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.

The Compliance Resource Center usually does not talk about products, however the Smart Monitor Series by Ericson can help the construction industry to help meet OSHA’s construction site gound fault protection.

Ericson Manufacturing announces the release of our newest “smart” series of electrical plugs and connectors. The Smart Monitor Series utilize a new “thinking” module which detects many common electrical problems including loss of earth ground which effects lack of compliance to OSHA’s Worksite Assured Grounding Program. The dual color RED & BLUE LEDS indicate correct or incorrect electrical conditions on the cordset. Smart Monitor Plugs & Connectors constantly monitors these conditions:

No Ground
Loss of Ground In Cord
Hot/Neutral Swap
Reverse Polarity
Hot on Ground
Open Neutral.
RED LEDs indicate an electrical problem (and lack of compliance to OSHA’s Worksite Safety Program), where as a bright BLUE indication shows the cord or supply is “Good-to-Go”.

Last April, The Compliance Resource Center reported that NIOSH, OSHA and NHCA (National Hearing Conservation Assoication), recently signed and agreement  to help prevent work-related hearing loss.
Now researchers at NIOSH’s Pittsburgh Research Laboratory have developed QuickFitWeb, an online tool to allow users to check their hearing protection in a minute or less. The site notes that ear muffs, ear plugs, and other hearing protection devices can reduce the risk of hearing loss, but only if the wearer gets a good fit and wears them properly. The NIOSH sound player tool allows users to perform a quick test of whether they are getting at least a minimal 15 decibel (dB) level of protection.

The test sounds are bands of random noise with a center frequency of 1000 Hz. This is the same type of sound used in standard hearing protector ratings including the “American National Standard Methods for Measuring the Real-Ear Attenuation of Hearing Protectors” (ANSI S12.6). Both tracks are the same, but the second track is 15 decibels (dB) louder than the first. Most hearing protectors will block or “attenuate” sound by more than 15 dB if they are the right size and shape to fit the ears and are worn correctly. A sound that is barely audible at a worker’s threshold of hearing without hearing protection should be inaudible though hearing protection even if it’s boosted by 15 dB.

To use the tool, visit www.cdc.gov/niosh/mining/topics/hearingloss/quickfitweb.htm.

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.

I recently got a call from a small company whose UPS shipment was not acceptable because the company was not aware the shipment contained a hazardous material, and no one at the company had the correct hazmat training.   How could they get their products to their customers?  Everyone had to scramble to get them in compliance.  This is not an uncommon occurrence for companies and organizations.

Shipping hazardous materials by UPS and/or FEDEX must be done in accordance to US DOT federal regulations (49CFR part 100-185), ICAO (air), or IMDG (ocean).  Both UPS and FedEx will decline shipments if the business cannot show the carriers that their employees have been trained and follow all compliance concerns of US DOT & ICAO. 

First let me dispel a BIG misunderstanding.  IATA is NOT a regulatory agency.  IATA is the International Air Transportation ASSOCIATION.  They wrote a very good reference book with regards to air shipping, but are not a regulatory agency.  ICAO (International Civil Aviation Organization) and the US DOT (49 CFR part 175) are the regulatory agencies for shipping hazardous materials by AIR.

If you are not sure if the material you are shipping is hazardous first look at an MSDS sheet, 2nd check out 49CFR part 172.101.  This is the DOT’s hazardous material table.  If your material is listed here then you MUST follow DOT compliance.  The table will also tell you if the material(s) can be transported by air.

It you have a question, use the comment box below and The Compliance Resource Center will answer you question.

The American Heart Assoication is adapting a new standard for CPR.  On March 31, an important advisory statement on “hands-only”  (compression-only) CPR was published in Circulation. This statement clarifies the 2005 AHA Guidelines for CPR and ECC, which included the recommendation that laypersons – or bystanders – should perform hands-only CPR if they are unable or unwilling to provide rescue breaths.  The Compliance Resource Center wrote about an article about a new study done in Lancet in April of 2007.  The Lancet study showed dramatic results when life-savers only had to worry about chest compressions without doing mouth-to-mouth breathing. 

”The report confirms that what we have learned in animal experiments applies to humans as well,” says Gordon A. Ewy, MD, director of the Sarver Heart Center at The University of Arizona in Tucson where chest-compression-only resuscitation was developed. “Bystander-initiated continuous chest compressions without mouth-to-mouth breathing are the preferable approach for witnessed unexpected collapse, which is usually due to cardiac arrest.”

Hopefully more people will consider doing CPR (compression only) on a person when needed.  Statistics show that when CPR is started and continued until help arrives, it can save lives.

The US department of labor estimates that 5.6 million workers risk exposure to bloodborne pathogens, including human immunodeficiency virus (HIV), hepatitis B virus (HBV), and hepatitis C virus (HCV), while on the job. An OSHA Standard Bloodborne Pathogens (1910.1030) Training Program is essential for any person who may be “reasonably anticipated” to face contact with blood and other potentially infectious materials as the result of performing their job duties. Professions at risk include, but are not limited to, healthcare professionals, educators, cosmetologists, tattoo artists, and construction workers. Industries whose employees have contracted infection from bloodborne pathogens while on the job run the risk of an OSHA citation up to $70,000 for facilities not in full compliance with bloodborne pathogens standard.

The Occupational Safety and Health Administration (OSHA) has recently begun to strictly enforce the bloodborne pathogens standard. Facilities not in full compliance with the standard, including failure to provide proof of OSHA standard bloodborne pathogens training to all employees, have received up to 70,000 dollars in fines.

A Bloodborne Pathogen program should include, but not be limited to:

• Exposure Control
• Methods of Compliance
• Personal Protective Equipment
• Housekeeping
• Regulated Waste Control
• Communication of Hazards to Employees
• Recordkeeping

It is the employers’ responsibility to train and inform their employees about hazards in the workplace.  It is also the responsibility of the employer to pay for all PPE necessary to keep the employee safe.

The Compliance Resource Center provides training and polices and procedures for Bloodborne Pathogens Programs and other OSHA and DOT compliance.

Happy New to all.  The Compliance Resource Center hopes you all had a wonderful and SAFE holiday season.   And now it is time to get back to work.
The beginning of a new year is a great time to do an annual assessment of your facility.  I always consider 4 parts to an assessment;

• Observation
• Conversation
• Compliance
• Evaluation 

OBSERVATION
I always to target 5 major areas that I am evaluating, during an assessment.  I start by looking and making notes with particular regards to these areas, but also notice if there are any other major concerns.  If time permits, I walk through the facility watching employee’s work and the equipment they are using.  I will often bring a camera and take pictures to support my findings.
CONVERSATION
Part of the assessment process should be talking with some of the employees.  This can give you a better understanding of employee’s opinion and understanding of the safety policies/procedures and their training.  Often the employees will tell a consultant some thing they would not tell their supervisor.
COMPLIANCE
My assessment is always based on compliance with OSHA regulations found in 49CFR.  If you are the safety person at your company, you should have a current 49CFR on your shelf.  This book is your bible for OSHA regulations and compliance.  Any assessment should follow these standards with regards to this manual.  Remember that OSHA standards are written for many industries.  You can also look at best practices to achieve a higher standard.  This is up to the individual company and location.
EVALUATION
After I stop, look and listen, I fill out an assessment tool that rates each area I observe.  This helps me keep my focus on facility and the good things they do and where they need improvement.  The final report is sent to my contact.  I follow-up in a few weeks to help the safety person develop a plan of action using the assessment made.  Finally, I check back every couple of months to see what progress is being made on the action plan.
So now you know some of the tricks of the trade; observe, converse, compliance and evaluate.  Have A SAFE NEW YEAR!

Are you aware of the The Safe, Accountable, Flexible, Efficient Transportation Equity Act of 2005 or SAFETEA-LU?  If you ship or receive hazardous materials as defined in 49 CFR parts 172.101

This act raised the DOT’s ability to impose a civil fine from $50,000/incident to $100,000/day/incident.  So, what does this mean to you?  If your shipment is NOT in compliance with 49 CFR parts 100-185 it could cost you significant fines. 

Today the US DOT is taking incorrect shipments very seriously.  Shipping hazardous materials incorrectly, in commerce, can cost your organization big bucks.   Consider that you send 1001 pounds of AMMONIUM NITRATE by ground transportation and have incorrect shipping papers, the wrong placard on your truck, and your employees have not been trained properly.  This represents a possible fine of $300,000/day. 

There are 5 parts to Hazmat training:

• General Awareness/Familiarization Training- How to use the 49CFR and identify hazardous materials
• Function-specific Training-What specific hazardous materials you ship or receive and how to do it correctly
• Safety Training-Emergency Response, safety measures used to protect employee’s, handling of hazardous materials
• Security Awareness Training-awareness of security risks and how to recognize possible security threats
• In-depth Security Training-If you ship certain classifications and quantities of hazardous materials you need more in-depth planning and training

An ounce of prevention is worth a pound of cure. 

The Compliance Resource Center offers customized on-site HAZMAT training.  Each class is customized to your organizations specific hazardous materials shipped or received.  Contact us for more information.

 by Allan Kaufman

President, The Compliance Resource Center

How often have you been in a training session where you are yawning, falling asleep, or just bored?  It happens more often than we think.  That’s why we really appreciate a speaker or trainer who really makes us sit up and listen.  So what makes these trainers different?  They know their audience, and they understand the principles of learning and how to motivate their audience.  They also understand the principles of learning.

There are four (4) basic principles of adult learning:

• Motivation
• Reinforcement
• Retention
• Transference

Adult Educators should understand that adults learn information differently.  Some people are VISUAL learners.  They learn by seeing or reading material.  Others learn by ORAL information they hear.  Still others respond better to KINESTHETIC or TACTILE training, where they benefit better from doing and touching.

Training should encompass all these types of learning realizing that is more interactive the training is, the greater the results.  If your training includes problems or case studies that are relevant to the students they will be more engaged.  Anytime the training directly relates to what we do we take a greater interest.  Whenever we do Hazmat training, we always find out what materials are being shipped, how they are shipped and what in what quantities.  We then incorporate this information to make the training function specific and relate that to what these employees use and do.  This always produces greater response and interest. 

One other area to consider is your PowerPoint presentation.   What is more boring than someone reading bullet point sentence after bullet point sentence?  A PowerPoint presentation should use bullet points that are short and concise.  They are a reminder or outline to help you make your points.  The old adage a picture is worth a thousand words is so true.  Use pictures or other graphics to make your presentation more interesting.  Whenever possible, a little humor keeps your audience engaged, but only if the situation is appropriate.

Trainers and/or adult educators need to be aware of their audience.  There are different types of learners and they need to feel that they are engaged into the learning process.  Anytime the learning is specific to the student they will have a greater interest.  Make sure your speak from your outline and do not read it.  I know you will find your audiences more appreciate of your presentation.