SCHC - Alliance Annual Report - January 12, 2005

ANNUAL ALLIANCE REPORT
The Occupational Safety and Health Administration
and the Society for Chemical Hazard Communication (SCHC)
January 12, 2005

  1. Alliance Background

    Date Signed

    October 22, 2003

    Evaluation Period

    October 22, 2003 ‐ October 21, 2004

    Overview

    OSHA's Alliance with SCHC focuses on working with small businesses and others and providing information and education that address issues associated with Hazard Communication and Material Safety Data Sheets (MSDSs) in the workplace. In addition, the Alliance will work to distribute information and increase awareness about the Globally Harmonized System (GHS) of Classification and Labeling of Chemicals.

    Implementation Team Members

    OSHA

    Patty Adair*
    Office of Outreach Services and Alliances (OOSA)
    Jackie Annis
    Directorate of Enforcement
    Karen Heckman
    Office of Training and Education
    David O'Connor
    Directorate of Standards and Guidance (DSG)
    Lisa Ramber
    OOSA
    Elizabeth Sherfy
    OOSA
    Jennifer Silk
    DSG

    ADC:

    Ann Brockhaus
    Vice President
    Denise Deeds
    President
    Bob Skogland†
    President (through March 2004)
    Michele Sullivan
    Chair

    *Patty Adair served as the Alliance Implementation Team Coordinator until May 2004
    †Bob Skogland served on the Alliance Implementation Team through March 2004

  2. Implementation Team Meetings

    December 3, 2003
    Kick-Off Implementation Team Meeting, Washington, DC
    March 16, 2004
    Implementation Team Meeting, Teleconference
    September 27, 2004
    Implementation Team Meeting, Teleconference

  3. Results

    1. Events and Products

      Training and Education Goal

      • Develop training and education programs to assist employers in complying with hazard communication requirements, and in preparing labels and MSDSs. Arrange to have these programs delivered in various locations around the country to reach small businesses.

        ‐ No products or resources have been developed to meet this Alliance goal.

      Outreach and Communication Goals

      • Develop and disseminate information through print and electronic media, including electronic assistance tools and links from OSHA's and SCHC's Web sites.

        Products

        Hazard Communication Safety and Health Topics page

        Representatives from the OSHA-SCHC Alliance helped to review and revise OSHA's Hazard Communication Safety and Health Topics page. Additionally, the following representative from SCHC serves as a member of the editorial board of OSHA's Hazard Communication Safety and Health Topics page:

        • Dan Levine, Product Safety Solutions, SCHC Board of Directors

        SCHC and OSHA Web pages

        The SCHC Website features a page about the OSHA-SCHC Alliance, which includes information about the goals of the Alliance and links to OSHA's Alliance Program and Hazard Communication resources.

        The OSHA-SCHC Alliance Webpage on OSHA's Website features information on the products and activities of the Alliance and includes links related documents, activities and events and milestones and successes. For information on the number of visits to the OSHA-SCHC Alliance Webpage, please see the Alliance Program Reach table on page 6.

        Print and Electronic Media

        Articles on the OSHA-SCHC Alliance have appeared in a number of printed and online publications, including: the SCHC Newsletter, OSHA's Press Releases and Alliance Quarterly Review and Quick Takes, BNA Daily Labor Report, and Business and Legal Reports. Over 50,000 individuals were reached through the publications. For more information on the articles, please see the Alliance Program Reach table on page 6.

      • Share information with, provide technical expertise and contribute to publications regarding safety and health issues, including Hazard Communication, MSDSs and the GHS.

        Checklist of MSDSs

        As part of the Alliance, SCHC is developing a checklist for MSDSs for OSHA to adopt for use by OSHA Compliance Safety and Health Officers (CSHOs) and members of the public.

      • Speak, exhibit, or appear at OSHA's and SCHC's conferences and local meetings, such as the SCHC's Spring and Fall meetings.

        2004 OSHA Compliance Assistance Training Sessions

        Representatives from SCHC exhibited at the 2004 OSHA Compliance Assistance Training Sessions, which were held June 14-18, 2004, in Falls Church, Virginia.

      • Work with other Alliance participants on specific issues and projects related to Hazard Communication, MSDSs and the GHS that are addressed and developed through the Alliance Program.

        American Industry Hygiene Association

        SCHC asked the American Industrial Hygiene Association (AIHA), another Alliance Program participant, to review and comment on the draft MSDS checklist that SCHC is developing for OSHA to adopt and make available to its CSHOs and the public.

      • Build relationships with OSHA's Regional and Area Offices and Ed Centers and present training seminars that address health and safety issues, including Hazard Communication, MSDSs and the GHS.

        ‐ No products or resources have been developed to meet this Alliance goal.

      • Cross-train OSHA personnel and industry safety and health professionals in SCHC's effective approaches, as jointly determined by OSHA and SCHC.

        ‐ No products or resources have been developed to meet this Alliance goal.

      • Promote and encourage SCHC's members' participation in OSHA's cooperative programs such as compliance assistance, the Voluntary Protection Programs, Consultation, and its Safety and Health Achievement Recognition Program.

        ‐ No products or resources have been developed to meet this Alliance goal.

      Promoting the National Dialogue on Workplace Safety and Health Goals

      • Convene or participate in forums, roundtable discussions, or stakeholder meetings on Hazard Communication, MSDS and GHS issues to provide input and help forge innovative solutions in the workplace.

        Senate Subcommittee on Employment, Safety and Training's Hearing "Hazard Communication in the Workplace"

        Representatives from both OSHA and SCHC testified at the 2004 Senate Subcommittee on Employment, Safety and Training's Hearing "Hazard Communication in the Workplace", which was held March 25, 2004, in Washington, DC.

        • March 25, 2004: Statements of John Henshaw, former Assistant Secretary of Labor for Occupational Safety and Health, and Michele Sullivan, Chairman SCHC.

        AIHce: "Promoting OEHS Excellence":

        Representatives from both OSHA and SCHC spoke at the 2004 AIHce: "Promoting OEHS Excellence," which was held May 8-13, 2004, in Atlanta, Georgia.

        • May 12, 2004: "Creation and Evolution of Material Safety Data Sheets: Cradle-to-Cradle -- Birth of the New GHS SDS Era!" ‐ "Government Perspective." Jennifer Silk, Deputy Director, Directorate of Standards and Guidance (DSG), USDOL-OSHA and "Professional Society Perspective." Michele Sullivan, Chair, Board of Directors, SCHC, MRS Associates, Arlington, VA.

        • May 11, 2004: "The Globally Harmonized System (GHS) of Classification and Labeling of Chemicals." Jennifer Silk, Deputy Director, Directorate of Standards and Guidance, USDOL-OSHA.

        Connecticut Business and Industry Association (CBIA) Health and Safety Conference

        A representative from SCHC spoke at the CBIA Health and Safety Conference, which was held April 27-28, 2004, in Southington, Connecticut.

        • April 28, 2004: GHS: Hazcom for the 21st Century." Denese Deeds, SCHC President.

        SCHC Spring 2004 Meeting

        Representatives from OSHA and SCHC spoke at the SCHC Spring 2004 Meeting, which was held March 20-24, 2004, in New Orleans Marriott Hotel, New Orleans, Louisiana.

        • March 23, 2004: "OSHA's Hispanic Initiatives/Multilingual HazCom Issues." John Miles, OSHA Regional Administrator.

        • March 23, 2004: "Update on OSHA-SCHC Alliance." Robert Skoglund, SCHC President.

        • March 23, 2004: "SCHC-OSHA Alliance." Poster Session, SCHC Alliance Committee.

        Intergovernmental Forum on Chemical Safety IV, "Chemical Safety in a Vulnerable World"

        A representative from SCHC spoke at the Intergovernmental Forum, on Chemical Safety IV, "Chemical Safety in a Vulnerable World," which was held November 1-7, 2003, in Bangkok, Thailand.

        • November 1, 2003: "Implementing the GHS: Opportunities and Challenges." Robert Skoglund, SCHC, President.

        SCHC Fall 2003 Meeting

        A representative of the OSHA-SCHC Alliance spoke at the SCHC Fall 2003 Meeting, which was held at October 18-22, 2003, in Crystal City, VA.

        • October 22, 2003: "OSHA-SCHC Alliance," Michelle Sullivan, SCHC Chair.

    2. Executive Summary

      Through the Alliance Program, OSHA and SCHC have reached out to SCHC's members and others, nationally and internationally, with information, guidance, and access to training resources to help them protect employees' health and safety, particularly by addressing issues associated with Hazard Communication, MSDSs and the GHS.

      In its first year, the OSHA-SCHC Alliance developed several resources with information about the Alliance, Hazard Communication, MSDSs and the GHS. The OSHA-SCHC Alliance Webpage on OSHA's Website features links to related documents, activities and events, and milestones and successes. The SCHC Website provides SCHC members and other visitors to the site with information on the OSHA Alliance, OSHA's Hazard Communication Initiative and other related resources. Additionally, members of the implementation team helped to review and revise OSHA's Hazard Communication Safety and Health Topics page and an SCHC representative continues to serve on the editorial board.

      As part of the Alliance, SCHC is developing an MSDS checklist for OSHA to adopt for use by OSHA CSHOs and members of the public. In addition, SCHC asked AIHA, another Alliance Program participant, to review the draft checklist. SCHC will submit the checklist to OSHA, which will put the checklist through the Agency's clearance process to become an official OSHA document.

      Representatives from the OSHA-SCHC Alliance made presentations and exhibited at many conferences and meetings during the first year of the Alliance to promote the Alliance and information to the public about Hazard Communication-related issues, including the 2004 OSHA Compliance Assistance Training Sessions, the 2004 AIHce: "Promoting OEHS Excellence," the Connecticut Business and Industry Association (CBIA) Health and Safety Conference, the SCHC Spring 2004 Meeting and Fall 2003 Meeting, and the Intergovernmental Forum on Chemical Safety IV, "Chemical Safety in a Vulnerable World."

    3. Alliance Program Reach

      Type of Activity (Conference, Training, Print and Electronic Distribution, etc.) Number of Individuals Reached or Trained
      OSHA Compliance Assistance Training Sessions, June 14-18, 2004, in Falls Church, VA
      • SCHC Exhibit
      		 230
      2004 AIHce: "Promoting OEHS Excellence," May 8-13, 2004, in Atlanta, GA
      • Presentation on May 12, 2004, by Jennifer Silk, Deputy Director, DSG, USDOL-OSHA, and Michele Sullivan, Chair, SCHC, on "Creation and Evolution of Material Safety Data Sheets: Cradle-to-Cradle ‐ Birth of the New GHS SDS Era!"
      		 180
      2004 AIHce: "Promoting OEHS Excellence," May 8-13, 2004, in Atlanta, GA
      • Presentation by on May 11, 2004, by Jennifer Silk, Deputy Director, DSG, USDOL-OSHA, on "The Globally Harmonized System (GHS) of Classification and Labeling of Chemicals."
      		 150
      Connecticut Business and Industry Association (CBIA) Health and Safety Conference, April 27-28, 2004, in Southington, Connecticut
      • Presentation on April 28, 2004, by Denese Deeds, SCHC President, on "GHS: HazCom for the 21st Century."
      		 Data Not Available
      SCHC Spring 2004 Meeting, March 20-24, 2004, at the New Orleans Marriott Hotel in New Orleans, Louisiana
      • Presentation on March 23, 2004, by Robert Skoglund, President, SCHC on "Update on OSHA-SCHC Alliance"
      		 160
      SCHC Spring 2004 Meeting, March 20-24, 2004, at the New Orleans Marriott Hotel in New Orleans, Louisiana
      • Presentation on March 23, 2004, by John Miles, OSHA Regional Administrator, on "OSHA's Hispanic Initiatives/Multilingual HazCom Issues."
      		 160
      SCHC Spring 2004 Meeting, March 20-24, 2004, at the New Orleans Marriott Hotel in New Orleans, Louisiana
      • Poster presentation on March 23, 2004, by SCHC Alliance Committee on "SCHC-OSHA Alliance"
      		 160
      Intergovernmental Forum on Chemical Safety IV, "Chemical Safety in a Vulnerable World" November 1-7, 2003, in Bangkok, Thailand.
      • Presentation on November 1, 2003, by Robert Skoglund, SCHC President, on "Implementing the GHS: Opportunities and Challenges."
      		 Data Not Available
      SCHC Fall 2003 Meeting, October 18-22, 2004, in Crystal City, VA.
      • Presentation on October 22, 2004, by Michelle Sullivan, Chair, SCHC, on "OSHA-SCHC" Alliance.
      		 150
      OSHA-SCHC Alliance Webpage on the OSHA Website 4,649
      SCHC Webpage featuring information on the Alliance Data Not Available
      Hazard Communication Safety and Health Topics page 12,000
      October 22, 2003 ‐ OSHA distributed a press release announcing the Alliance signing 25 News Services
      October 23, 2003 ‐ "OSHA Working on Several Initiatives on Hazard Communication," BNA Daily Labor Report Data Not Available
      October 23, 2003 ‐ "OSHA Enters Alliance for Chemical Safety," Business and Legal Reports Data Not Available
      November 1, 2003 ‐ "National Alliance Focuses on Chemical Safety," QuickTakes 50,000
      Fall 2003 ‐ "SCHC Signs OSHA Alliance," SCHC Newsletter 1,000
      Fall 2004 ‐ "Seeking Volunteers," SCHC Newsletter 1,000
      TOTAL 69,839

  4. Upcoming Milestones

    In the second year of the Alliance, OSHA and SCHC will continue to provide information, guidance, and access to training resources to protect employees' health and safety, particularly in the areas associated with Hazard Communication, MSDSs and the GHS.

    Members of the Alliance implementation team plan to participate in SCHC's 2004 Fall Meeting, which is scheduled for October 26-27, 2004, making presentations on the OSHA-SCHC Alliance, OSHA's Hazard Communication Initiative, Control Banding and the GHS. Additionally, OSHA plans to staff an exhibit booth with information about the OSHA-SCHC Alliance, the Alliance Program, and OSHA's other cooperative programs and compliance assistance resources

    OSHA and SCHC plan to finalize the MSDS checklist and give it to OSHA for Agency approval. A representative from the Alliance will continue to serve on the editorial board for OSHA's Hazard Communication Safety and Health Topics page. The implementation team is going to identify additional tools and training for the developers and users of MSDSs, particularly small businesses. The Alliance also will consider a number of other projects, including:

    • developing curriculum for a half-day workshop for small businesses and making it available to OSHA's Ed Centers;
    • creating a refresher training course OSHA's Compliance Officers that would cover discrepancies that commonly appear on MSDSs and explain how to review an MSDS to ensure that it's up-to-date and accurate;
    • developing a reference tool (e.g. interactive CD) that could be targeted towards helping small businesses complete an MSDS;

    • developing a PowerPoint® presentation to accompany a hazard determination guidance document developed by OSHA as part of the Agency's Hazard Communication Initiative. The presentation could be given to OSHA's Regional and Area Offices and Compliance Assistance Specialists for use in the field.

    Representatives from the OSHA-SCHC Alliance are looking for opportunities to work with other Alliance Program participants on projects related to Hazard Communication. OSHA and SCHC Alliance implementation team members will participate in the Alliance Hazard Communication Roundtable scheduled for February 15, 2005, which will give Alliance Program participants an excellent opportunity to learn about the status of OSHA's Hazard Communication Initiative; share information about their own Alliances, including any activities related to Hazard Communication; and learn about what other Alliances are doing to address Hazard Communication issues. The roundtable also will enable Alliance Program participants to establish workgroups and identify projects they can work on together to develop Hazard Communication-related compliance assistance resources.

    Report prepared by: Elizabeth Sherfy, Alliance Coordinator, Office of Outreach Services and Alliances, January 12, 2005.