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COTTON FARMING IS THE OFFICIAL PUBLICATION OF THE GINNING INDUSTRY.
Hazard Communications – A Serious Issue For Gins We’ve seen a lot of OSHA activity in gins during the past year or so. During nearly all of those inspections, the compliance officer asked for or cited the gins on the presence of a Hazard Communications Program. We mention HazCom at nearly every safety meeting we do. We write it up once in a while in newsletters and other reports, but Hazard Communications is still the No. 1-cited OSHA standard year after year – not just for cotton gins but all industries. Everyone has trouble with it, and there are lots of resources for compliance assistance. Hazard Communications is a regulation that pertains to making sure employees are well informed of the hazardous chemicals (and other materials) with which they are working, as well as possible exposure. In other words, you are required to COMMunicate the HAZards. Part of the reason we (all industries) have problems complying with this particular standard is because it is rare that someone becomes “hurt� by things that are considered hazardous chemicals in most industries. Additionally, there are several parts to the program – any of which can cause fits for even the most conscientious managers. The main parts of a HazCom program are identification of hazardous materials, Safety Data Sheets (SDS), training and labeling and, of course, a written program to tie everything together. One of the trickiest parts is identification of the hazardous materials. Part of the regulation says that consumer products in consumer packaging – used in a manner consistent with normal consumer use – are not subject to the regulation. The example I like to use is a citation that I heard about (an extreme example but true as far as I can tell) is an employee who was using Dawn dish soap to wash the company’s vehicles. The company was cited because Dawn was not on its list of hazardous materials. If Dawn was being used to wash dishes, there wasn’t a problem, but it is not a carwash so it was not being used in a manner consistent with normal consumer use. Therefore, it is subject to the regulation. In general, if it is bad for you to drink or eat something or get it in your eyes or have to handle it in a special way, you better have it on the list and have access to the SDS for that substance quickly. The point is OSHA activity is increasing. The new reporting requirements will
18 COTTON FARMING
JUNE 2015
Stover Module Retriever Bed
Stover Gin Mover
* Rubber Tracks * RMS Chain on entire bed * Specially designed hydraulic tracks * Stover sliding tracks * Splitter valve * Automatic rear bumper * Optional camera and monitor
* Easy to operate on gin yard *Driver can easily determine correct spacing of modules *Can be used for narrow module *Can be used on traveling head module feeders
800-689-7740 361-884-8961 www.stoverequipment.com