The Compliance Resource Center has reported that both the domestic hazardous materials transportation regulations and international rules for shipping batteries have undergone significant changes over the past two years.  All batteries, alkaline, lithium, lead, nickel metal hydride, carbon zinc, etc., or battery powered products are subject to 49 CFR 173.21(c) in the U.S. hazardous materials regulations.   Many batteries that were previously unregulated or under-regulated must now be thoroughly evaluated to determine hazard potential. Detailed packaging and communication standards must be followed under. 

Adding complexity to the issue is the fact that shipping requirements vary greatly, depending on the mode of transport and the type of battery.  Battery shipping regulations affect a wide array of industries from manufacturers and part suppliers to freight forwarders and distributors.  Regardless of whether a lithium or lithium ion cell or battery qualifies for the exceptions in the regulations, shippers must still comply with requirements of 49 CFR 173.21(c). That is, the cells and batteries must be securely packaged and offered for transportation in a manner that prevents the dangerous evolution of heat and short circuits.

Both FedEx and UPS will refuse to accept packages not meeting FedEx, Government or IATA requirements.

The other night I was driving down a street and came to a large construction area where they were building a new bridge across the road.  As I looked up I saw 2 large generators suspended from the idle crane, swinging in the breeze.  This is a common practice to protect generators from being stolen.  NOT SAFE.

Recently there has been a number of crane incidents and deaths.  This has lead OSHA to propose new crane standards.  Edwin G. Foulke, Jr., assistant secretary of labor for OSHA, said “This draft rule will both protect construction employees and help prevent crane accidents by updating existing protections and requiring crane operators to be trained in the use of construction cranes.”  In March The Compliance Resource Center published an article about which includes an 8 minute crane safety video from OSHA.

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We recently experienced 2 very powerful hurricanes, which not only left damage and destruction throughout the south, but also impacted the midwest with heavy rainfalls and flooding.  So was your company or organization emergency ready?  Many were not.

FEMA, Homeland Security, The Red Cross, along with others have materials to help you prepare for disruption of your business.

Here are some things you might want to consider:

• Back up your computer system. Make sure your computers are backed up, preferably off site, and the programs to restore your business data are current. Also, practice restoring your system. After the fact is not the time to test.
• Set up an employee call network. Get employee phone and cell numbers and break your workforce into groups. If there is a natural disaster, have one person in charge of calling everyone in their group, then reporting back to management.
• Have adequate generator capacity. Make sure you have a generator that can run your facility before a disaster strikes. Needless to say, a reliable fuel source is a must. Set it up and test it.
• Stockpile supplies. Store non-perishable food items and other essentials that may be needed after a storm, to create an environment where employees will want to come to work. If you take care of your employees after a disaster, they will take care of you.
• Train first responders on emergency procedures and then all the employees. Ensure that first responders have adequate notice to get employees to a safe area depending on the diaster.
• Secure your facility unless in the case of fire there is no time.
• Plan for after the diaster. Designate a team to assess damages and take stock of what’s happened after the danger has passed.

You can also review Compliance Resource Center articles on Emergency Prepardness:

Exit Routes and Emergency Action Plans (1910.33)

Emergency Preparedness Be Ready

Fire Prevention Plan

Communications Preparedness Tips

NFPA Evacuation Guide to People with Disabilities

There are more articles at www.thecrcenter.com.  So now is the time if you do not have a emergency plan GET ONE and the other important word is PRACTICE, PRACTICE, PRACTICE.

Do you ship or receive any materials considered hazardous by the US DOT (49 CFR 172.101)?  If so, you MUST have a security plan (49 CFR part 172.800) which includes security awareness training to all who load, unload or have some responsibility putting the hazardous materials in commerce.  This might include the person in the office who fills out the shipping papers, or the forklift driver who unloads the truck in your loading bay.  Everyone involved with the process must be trained. 

The DOT has become more active fining companies and organizations for not having a security plan and not doing the training.  Large or small, profit or not-for-profit, it doesn’t matter.  Security awareness training is now considered one of the 5 parts of HAZMAT training.  the 5 parts include: General Awareness, Function-Specific, Safety, Security Awareness, and Security In-Depth (if you need and have a security plan as classified by (49CFR 172.800(b)(1-7). If your hazardous materials fall under this last part, then you must do a full security plan including a assessment and training.  The plan needs to be in writing and available to all who are affected.

The Compliance Resource Center can help you do a security assessment, write a security plan and customize hazmat training specificly for your company.  All of our HAZMAT training is customize for the hazardous materials you ship or receive.  You employees get ALL the training required by the US DOT Pipline and Hazardous Materials Safety Adminsitration.  DOT Hazmat training for ground is required every 3 years and for air and/or ocean every 2 years. 

Here is part 2 of the Electrical Safety Quiz.  The answers will be posted next.

11. Exposed energized parts:
    a. Are enclosed
    b. Are capable of being accidentally approached nearer than a safe distance
    c. Are usually insulated
    d. Are always guarded

12. Exposed parts are considered to be energized:
    a. If they are not locked/tagged out
    b. If they are insulated
    c. If they are locked/tagged out
    d. If you can’t see that they are disconnected

13. A qualified person:
    a. Is automatically considered to be qualified to work on all electrical equipment
    b. Must be a licensed electrician
    c. Is familiar with the construction and operation of the equipment and the hazards involved
    d. All of the above

14. Lockout/tagout:
    a. Must be done by a qualified person
    b. Can be done by an unqualified person
    c. Must be done by a supervisor
    d. Can be done by anyone

15. If you are working under unguarded, energized overhead lines:
    a. The clearance distance is 10 feet for voltages of 50 kv or less to ground
    b. The clearance distance is 10 feet plus 4 inches for every 10 kv greater than 50 kv to ground
    c. The clearance distance is always 10 feet
    d. Both a. and b

16. When a vehicle is intentionally grounded because its elevated parts could possibly come into contact with energized overhead lines:
    a. An employee must stand near the grounding location to warn other people to stay away
    b. A qualified employee must stand near the grounding location to warn other people to stay away
    c. No one is allowed to stand near the grounding location
    d. The grounding location must be locked/tagged out

17. Portable cord- and plug-connected equipment:
    a. Must be inspected before use on every shift
    b. Should be inspected each morning
    c. Must be inspected annually by a licensed electrician
    d. Only needs an inspection if you notice a problem

18. When electrical hazard warning signs are posted and a barricade limits entry into an area:
    a. You must use the buddy system to enter the area
    b. A written entry permit must be posted near the space
    c. Non-qualified persons need special permission before they work in the area
    d. The area contains exposed energized parts

19. If you need to use a ladder while working near electrical parts:
    a. Use a conductive ladder
    b. Use a metal ladder
    c. Use a non-conductive ladder
    d. The ladder must be intentionally grounded

20. If a circuit breaker trips and deenergizes the machine you are using:
    a. You can just manually re-set the circuit breaker and continue to use the machine
    b. It must be determined that it would be safe to reenergize the circuit before the circuit breaker can be re-set
    c. You must immediately lock out the machine
    d. You must install a new circuit breaker

The Compliance Resource Center has an electrical quiz for you to use with your training (or we can do the training).  This is PART 1.  PART 2 will be published next week along with the answers to PART 1 and then the following week we will publish the answers to PART 2.  Confused yet?  Just try an answer the quiz.

ELECTRICAL SAFETY QUIZ – PART 1

1. A live wire without insulation or guarding is:
    a. Exposed
    b. De-energized
    c. Open
    d. Close

2. A worker who knows how to avoid the hazards of working on or near an exposed electrical part is:
    a. Authorized worker
    b. Unqualified worker
    c. Affected worker
    d. Qualified worker

3. Workers who are not qualified should have a clearance distance of _____ feet between energized 50 kv overhead power lines and themselves:
    a. 14
    b. 25
    c. 10
    d. 20

4. A flexible cord should be inspected for the following defects:
    a. Pinched outer jacket
    b. Missing or damaged outer jacket
    c. Damaged insulation
    d. All of the above

5. When using portable electric equipment, you should do all of the following except:
    a. Remove the ground pin on the plug so the plug matches the two prong receptacle
    b. Use adaptors that do not affect the equipment grounding connections
    c. Remove from service equipment that deformed plugs
    d. Use dry hands to plug and unplug equipment

6. Fuses can be used to open or close a lighting circuit.
    a. Never
    b. Always
    c. Only in emergencies
    d. None of the above

7. One safe work practice while working around electrical equipment is:
    a. Wear jewelry
    b. Use conductive ladders
    c. Use insulated tools
    d. Wear keys or keychains on your clothing

8. Exposed deenergized parts are parts that have:
    a. Their energy state at zero
    b. No electrical power source attached
    c. Their conductors and parts of the electrical equipment de-energized and locked out and/or tagged out
    d. None of the above

9. To alert you of exposed energized parts, you might see the following:
    a. A sign warning of shock hazard
    b. A barricades surrounding the electrical hazard area
    c. An attendant to warn you of the hazard
    d. All of the above

10. Flammable materials should be:
    a. Always be stored near electrical equipment that may cause a spark
    b. Not be stored near electrical equipment that may cause a spark
    c. Only stored near electrical equipment when precautions are taken to prevent the development of a hazardous condition
    d. Either b or c
 

This Instruction initiates and establishes a hearing conservation program that complies
with 29 CFR 1910.95 to protect OSHA personnel covered by PER 04-00-003 from the
effects of occupational noise exposure. The Hearing Conservation Amendment to the
OSHA Occupational noise exposure standard, 29 CFR 1910.95, requires that employers
establish a hearing conservation program for employees whose noise exposures equal or
exceed an 8-hour time-weighted average (TWA) of 85 dBA.

Employers are now mandated to have a hearing conservation program that includes:

• Monitoring of work area
• Audiometric testing program
• Employee notification
• Proper PPE
• Training on hearing protectors
• Annual employee training
• Proper Recordkeeping

The Compliance Resource Center reported earlier that NIOSH had developed online tool to allow users to check their hearing protection in a minute or less.  With this new directive employers might want to take a quick look at this online tool.

It is interesting that in the 29CFR 1910, there are 2 parts that have similar, yet vastly different relationships.  Both parts deal with hazardous materials but the difference is only one (1) zero or is it?  1910 part 120 is the regulation for hazardous waste operations and emergency response, and 1910.1200 is the compliance regulation for hazardous communications. 

Hazardous communications almost always is in the top 5 of most frequently cited standards of OSHA violations.  The most common citation is for failing to have a written program 1910.1200(e) and failure to train employees 1910.1200(h).

So what does this mean?  Employers are required to have an updated MSDS (Material Safety Data Sheet) book on ALL hazardous chemicals/materials in the workplace.  The book should be available to all employees who work with these hazardous materials.  Each time a new or changed hazardous material enters the workplace the MSDS book should be updated.  In addition, all hazardous materials must be properly labeled with a similar 3 or 4 part hazardous label similar to the ones seen above.  Some labels include proper PPE (personnel protective equipment) to be worn when working with this hazardous material.

Another key part of the Hazardous Communication standard is the training.  The training 1910.1200(h)(3) shall include at least:

• Methods and observations to detect the presence or release of a hazardous material in the work area.
• Physical and health hazards of hazardous materials in work area
• Measures take for protection.
• Information including how to use the hazardous labels, MSDS sheets and where employees can get information.

To avoid compliance issues with the Hazcom standard, start with a hazardous materials audit and develop you policies and procedures.  Next write a Hazcom program that includes training, and then do the training.  Remember, every time a hazardous material changes or is introduced into the workplace, or a new employee is put into that environment you must train or retrain all involved.  Avoid the problems and avoid the fines.  Write the program and do the training.

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”.