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Not a trick question, but boy do we get “the look” when we ask the question just as it is written in 68.79 and .119(o). What does OSHA and EPA mean by certifying an audit? Who does this certification? Is this a formal exercise of certifying? Why did OSHA/EPA use this term in the standard? Here is my take…
Recently OSHA.gov has been experiencing some serious issues and although it appears to have gotten almost back to normal, sometimes access to standards is lost. And if you're like me and do a lot of work in locations where there is no internet connection and you need the standards for a project, here is a FREE and simple way to have ALL of 1910, 1926, Part 68, etc. at your disposal 100% of the time. Heck the shortcuts and links even work and it is "searchable" using your browsers search function. Your computer will not even know your not on line. Here's what you do...
A lot is going on with HAZCOM this year and the biggest activity is the conversion from the old MSDSs to the new 16 section format for the SDSs. OSHA recently issued a LOI to clarify the the compliance date...
Question: When is an employer required to replace their MSDS collection with revised SDSs in order to be in compliance with HCS 2012? Would OSHA take enforcement action against employers who only have an MSDS available to employees?
Response: OSHA's final rule modifying the Hazard Communication Standard (HCS) was issued on March 26, 2012, and it became effective on May 25, 2012 [77 FR 17574-17896]. Under 1910.1200(j)(2), manufacturers, importers, and distributors must be providing SDSs (instead of MSDSs) for all shipments of hazardous chemicals to employers and downstream customers by June 1, 2015. SDSs may be provided before this date; however, for any shipment of chemicals after June 1, 2015, an SDS in the required 16-section format must be provided.
All employers, per 1910.1200(g)(1) and 1910.1200(g)(8), must have, maintain, and make available to employees the most recent MSDS or SDS received from a chemical manufacturer, importer, or distributor for each hazardous chemical in the workplace. If the employer is not maintaining the most current MSDS or SDS received, then enforcement action may occur. However, OSHA would not issue citations for maintenance of MSDSs when SDSs have not been received. As OSHA explained in the January 31, 2013, letter to Mr. Joel Gregier employers may, but are not required to, contact manufacturers or distributers of products they have previously ordered to request new SDSs, and under 1910.1200(g)(6)(vi), the SDSs must be provided.
I recently participated in a PHA for a large flammable liquids process and during the "facility siting" portion of the PHA we took a detailed tour of the process. During which, several significant "impact" hazards were identified. Of course the long-time engineering manager (40 plus years of fine service at the facility) quickly went to the "its been that way for 50+ years and no one has hit the pipe/pipe support or dropped a load on the pipe/pipe support". So the question is... How much "safety credit" should we give based on a 50 year run of no damage/incidents when we can plainly see that the scenario has a high potential?
OSHA issued a memorandum to its Regional Administrators and State Designees on 12/242014. The memorandum provides Area Offices with guidance on when an on-site inspection is warranted. OSHA has divided injury and illness reports into three categories. OSHA will inspect facilities that report an injury or illness that falls into one of the first two categories and will issue a RRI letter (commonly referred to as a phone/fax letter) to employers who report an injury or illness that falls into the third. Here is the memo...
A crew was conducting well kill operations on a sweet oil well. A worker was monitoring the return flow to the service rig trough from on top of the rig tank. When the returns became gassier, the return flow was opened to the degasser section of the rig tank and the trough flow was pinched in slightly. The rig manager proceeded to the top of the rig tank stairs where his personal gas monitor immediately began to alarm on high LEL (lower explosive limit). The rig manager looked up to observe both the rig tank and the worker on the rig tank being engulfed in flames. The worker standing on top of the rig tank jumped over the handrail to the ground, and suffered a broken hand from the landing. The flash fire resulted in minor burns to the worker’s face, chest, back and thighs, and extensive burns to the forearms which required skin grafting surgery and 18 days in the hospital. The rig manager jumped off the stairs and was not injured in the event. Ignition source was determined to be a poorly terminated electrical livestock control fence “jumper” wire on the perimeter fencing. CLICK on image below for the full alert from ENFORM.
This Alert is intended to inform the industry that companies must take responsibility to prevent accidental releases of dangerous chemicals like anhydrous ammonia through compliance with CAA’s Chemical Accident Prevention Program. Evidence gathered by the U.S. Environmental Protection Agency (EPA) indicates that some refrigeration facilities may be failing to properly manage hazardous chemicals, including anhydrous ammonia, as required by the Clean Air Act (CAA) Section 112(r). This Alert is intended to inform the industry that companies must take responsibility to prevent accidental releases of dangerous chemicals like anhydrous ammonia through compliance with CAA’s Chemical Accident Prevention Program.