Training


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.

Hazmat PlacardsYou 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.

Forklift Safety or Not

Many of us have seen pictures like this regarding how NOT to use a forklift.   Today forklift or Powdered Industrial Trucks (OSHA 1910.178) is number 6 on the most fined violations of OSHA’s Top Ten list.

About a year ago I posted the Forklift Quiz and answers.  The OSHA training requirements incorporate safe operation, training program implementation, training program content, refresher training and evaluation, avoidance of duplicate training, and certification.  Trainees must be initially trained in the following truck-related and workplace-related topics:

TRUCK-RELATED

  • Operating instructions, warnings and precautions for type of truck
  • Similarities and differences to automobiles
  • Control and instrumentation location and use
  • Engine or motor operation
  • Steering and maneuvering
  • Visibility
  • Fork and attachment limitations and use
  • Vehicle capacity
  • Vehicle stability
  • Vehicle inspection and maintenance refueling or charging batteries
  • Operating limitations
  • Other operating instructions, warnings or precautions listed in the operator’s manual

WORKPLACE-RELATED

  • Surface conditions where truck is used
  • Load composition and stability
  • Load stacking, unstacking and transport
  • Pedestrian traffic
  • Narrow aisle and restricted area operation
  • Operation in hazardous locations
  • Ramp and sloped surface operation
  • Unique or potentially hazardous conditions
  • Operating the vehicle in closed environments

Because powered industrial trucks are manufactured by different companies with various models available, the training must be specific to the operating characteristics of the specific powered industrial truck the employee will be using.

I was recently shopping at my local garden center and was watching the forklift operator move skids of soil and mulch.  The driver was not wearing a seatbelt, and had little regard for the shoppers or other employees his was operating the forklift near.  Twice he almost hit another employee with a skid load of soil.  Either the training was not complete or the safety person needed to become more aware of this conduct.  Either way it was an incident waiting to happen.

Hazmat Shipping LabelThere 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.

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.
    

 

When was the last time you took a safety class?  There are a lot of different sources available, with both for-profit companies and the not-for-profit organizations.  Three not-for-profit associations, ASSE (American Society of Safety Engineers),  NSC (National Safety Council) and the Construction Safety Council offer a variety of classes.  But the two sources I want to describe are the OTI (OSHA Training Institute) and the National Safety Education Center.

OTI is OSHA’s own training center in Arlington Heights, IL.  The OTI provides training and education in occupational safety and health for federal and state compliance officers, state consultants, other federal agency personnel, and the private sector.

The OSHA Training Institute (OTI) Education Center program was initiated as an extension of the OSHA Training Institute, which is the primary training provider of the Occupational Safety and Health Administration. OTI targets Federal and State compliance officers and State consultation program staff, but also provides training for private sector personnel and Federal personnel from agencies other than OSHA on a space available basis. However, during the 1980s, the number of requests for training from private sector personnel and Federal personnel from agencies other than OSHA increased substantially and the demand eventually exceeded the capacity of the OSHA Training Institute. To date there are 18 training centers with at least one in each OSHA region. 

As an example, the National Safety Education Center in Region V, is a consortium comprised of: Northern Illinois University, DeKalb, IL, Construction Safety Council, Hillside, IL and the National Safety Council, Itasca, IL.  The National Safety Education Center is authorized by Occupational Safety and Health Administration (OSHA) to deliver approved OSHA training courses. Upon completion of any program, your achievement is recognized through:

  • Department of Labor Course Completion Certificates
  • Outreach Trainer Cards for OSHA Courses 500, 501, 502 and 503
  • Availability of Continuing Education Units (CEUs)
  • Availability of American Board of Industrial Hygiene (ABIH) Safety and Industrial Health
  • Continuing Maintenance (CM) points.

Pick a class and increase your safety knowledge.

Am I passionate about training, YOU BET!  I recently read an article about developing and using on-line training for OSHA & HIPPA compliance.  It seems like more and more companies are looking at on-line training for their employees. On-line training is available for OSHA, DOT, HIPPA and more.  Push a few buttons and you are trained.  While it is economical and less time consuming, there are some drawbacks.

As a trainer:

  • I can look at a trainee and see in their eyes if they are understanding the material.   
  • I can evaluate if a student learns by seeing, hearing or doing and then work with that student using their best learning style. 
  • I can adjust the material if I see it is not relevant to YOUR students. 
  • I can have a student verbalize back to me how much they understand about the subject to detemine if they need more information.

Please tell me how the computer can make these deteminations except by continually quizing the student. 

Good safety trainers are good for business and payback their expense.  They help increase productivity and help keep worker’s compensation lower.  Both result in more profits going to the bottom line.  I have used this example before, but a average incident (according to OSHA) cost an employer about $25,000.  At 3% profit margin the company has to make an additional $833,000 to break even, and that’s if you have only 1 incident.

I am assistant scuba instructor and now there are some certifing agencies that have on-line classes for courses content.  Not the buddy I would want to be with at 80 feet under water, and to have to depend on saving my life if something went wrong.  How about the on-line First Aid/CPR class, want that person to work on you? 

On-line training for the refresher great, for the initial training, think about it and what it may really cost you.

 

The US DOT Pipeline and Hazardous Materials Safety Administration is presenting a FREE 1-day Hazmat Workshop in Rockford on May 6.  Registration information is below.

Hazardous Materials Transportation One-Day Workshop
The HMR apply to each person who performs, or causes to be performed, functions related to the transportation of hazardous materials such as determination of, and compliance with, basic conditions for offering; filling packages; marking and labeling packages; preparing shipping papers; handling, loading, securing and segregating packages within a transport vehicle, freight container or cargo hold; and transporting hazardous materials.
This one-day workshop provides an overview of how to use the HMR and a summary of many of the requirements found in the HMR that can affect transportation safety to include:
Training Requirements, Packaging, Hazard Communications, and Security.
 

For information call: (202) 366-4900 Workshop Highlights
Anyone who offers or transports hazardous materials in commerce or has a desire to learn more about
USDOT’s Hazardous Materials Regulations.
ONE-DAY AGENDA
7:30 - 8:00AM REGISTRATION
8:00 - 8:15AM WORKSHOP OVERVIEW
8:15 - 9:15AM HOW TO USE THE HMR
Review how to locate specific HM information in the Hazardous Materials Regulations (HMR; 49 CFR), e.g.,
Hazardous Materials Table, mode restrictions, proper shipping name, hazard class, division number, ID number, packing group, packaging, special provisions, labeling, marking, and placarding requirements.
9:30 - 10:30AM TRAINING REQUIREMENTS
Discuss the hazmat employer and employee training requirements in 49 CFR ®172.700.
10:45 - 11:45AM PACKAGE SELECTION, MARKING, AND LABELING
Learn how to select the proper package, properly mark the package, and label the package.
11:45 - 1:00PM LUNCH (on your own)
1:00 - 2:00PM SHIPPING PAPERS AND EMERGENCY RESPONSE INFORMATION
Learn how to properly describe a hazardous material on a shipping paper, including additional descriptions and emergency response information.
2:15 - 3:15PM PLACARDING REQUIREMENTS
Learn how to determine the required placarding when offering and/or transporting hazardous materials.
3:30 - 4:30PM SECURITY REQUIREMENTS
Provides an understanding of the security threat, an overview of the specific requirements of HM-232, and
suggestions and guidance on how to comply with the regulations.
4:30 - 4:45PM WRAP-UP QUESTIONS AND ANSWERS
Looking for more information on Hazardous Materials Please bring your 49 CFR to the workshop.
Transportation? Visit our website: http://hazmat.dot.gov/
Schedule
The Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) specify requirements for the safe and secure transportation of hazardous materials in commerce by rail car, aircraft, vessel, and motor vehicle. These comprehensive regulations govern transportation-related activities by offerors (e.g., shippers, brokers, forwarding agents, freight forwarders, and warehousers); carriers (e.g., common, contract, and private); packaging manufacturers, reconditioners, testers, and retesters; and independent inspection agencies.

May 6, 2008 - Rockford, IL

 

FlaggerWinter is officially over and our second season is starting.  No, not spring, CONSTRUCTION!  It is another season of road construction here in the Chicago area and throughout the US.  Traffic tie-ups, slow downs and the infamous flagger person telling you to “Slow down or STOP (for about 10 - 20 minutes).

I have been a flagger instructor for about 3 years.  I have also taught the flagger instructor class, but driving around the city, I must be the worst trainer ever.  I see people:

  • Using the emergency vehicle flag to direct traffic
  • Standing in the middle of the street with a Slow/Stop sign directing two-way traffic
  • Road construction people using their hands
  • Road construction people without safety vests
  • Construction people walking out into traffic to stop oncoming traffic to let a vehicle into or out of the construction site
  • Many other dumb things

Road construction injuries are up every year.  When I teach the flagger class I always like to start with the students telling about the scary incidents that have happended to them, and there are many.  Yet as I drive out on the road, I seldom see a flagger doing it right.  If they use the Stop/Slow sign they do not use hand signals, or they don’t use the sign correctly.   Having less road construction injuries means we have to be better drivers in these areas, but also the contruction people have to be better safety people.

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.

 

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