Changes To Hours Of Service, GHS And Shipping Papers

GAWDA CONSULTANT CORNER DOT, SECURITY, OSHA & EPA

I want to cover several topics in this article on things coming up and some things that are already in effect but may have been missed by some of our members.

Hours of Service Changes Effective July 1, 2013

The 34 hour restart provisions will require two periods between 1 a.m. and 5 a.m. It may only be used once per week.

Mandatory rest breaks will be a new item for our commercial vehicle drivers. The driver may drive only if eight hours or less have passed since the end of driver’s last off-duty period of at least 30 minutes. (HM 397.5 mandatory “in attendance” time may be included in break if no other duties performed.) If you are doing logbooks, then you will just show the break on the log. For the drivers not doing logs, I suggest that you show this on the time cards by either clocking in and out or just making remarks on the time card. Nothing in the rules address whether or not the employer pays or not pays for the breaks. That is totally up to the employer.

Globally Harmonized System

The Globally Harmonized System (GHS) is an international approach to hazard communication, providing agreed criteria for classification of chemical hazards, and a standardized approach to label elements and safety data sheets. The GHS was negotiated in a multi-year process by hazard communication experts from many different countries, international organizations and stakeholder groups. It is based on major existing systems around the world, including OSHA’s Hazard Communication Standard (HCS) and the chemical classification and labeling systems of other U.S. agencies.

I will be publishing a Safety Bulletin on this subject in the near future, but in the meantime there is a looming training date that you need to be aware of. The first compliance date of the revised HCS is December 1, 2013. By that time employers must have trained their workers on the new label elements and the Safety Data Sheet (SDS) format. Here is the OSHA website on this for more details: www.osha.gov/Publications/OSHA3642.pdf. I am sure that there will be training aids developed by the end of the year and available on the OSHA website to help you with this training. CGA is currently working on this as well. I foresee this being accomplished with a simple safety meeting about the new label elements and the SDS standardized 16-section format.

Shipping Papers

Beginning January 1, 2013, you must be showing the identification number (UN number) immediately in front of the shipping name followed by the hazard class number in your shipping paper description. Most of our members have already made this change, but I am still getting members asking about this new change to their shipping papers. DOT roadside inspections are finding this across the country. I will be happy to review your shipping paper at any time. Just email me a copy for review.

If there are any questions on any of these items, please contact me for more details and help.

Michael Dodd

Michael Dodd

GAWDA’s DOT, Security, OSHA &EPA Consultant Michael Dodd is president of MLD Safety Associates in Poplar Bluff, Missouri. Members can reach him at 573-718-2887 and MLDSafety@hotmail.com.