By Chuck Haling
From the May 2013 issue of Today’s Facility Manager
The clock is ticking on the time facility managers (fms) have to comply with the first deadline of the Occupational Health & Safety Administration (OSHA) revised Hazard Communication Standard (often referred to as HazCom 2012). Restructuring the standard brings it into alignment with the Globally Harmonized System of Classification and Labelling of Chemicals (GHS), the hazard communication system developed by the United Nations (UN). Any country or agency that adopts the GHS can adapt it to its needs and is entirely responsible for its enforcement.
The first HazCom 2012 deadline is December 1, 2013. That is the date by which employees in the United States who are exposed to hazardous chemicals must be trained on the GHS required changes to labels and material safety data sheets (MSDS).
Specifically, OSHA stipulates that employees who work with—or are otherwise exposed to—hazardous chemicals in the workplace must be familiar with the six new standardized label elements that are to appear on shipped containers. Additionally, OSHA says employees also must be updated on changes to safety data sheets, including an introduction to the numbering, ordering, and scope of the now standardized 16 section format.
High Level GHS Adoption
To understand HazCom 2012 training requirements it is helpful for fms to have background knowledge on how OSHA’s adoption of the GHS affects all stakeholders in the chemical life cycle, from chemical manufacturer through to employers.
The GHS was developed by the UN—with strong participation by OSHA and other U.S. agencies—to provide a global approach to defining and classifying chemical hazards, and to communicating those hazards via standardized safety data sheets and labels. When a country or agency like OSHA adopts the GHS, it takes only the GHS criteria and provisions that it deems appropriate and works them into its existing system (i.e., the HazCom Standard).
With OSHA’s adoption of the GHS, the changes begin with chemical manufacturers and distributors. These entities must reclassify chemicals using the OSHA approved GHS criteria for physical and health hazards. What qualifies as a physical or health hazard via GHS criteria is precise.
Reliable Roof Work
By Brad Richardson
Consider that every time someone steps on a roof—whether it is an employee, contractor, or other party—the chance for falls and damage claims increases. With a permanent fall protection system in place, facilities managers (fms) can feel secure that exposed workers and their organizations are protected against the potential loss associated with the negative consequences of a fall.
Implementing countermeasures and installing fall protection systems to protect employees and contractors as they traverse a roof not only provides a safer working environment but also demonstrates compliance with Occupational Health & Safety Administration (OSHA) regulations. OSHA has standards for both General Industry (1910.23) and Construction (1926.500-1926.503) that mandate and direct the requirements and use of fall protection. Failure to comply with OSHA regulations increases the likelihood of both fines and fatalities.
There are many fall hazard exposures associated with rooftop activities, including the roof perimeter, skylights, weak decking, roof hatches, and steep slope roofing. A fall hazard survey can help identify risks and exposures by evaluating which areas of the roof are accessed most frequently—and the areas and roof elements most likely to pose a risk.
Types of Permanent Fall Protection
Permanent fall protection either minimizes injury by stopping the person who is falling or preventing the fall from happening. There are multiple systems that, when installed and used properly, can provide a safer working environment.
Permanent fall arrest anchors. These anchors are secured to a roof’s substructure and/or roof deck, or are counterweighted. Eyelets on top serve as easily accessible personal fall arrest tie-off points. OSHA standards require personal fall arrest system lifelines be secured to an anchorage point capable of supporting 5,000 pounds. According to OSHA, a personal fall arrest system consists of “an anchorage, connectors, a body belt or body harness, and may include a lanyard, deceleration device, lifeline, or suitable combinations of these.” Whether it is an individual tie-off point or a component of a horizontal lifeline system, fall arrest anchors are an effective, sound option.
Horizontal lifeline. This fall arrest system is comprised of roof anchors and a cable lifeline to which individuals wearing body harnesses connect. While this won’t always prevent a fall, it will reduce the likelihood of an injury or fatality. If the determination is made to install fall arrest anchors, a horizontal lifeline is an option. A horizontal lifeline is a stainless steel cable that runs through the eyelets of the permanent fall arrest anchors. A worker can tie off to the cable and use it as an anchor in a personal fall arrest system. A benefit of the system is that it allows for the connector to trail the worker, thus maintaining continuous anchor connection and decreasing the chance of a pendulum swing fall, which can produce an equal amount of energy as the initial free fall itself.
Guardrails or a roof walk. Guardrails provide a physical barrier around roof hatches, perimeter edges, and skylights. A guardrail system is a passive form of protection that allows workers to perform most tasks without further fall protection equipment and interference. Guardrails can be secured permanently to a roof’s substructure (usually at the roof edge), or these can be a self-supporting modular system placed at a roof edge, skylight, roof hatch, or other areas where fall prevention is necessary.
OSHA requires that guardrail height be 42″ (plus or minus 3″) above the walking/working level. While roof walk solutions are most commonly employed to prevent damage to the roof from foot traffic, when it is used with safety rails, a roof walk can be an effective solution for preventing falls. This is because:
- similar to guardrails, the roof walk safety rails provide a barrier blocking individuals from falling through hatches or skylights and off the roof;
- the surface is slip-resistant; and
- the roof walk can be designed to only allow access to specified points on the roof.
Skylight screens or nets. These are other passive fall protection products and can prevent individuals from falling through to the level below. According to OSHA 1910.23(a)(4), every skylight floor opening and hole “shall be guarded by a standard skylight screen or a fixed standard railing on all exposed sides.”
Permanent/fixed ladder protection. Providing permanent ladders at points of worker access and ensuring that these meet OSHA regulations (e.g., ladders with safety cages, wells, etc.) can reduce the likelihood of injuries and fatalities. Additionally, guardrails can be erected in conjunction with the fixed ladders to provide protection when individuals first step onto a roof.
Installing And Maintaining Permanent Fall Protection
Clever design of a structure can remove a lot of fall exposures, but where the inclusion of fall protection anchorages is unavoidable specialist installers should be consulted. A qualified installer will design the system so it is user-friendly. If an anchorage system is too complex, users are unlikely to use it correctly, if at all.
Incorrect design and improper installation can be fatal. Effective design is crucial to the performance of fall protection systems, especially in regards to horizontal lifelines. It considers the following:
- Access. This considers how a worker gets to the permanent fall protection system.
- The type of work. The activities being performed and their frequency will influence the best option(s) for protection.
- Work area. The areas of the roof being trafficked and populated most impact the fall protection system that is chosen, as well as its placement and effectiveness.
- Number of workers exposed. This factor can impact which system to install. It is also a critical consideration for load calculations when a horizontal lifeline system is being employed.
When hiring a contractor to recommend and install permanent fall protection, fms should make sure the company they hire has a qualified person in fall protection and horizontal lifeline design on staff and that this individual, or others employed there, have been trained by the horizontal lifeline manufacturer in both installation and inspection of the system.
Once permanent fall protection is installed, proper signage is necessary. At each access point to the lifeline, a sign with the following information must be made visible:
- Maximum number of users
- The installer’s name
- The date of site acceptance
- The date of the next inspection
- The equipment authorized for use on the lifeline
On-site personnel should be trained in the use of the system. When evaluating installers, fms should ask if they are qualified to perform this responsibility. Users should learn the following during training:
- How to put on a body harness, personal protective equipment (PPE), lanyards, connectors, carabiners, and snap hooks properly
- The basics of the installed system(s)
- Descent and rescue
Individuals that will be using the permanent fall protection system should also be warned about improper use of the equipment (for example, the lifeline should never be used as a suspension system or anchorage point for lifting materials or equipment). In order for the system to perform as intended and continue to reduce exposure, annual inspection is also necessary.
Richardson is director of environmental health and safety at Cedar Rapids, IA based D.C. Taylor Co., a national industrial and commercial roofing contractor. He holds a degree in Occupational Safety and Environmental Health from Illinois State University, is a certified safety professional (CSP), and is a qualified person in fall protection and horizontal lifeline design.
As a result, three hazards previously covered under the old HazCom Standard are not included. Those hazards are: combustible dust, simple asphyxiants, and pyrophoric gas. OSHA did not want to drop protections for these three hazards, so it changed the definition of hazardous chemicals to include them alongside the GHS defined physical and health hazards.
Classification is so specific and important in HazCom 2012 because of the new way classification information flows to the label and safety data sheet. In the past, OSHA required chemicals to be classified, but largely left it up to manufacturers and distributers to decide what information to put on the labels. Those days are nearing an end.
Prescriptive Approach To Labels
Under HazCom 2012, once a chemical is classified OSHA then prescribes the exact language and pictorial elements that are to appear on a shipped label. (This information also goes in Section two/Hazard Identification of the new safety data sheet.)
Following are the six required GHS elements for labels on shipped containers. These are the elements fms will need to train their affected employees on by the December 1, 2013 deadline.
- Product Identifier: Matches product identifier on safety data sheet
- Pictogram(s): Black hazard symbol on a white background with a red diamond border
- Signal Word: Either “Danger” or “Warning” depending on hazard severity
- Hazard Statement(s): Describing the nature and degree of the hazard(s)
- Precautionary Statement(s): Describing relevant prevention, response, storage, and spill measures
- Supplier Information: Including name, address, and phone number
OSHA expects that by the training deadline, employees in affected facilities will have an understanding of how these six elements work together, how the information can be used to handle products safely, and how label information can be used in cases of emergency.
Safety Data Sheet Makeover
Fms also need to train their employees by December 1 of this year on the new safety data sheet format. A HazCom 2012 compliant safety data sheet has 16 sections in a strict order. It is similar in layout to the ANSI standard for MSDSs.
Once every chemical manufacturer and distributor operating in the U.S. completes its chemical reclassifications and updates its safety data sheets, employees will know exactly where to find information on a safety data sheet, regardless of product or manufacturer. For example, Section four will always be First Aid Measures, and Section seven will always be Handling and Storage.
A cosmetic change to safety data sheets that may take some getting used to is their name change. Under HazCom 2012, safety data sheets are called SDSs. It is important to note that whether these are called MSDSs or SDSs, their essential purpose is unchanged. From that respect an MSDS and an SDS are really one and the same.
Employees should be trained to know that safety data sheets are structured so that the most important safety and emergency response information is located towards the front of the document while the more technical information is towards the back. Employees should also understand how the information in sections one and two on the safety data sheet relates back to the label.
With all of these changes to chemical classification and safety data sheets, fms should anticipate that their entire safety data sheet library will turn over in a relatively short time frame. With that in mind, fms should be thinking about their overall strategy of managing safety data sheets. Many facilities are turning to electronic management of safety data sheets to manage the influx and to ensure employees have access to the most up to date information possible.
Of course, updates can only happen as quickly as manufacturers make the necessary changes. Once changes are made, however, manufacturers are required to ship the updated safety data sheets with the next order to downstream users. If a facility no longer uses certain chemicals, fms should not expect to receive updated documents and labels without making a special request.
Conversely, if facilities receive chemical shipments with non-compliant SDSs after the June 2015 manufacturer deadline, OSHA will expect fms to make a good faith effort to secure the updated information. In this situation as well, a good electronic safety data sheet solution can provide concrete value.
HazCom Training Considerations
OSHA does not require trainers to have special certification to conduct HazCom training. It does, however, expect training to be effective—meaning that employees will be able to deliver what they have learned back into the workplace.
OSHA also strongly recommends that training records be kept. With HazCom violations ranking second on OSHA’s Top 10 List of Most Cited Standards, fms should expect that OSHA inspections going forward, especially after the December 1 deadline, will include a thorough look at employee training.
Fms seeking help with training, labels, or any other facet of HazCom 2012 compliance, will find there are resources online like free webinars and GHS compliance checklists that can help to make the transition a smoother one for a facility.
Rather than waiting until the last minute, fms should consider conducting the first round of training as soon as they responsibly can. Trained employees can serve as a first line of defense for identifying updated safety data sheets and labels as these enter the facility, and this preparation also gives fms a leg up for working on their overall HazCom compliance.
The second employer deadline is June 1, 2016. By that time, fms must have made any necessary updates to their facility HazCom programs and workplace labeling systems, along with having trained employees on any newly identified hazards as determined by the reclassification process.
Haling is the vice president of sales at MSDSonline, a Chicago, IL based provider of cloud based compliance solutions that helps businesses of all sizes cost-effectively manage global environmental, health, and safety regulatory requirements.