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In This Issue

June 2007 Click here to view the pdf version of Techlines.

Don't miss an issue! Call 1-800-356-0783 to add your name to the mailing list.

High-viz wear critical to road crew safety
Free program helps identify, fix workplace hazards
Understanding the CSA stamp of approval
NFPA 704 signs quickly convey hazard info
Part II: The slippery slope of fall protection
Do you hear what I hear?
NIOSH issues sonographer safety recommendations
2007 DOT shipping classification changes
Ask a Tech Rep
worth noting . . .

High-viz wear critical to road crew safety

Summer is the prime time for road construction projects. Thousands of workers venture into harm’s way each summer to repair the nation’s roadways.

To help protect workers from vehicles traveling through work zones, outdoor crews should wear high-visibility clothing that allows motorists to see, acknowledge, recognize and respond to their presence.

To assist employers in selecting the proper level of high-visibility clothing for their employees, the American National Standards Institute and the International Safety Equipment Institute (ANSI/ISEA) have created a standard (ANSI/ISEA 107–2004) that defines three classes of high-visibility garments:

  • Class 1 provides the minimum conspicuity
  • Class 2 provides superior visibility for wearers and is more conspicuous than Class 1
  • Class 3 offers the greatest visibility against complex backgrounds

Class 1
Class 1 apparel is suggested for work activities that:

  • Permit full attention to approaching traffic
  • Provide ample separation of the worker from vehicle traffic
  • Permit optimum conspicuity in backgrounds that aren’t complex
  • Are conducted in areas where vehicle and equipment speeds do not exceed 25 mph

Delivery vehicle drivers, parking lot attendees, warehouse workers, shopping cart retrievers and sidewalk maintenance crews are some examples of workers who typically wear Class 1 apparel on the job.

These garments need to be conspicuous and use retro-reflective materials not less than 25mm in width.

Class 2
Class 2 apparel is suggested for work activities where:

  • Employees are performing tasks that divert their attention from approaching traffic
  • Activities are taking place in or close to traffic
  • Backgrounds are complex
  • Greater visibility is required during inclement weather
  • Vehicle and equipment speeds are greater than 25 mph

Road construction workers, survey crews, utility employees, law enforcement officials, emergency response personnel and tow truck operators typically wear Class 2 apparel. The minimum width of the retro-reflective material used on these garments is 35mm.

Class 3
Class 3 apparel is suggested for work activities where:

  • Employees are exposed to significantly higher speeds and/or reduced sight distances
  • Workers and vehicle operators have high task loads
  • Workers must be identifiable and conspicuous through a full range of body motions at a 1,280-foot minimum

Flagging and survey crews, emergency responders, towing operators and utility and road construction crews typically wear Class 3 garments for the greatest visibility. They are constructed with more retro-reflective material than Class 2 apparel and must have sleeves with retroreflective material between the shoulders and elbow.


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Free program helps identify, fix workplace hazards

A free on-site consultation program funded by the Occupational Safety and Health Administration (OSHA) helps employers identify potential hazards and improve their safety and health management systems.

Primarily targeted for smaller, highhazard businesses, the consultation program is separate from the OSHA inspection effort. There are no citations or penalties associated with the program, and confidentiality is maintained during the process.

Prior to the actual visit, employers must commit to correcting any identified serious job safety and health hazards in a timely manner. In the rare instances where the consultant finds an “imminent danger” situation during the walkthrough, the employer must take immediate steps to correct the hazard.

The process starts with the employer contacting its state’s OSHA consultation department office to discuss specific needs. A complete review of the firm’s safety and health situation is encouraged; however, the visit can be limited to specific problems. A visit will be scheduled based on the priority assigned to the request, the employer’s work schedule and the time needed for the consultant to prepare.

The visit starts with an opening conference to talk with company management to discuss the consultation process and review accident and injury rates. Then a walk-through of the facility is conducted with management representatives to help identify hazards.

After the walk-through is completed, a closing conference is conducted to review the hazards and identify a satisfactory timetable for correction of any hazards judged to be a serious violation. The consultant will also identify areas for possible employee safety training and education and offer assistance to develop or maintain an effective safety and health management system.

The consultant will follow-up with a detailed report reviewing the findings and confirming mutually agreed upon correction periods within 20 days. A list of hazards will be included in the report and it must be posted electronically or in an area that is easily observable by employees for three days or until the listed hazards are corrected.

The on-site consultants will not:

  • Issue citations or propose penalties
  • Report possible violations to OSHA enforcement staff
  • Guarantee that the workplace will “pass” an OSHA inspection

Company’s using the consultation process are deferred from OSHA’s scheduled inspections while the consultation remains “in progress.” This is the time between the onset of the consultation and the final correction dates, including any extensions.

OSHA does require hazard correction so that each consultation visit provides effective employee protection. If there is a failure to eliminate or control identified serious hazards according to the plan and within the limits agreed upon, the situation is referred from consultation to an OSHA enforcement office for appropriate action.

Utilizing the OSHA consultation service can help establish or strengthen a company’s safety and health program. Improving workplace safety and health also brings fewer accidents, lower injury and illness rates, decreased workers’ compensation costs and limits product losses.


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Understanding the CSA stamp of approval

Many products have a long list of approvals and related compliance listings. Approvals such as ANSI, ASTM, FM, NIOSH and UL are commonly seen on everything from boots to toaster ovens.

Another common agency is the Canadian Standards Association (CSA). Although the name implies its Canadian roots, the CSA does not stop at the border.

The CSA is a nonprofit membership-based association serving business, industry, government and consumers in Canada and the global marketplace. It serves as a neutral third party to provide a structure and forum for developing standards.

A standard is a document that sets a level of performance for a product. They are often developed to reduce the risk of personal injury due to fire or electrical shock.

Once developed, these standards do not automatically become law. Like many standard organizations, the CSA is not a government body. These standards do become law, however, if a governing body adopts them and references them in legislation.

A mark on a product from the CSA is similar to the mark of the Underwriters Laboratories (UL). It signifies that an authorized testing laboratory has evaluated a sample of the product to determine that it meets applicable national standards.

CSA International is accredited in the U.S. by the Occupational Safety and Health Administration (OSHA) as a Nationally Recognized Testing Laboratory (NRTL) and in Canada by the Standards Council of Canada (SCC). Some of the standards it tests products against include the American National Standards Institute (ANSI), UL, CSA and National Sanitation Foundation International (NSF).

The CSA testing mark is found on more than one billion products worldwide. It features a capital “C” with the letters “S” and “A” inside.

When something is tested specifically for U.S. markets, the letters “US” or “NRTL” will appear beneath the “C.” These items are tested to applicable U.S. standards. Items tested to both Canadian and U.S. standards will feature the letters “C” and “US” or the letters “NRTL/C” below the “C.”

The CSA also has specific marks for gas products and sanitation products. The CSA Blue Star indicates the product is certified to applicable U.S. standards for appliances using gas or other petroleum fuel.

For the myriad of different sanitation standards, the word “Sanitation” and the applicable NSF and/or ANSI standard number are printed below the “C.”

Click here for more information on the CSA.


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NFPA 704 signs quickly convey hazard info

The National Fire Protection Association (NFPA) designed the 704 rating system as a standard for the identification of the hazards of materials for emergency response. NFPA 704 provides a readily recognized and easily understood system for identifying specific hazards and their severity.

NFPA 704 addresses the health, flammability, instability and related hazards that may be presented as short-term, acute exposures most likely to occur as a result of a fire, spill or similar emergency. Spatial, visual and numerical methods are used to describe the relative hazards of a material in simple terms.

The system is characterized by its diamond or square-on-point shape. It identifies the hazards of a material and the degree of severity of the health, flammability and instability hazards. Hazard severity is indicated by a numerical rating that ranges from zero indicating a minimal hazard to four indicating a severe hazard.

The hazards are arranged spatially—health at the nine o’clock position, flammability at 12 o’clock and instability at three o’clock. In addition to the spatial orientation, they are also color coded: blue for health, red for flammability and yellow for instability.

The six o’clock position on the symbol represents special hazards and has a white background. The special hazards in use are , which indicates unusual reactivity with water and is a caution about the use of water in either firefighting or spill control response, and OX, which indicates the material is an oxidizer. These are the only authorized symbols for the special hazards quadrant.

Since NFPA 704 signs are intended to provide quick hazard information for emergency responders, they should be placed where responders are likely to enter. If there are numerous areas where the responders could enter, there should be numerous signs.

At a minimum, NFPA 704 suggests that signs should be posted on the two exterior walls of the facility, at the access to a room or area or at each principal means of access to an exterior storage area. The placement and quantity should be decided using your best judgment coupled with advice from local authorities.

For more information about NFPA 704, refer to LSS EZ Facts® Document 304 at www.LSS.com.


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Part II: The slippery slope of fall protection

Editor’s Note: This is the second part of a two-part series on OSHA Instruction Directive STD 3.01A, focusing on alternative procedures for protecting Group 2, 3 and 4 employees from falls.

The four groups of residential construction activities for which alternative fall protection plans are available include:

1. Installing floor joists, floor sheathing and roof sheathing; erecting exterior walls; setting and bracing roof trusses and rafters.
2. Working on concrete and block foundation walls and related formwork.
3. Performing work in attics and on roofs—installing drywall, insulation, HVAC systems, electrical systems, plumbing and carpentry.
4. Roofing work—removal, repair or installation of weatherproofing roofing materials.

The April issue of TECHlines discussed in detail the appropriate fall protection procedures for sheathing installations.

The alternative procedures for protecting Group 2 employees address trained workers, adequate support, bad weather, staging of materials/ equipment and impalement hazards.

The alternative procedures for protecting Group 3 employees address trained workers, staging of materials, impalement hazards, restricted access and bad weather.

Alternate procedures for roofing work (Group 4) may only be used when the roof slope is 8 in 12 or less and the fall distance, measured from the eave to the ground level, is 25 feet or less.

ALTERNATIVE PROCEDURES FOR GROUP 4 WORK
Roof Slope
Height
Roof Type
Description
</=4 in 12
</=25'
Any
1. Trained Workers. Only workers who have been trained to be proficient in the alternative methods of fall protection must be allowed onto the roof. In addition, each affected employee must be trained to ensure specific awareness of the fall hazards associated with work on roofs with rake edges (“rake edges” are inclined roof edges, such as those on the gable end or a building). 2. Slip Hazards. The roof surfaces must be inspected for slipping hazards. The employer must either eliminate any such hazard or take effective measures to have workers avoid them. The employer must have workers wear appropriate footwear to reduce the potential for slipping. 3. Bad Weather. When adverse weather (such as high winds, rain, snow or sleet) creates a hazardous condition, roofing operations must be suspended until the hazardous condition no longer exists. 4. Roof Holes/Openings. The employer must have any damaged portions of the roof deck repaired as soon as possible. Any holes (including skylight openings) or other areas where employees would not have safe footing must be covered or surrounded by guardrails that comply with the requirements of 1926.502. 5. Ladders/Scaffolds. If ladders or scaffolds are used, they must be erected and maintained in accordance with the requirements of Subparts X and L of OSHA’s construction standards. In addition, employees must be trained in accordance of these subparts. 6. Access to Roof. Employers must not allow workers to ascend or descend the roof’s slope within six feet of the rake edge except where that limitation would prevent the performance of work. 7. Location of Materials. Supplies and materials must not be stored within six feet of the rake edge, or three feet where tile roof systems are being installed. 8. Impalement Hazards. The area below the eaves and rakes must be kept clear of materials and other objects which could pose impalement or other hazards, or be properly guarded. 9. Slide Guards. Employer must use either a safety monitoring system that complies with 1926.502, or roofing slide guards. If slide guards are used, they must be built and installed as outlined below.
>4 in 12
</=8 in 12
</=25'
Any except metal or tile
First eight requirements listed for a roof slope of </=4 in 12 must be followed. Slide guards are required and they must be built and installed as outlined below. Safety monitoring system is not allowed.
</=8 in 12
</=25'
Metal or tile
First eight requirements listed for a roof slope of </=4 in 12 must be followed. Safety monitoring system may be used instead of slide guards.
>8 in 12
Or >25'
Any
This directive cannot be used. Must comply with all requirements found in 29 CFR Subpart M Part 1926.

 

REQUIREMENTS FOR MATERIALS, CONFIGURATION AND INSTALLATION OF SLIDE GUARDS
Roof Slope
Height
Roof Type
Description
<6 in 12
<25'
Any
1. Material. All slide guards must be constructed of 2'' x 6'' (nominal) stock. 2. Installation. No more than three rows of roofing material (installed across the lower eave) shall be applied before installing the slide guard. The roof jacks (or similar supports) must be installed using nails long enough to withstand an employee sliding into the guard. 3. Configuration. The face of the slide guard must be perpendicular (about 90°) to the surface of the roof. There must be continuous slide guards along the eave.
>6 in 12
<8 in 12
<25'
Any
1. Material. All slide guards must be constructed of 2'' x 6'' (nominal) stock. 2. Installation. Continuous slide guards must be <8 in 12 installed along the eave, as described above. Additional slide guards must be installed below each work area at intervals not to exceed eight feet. They must be installed using the following procedure: the employee, while standing on the slide guard below, secures the roof jacks for the next slide guard with nails and then installs the planks. The employee then climbs up to the new slide guard to continue the roofing work. This sequence is repeated as work proceeds up the roof. 3. Configuration. The continuous slide guards at the eave must be about 90° to the roof surface, as described above. The additional slide guards need not be continuous, but they must be long enough to protect the work area. They do not have to be at 90° to the roof surface. 4. Removal. Once the roofing material is installed to the ridge, the employee is to climb down to the next lower slide guard and remove the upper slide guard. The employee repeats this process down the roof until all the slide guards are removed. Only when the roofing job is completed may the slide guards at the eave be removed.
>8 in 12
>25'
Any
This directive cannot be used. Must comply with all requirements found in 29 CFR Subpart M Part 1926.

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Do you hear what I hear?

The International Safety Equipment Association (ISEA) has formally asked the Occupational Safety and Health Administration (OSHA) to reduce the noise level permissible exposure limit (PEL) to 85dB from 90dB (over an eight-hour time weighted average).

ISEA’s petition included a study it commissioned that documented a vast number of hearing loss cases that took place when sustained workplace noise levels rose above 85dB.

The petition noted that the current OSHA regulation was developed more than 20 years ago and was based on 1960’s research. It also noted the U.S. is one of only two countries still using the 90dB PEL, and one of three using the 5 dB exchange rate (a subtractor of noise levels as distance from the source of the noise is doubled).

In another occupational hearing development, the Environmental Protection Agency (EPA) Office of Noise and Radiation has committed to making a hearing regulation final that has been pending since 2003.

Since 1972, the EPA has used the noise reduction rating (NRR) as its measure of hearing protector efficiency. However, the NRR is based upon laboratory testing, and therefore it has been viewed as not real-world attenuation by the end-user in the workplace. This has always been a point of contention, and has led to some correction factors to help identify actual attenuation levels.

Changes proposed by the EPA include a new method of testing hearing protectors, developing a two-number range that would indicate the 20th and 80th percentile of attenuation among users and periodic retesting of hearing protectors by manufacturers.

The EPA has indicated it would like to publish the final rule by December 2007.


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NIOSH issues sonographer safety recommendations

In response to a case study that investigated the reason behind a high rate of musculoskeletal disorders among sonographers, the National Institute for Occupational Safety and Health (NIOSH) has published workplace safety recommendations for sonographers.

The recommendations focus on engineering controls, work practices, hazard communication and training to prevent musculoskeletal disorders.

NIOSH found sonographers or ultrasound technicians are at risk of developing musculoskeletal disorders such as tendonitis, tendon sheaths, bursitis, muscle strains and pathology of the nerves in the upper extremities, neck and back.

The study identified the following factors that can lead to injuries:

  • Static and awkward postures and movement resulting from the use of transducers and the positioning of patients and equipment
  • Persistent, continual pressure for sustained periods during exams
  • Poor ergonomic design of equipment, chairs, tables and lighting
  • Increased exam scheduling
  • Worker height, age and gender

NIOSH recommendations to help prevent sonographer injuries include:

  • Providing adequate work space for personnel, equipment and patient tables
  • Positioning the sonographer equipment monitor directly in front of the sonographer
  • Alternating the scanning hand and vary the grip used
  • Minimizing awkward and extreme postures
  • Scheduling different types of exams each workday to decrease strain on musculoskeletal tissues specific to one type of exam
  • Employing periodic training and ergonomic reassessment

Click here for the complete list of recommendations.


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2007 DOT shipping classification changes

The Pipeline and Hazardous Materials Safety Administration (PHMSA) often modifies the hazardous materials shipping regulations to promote harmonization between domestic and international standards. Maintaining alignment with the international regulations has become more and more necessary as international shipments continue to grow.

Last August, the PHMSA published a proposed rulemaking to address a number of issues in many areas of the Hazardous Materials Regulations (HMR). The final rule concerning this proposal was issued in December. Unless otherwise noted in the final rule, the changes go into effect on Jan. 1, 2008.

Prior to that, shippers may comply with either the applicable requirements in effect on Dec. 31, 2006 or the requirements published in the Dec. 29, 2006 final rule.

This final rule has adopted many amendments in many different areas of the HMR. Some of the more notable ones that will affect most hazardous material shippers and carriers include:

  • Adoption of a single shipping paper description sequence. This new sequence—identification number, proper shipping name, hazard class or division, packing group—has been allowed as an alternative by the Department of Transportation (DOT) for some time; however, it will soon become the only one allowed. A six-year transition period has been authorized to allow businesses enough time to change computer systems and deplete any preprinted shipping materials.
  • Organic peroxide labels and placards rule revisions. To reflect the fact that organic peroxides are highly flammable and to help transport workers distinguish organic peroxides from oxidizers, the organic peroxide label and placard rules are being revised. Current labels meeting the specifications in effect on Dec. 31, 2006 can continue to be displayed until Jan. 1, 2011. The placards’ transition period extends through Jan. 1, 2014 for transportation by highway and until Jan. 1, 2011 for transportation by rail, vessel or aircraft.
  • Flammable liquid packing Group III upper limit change. 49 CFR Section 173.121 will revise the classification of packing group III flammable liquids. The current upper limit for a packing group III material is being lowered to 140°F, a 1° drop. This change will cause some previously nonregulated materials to become hazardous materials. The PHMSA has authorized a five-year transition period for this change.
  • Poisonous (Division 6.1) materials packing group changes. The toxicity requirements for Division 6.1 materials are being aligned with the criteria in the United Nations (UN) Recommendations. This change, which also has a five-year transition period, will not only include items previously not regulated, but will also change the packing group of some items and make some items no longer regulated under the HMR. The following chart shows the changes concerning the classification of these packing groups.
Material Properties Current PG Assignment New PG Assignment
Oral LD50 >200, </=300 (Solid)
Not regulated
III
Oral LD50 >300, </=500 (Liquid)
III
Not regulated
Dermal LD50 >40, </=50
II
I
Inhalation toxicity by dusts and mists LC50 >0.2, </=0.5
I
II
Inhalation toxicity by dusts and mists LC50 >4, </=10
III
Not regulated

The final rule also includes the following changes:

  • Requires the net quantity of hazardous material per package on the shipping paper when transported by aircraft.
  • Amendments to the Hazardous Materials Table to add, revise and remove certain proper shipping names, hazard classes, packing groups, special provisions, packaging authorizations, bulk packaging requirements, passenger and cargo aircraft maximum quantity limitations, and vessels stowage provisions.
  • Requirements for the transportation of fuel cells containing flammable liquid.
  • Adoption of a one-packet limit for matches carried by airline passengers or crew members.

The full final rule can be viewed on the PHMSA Web site.


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Ask A Tech Rep

Padlocks
Tiffany
Technical Representative

What are master-keyed padlocks?
When padlocks within a set are master keyed, each padlock is keyed differently and has two keys that open only that padlock. Also, there is another key—the master key—that will open every lock in the set. The master key and master-keyed padlocks must be ordered at the same time.

If I lose the keys for my padlock, can I get new keys?
Replacement keys can be obtained from the supplier of the padlock if you have the key number, which would be stamped on the orginal keys. If you cannot find the key number, some locksmiths and hardware stores will be able to impression the lock, allowing you to order new keys. However, you should call ahead to check on the cost and availability of this service.

Can Master Lock® keep a record of my combination and/or key numbers for me?
Master Lock provides a new, exciting online tool called combolocker.com that allows you to store up to five combinations and/or key numbers in a secure database. You can access your combinations 24 hours a day, seven days a week.

Are there weather-resistant padlocks?
Yes. Weather-resistant padlocks have either a protective shroud, such as a weatherproof thermoplastic cover or a coated shackle, to protect the lock from the elements, or are constructed from weather-resistant material such as stainless steel.

What is a rekeyable padlock?
Rekeyable padlocks contain a removable cylinder that can be replaced with a new cylinder or repinned, allowing for security to be restored quickly when keys are lost or stolen without requiring a new lock.

What is the difference between keyedalike and keyed-different padlocks?
All the locks in a keyed-alike padlock set are opened by the same key, eliminating the need for unique keys for each padlock. In keyed-different padlock sets, each lock is opened by its own key that is unique to the padlock and will not open any other lock in the set.

Are there OSHA requirements for color coding lockout/tagout locks (for example, are red banded locks specified for any particular purpose/situation)?
No. The color options are available to make organizing work groups easier, but no OSHA requirements exist for color coding the locks.

What is meant by shackle clearance?
The shackle is the loop of metal that opens up to lock or unlock a device. Shackle clearance refers to the space within the shackle of the padlock. The horizontal shackle clearance is the width of the space within the shackle; the vertical shackle clearance is the height of the space within the shackle.

What is a breakaway shackle?
A padlock with a breakaway shackle is designed to be opened with a key, but can also be removed by breaking the shackle in an emergency situation.

LSS offers packages of keyed-alike padlocks. If I order two packages, will they all be keyed alike?
If you order multiple sets of keyedalike padlocks, generally the same key will not open the different sets. However, if it would be more convenient to have the multiple keyedalike sets share the same key, this can be accomplished through a custom order.

For more information about Padlocks, contact Safety TechLine® Technical Support at 1-800-356-2501 or via e-mail at techsvc@labsafety.com. Or visit us online at www.LSS.com.


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Worth Noting

To-Do List: The Occupational Safety and Health Administration (OSHA) released its semiannual “to-do” list in late 2006. Eleven topics are in the pre-rule stage, eight topics are in the proposed rule stage and five topics are in the final rule stage. Click here to view the full 2006 agenda.

ISEA: ISEA is revising the Emergency Eyewash and Shower Equipment (ANSI/ISEA Z358.1), the Industrial Head Protection (BSR/ISEA Z89.1) and the Minimum Requirements for Workplace First-Aid Kits (BSR/ISEA Z308.1) standards. State-of-the art technology, test methods and user considerations will be reflected in the modified standards.

NFSI: The National Floor Safety Institute has proposed a new standard, Walkway Surface Auditing Guideline for the Measurements of Walkway Slip Resistance (BSR/NFSI B101.0) to prevent and reduce the effects of injuries and fatalities resulting from slip injuries and fall accidents.

Free Poster: OSHA recently announced publication of its new “It’s the Law” poster. The free poster, also known as the OSHA notice of employee rights, must be displayed in every workplace in the U.S. Employers aren’t required to replace their existing poster with the new version. Copies are available in English and Spanish from OSHA’s Web site. Free printed copies may be obtained from any OSHA regional or area office, or by writing to the OSHA Publications Office, Room N3101, 200 Constitution Ave. N.W., Washington, D.C. 20210; phone 1-202-693-1888.

Final: OSHA issued the final rule for the updated electrical installation standard in the Feb. 14, 2007 Federal Register. Changes to this general industry standard focus on safety in the design and installation of electric equipment in the workplace.


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TECHlines® is published bi-monthly by LSS Inc., PO Box 1368, Janesville, Wisconsin 53547-1368.
TECHlines®'s goal is to provide accurate information on the subject matter covered. However, it is impossible to guarantee absolute accuracy of the materials. The publisher, therefore, cannot assume any responsibility for omissions, errors or misprinting contained within this publication.
For additional information, call LSS's Safety TECHline® at 1-800-356-2501.

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