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GHS June 2015 Deadline: Is Your Good Faith Effort Good Enough?


Have you done your due diligence to meet compliance for the June 2015 GHS deadline Or is your facility hoping for a Hail Mary? Unfortunately for all facilities “good faith effort” isn’t that loop hole you’ve been waiting for if that is the case.

After many downstream chemical repackagers voiced their concerns of relying on upstream manufacturers for hazard information, OSHA responded with steps companies could take to show a “good faith effort”. Companies who prove good faith effort can avoid citation even if they were unable to obtain all information. However, good faith effort does not mean businesses now have an excuse to slack off. Good Faith effort comes with just as much work and documentation to prove that your facility has taken the time and energy to try and comply with or without the help of upstream manufacturers.

What businesses need to do
In order to present a case of good faith effort to avoid citation companies must:

  • Be able to prove that you have made multiple attempts to get the proper SDS’s from your suppliers through both oral and written means of communication
  • Keep an organized and dated filing of all communication attempts that have been made upstream and downstream
  • Provide a clear timeline downstream of when the SDSs will be made available
  • Show that you have tried to find the necessary hazard information from other sources (e.g., chemical registries)
  • “Make an effort” to classify the chemicals in your facility yourself, using available sources

What OSHA will do
All of the information companies collect will then be reviewed by OSHA on a case by case basis to determine eligibility for exemption or possible citations and fines for non-compliance through guidelines such as:

  • The process used to gather classification information from upstream suppliers and the status of the efforts
  • Efforts to find hazard information from alternative sources (e.g., chemical registries)
  • The presence of a written account of continued dialogue with its upstream suppliers, including dated copies of all relevant written communication with its upstream suppliers
  • A written account of dialogue with distributors, including dated copies of all written communication with its distributors regarding why it has been unable to comply
  • A written course of action to make the necessary changes to SDSs and labels

OSHA has stated that if a facility had not started building their case for good faith effort as of mid March of this year, they may face an up hill battle in proving their exemption.  Regardless of your eligibility for claiming a good faith effort it is necessary to complete the process of obtaining the correct information and documenting it as soon as possible.

Now Trending in Workplace Safety: Mental Health in the Workplace

Now Trending in Workplace Safety: Mental Health in the Workplace

Stress, frustration, depression, these types of mental health issues can and often do have a greater impact on company productivity than physical injuries. Around 1 million employees in the U.S. alone miss work each day due to workplace stress and depression results in more days of disability than chronic health conditions.

Much emphasis is put on the maintaining a person’s physical capabilities but just as, if not more importantly their mental health is forgotten about. Have you ever had a day where you are physically at work but your mind is somewhere else. Perhaps thinking about a sick loved one, or dwelling on a personal situation? These distractions can be just as costly as physical injuries if not more so, putting the workers themselves but also those around them in danger. Stress alone causes absenteeism, productivity losses and sick leave totaling $300 Billion, so why does this issue continue to be ignored?

If you are looking to make the mental health of your workers a priority there are easy steps your facility can take, steps that will have long lasting benefits. Engagement of your employees is key. Engaged employees tend to perform better and achieve higher productivity because they have an emotional investment in creating value for their workplace. Unfortunately engagement levels today across differing industries are very low, no easier an opportunity to increase efficiency and have it carry over into other aspects of your facility. Perhaps first steps start with creating an open line of communication for worker feedback. How are you making the mental health of your workers a priority at your facility?

OUCH! My Back! Occupations In Need of Some Ergonomic Attention

OUCH! My Back! Occupations In Need of Some Ergonomic Attention

$59,000 per employer could be saved with improved ergonomics, Do I have your attention yet? Many workers are injured on the job everyday due to little nuances and awkward movements within their job that can easily be eliminated through ergonomics.

There are 2 common approaches taken when dealing with ergonomic issues in the workplace. The first of which being reactive: taking action because something needs fixing with corrective action. This type of action would most likely arise because workers are starting to feel the effects of Musculoskeletal Disorders (MSD’s)such as carpel tunnel, tendonitis, rotator cuff injuries and trigger finger. Secondly, the proactive approach is one that actively seeks out areas that could be improved before they become a larger problem. These fixes usually take the form of equipment design or task design.

Below are the top positions that suffer ergonomic related MSD’s most:

  • Nursing assistants
  • Laborers
  • Janitors and cleaners
  • Heavy and tractor-trailer truck drivers
  • Registered nurses
  • Stock clerks and order fillers
  • Light truck or delivery services drivers
  • Maintenance and repair workers
  • Production workers
  • Retail salespersons
  • Maids and housekeeping cleaners
  • Police and sheriffs patrol officers
  • Firefighters
  • First-line supervisors of retail sales workers
  • Assemblers and fabricators

If one of these areas of work apply to your facility, consider implementing ergonomics program. No need to think of ergonomics as an overwhelming undertaking. Start small by evaluating trends in your injury reporting, this may point you to the most immediate areas of concern within your workplace.

Workplace Safety News Roundup

Workplace Safety News Roundup

Keeping track of new OSHA regulations and taking advantage of supplemental safety training and reading materials makes a large difference in the success of the programs you implement in your workplace. Seeing what others are doing both for the better and worse help mold an all encompassing safety initiative. Here is a sampling of some of the news buzzing around workplace safety this month.

The High Cost of Low Protection

The use of personal protective equipment is a vital component of workplace safety, but many employers are unduly concerned with the cost of introducing new safety measures. Ignoring the fact that the safety of your employees far outweighs the initial costs of using new PPE in your workplace, there are many reasons why you should introduce PPE and why you can actually save money by making sure you have proper hand protection in place.

Read more here

Workplace Violence: How to Protect Yourself on the Job
Nearly 2 million Americans are the victims of violence in the workplace each year, and many other cases go unreported, according to the U.S. Department of Labor. Here’s what you should know about the dangers you may face at work and what you can do to protect yourself.

Get more information here

Public Interest Groups Release Database of State OSHA Laws

Public Citizen and the Public Health Law Research (PHLR) program of the Robert Wood Johnson Foundation have released the first comprehensive database of all state occupational safety and health regulations and laws intended to protect workers from specific workplace hazards, in the 25 states with federally authorized enforcement agencies. The database is designed for workers, unions, employers, occupational safety and health researchers and advocates, and state and federal regulatory officials, as a tool to compare and contrast regulations and laws across different states and with existing federal Occupational Safety and Health Administration (OSHA) rules.

If this is your first time hearing about the database and you would like to learn more click here

Iron Company faces penalties of more than $102K for exposing workers to machine, fire and explosion hazards, lack of training OSHA cites company for 2 willful, 4 repeated, 12 serious safety violations

Once again, workers were exposed to dangerous amputation hazards* while fabricating metal products because safety mechanisms were not in place. Responding to a complaint, inspectors found during an inspection initiated on Oct. 1, 2014, two willful, four repeated and 12 serious safety violations, including lack of training and personal protective equipment. The agency has proposed fines of $102,180 for the Barron-based company.

Continue reading here

Chicago Clark Street distribution center cited for electrical hazards

OSHA initiated an inspection of the mail sorting facility after receiving a complaint alleging unsafe working conditions and found workers were exposed to various electrical hazards and issued two repeated, four serious and one other-than-serious violation with proposed penalties of $63,540.

Continue reading here