Document KJJJYvEnM47nJJKe2jkKymmJX

A TO: Distribution Interoffice Communication FROM: DATE: SUBJ: T. G. Grumbles October 1, 1992 OSHA STANDARDS MOST FREQUENTLY CITED IN FY 1991 VISTA Attached is a chart indicating the mostly frequently cited standards. HAZCOM continues to lead the way as it has in past years. lt`s interesting to note that HAZWOPER is not on the list. I believe this is indicative of the fact that no enforcement/compliance guidelines have been completed and that inspectors simply aren't looking. T. G. Grumbles dlj dist2\344 Attachment Distribution: , SAFETY DIRECTORS Bruce Trego-Aber, Brent White-Bait, George Williams-Blane, Matt Tonkovich-Hrad, K. L. Fogg-LCCP, R. V. Gantz-LCLAB, Mike LunsfordLCVCM, Chris Markerson-Okc, Greg Lipps-Premiere, R. B. MartinAustin, J. R. Drumwright, J. G. Farrier, L. L. Zimmerman PLANT MANAGERS R. W. Seymour-Aber, L. R. Bauer-Balt, G. D. Williams-Blane, J. Pavao-Hmd, J. Friend-LCCP, J. W. Ware-LCLAB, P. Markey-LCVCM, H. D. Garrison-Okc, P. L. Foote-Prem, R. Ferrell-Austin VEV-146814 * must contain the chemical name and a hazard warning. The hazard warning should include the target organs affected. However, a recent ruling from the Occupational Safety and Health Review Commission (OSHRC) states that manufacturers do not have to list target organ warnings on container labels. The OSHA Instruction CPL 2-2.38C, Inspec tion Procedures for the Hazard Communicatioti Standard, October 22, 1990, details what OSHA wants in each section of Hazard Com munication compliance. The interpretation on labeling states: OSHA has interpreted this to include being apprised of the target organ effects of the hazardous chemicals employees are or may be exposed to while working... However, for shipped containers the hazard warning must be included on the label and must specifical ly convey the hazards of the chemical. OSHA has consistently maintained that this includes the target organ effects...There are some situations where the specific target organ effect is not known. Where this is the case, the more general warning statement would be permitted. American Cyanamid Co. was cited by OSHA, under Hazard Communication, for failing to describe on its labels which organs were affected by several of its hazardous chemicals. American Cyanamid appealed the citations to the OSHRC. The commission did not uphold OSHA's posi tion, requiring target organ effects on labels. Instead, because the Hazard Communication Standard is a performance-oriented rule, the commission felt that only minimal information was required on labels, and that other formats were the appropriate place for detailed data. These other formats would be on MSDSs and communicated during employee training. OSHA Standards Most Frequently Violated in Fiscal Year 1991 Subject Standard Section Hazard Communication/ General Industry Hazard Communication/ Construction Industry Lockout/Tagout Scaffolding Power Transmission Equipment Record Keeping Wiring Methods/General Industry OSHA Notice Machine Guarding Employee Exposure/ Medical-Records Access Wiring Design/Construction Respiratory Protection Guardrails Abrasive-Wheel Guarding General Electric Requirements Flammable and Combustible Liquids Wiring Methods/Construction Spray Finishing General Duty Clause 1910.1200 1926.59 1910.147 1926.451 1910.219 . 1904.2 1910.305 1903.2 1910.212 1910.20 1926.404 1910.134 1926.500 1910.215 1910.303 1910.106 1926.405 1910.107 Section 5(a)(1) Source: OSHA Up-to-Date, June 1992 Alleged Violations 19,214 16,894 6,110 5,001 4,995 4,623 4,323 4,185 4,090 3,939 3,922 3,868 3,555 3,405 3,115 3,049 2,761 2,666 2,228 VEV-146815