MSDSonline Environmental, Health & Safety Blog

The Department of Labor (DOL) and the Occupational Safety and Health Administration (OSHA) recently revised the personal protective equipment (PPE) standards concerning requirements for eye- and face protective devices, and head and foot protection for general industry, shipyard employment, longshoring and marine terminals. The final rule, which becomes effective Oct. 9, 2009, “Is another step in OSHA’s efforts to update or remove references to outdated national consensus and industry standards,” said Assistant Secretary of Labor for OSHA Jordan Barab.

According to the Federal Register notice, one of the changes includes “deleting editions of the national consensus standards that PPE must meet if purchased before a specified date.” The revisions to the standard require employers to follow guidelines from the most recent editions of applicable national consensus standards, standards set by groups like the American National Standards Institute (ANSI). The changes give the regulation sustainability, keeping it current as consensus standards evolve through time, and they also simplify compliance and enforcement.

“Workers exposed to occupational hazards requiring head, foot, or eye and face protection will now be provided protection based on a standard that reflects state-of-the-art technology and materials,” said Barab.

So, what does this mean for you if you’re the employer? Well, in an interview with EHS Today, from the article titled “OSHA Updates PPE Standards to Reference Consensus Standards,” the International Safety Equipment Association (ISEA) President Daniel K. Shipp summed it up nicely, he said, “It’s no great change. Companies will continue to use the same eye and face protection and head protection equipment they had been using that meets the current standard.” Shipp also concurred that the proposed changes will help to keep the regulation relevant in the future. He said, “We think the way that OSHA is proposing to update the standard will make it easier for the standard to stay up to date now with the state-of-the-art [advances] as new consensus standards are published.”

Visit OSHA’s Web site to read the complete new release or click here to read the final rule in the Federal Register.

If you’re considering purchasing new PPE, you can find a variety of products from trusted suppliers at MSDSonline’s Safety Mall.

– The MSDSonline Compliance Team

President Barack Obama recently announced his intention to nominate David Michaels, PhD, MPH, as assistant secretary for Occupational Safety and Health Administration (OSHA).  A permanent administrator hasn’t been in place since the resignation of Edwin Foulke Jr. in November 2008.   View the OSHA org. chart.

Michaels is an epidemiologist and research professor at the Department of Environmental and Occupational Health at George Washington University School of Public Health and Health Services.  According to a White House statement, “He has conducted numerous studies of the health effects of occupational exposure to toxic chemicals, including asbestos, metals and solvents, and has written extensively on science and regulatory policy.”

Continue reading ‘Obama Announces Intention to Nominate Dr. David Michaels to Oversee OSHA’

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