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Do Office Employees Need Training for GHS (Globally Harmonized System of Identification of Hazardous Substances)?

Back in 2013, employers were advised of the requirement to train employees regarding new label elements and safety data sheets but there have been questions about why some employees would need to be trained. For example, an office employee cleans their desk surface weekly with a cleaning product purchased by the employer from a grocery store and is available for employee use. Is GHS training required for that employee?

The Technical Answer
California Code of Regulations 5194(b)(5)(G) excludes incidental use as follows:
(G) Consumer products packaged for distribution to, and use by, the general public, provided that employee exposure to the product is not significantly greater than the consumer exposure occurring during the principal consumer use of the product; GHS training is required for employees working with hazardous substances on a regular basis in the course and scope of their employment.

The Practical Answer
GHS Training is not required for incidental use of a consumer product used in a consumer manner but general awareness training for all employees of the hazardous material identification system would be considered wise and a ‘best practice’ for all employers. Why? Because in the event of an injury to an employee caused by substances in the workplace, it could be deemed negligent that an employer provided a product but not information of its hazardous nature. Free information and GHS training materials are readily available from many sources, see below.

Still unsure of whether to train? Call OSHA Compliance 916-263-0704. I reached a knowledgeable person on my first try and/or call your insurance agent/broker for information.

Resources
California Code of Regulations-Hazard Communication https://www.dir.ca.gov/title8/5194.html
Cal OSHA Safety and Health Fact Sheet on GHS-Globally Harmonized System-DIR http://www.dir.ca.gov/dosh/dosh_publications/ghs_fs.pdf
Guide to the California Hazard Communication Regulation-DIR https://www.dir.ca.gov/dosh/dosh_publications/hazcom.pdf
US Department of Labor –OSHA Hazard Communication https://www.osha.gov/dsg/hazcom/index.html
Free PowerPoint presentation http://www.osha.gov/SLTC/hazardcommunications/ghsoverview.ppt
Free YouTube Training Video https://www.youtube.com/watch?v=PkGbof7FeZA
Sacramento Safety Center http://safetycenter.org/

If you have any questions or comments, please do not hesitate to contact me.

Jackie Sudia-Reno, AIC, ARM, CRIS
Claims and Risk Management Liaison
Warren G. Bender Co.
License #0406967
jsudia@wgbender.com
(916)380-5333 (Direct Phone & Fax)
(916)960-6957 (Mobile/Text)

Filed under: OSHA,Property & Casualty,Safety — Jillian Bender-Cormier @ 1:29 pm March 30, 2016


Oh Rats! Surprising Risks You Should Know About the Drought

By: Jackie Sudia-Reno, AIC, ARM, CRIS, Claims & Risk Management Liaison, Warren G. Bender Co.

We’re all changing the way we do things due to the severe drought that our area is experiencing. Here is an example of an unexpected consequential hazard from the drought…

A large commercial building sustained water damage; the culprits are rats. The rats chewed holes in condensation water lines above the ceiling tiles of the building to get to the water inside. When the hot weather hit and the condensation flow increased for several days running, the water escaped through the holes in the lines and caused major damage to the ceiling, walls, and flooring which produced mold growth quite quickly into the warm air. (more…)

Filed under: Property & Casualty,Safety — Jillian Bender-Cormier @ 6:17 pm June 25, 2015


CNA Endorsed By California Manufacturers & Technology Association

cnaSAN FRANCISCO, May 19, 2015 /PRNewswire/ — CNA and the California Manufacturers & Technology Association (CMTA) today announced that CNA has been chosen as the endorsed business insurance carrier of choice by the CMTA.

As a world leader in advancing safety and writing coverages across 90 percent of all manufacturing classes, CNA was selected by the CMTA, working with broker Warren G. Bender Co., because of its depth of experience in the industry, financial strength and expertise in coordinating end-to-end coverage programs for today’s modern manufacturers.

“This endorsement affirms CNA’s positon as the premier provider of insurance coverages, claim and risk control services for manufacturers,” said Franklin Maccotan, director and industry leader, Manufacturing, CNA. “CNA’s goals align with the CMTA’s mission of helping California manufacturers protect the safety of their employees and the public, as well as the assets of its members. The endorsement allows CNA to be even more responsive to the unique needs and concerns of the manufacturing community.”

The CMTA represents over 400 manufacturing, processing and technology-based companies, and works to improve a strong business climate for an economic sector that generates more than $230 billion annually and employs more than 1.2 million Californians.

“CMTA is proud to announce its partnership with CNA to deliver a premier and cost-competitive commercial insurance package to its members,” said Dorothy Rothrock, president, CMTA. “California manufacturers are the backbone of our state’s economy and innovation. Because comprehensive insurance protection and effective risk control support is a critical component to operating in California, the CMTA looked at many potential partners. CNA, with its experience and long history of end-to-end coverage and manufacturing focus, was the clear choice to deliver the best program.”

CNA is the endorsed business insurance carrier for more than 15 national trade associations, including the Fabricators & Manufacturers Association, International (FMA) and the National Precast Concrete Association (NPCA). CNA is also a member of the National Association of Manufacturers (NAM).

To learn more about CNA’s manufacturing industry capabilities, visit www.cna.com/manufacturing.

About CNA
Serving businesses and professionals since 1897, CNA is the country’s eighth largest commercial insurance writer and the 13th largest property and casualty company. CNA’s insurance products include standard commercial lines, specialty lines, surety, marine and other property and casualty coverages. CNA’s services include risk management, information services, underwriting, risk control and claims administration. Please remember that only the relevant insurance policy can provide the actual terms, coverages, amounts, conditions and exclusions for an insured. All products and services may not be available in all states and may be subject to change without notice. Use of the term “partnership” and/or “partner” should not be construed to represent a legally binding partnership. For more information, please visit CNA at www.cna.com. “CNA” is a service mark registered by CNA Financial Corporation with the United States Patent and Trademark Office. Certain CNA Financial Corporation subsidiaries use the “CNA” service mark in connection with insurance underwriting and claims activities.

About CMTA
CMTA works to create a strong business climate for a manufacturing sector that generates more than $230 billion in revenue every year and employs more than 1.2 million Californians. For more information, please visit the CMTA at www.cmta.net.

CONTACTS:
Andy Viglietti, 916-498-3340, CMTA
Gino DiCaro, 916-498-3347, CMTA
Brandon Davis, 312-822-5167, CNA
Sarah Pang, 312-822-6394, CNA

SOURCE CNA; California Manufacturers & Technology Association (CMTA)

Filed under: Property & Casualty — Jillian Bender-Cormier @ 2:09 pm May 19, 2015