Safety Tips

Exploring Exposure Limits: What do those numbers mean?

If you’ve ever attended safety training, you surely have heard the terms PEL, TLV, REL and STEL.  Do these letters really have a meaning or are they just a bunch of alphabet soup?  These acronyms all represent different occupational exposure limits (OELs) that are derived by different organizations.  An OEL is representative of the highest concentration a healthy worker can be exposed to for a full work week over the duration of their working life without experiencing an adverse effect.  Although similar, they each have a different goal and meaning.

Permissible Exposure Limit (PEL)

The Permissible Exposure Limit, or PEL, is the most widely known exposure limit.  This is the OSHA 8-hour time weighted average (TWA) exposure limit and is the only limit directly enforceable by regulation.  OSHA limits must be approved by Congress and take into account both health benefits and industry costs.  PELs are difficult to change because of the congressional approval required.  These […]

February 5th, 2020|Categories: Insights|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 […]

Is an In-House Blood Donation Program Necessary at Your Company?

The use of fresh blood drawn from company employees is sometimes required when timelines in experiments are too tight to use an outside blood supply vendor. That said, it is considered to be preferable from a safety standpoint, and often a logistical one as well, that an outside blood supply vendor be used rather than establishing an in-house program.

When research needs require establishing an in-house blood donation program, there are numerous considerations to take into account including:

  • Involvement of the legal department to develop an informed consent form for voluntary blood donation. This form should include an explanation of the risks associated with participating in the program, confidentiality concerns, and compensation for program participation, if any.
  • An evaluation of the need to establish an Institutional Review Board. If your company receives federal funding and/or the blood collected is being used to support an FDA submission, it’s very important to determine the need for […]

Are You a Virtual Manufacturer?

Many of Safety Partners’ clients hold Controlled Substances Registrations (Researcher) for the research use of controlled substances.  In Massachusetts, a controlled substance includes all drugs regulated by the Drug Enforcement Agency (DEA) in schedules I through V as well as Schedule VI, which is defined as all prescription drugs, which are not included in any other schedule.  In addition to Researcher Registrations, the Massachusetts Department of Public health (DPH) has required registrations for controlled substances Manufacturers.

Did you know that the Mass DPH now requires registrations for Virtual Manufacturers?  A Virtual Manufacturer is defined as “a person in the business of manufacturing or distributing a controlled substance and who has a principal place of business located in the Commonwealth, but at no time takes physical possession of any controlled substance in the Commonwealth.”  Under this definition, you would be a virtual manufacturer if your company was using a contract manufacturing organization (CMO) for drug manufacturing.

This […]

Proposed Changes to the MWRA Regulations

Proposed changes to the Massachusetts Water Resources Authority (MWRA) Sewer Use Regulations (360 CMR 10.000) were published in April 2019 and a public hearing on the changes was held this week on May 13. For those of you who didn’t get to participate in the public hearing and would still like to submit comments, the deadline for written comments to the MWRA is May 20th.

For most Safety Partners’ clients, the proposed changes are relatively minor. The most noticeable impact will likely be for those of you that hold Low Flow/Low Pollutant Permits. The fee for these permits will be increasing from an initial one-time fee of $244.00 for the 5-year duration of the permit to an annual fee starting in 2020 of $100.00/per year, increasing about 3% each year, for a total cost for the 5-year duration of the permit of $532.00.

Those clients holding Category 2 permits will also be seeing an increase in […]

Responding to an Exposure Incident – The Steps to Take

Would you know what to do if an employee at your company had a needlestick injury or other exposure incident?  Other routes of exposure to biological material include accidents with other types of sharps as well as exposure to the mucous membranes of the eyes, nose, mouth, and non-intact skin.

Don’t be caught off guard! The last thing you want to be doing following an incident involving an exposure to potentially infectious material, or material known to be infectious, is figuring out the appropriate steps to take.  Proper incident response is critical to worker health and safety.  The Centers for Disease Control (CDC) recommends that these steps be followed after an exposure incident:

Step 1, provide immediate care to the exposure site: this includes washing the puncture area for 15 minutes with soap and water.  Remember, do not force bleed the wound!  Splashes to the mucous membranes (eyes, nose, mouth, or non-intact skin) should also be […]

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.