Volume 2, Issue 17

January 27 -- 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 copy by clicking here. For information on how to unsubscribe, see the instructions at the end of this email.

Ask the 3Experts.....................................................................................................
 
Does OSHA require that secondary container labels have to indicate the manufacturer's name AND contact details, such as phone number and address for hazardous materials in the workplace?

There is no specific requirement for a manufacturer's name and contact information to be supplied on an in-plant or secondary label. Under Federal Hazard Communication regulations the chemical manufacturer, defined to also include chemical importers or distributors, is responsible for ensuring that each container of hazardous chemicals leaving their site is labeled, tagged or marked with the following information: (i) Identity of the hazardous    chemical(s); (ii) Appropriate hazard warnings; and (iii) Name and address of the chemical manufacturer, importer, or other responsible party [29CFR1910.1200(f)(1)]
 
Once the product is at a worksite the employer is responsible for ensuring that each container of hazardous chemicals in the workplace is labeled, tagged or marked with the following information: (i) Identity of the hazardous chemical(s); and (ii) Appropriate hazard warnings. [29CFR1910.1200(f)(5)]  Appropriate hazard warnings can be words, pictures, symbols, or a combination thereof as long as they provide at least general information regarding the hazards of the chemicals.  This information is intended to be used in conjunction with the other information immediately available to employees under the hazard communication program in order to provide employees with specific information regarding the physical and health hazards of hazardous chemicals at the worksite.  Under this definition the manufacturer's container label is sufficient.  However, if the product's original label is damaged or the product is removed from the original container into an alternate container it must be labeled with at least the identity of the chemical and appropriate hazard warnings, according to the requirements listed above, in order to be in compliance with the requirements of the hazard communication standard.  
 
OSHA has recognized, in CPL 2-2.38D (Inspection Procedures for the Hazard Communication
Standard), the use of alternative in-plant labeling systems such as the HMIS and NFPA as well as others which may be used in industry to meet the employer requirements for in-plant or secondary labels.  Employers must also ensure that their training program instructs employees on how to use and understand the alternative labeling systems so that employees are aware of the effects (including target organ effects) of the hazardous chemicals to which they are potentially exposed.  A component of this understanding would be knowledge of how to access the MSDS for the product, which would contain the manufacturer's name, address and emergency contact information.

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

How to get the most out of 3E Online-MSDS Classification Module

Did you know that you can access classification ratings and information on a per product basis online?  3E will provide the ratings (NFPA & HMIS for example) for each applicable inventory item, for an additional cost. To access this information, click on Search> enter in your search criteria> click on the product name> click on the Class link at the bottom of the page.  3E has also provided a legend for further understanding of what the ratings mean. 

In addition to the Class link, you can also access reports under Modules> Classification or Sara Reports.  These reports will give you access to information such as Main Hazard, Physical State, VOC, and Tier II Candidate List.  

 
 
Do you Have the Time, Resources and Expertise to Author MSDSs?
Most companies are challenged with keeping up-to-date with the constantly changing EH&S regulations.  Add to the pressure companies are under to reduce their EH&S costs and take into consideration the lack of time, resources and expertise available within companies to author MSDSs. 

The most practical solution is to outsource these non-core business functions to the experts - 3E Company.

Ariel MSDS Authoring service, by 3E Company, utilizes experts (authors, toxicologists, industrial hygienists, global regulatory professionals, chemists, chemical engineers, IT professionals and multi-lingual staff) to create, manage and maintain globally compliant documents including MSDSs, labels and hazardous materials transportation data.  All documents are kept up-to-date with global regulatory changes on a quarterly basis.  These authoring capabilities can be performed using your internal system or using Ariel's EH&S system, which also provides for automated distribution of MSDSs, online access to MSDSs, label management, expert rules and an EH&S library in 26 languages. Start the year off right by:

  • Reducing your authoring costs by 20-50%
  • Improving regulatory compliance
  • Improving MSDS and label turn-around times by 40-70%
  • Standardizing globally compliant MSDSs
  • Assuring professionally-authored MSDSs
  • Reallocating resources to focus on more critical EH&S functions
  • Reducing IT costs
  • Providing staffing flexibility based on business needs

Click here or call 800-346-6737 to qualify for a complimentary 1-hour consultation on your company's MSDS Authoring needs.


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

From Compliance Magazine

Beefing Up Your Emergency Response Training - More organizations are investing in emergency response programs, whether they are intended to protect employees and the facility from a terrorist attack, accident or natural disaster. A survey conducted by Compliance Magazine recently found that almost two-thirds of respondents work for companies that have increased activity in homeland protection programs.  Eighty percent plan to increase emergency response planning, while 47 percent are paying more attention to their hazardous materials security and storage.  In addition, almost 70 percent said that their additional budget dollars would be spent on training programs and resources.  All factors point to more organizations looking to beef up homeland protection programs and the training to go along with them.  Read the full story here.

From Truckline Express

DOT's HazMat Electronic Incident Reporting Available Online - DOT’s electronic hazmat incident reporting option is now available.  Motor carriers that wish to use this option for filing form 5800.1 should access DOT’s online reporting system through the following link:  https://hazmatonline.volpe.dot.gov/incident/Index.aspx.  To find out what conditions are necessary for filing your report electronically, click here.

RSPA to Ban Flammable Liquids From Tank Truck Wetlines - Last year (December 30th), RSPA published a long-awaited, controversial notice of proposed rulemaking on wetlines. The proposed rule would amend the Hazardous Materials Regulations to prohibit flammable liquids from being transported in unprotected product piping on existing and newly manufactured DOT specification tank trucks. RSPA's prohibition would take the form of a performance standard that requires that there be less than one liter of product in each pipe after it is drained. RSPA is not proposing a specific method for achieving this standard.  Read the full story here.

From Environmental Protection

EPA Proposes to Modify Toxics Release Inventory Reporting Requirements - EPA announced on Jan. 12 the first of two proposed rules intended to reduce the time and resources needed to submit annual reports to EPA's Toxics Release Inventory (TRI). TRI data and information are currently provided to federal officials by nearly 23,000 industrial and federal facility owners and operators nationwide.  Read more here.

From Occupational Hazards

OSHA Schedules Public Hearings on Hexavalent Chromium - OSHA will hold public hearings in Washington, D.C., to discuss the agency's proposed rulemaking for occupational exposure to hexavalent chromium. The hearings will begin on Feb. 1 and are expected to run through Feb. 17.  Read more here.

OSHA Inspectors Test Positive for Beryllium Exposure - After years of belittling the hazards beryllium posed to its inspectors, medical tests have revealed that at least three OSHA employees have developed blood abnormalities associated with beryllium exposure, according to a report in the Chicago Tribune.  Read more here.

EPA Studying Potential Health Risks of Chemical Used to Make Teflon - The Environmental protection Agency (EPA) is trying to determine whether a chemical used in the production of Teflon poses a health threat to people throughout the nation. Read more here.

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

Tradeshows & Conferences - Stop by and see 3E at the following events:

ASA - American Subcontractors Association National Conference
March 17-19
Omni Orlando Resort at Championsgate
Orlando, FL

GlobalChem - Global Chemical Regulations Conference
March 22-23
Hyatt Regency Crystal City, Arlington, VA

RILA (Retail Industry Leaders Association) Loss Prevention, Auditing and Safety Conference
March 29-April 1
Sheraton New Orleans
New Orleans, LA

COSTHA (Conference on Safety Transportation of Hazardous Articles)
April 3-6
Hilton San Diego Resort
San Diego, CA
Come have dinner and take a tour of 3E's HazMat Mission Control during COSTHA!  Email us for more information.

SCHC (Society for Chemical Hazard Communication) Spring Meeting 2005
April 12-13
Wyndham Phoenix Hotel
Phoenix, AZ

ABC (Associated Builders and Contractors) Safety Conference
April 20-22
Sheraton New Orleans
New Orleans, LA

EEI (Edison Electric Institute) Occupational Safety & Health Conference
April 24-27
JW Marriott Hotel
Houston, TX

3E HazMat Management Web Seminar Series:

"Are you Ready for REACH? Implications of the Proposed
New European Chemicals Policy"

A proposal for a new European chemicals policy is in review with the European Council of Ministers and the European Parliament. The initial legislative review is expected to be completed in the fall of 2005.

REACH will introduce a single regulatory framework for Registration, Evaluation and Authorization of Chemicals to replace the current dual system for assessing the risks of existing (those placed in the market before 1981 and included in the EINECS inventory) and new substances (included in the ELINCS inventory). REACH will reverse the burden of proof for testing and risk assessment from authorities to industry. Through the introduction of this regulation, the European Union will make a fundamental change in the way chemicals are controlled, directly affecting the practices of importers (and manufacturers) of chemicals in Europe. The main elements of the proposal are the collection of information on chemicals and the preparation of chemicals safety reports.

During this Web Seminar, 3E's Regulatory Specialist, Sonja Mikkelsen, will discuss the implications for companies outside the European Union, that desire to export chemicals to EU:

  • Strategies that should be considered by exporters of chemical-based products from outside Europe
  • Activities that should be undertaken today to ensure compliance with REACH when implemented
  • Differences and similarities between the current and proposed REACH regulation
  • Registration requirements and downstream user requirements for non-European companies
  • Export of chemicals to a company's overseas production facility
  • Export of chemicals for sale to Europe
  • Export of chemicals for use in the production of articles

When: Thursday, February 17

Time: 9:00 - 11:00 a.m. PST

Where:  Web browser (both audio and visual)

Register here.

 

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. 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. 

And don't forget!  Those who participate in the 2 hour Web Seminars and submit answers to the quiz will be eligible to receive certificates for certification maintenance points (CMP) credits through the Institute of Hazardous Materials Management (IHMM). 

Additionally, these Web Seminars are available for CUSA credits through the National Safety Council (NSC).

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

 
Need to Save your Company Time and Money? 
An Accurate Inventory Assessment is the Answer.
 
How important is an accurate inventory? An inaccurate inventory can lead to misguided compliance programs, misleading reporting, insufficient training and poor decision-making.  Does your company have the following issues?
  • Many of the products listed in the inventory do not exist in the actual workplace?
  • Products do not have associated MSDS data, quantities, storage locations or container data?
  • Inventories are constantly changing across locations, sites or departments?
If so, 3E Company can help with 3E’s Inventory Assessment, which provides companies with an accurate, site-specific, hazardous materials inventory report.  3E can help your company capture an accurate snapshot of your inventory, enabling you to better manage all issues associated with HazMat compliance, acquisition, disposal and ensure inventory matching for MSDS management.  Click here to learn more about 3E’s Inventory Assessment service.

 


•• Visit: www.3ECompany.com   •• Contact 3E Company ** 1905 Aston Avenue, Carlsbad, CA 92008