Jan & Henry W. D. Parker
Are you aware that among other things OSHA adopted revisions to their Hazardous Communications Standard that requires EVERY dry cleaner (no matter what solvent you may be using) to train their employees about virtually all the chemicals in use in the facility.
The OSHA mandated compliance deadline for you is December 1, 2013. That's right. It is less than 2 months away!
RMFA has contracted with Safety & Environmental Compliance Consultants to scheduled two training seminars to assist drycleaners in complying with the new standard S&ECC is owned by Henry and Jan Parker and is unique in our industry because they are a nationwide regulatory compliance consultant who actually guarantee their work. S&ECC has consulting experience with small and medium size businesses throughout the United States, providing total EPA/OSHA compliance programs. All S&ECC programs are turnkey, closed-loop solutions which provide you with a safe workplace and a healthy environment.
Failure to provide HAZ COM training is the #3 most popular violation during OSHA inspections.
"The only way to beat an OSHA audit is to provide the required information to them before they come into your business," said Henry Parker, S&ECC President. "My advice to clients has always been to greet the inspector at the counter and direct them to the areas they want to see but only after you prove to them that a Hazard Assessment has been done by you. This assessment must indicate you have classified the hazards and you have trained employees in the required Hazard Communication programs. The only way to prove this has been done is with written proof."
If you attend this seminar, you will be given the knowledge and tools to comply with the mandated compliance deadline.
By December 1, 2013 all employees in the United States will be required to learn the new symbols that are initiated in the HCS 2012 and the GHS because a need was found to consolidate a new easily and harmonized definition of hazards. Specific criteria have been established for labels and a harmonized format for what was the Material Safety Data Sheet (MSDS) will become the Safety Data Sheet. This may sound kind of the same but it will be different because the labels will no longer carry the Red-Blue-Yellow and White sections with numbers from 0 to 4 to indicate a hazard. The hazard will now be one of the 9 symbols in the chart below and the SDS will have a 16 section format.
According to Mr. Parker, the HCS Pictograms and Hazards are similar but not the same as those used on commercial trucks in the US now except that the colors are different. The specific hazard will show a Pictogram to describe the conditions shown in the RED diamond shape with a white background. They have changed the way hazards are defined in what were "performance-oriented" identification of hazards to a "specification" approach. They will now be Hazard Classified based on what they are rather than what they do.
The new Hazard Communication Standard carries responsibilities for manufacturers of chemicals and Shippers, Importers and Distributors as well as the customer or business that will ultimately use the chemicals in the workflow process. Just like you receive a MSDS now you will receive a SDS with your chemical shipment, this will be in place by June 1, 2016. You will be required to ultimately replace the MSDS with the SDS in your file in the future and during the transition files must be kept in an integrated fashion so as not to confuse those with the need to study the SDS.
Your current written Hazard Communication program will need to be updated and in some cases replaced unless you have been updating the information in the training part of your HazCom program since you first put it in place. It might be time to reevaluate the written program materials that you have been using to train your employees. This goes beyond the OSHA poster that you have posted on the wall (it is not a HazCom training program, it is a poster). OSHA still requires you to have a written Hazard Communication Program in place that has a training component so you can teach the employee what is required by OSHA. IF you have an ongoing relationship with a consultant or training provider you will most likely be upgraded with new program materials and training materials.
Once again, if you attend this seminar, you will be given the knowledge and tools to comply. Click here to complete the registration form to attend this seminar.