NC State of Business

The famous “Golden Arches” indicate the McDonald’s restaurant, regardless of the country in which you are located. The universal symbol of a cigarette with an X marked through it indicates that smoking is not allowed, regardless of the country. For chemical classification, the symbol for a toxic or flammable chemical may be different in the US than in other countries where chemicals are imported or exported. In fact, within the US we currently are charged with understanding the classification and labeling of hazardous chemicals between various regulatory agencies: Department of Transportation (DOT), Environmental Protection Agency (EPA), Occupational Safety and Health Administration (OSHA), and others.

Enter the Global Harmonization System (GHS), an internationally harmonized approach to classification and labeling of chemicals. This voluntary system provides the foundation for all countries to develop comprehensive national programs to ensure the safe use of chemicals. In other words, a chemical labeled with the words “Highly Flammable”, and a symbol of a flame, has the same meaning in the US as in Italy.

GHS introduces standard elements for chemicals:

• Hazard statement- phrases assigned to hazard categories; e.g. “Harmful if swallowed”
• Pictograms – symbol inside a diamond with a red border; e.g. a skull and crossbone
• Precautionary statement - phrases describing measures to minimize or prevent adverse effects
• Product identifier - Names or numbers used on a hazardous product label or in a safety data sheet
• Signal word - One word used to indicate the relative severity of hazard; e.g. “Warning” or “Danger”
• Supplier Identification - name, address and telephone number of the manufacturer or supplier of the substance

Keep in mind that this system is voluntary, and the US has yet to fully embrace the implementation of GHS. However, in the past week OSHA issued a proposed rule to adopt the Globally Harmonized Hazard Communication System. This is a tremendous step in aligning the OSHA Hazard Communication standard, 29 CFR 1910.1200, with the elements of GHS.

The EPA presents methods for implementation of GHS within their organization.

How does this affect you? If you manufacture, import, and/or export chemicals, you will be classifying and labeling your products according to this international system. Employees that handle or store chemicals will need updated training on the identification of hazardous chemicals in the workplace. And perhaps in the US we can enjoy regulatory agencies that align their definitions of hazardous chemicals.

Last week I visited a meeting in Williamston hosted by the Northeast Alliance for Agricultural Biotechnology. There was a buzz around this group as they received a check from the NC Tobacco Trust Fund and as we where shown some preliminary design and location analysis models for an area Pilot Extraction Facility. This project will allow the Alliance to attract research and development activities into the eastern NC area leading to important breakthroughs in agricultural biotechnology. From food to medicine to fragrance, we rely on the extraction process to convert the important ingredients from specialty grown plants to chemicals ready for use by production processes.

I was intrigued by the emphasis placed on establishing a formal quality management system in support of the development and operation of this new facility along with the interaction between local biotech growers and agricultural biotech companies to safely grow new genetically modified crops. We have been asked to support their efforts in creating the appropriate quality management system processes to align with the emerging USDA Biotechnology Quality Management System (BQMS) program.

It seems like just yesterday when business owners more often than not spoke of ISO 9000 and its quality management system standard requirements as a relic destined for extinction. As I look at the draft version of the BQMS, I see the familiar structure and basic quality management system requirements of the ISO 9001 standard as it was released in its new process-focused format during 2000. We now see the biotechnology industry join what now appears to be a worldwide consent that the fundamental guidelines of ISO 9000 represent a successful blueprint for consistency, quality, and safety.

So from the brink of perceived extinction, certified quality management systems based on ISO 9001 requirements now appear to have amazingly proliferated so much so that emerging industries are investing in establishing appropriate standards as part of new process commitments. What an evolutionary concept!

Cleanliness in the workplace may be subjective among your employees. OSHA requires good housekeeping, as 29 CFR 1910.22 indicates, “All places of employment, passages, store rooms and service rooms shall be kept clean, orderly, and in a sanitary condition.”

However, if your organization contains combustible dust hazards, one of the best methods to avoid the potential for a combustible dust explosion is to enforce good housekeeping rules. This is not subjective. NFPA 654 warns that a dust layer >1/32 of an inch accumulated on surface areas of at least 5 percent of a room’s floor area presents a significant explosion hazard. The Chemical Safety Board found that the West Pharmaceutical explosion in Kinston, NC in 2003 was caused by dust accumulations primarily under ¼ inch.

Materials that may form combustible dust include metals (such as aluminum and magnesium), wood, coal, plastics, biosolids, sugar, paper, soap, dried blood, and certain textiles. Since 1980, more than 130 workers have been killed and more than 780 injured in combustible dust explosions.

OSHA has not only identified a National Emphasis Program on combustible to educate employers of combustible dust hazards, it recently announced that an Advanced Notice of Proposed Rulemaking will be issued. Stay tuned for this regulatory agenda, and start evaluating your worksite for combustible dust hazards. Find more information here.

Finally, to all of you in the profession of protecting workers, happy North American Occupational Safety and Health week. Check out the safety posters created by children of members of the American Society of Safety Engineers!