The final GHS (Global Harmonization System) deadline is now long past. OSHA’s alignment of the HazCom (Hazardous Communication Standard) to GHS has provided a wakeup call to millions of companies across the U.S. to do a better job with their HazCom programs, especially when it comes to training. Unfortunately, not all Oklahoma municipalities have embraced this new standard. HazCom violations remain the number 2 violation on OSHA’s top 10 list of violations.
This article provides four steps employers can take to ensure employees understand the chemical hazards present in their work environments and to comply with GHS updates to HazCom.
Step One: Build a Training Program Focused on Usefulness
While OSHA, and here in Oklahoma, the Department of Labor’s PEOSH division don’t specify how to do training, they do state that training must be effective. Employees must carry their learning into the workplace and be able to put it to use. HazCom has two key components: 1) providing employees with a basic understanding of the HazCom standard (OMAG works with many of our cities and towns to provide this understanding.); and 2) training employees on the specific hazards of the chemicals to which they are exposed and providing protection through administrative controls, engineering controls, and personal protective equipment (These are the responsibility of the employer and its departmental supervisors.)
In the past, HazCom with GHS focused on training workers to understand the new SDS (safety data sheets) and labeling formats accompanied with GHS adoption. However, many employers lacked a basic level of understanding about HazCom (municipalities included), making it difficult for them to comprehend and address the changes brought by the new GHS alignment. As a result, workers were never adequately trained on HazCom in the first place or had been trained so long ago that what they learned had been forgotten. It is critical that employers continue to emphasize basic HazCom training, which now includes GHS information to ensure employees are able to use the information in their day-to-day activities.
The second component of an effective HazCom training program focuses on the individual hazards employees face. Departmental supervisors must train their employees on the specific chemicals used and their hazards. The key here is to provide employees with a deeper understanding of the dangers and emergency situations they face, and counter them by following written policies and procedures.
Step Two: Deliver Training So Employees Can Understand It
When OSHA first published the HazCom Standard in 1983, it followed the concept of the employee’s “right to know” about the hazards to which they might be exposed. A primary driver for OSHA’s adoption of the GHS has been the desire to improve employee comprehension of critical chemical safety information.
With GHS, OSHA is indicating it’s not enough for workers to just know about the hazards; instead they have the “right to understand” those hazards and know what related safety precautions to take.
The pre-GHS employee “right to know” concept often translated into giving workers access to MSDSs and labels and making sure they were aware of the hazards that existed from chemicals in their work environment. This approach didn’t always translate to employees understanding the safety and health information being conveyed on the MSDS and labels. GHS adoption helped solve this issue by bringing harmonization and consistency to the structure of the safety data sheets (formerly MSDS, now SDS) and labels. Use of standardized hazard communication elements, such as pictograms, make it possible for workers to more easily understand the hazards associated with chemicals workers use or are around. This simplified approach to communicating hazard information makes it possible to protect workers of all backgrounds. For instance, pictograms make it easier for illiterate and non-English speaking employees to understand the nature of a product’s hazardous properties.
The “right to understand” concept compliments OSHA’s rule on employee HazCom training – that it must be presented in a manner all employees can comprehend and retain. When applied to HazCom training, this means that employees who work with or around hazardous chemicals must receive training in a language they can understand, even if the documents (SDSs and labels) are only required in English.
Step Three: Provide Easy Access to SDSs
A key aspect of HazCom training is to make sure employees know how to get direct access to Safety Data Sheets (SDSs) and other hazardous chemical information. Some employers are using electronic solutions to help employees retrieve information from their inventory of SDSs. If this is true with your municipality, it is incumbent on you to make sure employees are made aware of the system, how to access it, and how to use it. Without that access, in the event of an emergency, even an employee that has received adequate training on labels and SDSs will still be at risk should a chemical event occur that requires quick action. For that reason, many employers are taking advantage of technological advancements and using mobile solutions to put SDSs in the hands of their employees. The best Environmental, Health, and Safety (EHS) software solutions today leverage the cloud to make critical chemical safety information available anywhere, any time. One problem with using technology solutions, however, is many municipalities don’t have the financial resources to provide such innovative techniques. Therefore, keeping updated SDSs available to workers in a binder within the work environment of the workers may still be the best way to provide them with quick environmental, safety, and health information when a chemical event occurs. These binders can be kept in trucks, shops, and offices - wherever the employee has access to them.
Step Four: Keep It Consistent
While OSHA and OK DOL-PEOSH don’t require employee training to be performed in specific intervals of time, regular training (at least annually) is a best practice to help ensure your employees better retain HazCom with GHS information. Other instances for training may include newly hired employees, temporary employees, visiting contract workers, or when a new chemical is introduced to a department. This helps ensure that employees who might work with or around a hazardous chemical understand its potential hazards.
It is vitally important to view HazCom and GHS training as an ongoing obligation. Over my years of travel around the state performing inspections and trainings for OMAG shareholders (cities and towns), I have personally noted frequent inadequacies with regard to HazCom and GHS training and information resources. The safety of your employees must be a priority in your day-to-day operations for their sake, for your municipality’s sake, and for the health and welfare of the state of Oklahoma.
Are you a Police Chief, or an officer responsible for developing policies for your law enforcement agency? If so, it’s time to spring into action and take advantage of another OMAG Value Added Service. We’ve reached the two-year mark since the Title 11 policy mandate went into effect. As of January 1, 2016, every municipal police agency has been required to have written policies which address critical safety and liability issues which officers are confronted with on a regular basis.
The Oklahoma Municipal Assurance Group has assisted our law enforcement agencies with policy development for over a decade now. Two years ago, OMAG took policy development assistance to the next level by partnering with Lexipol. Have you considered Lexipol and just need assistance with getting started? Are you stuck in the middle and just can’t find the time? Your OMAG Law Enforcement Specialist can come alongside you and assist in the development and implementation of your new policy manual.
If you would like to learn more about Lexipol, the country’s premier policy development tool for law enforcement, contact Kevin McCullough at 405-657-1408. You can also email Kevin at email@example.com.
In route to repair a water main leak, a newly hired backhoe operator drifts to the edge of the road and slams into the back of a car, injuring a mother waiting for her kids to get out of school.
The young operator is near tears, the supervisor overflows with accusations, another worker slams their hand in a door. Everything is confusion.
Eventually, when the mess is sorted out, the safety coordinator will investigate the accident. He learns the steering and brakes on the backhoe were bad. Someone will get blamed, and the equipment issues will be repaired. The safety coordinator, overwhelmed by the demands on his time, will go off to fight the next fire.
This is not an extreme case. Accidents are handled like this every day. At best, this type of approach deals with symptoms and not the actual or root cause. In a few days, another piece of equipment, perhaps a manifold at the water plant, will fail. Someone else will be injured or maybe killed. The plant will shut down for a while and the damage will be repaired, but the risks will remain.
To identify and control risk, an accident investigation must get to root causes. Why was a new employee operating the backhoe? How much training had they received? Why wasn’t the faulty equipment taken out of service immediately? Why wasn’t it clearly tagged out of service? Reported? Was the equipment regularly inspected? Is there a preventative maintenance program? What must be changed in maintenance, training or safety to keep this from happening again?
Accident investigation should be a critical part of overall safety program strategy. Done correctly, it can enhance safety and reduce costs. All accident investigations should be conducted in a professional manner and should always focus on causes: the why's. Using the 5 “Why’s” of a typical Root Cause Analysis allows the employer to discover the underlying or systemic, rather than the generalized or immediate, causes of an accident. Correcting only immediate cause may eliminate a symptom of the problem, but not the problem itself. The more incidents that are reported, the more problems can be investigated and resolved. The more problems solved, the safer and more cost effective the operation will be.
The fact is that the only difference between a near miss and a catastrophe may be chance. That's why every potential problem should be resolved.
For more information on conducting accident investigations, and developing a Root Cause Analysis please view “Incident [Accident] Investigations: A Guide for Employers” https://www.osha.gov/dte/IncInvGuide4Empl_Dec2015.pdf
Accidents and injuries are not a cost of doing business; all are preventable!
By 2020, one in four American workers will be over 55, according the U.S. Bureau of Labor Statistics (BLS). To raise awareness of the health and safety issues affecting older workers, the National Institute for Occupational Safety and Health (NIOSH) developed a web page with information to help employers match the needs of an aging workforce (https://www.cdc.gov/niosh/topics/productiveaging/).
According to NIOSH, older workers tend to experience fewer workplace injuries than their younger colleagues, perhaps due to their experience and their lowered likelihood to take risks. However, when older workers are injured the health care costs are higher and the recuperation period is longer. In addition, statistically there has been a dramatic jump in fatalities around age 60.
The following are some of NIOSH’s tips for keeping older workers safe:
Match Tasks to Abilities: Everyone benefits when workers are able to perform their jobs well. If older workers have physical limitations, assign them to tasks that do not require them to strain beyond their ability. Consider using self-paced work and splitting physically strenuous work up with self-directed rest breaks.
Manage Hazards: When assessing hazards in the workplace, make sure to consider whether conditions that might not be hazardous for younger employees could pose a problem for older workers. For example, a noisy work environment might not bother a 25-year-old (though you should still assess noise levels and provide hearing protection if necessary), but an older worker in the same environment might have difficulty hearing coworkers to communicate about important safety issues.
Consider Ergonomics: Provide and design work environments that address ergonomic concerns. Examples include better illumination, screens and surfaces with a minimum amount of glare and ergonomic sit/stand workstations. In addition, the use of ergonomically designed tools for high frequency task should also be taken into account.
Invest in Training: It should be a priority to build work skills at all age levels. Older and younger workers can learn from each other, with older works serving as mentors and sharing their experience, and younger workers helping older workers adapt to new technologies.
Manage Return to Work Process: Statistics and anecdotal evidence have shown that employees recover more quickly from injury and illness when they’re at work. Proactively managing reasonable accommodations and the return-to-work process, is a win-win situation.
Train Supervisors: Train specifically on the issues associated with an aging workforce and the best way to address them.