Business Aviation Insider - November/December 2013 (PREVIEW) - (Page 9)
Deadline Nears for Training Staff on New Hazard
A United Nations system for classifying and labeling chemicals is
being used to harmonize hazard
classification in the U.S., requiring
operators to update their training
programs and labeling systems
in phases through 2016, with the
first training requirement due on
NBAA offered training on this
topic during an Inspection
Authorization Renewal course
held in conjunction with its 2013
Convention in Las Vegas, and
at press time, NBAA also was
developing a webinar on the topic
to assist Members in fulfilling the
Dec. 1 training requirement.
An Occupational Safety and Health Administration (OSHA) regulation requires widespread
training of employees on a new Hazard Communication Standard (HCS) by Dec. 1.
"Every flight department, every company in the United States, has to comply with the
OSHA regulations for hazard communication for all their associates," says Marty Grier, a
member of the NBAA Safety Committee and senior manager of aircraft maintenance for The
Home Depot in Atlanta, GA.
The new training requirements apply not only to aircraft maintenance department employees and pilots, but also to all employees in a company who might come in contact with
hazardous materials while on the job.
"Every associate has to understand the new language used to communicate hazards in the
workplace," Grier said. "Every office person that uses ink...cleaning chemicals, all are going
to fall under these [new] standards."
OSHA's new Hazard Communication Standard is aimed at bringing the U.S. into compliance with the United Nations' Globally Harmonized System of Classification and Labeling
of Chemicals. The new OSHA requirement was published in the Federal Register in March
2012. The Dec. 1 HCS deadline is the first of a number of requirements related to this initiative that are scheduled to be phased in through June 1, 2016.
The number of chemicals present in a flight department hangar will vary widely, depending on the size and scope of the operation. For a single-aircraft operator that contracts out
its maintenance, the list might have fewer than a dozen items, such as fuel, oil, grease and
cleaning materials. On the other hand, a multi-aircraft flight department that employs its own
maintenance technicians might have more than 150 different chemicals that fall under the
new standards, Grier said.
Two of the most important elements in the new standards require use of new labeling
elements and a standardized format for safety data sheets, formerly known as material safety
data sheets. Both are aimed at improving worker understanding of the hazards associated
with the chemicals in their workplace.
Training on the new labeling elements must include information on the product identifier,
i.e., how the hazardous chemical is identified. This can be the chemical name, code number
or batch number. Manufacturers, importers or distributors can decide on the appropriate
In addition to written warnings, the new HCS includes a series of eight pictograms to alert
workers. The pictograms are in the shape of a square set at a point and include a black
hazard symbol on a white background with a red frame.
Hazard statements on labels describe the nature of a hazard and what sort of damage
or injury the chemical can cause. Precautionary statements consist of a phrase describing
recommended measures that should be taken to minimize or prevent adverse effects resulting from exposure to a hazardous chemical or its improper storage or handling.
During HCS training, employees must be shown how information on the label can be used
to ensure proper storage of hazardous materials and how to quickly locate first-aid measures
for use by workers and emergency personnel. ✣
For More Information
Visit OSHA's Hazard Communication website at www.osha.gov/dsg/hazcom.
November/December 2013 | 9
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