2021 Summer Leader - Chemical Safety & Hazard Communication

VOL8/NO3/SUMMER 2021 CHEMICAL SAFETY & HAZARD COMMUNICATION





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CONTENTS VOL 8 | NO 3 | SUMMER 2021 FEATURES 32 SPECIAL SECTION: 24 COLUMNS OSHA’s Proposed Changes to the Planning for and 6 Message from the Chairperson HazCom Standard Preventing Chemical 8 Women in Safety Emergencies: 10 A Safety Management SECTIONS System Approach Chemical Safety 36 Membership Corner and Hazard By Phil N. Molé 38 Ad Index Communication 39 Infographic Corner 28 By the Occupational Safety & Health Administration Hazard Communication: Lessons From the Field 12 By Mackenzie Barnwall, MS, What It Means for You GSP, and Megan Scherer, Safex By Glenn Trout 32 16 The Future of Soil Will History be By Warren Silverman, MD Repeated? FACOEM, Medical Director, Workplace Forensics LLC By Lawrence P. Halprin, Partner, Keller & 34 Heckman LLP Protect Yourself 20 Against Chemical Hazards on the Job HazCom Leading Indicators: Written by the International Implementation Under Safety Equipment the VPP Elements Association (ISEA) By Michelle Zapanta Control Board Operator, Step-Up Operations Supervisor, Industrial Fire Fighter, former Lead VPP Coordinator and current Chairperson for the Employee Safety Leadership Team Valero Benicia Refinery vpppa.org Leader—Summer 2021 5

A Message From the VPPPA Chairperson I cannot think of a better Hello my fellow VPPPA members, organization than the VPPPA for you or your T he summer sun is in high gear and so is the VPPPA! Our membership is spending organization to partner this summer sharing and caring as they always have. Many of our Regions will with in achieving be holding virtual and in-person events throughout the year and we encourage long-lasting Safety & you to participate. We also encourage everyone to register for our Safety+ Symposium, Health Excellence. August 31–September 2, at the beautiful Gaylord Opryland in Nashville, Tennessee. We are excited to be partnering with Region IV in hosting this event. Bonus: if you’re still wary of traveling (or you’re receiving this issue too late to make travel plans), you can attend Safety+ virtually. With all the exciting events occurring and opportunities available to the VPPPA membership, I reflect on the true meaning of partnership. Its simple definition is, “parties agree to cooperate to advance their mutual interests.” In the world of Safety & Health Excellence this definition certainly applies. Obtaining and maintaining excellence almost mandates that you surround yourself with successful and talented people. I cannot think of a better organization than the VPPPA for you or your organization to partner with in achieving long-lasting Safety & Health Excellence. The VPPPA has recently enhanced its partnership with the Board of Certified Safety Professionals (BCSP) and established a new partnership with the Health and Safety Council (HASC). Additionally, we have partnered with an advocacy firm (LobbyIt.com) to assist us with our efforts in educating members of Congress and creating an advocacy page on our website. We encourage you to visit our website and use the email writing link to ensure your voice is heard on Capitol Hill. We believe all our partners enhance our collective mission capabilities. We look forward to sharing more about what we are working on with our great partners soon. Partnerships can also be on an individual basis. We all have a network of people that help make us better. Seeking new people to be part of your network is something all of us should do to be successful. I can’t think of a better way to increase your network and gain new partners than by participating in this year’s national & regional events. We are gearing up and looking forward to all of our partners demonstrating their sharing and caring spirit during this year’s Safety+ Symposium. I am very excited at the opportunity to see my VPPPA family and friends again. I am equally excited about meeting new people and adding to my network of partners in achieving Health & Safety Excellence. See all of you soon! —T erry Schulte, Chairman—National VPPPA Board of Directors We are better together! 6 Leader—Summer 2021 vpppa.org

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Women in Safety Guest Author: Adele L. Abrams, Esq., CMSP President, Law Office of Adele L. Abrams PC www.safety-law.com What Do Women Want? Safety! VPPPA Presents… “WHAT DO WOMEN WANT?” decisions. Fortunately, more resulting in significant liability Women in Safety is a question sometimes arising manufacturers are now for the employer. in romantic comedies . . . but marketing PPE designed for VPPPA is excited to when it comes to workplace women, but the challenge is Workplace violence is the introduce a new column safety, the needs of women are getting employers to purchase it. number one cause of death for for the Leader magazine: no laughing matter. Hazards women in the workplace, with Women in Safety. While causing injury and illness Ergonomic issues can many of these fatal injuries the safety industry is still a to women in the workplace also impact women workers occurring in the health care male-dominated industry, are not necessarily unique disproportionately. Often, and social services sectors. This the number of women is to that gender, but the data women working in construction is why OSHA is now focusing increasing each year. It’s shows that women may be suffer musculoskeletal disorders efforts on these sectors in its important to identify and disproportionally harmed. because of their smaller hand pending rulemaking activities, communicate the issues Clearly, issues surrounding size, and lower grip strength, and the Spring 2021 Regulatory that women face. keeping female workers safe which is inconsistent with the Agenda calls for a draft rule to warrants additional study. design of many tools. One union be considered for small business Each issue of the Leader, study found that women have impact in December 2021. we will be including an There are myriad factors that higher rates of sprains/strains article from a prominent can contribute to elevated on- and nerve conditions of wrists/ High risk factors include: woman working in the the-job injuries and illnesses forearms than men—likely due safety and health industry. for female workers, but one to assignment of more repetitive • Working alone, at night, or in If you, or someone you obvious one is the lack of tasks and the tool design. In know, would like to write for appropriately fitting personal addition, with reduced upper isolated or high crime areas. this column, please contact protective equipment (PPE). body strength, women may be VPPPA at communications@ Respirators, safety harnesses, more prone to back problems • Working with volatile or vpppa.org. protective shoes, gloves, from repetitive lifting. The coveralls, hardhats, safety solution is to design the job to unstable people. goggles, and even welding gear, the worker, not to avoid hiring may not be properly sized for women in the construction or • Handling money or valuables. women because, historically, heavy industrial workforce. • Providing services or care. most manufacturers used the • Working where alcohol is male anthropomorphic models Women in construction and for design. mining may also be adversely served. affected by lack of access OSHA is clear that PPE must to appropriate sanitation In addition, all workers can properly fit each affected facilities on the job. OSHA become targets during mass employee. If a respirator does recognizes lack of clean shootings by strangers, which not form a tight seal, heightened facilities (including temporary occur everyplace from bars to chemical exposures will occur. If johns) as a citable hazard, retail stores to schools—these clothing is loose, it can become because the lack of safe toilets are all somebody’s workplace. caught in moving machine and drinking water can lead to Some workplace violence cases, parts, resulting in death or bladder and kidney issues. such as the recent tragedy in injury. A 2014 study by Mt. Sinai San Jose, CA, involve worker- Hospital found that a majority The lack of locks on portable on-worker homicide, while of contractors were not mindful facilities can also be a safety others may involve domestic of the “PPE fit” issue and never issue. One construction company violence that spills into the considered design for women reported that a female worker workplace. While some states during their PPE purchasing was sexually assaulted inside of a bar employers from restricting portable facility by a supervisor, guns on company property, this is not universal, and employers should implement rules where legal. Some states have now adopted laws protecting victims of domestic violence from 8 Leader—Summer 2021 vpppa.org

employment discrimination, such hazards such as enhanced • Reviewing training materials Another area which can occur when an security and training. warranting more employee notifies the employer to ensure they are gender/ research is whether that a restraining order is Recognition that addressing race/ethnicity neutral, and Occupational in place against a spouse or hostile work environments is include positive images of Exposure partner and the employer key to prevention of workplace diversity of workers. Limits (OELs) does not want to address any violence has also become for hazardous necessary precautions. part of the “DEI” initiatives • Providing safe and sanitary chemicals and air (Diversity, Equity, and contaminants are Too often, employers focus Inclusion) adopted proactively restroom facilities for workers. appropriate for both prevention efforts on criminal by many employers, as well men and women. or active shooter events, and as being an element in Total • Raising awareness of ignore the broader definitions, Worker Health programs. The viewing the issue from an National Safety Council has workplace violence occupational safety and health adopted the slogan “You can’t prevention related to gender perspective. NIOSH defines be safe if you don’t feel safe” to (and race, ethnicity, age, workplace violence as “violent urge employers to implement disability) and implementing acts (including physical effective training and policies. DEI training where needed assaults and threats of assaults) to ensure that everyone feels directed toward persons at Finally, another area safe and is free from a hostile work or on duty.” OSHA defines warranting more research work environment. it as “any act or threat of is whether Occupational physical violence, harassment, Exposure Limits (OELs) for The bottom line is that intimidation, or other hazardous chemicals and air workplace protections must threatening disruptive behavior contaminants are appropriate be effective for all workers, that occurs at the worksite.” for both men and women. regardless of gender. This can include incidents of NIOSH has studied the impact bullying or sexual harassment on women occupationally and assault. Those reporting exposed to substances including such harassment or assault are Ethylene oxide, PCBs and also protected under OSHA’s Perchloroethylene concerning whistleblower protections, development of possible embedded in Section 11(c) cancers, but older OELs are of the Occupational Safety & based on studies involving Health Act, and incorporated by primarily white males and reference into 29 CFR 1904.36. should be revisited. Moreover, in the Johnson Controls case, the OSHA CPL 02-01-052, U.S. Supreme Court held that Enforcement Procedures for refusing to hire women who Investigating or Inspecting could become pregnant, because Workplace Violence, states: of concerns about the impact “Workplace violence is of workplace chemicals on fetal recognized as an occupational development, violated Title VII hazard in some industries of the Civil Rights Act. and environments which can be avoided or minimized if Proactive solutions include: employers take appropriate precautions.” The CPL instructs • Additional study and sharing OSHA inspectors to cite the General Duty Clause if there of resources by employers is evidence the employer and organizations. recognized the existence of a potential workplace violence • Inclusion of women (and hazard affecting employees, and if there is a feasible means minorities) in OHS research of preventing or minimizing to ensure they are adequately represented in studies of chemicals, PPE, and more. • Ensuring that there is parity in workplace training and mentoring. vpppa.org Leader—Summer 2021 9

SPECIAL SECTION OSHA’S PROPOSED CHANGES TO THE HAZCOM STANDARD CHEMICAL SAFETY AND HAZARD COMMUNICATION By the Occupational Safety & Health Administration OSHA first promulgated the hazard communication standard (HCS) in 1983 to provide a standardized approach to workplace hazard communications associated with exposure to hazardous chemicals. At that time, the HCS covered only the chemical manufacturing industry. OSHA updated the HCS in 1987 to expand coverage to all industries where workers are exposed to hazardous chemicals. In 1994, OSHA promulgated an additional update to the HCS with technical changes and amendments designed to ensure better comprehension and greater compliance with the standard. The agency believed that the HCS should be continually updated to incorporate the progression of scientific principles and best approaches for classification and communication. 10 Leader—Summer 2021 vpppa.org

T he agency also had a by maintaining alignment – Potential to align OSHA is currently commitment to work reviewing comments with international with trading partners such as with WHMIS submitted by trading partners to stakeholders. In develop an internationally Australia, New Zealand, the – Would allow for addition, OSHA will be harmonized hazard holding an informal communication standard EU, and Canada. Additionally, claiming prescriptive hearing on September and was involved in working 21, 2021, for interested with the UN Sub-committee since implementing the 2012 concentration ranges stakeholders to provide of Experts on the Globally additional comments Harmonized System of HCS, OSHA has provided for materials claimed as to the record. Classification and Labelling of Chemicals (UN SCEGHS) from stakeholders with numerous trade secret its inception. The first edition of the UN GHS purple book (which letters of interpretation to – Proposing prescriptive provides the building blocks for classifying chemical hazards) address issues with the new concentration ranges as was published in 2002. The Globally Harmonized System classification and labeling mandatory if claiming of Classification and Labelling of Chemicals (GHS) provides a system. The proposed update CBI for range common and coherent approach to classifying to the HCS addresses many ° Small packages chemicals and communicating hazard information. of these issues. In all, the • ° HNOC and PNOC Improve alignment with In 2012, OSHA updated the proposed modifications to HCS to incorporate and align other U.S. agencies with the GHS. The 2012 update the HCS fall under four was based on the 3rd revision of ° Department of the GHS. The GHS is updated general categories: and revised every two years Transportation based on information and • Maintain alignment with experience gained by regulatory GHS Rev. 7 – Bulk packaging agencies, industry, and non- ° Appendix A (health – GHS pictogram governmental organizations. hazards): mostly editorial ° Since 2012, the GHS has been – Revised health hazard EPA updated five times, and has definitions for shipment recently published its 9th – Updated skin corrosion/ – Release revision (2021). irritation and serious The agency has preliminarily On February 16, 2021, OSHA eye damage/eye determined the proposed published a notice of proposed modifications will enhance the rulemaking (NPRM) to update irritation chapters effectiveness of the HCS by the HCS. This is part of the ensuring that employees are notice and comment rulemaking – General updates to appropriately apprised of the process which includes receiving chemical hazards to which they comments and information hazard classes may be exposed, thus reducing from public stakeholders. the incidence of chemical- ° Appendix B related occupational illnesses The NPRM proposes to align and injuries. As part of the the HCS to the GHS Rev. 7 while (physical hazards): rulemaking process, OSHA has exploring whether OSHA should asked for stakeholder input on include certain elements from – Flammable gases— the efficacy and feasibility of the 8th revision, such as updates these proposed updates. to chapter 3.2 with expanded expanding hazard non-animal test methods. OSHA is currently reviewing The agency anticipates that categories comments submitted by these updates should help stakeholders. In addition, OSHA facilitate international trade – Desensitized explosives will be holding an informal – Aerosols—including hearing on September 21, 2021, for interested stakeholders to an additional hazard provide additional comments to the record. Information category regarding the hearing and comment process can be ° Appendix C (label found at https://www.osha.gov/ hazcom/rulemaking. Once OSHA elements) has closed the comment period, the agency will promulgate a – New or updated hazards, final standard based on the entire record which includes updated guidance, and comments and information received through this precautionary statements rulemaking process. – ° Appendix D (SDS) Updates to SDS Sections 9, 11 • Address issues that have come to light since implementation of the 2012 HCS; ° Release for shipment ° Small packages labeling • ° Safety Data Sheets Alignment with Canada; ° Concentration ranges for confidential business information (CBI) or trade secrets vpppa.org Leader—Summer 2021 11

SPECIAL SECTION OSHA’S PROPOSED CHANGES TO THE HAZCOM STANDARD WHAT IT MEANS FOR YOU By Glenn Trout Earlier this year, the Occupational Safety and Health Administration (OSHA) published a Notice of Proposed Rulemaking (NPRM) to update the Hazard Communication Standard (HazCom) to align with Revision 7 (Rev 7) of the UN’s Globally Harmonized System of Classification and Labelling of Chemicals (GHS). As one of the industry’s leading GHS / HazCom experts, I’ve received many questions about the NPRM and its proposed changes. This is understandable, since this NPRM would bring the first formal revision of the HazCom Standard since 2012, and the proposed changes are likely to have major impacts on chemical product users throughout the supply chain. Following is a breakdown of the proposed changes and some of the most common concerns I’ve heard from EHS professionals looking to prepare for the coming changes. 12 Leader—Summer 2021 vpppa.org

But First, Some products and develop new SDSs the classification of aerosols This NPRM would Background and shipped container labels. differ from their current bring the first formal Information classification under HazCom revision of the Let’s take a deeper look 2021. OSHA believes that under HazCom Standard Before I dive into the proposed at these changes, starting HazCom 2012, flammable since 2012, and the changes that would align with the reason OSHA is aerosols are either classified proposed changes HazCom with Rev 7 of GHS, it’s proposing to change the way as gases under pressure or are likely to have important to understand how that desensitized explosives flammable aerosols, or both. major impacts on we got here. are classified. “Desensitized OSHA also maintains that chemical product explosives” are chemicals non-flammable aerosols are users throughout the In 2012, OSHA revised that are stabilized to currently either not classified supply chain. HazCom to align it with GHS suppress their unstable and at all or classified as gases and introduce its concepts to the explosive properties through under pressure. U.S. regulatory framework as methods such as wetting part of a larger global adoption with water. Under HazCom The NPRM states that the of GHS. Changes included 2012, desensitized explosives current classification of aerosols updated hazard classification, are currently classified as is largely based on information the introduction of the explosives and are represented pertaining to the transport standardized 16-section Safety by the “exploding bomb” of compressed gas cylinders, Data Sheets (SDS), new labels pictogram. HazCom 2012 which OSHA now believes does elements and employee training addressed the special handling not accurately represent the on the changes. This was the precautions for these chemicals hazards of aerosol containers first update to HazCom since through hazard statements. (which have different structure 1994 and was widely viewed and characteristics than gas as a major shift for employers However, the UN had added cylinders, including failure covered by the standard. a new separate hazard class for mechanisms) as used and stored “desensitized explosives” to in workplaces. OSHA’s proposal At that time, HazCom 2012 the GHS (associated with the in the NPRM is to expand the was based on GHS Rev 3. The UN flame pictogram rather than existing Flammable Aerosols updates and revises the GHS on the exploding bomb) to better hazard class (appendix B.3) to a biannual basis. While the most ensure that users receive the include non-flammable aerosols, current version as of this writing specific information they need as well as flammable aerosols. is Rev 8, OSHA is proposing about procedures to stabilize Non-flammable aerosols would an update to align with Rev 7 and safely work with these now be under Category 3 and (which the UN published in chemicals. OSHA agrees that a flammable aerosols will be 2017) with consideration of new hazard class is warranted under Category 1 or Category 2. specific elements of Rev 8. In and proposes to classify these Additionally, categories 1 and the NPRM, OSHA clarifies that chemicals in Categories 1 2 would be associated with the it is not proposing to change (lowest explosive hazard) flame pictogram, while Category the fundamental structure of through Category 4 (highest 3 would have no associated HazCom, but is instead seeking explosive hazard). Under the pictogram. These proposed to maintain alignment with NPRM, chemicals that have changes would help ensure that the GHS and address specific the properties of desensitized users have more accurate and implementation issues identified explosives would be placed representative information since the 2012 rulemaking. within this new category regarding the hazards of aerosols. unless they have a corrected Changes in Hazard burning rate higher than 1200 Another question I’ve Classifications kilogram per minute (kg/ received is whether pyrophoric min), or are chemical products gases were already defined Some of the biggest proposed intentionally designed to be as a hazard class under changes include changes explosive, such as pyrotechnics/ HazCom 2012, and what would to classification for several fireworks. In those cases, change with the proposed categories of hazardous manufacturers would classify rule. Pyrophoric gases were chemicals, including flammable them as explosives and use the specifically included in the gases, aerosols, and desensitized exploding bomb pictogram. definition of a hazardous explosives, with the latter chemical in paragraph (c) of defined as a new hazard class. Some correspondents have the HazCom Standard starting These changes will require asked for additional clarity on with the 1994 version of the manufacturers of affected how the proposed changes to products to reclassify their vpppa.org Leader—Summer 2021 13

SPECIAL Standard. When OSHA revised would revise SDS and labeling on the outer packaging label, SECTION the HazCom Standard in 2012, it requirements with new as OSHA had also stated in the continued to include pyrophoric proposed warning language 2013 guidance document. OSHA’S PROPOSED gases within the definition of and precautionary statements CHANGES TO THE a hazardous chemical even to help clarify chemical The NPRM also proposes HAZCOM STANDARD though pyrophoric gases were hazards to workers. Other a new requirement that not classified within GHS Rev proposed changes introduce manufacturers would need to 3 with which OSHA aligned the entirely new statements for provide instructions with the HazCom Standard at that time. hazard classes and categories shipment stating that when which would require many the containers are not in use, Following 2012, OSHA chemical manufacturers, they are to be stored within the continued to work with the importers, and suppliers to outer packaging containing UN Sub-Committee of Experts revise and update SDSs and the full shipped container label on the Globally Harmonized labels for certain products. information. These instructions System of Classification would help ensure that end and Labelling of Chemicals OSHA’s proposed rule aims users have better access to all of (UNSCEGHS) to get pyrophoric to make the standard more the information on the shipped gases added to the GHS. effective in certain unique container label. OSHA agrees with the current circumstances, such as for inclusion of pyrophoric gases labeling of small containers. While stakeholders have within the GHS as Category 1A The labeling of individual asked about the use of electronic flammable gases and proposes small, shipped containers labelling systems—like QR to follow that classification is currently required under codes on shipped container in the HazCom Standard. The HazCom2012, however the labels—the NPRM does not proposed change would help NPRM proposes to codify include a proposal to allow it. ensure that users receive better an allowance for using However, OSHA does invite communication about the abbreviated label information public comment on whether specific hazards and associated on “small containers” that OSHA should consider doing precautions to be followed for was first provided in a 2013 so in a future revision of pyrophoric gases. guidance document released the HazCom Standard and by OSHA, while also more acknowledges that there are Some have also asked if there precisely defining a “small international efforts “actively are any updates to combustible container” as 100 milliliters promoting the application of dust classifications. While there (mL) or less in capacity. electronic labels for chemicals.” are no proposed updates or revisions of combustible dust For more information on OSHA has participated in classifications themselves in small container labelling, discussions about QR codes the NPRM, OSHA has stated VelocityEHS has a great free and has typically expressed that manufacturers would need eBook, “Guide to Labeling awareness of potential to assess whether ordinary Small Containers.” (https:// benefits, along with some use of their product would www.ehs.com/white-papers- reservations about how to generate combustible dust, and-guides/guide-to-labeling- ensure that such a system and if so, to include that in the small-containers/) would, in practice, maintain classification of the product and a high level of protection provide the “combustible dust” Additionally, the NPRM for workers. For example, classification on the product proposes a new allowance in a 2019 public meeting, shipped container label, as well for “very small containers,” Maureen Ruskin, Deputy as in Section 2 of the SDS. defined as less than 3 mL, that Director of OSHA’s Directorate allows manufacturers to put of Standards & Guidance Labels and SDS only the product identifier stressed the importance of Content Amendments on the immediate container having immediate access to the if they can demonstrate chemical safety information While the proposed HazCom that affixing a label to the provided on container labels, revisions do not necessarily container would interfere with and that require workers change the existing the intended use. However, to go elsewhere to obtain requirements for hazards to be manufacturers following that information could add communicated to downstream either allowance would need additional steps to that process. users and workers through to provide the full shipped It will be interesting to see what labeling and SDSs, they container label information develops in the future on this 14 Leader—Summer 2021 vpppa.org

issue as OSHA receives feedback provide new shipped labels provide workplace HazCom No matter where a from stakeholders, and as OSHA and SDSs. training on the changes. company is in the continues to participate in chemical supply chain, UNSCEGHS discussions about • Distributors would also need to OSHA will most likely not there will be a lot of the benefits of digitalization. issue a final rule until late in work they will need ensure they obtain any updated 2021, at the earliest. OSHA to do to get up to Application of SDSs and shipped container will be holding an informal speed with new the Changes labels from upstream public hearing on September HazCom requirements. suppliers and provide them to 21, 2021, at 10:00 AM Eastern In the general sense, the downstream users. Time (ET). The key takeaway HazCom Plan to determine proposed rule does not change is that changes are coming. if you need outside help in any general requirements for • End-users/employers would With modifications to existing managing its elements. A good manufacturers, distributors, hazard classifications and chemical management software or end users. They will need to make sure to update the addition of new hazard solution—like VelocityEHS— continue to have the same their SDS library with any classes, hazardous product can simplify compliance with broad responsibilities they newly re-authored SDSs. If manufacturers, importers hazardous communication currently have under HazCom, they have chemicals affected and distributors in the U.S. requirements and improves meaning that: by the classification changes, will need to re-evaluate the workplace chemical safety. they would need to train their hazards of the products they What’s more, they have an in- • Manufacturers and importers employees on the updated sell or import into the country house team of SDS Authoring classifications and information to ensure product hazards and chemical safety experts still need to classify their changes, such as changes are classified according that can help ensure SDSs are chemicals, develop SDSs to hazard statements and to GHS Revision 7 hazard 100 percent in-compliance and shipped container labels pictograms, and potentially classification criteria. with hazard communication based on those classifications, update their written HazCom regulations and chemical and provide the SDSs and Plan where appropriate. Many SDSs and shipped safety best practices around shipped container labels to container labels will need the globe. Lastly VelocityEHS’ downstream users. While there are no changes to to be re-authored to reflect Emergency Response Service general training requirements changes in chemical hazard can help you improve workplace • Distributors in the middle of proposed in the NPRM, because classification or information safety regarding chemicals the proposed rule would and ensure compliance with with on-the-spot chemical the chemical supply chain change key aspects of HazCom, updated requirements. Specific exposure support to prevent need to provide SDSs and including the ways that several industry sectors identified serious injuries, and even save shipped container labels to categories of hazardous by OSHA within the NPRM lives in the event of a chemical downstream users. chemicals are classified and as being most affected by emergency. Toxicologists and the shipped container label the proposed rule include medical technicians are on call • Employers/end users who elements, employers would chemical manufacturing, at all times to provide critical need to identify whether they oil and gas extraction, and chemical safety information have hazardous chemicals have chemicals affected by plastics and rubber products and escalated incident reporting in their workplace need to those changes in the workplace. manufacturing. Downstream through a convenient hotline. maintain a written HazCom In that case they would need to users will also need to be Plan, an up-to-date chemical train their workers on changes prepared to manage the Glenn Trout is a VPPPA Region inventory list, a library to any classifications, SDSs, influx of updated SDSs as they V Board Member and one of the of SDSs for all hazardous shipped container labels, and enter the workplace, and to industry’s leading GHS / HazCom chemicals that employees associated HazCom elements revise their written HazCom experts with more than 20 years can access without barriers, such as hazard pictograms. Plans and HazCom training of experience in the EHS industry. a system for managing as needed to account for new shipped container labels and It is important to remember classifications and new hazard workplace container labels. these changes also impact the and precautionary statements. They must also provide written HazCom Plan. The HazCom training to all classifications of several classes Software to the Rescue employees who work with of hazardous chemicals are hazardous chemicals. changing, as well as associated No matter where a company label elements such as hazard is in the chemical supply That said, all of these pictograms. Employers will chain, there will be a lot of groups may have specific need to assess whether they work they will need to do things to address once the have chemicals in the workplace to get up to speed with new proposed changes become affected by the proposed HazCom requirements. Now effective, including: classification changes, and is a good time to review your those that do will need to update • Manufacturers and importers their written HazCom Plan and will need to reclassify some classes of hazardous chemicals and develop and vpppa.org Leader—Summer 2021 15

SPECIAL SECTION OSHA’S PROPOSED CHANGES TO THE HAZCOM STANDARD WILL HISTORY BE REPEATED? By Lawrence P. Halprin, Partner Keller & Heckman LLP, [email protected] In the long term, the OSHA Hazard Communication Standard (HCS) is likely to be one of the most significant standards ever adopted by OSHA in terms of lives saved and injuries and illnesses avoided. It also has one of the highest initial and ongoing costs of compliance1 (something that OSHA stubbornly refuses to acknowledge in consistently understating the costs of hazard classification, preparation of safety data sheets and labels, and employee training). This creates a compelling need for OSHA to make every reasonable effort to ensure the requirements of the HCS are developed and implemented to achieve their objectives in the most cost-effective manner and that the compliance obligations are fairly imposed on the appropriate party in a manner consistent with generally recognized principles of chemical safety and within the bounds of what Congress intended in Section 6(b) of the Occupational Safety and Health Act. 1 JAMES JR., H., Estimating OSHA compliance costs, Policy Sciences 31: 321-341, 1998. https://link.springer.com/ content/pdf/10.1023/A:1004478930401.pdf 16 Leader—Summer 2021 vpppa.org

T he statement by Winston (HCS) to conform with the period is permitted when underline, bold language inserted Churchill, “Those that United Nations’ (UN) Globally the required information by the author to clarify OSHA’s fail to learn from history Harmonized System of from the upstream supplier apparent intent as stated in the are doomed to repeat it,” Classification and Labelling is not available in time Preamble to the proposed rule):2 appears particularly applicable of Chemicals (GHS). . . . OSHA for a downstream user- to the pending rulemaking to is also proposing to modify manufacturer to comply with (d)(1) Chemical manufacturers revise the HCS, which is the provisions of a number of the proposed revision to the and importers shall evaluate most frequently amended and other [OSHA] Standards . . . to HCS as currently structured. chemicals produced in their by far the most complex OSHA ensure consistency with the This issue was not adequately workplaces or imported by standard ever adopted by the modified HCS requirements. addressed in the HCS 2012 them to classify the chemicals agency. rulemaking. The proposal in accordance with this Most, if not all, of the to establish a compliance section. For each chemical, In the Summary of the major issues encompassed deadline of 14 months for those the chemical manufacturer February 16, 2021 Federal in the objective described as “reviewing” substances and 26 or importer shall determine Register notice announcing this “address[ing] issues that arose months for those “reviewing” the hazard classes, and where rulemaking, OSHA stated: during the implementation of mixtures is helpful but hardly appropriate, the category of the 2012 update to the HCS” adequate in the complex each class that apply to the OSHA is proposing through could have been avoided with chemical industry where the chemical being classified this notice of proposed more effective communication chemical distribution system under normal conditions rulemaking (NPRM) during the HCS 2012 involves tiers of manufacturers of use and foreseeable to modify the Hazard rulemaking. They now appear and user-manufacturers, and emergencies [anywhere in Communication Standard to be the critical issues of the one manufacturer’s mixture is the chain of manufacture, (HCS) [1] to conform to the pending rulemaking. the raw material for another distribution, and use]. United Nations’ Globally user-manufacturer’s chemical The hazard classification Harmonized System of The substance of the reaction. These concerns were shall include any hazards Classification and Labelling relatively narrow changes to brought to OSHA’s attention associated with a change in of Chemicals (GHS) Revision the mandatory classification in the HCS 2012 rulemaking, the chemical’s physical form 7 (GHS, Rev. 7), [2] to criteria and the almost but apparently were not given or resulting from a reaction address issues that arose wholesale changes to the adequate consideration because with other chemicals under during the implementation required precautionary industry generally raised them normal conditions of use of the 2012 update to the statements that would be on a generic basis rather than [anywhere in the chain of HCS, and [3] provide better brought about by adopting providing a sufficient number manufacture, distribution, alignment with other U.S. GHS, Rev. 7 will introduce of specific examples. and use]. Employers are not agencies and international additional complexity and required to classify chemicals trading partners, without uncertainty. They will On no single issue is the need unless they choose not to lowering overall protections require time and resources for specific examples of the rely on the classification of the standard. for retraining and to revise infeasible burden of compliance performed by the chemical most of the existing safety greater or more important than manufacturer or importer for In the Summary of the data sheets (SDS) and labels the proposed changes to the the chemical to satisfy this September 30, 2009 Federal for the hazardous chemicals general hazard classification paragraph (d)(1). Register notice announcing imported and produced in the provisions of 29 CFR 1910.1200(d) the rulemaking that led to the United States. There will be (1) and the corresponding [Table D.1 Section 2] . . . adoption of the current HCS the recurring issues of when provisions, in the mandatory (c) Hazards identified (known as “HCS 2012”), the revised requirements go SDS template in Appendix D under normal conditions OSHA stated: into effect, whether a phase- of the HCS. With the proposed of use that result from a in period is permitted, what changes, those provisions would [downstream] chemical OSHA is proposing to extension of the compliance read as follows (new language in reaction (changing the modify its existing Hazard Communication Standard 2 The following excerpts from the February 16, 2021 Federal Register Notice should eliminate any doubt: OSHA also proposes to add a new sentence to paragraph (d)(1) stating that the hazard classification shall include any hazards . . . resulting from a [downstream] reaction with other chemicals under normal conditions of use. OSHA believes this language is necessary because there has been some confusion about whether chemical reactions that occur [downstream] during normal conditions of use must be considered during classification. The agency’s intent has always been to require information on SDSs that would identify all chemical hazards that workers could be exposed to under normal conditions of use and in foreseeable emergencies (see paragraph (b)(2)). This issue has been raised, for instance, when multiple chemicals are sold together with the intention that they be mixed together [downstream] before use. For example, epoxy syringes contain two individual chemicals in separate sides of the syringe that are mixed under normal conditions of use. While OSHA intends for the hazards created by the mixing of these two chemicals to be considered in classification, those hazards need only appear on the SDS . . . and not on the label. vpppa.org Leader—Summer 2021 17

SPECIAL chemical structure of include reactions with other manufacturing that product, SECTION the original substance or chemicals at the downstream and the supplier’s employees mixture) . . . facility provided by another presumably were exposed to OSHA’S PROPOSED supplier and not involved the hazards of that reaction CHANGES TO THE [Section 10] . . .(c) Possibility of in the same process as the and its reaction products HAZCOM STANDARD hazardous reactions, including supplied chemical). during those activities. Viewed those associated with in light of the current proposal, foreseeable emergencies . . . OSHA had never previously it appears OSHA would have taken the position that the the manufacturer/importer Under OSHA’s interpretation upstream manufacturer/ classify both chemicals for of this language, the chemical importer was required by the the hazards of the chemical manufacturer/importer would HCS to classify its chemical reaction and reaction products. be required to identify all uses to reflect the hazards of The syringe would be a of its chemical that are known planned downstream chemical container and an article. or could be discovered by due reactions of its chemical diligence, and then classify its and the products of that The second unique example chemical to reflect: reaction on a broad generic cited by OSHA in support of (1) All hazards of the chemical basis. Rather, it had asserted its position was the mixing that position, without any of ready-mix cement and as shipped; persuasive authority, in three water. The ready-mix cement (2) All hazards resulting from unique situations. The first can only be used with water. involved the manufacturer Under OSHA’s proposal, the changes in the physical of epoxy syringes containing utility company would need to form of the chemical (such two individual chemicals in prepare an SDS for its processed as reduction to respirable separate sides of the syringe water, which would become a or nano size, reduction to that are mixed under normal hazardous chemical because combustible dust, removal conditions of use. OSHA was of its potential use in water- of solvent to leave asked whether, in performing reactive reactions. residual solute); the hazard classification, the (3) All hazards posed by all manufacturer/importer was The third example cited by downstream reactions of required to take the hazards OSHA in support of its position the chemical in the US— of the chemical reaction into was the combustion of fuels. including planned reactions, account. Possibly influenced Those fuels perform their unique intermediates, upset by its understanding of function through combustion conditions, by-products, and tort law, OSHA answered and that circumstance cannot be decomposition products; in the affirmative, without used to support OSHA’s position (4) All hazards posed by all meaningful explanation. that the current HCS requires the downstream reaction OSHA’s response seems upstream supplier to classify its products of the chemical appropriate in that context chemical to reflect the hazards of in the US—including where the supplier designed downstream chemical reactions. planned reaction products, the kit (container/delivery intermediates, products system) to hold the chemicals Under OSHA’s pending of upset conditions, by- and deliver them in the proposal, an importer/ products, and decomposition appropriate ratio to form manufacturer of a chemical products; and the finished product, the apparently would be (5) All hazards of foreseeable supplier presumably had responsible for classifying its emergencies involving conducted R&D and QA chemical all the way through the chemical, including testing in developing and the distribution system to those resulting from all the point where the chemical downstream chemical was fully reacted.3 Where the reactions (which would chemical is not fully reacted, 3 This is suggested by the following statement in OSHA 2015 HCS Compliance Directive: The first employer meeting the definition of a manufacturer does not need to consider uses of a chemically reacted version of their product. An example of this is a company providing methyl methacrylate to a second manufacturer who creates polymethyl methacrylate and then makes products from the polymethyl methacrylate; the first manufacturer does not need to warn on the hazards of the products made from the polymethyl methacrylate. OSHA CPL 02-02-079, Inspection Procedures for the Hazard Communication Standard (HCS 2012), July 9, 2015, p. 22. https://www.osha.gov/OshDoc/Directive_pdf/CPL_02-02-079.pdf 18 Leader—Summer 2021 vpppa.org

the chemical supplier might Standard into the HCS. From planned downstream chemical It would be highly continue to be responsible a policy standpoint, it would reaction is neither produced in inappropriate for for classifying its chemical inappropriately place the their workplaces nor imported OSHA to completely to reflect its ongoing hazards responsibility for classifying by them. No other nation overturn the existing until some point where an the hazards of downstream or region in the world has regulatory scheme as OSHA compliance officer, in reactions and reaction adopted or proposed such an it has proposed to do. the exercise of discretion, products on an upstream inverted regulatory scheme. We determines those further chemical supplier that are not aware of a single OSHA hazards would no longer be generally will not have selected enforcement action based known or discovered through the chemicals for that process, on this position. It would be due diligence. designed that downstream highly inappropriate for OSHA process or exercised any to completely overturn the In short, OSHA’s position control over that process, existing regulatory scheme as on this issue would create much less other unrelated it has proposed to do. an inherent conflict in the processes in the same facility. hazard classification provision In asserting this proposed of the HCS, would upend the Section 1910.1200(d) change is simply a clarification principles underlying chemical currently provides and would of existing law, OSHA has safety and harmonization continue to provide that sidestepped the fundamental under the GHS, would “chemical manufacturers legal obligation to assess effectively incorporate the and importers shall evaluate its technical and economic process hazard analysis chemicals produced in their feasibility. The HCS is a critical provisions of the OSHA workplaces or imported standard. It is also critical to Process Safety Management by them.” The product of a get it right. ® • Keeps extension ladders from Ladder falls – slipping on slick surfaces such as 2nd leading cause of composite decking work-related • Unique design of foam creates tiny injur ie s! * suction cups that grip the surface, even when wet * https://www.cdc.gov/niosh/ nioshtic-2/20034690.html • Light weight for easy use, weighs less than 6 pounds Working Concepts, Inc. • Works on smooth surfaces, plastic, 888-456-3372 • www.softknees.com • [email protected] wood, concrete, etc., even when wet Patent Pending • Prevents marring and scratches to deck caused by ladder feet • Attaches to the bottom ladder rung, with adjustable strap, for easy movement of ladder along wall • Fits most extension ladders, up to 21” wide • Replaceable self-adhesive foam pad vpppa.org Leader—Summer 2021 19

HAZCOM LEADING INDICATORS Implementation Under the VPP Elements By Michelle Zapanta Control Board Operator, Step-Up Operations Supervisor, Industrial Fire Fighter, former Lead VPP Coordinator and current Chairperson for the Employee Safety Leadership Team Valero Benicia Refinery 20 Leader—Summer 2021 vpppa.org

The “Communication” a site; the safety data sheet But how can we gauge HazCom deficiencies—this is in Hazard (SDS) for a process, mixture, if our implementation of preventative safety. Communication or chemical; and the written HazCom standards is truly HazCom safety program effective? This can be put in In terms of HazCom, lagging In the safety world, the term itself. Visual communication simpler terms with two basic indicators can be identified “hazard” is a regular part comprises the graphic elements questions: through simple data analysis of our vocabulary. We speak found on placards, labels, and 1. What do we say we do? and trending of incidents of hazards frequently in signage. These include colors, 2. Are we doing what we say specific to those that resulted conjunction with workplace symbols, and pictograms. from HazCom deficiencies. safety: hazard identification, we do? For incorporating HazCom hazard classification, hazard Why is highlighting these in leading indicators, the mitigation. Yet a critical part in various communication This is where the inclusion process is considerably more the effectiveness of managing components important? of HazCom in the leading complicated. Employers must hazards at the workplace— Because identifying them lays indicators at our site comes take a more comprehensive Hazard Communication—may the foundation for thoroughly into play. look at HazCom program not be as prevalent in our gauging the effectiveness of deficiencies that may be present safety highlights. our implementation of HazCom Lagging indicators throughout the site, regardless standards at our worksite. can dominate our safety of whether an associated A common finding in post- statistics, as incident data incident has occurred. incident debriefs or critiques HazCom Leading vs trends have historically is a lack of communication or Lagging Indicators been the focal point of most This process is similar to the breakdown in communication. traditional safety campaigns. methodologies applied when This applies to all facets of the HazCom standards are in place However, lagging indicators performing a Process Hazard workplace, making it is easy to ensure chemical safety are the antecedents of the Analysis (PHA), where process to recognize the importance of in the workplace, setting consequences: incidents—the hazards and consequences effective communication in our the minimum requirements injuries and illnesses that of deviation are analyzed for day-to-day operations. that employers must meet occur at the workplace. As causal factors along with both to ensure that all process such, focusing on lagging risk potential and probability— Workplace safety is not and chemical hazards are indicators alone leaves you even if the consequences have an exception to this, so it is identified and communicated always looking backward when never actually transpired. also important to recognize to the employees that may assessing deficiencies—this is Such as with the commonly the significance of effective encounter these hazards. reactive safety. used “What-if” methodology communication in terms of These regulations require for PHAs, identifying leading Hazard Communication. Let comprehensive hazard Leading indicators, on the indicators for HazCom at our us not forget that the word communication programs to other hand, are the precedents worksite compels us to ask, communication is right in be written in accordance with to the consequences and “What if?” What if this chemical there. This entreats us to ask these requirements. therefore provide a predictive container was left unlabeled? ourselves the question, “Do measurement for potential What if that warning sign was we apply the standards for incidents that may result from illegible? What if the SDS for this effective communication in our implementation of Hazard Communication (HazCom) at our worksite?” The communication element in any HazCom program comes in various forms: verbal, written, and visual. Verbal communication may be present in an instructor-led training class, on-the-job training with a mentor or supervisor, verbally communicated information at a safety meeting or safety presentation, or discussion of hazards as part of a job hazard analysis conducted during a jobsite visit. Written communication includes the words on placards, labels, and signage; the written policies and procedures governing vpppa.org Leader—Summer 2021 21

The true key to successfully implementing HazCom leading indicators goes back to the basis for incorporating HazCom leading indicators in the first place . . . mixture was missing? What if like a formidable construct. of any solid construction— This foundation can then be our employees were not trained Nonetheless, whether a small in which to lay the various built upon with additional on the proper PPE to wear when or large site with simple or components of HazCom HazCom leading indicators handling this substance? What if complex operations, whether applicable to our site. by systematically identifying, this drum developed a leak? a long-term VPP Star site under one VPP element or sub- or just in the early stages of What does this mean? This element at a time, any other The main differences in the reaching or incorporating essentially means outlining the HazCom-related components methodology of identifying HazCom leading indicators elements of VPP (Management as they apply to our site per HazCom leading indicators is (which may initially appear Leadership & Employee HazCom regulatory standards. the absence of the deviation to be a daunting task) can be Involvement, Worksite guesswork and risk-ranking accomplished by anyone using Analysis, Hazard Prevention & While this approach components: if something does this methodical approach: Control, and Safety & Health is systematic, laying the not meet HazCom regulatory Utilizing the VPP elements Training) and inputting each foundational HazRec standards then it is a deviation as the modules to form the HazCom communication components under their and, if it is a deviation, foundation—the starting point component under the corresponding VPP elements then there is a consequent appropriate VPP element. will not be a simple copy- risk. Period. Employing this forward-thinking approach in the prevention of incidents is at the core of leading indicators, providing predictive data trends that indicate where improvements should be made and thereby allowing us to preemptively mitigate and correct HazCom deficiencies. HazCom Leading Indicators under the VPP Elements Depending on the size and complexity of our worksite, the incorporation of HazCom leading indicators can seem 22 Leader—Summer 2021 vpppa.org

and-paste job. Each worksite • Employees trained on the receiving of shipments of hours). We must additionally needs to self-assess exactly hazardous chemicals select the suitable data which HazCom leading physical and health hazards collection and trending/ indicators are applicable to of hazardous chemicals • Hazard information for tracking methods, e.g., survey, their site and their employees, audit, database tracking, while overlapping or related • Employees aware of stationary process containers spreadsheet reporting, etc., aspects of each VPP element documented in other written from which to develop our may also lead to differing where hazardous materials (such as operating predictive data trends. determinations of how to chemicals are present procedures) in accordance lay out certain HazCom with HazCom requirements It is important to note that components based on the • Employee knowledge & when in lieu of affixed labeling this given breakdown under the metric that is chosen. VPP elements may not cover all understanding of HazCom • Employees informed of applicable HazCom standards For example, we may standards spot-checked in or requirements at our site; choose to track completion the field hazards associated with non- it is by no means an inclusive rates of required employee routine tasks and chemicals nor a must-follow element HazCom training under Safety Worksite Analysis contained in unlabeled pipes categorization of HazCom & Health Training while in their work areas components. It serves merely choosing to quantify allotted • HazCom placards, labels, to illustrate the foundation of hours for employee HazCom Safety & Health Training incorporating HazCom leading training under Management and signage in place, legible, indicators at our site under the Leadership. Such specifics are in English (at minimum) • On-the-job training for VPP elements. generally up to our judgment within the scope of each VPP • SDSs readily available at affected employees The true key to successfully element, as modeled in the implementing HazCom following breakdown of various the worksite • Employees trained on SDS leading indicators goes back components that may be used to the basis for incorporating to identify HazCom leading • Documented job hazard use & access HazCom leading indicators in indicators under the the first place—to accurately VPP elements: analyses performed • Employees trained on gauge the effectiveness addressing HazCom of our implementation of Management Leadership requirements and safety HazCom requirements HazCom standards at our & Employee Involvement mitigations worksite—and those two • New-hire employees basic questions that bear • Written comprehensive • All containers of hazardous repeating: What do we say we trained on HazCom do and are we doing what we HazCom program chemicals at the worksite definitions and requirements say we do? When it comes reviews/updates legibly labeled, tagged, or to identifying our HazCom marked as required • Training includes specified leading indicators, keeping • Instructor-led training these two basic questions • Shipping containers pictogram, hazard in mind as we input our classes provided to all statement, signal word, and HazCom components under affected employees labeled, tagged, or marked precautionary statement for the VPP elements translates to appropriately and sent with each hazard class and category cumulatively assessing both • On-the-job training the appropriate SDS(s) the design of our HazCom • Additional training provided program in accordance with time with a mentor or • Engineering controls for HazCom standards, as well as supervisor provided to whenever new chemical our actual application of those affected employees the protection of employees hazards are introduced into standards in the workplace. from chemical hazards in the workplace Thus, it is in this way that • Incident investigation results place and not modified incorporating HazCom leading • Training covers the indicators under the VPP communicated to employees Hazard Prevention elements can accomplish via safety meetings or & Control appropriate handling our objective of thoroughly other mediums of chemicals gauging how truly effective • HazCom placards, labels, our implementation of • Contract employees included • Training informs employees HazCom standards at our site and signage in accordance is (or isn’t). in HazCom program with GHS of protective measures from hazards (use of • Readily available means of • SDSs up to date with all engineering controls, use of administrative controls access to safety data sheets 16 sections per HazCom such as work practices and standards (1. Identification, procedures, PPE) • Employee exposure to 2. Hazard(s) identification, 3. Composition/information For the final step (of which hazardous chemicals covered on ingredients, 4. First-aid the specifics are a topic for in emergency response/ measures, 5. Fire-fighting another article!), we must action plan measures, 6. Accidental determine the specific metric release measures, 7. measurements we will be • Employees participate Handling and storage, 8. using, e.g., percentage of Exposure controls/personal total, total count, average, in audits that address protection, etc.) completion rate, etc., for each HazCom requirements HazCom component that we • Chemical inventory identify as an appropriate leading indicator (such as in current and updated the example of using employee regularly as required HazCom training completion rates versus allotted training • Control measures in place for the ordering and vpppa.org Leader—Summer 2021 23

01 02 03 04 01 PLANNING FOR AND PREVENTING 02 CHEMICAL 03 EMERGENCIES 04 A Safety Management System Approach By Phil N. Molé 05 24 Leader—Summer 2021 vpppa.org

05 It seems that every time ability to achieve the intended Intentionally we hear of a major outcomes of its management building a vpppa.org chemical accident, we system, such as reductions solid safety eventually learn of gaps in numbers of occupational management in the location’s safety practices illnesses and injuries. Chemical system, we have that either directly led to the management is one of the a better chance incident, exacerbated it, or both. factors an organization should of preventing For example, most accident consider here, as well as how chemical investigations conducted by the well their current hazard accidents, or at U.S. Chemical Safety and Hazard communication practices least of mitigating Investigation Board (CSB) protect workplace safety the potential harm identify failures at the safety and health. They should also if they do occur. management system level as root consider their relationships causes of the accident. That with their chemical suppliers, ! means that there were problems as well as with first responders with the policies, procedures, and area medical centers. Leader—Summer 2021 25 and everyday safety practices, including the safety culture, Consultation and of the organization. Of course, participation of workers the corollary to that is that by intentionally building a solid Section 5.4 states that an safety management system, organization must establish we have a better chance of and maintain a process for preventing chemical accidents, consultation and participation or at least of mitigating the of all workers at all applicable potential harm if they do occur. levels, and specifically In what follows, we’ll explore notes that non-managerial how taking a safety management employees must be included. system approach can help Additional information on this us improve our chemical section located in the annex emergency planning, improve to the standard states that engagement of our workers with “consultation implies a two- workplace safety, and protect way communication involving the safety and health of our dialogue and exchanges. workers and our community. Consultation involves the timely provision of the information Emergency Planning necessary for workers, and, and ISO 45001 where they exist, workers’ representatives, to give informed Emergency planning is a feedback to be considered by the significant part of any effective organization before making a safety management system. decision.” The idea here is that ISO 45001, the global standard workers need to participate in for occupational health and a meaningful way in the safety safety (OHS) management of their workplace, including systems, outlines a number the ability to conduct key safety of elements relevant to tasks and help identify hazards, emergency planning that an risks and opportunities. organization needs, including: Actions to address risks Understanding the and opportunities organization and its context Section 6.1 is interesting. Everything in safety Employers aligning their safety management ultimately management system with comes down to identification Section 4.1 of ISO 45001 should and control of risks. Failure determine the external and to identify and address risks internal issues relevant to its related to chemical products purpose, and which affect its in our workplace can have

Workers need to disastrous consequences in should make sure that they’re encountered when responding participate in a the event of an emergency. making them in a language and to an incident places emergency meaningful way Employers need an effective and format that all of their workers personnel at risk, because it in the safety of robust system for managing can understand, and verify that reduces the likelihood that their workplace, corrective actions, including they’ve understood them. they’ll have the proper personal including the simple ways to initiate, assign, protective equipment (PPE) and ability to conduct prioritize, and track these Eliminating hazards and response tactics. key safety tasks actions to completion. reducing OHS risks and help identify Lack of chemical hazard hazards, risks, and Resources In section 8.1.2 of the standard, information also places opportunities. the expectation is set for an communities at risk—as Section 7.1 of ISO 45001 states organization to do its best members of the community, 01 that an organization needs to to eliminate hazards (i.e., health care providers, provide the resources necessary sources of risk) and reduce the municipal officials, and other 02 to establish, implement, likelihood and severity associated community stakeholders maintain, and continually with remaining risks. The need this information to 03 improve safety management. “consultation and participation recognize and understand This means it must budget for of workers” mentioned in exposure symptoms, identify 26 Leader—Summer 2021 equipment needed to meet the Section 5.4 is especially helpful vulnerable populations, and needs of all employees during here, because if employers can take sufficient precautionary emergencies. This equipment get all of their workers involved and treatment measures. As may include, but is not limited in identifying risks, such as by we can see, our own gaps in to, transportation devices, doing inspections and submitting hazard communication create communication devices, hazard reports, they can harness a pattern of additional risk that emergency control systems, the collective knowledge of radiates outward like a fracture alarms and other warning their workforce and share on a windshield, affecting the systems. Software systems responsibility for safety. entire community. for managing and providing access to SDSs, improving Don’t Go it Alone Emergency planning isn’t just access to safety data and something businesses need to simplifying management of We can draw a couple of do—it’s something businesses, safety tasks (e.g. inspections of conclusions by reviewing the emergency responders, and chemical storage locations and parts of ISO 45001 relevant to regulatory agencies need to investigations of chemical spills emergency planning. First, it’s do together. It’s a collaborative or exposure incidents) can be important that our emergency process that goes beyond the great potential resources. planning and response is well- sharing of information, as integrated with the rest of our important as that may be. It’s Communication safety management system. about having relationships with Second, doing emergency all stakeholders, involving them According to Section 7.4 of planning well requires the early in the planning process and the standard, an organization direct engagement and making sure there are no gaps in must establish processes consultation of our workforce. communication that could prove for communicating safety Meaning, we won’t succeed if costly in the event of a disaster. management information to we try to go it alone. employees. Communications And it goes beyond even specific to chemical emergency Consider the importance of that, to our own roles in the planning might include having access to emergency chemical supply chain. No methods of providing access response information in the matter where we sit in the chain, to safety data sheets (SDSs), event of a major chemical we have responsibilities to and procedures to follow release. Without information ensure the flow of information in the event of a chemical about the identity of the to all stakeholders. If we are emergency, including how to chemicals on-site, their a chemical supplier, we need locate and use the emergency physical and health hazards, to classify the hazards of our contact telephone number in and appropriate firefighting chemical products, develop SDSs Section 1 of SDSs, and specific and emergency response and shipped container labels, procedures to be followed for measures, first responders and provide an emergency various kinds and sizes of spills. lack information necessary to contact number in Section 1 of It’s important to remember safely control and extinguish the SDSs. If we’re end users, we that when making these a fire or address dangerous need to keep communication communications, employers releases. Uncertainty about open with our suppliers to chemical hazards that may be ensure we’re getting the most vpppa.org

! up-to-date documents from to have a successful emergency incident investigations related support and mitigation them—which will be especially planning program. When we’re to chemical hazards, completion assistance in the event of a important now that OSHA has planning our “resources” per of job safety analyses (JSAs) for chemical spill or other incident, issued a notice of proposed Section 7.1 of ISO 45001, we chemical management tasks, including incident notification rulemaking (NPRM) to update should consider the benefits scheduling of safety meetings, and reporting to designated the HazCom Standard that will of a purpose-built safety and easy tracking of corrective emergency contacts. change the way manufacturers management software solution, actions related to chemical of certain chemical products as well as contracted emergency management. Even better, it Even the most well managed like aerosols, desensitized response services. gives you visibility into your facilities still bear the risk for explosives, and flammable gases most important safety metrics so a serious chemical-related are classified. Employers also For example, a modern-day, you can keep everyone involved emergency. But with the right need to provide barrier-free full-blown safety management in your emergency planning planning and the right tools, you access to SDSs in the workplace, solution—like VelocityEHS— practices well-connected and can minimize the impact of an and train their employees on helps achieve this. It includes informed, allowing for better incident on your business and HazCom, including how to find cloud-based tools to manage decision-making. reduce the risks to your workers emergency contact information your chemical inventory and your community. in Section 1. and SDSs, strengthening And no matter where you are your emergency plans, and in the chemical supply chain, Phil N. Molé, MPH, is an EHS Planning for Safety streamlining access to SDSs, you can benefit from emergency & Sustainability Expert at and the chemical hazard and response services. If you’re VelocityEHS, the global leader in Getting the right safety emergency response information a supplier, for instance, you cloud environment, health, safety management system in place contained within. It takes this can get a 24-hour toll-free (EHS) and sustainability software. takes planning. Too often, important functionality and emergency phone number to To learn more about VelocityEHS one of the obstacles is that combines it with the ability include in Section 1 of SDSs and how its Safety Management EHS professionals lack the to simplify and share other for your chemical products. If Solution provides real support support they need to take the key safety tasks, such as you’re an end-user, you get for managing safety tasks and proactive approach they need performance of inspections and chemical incident exposure improves safety performance visibility, visit www.EHS.com. vpppa.org Leader—Summer 2021 27

HAZARD COMMUNICAT By Mackenzie Barnwall (top), MS, GSP, and A s a health and safety safe workplace and reduce Megan Scherer (bottom), Safex consultant, I’ve exposure and injury. performed my share of The compliant program 28 Leader—Summer 2021 chemical inventories and found includes training, chemical secret stashes of chemicals inventories, labeling, and strewn about facilities. Even safety data sheets. businesses that appear to 2. Training—Employees have hazard communication who may be exposed to (HazCom) procedures in order hazardous chemicals can do some simple things to during routine operating better ensure worker safety. procedures or emergencies are required to be trained. Before we dig into best While there are a few practices from my experiences, exceptions for employees it is important to understand the related to non-routine following key elements of the scenarios, it is a best OSHA Hazard Communication practice to error on the side standard (29 CFR 1910.1200), of caution when determining frequently referred to as HazCom. who needs to be trained. 1. Written HazCom Training must include Program—If your facility methods and observations to produces, uses, or stores detect releases of hazardous hazardous chemicals, you chemicals in the work area, are obligated to have a the hazards of the chemicals written HazCom program. in the work area, measures OSHA’s intent with the employees can take to program is to support a vpppa.org

ION LESSONS From the Field protect themselves using handling. Employers are 16-section format, that OSHA’s second work practices, emergency responsible for making sure includes the properties of most frequently procedures, personal that the labels provided each chemical; the physical, cited standard protective equipment, and by the manufacturer, health, and environmental is hazard the details of the site-specific importer, or distributor health hazards; protective communication. hazard communication are legible, so the chemical measures; and safety program, including an name, pictograms, hazard precautions for handling, explanation of labeling, statements, signal word, and storing, and transporting safety data sheets (SDSs), and precautionary statement for the chemical. how employees can obtain each hazard class are visible. hazard information. Employers must also ensure Sections 1 through 8 contain 3. Chemical Inventory— that all secondary containers general information about the Completing an annual are appropriately labeled. chemical, identification, hazards, chemical inventory audit 5. Safety Data Sheets (SDS)— composition, safe handling can help you determine Safety Data Sheets must be practices, and emergency control which chemicals are in use readily available in paper measures. Sections 9 through 11 at your facility. You’ll be able or electronic format, for and 16 contain other technical to identify new chemicals, employees to view when and scientific information, such purge and acquire new working with hazardous as the physical and chemical SDSs, and determine if the chemicals. If SDSs are properties, stability and reactivity chemicals are labeled and electronic, they must have information, toxicological stored properly. no access barriers (i.e., information, exposure control 4. Labeling—Hazardous everyone must be able to information, and other chemicals must be labeled log in to the computer or information, including the date of properly to notify employees server that stores them). preparation or last revision. of the hazards involved in SDSs must have a uniform, vpppa.org Leader—Summer 2021 29

1LESSON OSHA can, and will, fine for HazCom noncompliance. OSHA’s second most frequently cited standard is hazard communication. Fines are generally issued around not maintaining the all-important hazard communication plan, not fully training employees (more on that in Lesson #4), failing to label correctly, and other chemical inventory issues. One of my colleagues tells a story about a mechanical contractor he worked with many years ago. He noticed they were deficient in several areas of HazCom. Their SDSs were stored haphazardly. Also, instead of replacing the old SDSs with newer versions, they had every single version, and they weren’t easily accessible for emergency use. Despite his efforts to convince them to be proactive and change their practices with labeling and training, the owners decided not to take his suggestions. Two years later, the company was issued an OSHA citation for the exact issues he was concerned about. 2LESSON 3LESSON Annual reviews are critical. Establish a process to ensure the If your facility chemical inventory is up-to-date, produces, Annual reviews of your program especially with new chemicals. uses, or stores and chemical inventory can hazardous help keep everything in order. During a recent visit with a client, we determined that their muriatic chemicals, The annual review is a great acid supplier changed, and the SDS on file was from the previous you are time to make sure you have all manufacturer. Even though the chemical was the same, they were obligated to necessary SDSs in a binder or out of compliance because the SDS did not match. We helped them have a written electronic folder. And remember request an SDS from the new manufacturer to ensure compliance. HazCom to save the SDSs of chemicals no program. longer in use in a different file; Establishing a chemical review process before allowing a new SDSs for legacy chemicals must chemical to be purchased, may be helpful in preparing for what be saved for 30 years after they chemicals are going to come into the facility. Additionally, another are taken out of service. way to ensure you are aware of new chemicals, is by building a relationship with your purchasing department. Since they typically Take it from me, investing a are the gatekeepers, the purchasing department will be able to alert little time each year in keeping you when something new is in use and can even help you obtain your SDS binder current saves the SDS. Following these best practices will help you be proactive time in the long run. I’ve rather than reactive. uncovered SDSs with pages browned and older than me, 30 Leader—Summer 2021 and programs lacking the required physical hazards, health hazards, and personal protective equipment. These tasks are low hanging fruit, so tackle them annually. It is also important that SDSs from 2012 or prior are reviewed and updated to ensure they comply with the HazCom standard changes made that year. Prior to 2012, manufacturers provided Material Safety Data Sheets (MSDSs) that were not aligned with Globally Harmonized System of Classification and Labeling of Chemicals (GHS) rules. vpppa.org

4LESSON SDSs for legacy chemicals must be saved for 30 years after they are taken out of service. Stay on top of 5LESSON Mackenzie Barnwell, MS, GSP, is an industrial hygiene consultant HazCom and at Safex, a health and safety consulting firm in Westerville, Ohio. chemical safety Electronic Safety Megan Scherer is a marketing communications professional at training and Data Sheets (SDS) Safex specializing in digital communication and content creation. make it fun. are imperative. Training, as required by Having a binder in a central the OSHA standard, must location makes it easy for be completed at the time employees to access SDSs. of initial assignment and But I’ve also seen many whenever a new physical or customers struggle when health hazard is introduced the binder is misplaced into the workplace. Many or damaged. I always of our clients reiterate recommend having all your the importance of hazard SDSs saved electronically, communication by regardless of whether you conducting annual training, have a binder in use. or giving 10-15-minute toolbox talks, as repetition is There are companies that required for retention. provide access to online SDS databases that you can build One of my hacks for up based on what you have interactive HazCom training in your facility, or you can is to provide employees create your own database with an SDS and ask them using spreadsheet software, hazard-based questions such as Microsoft Excel. they can answer by looking through the SDS. Creating a trivia game, which includes all five key elements of a hazard communication program as the categories, is another fun and competitive way to keep employees engaged in the training. vpppa.org Leader—Summer 2021 31

By Warren Silverman, MD FACOEM Medical Director Workplace Forensics LLC T he Native American the desert to the mountain With the industrial people of the Lakota tops, the earth provides the revolution, man’s technology culture called her Unci sustenance of our lives. sparked a hunger and an Maka, or Mother Earth. She obsession with creating, was the “giver of life,” and as Throughout the history of building, growing, and such, needed to be protected man, our impact on the earth manipulating the earth to at all times. We live and work has been tiny compared to its accommodate for our increasing on the earth. It’s erosion from vastness. We chipped rocks, dug numbers and our variety of many eons, worn by the winds for metals like copper and iron, curiosities. We tapped into over millions of years to make plowed it for our crops, but in chemists and other scientists the precious soil in which the general, these tiny scratches on who learned how to use the flora of the earth thrive. From the vastness of our earth made many gifts hidden in our planet. hardly a scratch in it. 32 Leader—Summer 2021 vpppa.org

The earth has felt us. We have levels of Cadmium. Fertilizer soil-based agriculture just at There is no place poured our chemicals into the in Europe contains bout 32 a time when our soil will be earth. We have sprayed them, mg Cadmium per kilogram experiencing marked fatigue on earth now spread them, released them, and has been measured up to and contamination. We can and the earth has taken them in. 200 mg Cd/kg. Cadmium has accommodate to some degree where the soil is There is no place on earth now been linked to kidney disease by decreasing food waste, where the soil is virgin. Even in and bone disorders. The metal but that will not be enough to virgin. Even in ice ice cores hundreds of feet deep, concentration in the soil will sustain our population which we find hundreds of years of only increase over time and is expanding in developing cores hundreds airborne chemicals deep under eventually the soil will be too countries and decreasing in the surface. poisonous to use. developed countries. of feet deep, we Something important to And what about those The answer will come from find hundreds of consider is that we are changing phosphates. These mined technology. Agriculture will need our soil in a permanent fashion. chemicals have helped us to to become more efficient, and years of airborne It will never be the soil of your produce increasingly bountiful less soil based. Hydroponics and forefathers. The impact is crops to feed a growing alternative means of producing chemicals deep cumulative. While some things population, but at the same man made proteins will make may decompose and degenerate, time, they are causing more for a vastly different dining under the surface. there is always residue, always long-term problems than they experience by the year 2050. an impact. aid. When you look at a fertilizer REFERENCES: bag it tells a story. There are The good news is that we In 2014, China released a 3 numbers (N-P-K). The first can delay some of this. We 1 https://qz.com/200602/ report citing that 19.4% of its number is the Nitrogen content. can delay it by limiting soil china-just-revealed-a- farmland, or 64 million acres, The second is the phosphorus pollution. We can learn to major-state-secret-nearly- were polluted with Cadmium, content (P2O5), and the third is abate other soil contaminants. 20-of-its-farmland-is- Nickel, and Arsenic to the point the potash content representing We can try to capture polluted/ where it could not be used to potassium content. nonarable land and use it, an grow crops. These regions near initiative that might rely on 2 https://www.economist. the Yangtze and Pearl Rivers Too much phosphorus will water sources which will not com/briefing/2017/06/08/ also supply the water to millions cause plants to grow poorly and be available due to increasing the-most-neglected-threat- of people. Half of all the rice will limit a plant’s ability to take water shortages. We can to-public-health-in-china- crop tested in Guangzhou were up iron and zinc, which they anticipate the impact of is-toxic-soil found to have toxic levels of need. Even more disturbing, global warming and move our Cadmium. In addition to metal run-off of phosphorus into agricultural areas northward 3 https://pubmed.ncbi.nlm. and other organic and inorganic our waters, our lakes, and our and repurpose agricultural nih.gov/20485999/#:~:text= material contamination, more streams, can kill the life in these lands in areas that will suffer Polished%20rice%20 than 40% of the soil in China is bodies. Large algae blooms from heat and drought. from%20various%20 degraded from overuse, erosion, develop and oxygen levels in production,114.4%20ng%20 and pollution. The heavy the water drop. Dead zones can Countries like Cambodia, g(%2D1). metals, organic, and inorganic form, and the algae can cause which a decade ago had chemicals coming out of the sickness in humans. agricultural climates like 4 https://www.euractiv.com/ smokestacks of these large southern California, now suffer section/agriculture-food/ industrial areas cause markedly Let us put this into a bigger from severe yearly droughts news/wed-the-cadmium- elevated levels of arsenic and perspective. Whether you which make growing crops war-eu-in-the-midst-of-a- other chemicals in rice and like it or not, or participate impossible. The droughts in geopolitical-arm-wrestling/ other crops. in it or not, the human diet is Africa are destabilizing and vast changing, and in 20 years it human migrations are being 5 https://www.ncagr.gov/ But don’t think that this will be dramatically changed. felt. The impact on humans is cyber/kidswrld/plant/ problem is contained to one Part of this is generational, already quite real. label.htm#:~:text=All%20 country or even one region. It but part is due to the inability fertilizer%20labels%20 is all over the earth. In 2018 the to sustain our current diet. The point is, we have to have%20three,)%20%2D%20 European Commission began The general trend involves the be smart. We have to plan. potassium(K)). a debate about Cadmium in its protein we eat and need. There We have to recognize and soil. Where did it come from? is an early, but rapidly growing acknowledge that we have 6 https://www.usgs.gov/ Not the industrial smokestacks evolution to move from an committed a grave sin against special-topic/water- causing the problem in China. In animal-based source of protein Unci Maka, our Mother Earth, science-school/science/ Europe, the phosphate fertilizer to a plant-based source. Within and its soils, and we have to phosphorus-and- spread on the ground to 20 years, there will be marked amend. It will only be a matter water?qt-science_center_ increase crop yields is mined in limitations and constraints on of time before our dinner is objects=0#qt-science_ places in North Africa where the animal-based foods. This will sucked out of tubes, and people center_objects sedimentary rock contains high put a much bigger demand on will talk about the legend of a steak and potatoes meal. 7 https://counties.agrilife. org/valverde/files/2014/11/ Phosphorus-Too-Much- Plants-May-Suffer.pdf 8 https://www. nationalgeographic.com/ environment/article/ mekong-river-lowest-levels- 100-years-food-shortages vpppa.org Leader—Summer 2021 33

Written by the International Safety Equipment Association (ISEA) PROTECT YOURSELF Against Chemical Hazards on the Job W orkers across will protect the arms and hands ANSI/ISEA Z87.1-2020 operating procedure covering many industries from harmful substances and American National Standard on regular training, fit-testing, fit- are at risk daily skin absorption. Occupational and Educational checking, periodic environmental of coming Personal Eye and Face Protection monitoring, maintenance, into contact with hazardous NIOSH offers a includes an Eye and Face medical monitoring, inspection, chemicals, including those in Recommendations for Chemical Protector Selection Chart to aid cleaning, storage and periodic agriculture, manufacturing, Protective Clothing (CPC) in identifying and selecting the program evaluation. The current construction, transportation, database, which provides types of eye and face protectors listing of NIOSH certified laboratories, and more. In fact, CPC recommendations for available, and their capabilities respirators can be found in the the Centers for Disease Control the chemicals listed in the and limitations for different NIOSH Certified Equipment List, and Prevention (CDC) estimates NIOSH Pocket Guide to Chemical hazards, including potential which is available on the NIOSH more than 13 million workers in Hazards. Access the database at chemical exposure. web site. the United States are potentially cdc.gov/niosh/ncpc. exposed to chemicals while on Protect Your Lungs In Case of an the job. OSHA also provides Emergency guidelines on the various types Chemicals can harm a worker From severe chemical burns of clothing that are appropriate internally, as well. Lungs, If accidents do happen and a to corrosion of the skin and for use in various chemical organs, and the nervous system worker is exposed to dangerous skin cancer, whether effects operations. See Section 8, are at risk if hazardous chemicals chemicals, emergency eyewash are temporary or have lifelong Chapter 1 of the OSHA Technical are inhaled. In these cases, and shower equipment, when consequences, having access Manual at osha.gov/otm. respirators can filter out toxins used correctly, can help to to and wearing the appropriate to provide users with breathable minimize injury and should be personal protective equipment Protect Your Eyes & Face oxygen. The NIOSH Pocket Guide part of an employer’s worker (PPE) to protect the skin, eyes, to Chemical Hazards provides a protection program. and respiratory system is vital A worker’s eyes are also at risk to table of allowable respirators to to workers’ safety. chemical hazards, and exposure be used for certain chemicals. OSHA, 29 CFR 1910.151, or contact can cause permanent requires that: “Where the eyes Protect Your Skin eye damage and blindness. Safety All respirators selected must or body of any person may be goggles will protect a worker from be approved by NIOSH, and a exposed to injurious corrosive Coveralls with hoods or other acids, chemical gases, vapors, and complete respiratory program materials, suitable facilities for full-body protective suits are from liquid chemicals splashing must be implemented. A quick drenching or flushing often used for skin protection, into the eye. Face shields help respiratory protection program of the eyes and body shall be and chemical resistant gloves protect against splashing or includes a written standard provided within the work area misting onto the face. 34 Leader—Summer 2021 vpppa.org

for immediate emergency Leader—Summer 2021 35 use.” Some states also require emergency eyewash and shower equipment in workplaces where there are irritants or chemicals that are toxic by absorption. Many states require the use of ANSI/ISEA Z358.1 (American National Standard for Emergency Eyewash and Shower Equipment) compliant equipment, which provides guidance to users on the need for proper emergency eyewash and shower equipment to mitigate injury from splash and ocular incidents, to illustrate eyewash and shower equipment systems, and to assist in the proper selection, use and maintenance of emergency eyewash and shower equipment. Know Your Chemicals The NIOSH Pocket Guide to Chemical Hazards is an excellent source of general industrial hygiene information for workers, employers, and occupational health professionals, aimed at helping users recognize and control occupational chemical hazards. Get the full guide at cdc.gov/niosh/npg. To better understand how many workers in the U.S. and by state are using these PPE products across multiple industries, visit ISEA’s new Economic and Safety Impact Tool at safetyequipment. org/industryimpact. VPPPA Partner, ISEA, is the leading association for personal protective equipment and technologies that enable people to work in hazardous environments, and an ANSI accredited standards developing organization. The association works closely with manufacturers, test labs, subject matter experts, end-users and government agencies in the standards development process. ISEA members—leaders in safety equipment manufacturing, testing and application—are united in the goal of protecting workers worldwide. Visit their website to learn more at safetyequipment.org. vpppa.org

Membership Corner Follow us on social media! Facebook @VPPPA Twitter: @VPPPA Instagram: @VPPPA_Inc LinkedIn: VPPPA, Inc. Summer June: July: August: Members of Nina Mendonca Fady Guirguis Michael Hancock the Month T. Marzetti Company, Chatham Morton Salt—Production & Marine Corps Air Facility Village, Warehouse Personnel Maintenance Manager Quantico—Director of Safety, Congratulations to our summer VPP Site Coordinator Members of the Month! Region I Region IX Region III Want to submit someone to be considered as a VPPPA Member of the Month? Email [email protected]. Visit vpppa.org to read more about the current Member of the Month. Welcome! The VPPPA National Board has welcomed two new faces during a special election held this past spring. Please join us in welcoming our two new Board members! There’s still time Michelle Keever Daniel Charles to make it to the annual Safety+ Director from a DOE-VPP Site Director-At-Large Symposium in Nashville, TN, UCOR, an Amentum-Led Brandenburg Industrial Service August 31–September 2. In fact, Partnership with Jacobs there are three ways to attend! Oak Ridge, Tennessee Company Chicago, Illinois In-Person The annual elections for the VPPPA National Board of Directors Join us at the Gaylord Opryland will be held at the 2021 Safety+ Symposium in Nashville, TN, August Convention Center in Nashville. 31–September 2. Register at vpppa.org/events or onsite during the symposium. Join the VPPPA N.O.W. (Network of Women) Facebook Group Virtually Are you a woman in safety looking to network with industry peers? No plane ticket required. Join us Consider joining the VPPPA N.O.W. Facebook group! This is from your computer. a private space to come together as women to encourage, pose questions, and empower. Because women are what is happening in Hybrid Access safety NOW. Come to Nashville to enjoy the To find the group, simply search for “VPPPA N.O.W.” on Facebook symposium AND receive every and request to join. workshop recording to listen to for 30 days post-symposium. Learn more or register today! vpppa.org/events 36 Leader—Summer 2021 vpppa.org

A Note from the VPPPA Membership & Outreach Manager, Son Nguyen As the country starts Your continued support this year has allowed the VPPPA to: Please continue to support us by renewing to open back up and your membership. You will gain access to: employees return to the • Host 9 webinars on topics such as OSHA Under the Biden office, companies face • FREE live and recorded webinars both old and new health Administration, Virtual VPP Audits, and Rethinking the • Mentoring partnership program and safety challenges. • Member content library These challenges cry Near Miss. • Discounted rates on exclusive VPPPA out for companies to improve occupational • Conduct our first virtual Next Level Safety conference, conferences, events, and other association health and safety, building a dependable which offered 24 workshops presented by industry leaders training and networking opportunities. safety culture. Leading the way in safety culture and top federal and state-plan VPP OSHA representatives. • Our new advocacy webpage, which allows is the VPPPA. • Produce the Leader magazine, our award-winning VPPPA members to connect with their quarterly magazine; providing in-depth information and local representatives to take action and have their voices heard. Visit vpppa.org/ guidance on the most crucial issues that affect advocacy for more information. our members. • Move our award-winning blog from twice a month postings to once a week. If you have any questions regarding your VPPPA membership, please contact me at 703-761-6515, or email [email protected]. Thank you again for your dedication and we look forward to serving you in the upcoming year. vpppa.org Leader—Summer 2021 37

www.vpppa.org VPPPA National Board of Directors Ad Index Chairperson Advertiser Website Page Terry Schulte, NuStar Energy, LP AIM www.aimforsafety.com 9 Vice Chairperson Dan Lazorcak, CSP, Honeywell International Bulli Ray www.bulliray.com 40 Enterprises Treasurer Sean D. Horne, Valero Energy Creative Safety www.creativesafetyllc.com 31 Secretary Ericson www.ericson.com 37 Kristyn Grow, CSP, CHMM, SGE Cintas Corporation Glove Guard www.gloveguard.com 27 Director from a Site With a Collective Industrial Scientific www.indsci.com 3 Bargaining Unit Jack Griffith, CH2M Hill Plateau Roco Rescue www.rocorescue.com 4 Remediation Company VelocityEHS www.ehs.com 2 Director from a Site Without a Collective Bargaining Agent Working Concepts www.softknees.com 19 Johnathan “JD” Dyer, Shermco Industries VPPPA contacts T o reach the VPPPA National Office, call (703) 761-1146 or visit Director from a DOE-VPP Site www.vpppa.org. To reach a particular staff member, Michelle Keever, UCOR, an Amentum-Led please refer to the contact information below. Partnership with Jacobs Sara A. Taylor, CMP Sierra Johnson Kerri Usher Director from a VPP Contractor/ Director of Operations Senior Education Coordinator Communications Construction Site [email protected] [email protected] & Outreach Manager Brad Gibson, S&B Engineers & Constructors [email protected] Natasha Cole Son Nguyen Director-at-Large Events Coordinator Membership & Ariana Hanaity Shelly Ettel, PCAPP [email protected] Outreach Manager Communications Coordinator [email protected] [email protected] Director-at-Large Heidi Hill Bill Linneweh, CSP, Hendrickson International Partnership Manager [email protected] Director-at-Large Andy Youpel, SGE, Brandenburg Industrial vpppa.org Service Company Director-at-Large Christina Ross, Morton Salt Director-at-Large Daniel Charles, Brandenburg Industrial Service Company Director-at-Large Rocky Simmons, Mission Support Alliance Editor Kerri Usher, VPPPA, Inc. Associate Editor Ariana Hanaity, VPPPA, Inc. EDITORIAL MISSION The Leader (ISSN 1081-261X) is published quarterly for VPPPA members. The Leader delivers articles from members for members, safety and health best practices, developments in the field of occupational safety and health, association activities, educational and networking opportunities and the latest VPP approvals. Subscriptions are available for members as part of their membership benefits and at a 50 percent discount beyond the complimentary allotment. The nonmember subscription rate is $25 a year. Ideas and opinions expressed within The Leader represent the independent views of the authors. Postmaster >> Please send address changes to: VPPPA, Inc. • 7600 Leesburg Pike, East Building, Suite 100 • Falls Church, VA 22043-2004 VPPPA, Inc., the premier global safety and health organization, is a nonprofit 501(c)(3) charitable organization that promotes advances in worker safety and health excellence through best practices and cooperative efforts among workers, employers, the government and communities. 38 Leader—Summer 2021

Infographic Corner In 2020, OSHA More named Hazard than 40% Communication as of the soil in China is #2 on degraded from overuse, their Top 10 erosion, and pollution. Most Frequently Cited Standards. 13 million In 2014, China released a report citing workers that 19.4% of its farmland, or in the United States are 64 million acres, potentially exposed to chemicals while were polluted with on the job according to the CDC. Cadmium, Nickel, In the Johnson Controls case, the U.S. and Arsenic Supreme Court held that to the point where it refusing to hire women could not be used to grow crops. who could become pregnant, because of concerns about the Workplace impact of workplace violence chemicals on fetal development, is the number one cause of violated Title death for VII of the Civil women in Rights Act. the workplace. vpppa.org Leader—Summer 2021 39

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