One of the steps I would undertake to ensure that the company complies with the HCS is ensuring the firm maintains all relevant MSDS for all concerned producers and manufacturers of the chemicals. Second, I would ensure that the Material Safety Data Sheets for all chemicals are under clearly printed on packages during their delivery as required by the relevant guidelines (United States Department of Labor, 2016). Thirdly is to make sure that all workers in the firm are aware of the risk involved in handling hazardous chemicals. Finally, the United States Department of Labor (2016) demands the need for training of all members of staff on the handling of these chemicals.
The problem is both a safety and regulatory point of view. The reason because members of staff who have worked at the facilities already have knowledge on the chemicals inside the pipes and tanks, hence making it a regulatory based problem. However, outsiders without information on the contents of the pipe ought to be protected by the labeling of the tanks, thus making it a safety issue (United States Department of Labor, 2016).
I would base my recommendations based on the United States Department of Labor's directives on the labeling. The guidelines under provision involve the employer ensuring that all containers with the hazardous chemicals have means of identification. The labeling ought to be done in such a manner as to show the name of the chemicals as well as amalgamate different signs, pictures, or both for clarification purposes (Haight, 2012). Besides, all the employers ought to ensure that the workers subject not all labels to interference.
The premature delivery of content shows that there was a problem either with the person giving the training or with the recipients of the information. According to Berkun and Longacre (2007), there ought to be an understanding between the trainer and the staff, which lacked in the above example. Similarly, there is need to ensure that adequate mechanisms are utilized especially in the presentation of the information. For instance, cracking jokes and getting to understand the staff would lead to their increased concentration and participation.
The improvement in future training is dependent on various attributes. First is the type of relationship between the OSHA officers who train the workers and the members of staff (Berkun and Longacre, 2007). Improvement in the relationships should be based on friendliness and not on fear or suspicion. Secondly getting to understand the audience concerning their preferences, goals is a prerequisite for success. Berkun and Longacre (2007) also urge the need for changing the setting or training criterion and environment. Finally encouraging of participatory training ought to involve group work coupled with discussions will lead to increased participation and understanding by the workers.
According to UC San Diego website (2016), the first step is checking out whether there is a Safety Data Sheet. Then submit the chemical to the appropriate OSHA officers or to the proper office in the firm, which was using the chemical. The last option may involve looking for the CAS number, which shows details about the manufacturer.
According to UC San Diego website, (2016) identifying whether a chemical is hazardous involves looking out for the Safety Data Sheet. In this case, compounds without the Safety Data Sheet are likely not to be dangerous. However one ought to make the deductions based on assessing whether the chemical has an acute oral LD50<=50mg/kg. Similarly, check out for an acute dermal LD50<=43mg per kilogram. If the answers are no then the chemical is probably hazardous. However, if the answers are affirmative, the chemical is extremely dangerous (Haight, 2012).
First, I would submit the chemical to the management and then find out the department that was using the chemical. These are the people that would provide a facilitating environment to obtain answers on the type of chemical and whether it is non-hazardous or hazardous (Haight, 2012). Inherently the other step is contacting the Environmental Health and Safety Centers for professional analysis of chemical.
Berkun, S., & Longacre, V. (2007, March 12). #29 – the problems with training. Retrieved from Scott Berkun, http://scottberkun.com/essays/29-the-problems-with-training/
Guidance for hazard determination for compliance with the OSHA hazard communication standard. (2016, September 21). Retrieved from United States Department of Labor, https://www.osha.gov/dsg/hazcom/ghd053107.html
Haight J.M. (2012) Hazard Material Management and Hazard Communication. American Society of Safety Engineers.
How to identify hazardous chemical waste. (2016, November 02). Retrieved from UC San Diego Faculty and Staff, http://blink.ucsd.edu/safety/research-lab/hazardous- waste/identify.html#2.-Determine-if-the-chemical-is
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