The TopTen OSHA Violations Before Christmas. On the Ninth Day

Santa received a notice of violation(1910.1200) Hazard Communication #2 on OSHA’s TopTen violations for 2019.  (Still #2 in 2023 – not good for employees or people).

Santa openly admits that he’s been so busy running the family business that he has not always kept up with changes in regulations and was very surprised to find out that his old MSDS book was incredibly out of date.  Back in 2012, the U.S. joined the Globally Harmonized System (GHS) which makes it easier for companies to classify, label, and produce data sheets for chemicals by complying with one system, across the world.  As of June 1, 2016, it became mandatory for all U.S. companies under the Hazard Communication Standard (HCS) or as it’s also referred to HazCom.

If you work where chemicals are either produced, stored, shipped, transported, or used you may face several health hazards including irritation of skin, eyes, or lungs, and physical hazards like flammability or corrosion.  That is why training on HCS and understanding the processes and procedures that you must use in handling, labeling, and shipping, to minimize any form of exposure to chemicals during transport and storage.  All of the information is included in the Safety Data Sheets (SDS) which should be located at every warehouse or facility where it is accessible by ALL.  Anyone who is involved, the truck driver loading chemicals, the UPS driver delivering, the dock forklift driver, the order picker, the clerk at the cheap retail store.  You all should have access to the SDS so you know what you are dealing with, what protective measures you must use, and how to handle in the case of a spill or leak.  The main change you will find between the old MSDS and the current SDS is the order the information must appear:

1. Identification
2. Hazard(s) identification
3. Composition/information on ingredients
4. First-aid measures
5. Fire-fighting measures
6. Accidental release measures
7. Handling and storage
8. Exposure controls/personal protection
9. Physical and chemical properties
10. Stability and reactivity
11. Toxicological information
12. Ecological information
13. Disposal considerations
14. Transport information
15. Regulatory information
16. Other information

Santa’s crew are busy updating their SDS and chemical handling procedures as well as, yep, more training. It feels like we cleared a pretty big hurdle but the biggest is yet to come.