Newsletters

The Safety Net is a newsletter published by NETC. The following articles were from the Spring 2004 edition.

From the President....

I was sitting in a conference one day listening to the speaker, borderline day-dreaming (about all the work I was missing in the office), when the speaker caught my ear when he said, “managements primary focus is to turn risk into profit.” I was stunned. He was actually saying that as long as product got out profits were on the rise. He was implying that obstacles, ‘safety’ related issues being one of them, cut into the bottom line. Now, I too am a business man and I can understand the underlying rationale to this, but it left me stunned none-the-less that this philosophy still prevails, and is practiced in many large companies.

Then, during another workshop, I hear a speaker talking in proverbs. I thought, these are very apropos to the last conference I attended, and our work environment in general. For instance, ‘You can’t judge a book by it’s cover.’ Well, we’ve all heard that one before, but you know, in business, we make those rash first impressions all the time. A company or a product are deemed worthy by the first impression. I’d like to think we are making some very good, and lasting, first impressions.

Then there was ‘You can’t shake a hand with a closed fist.’ and lastly, ‘there can’t be a rainbow without rain.’ I think these two work off each other. We all have to learn to be more trusting and open to suggestions and assistance. No-one today can go-it alone. Outsourcing, sub-contracting, etc. are all ways to accomplish a task—while taking all the credit of course. What matters ultimately is that work gets done. If there is hesitation and trepidation in a product or service, then often it is simply put on the back burner. The unknowns can be difficult to deal with, and many companies do not openly embrace change. We are now a world full of change. We have to re-think our approaches and philosophies. We have to review our plans and procedures more thoroughly and regularly. We have to openly accept assistance and change, to think outside the box.

I’d like to think that we at NETC are part of the solutions and not part of the hesitation. We have matched every need of a client with a solution. Yes on occasion we have outsourced, but mostly we have performed all our work in-house. That is what has grown our business. To that end, I’d like to introduce a few more services and associated staff. Fleet safety and driving related incidents have become a major factor for many companies. We are fortunate to be able to service these needs with Joe Sparaco, a recently retired DMV truck squad inspector. We are now able to perform fleet inspections and provide CDL training and defensive driving programs.

A specialty in it’s own, high voltage electrical, is now able to be covered by Ed LaFrance, a recently retired NU employee and trainer.  Ed is also well versed in both the general industry and construction standards, complimenting our current staff’s capabilities and workload. And lastly, with the new DOT HazMat Security requirements now in affect, we have elicited the services of Charlie Zieminski, a recently retired DEP HazMat Response Team Supervisor, who will also add to the capabilities for the many requests for HazMat and HazWoper training we receive. Add to this the addition of our Human Resources services last year, and we have positioned ourselves very nicely to accommodate and successfully provide most all services a company could want and need. If you haven’t looked at all of our services and capabilities lately, please do so. You will find we can do more for you now then we could a couple of years ago.

If you find an area that we have not listed, ask us anyway, we may still be able to provide the service.

Please visit our website, though we are in process of updating it to reflect all our changes. As times and needs change, let’s all work together to the common goal—a Safe and Prosperous work environment.

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By: David Lundquist
Director of Training

Although Emergency Response Planning has been on most facilities and regulators minds of late, the requirements for this planning have been in Standards and Codes for a long time. Here are some highlights.

Occupational Safety and Health Administration requires Emergency Action Plans (1910.38) to cover fire reporting, evacuation procedures, critical equipment shut down, personal accounting, and employee training. 1910.39 requires the often overlooked fire prevention plan. The response plan must also include other potential emergencies that may occur. Predictable emergencies are often categorized as internal and external.

External events to consider include, chemical spill, weather related emergencies (flood, hurricanes, high wind, tornadoes, snow/ice storms), civil unrest, and workplace violence. External events may require a sheltering in place tactic until the event allows individuals to leave. Your plan needs to include how and where this tactic will be implemented.

Internal events besides fire include, mail/phone threats (remember anthrax), power loss, chemical spill, medical emergencies, and workplace violence.

The OSHA HAZWOPER Standard (1910.120q) requires a written emergency plan as well as the Confined Space Standard requiring emergency response and planning. If you employ elevating lifts and fall protection equipment, a rescue plan is also required.

Part of planning includes maintenance of emergency equipment and egress routes. Backup generators have specific testing requirements depending on the type of facility they are installed in. Egress lighting, exit lighting, fire extinguishers, sprinklers, hoods, fire doors and barriers, and alarm systems also have testing and maintenance requirements. The National Fire Protection Association (NFPA) set code for this equipment which is adopted by the State and local authorities for enforcement.

A Command Structure should be clearly defined. The Incident Commander for the workplace should be identified (with alternatives).

Develop your structure to accommodate a large scale emergency, the system can be contracted to handle smaller events. Your workplace Incident Commander should be familiar with and a component of the emergency responders Incident Command System. Establish an Incident Command Post within the facility from where emergency operations can be managed. An event may cause the total evacuation of a facility, so consider the establishment of an off site or portable Incident Command Post where you can direct operations from a safe area. Preplanning of events with the first responders is key to having a workable plan. If chemical spills/releases are a potential, remember that your spill contractor should develop a pre-event plan as well as part of the response team.

A special note on medical emergencies. OSHA has changed their interpretation of a response to medical emergencies. Note the letter of interpretation dated 4/18/02 stating a 3 to 4 minute response time for a trained person in first aid (read CPR as well) to administer care. Most facilities cannot have that response time from outside responders so an in-house response is necessary.

Also of note is the recent support of OSHA to encourage Automatic External Defibrillators (AED) into medical responses. This encouragement also comes form the American Red Cross, American Heart Association, the State for Connecticut and other organizations. The facility placing an AED should also implement management programs for these devices. This would include written program management, maintenance requirements, ancillary equipment for the unit, medical control oversight, quality assurance program, and other requirements. A review of liability issues with AEDs points to an interesting trend. It is the absence of the AED that has brought lawsuits. It is estimated that in 2000, 40,000 AEDs were sold with a doubling every 18 months. The question is becoming why you do not have an AED!?

Recovery is often an afterthought. Recovery needs to include smoke/fire/water restoration, structural restoration, product safety determination, data recovery and employee retention.

As you may have surmised, emergency planning is a necessary and often complex issue. The key is in both in the written plan and with employees training to this plan. NETC is here to assist you in this critical component of your Safety Management Plan.

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How does a Material Safety Data Sheet travel through a company

By: Andrea Greene, MBA, IH
Senior Safety Specialist

What do I do with a Material Safety Data Sheet that comes in with the chemical that I just received through the Shipping & Receiving Department? What do I do if a new chemical is received into the company. What if a new products are being researched new chemicals must be investigated?

Clients have asked all of these questions and more when it comes to handling Material Safety Data Sheets, MSDSs. MSDS handling and maintaining the annual chemical inventory can be quite labor intensive. All of these questions tie in with the OSHA Hazard Communication Standard, 29 CFR 1910.1200. New employees must be trained to the hazards in the work environment prior to working in that environment. One way this may be accomplished is through an understanding of the MSDS and labeling requirements.

Let’s take a step back. What is an MSDS. An MSDS is a detailed sheet of information for a hazardous chemical providing the potential hazardous effects, its physical and chemical properties, and recommendations for appropriate protective measures. This information is required of chemical manufacturers, importers, or employers by the OSHA Hazard Communication Standard, 1910.1200, to supply to users this information.

MSDSs are important because they give the necessary information to work safely with that chemical. All employees must know how to read and understand an MSDS. A training class alone is not enough. The employees must demonstrate that they know what an MSDS is and how to read it. The OSHA Hazard Communication Standard is performance based and requires that employees demonstrate their understanding.

Companies take various approaches in handling the MSDS system at their facilities. Having a department specific book located so that all employees in that department can access it seems to work fine as long as someone in that department is responsible for maintaining it. When a new MSDSs is introduced the individual updates the book and the chemical inventory list and shares it with their fellow co-workers.

Depending on company size, a master set of books centrally located may be the way to go. The individual responsible may have a direct relationship with the Purchasing department or the Shipping & Receiving department. These two departments are usually intricately involved in the MSDS process because of their overall company responsibility.

Some companies choose to contract with an MSDS service that allows employees computer access to updated MSDS. This is a great process as long as a few things are considered.

All employees must have access to a computer and know how to navigate the system to find an MSDS they are looking for.

Now that we have reviewed what an MSDS is and how some companies give their employees access to them, let’s review the path the MSDS takes through a company to get in the system for employee accessibility.

The MSDS enters the company with the product. It must get into the computer system, the central file or the department specific book and on the chemical inventory list if it is new.

Product that contains a hazardous material is ordered. Purchasing has a special note on the order requesting an MSDS.

Product comes in through Shipping & Receiving with the MSDS.

Shipping & Receiving forwards the MSDS to the Safety Department and/or the department that uses the material. The MSDS is reviewed for accuracy and completeness, hazardous ingredients, and physical & health hazards and the recommended appropriate protective measures of that new material. A visit to the department by the safety professional may be necessary to evaluate the proper safe use of the material, engineering controls and the necessary Personal Protective Equipment, PPE.

The company files the original MSDS in the central file online or in the department specific books.

If it is a new chemical the product name is added to the master chemical inventory list.

If the MSDS is updated it must be reviewed with the previous MSDS, if everything is the same, ingredient wise, except for the date, the old one is discarded and the revised MSDS is placed in the book. If the ingredients are different, the old MSDS is archived, with “discontinued” written across the top with the date, and placed in the back of the book as an archived MSDS.

The company revises the chemical inventory list and writes “discontinued” along with the date on the chemical inventory list. If it is a new product, the name is added to the list.

The Master Chemical Inventory list must be reviewed annually as required by the OSHA Hazard Communication Standard, 1910.1200.

FAQ’s

What if the product is received directly by the department?

The department forwards a copy of the MSDS to the Safety professional for review. The MSDS is placed in the Master file.

The company must contact the manufacturer and request an MSDS. A note of the request should be kept until the MSDS is received. The product must not be used until an MSDS is received and reviewed.

An MSDS must be available for all employees to access. The area that dispenses the chemical must have an MSDS if there is an exposure potential during dispensing.

If you have any questions regarding the review, implementation or training of your Hazard Communication program please contact one of our Safety Specialists.

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Topics / Areas of Interest

• From the ‘pat on the back’ section, NETC’s President, Bob Ziegler, was recently elected as President of the American Society of Safety Engineer’s (ASSE) CT River Valley Chapter covering most of CT and Western, Mass.

• If you’re looking for an OSHA 10-hour General Industry Outreach course, NETC will be providing one for the Middlesex County Chamber of Commerce on July 15 and 16 in Middletown. Feel free to call us or the Chamber for registration details.

• Are you aware of OSHA’s new targeted inspection initiative? Do you know if you are on the radar screen? This year OSHA is using the new DART rate. That is, sites that have reported 15 or more injuries for every 100 full-time workers can potentially expect a visit from OSHA. You may also be on the radar, for either a primary or secondary inspection list, if you have an LWDII of 10 or higher.

This has caused several of our clients to develop an “OSHA’s at our door and what do we do?” policy. Do you have one?

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