Page 71 - Occupational Health & Safety, September 2019

cians have the potential for direct contact with hazardous materials. Although it is typically on a smaller scale than in manu- facturing, lab employees may work with all the chemicals found in the manufacturing process as well as chemicals that are unique to the laboratory.
The OSHA Laboratory Standard (29 CFR 1910.1450) specifies that laboratory workers must be taught about the physical and chemical hazards in their work area, measures to take to protect themselves, and methods that they are to use to detect the presence or release of a chemical. They must also be taught about the details of the facility’s chemical hygiene plan.
Lobbies and Security
It is easy to overlook the need to train re- ceptionists and security personnel on the need to handle hazardous materials safely because they are not typically involved with receiving, operations or shipping. However, when there is an emergency, they are usu- ally among the first to be called to make evacuation announcements.
Including these personnel as well as buildings and grounds crews and other service areas in hazard communication trainings fosters a better understanding of potential hazards. It can also facilitate dialogue between different areas that pro- motes better site safety during emergencies.
Shipping
If all has gone well, the finished prod- ucts being shipped to customers should be packaged in containers that are in good condition. This helps to minimize the chance of exposure for anyone in the shipping crew.
If any product or waste being shipped contains a hazardous material that is sub- ject to DOT hazardous materials ship- ping regulations, employees involved in the shipping process may be considered hazmat employees (40 CFR 172.704) and need additional DOT hazmat employee training. This training helps them to rec- ognize shipments that need special packag- ing, labeling and marking to comply with DOT shipping requirements.
Following hazardous materials through their life cycle at the facility from the time they arrive as a raw material to the time when they leave as a product or a waste helps to ensure that the correct procedures
are put in place to handle them safely dur- ing each step of the process. Targeting training efforts on the specific needs within each area helps employees to focus on the specific actions they need to take to handle hazardous materials safety.
Karen D. Hamel, CSP, WACH, is a regu- latory compliance professional, trainer, and technical writer for New Pig. She has more than 22 years of experience helping EHS professionals find solutions to meet EPA, OSHA, and DOT regulations and has had more than 100 articles published
on a variety of EHS topics. She is a Cer- tified Safety Professional (CSP,) Walkway Auditor Certificate Holder (WACH,) Com- munity Emergency Response Team (CERT) trainer, hazmat technician, serves on the Blair County, PA LEPC, and has completed a variety of environmental, safety, emer- gency response, DOT and NIMS courses, including Planning Section Chief. She has conducted seminars at national confer- ences and webinars for ASSE and other national organizations. She can be reached at 1-800-HOT-HOGS® (468-4647) or by email, karenh@newpig.com.
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