Chemical Safety

Hazard and Risk Analysis

The terms risk and hazard are used often in the safety world, many times interchangeably. They have very different meanings, however, and when using these terms, care should be taken to use them appropriately. When evaluating a process or procedure, assigning these terms appropriately can help simplify the safety assessment process.

What is a hazard?

A hazard refers to a potential source of harm. Examples can include chemical, biological, radiological, and physical hazards. Toxic chemicals, infectious biologics, and moving mechanical parts are all different types of hazards. The hazard level of a particular item or condition is static, meaning it does not vary. However, it can be evaluated relative to other hazards. Simply put, a hazard is a material or condition that can have an adverse effect on a person’s health or physical property.

What is risk?

Risk is the potential for interaction with a hazard. Generally speaking, risk is referenced in relative […]

March is Workplace Eye Wellness Month

Prevent Blindness, the nation’s first eye health and vision care nonprofit organization, has deemed March as Workplace Eye Wellness Month. Did you know that thousands of people are blinded each year from work-related eye injuries? According to the CDC, each day about 2,000 U.S. employees sustain a work-related eye injury that requires medical treatment. About one third of the injuries are treated in hospital emergency departments, and more than 100 of these injuries result in one or more days away from work.

How do eye injuries happen to workers? The majority of eye injuries result from small foreign objects or flying particles getting in the eye. Large objects may also strike the eye or a worker may run into an object causing blunt-force eye trauma. Many eye injuries are also caused by chemical burns from chemicals such as acids and caustics as well as workplace cleaning products.

The encouraging news is that approximately 90% of eye injuries that occur in the workplace are […]

Biennial Reports Are Due March 1, 2020!

 

If your facility is registered with the MA DEP as a Large Quantity Generator (LQG) of hazardous waste, don’t forget that 2020 is a year when biennial reports must be filed.  Biennial reports are due by March 1st of even numbered years for any facility that exceeded the LQG threshold during the preceding odd numbered year, even if your facility is no longer registered as an LQG.  Treatment, Storage, and Disposal Facilities (TSDFs) are also required to report every two years.

Biennial reports provide the DEP with information on the quantity and nature of the hazardous waste that was generated in the previous year and whether the waste was sent for recycling, treatment, storage, or disposal. As of 2018, biennial reports need to be filed electronically using the RCRAInfo Industry Application. The electronic submission includes the following:

  • RCRA Subtitle C Site Identification Form
  • Waste Generation and Management (GM) Form
  • Waste Received From Off-Site (WR) Form, and […]

How to Protect Your Company From OSHA HazCom Violations

Did you know that violations related to the OSHA Hazard Communication standard ranked #2 in the OSHA top 10 list for most frequently cited violations in 2018? Common citations included not having a written program or safety data sheets (SDS) for all chemicals, lack of employee training, and deficiencies related to secondary container labels.

What can you do to protect your company from HazCom violations? Employers are responsible for ensuring that the labels and SDSs are readily available to all employees.  They are also responsible for training employees on how to properly recognize the hazards associated with chemicals and how to properly handle the chemicals based on the hazards conveyed.  For laboratories that use chemicals this specifically means that employers must ensure that:

  • Labels on incoming containers of hazardous chemicals are not removed or defaced. Incoming container labels must include the identity of the hazardous chemical(s), appropriate pictograms and signal word, and hazard and precautionary statements.
  • Labels […]

Reconcile Safety Data Sheets

Be sure to reconcile the Safety Data Sheets at your facility to verify that you have an SDS for all hazardous chemicals present on site.

29 CFR 1910.1200 Appendix D stipulates the minimum information required to be contained on a SDS, and specifies each section number and heading.  Hazard identification, first-aid measures, proper handling and storage requirements, appropriate personal protective equipment, exposure limits, and toxicological information are all covered on a SDS.  Information on the likely routes of exposure, symptoms of exposure, and immediate and delayed effects from short-term and long-term exposure are reported.  All of this information should be known by each individual working with a particular chemical.

It is the responsibility of the manufacturer, distributor, or importer to provide a SDS for each chemical.  It is the responsibility of the employer to make a SDS for each chemical in the workplace readily available to all employees.  And it is the responsibility of each individual […]

OSHA Announces Safe + Sound Week 2019

OSHA has announced that Safe + Sound 2019 will be held August 12-18, 2019.  This national event is intended to promote the value of workplace health and safety programs.

OSHA is encouraging employers to share the safety successes they have enjoyed over the past year during this week.  Employers are encouraged to hold events and activities that highlight the elements of their health and safety program during this week.  Developing fun interactive activities can engage employees and remind them of the established policies in a creative way.  Even though it is a long way away, take advantage of the long lead time to develop daily activities to highlight the importance of your EHS program!  You have plenty of time to prepare and think about the daily themes to cover during this week.

Updated MA Law for Public Workplaces

The updated Law M.G.L. Chapter 149 § 6 ½ requiring public sector workplaces to comply with OSHA regulations went into effect on February 1, 2019.  While this is a significant change for public workplaces, OSHA does continue to have jurisdiction over private employers. The Massachusetts requirements found in this updated law are as strict as the OSHA regulations.

The update clarifies that the definition of public sector workplace includes counties, municipalities, all state agencies, quasi-public independent entities, courts, bureaus, commissions, divisions or authorities of the commonwealth, political subdivisions, and public colleges and universities.  The Massachusetts Department of Labor Standards is responsible for enforcing this law at public sector workplaces.

If you have not heard about this update, know that public workplaces are now responsible for complying with OSHA regulations.

 

 

Remember to Conduct Chemical Inventories

OSHA’s Hazard Communication Standard, 29 CFR 1910.1200 requires that employers maintain a list of the hazardous chemicals known to be present in the workplace.  While conducting chemical inventories, it is prudent to ensure that the SDS files are up to date for all chemicals found during the inventory.  The Lab Standard, 29 CFR 1910.1450, applies to laboratory scale use of hazardous chemicals, and requires the implementation of a Chemical Hygiene Plan.  The Chemical Hygiene Plan in place at your institution should specify how the chemical inventory will be maintained and how the SDS system works.

Safety Partners recommends conducting physical chemical inventories on an annual basis, at a minimum.  There are several chemical inventory barcode software systems available for companies choosing to maintain on-going chemical tracking.  These systems track chemicals from receipt to disposal, relying on the users to track their use using the barcoding system.  If a full bar coding system is not an […]

Making Safety Training Fun

“I Love Safety Training!”

Wait…what?  Have you heard many people utter these words before?

It is easy to say that the importance of developing an effective safety training program should not be overlooked, but how do you put a fun and therefore effective safety training program into practice?

Developing a robust new employee safety orientation that encompasses a safety tour of the facility and interactive sessions to demonstrate the safety policies will likely improve material retention.  If new hires are forced to sit through hours of lectures to cover material that checks the boxes for various regulations, the details will be lost in the myriad of information given to them on their first day at a new job.  Encourage questions, ask questions, and get to know the new hires’ previous experiences with safety.  Start to build trust that a collaborative environment will be fostered from day one.

Even though annual refresher trainings are mandatory, this does not mean […]

Gap Analyses Benefit Everyone

If you have never conducted a gap analysis or if it has been some time since the last one, consider investing in this invaluable process.  Even if you have established a robust program, a gap analysis can provide input into what areas could use improvement or redefined focus.

A gap analysis should start with a thorough review of your EHS needs and an evaluation of the regulatory standards that are applicable to your site based on the work being conducted. This should include taking a deep dive into the hazardous materials present and how they are being stored, manipulated, and disposed of. When reviewing compliance with permit and license requirements, consider any permits or licenses that may have been overlooked due to changing needs or regulatory updates.

Gap analyses almost always produce a list of action items. Nice to have or do items that fell off the radar may be re-identified during the gap analysis and […]