OSHA recently published a brief relating to the new hazardous chemical labeling requirements under the Hazard Communication Standard, 29 CFR 1910.1200 (HCS), which brought the standard into alignment with the United Nations’ Globally Harmonized System of Classification and Labelling of Chemicals (GHS).

The brief outlines the labeling requirements under the new standard. OSHA also discussed an exciting change, that it intends to make to Appendix C, Allocation Of Label Elements, along with a clarification.

Previously, OSHA did not allow a GHS pictogram to be shown on a shipped container label if it conflicted with the DOT hazmat label. Section C.2.3.3 stated:

“Where a pictogram required by the Department of Transportation under Title 49 of the Code of Federal Regulations appears on a shipped container, the pictogram specified in C.4 for the same hazard shall not appear.”

This statement caused a lot concern for those companies shipping 55 gallon drums and/or smaller containers. Those companies would be forced to have various label designs and train workers to recognize the hazards, even without the pictogram showing (on the drum label due to the 4 x 4 hazmat label). OSHA was petitioned to change the requirement almost immediately after the final rule was published in March of 2012.

In the recent brief, OSHA announced its intent to make the change, allowing the use of both the pictogram and the hazmat label.

“However, DOT does not view the HCS pictogram as a conflict and for some international trade both pictograms may need to be present on the label. Therefore, OSHA intends to revise C.2.3.3. In the meantime, the agency will allow both DOT and HCS pictograms for the same hazard on a label.”

I would imagine that many companies will read this and breathe a sigh of relief. This is a welcome change that should make everyone’s job easier.

For more information, you can view the complete blog here: http://www.osha.gov/Publications/OSHA3636.pdf

ICAO has issued an addendum to the 2013-2014 edition of the Technical Instructions with IATA following suit with their second addendum to the 54th edition of the Dangerous Goods Regulations. These addendums remove the special provision A51 for the carriage of large lithium batteries on aircraft. In light of recent problems with Boeing 787 aircraft, A51 would allow such batteries to be carried as cargo. This special provision applies to UN 2794 Batteries, wet, filled with acid and UN 2795 Batteries, wet, filled with alkali only.

The ICAO addendum is available: here »
The IATA addendum is available: here »

The Occupational Safety and Health Administration (OSHA) has issued a correction and technical amendment to the March 26, 2012 final rule incorporating the GHS recommendations into the Hazard Communication Standard.

The majority of the corrections are to references originally missed in the original final rule. Other corrections include correcting values and notations in table and updating references to terms (e.g. Material Safety Data sheet (MSDS) to Safety Data Sheet (SDS)).

http://www.gpo.gov/fdsys/pkg/FR-2013-02-08/pdf/2013-01416.pdf

ICC is your source for OSHA Hazcom 2012 (GHS) information. Ask how we can help.

In a recent press release, OSHA announced their directive for worksite inspections in 2013.

The inspection targeting program began in 2008 in response to a Government Accountability Office audit report recommending that OSHA develop a targeted inspection program for federal worksites.

OSHA‘s notice (view the PDF) outlines that they plan to work from primary and secondary inspection lists.

The primary inspection list includes: 100% of the establishments reporting 100 or more lost time cases (LTCs), 50% of the establishments reporting 50 to 99 LTCs, and 10% of the establishments reporting 20 to 49 LTCs. Time permitting; OSHA will use their secondary list which includes smaller numbers of lost time cases and other reported incidents.

Once the list is prepared, it is distributed to the local OSHA Regions for implementation.

What’s the best way to stop lost time for workers? Educate them. Train them. Make sure they understand what they are doing and how to handle the chemical or the possible hazard(s) of the machine or environment they are working with/in.

ICC has recently developed a variety of workplace training programs including Lockout/Tagout. Watch for our new OSHA courses being released shortly.

ICC also offers services such as plant audits that could prepare your workplace for an inspection.

Every four years the transportation agencies in USA, Canada and Mexico jointly publish the North American Emergency Response Guidebook. There are more than one million shipments of Hazardous Materials across North America each day. While most arrive without incident at the destination, there are situations where emergency action/response is needed.

This past May more than 2 million free copies of the 2012 Emergency Response Guidebook were distributed to firefighters, emergency medical technicians, and law enforcement officers by PHMSA.

Now, there is an app for that!

The free app, which is geared for first responders—can be downloaded from iTunes and Google Play.

Authors of this app, warn that this app is for reference and not to be used in an emergency response situation and the only way to stay up to date is to have your own ERG.

The 2012 North American ERG book in English, French or Spanish is available in two sizes: 4 x 6 and 5 x 7. If you do not already have your copy, buy one today.