Happy New Year to All!

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1 Volume 18 No. 1 Pacific Management Services January 1, N. Fine Avenue #101, Fresno CA Phone (559) Fax (559) pacmansot@pacificmgt.com Professional Services Provided with Integrity Happy New Year to All! May 2013 be your best year ever! Revised Hazard Communication Standard A.k.a. Globally Harmonized System OSHA s revised Hazard Communication Standard (HSC), also known as the Globally Harmonized System (GHS), requires that a comprehensive hazard evaluation and communication process be developed at each workplace with chemical hazards. The intent of the revised rule is to standardize the labeling requirements at each workplace so that employees can take the necessary protective measures. The HCS achieves this goal by requiring chemical manufacturers and importers to review available scientific evidence concerning the physical and health hazards of the chemicals they produce or import to determine if they are hazardous. All employers with employees exposed to hazardous chemicals must develop a hazard communication program, and ensure that exposed employees are provided with labels, access to safety data sheets (SDS), and training on the hazardous chemicals in their workplace. The revised standard will align American companies with the internationally recognized system for classifying chemical hazards and developing labels and safety data sheets. The first step to being in compliance is to have a written Hazard Communication Plan that meets the requirements of 29 CFR , the final rule promulgated in 77 FR and Cal/OSHA Prop 65 requirements. The plan must contain the following essential elements: How the requirements for labels and other forms of warning will be met How the requirements for SDSs will be met How employee information and training requirements will be met List of hazardous chemicals known to be present in the workplace that includes a product identifier (common name or number) for each chemical that is referenced on the appropriate SDS How hazards of nonroutine tasks will be addressed How the employer will inform employees about chemical hazards in unlabeled pipes How HCS will be handled in a multiemployer workplace situation (i.e., multiemployer worksites) Complete chemical inventory list and SDS (formerly MSDS) This rule requires that employers train all employees on the new standard by December 1 st, 2013, but without a written plan and chemical inventory the training alone will not keep you in compliance. Pacific Management Services is prepared to develop a plan specific to your company and create an inventory list of the chemicals in your workplace. Don t risk an OSHA fine, please call for additional details (559)

2 ADDRESS for Dean Lowe It s too darn confusing to have more than one address! Please cancel the following address: DLowe@pacificmgt.com (No longer in use.) Please use the following address: ldeanlowe@pacificmgt.com (My long-time .) Contact me anytime by , phone or fax at the PacMan office. (I m simplifying my life.) REMINDER: POST OSHA FORM 300 Beginning February 1, employers who are required to keep the OSHA form 300 Injury and Illness log must post a summary of the log. Employers must post OSHA s Form 300A from February 1 to April 30, in a common area wherever notices to workers are usually posted. The summary must list the total numbers of job-related injuries and illnesses that occurred in All establishment summaries must be certified by a company executive. Copies of the OSHA Forms 300, 300A and 301 are available for download on the OSHA Recordkeeping Web page. Ask Pacific Management Services for your Respiratory Protection Plan Order 2013 Poster Sets All California businesses with one or more employees are required to post employment notices in a central location. Purchase an updated 2013 poster that includes all the state and federal employer notices that California employers are required to display. Keep your business compliant with the 2013 California and Federal Employment Notices. 2

3 Respiratory Hazard Assessment: When? What? How Much? When assessing the potential for respiratory hazard exposure in the workplace, OSHA says the key issues are when, what, and how much. Paragraph (d)(1)(iii) of the Respiratory Protection Standard (29 CFR ) requires you to identify and evaluate the respiratory hazards in your workplace. Specifically it says: "The employer shall identify and evaluate the respiratory hazard(s) in the workplace; this evaluation shall include a reasonable estimate of employee exposures to respiratory hazard(s) and an identification of the contaminant's chemical state and physical form. Where the employer cannot identify or reasonably estimate the employee exposure, the employer shall consider the atmosphere to be IDLH." Your evaluation has to identify the physical state and chemical form of these airborne contaminants. You must also make a "reasonable estimate" of the employee exposures that could occur as a result of those hazards, including those likely to be encountered in reasonably foreseeable emergency situations. Note that OSHA does not specify how to make reasonable estimates of employee exposures for the purposes of selecting respirators. This is your choice and your decision. When? Examples of when to assess respiratory hazard exposures include: * When OSHA has a substance-specific standard (for example, lead or methylene chloride) * When employees notice signs (for example, odor) or complain of respiratory symptoms (for example, irritation in the throat or nose) * When the workplace contains visible emissions (for example, fumes, dust, or aerosols) What? Specific characteristics of the airborne hazard must be established in order to select an appropriate respirator. Questions such as these can help you make that determination: * Is the airborne contaminant a particulate (dust, fumes, mist, aerosol) or a gas/vapor? * Is the airborne contaminant a chemical and are material safety data sheets available? * Is the airborne contaminant a biological (bacteria, mold, spores, fungi, virus)? * Are there any mandatory or recommended occupational exposure levels for the contaminant? How Much? The respiratory protection standard allows you to use many approaches for estimating worker exposures to respiratory hazards. For example: Sampling. OSHA calls personal exposure monitoring the "gold standard" for determining employee exposures because it is the most reliable approach for assessing how much and what type of respiratory protection is required in a given circumstance. To comply with the standard, sampling should: * Use methods appropriate for contaminants; * Present the worst-case exposures; or * Represent enough shifts and operations to determine the range of exposure. Continued on Page 4 3

4 Continued from Page 3 Objective Information. OSHA identifies different kinds of information as acceptable. For example: * Information and data that indicate that use or handling of a product or material cannot, under worst-case conditions, release concentrations of a respiratory hazard above a level that would trigger the need for respirator use or require use of a more protective respirator. * Data on the physical and chemical properties of air contaminants, combined with information on room dimensions, air exchange rates, contaminant release rates, and other pertinent data, including exposure patterns and work practices, to estimate the maximum exposure that could be anticipated in the workplace. * Data from industry-wide surveys by trade associations for use by their members, as well as from stewardship programs operated by manufacturers for their customers, are often useful in assisting employers, particularly small business owners, to obtain information on employee exposures in their workplaces. OSHA points out that when assessing respiratory hazard exposure, you have to account for potential variation in exposure by using exposure data collected with a strategy that recognizes exposure variability, or by using worst-case assumptions and estimation techniques to evaluate the highest foreseeable employee exposure levels. What to Tell Workers About Spirometry If you've got respiratory hazards in your workplace, your workers should know about spirometry testing, which helps reduce or prevent worker exposure to respiratory hazards. What is spirometry? Spirometry is a common pulmonary function test that measures how well a person moves air in and out of the lungs. Workers who inhale some types of dusts, gases, or other air contaminants can, over time, experience lung damage. The spirometry test can detect breathing problems or significant changes in a worker's lung function at an early stage. Spirometry assists employers with identifying and eliminating hazardous workplace exposures and helping reduce or prevent the chances of workers developing lung disease. How does it help protect workers? Periodic spirometry screening of individual workers identifies breathing problems or significant changes in lung function. This means that hazardous exposures can be identified and eliminated to prevent or reduce occupational lung disease. Equally important, surveillance can detect changes in lung function over time among groups of workers with similar exposures and thus help to recognize serious health effects in the workplace at a time when individual results may not be severe or noticeable. OSHA says you should consider periodically reviewing grouped data from worksite exposure assessments with a healthcare professional and should be alert for any significant changes in grouped results. Reviewing grouped data may help identify occupational exposures and assist in reducing or eliminating any hazards identified. When is spirometry testing needed? Periodic spirometry tests must be performed in accordance with OSHA standards. For occupational exposures to substances for which no OSHA standard applies, periodic spirometry is usually recommended, although it can be done more or less frequently. The frequency of testing should be determined by the specific hazard to which workers are being exposed. At a minimum, OSHA recommends testing at least every 3 years. Where can you find out more about spirometry? OSHA has posted a fact sheet for employers on its website < This page will give you more details and links to additional information. 4 Continued on Page 5

5 Continued from Page 4 Why It Matters * Workers who inhale some types of dusts, gases, or other air contaminants can, over time, experience lung damage. * Spirometry can detect breathing problems or significant changes in a worker's lung function at an early stage when the problems are more treatable. * OSHA says that spirometry is "the best available test for early detection of decreasing or abnormal lung function." * NIOSH says that spirometry is "a vital component of health and safety programs in workplaces where workers may be exposed to hazardous airborne contaminants." The Case of the Wrong Respirator We read about an actual accident, investigated by OSHA, which had real-life implications for a worker, his co-worker, and the employer. This safety incident, investigated by OSHA illustrates the danger of poorly trained employees. It also provides you with the perfect training tool to make sure none of your workers is ever involved in an accident like this one. An employee was applying primer that was pure 1,1,1-trichloroethane to the inside concrete walls of 5' x 5' planter boxes with varying depths of 8', 12', and 16'. Two of each size, six in all, were to be primed. Please note that in addition to the chemical safety hazard, there's also another critical issue. Those planter boxes should have been considered confined spaces, and apparently weren't. Anyway, the employee was wearing an air-purifying half-face respirator rather than the supplied-air respirator required for 1,1,1-trichloroethane. So it wasn't long before the employee was overcome and became unconscious from the toxic vapors. To make matters worse, a co-worker rushed to rescue the employee. The co-worker wasn't wearing any respirator. Naturally, he also was also overcome and became unconscious. Fortunately, somebody in this workplace must have been using his or her head and called for emergency assistance. The fire department arrived in time to rescue both employees. Measurements indicated at least 80,000 parts per million (ppm) of 1,1,1-trichloroethane vapors at the bottom of the 16' planter box that the employee had entered. The immediately dangerous to life and health (IDLH) level for 1,1,1-trichloroethane is 1,000 ppm. These employees could have died from the exposure. They were very fortunate. What Went Wrong Several things went wrong here, and together they created a near-fatal accident scenario. * The employee did not assess the potential respiratory hazards before starting the job. * The employee selected the wrong type of respirator for the high concentration of 1,1,1- trichloroethane. * Although the investigation report does not tell us, we can probably assume that the employee was not properly trained in how to assess the respiratory hazards of the job or how to select the appropriate respirator. Continued on Page 6 5

6 Continued from Page 5 * The investigation report does not tell us for sure, but we can also probably assume that the employer did not have a written respiratory protection plan, because a properly written program would include respiratory protection practices for each job or task. Training Implications This case study has several important implications for respiratory protection training: * Make sure your respiratory protection plan is comprehensive and up to date. Ensure that all employees who must use respiratory protection are familiar with the plan. * Assess respiratory hazards of each job. Look for exposure to dusts, vapors, or lack of oxygen. * Make sure employees who perform those jobs know the level of exposure. * Monitor exposures routinely and require respiratory protection whenever OSHA exposure limits are exceeded. * Teach employees to select the appropriate respirator. Air-purifying cartridge respirators are acceptable for exposure to low concentrations of many chemicals. Air-supplied respirators, however, must be used when employees are exposed to high concentrations of chemicals or to extremely hazardous chemicals. * Make sure employees know how to get a good fit, and know how to conduct a proper seal check. Also see to it that employees are properly fit-tested at least annually. * Train and require employees to keep your respirator in good condition by cleaning them regularly and storing them so that they are protected from contaminants and maintain their natural shape. Reviewing case studies of real accidents with your employees will help them grasp the significance of safety training, better understand hazards, and be prepared to act safely to prevent similar incidents. Case studies are also a great starting point for a broader discussion of workplace safety issues. Thoughts for a New Year Never look back unless you are planning to go that way. -Henry David Thoreau What lies behind us and what lies before us are tiny matters compared to what lies within us. - Ralph Waldo Emerson Signs of the Times is an informational newsletter to inform and update our clients about the continuous changes in environmental compliance and safety news. This subscription service is provided by Pacific Management Services, 1735 North Fine, Suite 101, Fresno, California, , Phone (559) , FAX (559) , address: ldeanlowe@pacificmgt.com. Please contact L. Dean Lowe, Ph.D. with information, requests or questions. Visit our Web Site at pacificmgt.com. Pacific Management Services reports to Dun & Bradstreet, the Credit-Rating Service. Reproduction of Safety Meeting Repros is granted under license #