Notable Safety Regulations

OSHA’s final rule to revise the Hazard Communication Standard (HCS) has spurred much discussion about new GHS label elements and the new uniform format for safety data sheets (SDS). We’ve talked about those changes in previous posts.

But what you may not have heard yet is that some standard workplace warning signs are getting a facelift. 

Just a little over halfway through the final rule document (323 pages) is a section called Workplace Warning Language on Signs and Labels, which begins this way:

OSHA proposed to update the language for workplace signs and labels to incorporate the GHS hazard statement and the applicable precautionary statement(s), where required. Most OSHA substance-specific health standards require hazard warning signs, usually for regulated areas, and the language required on the signs varies greatly… OSHA proposed to modify the language to be compatible with GHS and consistent throughout the OSHA standards.

Read on, and you’ll find that the proposed changes carried through to the final rule.

In short, OSHA is revising the wording on warning signs to be consistent with the language of GHS hazard and precautionary statements. Let’s find out what that means for facility identification.

Which warning signs are changing?

Specifically, OSHA is referring to warning signs for cancer-causing substances.

The final rule gives the example of three current hazard statements to show the need for consistent wording:

Does one statement imply a higher risk than the others? No, the intent was not to suggest tiers of cancer warnings; however, it's easy to see how someone could misinterpret the different statements to mean different hazard levels.

To prevent confusion and promote clarity, OSHA has settled on the wording “May Cause Cancer,” which will become the standard wording for carcinogen warning signs.

Table XIII-4. Regulated Areas in Substance-Specific Health Hazards summarizes the changes to the warning message for each substance.

When will the old signs be phased out?

Until June 1, 2016, employers may use the current sign language. Existing substance-specific label warnings may be used until June 1, 2015.

But why wait? Now is the time to start updating your facility signage to meet the new warning sign requirements.

Accuform offers signs and labels that reflect the new warning messages as prescribed in the final rule. Visit our Carcinogen Warning Signs section on our website, or contact us to today to learn more. 

The information provided is for general purposes only, and not to be relied upon as legal advice, legal opinion, and absolute and complete for the specific facts or circumstances. 

You may see these signs on buildings when you are out shopping, going to work, or picking up your children from school. In Florida, the signs are in the shape of a Maltese cross, while in other states, they are shaped as a circle or triangle. The question is: What are these signs, and what do they mean?

Truss signs are specific to states (or cities) and serve to identify buildings that have a light-frame, truss-type construction. What that means is repetitive wood or light steel framing comprises the primary elements of the structure.

Appearances are deceiving

Buildings that use trusses pose a greater hazard for collapse during a fire than traditional roof and floor construction. The Occupational Safety and Health Administration (OSHA) recognizes the potential hazard posed by truss signs, describing it as a “hazard to the fire service” in the publication Fire Service Features of Buildings and Fire Protection Systems. The publication states:

“Trusses are widely used in construction to span wide areas without the need for vertical supports, reducing both material and construction costs. Under ordinary conditions, trusses work well and building codes have permitted this type of construction for many years. However, trusses often fail suddenly and totally during a fire … It is impossible for crews operating at a fire to predict the time or extent of a collapse since they cannot see how many trusses are affected, which components, and to what extent.”

Thus, a building’s exterior offers no indication to firefighters as to whether or not trusses were used in the construction, and that is why truss signs are important. They provide a visual identifier to warn firefighters about the increased potential for collapse and help them determine whether or not they can safely enter the structure. 

The National Institute for Occupational Safety and Health (NIOSH) published an alert on Preventing Injuries and Deaths of Fire Fighters Due to Truss System Failures, recommending that building owners “should consider posting building construction information outside a building to advise fire fighters of the conditions they may encounter.”

No national standard

The National Fire Protection Association (NFPA) has developed voluntary standards that address fire fighter safety related to roof and floor trusses, including NFPA 1620, NFPA 1521, NFPA 1001, and NFPA 921. Some states, such as Florida in rule 69A-3.012, have incorporated NFPA standards into their truss sign laws.

However, there is no national standard for truss signs. Some states and cities have adopted truss sign laws, and although the requirements for truss signs often vary in shape and size, the signs generally share some key elements:

• The letters F, R and F/R appear in the center of the truss sign and indicate whether the Floor, Roof, or Floor and Roof use light-frame truss structures.
• The sign is required to be a bright, reflective color and/or made of a reflective material.

Accuform currently offers truss signs for Florida; New Jersey; New York; Vermont; Mississippi; San Francisco, Calif.; and Acushnet, Mass. If your state or city has truss sign regulations and you need a sign made, contact us today to find out how we can help.

The information provided is for general purposes only, and not to be relied upon as legal advice, legal opinion, and absolute and complete for the specific facts or circumstances. 

Handwashing seems like such a simple practice, but it can make all the difference in reducing the spread of infection, which is especially important in healthcare settings.

In fact, handwashing is so important that OSHA’s Bloodborne Pathogens Standard 29 CFR § 1910.1030 outlines several requirements for it.

1910.1030(d)(2)(iii). Employers shall provide handwashing facilities which are readily accessible to employees.

According to the Centers for Disease Control and Prevention (CDC), hospital patients in the United States contract nearly 2 million infections per year or approximately 1 infection per 20 patients. The CDC has a dedicated page on Hand Hygiene in Healthcare Settings that underscores handwashing as one of the most important precautions to prevent infections from spreading.

1910.1030(d)(2)(iv). When provision of handwashing facilities is not feasible, the employer shall provide either an appropriate antiseptic hand cleanser in conjunction with clean cloth/paper towels or antiseptic towelettes. When antiseptic hand cleansers or towelettes are used, hands shall be washed with soap and running water as soon as feasible.

The bottom line is that using soap and water is the most effective method for reducing the spread of infection. However, alcohol-based antiseptics provide an alternative solution when soap and water aren’t available. The CDC recommends using an alcohol-based hand sanitizer containing at least 60% alcohol but warns that hand sanitizers do not remove all types of germs.

1910.1030(d)(2)(v). Employers shall ensure that employees wash their hands immediately or as soon as feasible after removal of gloves or other personal protective equipment.

Gloves can help reduce the spread of infection but are not an alternative to handwashing. The World Health Organization (WHO) published a document called WHO Guidelines on Hand Hygiene in Healthcare (2009). They conducted several studies regarding the role of gloves in preventing the spread of infection and concluded that “gloves reduce hand contamination, but do not fully protect from acquisition of bacteria during patient care.”

1910.1030(d)(2)(vi). Employers shall ensure that employees wash hands and any other skin with soap and water, or flush mucous membranes with water immediately or as soon as feasible following contact of such body areas with blood or other potentially infectious materials.

Is there a right way to wash your hands? The CDC web page Handwashing: Clean Hands Save Lives outlines the proper steps for handwashing:

• Wet your hands with clean, running water (warm or cold) and apply soap.
• Rub your hands together to make a lather and scrub them well; be sure to scrub the backs of your hands, between your fingers, and under your nails.
• Continue rubbing your hands for at least 20 seconds. Need a timer? Hum the "Happy Birthday" song from beginning to end twice.
• Rinse your hands well under running water.
• Dry your hands using a clean towel or air dry them.

Post visual reminders

Yet for all the awareness and evident need to wash hands regularly, OSHA’s Hospital eTool  on Healthcare Wide Hazards reports that “compliance with hand washing by healthcare providers is poor.”

Accuform Signs offers several stock handwashing signs, as well as a hand hygiene poster, and custom solutions to create your own unique reminders. Visit our website, or contact us to learn about how we can help you create visual identification solutions for your facility to encourage proper hand washing.

What do the U.S. Military and the Revised Hazard Communication Standard (HCS 2012) have in common?

Uniformity requirements. Uniforms identify a soldier’s class or division and send a clear message about required protocol. Similarly, the uniformity requirements of OSHA’s Revised Hazard Communication Standard (HCS 2012) set defined expectations for Safety Data Sheets (SDS).

Published in the Federal Register on March 26, 2012, the final rule aligns HCS 1910.1200 with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). One of the many changes is the move from a performance-oriented to a uniformity-oriented approach or standardized format for Safety Data Sheets (SDS), previously called Material Safety Data Sheets (MSDS).

New Provisions

Under HCS 2012, SDS must be in a uniform format that includes at least the required section numbers*, headings and associated information. This format basically follows the ANSI standard format, which includes the following (taken from pages 449-450 of the final rule).

Section 1. Identification.
Section 2. Hazard(s) identification.
Section 3. Composition/Information on ingredients.
Section 4. First-aid measures.
Section 5. Fire-fighting measures.
Section 6. Accidental release measures.
Section 7. Handling and storage.
Section 8. Exposure controls/personal protection.
Section 9. Physical and chemical properties.
Section 10. Stability and reactivity.
Section 11. Toxicological information.
Section 12. Ecological information*
Section 13. Disposal considerations*
Section 14. Transport information*
Section 15. Regulatory information*
Section 16. Other information, including date of preparation of the last revision.
 

*Sections 12-15 are considered non-mandatory, meaning that they fall outside of OSHA’s jurisdiction and will not be enforced. However, OSHA includes them in Appendix D to 1910.1200 – Safety Data Sheets to show what sections a fully GHS-compliant SDS would have to include.

Retained Requirements

Many provisions remain the same from HCS 1994 but have been re-numbered in HCS 2012. These include the following:

• Employers must have an SDS in the workplace for each hazardous chemical used (1910.1200(g)(1),(g)(8)).
• SDS must be readily available to employers in their work areas and during their shifts (1910.1200(g)(8)).
• SDS must be in English (1910.1200(g)(2)).

For a full list of SDS requirements, refer to the Safety Data Sheets section of OSHA’s side-by-side comparison of HCS 1994 with HCS 2012.

Compliance Dates

The phase-in dates for compliance with the revised SDS requirements are as follows:

• By December 1, 2013, employers must train employees on new safety data sheets.
• By June 1, 2015, all SDSs must be in the uniform format as prescribed in HCS 2012.

In the meantime, OSHA has established a “Transition Period” where chemical manufacturers, importers, distributors and employers may comply with either 29 CFR 1910.1200 (the final standard) or the existing HCS 1994 or both.

The information provided is for general purposes only, and not to be relied upon as legal advice, legal opinion, and absolute and complete for the specific facts or circumstances. 

A patient unexpectedly jerks, and the needle dislodges, puncturing the nurse’s finger. It was just a prick. But the patient might be HIV positive. The nurse feels his blood go cold.

This scenario is far too close to home for many healthcare professionals.

• The Centers for Disease Control and Prevention (CDC) show that between 600,000 and 800,000 occupational needlestick injuries occur annually, leading to serious or potentially fatal bloodborne pathogen infections.
• The Occupational Safety and Health Administration (OSHA) estimates 5.6 million healthcare workers risk exposure to bloodborne pathogens.

In 2001, OSHA updated its Bloodborne Pathogens Standard 29 CFR §1910.1030 to include the requirements for safer needle device selection as mandated by the Needlestick Safety and Prevention Act (NSPA). The revision established requirements for employers to identify and effectively use safer medical devices, and understand in greater detail the need for engineering controls to help eliminate worker exposure.

According to a study by The New England Journal of Medicine, sharps injuries fell by about 38% in 2001 after NSPA legislation took effect and have remained lower since then, based on information to date. Legislation has helped pave the way for safer healthcare practices, but certainly even one needlestick injury is still one too many.

Finding out more

There is a wealth of resources available to healthcare professionals, and my research barely scratches the surface. However, if you’re looking for available healthcare tools and standards information, you might find the sources below helpful.

• OSHA’s page on the Bloodborne Pathogens Standard Revision provides a summary of the revision requirements, including engineering controls, exposure control plan, documentation, and much more.
• OSHA also has a Hospital eTool page that provides information on Needlestick/Sharps Injuries.
• The International Sharps Injury Prevention Society (ISIPS) website focuses on reducing needlestick and sharps injuries around the globe. Their Sharps Injury Resources page contains helpful links for more information.
• The Centers for Disease Control and Prevention (CDC) has published a NIOSH Alert on Preventing Needlestick Injuries in Health Care Settings. This document talks about the risk of needlestick injuries and transmitted bloodborne infections that healthcare professionals face.
• The CDC also has an Emergency Needlestick Information page on how to respond to a needlestick incident.
• The Online Journal of Issues in Nursing (OJIN), a scholarly journal of the American Nurses Association (ANA), has a publication that discusses Needlestick and Sharps Injury Prevention.

According to the CDC/NIOSH, “The emotional impact of a needlestick injury can be severe and long lasting, even when a serious infection is not transmitted.” Preventing needlestick injuries through proper engineering controls, safe medical devices and proper handling/disposal procedures is critical to the safety of healthcare employees.

How we can help

This month, Accuform Signs released its first Prospect Catalog with a Healthcare Industry focus. The product focus includes a selection of items designed to help meet the unique needs of healthcare facilities.

If you’re in charge of safety at your location and would like to learn more about our product solutions geared toward healthcare settings, visit Accuform.com/health.

Back in January, I wrote about distracted driving and the need for drivers to be aware that the rules differ from state to state. I’d like to follow up to that post by talking about the discussion that’s been spurred by the call for a nationwide ban on portable electronic devices (PEDs) by the National Transportation Safety Board (NTSB).

In December of last year, the NTSB issued a press release calling for a nationwide ban on driver use of any PED. This proposed ban would apply to all drivers – not just federal and commercial employees.

Rules already in place

There are currently rules on the books that prohibit commercial drivers from using hand-held PEDs. The most recent took effect this January when the Federal Motor Carrier Safety Administration (FMCSA) implemented a new law banning commercial truck and bus drivers from using hand-held cell phones while driving. To learn more about this ban, read the news release announcing the final rule; for more information on the U.S. Department of Transportation's (DOT) regulatory campaign, visit distraction.gov.

Similar policies apply to federal employees. Back in 2009, President Obama signed an Executive Order prohibiting federal employees from texting while driving – and encouraging contractors and other businesses who work with the government to implement similar texting policies.

The key is that these bans only apply to hand-held devices. The NTSB is calling for an end to both hand-held and hands-free cell phone use – for all drivers.

As I talked about in my earlier post, many states have their own distracted driving rules in place, but to date, there’s nothing on a national level. And that’s why the debate is heating up.

Watching the reaction

While most people agree that texting while driving isn’t safe, they don’t agree about whether or not to ban drivers from using PEDs altogether.

The reaction to the NTSB’s call for a cold turkey ban on cell phone use has been interesting to watch. I follow the ANSI/ASSE SH&E Standards Information Center LinkedIn group, and one discussion on Distracted Driving showed the varied responses people have to the proposed ban, ranging from:

• Yes, a nationwide ban on all hand-held and hands-free devices is needed.
• No, best practices and driver education are preferred to mandatory rules.
• No, we shouldn’t tailor “one-size-fits-all” rules to the least competent person.
• Yes, more regulations are good but should exclude hands-free devices.
• No, distracted driving takes many other forms as well – like eating/drinking, grooming, smoking, music, etc.

Motor Trend provides insight into how members of the automobile industry view the proposed ban in a post called NTSB’s Cell Phone Ban Recommendation – Why It’s Unenforceable. Author Edward A. Sanchez makes a case for the use of hands-free devices in cars and the need for the NTSB to work with the electronics and auto industries “to try to find a reasonable middle ground that finds a way to safely and reasonably accommodate technology that has become integral to tens (if not hundreds) of millions of Americans, without resorting to a sweeping, absolute mandate that for all intents would be practically unenforceable.”

Clearly, there’s more debate to come. Take a minute to voice your opinion using the Quipol poll below. I welcome your comments.

In a press release yesterday, the U.S. Department of Labor (DOL) announced that OSHA has revised its Hazard Communication Standard §1910.1200 to align with the United Nations’ Globally Harmonized System (GHS). The Final Rule will be published in the Federal Register on March 26, 2012 and becomes effective 60 days after publication.

OSHA has updated its Hazard Communication page with a wealth of information about the revised requirements, designed to provide consistency in chemical hazard identification. Here’s a quick summary of some highlights.

Chemical labeling

Employers must now use chemical labels as specified under the revised rule or approved alternatives. On their questions and answers page, OSHA clarifies that acceptable alternatives include the National Fire Protection Association (NFPA) 704 Hazard Rating and the Hazardous Material Information System (HMIS) as long as these formats present no conflicting information (e.g., hazard warnings or pictograms).

OSHA provides a sample label to show what information compliant labels must contain – the same key components identified in the UN’s document.

• Pictograms
• Signal word
• Hazard & precautionary statements
• Product identifier
• Supplier identification

Safety Data Sheets

Under the revised Hazard Communication Standard, Safety Data Sheets (SDS) - no longer called Manufacturer Safety Data Sheets (MSDS) - will follow the ANSI standard 16-section format. Important to note is that OSHA will not mandate Sections 12-15 since other agencies regulate this information. 

Pictograms

OSHA has created a Quick Card™ to identify the nine pictograms and outline what hazards each represents. The Environment pictogram is considered non-mandatory since environmental hazards fall outside OSHA’s jurisdiction.

All pictograms must have a red border - no exceptions.

It’s time to get busy

The Final Rule becomes effective 60 days after publication. OSHA's Fact Sheet outlines what that means for compliance dates. I've reframed that information (shown below) to answer the big Who, What, and When.

Stay tuned for more on GHS in the coming weeks. For available GHS solutions from Accuform Signs, visit our GHS product page.

The information provided is for general purposes only, and not to be relied upon as legal advice, legal opinion, and absolute and complete for the specific facts or circumstances.

A few weeks back, I wrote a post on NCHRP Report 350, a standard to which many of our facility and traffic products have been tested. I want to follow up to that post by talking about the more recent update to NCHRP-350 known as MASH or the Manual for Assessing Safety Hardware.

The purpose of MASH, like NCHRP-350, is to provide criteria and standards for evaluating new safety hardware devices. According to the FHWA, MASH is “the new state of the practice for the crash testing of safety hardware devices for use on the National Highway System (NHS).”

If you’re like me, you’re probably wondering why we needed new testing criteria and what exactly that means for products already tested to NCHRP-350. Well, I’m glad you asked.

Why was updated crash testing needed?

Just think about the style and size of trucks today versus back when you were growing up. Today, we have the Ford F450, available with king cab, dually with an 8-ft bed, 6” lift kit and 33” mudders. (No, I’m not a truck expert… I just have brothers.) I’m not sure what the “cool” truck model was back when I was a kid, but I doubt it was half the size of this monster.

The size factor helps explain the reasoning behind the revised testing criteria. The NCHRP-350 testing standards date back to 1993. Increased vehicle size, in addition to rising truck bumper heights, helped drive the changes in crash testing requirements.

The FHWA provides a helpful comparison chart between the old and new requirements. For example, vehicle weight increased from 1,800 lbs. to 2,420 pounds for the small car test and from 4,400 lbs. to 5,000 lbs. for the light truck test. Other factors that changed include impact angle and windshield damage, to name a few.

For more information on performance testing, visit the FHWA’s Roadside Hardware Policy and Guidance.

What about products already tested to NCHRP-350?

As of January 1, 2011, new or revised safety hardware must be tested to MASH criteria and can no longer be tested using NCHRP-350. However, here are some key points to remember about products previously tested to NCHRP-350: 

• Hardware tested to NCHRP-350 prior to the adoption of MASH may continue to be manufactured and installed.
• Hardware tested to NCHRP-350 prior to the adoption of MASH does not require retesting based on the MASH criteria.
• Products accepted under both NCHRP-350 and MASH are appropriate for use on new construction and reconstruction projects.

Basically, the “grandfather” rule applies to products tested and accepted prior to January of last year. However, any product not previously tested to NCHRP-350 must be evaluated to meet the revised, more rigorous MASH testing requirements.

The information provided is for general purposes only, and not to be relied upon as legal advice, legal opinion, and absolute and complete for the specific facts or circumstances. 

Effective March 15, 2012, the U.S. Department of Justice (DOJ) requires compliance with the Americans with Disabilities Act (ADA) 2010 Standards for Accessible Design. Published in the Federal Register on September 15, 2010, the 2010 ADA Standards document replaces the 1991 version.

Among the accessibility provisions outlined are signage requirements designed to assist people with physical challenges. Understanding these requirements is a must for anyone in the business of manufacturing ADA compliant signs.

Where to find signage requirements

There are two sections in the 2010 Standard that address signage. The first is section 216, which provides the scoping requirements for signs. In other words, it talks about signs based on where and how they are used, such as “Directional and Informational” and “Means of Egress.” For each situation, the standard references the specific sign features and requirements found in section 703 which describes the communication elements and features of compliant signage.

Section 216 starts off with a list of signs exempt from the standard and then moves right into what signs must comply.

216.2 Designations. Interior and exterior signs identifying permanent rooms and spaces shall comply with 703.1, 703.2 and 703.5…

That statement begs the question of what defines a “permanent” room or space.

What constitutes a permanent sign

The DOJ published Guidance on the 2010 ADA Standards for Accessible Design which offers an answer to this question. The document clarifies under the section heading 216 and 703 Signs that:

… [T]he exception for temporary signs applies to signs used for seven days or less.

Industry expert Craig Berger cautions that this definition is not as clear as it seems, because it doesn’t specify if the “seven days” refers to the duration of the sign or the timeframe in which a facility operates. Berger offers this explanation: “This gray area is often construed to mean facilities that can’t quickly be repurposed for another use should be marked with a permanent designation.” To read his entire article, click here.

For more information on the revised requirements, visit the ADA Home Page and find the 2010 ADA Standards for Accessible Design link. Then, check out the sections on signage referenced above.

How Accuform Signs can help

Designing custom ADA compliant signage is easy with Accuform Signs. We will help you develop attractive Braille signs that conform to requirements and complement your facility.

1. Specify your sign size. Be aware that sign size and design will determine the number of characters and rows allowed.
2. Convey your message. Provide your message or legend, and we will format it for you. Be sure to let us know if you want to include a slide insert area.
3. Pick your colors. Do you want a single- or multi-color sign? There is no extra charge for using more than one color. Just remember that the ADA requires characters to contrast with their background. For more information on contrast, see section 703.5.1 of the standard.
4. Add optional symbols. Symbols enforce the meaning of your message and communicate across language barriers. ADA requires that symbols be at least 6” high with equivalent text description and accompanying Grade 2 Braille directly underneath. For more information on pictograms, see section 703.6.
5. Include graphic elements. Create a sign that complements your corporate identity and interior design. Add full-color graphics at no extra charge!

For online ordering information, check out our Custom ADA Braille Signs page.

If you need tactile and visual identification for your facility, contact us today to see how we can help you create ADA compliant signage. 

The information provided is for general purposes only, and not to be relied upon as legal advice, legal opinion, and absolute and complete for the specific facts or circumstances. It is your responsibility to ensure your sign complies with state and local building code requirements.

Back in kindergarten, we learned that reading starts with the alphabet, and the alphabet starts with A-B-C. End of story, right?

Depends who you ask. According to the American Heart Association, there is a time and place where your A-B-C’s might not be the wise choice to remember.

In 2010, the AHA released the 2010 AHA Guidelines for CPR and ECC, as well as a Guidelines Highlights document that summarizes the recommended changes to CPR. Some of the key revisions require relearning some basics.

Forget A-B-C

At the top of the list is the change from A-B-C (Airway, Breathing, Chest compressions) to C-A-B (Chest compressions, Airway, Breathing) in the Basic Life Support (BLS) sequence.

The American Heart Association believes that a change in the BLS sequence might help prevent hesitation on the part of bystanders to administer CPR. After all, which would you rather do: clear a complete stranger’s airway and provide mouth-to-mouth rescue breaths or give chest compressions?

That’s not a trick question. According to the AHA, the reason fewer than 50% of cardiac arrest victims receive bystander CPR is that people are reluctant to start CPR by opening the airway and delivering rescue breaths.

The AHA believes that starting the BLS sequence with chest compressions will help encourage bystanders to take a more active role. Additionally, starting CPR chest compressions should remove the delay caused by clearing the airway first (as in the old A-B-C sequence), allowing the victim to receive chest compressions immediately.

Hands-Only CPR for Bystanders

The 2010 Guidelines also draw a distinction between how a trained versus an untrained rescuer should respond. The revised guidelines encourage untrained bystanders to practice “Hands Only” CPR or chest compressions until help arrives.

The trained rescuer should also begin with chest compressions, but unlike the bystander, should follow compressions with rescue breaths.

Simplify “Look, Listen, Feel”

Another change is a simplification of the old adage “Look, Listen and Feel” to judge whether or not someone needs CPR.

The argument behind removing this step is that precious time may be wasted in the process. Instead of “Look, Listen and Feel,” the AHA says to quickly access whether the adult victim is not breathing or not breathing normally (gasping). Then, immediately begin chest compressions.

Be Prepared

According to the American Red Cross, one quarter of Americans have encountered someone who needed CPR. 
  

The American Red Cross offers Citizen CPR classes at local chapters. At 30 minutes long, the class is not a huge time investment – but it may be one of the best investments you’ll make if your child decides to swallow a candy cane at Christmas, your coworker takes too big a handful of M&Ms, or the person in line behind you at the supermarket goes into cardiac arrest.

To learn more, check out the American Red Cross information on Getting Trained, and locate the Red Cross chapter nearest you.

Raise Awareness

Accuform Signs offers several posters* that reflect the 2010 AHA Guidelines. They are ideal for posting around the office or facility to help raise awareness for adult CPR.

So just remember: When you think about CPR, take a moment to mentally shuffle your A-B-Cs to C-A-B.

Relearning the CPR sequence and taking time to understand some basic life procedures could save a life one day.

*Accuform's CPR posters are based on Accuform's interpretation of the AHA Guidelines and are intended to provide an overview, not comprehensive guidance, for emergency CPR. Users are responsible for determining the product's appropriateness for their respective situations. When in doubt, always consult a medical authority, the American Heart Association or the American Red Cross. 
 

As of January 1, 2011, the International Air Transport Association (IATA) implemented new requirements for packaging of limited quantities shipped by air. Effective January 1, 2012, the International Maritime Organization (IMO) began enforcing new limited quantity requirements for packages shipped by vessel.

In light of these changes, let’s take a moment to understand labeling procedures for limited quantities. 
 

What is a Limited Quantity?

According to the United States Postal Service (USPS), a limited quantity “is the maximum amount of a specific hazardous material exempted from DOT labeling or packaging requirements in 49 CFR...” In other words, a limited quantity is an allowable amount of a restricted, hazardous material otherwise required to meet specific packaging requirements.

How the material is transported determines how it should be labeled, and that is where the revised labeling standards come into play.

Limited Quantities by Air  

If a limited quantity material ships by air, it falls under the authority of the IATA. The 52^nd Edition of the IATA Dangerous Goods Regulations became available September 2010 and took effect January 1, 2011. It addresses Dangerous Goods in Limited Quantities in Section 2.7, requiring a new mark in place of the text “LTD QTY” (previously required on the Shipper’s Declaration).

Limited Quantities by Vessel

 If a limited quantity material ships by vessel, it falls under the authority of the IMO. The revised edition of the International Maritime Dangerous Goods (IMDG) Code is mandatory as of January 1, 2012 with voluntary compliance beginning January 1, 2011.

Placement & Appearance of Labels

The U.S. Department of Transportation (DOT) amended its Hazardous Materials Regulations to align with international standards. In 49 CFR Part 172.315, the DOT provides details on the placement and appearance of the new marks/labels. Included are the following requirements:

·         Must be durable, legible and sized relative to the package

·         Must be applied on at least one side or one end of outer packaging

·         Overall dimensions: minimum of 100 mm (4 inches) on each side unless reduced label size of 50 mm (2 inches) is required

·         Shape: square-on-point (diamond)

·         Appearance: Top and bottom portions and line forming the diamond must be black with a white center

·         For transportation by aircraft, the limited quantity mark includes the black symbol “Y” located in the center of the square-on-point.

·         For transportation by vessel (excluding aircraft), the limited quantity mark excludes the symbol “Y”

For more information on limited quantity shipping requirements, refer to 49 CFR Part 172.315 or visit the IMO’s and IATA’s websites.

The information provided is for general purposes only, and not to be relied upon as legal advice, legal opinion, and absolute and complete for the specific facts or circumstances. 

Last month, we did product and catalog training with our sales staff, and one of the questions we asked our team was this: What standard must work zone traffic control devices meet? Some of them guessed MUTCD, the Manual on Uniform Traffic Control Devices, which defines the national standards for all traffic-related products, including those used on public streets, highways and private roads.

This was a good guess, but it wasn’t specific enough. The answer we were looking for was NCHRP-350.

NCHRP-350 stands for National Cooperative Highway Research Program Report 350 and is a part of FHWA (Florida Highway Administration) policy that provides crash testing guidance for traffic control devices used in work zones. The standard was published in 1993 and implemented in 1998. 
 

Who Is Responsible for NCHRP-350 Compliance?

The FHWA requires that traffic control devices used in work zones on the NHS (National Highway System) meet the crashworthy requirements of NCHRP-350. A device is considered “crashworthy” once it has met the testing criteria of NCHRP-350 and/or has been issued an Acceptance Letter from the FHWA.

When we think of a work zone and traffic devices, the image that comes to mind is a construction team on the side of the road.

But there’s much more involved behind the scenes than we realize, and that’s where the responsibility of compliance rests.

An article by Water & Wastes Digest explains the shared responsibility this way: “State and local transportation departments would have to ensure their NHS projects comply with the new ruling or risk losing federal funds for a given project. Road contractors would need to use devices that comply with the ruling or risk losing the project. Traffic-control companies would need proof their devices are FHWA-accepted to win projects. And traffic-control device manufacturers will need to show that their devices are crashworthy to obtain sales.”

That said, the reference to NCHRP-350 in a safety product catalog clearly means more than meets the eye. The responsibility of compliance affects multiple levels of interest – from the manufacturer to transportation departments. 
 

Types of Work Zone Devices

Most safety product catalogs, including our own, provide a general organization for work zone products. The NCHRP-350 crash testing guidance goes beyond general product groups by breaking down work zone devices into four specific categories.
 

1.     Category 1 refers to lightweight devices which can be self-certified by the manufacturer. These include cones, barrels, and delineators.

2.     Category 2 refers to lightweight devices, such as barricades and sign stands, that require individual crash testing.

3.     Category 3 refers to barriers and other fixed or large devices that require crash testing.

4.     Category 4 refers to trailer-mounted devices and similar devices, such as arrow panels.

For more information on the types of categories, refer to the FHWA’s website page on Crashworthy Work Zone Traffic Control Devices.

Additional Resources

If you’re looking for additional information on work zone traffic control devices and crash testing requirements, some of these resources may be helpful:

·         NCHRP Report 350

·         Manual for Assessing Safety Hardware (MASH)

·         Work Zone Mobility & Safety Program

·         Work Zone Positive Protection Toolbox

The next time you see the short phrase “Meets NCHRP-350” in a catalog product description, don’t just skim over it. Remember that a product tested to this standard is guaranteed to perform dependably and withstand required impact levels. 
 

 The information provided is for general purposes only, and not to be relied upon as legal advice, legal opinion, and absolute and complete for the specific facts or circumstances. 

One of the hot topics in the international commerce community is GHS, the Globally Harmonized System of Classification and Labeling of Chemicals. This system encompasses everything from a new format for material safety data sheets (MSDS) – now referred to as simply safety data sheets (SDS) – to new container label and chemical classification requirements, and much more.

There has been a good deal of discussion on what the system involves, and this post is not going to attempt to delve into the details. (If you want in-depth, check out the United Nation’s 568-page fourth revised edition.)

What I would like to do is take a step back, review a little GHS history, and talk about where the Occupational Safety and Health Administration (OSHA) is today in terms of aligning its Hazardous Communications Standard (HCS) 29 CFR § 1910.1200 with the GHS.

A Little History on GHS

First, why create an international system for classifying and labeling chemicals? The answer boils down to a need for uniformity. Global trade involves all types of workers – from production, handling, and transportation – all the way down to end users. These people vary in language, literacy and comprehension of chemical labeling requirements.

Moreover, the information on labels and SDS can vary for the same chemical from one country to the next. When you start combining varying levels of comprehension plus different requirements by country, the ensuing risk compromises not only safety, but also the effectiveness of trade from one country to another.

In 1992 at the United Nations Conference on the Environment and Development (UNECD), the United Nations set forth the agenda for a worldwide program that would provide a consistent, harmonized system to address the classification of chemical hazards on labels and SDS. The resulting GHS program defines the structure for harmonizing the rules and regulations on chemicals at national, regional and worldwide levels.

GHS Compliance

An important parenthesis is that the GHS itself is not a regulation or a standard. Rather, it is a voluntary system designed for the international community to use as guidance for creating or revising existing regulatory structures.

However, the term “voluntary” is not synonymous with “optional.” OSHA’s Guide to the GHS explains it this way:

“The GHS is a voluntary international system that imposes no binding treaty obligations on countries. To the extent that countries adopt the GHS into their systems, the regulatory changes would be binding for covered industries. For countries with existing systems, it is expected that the GHS components will be applied within the framework/infrastructure of existing hazard communication regulatory schemes… However, the specific hazard criteria, classification processes, label elements and SDS requirements within an existing regulation will need to be modified to be consistent with the harmonized elements of the GHS. It is anticipated that ALL existing hazard communication systems will need to be changed in order to apply the GHS.”

Here’s another way to look at compliance. We’ve all heard the expression, “If you want to play the game, you have to follow the rules.” If a country wants to be competitive in international trade, implementing the GHS structure into its regulatory standards is not an option.

OSHA and GHS

That said, where is the United States, or more specifically, OSHA, in adopting the GHS? On September 30, 2009, OSHA’s Department of Labor (DOL) published a Proposed Regulation to modify the existing HazCom Standard (HCS) to conform to the GHS. Public hearings occurred in the spring of 2010. The final rule is forthcoming – expected sometime early this year.

So what does that mean for those who must comply with new regulations once the final rule is published? The Proposed Regulation offers some insight:

(1)     Within two years from publication, employers will need to train employees on new labels and SDS.

(2)     Within three years from publication, chemical manufacturers, importers, distributors, and employers will need to fully comply with the revised standard.

Getting Ready for GHS

In the meantime, perhaps you are wondering how you can prepare for the GHS today. There are several good articles out there that offer suggestions, including the following:

• ISHN’s Get ready for GHS
• ICC Compliance Center Blog’s Get Ready… Get Set… GHS!!!
• Industry Week’s How to Convert to the Globally Harmonized System of Chemical Classification

Or, if you are interested in doing some additional research on GHS, some good resources to review include:

• OSHA’s Hazard Communication page on The Globally Harmonized System for Hazard Communication
• OSHA’s Facts on Aligning the Hazard Communications Standard to the GHS
• OSHA’s Guide to the GHS
• United Nations Economic Commission for Europe
• Health Canada’s Overview of the GHS

Until OSHA publishes the final rule, the story remains “hurry up and wait.” For now, the best advice is simply this: get ready.

Take down the tree. Toss the tinsel. It’s a new year, and the holidays are behind us. Many Americans will be heading home after the holidays and over 90% will be driving, according to the Bureau of Transportation Statistics. Impatient to get home, most probably won’t consider that distracted driving laws on cell phone and texting use vary from state to state.

Plan Ahead 

While some states have handheld bans only, others have handheld and texting bans. In some states, cell phone and texting bans apply only to “novice drivers” or young drivers.

Some resources that will help you understand your state’s cell phone and texting laws, while also helping you plan for the road trip home, include the following:

• Distraction.gov provides a summary of distracted driving laws by state.
  
• Governors Highway Safety Association (GHSA) provides a chart outlining state cell phone and texting laws and offers additional resources to learn more about distracted driving.
  
• Insurance Institute for Highway Safety (IIHS) provides a table and state maps for handheld bans, young driver bans, and texting bans.

Enforcement Varies from State to State

The type of enforcement is another variable to consider in understanding distracted driving laws by state.

If handheld cell phone use or texting falls under primary law enforcement, then you could be pulled over and ticketed for just that offense alone. For example, California has a handheld ban with primary enforcement. If you’re caught using a cell phone while driving in this state, an officer can pull you over even if you aren’t breaking any other driving law. That ticket will cost you $159, according to ca.gov.

If cell phone or texting violations are enforced as a secondary law, you won’t be ticketed unless you have first been pulled over for a different driving offense.

Some states, like Montana and Ohio do not have any current bans for distracted driving. Florida is another similar state, operating under preemption law that prevents local jurisdictions from implementing bans on distracted driving. For more information, visit distraction.gov.

Not So Common Sense?

Common sense safety says to avoid cell phone and texting use while driving. Just take a look at the statistics. According to the National Safety Council (NSC), 23% of crashes or an estimated 1.3 million crashes per year can be attributed to talking on cell phones or texting while driving.

However, if you find yourself crossing state lines on your road trip home from the holidays, you may need to remember more than just your common sense – or you could find yourself with a ticket in place of the cell phone in your hand.