OSHA’s Hazard Communication Standard (HCS)

Monday June 04, 2012

OSHA’s Hazard Communication Standard (HCS), first issued in 1983, was designed to ensure that employers provide information about potential health and physical hazards and associated protective measures to their workers. OSHA has just announced on March 20, 2012, a final rule updating OSHA’s Hazard Communication Standard to align with the United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals. Globally_Harmonized_System_Guide.

Employers must start training to understand the new label elements and Safety Data Sheets format by December 1, 2013. Resources to assist PMPA members with compliance to this new standard are provided here.

Scratches are longitudinal or near longitudinal indentations caused by mechanical rubbing of the bar on protrusions as it is processed.–AISI Technical Committee on Rod and Bar Mills, Detection, Classification, and Elimination of Rod and Bar Surface Defects

I’d bet dollars to donuts that there were sparks on the mill where this product was in contact with something during rolling.

Scratches are detected visually and are caused by unintentional contact with build up  on mechanical parts and mill components during rolling. Scratches typically have a more rounded bottom and less scale than a seam or crack.

They can range from small, sharp indentations, to broad gouges with partially projecting edges. The metal that is displaced by the mechanical working often appears to be of an undetermined structure. This is usually referred to as a Bielby layer.

Hot roll scratches can ‘fill in’ during cold drawing as the drawing process displaces steel into the depression. The bright surface, lack of scale and lack of decarb under the metal so moved are evidence that the are beneath the displaced material was pickled or descaled and so the displacement ocurred during cold drawing and the scratch pre existed that operation.  This metal can then flake off, (usually during straightening) prompting a call that the material has slivers. The correct identification remains scratch.

A foreign object (wire) or material build up in the  cold drawing die can result in a bright scratch on the resulting cold drawn bar.

The sample that inspired this 1986 entry into my Lab Notebook was caused by the bar scratching on some build up on the mill’s exit table.

While a scratch should be rejectable as a “mechanical defect” the fact is that most scratches seldom exceed the depth for minimum stock removal limits.

Scratches are generally found on softer materials.

Due to their larger radius, scratches seldom open up during upset or torsion tests.

In my experience most mill hands will call any longitudinal imperfection a seam, so many times scratches are falsely described to be seams.

European Environmental Directives and Regulations

 

The attached report provides an overview of The European System for Environmental Protection and details 5 European Directives and Regulations, End of Life Vehicles (ELV); Restriction of Hazardous Substances, (RoHS); Waste Electrical and Electronic Equipment (WEEE); Registration, Evaluation, and Authorization of Chemicals (REACH); and Packaging and Packaging Waste. Additional relevant material regarding European Union requirements on wood packing materials is provided as part of the Packaging and Packaging Waste report.

The impact of some of these directives has already reached our shores and companies, with End of Life Vehicles and RoHS already affecting the materials permitted and specified for use, and causing confused customers to turn to us, their suppliers, for clarity on these Directives. Leaded free-machining materials are still acceptable, though the details vary by Directive and end use. This is documented for each of the directives discussed and analyzed here.

The materials provided here are the results of lengthy research and technical analysis. They are not, and should not be considered legal advice. We have reviewed the technical requirements, and after careful analysis, have provided responses to potential customer questions on each of these Directives.

We are confident that the attached material will help you understand and successfully manage the growing number of environmental questions that we currently face coming out of the European Market. Please forward any comments, concerns, or new developments in this area to Miles Free, PMPA’s Director of Technology Services, gro.apmp@eerfm.

 

European Environmental Directives

 

Economic activity in the manufacturing sector expanded in May for the 34th consecutive month, and the overall economy grew for the 36th consecutive monthFabricated metals was one of 13 sectors reporting expansion in May.

According to ISM’s Bradley J. Holcomb, “The PMI registered 53.5 percent, a modest decrease of 1.3 percentage points from April’s reading of 54.8 percent, indicating expansion in the manufacturing sector for the 34th consecutive month. The New Orders Index continued its growth trend for the 37th consecutive month, registering 60.1 percent in May. This represents an increase of 1.9 percentage points from April and also the highest level recorded by the index since April 2011. The Prices Index for raw materials fell to 47.5 percent in May, dropping 13.5 percentage points from April, indicating lower prices for the first time since December 2011. Comments from the panel generally reflect stable-to-strong orders, with sales showing steady improvement over the first five months of 2012.”

The dropping of the price index for raw materials is noteworthy, being the first such drop since December 2011.

Certainly the global uncertainty is likely to affect our markets in the coming months, but for now North American Manufacturing continues to lead the recovery.

PMPA’s Business Trends Report for the first four months of the year is consistent with The latest ISM report and indicates that the industry’s 2012 average shipments will likely finish up 8 to 9 points higher than last year.

Every stapler in our office is black and metallic silver. Or grey.

Except for two red staplers.

This red stapler better be at the copier – Or Else!!!

While visual management is generally thought of as a way to error proof manufacturing processes, the use of visual management techniques can be applied in the office as well.

The red staplers are deployed at our copier and fax machine- our office ‘commons.’

You might think that they are red so that they will be easily spotted.

While that would be true, that is not why they are so colored.

The  real reason for the red color  is to provide a clear visual signal that they were out of place if someone walked off with them, since all other staplers in our office are shades of metallic and black.

So a missing ‘commons stapler’ would have someone “Seeing Red!”

But they are never missing, the visual difference alone seems to be self enforcing.

The case of missing shared tools or supplies is called the tragedy of the commons, and it is one of the more interesting  concepts from my college career.

Although my Malthusian Eco-Freako Professors would be aghast to find out it applies to the mundane  utensils of everyday office work.

If you have a problem with shared resources or “commons issues”-  understanding the “tragedy of the commons’ concept and that visual lean techniques can help to protect the ‘commons’ is an idea worth pursuing.

What kind of visual lean techniques have you deployed in your office or shop that have made a difference in resource availability?

Science

A colleague asked me “Why am I standing in line at the restaurant if there are so many in the unemployment line?”

I told him that we were standing in line with the 91.7% of the folks who are employed, not the 8.3% who are unemployed (U-3 unemployment measure).

I should have told him that we were standing in line with the 85.2% of folks who are fully employed, as opposed to the 14.8% who are not (U-6 unemployment measure).

Blue line indicates those of us who are standing in line at Applebees, Red line indicates people suffering from the “jobless recovery.”

The blue line shows the average number of hours worked by people with jobs in the private sector. It shows that those of us who are working are doing fine.

The red line in the chart below is a monthly index of the employment-to-population ratio, normalized to a value of 100 in December 2007, when the recession began. The lack of an uptick in the redline since 2009 is, we think, the essential tale.

Regardless of how one chooses to explain it, the fact that it has not improved is the critical issue.

We recall Dicken’s opening line from A Tale of Two Cities:

“It was the best of times, it was the worst of times, it was the age of wisdom, it was the age of foolishness, it was the epoch of belief, it was the epoch of incredulity, it was the season of Light, it was the season of Darkness, it was the spring of hope, it was the winter of despair, we had everything before us, we had nothing before us, we were all going direct to heaven, we were all going direct the other way – in short, the period was so far like the present period, that some of its noisiest authorities insisted on its being received, for good or for evil, in the superlative degree of comparison only.”

Sobering fact: Long term unemployment, defined to be 27 weeks or more out of work climbed to  5.4 million, or 41.3% of unemployed(U3) people.

Photo

New Stormwater Regulations (in Ohio) – Training Manual

Monday June 04, 2012

 

The State of Ohio is in the process of updating its Stormwater General Permit to match the Federal multi sector requirements. The new permit is 171 pages long and involves greatly increased testing and monitoring.

We urge you to give consideration to the NO Exposure Conditional Exclusion described in one of the attachments below. Attachments are provided for a review of SPCC plans, as well as the Stormwater Webinar and supporting documents presented by Barb Knecht of Hzw Environmental on September 20th.

(Note: Materials are prepared anticipating the State of Ohio’s Promulgation of the regulations. The SPCC materials and other resources may be appropriate for shops in other states for planning and forward looking activities.)

 

SPCC Training Compatibility Mode

Changes in General Industrial Storm Water Permit

Industrial Storm Water Draft 

Industrial Storm Water Final

No Exposure Guidance

Notice of Intent Form September 2011

OSHA’s Hazard Communication Standard (HCS)

 

OSHA’s Hazard Communication Standard (HCS), first issued in 1983, was designed to ensure that employers provide information about potential health and physical hazards and associated protective measures to their workers. OSHA has just announced on March 20, 2012, a final rule updating OSHA’s Hazard Communication Standard to align with the United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals. Globally_Harmonized_System_Guide.

Employers must start training to understand the new label elements and Safety Data Sheets format by December 1, 2013. Resources to assist PMPA members with compliance to this new standard are provided here.

 

OSHA’s Global Harmonized Hazard Communication Standard Fact Sheet