OSHA Updates for the Aviation Maintenance Technician Bob Gould Bravo Golf Aviation
Bob Gould Who Am I? dba Bravo Golf Aviation 47 years in aviation and aircraft maintenance Retired from US Navy and industry Teach various Human Factors, Risk Management, and SMS courses, including USC Accredited IS-BAO auditor
OSHA Updates OSHA HAZCOM and the changes to a Globally Harmonized System of Classification and Labeling of Hazards OSHA Standards for Aircraft Cabin Crewmembers (coming down the road very soon!)
HAZMAT Updates What is all the hoopla about the new HAZCOM requirements? Globalization of safety standards Called the Globally Harmonized System
Remember the Reason for HAZCOM and MSDS? Basically provides the employer and the employee with the basic information of a chemical s hazard and risk. The chemical identity, physical characteristics, and primary routes of toxic entry. Right-to-Know becomes the Right-to-Know and Right-to-Understand.
What is Globally Harmonized System? GHS is the culmination of many countries agreed upon criteria in 2003 for classifying and standardizing label elements and safety data sheets. Result of agreement is now called Globally Harmonized System of Classification and Labeling of Chemicals.
GHS Why? OSHA agreed to this concept for improving information received from international countries. New labeling and information sheets will be of a consistent manner for improved communication and safety.
Who is covered by OSHA s Hazard Communication Standard (HCS)? Chemical manufacturers and importers must convey the information downstream to customers. Distributors are required to transmit chemical safety information to customers. Employers are required to provide to employees the chemical hazards in the workplace.
What Must an Employer Do? Identify all hazardous materials in the workplace, Develop a HazCom Program, Get Safety Data Sheets (SDS) for each hazardous chemical (formerly called MSDS), Label all hazardous material containers, Design and implement an employee protection program (PPE), Train employees about the (new) standard, Assure access to SDS and written HazCom program.
Phase-in Periods What is the current required OSHA time table for this new Hazard Communication Standard? December 1, 2013 Train all employees on the new label elements and safety data sheet (SDS) format. Employer responsibility.
Phase-in Periods What is the current required OSHA time table for this new Hazard Communication Standard? December 1, 2015 Distributor shall not ship containers labeled by the chemical manufacturer or importer unless it is a GHS label. Chemical manufacturer, imports, distributors, and employers responsibility.
Phase-in Periods What is the current required OSHA time table for this new Hazard Communication Standard (HCS)? June 1, 2016 Update alternative workplace labeling and hazard communication program as necessary, and provide additional employee training for newly identified physical or health hazards. Employer responsibility.
Phase-in Periods During the phase-in period, employers will be considered in compliance utilizing either the existing HCS or the revised HCS, or both. Employers will not be required to maintain two sets of labels and SDSs for compliance purposes.
Why the December 1, 2013 Training Date Requirement? OSHA believes that the workplaces will soon begin receiving the newer labels and SDSs since many American and foreign chemical manufacturers have begun to produce the newer compliant labels. American workers need to be familiar with the newer labels and SDSs now.
What Has Changed? The revised Hazard Communication Standard (HCS) is a modification of our existing standard. Some chemical hazard evaluation standards have been changes to meet EU standards. Verbiage changes include: Material Safety Data Sheet is now Safety Data Sheet hazardous determination is now hazardous classification
What Has Changed? Major changes to the HCS include: Hazard classification: Definitions of hazards have been changed to provide more specific criteria for classification. Labels: Now has uniform verbiage, pictograms, and hazard description. Safety Data Sheets: Now has new specified 16 section format.
How Has Labeling Changed? Under the current system, the label preparer has to provide the chemical identity, and appropriate warnings. This could be done in a variety of methods and left to the preparer. Under the newly revised HCS, labels will be standardized with a Pictogram, Signal Words ( danger or warning ), a Hazard Statement, and a Precautionary Statement.
Standardized Pictograms Pictogram on the label is determined by the chemical hazard classification by the manufacturer. 9 standard labels (8 required) Health Hazard Flame HCS Pictograms and Hazards Exclamation Mark Carcinogen Mutagenicity Reproductive Toxicity Respiratory Sensitizer Target Organ Toxicity Aspiration Toxicity Gas Cylinder Flammables Pyrophorics Self-Heating Emits Flammable Gas Self-Reactives Organic Peroxides Corrosion Irritant (skin and eye) Skin Sensitizer Acute Toxicity Narcotic Effects Respiratory Tract Irritant Hazardous to Ozone Layer (Non- Mandatory) Exploding Bomb Gases Under Pressure Flame Over Circle Skin Corrosion/Burns Eye Damage Corrosive to Metals Environment (Non-Mandatory) Explosives Self-Reactives Organic Peroxides Skull and Crossbones Oxidizers Aquatic Toxicity Acute Toxicity (fatal or toxic)
The New Hazard Communication Label 1 Product Identifier 2 Supplier Information 3 Precautionary Statements 4 Hazard Pictograms 5 Signal Word 6 Hazard Statement 7 Supplemental Information
What About Workplace Labeling? Under the revise rules, OHSA has retained flexibility to permit employers to continue to use either the new GNS labels, or the currently accepted labels.
What About Workplace Labeling? Hazardous Material Information System (HMIS) National Fire Protection Association (NFPA)
How is the Material Data Sheet Changing? Now called Safety Data Sheet (SDS) 16 standardized sections Sections 1-11, and 16 are mandatory, and must comply with the new GHS system of classification and labels. Sections 12-15 have mandatory headings, but the content is optional and OSHA will not enforce due to outside agencies jurisdiction.
How is the Material Data Sheet Changing? 1 Identification 2 Hazard(s) Identification 3 Composition/Ingredients 4 First Aid Measures 5 Fire Fighting Measures 6 Accidental Release 7 Handling and Storage 8 Exposure / PPE 9 Physical / Chemical Properties 10 Stability and Reactivity 11 Toxicology Information 12 Ecological Information 13 Disposal Information 14 Transportation Information 15 Regulatory Information 16 Other Information
What Else is New Regarding the revised Hazardous Communication Standard? OSHA has added the following categories to the new SDS: Pyrophoric Gases and Simple Asphyxiants must use signal word Danger and the hazard statement of catches fire spontaneously if exposed to air Combustible Dust - signal word Danger and the hazard statement of may form combustible dust concentrations in the air
How Often will SDS be updated? UN revises the GHS on a 2 year cycle OSHA will update as required and will continue to utilize various internal agency rulemaking options such as; Technical updates Direct Final Notices Notice and Comment rulemaking
Summary GHS has revised labeling of chemicals Standardized the older MSDSs now known as Safety Data Sheets (SDS) for improved employee understanding of the hazards OSHA has mandated training date to employers for familiarization with the new labeling requirements. www.osha.gov/dsg/hazcom HAZCOM Made Easier by J.J. Keller & Assoc
AIRCRAFT CABIN and OSHA FAA Modernization and Reform Act of 2012 and becomes effective on September 23, 2013. Expands the MOA between OSHA and FAA in 2000. New policy statement that says enhance Occupational Safety and Health Administration (OSHA) standards for working conditions of aircraft cabin crewmembers while they are onboard aircraft in operation. (FAA continues health and operational standards for flight crew members).
AIRCRAFT CABIN and OSHA OSHA will have jurisdiction (enforcement) over cabin safety issues such as; Hazardous chemicals Exposure to bloodborne pathogens Hearing conservation programs Recordkeeping requirements Access to employee exposure and medical records
THANK YOU FOR YOUR ATTENTION Bob Gould Bravo Golf Aviation