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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.
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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. | |
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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.
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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. |
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