Audit, Compliance and Risk Blog

A recent news headline told the story of two nurses who were involved in a scuffle with the father of a newborn inside a New York hospital--apparently, the father was a high profile member of the Kennedy family. The conflict was triggered when he began to carry his infant son out of the hospital without the usual authorized procedures--at which point one of the nurses attempted to block him from leaving.

On Monday, March 26, 2012, the Occupational Safety and Health Administration (OSHA) promulgated a final rule officially adopting the Globally Harmonized System of Classification and Labeling of Chemicals (GHS) as part of the Hazard Communication Standard [29 CFR 1910.1200]. Employers that make, transport, handle or otherwise use chemicals should start now to prepare for the transition to GHS.

OSHA’s New Hazcom Explained

Everything you think you know about

about hazardous chemicals is about to change

Since the 1980s, most employers throughout the U.S. and Canada have been required to protect workers from workplace chemical hazards, and to train workers to protect themselves.  The cornerstones of these programs have been manufacturer-supplied summaries called Material Safety Data Sheets (MSDSs).  Sad to say, but sometimes they’re wobbly cornerstones, because they start with hazard information developed by company scientists for agency scientists, and may or may not extend that information into practical hands-on guidance for employers and workers.  They also vary in detail, because the Occupational Safety and Health Administration (OSHA) provides guidance for appropriate topics but no requirements that the content be practical.  While some MSDSs are fine, we’ve all grumbled about others that report clinical results of the lethal dose of constituent chemicals to half the test population (LD50), but then recommend no more than "use appropriate personal protective equipment."

Webinar Scheduled for March 7, 2012:  Headlines following catastrophic incidents such as fatal or crippling injuries, fires and explosions, lead to demands for answers as to who was at fault and how the event could have been prevented. EHS managers, auditors, operations, risk managers, and legal counsel all have a role in uncovering the potential for and preventing high-consequence/low-frequency events.

The most recent update of STP's OSHA Compliance: A Simplified National Guide alerts readers to OSHA’s new “Enforcement Procedures for Investigating or Inspecting Workplace Violence Incidents” at nursing and personal care facilities.  The Procedures are effective September 11. OSHA has long had numerous prevention guidelines targeted to employers whose establishments are likely to be at highest risk for workplace violence, and some states have issued more detailed guidance to complement OSHA’s efforts, focusing on planning, facility design, and employee training.