MSDSonline Environmental, Health & Safety Blog

The Chemical Safety Board (CSB) recently released a safety video titled “Combustible Dust: An Insidious Hazard,” which demonstrates the dangers of accumulating combustible dust particles and how they lead to catastrophic explosions that kill and maim workers and damage surrounding communities. 

The video illustrates how combustible dust buildup lead to three major accidents that the CSB has investigated and it includes actual news footage and photographs from the events.

Combustible dusts are solids that have been ground down into small bits, fibers, particles or flakes that have the ability to ignite into flames when suspended in air under certain conditions. They exist in a variety of industries from sugar manufacturing to metal processing to recycling operations. Many times companies don’t realize the dangers that these particles present until it’s too late.  According to OSHA, more than 130 workers have been killed and more than 780 injured in combustible dust explosions since 1980.

OSHA has recognized the dangers of these explosive particles for some time and earlier this year announced its plan to initiate a comprehensive rulemaking on combustible dust.  In a statement made on April 29, 2009, Secretary of Labor Hilda L. Solis said, “Over the years, combustible dust explosions have caused many deaths and devastating injuries that could have been prevented. OSHA is reinvigorating the regulatory process to ensure workers receive the protection they need while also ensuring that employers have the tools needed to make their workplaces safer.” 

For details about current OSHA standards related to combustible dust as well as fact sheets, explanations and guidelines for preventing explosions, visit the OSHA Web site.

To access the new CSB combustible dust video you can visit the CSB Web site or you can view it on You Tube here.  We think it does a great job of detailing the effects of this preventable workplace hazard and it does it in a captivating way.

– The MSDSonline Compliance Team

Do you have employees that primarily work outdoors?   Is so, know this…outdoor workers are at particular risk of developing skin cancer due to prolonged, often, year-round exposure to ultraviolet rays.  According to the Skin Cancer Foundation, outdoor workers experience twice the amount of nonmelanoma skin cancers (basal cell carcinomas and squamous cell carcinomas ) as indoor workers.

The Laborers’ Health and Safety Fund of North America recognizes this danger and has been building awareness about these dangers to its members for years through sun-safety awareness posters and anecdotal and informational newsletter articles like this one:  “Skin Cancer and Construction Laborers: Something New Under the Sun”.

Those Harmful Rays
The sun emits two types of UV light that we need to be concerned with when it comes to skin protection: UVA and UVB.

Continue reading ‘Outdoor Workers are Twice as Likely to Develop Skin Cancer’

At the recent American Society of Safety Engineers’ (ASSE) annual conference in San Antonio, attendees were treated to speeches delivered from both U.S. Labor Secretary Hilda Solis and Acting Assistant Secretary of Labor for OSHA, Jordan Barab. 

The resounding message being that Department of Labor (DOL) and Occupational Safety and Health Administration (OSHA) enforcement efforts are now, and will continue to be, a high priority.

Fred Hosier, editor for Safety NewsAlert, quoted Solis as saying, “We’re here to help companies provide safe workplaces, but we’ll also crack down on those who don’t,” in his article titled “Secretary Solis: We’re back in the enforcement business.”

Let this be yet another reminder that employers must do more to ensure OSHA compliance, especially those with previous and repeat violations. And, OSHA is not wasting time acting on its claim to be tougher on enforcement.

In fact, Dave Johnson, editor for Industrial Safety & Hygiene News (ISHN), provided insight into the new OSHA agenda as described by Barab, in his article titled “Full Speed Ahead.”

Here are a few excerpts:

• “OSHA will not wait any longer to deal with construction fatalities. SWAT teams of inspectors will sweep over Texas in the coming weeks as part of a new initiative aimed specifically at the Texas construction industry.
• National Emphasis Programs are in the works for enforcement action in the chemical industry and closer review of injury and illness recordkeeping for evidence of under-reporting.
• OSHA’s look into the recordkeeping accuracy of a select number of companies will also include reviewing medical records and safety program policies that might affect injury and illness reporting.  ’I know safety bingo and incentive contests are a very big business, along with the behavioral philosophies that back up many of these programs’ said Barab.  ‘But we are going to take a very close look at incentive programs that award prizes for fewest recorded injuries. That make workers reluctant to report.’   In general, said Barab, ‘we believe the focus should be on engineering out the hazards, on physical conditions, not worker behaviors.”

To read the full article, as well other ASSE recaps from Johnson, including one titled the “10 Tenets of Obama’s OSHA,” click here.

– The MSDSonline Compliance Team

Just back from the American Society of Safety Engineers (ASSE) show in San Antonio.  Great show and thanks to all that stopped by our booth.  A number of people at the show asked me if material safety data sheets (MSDSs) are required for consumer products like Windex or Lysol?

This is a common question we receive; especially now, with companies focusing more on safety and compliance in response to OSHA ramping up its regulatory enforcement efforts.

In general, the OSHA Hazard Communication Standard (HCS) requires businesses to have Material Safety Data Sheets (MSDSs) for all potentially  hazardous chemicals present at a work site.  But the answer more accurately lies in how your employees use these types of products at your workplace.

Essentially, if your employees use consumer chemical products in the same manner that any other consumer would, and as directed by the manufacturer, you probably don’t need to worry about having an MSDS.

On the contrary, however, if your employees use consumer chemical products for purposes that extend beyond that of an average consumer, especially in regards to the frequency and quantity of use, then their exposure rate is higher and you most likely do need to supply MSDSs for those products.

Here are a couple of real-world use scenarios:

Scenario 1: An employee  uses a disinfectant spray to clean off a desk or work area once or twice a day. This squarely falls into the “as directed by the manufacturer,” camp and would constitute a consumer use of that product. Therefore, you would not be required to provide an MSDS.

Scenario 2: The employee uses the same disinfectant spray in a health care setting to continually clean and disinfect numerous surfaces throughout the workday.  In this case, the frequency of use would likely constitute non-consumer use of the product.  Therefore, you would be required to incorporate that product into your HCS program and provide the appropriate MSDS and training for your employees.

When thinking about this, let common sense be your compass.  And, as we tell our customers, better safe than sorry… there’s no penalty for erring on the side of caution.  If you’re unsure, better to simply have the MSDS.

For more information on this topic, we recommend reading the OSHA Letter of Interpretation titled, “Requirements for maintaining material safety data sheets (MSDSs) for consumer art products and office cleaning products.”

We hope this helps.  If you have other questions regarding your MSDS compliance requirements, let us know.

– Glenn Trout, President, MSDSonline

By July 1, some companies that produce, manufacture, process or use certain chemicals must submit Toxics Release Inventory (TRI) reports to the EPA and the states where they operate as part of the Emergency Planning and Community Right-to-Know Act (ECPRA) of 1986.

The quantities and types of chemicals in your inventory determine which form, Form A or Form R, you use to submit your reports.  Each year, the EPA collects and consolidates these reports into a publicly accessible TRI database.

The TRI reports that are due on July 1, 2009, should include hazardous chemical inventory information from 2008, and must comply with the new guidelines that became effective on March 11 when President Barack Obama signed the 2009 Omnibus Appropriations Act. 

The new guidelines essentially call for more detailed reporting and revert back to requirements that were in place prior to December 22, 2006.  According to the EPA, “The change requires that all reports on persistent, bioaccumulative, and toxic (PBT) chemicals be submitted on “Form R,” the more detailed form. For all other chemicals the shorter form, “Form A” may be used only if the “annual reporting amount” is 500 pounds or less and that the chemical was manufactured, processed or otherwise used in an amount not exceeding 1 million pounds during the reporting year.”

Should you be reporting?
Hopefully, you already know whether your company must comply with this federal law, but if  not your not sure, the EPA’s First Time Filers resource page is available to help you make the determination.

If you still have questions, we encourage you to contact a representative in the EPA’s TRI  Program Division.

– The MSDSonline Compliance Team