2021 Summer Leader - Chemical Safety & Hazard Communication

VOL8/NO3/SUMMER 2 021

CHEMICAL SAFETY & HAZARD COMMUNICATION

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CONTENTS FEATURES

SPECIAL SECTION: OSHA’s Proposed Changes to the HazCom Standard

10

Chemical Safety and Hazard Communication

By the Occupational Safety & Health Administration

12

What It Means for You

By Glenn Trout

16

Will History be Repeated?

By Lawrence P. Halprin, Partner, Keller & Heckman LLP

32

24

Planning for and Preventing Chemical Emergencies: A Safety Management System Approach

By Phil N. Molé

28

Hazard Communication: Lessons From the Field

By Mackenzie Barnwall, MS,

GSP, and Megan Scherer, Safex

32

The Future of Soil

By Warren Silverman, MD FACOEM, Medical Director, Workplace Forensics LLC

34

Protect Yourself Against Chemical Hazards on the Job

Written by the International

20

HazCom Leading Indicators: Implementation Under the VPP Elements

VOL 8 | NO 3 | SUMMER 2 0 21

Safety Equipment Association (ISEA)

COLUMNS 6 8

Message from the Chairperson Women in Safety

SECTIONS

By Michelle Zapanta Control Board Operator, Step-Up

Operations Supervisor, Industrial Fire Fighter, former Lead VPP Coordinator and current Chairperson for the Employee Safety Leadership Team Valero Benicia Refinery

vpppa.org

36 38 39

Membership Corner Ad Index Infographic Corner

Leader—Summer 2021

5

A Message From the VPPPA Chairperson Hello my fellow VPPPA members,

T

he summer sun is in high gear and so is the VPPPA! Our membership is spending this summer sharing and caring as they always have. Many of our Regions will be holding virtual and in-person events throughout the year and we encourage

you to participate. We also encourage everyone to register for our Safety+ Symposium, August 31–September 2, at the beautiful Gaylord Opryland in Nashville, Tennessee. We are excited to be partnering with Region IV in hosting this event. Bonus: if you’re still wary of traveling (or you’re receiving this issue too late to make travel plans), you can attend Safety+ virtually.

With all the exciting events occurring and opportunities available to the VPPPA membership, I reflect on the true meaning of partnership. Its simple definition is, “parties agree to cooperate to advance their mutual interests.” In the world of Safety & Health Excellence this definition certainly applies. Obtaining and maintaining excellence almost

I cannot think of a better organization than the VPPPA for you or your organization to partner with in achieving long-lasting Safety & Health Excellence.

mandates that you surround yourself with successful and talented people. I cannot think of a better organization than the VPPPA for you or your organization to partner with in achieving long-lasting Safety & Health Excellence.

The VPPPA has recently enhanced its partnership with the Board of Certified Safety Professionals (BCSP) and established a new partnership with the Health and Safety Council (HASC). Additionally, we have partnered with an advocacy firm (LobbyIt.com) to assist us with our efforts in educating members of Congress and creating an advocacy page on our website. We encourage you to visit our website and use the email writing link to ensure your voice is heard on Capitol Hill. We believe all our partners enhance our collective mission capabilities. We look forward to sharing more about what we are working on with our great partners soon.

Partnerships can also be on an individual basis. We all have a network of people that help make us better. Seeking new people to be part of your network is something all of us should do to be successful. I can’t think of a better way to increase your network and gain new partners than by participating in this year’s national & regional events.

We are gearing up and looking forward to all of our partners demonstrating their sharing and caring spirit during this year’s Safety+ Symposium. I am very excited at the opportunity to see my VPPPA family and friends again. I am equally excited about meeting new people and adding to my network of partners in achieving Health & Safety Excellence.

See all of you soon!

— Terry Schulte, Chairman—National VPPPA Board of Directors We are better together!

6

Leader—Summer 2021

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Guest Author: Adele L. Abrams, Esq., CMSP President, Law Office of Adele L. Abrams PC www.safety-law.com

Women in Safety

What Do Women Want?

Safety!

VPPPA Presents…

Women in Safety

VPPPA is excited to introduce a new column for the Leader magazine: Women in Safety. While the safety industry is still a male-dominated industry, the number of women is increasing each year. It’s important to identify and communicate the issues that women face.

Each issue of the Leader, we will be including an article from a prominent woman working in the safety and health industry.

If you, or someone you know, would like to write for this column, please contact VPPPA at communications@ vpppa.org.

“WHAT DO WOMEN WANT?”

decisions. Fortunately, more

resulting in significant liability

is a question sometimes arising

manufacturers are now

for the employer.

in romantic comedies . . . but

marketing PPE designed for

Workplace violence is the

when it comes to workplace

women, but the challenge is

number one cause of death for

safety, the needs of women are

getting employers to purchase it.

women in the workplace, with

no laughing matter. Hazards

also impact women workers

occurring in the health care

to women in the workplace

disproportionately. Often,

and social services sectors. This

are not necessarily unique

women working in construction

is why OSHA is now focusing

to that gender, but the data

suffer musculoskeletal disorders

efforts on these sectors in its

shows that women may be

because of their smaller hand

pending rulemaking activities,

disproportionally harmed.

size, and lower grip strength,

and the Spring 2021 Regulatory

Clearly, issues surrounding

which is inconsistent with the

Agenda calls for a draft rule to

keeping female workers safe

design of many tools. One union

be considered for small business

warrants additional study.

study found that women have

impact in December 2021.

There are myriad factors that

higher rates of sprains/strains

can contribute to elevated on-

and nerve conditions of wrists/

the-job injuries and illnesses

forearms than men—likely due

for female workers, but one

to assignment of more repetitive

obvious one is the lack of

tasks and the tool design. In

appropriately fitting personal

addition, with reduced upper

protective equipment (PPE).

body strength, women may be

Respirators, safety harnesses,

more prone to back problems

protective shoes, gloves,

from repetitive lifting. The

coveralls, hardhats, safety

solution is to design the job to

goggles, and even welding gear,

the worker, not to avoid hiring

may not be properly sized for

women in the construction or

women because, historically,

heavy industrial workforce.

Women in construction and

High risk factors include:

• Working alone, at night, or in isolated or high crime areas.

• Working with volatile or unstable people.

• Handling money or valuables.

• Providing services or care.

• Working where alcohol is served.

In addition, all workers can become targets during mass shootings by strangers, which occur everyplace from bars to

male anthropomorphic models

mining may also be adversely

retail stores to schools—these

for design.

affected by lack of access

are all somebody’s workplace.

to appropriate sanitation

Some workplace violence cases,

properly fit each affected

facilities on the job. OSHA

such as the recent tragedy in

employee. If a respirator does

recognizes lack of clean

San Jose, CA, involve worker-

not form a tight seal, heightened

facilities (including temporary

on-worker homicide, while

chemical exposures will occur. If

johns) as a citable hazard,

others may involve domestic

clothing is loose, it can become

because the lack of safe toilets

violence that spills into the

caught in moving machine

and drinking water can lead to

workplace. While some states

parts, resulting in death or

bladder and kidney issues.

bar employers from restricting

OSHA is clear that PPE must

injury. A 2014 study by Mt. Sinai

Leader—Summer 2021

many of these fatal injuries

causing injury and illness

most manufacturers used the

8

Ergonomic issues can

The lack of locks on portable

guns on company property, this

Hospital found that a majority

facilities can also be a safety

is not universal, and employers

of contractors were not mindful

issue. One construction company

should implement rules where

of the “PPE fit” issue and never

reported that a female worker

legal. Some states have now

considered design for women

was sexually assaulted inside of a

adopted laws protecting victims

during their PPE purchasing

portable facility by a supervisor,

of domestic violence from

vpppa.org

employment discrimination,

such hazards such as enhanced

which can occur when an

security and training.

employee notifies the employer

Recognition that addressing

that a restraining order is

hostile work environments is

in place against a spouse or

key to prevention of workplace

partner and the employer

violence has also become

does not want to address any

part of the “DEI” initiatives

necessary precautions.

(Diversity, Equity, and

Too often, employers focus

Inclusion) adopted proactively

• Reviewing training materials to ensure they are gender/

race/ethnicity neutral, and include positive images of diversity of workers.

• Providing safe and sanitary

restroom facilities for workers.

• Raising awareness of workplace violence

prevention efforts on criminal

by many employers, as well

prevention related to gender

or active shooter events, and

as being an element in Total

(and race, ethnicity, age,

ignore the broader definitions,

Worker Health programs. The

disability) and implementing

viewing the issue from an

National Safety Council has

DEI training where needed

occupational safety and health

adopted the slogan “You can’t

to ensure that everyone feels

perspective. NIOSH defines

be safe if you don’t feel safe” to

safe and is free from a hostile

workplace violence as “violent

urge employers to implement

work environment.

acts (including physical

effective training and policies.

assaults and threats of assaults)

Finally, another area

directed toward persons at

warranting more research

work or on duty.” OSHA defines

is whether Occupational

it as “any act or threat of

Exposure Limits (OELs) for

physical violence, harassment,

hazardous chemicals and air

intimidation, or other

contaminants are appropriate

threatening disruptive behavior

for both men and women.

that occurs at the worksite.”

NIOSH has studied the impact

This can include incidents of

on women occupationally

bullying or sexual harassment

exposed to substances including

and assault. Those reporting

Ethylene oxide, PCBs and

such harassment or assault are

Perchloroethylene concerning

also protected under OSHA’s

development of possible

whistleblower protections,

cancers, but older OELs are

embedded in Section 11(c)

based on studies involving

of the Occupational Safety &

primarily white males and

Health Act, and incorporated by

should be revisited. Moreover,

reference into 29 CFR 1904.36.

in the Johnson Controls case, the

OSHA CPL 02-01-052,

refusing to hire women who

Investigating or Inspecting

could become pregnant, because

Workplace Violence, states:

of concerns about the impact

“Workplace violence is

of workplace chemicals on fetal

recognized as an occupational

development, violated Title VII

hazard in some industries

of the Civil Rights Act.

be avoided or minimized if employers take appropriate precautions.” The CPL instructs OSHA inspectors to cite the General Duty Clause if there

of resources by employers and organizations.

• Inclusion of women (and

minorities) in OHS research to ensure they are adequately represented in studies of

and if there is a feasible means of preventing or minimizing

vpppa.org

regardless of gender.

Proactive solutions include:

recognized the existence of a hazard affecting employees,

be effective for all workers,

• Additional study and sharing

is evidence the employer potential workplace violence

workplace protections must

U.S. Supreme Court held that

Enforcement Procedures for

and environments which can

The bottom line is that

Another area warranting more research is whether Occupational Exposure Limits (OELs) for hazardous chemicals and air contaminants are appropriate for both men and women.

chemicals, PPE, and more.

• Ensuring that there is

parity in workplace training and mentoring.

Leader—Summer 2021

9

SPECIAL SECTION OSHA’S PROPOSED CHANGES TO THE HAZCOM STANDARD

CHEMICAL SAFETY AND HAZARD COMMUNICATION By the Occupational Safety & Health Administration

OSHA first promulgated the hazard communication standard (HCS) in 1983 to provide a standardized approach to workplace hazard communications associated with exposure to hazardous chemicals. At that time, the HCS covered only the chemical manufacturing industry. OSHA updated the HCS in 1987 to expand coverage to all industries where workers are exposed to hazardous chemicals. In 1994, OSHA promulgated an additional update to the HCS with technical changes and amendments designed to ensure better comprehension and greater compliance with the standard. The agency believed that the HCS should be continually updated to incorporate the progression of scientific principles and best approaches for classification and communication.

10

Leader—Summer 2021

vpppa.org

T

he agency also had a

by maintaining alignment

commitment to work

with trading partners such as

with international

Australia, New Zealand, the

trading partners to

EU, and Canada. Additionally,

– Potential to align with WHMIS

– Would allow for

claiming prescriptive

develop an internationally

since implementing the 2012

concentration ranges

harmonized hazard

HCS, OSHA has provided

for materials claimed as

communication standard

stakeholders with numerous

and was involved in working

letters of interpretation to

with the UN Sub-committee

address issues with the new

of Experts on the Globally

classification and labeling

Harmonized System of Classification and Labelling of Chemicals (UN SCEGHS) from its inception. The first edition of the UN GHS purple book (which provides the building blocks for classifying chemical hazards) was published in 2002. The Globally Harmonized System of Classification and Labelling of Chemicals (GHS) provides a common and coherent approach to classifying chemicals and communicating hazard information.

In 2012, OSHA updated the HCS to incorporate and align with the GHS. The 2012 update was based on the 3rd revision of the GHS. The GHS is updated and revised every two years based on information and experience gained by regulatory agencies, industry, and nongovernmental organizations.

Since 2012, the GHS has been updated five times, and has recently published its 9th revision (2021).

On February 16, 2021, OSHA published a notice of proposed rulemaking (NPRM) to update the HCS. This is part of the notice and comment rulemaking process which includes receiving comments and information from public stakeholders.

system. The proposed update to the HCS addresses many of these issues. In all, the proposed modifications to the HCS fall under four general categories:

• Maintain alignment with GHS Rev. 7

° Appendix A (health

hazards): mostly editorial

– Revised health hazard definitions

– Updated skin corrosion/ irritation and serious eye damage/eye

trade secret

– Proposing prescriptive

concentration ranges as mandatory if claiming CBI for range

° Small packages

° HNOC and PNOC

• Improve alignment with other U.S. agencies

° Department of

Transportation

– Bulk packaging – GHS pictogram

° EPA

– Release for shipment

The agency has preliminarily determined the proposed modifications will enhance the

irritation chapters

effectiveness of the HCS by

hazard classes

appropriately apprised of the

– General updates to ° Appendix B

(physical hazards):

–

Flammable gases— expanding hazard categories

– Desensitized explosives – Aerosols—including

ensuring that employees are chemical hazards to which they may be exposed, thus reducing the incidence of chemicalrelated occupational illnesses and injuries. As part of the rulemaking process, OSHA has asked for stakeholder input on

an additional hazard

the efficacy and feasibility of

category

these proposed updates.

° Appendix C (label elements)

– New or updated hazards,

OSHA is currently reviewing comments submitted by stakeholders. In addition, OSHA

updated guidance, and

will be holding an informal

precautionary statements

hearing on September 21, 2021,

° Appendix D (SDS)

–

for interested stakeholders to

Updates to SDS

provide additional comments

Sections 9, 11

to the record. Information

• Address issues that have come

regarding the hearing and

to light since implementation

comment process can be

the HCS to the GHS Rev. 7 while

of the 2012 HCS;

found at https://www.osha.gov/

exploring whether OSHA should

° Release for shipment

hazcom/rulemaking. Once OSHA

° Safety Data Sheets

the agency will promulgate a

° Concentration ranges

entire record which includes

The NPRM proposes to align

include certain elements from the 8th revision, such as updates to chapter 3.2 with expanded non-animal test methods.

° Small packages labeling

• Alignment with Canada;

has closed the comment period, final standard based on the

for confidential business

comments and information

these updates should help

information (CBI) or

received through this

facilitate international trade

trade secrets

rulemaking process.

The agency anticipates that

vpppa.org

OSHA is currently reviewing comments submitted by stakeholders. In addition, OSHA will be holding an informal hearing on September 21, 2021, for interested stakeholders to provide additional comments to the record.

Leader—Summer 2021

11

SPECIAL SECTION OSHA’S PROPOSED CHANGES TO THE HAZCOM STANDARD

WHAT IT MEANS FOR YOU

By Glenn Trout

Earlier this year, the Occupational Safety and Health Administration (OSHA) published a Notice of Proposed Rulemaking (NPRM) to update the Hazard Communication Standard (HazCom) to align with Revision 7 (Rev 7) of the UN’s Globally Harmonized System of Classification and Labelling of Chemicals (GHS).

As one of the industry’s leading GHS / HazCom experts, I’ve received many questions about the NPRM and its proposed changes. This is understandable, since this NPRM would bring the first formal revision of the HazCom Standard since 2012, and the proposed changes are likely to have major impacts on chemical product users throughout the supply chain.

Following is a breakdown of the proposed changes and some of the most common concerns I’ve heard from EHS professionals looking to prepare for the coming changes.

12

Leader—Summer 2021

vpppa.org

But First, Some Background Information

products and develop new SDSs

the classification of aerosols

and shipped container labels.

differ from their current

at these changes, starting

2021. OSHA believes that under

changes that would align

with the reason OSHA is

HazCom 2012, flammable

proposing to change the way

aerosols are either classified

that desensitized explosives

as gases under pressure or

are classified. “Desensitized

flammable aerosols, or both.

explosives” are chemicals

OSHA also maintains that

that are stabilized to

non-flammable aerosols are

suppress their unstable and

currently either not classified

explosive properties through

at all or classified as gases

methods such as wetting

under pressure.

Before I dive into the proposed HazCom with Rev 7 of GHS, it’s important to understand how we got here.

In 2012, OSHA revised HazCom to align it with GHS and introduce its concepts to the U.S. regulatory framework as part of a larger global adoption of GHS. Changes included

Let’s take a deeper look

with water. Under HazCom

classification under HazCom

The NPRM states that the

2012, desensitized explosives

current classification of aerosols

are currently classified as

is largely based on information

explosives and are represented

pertaining to the transport

by the “exploding bomb”

of compressed gas cylinders,

elements and employee training

pictogram. HazCom 2012

which OSHA now believes does

on the changes. This was the

addressed the special handling

not accurately represent the

first update to HazCom since

precautions for these chemicals

hazards of aerosol containers

1994 and was widely viewed

through hazard statements.

(which have different structure

updated hazard classification, the introduction of the standardized 16-section Safety Data Sheets (SDS), new labels

as a major shift for employers

However, the UN had added

and characteristics than gas

a new separate hazard class for

cylinders, including failure

At that time, HazCom 2012

“desensitized explosives” to

mechanisms) as used and stored

was based on GHS Rev 3. The UN

the GHS (associated with the

in workplaces. OSHA’s proposal

updates and revises the GHS on

flame pictogram rather than

in the NPRM is to expand the

a biannual basis. While the most

the exploding bomb) to better

existing Flammable Aerosols

current version as of this writing

ensure that users receive the

hazard class (appendix B.3) to

is Rev 8, OSHA is proposing

specific information they need

include non-flammable aerosols,

an update to align with Rev 7

about procedures to stabilize

as well as flammable aerosols.

(which the UN published in

and safely work with these

Non-flammable aerosols would

2017) with consideration of

chemicals. OSHA agrees that a

now be under Category 3 and

specific elements of Rev 8. In

new hazard class is warranted

flammable aerosols will be

the NPRM, OSHA clarifies that

and proposes to classify these

under Category 1 or Category 2.

it is not proposing to change

chemicals in Categories 1

Additionally, categories 1 and

the fundamental structure of

(lowest explosive hazard)

2 would be associated with the

HazCom, but is instead seeking

through Category 4 (highest

flame pictogram, while Category

to maintain alignment with

explosive hazard). Under the

3 would have no associated

the GHS and address specific

NPRM, chemicals that have

pictogram. These proposed

implementation issues identified

the properties of desensitized

changes would help ensure that

since the 2012 rulemaking.

explosives would be placed

users have more accurate and

within this new category

representative information

unless they have a corrected

regarding the hazards of aerosols.

covered by the standard.

Changes in Hazard Classifications

burning rate higher than 1200

Another question I’ve

Some of the biggest proposed

kilogram per minute (kg/

received is whether pyrophoric

changes include changes

min), or are chemical products

gases were already defined

to classification for several

intentionally designed to be

as a hazard class under

categories of hazardous

explosive, such as pyrotechnics/

HazCom 2012, and what would

chemicals, including flammable

fireworks. In those cases,

change with the proposed

gases, aerosols, and desensitized

manufacturers would classify

rule. Pyrophoric gases were

explosives, with the latter

them as explosives and use the

specifically included in the

defined as a new hazard class.

exploding bomb pictogram.

definition of a hazardous

These changes will require

Some correspondents have

chemical in paragraph (c) of

manufacturers of affected

asked for additional clarity on

the HazCom Standard starting

products to reclassify their

how the proposed changes to

with the 1994 version of the

vpppa.org

This NPRM would bring the first formal revision of the HazCom Standard since 2012, and the proposed changes are likely to have major impacts on chemical product users throughout the supply chain.

Leader—Summer 2021

13

SPECIAL SECTION OSHA’S PROPOSED CHANGES TO THE HAZCOM STANDARD

Standard. When OSHA revised

would revise SDS and labeling

on the outer packaging label,

the HazCom Standard in 2012, it

requirements with new

as OSHA had also stated in the

continued to include pyrophoric

proposed warning language

2013 guidance document.

gases within the definition of

and precautionary statements

a hazardous chemical even

to help clarify chemical

a new requirement that

though pyrophoric gases were

hazards to workers. Other

manufacturers would need to

not classified within GHS Rev

proposed changes introduce

provide instructions with the

3 with which OSHA aligned the

entirely new statements for

shipment stating that when

HazCom Standard at that time.

hazard classes and categories

the containers are not in use,

which would require many

they are to be stored within the

continued to work with the

chemical manufacturers,

outer packaging containing

UN Sub-Committee of Experts

importers, and suppliers to

the full shipped container label

on the Globally Harmonized

revise and update SDSs and

information. These instructions

System of Classification

labels for certain products.

would help ensure that end

Following 2012, OSHA

and Labelling of Chemicals

to make the standard more

the information on the shipped

gases added to the GHS.

effective in certain unique

container label.

OSHA agrees with the current

circumstances, such as for

inclusion of pyrophoric gases

labeling of small containers.

asked about the use of electronic

within the GHS as Category 1A

The labeling of individual

labelling systems—like QR

flammable gases and proposes

small, shipped containers

codes on shipped container

to follow that classification

is currently required under

labels—the NPRM does not

in the HazCom Standard. The

HazCom2012, however the

include a proposal to allow it.

proposed change would help

NPRM proposes to codify

However, OSHA does invite

ensure that users receive better

an allowance for using

public comment on whether

communication about the

abbreviated label information

OSHA should consider doing

specific hazards and associated

on “small containers” that

so in a future revision of

precautions to be followed for

was first provided in a 2013

the HazCom Standard and

pyrophoric gases.

guidance document released

acknowledges that there are

by OSHA, while also more

international efforts “actively

are any updates to combustible

precisely defining a “small

promoting the application of

dust classifications. While there

container” as 100 milliliters

electronic labels for chemicals.”

are no proposed updates or

(mL) or less in capacity.

revisions of combustible dust classifications themselves in the NPRM, OSHA has stated that manufacturers would need to assess whether ordinary use of their product would generate combustible dust, and if so, to include that in the classification of the product and

For more information on

While stakeholders have

OSHA has participated in discussions about QR codes

small container labelling,

and has typically expressed

VelocityEHS has a great free

awareness of potential

eBook, “Guide to Labeling

benefits, along with some

Small Containers.” (https://

reservations about how to

www.ehs.com/white-papers-

ensure that such a system

and-guides/guide-to-labeling-

would, in practice, maintain

small-containers/)

a high level of protection

Additionally, the NPRM

for workers. For example,

proposes a new allowance

in a 2019 public meeting,

for “very small containers,”

Maureen Ruskin, Deputy

defined as less than 3 mL, that

Director of OSHA’s Directorate

allows manufacturers to put

of Standards & Guidance

only the product identifier

stressed the importance of

on the immediate container

having immediate access to the

if they can demonstrate

chemical safety information

While the proposed HazCom

that affixing a label to the

provided on container labels,

revisions do not necessarily

container would interfere with

and that require workers

change the existing

the intended use. However,

to go elsewhere to obtain

requirements for hazards to be

manufacturers following

that information could add

communicated to downstream

either allowance would need

additional steps to that process.

users and workers through

to provide the full shipped

It will be interesting to see what

labeling and SDSs, they

container label information

develops in the future on this

provide the “combustible dust” classification on the product shipped container label, as well as in Section 2 of the SDS.

Labels and SDS Content Amendments

Leader—Summer 2021

users have better access to all of

(UNSCEGHS) to get pyrophoric

Some have also asked if there

14

OSHA’s proposed rule aims

The NPRM also proposes

vpppa.org

issue as OSHA receives feedback

provide new shipped labels

provide workplace HazCom

from stakeholders, and as OSHA

and SDSs.

training on the changes.

ensure they obtain any updated

issue a final rule until late in

SDSs and shipped container

2021, at the earliest. OSHA

labels from upstream

will be holding an informal

suppliers and provide them to

public hearing on September

downstream users.

21, 2021, at 10:00 AM Eastern

continues to participate in UNSCEGHS discussions about the benefits of digitalization.

Application of the Changes

In the general sense, the proposed rule does not change any general requirements for manufacturers, distributors, or end users. They will continue to have the same broad responsibilities they currently have under HazCom, meaning that:

• Manufacturers and importers still need to classify their

• Distributors would also need to

• End-users/employers would

is that changes are coming.

their SDS library with any

With modifications to existing

newly re-authored SDSs. If

hazard classifications and

they have chemicals affected by the classification changes, they would need to train their employees on the updated classifications and information changes, such as changes to hazard statements and pictograms, and potentially

and shipped container labels

update their written HazCom

based on those classifications,

Plan where appropriate.

shipped container labels to downstream users.

• Distributors in the middle of the chemical supply chain need to provide SDSs and shipped container labels to downstream users.

• Employers/end users who

have hazardous chemicals in their workplace need to maintain a written HazCom Plan, an up-to-date chemical inventory list, a library of SDSs for all hazardous chemicals that employees can access without barriers, a system for managing shipped container labels and workplace container labels.

They must also provide HazCom training to all employees who work with hazardous chemicals.

That said, all of these

Time (ET). The key takeaway

need to make sure to update

chemicals, develop SDSs

and provide the SDSs and

OSHA will most likely not

While there are no changes to general training requirements proposed in the NPRM, because

the addition of new hazard classes, hazardous product manufacturers, importers and distributors in the U.S. will need to re-evaluate the hazards of the products they sell or import into the country to ensure product hazards are classified according to GHS Revision 7 hazard classification criteria.

Many SDSs and shipped container labels will need to be re-authored to reflect

the proposed rule would

changes in chemical hazard

change key aspects of HazCom,

classification or information

including the ways that several

and ensure compliance with

categories of hazardous

updated requirements. Specific

chemicals are classified and

industry sectors identified

the shipped container label

by OSHA within the NPRM

elements, employers would

as being most affected by

need to identify whether they

the proposed rule include

have chemicals affected by

chemical manufacturing,

those changes in the workplace.

oil and gas extraction, and

In that case they would need to

plastics and rubber products

train their workers on changes

manufacturing. Downstream

to any classifications, SDSs,

users will also need to be

shipped container labels, and

prepared to manage the

associated HazCom elements

influx of updated SDSs as they

such as hazard pictograms.

enter the workplace, and to

It is important to remember

revise their written HazCom

these changes also impact the

Plans and HazCom training

written HazCom Plan. The

as needed to account for new

classifications of several classes

classifications and new hazard

of hazardous chemicals are

and precautionary statements.

changing, as well as associated

Software to the Rescue

groups may have specific

label elements such as hazard

things to address once the

pictograms. Employers will

proposed changes become

need to assess whether they

is in the chemical supply

effective, including:

have chemicals in the workplace

chain, there will be a lot of

affected by the proposed

work they will need to do

will need to reclassify

classification changes, and

to get up to speed with new

some classes of hazardous

those that do will need to update

HazCom requirements. Now

chemicals and develop and

their written HazCom Plan and

is a good time to review your

• Manufacturers and importers

vpppa.org

No matter where a company is in the chemical supply chain, there will be a lot of work they will need to do to get up to speed with new HazCom requirements.

No matter where a company

HazCom Plan to determine if you need outside help in managing its elements. A good chemical management software solution—like VelocityEHS— can simplify compliance with hazardous communication requirements and improves workplace chemical safety.

What’s more, they have an inhouse team of SDS Authoring and chemical safety experts that can help ensure SDSs are 100 percent in-compliance with hazard communication regulations and chemical safety best practices around the globe. Lastly VelocityEHS’ Emergency Response Service can help you improve workplace safety regarding chemicals with on-the-spot chemical exposure support to prevent serious injuries, and even save lives in the event of a chemical emergency. Toxicologists and medical technicians are on call at all times to provide critical chemical safety information and escalated incident reporting through a convenient hotline.

Glenn Trout is a VPPPA Region V Board Member and one of the industry’s leading GHS / HazCom experts with more than 20 years of experience in the EHS industry.

Leader—Summer 2021

15

SPECIAL SECTION OSHA’S PROPOSED CHANGES TO THE HAZCOM STANDARD

WILL HISTORY BE REPEATED?

By Lawrence P. Halprin, Partner Keller & Heckman LLP, halprin@khlaw.com

In the long term, the OSHA Hazard Communication Standard (HCS) is likely to be one of the most significant standards ever adopted by OSHA in terms of lives saved and injuries and illnesses avoided.

It also has one of the highest initial and ongoing costs of compliance1 (something that OSHA stubbornly refuses to acknowledge in consistently understating the costs of hazard classification, preparation of safety data sheets and labels, and employee training). This creates a compelling need for OSHA to make every reasonable effort to ensure the requirements of the HCS are developed and implemented to achieve their objectives in the most cost-effective manner and that the compliance obligations are fairly imposed on the appropriate party in a manner consistent with generally recognized principles of chemical safety and within the bounds of what Congress intended in Section 6(b) of the Occupational Safety and Health Act. 1

16

Leader—Summer 2021

JAMES JR., H., Estimating OSHA compliance costs, Policy Sciences 31: 321-341, 1998. https://link.springer.com/ content/pdf/10.1023/A:1004478930401.pdf

vpppa.org

T

he statement by Winston

(HCS) to conform with the

period is permitted when

underline, bold language inserted

Churchill, “Those that

United Nations’ (UN) Globally

the required information

by the author to clarify OSHA’s

fail to learn from history

Harmonized System of

from the upstream supplier

apparent intent as stated in the

are doomed to repeat it,”

Classification and Labelling

is not available in time

Preamble to the proposed rule):2

appears particularly applicable

of Chemicals (GHS). . . . OSHA

for a downstream user-

(d)(1) Chemical manufacturers

to the pending rulemaking to

is also proposing to modify

manufacturer to comply with

and importers shall evaluate

revise the HCS, which is the

provisions of a number of

the proposed revision to the

chemicals produced in their

most frequently amended and

other [OSHA] Standards . . . to

HCS as currently structured.

workplaces or imported by

by far the most complex OSHA

ensure consistency with the

This issue was not adequately

them to classify the chemicals

standard ever adopted by the

modified HCS requirements.

addressed in the HCS 2012

in accordance with this

rulemaking. The proposal

section. For each chemical,

to establish a compliance

the chemical manufacturer

deadline of 14 months for those

or importer shall determine

“reviewing” substances and 26

the hazard classes, and where

months for those “reviewing”

appropriate, the category of

agency.

In the Summary of the February 16, 2021 Federal Register notice announcing this rulemaking, OSHA stated: OSHA is proposing through this notice of proposed rulemaking (NPRM) to modify the Hazard Communication Standard (HCS) [1] to conform to the United Nations’ Globally Harmonized System of Classification and Labelling of Chemicals (GHS) Revision 7 (GHS, Rev. 7), [2] to address issues that arose during the implementation of the 2012 update to the HCS, and [3] provide better alignment with other U.S. agencies and international trading partners, without lowering overall protections

Most, if not all, of the major issues encompassed in the objective described as “address[ing] issues that arose during the implementation of the 2012 update to the HCS” could have been avoided with more effective communication during the HCS 2012 rulemaking. They now appear to be the critical issues of the pending rulemaking.

The substance of the relatively narrow changes to the mandatory classification criteria and the almost wholesale changes to the required precautionary statements that would be

mixtures is helpful but hardly adequate in the complex chemical industry where the chemical distribution system involves tiers of manufacturers and user-manufacturers, and one manufacturer’s mixture is the raw material for another user-manufacturer’s chemical reaction. These concerns were brought to OSHA’s attention in the HCS 2012 rulemaking, but apparently were not given adequate consideration because industry generally raised them

brought about by adopting

on a generic basis rather than

GHS, Rev. 7 will introduce

providing a sufficient number

additional complexity and

of specific examples.

uncertainty. They will

On no single issue is the need

each class that apply to the chemical being classified under normal conditions of use and foreseeable emergencies [anywhere in the chain of manufacture, distribution, and use].

The hazard classification shall include any hazards associated with a change in the chemical’s physical form or resulting from a reaction with other chemicals under normal conditions of use [anywhere in the chain of manufacture, distribution, and use]. Employers are not required to classify chemicals unless they choose not to

require time and resources

for specific examples of the

for retraining and to revise

infeasible burden of compliance

most of the existing safety

greater or more important than

September 30, 2009 Federal

data sheets (SDS) and labels

the proposed changes to the

Register notice announcing

for the hazardous chemicals

general hazard classification

the rulemaking that led to the

imported and produced in the

provisions of 29 CFR 1910.1200(d)

adoption of the current HCS

United States. There will be

(1) and the corresponding

[Table D.1 Section 2] . . .

(known as “HCS 2012”),

the recurring issues of when

provisions, in the mandatory

(c) Hazards identified

OSHA stated:

the revised requirements go

SDS template in Appendix D

under normal conditions

OSHA is proposing to

into effect, whether a phase-

of the HCS. With the proposed

of use that result from a

modify its existing Hazard

in period is permitted, what

changes, those provisions would

[downstream] chemical

Communication Standard

extension of the compliance

read as follows (new language in

reaction (changing the

of the standard.

In the Summary of the

2

rely on the classification performed by the chemical manufacturer or importer for the chemical to satisfy this paragraph (d)(1).

The following excerpts from the February 16, 2021 Federal Register Notice should eliminate any doubt: OSHA also proposes to add a new sentence to paragraph (d)(1) stating that the hazard classification shall include any hazards . . . resulting from a [downstream] reaction with other chemicals under normal conditions of use. OSHA believes this language is necessary because there has been some confusion about whether chemical reactions that occur [downstream] during normal conditions of use must be considered during classification. The agency’s intent has always been to require information on SDSs that would identify all chemical hazards that workers could be exposed to under normal conditions of use and in foreseeable emergencies (see paragraph (b)(2)). This issue has been raised, for instance, when multiple chemicals are sold together with the intention that they be mixed together [downstream] before use. For example, epoxy syringes contain two individual chemicals in separate sides of the syringe that are mixed under normal conditions of use. While OSHA intends for the hazards created by the mixing of these two chemicals to be considered in classification, those hazards need only appear on the SDS . . . and not on the label.

vpppa.org

Leader—Summer 2021

17

SPECIAL SECTION

chemical structure of

include reactions with other

manufacturing that product,

the original substance or

chemicals at the downstream

and the supplier’s employees

mixture) . . .

facility provided by another

presumably were exposed to

supplier and not involved

the hazards of that reaction

in the same process as the

and its reaction products

supplied chemical).

during those activities. Viewed

[Section 10] . . .(c) Possibility of

OSHA’S PROPOSED CHANGES TO THE HAZCOM STANDARD

hazardous reactions, including those associated with foreseeable emergencies . . .

Under OSHA’s interpretation of this language, the chemical manufacturer/importer would be required to identify all uses of its chemical that are known or could be discovered by due diligence, and then classify its chemical to reflect: (1) All hazards of the chemical as shipped; (2) All hazards resulting from changes in the physical form of the chemical (such as reduction to respirable or nano size, reduction to combustible dust, removal of solvent to leave residual solute); (3) All hazards posed by all downstream reactions of the chemical in the US— including planned reactions, intermediates, upset conditions, by-products, and

importer was required by the HCS to classify its chemical to reflect the hazards of planned downstream chemical reactions of its chemical and the products of that reaction on a broad generic basis. Rather, it had asserted that position, without any persuasive authority, in three unique situations. The first involved the manufacturer of epoxy syringes containing two individual chemicals in separate sides of the syringe that are mixed under normal conditions of use. OSHA was asked whether, in performing the hazard classification, the manufacturer/importer was required to take the hazards of the chemical reaction into

the manufacturer/importer classify both chemicals for the hazards of the chemical reaction and reaction products.

The syringe would be a container and an article.

The second unique example cited by OSHA in support of its position was the mixing of ready-mix cement and water. The ready-mix cement can only be used with water.

Under OSHA’s proposal, the utility company would need to prepare an SDS for its processed water, which would become a hazardous chemical because of its potential use in waterreactive reactions.

The third example cited by OSHA in support of its position was the combustion of fuels.

Those fuels perform their unique function through combustion and that circumstance cannot be used to support OSHA’s position

downstream reaction

tort law, OSHA answered

that the current HCS requires the

products of the chemical

in the affirmative, without

upstream supplier to classify its

in the US—including

meaningful explanation.

chemical to reflect the hazards of

planned reaction products,

OSHA’s response seems

downstream chemical reactions.

intermediates, products

appropriate in that context

of upset conditions, by-

where the supplier designed

proposal, an importer/

products, and decomposition

the kit (container/delivery

manufacturer of a chemical

products; and

system) to hold the chemicals

apparently would be

and deliver them in the

responsible for classifying its

emergencies involving

appropriate ratio to form

chemical all the way through

the chemical, including

the finished product, the

the distribution system to

those resulting from all

supplier presumably had

the point where the chemical

downstream chemical

conducted R&D and QA

was fully reacted.3 Where the

reactions (which would

testing in developing and

chemical is not fully reacted,

(5) All hazards of foreseeable

Leader—Summer 2021

upstream manufacturer/

it appears OSHA would have

by its understanding of

(4) All hazards posed by all

18

taken the position that the

in light of the current proposal,

account. Possibly influenced

decomposition products;

3

OSHA had never previously

Under OSHA’s pending

This is suggested by the following statement in OSHA 2015 HCS Compliance Directive: The first employer meeting the definition of a manufacturer does not need to consider uses of a chemically reacted version of their product. An example of this is a company providing methyl methacrylate to a second manufacturer who creates polymethyl methacrylate and then makes products from the polymethyl methacrylate; the first manufacturer does not need to warn on the hazards of the products made from the polymethyl methacrylate.

OSHA CPL 02-02-079, Inspection Procedures for the Hazard Communication Standard (HCS 2012), July 9, 2015, p.

22. https://www.osha.gov/OshDoc/Directive_pdf/CPL_02-02-079.pdf

vpppa.org

the chemical supplier might

Standard into the HCS. From

planned downstream chemical

continue to be responsible

a policy standpoint, it would

reaction is neither produced in

for classifying its chemical

inappropriately place the

their workplaces nor imported

to reflect its ongoing hazards

responsibility for classifying

by them. No other nation

until some point where an

the hazards of downstream

or region in the world has

OSHA compliance officer, in

reactions and reaction

adopted or proposed such an

the exercise of discretion,

products on an upstream

inverted regulatory scheme. We

determines those further

chemical supplier that

are not aware of a single OSHA

hazards would no longer be

generally will not have selected

enforcement action based

known or discovered through

the chemicals for that process,

on this position. It would be

due diligence.

designed that downstream

highly inappropriate for OSHA

process or exercised any

to completely overturn the

on this issue would create

control over that process,

existing regulatory scheme as

an inherent conflict in the

much less other unrelated

it has proposed to do.

hazard classification provision

processes in the same facility.

In short, OSHA’s position

of the HCS, would upend the

Section 1910.1200(d)

It would be highly inappropriate for OSHA to completely overturn the existing regulatory scheme as it has proposed to do.

In asserting this proposed change is simply a clarification

principles underlying chemical

currently provides and would

of existing law, OSHA has

safety and harmonization

continue to provide that

sidestepped the fundamental

under the GHS, would

“chemical manufacturers

legal obligation to assess

effectively incorporate the

and importers shall evaluate

its technical and economic

process hazard analysis

chemicals produced in their

feasibility. The HCS is a critical

provisions of the OSHA

workplaces or imported

standard. It is also critical to

Process Safety Management

by them.” The product of a

get it right.

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vpppa.org

Leader—Summer 2021

19

HAZCOM LEADING INDICATORS Implementation Under the VPP Elements

By Michelle Zapanta Control Board Operator, Step-Up Operations Supervisor, Industrial Fire Fighter, former Lead VPP Coordinator and current Chairperson for the Employee Safety Leadership Team Valero Benicia Refinery

20

Leader—Summer 2021

vpppa.org

The “Communication” in Hazard Communication

a site; the safety data sheet

But how can we gauge

HazCom deficiencies—this is preventative safety.

(SDS) for a process, mixture,

if our implementation of

or chemical; and the written

HazCom standards is truly

In the safety world, the term

HazCom safety program

effective? This can be put in

indicators can be identified

“hazard” is a regular part

itself. Visual communication

simpler terms with two basic

through simple data analysis

of our vocabulary. We speak

comprises the graphic elements

questions:

of hazards frequently in

found on placards, labels, and

1. What do we say we do?

conjunction with workplace

signage. These include colors,

2. Are we doing what we say

safety: hazard identification,

symbols, and pictograms.

hazard classification, hazard

Why is highlighting these

mitigation. Yet a critical part in

various communication

the effectiveness of managing

components important?

hazards at the workplace— Hazard Communication—may not be as prevalent in our safety highlights.

A common finding in postincident debriefs or critiques is a lack of communication or breakdown in communication.

This applies to all facets of the

Because identifying them lays the foundation for thoroughly gauging the effectiveness of our implementation of HazCom standards at our worksite.

HazCom Leading vs Lagging Indicators

we do?

This is where the inclusion

In terms of HazCom, lagging

and trending of incidents specific to those that resulted from HazCom deficiencies.

For incorporating HazCom in leading indicators, the process is considerably more

of HazCom in the leading

complicated. Employers must

indicators at our site comes

take a more comprehensive

into play.

look at HazCom program

Lagging indicators can dominate our safety statistics, as incident data trends have historically been the focal point of most traditional safety campaigns.

However, lagging indicators

deficiencies that may be present throughout the site, regardless of whether an associated incident has occurred.

This process is similar to the methodologies applied when performing a Process Hazard Analysis (PHA), where process

HazCom standards are in place

are the antecedents of the

to ensure chemical safety

consequences: incidents—the

in the workplace, setting

injuries and illnesses that

the minimum requirements

occur at the workplace. As

Workplace safety is not

that employers must meet

such, focusing on lagging

an exception to this, so it is

to ensure that all process

indicators alone leaves you

also important to recognize

and chemical hazards are

always looking backward when

the significance of effective

identified and communicated

assessing deficiencies—this is

communication in terms of

to the employees that may

reactive safety.

Hazard Communication. Let

encounter these hazards.

Leading indicators, on the

us not forget that the word

These regulations require

other hand, are the precedents

communication is right in

comprehensive hazard

to the consequences and

there. This entreats us to ask

“What if?” What if this chemical

communication programs to

therefore provide a predictive

ourselves the question, “Do

container was left unlabeled?

be written in accordance with

measurement for potential

What if that warning sign was

these requirements.

incidents that may result from

illegible? What if the SDS for this

workplace, making it is easy to recognize the importance of effective communication in our day-to-day operations.

we apply the standards for effective communication in

hazards and consequences of deviation are analyzed for causal factors along with both risk potential and probability— even if the consequences have never actually transpired.

Such as with the commonly used “What-if” methodology for PHAs, identifying leading indicators for HazCom at our worksite compels us to ask,

our implementation of Hazard Communication (HazCom) at our worksite?”

The communication element in any HazCom program comes in various forms: verbal, written, and visual. Verbal communication may be present in an instructor-led training class, on-the-job training with a mentor or supervisor, verbally communicated information at a safety meeting or safety presentation, or discussion of hazards as part of a job hazard analysis conducted during a jobsite visit. Written communication includes the words on placards, labels, and signage; the written policies and procedures governing vpppa.org

Leader—Summer 2021

21

The true key to successfully implementing HazCom leading indicators goes back to the basis for incorporating HazCom leading indicators in the first place . . .

mixture was missing? What if our employees were not trained on the proper PPE to wear when handling this substance? What if this drum developed a leak?

The main differences in the methodology of identifying HazCom leading indicators is the absence of the deviation guesswork and risk-ranking components: if something does not meet HazCom regulatory standards then it is a deviation and, if it is a deviation, then there is a consequent risk. Period. Employing this forward-thinking approach in the prevention of incidents is at the core of leading indicators, providing predictive data trends that indicate where improvements should be made and thereby allowing us to preemptively mitigate and

like a formidable construct.

of any solid construction—

This foundation can then be

Nonetheless, whether a small

in which to lay the various

built upon with additional

or large site with simple or

components of HazCom

HazCom leading indicators

complex operations, whether

applicable to our site.

by systematically identifying,

a long-term VPP Star site

What does this mean? This

under one VPP element or sub-

or just in the early stages of

essentially means outlining the

element at a time, any other

reaching or incorporating

elements of VPP (Management

HazCom-related components

HazCom leading indicators

Leadership & Employee

as they apply to our site per

(which may initially appear

Involvement, Worksite

HazCom regulatory standards.

to be a daunting task) can be

Analysis, Hazard Prevention &

accomplished by anyone using

Control, and Safety & Health

is systematic, laying the

Depending on the size and

this methodical approach:

Training) and inputting each

foundational HazRec

complexity of our worksite,

Utilizing the VPP elements

HazCom communication

components under their

the incorporation of HazCom

as the modules to form the

component under the

corresponding VPP elements

leading indicators can seem

foundation—the starting point

appropriate VPP element.

will not be a simple copy-

correct HazCom deficiencies.

HazCom Leading Indicators under the VPP Elements

22

Leader—Summer 2021

While this approach

vpppa.org

and-paste job. Each worksite needs to self-assess exactly which HazCom leading indicators are applicable to

• Employees trained on the

physical and health hazards of hazardous chemicals

• Employees aware of

receiving of shipments of

hours). We must additionally

hazardous chemicals

select the suitable data

• Hazard information for

tracking methods, e.g., survey, audit, database tracking,

their site and their employees,

where hazardous

documented in other written

while overlapping or related

chemicals are present

materials (such as operating

aspects of each VPP element

• Employee knowledge &

may also lead to differing

understanding of HazCom

determinations of how to

standards spot-checked in

lay out certain HazCom

the field

procedures) in accordance with HazCom requirements when in lieu of affixed labeling

• Employees informed of

hazards associated with non-

components based on the metric that is chosen.

For example, we may choose to track completion

& Health Training while choosing to quantify allotted hours for employee HazCom

in English (at minimum)

• SDSs readily available at

chemicals at the worksite

legibly labeled, tagged, or

components that may be used

marked as required

• Shipping containers

labeled, tagged, or marked appropriately and sent with the appropriate SDS(s)

• Engineering controls for

the protection of employees from chemical hazards in place and not modified

reviews/updates

classes provided to all affected employees

• On-the-job training

time with a mentor or supervisor provided to

Hazard Prevention & Control

• HazCom placards, labels,

•

use & access

Employees trained on

components. It serves merely incorporating HazCom leading

HazCom requirements

VPP elements.

trained on HazCom

implementing HazCom

definitions and requirements

leading indicators goes back

• New-hire employees

• Training includes specified

The true key to successfully

to the basis for incorporating

pictogram, hazard

HazCom leading indicators in

statement, signal word, and

the first place—to accurately

precautionary statement for

gauge the effectiveness

each hazard class and category

of our implementation of

• Additional training provided whenever new chemical

hazards are introduced into the workplace

• Training covers the

appropriate handling of chemicals

• Training informs employees of protective measures from hazards (use of

with GHS

engineering controls, use of administrative controls

HazCom standards at our worksite—and those two basic questions that bear repeating: What do we say we do and are we doing what we say we do? When it comes to identifying our HazCom leading indicators, keeping these two basic questions in mind as we input our HazCom components under the VPP elements translates to

standards (1. Identification,

procedures, PPE)

cumulatively assessing both

communicated to employees

2. Hazard(s) identification,

via safety meetings or

3. Composition/information

For the final step (of which

other mediums

on ingredients, 4. First-aid

Contract employees included

measures, 5. Fire-fighting

in HazCom program

measures, 6. Accidental

Readily available means of

release measures, 7.

access to safety data sheets

Handling and storage, 8.

Employee exposure to

Exposure controls/personal

completion rate, etc., for each

hazardous chemicals covered

protection, etc.)

HazCom component that we

Chemical inventory

identify as an appropriate

our objective of thoroughly

current and updated

leading indicator (such as in

gauging how truly effective

regularly as required

the example of using employee

our implementation of

Control measures in place

HazCom training completion

HazCom standards at our site

for the ordering and

rates versus allotted training

is (or isn’t).

in emergency response/

•

affected employees

and signage in accordance

• SDSs up to date with all

16 sections per HazCom

• Incident investigation results

•

nor a must-follow element

such as work practices and

affected employees

•

it is by no means an inclusive

indicators at our site under the

following breakdown of various

• Instructor-led training

or requirements at our site;

•

• All containers of hazardous

HazCom program

applicable HazCom standards

to illustrate the foundation of

mitigations

• Written comprehensive

VPP elements may not cover all

• Employees trained on SDS

generally up to our judgment

Management Leadership & Employee Involvement

It is important to note that this given breakdown under the

analyses performed

• Documented job hazard

VPP elements:

predictive data trends.

categorization of HazCom

requirements and safety

indicators under the

from which to develop our

• On-the-job training for

Leadership. Such specifics are

to identify HazCom leading

Safety & Health Training

spreadsheet reporting, etc.,

the worksite

addressing HazCom

element, as modeled in the

in their work areas

and signage in place, legible,

training under Management

within the scope of each VPP

contained in unlabeled pipes

• HazCom placards, labels,

rates of required employee HazCom training under Safety

routine tasks and chemicals

Worksite Analysis

collection and trending/

stationary process containers

action plan Employees participate in audits that address HazCom requirements

vpppa.org

• •

the specifics are a topic for another article!), we must determine the specific metric measurements we will be using, e.g., percentage of total, total count, average,

the design of our HazCom program in accordance with HazCom standards, as well as our actual application of those standards in the workplace.

Thus, it is in this way that incorporating HazCom leading indicators under the VPP elements can accomplish

Leader—Summer 2021

23

01 02 03 04

01

02

03

04

PLANNING FOR AND PREVENTING CHEMICAL EMERGENCIES A Safety Management System Approach

By Phil N. Molé

05 24

Leader—Summer 2021

vpppa.org

I 05

t seems that every time

ability to achieve the intended

we hear of a major

outcomes of its management

chemical accident, we

system, such as reductions

eventually learn of gaps

in numbers of occupational

in the location’s safety practices

illnesses and injuries. Chemical

that either directly led to the

management is one of the

incident, exacerbated it, or both.

factors an organization should

For example, most accident

consider here, as well as how

investigations conducted by the

well their current hazard

U.S. Chemical Safety and Hazard

communication practices

Investigation Board (CSB)

protect workplace safety

identify failures at the safety

and health. They should also

management system level as root

consider their relationships

causes of the accident. That

with their chemical suppliers,

means that there were problems

as well as with first responders

with the policies, procedures,

and area medical centers.

and everyday safety practices, including the safety culture, of the organization. Of course, the corollary to that is that by intentionally building a solid safety management system, we have a better chance of preventing chemical accidents, or at least of mitigating the potential harm if they do occur.

In what follows, we’ll explore how taking a safety management system approach can help us improve our chemical emergency planning, improve engagement of our workers with workplace safety, and protect the safety and health of our workers and our community.

Emergency Planning and ISO 45001

Consultation and participation of workers

Intentionally building a solid safety management system, we have a better chance of preventing chemical accidents, or at least of mitigating the potential harm if they do occur.

Section 5.4 states that an

!

organization must establish and maintain a process for consultation and participation of all workers at all applicable levels, and specifically notes that non-managerial employees must be included.

Additional information on this section located in the annex to the standard states that “consultation implies a twoway communication involving dialogue and exchanges.

Consultation involves the timely provision of the information necessary for workers, and, where they exist, workers’ representatives, to give informed

Emergency planning is a

feedback to be considered by the

significant part of any effective

organization before making a

safety management system.

decision.” The idea here is that

ISO 45001, the global standard

workers need to participate in

for occupational health and

a meaningful way in the safety

safety (OHS) management

of their workplace, including

systems, outlines a number

the ability to conduct key safety

of elements relevant to

tasks and help identify hazards,

emergency planning that an

risks and opportunities.

organization needs, including:

Understanding the organization and its context

vpppa.org

Actions to address risks and opportunities Section 6.1 is interesting.

Everything in safety

Employers aligning their safety

management ultimately

management system with

comes down to identification

Section 4.1 of ISO 45001 should

and control of risks. Failure

determine the external and

to identify and address risks

internal issues relevant to its

related to chemical products

purpose, and which affect its

in our workplace can have

Leader—Summer 2021

25

Workers need to participate in a meaningful way in the safety of their workplace, including the ability to conduct key safety tasks and help identify hazards, risks, and opportunities.

01

disastrous consequences in

should make sure that they’re

encountered when responding

the event of an emergency.

making them in a language and

to an incident places emergency

Employers need an effective and

format that all of their workers

personnel at risk, because it

robust system for managing

can understand, and verify that

reduces the likelihood that

corrective actions, including

they’ve understood them.

they’ll have the proper personal

simple ways to initiate, assign, prioritize, and track these actions to completion.

Resources

protective equipment (PPE) and

Eliminating hazards and reducing OHS risks

response tactics.

the expectation is set for an

communities at risk—as

In section 8.1.2 of the standard, organization to do its best

that an organization needs to

to eliminate hazards (i.e.,

provide the resources necessary

sources of risk) and reduce the

to establish, implement,

likelihood and severity associated

maintain, and continually

with remaining risks. The

need this information to

improve safety management.

“consultation and participation

recognize and understand

This means it must budget for

of workers” mentioned in

exposure symptoms, identify

equipment needed to meet the

Section 5.4 is especially helpful

vulnerable populations, and

needs of all employees during

here, because if employers can

take sufficient precautionary

emergencies. This equipment

get all of their workers involved

and treatment measures. As

may include, but is not limited

in identifying risks, such as by

we can see, our own gaps in

to, transportation devices,

doing inspections and submitting

hazard communication create

communication devices,

hazard reports, they can harness

a pattern of additional risk that

emergency control systems,

the collective knowledge of

radiates outward like a fracture

alarms and other warning

their workforce and share

on a windshield, affecting the

systems. Software systems

responsibility for safety.

entire community.

Don’t Go it Alone

something businesses need to

conclusions by reviewing the

emergency responders, and

access to SDSs, improving access to safety data and simplifying management of safety tasks (e.g. inspections of chemical storage locations and investigations of chemical spills or exposure incidents) can be great potential resources.

Communication

26

Leader—Summer 2021

health care providers, municipal officials, and other community stakeholders

Emergency planning isn’t just We can draw a couple of parts of ISO 45001 relevant to emergency planning. First, it’s important that our emergency planning and response is wellintegrated with the rest of our safety management system.

Second, doing emergency

According to Section 7.4 of

planning well requires the

the standard, an organization

direct engagement and

must establish processes

consultation of our workforce.

for communicating safety

Meaning, we won’t succeed if

management information to

we try to go it alone.

employees. Communications

03

members of the community,

Section 7.1 of ISO 45001 states

for managing and providing

02

Lack of chemical hazard information also places

Consider the importance of

do—it’s something businesses, regulatory agencies need to do together. It’s a collaborative process that goes beyond the sharing of information, as important as that may be. It’s about having relationships with all stakeholders, involving them early in the planning process and making sure there are no gaps in communication that could prove costly in the event of a disaster.

And it goes beyond even that, to our own roles in the

specific to chemical emergency

having access to emergency

chemical supply chain. No

planning might include

response information in the

matter where we sit in the chain,

methods of providing access

event of a major chemical

we have responsibilities to

to safety data sheets (SDSs),

release. Without information

ensure the flow of information

and procedures to follow

about the identity of the

to all stakeholders. If we are

in the event of a chemical

chemicals on-site, their

a chemical supplier, we need

emergency, including how to

physical and health hazards,

to classify the hazards of our

locate and use the emergency

and appropriate firefighting

chemical products, develop SDSs

contact telephone number in

and emergency response

and shipped container labels,

Section 1 of SDSs, and specific

measures, first responders

and provide an emergency

procedures to be followed for

lack information necessary to

contact number in Section 1 of

various kinds and sizes of spills.

safely control and extinguish

the SDSs. If we’re end users, we

It’s important to remember

a fire or address dangerous

need to keep communication

that when making these

releases. Uncertainty about

open with our suppliers to

communications, employers

chemical hazards that may be

ensure we’re getting the most

vpppa.org

!

up-to-date documents from

to have a successful emergency

incident investigations related

support and mitigation

them—which will be especially

planning program. When we’re

to chemical hazards, completion

assistance in the event of a

important now that OSHA has

planning our “resources” per

of job safety analyses (JSAs) for

chemical spill or other incident,

issued a notice of proposed

Section 7.1 of ISO 45001, we

chemical management tasks,

including incident notification

rulemaking (NPRM) to update

should consider the benefits

scheduling of safety meetings,

and reporting to designated

the HazCom Standard that will

of a purpose-built safety

and easy tracking of corrective

emergency contacts.

change the way manufacturers

management software solution,

actions related to chemical

of certain chemical products

as well as contracted emergency

management. Even better, it

facilities still bear the risk for

like aerosols, desensitized

response services.

gives you visibility into your

a serious chemical-related

most important safety metrics so

emergency. But with the right

explosives, and flammable gases

For example, a modern-day,

Even the most well managed

are classified. Employers also

full-blown safety management

you can keep everyone involved

need to provide barrier-free

planning and the right tools, you

solution—like VelocityEHS—

in your emergency planning

access to SDSs in the workplace,

can minimize the impact of an

helps achieve this. It includes

practices well-connected and

and train their employees on

incident on your business and

cloud-based tools to manage

informed, allowing for better

HazCom, including how to find

reduce the risks to your workers

your chemical inventory

decision-making.

emergency contact information

and your community.

and SDSs, strengthening

in Section 1.

your emergency plans, and

in the chemical supply chain,

streamlining access to SDSs,

you can benefit from emergency

Planning for Safety

And no matter where you are

and the chemical hazard and

response services. If you’re

Getting the right safety

emergency response information

a supplier, for instance, you

management system in place

contained within. It takes this

can get a 24-hour toll-free

takes planning. Too often,

important functionality and

emergency phone number to

one of the obstacles is that

combines it with the ability

include in Section 1 of SDSs

EHS professionals lack the

to simplify and share other

for your chemical products. If

support they need to take the

key safety tasks, such as

you’re an end-user, you get

proactive approach they need

performance of inspections and

chemical incident exposure

vpppa.org

Phil N. Molé, MPH, is an EHS & Sustainability Expert at VelocityEHS, the global leader in cloud environment, health, safety (EHS) and sustainability software.

To learn more about VelocityEHS and how its Safety Management Solution provides real support for managing safety tasks and improves safety performance visibility, visit www.EHS.com.

Leader—Summer 2021

27

HAZARD COMMUNICAT

By Mackenzie Barnwall (top), MS, GSP, and Megan Scherer (bottom), Safex

A

s a health and safety

safe workplace and reduce

consultant, I’ve

exposure and injury.

performed my share of

The compliant program

chemical inventories and found

includes training, chemical

secret stashes of chemicals

inventories, labeling, and

strewn about facilities. Even businesses that appear to have hazard communication

who may be exposed to

(HazCom) procedures in order

hazardous chemicals

can do some simple things to

during routine operating

better ensure worker safety.

procedures or emergencies

Before we dig into best

are required to be trained.

practices from my experiences,

While there are a few

it is important to understand the

exceptions for employees

following key elements of the

related to non-routine

OSHA Hazard Communication

scenarios, it is a best

standard (29 CFR 1910.1200),

practice to error on the side

frequently referred to as HazCom.

of caution when determining

1. Written HazCom

who needs to be trained.

Program—If your facility

28

Leader—Summer 2021

safety data sheets.

2. Training—Employees

Training must include

produces, uses, or stores

methods and observations to

hazardous chemicals, you

detect releases of hazardous

are obligated to have a

chemicals in the work area,

written HazCom program.

the hazards of the chemicals

OSHA’s intent with the

in the work area, measures

program is to support a

employees can take to

vpppa.org

LESSONS

ION

From the Field

protect themselves using

handling. Employers are

16-section format, that

work practices, emergency

responsible for making sure

includes the properties of

procedures, personal

that the labels provided

each chemical; the physical,

protective equipment, and

by the manufacturer,

the details of the site-specific

importer, or distributor

health, and environmental

hazard communication

are legible, so the chemical

program, including an

name, pictograms, hazard

explanation of labeling,

statements, signal word, and

safety data sheets (SDSs), and

precautionary statement for

how employees can obtain

each hazard class are visible.

hazard information.

Employers must also ensure

3. Chemical Inventory—

that all secondary containers

Completing an annual chemical inventory audit

are appropriately labeled.

5. Safety Data Sheets (SDS)—

can help you determine

Safety Data Sheets must be

which chemicals are in use

readily available in paper

at your facility. You’ll be able

or electronic format, for

to identify new chemicals,

employees to view when

purge and acquire new

working with hazardous

SDSs, and determine if the

chemicals. If SDSs are

chemicals are labeled and

electronic, they must have

stored properly.

no access barriers (i.e.,

health hazards; protective measures; and safety precautions for handling, storing, and transporting the chemical.

Sections 1 through 8 contain general information about the chemical, identification, hazards, composition, safe handling practices, and emergency control measures. Sections 9 through 11 and 16 contain other technical and scientific information, such as the physical and chemical properties, stability and reactivity information, toxicological

everyone must be able to

information, exposure control

chemicals must be labeled

log in to the computer or

information, and other

properly to notify employees

server that stores them).

information, including the date of

of the hazards involved in

SDSs must have a uniform,

preparation or last revision.

4. Labeling—Hazardous

vpppa.org

OSHA’s second most frequently cited standard is hazard communication.

Leader—Summer 2021

29

1

LESSON

OSHA can, and will, fine for HazCom noncompliance.

OSHA’s second most frequently cited standard is hazard communication.

Fines are generally issued around not maintaining the all-important hazard communication plan, not fully training employees (more on that in Lesson #4), failing to label correctly, and other chemical inventory issues.

One of my colleagues tells a story about a mechanical contractor he worked with many years ago. He noticed they were deficient in several areas of HazCom. Their SDSs were stored haphazardly. Also, instead of replacing the old SDSs with newer versions, they had every single version, and they weren’t easily accessible for emergency use. Despite his efforts to convince them to be proactive and change their practices with labeling and training, the owners decided not to take his suggestions. Two years later, the company was issued an OSHA citation for the exact issues he was concerned about.

3

LESSON

2

LESSON

out of compliance because the SDS did not match. We helped them request an SDS from the new manufacturer to ensure compliance.

Establishing a chemical review process before allowing a new chemical to be purchased, may be helpful in preparing for what chemicals are going to come into the facility. Additionally, another way to ensure you are aware of new chemicals, is by building a relationship with your purchasing department. Since they typically are the gatekeepers, the purchasing department will be able to alert you when something new is in use and can even help you obtain the SDS. Following these best practices will help you be proactive rather than reactive.

30 Leader—Summer 2021

and chemical inventory can help keep everything in order.

The annual review is a great time to make sure you have all necessary SDSs in a binder or electronic folder. And remember to save the SDSs of chemicals no longer in use in a different file; SDSs for legacy chemicals must are taken out of service.

Take it from me, investing a little time each year in keeping your SDS binder current saves time in the long run. I’ve uncovered SDSs with pages browned and older than me, and programs lacking the required physical hazards, health hazards, and personal protective equipment. These tasks are low hanging fruit, so

During a recent visit with a client, we determined that their muriatic manufacturer. Even though the chemical was the same, they were

Annual reviews of your program

be saved for 30 years after they

Establish a process to ensure the chemical inventory is up-to-date, especially with new chemicals.

acid supplier changed, and the SDS on file was from the previous

Annual reviews are critical.

If your facility produces, uses, or stores hazardous chemicals, you are obligated to have a written HazCom program.

tackle them annually.

It is also important that SDSs from 2012 or prior are reviewed and updated to ensure they comply with the HazCom standard changes made that year. Prior to 2012, manufacturers provided Material Safety Data Sheets (MSDSs) that were not aligned with Globally Harmonized System of Classification and Labeling of Chemicals (GHS) rules.

vpppa.org

4

LESSON

Stay on top of HazCom and chemical safety training and make it fun.

Training, as required by the OSHA standard, must be completed at the time of initial assignment and whenever a new physical or health hazard is introduced into the workplace. Many of our clients reiterate the importance of hazard communication by conducting annual training, or giving 10-15-minute toolbox talks, as repetition is required for retention.

One of my hacks for interactive HazCom training is to provide employees with an SDS and ask them hazard-based questions they can answer by looking

SDSs for legacy chemicals must be saved for 30 years after they are taken out of service.

5

LESSON Mackenzie Barnwell, MS, GSP, is an industrial hygiene consultant at Safex, a health and safety consulting firm in Westerville, Ohio.

Megan Scherer is a marketing communications professional at Safex specializing in digital communication and content creation.

Electronic Safety Data Sheets (SDS) are imperative.

Having a binder in a central

through the SDS. Creating a

location makes it easy for

trivia game, which includes

employees to access SDSs.

all five key elements of

But I’ve also seen many

a hazard communication

customers struggle when

program as the categories, is

the binder is misplaced

another fun and competitive

or damaged. I always

way to keep employees

recommend having all your

engaged in the training.

SDSs saved electronically, regardless of whether you have a binder in use.

There are companies that provide access to online SDS databases that you can build up based on what you have in your facility, or you can create your own database using spreadsheet software, such as Microsoft Excel.

vpppa.org

Leader—Summer 2021

31

By Warren Silverman, MD FACOEM Medical Director Workplace Forensics LLC

T

the desert to the mountain

people of the Lakota

tops, the earth provides the

revolution, man’s technology

culture called her Unci

sustenance of our lives.

sparked a hunger and an

Maka, or Mother Earth. She

32

With the industrial

he Native American

Throughout the history of

obsession with creating,

was the “giver of life,” and as

man, our impact on the earth

building, growing, and

such, needed to be protected

has been tiny compared to its

manipulating the earth to

at all times. We live and work

vastness. We chipped rocks, dug

accommodate for our increasing

on the earth. It’s erosion from

for metals like copper and iron,

numbers and our variety of

many eons, worn by the winds

plowed it for our crops, but in

curiosities. We tapped into

over millions of years to make

general, these tiny scratches on

chemists and other scientists

the precious soil in which the

the vastness of our earth made

who learned how to use the

flora of the earth thrive. From

hardly a scratch in it.

many gifts hidden in our planet.

Leader—Summer 2021

vpppa.org

levels of Cadmium. Fertilizer

soil-based agriculture just at

poured our chemicals into the

in Europe contains bout 32

a time when our soil will be

earth. We have sprayed them,

mg Cadmium per kilogram

experiencing marked fatigue

spread them, released them,

and has been measured up to

and contamination. We can

and the earth has taken them in.

200 mg Cd/kg. Cadmium has

accommodate to some degree

There is no place on earth now

been linked to kidney disease

by decreasing food waste,

where the soil is virgin. Even in

and bone disorders. The metal

but that will not be enough to

ice cores hundreds of feet deep,

concentration in the soil will

sustain our population which

we find hundreds of years of

only increase over time and

is expanding in developing

airborne chemicals deep under

eventually the soil will be too

countries and decreasing in

the surface.

poisonous to use.

developed countries.

The earth has felt us. We have

Something important to

And what about those

The answer will come from

consider is that we are changing

phosphates. These mined

technology. Agriculture will need

our soil in a permanent fashion.

chemicals have helped us to

to become more efficient, and

It will never be the soil of your

produce increasingly bountiful

less soil based. Hydroponics and

forefathers. The impact is

crops to feed a growing

alternative means of producing

cumulative. While some things

population, but at the same

man made proteins will make

may decompose and degenerate,

time, they are causing more

for a vastly different dining

there is always residue, always

long-term problems than they

experience by the year 2050.

an impact.

aid. When you look at a fertilizer

The good news is that we

In 2014, China released a

bag it tells a story. There are

can delay some of this. We

report citing that 19.4% of its

3 numbers (N-P-K). The first

can delay it by limiting soil

farmland, or 64 million acres,

number is the Nitrogen content.

pollution. We can learn to

were polluted with Cadmium,

The second is the phosphorus

abate other soil contaminants.

Nickel, and Arsenic to the point

content (P2O5), and the third is

We can try to capture

where it could not be used to

the potash content representing

nonarable land and use it, an

grow crops. These regions near

potassium content.

initiative that might rely on

Too much phosphorus will

water sources which will not

also supply the water to millions

cause plants to grow poorly and

be available due to increasing

of people. Half of all the rice

will limit a plant’s ability to take

water shortages. We can

crop tested in Guangzhou were

up iron and zinc, which they

anticipate the impact of

found to have toxic levels of

need. Even more disturbing,

global warming and move our

Cadmium. In addition to metal

run-off of phosphorus into

agricultural areas northward

and other organic and inorganic

our waters, our lakes, and our

and repurpose agricultural

material contamination, more

streams, can kill the life in these

lands in areas that will suffer

than 40% of the soil in China is

bodies. Large algae blooms

from heat and drought.

degraded from overuse, erosion,

develop and oxygen levels in

and pollution. The heavy

the water drop. Dead zones can

which a decade ago had

metals, organic, and inorganic

form, and the algae can cause

agricultural climates like

chemicals coming out of the

sickness in humans.

southern California, now suffer

the Yangtze and Pearl Rivers

smokestacks of these large

Let us put this into a bigger

Countries like Cambodia,

from severe yearly droughts

industrial areas cause markedly

perspective. Whether you

which make growing crops

elevated levels of arsenic and

like it or not, or participate

impossible. The droughts in

other chemicals in rice and

in it or not, the human diet is

Africa are destabilizing and vast

other crops.

changing, and in 20 years it

human migrations are being

will be dramatically changed.

felt. The impact on humans is

problem is contained to one

Part of this is generational,

already quite real.

country or even one region. It

but part is due to the inability

is all over the earth. In 2018 the

to sustain our current diet.

be smart. We have to plan.

European Commission began

The general trend involves the

We have to recognize and

a debate about Cadmium in its

protein we eat and need. There

acknowledge that we have

soil. Where did it come from?

is an early, but rapidly growing

committed a grave sin against

Not the industrial smokestacks

evolution to move from an

Unci Maka, our Mother Earth,

causing the problem in China. In

animal-based source of protein

and its soils, and we have to

Europe, the phosphate fertilizer

to a plant-based source. Within

amend. It will only be a matter

spread on the ground to

20 years, there will be marked

of time before our dinner is

increase crop yields is mined in

limitations and constraints on

sucked out of tubes, and people

places in North Africa where the

animal-based foods. This will

will talk about the legend of a

sedimentary rock contains high

put a much bigger demand on

steak and potatoes meal.

But don’t think that this

vpppa.org

There is no place on earth now where the soil is virgin. Even in ice cores hundreds of feet deep, we find hundreds of years of airborne chemicals deep under the surface.

REFERENCES: 1

https://qz.com/200602/ china-just-revealed-amajor-state-secret-nearly20-of-its-farmland-ispolluted/

2

https://www.economist. com/briefing/2017/06/08/ the-most-neglected-threatto-public-health-in-chinais-toxic-soil

3

https://pubmed.ncbi.nlm. nih.gov/20485999/#:~:text= Polished%20rice%20 from%20various%20 production,114.4%20ng%20 g(%2D1).

4

https://www.euractiv.com/ section/agriculture-food/ news/wed-the-cadmiumwar-eu-in-the-midst-of-ageopolitical-arm-wrestling/

5

https://www.ncagr.gov/ cyber/kidswrld/plant/ label.htm#:~:text=All%20 fertilizer%20labels%20 have%20three,)%20%2D%20 potassium(K)).

6

https://www.usgs.gov/ special-topic/waterscience-school/science/ phosphorus-andwater?qt-science_center_ objects=0#qt-science_ center_objects

7

https://counties.agrilife. org/valverde/files/2014/11/ Phosphorus-Too-MuchPlants-May-Suffer.pdf

8

https://www. nationalgeographic.com/ environment/article/ mekong-river-lowest-levels100-years-food-shortages

The point is, we have to

Leader—Summer 2021

33

Written by the International Safety Equipment Association (ISEA)

PROTECT YOURSELF

Against Chemical Hazards on the Job

W

ANSI/ISEA Z87.1-2020

operating procedure covering

orkers across

will protect the arms and hands

many industries

from harmful substances and

American National Standard on

regular training, fit-testing, fit-

are at risk daily

skin absorption.

Occupational and Educational

checking, periodic environmental

Personal Eye and Face Protection

monitoring, maintenance,

of coming

NIOSH offers a

into contact with hazardous

Recommendations for Chemical

includes an Eye and Face

medical monitoring, inspection,

chemicals, including those in

Protective Clothing (CPC)

Protector Selection Chart to aid

cleaning, storage and periodic

agriculture, manufacturing,

database, which provides

in identifying and selecting the

program evaluation. The current

construction, transportation,

CPC recommendations for

types of eye and face protectors

listing of NIOSH certified

laboratories, and more. In fact,

the chemicals listed in the

available, and their capabilities

respirators can be found in the

the Centers for Disease Control

NIOSH Pocket Guide to Chemical

and limitations for different

NIOSH Certified Equipment List,

and Prevention (CDC) estimates

Hazards. Access the database at

hazards, including potential

which is available on the NIOSH

more than 13 million workers in

cdc.gov/niosh/ncpc.

chemical exposure.

web site.

Protect Your Lungs

In Case of an Emergency

the United States are potentially

OSHA also provides

exposed to chemicals while on

guidelines on the various types

the job.

of clothing that are appropriate

From severe chemical burns

for use in various chemical

to corrosion of the skin and

operations. See Section 8,

skin cancer, whether effects

Chapter 1 of the OSHA Technical

are temporary or have lifelong

Manual at osha.gov/otm.

personal protective equipment (PPE) to protect the skin, eyes, and respiratory system is vital to workers’ safety.

Protect Your Skin

internally, as well. Lungs,

If accidents do happen and a

organs, and the nervous system

worker is exposed to dangerous

are at risk if hazardous chemicals

chemicals, emergency eyewash

are inhaled. In these cases,

and shower equipment, when

respirators can filter out toxins

used correctly, can help to

to provide users with breathable

minimize injury and should be

A worker’s eyes are also at risk to

oxygen. The NIOSH Pocket Guide

part of an employer’s worker

chemical hazards, and exposure

to Chemical Hazards provides a

protection program.

or contact can cause permanent

table of allowable respirators to

eye damage and blindness. Safety

be used for certain chemicals.

consequences, having access to and wearing the appropriate

Chemicals can harm a worker

Protect Your Eyes & Face

goggles will protect a worker from

All respirators selected must

OSHA, 29 CFR 1910.151, requires that: “Where the eyes or body of any person may be

acids, chemical gases, vapors, and

be approved by NIOSH, and a

exposed to injurious corrosive

Coveralls with hoods or other

from liquid chemicals splashing

complete respiratory program

materials, suitable facilities for

full-body protective suits are

into the eye. Face shields help

must be implemented. A

quick drenching or flushing

often used for skin protection,

protect against splashing or

respiratory protection program

of the eyes and body shall be

and chemical resistant gloves

misting onto the face.

includes a written standard

provided within the work area

34 Leader—Summer 2021

vpppa.org

for immediate emergency use.” Some states also require emergency eyewash and shower equipment in workplaces where there are irritants or chemicals that are toxic by absorption.

Many states require the use of ANSI/ISEA Z358.1 (American National Standard for Emergency Eyewash and Shower Equipment) compliant equipment, which provides guidance to users on the need for proper emergency eyewash and shower equipment to mitigate injury from splash and ocular incidents, to illustrate eyewash and shower equipment systems, and to assist in the proper selection, use and maintenance of emergency eyewash and shower equipment.

Know Your Chemicals The NIOSH Pocket Guide to

Chemical Hazards is an excellent source of general industrial hygiene information for workers, employers, and occupational health professionals, aimed at helping users recognize and control occupational chemical hazards. Get the full guide at cdc.gov/niosh/npg.

To better understand how many workers in the U.S. and by state are using these PPE products across multiple industries, visit ISEA’s new Economic and Safety Impact Tool at safetyequipment. org/industryimpact.

VPPPA Partner, ISEA, is the leading association for personal protective equipment and technologies that enable people to work in hazardous environments, and an ANSI accredited standards developing organization. The association works closely with manufacturers, test labs, subject matter experts, end-users and government agencies in the standards development process. ISEA members—leaders in safety equipment manufacturing, testing and application—are united in the goal of protecting workers worldwide. Visit their website to learn more at safetyequipment.org. vpppa.org

Leader—Summer 2021

35

Follow us on social media!

Facebook @VPPPA

Membership Corner

Twitter: @VPPPA

Instagram: @VPPPA_Inc LinkedIn: VPPPA, Inc.

Summer Members of the Month

Congratulations to our summer Members of the Month!

June:

Nina Mendonca

July:

Fady Guirguis

T. Marzetti Company, Chatham

Morton Salt—Production &

Region I

Region IX

Village, Warehouse Personnel

Maintenance Manager

August:

Michael Hancock

Marine Corps Air Facility

Quantico—Director of Safety, VPP Site Coordinator Region III

Want to submit someone to be considered as a VPPPA Member of the Month? Email membership@vpppa.org.

Visit vpppa.org to read more about the current Member of the Month.

Welcome!

The VPPPA National Board has welcomed two new faces during a special election held this past spring. Please join us in welcoming our two new Board members!

There’s still time

to make it to the annual Safety+ Symposium in Nashville, TN, August 31–September 2. In fact, there are three ways to attend!

In-Person

Join us at the Gaylord Opryland Convention Center in Nashville.

Register at vpppa.org/events or onsite during the symposium.

Virtually

No plane ticket required. Join us from your computer.

Hybrid Access

Come to Nashville to enjoy the symposium AND receive every workshop recording to listen to for 30 days post-symposium.

Learn more or register today! vpppa.org/events

36

Leader—Summer 2021

Michelle Keever

Daniel Charles

UCOR, an Amentum-Led

Brandenburg Industrial Service

Director from a DOE-VPP Site

Director-At-Large

Partnership with Jacobs

Company

Oak Ridge, Tennessee

Chicago, Illinois

The annual elections for the VPPPA National Board of Directors will be held at the 2021 Safety+ Symposium in Nashville, TN, August 31–September 2.

Join the VPPPA N.O.W. (Network of Women) Facebook Group

Are you a woman in safety looking to network with industry peers?

Consider joining the VPPPA N.O.W. Facebook group! This is a private space to come together as women to encourage, pose questions, and empower. Because women are what is happening in safety NOW. To find the group, simply search for “VPPPA N.O.W.” on Facebook and request to join.

vpppa.org

A Note from the VPPPA Membership & Outreach Manager, Son Nguyen As the country starts to open back up and employees return to the office, companies face both old and new health and safety challenges.

These challenges cry out for companies to improve occupational health and safety, building a dependable safety culture. Leading the way in safety culture is the VPPPA.

Your continued support this year has allowed the VPPPA to:

• Host 9 webinars on topics such as OSHA Under the Biden Administration, Virtual VPP Audits, and Rethinking the Near Miss.

• Conduct our first virtual Next Level Safety conference,

which offered 24 workshops presented by industry leaders and top federal and state-plan VPP OSHA representatives.

• Produce the Leader magazine, our award-winning

quarterly magazine; providing in-depth information and guidance on the most crucial issues that affect our members.

• Move our award-winning blog from twice a month postings to once a week.

Please continue to support us by renewing your membership. You will gain access to:

• FREE live and recorded webinars • Mentoring partnership program • Member content library • Discounted rates on exclusive VPPPA

conferences, events, and other association training and networking opportunities.

• Our new advocacy webpage, which allows VPPPA members to connect with their

local representatives to take action and have their voices heard. Visit vpppa.org/ advocacy for more information.

If you have any questions regarding your VPPPA membership, please contact me at 703-761-6515, or email snguyen@vpppa.org.

Thank you again for your dedication and we look forward to serving you in the upcoming year.

vpppa.org

Leader—Summer 2021

37

www.vpppa.org

VPPPA National Board of Directors Chairperson Terry Schulte, NuStar Energy, LP

Vice Chairperson Dan Lazorcak, CSP, Honeywell International Treasurer Sean D. Horne, Valero Energy Secretary Kristyn Grow, CSP, CHMM, SGE Cintas Corporation Director from a Site With a Collective Bargaining Unit Jack Griffith, CH2M Hill Plateau Remediation Company Director from a Site Without a Collective Bargaining Agent Johnathan “JD” Dyer, Shermco Industries

Ad Index

Advertiser Website

Page

AIM

www.aimforsafety.com 9

Bulli Ray Enterprises

www.bulliray.com 40

Creative Safety

www.creativesafetyllc.com 31

Director-at-Large Bill Linneweh, CSP, Hendrickson International

Ericson

www.ericson.com 37

Director-at-Large Andy Youpel, SGE, Brandenburg Industrial Service Company

Glove Guard

www.gloveguard.com 27

Director from a DOE-VPP Site Michelle Keever, UCOR, an Amentum-Led Partnership with Jacobs Director from a VPP Contractor/ Construction Site Brad Gibson, S&B Engineers & Constructors Director-at-Large Shelly Ettel, PCAPP

Director-at-Large Christina Ross, Morton Salt

Industrial Scientific www.indsci.com 3

Director-at-Large Daniel Charles, Brandenburg Industrial Service Company

Roco Rescue

www.rocorescue.com 4

Director-at-Large Rocky Simmons, Mission Support Alliance

VelocityEHS www.ehs.com

Editor Kerri Usher, VPPPA, Inc.

Working Concepts

2

www.softknees.com 19

Associate Editor Ariana Hanaity, VPPPA, Inc. EDITORIAL MISSION

The Leader (ISSN 1081-261X) is published quarterly for VPPPA members. The Leader delivers articles from members for members, safety and health best practices, developments in the field of occupational safety and health, association activities, educational and networking opportunities and the latest VPP approvals. Subscriptions are available for members as part of their membership benefits and at a 50 percent discount beyond the complimentary allotment. The nonmember subscription rate is $25 a year.

Ideas and opinions expressed within The Leader represent the independent views of the authors.

Postmaster >> Please send address changes to: VPPPA, Inc. • 7600 Leesburg Pike, East Building, Suite 100 • Falls Church, VA 22043-2004 VPPPA, Inc., the premier global safety and health organization, is a nonprofit 501(c)(3) charitable organization that promotes advances in worker safety and health excellence through best practices and cooperative efforts among workers, employers, the government and communities.

38 Leader—Summer 2021

VPPPA contacts

o reach the VPPPA National Office, call (703) 761-1146 or visit T www.vpppa.org. To reach a particular staff member, please refer to the contact information below.

Sara A. Taylor, CMP Director of Operations staylor@vpppa.org

Sierra Johnson Senior Education Coordinator sjohnson@vpppa.org

Natasha Cole Events Coordinator ncole@vpppa.org

Son Nguyen Membership & Outreach Manager snguyen@vpppa.org

Heidi Hill Partnership Manager hhill@vpppa.org

Kerri Usher Communications & Outreach Manager kusher@vpppa.org Ariana Hanaity Communications Coordinator ahanaity@vpppa.org

vpppa.org

Infographic Corner

In 2020, OSHA named Hazard Communication as

#2 on their Top 10

Most Frequently Cited Standards.

13 million workers

in the United States are potentially exposed to chemicals while on the job according to the CDC.

In the Johnson Controls case, the U.S. Supreme Court held that

refusing to hire women who could become pregnant, because of concerns about the impact of workplace chemicals on fetal development,

violated Title VII of the Civil Rights Act. vpppa.org

More than 40%

of the soil in China is degraded from overuse, erosion, and pollution.

In 2014, China released a report citing that 19.4% of its farmland, or

64 million acres, were polluted with

Cadmium, Nickel, and Arsenic

to the point where it could not be used to grow crops.

Workplace violence is the number one cause of death for women in the workplace.

Leader—Summer 2021

39

7600 Leesburg Pike, East Building, Suite 100 Falls Church, VA 22043-2004 Tel: (703) 761-1146 Fax: (703) 761-1148 www.vpppa.org VPPPA, a nonprofit 501(c) (3) charitable organization, promotes advances in worker safety and health excellence through best practices and cooperative efforts among workers, employers, the government and communities.

SCAN QR CODE TO LEARN MORE ABOUT VPPPA, INC.

http://bit.ly/jVQcBo

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