IN THIS EDITION OF PARTHENON COMPLIANCE E-NEWS:
Parthenon Compliance Update
New Login Area
Software Version 2
Reward Employees for Reporting Near-Miss Incidents
In the News
Noteworthy - Hazardous Materials FAQ
Parthenon Compliance Update
The long-awaited Training Module development is in full swing! It's very exciting and it will be fun to show to everyone in the near future.
Another software change is that we will be allowing Safety Directors and Human Resource Managers to enter new employees regardless of whether they are a CDL driver or not. We feel this will help us ensure new employees receive the proper training upon hire.
 New Login Area
In order to avoid confusion as to how to log in to the software, a login area has been added to the main Parthenon Risk Partners Web site.
You can get to the link by using www.parthenonriskpartners.com/compliance. Archived issues of the newsletter and helpful links can also be found on this page. Please add this link to your favorites and use it as your primary login page.
Software Version 2
On May 18, 2009, the Parthenon Compliance application was upgraded to Version 2. The new version contains the Safety Training Module as well as several enhancements to expand functionality and increase workflow efficiency.
The following enhancements were implemented with Version 2:
- Quick Party Search – The top bar of the application now contains a search mechanism to quickly look up a location and/or employee data. The quick search begins searching the database as soon as you begin typing.
- Document Archives – The document archives section for a client/location was enhanced to only show recent documents, but allows the user to filter on the document modification date.
- Enter/Edit Employees – The client management section was enhanced to allow HR Managers and Safety Directors to enter new employees or edit current employee information.
- Additional Information on Employee Listing – The employee listing under the client and location detail sections now indicates the employment type (Full-Time, Part-Time, or Seasonal).
- Written Safety Program – The page numbering system for the WSP document generation was enhanced to restart page numbers at each new section. This allows individual sections to be printed with accurate page numbers.
- Performance Enhancements – Several enhancements have been made to reduce page load times in the client management screens, written safety program, and document retrieval sections.
Reward Employees for Reporting Near-Miss Incidents
Does your current Safety Incentive Program reward employees for reporting near-misses? If not, it may be something to consider. By rewarding your employees, it may make them more apt to report near-miss incidents that could in turn help you to avoid accidents in the future.
In the News
FMCSA Increases Maximum Penalties for Repeat Violators
On April 1, the Federal Motor Carrier Safety Administration began a new "two strikes" policy that applies maximum penalties to motor carriers with drivers who have committed a "pattern of violations."
A notice (.pdf file) published in the March 30 Federal Register states that the changes act as policy supplements to existing regulations and were made in response to an August 2007 report from the Government Accountability Office, which concluded FMCSA's "three strikes" policy failed to assess maximum penalties against all serious violators. The policy was designed to assess penalties after three closed cases with the same or a related violation were found within a six-year period. The new policy changes aim to:
- Adopt a "two strikes" policy, which applies maximum penalties if a violation is discovered during an investigation within six years of a previously closed case that found a similar violation.
- Define "pattern of violations" as "occurring when the agency discovers two or more critical and/or acute violations in each of three or more different regulatory parts." A previous enforcement violation is not required, and a second violation can be found even during a first-time investigation.
OSHA Announces Rule Making on Combustible Dust Hazards
The U.S. Department of Labor's Occupational Safety and Health Administration (OSHA) is initiating a comprehensive rulemaking on combustible dust. OSHA will issue an Advanced Notice of Proposed Rulemaking and convene related stakeholder meetings to evaluate possible regulatory methods and request data and comments on issues related to combustible dust such as hazard recognition, assessment, communication, defining combustible dust, and other concerns. Since 1980, more than 130 workers have been killed and more than 780 injured in combustible dust explosions. View article...
Risk Management Plan Resubmission
Risk Management Plans for anhydrous ammonia storage locations are due for many of you in June. It is a rather lengthy process to get started and could take a few weeks to get an account set up. After the initial set up, the process seems to be going smoothly—especially for resubmissions without any facility changes. The following is a link for a RMP resubmission checklist along with several helpful references: www.epa.gov/emergencies/docs/chem/RMP_checklist.pdf
*Please Note: Anhydrous Ammonia is considered Program 2, so disregard all references to Program 3.*
NOTEWORTHY
**Please note these are GENERAL answers in regards to hazardous materials. Every hazardous material is different!**
When should a pickup hauling hazardous chemicals be placarded?
It depends...if the material is DOT regulated, the first place to look would be on the MSDS. Generally, placards would be required if hauling over 1,001 pounds or 119 gallons. However, some of the chemicals are DOT Class 9 which do not require placards for domestic transportation.
 If a product is mixed with water in the sprayer, and the sprayer is then loaded on to a truck for transport to the field, does the truck need to be placarded?
Again, it depends on what you are hauling...look at the MSDS first to determine if it is DOT regulated. It may still be regulated depending on the concentration. Placards would then be determined on the classification of the material.
If a truck has several mini bulks on it (such as a semi tractor trailer tending to a sprayer) and each mini-bulk has placards on them, is there a quantity hauled where the truck itself would then also need to be placarded?
If the mini-bulk exceeds 119 gallons, then vehicle placards are required (except Class 9), unless placards are visible on the containers. If the containers are less than or equal to 119 gallons, then placards would be required if the weight hauled exceeds 1,000 pounds.
Do we need to provide shipping papers to farmers picking up chemicals from retail facilities if it exceeds the placardable amounts?
In Minnesota, farmers are exempt from Driver Qualification Files and Shipping Papers, but not from placarding and marking. If you are offering a bulk (over 119 gallons) hazardous material for shipment, you must provide placards with proper ID numbers to the farmer. Placards may also be required for subject materials in non-bulk packages if more than 1,000 pounds, with the exception of Class 9.
Are feed trucks considered tankers and do drivers need a tanker endorsement to drive them?
No, feed trucks are NOT considered tankers and DO NOT require a tanker endorsement because they are not designed to transport liquids or gaseous materials.
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Please contact Katie or me if you have any questions on the information presented in this newsletter or if anyone you know should be added to this distribution list.
Sincerely,
Jenny Hedrick
Compliance Specialist - Parthenon Risk Partners
(320) 894-9765 (Office/Cell)
jhedrick@parthenonriskpartners.com
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