In this week’s Newsletter
- What the new "GHS" means to our HAZCOM compliance efforts with flammable liquids
- Flammable Storage Cabinets... Did you know?
- EPA uses RMP General Duty Clause to cite a flammable liquids business
- Tallying the Benefits of Regulation: Five Worker Health and Safety Rules Have Saved Thousands of Lives, Prevented Tens of Thousands of Injuries
- BST Publishes notable new findings on serious injury and fatality prevention, surpasses 30 years of practice in workplace safety improvement
Side Bar Items:
- SAFTENG Blog & SAFTENG LinkedIn Forum
- Safety and Health Tip – OSHA releases mobile app to help protect workers from heat-related illnesses
- Civilian Fire Fatalities
- Safety Recalls
- EHS Events
What the new "GHS" means to our HAZCOM compliance efforts with flammable liquids
We all know that OSHA's Hazardous Communications (HAZCOM) Standard (1910.1200) has been the most cited OSHA standard in the history of OSHA. This has largely been because almost every single workplace falls under the standard. The HAZCOM standard stands to maintain this #1 ranking, but for an entirely different reason: The Globally Harmonized Standard! OSHA has "indicated" they plan to adopt this system. I have not seen any compliance deadline dates or anything like that, but everything I see from the government is that we have completed the Public Rule Making steps and had the Public Hearing(s) and are now in the "Final Action". I would think that a change of this magnitude would have a lengthy implementation period, but I have been wrong before!!! In this article I want to try an point out some SERIOUS CHANGES that will be coming with the GHS in regards to our flammable liquids.
The biggest change that I see in this area is how the new standard defines and categorizes flammable and combustible liquids. Basically, anything with a flash point below 200F is defined as a "Flammable Liquid". The new standard eliminates the definition of a "combustible liquid". The GHS then breaks flammable liquids down into four (4) categories. In our current NFPA 704 and HMIS labeling systems we use the numerical value of ZERO (0) to indicate no hazard and the numerical value of four (4) to indicate the highest degree of hazard. In the new GHS categorization of "flammable liquids" the numerical value of one (1) indicates the highest degree of hazard and the numerical valve of four (4) indicates the lowest degree of hazard!!!
Category 1 has a Flash point < 23°C (73.4°F) and initial boiling point ≤35°C (95°F); we used to call this a Class IA flammable liquid.
Category 2 has a Flash point < 23°C (73.4°F) and initial boiling point > 35°C (95°F); we used to call this a Class IB flammable liquid.
Category 3 has a Flash point ≥ 23°C (73.4°F) and < 60°C (140°F); we used to call this a Class IC flammable liquid, but the old IC class used an upper FP of 100F instead of 140F.
Category 4 has a Flash point > 60°C (140°F) and less than or equal to 93°C (199.4°F); we used to call this a Class IIIA Combustible Liquid.
This will be tough reversing the numbering system for risk levels, as it is a complete reversal from our current NFPA and HMIS values. I am also at a loss as to how OSHA plans to revise 1910.106 and 1910.119 so as to make them work with this new classification system. I am guessing, they can leave .106 and .119 as they are and have multiple definitions in different standards for what a "flammable liquid". However, with this new classification, some Class IC flammable liquids will NO LONGER be covered by the PSM Standard!!!
Where do I begin? Our labeling systems have for the most part followed the Hazardous Materials Identification Systems (HMIS) or NFPA 704 (the "diamond"). Neither of these systems will meet the new labeling requirements of the GHS! We will not have to remove the old labels, but we WILL HAVE TO apply new labels that have a COMPLETELY different numbering system and will also include "pictograms". "Pictograms" are defined as "a composition that may include a symbol plus other graphic elements, such as a border, background pattern, or color, that is intended to convey specific information about the hazards of a chemical. Eight pictograms are designated under this standard for application to a hazard category." This means ALL containers will have to be labeled AGAIN but with the new labeling under the GHS. For many large facilities this will be a MAJOR exercise and at considerable costs. I have no way of quantifying the lost money in the labels we have in stock that will NO LONGER be of use, but we can quantify the costs of the new labels and it ain't going to be cheap! Here is an example of what the new label will look like on our flammable liquids.
Material Safety Data Sheets
Some MSDS's will already be in the required GHS 16 section format; however, the contents will have to be rewritten using the new hazard classes. And by the way, they will be just "Safety Data Sheets" rather than "Material Safety Data Sheets".
Just think, this is all just for your flammable and combustible liquids! You will have to get new MSDS (or SDS as they are called in GHS) for the gasoline and diesel used in vehicles on site, change the labels on the fuel tanks and portable containers, and retrain workers on the new hazard classes and labels. How about those containers that we bought with the HMIS or NFPA labels imprinted on them, or maybe they have hazard wording that is no longer accepted under the GHS! This is just scratching the surface on this upcoming change.
For more info on this change, here is some info provided by OSHA.
Proposed HCS regulatory text [63 KB PDF*, 30 pages]
Proposed Appendix A: Health Hazard Criteria (Mandatory) [347 KB PDF*, 68 pages]
Proposed Appendix B: Physical Hazard Criteria (Mandatory) [130 KB PDF*, 28 pages]
Proposed Appendix C: Allocation of Label Elements (Mandatory) [350 KB PDF*, 75 pages]
Proposed Appendix D: Safety Data Sheets (Mandatory) [53 KB PDF*, 3 pages]
Proposed Appendix E (Existing Appendix D): Definition of Trade Secret (Mandatory) [21 KB PDF*, 2 pages]
Proposed Appendix F: Guidance for Hazard Classifications Regarding Carcinogenicity (Non-Mandatory) [62 KB PDF*, 4 pages]
Proposed HCS regulatory text (redline strikeout) [261 KB PDF*, 38 pages]
Side-by-side comparison of the current HCS to the Proposed Rule [327 KB PDF*, 45 pages]
Facts on Aligning the Hazard Communication Standard to the GHS
OSHA has also completed a detailed comparison of the provisions of the GHS to the requirements of the HCS. This document indicates the changes that would have to be made to be consistent with the GHS. [Also available as a 901 KB PDF, 153 pages.]
Other Federal Agency Activities
Flammable Storage Cabinets... Did you know?
A flammable storage cabinet is MUCH different than a regular office cabinet! They may look similar in size and shape, but that is where their similarity ends. There are special features that a flammable storage cabinet MUST HAVE to comply with NFPA 30 and/or 1910.106(d)(3).
1) the door(s) MUST have three point latching. One at the top of the door, side/mid-way on the door and the bottom of the door. This is usually the first thing to go bad on a cabinet, but are actually the MOST CRITICAL function of any moving parts on the cabinet. Without adequate latching at the three points, the heat the cabinet could be exposed to will warp the door and actually open a crease that allows the heat inside the cabinet, thus rendering the cabinet useless.
2) The bottom, top, door(s), and sides of cabinet must be at least No. 18 gage sheet iron and double walled with 1.5" air space. This is what really separates these cabinets from the "office type" cabinet and what makes them "fire safe" cabinets.
3) The door sill MUST be raised at least 2" above the bottom of the cabinet. This 2" raised sill acts as a secondary containment for any spills inside the cabinet. This prevents the formation of a "fuse". Without this secondary containment any spill inside the cabinet could run outside of the cabinet and act like a fuse to allow fire to burn the spilled material and enter the cabinet.
4) Cabinets MUST be labeled in conspicuous lettering, "Flammable - Keep Fire Away." The labeling is a REQUIREMENT that is often overlooked. We have seen cabinets that meet the construction requirements, but had their original labeling painted over or removed. 1910.106(d)(3) does not have a size requirement, but NFPA 30 does. NFPA 30-9.5.5 states "Storage cabinets shall be marked in lettering that is at least 2 in. (50 mm) high as follows:WARNING: FLAMMABLE — KEEP FIRE AWAY."
5) To vent or not to vent. Cabinets are NOT required to be vented. In fact NFPA 30 suggest that cabinets should NOT be vented, but if they are vented, they MUST BE VENTED properly. This means that the storage cabinet vent openings shall be ducted directly to outdoors in such a manner that will not compromise the specified performance of the cabinet and in a manner that is acceptable to the authority having jurisdiction. Here is what NFPA 30 states about venting cabinets..."Venting of storage cabinets has not been demonstrated to be necessary for fire protection purposes. Additionally, venting a cabinet could compromise the ability of the cabinet to adequately protect its contents from involvement in a fire, because cabinets are not generally tested with any venting. Therefore, venting of storage cabinets is not recommended. However, it is recognized that some jurisdictions might require storage cabinets to be vented and that venting can also be desirable for other reasons, such as health and safety. In such cases, the venting system should be installed so as to not affect substantially the desired performance of the cabinet during a fire. Means of accomplishing this can include thermally actuated dampers on the vent openings or sufficiently insulating the vent piping system to prevent the internal temperature of the cabinet from rising above that specified. Any make-up air to the cabinet should also be arranged in a similar manner. If vented, the cabinet should be vented from the bottom with make-up air supplied to the top. Also, mechanical exhaust ventilation is preferred and should comply with NFPA 91, Standard for Exhaust Systems for Air Conveying of Vapors, Gases, Mists, and Noncombustible Particulate Solids. Manifolding the vents of multiple storage cabinets should be avoided."
6) Can I put my cabinet on wheels or set it on a pallet? We see this more and more with all the 5-S type housekeeping and organizing efforts; but is it safe to put wheels on a cabinet or to sit it on a pallet for easy moving with a forklift? A big NO is the answer and here is why. Installing wheels on the bottom of the cabinet requires drilling into the cabinet and this will hamper it's fire rating. Setting the cabinet on a wheeled cart is a bad idea as it makes it very unstable. Setting the cabinet on a wooden or plastic pallet is a bad idea as the pallet can weaken in a fire and cause the cabinet to fall over causing a large flammable liquid spill in the middle of a fire. The idea that setting the cabinet on a pallet makes it easy to move, also makes it prone to falling over and creating a flammable liquid spill. PLEASE DO NOT use employees to hold onto the cabinet as it is being moved by the PIT. You should ALWAYS EMPTY the cabinet before it is MOVED.
7) Do I need to ground my cabinets? Grounding cabinets certainly does not hurt, but is NOT required when the cabinet is storing individual containers that are small quantity. If your cabinet stores containers and workers will be transferring OUT of or INTO the container(s) inside the cabinet, then the cabinet MUST BE GROUNDED properly (see picture below for the type of cabinet that needs grounding).
In fact, the entire ground path needs to be verified it is effective as some of these cabinets and their drum carriages require some basic assembly and if instructions are not followed to the letter, we have found some drums within the cabinets NOT actually grounded, even though the cabinet was grounded. Do you see anything wrong with the grounding of the drum in the picture below? This is a "commercially available" system that can be bought from a reputable vendor, but if this system is NOT set up and tested for grounding properly, there could be some SERIOUS flammable liquid issues! By the way, the drums in these cabinets MUST be equipped with "dead man" (e.g. spring-loaded) valves that are made of a compatible metal and NOT plastic! More on this in future postings.
EPA uses RMP General Duty Clause to cite a flammable liquids business
The United States has reached agreement with the owners and a former operator of an inks and paint products manufacturing facility in Danvers, Mass., that exploded and burned in 2006 the day before Thanksgiving. Under a consent decree by the U.S. Department of Justice on behalf of the Environmental Protection Agency (EPA), the owners and operator will pay the U.S. Government a projected $1.3 million, including cash and the net proceeds from sale of the facility property, assuming the property sells for its appraised value. Most of that recovery will go to reimburse EPA for its $2.7 million in costs of cleaning up hazardous waste after the explosion. In addition, the company will pay EPA a penalty of $100,000 to settle allegations that conditions at the facility violated the General Duty Clause in Section 112(r) of the Clean Air Act. The consent decree resolves claims in a complaint against former owners and a realty trust. A separate consent decree with former operator of the facility was entered by the court in July 2011. The settlement amounts in both consent decrees were based on demonstrations by the settling defendants of limited financial resources. EPA’s cleanup action and investigation were undertaken as a result of the explosion and chemical fire that occurred on Nov. 22, 2006, at the industrial building in Danvers. On the night before Thanksgiving, a series of explosions demolished the manufacturing facility. The plant stored and used considerable quantities of ignitable and flammable substances in their manufacturing of solvent-based ink, paint, thinners and/or industrial coatings. The explosion and subsequent fire destroyed the 12,000 square foot building, and the surrounding commercial and residential community experienced significant structural and property damage from the blast. Approximately 24 homes and six businesses were severely damaged and subsequently demolished; another 70 homes were damaged. An estimated 300 residents within a half-mile radius of the facility were evacuated by the Danvers fire department. Firefighting efforts lasted nearly 17 hours. While several people were injured and hospitalized, no fatalities occurred.
From Nov. 2006 to March 2007, EPA performed a removal of hazardous substances released or threatened to be released to the environment as a result of the explosion. EPA fenced off the site, took air samples, drained vats, totes and underground storage tanks, removed drums of chemicals, pumped off stormwater runoff, and removed soil, debris and scrap steel. After the incident, EPA, in close coordination with other federal and state agencies, investigated the facility operators’ compliance with various federal laws, including the General Duty Clause of the Clean Air Act. Under the agreement, operator will pay EPA a penalty of $100,000 to settle EPA allegations that the following conditions at the facility, among others, contributed to the General Duty Clause violations: failure to identify the hazards of operating an ink mixing process overnight without proper ventilation; lack of appropriate ventilation, lack of vapor detectors and alarms to detect buildup of dangerous vapors while workers were not present, lack of automatic shut-off valves that could shut down processes if human operators forgot to do so, failure to have the proper fire permits, and lack of explosion venting construction. The plants penalty also resolved a claim under Section 114(a) of the Clean Air Act for failure to respond to an EPA request for information related to the company’s handling of extremely hazardous substances.
Tallying the Benefits of Regulation: Five Worker Health and Safety Rules Have Saved Thousands of Lives, Prevented Tens of Thousands of Injuries
Five major worker health and safety rules, most of which were initially opposed by industry, have saved thousands of lives, prevented tens of thousands of injuries and in at least one case improved productivity, a Public Citizen analysis shows. The analysis comes as corporate interests ramp up efforts to gut the federal regulatory system. To make their case, they claim that rules are burdensome and costly, but they fail to acknowledge that the rules have benefits. Regulations often yield enormous advantages, sometimes at minimal costs to industry, Public Citizen’s analysis found. The five major worker health and safety rules outlined in the report include:
• A rule requiring the cotton industry to reduce dust in textile factories lowered the prevalence of brown lung among industry employees by 97 percent in the first five years. In addition, when factories upgraded their equipment to comply with the rule, they found the new machines were seven times faster than the old ones. Also, compliance cost far less than originally anticipated.
• A rule requiring manufacturers to place locks and warning labels on powered equipment prevents 50,000 injuries and 120 fatalities per year.
• A rule on excavations at construction sites has reduced the fatality rate from cave-ins by 40 percent.
• A grain-handling facilities standard has reduced the number of fatalities caused by dust-related explosions by 95 percent. When the rule was being considered, industry groups and the Reagan administration opposed it. Years after the standard was issued, however, the National Grain and Feed Association said it is remarkably effective.
• A law instituting inspections in coal mines as well as new mine health and safety standards led to a rapid 50 percent decrease in the coal mine fatality rate.
BST Publishes notable new findings on serious injury and fatality prevention, surpasses 30 years of practice in workplace safety improvement
At the turn of its 30th year of incorporation, California-based global workplace safety consultancy BST (Behavioral Science Technology, Inc.) has published notable new findings about the causation and prevention of serious injuries and fatalities in the workplace. These findings were the product of a year-long joint research study conducted by BST and ORC Mercer Worldwide, along with representation and extensive data from seven global corporations(ExxonMobil, PotashCorp, Shell, BHP Billiton, Cargill, Archer Daniels Midland Company, and Maersk). BST Chairman Tom Krause explained that “over the past several years we’ve seen a troubling patternemerge where minor injury incident rates have steadily decreased at the same time incident rates for serious injuries and fatalities have generally held flat and in some segments have increased. This contradicts a decades-old paradigm in the safety community which has held that declines inminor injuries produce proportionate declines in serious injuries and compelled us and our client community to learn more about differences in causation and what these findings mean for prevention approaches.” Highlighting key study elements, Krause shared that “interestingly, our research found that: 1) all minor injuries are not the same in their potential for serious injury or fatality, 2) injuries of differing severity have differing underlying causes, and 3) reducing serious injuries requires a different strategy than reducing less serious injuries. We believe these findings and the implementation requirements they inform will lead to new and improved prevention methodologies for serious injuries and fatalities.” Reflecting on the timing of the study related to BST’s 30th anniversary of incorporation,Krause noted, “I’m pleased that after 30 years of partnering with organizations to make work safer, our curiosity to know more through continuous research persists. We’ve learned a lot, but there is much more we need to better understand and apply to promote injury-free workplaces.” For a copy of the white paper detailing the study and its findings, visit www.BSTsolutions.com/SIF.
SAFTENG Blog &
SAFTENG LinkedIn Forum
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Topics this week:
- OSHA orders Burlington Northern Santa Fe Railway in Seattle to pay more than $300,000 to suspended whistleblower
- What the new "GHS" means to our HAZCOM compliance efforts with flammable liquids
- Does anyone know if they are still going to roll out the GHS standard this year?
- ARE RX PAINKILLERS DOING HARM OR GOOD TO THE INJURED WORKER?
- OSHA cites Georgia company for exposing employees at Dayton, NJ, facility to amputation hazards
- OSHA cites Newark, NJ, construction company for exposing workers to fall, other hazards
- 43 incidents & 0 updates (8/18/11)
- Hand Injury Reduction
- Timber firm fined after worker injured
- First aid at work
- Meat plant worker killed by forklift
- OSHA cites Alabama manufacturer for combustible dust and other hazards; proposes nearly $55,000 in fines
- Linkedln using personal information in advertising
- OSHA issues hazard alerts on dangers of worker engulfment and suffocation in grain bins
- OSHA cites Swedesboro, NJ, food processing company for exposing employees to safety hazards
- OSHA cites Ashland, Ohio-based Americarb for 11 safety violations after workplace fatality
- OSHA cites Buffalo Framing and Truss with serious and repeat violations for construction
- How strong does my explosion have to be to do damage?
- Worker crushed between two skips
- PPE Assessment [Aug 2011]
- OSHA to sponsor 2 heat illness prevention training events in August for Florida construction
- OSHA notifies Hill Air Force Base in Ogden, Utah, of unsafe and unhealthful working conditions
- Substances hazardous to health in agriculture include: dusts from plants, animals, composted and fermented materials; regulated products - pesticides, medicines, feed additives; products used in silage making (and off-gases)
- EPA Update on Yellowstone River Oil Spill (Silvertip Pipeline), August 12th, 2011
- Interesting data from DC– top 10 industries that had complaints
- Another valve that needs to be Car-Sealed OPEN
- New Funding Opportunity: NLM Disaster Health Information Outreach and Collaboration Project 2011
- 30 incidents & 0 updates (8/12/11)
- Jeremy Williams and Brian Chapin of Garden City Ammonia Program discuss the outline of the chemical and refinery NEP and the results
Jobs posted on SAFTENG LinkedIn Forum:
- Molycorp Minerals is hiring a Safety Specialist who specializes in MSHA training to work at our new chemical processing plant located in Mountain Pass, CA, 60 miles south of Las Vegas, NV.
- Seeking Oil & Gas clients with requirements for Process Engineer professionals to work either on Permanent or Contract basis in the UK
- Principal Consultant - CFD specialist - London
- Various Safety Positions in Northern NJ and NY Metropolitan Areas
- Safety Engineer
URGENTLY NEED NUCLEAR SAFETY AND SYSTEMS SECTION LEADER (SC CLEARED) in UK, (£DOE)
Safety and Health Tip
OSHA releases mobile app to help protect workers from heat-related illnesses
The app, available in English and Spanish, combines heat index data from the U.S. National Oceanic and Atmospheric Administration with the user’s location to determine necessary protective measures. Based on the risk level of the heat index, the app provides users with information about precautions they make take such as drinking fluids, taking rest breaks and adjusting work operations. Users also can review the signs and symptoms of heat stroke, heat exhaustion and other heat-related illnesses, and learn about first aid steps to take in an emergency. Information for supervisors is also available through the app on how to gradually build up the workload for new workers as well as how to train employees on heat illness signs and symptoms. Additionally, users can contact OSHA directly through the app. The app is designed for devices using an Android platform, and versions for BlackBerry and iPhone users will be released shortly. To download it, visit http://go.usa.gov/KFE.
Civilian Fire Fatalities
On August 18, 2011, 5 residential fire fatalities were reported by news media throughout the United States.
Office Depot Recalls Desk Chairs Due to Pinch Hazard
Macy's Recalls Martha Stewart Collection Enamel Cast Iron Casseroles Due to Laceration and Burn Hazard
C. O. Lynch Enterprises Inc. Recalls Itasca Fusion Hiker Boots Due to Foot Injury Hazard; Sold Exclusively at Big 5 Sporting Goods
Table-Top Clip-on Chair Recalled by phil&teds USA Due to Fall and Amputation Hazards
Riding Toy Recalled by Radio Flyer Due to Fall Hazard
Umarex USA Recalls to Repair Browning 800 Mag Air Pistols; Pistols Can Fire Unexpectedly
Dining Tables Recalled by EQ3 Due to Collapse and Impact Hazards
Philips Lighting Recalls EnergySaver and Marathon Compact Fluorescent Dimmable Reflector Flood Lamps Due to Laceration Hazard
Emergency Exit Signs Recalled by Best Lighting Products Due to Failure to Illuminate
Target Recalls Step Stools with Storage Due to Fall Hazard
Child Safety Seat Recalls
2011 Georgia Safety, Health and Environmental Conference
September 6-9, 2011
NJ ASSE Summer PDC
September 14, 2011
Mary Kay O'Connor Process Safety Center International Symposium
October 25-27, 2011
College Station, TX
If you have a conference or an outing for your safety organization, let me now and I can help spread the message. And yes, posting is FREE!