OSHA

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 […]

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 […]

OSHA Safe + Sound Week- Do you want to energize your safety program?

The third annual OSHA Safe + Sound Week is being held August 12-18, 2019. This national event is intended to promote the value of workplace health and safety programs. Employers are encouraged to hold events and activities that highlight the elements of their health and safety program during this week. It has been a huge success at Safety Partners’ clients who have participated in previous years!

Why participate?

Participating in the program is a great way to recognize your safety successes and show your commitment to safety! It’s also a perfect opportunity to raise awareness of your safety program in a fun and engaging way. Participating in Safe + Sound Week can help get your program started, energize an existing one, and provide a chance to recognize your safety successes.

Remember- safe workplaces are sound businesses. Successful safety and health programs can proactively identify and manage workplace hazards before they cause injury or illness, improving sustainability and […]

August 7th, 2019|Categories: Events|Tags: |

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 […]

Did You Know About Planned Changes to the OSHA Hazard Communication Standard?

OSHA has been involved with a long-term project to be aligned with the Globally Harmonized System (GHS) of classifying chemical hazards and providing labels and safety data sheets for hazardous chemicals. OSHA incorporated the GHS system into the Hazard Communication Standard (HCS) in March 2012 to specify requirements for hazard classification and to standardize label components and information on safety data sheets, in an effort to enhance both employer and worker comprehension of hazards and facilitate international compliance.

The GHS has been updated several times since OSHA’s 2012 rulemaking which was based on the third edition of the GHS and the United Nations recently completed the seventh edition. OSHA is now in the process of conducting rulemaking to harmonize the Hazard Communication Standard (HCS) to the latest edition of the GHS and to codify a number of enforcement policies that have been issued since the 2012 standard. OSHA has recently published a new Proposed Rule “Update […]

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.

 

 

Start Preparing OSHA Form 300A

All establishments covered by OSHA’s Part 1904 are required to complete Form 300A, Summary of Work-Related Injuries and Illnesses, on an annual basis.

This form summarizes the number of recordable work-related injury and illness cases, the number of days work was affected, and the types of injuries and illnesses.  Information about the company, including the average number of employees and total hours worked by all employees must also be recorded.  Form 300A must be posted from February 1 through April 30 of the year following the year covered by the OSHA 300 log.  Even if no recordable incidents or illnesses occurred during the previous year, the 300A form must be completed and posted reflecting zeros.  While going through this process, also take the time to review the incidents on the OSHA 300 log to ensure they have been recorded properly.

If you have not started completing this form already, be sure to get started so you […]

Revisit Manuals

When facilities are established, safety manuals need to be put into place. Customization of the initial manuals can be challenging when the full scope of lab operations is not completely certain.  As work evolves and work practices become firmly established, updates to the manuals may be necessary.

Waste handling practices, safe work practices, safety equipment locations, and just about any other content may need to be updated over time.  As job safety analyses and risk assessments are conducted, SOPs may need to be added as appendices to the corresponding manual.  As safety officers change with time, the contact information and responsibilities need to be updated.  Ensure your manuals are living documents, and not just quickly reviewed every couple years.  At a minimum, a thorough review of each manual should be conducted on an annual basis.  Various regulations also stipulate that manuals need to be updated if the established procedures are found to be deficient in an emergency situation.

Take […]

 OSHA’s Exposure and Medical Record Standard

OSHA’s Access to employee exposure and medical records standard, 29 CFR 1910.1020, stipulates the requirements for medical and exposure records.  The requirements for how to keep these records as well as the retention of these records is specified in this standard.

29 CFR 1910.1020(c)(6) defines an “employee medical record” as a record concerning the health status of an employee which is made or maintained by a physician, nurse, or other health care personnel, or technician, including various records further defined in this section.  There are numerous requirements stipulated in this standard, but employee medical and exposure records must be kept for the duration of employment plus 30 years.  If the company closes, all records must be transferred to the successor. If there is no successor, current employees must be notified of their right to access their medical records at least 3 months before the closure.

There are other standards that stipulate additional recordkeeping requirements so be […]