Q: What kinds of operations present a crystalline silica hazard?
A: According to OSHA, industries and operations in which exposure to crystalline silica can occur include, but are not limited to:
Q: What is the Silica Compliance Schedule?
A: The final rule took effect on June 23, 2016. Industries have 1 to 5 years to comply with most requirements, based on the following schedules:
Information on OSHA’s Silica rule can be found here.
Q: How often do we need to do Haz Com training?
A: Haz com training is required:
NOTE: Some companies provide refresher training annually as a best practice.
Q: Does HazCom training only cover chemical hazards?
A: No. HazCom training covers any physical and health hazard in a work area. Due to labeling requirements, we tend to get conditioned to think that HazCom only applies to the chemicals in our work areas.
Q: Is combustible dust a hazard that we need to train on?
A: Combustible dust is identified as a physical hazard, and if present in your facility you will need to train on combustible dust hazards.
Q: Do you need to keep SDSs for commercial products such as "Windex" and "White-Out"?
A: OSHA does not require that SDSs be provided to purchasers of household consumer products when the products are “used in the workplace in the same manner that a consumer would use them.” [i.e.; where the duration and frequency of use (and therefore exposure) is not greater than what the typical consumer would experience].
This exemption in OSHA's regulation is based, however, “not upon the chemical manufacturer's intended use of his product, but upon how it actually is used in the workplace.” Employees who are required to work with hazardous chemicals in a manner that results in a duration and frequency of exposure greater than what a normal consumer would experience would need to be trained in those hazards.
For example, if a manufacturer uses Windex to clean stainless steel panels all day long, this could be considered as a duration and frequency condition (exposure) much greater than the average home owner (consumer). As a result, companies would need to have the SDS for Windex, and train their employees on its hazards.
Q: What about janitorial use of chemicals?
A: Janitorial use of chemicals is not considered to be the same duration and frequency of exposure scenario as a consumer (home owner). Janitors use the chemicals during extended periods and likely have a higher exposure. Chemical SDSs used for janitorial purposes should be maintained at the facility by the employer in charge of the janitorial services.
Information on interpretations of OSHA’s hazard communication standard can be found here.
By now you should be knee deep in assembling information reviewing data and getting ready to prepare and submit your Q1 reports.
OSHA 300A Logs – Your OSHA Log Posting is due February 1st. Make sure you have re-reviewed some 2016 incidents with your incident investigation team to ensure you have all the information you need and that it is still current. Sometimes reporting information changes weeks and even months after an incident so you want to be sure days away, transfer and other information is still correct.
Hazardous Waste Biennial Report – Review your waste shipping records to verify you have all the original signed manifests, LDR documents and waste characterization files for all wastes generated during 2016. Do a quick generator status check to determine whether or not your generator status has changed.
Tier 2 Reports – Has your company started any new processes this past year or started storing new chemicals on site? If so, determine the quantities you now store and how the materials are managed. This is a good time to update your chemical inventory.
Air Permit Reports – Depending on your emission units and permit terms and conditions, you may have monthly, quarterly, semi-annual and annual reports to submit. It is a good idea to check in with the staff responsible for collecting the data to ensure it will be available when needed and it is accurate.
Online Reporting Access – Just like the fire department wants you to check the batteries in the smoke detectors in your home, the new year is a good time to check your online access user names and passwords to make sure they are current and still work. Some agencies require you to change your password annually. The new year is a good time to make sure that everyone involved in the reporting process still knows their login information. Getting these items resolved now will help avoid headaches as you approach reporting deadlines.
If you have questions, give us a call and we will be happy to help.