Safety Tips

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 […]

Protect Your Eyes from Blue Light

As I mentioned in last week’s blog, Prevent Blindness has deemed March as Workplace Eye Wellness Month. This non-profit organization is currently promoting awareness about the dangers of blue light exposure from computers, televisions, and device screens including smart phones and tablet screens. Recent studies suggest that long-term exposure to the blue light emitted from these screens can cause digital eye strain with eye fatigue and dry eyes that can in some cases lead to eye problems like macular degeneration from damage to the cornea.

The largest source of blue light is sunlight. However, there is concern over the long-term effects of screen exposure because of the close proximity of the screens and the length of time spent looking at them, both during the workday and after.

So what can you do to protect your eyes from blue light?

  1. Screen time: Try to decrease the amount of time spent in front of screens and/or take frequent […]

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 […]

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 […]