When I was young, 8 or 9 years old, I approached my dad. He was applying some kind of chemical to our lawn. I asked him the purpose of the powder. He answered me without hesitation. It’s pink elephant powder. “What do you mean” I exclaimed. “We don’t have pink elephants around here! We don’t have pink or even regular elephants!” Without missing a beat, he said that was because the powder worked so well. Even at that age, I recognized my dad was setting me up. I had been had. It would happen again and again over the next ten or so years.

  I bring this up as a prelude to a related event. In October, I’m scheduled to speak in Ohio. I’ll be discussing the revised Hazard Communication Program that is based on the Global Harmonized System (GHS). It will literally change our world by eliminating Material Safety Data Sheets. In their place will be a replacement aptly named a Safety Data Sheet (SDS). Employees must receive GHS training by December 1st, 2013. In some ways, this is a very timely event.

  OHSA has announced that the issuance of the revised standard will cause an increase in inspections over the next two years. Any problems found with your new GHS program, or lack of one, will result in citations but not in penalties or fines. This does not mean there will not be penalties with citations in other areas. In order to give the good people of Ohio a feel for how inspections would increase, I looked at the history of OSHA funeral home inspections.

  Now I’m getting back to the story of the pink elephant powder. Whatever powder Ohio funeral directors and embalmers are using works just as good as the elephant powder my dad was using. Folks, there has never been a funeral home inspection in Ohio. If you look at the list, there are four. But, those were to funeral homes with cemeteries or funeral home with crematories. In all cases, the funeral home itself did not receive the inspection.

  I was surprised by the lack of inspections in Ohio. According to OSHA, no employee has ever lodged a complaint. I could have addressed North Carolina funeral directors. They have to date, had over one hundred inspections and they add to that total every month. I should be investigating just exactly what Ohio funeral homes are doing and file my report with my North Carolina customers.

  So I’ll still be showing up to let everyone in Ohio know just what the new OSHA regulations entail. And if I have a little time in my two hour slot, I’m going to ask them about the elephant powder they use to keep President Obama and his elephant herd from the kind of invasion that is commonly felt in other states. When I find out why employee complaints that are common in Texas and Michigan but unheard of in Ohio, I’ll do more than let you know. I’ll process it into a powder and market it for $50 a bag. Anyone interested in buying?