Safety data sheet (SDS’s) are intended to inform manufacturers, users, and suppliers of chemical hazards, especially if there is a danger to the human body and/or the environment. Additionally, SDS’s alert users to measures that need to be taken should there be risk of exposure. On top of that, SDS labels are meant to bring attention to dangers in a quick and efficient manner.
Manufacturers of chemicals may be the only individuals involved in the label-generation process, but suppliers and users should also heed the warnings and, subsequently, take the necessary steps to keep workers safe. These additional steps include providing adequate training, providing respirators, providing protective gear, and providing safe infrastructure to handle the chemicals. Any employer who does not provide for all of the OSHA required protection and training is at risk of violation penalties.
Willful negligence was the case at WKW Erbsloeh North America Inc’s Pell City, Alabama facility. A worker was standing above acid-filled tanks while helping with tank maintenance when he slipped, fell backwards, and was submerged in the tank’s highly corrosive phosphoric and sulfuric acid. The man was saved before suffering severe burns to his face and internal organs. WKW was issued a willful citation for exposing workers to falls from walkways without OSHA-required railings and toe-boards. A willful violation is one committed with intentional, knowing, or voluntary disregard for the law’s requirement, or with plain indifference to worker safety and health.
OSHA also issued WKW two repeated violations for failing to ensure that machinery would not start up while workers performed machine maintenance and service and for not training workers on how to prevent accidental startup. Five serious citations were issued:
1. Failing to provide workers with equipment to prevent accidental machine startup
2. Not ensuring that workers followed procedures to prevent accidental machine startup
3. Failing to monitor air quality inside chemical tanks that workers enter
4. Not warning workers on the hazards of confined spaces
5. No periodic inspections of worker procedures to prevent accidental machine startup.
In April 2013, OSHA announced an initiative to use outreach, training, and enforcement to improve workplace safety and health for temporary workers. The National Institute for Occupational Safety and Health has also issued a “Recommended Practices” publication that focuses on ensuring temporary employees received the same training and protection as permanent workers.
When regulation-enforcing organizations update their policies and release documents that would assist employers in maintaining a safe workplace, it is extremely important to quickly familiarize yourself with these new and available resources so as to prevent violations from occurring. Since the GHS Purple Book is updated frequently with updates to new or existing regulations, it is imperative that manufacturers, suppliers, and users are up-to-date with GHS compliance policies.
