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Tuesday, August 26, 2014
Thursday, August 21, 2014
Hazard Communication
Good Day,
Welcome to OUR blog, our first post concerns “HAZARD
COMMUNICATION” of which I have included the precise wording for The United
States Standard and its South African counterpart.
Why begin with this section?
This in my humble opinion is where Health and Safety begins,
or intent is shown by the employer, should all employees be informed? Of that I
can affirmatively confirm – YES!
What should be communicated?
Chemical Hazards, Processes, Dust, Vapours, mechanical
hazards, biological hazards, ergonomical hazards, environmental hazards . . . I
understand that legislation has Regulations governing all hazards, however, are
we not dealing with communicating hazards?
How should it be communicated?
All companies should make it a condition of appointment,
once employee has been informed, tested and certified that they comprehend the
hazards and its consequences, only then can their employment be ratified and
their duties can commence. Booklet, hand-outs and Intranet can be used to
communicate, my problem with MSDS files are that they are never regularly
updated and procurement does not follow procedure and requirements of
disclosure, so new hazards find their way into the system. Company order forms must have a condition
attached to them that require supplier companies to disclose any substance that
may be hazardous and concentrations thereof.
Signage – Signage should be not negotiable and the
foundation of hazard communication.
My problem with both countries statutes are the following;
(a)
They focus almost exclusively on Chemical
Hazards
(b)
There is no standard for communication, should
it be pictorial/ or should it be in a hand-out written format? Or both?
(c)
What needs to be disclosed? – Only UN certified
and classified substances?
(d)
What about environmental impacts? Does the
worker not have the right to know?
(e)
Records of disclosure that must be kept?
(f)
How is outcome of training and information
measured?
|
• Standard
Number:
|
DEPARTMENT OF LABOUR
Occupational Safety and Health
Administration
29 CFR Parts 1910, 1915, 1917,
1918, 1926, and 1928
RIN 1218-AB02
Hazard Communication
AGENCY: Occupational Safety and Health
Administration (OSHA); Labour.
ACTION: Final rule.
SUMMARY: The HCS requires employers to establish
hazard communication programs to transmit information on the hazards of
chemicals to their employees by means of labels on containers, material safety
data sheets, and training programs. Implementation of these hazard
communication programs will ensure all employees have the "right-to-know"
the hazards and identities of the chemicals they work with, and will reduce the
incidence of chemically - related occupational illnesses and injuries.
This modified final rule includes a number
of minor changes and technical amendments to further clarify the requirements,
and thereby help ensure full compliance and achieve protection for employees.
In particular, the rule adds and clarifies certain exemptions from labelling
and other requirements; modifies and clarifies aspects of the written hazard
communication program and labelling requirements; clarifies and slightly
modifies the duties of distributors, manufacturers, and importers to provide
material safety data sheets (MSDSs) to employees; and clarifies certain
provisions regarding MSDSs.
South African Legislation
Section 13 - of Occupational Health and Safety Act, Act 85
of 1993 as amended.
Duty to Inform –
Without derogating from any specific duty imposed on an employer by this Act,
every employer shall –
(a)
As far as is reasonably practicable, cause every
employee to be made conversant with the hazards to his health and safety
attached to any work which he has to perform, any article or substance which he
has to produce, process, use, handle, store or transport and any plant or
machinery which he is required or permitted to use, as well as with the
precautionary measures which should be taken and observed with respect to those
hazards;
(b)
Inform the Health and Safety representatives
concerned beforehand of inspections, investigations or formal enquiries of which
he has been notified by an inspector, and of any application for exemption made
by him in terms of Section 40; and
(c)
Inform a Health and Safety representative as
soon as reasonably practicable of the occurrence of an incident in the
workplace or section of the workplace for which such representative has been
designated.
(Section 40 = the
incumbent Minister of Labour has the power to exempt any employer or user or
any category of employers or users. . .) Worrying insertion into the Act, open
to abuse?
The South African legislation is contrary
to our Constitution by including the following gender based language – HE – HIS
– HIM and requires urgent intervention.
Sunday, July 27, 2014
Why Ten Ten
Why Ten Ten?
Preserving life and limb at the work-place is our primary objective, preserving all Ten fingers and all Ten toes is our passion. . .
Join us in our endeavor to share - Information, Educate and inform as well as compliance with various legal and statutory requirements of Occupational Health, Safety and Environmental issues. . .
Our years of experience, training and application of statutes, laws and legal requirements will assist you in your application and interpretation of Occupational Health and Safety and Environmental issues.
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