From: John Callen <jbcallen**At_Symbol_Here**GMAIL.COM>
Subject: Re: [DCHAS-L] EXTERNAL EMAIL: Focusing on Meeting Regulations When the Focus Should BE On What Makes Sense
Date: Tue, 27 Oct 2020 17:30:25 -0500
Reply-To: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU>
Message-ID: 3D5702A4-56C3-4E1E-8A9A-F8F9EE4681FA**At_Symbol_Here**

Yaritza & All:

Yaritza brings up a great point, which can be extended to industry as it relates to direct and indirect costs to manufacture a widget.

Those of you who can remember, witnessed or were a part of the large corporate and regional occupational health, safety and environmental affairs departments during the "hay days" of the 1960's through the mid-1980's, know that these positions have almost evaporated into thin air.  The reason was that industrial hygienists, health physicists, toxicologists, safety and environmental affairs managers, etc., were considered by the accountants and "bean counters" to be indirect costs to the manufacture of a widget.  Corporations, in order to make a profit and pay nice dividends to shareholders and bonuses to board members, sought ways to reduce these indirect expenses or "overhead," and consequentially, eliminating these positions seemed justified and the right thing to do.  I saw many of my friends, business colleagues and valued customers in these positions "let go" who in turn became consultants themselves or joined consultant firms.  In fact, I know of one industrial hygiene department who was let go and then told by their former employer to form their own firm so the company could hire them as consultants instead of keeping them as employees.

Richard (Rick) D. Fulwiler, PhD, CIH, CSHM, a true "EHS Legend in our Time," and a dear friend of mine, came to our defense through his insightful lectures and writings on the justification of these positions to "corner office management." He was then and still is a champion of our cause!  

Last Words: Keep a diary of what you do to justify your position and how you directly impact the "bottom line!" 

Be Safe and Stay Well!

All My Best,

John B. Callen, Ph.D.
3M Personal Safety Division - Retired
ACS/DCHAS Founding Member
(312) 632-0195

On Oct 27, 2020, at 4:07 PM, Yaritza Brinker <YBrinker**At_Symbol_Here**FELE.COM> wrote:

There=E2=80™s a saying in Spanish- "Barriga llena no cree en hambre ajena". This translates to "A full belly doesn't believe in a stranger's hunger".
When you work in an organization managed by chemists, it's a lot easier to get people to do the right thing for the right reasons regardless of whether it is required by regulation or not. When you work for a company that employs chemists and is run by accountants, then you have to leverage regulation to justify improvements in safety.
Cultural awareness is free, lab coats are a 1-time cost, and lab coat laundering is a recurring cost. To a chemist, it's a no brainer. To an accountant, you just increased the annual operating budget, decreased revenue, and messed with the annual bonus.
Yaritza Brinker
From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU> On Behalf Of Roger McClellan
Sent: Saturday, October 24, 2020 4:07 PM
To: DCHAS-L**At_Symbol_Here**Princeton.EDU
Subject: Re: [DCHAS-L] EXTERNAL EMAIL: Focusing on Meeting Regulations When the Focus Should BE On What Makes Sense

** External Email **

Protecting Individuals and Institutions.
To all;
  I would like to offer a different opinion on the issues of creating and maintaining a culture of chemical health and safety, training/education and documentation. Recall this is the DIVISION OF CHEMICAL HEALTH AND SAFETY.
 Why is the focus repeatedly on what are the government regulations? I start with a different premise-- as professionals I expect the senior members of this section to know based on their scientific training and experience  what is appropriate and makes sense to protect workers, the environment and institutions.
 I view federal , state  and local government regulations as a starting point. It is given that  these regulations and rules must be followed. However, for any particular situation I expect  individuals (be they employees , students, senior staff, Professors, independent investigators or institutional officials) to subscribe to a culture of chemical health and safety ---- of knowing what is right and  doing what is right. 
Why does this group so often address a health and safety issue by first asking what are the government rules and regulations. Do the individuals asking the question not know what is the right thing to do?
One has to start with creating and maintaining a culture of chemical health and safety. A few weeks ago  some one on this web site  raised the issue of appropriate clothing when using a glove box. One individual responded by noting he liked his casual attire. In my opinion, that response was ridiculous! I hope his studends DO NOT FOLLOW HIS EXAMPLE.  I  start with the assumption that the glove box is being used because hazardous materials are being used and the glove box is within a laboratory. I  subscribe to a view that special clothing should always be used in the laboratory. That is part of creating a culture of health and safety. Adherence to that culture is part of the privilege of working in a laboratory.
 I learned the importance of a  culture of health and safety and training and education and proper procedures  as a summer intern when working at the Hanford Nuclear Labs in Richland, WA in 1957. It had been  reinforced  years earlier when my father , who worked in the Hanford Chemical Separations facility, explained to me what was in the grey box that periodically appeared on the doorstep. When asked he responded -  "those are my pee bottle. I work with some hazardous materials and they check my urine to see if I have been exposed to anything bad. Some times accidents happen!" That introduced me to the use of bioassays. I later learned he worked in the PUREX operation separating Plutonium from irradiated Uranium.
Most recently, the discussion has focused on training and documentation of training. I was the senior official at two major laboratories, the Lovelace Inhalation Toxicology Research Institute and the Chemical Industry Institute of Toxicology. We worked with some very hazardous materials. We aspired to maintain a culture of safety and health promotion. We did a lot of training and educating, using both group sessions and individual to individual sessions.  Internal training was augmented by off-site training. 
Yes, we maintained records documenting training. The government agencies and private entities that funded are worked expected us to have such records. However, that is not why we maintained the records. We maintained them because you can not be operating a program of promoting health and safety if you do not have appropriate documentation ( who gave the instruction, who participated, what was the subject matter, when were the sessions held, etc). We managed our operations, they were not "happenings". Management requires documentation, records are mandatory. My Board of Directors set high standards for me and they expected me to set an example and set high standards for all our employees and operations.
The next time some one (your colleague, your Institute's CEO or a colleague) asks you what are the applicable government regulations  for a situation respond by asking them to explain the situation and then tell you what they think is the right thing to do  and why --- before you quote the applicable regulation.
Quite frankly I think as members of the Division of Chemical Health and Safety  we need to closely examine our own culture and expectations in protecting the health and safety of our co-workers and students and the Institutions we serve. 
   Roger O. McClellan
On Saturday, October 24, 2020, 11:22:04 AM MDT, Wright, Mike <mwright**At_Symbol_Here**> wrote:

The problem with OSHA-mandated training isn't documentation, it's quality. Most standards that require training don't directly require documentation; Powered Industrial Trucks is an exception, but even there what gets documented is the certification that the training leads to. Nevertheless, employers almost always "document" the training so they can prove they did it. That's usually done by a sign-in sheet. But that only documents attendance. OSHA will cite if the required training wasn't done, but I've never seen a citation for poor training. In the agency's defense, it would be hard to sustain, given how subjective the judgement would be.


Many of our employers do very good training, and they'd do it even if OSHA didn't exist. A lot of it is designed by joint safety committees, and delivered by experienced workers - both in classroom and on-the-job. We've also designed modules on hazard communication, process safety management, accident investigation and what we call "systems of safety," which is an expansion of the hierarchy of controls.


Sadly, however, some employers skimp on training. We've seen cases where a 10-minute video gets teed up, during which everybody signs a sheet, and bingo-they're all trained. We once ran a little contest to find the shortest employer hazard communication training. The winner came in at a little over three minutes.


We're also seeing a lot of OJT training being done by inexperienced workers, either because there's high turnover or because management doesn't want to assign the more experienced and productive older workers. We call it "green training green," and it's a real problem.  


The Hazwoper standard at least requires minimum training hours, but it's an exception. MSHA is a lot better. New miners get a week of classroom training (except in surface stone, sand and gravel operations), and then an 8-hour refresher every year. That doesn't guarantee quality, but it helps.


One last point: we use the word "training" a lot, but we really prefer "education." They may be synonyms, but to us, training deals with how to do a job. Education is a more thorough grounding in why it's done that way and how that job fits into the more general process. We've had fatalities where people followed the job steps precisely, but circumstances had changed in a way they didn't fully understand.  





Michael J. Wright

Director of Health, Safety and Environment

United Steelworkers


412-562-2580 office

412-370-0105 cell


"My friends, love is better than anger. Hope is better than fear. Optimism is better than despair. So let us be loving, hopeful and optimistic. And we'll change the world." 

                                                                                                                                                                                         Jack Layton





From: ACS Division of Chemical Health and Safety [mailto:DCHAS-L**At_Symbol_Here**Princeton.EDU] On Behalf Of Monona Rossol
Sent: Friday, October 23, 2020 8:09 PM
To: DCHAS-L**At_Symbol_Here**Princeton.EDU
Subject: EXTERNAL EMAIL: Re: [DCHAS-L] Fwd: OSHA COVID-19 Tip of the Day for October 23, 2020


There are many laws like Hazcom that require documented training.  I have a list somewhere of about 15 such laws. Monona

-----Original Message-----
From: Daniel Kuespert <0000057d3b6cd9b7-dmarc-request**At_Symbol_Here**LISTS.PRINCETON.EDU>
To: DCHAS-L**At_Symbol_Here**Princeton.EDU
Sent: Fri, Oct 23, 2020 4:12 pm
Subject: Re: [DCHAS-L] Fwd: OSHA COVID-19 Tip of the Day for October 23, 2020

No, they cannot. As I recall, there was a court decision (OSHA v. Westvaco?) that held that OSHA cannot require any documentation not specifically asked for by a reg. The decision had to do with the Process Safety Management standard, which has specific documentation requirements, and OSHA tried to cite Westvaco for not having some docs that they weren't required by reg to have. Annoyingly, I cannot find the reference, though. Might have been OSHRC, rather than a court, but I can't find it there either.


Figure on it this way: if it hasn't been through public review and comment (via the Administrative Procedures Act processes), then they'd be free to require different docs of different companies, which is kind of the definition of "arbitrary and capricious."


Regards, Dan

Sent from my iPad


On Oct 23, 2020, at 15:17, DCHAS Membership Chair <membership**At_Symbol_Here**> wrote:


I found today's Covid tip from OSHA odd. It's a "good idea" to document safety training? OSHA doesn't require this documentation?


- Ralph


Begin forwarded message:


From: "OSHA Tip of the Week" <**At_Symbol_Here**>

Subject: OSHA COVID-19 Tip of the Day for October 23, 2020

Date: October 23, 2020 at 9:11:04 AM GMT-4




Visit OSHA's website to see more safety tips of the day.

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Ralph Stuart, CIH, CCHO
Membership Chair
American Chemical Society Division of Chemical Health and Safety 

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