Sources have been telling me that both OSHA & DOT’S PHMSA (Pipeline and Hazardous Materials Safety Administration) are actively conducting on-site inspections for violations.  OSHA has released it Site Specific Targeting Plan, while PHMSA is

The U.S. Department of Labor’s Occupational Safety and Health Administration in May announced that it would focus on roughly 3,800 high-hazard work sites for unannounced comprehensive safety inspections in 2008. The visits will be part of OSHA’s 2008 site-specific targeting plan, according to a news release. OSHA has used such plans for more than a decade, honing in on different work sites based on injury and illness data.

“This program emphasizes to employers the importance of our enforcement efforts in ensuring safe working conditions for employees,” said Edwin G. Foulke Jr., assistant secretary of labor for OSHA, in a news release.  The work sites that will be included in this year’s targeting plan are those that have reported 11 or more injuries or illnesses resulting in days away from work, restricted work activity, or job transfers for every 100 full-time employees.

OSHA also will randomly select and inspect about 175 workplaces with 100 or more employees that reported low injury and illness rates for the purpose of reviewing how well they actually comply with OSHA requirements, the release said.  

PHMSA has been very active in enforcement of hazmat (49CFR parts 100-185) regulations concerning the shipment of hazardous materials in commerce.  DOT’s current maximum civil penalty is $50,000 per violation.  Considering a shipment may have multiple vioaltions this amount can increase rapidly.  The number 1 fined incident is lack of current training.

So you better be good and you better be nice or OSHA/PHMSA might fine you twice.

You know The Compliance Resource Center does not often write about products, but there are times when something comes along which our readers might find interesting and/or useful.  Here is one of those products. 

If you ship hazardous materials you might want to consider the new software program by EZHAZMAT.  This new software walks you through the process of correctly shipping hazardous materials in compliance with 49CFR part 100-185.  The program identifies the correct shipping name, gives the shipper the correct markings on the package, creates a bill of lading and more. 

However, this is NOT a substitute for the training requirement in 49CFR part 172.700 or the security plan part (HM-232).  Training is still required every 3 years for ground shipping and every 2 years for air and ocean shipping.  Also all new employees involved with the loading or unloading of hazardous materials must be trained within 30 days.  

There are other software programs that will help you ship hazardous materials such as UPS’s WorldShip, and others. If you go to the EZHAZMAT site you might also want to take the hazmat quiz and test your knowledge.

There have been a lot of inquiries into how to ship hazardous material and questioning whether you can ship it at all with today’s transportation laws. The United States Department of Transportation (DOT) Pipeline and Hazardous Materials Safety Adminsitration heavily regulates the transportation of materials in the United States. Previously, we wrote about shipping hazardous by air with FedEx and/or UPS.

The specific regulations define hazardous materials and specify how to conduct practically every aspect of hazardous material shipping. The shipping of hazardous materials can pose a serious danger to anyone who might come in contact with the shipment. The inappropriate shipping of hazardous materials is a serious problem that can result in injury, loss of life, major fines, jail time, and damage to property. Therefore, it is critical that one carefully follow the rules so that any possible unsafe condition is minimized.

The D.O.T. can and does impose severe penalties for anyone who knowingly or unknowingly violates these regulations. Packages that contain hazardous materials need to be properly labeled for shipping and the label designates the type of hazard the material presents. Hazardous material items that are commonly shipped incorrectly are aerosol cans, cosmetics, perfumes, nail polish, lipsticks, alcohol, products containing alcohol such as cleaning products and even alcoholic beverages are considered dangerous. The following are the officially designated hazard categories:

o 1.1 - EXPLOSIVES 1.1
o 1.2 - EXPLOSIVES 1.2
o 1.3 - EXPLOSIVES 1.3
o 1.4 - EXPLOSIVES 1.4
o 1.5 - EXPLOSIVES 1.5
o 1.6 - EXPLOSIVES 1.6
o 2.1 - FLAMMABLE GAS
o 2.2 - NONFLAMMABLE GAS
o 2.3 - POISON GAS
o 3 - FLAMMABLE LIQUID
o 4.1 - FLAMMABLE SOLID
o 4.2 - SPONTANEOUSLY COMBUSTIBLE
o 4.3 - DANGEROUS WHEN WET
o 5.1 - OXIDIZER
o 5.2 - ORGANIC PEROXIDE
o 6.1 - POISON INHALATION HAZARD (zone A or B)
o 6.1 - POISON (other than inhalation hazard)
o 6.2 - INFECTIOUS SUBSTANCE
o 7 - RADIOACTIVE WHITE-I
o 7 - RADIOACTIVE YELLOW-II
o 7 - RADIOACTIVE YELLOW-III
o 7 - EMPTY (empty packages of radioactives)
o 8 - CORROSIVE
o 9 - CLASS 9

D.O.T. shipping labels are available for all of these categories. These shipping labels are 4″x 4″ and come on rolls of 500, have semi gloss face stock, permanent adhesive, and come on a 1″ inch core. They also have the ability to custom make these labels to have a special blank white region to write your own personal messages or instruction on. This region does not come on the stock labels. It has to be requested and it can be requested blank or with a message preprinted.

If your application calls for a little more durable label, there are several material solutions for you. They can offer several different films such as polyester, Kimdura, and polypropylene. These materials will withstand water, chemicals, UV rays, and other environmental factors that paper will not.

These special materials are not stock and would have to be custom made by most manufacturers. They would also have a 7-10 business day lead time. FedEx and UPS both offer shipping methods for hazardous material. They also offer guides that explain their rules and regulations for shipping these products.

Shipping hazardous material can be quick and easy as long as the appropriate steps are taken. Knowing how to ship hazardous material the correct way is important. Please pass this information to those that are interested in this topic.

The Compliance Resource Center offers on-site, function specific training for the shipping of hazardous materials (Hazmat 49 CFR, part 100-185) by ground, air and ocean.  The CR Center can also assist with hazardous materials audits, security plans, hazardous spill training and more. Contact us at info@thecrcenter.com or 847-298-3063.

Trains transporting the most toxic hazardous materials must use the safest, most secure route.   Railroads will be required to route every train carrying the most toxic and dangerous hazardous materials on the safest and most secure route under a new federal rule announced today by U.S. Secretary of Transportation Mary E. Peters.

Railroads will be required to route every train carrying the most toxic and dangerous hazardous materials on the safest and most secure route under a new federal rule announced today by U.S. Secretary of Transportation Mary E. Peters.

“This strong measure better ensures that rail shipments of hazardous materials will reach their final destinations safely and without incident,” said Secretary Peters, noting the rule applies to trains hauling Poison Inhalation Hazard ( PIH ) commodities such as chlorine and anhydrous ammonia which are heavily used in farming, water purification, and manufacturing.

Secretary Peters explained that beginning June 1, the rule requires railroads to conduct a comprehensive safety and security risk analysis of its primary route and any practicable alternative routes over which it has authority to operate. The analysis must consider information provided by local communities and a minimum of 27 risk factors like trip length, volume and type of hazmat being moved, existing safety measures along the route, and population density, she said. Railroads must implement their routing decisions based on these analyses by September 2009.

In addition, the rule includes several rail security provisions designed to guard against tampering with the rail hazmat car during transportation, the Secretary said.

The new rule complements the Department’s proposal last month to increase by 500 percent on average the amount of energy a rail hazmat tank car must absorb during a train accident before a catastrophic failure occurs, Secretary Peters said. This dramatic improvement in puncture resistance can be achieved with innovative designs, materials, and technologies available today and in combination with speed restrictions, she said.

“Stronger hazmat tank cars moving on the safest and most secure rail routes will enhance safety for people living in big cities and rural towns all across America,” Secretary Peters said.

The interim final rule on rail hazmat routing was developed by the Department’s Pipeline and Hazardous Materials Safety Administration in consultation with the Federal Railroad Administration, and fully complies with the provisions of the Implementing Recommendations of the 9/11 Commission Act of 2007.
 

A typical day in the life of the EH&S manager might go something like this:

Get in the office at 7 AM and go over all the previous days reports about any incident(s) that occurred.  Next you get that cup of coffee to spill over all those reports.  Now you check out the 50 or so E-mails of which at least 30 require a response.  Now it is time to walk the facility and do a short audit to make sure the people are wearing their PPE.  Go back and check more e-mails, and go over the budget for this month.  It’s 9AM and time for your first managers meeting of the day.  You report on 1 incident and what is happening to the employee.  Now back to the office to write your agenda for the weekly safety meeting and go over the OSHA 300 log.  After a short break you need to go over training records to see who needs what training and when can you get it done. Time to start designing a hazardous materials training class for new employeesas some of your MSDS sheets have changed.  Lunch, and then back to designing the training class you use to outsource, but not in this year’s budget.   Call coming in from the floor about a machine-guarding problem (no one hurt).  Have to go on the floor with maintenance to check the machine (lockout/tagout), they need it running for the production line.  Another call on the Nextel that employee requires minor first aid.  Go back to the office to call supervisors to schedule training, but hey are NOT happy to have to take people away from production.  Your boss calls and wants a report about safety to give to his/her boss.  Day almost over, you go back and check on machine to make sure it is properly guarded and find some flammable hazardous materials left out unattended.  Talk with supervisors about this and how to put them away correctly. 5:30PM, time to leave the building, but have to keep Nextel on just in case.  Oh no, I forgot to get the safety meeting agenda put together, well tomorrow is another day.

Here is who I was today:

• A manager
• An IT person
• Asafety person
• Administrative assistant
• A finance person
• An instructional designer
• A maintenance person
• A medic
• An arbitrator
• An employee
• Oh Ya! a family person too!!!

So what do you think, sound something like your day?  How many other jobs do you do that I left out?  Send a comment and we will compile a complete (as possible) of all the jobs a safety manager has to do.  Let’s hear from you.