Retail Safety Solutions

Transcription

1 Retail Safety Solutions Inside this issue OSHA Updates for 2015 OSHA Recordkeeping Rule OSHA Hazard Communication Standards Strategy for Compliance Zurich Safety Calendars Important OSHA Updates for 2015 William Cooper, Sr. Risk Engineering Consultant Just a quick mention, the Zurich Retail Safety Calendar s for 2015 for Retail, Grocery and Distribution Centers are available. Safety topics are for each day, throughout the entire year. Calendars are available in English and Spanish. OSHA updated two (2) current standards in The information below regarding these updates can serve as a valuable tool to the Retail / Wholesale Stores and Distribution Center partners.. First a couple of quick compliance dates to remember regarding OSHA Recordkeeping Standard 29 Code of Federal Regulation (CFR) Part 1904 Recording and Reporting Occupational Injuries and Illnesses (effective January 1, 2015) and OSHA HAZCOM 2012 (June 1 and December 1, 2015). Refer to OSHA Recordkeeping Rule and OSHA Hazard Communication Standard (29 CFR ) sections below for more details. OSHA Recordkeeping Rule (Ref. 1) Starting January 1, 2015) OSHA's updated record keeping rule will expand the list of severe injuries that all employers must report to OSHA. Establishments located in states under federal OSHA jurisdiction must begin to comply with the new requirements starting January 1, 2015; those located in states that operate their own safety and health programs should check with their state plan for the implementation date of the new requirements. Previously, employers had to report all work-related fatalities and hospitalizations of three or more employees. Now,

2 employers have to report the following to OSHA: All work-related fatalities must be reported within 8 hours. All work-related inpatient hospitalization, amputation, or eye loss incident must be reported within 24 hours. For any fatality that occurs within 30 days of a work-related incident, employers must report the event within 8 hours. An OSHA fact sheet regarding these changes, can be obtained from OSHA s webpage using the link below: recordkeeping2014/osha3745.pdf OSHA Hazard Communication Standard (29 CFR ) (Ref. 2) 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. (source chart below-osha.gov website) Effective Completion Date December 1, 2013 Requirement(s) Train employees on the new label elements and SDS format. Who 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, 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 (this final standard), or the current standard, or both. All chemical manufacturers, importers, distributors and employers An OSHA Hazard Communication Final Rule regarding these changes, can be obtained from OSHA s webpage using the link below: 2

3 Strategy for Compliance (Ref.3) Here is a strategy that users of chemicals (those that OSHA calls employers ) might consider in complying with the revised standard. Those companies that manufacture or import chemicals have significant responsibilities over and above the steps outlined below. Specialized expertise may be needed to assist in the hazard classification, label and SDS development aspects of the standard, hence the extended timetable for compliance. 1. Inventory chemicals and mixtures in use. This is a perfect time to conduct a review of operations and inventory the materials that are used. This will allow reconciliation with the current list of hazardous chemicals and prepare for the receipt of updated SDS. 2. Review and revise the hazard communication program documents. The broad provisions of the OSHA standard related to the hazard communication program have not changed significantly. Review the written hazard communication program documents and update sections related to receipt of chemical information, SDS review, labeling and training. 3. Update the training program and materials. Employees will need to be updated on the changes to the standard and trained on how to recognize and understand the new labeling systems and SDS. In addition, employees will need to be re-trained on the chemical hazards when updated information on any particular chemical is received. A plan for just in time training as information and changes are made available may be most effective in protecting employees during the transition. 4. Provide training for employees. As noted above, two phases of training will be needed. Since many foreign countries are implementing the GHS standards following a different timetable than the United States, it is likely that revised labels and SDS will be seen by employees much sooner, particularly on chemicals provided by international suppliers. It may be prudent to provide initial awareness training on changes in labeling and SDS as long as six months or more before the initial compliance date (of 12/1/2013). This will allow employees to be familiar with the labels and assure they protect themselves while handling chemicals. 5. Review in-plant and process labeling and hazard warnings. As chemical container labeling and SDS are changing, so too may in-plant labeling change. OSHA indicates that currently used methods of labeling through signs, placards and warnings on process or batch sheets can continue to be used. Also, alternative labeling systems, such as NFPA or HMIS labeling systems can remain. It is important to review current in-plant labeling to assure that the warnings that are communicated are appropriate, particularly as chemicals are newly classified. 6. Audit the company s efforts to come into compliance to assure that all aspects have been addressed. As various compliance dates approach, it is good to audit the company s efforts at updating programs, training and labeling. Verify that updated SDS and labeled supplies have been received. Confirm that in-plant labeling has been reviewed and either updated or verified that it is still appropriate. Assure that programs and other materials have been updated and that employees have been trained on all aspects of the standard changes. 3

4 Retail manager's 2015 safety calendar Conclusion OSHA s Hazard Communication Standard changes will allow use of the globally consistent GHS hazard classification, labeling and information transfer (SDS) methodologies. While compliance dates may seem to be well into the future, it is prudent to begin now to plan for coming into compliance. Proactive and prompt action will not only assure compliance, but also may help improve operations by updating the chemical inventory, reviewing changes in process hazards and updating the training of employees. This will help the company and most importantly employees to be fully prepared for this program. Zurich Retail Calendars (Ref. 4) Electronic 2015 Retail, Grocery and Distribution Center Safety Calendars. Available in both English and Spanish translations. Contact your Account Engineer or Risk Engineer to obtain your copy. How the calendar works Each calendar date has a daily safety topic listed. After the month of December 2015, or page 16 of the calendar, there are talking points listed that correspond with the safety topic for that date. Retail managers can use the talking points to assist in communicating the safety message for the day. The safety topics in the calendar repeat every three months. The information in this calendar is an accumulation of best practices. The calendar should be of great value to your operation. Management generating safety awareness is one of the best ways of helping control and reduce claims and related expenses. The safety topics provided cover slip, trip and fall prevention, powered material handling, manual material handling, cutting safety, fire extinguisher safety, sprinkler system testing, industrial rack/ module safety and a large number of other topics. References 1. OSHA. Gov Webpage: recordkeeping2014/osha3745.pdf 2. OSHA.Gov Webpage: HCSFactsheet.html 3. Zurich Risk Topic: HAZCOM 2012: Strategies for Compliance 4. Zurich Retail Safety Calendars for 2015 Sample of the month of January 2015 safety calendar 4

5 The Zurich Services Corporation 1400 American Lane, Schaumburg, Illinois The Zurich Services Corporation Risk Engineering The information in this publication was compiled by The Zurich Services Corporation from sources believed to be reliable. We do not guarantee the accuracy of this information or any results and further assume no liability in connection with this publication, including any information, methods or safety suggestions contained herein. Moreover, The Zurich Services Corporation reminds you that this cannot be assumed to contain every acceptable safety and compliance procedure or that additional procedures might not be appropriate under the circumstances. The subject matter of this publication is not tied to any specific insurance product nor will adopting these policies and procedures ensure coverage under any insurance policy The Zurich Services Corporation. All rights reserved. (01/15)