water cooler’ effect takes over. Perceptions and eye witness accounts start being influenced by the storytelling. However, even though you want to get started right away do not get locked into a deadline for completing the investigation. If you are too rushed you may reach the wrong conclusions about the root causes.

Who should conduct the Investigation?

Most minor incidents and accidents can be investigated by the supervisor who is often the person most familiar with the operation. The supervisor is also in position to implement remedial measures as necessary. More serious and complicated incidents and accidents require more expertise. A team approach that includes the supervisor, safety professional or risk manager, management representative, perhaps a safety committee member and even a human resources representative will allow for a wide range of issues to be addressed. In addition, your insurance company will certainly be involved with any serious accident.

The purpose of the Investigation is Prevention not Blame.

It is crucial to the success an accident investigation to make sure you are getting full cooperation from witnesses or those involved in the accident. Remember, the people you are interviewing may be afraid that you will blame them and react defensively or even embellish the facts if they feel threatened. It is important to make sure they understand that you are simply trying to find the factors that led to the accident so future accidents can be avoided.

Review the facts.

  • Description of the accident
  • Witness Discrepancies
  • Condition of any equipment involved
  • Environmental factors
  • Personnel issues with injured employee(s) (training, competence, attitude, past performance, alcohol/drug use, etc.)
  • Routine or non-routine task

Consider all the possibilities

  • The immediate cause?
  • Contributing factors?
  • Underlying root causes?
  • Unpredictable factors?
  • Alternative theories?

Accident Investigation Reporting

Your report should summarize the facts of the accident and events leading up to it. Include any injuries suffered from the accident, the total of all property damages and any other costs of the accident, and if “human error” was involved, this should be included in the report; however, disciplinary recommendations should not be included as part of the investigation. It is however crucial to include information about the immediate and underlying causes and definitely report any dissenting opinions if the investigation was a team effort.

Management can’t do accident prevention in a vacuum, employees need to be involved. Without their understanding and cooperation, nothing management does will really work in the long run to stop the accidents and injuries.

Updated OSHA Videos Intended To Provide Respirator Training Resources


The Occupational Safety and Health Administration (OSHA) has recently posted a series of 17 videos to help workers learn about the proper use of respirators on the job.

These short videos are intended to provide information to workers in general industry and construction.  Topics include OSHA’s Respiratory Standard, respirator use, training, fit-testing and detecting counterfeit respirators. The videos are available with closed captioning for streaming or download from OSHA’s Web site.

OSHA’s Safety and Health topics page on Respiratory Protection also includes additional training materials, information about occupational respiratory hazards in different industries, and details of OSHA’s Respiratory Protection Standard (29 CFR 1910.134 and 29 CFR 1926.103).

Near Miss Safety Incidents Are Learning Opportunities

[tweetmeme]Have you ever been involved in an accident investigation where the contributing factors of the accident happened before but weren’t reported?   After one such serious accident involving work on live switchboards that resulted in explosions that caused extensive damage and one forced the closure of an elementary school for a day, the following was quoted in an ABC news report.

“They were very, very lucky indeed. There was a similar incident on the mainland where a person received severe burns to his face working on a live switchboard and that person has been in hospital for months and months and will probably never work again.”

If you were asked to define what a near miss is what would you say? A close call where no one was injured but may have resulted in property damage?

A near miss safety incident is undoubtedly a “do over” without an injury.   However near misses must still be reported and the unsafe situation corrected in a timely manner and they should be used as a learning experience.

Here are some real life examples of near misses.

  • A forklift tipped over while carrying a load that shifted on an uneven work surface.  The driver escaped without a scratch by staying buckled inside the cage.
  • A mechanic working under railcar had just stepped away when the car was struck by another railcar being positioned on an active work track.
  • A forklift ran over a welder’s foot which was protected by his steel toed boots when the driver backed up and did not see him walking behind his lift.

Reporting of a near miss and the subsequent investigation will more than likely reveal unsafe acts and conditions that will need to be corrected.  Near miss incidents that are severe in nature should receive as much attention and corrective action as an actual accident / injury.  But it is difficult to get everyone to report near misses.

Reasons Why Our People are Reluctant to Report

  • There is no system for near miss reporting.
  • Workers believe that their supervisors will hold such near miss reporting against them.
  • Generates additional work,  i.e., paperwork, subsequent investigation, etc.
  • Supervisors and/or workers have not been instructed how to report near misses.
  • Once reported nothing is done to address or correct what caused the near miss.
  • Upon reporting there is no follow-up
  • Near misses are so frequent that they become common place and part of the everyday work life
  • Employees may fear a possible job loss or be penalized if they are found to be a contributing factor of the near miss incident.
  • Workers have the mindset that being safe in the workplace also includes being lucky.

It is important to report and follow up on near misses because you can’t predict severity in accidents.  While zero accidents is a possibility, zero risk isn’t.  It is impossible to completely engineer out all of the risks so you must continue to work to identify those hidden risks and develop ways to minimize the exposure, and reporting and investigating near misses is a critical part of this process.

It is also important to look beyond employee behavior/actions, if this is found as a “root cause” or contributing factor.   Many people will stop there because they can’t answer the “Why Question”.  In reality though if one person feels encouraged to take a risk, usually others are as well.   It is important to look at your organization’s cultural aspects during an investigation/analysis.   When the culture supports the measurement and understands why they need to investigate near misses, an in depth analysis can be a very positive thing.

EPRCA Tier II Reports born from Tragedy

[tweetmeme]In the early morning of December 3, 1984, a Union Carbide plant near Bhopal, India released approximately forty tons of Methyl Isocyanate (MIC) into the air. The gas quickly spread over the ground and, in the end, killed upwards to 5,000 people and injured 50,000 more. The other place that Union Carbide manufactured MIC was at its Institute plant in West Virginia. Following the Bhopal release Union Carbide elected to shut down production of the deadly chemical at its West Virginia location until it could make $500 million worth of safety improvements.

New Safety Programs

Approximately four months after completion of the safety improvement program, 500 gallons of highly toxic aldchiloxin (and MIC) leaked from the plant. Although no one was killed, 134 people living around the plant were treated at local hospitals.

Both the Bhopal and West Virginia incidents highlighted the serious nature of modern-day chemical production — no matter what safety precautions are taken, no matter how well trained a plant’s employees may be, and no matter how prepared a plant may be to handle an emergency situation, accidents can still occur and people may die.

Congress Acts

With thousands of chemical accidents occurring in the United States within a five year period in the mid-1980s, Congress passed the Emergency Planning and Community Right-to-Know Act (EPCRA) in 1986, ushering in a new wave of regulations and reporting requirements designed to alert the surrounding communities of the dangers posed at chemical facilities in the U.S.

To implement EPCRA, Congress required each state to appoint a State Emergency Response Commission (SERC). The SERCs are required to divide their states into Emergency Planning Districts and to name a Local Emergency Planning Committee (LEPC) for each district.

The facilities covered by EPCRA requirements are now required to submit an Emergency and Hazardous Chemical Inventory Form to their LEPC, as well as their SERC, and their local fire department annually by March 1st.

The reports known as “Tier II Reports,” require basic facility identification information, employee contact information for both emergencies and non-emergencies, and information about chemicals stored or used at the facility.
Under the EPCRA, SERCs and LEPCs are charged with four primary responsibilities:

  1. Write emergency plans to protect the public from chemical accidents;
  2. Establish procedures to warn and, if necessary, evacuate the public in case of an emergency;
  3. Provide citizens and local governments with information about hazardous chemicals and accidental releases of chemicals in their communities; and
  4. Assist in the preparation of public reports on annual release of toxic chemicals into the air, water, and soil.

Tier II Reporting Information

What facilities are covered?

  • Any facility required under Occupational Safety and Health Administration (OSHA) regulations to maintain material safety data sheets (MSDSs) for hazardous chemicals stored or used in the work place. Facilities with chemicals in quantities that equal or exceed the following thresholds must report:
  • For Extremely Hazardous Substances (EHSs) , either 500 pounds or the Threshold Planning Quantity (TPQ), whichever is lower
  • For gasoline (all grades combined) at a retail gas station, the threshold level is 75,000 gallons (or approximately 283,900 liters), if the tank(s) was stored entirely underground and was in compliance at all times during the preceding calendar year with all applicable Underground Storage Tank (UST) requirements at 40 CFR part 280 or requirements of the State UST program approved by the Agency under 40 CFR part 281.
  • For diesel fuel (all grades combined) at a retail gas station, the threshold level is 100,000 gallons (or approximately 378,500 liters), if the tank(s) was stored entirely underground and the tank(s) was in compliance at all times during the preceding calendar year with all applicable Underground Storage Tank (UST) requirements at 40 CFR part 280 or requirements of the State UST program approved by the Agency under 40 CFR part 281.
  • For all other hazardous chemicals, 10,000 pounds.

Tier2 Submit Software

  • EPA has recently developed ‘Tier2 Submit,’ an online software program designed to help facilities prepare an electronic chemical inventory report. Although many states accept Tier2 Submit, some states such as Missouri do not.


  • The owner or operator or the officially designated representative of the owner or operator must certify that all information included in the Tier Two submission is true, accurate, and complete.


  • Any owner or operator who violates any Tier II reporting requirements shall be liable to the United States for civil penalty of up to $27,500 per day for each such violation.
  • Although each day a violation continues shall constitute a separate violation it has been EPA’s policy not to enforce the daily penalty on those companies making a good faith effort to come into compliance with the reporting requirements.

For more information on EPA Tier II reporting requirements visit their website.  Specific state requirements links can also be found there.

OSHA 2013 Budget Request Unchanged From 2012

[tweetmeme]The U.S. Department of Labor today outlined its part of the president’s fiscal year 2013 budget request to Congress, which according to DOL focuses on efficiently achieving the department’s goals while exercising fiscal restraint.    See Summary below:

For information on the president’s FY 2013 budget request for the Department of Labor, visit http://www.dol.gov/budget.


Recruit Safety Champions to Reduce Workplace Accidents

[tweetmeme]During a particular busy work shift you see a heavy object fall off a ledge or shelf and thud to the floor a foot or so away from a coworker. Whew…no harm, no foul.  Right?  Consider this Seventy-five percent of all accidents are preceded by one or more near misses, according to the National Safety Council.

There is a serious real-life danger in near misses that don’t result in damage to persons or property, because of the tendency to think of them like a Hollywood horror movie; scary for a few moments, but with no real harm done.  This is a dangerous attitude though; if you don’t notice and correct whatever condition or behavior that caused the close call, it’s very likely that there will be further close calls, some minor accidents, and finally-with just the right combination of circumstances, there may be a very serious or fatal accident.

What is a near miss?

“Near misses” can be defined as minor accidents or close calls that have the potential for property loss or injury.  A near miss will prevent a task from being completed as planned.   Most accidents can be predicted by close calls.  These are accidents that almost happened or possibly did happen but simply didn’t result in an injury this time around.

What is an accident?

An accident is an unplanned, unexpected event that interferes with or interrupts normal activity and potentially leads to personal injury or dollar loss, including equipment damage.  Accidents have two things in common. They all have outcomes and they all have contributory factors that cause the accident.

There are numerous negative outcomes of accidents including injury and possible death, damage to equipment and property, litigation costs and possible citations, lost productivity, and morale issues. However from that, positive outcome from accidents can include an accident investigation which identifies key issues that can lead to prevention of recurrence, changes to existing safety paradigms which can lead to changes to policies and procedures, and changes to equipment design.

The seven deadly sins (workplace accidents):

  1. Falls to the same or lower level;
  2. Contact with chemicals, electricity, heat or cold;
  3. Caught in, on, or between;
  4. Bodily reaction from voluntary or involuntary motion;
  5. Struck against a stationary, moving, or protruding object or a sharp or jagged edge;
  6. Struck by a moving, flying, or falling object; and
  7. Rubbed or abraded by fiction, pressure, or vibration.

Obviously every close call or accident is a call for action.  Sometimes its cause can be easily fixed.  In other cases, the whole system may need a major revision. But near misses and accidents should never be ignored.  Make your employees “accident aware” by informing them of what the organization is doing to prevent accidents.

As working safely often means looking out for each other, it is no wonder that  employee involvement is the key to reducing accidents.  There are several ways to accomplish this, including providing opportunities to give voice to the needs and concerns of your frontline employees.  Consider recruiting employees from across multiple areas of your company to be safety champions, and design multiple communication strategies for them including using internal blogs, group email, safety newsletters, e-learning and classroom training, as well as encouraging the development of live forums or town hall meetings to further training efforts and to share success stories and shared challenges.

Ways to Reduce Accidents

  • Obtain top level management support for accident prevention
  • Perform a hazard analysis for each job
  • Review the use of hazardous chemicals
  • Study and evaluate the layout of workstations
  • Analyze your worker’s duties for ergonomic risks
  • Review your worker’s behavior and pay attention to their attitudes
  • Recruit your front line supervisors for safety initiatives
  • Complete regular safety checks of all equipment
  • Inspect your facility for layout and environmental hazards
  • Review and keep your worker training program current
  • Always enforce safety rules
  • Make the changes necessary to reduce hazards

As your workers and supervisors cooperate with these programs, stay alert for hazards, and follow reporting instructions, they will be able to avoid most accidents in the workplace.

OSHA Logs Must Be Certified By An “Executive of the Company” Is that You?

[tweetmeme]“The U.S. Department of Labor’s Occupational Safety and Health Administration (OSHA) recently cited the Lowe’s Home Centers Inc. regional distribution center in Rockford, Illinois with $182,000 in penalties for failure to document and report employee injuries and illnesses, as required by OSHA safety and health regulations.”

That got your attention didn’t it?


There should be no doubt about it, OSHA takes record keeping very seriously.   Remember, it’s not about the paperwork itself, its about the information on the paperwork.   OSHA doesn’t have an army of compliance officers to constantly check in on every employer so they must rely on the employers themselves to self-report on injuries and illnesses.

To OSHA the lack of proper paperwork demonstrates a lack of respect for safety and raises reasonable doubts as to the employers commitment to safety.   So do yourself and your employees a favor and keep up on your record keeping requirements.

According to OSHA 1904.32(b)(5) You must post a copy of the annual summary (OSHA 300-A Log) in each establishment in a conspicuous place or places where notices to employees are customarily posted.   You must ensure that the posted annual summary is not altered, defaced or covered by other material.   Everyone knows that…right?

Did you also know that the OSHA 300 Log must be certified as accurate by a company executive?   Did you know that most safety managers, supervisors, directors, and/or coordinators do NOT qualify as an executive?

According to the OSHA, The company executive who certifies the log must be one of the following persons:

  • An owner of the company (only if the company is a sole proprietorship or partnership);
  • An officer of the corporation;
  • The highest ranking company official working at the establishment; or
  • The immediate supervisor of the highest ranking company official working at the establishment.

If as a safety manager, director, or supervisor you meet one or more of these definitions, then I congratulate you on a career well done!   But for the rest of us, we need to make sure that a company executive certifies the OSHA 300 log.   The company executive must certify that they have examined the OSHA 300 Log and that they reasonably believe that the annual summary is correct and complete.
Employers must post the summary no later than February 1 of the year following the year covered by the records and keep the posting in place until April 30.When do I have to post the annual summary?

Who Must Maintain the OSHA 300 Log?

All employers with 11 or more employees in the selected industries, as determined by their SIC and/or NAICS classification (e.g., Agriculture, Oil and Gas, Manufacturing, Construction, Transportation, General Merchandise Stores, Hospitality, and Health Services), must keep injury and illness records.

Some employers are normally exempt for these recordkeeping requirements, such as Retail trade, Financial, Banking, Insurance and Real Estate sectors.

Employers who operate establishments that are required by the rule to keep injury and illness records are required to complete three forms: the OSHA 300 Log of Work-Related Injuries and Illnesses, the annual OSHA 300A Summary of Work-Related Injuries and Illnesses, and the OSHA 301 Injury and Illness Incident Report.

Employers are required to keep separate 300 Logs for each establishment that they operate that is expected to be in operation for one year or longer. The Log must include injuries and illnesses to employees on the employer’s payroll as well as injuries and illnesses of other employees the employer supervises on a day-to-day basis, such as temporary workers or contractor employees who are subject to daily supervision by the employer.

OSHA Slashes Number of Online Trainers and Encourages Enrollment at OTI Ed. Centers

[tweetmeme]The Occupational Safety and Health Administration (OSHA) announced earlier this month, its selection of only 10 OSHA authorized training providers out of the hundreds of applicants to deliver online courses as part of its Outreach Training Program.  Although more than 135,000 workers were trained online in 2011, which represents a five-fold increase from the number of online students trained in 2007, OSHA dramatically curtailed the overall number of online training providers available for prospective students to chose from.

Of the newly anointed 10 authorized providers, only two are non-profits or Universities, with the bulk of the providers being private for-profit companies.   Several high profile online providers who previously offered OSHA online Outreach courses were not selected by OSHA including, The University of South Florida, 360Training.com, Coastal Training Technologies, Summit Training Source, and Redvector.

Not all of the new providers that OSHA authorized even have currently available programs, according to OSHA.  Those organizations must still work on building an acceptable program in order to receive a full blessing from OSHA. So the overall number of online course providers may get smaller in the coming months.  In an email received from Mr. Don Guerra, OSHA Program Manager, OSHA continued to recommend that prospective students “compare program offerings and pricing from multiple providers” in order to determine which one best meets their training needs.  However given this latest round of cuts to available online providers, it is highly probable the cost for this online training will rise dramatically for prospective students and employers given the lack of competition in the marketplace.

OSHA also continues to encourage  students to consider taking classroom training instead of online courses.   Which of course, are being offered  and marketed by the OSHA Education Centers around the country in direct competition to private and public classroom training providers.   Although no direct link has been suggested between the slashing of online providers and the encouragement to go to the OSHA Ed. Centers; a clearer message could not have been received!

See the January 12, 2012 news release on new online Outreach Training Program selections.

New and Currently available programs 

Programs that will no longer be available after March 31, 2012