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WHMIS More Than Just SDS and Labels

WHMIS has changed a bit, nothing big in my opinion, it is and will always be an information system on hazardous materials, including bio and physical agents. That was always the intent of WHMIS 1988 and with the advent of GHS 2015, WHMIS hasn't changed. Updated symbols, some new hazard classifications to try and streamline WHMIS, dropping M from MSDS, going to the 16 ANSI data sheet rather than our Canadian 9 part data sheet; but again all to the same end. How will the material hurt you and how to protect yourself.

So employers, you have to train your people on the new WHMIS, what exactly does that mean? Unfortunately in most cases we are missing the word 'review'. To review someones WHMIS in 2019 definitely includes an explanation of the new updated system, but it should not forget about reminding workers of the core information on a SDS in order for workers to properly interpret the hazard to protect themselves.

What I mean is a review on the basic scientific principals which as 'vapour density', 'specific gravity', 'upper and lower explosive levels', the term 'LD-50' is a critical reminder to workers, because if the LD-50 number is just right, we can have potentially poisonous deadly consequences for workers. Even though they were refreshed on WHMIS 2015, but will fail to see the reality of the hazards of being poisoned, burned, creating a lack of breathable oxygen or possibly accidentally mixing two synergistic products together and create a poison gas cloud or even a bomb. All accidentally because we only reviewed the WHMIS GHS changes not the core information that will save our lives.

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Heated Construction Washrooms

The Construction regulations state that construction washrooms shall be heated 'if that is possible'.

 

The term 'if that is possible' leaves some contractors to believe it is optional, but not so fast... The MOL will take into consideration if you have a heated site trailer or availability of electricity in order to determine if heat is possible.

 

Washroom trailers are really the way to go to have happier workers who will likely produce better work. As a worker, if I have to sit in a freezing cold plastic box I will drive to the nearest public washroom at my employers expense. Cold in the kidneys is no fun health matter for any worker to deal with.

 

The MOL has indicated they use the OASIS Ontario guideline of 10 degrees Celsius as considered at minimum an adequate amount heat.

 

 

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New Set Safety Fines

Hot off the press,

 

A substancial increase in the amount of set fines an inspector can issue on site. Set fines are a relatively new thing in the past 10 years or so. Up to now there were 16 set fines from 2 schedules. Now that has increased to 179 set fines from 4 schedules.

 

I have condensed everything that has reference or impact to typical construction and for your reference, I will include the link to the Ontario Justice website where the schedules are listed. Schedules; 66.2, 67, 67.1 and 67.5

 

MOL Set fines for Construction.pdf

 

Link to Schedules of fines

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Step Stools

As many; Framers, Drywaller's, Tapers and Painters know 2 & 3 rung step stools have been a point of contention by MOL inspectors for many years.

 

In 2015, the ladder regulations were revamped and in November a new definition of a 'step stool' has appeared for the first time.

 

“step stool” means a self supporting, portable, fixed or foldable ladder, not adjustable in length, and having,

(a) a height of 800 millimetres or less, excluding side rails, if any, above the top cap,

(b) flat steps, but no pail shelf, and

(c) a ladder top cap that can be stood or stepped on;

 

In my opinion this new definition should clear up any confusion about use of 2 & 3 step stools that are under 800mm and where the manufacturer allows standing on the top.

 

Remember section 93(3) if you are following the manufacturer's instructions on any piece of equipment, there is no reason you should have to worry about MOL charges. Should charges happen anyway, you may have a valid defence, provided you were working in adherence with the manufacturer's instructions.

 

As seen in Werner Ladder manufactures picture (borrowed from thei Website), it would appear to me that they do allow to stand on the top of  their 'work stand'. Also they list the maximum step height on the 2 step as 1'11".

 

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Lou LeBlanc
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March 24, 2019
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