IN 2012, OSHA updated the standard on Hazard Communication. New guidelines were put in place requiring, among other things, more rigorous training surrounding the communication of hazardous materials, with a training deadline of December 1st. That deadline is soon approaching, and a failure to properly train employees will be a serious problem for employers.

The update to the standard aligned it with the Globally Harmonized System of Classification and Labeling of Chemicals. This creates an easier system for employees when trying to understand what chemicals they are working with, and should create a safer workplace.

The full update is coming in phases, and one of the most important phases, the training phase, is required to be completed by Saturday. If you have not finished, or even started, to prepare for this update, it is time to take a hard look at your safety plan to ensure you will be ready by December 1st.

Employers must train their employees on the type of information which might be found on the new required labels. Employees must also be trained on how the various warnings on a label work together, and how to most effectively utilize the labels at work. Additionally, employees must be trained on the new 16-section format and the new Safety Data Sheets.

If you have any questions about the updates to the hazard communication standard, about the Globally Harmonized System of Classification and Labeling of Chemicals, or about the December 1st training deadline, please contact us. And if you have anything to add about these topics, please leave a comment.

The Toxic Substance Control Act (TSCA) was signed into law in 1976. It was the end result of six years of negotiations, and does little to actually help protect people. This law regulates which hazardous chemicals may and may not be used. It is the only law which governs the legality of specific substances, and it places the entire burden of testing on the Environmental Protection Agency (EPA).

To make matters worse, there is only a 90 day window for the EPA to determine if a hazardous chemical poses “unreasonable risk of injury to health or the environment.” If the EPA cannot test the substance, review the data, and come up with conclusive evidence that a substance should be banned during that time, it will, instead, be released for mass production. This system does not work; in the 23 years since 1990, less than 200 of the 62,000 chemicals currently in use were tested by the EPA. Of those chemicals, only 5 have been banned.

Obviously, something more had to be done. For these reasons, OSHA created Standard 1910.120, Hazardous Waste Operations and Emergency Response (HAZWOPER). OSHA has no oversight to test or ban specific chemicals, so instead OSHA created this standard to regulate the handling, transportation, and destruction of these substances. Closely following this standard is the only way to ensure employee safety in relation to the many dangerous substances used on a daily basis all across the country which have never truly been tested for safety.

If your company uses any hazardous chemicals, it is imperative you ensure that your procedures follow the HAZWOPER guidelines perfectly. Should you have any questions about the standard or about your procedures, please contact us so that we can help you. If you have anything to add about TSCA or HAZWOPER, please leave a comment.

If your company handles hazardous waste in any capacity, it is important to ensure that your facility is compliant with OSHA Standard 1910.120. Standard 1910.120 covers HAZWOPER (hazardous waste operations and emergency response). This important standard helps protect employees who handle or work near hazardous materials.

This standard specifically covers the storage, handling, transportation, disposal, and cleanup of all hazardous materials. A HAZWOPER plan must be in place in applicable facilities, and should, at a minimum, include policies for reporting hazardous materials to management, local authorities, and local law enforcement, policies for the storage of hazardous materials, and the processes in place surrounding the transportation of these materials. The plan should also include policies relating to who has access to areas with hazardous materials, the locations of the hazardous materials, the frequency with which these individuals have access to the hazardous materials, the medical screenings performed for these individuals, and the frequency of the screenings performed.

An effective HAZWOPER plan should cover every step of the lifecycle of hazardous material while it is in your company’s control. If you cannot track hazardous material from the time it enters your control to the moment you get rid of it, then there is something wrong. If you need help in finalizing a plan, we recommend having an audit of the plan completed.

If you have any questions about HAZWOPER guidelines, or if you would like to have your HAZWOPER plan audited, please contact us. If you have anything to add about HAZWOPER, please leave a comment.

In May of 2012, there were updates made to OSHA Standard 1910.1200, which regulates the communication of potential hazards associated with hazardous materials. The updates were made to bring the OSHA standard in line with the United Nations Globally Harmonized System of Classification and Labeling of Chemicals, Revision 3. And while many standards are updated every year, this was the first major update to this standard in nearly 20 years; the first since a major update in 1994. So if your business deals in hazardous materials but your safety team has not reviewed and updated this section of the safety and health management system since last May, there is a good chance your company is no longer compliant, which means it is in danger of potential fines and your employees are potentially at risk.

A company in any industry which deals in hazardous materials, including laboratories, wholesalers, manufacturers, importers, warehouses, and retail stores, just to name a few, needs to ensure that it is up to code in relation to Standard 1910.1200. This standard specifies how to identify and classify hazardous materials and how to communicate this information to employees. It also covers protective communications to employees. This standard is very clear about what is – and is not – a hazardous material, and what preventative steps must be taken to ensure all details of the material are communicated to anyone who might come in contact with the material.

If you have not reviewed your procedures on hazard communication since last May, it is important to have your procedures audited to ensure your company is still up to code. If you would like help in this task, or would like some guidance on how to properly label any new products you have begun working with, please contact us. Should you have any general questions about hazard communication, or would like to add anything else about this standard, please leave a comment.

Hazardous waste is not a subject to be taken lightly. Improper handling of hazardous waste at any point from transportation to storage to disposal can lead to serious and potentially lethal consequences for the handlers of the waste material. Because of the serious nature of hazardous waste, OSHA takes your company’s hazardous waste operations very seriously. As a result, standard 1910.120, dubbed HAZWOPER (short for hazardous waste operations and emergency response), was created. This standard covers the cleanup, transportation, storage, handling, and disposal of all hazardous waste materials.

HAZWOPER needs to be an integral part of the Emergency Action Plan for any company which deals with hazardous materials. The HAZWOPER plan should include the policy for reporting hazards to the safety and management teams, as well as any applicable state or local authorities. Further, this plan needs to discuss who is permitted access the hazardous areas and the locations where hazardous materials are stored, the frequency with which these team members have access, the medical screenings performed, the regularity of the screenings. It also needs to discuss in detail the containment devices utilized for the hazardous waste, the transportation procedures for moving the hazardous waste, and the disposal procedures for the waste. There are very clear and well defined procedures for each of these requirements.

If you have any questions about your HAZWOPER procedures, it is important to have a qualified third party review your Emergency Action Plan and audit your workplace. And if you need any help with updating or instituting your procedures, please contact us. If you have anything to add about HAZWOPER, please leave a comment.

Hazardous waste operations and emergency response (HAZWOPER, for short) guidelines are covered by OSHA standard 1910.120. This standard explains required training for employees dealing with hazardous materials, as well as procedures for the storage, disposal, and operations of all hazard materials and potential accidents with said materials. It explains who may and may not be granted access to such materials, and who is in charge of monitoring the site. Finally, it explains what is required in your business site safety and health plan.

1910.20 gives specific details about what is required in the site safety and health plan. It must include the specifics related to which hazards have been identified, how they were identified, and how these hazards were communicated to the individuals working on site. It also requires that all hazardous sites have an emergency response plan, including applicable state and local authorities where applicable. In addition, specific guidelines are set for monitoring the health of individuals who have been granted access to the site, as well as guidelines for the frequency of medical examinations. Further, the standard goes into detail about what is required of employee trainers, and how often employees must be trained. The standard also covers what personal protective equipment is to be worn. It covers what drums and barrels will be used to store and dispose of the materials, as well as how said containers are to be opened and sealed. The standard additionally discusses at length the proper disposal process for hazardous materials. This is of course, an abridged, and hardly all inclusive, list of what is required; but it does touch on the key points and shows how far reaching this site safety and health plan really is.

Even if you have had a full audit from a third party in the past, and created an in-depth site safety and health plan, it is important to make sure you are keeping adequate records of events and changes. Further, you must ensure that you are still up to code and that no additional risks have presented themselves in the interim. If you have any questions about your current plan, or would like to begin a new plan, please contact us for more information. And if you have any additional information to add, please leave a comment.