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Controlling your risk by Bob Carruth

As Risk Control Manager for the NCACC, Bob Carruth manages the operation of the Risk Control Team for the Risk Management Pools. The team assists members with development of safety policies and programs and identification of liability exposures and controls. Carruth is a Certified Safety Professional and is certified as an Associate – Risk Management.  For archives of this column click here

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Mar 04

Strides being made to ease burden of standardized labeling for chemicals

Posted on March 4, 2015 at 2:48 PM by Chris Baucom

This helps the international chemical manufacturing community provide a level of safety and confidence to end users that all the critical information needed to safely handle and use chemicals is provided.

In adopting these new standards in the U.S., OSHA has also updated its Hazards Communication & Right-to-Know standards to reflect the new requirements under the Global Harmonization Standards. Included in the program are three primary requirements.

First, by December 2013, every employer was to complete training for their employees on the new Safety Data Sheet format, as well as the new container labeling requirements. To help accomplish this, the NCACC provided a training package for its pools members to assist them with compliance. For those that have not completed the training, this package is still available through our online Risk Control Services Resource Library.

The second requirement is for all chemical manufacturers to update their container labeling and safety data sheets to reflect the new requirements by June 1, 2015. This has already begun, and for those who handle the purchase and receipt of chemicals, they may have already begun to see the new formats as new chemical shipments are received.

The final requirement is the employer’s responsibility. Part of OSHA’s HAZCOM standard already requires every employer to maintain a copy of every chemical used in the workplace and make it available upon the request of any employee. For every employer, this has been a pretty daunting administrative burden, as hefty fines can result from not having an MSDS readily available for an employee to review when needed.

The burden to keep the MSDS updated is difficult for any safety coordinator in any organization and is even more difficult for counties, given the often decentralized nature of county operations, as well as the limited staff support that is often available to ensure continued compliance. Many of our members have set up a system that requires the continual update of “MSDS Stations” at numerous county facilities. Each of these “stations” is an opportunity for a citation, or worse, a critical error in an emergency, if an MSDS is either missing or outdated.

Now that all of our pool members will be faced with updating their safety data sheets over the next 18 months, the burden will be greater to update every safety data sheet as they arrive. Many of our members do not have the staff time available to dedicate to this. Non-compliance is not an option, as by December 2016, OSHA will be ready to begin issuing citations for failing to update this critical data.

It is for these reasons that the NCACC Risk Management Pools have been working with MSDS Online to develop an online, cloud-based tool that our members can use to update and manage their own chemical inventories, to include making every newly formatted safety data sheet immediately available.

Although this resource involves a nominal annual subscription cost on the part of our members, when balancing this with the administrative cost for staff to manually update all of the records, as well as the risk of fines and citations for noncompliance, the annual cost of an online service is worth exploring. In fact, MSDS Online will provide an online calculator that will help to calculate the current cost of manual compliance as well as what savings can be realized by converting your chemical information library to an online system.

Finally, to help make our membership aware of this valuable resource, we will be discussing this tool at our regional meetings, and we will send out additional information. As always, our risk control staff is available to answer any questions you may have. Please feel free to contact our Risk Control team for more information. Contact Bob Carruth at bob.carruth@ncacc.org or by calling (919) 719-1150.