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ANNUAL ALLIANCE REPORT

The Occupational Safety and Health Administration
and
Society for Chemical Hazard Communication (SCHC)

January 30, 2006


  1. Alliance Background

    Date Signed

    October 22, 2003

    Evaluation Period

    October 22, 2004 ‐ October 21, 2005

    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 is distributing information and increasing awareness about the Globally Harmonized System (GHS) of Classification and Labeling of Chemicals.

    Implementation Team Members

    OSHA:

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

    SCHC:

    Ann Brockhaus
    Vice President
    Denise Deeds
    President
    Michele Sullivan
    Chair
  2. Implementation Team Meetings

    January 14, 2005
    Implementation Team Meeting, Washington, DC
    February 15, 2005
    Alliance Program Hazard Communication Roundtable, Washington, DC
    April 26, 2005
    Implementation Team Meeting, Teleconference
    August 1, 2005
    Alliance Program Workgroup Promoting the Globally Harmonized System for Classification and Labeling of Chemicals Meeting, Washington, DC
    August 10, 2005
    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.

      During this reporting period, OSHA and SCHC did not work on projects to address this 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

      OSHA's Hazard Communication Safety and Health Topics page

      Representatives from the OSHA and SCHC Alliance continue to review and revise OSHA's Hazard Communication Safety and Health Topics page. Additionally, the following representatives from SCHC serve as members of OSHA's Hazard Communication Safety and Health Topics page editorial board:

      • Daniel Levine, Product Safety Solutions; Basking Ridge, NJ
      • Michele Sullivan, MRS Associates, Annandale, VA

      OSHA and SCHC Alliance Web Page

      OSHA continues to update the OSHA-SCHC Alliance Web page on OSHA's Web site. The Web page features links to the Alliance agreement and related documents, information on activities and events, and milestones and successes. For information on the number of visits to the OSHA-SCHC Alliance Web page, please see the Alliance Program Reach table on page 7.

      SCHC Web Site

      SCHC continues to update a page about the OSHA and SCHC Alliance on its Web site. The Web page includes information about the goals of the Alliance and links to OSHA's Alliance Program and hazard communication resources.

      Print and Electronic Media

      Articles on the OSHA and SCHC Alliance appeared in print and online publications, including: BNA Occupational Safety and Health Reporter, and BNA Daily Labor Report. For more information on the articles, please see the Alliance Program Reach table.

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

      Checklist for Evaluation of Material Safety Data Sheets (MSDSs) for OSHA Hazardous Chemicals

      On July 22, 2005, SCHC Alliance representatives provided OSHA with a checklist for evaluation of MSDSs to OSHA. The checklist reviews the Agency's hazard communication requirements and also includes recommended practices from American National Standards Institute (ANSI) and GHS. The document was sent to OSHA's Directorate of Standards and Guidance.

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

      SCHC 2004 Fall Meeting, Arlington, Virginia, October 26-27, 2004

      The following OSHA staff members made several presentations during SCHC's 2004 Fall Meeting in Arlington, Virginia, October 26-27, 2004.

      • Jennifer Silk, Deputy Director, DSG, David O'Connor, DSG, and Maureen O'Donnell, Directorate of Enforcement Programs, DEP, made a presentation to 150 attendees entitled, "OSHA's New Hazard Communication Initiative," on October 26, 2004.

      • Jennifer Silk, Deputy Director, DSG, made a presentation to 150 attendees entitled, "Emerging Issues: Control Banding ‐ What Hazard Communication Professionals Need to Know," on October 26, 2004.

      • Jennifer Silk, Deputy Director, DSG, made a presentation to 150 attendees entitled, "GHS ‐ US Update on Implementation," on October 27, 2004.

      • OSHA representatives also staffed an exhibit booth and distributed its publications October 26-27, 2004.

      ISSA HazCom 101, New Orleans, Louisiana, November 15, 2004

      Michele Sullivan made presentation to 75 attendees on "GHS, ANSI Z400 MSDS Standard," at the ISSA HazCom 101 in New Orleans on November 15, 2004.

      The Chemical Producers and Distributors Association and Consumer Specialty Products Association, Alexandria, Virginia, November 16, 2004

      Michele Sullivan made a presentation on GHS panels to 125 attendees at a meeting of the Chemical Producers and Distributors Association and Consumer Specialty Products Association in Alexandria, Virginia on November 16, 2004.

      Ohio Safety Congress and Expo, Columbus Ohio, March 30, 2005

      Michele Sullivan made a presentation to 100 attendees on "Global Harmonization of Material Safety Data Sheets and Hazard Communication," at the Ohio Safety Congress and Expo in Columbus, Ohio on March 30, 2005.

      SCHC 2005 Spring Meeting, Phoenix, Arizona, April 12-13, 2005

      Ann Brockhaus gave an Alliance update to 145 attendees at SCHC's 2005 Spring Meeting in Phoenix, Arizona on April 12, 2005.

      SCHC 2005 Fall Meeting, Arlington, Virginia, September 27-28, 2005

      The following OSHA staff members made several presentations at SCHC's 2005 Fall Meeting in Arlington, Virginia, September 27-28, 2005.

        • Jennifer Silk, Deputy Director, DSG made a presentation to 150 attendees entitled, "US Move Toward GHS Implementation," on September 27, 2005.

        • Jackie Annis, DEP, made a presentation to 150 attendees entitled, "Hazard Communication Enforcement," on September 28, 2005.

        • OSHA also staffed an exhibit booth and distributed OSHA publications September 27-28, 2005.

      • 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 Industrial Hygiene Association (AIHA) and American Society of Safety Engineers (ASSE) Chapter Meetings, Washington, DC, March 2, 2005

      Michele Sullivan provided an overview of the GHS to 85 attendees at a meeting of ASSE's National Capital Chapter and AIHA's Potomac Section, in Washington, DC on March 2, 2005.

      • 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.

        During this reporting period, OSHA and SCHC did not work on projects to address this goal.

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

        During this reporting period, OSHA and SCHC did not work on projects to address this 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.

        During this reporting period, OSHA and SCHC did not work on projects to address this 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.

      Alliance Program Hazard Communication Roundtable, Washington, DC, February 15, 2005

      Michele Sullivan and Denese Deeds attended the Alliance Program Hazard Communication Roundtable, which was February 15, 2005, in Washington, DC. The Roundtable brought together 18 Alliance Program participants to identify hazard communication compliance assistance projects and activities that they could work on together. The Promoting the GHS Workgroup was developed at the Roundtable meeting.

      • Promoting the GHS Workgroup

      • August 1, 2005, Washington, DC - Michelle Sullivan, Ann Brockhaus and Denese Deeds attended the workgroup meeting. The workgroup identified a number of compliance assistance tools that it could develop to support OSHA's plans to adopt the GHS as part of its Hazard Communication Standard.

      ISSA Legislative and Regulatory Forum, Arlington, Virginia, May 19, 2005

      OSHA and SCHC Alliance implementation team members made two presentations at the ISSA Legislative and Regulatory Forum in Arlington, Virginia on May 19, 2005. Michele Sullivan and David O'Connor, DSG, made a presentation entitled, "GHS ‐ Update on U.S. Implementation," to 125 attendees. Maureen O'Donnell, DEP, Jackie Annis, DEP, and David O'Connor, DSG, made a presentation on "Hazard Communication Enforcement," to 125 attendees.

    2. Executive Summary

      During the 2004-2005 reporting period, OSHA and SCHC worked together to reach out to small business and others to provide resources and increase awareness about hazard communication, MSDSs and the GHS.

      Through the Alliance Program, OSHA and SCHC developed several resources with information about the Alliance and hazard communication. The OSHA and SCHC Web site on OSHA's Web page provides links to the Alliance agreement, related documents, activities and events, and milestones and successes. SCHC maintains a Web page with information about the Alliance and links to OSHA's Web site. Further, representatives from SCHC serve as members of OSHA's Hazard Communication Safety and Health Topics page's editorial board. In addition to these online resources, the OSHA and SCHC Alliance developed a Checklist for Evaluation of MSDSs for OSHA Hazardous Chemicals, which includes OSHA requirements and GHS and ANSI recommendations.

      In addition, the Alliance implementation team members worked with other Alliance Program participants throughout the year. SCHC representatives worked with other Alliance Program participants to identify compliance assistance tools and resources to promote hazard communication to the public and small business at the Alliance Program Hazard Communication Roundtable in Washington, DC, on February 15, 2005. SCHC also worked with other Alliances to identify resources for educating the public about the GHS at the Alliance Program Promoting the GHS Workgroup meeting, on August 1, 2004. Michele Sullivan also made a presentation on the GHS to representatives from AIHA's Potomac Section and ASSE's National Capitol Chapter on March 2, 2005.

      OSHA and SCHC representatives promoted the Alliance and hazard communication awareness during numerous speaking and exhibiting opportunities. For example, Ann Brockhaus gave an Alliance update to the attendees at SCHC's 2005 Spring Meeting in Phoenix, Arizona, on April 12, 2005. OSHA staff made several presentations and hosted an OSHA and SCHC exhibit at SCHC's 2004 and 2005 Fall Meetings in Arlington, Virginia. In addition, OSHA and SCHC representatives made presentations on hazard communication at several industry-related meetings, including ISSA's Legislative and Regulatory Forum in Arlington, Virginia, May 19-20, 2005.

    3. Alliance Program Reach

      Type of Activity (Conference, Training, Print and Electronic Distribution, etc.) Number of Individuals Reached or Trained
      OSHA and SCHC Web page on OSHA's Web site 4,649
      SCHC's Web site Data Not Available
      OSHA's Hazard Communication Safety and Health Topics page 194,000
      MSDS Checklist Data Not Available
      "OSHA's New Hazard Communication Initiative," SCHC 2004 Fall Meeting, Arlington, Virginia, October 26, 2004
      Speakers:
      Jennifer Silk, DSG
      David O'Connor, DSG
      Maureen O'Donnell, DEP
      150
      "Emerging Issues: Control Banding ‐ What Hazard Communication Professionals Need to Know," SCHC 2004 Fall Meeting, Arlington, Virginia, October 26, 2004
      Speaker: Jennifer Silk, DSG
      150
      "GHS ‐ US Update on Implementation," SCHC 2004 Fall Meeting, Arlington, Virginia, October 27, 2004
      Speaker: Jennifer Silk, DSG
      150
      SCHC 2004 Fall Meeting, Arlington, Virginia, October 26-27, 2004
      Alliance exhibit
      50
      November 11, 2004, "MSDS Guidance Under Review, Enforcement Initiative Still to Come,"
      BNA Occupational Safety and Health Reporter
      Data Not Available
      "GHS, ANZI Z400 MSDS Standard," ISSA HazCom 101, New Orleans, Louisiana, November 15, 2004
      Speaker: Michele Sullivan
      75
      The Chemical Producers and Distributors Association and Consumer Specialty Products Association, Alexandria, Virginia, November 16, 2004
      Speaker: Michele Sullivan
      125
      Alliance Program Hazard Communication Roundtable, Washington, DC, February 15, 2005
      SCHC Participated
      18
      "GHS: Overview," Meeting of ASSE's National Capitol Chapter and AIHA's Potomac Section, in Washington, DC on March 2, 2005.
      Speaker: Michele Sullivan
      85
      "Global Harmonization of Material Safety Data Sheets and Hazard Communication," Ohio Safety Congress and Expo, Columbus Ohio, March 30, 2005
      Speaker: Michele Sullivan
      100
      "Alliance Update," SCHC's 2005 Spring Meeting, Phoenix, Arizona, April 12, 2005
      Speaker: Ann Brockhaus
      145
      "GHS ‐ Update on US Implementation," ISSA Legislative and Regulatory Forum, May 19, 2005
      Speakers:
      David O'Connor, DSG
      Michele Sullivan
      125
      "OSHA Hazard Communication Initiative," ISSA Legislative and Regulatory Forum, May 19, 2005
      Speakers:
      Maureen O'Donnell, DEP
      Jackie Annis, DEP
      David O'Connor, DSG
      125
      Alliance Program Promoting the Globally Harmonized System for Classification and Labeling of Chemicals (GHS) Workgroup Meeting, Washington, DC, August 1, 2005
      SCHC participated
      12
      "U.S. Move Toward GHS Implementation," SCHC's 2005 Fall Meeting, September 27, 2005
      Speaker: Jennifer Silk
      150
      "Hazard Communication Enforcement," SCHC's 2005 Fall Meeting, September 28, 2005
      Speaker: Jackie Annis
      150
      SCHC's 2005 Fall Meeting, September 27-28, 2005
      Alliance exhibit
      50
      September 30, 2005, "OSHA Official Discusses Citation Trends at Hazard Communication Conference," BNA Daily Labor Report Data Not Available
      TOTAL 200,309
  4. Upcoming Milestones

    In the coming year, OSHA and SCHC will renew the Alliance agreement and continue to promote awareness of the Program and hazard communication related issues. The Alliance implementation team members will also continue to maintain and update the OSHA and SCHC Alliance Web page on OSHA's Web site and SCHC's Alliance-related Web page. In addition, SCHC representatives will review and update OSHA's Hazard Communication Safety and Health Topics page through their participation on the editorial board.

    OSHA and SCHC will work together to develop a training curriculum on MSDSs for use by the Agency's Office of Training and Education. In addition, representatives from the OSHA and SCHC Alliance will work with AIHA to educate the public about the GHS. Representatives from OSHA will continue to promote the Alliance and hazard communication through speeches and exhibits at meetings such as SCHC's 2006 spring and fall meetings.

    Report prepared by: Elizabeth Sherfy, Alliance Coordinator, Office of Outreach Services and Alliances, January 30, 2006.

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