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What You Need to Know about Your Written Hazard Communication Plan

by Michael Collins, CIH, CSP, CIEC, GLE Associates

The United States Occupational Safety and Health Act (OSHA) requires employers to maintain a written hazard communication plan that effectively protects workers from potentially harmful chemical exposure in the workplace. On the surface, the requirement sounds simple, yet failure to meet this requirement is the second most commonly cited OSHA violation.

Here’s what you need to know to ensure you comply with this simple, critical OSHA requirement.

Who Needs a Written Hazard Communication Plan?

OSHA regulation 1910.1200 requires all employers with hazardous chemicals in their workplaces to prepare and implement a written hazard communication plan. This applies, according to the regulation, “to any chemical which is known to be present in the workplace in such a manner that employees may be exposed under normal conditions of use or in a foreseeable emergency.”

There are some exclusions to the requirement, including ingredients in food, certain pesticides, and distilled spirits. In most cases, the excluded chemicals are covered by other regulations. For full information, visit OSHA’s hazard communications page.

What are the Key Requirements of the Written Hazard Communication Plan?

Employers are responsible for developing and maintaining a written hazard communication program for the workplace that includes:

  • Safety Data Sheets (SDSs) for each chemical present
  • Lists of hazardous chemicals present, referenced in each case to the appropriate SDS
  • Appropriate labeling of containers of chemicals in the workplace
  • Labeling of containers of chemicals being shipped to other workplaces
  • Preparation and distribution of SDSs to employees and downstream employers
  • Development and implementation of employee training programs regarding hazards of chemicals and protective measures, which must be provided at the time of the employee’s initial assignment, as well as whenever a new chemical hazard is introduced to the work area
  • The methods the employer will use to inform employees of the hazards of non-routine tasks, and the hazards associated with chemicals contained in unlabeled pipes in their work areas

Employers are further responsible for making the written hazard communication program available, upon request, to employees and their designated representatives.

What Hazards Does the Standard Protect From?

Chemicals can pose a wide range of health hazards, including but not limited to:

  • Irritation
  • Sensitization
  • Carcinogenicity
  • Flammability
  • Corrosion
  • Reactivity

The written hazard communication plan helps protect workers from these and other risks associated with exposure in the workplace.

How to Prepare Your Written Hazard Communication Plan

Writing a hazard communication plan is not overly complicated, but it’s critical that you get it right. Start by collecting data on all potentially hazardous chemicals in use at your work site. Make a list of them. Gather SDSs for each chemical, and reference the SDS for each one inside the master list.

Identify which workers experience exposure risk during the course of their workday, as well as in foreseeable emergency circumstances. Develop an information and training program to ensure workers understand the hazards present in their workplace, as well as appropriate protective measures for those hazards. And, conduct personal air sampling for these chemicals to establish OSHA-required Negative Exposure Assessments (NEAs).

Many employers prefer the confidence and ease of hiring an experienced firm like GLE to prepare an OSHA-compliant written hazard communication plan on their behalf and conduct NEAs.

 

This article was first published on the GLE Associates website.  GLE is an integrated architecture, engineering, and environmental consulting firm, headquartered in Tampa, Florida, with offices throughout Florida and the Southeastern United States.

 

New Technology on Track to Vitalize Confined Space HazMat Training

by Steven Pike , Argon Electronics

Teams operating in confined spaces within hazardous industrial buildings or process facilities understand all too well the importance of adhering to strict health and safety regulations.

The hazards that confined spaces present can be physical or atmospheric in nature – from the risks of asphyxiation or entrapment to exposure to extremes of temperature or the release of toxic chemicals.

Confined Space Entry

According to the Census of Fatal Occupational Injuries, on average two people die in the US every day as the result of incidents that take place within confined spaces.

In many cases too, it is not just the victim who is at risk, but the rescuer or first responder who may be unaware of the hazard they are about to encounter.

Directives such as the Occupational Safety and Health Administration (OSHA), the Control of Major Accident Hazards Regulations (COMAH), the Dangerous Substances and Explosive Atmospheres Regulations (DSEAR), Atex and many others all have a pivotal role to play in ensuring safety.

But despite the emphasis on prevention, any potentially harmful chemical release, and specifically one that occurs within the context of a confined space, will require personnel who are skilled and confident to handle a variety of complex challenges.

With these challenges in mind, a new app-based multigas simulator technology, specifically designed for use in confined space settings, is scheduled for release in late summer 2018.

And the new system looks set to deliver an enhanced level of realism for industrial HazMat training scenarios.

Applying CWA Technology to Industrial HazMat Training

The use of simulation technology for chemical warfare agent (CWA) training is already well established, with intelligent, computer-based training aids such as Argon Electronics’ PlumeSIM and PlumeSIM-SMART systems currently in use by military forces around the world.

The launch of PlumeSIM in 2008 provided CWA and CBRN instructors with a simulation package that enabled them to use their laptops, in conjunction with a map or images, to plan a diverse range of field and table-top exercises.

The type of substance, whether a single or multiple source and an array of environmental conditions (such as wind direction and speed) could all be easily configured. And the innovative technology enabled whole exercises to be recorded for after action review (AAR) and future contingency planning.

In 2016 came the introduction of PlumeSIM-SMART – which offered similar capabilities to PlumeSIM but replaced the use of simulator devices in the field with the simplicity of a mobile phone.

The ability to transform a mobile phone into a look-alike gas detector was to prove especially practical (and budget-friendly) for high-hazard industrial organizations and municipal responders.

And using mobiles offered some additional and unexpected benefits in that it enabled field exercises to take place in any location.

Realistic Multigas Training

The newest addition to Argon’s simulation technology portfolio has been devised for specific use within the training environs of confined spaces and multi-level buildings.

The device will offer HazMat instructors the flexibility to simulate specific levels and concentrations of gases, whether these be in the form of a gas escape or a dangerous device (or devices) concealed within a building.

It will also be highly configurable to enable instructors to select the use of either single or multigas sensors within their training scenarios.

The hardware will be identical to that currently available for CWA training and toxic industrial response training. It has also been configured to interact with existing hand-held gas detection simulators, such as PlumeSIM-SMART, to provide an enhanced level of realism and a more focused training experience.

Simulation sources will be able to be set to emit a signal that replicates the conditions of a particular substance, a low level or oxygen or an explosive atmosphere.

And as students move around the training environment, their display readings will adjust accordingly to simulate an event such as a breached alarm.

The latest detector also promises to overcome the issues posed by communications interference within buildings where GPS technology can often be limited.

Working in confined spaces within industrial complexes can present a daunting array of hazards, both for the staff operating within the facilities and for the emergency teams charged with first response.

The continued development of simulator technology can help to address these challenges by providing realistic, hands-on training opportunities that replicate real-life conditions.

This article was originally published in the Argon Electronics website.

_______________________

About the Author

Steven Pike is the Founder and Managing Director of Argon Electronics, a world leader in the development and manufacture of Chemical, Biological, Radiological and Nuclear (CBRN) and hazardous material (HazMat) detector simulators.

In use worldwide, Argon simulators have applications for training and preparedness within civil response, the military, EoD, unconventional terrorism / accidental release, and international treaty verification, with a growing presence in the nuclear energy generation and education markets. We have been granted a number of international patents in this field.

Hazmat University launches Hazardous Material Online Training

The U.S. Department of Transportation requires anyone whose job involves the performance of any task regulated by the U.S. Hazardous Materials Regulations to undergo hazardous materials shipping training. Likewise, all employers must provide their employees with relevant training applicable to their job function. Hazmat University offers online training programs that can be completed on your desktop, laptop, tablet, or smartphone 24/7.

“When transporting hazardous materials/dangerous goods in commerce, compliance is a primary concern. Compliance is achieved through well maintained training programs by the hazmat employer. Training is an essential component of any shipping operation to achieve safety in the transport of hazardous materials,” said Sonia Irusta, Vice President of Bureau of Dangerous Goods, LTD.

Hazmat University recognizes the need for anyone entrusted with the handling of dangerous goods to be trained on the dangerous goods regulations and to be able to perform their job functions when handling dangerous goods.

Hazmat University makes certain their training programs are exemplary and features are excellent and easy to access. Listed below are the four reasons Hazmat University is your one-stop-shop for hazardous material shipping training.

A Variety of Training Options

  • A wide range of classes that suit a variety of needs such as different modes of transportation including ground, air and sea.
  • Classes cover a wide range of regulations including: 49 CFR Hazardous Materials Regulations, the International Air Transport Association Dangerous Goods Regulations, and the International Maritime Dangerous Goods Code.

Regular Updates

  • Hazmat University updates based on “The Hazardous Materials Regulations” multiple times each year which keeps lesson plans and materials for online content up-to-date.
  • Anyone handling hazardous materials is required stay on top of any amendments and regulatory changes made.

Everything is Online

  • All courses are offered online to relieve the stresses of travel, parking and changing schedules.
  • Lessons can be accessed from anywhere at any time whether at home or in the office.

Start Immediately

  • Begin your training from the moment that you finish placing your order.
  • Your enrollment codes come with your order confirmation, so there is no delay in getting started.
  • Certificates are issued instantly upon completion.

Hazmat University provides specialized courses in the transportation of dangerous goods by air, ground, or vessel, and training for specialized needs, such as lithium batteries, general awareness, segregation, and others.

Degrees in urban revitalization, brownfield redevelopment, and environmental restoration

Revitalization News recently assembled a catalog of 38 undergrad, graduate and certificate courses in urban revitalization, brownfield redevelopment, and environmental restoration worldwide.  The courses are from institutions from all over the world, including the United States and Canada.  The catalog has something for almost anyone ranging from an online course on Landscape Restoration for Sustainable Development , a Master’s degree in technical brownfields revelopment at to the Technical University of Ostrava in the Czech Republic, to a B.Sc. in ecological restoration at Trent University and Fleming College in Ontario.  A complete list of the courses can be found at https://revitalizationnews.com/training-education.

Students participating in 1-YEAR graduate certificate in ecological restoration (Niagara College, Ontario, Canada)

U.S.: FEMA Releases Refreshed National Incident Management System Doctrine

The U.S. Federal Emergency Management Agency (FEMA) recently released the refreshed National Incident Management System (NIMS) doctrine.  NIMS provides a common, nationwide approach to enable the whole community to work together to manage all threats and hazards. NIMS applies to all incidents, regardless of cause, size, location, or complexity.

In April and May 2016, FEMA held a 30-day National Engagement Period, in which stakeholders submitted nearly 3,000 comments and provided feedback on the draft NIMS update, ensuring that it reflects the collective expertise and experience of the whole community.

FEMA will host a series of 60-minute webinars with stakeholders to discuss the updates in the refreshed NIMS and answer questions related to NIMS. All webinars are open to the whole community. For webinar dates, times, and registration information, please go here: https://www.fema.gov/latest-news-updates.

The refreshed NIMS retains key concepts and principles from the 2004 and 2008 versions, while incorporating lessons learned from exercises and real-world incidents, best practices, and changes in national policy.

Download the refreshed NIMS here: www.fema.gov/nims-doctrine-supporting-guides-tools

The refreshed NIMS:

  • Retains key concepts and principles of the 2004 and 2008 versions of NIMS;
  • Reflects and incorporates policy updates and lessons learned from exercises and real-incidents;
  • Clarifies the processes and terminology for qualifying, certifying, and credentialing incident personnel, building  a foundation for the development of a national qualification system;
  • Clarifies that NIMS is more than just the Incident Command System (ICS) and that it applies to all incident personnel, from the incident command post to the National Response Coordination Center;
  • Describes common functions and terminology for staff in Emergency Operations Centers (EOC), while remaining flexible to allow for differing missions, authorities, and resources of EOCs across the nation; and
  • Explains the relationship among ICS, EOCs, and senior leaders/policy groups.

NIMS guides all levels of government, nongovernmental organizations (NGO), and the private sector to work together to prevent, protect against, mitigate, respond to, and recover from incidents. NIMS provides stakeholders across the whole community with the shared vocabulary, systems, and processes to successfully deliver the capabilities described in the National Preparedness System. NIMS defines operational systems, including the Incident Command System (ICS), Emergency Operations Center (EOC) structures, and Multiagency Coordination Groups (MAC Groups) that guide how personnel work together during incidents. NIMS applies to all incidents, from traffic accidents to major disasters.

Please refer to the descriptions below to gain an understanding of where to locate certain information.

NIMS Doctrine Supporting Guides & Tools: The National Integration Center develops supporting guides and tools to assist jurisdictions in their implementation of the National Incident Management System (NIMS).

Training: The NIMS Training Program defines the national NIMS training program. It specifies National Integration Center and stakeholder responsibilities and activities for developing, maintaining and sustaining NIMS training.

Resource Management & Mutual Aid: National resource management efforts aid a unified approach in building and delivering the core capabilities across all five mission areas (Prevention, Protection, Mitigation, Response and Recovery).  Effective resource management is founded on the guiding principles of the NIMS.

Implementation Guidance & Reporting: Federal Departments and agencies are required to make adoption of NIMS by local, state, territorial, and tribal nation jurisdictions a condition to receive Federal Preparedness grants and awards.

NIMS Alerts: The National Integration Center announces the release of new NIMS guidance, tools, and other resources through the distribution of NIMS Alerts.

FEMA NIMS Regional Contacts: The FEMA Regional NIMS Coordinators act as subject matter experts regarding NIMS for the local, state, territorial, and tribal nation governments within their FEMA Region, as well as for the FEMA Regional Administrator and staff.

Incident Command System Resources: The Incident Command System (ICS) is a fundamental element of incident management. The use of ICS provides standardization through consistent terminology and established organizational structures.

U.S. Instructor Training Aims To Reduce Hazmat Shipping Incidents

Hazardous Materials Instructor Training is now available at no cost in 12 states to help reduce transportation incidents involving undeclared hazardous materials.

The training is offered by the Texas A&M Engineering Extension Service (TEEX) thanks to a $708,000 grant from the U.S. Department of Transportation (DOT).  The goal of the grant from DOT’s Pipeline and Hazardous Materials Safety Administration is to enhance the safe transport of hazardous materials by highway, rail, water and air.  During the next 12 months, TEEX plans to offer 48 classes in cities that are adjacent to major interstate shipping highways and trucking hubs.

The TEEX training will provide instructors with information to help them develop a systematic training program that ensures a hazmat employee has familiarity with the general provisions of the hazardous materials regulations, Also, the training will ensure an employee is able to recognize and identify hazardous materials, has knowledge of specific requirements applicable to functions performed by the employee, and has knowledge of emergency response information, self-protection measures, and accident prevention methods and procedures.

“It is vital that these materials be properly packaged, labeled and stowed for transportation or they could pose significant threats to transportation workers, carrier operators, emergency responders and the general public,” said Jeff Bowman, Environmental Training Manager with the TEEX Infrastructure Training and Safety Institute. The training will help companies meet their safety goals and reduce hazmat incidents caused by human error, he added.

This course will also assist employers in developing a systematic program that ensures employees can recognize and identify hazardous materials and are knowledgeable of emergency response information, self-protection measures, and accident prevention methods and procedures, Bowman said.

About The Pipeline and Hazardous Materials Safety Administration
The Pipeline and Hazardous Materials Safety Administration develops and enforces regulations for the safe, reliable, and environmentally sound operation of the nation’s 2.7 million mile pipeline transportation system and the nearly one million daily shipments of hazardous materials by land, sea and air.

About The Texas A&M Engineering Extension Service
TEEX is an internationally recognized leader in the delivery of emergency response, homeland security and workforce training and exercises, technical assistance, and economic development. Last year, TEEX served more than 168,000 people from every U.S. state and territory and 82 countries worldwide. TEEX makes a difference by providing training, developing practical solutions, and saving lives.

SOURCE: The Texas A&M Engineering Extension Service

U.S. PHMSA Provides funding for Hazardous Materials Instructor Training

The United States Pipeline and Hazardous Materials Safety Administration (PHMSA) recently announced it was providing more than $4 million (U.S.) in grants to Hazardous Materials Instructor Training (HMIT) and Supplemental Public Sector Training (SPST).

The HMIT grants fund the training of instructors who then train private-sector hazardous materials employees.  The SPST grant funds national non-profit fire service organizations to train instructors to conduct hazardous materials response training programs for local responders.

“Enhancing the safe transport of hazardous materials by highway, rail, water, and air is one of the Department’s top priorities,” said U.S. Transportation Secretary Elaine L. Chao. “These grants are force multipliers in helping communities get more local first responders and employees prepared for transportation incidents involving hazardous materials.”

The following HMIT grants were awarded for 2017:

  • The International Association of Machinists and Aerospace Workers Corporation for Re-Employment and Safety Training ($729,197)
  • The International Chemical Workers Union Council ($399,608)
  • Sustainable Workplace Alliance ($817,950)
  • Texas A&M Engineering Extension Service ($708,239)
  • Short Line Safety Institute ($500,000)

For 2017, one national non-profit fire service organization, the International Association of Fire Fighters was awarded a grant of $931,000.

“Well-trained first responders play a critical role in any hazardous materials incident, and this grant funding supports their efforts to protect their communities,” said PHMSA Acting Administrator Drue Pearce. “These grants are part of our comprehensive approach to improving the safe transportation of hazardous material across the country.”

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