OSHA Holds Public Meeting to Solicit Comments, Suggestions

Last week on March 4th OSHA held a public meeting to solicit comments and suggestions from OSHA stakeholders on key issues facing the agency such as enhancing awareness of hazards in the workplace, engaging stakeholders in programs and initiatives, and efforts to control workplace chemical exposures.

Lasting for more than 8 hours, thirteen Panels testified after the opening statements of OSHA's Assistant Secretary David Michaels, and OSHA's Chief of Staff, Deborah Berkowitz, in which they expressed OSHA's commitment to workplace health and safety and their eagerness to engage public stakeholders in OSHA initiatives.

The first Panel was made up of individuals that had family members die from workplace injuries. After sharing their experiences of workplace injuries and deaths, they suggested that OSHA create more stringent standards that deal with workplace injuries to ensure they do not occur again, such as requiring employers to report to OSHA workplace fatalities immediately following the injury to reduce risks posed to other workers and to allow OSHA to better survey the workplace and injury and that OSHA create a specific division that would deal predominantly with workplace injuries and deaths in order to ensure all workplace injuries and deaths are addressed and in a timely, effective fashion. The rest of the Panels consisted of various representatives from a broad spectrum of organizations, associations, agencies, and businesses. The following are some of the highlights from the public meeting:

Some representatives, like the American Society for Safety Engineers, suggested performance-based OSHA standards to encourage employers to meet growing performance levels.

The Association of Occupational and Environmental Clinics (AOEC) called for the need to engage the younger generation into the work safety and health field and that worker’s comp data needed from health professions to ensure accuracy.

There was a general consensus among the representatives that the OSHA Voluntary Protection Program (VPP) is very vital and useful in work safety and health and needs to be retained, and expanding training to employers and employees in the private sector. Many suggested that OSHA conduct partnerships and consultations with professional associations before drafting standards.

Stay tuned with SGIA as we keep you updated on OSHA public meetings, hearings, initiatives and programs.

Written by Zulaikha Safi

OSHA Holds Public Hearing on Revisions to HazComm Standard

March 2nd opened the first of four days of public testimony on the Occupational Safety and Health Administration's revisions to the Hazard Communication Standard. The meetings, held in Washington DC, will be followed by a series of hearings set for early April in Pittsburgh, PA.

Dorothy Dougherty, Director of the Directorate of Standards and Guidance, testified on behalf of OSHA. In her public testimony, Doughterty stated that "OSHA is proposing to revise its requirements to increase the effectiveness of the HCS and make it reflective of the 21st century workplace. While maintaining the framework of the existing rule, OSHA is initiating changes that, for the first time in OSHA's history, are bad on a series of international negotiation's among experts from many countries and international organizations." After her public testimony, those in the audience were permitted to question the Agency representative.

Questions from representatives from organized labor organizations focused on the non mandatory nature of Section 15 of the proposed format for the Safety Data Sheets. This section contains regulatory information based on the chemicals found in the product represented by the specific Safety Data Sheet.

Another representative raised the issue of combustible dust as it applies to the HCS. The attendee asked OSHA about the criteria the Agency will provide to the regulated community regarding this issue given the fact that OSHA is simultaneously working on a proposed rule covering combustible dust. OSHA responded that they have not fully resolved the issue of covering combustible dust within the HCS. However, Agency personnel feel very strongly that it should be covered. The manner in which this will be accomplished is still up in the air.

Other witnesses focused on the reclassification of combustible liquids within the definition of flammable liquids. A representative from the National Fire Protection Association indicated that the removal of combustible liquids as a separate category. OSHA representatives indicated that they had received many comments regarding this issue, specifically as it relates to the changes that may need to occur within facility's electrical systems; quantities of chemicals stored, as well as storage requirements. The Agency representative did not offer any insights into OSHA's plans regarding this issue as the HCS reform process moves forward.

For a summary of the proposed changes to the HCS standard, please contact Marci Kinter at marcik@sgia.org

European Commission urges producers and importers to 'Act Now'

Aimed at small and medium sized businesses, the European Commission's Enterprise and Industry recently put together a leaflet that outlines REACH and Classification, Labeling and Packaging (CLP) requirements, calling them to "act now" and to begin preparations for upcoming 2010 and early 2011 deadlines.

Upcoming Deadlines

Under REACH

November 30, 2010 for registration of most hazardous substances above 1 tonne per year, for substances very toxic to the aquatic environment above 100 tonnes per year, or substances manufactured or imported above 1 000 tonnes per year.

Under CLP

December 1, 2010 for reclassification of substances.

January 3, 2011 for notification by manufacturers and importers of the classification of substances placed on the market that are subject to REACH Registration (for substances to be registered by 30 November 2010, notification will be part of the registration dossier); classified as hazardous (regardless of volume!); in mixtures above certain concentration limits, which result in the need for classification.

For details on the requirements and deadlines cick here for a print version of the leaflet. Stay tuned with SGIA for more updates on REACH.


Written by Zulaikha Safi

Attention All New York State Printing Facilities!

The New York State Department of Environmental Conservation has issued a proposed rule to amend portions of the air pollution control standard that impacts both digital and screen printing facilities operating in the state of New York.

Part 234, Graphic Arts, is the regulation that contains the specific air pollution control requirements. These specific air pollution control requirements detail which ink systems can be used. Currently, the rule is still in the proposal stage and SGIA, in conjunction with the Printing Industries of America and the Flexographic Technical Foundation, submitted comments requesting changes to the proposed rule.

Under the proposal, all facilities that are located in a severe non attainment area, also known as New York City, and facilities that have actual VOC emissions of 3 tons or more per year on a rolling 12 month basis will be subject to these rule requirements. Actual emissions of 3 tons per year equates to the use of approximately 750 gallons of VOC containing materials per year. This would include inks, solvents, and other materials used in your facility with VOCs.

The NY DEC has proposed that digital printing presses would be exempt from these requirements. Digital printing press has been defined as a printing press that transfers electronic files from a computer to an electronically driven output device that prints the image directly on a substrate. The DEC's decision to exempt digital printing presses is consistent with decisions made in other state and regional air quality management districts.

SGIA will continue to work with the NY State DEC to ensure that the final regulation adopted allows the industry to use technologies appropriate for our printing process. For more information, or a copy of SGIA's comments, please contact Marci Kinter at marcik@sgia.org

Hearing on the Science of Public Exposures to Toxic Chemicals

Another hearing was finally held on reforming the Toxic Substances Control Act (TSCA). On February 4th the Senate Subcommittee on Superfund, Toxics and Environmental Health held a hearing on the public health threats posed by exposure to toxic chemicals, as part of efforts to discuss the need to reform toxics laws and the nation's chemical management system. Here are some highlights from the hearing:

Senator Frank R. Lautenberg said he will soon introduce a safer chemicals bill that would greatly reform the nation's current chemical laws.

Steven Owens of EPA's office of Prevention, Pesticides and Toxic Substances stated in his testimony the EPA's commitment to improving chemical safety and argued that EPA's authority is "outdated", preventing the EPA from acquiring the proper tools needed to protect the public health and the environment from exposures to toxic chemicals. Lautenberg argued the need for to bring TSCA into the 21st century through reform that would make TSCA authorities more efficient.

Henry Falk, the Acting Director of the National Center for Environmental Health at the Center for Disease Control and Prevention (CDC), discussed the significance of biomonitoring and its potential to provide solid human data that can assist in making important health decision, particularly concerning exposure to chemicals. The other panel speakers also expressed their praise and support for biomonitoring.

Stay tuned with SGIA as we keep you updated on the development of TSCA reform.


Written by Zulaikha Safi

Are your OSHA Forms posted?

It is that time of year again. Time to post your OSHA Form 300. It is recommended that you post this form in your employee lunchroom, break room, or the area where you post all other required employment notices.

The OSHA Form 300, which can be found at http://www.sgia.org/members/govt/ga_oshaForms.cfm, must be posted from Feb to April of each year. You must post this form even if your injuries and illnesses for 2009 were zero across the board.

All facilities, regardless of size, are required to comply with the Occupational Safety and Health Administration’s recordkeeping requirements. Many believe that if a facility has fewer than 10
employees, none of the safety and health regulations apply. This is a false assumption. As a manufacturing site, you are required by the Occupational Safety and Health Act of 1970 to not only comply with safety standards, but to maintain records of injuries and illnesses that occur
in your facility.

For further information of if you have questions, please contact Marci Kinter at marcik@sgia.org.

EO 13514 -- Obama Adminstration's Green Procurement Strategy

In 2009, President Obama signed Executive Order 13514, Federal Leadership in Environmental, Energy and Economic Performance. The intent of the EO is to "establish an integrated strategy towards sustainability in the Federal Government and to make reduction of greenhouse gas emissions a priority for Federal Agencies." Section 13 requires the General Services Administration (GSA), in coordination with other Federal agencies, to provide recommendations on the impact of tracking and reducing greenhouse gas emissions within the Federal procurement process.

By April 1 of this year, the inter agency group, spearheaded by the GSA, is to provide recommendations on the integration of sustainability as well as greenhouse gas reporting into the federal procurement process. These recommendations would impact all government contracts, and would be overseen by each individual Federal agency. Recommendations are to consider the following:

• The feasibility of requiring vendors and contractors to register with a voluntary greenhouse gas registry;
• Requiring contractors to make available greenhouse gas inventories and efforts undertaken to mitigate emissions;
• Using the Federal purchasing preferences or other incentives for products manufactured using processes that minimize greenhouse gas emissions; and
• Other options for encouraging sustainable practices and reducing greenhouse gas emissions.

It is the intent of the GSA to develop a set of action oriented recommendations to implement the provisions found in Section 13 of the EO. However, it is anticipated that any changes in the procurement system will take several years.

For more information on this issue, please contact Marci Kinter at marcik@sgia.org.