askralph

The frequency of requests on these two subjects are increasing, but are currently not numerous. If you are not a follower of the ASKRalph! blog, now may be the time to register your email. If you are involved in food grade packaging in a primary, secondary, or tertiary system, you may want to begin to follow the developments more closely.

Here is a link to a webinar on the GPPS initiative hosted by Consumer Goods Forum, Kraft Foods, Unilever, Nestlé, European, and GreenBlue. This one hour presentation will bring you into the current thinking of this universal project. Global Packaging Forum

The issue of Mineral Oil Migration is still a developing issue. Our associates at Sun Chemical provided the link to the National Association of Printing Ink Manufactures. While there is a $25 charge for this OSHA compliance webinar with highlights in dust control and the Globally Harmonized System. Only Germany has implemented the program. OSHA Webinar

As always please contact me if you need further details. Our friend Maryanne Jashinske, who has done two UN HazMat webinars for us, is becoming Food Safety certified and is another excellent resource that you can reach through this association.

– Ralph

Tyler asks:

I have a customer asking about the new Globally Harmonized Standard (GHS) pictogram labels that will be mandatory starting in June 2015. As OSHA converts to the new GHS for chemical hazard identification, they are changing the pictogram. Do you have any insight into how picky they will be on shipping boxes. The pictograms consist of a symbol on a white background framed with a red border. This could result in a 2 or 3 color to print which could get expensive on a plain kraft box.

It’s not easy to find a definitive answer. I believe the end chemical manufacturer or shipper has ultimate accountability since they tell us what to print on the box, but really don’t want to leave my customers hanging like that if there are any interpretations out there that I could not find.

I had to do a lot of additional HAZCOM training of employees to teach the pictograms, and I still need to change the labels on all my decanted chemicals. Also as part of the GHS, MSDS forms will become SDS forms and OSHA will require the use of one single standardized form. Currently there are about four different MSDS form designs.

I can tell you that when the pictograms are required to be printed, they must have a RED border. OSHA has confirmed that (see attached presentation). For boxes that already carry DOT diamonds, those marks will suffice and the GHS marks are not required on the outer box, for ground shipment in the US. I am not 100% sure that they will need to be printed on the outer package of a combination package that is either not hazardous by DOT standards, or that meets the Limited Quantity/CC-ORM-D requirements for DOT. I am trying to get more clarification on that.

Here are a couple links to documents that might be helpful as well. Implementation of New HazMat Requirements and OSHA Brief – Hazard Communication Standard: Labels and Pictograms.

The new GHS rules are changing the way we do a lot of things. AICC is offering a HAZMAT training and Certification webinar and test on December 3, 2013. Hosted by Maryann Jashinske, “General Awareness and Security Awareness Training for Hazardous Materials Packaging Suppliers” this webinar provides two of the three types of training, testing and certification required for packaging suppliers: General Awareness and Security Awareness. Click here for details and registration.

For almost two years now we have been tracking the Chemical Safety Hazard Investigation Board’s study of combustible dust. The CSB is an independent federal safety board. It cannot draft regulations, levy fines or otherwise formally rebuke companies for safety hazards. Since 2009 this agency has sought to develop some guidelines for the control of suspended particles which could include sheet feeders and corrugated box plants. We have suggested that you begin your own investigation for your own unique manufacturing operation as this may likely have an impact on your operation. Now it appears that this November OSHA will begin to move toward the next step, seeking input from small businesses. It is in this step that OSHA will study the cost of compliance and collect comments from industry.

While the largest accidents and threats still remain with the flour, coal, plastic, pharmaceutics, metals, and wood processing industries there can be a spillover effect to paper processing. The worst U.S. incident occurred here in Georgia in 2008 at the Port Wentworth Imperial Sugar Plant where 14 died and dozens were injured.

Your Association attended one of the early stakeholders meetings along with other industry, labor, insurance, and trade groups to offer input. We will continue to monitor the situation. Lewellyn Technologies is offering three seminars on this subject and AICC members are being offered a $100.00 discount. Contact them or us for more information.

Chicago, IL • August 28, 2013
Atlanta, GA • September 10, 2013
Indianapolis, IN • October 8, 2013