Safety Data Sheet Deadline is Approaching

• Classify your products according to the new hazard classification provisions of 29 CFR 1910.1200(d). The new health and physical hazard definitions must be used.
• Ensure the information provided on SDSs accurately reflects the scientific evidence used in making the hazard classification
• Complete the required sections of the SDS in the order specified at 29 CFR 1910.1200 - Appendix D
• Provide your customers with an SDS prior to or with their initial shipment of a hazardous chemical
• Revise any SDS within three months of becoming aware of new information pertaining to the hazardous chemical
• Provide your customers with an updated SDS at the time of their next chemical shipment when information on the previous SDS version has changed

1. Identification
   1. Product identifier used on the label
   2. Other means of identification
   3. Recommended use of the chemical and restrictions on use
   4. Name, address, and telephone number of the chemical manufacturer, importer, or other responsible party
   5. Emergency phone number
2. Hazard(s) Identification
   1. Classification of the chemical in accordance with 29 CFR 1910.1200(d)
   2. Signal word, hazard statement(s), symbol(s), and precautionary statement(s) in accordance with 29 CFR 1910.1200(f). Ensure that you use the exact wording specified in the rule for your hazard and precautionary statements. Also ensure that you follow OSHA’s instructions for including specific information on PPE and first aid. The hazard symbols (pictograms) may be provided as graphical reproductions in black and white or the name of the symbol, e.g., flame, skull, and crossbones.
   3. Describe any hazards not otherwise classified that have been identified during the classification process
   4.  Where an ingredient with unknown acute toxicity is used in a mixture at a concentration ≥ 1% and the mixture is not classified based on testing of the mixture as a whole, a statement that X% of the mixture consists of ingredient(s) of unknown acute toxicity is required
3. Composition/Information on Ingredients. Except as provided for in 29 CFR 1910.1200(i) on trade secrets:

1. First-aid Measures
   1. Description of necessary measures, subdivided according to the different routes of exposure, i.e., inhalation, skin and eye contact, and ingestion
   2. Most important symptoms/effects, acute and delayed
   3. Indication of immediate medical attention and special treatment needed, if necessary
2. Firefighting Measures
   
   1. Suitable (and unsuitable) extinguishing media
   2. Specific hazards arising from the chemical (e.g., nature of any hazardous combustion products)
   3. Special protective equipment and precautions for firefighters
3. Accidental Release Measures
   1. Personal precautions, protective equipment, and emergency procedures
   2. Methods and materials for containment and cleaning up
4. Handling and Storage
   1. Precautions for safe handling
   2. Conditions for safe storage, including any incompatibilities
5. Exposure Controls/Personal Protection
   1. OSHA permissible exposure limit (PEL), American Conference of Governmental Industrial Hygienists (ACGIH) Threshold Limit Value (TLV), and any other exposure limit used or recommended by the chemical manufacturer, importer, or employer preparing the safety data sheet, where available
   2. Appropriate engineering controls
   3. Individual protection measures, such as personal protective equipment
6. Physical and Chemical Properties
   1. Appearance (physical state, color, etc.)
   2. Odor
   3. Odor threshold
   4. pH
   5. Melting point/freezing point
   6. Initial boiling point and boiling range
   7. Flash point
   8. Evaporation rate
   9. Flammability (solid, gas)
   10. Upper/lower flammability or explosive limits
   11. Vapor pressure
   12. Vapor density
   13. Relative density
   14. Solubility(ies)
   15. Partition coefficient: n-octanol/water
   16. Auto-ignition temperature
   17. Decomposition temperature
   18. Viscosity
7. Stability and Reactivity
   1. Reactivity
   2. Chemical stability
   3. Possibility of hazardous reactions
   4. Conditions to avoid (e.g., static discharge, shock, or vibration)
   5. Incompatible materials
   6. Hazardous decomposition products
8. Toxicological Information Description of the various toxicological (health) effects and the available data used to identify those effects, including:
   1. Information on the likely routes of exposure (inhalation, ingestion, skin, and eye contact)
   2. Symptoms related to the physical, chemical, and toxicological haracteristics
   3. Delayed and immediate effects and also chronic effects from short and long-term exposure
   4. Numerical measures of toxicity (such as acute toxicity estimates)
   5. Whether the hazardous chemical is listed in the National Toxicology Program (NTP) Report on Carcinogens (latest edition) or has been found to be a potential carcinogen in the International Agency for Research on Cancer (IARC) Monographs (latest edition), or by OSHA
9. Ecological Information*
   1. Ecotoxicity (aquatic and terrestrial, where available)
   2. Persistence and degradability
   3. Bioaccumulative potential
   4. Mobility in soil
   5. Other adverse effects (such as hazardous to the ozone layer)
10. Disposal Considerations*
    1. Description of waste residues and information on their safe handling and methods of disposal, including the disposal of any contaminated packaging
11. 14. Transport Information*
    1. UN number
    2. UN proper shipping name
    3. Transport hazard class(es)
    4. Packing group, if applicable
    5. Environmental hazards (e.g., Marine pollutant)
    6. Transport in bulk (according to Annex II of MARPOL 73/78 and the IBC Code)
    7. Special precautions a user needs to be aware of, or needs to comply with, in connection with transport or conveyance either within or outside their premises
12. Regulatory Information*
    1. Safety, health, and environmental regulations specific for the product in question
13. Other Information, including date of preparation or last revision

How to Implement OSHA’s Globally Harmonized Hazard Communication Standard (GHS)

OSHA has issued a final rule revising its Hazard Communication Standard, aligning it with the United Nations’ globally harmonized system (GHS) for the classification and labeling of hazardous chemicals. This means that virtually every product label, safety data sheet (formerly called “material safety data sheet” or MSDS), and written hazard communication plan must be revised to meet the new standard. Worker training must be updated so that workers can recognize and understand the symbols and pictograms on the new labels as well as the new hazard statements and precautions on safety data sheets.

Tampa RCRA and DOT Training

Dallas RCRA and DOT Training

Chicago RCRA, DOT, and IATA/IMO Training

Mitoxanthrone Hydrochloride Found to be Carcinogen

California’s Office of Environmental Health Hazard Assessment (OEHHA) has added mitoxantrone hydrochloride (CAS No. 70476-82-3) to the list of chemicals known to the State to cause cancer for purposes of Proposition 651. With this action, the chemical is now listed under Proposition 65 as causing reproductive toxicity (developmental endpoint) and cancer.

The listing of mitoxantrone hydrochloride is based on a formal requirement by a state or federal agency that the chemical be identified or labeled as causing cancer as provided under the Act. Mitoxantrone hydrochloride has been identified or labeled to communicate a risk of cancer in accordance with formal requirements by the US Food and Drug Administration. Regulations governing the listing of chemicals under the “formally required to be labeled or identified” mechanism are published in Title 27, California Code of Regulations, section 25902.

Time to Post Job-Related Injuries and Illnesses and New Recordkeeping Requirements

Michigan Occupational Safety and Health Administration (MIOSHA) Director Martha Yoder reminded Michigan employers they are required to post the total number of job-related injuries and illnesses that occurred in 2014.

“Accurate recordkeeping is an important piece of an employer’s safety and health management system,” said Yoder. “MIOSHA’s recordkeeping logs allow an employer to keep detailed records that can help identify and correct problem areas, prevent future injuries and illnesses, and continuously improve their workplace safety.”

MIOSHA requires most Michigan employers with 11 or more employees to log and maintain records of work-related injuries and illnesses, and to make those records available during MIOSHA inspections of the workplace.

These records include:

The summary must list the total numbers of job-related injuries and illnesses that occurred in 2014 and were logged on the MIOSHA Form 300. Employment information about annual average number of employees and total hours worked during the calendar year is also required to assist in calculating incidence rates.

Companies with no injuries and illnesses during the previous year are still required to post the MIOSHA Form 300A with zeros entered on the total line. A company executive must certify that the totals are correct and sign the form, which is then displayed wherever notices to employees are usually posted.

Employers with 10 or fewer employees and employers in certain industry groups (retail trade, finance, insurance and real estate, and certain services industries) are normally exempt from the MIOSHA recordkeeping and posting requirements. These exemptions do not exclude any employer from coverage by MIOSHA or from compliance with all applicable safety and health standards.

“As MIOSHA reminds employers to post last year’s job-related injuries and illnesses, the agency also wants to make them aware of new federal recordkeeping requirements,” said Yoder. “As of January 1, 2015, the federal Occupational Safety and Health Administration (OSHA) is enforcing an updated recordkeeping rule that expands the list of fatalities and severe injuries that must be reported to OSHA.”

MIOSHA, which is housed within the Michigan Department of Licensing and Regulatory Affairs and operates Michigan’s own OSHA program, must promulgate standards which are at least as effective as the federal standards within six months of their publication in the Federal Register. Michigan plans to adopt identical rules and will provide an update on their adoption in early spring.

The federal revised rules includes two significant changes:

• The new federal regulation maintains the current exemption for any employer with 10 or fewer workers from the requirement to maintain the 300 logs of worker injuries and illnesses.
• The list of severe-work related injuries that employers must report to OSHA has expanded. This requires employers to file a detailed report within eight hours of fatal workplace accidents. Severe on-the-job injuries that do not result in death, but require hospitalization must be reported within 24 hours. Additionally, any amputation or loss of an eye must also be reported within 24 hours. Such reports must be filed regardless of the size of the business.

Previously, the regulations required such reports only if a worker was killed or three or more workers were hospitalized as a result of a workplace accident. All employers will be required to comply with the new reporting requirements, even those exempt from routinely keeping OSHA injury and illness records due to company size or industry.

North Carolina Releases Workplace Fatality Figures

Work-related fatalities in North Carolina increased in 2014 based on preliminary figures released recently by the state Labor Department. The construction industry experienced 19 fatalities, 12 more than 2013. Construction fatalities accounted for 43% of the 44 workplace fatalities that occurred.

“These deaths are tragic,” Labor Commissioner Cherie Berry said. “I never lose sight of the fact that these are human lives lost at work, and I take each one personally. These were someone’s husband or wife, mother or father, brother or sister, son or daughter, and in some cases grandparent. They were best friends and co-workers. The average age was 43 years old, much too young to become a workplace statistic.”

Other industry data show that many construction accidents are happening within the first 60 to 90 days on the job and in some cases on the first day of work.

“To hear that workers are getting injured on the first day or between 60 and 90 days on the job sends a red flag that the workers are not getting the necessary training prior to starting the work,” Commissioner Berry added. “Whether the workers are new to the industry or returning after the lull in construction that began in 2007, the workers need training or refresher training before starting the job, training that we provide at no cost to the employer. Just call us at 1-800-NC- LABOR.”

Struck-by events accounted for the most work-related deaths with 18. Falls accounted for 13 deaths, including one fall from the same level and 12 falls from an elevation. Seven workers died after being caught in/between objects.

“All of us—safety professionals, employers and employees—must do better in identifying struck-by hazards, which represented nearly half of the fatalities last year,” said Allen McNeely, director of the Occupational Safety and Health Division. “Staying vigilant around heavy machinery and construction material is critical.”

The Labor Department’s OSH Division has taken a proactive approach to help prevent injuries, illnesses and fatalities in North Carolina workplaces by establishing partnerships with some of the most hazardous industries. The OSH Division also issues industry hazard alerts on forklifts, struck-bys, heat stress, firefighter safety, and other hazards to heighten awareness.

“The department detected a spike in construction incidents earlier in the year and began working with Builders Mutual Insurance Company to address the problem,” Commissioner Berry said. “We put our heads together and created public service announcements addressing top hazards that began airing on Univision during the last quarter of 2014 paid for by Builders Mutual and Univision. Thanks to another donation by Skanska USA Building and Univision, the PSAs will continue airing through March of this year.”

The public service announcements address falls and struck-bys—two of the construction industry’s “big four” hazards—which were the top two leading causes of work-related deaths in 2014. The PSAs also address the importance of returning home to loved ones at the end of the workday.

The OSH Division’s Education, Training and Technical Assistance Bureau will increase training opportunities for the construction industry and has put additional emphasis on outreach regarding falls and struck-by hazards.

The state’s injury and illness rate for private industry dropped to an all-time low of 2.7 per 100 full-time workers for 2013. The US Bureau of Labor Statistics compiles the injury and illness rate data. Based on the most recent data released by the BLS, North Carolina was one of 12 states with a rate statistically lower than the national average of 3.3.

Manufacturing had the second highest number of work-related deaths with nine, five more than the previous year. The services industry increased from one fatality to six work-related fatalities.

Agriculture, forestry, and fishing decreased from seven fatalities in 2013 to three in 2014. There were also three fatalities in the transportation and public utility industry, an increase from one in 2013. Government increased from no work-related fatalities in 2013 to two in 2014, and finance, insurance, and real estate increased from none to one. Retail trade had no work-related fatalities, and the wholesale trade experienced one in 2014.

There were no work-related fatalities in 69 of North Carolina’s 100 counties. Mecklenburg County led with five fatalities. Union County and Wake County experienced three each. Forsyth, Gaston, Guilford, Henderson, and Pender experienced two fatalities each. There were 23 counties that experienced one fatality.

Whites accounted for 26 of the 44 work-related fatalities. Blacks accounted for 7, and Hispanics for 11. Men accounted for 43 of the 44 deaths. One woman died in the services industry.

Oregon Businesses Encouraged to Take a Safety Break May 13

Employers across Oregon are invited to promote workplace safety and health with training, award recognition events, or other creative activities during Safety Break for Oregon on Wednesday, May 13, 2015.

Oregon OSHA coordinates the one-day event, designed to raise awareness and promote the value of safety and health in preventing on-the-job injuries and illnesses. The event is voluntary for employers and businesses can determine what activities are beneficial to their workforce.

“Like any safety stand down, Safety Break by itself cannot promise to magically make an employer’s health and safety program real or more effective,” said Michael Wood, Oregon OSHA administrator. “But as part of a genuine effort to address workplace hazards, this event provides an opportunity to sharpen the focus, and to remind both workers and their employers that it requires continued focus and diligence to create a workplace free from the hazards that can cause serious injury, illness, or even death.”

Safety Break encourages employees and management to work together on identifying safety and health concerns. The result of this cooperation can lead to fewer injuries and reduced workers’ compensation costs for employers.

Companies planning to participate will be entered to win one of three $100 pizza luncheons when they sign up online by Friday, May 8. The prizes will be given to participating companies as part of a random drawing. The Oregon SHARP Alliance is sponsoring the contest.

Bend Laboratory Earns Safety Recognition

SHARP provides an incentive for Oregon employers to work with their employees to find and correct hazards, develop and implement effective safety and health programs, and continuously improve. The ultimate goal of SHARP is to encourage employers to become self-sufficient in managing workplace safety and health issues. Currently, about 34 employer locations are active SHARP employers, in addition to approximately 136 facilities that have graduated from the program.

With 25 employees, VR Analytical is a contract research organization that specializes in extractables and leachables testing, which is necessary to qualify materials for use in bio/pharmaceutical drug development. The company offers guidance about organic and inorganic chemical entities that may be extracted from materials used in the manufacture, storage, and delivery of pharmaceuticals. The oversight is necessary to achieve patient safety and to minimize potential delays in regulatory approval.

“Our first priority is to provide a working environment and appropriate safety training that ensures the well-being of our employees. And safety has business benefits beyond fewer injuries and lost-time accidents,” said Raymond Colton, president of VR Analytical. “It turns out that our customers are starting to demand that we have a robust safety program and include safety on the agenda during their periodic quality systems audits. By participating in the SHARP program, we also commit to continually improving our safety program so that it exceeds requirements. This sort of continuous improvement fits with the culture of our organization.”

Participation in SHARP does not eliminate regulatory enforcement, although SHARP participants do receive a limited exemption from programmed inspections. Employees retain all workplace safety and health rights contained in the Oregon Safe Employment Act. Oregon employers that have been in business for more than one year are eligible to apply for SHARP regardless of size or type of business.

Safety News Links

Do You Have News to Share?