The deadline for employers to train employees on the new GHS system is December 2013.

December 1, 2013
December 1, 2013

It is our pleasure to provide you with the essential links to the materials you need for providing the training your employees will need.
Final Rule : https://www.osha.gov/dsg/hazcom/GHSfinal-rule.pdf
OSHA Guide to GHS: https://www.osha.gov/dsg/hazcom/ghs.html
Training Requirements: https://www.osha.gov/Publications/OSHA3642.pdf
Labels and Pictograms: https://www.osha.gov/Publications/OSHA3636.pdf
Safety Data Sheets: https://www.osha.gov/Publications/OSHA3514.pdf
And just a note, the GHS pictograms do NOT replace those  diamond shaped DOT labels we’re also used to seeing.
disodium flammy
By the way we posted on this originally in March of 2012.

PMPA invited Assistant Secretary of Labor, OSHA Director David Michaels, PhD, MPH to speak to attendees at our Management Update Conference held last week in Glendale, Arizona.

"OSHA levels the playing field for responsible employers competing with those who cut corners on safety."
“OSHA levels the playing field for responsible employers competing with those who cut corners on safety.”

PMPA member companies, and OSHA, share a committment to worker safety, reducing hazards, and operating safe workplaces.

So we thought that it would be good to hear from OSHA first hand about their programs and approach to their job, since the view from  us in the regulated community  seems to be one quite focused on adversarial enforcement.

Here are a half a dozen thoughts shared by Director Michaels on OSHA and its role.

  • “Given (very) limited resources, OSHA’s challenge is to apply the most efficient mix in order to maximize the abatement of hazards and therefore the prevention of injuries, illnesses, and fatalities.”
  • “OSHA provides training resources in multiple languages to aid employers in training employees in all occupations  so that they can safely perform their jobs.”
  • “It always makes us laugh when we are asked ‘How many OSHA standards have you issued this month?’ We issue about one standard a year, and have for the last four years. Last year we issued one on the Globally Harmonized System. However, our standards have an impact. Our standards save lives.”
  • “We just issued our new GHS- Globally Harmonized Standard- for communicating hazards in materials you get. This will assure that the cmmunications and information that you get on the possible hazards that these materials may present  is much better than what you have been getting. They use pictograms so workers can see immediately the type of hazard without reading.”
  • “OSHA is not just an enforcement agency. We provide many resources for compliance assistance. In 2011, we had 200 million visitors to our website, over 200,000 responses to OSHA 1-800 for help, replied to over 33,000 emails for assistance, conducted 5,300 outreach activities regionally and in our area offices. We performed about 27,000 small business consultations in 2012. Our  budget for consultation  assistance programs increased $3.2 million over 2011 budget.”
  • “In the last full year of the previous administration, OSHA did 39,324 inspections; in 2012, we did 40,961. We get about 40,000 inspections per year. What we try to do is to get our inspections targeted, to do everything that we can to make those 40,000 inspections useful. We try to assure the effectiveness of our enforcement efforts.”

Having the regulated community (that’s us) see the fines and press releases and press coverage of OSHA enforcement is one way that OSHA can leverage its limited staff and resources to promote safety in all industries and shops, not just the ones they visit. OSHA has certainly been successful on that account!

Dr. Michaels’ visit to the PMPA Management update meeting helped me, and our attendees, get a bit of understanding, a bit of empathy, of what the challenge must look like for OSHA. I recall a line from To Kill A Mockingbird:

“You never really know a man until you understand things from his point of view, until you climb into his skin and walk around in it.”

PMPA thanks Dr. Michaels for taking the time to address us and our concerns about  the perceived enforcement focus.