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Phased Compliance of the Hazard Communication Standard Begins Dec 2013

Posted on Thu, Nov 07, 2013

The Hazard Communication Standard (HCS) is now aligned with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). The first phase for compliance begins on December 1, 2013. At that time, the HCS will require employees to be trained on the new label elements and the updated Safety Data Sheets (SDS) format.

The revised HCS will provide a common and coherent approach to classifying chemicals and communicating hazard information on labels and safety data sheets. The goal is to improve the quality and consistency of hazard information in the workplace, making it safer for workers by providing easily understandable information on appropriate handling and safe use of hazardous chemicals.

Hazard Communication Standard Updates

Two significant changes contained in the 2012 HCS include the revised labeling elements and the standardized format for SDSs, formerly known as the Material Safety Data Sheets (MSDSs). Employees may have already been exposed to the new labels and SDSs on the chemicals in their workplace during the transition phase. However, to ensure workplaces are compliant with the new regulations, it is critical that employees understand the new label and SDS formats.

OSHA requires the following training criteria to be in place prior to December 1, 2013.

Label training must include:

  • Product identifier: The chemical may be identified by the name, code number or batch number. The manufacturer, importer, or distributor can decide the appropriate product identifier. The same product identifier must be both on the label and in Section 1 of the SDS.
  • Signal word: DANGER and WARNING are the two classes utilized on the labeling. The word DANGER is used for the more severe hazards and the word WARNING is used for the less severe hazards.
  • Pictogram: OSHA has designated eight pictograms to be associated with a hazard category.

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  • Hazard statement: The hazard statements are specific to the hazard classification categories, and chemical users should always see the same statement for the same hazards, no matter what the chemical is or who produces it.
  • Precautionary statement: Describes recommended measures that should be taken to minimize or prevent adverse effects resulting from exposure to a hazardous chemical or improper storage or handling.
  • Contact information: Name, address and phone number of the chemical manufacturer, distributor, or importer.
  • Workplace label use: Describes proper storage requirements and first aid procedures
  • Element integration: For chemicals that have multiple hazards, different pictograms are used to identify the various hazards. The employee should expect to see the appropriate pictogram for the corresponding hazard class. When there are similar precautionary statements, the one providing the most protective information will be included on the label.
 

Safety Data Sheet Format

SDS format and information training must cover the following topics:
  • Standardized 16-section format including the section numbers, the headings, and associated information:
    • Section 1: Identification includes product identifier; manufacturer or distributor name, address, phone number; emergency phone number; recommended use; restrictions on use.
    • Section 2: Hazard(s) identification includes all hazards regarding the chemical; required label elements.
    • Section 3: Composition/information on ingredients includes information on chemical ingredients; trade secret claims.
    • Section 4: First-aid measures includes important symptoms/ effects, acute, delayed; required treatment.
    • Section 5: Fire-fighting measures lists suitable extinguishing techniques, equipment; chemical hazards from fire.
    • Section 6: Accidental release measures lists emergency procedures; protective equipment; proper methods of containment and cleanup.
    • Section 7: Handling and storage lists precautions for safe handling and storage, including incompatibilities.
    • Section 8: Exposure controls/personal protection lists OSHA’s Permissible Exposure Limits (PELs); Threshold Limit Values (TLVs); appropriate engineering controls; personal protective equipment (PPE).
    • Section 9: Physical and chemical properties lists the chemical’s characteristics.
    • Section 10: Stability and reactivity lists chemical stability and possibility of hazardous reactions.
    • Section 11: Toxicological information includes routes of exposure; related symptoms, acute and chronic effects; numerical measures of toxicity.
    • Section 12: Ecological information*
    • Section 13: Disposal considerations*
    • Section 14: Transport information*
    • Section 15: Regulatory information*
    • Section 16: Other information, includes the date of preparation or last revision 

*Note: Since other Agencies regulate this information, OSHA will not be enforcing Sections 12 through 15 (29 CFR 1910.1200(g)(2)).

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Tags: HAZCOM, Training and Exercises, Emergency Management Program, Safety, Workplace Safety, Chemical Industry

Maximizing Hazardous Material Railway Safety Through Planning Efforts

Posted on Mon, Sep 16, 2013

On August 27/28, 2013, representatives from the Department of Transportation’s Pipeline and Hazardous Materials Safety Administration (PHMSA) and the Federal Railroad Administration (FRA) met with stakeholders to initiate a comprehensive review of operational factors that affect the safety of the transportation of hazardous materials by railway.

“We know we can’t wait. The volume of crude oil moving by rail has quadrupled in less than a decade,” said Cynthia Quarterman, PHMSA Administrator. “As greater quantities of HAZMAT are transported by rail, the risks increase, and we have to make sure our regulations and practices keep pace with the market and new technology. We have to identify gaps and close them.”

The late August meeting was used to pinpoint potential reforms, including tougher regulations, and railroad and personnel controls of trains carrying large volumes of crude oil, ethanol and other hazardous cargo. According to the Oil and Gas Financial Journal, total petroleum-based shipments increased 46% from 2011 to 2012. Railroads are used to haul petroleum-based products from locations that such as North Dakota’s Bakken shale fields, where pipelines are lacking. Because of the statistics and a recent accident, there is a heightened awareness for new inspections and oil samplings. This effort, dubbed the “Bakken blitz” by some regulators puts a spotlight on concerns about improper classification of crude oil hazards, the use of unsuitable or unsafe tank cars, security issues, and best practices.

The review comes on the heels of the July 6th Lac-Megantic, Quebec railcar disaster that killed 47 people, forced evacuation of 2,000, and destroyed the town center. The incident was sparked when an unmanned train with a boxcar and 63 loaded tank cars derailed and exploded in the core of town.

FRA’s inspection data since January 2010 shows significant non-compliance with FRA’s securement regulations, 49 CFR 232.103(n), with nearly 4,950 recorded defects in that time. Although railcar accidents have an overall downward trend, accidents associated with “securement” problems rose 31% in the last fiscal year. This data, coupled with the significant increase in hazardous crude by rail transportation, reveals key gaps in railroad and regulatory efforts.

In early August, the FRA and PHMSA issued emergency orders on securing unattended and managing stationary trains.  While train accidents involving hazardous materials are caused by a variety of factors, nearly one-half of all accidents are related to railroad human factors or equipment defects. Under current DOT regulations, all freight railroads are required to develop and implement risk assessments and security plans in order to transport any hazardous material, including a plan to prevent unauthorized access in rail yards, facilities and trains carrying hazardous materials. The emergency order highlights the regulation and requires the following:

  • Railroads are prohibited from leaving trains or vehicles that are transporting hazardous materials unattended unless the railroad complies with a plan that identifies the specific locations and circumstances for which it is safe and suitable for leaving such trains or vehicles unattended.
  • Railroads must develop specific processes for employees responsible for securing any unattended train or vehicles transporting hazardous materials.
  • Railroads must review, verify, and adjust, as necessary, existing requirements and instructions related to the number of hand brakes to be set on unattended trains and vehicles and that railroads review and adjust, as necessary, the procedures for verifying that the number of hand brakes is sufficient to hold the train or vehicle with the air brakes released.
  • Railroads must implement operating rules and practices requiring the job briefing of securement among crewmembers and other involved railroad employees before engaging in any job that will impact or require the securement of any train or vehicle in the course of the work being performed.
  • Railroads must develop procedures to ensure that a qualified railroad employee inspects all equipment that any emergency responder has been on, under, or between for proper securement before the rail equipment or train is left unattended.
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Tags: HAZCOM, PHMSA, Training and Exercises, Regulatory Compliance, Safety

Hazardous Material Incident Management

Posted on Mon, May 06, 2013

Hazardous materials become most hazardous when they are released. The potential risks associated with hazardous material releases heighten the need for risk-based decision making. As a result, hazardous material incident management should reflect site specific planning, training, and exercises that minimize hazardous material impacts and restrict potential chaos.

  • Response plans should clearly dictate processes and procedures that minimize hazardous material impacts.
  • Training must be aligned with response roles and responsibilities, facility operations, and regulatory requirements. (see Hazard Communication Standard - 29 CFR1910.1200)
  • Exercises should include hazardous material release scenarios that allow response team members to collaborate and communicate assigned roles, responsibilities, and required actions in response to one or more site specific scenarios.

“Hazardous Materials” is a general term intended to mean hazardous substances, pollutants, and contaminants as defined by the National Oil and Hazardous Substances Pollution Contingency Plan (NCP). The term includes blood borne pathogens and infectious disease as defined by OSHA's Blood borne Pathogens Standard (29 CFR 1910.1030).

The potential for harm to individuals, the environment, or the facility may be escalated due to the release of certain hazardous materials. However, expedient and safe cleanup operations can minimize exposures and limit the impact of an incident. Hazardous substance releases must be removed, contained, incinerated, neutralized, or stabilized with the ultimate goal of making the site safer for people or the environment.

Identifying the potential threats and probable incident scenarios enables proper pre-planning. Response procedures and processes can be incorporated into the site-specific plans to proactively facilitate corrective actions in the event of a hazardous release. The following hazardous material incident management concepts should be considered and incorporated in planning, training, and exercising a response:

  • Proper PPE for employees, contractors, and responders
  • Specific waste handling procedures and, if applicable, appropriate contractors
  • Disposal plan in accordance with any federal, state, and/or local regulations
  • Facility-specific disposal locations for different types of materials
  • Continuous tracking of hazardous materials quantities to better estimate amount of waste generated
  • Methods and procedures for waste collection, segregation, storage, transportation, and proper disposal
  • Regulatory review of applicable laws to ensure compliance and appropriate permitting
  • Documentation of all waste handling and disposal activities

From the onset of an incident involving hazardous materials, incident managers should establish specific, measurable objectives for functional response activities. Incident Action Plans (IAPs) are used to guide hazardous response activities and provide a concise means of capturing and communicating the incident manager’s priorities, objectives, strategies, protocol, and tactics  for both operational and support activities.

The incident manager must manage all resources, both internal and external. Unless, a facility has a dedicated, trained, and certified response team, external responders should be identified for hazardous material response operations support. However, the incident manager must maintain clear communication of response objectives as to eliminate confusion caused by multiple, conflicting directives and authorities.

The level of detail required in IAPs  varies with each scenario. However, plans should facilitate the sharing of critical incident status information. Because hazardous material incident parameters may continually evolve, IAPs must be revised on a regular basis (at least once per operational period) to maintain consistent, up-to-date guidance for incoming responders or management.

At each phase of a response, the incident manager should perform critical assessments and specify clear operational objectives to responsible parties, eliminating potential confusion caused by multiple, conflicting directives and authorities. Through proper preparedness planning and cleanup and disposal procedures, hazardous material management planning can limit environmental liability, and as an effect, minimize additional immediate and long-term financial burdens.

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Tags: HAZCOM, ICS, Emergency Management Program, HAZWOPER

Technology and Emergency Response

Posted on Thu, Jun 28, 2012

Contributed by Terry Strahan; GIS Manager, Houston Operations at Morris P. Hebert, Inc.

As the Emergency Response industry has grown over the years, so has the technology that supports it. In order to record an emergency response event, technical support consisted of paper documentation translated from illegible field notes. Visual recorded documentation included paper maps detailing the location and path of the spill or release. Occasionally, these documents were used for spill response training, but they typically remained stagnant and inoperative.

As computers and electronic documentation became more commonplace, the ability to digitally record events became easier, more efficient, and viable. Technologies and computer software allowed for systematic formats to be accepted across industries, mainstreaming methodology and digital response tactics. The ease of Internet attainability enabled processes, such as the Incident Command System (ICS), to be accessible and incorporated in every emergency response.

Additionally, the average mobile phone has components such as high-resolution cameras and email capability, making digital communications updates plausible from nearly any location. Advanced technology, such as GPS tracking, allows for real-time positional updates at any given time throughout an event. Satellite imagery can provide detailed visual images of the status of a location, and before and after comparison photos to aid in the documentation of the effects of the incident. Free emergency response software is enabling responders to accurately and preemptively respond to escalating emergencies. There are a large number of resources available that can be accessed from the Internet for any incident. The National Oceanic and Atmospheric Administration (NOAA) software listed below is available to responders:

In today’s highly technical environment, gathering data from multiple sources, organizing it systematically, displaying information for logistical value, and storing response data can be overwhelming. By embracing and successfully managing continual advances in technology, emergency managers will be able to create a sustainable and proactive emergency management program. However, logistical hurdles and successful interoperability will continue to be an issue as the industry utilizes advancing technology in different capacities and formats.

Terry Strahan is the GIS Manager – Houston Operations at Morris P. Hebert, Inc. Terry has 20 years’ experience applying GIS technology to solving real-world problems in various fields, including Pipeline GIS Management and Environmental and Emergency Response and Gas, Electric and Landbase Data Management. He can be reach at 713-219-1470 ext. 4419.

For an understanding of the necessary elements in creating an effective fire pre plan, download our Fire Pre Planning Guide.

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Tags: HAZCOM, Resiliency, Incident Management, Training and Exercises, Disaster Response, Notification Systems

Hazardous Materials Response Team Training Requirements

Posted on Mon, Jan 30, 2012

A Hazardous Materials (HAZMAT) Response team is comprised of hazardous material experts who specialize in detecting, containing, and removing any release or potential release of hazardous substances in order to control or stabilize an incident. According to the Hazardous Waste Operations and Emergency Response Standard (HAZWOPER), a HAZMAT team “is not a fire brigade, nor is a typical fire brigade termed a HAZMAT team. However, a HAZMAT team is often a separate component of a fire brigade or fire department.”

The acronym  HAZMAT refers to any substance (gas, liquid or solid) capable of creating harm to people, the environment, or property. It is often used when discussing the production, transport, use, disposal, cleanup, or emergency response of hazardous materials.

HAZWOPER is one of the training components of a HAZMAT team. The intent of the HAZWOPER standard is to protect workers engaged in "Emergency response operations for releases of, or substantial threats of releases of, hazardous substances without regard to the location of the hazard." (29 CFR 1910.120(a)(1)(v)).

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According to the HAZMAT Team Planning Guide of the EPA’s Office of Superfund Remediation and Technology Innovation, a HAZMAT Team should be trained to the “Hazardous Materials Technician” level defined by NFPA Standard 472 and HAZWOPER 29 CFR 1910.120.

HAZMAT Training Regulations

HAZMAT employees, that may or may not be part of a HAZMAT team, must be trained, at a minimum, in accordance with:

Records need to be maintained for all employees that have been, or will be trained before handling hazardous materials, in accordance with the training requirements set forth in 49 CFR §172.704 and 172.602, and 29 CFR §1910.120 and 1910.1200.

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Tags: HAZCOM, PHMSA, OSHA HAZWOPER, Training and Exercises, Emergency Management Program, Disaster Recovery, HAZWOPER, OSHA HAZWOPER standard training, Fire Department HAZWOPER training