51 Days: Do a walk-through!
SARA 312 Tier 2: 51 Days until deadline & counting down
(Even if you don’t do a physical inventory)
“Anything that goes on long enough becomes normal,” Mentor
If you conduct a physical inventory, you can do the walk through as part of it.
And if you don’t do a physical inventory, I highly, highly, HIGHLY recommend that you do a walk through of your facility.
Every aisle. Every nook and cranny. Every door that you’ve ever walked through without even wondering what was behind it (have Security help you).
Why? You will (probably) find all kinds of things that you wish you hadn’t (but now you can fix). Below is a link to a Safety+Health magazine article listing the 5 most common OSHA Hazard Communication Standard violations.
A walk through won’t help you with the first, failure to develop and maintain a written program, and probably won’t help you with the second, since you won’t have time to stop and ask workers about what they know about the chemials around them and where the Safety Data Sheets SDS’s are.
But you can take a sheet of labels with you so that you can label transfer containers (or hand that off to the department personnel, then come back to verify in a day or so that the labels were used).
In my experience, the way most companies demonstrate that they have a (Material) Safety Data Sheet SDS for each hazardous chemical is that they assign numbers to their SDS’s (typically the order they came in and were put in the filing cabinet), and they write those numbers on the containers.
So any container without an SDS number on it is suspect of not having a Safety Data Sheet in your system. This is especially true of items that appear to have been purchased from your local “big box” store and walked in.
For the last violation, an electronic version of the Safety Data Sheet is acceptable as long as the employees know that an electronic ap is how they look up SDS’s and can point you to the ap. Another item for verification during your (annual) update training. March 2nd, as the joke goes.
The most common problems you are likely to encounter during your walk-through that affect your ability to conduct Tier2 Threshold Determinations:
Unlabeled transfer containers.
Safety Data Sheet number not written on the container
Chemicals that appear to have been “walked in”, bypassing your receipt and labeling process
You may find a whole host of other minor operational issues that you may want to address (probably “virtually” March 2nd, after your Tier2 report is out the door)
I also recommend that you do some or all of the walk-through yourself. It was always amazing to me the things that departmental personnel didn’t notice. The most common was “Unlabeled containers? We didn’t include them on your inventory survey since they didn’t have a Safety Data Sheet Number on them”.
Call for community input:
Do you conduct a walk-through? In person or do you delegate it? What is the most interesting item you found?
(My most interesting “find” was a 55 gallon unopened drum of Arochlor (PCB transformer fluid) quietly sitting up against the wall of a 2nd floor vehicle assembly area. Hadn’t been manufactured since the 50’s).
More tomorrow, here’s to Mar 2nd!
