Volume 2, Issue 27

December 1 -- Happy Holidays and Best Wishes from your friends at 3E Company for a safe and wonderful holiday season!

Welcome to another issue of 3E HazMat Matters. Please forward this newsletter to any colleagues who might find it useful or have them request a subscription by clicking here. For information on how to opt-out, see the instructions at the end of this email.

In this Issue:
Ask the 3Experts
3E News
Tips N Tricks - Getting the most out of 3E services
Regulatory Alert - Transportation Regulations Taking Effect in 2006
Events - Tradeshows, Conferences & Web Seminars
Industry Articles - News you can use

Ask the 3Experts...................................................................................................

This month's Guest Expert:  Santa Clause

As the manufacturer, air transporter and distributor of many toys-- some of which could theoretically contain hazardous substances-- are you required to conform to the Federal Hazardous Substances Act like other toy makers?  And, who authors the MSDSs for the toys that may contain said hazardous substances?

Like the Tooth Fairy and Easter Bunny, I'm regulated by the DOMD (Department of Mythical Distribution) so OSHA, the DOT and other agencies have no jurisdiction over me. However, I obviously feel a responsibility to the community, environment and my adorable end-users, therefore we voluntarily avoid using dangerous substances throughout the manufacturing process.  If, however, a toy does contain something potentially hazardous, we properly label the item with warnings and print 3E Company's toll free 800 number on the package so that the parents can request a MSDS, if necessary.  Also, a number of elves on my staff are highly qualified industrial hygienists, chemical engineers, toxicologists and product stewards. They efficiently handle the small number of MSDSs required, but I have, on occasion, relied on 3E Company's staff of MSDS authors to handle over-flow situations when we are behind schedule.

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Do You Have the Time, Resources and Expertise               to Author MSDSs?

Now you can improve risk management, cost efficiency and control,
while increasing productivity

Ariel? MSDS Authoring service utilizes Ariel in-house experts to create, manage and maintain globally compliant documents including MSDSs and labels.  Authoring can be performed using your system (e.g, SAP or WERCS) or using 3E?s system. 3E can also provide MSDS distribution to your customers.  Call us to discuss the 3E difference:

  • Fully dedicated, highly qualified multi-lingual authors, not sub-contractors, so that you can talk to the regulatory expert who authored your MSDS
  • World class Ariel Regulatory and Chemical Data?the most up-to-date, comprehensive collection available? used by the leading global chemistry producing companies

Click here or call 800.346.6737 to learn more about the difference in         3E Company?s Ariel MSDS Authoring. 
 

3E News....................................................................................................................

3E's Director of Product Management, Prabhu Natarajan has been elected as chairman of the DGAC (Dangerous Goods Advisory Council) for 2006, after serving one year as vice chairman. The DGAC, also known as the Hazardous Materials Advisory Council, is an international, nonprofit, educational organization devoted to promoting safety in domestic and international transportation of dangerous goods. Read the full story here.

 

Environmental Expert published our Ask the 3Experts column in a recent issue of its newsletter.  The question was about new EU regulations of detergents and their effect on industry.  In case you missed it in a previous issue of 3E HazMat Matters, you can read it here.

 

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Tips N Tricks...........................................................................................................

3E MSDS On Demand Requests:  Have you ever requested a MSDS from 3E and the manufacturer on the MSDS did not match the Manufacturer Name I supplied to 3E?  If so, it could be the result of the following:

Distributor Name vs. Manufacturer Name: In some cases the manufacturer name used within your organization may actually be the distributor of that product and not the manufacturer. 

Manufacturer Out of Business: If a manufacturer goes out of business, the MSDS could contain the manufacturer name of the company that has purchased the rights to that product from the out-of-business manufacturer.

What to do?

  • Be sure to provide as much information about the product as possible, including Full Product Label Name, Full Manufacturer Name and Manufacturer Part Number. if applicable.
  • Be sure to provide complete product name, including color, fragrance, etc.

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Regulatory Alert..........................................................................................................
Changes to Transportation Regulations in 2006

Any company transporting hazmat or dangerous goods should be aware of some changes in regulations coming up in 2006 and be on the look out for more later in the year: 

  • IATA has published its 47th Edition.
  • TDG has published proposed amendments -- no final version is available to date, but it is anticipated that a new version will be finalized early 2006.
  • 49 CFR published several corrections and amendments to the HAZMAT Table (70 Fed. Reg. 56084; September 23, 2005). We anticipate more changes will be announced by the end of the year 2005.
  • IMDGs 2004 Edition incorporating amendment 32-04, was available for voluntary use beginning January 1, 2005 and will enter into force on January 1, 2006 without any transitional period.

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Events...........................................................................................................................

3E HazMat Management Web Seminar Series

3E is always looking for topics of interest to you to include in our HazMat Management Web Seminar Series.  Email your topic ideas to info@3ecompany.com.

Miss one of our seminars? 3E has made many of our Web Seminars, part of the 3E HazMat Management Web Seminar Series, available for replay, including our most recent seminars:

  • Dangerous Goods Safety Adviser and DGSA Work
  • Importing Products - TSCA Considerations
  • EPA Issues in Healthcare
  • HazMat, Homeland Security and International Requirements: What Companies Need to Know About Shipping HazMat
  • What Companies Need to Know About OSHA's Occupational Exposure to Hexavalent Chromium: Proposed Rule
  • Maximizing Value Creation Through Integration
  • Are you Ready for REACH? Implications of the Proposed
    New European Chemicals Policy
  • Best Practices in MSDS Authoring

Click here to access the Web Seminar topic of your choice.  Please forward this information on to any of your colleagues who may benefit from this information. 

If you have any questions about this program, please email info@3ecompany.com.

Trade Shows & Conferences

California Industrial Hygiene Council's 15th Annual Conference
December 5-7
Crown Plaza Union Square
San Francisco, CA

IEA & CMTA Environmental Conference & Expo
December 13-14
San Diego Mission Valley Marriott
San Diego, CA

For a complete list of 3E events anytime, visit the Events page on our website.

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HOW DOES YOUR COMPANY MANAGE HAZARDOUS WASTE COMPLIANCE? 

3E?s Waste Management service provides customers with professional knowledge and services to help our customers satisfy their hazardous waste management obligations from cradle to grave. 3E Hazardous     Waste Specialists negotiate the best possible contract from a nationwide network of pre-qualified contractors for hazardous waste pickups on scheduled dates or to respond to large chemical spills. 3E coordinates    the entire process, including waste pick up, transportation, disposal at a designated TSDF and reporting to appropriate federal or state agencies.  3E also scans and tracks waste disposal documentation forms such as manifests, and bills of lading related to a customer's project in for future reference and reporting purposes.  Other key features of this service include:

  • 24-7-365 access to hazardous waste professionals for customer specific guidance on waste classification, storage, labeling, transportation and disposal
  • Continuous monitoring and evaluation of hazardous waste projects
    Obtainment of Proper licenses and/or EPA ID numbers and State ID numbers
  • Electronic storage and recall of waste related documents (e.g. manifests and bills of lading)
  • Documentation on all communication related to a customer's waste management project
  • Activity and trend reporting on hazardous waste generation, storage and disposal

Click here or call 800.346.6737 to learn more!

Industry Articles:  News You Can Use..................................................................

From Occupational Health & Safety

Chemical Industry Commits To Safety In Alliance With OSHA
On Nov. 15, the American Chemistry Council (ACC) and OSHA signed an alliance to recognize and promote the common safety commitments of ACC's Responsible Care(r) initiative and OSHA's Voluntary Protection Programs (VPP) -- the first time that OSHA has entered into an agreement with an industry-wide performance improvement program.

ACC officials said the alliance identifies joint opportunities to make VPP evaluations and Responsible Care audits more efficient. Responsible Care is ACC's environment, health, safety and security performance improvement initiative. Companies implementing Responsible Care are required to implement a management system and have it certified by independent third-party auditors and report their individual safety performance on a public Web site.

OSHA's VPP promotes effective worksite-based safety and health using an assessment process of companies' safety and health management systems. Approval into VPP is OSHA's official recognition of outstanding efforts in achievement of exemplary occupational safety and health.

In addition, ACC and OSHA will work to protect employees' health and safety by sharing information, providing training and more effectively using resources with each other, ACC members, Responsible Care Partners, health and safety professionals and the public.

Details on the alliance can be accessed at http://www.americanchemistry.com
Additional information on Responsible Care can be found at http://www.responsiblecare-us.com
For information on Voluntary Protection Programs, go to http://www.osha.gov/dcsp/vpp

NIOSH Recommends Titanium Dioxide Nano Exposure Limits
NIOSH is seeking comments by March 31, 2006, on a draft Current Intelligence Bulletin, "Evaluation of Health Hazard and Recommendations for Occupational Exposure to Titanium Dioxide," that contains the agency's assessment of the most current scientific information about the powder, which is used in fine and ultrafine sizes during manufacture of paint, cosmetics, plastics, paper, food, and other products.

NIOSH Director Dr. John Howard said Nov. 23, "We encourage our partners and stakeholders to provide input and feedback before we proceed to a final document. We are also posting a link to the draft document from the NIOSH Web topic page on the occupational safety and health implications and applications of nanotechnology. We hope that the discussion of issues pertaining to ultrafine particles of titanium dioxide at the nanoscale size, that is, particles smaller than 0.1 micrometers in diameter, will also help advance our concurrent dialogue about the science relating to potential occupational health effects of nanomaterials."

The bulletin recommends exposure limits of 1.5 milligrams per cubic meter for fine TiO2 and 0.1 milligrams per cubic meter for ultrafine particles as time-weighted averages for up to 10 hours per day during a 40-hour work week. Exposures should be reduced to levels as low as feasible below those recommended limits, it says, adding that these recommended exposure limits would control occupational exposures to levels unlikely to raise a risk of work-related lung cancer, based on available evidence from laboratory animal studies. NIOSH will hold a public meeting on the document on Feb. 27, 2006; contact Christine Sofge, Ph.D., at (513) 533-8439 for information.

The bulletin is posted at http://www.cdc.gov/niosh/docs/preprint/tio2

From Occupational Hazards

Are You Ready for Z10?
Organizations looking to improve their occupational health and safety performance, productivity, financial performance, and other business objectives now have a new tool. It?s called ANSI/AIHA Standard Z10, Occupational Health and Safety Management Systems, and it is a voluntary standard designed to help businesses comprehensively integrate occupational health and safety management into business practices and systems. The American Industrial Hygiene Association (AIHA) led the development of the standard as secretariat for the Z10 Committee, which included experts from labor, government, professional organizations and industry. The standard was recently approved by the American National Standards Institute (ANSI).

?This gives you a road map to help you come up with the elements of an occupational safety and health management system, the kind that world class companies are already using,? commented Z-10 member James Smith, director of risk control services at Arthur J. Galagher?s Florida office.
Smith listed some of the elements contained in the new standard:

  • Communication;
  • Education;
  • Employee participation;
  • Management leadership;
  • How to measure if safety interventions are successful.

Smith, who represented the American Society of Safety Engineers (ASSE) on the committee, pointed to one disappointment with the final product.?This standard doesn?t identify who is to coordinate the management system process,? said Smith. ?Most companies with a management system have an EHS professional who does that.? While the committee debated this issue, Smith said no consensus was reached.?From our point of view,? commented Bill Kojola, an industrial hygienist who represented the AFL-CIO on the committee, ?there is substantial worker involvement woven throughout the entire document ? a critically important element.?

Kojola also thought the fact that the final document was approved without a single dissenting vote was a major accomplishment.?There?s been a very strong anti-regulatory environment ever since the Bush administration took over,? he said. ?It?s really quite remarkable that this document saw the light of day.?

America?s Safest Companies Share a Passion for Safety
At first blush, Occupational Hazards? 12 picks for America's Safest Companies of 2005 have about as much in common as a bag of Doritos and a gallon of Speedway SuperAmerica gasoline. Click here for the full story.

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