OSHA Updates Walk Around Rule for Inspections

OSHA Updates Walk Around Rule for Inspections

Apr 19, 2024

A new final rule issued by OSHA gives employees the opportunity to designate an employee representative to accompany an inspector during OSHA inspections. The original rule, at 29 CFR 1903.8(c), allowed for employers to have a representative to accompany an inspector, now employees can designate one as well.

This new rule is a result of a 2017 court case where it was found the rule could be interpreted to allow employees to have a representative, but the rule wasn’t written that way.

What’s a Representative Do?

An example of an employer representative to accompany an OSHA inspector would be someone like iSi who provides a safety specialist to be there on behalf of the employer or provides an industrial hygienist for side-by-side sampling.  Now, employees can designate a representative as well.

Employee representatives can be someone internally employed by the company, a union representative, or a non-employee third party.  Third parties need to be someone “reasonably necessary” who can provide technical knowledge or practical experience about the processes and hazards of the types present in the workplace, or provide language and communication skills that facilitate the gathering of information from employees.

What Do You Need to Do?

The final rule is a right for employees, not a standard that requires employers to have any special compliance duties for.  It’s up to the employees to come up with their representative and there’s no formal instructions on how they should do that.  OSHA gives some suggestions on the process employees can use:

  • Chapter 3 of OSHA’s Field Operations Manual says in workplaces where employees are represented by a certified or recognized collective bargaining agent, the highest-ranking union official or union employee representative on-site designates who participates in the walkaround;
  • Employee members of an established safety committee or employees at large can designate the employee walkaround representative (per Chapter 3);
  • Employees can designate an authorized employee representative when they authorize them to file a complaint on their behalf;
  • Employees can also inform the inspector during the walkaround or during interviews that they have an authorized employee representative; or
  • An authorized employee representative can also inform the inspector or OSHA Area Office that they represent employees.

No set number of votes is required to designate an employee representative.  It doesn’t even have to be by a majority.  The person just must be authorized by more than one employee.

OSHA inspectors may determine at the complaint stage who the employee representative is based on who files the complaint or if they are represented by a labor organization. When they arrive onsite, inspectors may also ask if the employees have a designated representative or they may ask employees directly who their representative is.

Qualifications of Representatives

Inspectors have the right to question third party employee representatives on their qualifications or purpose for being there to ensure they’re making a positive contribution to a thorough and effective inspection. Third parties must be an aid in an inspection, not a distraction.  Typically, one employer representative and one employee representative will be allowed during the inspection.  An inspector can allow additional representatives in cases where they think it may benefit the inspection.  If there is more than one employer onsite that will be affected by the inspection, they may be allowed to have their own employer and employee representative. 

In cases where the employer disputes the necessity for the employee representative, and vice versa, the inspector has the final determination on who stays and who doesn’t.

Ground Rules for Inspections

All representatives will need to follow rules that all other visitors to the facility would be asked to follow regarding PPE use, confidentiality, limits on access to certain areas due to trade secrets, use of cell phones/cameras, etc.  Limitations on access, however, cannot interfere with the inspection. Special requirements cannot be placed on inspection representatives.  A documented Visitors Policy would be a good item to have on file at your facility to clearly state requirements for all visitors.

Representatives are not allowed to discuss matters unrelated to the inspection with the employees.

Third parties can participate in the opening conference, the inspection and the closing conference.  Both employer and employee representatives are not to be present for private interviews of the employees unless the employee specifically requests their presence.

Third party representatives cannot disrupt the inspection by doing anything that’s not directly related to a fair and orderly inspection.  Some examples would be preventing an inspector from taking photos, videos, or monitoring samples, preventing the inspector from privately interviewing employees, failing to always stay with the inspector, taking unauthorized photographs, handing out materials or cards, or failing to comply with any other ground rules set by the inspector.

Per the current policy, OSHA will only delay their inspection by 1 hour at the most to allow for offsite representatives to get to the facility.   This applied to employer representatives and will apply to employee representatives as well.

Future Challenges to the Rule

Already it appears this rule could be facing some legal challenges.  The rule was put together pretty quickly for an OSHA rule.  Among the issues brough up that challengers have already voiced include the possibility of introducing union reps in non-union workplaces to solicit and campaign during work hours; attorneys may use this to conduct pre-litigation discovery in personal injury or wrongful death actions; it could bring worker advocacy groups and community organizations without safety expertise into the workplace to organize non-union employees; and, competitors or other security threats could potentially gain access to proprietary information for economic or physical harm.

Learn More

Check out the new rule here.  If you have any questions, or would like to know more about the onsite employer representative services we can provide to you in your next regulatory inspection, contact us here.

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Safety Inspections and Corrections

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Curtis Leiker, CSP
Curtis Leiker, CSP

Contributing:

Curtis Leiker, CSP

Certified Safety Professional |  ISO 45001 and 14001 Lead Auditor

Curtis Leiker, CSP is a project manager at iSi Environmental. Besides assisting companies with ISO 14001 and 45001 implementation, Curtis manages environmental and safety programs, reporting and compliance issues for aviation, general industry and agricultural facilities. He’s able to see the big picture, but focus on the details and enjoys working to solve EHS issues.

Email  |  LinkedIn

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Who Needs DOT Hazmat Training?

Who Needs DOT Hazmat Training?

Apr 12, 2024

Photo of a person preparing a hazmat package for proper shipping.

Often we get the question, “Who needs DOT hazmat training?”  Not only are there nuances between the various agencies of DOT and the international transportation organizations DOT defers to, but often in companies there could be a number of people involved in the process – knowingly or unknowingly.

Basically, anyone involved in the process of sending hazardous materials (hazmat) will need to be trained. This would include anyone who:

  • Purchases the packaging and/or determines it’s the correct packaging for your materials;
  • Prepares the package for sending (boxes, labels, determines which box to use, etc.);
  • Fills out the paperwork, choosing labels or choosing placards;
  • Signs off on manifests or paperwork (including sending hazardous waste);
  • Loads, unloads, and handles hazmat;
  • Sells, tests, reconditions, repairs or modifies packaging for use in shipping hazmat;
  • Screens baggage, cargo, or mail;
  • Transports hazmat or operates a vehicle transporting hazmat;
  • Is a freight forwarder who accepts/transfers/handles/unloads cargo; and,
  • Anyone who supervises or conducts training for any of the above personnel.

Who Could be Involved?

So this could involve multiple departments or people at your company.  Roles such as:

  • Shipping & Receiving
  • Mailroom Clerks
  • Environmental, Health and Safety People
  • Hazardous Waste Handlers/Manifest Signers
  • Administrative Staff
  • Procurement/Purchasing and Finance
  • Warehouse
  • Plant Personnel
  • Operations Management

Take a look at your process. Who’s involved? Do they need to be involved? Have they been trained?

Training Content

DOT training is required by 49 CFR 100-185.  49 CFR regulates all hazmat shipments for the following agencies of the Department of Transportation:

  • Pipeline and Hazardous Materials Security Administration (PHMSA)
  • Federal Aviation Administration (FAA)
  • Federal Motor Carrier Safety Administration (FMCSA)
  • Federal Railroad Administration (FRA)
  • State agencies with authority to enforce DOT regulations

Your training content is required to include general awareness, security awareness, safety and then function-specific training to the role each person is doing in the process.  So the training durations could be different for different roles.

What if Someone Ships Hazmat For You?

Even if you have a third-party do the packaging for you, your company is still the shipper of record. That means anyone involved in the process from your end, even if it’s just one person signing paperwork that your vendor prepares, will need training.  By signing paperwork, that employee is legally certifying the hazmat is properly packaged and ready for transport. This would apply to companies you use for hazardous waste transports, crate building, or freight forwarding.

Planes, Trains and Automobiles (and Ships)

If your packages are going by ground, that is, truck or train, you’ll need DOT training with refreshers every three years. There are additional railroad regulations that need to be covered if you’re shipping by rail.

If packages are going by plane, such as overnight service, you’ll need separate IATA training with refreshers every two years. Please note that unless you specify your hazmat as “ground only”, there’s a possibility it could be put onto an airplane.  IATA has their own set of regulations in addition to the DOT, and air regulations are also covered in 49 CFR.

If packages are going on a ship, you’ll need IMDG training with refreshers every three years. This not only includes overseas shipments, but shipments to U.S. states such as Hawaii and Alaska or territories like Puerto Rico.

For more information about how the agencies work together, read our blog article, “Who Regulates Hazmat Shipments?”

If you need help sorting out who should be trained, or if you have employees you know need training or refreshers, contact us and we’d be happy to help! Check out our current hazmat shipping training schedule.

 

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OHSAS 18001 and ISO 45001: What’s the Difference?

OHSAS 18001 and ISO 45001: What’s the Difference?

Apr 11, 2024

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On November 27, 2017, a final version of the new International Standards Organization (ISO) 45001 standard was published, creating an official ISO standard for occupational health and safety programs.

In the early 2000s there were international standards for environmental management systems with ISO 14001, but not health and safety. Thus, a British Standard was developed, called Occupational Health and Safety Assessment Series (OHSAS) 18001.

ISO 45001 takes much of what’s already in OHSAS 18001 and adds to it, reorganizes it to match current ISO formats, and modifies some areas.  If you’re already OHSAS 18001 certified, you will have a good head start on ISO 45001 certification.

ISO 45001 brings the responsibility of safety to company leadership and establishes how safety incorporates into the entire organization, rather than making it a responsibility of safety management. The standard has more detailed clauses lining out its expectations of employee involvement, requiring the documentation of results and program effectiveness, risk evaluation and considering how safety affects all affected parties, not only employees but contractors, outsourced operations, vendors, etc.

Here are just a few of the differences between the two standards:

OHSAS 18001ISO 45001
British StandardInternational Organization of Standardization Standard
Reactive planningProactive planning
Hazard controlRisk evaluation, reduction and prevention
Procedures are preparedDocumented results are required
Safety management personnel play leadership roleTop management plays leadership role
Company management reviews the process after developmentCompany leadership takes leading role to ensure it fits within the overall organization’s processes.
Safety and health is the responsibility of safety management personnelSafety and health is the responsibility of leadership and the overall management system of the organization. External and internal issues related to the safety management system should be addressed by leadership. Workers and interested parties’ needs should be addressed and incorporated into the plan.
Employee participation consultationEveryone, including leadership, is responsible for safety. Workers should be provided education to help identify risks and everyone should participate. Internal audits and risk assessments should be shared with all employees and non-managers should participate in internal audits, risk assessments and incident investigation.
Information and communication procedures are preparedInformation and communication documentation is required including who, what, when, the objective of the communication and was it effective?
—Additional Elements
• Outsourced processes, procurement and contractors are addressed.
• Hierarchy of controls are to be used.
• Procurement of goods are to be considered.
• Contractor controls and communication requirements for their workers, your workers and any other affected parties are required.

iSi can help with developing ISO 45001 programs!  Contact us today!

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ISNetworld: The Top 10 Items You Need for Compliance

ISNetworld: The Top 10 Items You Need for Compliance

Apr 1, 2024

Contractor/vendor prequalification is becoming more and more the norm. ISNetworld is an online contractor safety prequalification program and just one among a crop of other programs like it, including Avetta, PEC Safety, Browz, Veriforce, ComplyWorks, First Verify and others.

Contractor prequalification programs give companies a way to limit the liability risks that onsite contractors can bring.   If you want to work for clients who use these programs, you must pay the cost to be a member and then take the time and effort to enter your company information into the system.

The number of clients for whom we have been asked to complete prequalification paperwork or join these types of systems has exploded in the last couple of years.  Some of our clients used to have teams of people tracking this information from contractors (and some didn’t track this stuff at all.).  These programs allow them to turn that responsibility over to someone else, and it puts a lot of the tracking responsibilities back onto the contractors themselves.  Sometimes this is seen as a way to narrow the field of potential contractors to just the serious ones who have good policies and performance.

Although there are lots of programs out there, we’re going to focus on ISNetworld because they are one of the leaders in this industry and they are one of the ones who ask for the most information.  At first glance, ISNetworld setup can be a daunting task. To help get you prepared, we present the Top 10 items you’ll need to gather for ISNetworld compliance (and just about any other safety prequalification program).

  1. General Company Information

You will need to know basic information about your company such as date established, structure, addresses and contacts, special codes and numbers (NAICS, Tax ID, DUNS, etc.), number of employees, financial and project references and more.

  1. Safety Policies and Procedures

You will be asked a number of questions about your safety policies. How is your safety program set up, how is it built and who’s responsible?  What’s the management structure and is company leadership involved?  Are hourly employees involved and do you have full-time safety personnel?  What training do supervisors get? Do you do audits, who does them and how often?  

Also included are questions about safety meetings, training, documentation, observations, stop work policies, hazard reporting, policies for new hires, incident investigation and communication.

  1. Written Safety Programs

If you’re following OSHA compliance, you should already have written safety programs for the hazards your employees can be exposed to. Depending on the services you say you provide, ISNetworld and your client will generate a list of the individual written safety programs that you need. There will be specific elements that you’ll be required to incorporate into your written programs, so it’s likely you’ll need to update your programs. Be very mindful what your revised program commits your company to. If it’s written in your program that your company will do something, you need to do it. If not, you could expose yourself to fines from OSHA for not following your own plan.

ISNetworld will ask you every 3 years to revalidate these programs to ensure they are still current.

  1. Training Programs

For many of the written programs, you’ll be asked to upload corresponding training sign-ins and information from those classes, so you may need to conduct additional training on a variety of topics. Be prepared to answer questions related to what kind of training you provide to new hires and routine employees, how often and how they are documented.

  1. Regulatory Data

You will need to track OSHA injury and illness data on a quarterly basis. This information is required to be input both quarterly and annually. You’ll also need 3 years of historical data. In ISNetworld you are graded on your 3-year average safety numbers and how they compare to industry standards. Thus, if you have a bad year, your grades may suffer for 3 years.

If you have commercial vehicles, you may need to enter DOT numbers and annual stats for number of drivers, miles driven, number of units, owner operators and violations. You’ll also need to enter in information about your company vehicle/driver programs and policies.

  1. Insurance

Individual insurance certificates will need to be uploaded for each client, and each will have specific requirements.  Be mindful of what the insurance requirements are for each client and know ahead of time what policies you have and what that covers.  Sometimes clients will require specialized policies or varying levels of coverage for certain items that can end up costing thousands of dollars if you agree to that.  However, sometimes these things can be negotiated down, depending on what you’re going to do onsite.  It just depends on the client and the situation.

Check with your insurance company to see if they’re a member of ISNetworld. If so, you can assign them to your account and they can upload certificates and deal with the nuances and negotiations for you. You will also need to enter 3 years of experience modification rate data and upload those documents as well.

  1. Employee and Contractor Data

Some clients will require you to track the number of hours that you and/or your subcontractors spent on the site each month.  These reports are required at the beginning of the month and are often required per site location.  Among the data you may need to report (depending on client requirements) will be hours spent onsite, number of employees onsite, number of miles driven, number of incidents (accidents, fires, spills), subcontractor hours, subcontractor numbers, subcontractor travel data, etc.  Some companies need to keep track of this information for PSM purposes and some like to keep track of contactor activities onsite.

  1.  Human Resources-Type Information

You’ll be asked to input your drug and alcohol policies and procedures.  Some owner clients will require you to have individual employees tested for drugs and alcohol through one of their approved vendors who shares the data directly with the program so that they can see if employees are in a green “OK” status or a red status.  They may also require background checks for each employee who will come onsite as well.   You may also need to provide employee personal information separately to your client to comply with Department of Homeland Security checks as well.  Pandemic preparedness programs are required from many clients, so what are your procedures and policies with that?  Thus, you may need to pull in some of your HR department to help you accomplish some of these requirements and get some answers.

  1. Other Procedures — Sustainability and Cyber Security

Within the past year we’ve seen questions pop up in ISNetworld and throughout multiple programs about our corporate sustainability and social responsibility programs.  One program (not ISNetworld) required us to write a separate written policy statement against human trafficking and a written policy on our stance on child and forced labor.  ISNetworld has also started getting into cyber security policies. There is an extensive questionnaire regarding computer systems and cyber security measures.  Several owner clients required us to develop a written cyber security program.  So besides HR personnel, you may need to bring in your IT people and anyone responsible for sustainability programs.

  1. Individual Training

More and more clients are requiring individuals to do the facility-specific safety orientation training ahead of time before ever stepping onsite.  Thus, if you have a specific project that you’re getting ready for, you may need to know exactly who is going to be involved in the project so that you can assign this training to them.  This would include subcontractor employees too.  Some clients will let you do the training all at once in a group, but more and more are requiring individuals to be given separate logins so that they can complete the training themselves.  So you may need to eventually gather email addresses for individuals who may not have a company email address and budget for time for those employees to take that training.

A Plan for Management and Completion

This isn’t a requirement, but certainly a best practice. You will need to identify a person(s) on your team who’s going to be responsible for managing sites such as ISNetworld. There can be a number of time-sensitive items which need to be managed. Not maintaining them will make your grades drop, hindering your ability to get further work with them, or even issue invoices.

The initial setup may require the assistance of a number of people in your company, or the help of an outside firm. You may need a combination of compliance personnel and administrative staff to handle the day-to-day management. Please note that if you do involve administrative staff, please keep in mind that policy questions and program creation are best completed by someone with a compliance background. You need to be very careful on how you answer the questions and what you commit yourself to. It could make all the difference between an “A” and an “F”.

Other Considerations

ISNetworld automatically uploads any OSHA citations for your clients to see, and these will likely affect your grade. You may also be required to have your own subcontractor management program, that is, a procedure for vetting your own subs.

We’ve found that ISNetworld is one of the most detailed prequalification sites. The silver lining is if you can get through ISNetworld, you have a good head start on some of the others.  However, every single site will ask for something new that one of the others didn’t, so don’t get too frustrated.  For example, some sites want you to upload your entire safety manual, some require specific procedures such as JSAs, and some will require much more if your employees perform specific tasks that require additional “operator qualifications” for each.

Resources

Make sure you keep your information stored in one central place so that it’s easy to access when you need it because it’s likely there will be information you’ll need to input a number of times.

iSi helps companies get setup in ISNetworld by providing policy and procedure guidance, written programs and training.  We also manage ISNetworld day-to-day compliance for companies.

Our sister company SafetyPlans.com has a number of ISNetworld-related program templates that will help you get a good start on developing a new plan if needed.

What can we do to help make the process smoother for you? Contact us today!

Need Help?

Need an extra hand to get this done? How about policies/programs developed or training conducted?

Get Help Here

Need Help?

Need an extra hand to get this done? How about policies/programs developed or training conducted?

Get Help Here

Contractor/vendor prequalification is becoming more and more the norm. ISNetworld is an online contractor safety prequalification program and just one among a crop of other programs like it, including Avetta, PEC Safety, Browz, Veriforce, ComplyWorks, First Verify and others.

Contractor prequalification programs give companies a way to limit the liability risks that onsite contractors can bring.   If you want to work for clients who use these programs, you must pay the cost to be a member and then take the time and effort to enter your company information into the system.

The number of clients for whom we have been asked to complete prequalification paperwork or join these types of systems has exploded in the last couple of years.  Some of our clients used to have teams of people tracking this information from contractors (and some didn’t track this stuff at all.).  These programs allow them to turn that responsibility over to someone else, and it puts a lot of the tracking responsibilities back onto the contractors themselves.  Sometimes this is seen as a way to narrow the field of potential contractors to just the serious ones who have good policies and performance.

Although there are lots of programs out there, we’re going to focus on ISNetworld because they are one of the leaders in this industry and they are one of the ones who ask for the most information.  At first glance, ISNetworld setup can be a daunting task. To help get you prepared, we present the Top 10 items you’ll need to gather for ISNetworld compliance (and just about any other safety prequalification program).

  1. General Company Information

You will need to know basic information about your company such as date established, structure, addresses and contacts, special codes and numbers (NAICS, Tax ID, DUNS, etc.), number of employees, financial and project references and more.

  1. Safety Policies and Procedures

You will be asked a number of questions about your safety policies. How is your safety program set up, how is it built and who’s responsible?  What’s the management structure and is company leadership involved?  Are hourly employees involved and do you have full-time safety personnel?  What training do supervisors get? Do you do audits, who does them and how often?  

Also included are questions about safety meetings, training, documentation, observations, stop work policies, hazard reporting, policies for new hires, incident investigation and communication.

  1. Written Safety Programs

If you’re following OSHA compliance, you should already have written safety programs for the hazards your employees can be exposed to. Depending on the services you say you provide, ISNetworld and your client will generate a list of the individual written safety programs that you need. There will be specific elements that you’ll be required to incorporate into your written programs, so it’s likely you’ll need to update your programs. Be very mindful what your revised program commits your company to. If it’s written in your program that your company will do something, you need to do it. If not, you could expose yourself to fines from OSHA for not following your own plan.

ISNetworld will ask you every 3 years to revalidate these programs to ensure they are still current.

  1. Training Programs

For many of the written programs, you’ll be asked to upload corresponding training sign-ins and information from those classes, so you may need to conduct additional training on a variety of topics. Be prepared to answer questions related to what kind of training you provide to new hires and routine employees, how often and how they are documented.

  1. Regulatory Data

You will need to track OSHA injury and illness data on a quarterly basis. This information is required to be input both quarterly and annually. You’ll also need 3 years of historical data. In ISNetworld you are graded on your 3-year average safety numbers and how they compare to industry standards. Thus, if you have a bad year, your grades may suffer for 3 years.

If you have commercial vehicles, you may need to enter DOT numbers and annual stats for number of drivers, miles driven, number of units, owner operators and violations. You’ll also need to enter in information about your company vehicle/driver programs and policies.

  1. Insurance

Individual insurance certificates will need to be uploaded for each client, and each will have specific requirements.  Be mindful of what the insurance requirements are for each client and know ahead of time what policies you have and what that covers.  Sometimes clients will require specialized policies or varying levels of coverage for certain items that can end up costing thousands of dollars if you agree to that.  However, sometimes these things can be negotiated down, depending on what you’re going to do onsite.  It just depends on the client and the situation.

Check with your insurance company to see if they’re a member of ISNetworld. If so, you can assign them to your account and they can upload certificates and deal with the nuances and negotiations for you. You will also need to enter 3 years of experience modification rate data and upload those documents as well.

  1. Employee and Contractor Data

Some clients will require you to track the number of hours that you and/or your subcontractors spent on the site each month.  These reports are required at the beginning of the month and are often required per site location.  Among the data you may need to report (depending on client requirements) will be hours spent onsite, number of employees onsite, number of miles driven, number of incidents (accidents, fires, spills), subcontractor hours, subcontractor numbers, subcontractor travel data, etc.  Some companies need to keep track of this information for PSM purposes and some like to keep track of contactor activities onsite.

  1.  Human Resources-Type Information

You’ll be asked to input your drug and alcohol policies and procedures.  Some owner clients will require you to have individual employees tested for drugs and alcohol through one of their approved vendors who shares the data directly with the program so that they can see if employees are in a green “OK” status or a red status.  They may also require background checks for each employee who will come onsite as well.   You may also need to provide employee personal information separately to your client to comply with Department of Homeland Security checks as well.  Pandemic preparedness programs are required from many clients, so what are your procedures and policies with that?  Thus, you may need to pull in some of your HR department to help you accomplish some of these requirements and get some answers.

  1. Other Procedures — Sustainability and Cyber Security

Within the past year we’ve seen questions pop up in ISNetworld and throughout multiple programs about our corporate sustainability and social responsibility programs.  One program (not ISNetworld) required us to write a separate written policy statement against human trafficking and a written policy on our stance on child and forced labor.  ISNetworld has also started getting into cyber security policies. There is an extensive questionnaire regarding computer systems and cyber security measures.  Several owner clients required us to develop a written cyber security program.  So besides HR personnel, you may need to bring in your IT people and anyone responsible for sustainability programs.

  1. Individual Training

More and more clients are requiring individuals to do the facility-specific safety orientation training ahead of time before ever stepping onsite.  Thus, if you have a specific project that you’re getting ready for, you may need to know exactly who is going to be involved in the project so that you can assign this training to them.  This would include subcontractor employees too.  Some clients will let you do the training all at once in a group, but more and more are requiring individuals to be given separate logins so that they can complete the training themselves.  So you may need to eventually gather email addresses for individuals who may not have a company email address and budget for time for those employees to take that training.

A Plan for Management and Completion

This isn’t a requirement, but certainly a best practice. You will need to identify a person(s) on your team who’s going to be responsible for managing sites such as ISNetworld. There can be a number of time-sensitive items which need to be managed. Not maintaining them will make your grades drop, hindering your ability to get further work with them, or even issue invoices.

The initial setup may require the assistance of a number of people in your company, or the help of an outside firm. You may need a combination of compliance personnel and administrative staff to handle the day-to-day management. Please note that if you do involve administrative staff, please keep in mind that policy questions and program creation are best completed by someone with a compliance background. You need to be very careful on how you answer the questions and what you commit yourself to. It could make all the difference between an “A” and an “F”.

Other Considerations

ISNetworld automatically uploads any OSHA citations for your clients to see, and these will likely affect your grade. You may also be required to have your own subcontractor management program, that is, a procedure for vetting your own subs.

We’ve found that ISNetworld is one of the most detailed prequalification sites. The silver lining is if you can get through ISNetworld, you have a good head start on some of the others.  However, every single site will ask for something new that one of the others didn’t, so don’t get too frustrated.  For example, some sites want you to upload your entire safety manual, some require specific procedures such as JSAs, and some will require much more if your employees perform specific tasks that require additional “operator qualifications” for each.

Resources

Make sure you keep your information stored in one central place so that it’s easy to access when you need it because it’s likely there will be information you’ll need to input a number of times.

iSi helps companies get setup in ISNetworld by providing policy and procedure guidance, written programs and training.  We also manage ISNetworld day-to-day compliance for companies.

Our sister company SafetyPlans.com has a number of ISNetworld-related program templates that will help you get a good start on developing a new plan if needed.

What can we do to help make the process smoother for you? Contact us today!

iSi can help you with contractor safety prequalification programs — Contact us today!

Get Pricing
Ask a Question
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What is a Toxic Release Inventory (aka TRI, SARA 313, Form R)?

What is a Toxic Release Inventory (aka TRI, SARA 313, Form R)?

Mar 26, 2024

What Is It?

TRI first came into existence in 1986 as part of the Superfund Amendments and Reauthorization Act (SARA) and Emergency Planning and Community Right-to-Know Act (EPCRA). TRI’s creation was influenced by an event in Bhopal, India in 1984 where a cloud of toxic gas from the Union Carbide chemical plant killed thousands. Then in 1985 a serious chemical release occurred to a similar chemical plant in West Virginia. EPA wanted a way for the public to learn more information about the chemicals used in their communities so it setup a reporting system for companies using potentially harmful chemicals above certain thresholds.

What’s the Difference Between TRI, Form R and SARA 313?

There are other names that are often used to refer to TRI reporting.

The first is “SARA 313.” TRI reporting is covered under Section 313 of SARA. Thus, TRI reporting is also referred to as “SARA 313” reporting. Other SARA reporting requirements include SARA 311 and 312 which are the Tier II chemical inventory reporting requirements we covered in our EPCRA Tier II blog, SARA 304 which is emergency spill reporting, and SARA 302 and 303 which cover emergency planning and notification requirements.

TRI reporting can also be known as “Form R” reporting. This is because one of the names of the forms used for TRI reporting is called Form R.

Reporting Criteria

In order to qualify for TRI reporting, your company must meet this criteria:

  • Employ 10 or more employees;
  • Fall under an identified NAICS code from the 2017 NAICS list; and,
  • Manufactures, processes, or uses a chemical on the TRI list of approximately 770 chemicals at a threshold above allowed levels. These chemicals have been identified as ones with significant effects to the environment or human health.  Chemicals are continually being added to this list.

2022 Updates

Due July 1, 2022:

  • All natural gas processing facilities that receive and refine natural gas are now subject to reporting.
  • Four PFAS chemicals have also been added:  silver(I) perfluorooctanoate (335-93-3), perfluorooctyl iodide (507-63-1), potassium perfluorooctanoate (2395-00-8), and 2-Propenoic acid, 2-methyl-, 3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,11,11,12,12,12-heneicosafluorododecyl ester, polymer with 3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,10-heptadecafluorodecyl 2-methyl-2-propenoate, methyl 2-methyl-2-propenoate, 3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,11,11,12,12,13,13,14,14,14-pentacosafluorotetradecyl 2-methyl-2-propenoate and 3,3,4,4,5,5,6,6,7,7,8,8,8-tridecafluorooctyl 2-methyl-2-propenoate (65104-45-2).
  • 29 contract sterilization facilities now must estimate their quantities of ethylene oxide and/or ethylene glycol manufactured, processed or otherwise used to determine if they are subject to TRI reporting.

In the previous reporting year (due July 1, 2021), over 172 PFAS chemicals were added to the list of chemicals and the thresholds for these were significantly less than other chemicals.

Report Format

TRI uses two different forms for reporting, Form R and Form A.  First, you will use Form R to identify chemicals.  For the rest of the reporting, you need to continue with Form R or use Form A.  Form A is a shortened form and only available if your company meets certain criteria in type of chemical, quantity, and waste generated. If you don’t meet the criteria for Form A, then you must use the longer Form R.

A form (R or A) must be completed for each chemical you manufacture, process or use in quantities above the threshold.

How are TRI Reports Submitted?

TRI reports are completed federally through EPA’s TRI-MEweb website. You will need to make copies to submit to your state agency as well.

This information will become public information and be searchable in several online databases.

Supplier Notifications

Companies who process or manufacture chemicals or chemical mixtures are required to send annual supplier chemical notifications per EPCRA Section 313.  For more details on who and what that entails, check out our blog “Annual Supplier Notifications: Does This Affect Your Company“?

Have Questions? Need Help?

Do you need help with this environmental reporting requirement? iSi’s compliance team can help determine if you are required to submit and help you get the forms submitted. Contact us here for more information and pricing.

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Example General Duty Clause Citations to Look for in Your Workplace

Example General Duty Clause Citations to Look for in Your Workplace

Mar 25, 2024

OSHA has a number of regulations that govern many aspects of the workplace. When there is not a specific regulation reference, they will often cite the General Duty Clause.

What is the General Duty Clause?

The General Duty Clause is found in Section 5(a)(1) of the Occupational Safety and Health Act. The General Duty Clause requires an employer to furnish to its employees “employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees.”

Employers can be cited for violation of the General Duty Clause if a recognized serious hazard exists in their workplace and the employer does not take reasonable steps to prevent or abate the hazard.   The General Duty Clause is used only where there is no OSHA standard that applies to the particular hazard. The following elements are necessary to prove a violation of the General Duty Clause:

1. The employer failed to keep the workplace free of a hazard to which employees of that employer were exposed;
2. The hazard was recognized;
3. The hazard was causing or was likely to cause death or serious physical harm; and
4. There was a feasible and useful method to correct the hazard.

OSHA cannot just cite anything under the clause, but there is a lot of room for interpretation of the effects of the hazard. The hazard needs to be recognized by that industry, another industry or another entity as a hazard. It can be something that would be considered a common sense hazard or is something that could cause or likely cause serious harm or death. It must be correctable, and if injuries have been documented related to it, it can be cited.

Examples of Common General Duty Clause Citations

While OSHA has issued citations under the General Duty Clause for a wide variety of issues including risk of lightning strikes to employees, there are a number of situations OSHA has cited that have been consistent and steady over the years.

Some common violations where OSHA would use the General Duty Clause:

  • Boilers not inspected and maintained
  • Cell phone use while driving
  • Combustible dust hazards
  • Ergonomic hazards
  • High visibility clothing not provided where struck by hazard exists with vehicular traffic
  • Industrial storage racking not:
    • Having maximum permissible load amount posted,
    • Not secured in place where there is potential to be tipped over, or
    • Significant damage
  • Personal fall protection equipment not inspected on annual basis
  • Powered Industrial Truck (forklift) drivers not wearing a seat belt while operating
  • Respiratory hazards from an air contaminant that is not covered by an OSHA permissible exposure limit (PEL)
  • Safety latch not in use on crane
  • Storing incompatible chemicals together
  • Structural damage to building causing struck by hazard
  • Thermal stress (high heat and cold)
  • Workplace violence risk that goes unmitigated

Do you have any of these issues at your facility?  iSi’s team of safety professionals can help through safety audits, safety inspections, issue corrections, training and program development.  Contact us today!

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Safety Inspections and Corrections

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Curtis Leiker, CSP
Curtis Leiker, CSP

Contributing:

Curtis Leiker, CSP

Certified Safety Professional |  ISO 45001 and 14001 Lead Auditor

Curtis Leiker, CSP is a project manager at iSi Environmental. Besides assisting companies with ISO 14001 and 45001 implementation, Curtis manages environmental and safety programs, reporting and compliance issues for aviation, general industry and agricultural facilities. He’s able to see the big picture, but focus on the details and enjoys working to solve EHS issues.

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What’s the Difference Between the HAZWOPER’s Emergency Response Plan and an Emergency Action Plan?

What’s the Difference Between the HAZWOPER’s Emergency Response Plan and an Emergency Action Plan?

Mar 18, 2024

hazardous cleanup emergency

Being prepared for emergencies at your facility is vital, and having that plan communicated to your employees is even more critical.  OSHA references a couple of different plans in its regulations, one is the Emergency Action Plan and then OSHA’s HAZWOPER standard mentions requirements for an Emergency Response Plan.  So, what’s the difference between these two plans?

HAZWOPER emergency response team

Emergency Action Plans (EAP)

When reading the OSHA standards for Emergency Action Plans, it’s easy to be confused because they can be pretty complicated.

EAP requirements are found in 29 CFR 1910.38(a).  They are part of Exit Routes and Emergency Planning in Subpart E.  A number of OSHA standards require that you have an EAP, including the regulations related to Process Safety Management, Fixed Extinguishing System-General, Fire Detection Systems, Grain Handling, Ethylene Oxide, Methylenedianiline and 1,3-Butadiene.

In 29 CFR 1910.157, Portable Fire Extinguishers, there is mention of needing EAPs as an alternative to teaching your employees how to fight fires.  There are a bunch of if/then conditions, but OSHA really puts it plainly in their online eTools that the only way a company wouldn’t have to have an EAP is if you have an in-house fire brigade where every employee was trained and equipped to fight fires.  So basically, it doesn’t matter which regulations require EAPs, if you don’t have an in-house fire brigade where every employee is trained to fight a fire, you’re going to need an EAP.

So, Then What’s in an EAP?

This standard says that an EAP must be in writing, kept in the workplace, and available to employees for review.

At a minimum, EAPs need to include procedures for:

  • Reporting a fire or other emergency;
  • Emergency evacuation, including type and exit routes;
  • Employees who remain to operate in critical plant operations before they evacuate;
  • Accounting for all employees after evacuation;
  • Employees performing rescue or medical duties; and,
  • Name and job title of every employee who may be contacted by employees who need more information about the plan or their duties under the plan.

Employers with more than 10 employees are required to have an employee alarm system with a distinctive signal.

As an employer, you must train employees in the safe and orderly evacuation of other employees.  You must review the EAP with every employee covered by the plan when they are initially assigned to a job, when that employee’s responsibilities in the plan have changed, or whenever you make any changes to the plan.

If you have 10 or fewer employees you can communicate the plan orally to employees however, it’s a good practice to still have it in writing because when you get your 11th employee unless you’re super organized, it’s unlikely that will trigger a reminder to put your plan in writing.

HAZWOPER Emergency Response Plan

The OSHA HAZWOPER (Hazardous Waste Operations & Emergency Response) standard at 29 CFR 1910.120 goes into detail about Emergency Response Plans.

If you are going to have your employees respond to releases and spills, you are required to have an Emergency Response Plan.  This also applies to employees that are dispatched to an incident such as from a fire station, fire brigade, or emergency medical service. This plan describes what the employees are expected to do in an emergency response.

If your facility intends to evacuate everyone from the danger area when there’s a release and have someone else do the emergency response portion, then you just need an Emergency Action Plan.  Otherwise, if you are having employees respond, you need the Emergency Response Plan.

HAZWOPER emergency response

Emergency Response Plans need to include procedures/instructions for:

  • Pre-emergency planning and coordination with outside parties;
  • Personnel roles, lines of authority, training, and communication;
  • Emergency recognition and prevention;
  • Safe distances and places of refuge;
  • Site security and control;
  • Evacuation routes and procedures;
  • Decontamination;
  • Emergency medical treatment and first aid;
  • Emergency alerting and response procedures;
  • Critique of response and follow-up; and,
  • PPE and emergency equipment.

Emergency response organizations may use the local emergency response plan or the state emergency response plan or both, as part of their emergency response plan to avoid duplication. The HAZWOPER plan has also been adopted by EPA’s SARA regulations at 40 CFR 311 for state and local government employees in federal-OSHA states and their volunteers.

Other Emergency Response Plans Required

These are just two plans from a whole laundry list of emergency-related plans required by OSHA, EPA, DOT, and several other agencies.  Want to learn more?  Read our blog about all the other emergency plans required here.

Need Help?

If you need help determining which plans apply to you, need help writing one of these plans, or just want a review, contact us!

 

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PSM Compliance Audits: How Often Are They Required? What’s Involved?

PSM Compliance Audits: How Often Are They Required? What’s Involved?

Mar 17, 2024

Companies that fall under Process Safety Management (PSM) requirements because of their highly hazardous chemicals are required to recertify that they have completed an evaluation of PSM compliance.

Compliance evaluations must occur at least once every 3 years.  Companies must certify that PSM compliance has been evaluated in order to verify that procedures and practices being followed are adequate and are being followed.

The audit needs to be planned ahead of time with plans for ensuring compliance, documenting findings, determining corrective actions and including field inspections of safety and health conditions and practices.

The Team

Audit team members should be chosen based on their experience, knowledge, training and familiarization with the standard.  Smaller companies may be able to have teams as small as one, but larger companies like refineries with 3 or 4 processes may need a team of 5-6 people over the course of 1-2 weeks.  You can use your own personnel, personnel from other plants, or consultants to conduct the audit.

The Audit

The audit should:

  • Make sure all PSM requirements are being followed;
  • Identify elements that need special attention;
  • Review pertinent documentation with samples large enough to ensure the audit results accurately reflect compliance;
  • Inspect the physical facilities to observe actual practices;
  • Interview all levels of plant personnel to determine awareness/knowledge of PSM requirements, safety procedures, and emergency procedures; and,
  • Record any deficiencies.

Report of Findings

Following the audit, a report of findings should document the results, and that should be signed by a responsible manager.  This becomes the official certification.  If you use an outside consultant as the auditor, the employer still needs to make that certification, not the consultant.

The report should include facts and information to support the audit did indeed determine and review compliance.  It should document corrective actions required and document any findings so that they can be compared to future audits to determine trends.  Additional observations discovered can also be included.

Deficiencies should be described, given milestones, tracked and assigned to affected personnel, then periodically followed up on.  Anything that was logged as a deficiency where no corrective action was taken needs to have explanations on why it wasn’t followed up on.

Recordkeeping

Companies are required to keep their two most recent compliance reports on file.  You do not need to turn those in to OSHA, just keep them on file and available for inspection.  Some companies choose to destroy earlier reports because they tend to list more findings on them.  Some companies also choose to do their reevaluations every 1-2 years for that reason as well.

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[For more about what PSM is, check out our blog “What is PSM?”]

Need help with PSM?  We can help you get compliant with your 14 PSM elements, conduct or participate in your recertification audit, or help you correct findings.  Check out our PSM page for more details!

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Curtis Leiker, CSP
Curtis Leiker, CSP

Contributing:

Curtis Leiker, CSP

Certified Safety Professional |  ISO 45001 and 14001 Lead Auditor

Curtis Leiker, CSP is a project manager at iSi Environmental. Besides assisting companies with ISO 14001 and 45001 implementation, Curtis manages environmental and safety programs, reporting and compliance issues for aviation, general industry and agricultural facilities. He’s able to see the big picture, but focus on the details and enjoys working to solve EHS issues.

Email  |  LinkedIn

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Which Environmental Regulations Apply to Emergency Power Generators?

Which Environmental Regulations Apply to Emergency Power Generators?

Mar 17, 2024

Emergency power generators can be critical pieces of equipment for any facility, especially in the stormy seasons of spring or winter or in disasters such as floods and the hurricanes of summer and early fall. If you have one in your facility now, or are thinking about getting one, you need to be aware of the environmental regulations which are triggered by having one onsite.

EPA defines emergency generators as “…stationary combustion devices, such as reciprocating internal combustion engine or turbines that serve solely as a secondary source of mechanical or electrical power whenever the primary energy supply is disrupted or discontinued during power outages or natural disasters that are beyond the control or operator of a facility.” There are no time limits to using emergency generators during an emergency, but there are limits to the number of hours a generator can be used in non-emergency situations such as maintenance, testing, and other occasions such as offsetting electrical demand or to reduce electrical costs.

The bigger the generator, and the older the generator, the more likely environmental regulations will be triggered. The type of fuel used to power the generator also affects compliance. Generators can run on diesel fuel, gasoline, propane or natural gas.

The following environmental regulations may be triggered by your emergency generator:

Air Emissions

Emergency generators can have the potential to emit various air pollutants such as carbon monoxide, volatile organic compounds, xylene, carbon dioxide, sulfur dioxide, and others.

Depending on your state or local environmental regulations and the type of generator you have, you may need to prepare and file for an air permit whether it be a general permit, an operating permit, or a construction permit.

There are specific rules which govern the various types of generator engines. 40 CFR 60, Subpart IIII is for stationary compression ignition generators, 40 CFR 60, Subpart JJJJ is for stationary spark generators, and 40 CFR 63, Subpart ZZZZ applies to reciprocating internal combustion engines (RICE). Each regulation has strict operating guidance and compliance obligations.

Spill Prevention, Control and Countermeasures (SPCC)

If the fuel which you store onsite is in a tank with aboveground storage above 1,320 gallons, you will need to prepare an SPCC plan. SPCC Plans identify discharge prevention potential, discharge prevention measures and tasks, training, and the procedures to be followed if a spill does occur.

Emergency Planning and Community Right to Know Act (EPCRA)

If your fuel storage is above certain amounts, you will be required to conduct EPCRA annual reporting, chemical inventorying, and notifications. (For more information about EPCRA read our EPCRA blog article.)

Tank Certifications and Registrations

Aboveground and underground fuel storage tanks may need to be registered, permitted, inspected, and certified per state and local regulations.

PCBs

A potential for the presence of polychlorinated biphenyls (PCBs) can be found in any transformers, capacitors, electrical equipment, thermal insulation and motor/hydraulic oils. Cleanups, exposures and removals would need to be handled according to EPA’s PCB regulations.

Employee Exposure Issues

Though technically a safety issue, any backup generator which is brought into a facility could cause additional employee exposure issues. Before the use of generators, noise monitoring would need to be conducted to determine the potential noise exposures to employees in the area. Exhausts emitted from indoor generators may cause additional issues with employee exposure to chemicals, causing the need for engineering controls or additional employee personal protective equipment use.

Which Environmental Regulations Apply to Your Emergency Power Generator?

The regulations which apply to emergency power generators can vary greatly depending on style, type, model, your location, facility setup and other factors. What are your specific permitting requirements? Let iSi figure this out for you. Contact us for more information about environmental obligations, or ask us for a pricing quote to take a look at your situation.

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EPA Makes Final Rule to Update RMP Requirements

EPA Makes Final Rule to Update RMP Requirements

Mar 15, 2024

EPA has issued a change to its Risk Management Program, or RMP regulations for those who process, produce, handle or store hazardous substances or chemicals.  The changes are in an amendment to the rule, officially called the Safer Communities by Chemical Accident Prevention, or SCCAP.  These new rules hope to help increase protection for human health and environment from chemical hazards using lessons learned and process safety procedures.

First, What’s RMP?

RMP can be found in EPA’s Clean Air Act.  If you produce, process, handle or store one of 140 targeted toxic or flammable chemicals that have the potential to be released at certain threshold quantities, then you fall under RMP requirements.  Some examples of the 140 chemicals included are ammonia, chlorine, propane, formaldehyde and sulfur dioxide.

Water treatment plants, agricultural COOPs and chemical manufacturers are typical types of companies who need to comply with RMP.

RMPs must include:

  • Hazard assessments
  • Potential effects of a chemical accident
  • 5-year accident history
  • Evaluation of worst-case scenarios and alternative accident release potentials
  • Prevention programs that include safety precautions, maintenance, monitoring, and employee training measures
  • Emergency response program that lists emergency health care, employee training measures, procedures for informing the public.

RMPs are similar to OSHA’s Process Safety Management (PSM) standard, but RMP is concerned with protecting the environment and human health while PSM is focused on protecting the worker.  Unlike PSM, RMPs are directly submitted to EPA and information is input into a public database for transparency purposes.

Program Levels

A number of the changes are related to specific program levels of RMP.  There are 3 levels to RMP:

Program 1

Processes which would not affect the public in the case of a worst-case release and with no accidents with specific offsite consequences within the past five years.  These sites have limited hazard assessment and minimal prevention and emergency response requirements.

Program 3: 

This is for processes not eligible for Program 1 and are either subject to OSHA’s PSM standard or have one of 10 specified North American Industrial Classification System (NAICS) codes (NAICS code 32211, 32411, 32511, 325181, 325188, 325192, 325199, 325211, 325311, or 32532).  This program requires using OSHA’s PSM standard as your prevention program plus there are additional hazard assessment, management, and emergency response requirements.

Program 2:

If you don’t fit into Program 1 or 3, then you are a Program 2.  This program imposes streamlined prevention program requirements, as well as additional hazard assessment, management, and emergency response requirements.

The Rule Changes

Emergency Response

  • RMP facilities must develop procedures for informing the public about accidental releases.
  • Release notification data must be provided to local responders.
  • A community notification system must be in place for RMP-reportable accidents.
  • Field exercises must be conducted every 10 years unless local responders indicate that’s infeasible.
  • Emergency response exercises are to follow mandatory scope and reporting requirements.

Third-Party Compliance Audits

  • A third-party must do the next scheduled compliance audit when an RMP-regulated facility experiences two RMP-reportable accidents within five years or when a Program 3 facility under NAICS 324 or 325 has one reportable accident within one year AND that facility sits within one mile of another NAICS 324 or 325 process facility.

Program Requirements

  • Facility siting must be considered in Program 2 hazard reviews and Program 3 process hazard analyses.
  • When facilities have a reportable accident, a formal root cause analysis incident investigation must be conducted.
  • Program 2 hazard reviews and Program 3 process hazard analyses must now address natural hazards (including those resulting from climate change) and power losses.
  • Whenever a recommendation from a hazard evaluation, facility siting, or a third-party compliance audit is not adopted, a justification needs to be put into the RMP.

Employee Participation

  • Employee participation is required in resolving process hazard analyses, compliance audit and incident investigation recommendations and findings.
  • Employee participation is required for stop work procedures in Program 3.
  • Program 2 and 3 sites must provide opportunities for employees to anonymously report RMP accidents or issues of non-compliance.

Safer Technologies and Alternatives Analysis (STAA)

  • A STAA evaluation is required for all Program 3 NAICS 324 and 325 processes.
  • A Practicability assessment of inherently safer technologies and designs (IST/ISD) should be considered if your process falls within one of these conditions:
    • It’s a Program 3 under NAICS 324 and 325 within one mile of another Program 3 NAICS 324 or 325 process,
    • It’s a process under NAICS 324 using with hydrofluoric acid alkylation,
    • You’ve had one RMP accident since the facility’s most recent process hazard analysis.
  • Implement at least one passive measure at the facility, or IST/ISD, or a combination of active and procedural measures equivalent to or greater than the risk reduction of a passive measure for the same facilities required to conduct the practicability assessment.
  • When STAA recommendations are not adopted, then you must provide justification.

Communication

  • The facility must now provide chemical hazard information, upon request, to residents living within 6 miles of the facility in the language they request.

Other

  • Hot work permits must be kept for 3 years.
  • Program 2 and Program 3 requirements should be consistent for recognized and generally accepted good engineering practices.
  • Program 3 process safety info must be kept up to date.

Compliance Dates

The SCCAP is effective May 10, 2024.  There are two separate compliance dates.  Emergency response field exercise frequencies are due by March 15, 2027, or within 10 years of the date of an emergency response field exercise conducted between March 15, 2017 and August 31, 2022.

The following items are due three years after Final Rule publication (May 10, 2027)

  • Root cause analyses
  • Third-party compliance audits
  • Safer Technologies and Alternatives Analysis (STAA)
  • Employee participation
  • Emergency response public notification
  • Exercise evaluation reports

More Information

If you have questions or need assistance in determining if your facility is required to comply with RMP, or if you need help getting one setup, contact us!

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OSHA Looks to Issue “Emergency Response” Standard, But Despite Name, Will Have Little Effect on HAZWOPER

OSHA Looks to Issue “Emergency Response” Standard, But Despite Name, Will Have Little Effect on HAZWOPER

Mar 4, 2024

In January, OSHA issued a notice of proposed rulemaking to replace the existing general industry Fire Brigade standard at 1910.156 with a new broader standard called “Emergency Response.”  Despite the name, the standard will still not be the same as the current HAZWOPER (Hazardous Waste Operations and Emergency Response) standard, but HAZWOPER and other related standards will see still some minor changes and additions as a result of this effort.

The New Standard

The current Fire Brigade standard applies to general industry facilities that have in-house fire brigades, industrial fire departments, and private or contract fire departments.  This doesn’t include people trained to put out fires with fire extinguishers or standpipe hose systems, it’s actually for those companies with an in-house firefighting team. The new rule would include those same entities PLUS employers that provide pre-hospital emergency medical services, technical search and rescue services, or have employees that perform emergency services as their primary duties.  The new standard still stays more toward fire, rescue and medical-related emergency responses, not the hazardous materials spills that HAZWOPER is related to.

The new standard will divide companies into two groups.  One is “Emergency Service Organizations,” or ESOs, and the other is “Workplace Emergency Response Employers,” or WEREs.

Emergency Service Organizations pay employees, entities with volunteers, or entities that have both members and volunteers primarily to do response activities such as firefighting, EMS and technical search and rescue.  ESO employees in this function will be called “responders.”  The only volunteers covered in this standard are those who get significant pay or other compensation, which OSHA doesn’t believe there are many. Federal OSHA standards do not cover volunteers, but some state plans do.  If you are in an OSHA state plan state, check your state’s requirements regarding volunteers.

The other group, Workplace Emergency Response Employers, are companies where the employees have other primary jobs at the site and do emergency responses infrequently. The responses still involve firefighting, emergency medical services, and/or technical search and rescue. Individuals in WEREs will be called “team members” and the group of team members will collectively be called “Workplace Emergency Response Teams.”

The point of this new standard is to bring in more up-to-date consensus standards from the National Fire Protection Association (NFPA) and to align better with the Federal Emergency Management Agency (FEMA) and its National Incident Management System (NIMS) processes.  The Fire Brigades standard was written in 1980 with no significant changes, and thus is quite outdated.  The new standard is also aimed to move related items from other standards and get them into one place.

There will be a number of requirements for ESOs and WEREs including written Emergency Response Plans, Facility Vulnerability Assessments, and Pre-Incident Plans. Vulnerability assessments will analyze each area of the facility to determine which areas need pre-incident plans and if the equipment, firefighting capability and PPE is sufficient to handle a potential incident there. Additional medical and physical requirements, training, equipment and PPE, post-incident analysis, and incident management system development directions will be detailed.  The standard will not apply to cleanups or the aftermath of an incident, just the emergency portion.

Other Standards Affected

OSHA realizes that emergency response information is scattered throughout different parts of 1910 that need to be consolidated, and while they’re addressing emergency response, there are a number of NFPA and ANSI standards that are newer and relevant that also need to be included.  As a result, OSHA is proposing to make these additional standard changes:

1910.6            Incorporation by Reference

A number of newer ANSI and NFPA standards related to emergency response, fire, medical services response, and PPE will be added.

1910.120       HAZWOPER, including Subpart H Hazardous Materials

OSHA wants to add an Appendix D to include references to new consensus standards for personal protective equipment.  The specific NFPA standard referenced is NFPA 1990 – Standard for Protective Ensembles for Hazardous Materials and CBRN Operations [2022 ed]. These are standards for chemical protective suits.

Changes in standard text will include:

(q)(3)(iii) Based on the hazardous substances and/or conditions present, the individual in charge of the ICS shall implement appropriate emergency operations, and ensure that the personal protective equipment worn is appropriate for the hazards to be encountered. However, personal protective equipment shall meet, at a minimum, the criteria contained in § 1910.156(k) when worn while performing firefighting operations beyond the incipient stage for any incident.

(r) Appendices to this subpart—Hazardous Waste Operations and Emergency Response. Appendices A through E to this subpart serve as non-mandatory guidelines to assist employees and employers in complying with the appropriate requirements of this section. However, paragraph (g) of this section makes mandatory in certain circumstances the use of Level A and Level B PPE protection set forth in the appendices.

Changes to Appendix B of Subpart H will read:

  1.  

Level D

—Level D protection should be used when:

  1. The atmosphere contains no known hazard; and
  1. Work functions preclude splashes, immersion, or the potential for unexpected inhalation of or contact with hazardous levels of any chemicals.

Note:

As stated before, combinations of personal protective equipment other than those described for Levels A, B, C, and D protection may be more appropriate and may be used to provide the proper level of protection.

As an aid in selecting suitable chemical protective clothing, it should be noted that the NFPA has developed standards on chemical protective clothing. The standards that have been adopted include:

NFPA 1990, Standard on Protective Ensembles for Hazardous Materials and CBRN Operations, [2022 ed]. (as incorporated by reference, see § 1910.6).

 

This standard applies documentation and performance requirements to the manufacture of chemical protective suits. Chemical protective suits meeting these requirements are labelled as compliant with the appropriate standard. It is recommended that chemical protective suits that meet these standards be used.

1910.134       Respiratory Protection, including and Subpart I Personal Protective Equipment

OSHA will be removing the definition of Interior Structural Firefighting out of the respiratory protection standard and will be moving it to the new 1910.156.

1910.155       Subpart L, Fire Protection – Scope, application and definitions

A number of definitions will be removed from this section, while others will be added.

1910.157       Portable Fire Extinguishers

There currently is no mention of the Class K fire extinguisher, so revisions and additions will include:

(c)(3) The employer shall not provide or make available in the workplace portable fire extinguishers using carbon tetrachloride, chlorobromomethane, or methyl bromide extinguishing agents.

(d)(7) The employer shall distribute portable fire extinguishers of Class K extinguishing agent for use by employees so that the travel distance from the Class K hazard area to any extinguisher is 30 feet (9.15 m) or less.

1910.158       Standpipe and Hose Systems

Facilities will be required to have fire hose connections/adapters that are compatible with your local fire department or the WERE that’s pumping water into the emergency.

(c)(2)(iii) The employer shall ensure that standpipe system inlet connections and fittings are compatible with, or adapters are provided for, the fire hose couplings used by the fire department(s) or Workplace Emergency Response Team(s) that pump water into the standpipe system through the connections or fittings.

1910.159       Automatic Sprinkler Systems

Compatible adapters and equipment will be required here as well.

(c)(12) Inlet connections. The employer shall ensure that sprinkler system inlet connections and fittings are compatible with, or adapters are provided for, the fire hose couplings used by the fire department(s) or Workplace Emergency Response Team(s) that pump water into the sprinkler system through the connections or fittings.

The Regulation and Public Comment Period

You can read more about this new standard here.  Comments are being solicited until May 6, 2024.  Additional stakeholder meetings may also be held upon request.  iSi will keep an eye on this standard’s progress.

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Compressed air, either through a fixed or a portable system, can be used to supply air to employees as they perform tasks that could not be done using an air purifying respirator.

Supplied air respirators are respirators that supply the user with breathing air from a source independent of the ambient atmosphere.

First we’ll take a look at breathing air components, then we’ll cover its OSHA requirements.

paint booth worker

What Operations Use Supplied Breathing Air?

Supplied breathing air can be used across all industries for many different functions throughout the facility.  Some of the most common include:

  • Confined Space Entry
  • Sand/Media Blasting Operations
  • Working in Paint Booths
  • Welding

What Are the Components of a Breathing Air System?

A simple breathing air system has four basic components.

Air Source

The air source can be from a fixed or portable compressor. This compressor can be either electric, gas or diesel powered. Another source can be from bottled or tanked air. The air source should be sized to provide a minimum of 4 cubic feet per minute (CFM), but depending on the work being done, workers may require up to 15 CFM. Typical systems operate around 10 to 12 CFM. Pay special attention to the intake area of the compressor to be sure that no gasses or vapors can be drawn into the system as they will be passed down to the employee.

Filtration

The filtration used is very important. The filtration system should be able to remove water, oil and particles, and many use a charcoal bed to remove odors and tastes. Remember to make sure the filtration system can supply the required CFM. Carbon monoxide (CO) is a special danger if the air source is not an oilless compressor and a CO monitor with alarm is then required. This alarm needs to be able to be heard by everyone connected to the air source at their point of use.

Air Distribution

The filtered air then needs to be set to the proper pressure required by the specific respirator so a regulator will be needed to drop the air pressure and not overpressure the employee’s mask. Employees are able to connect to a breathing air system via quick connect couplings, OSHA requires these couplings to be unique to the breathing air system. This ensures that employees are unable to connect a respirator to a non-breathing air system (shop air). It is also a requirement that the hose the employee uses is a maximum of 300 feet.

Respirator

The selected respirator can be of several varieties such as pressure demand or continuous flow, tight fitting face piece or loose-fitting hoods or helmets. These choices need to be made prior to the set up of the system as they can affect the design of the system. For example, if you are planning to use a continuous flow system a bottle supplied air source will not last very long.

breathing air system

What are OSHA’s Requirements for a Breathing Air System?

Breathing Air Gases Testing

The OSHA standard requires the employer provide employees using atmosphere-supplying respirators with breathing gases of high purity. To this end, OSHA has incorporated the ANSI/Compressed Gas Association Commodity Specification for Air, G-7.1 to include testing to meet the following:

  • Oxygen content percentage by volume: Between 19.5% and 23.5%
  • Hydrocarbon (oil and particulate): maximum of 5 milligrams per cubic meter of air
  • Carbon monoxide: maximum of 10 parts per million by volume
  • Carbon dioxide: maximum of 1000 parts per million by volume
  • Lack of noticeable odor

breathing testing

This breathing air gases are also commonly referred to as Grade D breathing air.  There are other grades of breathing air available that differ in oxygen content, hydrocarbons and water content that are used by fire departments and other SCBA wearers, but Grade D breathing air is the standard for industry.

While OSHA does not require breathing testing to be done on any interval, the industry standard for this testing is to be done annually for each distribution point.

Written Respiratory Protection Plan

Any company requiring employees to use respiratory protection must have a written Respiratory Protection Program that meets all the requirements of 29 CFR 1910.134.

Medical Evaluations

OSHA first requires the respirator user to be medically cleared to use a respirator. The doctor will need to know that the employee will be using a supplied air respirator so they can understand the physical requirements of the respirator being used.

Training

OSHA then requires that all respirator users be trained on how to use their respirator, the limitations of that respirator and any procedures such as when the CO alarm goes off what needs to be done.

Fit-Testing

If the respirator selected is a tight fitting facepiece, OSHA requires a fit test to ensure the facepiece provides a proper seal to the users face.

Preventative Maintenance Plan

On a system that has a CO monitor, a preventive maintenance plan needs to be established to perform calibration on the monitor. Most manufacturers require monthly calibration with a certified canister of carbon monoxide gas. Calibration dates should be documented.

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iSi has Grade D breathing air system testing equipment and routinely conducts tests for our clients.  We can also help you with the other breathing air system requirements of OSHA.  Contact us today!

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Contributing:

Keith Reissig

Industrial Hygienist | Project Manager

Keith brings over 20 years of industrial hygiene and safety experience to iSi and its clients. An industrial hygienist, Keith jokes that he "sucks air for a living."  He specializes in workplace exposure testing and sampling strategies, safety compliance, ergonomics and training in a variety of topics in both the industrial hygiene and safety field.

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What is PSM?

What is PSM?

Feb 26, 2024

Process Safety Management, or PSM, is an OSHA regulation that is concerned with processes at your facility that use highly hazardous chemicals.  PSM provides a compliance framework to evaluate each process with the end goal of no spills, fires, explosions, reactions, releases or other incidents arise from their use.  The official standard can be found at 29 CFR 1910.119.

PSM applies to

  • Processes which involve certain threshold quantities of chemicals listed in the standard’s Appendix A
  • Processes where there are 10,000 lbs. or more of a Category I flammable gas (per 1910.1200(c)) or flammable liquids with a flashpoint below 100 degrees on site in one location
  • Manufacturing explosives or pyrotechnics in any quantity

Exceptions to these include retail facilities, hydrocarbon fuels for workplace consumption of fuels, oil or gas well drilling or servicing operations and unoccupied remote facilities.  Facilities with flammable liquids with a flashpoint below 100 degrees that are stored in atmospheric tanks or that are transferred below their normal boiling point without being refrigerated are also exempt.

The 14 Elements of Compliance

There are 14 elements to a Process Safety Management compliance program.  These include:

 1.  Employee Participation

Those who are most familiar with the process need to be involved.  Facilities must have a written plan of action on how they’re going to incorporate employees into the process hazard analyses and development of other elements of PSM.  Both operations and maintenance personnel and any other employees that play a heavy role in facilities operations must be involved.  Employees must be represented at meetings and teams should include persons involved in the process being used.

2.  Process Safety Information

Facilities must first compile written process safety information before they can do their hazard analysis.  Process safety information looks at the hazards involved with the processes at the facility.  Information should include:

  • Toxicity
  • Permissible exposure limits
  • Physical, reactive and corrosivity data
  • Thermal and chemical stability data, especially the hazards in mixing different materials
  • Flow diagram of the process
  • Process chemistry
  • Maximum intended inventory
  • Safe upper and lower limits for temperatures, pressures, flows, compositions
  • Consequences of deviations

Facility equipment must be evaluated for its compliance with engineering standards, including:

  • Materials of construction
  • Piping and instrument diagrams
  • Electrical classification
  • Relief and ventilation system designs
  • Design codes and standards
  • Material and energy balances
  • Safety systems

3.  Process Hazard Analysis

Process hazard analysis should identify, evaluate and determine ways to control hazards involved within the process.  OSHA lists some suggested methods you can use to do your process hazard analysis.  The analysis needs to be updated, revalidated and documented every 5 years.  It’s suggested that not only persons knowledgeable in the specific processes be involved, but engineering and maintenance experts need to be involved as well.

Some of the items to be evaluated:

  • The hazards of the process
  • The identification of any previous incident that had a potential for catastrophic consequences
  • Engineering and administrative controls applicable to the hazards and their interrelationships, like detections to provide early warning of releases
  • Consequences of failure of engineering and administrative controls
  • Facility siting
  • Human factors
  • A qualitative evaluation of a range of the possible safety and health effects if a failure of controls occurs.

Facilities are required to develop and document a system to address the findings and get them resolved in a timely manner.

4.  Operating Procedures

Written operating procedures need to be developed with safety in mind.  Some of these include procedures for:

  • Initial startup and startups after turnarounds
  • Normal operations
  • Temporary or emergency operations
  • Shutdowns
  • Operating limits
  • Precautions to prevent exposures
  • Safety systems
  • Quality control for raw materials
  • Safe work practices

5.  Training

Initial PSM training is required for new employees or persons assigned to new processes.  Refresher training is required every 3 years.

6.  Contractors

PSM applies to contractors conducting maintenance, repair, turnaround, major renovation or specialty work adjacent to a covered process.   Facilities are responsible for gathering contractor safety performance and programs, informing contract employers of known fire, explosion or toxic release hazards, explaining the emergency action plan, developing and implementing safe work practices to control the presence, entrance and exit of contract personnel and maintaining contractor injury and illness log information.

7.  Pre-Startup Safety Review

Safety procedures must be reviewed in a pre-safety review before a new facility starts up or modified facility starts up again.

8.  Mechanical Integrity

Mechanical integrity requirements apply to pressure vessels, storage tanks, piping systems, relief and vent systems and devices, emergency shutdown systems, controls and pumps.

Written procedures must be developed to ensure ongoing integrity of process equipment is   maintained and routinely inspected using good engineering practices.  Any deficiencies found must be corrected before further use.

9.  Hot Work Permit

Hot work permits are required to be issued for work on or near a covered process and kept on file until completion of the work.

10.  Management of Change

Any change to a process must be thoroughly evaluated for its impact on employee safety and health.  Written procedures must be developed to discuss the change’s:

  • Technical basis
  • Impact on employee safety and health
  • Modifications to operating procedures
  • Time period
  • Authorization requirements

Any affected employees must be informed of and trained in the change prior to startup.  Any changes that affect process safety information will mean changes in operating procedures or safety procedures as well.

11.  Incident Investigation

Each incident that resulted in, or could have reasonably resulted in, a significant release of highly hazardous chemicals must be thoroughly investigated to identify the chain of events that led to it. The investigation needs to be held no later than 48 hours from the incident and must include at least one person knowledgeable of the process and any contractors involved.  An investigation report needs to be developed and kept on file for 5 years.

12.  Emergency Planning and Audits

An Emergency Action Plan must be developed for the entire plant in accordance with 29 CFR 1910.138(a).  The plan needs to include procedures for small releases and may need to also follow HAZWOPER (Hazardous Waste Operations and Emergency Response) regulations 29 CFR 1910.120 (a), (p) and (q).

13.  Compliance Audits

Compliance evaluations must be conducted every 3 years to verify PSM practices are adequate and being followed.  A report of these evaluations need to be certified and the most recent 2 reports need to be kept on file.

14.  Trade Secrets

Some companies didn’t want to disclose PSM information to their employees because of trade secret concerns, so OSHA added that they must make compliance, emergency and operational procedures information available anyway, as well as incident information available to investigators.  A company can, however, ask an employee to sign a confidentiality agreement to protect trade information.

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Steve Hieger
Steve Hieger

Contributing:

Steve Hieger

Consulting Services Manager

Steve manages and oversees all of iSi’s environmental, health and safety consultants and provides as-needed technical support for all environmental and safety client projects.  A former plant manager for chemical manufacturing facilities, Steve brings a vast knowledge in process hazard analysis, process safety management, facility safety and environmental issues.  

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OSHA Electronic Injury and Illness Reporting Due March 2

OSHA Electronic Injury and Illness Reporting Due March 2

Feb 23, 2024

OSHA’s final rule on electronic injury and illness reporting that passed in 2023 took effect on January 1, 2024.  The new rule added some new companies and increased some of the reporting requirements.  Electronic reports for 2023 injuries and illnesses are due March 2.   Make sure you know what your company’s responsibilities are – do you need to report electronically?

What’s New in Electronic Reporting Standard

Companies with 20-249 employees whose NAICS codes were listed on Appendix A of the standard were required to submit their 300A electronically.  This did not change, however a new appendix, Appendix B, was created for companies with 100 or more employees.  This requires many more industries to report electronically.  In addition to submitting the 300A, the 100+ employee companies who fall under Appendix B will also now need to submit their 300 and 301 forms.

As with 300A information, data from the 300 and 301 logs will be published on the OSHA website.  Personally identifiable information from the 301, such as fields 1, 2, 6 and 7: employee name, employee address, physician name, and treatment facility name and address will not be collected.

The rules did not change for all companies with 250 or more employees.  All companies, regardless of NAICS code, will need to submit their 300A forms.  Those with 19 or fewer employees will still not be required to report.

Another change includes making inclusion of your company’s legal name required.  Previously, only the Tax Identification number was required.

See Appendix A Here

See Appendix B Here

Industries Moved from Appendix A to Appendix B

Some NAICS codes were moved from Appendix A to Appendix B due to increased fatalities or increases in DART (Days Away; Restricted; Transfer) rates.  Those companies with 20-249 employees who had been submitting only the 300A are now required to submit the 300 and 301.  These include:

  • NAICS 1133-Logging
  • NAICS 1142-Hunting and Trapping
  • NAICS 3379-Other Furniture Related Product Manufacturing
  • NAICS 4239-Miscellaneous Durable Goods Merchant Wholesalers
  • NAICS 4853-Taxi and Limousine Service
  • NAICS 4889-Other Support Activities for Transportation

Why They Are Requiring the 300 and 301 Log for Some Industries?

Besides finding additional industry data on increased injuries, DART rate and fatalities, OSHA’s intent is to collect more accurate and detailed information for injuries and illnesses to help ultimately make workplaces safer.  The detailed information is meant to help make statistics more accurate and to help identify trends that are relevant to industries and types of workers.  The only time OSHA was able to get detailed information was through inspections.  The type of data they will be gathering allows for different kinds of statistical analyses and to help determine where initiatives are successful, are failing, or need to be developed.

OSHA sees gathering 300 and 301 information as a benefit not only to themselves, but by posting it online it can be beneficial information to industries, employers, employees, safety consultants like iSi, and to the general public.

Some examples of this that they used in their final rule document include:

  • 300A information only tells how many of each type of incident on that form are occurring. Now they will be able to see the different kinds of injuries and what they are.  For example, “respiratory conditions” could mean as a result of chemical exposure, COVID, TB, or Legionnaires.
  • Now data can be pulled by roles within any type of company. For example, injuries for nurses aides vs. nurses vs. doctors in medical facilities.
  • The Presidential directive on climate change has OSHA them focused on heat hazards. The new information will help them figure out what kinds of injuries and illnesses are attributed to heat.
  • This will help give employers another resource to consult besides industry groups and insurance to benchmark themselves against others in their industry. For example, the state of Michigan independently researched and found that bath refinishing contractors had 13 deaths in the span of 12 yrs.  From that information, they found it was because of the chemical strippers that were being used. As a result, safety guidance and training was sent to those companies to help improve safety and to alert them of those hazards in order to reduce the deaths.
  • Another employer in New York researched all injuries from their multiple worksites and found that there had been 11,000 lost workdays because of ladders. To reduce those numbers, they increased training in that area, making injuries drop to close to none.  With publicly available information, research like that can be done by multiple parties to help find ways to strengthen workplace safety.

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Which Annual Environmental Training Should You Add to Your Calendar?

Which Annual Environmental Training Should You Add to Your Calendar?

Jan 31, 2024

Recently we covered the required annual OSHA safety training requirements your company should be scheduling each year.  What about the most common annual EPA or environmental training requirements?

RCRA Hazardous Waste

Training is required for anyone handling or managing hazardous waste. For large quantity generators this training is required annually by federal regulations. For conditionally exempt small quantity generators and small quantity generators, annual training is not specified in the federal regulations but is considered a best practice.

Many states have their own hazardous waste regulations which can vary from the federal version and even be stricter, so be aware of the regulations for your area. For example, in Kansas, small quantity generators are specifically required to have annual training.

Stormwater Pollution Prevention Plan (SWP3)

Training is required annually for any facility required to have a Stormwater Pollution Prevention Plan, and in some locations, additional training may also be required. iSi did a stormwater training project for a client who had facilities in 48 states, and one of the modules we produced had a clickable state map where the learner could go learn about the rules for their state.   In our research, we found stormwater rules can vary greatly from state to state, and in some cases, from municipality to municipality.  State general permits have expiration dates on them and will be updated when the new one is issued, so check with your state’s environmental agency and find their general permit to see what the rules are.

[Don’t have time to look it up?  Contact us and we can get you pricing to have one of our environmental team members look up the most recent permit for your state(s) and determine what your requirements are, and what your training needs to cover.  (We can do the training too or make the slides for you if you need it.)]

Spill Prevention, Control and Countermeasures (SPCC)

Any company required to have an SPCC Plan must conduct training annually.  SPCC Plans ensure facilities have containment and other countermeasures in place to prevent oil spills from reaching navigable waters. Annual training is required for oil-handling personnel to ensure the prevention measures and procedures are in place, understood and followed.  This training should include the procedures and policies written in your SPCC plan.

Facility Response Plan (FRP)

FRPs are plans regarding oil spill responses after the spills occur. For those who are required to have FRPs in accordance with 40 CFR Part 112, there is training required as well as hands-on exercises. The National Preparedness for Response Exercise Program (PREP) is to be used for the hands-on portion and the U.S. Coast Guard’s Training Elements for Oil Spill Response can be used for the classroom training.

Qualified individual and emergency procedures exercises must be conducted quarterly, equipment deployment exercises must be conducted semiannually, and incident management team tabletop exercises must be conducted annually. There are additional requirements for unannounced and after business hour training.

This is different from HAZWOPER, which is an OSHA requirement, but you could incorporate some of the exercises as part of your annual HAZWOPER training.

Asbestos

Those certified as asbestos workers, contractor/supervisors, inspectors, planners and project designers are required to complete annual refresher training.

On the OSHA side, maintenance personnel who may disturb asbestos within the course of their duties are required to have annual awareness training. Although EPA addresses awareness training for these workers, it’s OSHA that requires the training annually.

Others Worth Mentioning

TSDF facility personnel must have RCRA emergency response training, and that training can be HAZWOPER if it meets the RCRA requirements. HAZWOPER refresher training is due annually.

There are other annual environmental training requirements for industrial processes which are not as widespread including municipal solid waste combustors, medical waste incinerators, and underground hazardous waste injection wells. Much of this training is also conducted by EPA or state-approved training providers.

Others Required, but Not Annually:

  • NESHAP Subpart HHHHH (6H) for Paint Stripping and Surface Coating Operations:  Every 5 years
  • Risk Management Plans: Every 3 years
  • Pesticides: Every 5 years
  • Lead-Based Paint (Lead Renovation, Repair and Painting Rule (RRP)): Every 3-5 years depending on the initial test you took
  • DOT (for hazardous waste manifest signing): Every 3 years
  • IATA (for air shipments of hazardous materials): Every 2 years
  • IMDG (for vessel shipments of hazardous materials): Every 3 years

Annual OSHA Safety Training

If you missed our blog on annual OSHA safety training needed, you can find that here.

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Which Annual Safety Training Requirements Should You Add to Your Calendar?

Which Annual Safety Training Requirements Should You Add to Your Calendar?

Jan 25, 2024

photo depicting annual OSHA safety training requirements for industry and constuction

Annual safety training is a best management practice and is most often required when conditions in the workplace change. However, the OSHA standards don’t specifically require annual safety training for all of its topic areas, just a handful of them.

Employee Access to Medical Records

This is one of the most overlooked requirements and one of the top items which pops up in our safety compliance audits. Annual notification for employee access to medical records is required. As a company you’re required to inform workers of their rights to access their medical records, where they’re kept, how to obtain them and who is responsible for keeping them.  This applies to both general industry and construction – the construction standard references the general industry standard, 1910.1020.

Respiratory Protection and Fit-Testing

Employees wearing respirators or participating in your company’s respiratory protection program are required to receive annual training regarding respirator use, care, inspection, maintenance, limitations and other requirements. In addition, employees must be fit-tested in their respirator annually. That is, each employee should be tested to ensure the seal is still fitting their face and protecting them. There are standard fit-testing procedures to use to accomplish this item.  This applies to both general industry and construction and the construction standard references general industry standard 1910.134.

Hearing Protection

If your employees are exposed to noise at or above an 8-hour time weighted average of 85 decibels, your company is required to have a hearing conservation program. As part of this program, annual training is required. Ensure you post a copy of the occupational noise exposure standard in your workplace and make any and all training materials related to this available to your employees.  Hearing conservation programs are required by both general industry and construction.

HAZWOPER

Employees responding to hazardous materials spills, conducting hazardous substance removals, or working at Resource Conservation and Recovery Act (RCRA) corrective action or treatment, storage, and disposal facility (TSDF) facilities are required to have hazardous waste operations and emergency response (HAZWOPER) training. There are various levels of HAZWOPER. Those with 24 and 40 hour initial training are required to have 8 hours of training annually per year.  Annual training requirements for HAZWOPER can be found in 1919.120 for general industry and 1926.65 for construction.

Bloodborne Pathogens

Anyone with potential bloodborne pathogen exposure potential in general industry must have annual training and additional training whenever procedures and tasks are changed.  Those who conduct first aid in construction are required to have training in hazards associated with bloodborne pathogens, as well as employees conducting maintenance activities, those collecting or separating wastes (sharps), or who could be exposed to blood or other potentially infections material as part of their job. 

Fire Extinguishers and Fire Brigades

If your company provides portable fire extinguishers or other fire-fighting devices for designated employees to use in the workplace, training is required annually. For employees designated to inspect, maintain, operate or repair fixed fire extinguishing systems, annual training reviews are required.   Fire fighters in shipyard operations are required to have semi-annual drills and annual training for fire watchers.

If your company houses an internal fire brigade that fight fires beyond the incipient stage, all fire brigade members are to be provided with annual training. Any members who are required to conduct internal structural firefighting are to have quarterly educational sessions or training as well.

Fire protection programs must be developed for all phases of construction and demolition jobs and, as a result, employers shall provide firefighting equipment and a trained and equipped fire fighting organization (fire brigade/group of employees that are knowledgeable, trained and skilled in the safe evacuation of employees during emergency situations and in assisting in fire fighting operations).

Confined Space Rescuers

Those who conduct confined space rescue are supposed to hold practice drills once per year.  This applies to both general industry and construction.

Asbestos and Other Chemical and Substance-Specific Training

Anyone exposed to asbestos at or above permissible exposure limits are required to have annual asbestos awareness training. Maintenance personnel who may disturb asbestos within the course of their duties are also required to have annual awareness training.  Those who conduct Class I through IV asbestos operations (removal activities) are also required to have annual training through the construction standards.

Employees with potential exposures to OSHA 1910.1003’s 13 carcinogens, vinyl chloride, polyvinyl chloride, inorganic arsenic, lead, cadmium, benzene, coke oven emissions, cotton dust, acrylonitrile (vinyl cyanide), ethylene oxide, formaldehyde, Methylenedianiline (MDA) and 1, 3-Butadiene are required to have annual safe usage training.  Many of these are referenced individually in both the general industry and construction standards, but the construction standards will often reference the general industry standard rather than having separate rules.  Construction has specific rules for cadmium, chromium, ethylene oxide, lead and MDA.

Others Worth Mentioning

Mechanical Power Presses – Operators of mechanical power presses with the Presence Sensing Device Initiation (PSDI) mode on them are required to have annual operator training.

Agriculture Industry – In grain handling facilities annual training is required for workers at grain handling facilities. Topics to be covered include dust hazards, dust accumulation, ignition control and prevention, cleaning/clearing/housekeeping procedures, hot work procedures, preventative maintenance, lockout/tagout and bin entry and engulfment hazards (for those entering bins). In other agriculture-related workplaces where employees are required to use tractors, annual training regarding rollover protective structures is required and those using farm field equipment, farmstead equipment and cotton gins are required to have safe operating and guarding training annually.

Logging Industry – Supervisors and employees in logging industry operation are required to have annual CPR training, with first aid training every 3 years.

Every 3 years – Because of their prevalence in industry, we thought we’d also mention that forklift recertifications are due every 3 years as is refresher training for Process Safety Management.

Lockout/Tagout – Not necessarily a training requirement, but an annual requirement nonetheless, employers are required to review their energy control procedures at least annually to ensure the procedure and the requirements of the lockout/tagout standard is being followed.

Environmental Training

Looking for annual EPA and environmental training?  In addition to annual safety training, check out our article regarding annual environmental training requirements your company should schedule for the year.

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Environmental Training

Now that you’ve learned what safety training is required annually, learn more about what environmental training is required annually.

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State, Regional and National Safety and Environmental Conferences for 2024

State, Regional and National Safety and Environmental Conferences for 2024

Jan 22, 2024

We exhibit and speak at many different safety and environmental conferences throughout the region.  What’s the schedule look like for 2024?

Here is a list of some upcoming state, regional and national safety and environmental conferences that you may want to add to your calendar.  (For now, we’re listing the ones near where we have offices. )

We will work to keep this list updated as we find out changes, if any.

Central U.S. / Region VII

 

Region VII (KS, MO, IA, NE)

Midwest Environmental Compliance Conference (MECC)
Sept. 24-25 | Overland Park | In-Person and Online | Learn More

Region VII VPPPA Midwest Safety and Health Conference
TBD | Des Moines | Learn More

Kansas

KDHE Environmental Conference
Aug. 7-8 | Wichita | In-Person | Learn More

Kansas Safety and Health Conference
Oct. 1-2 | Wichita | In-Person| Learn More

Missouri

Mid-America Safety, Health & Environmental Conference and Expo
TBD | Springfield | In-Person | Learn More

Greater St. Louis Safety & Health Conference
Oct. 1 | St. Louis | In-Person | Learn More

Missouri Hazardous Waste Seminar
April 30 | Online | Learn More

Safety & Health Council of Western Missouri & Kansas SAFECONEXPO
May 14-16 | Lake Ozarks, MO | In-Person | Learn More

Nebraska

Nebraska Safety & Health Summit
Oct. 14  | Omaha | In-Person | Learn More

Iowa

Hawkeye on Safety
Sept. 5 | Coralville | In-Person | Learn More

Iowa Governor’s Safety & Health Conference
Oct. 29-30  | Des Moines | Altoona | Learn More

Central U.S. / Region VI

 

Region VI (OK, TX, NM, LA, AR)

Region VI VPPPA
April 30 – May 2 | Oklahoma City, OK | In-Person | Learn More

Oklahoma

Oklahoma Safety and Health Conference
July 24-26 | Norman | In-Person | Learn More

Environmental Federation of Oklahoma (EFO) Annual Meeting & Trade Show
Oct. 14-17 | Midwest City | In-Person | Learn More

Southeast / Region IV 

 

Region IV (GA, AL, MS, KY, TN, NC, SC, FL)

Region IV VPPA Safety + Symposium
Aug. 25-28 ​ | Aurora, CO | In-Person | Learn More

Georgia

Georgia Environmental Conference
Aug. 21-23 | Jekyll Island | In-Person | Learn More

Georgia Safety, Health and Environmental Conference
Sept. 4-6 | Savannah | In-Person | Learn More 

Tennessee

Chattanooga Regional Manufacturers’ Association Environmental, Health and Safety Summit
TBD | Chattanooga | In-Person | Learn More 

Tennessee Environmental Network Show of the South
May 15-17 | Chattanooga | In-Person | Learn More 

Alabama

Alabama Governor’s Safety and Health Conference
Aug. 26-28 | Orange Beach | In-Person | Learn More

Manufacture Alabama HR, Safety & Environmental Conference
TBD | Birmingham | Learn More

North Carolina

NC Statewide Safety Conference
TBD | Learn More

Carolina Star Safety Conference
Sept. 18-20 | Greensboro | In-Person | Learn More

Eastern Carolina Safety & Health Conference
Apr. 10-12 | Atlantic Beach | Learn More

South Carolina

South Carolina Environmental Conference
Mar. 10-13 | Myrtle Beach | In-Person | Learn More

ASSP Region VI Conference
Sept. 18-20 | Virginia Beach | In-Person and Online | Learn More

NSC Southeast Regional Conference & Expo
May 14-16 | Rosemont, IL | Learn More

National Conferences


American Industrial Hygiene Conference and Expo (AIHCE) EXP 2023 
May 20-22 | Columbus, OH | Learn More 

American Society of Safety Professionals (ASSP) Conference and Expo
Aug. 7-9  | Denver, CO | In-Person and Online | Learn More

National Safety Council (NSC) Safety Congress
 Sept. 13-19 | Orlando, FL | In-Person| Learn More

Associated General Contractors (AGC) Construction Safety, Health & Environmental Conference
July 16-18 | St. Louis, MO |  In-Person | Learn More

Associated General Contractors (AGC) Construction Safety & Health Conference
Jan. 10-12  | Newport Beach, CA |  In-Person | Learn More

Alliance of Hazardous Materials Professionals (AHMP) National Conference
July 14-17 | Kansas City, MO | Learn More

National Association of Environmental Professionals (NAEP) Annual Conference and Training Symposium
May 5-8 | Minneapolis, MN | Learn More

National Environmental Health Association (NEHA) Annual Education Conference & Exhibition
TBD | Spokane |  In-Person and Virtual | Learn More

Which safety and environmental conferences did we miss?  Let us know by emailing us here.

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Back to Work Safety Mindfulness

Back to Work Safety Mindfulness

Jan 8, 2024

After being off for the holidays or any time of vacation, sometimes it’s hard to get back into the groove of working.  This is a time where it’s easy to not be as mindful about safety as we usually are.

Workplace accidents tend to be higher after people come back from an extended break, whether it be the holidays or a vacation. As a result, we need to be extra mindful about a safety focus when we come back.

Here are some tips to help get back in a safety mindset:

  • Review Job Safety/Job Hazard Analyses—What are the correct safety procedures and PPE required to do the job safely?
  • Take a look around—is the jobsite safe? Have there been changes?  Are there safeguards missing?
  • Don’t take shortcuts
  • As you go about your work, take extra time and effort throughout the days to stop and focus on safety hazards in front of you. Take a few seconds to look around and survey the area to see if there are hazards that can hurt you or co-workers.
  • The first of the year is a good time to stop and do some safety reviews to easily jog memories and get back into the right mindset. This also will allow workers the opportunity to ease back into the routine.
  • Start off the year by taking stock and inventory of tools and equipment. Do inspections to make sure they’re in good condition and functioning correctly.
  • Do your eyewash stations and emergency decon stations work correctly?
  • Do first aid kits need restocking?
  • Does signage need to be replaced?
  • Are labels intact and legible?
  • Do fire extinguishers need recharging?
  • How does housekeeping look? Do we need to clean up and clean out work areas?
  • What are your safety goals for the year? What do we want them to be?
  • Make sure you are getting good rest, nutrition, hydration and exercise. Sometimes the holidays can take a lot out of us and break our routine and this will help us get back to “normal.”
  • Return to a normal home routine as well. If operations are normal at home, they’re more likely to become normal at work.
  • Before you get to work, clear your head of lingering issues and put those away for after work.
  • Look out for each other. Be mindful that others may be distracted and unfocused too.
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Christmas Safety

Christmas Safety

Dec 19, 2023

new years party safety
Christmas can be a wonderful time of the year, but it can also be a time for accidents.
  • Keep Real Trees Watered: The combination of shorts in electrical lights and a tinder-dry tree can be deadly. Keep your tree well-watered. Water levels should never get below the base of the tree. Unplug lights before watering.
  • Sockets and Outlets: Water and debris can get into outdoor sockets, so make sure outdoor lights are plugged into a ground fault circuit interrupter outlet to reduce the risk of shorts and shocks. Hire a licensed electrician if you need to install GFCI outlets. Make sure you only use one plug per outlet and do not exceed the wattage rating for the outlet.
  • Extension Cords: Keep an eye on extension cords, as they can occasionally overheat. Just touch-test the cord. If it’s hot, unplug it. When running extension cords along the ground, make sure to elevate plugs and connectors with a brick to keep snow, water and debris out of the connections.
  • Turn Christmas Lights Off: Don’t leave Christmas lights running when you go to bed at night or when you leave the house.
  • Keep an Eye on Candles: Make sure you don’t leave your candles unattended, or burn them close to other decorations. Consider using the battery-powered ones.
  • Walkways: Keep on top of removing wrapping paper, toys, boxes and other debris from walkways.
  • Scissors and Knives: Some gifts that come in plastic clam shells, Aunt Tami’s overzealous tape jobs, and others with plastic fasteners may require a knife or a pair of scissors. Make sure to use knife safety principles and don’t let children use them.
  • Lights on for Guests: If you have overnight guests, keep a light on in hallways to allow them to navigate to the bathroom without tripping.
  • Fireplaces: Keep trees, wreaths, greeting cards, and the wrapping paper away from and out of the fireplace as they can quickly ignite. Use a screen to contain any flying sparks.  Make sure your chimney has been swept if you haven’t used it in a while.
  • Batteries: Take all batteries out of decorations before storing them. Have some spare batteries available for electronics. Don’t leave batteries sitting on the mantle, by the fireplace or near stoves or open flames.  The heat can spark them or make them explode.
  • Food: Don’t leave food out on buffets for hours on end, no one wants food poisoning as a party favor. Cover and refrigerate anything that could spoil within an hour. Keep kids and pets out of the kitchen when cooking (hot stoves, knives, trip hazard potential). Make sure you take allergies and dietary restrictions into account.
  • Alcohol: Try to keep track of what you take in and make sure you count any puddings or foods that contain alcohol into your calculations.  If you have multiple events to attend, try to give your liver a day’s break between them.
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Be Safe When Ringing in the New Year

Be Safe When Ringing in the New Year

Dec 19, 2023

Regardless of whether you’re going out, or staying in for New Years celebrations, safety should always be top of mind. New Year’s Eve is actually one of the more dangerous holidays for car accidents. Here are a few tips to share about being safe when ringing in the new year:
  1. Drink responsibly — This can be whether you decide to go out, or even if you choose to stay home. Alcohol and safety don’t always go hand-in-hand. Pace yourself, and if you’re away from home, make sure you have a designated driver. If you’re the host, make sure those who are buzzed don’t get behind the wheel of a car. In some states, you can be held responsible for people who leave your party and cause damage.
  2. If you’re the host, serve plenty of food. Not only will it keep guests happy, it’ll counter the effects of alcohol. If you’re going to a party and don’t plan to eat, make sure you do so before you leave.
  3. Avoid loud music where guests will have to shout.
  4. If you do have guests, avoid accidental sharing of glasses by making sure everyone’s glass or champagne flute looks different. Use wine glass markers, colored glasses, or look into single serving wines or cans of bubbly.
  5. No guns or fireworks — Shooting guns into the air is dangerous because the bullets will land somewhere and they could seriously hurt. Fireworks can be dangerous and may break local laws and noise ordinances. Stick to sparklers and noise makers.
  6. Keep pets and children away from lit candles and fireplaces. Also, keep matches and lighters in a locked cabinet out of reach of children.
  7. Do not leave food unattended in the kitchen when you are cooking, this is especially true when frying and boiling items on the stovetop. Keep children and pets away from cooking surfaces and hot pans and dishes.
  8. Be mindful of your car. New Year’s Day is a top holiday for car thefts! If you’ll be away, don’t leave your car overnight, leave it at home if you won’t be driving home. Keep it in the driveway, and keep it locked.
  9. Stay alert when walking and stay off your phone when walking. Did you know that New Year’s Day is the most dangerous day for pedestrians? Do not ignore traffic lights or crosswalks and be on the lookout for impaired drivers.  The most dangerous time is 1-3 am.
  10. And when it comes time for the New Year’s kiss, with COVID and the hacking cough lurking around, stick to kissing someone familiar, or at least someone who won’t get you a black eye afterward.

 

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Inspection Data Shows Common Hazardous Waste Violations

Inspection Data Shows Common Hazardous Waste Violations

Nov 28, 2023

We decided to take a look at some of the EPA enforcement sites to review hazardous waste violations issued across the U.S. within the past couple of years.  We wanted to see if there were some common themes that readers should be on the lookout for because sometimes the best lessons can be learned from the experience of others.  We chose, at random, sites from all across the U.S. and looked at the federal citations (not state citations) noted.  

Here are some of the most common items we found.  How well is your company managing these items?

Container and Labeling Issues 

The top 2 areas that kept coming up, maybe because they could be considered low hanging fruit, were related to container management and labeling.  

Container issues included:

  • Keeping containers closed
  • Keeping containers in the waste storage area past the required time limit per generator status
  • Keeping incompatible wastes separated during accumulation
  • Not enough aisle space between drums
  • Container condition issues such as cuts and dents
  • Not having proper spill and leak prevention and cleanup supplies
  • Not immediately cleaning up spills and leaks

Labeling issues were basically incorrect labels to not having any labels at all.  Improper labeling examples included not marking drums as “Hazardous Waste” or not marking used oil storage containers as “Used Oil.”  This was not limited to just hazardous waste, but also included not marking universal wastes what they were, such as spent bulbs.  There were also several instances of containers not having the accumulation start dates marked on them.

Inspections

One of the next most popular items cited was hazardous waste inspections.  Companies either didn’t do them at all, did not document them, or did not do them adequately.  

Make sure this is something you are doing and documenting.  Make sure your inspectors are just not going through the motions and checking the same boxes.  Are the items considered out of compliance showing up on the checklist each week?  If so, why aren’t they being addressed?  If you find items out of compliance, were they noted on the last inspection and why or why not?

Training

Many companies were cited for not providing training or not providing it annually, where applicable.  Different levels of generators have different training requirements depending on federal regulations and specific state regulations, however, it was one of the areas most cited. 

In one instance, a company was fined for not having job titles and job descriptions for each position in the facility related to hazardous waste management.  This is a requirement for large quantity generators on a federal level (and may be an additional state requirement depending on which state you’re in). We have seen job titles and descriptions asked for in DOT hazmat inspections as well.  This is to help inspectors determine who at the facility needs to have training. Then once they know who needs training they will ask for employee start dates to determine timeframes so they can calculate when initial and refresher trainings should have been conducted.

Waste Determinations

Several companies were fined for not conducting waste determinations.  This is one of the first things you need to be doing so that you know the hazards of the waste you’re storing and how you will need to properly manage it.

Contingency Plans

A number of companies had contingency plan issues.  Some of these included:

  • Not having a contingency plan when required to
  • Not describing what the company’s response would be to fires and explosions in the plan
  • Not including an evacuation plan
  • Not listing emergency equipment capabilities in the plan

Tanks and Air Emissions 

Many tank-related issues were cited, but not only about the tanks themselves, but the air emissions issues related to tanks.  In a previous blog, we wrote about how there are air emissions regulations written into the hazardous waste regulations.  Subparts BB and CC of the RCRA air regulations pertain to tanks.   EPA’s 2021 compliance initiatives included a statement that said a number of facilities were not complying with RCRA air requirements and as a result, inspectors were being directed to look at these items in inspections. Some of the air-related violations included:

  • Failing to comply with emissions control standards for tanks
  • Failing to comply with regulations regarding leaks such as marking equipment subject to Subpart BB air emissions standards
  • Not developing a monitoring plan for valves that are difficult or unsafe to monitor
  • No calibration testing
  • Not passing the required leak test requirements and not having records showing passing scores every 30 days for the past 12 months
  • Not doing required monthly monitoring

Some examples of the tanks-only (not related to air) violations included:

  • Storing hazardous waste in a tank for more than 90 days
  • Not doing daily inspections
  • Not having hazardous waste tank inspection records
  • Not doing periodic testing and monitoring of spill prevention equipment or containment sumps
  • Not having a qualified engineer assess the integrity of an existing tank used to store hazardous waste
  • Not conducting annual line tightness testing for underground storage tanks

Other Items

There were a number of other items cited that appeared less often, but are still worth mentioning.  They include:

  • Storing hazardous waste without a permit or without notifying the local authority that they had hazardous waste onsite
  • Not following the conditions of their hazardous waste permit
  • Not complying with manifest requirements and not completing them correctly
  • Not following hazardous waste transportation regulations or following regulations for proper disposal
  • Not meeting land disposal requirements
  • Not submitting biennial reports

Conclusion

With the majority of the cases, more than one item was cited.  Some of the fines for single violations fell within the $5,000 area while most with multiple citations were $50,000-$100,000.  Some companies were allowed to pay about half in fines and then spend the other half to do supplemental purchases of emergency response equipment for their local fire departments.  That was used in a few instances, especially in the central states.

Does your facility have any of these issues?  Do you need help with a contingency plan? Do you need to get caught up on your worker training?  Do you need someone to come evaluate your entire program to see where your gaps are?  iSi can help with all things hazardous waste.  Contact us today with any questions or for some pricing for us to lend you a hand.

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Thanksgiving Safety Tips to Share With Your Employees, Family and Friends

Thanksgiving Safety Tips to Share With Your Employees, Family and Friends

Nov 16, 2023

As a safety consultant, we make sure that our teams know about safety in all aspects of their life, not just the OSHA kind at work.   Safety at home is just as important as safety at work.  Below are some tips for Thanksgiving Safety, including a link to download a PDF copy to share with your own team.

The Food

  • Keep your food preparation surfaces and utensils clean and sanitized to reduce the risk of salmonella. Keep your cutting boards separate: one for meats and one for cooked foods, vegetables and fruits. Sanitize cutting boards after each use.
  • Thaw your frozen turkey safely in the refrigerator by allowing 3-4 days or approximately 1 day per every 5 pounds. Another way to safely thaw a frozen turkey is submerging it in cold water. Replace the water every 30 minutes until the turkey is thawed. This method takes approximately 30 minutes for each pound the turkey weighs. Once it’s thawed, make sure it’s cooked within 2 days of thawing. Small turkeys can be defrosted in the microwave, but they’ll need to be immediately cooked.
  • If you cook your stuffing inside the turkey, stuff it just before roasting.
  • Always use a meat thermometer to see if the turkey is completely cooked. The temperature needs to reach 165° F when inserted in the thickest area of the thigh.
  • Refrigerate all leftovers within 2 hours after cooking. Leftovers should be eaten within 3-4 days. If you are going to freeze leftovers, do that right away.

Cooking and the Kitchen

  • Stay in the kitchen when you are cooking on the stovetop so you can keep an eye on the food, and be in the home when cooking your turkey – check on it frequently.
  • Keep children 3 ft. away from a hot stove. Steam or splash from vegetables, gravy or coffee could cause serious burns.
  • Keep the floor clear so you don’t trip over kids, pets, bags or other items.
  • Be sure electric cords from a coffee makers, plate warmers, mixers and electric knives are not dangling off the counter that could easily be bumped, or come within easy reach of a child.
  • Follow all instructions carefully when using a deep fryer and monitor closely! Do not use indoors, in garages or on decks and never leave it unattended.
  • Never wear loose fitting clothing such as long open sleeves that can catch fire from a gas flame.
  • Keep baking soda on hand to put out kitchen fires.
  • Do not leave food cooking or the stove unsupervised.
  • Keep a household fire extinguisher nearby.

Pets

  • While your family enjoys a special meal, give your cat and dog a small feast of their own. Offer them made-for-pets chew bones. Or stuff their usual dinner—perhaps with a few added tidbits of turkey, vegetables (try sweet potato or green beans) and dribbles of gravy—inside a food puzzle toy. They’ll be happily occupied for awhile, working hard to extract their dinner from the toy.
  • A few small boneless pieces of cooked turkey, a taste of mashed potato or even a lick of
    pumpkin pie shouldn’t pose a problem. However, don’t allow your pets to overindulge, as they could wind up with a case of stomach upset, diarrhea or even worse — an inflammatory condition called pancreatitis.
  • Never give your pets turkey bones.
  • Do not give your pets stuffing since herbs, such as sage, even in small amounts can cause an upset stomach and
    gastrointestinal problems.
  • Never give your pet raw bread dough. When a dog or cat ingests raw bread dough, the yeast continues to convert the sugars in the dough to carbon dioxide gas and alcohol. This can result in bloated drunken pets, which could become a
    life-threatening emergency, requiring hospitalization.
  • If you plan to bake Thanksgiving desserts, be sure your pets keep their noses out of the batter, especially if it includes raw eggs—they could contain salmonella bacteria that may lead to food poisoning.

Have a great and SAFE Thanksgiving holiday from all of us at iSi!

 

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Are You Required to Have IMDG Training?

Are You Required to Have IMDG Training?

Oct 27, 2023

Recently one of our clients had a shipment of their product rejected at a port in Europe.  They had been sending it there for years without incident, but this time was different.  Inspectors chose to verify their paperwork and they were missing crucial IMDG dangerous goods paperwork.  All methods of hazardous materials transportation have specific training requirements, but the one which often catches people by surprise is IMDG.

If you ship hazardous materials by vessel or over water, you are required to follow the rules of the International Maritime Dangerous Goods (IMDG) code.  This includes companies who are:

  • Loading shipping containers onsite;
  • Using third-party companies to load shipping containers for them onsite; and,
  • Sending hazardous materials to freight forwarders or third-parties to be loaded somewhere else.

You May Qualify Without Knowing It

Shipping containers are used for overseas transport, but also keep in mind they are used to transport products to U.S. states such as Hawaii and Alaska as well as U.S. territories.  For example, a different client of ours was responsible for gathering together all the products needed for opening a new Wal-Mart store, and some of those were hazardous materials.  When there were new Wal-Marts to open in Alaska and Hawaii, those products needed to be loaded into shipping containers.  As a result, that company became subject to the rules of IMDG.

Keep in mind that even small quantities can trigger requirements.  For example, we have clients who send vehicles and farm implements via vessel.  Along with the vehicles are boxes of oils and lubricants for operation once they are unpacked.  This triggers hazardous materials regulations.  Even residual fluids left over in the engines that got there when the factory tested it to make sure it worked triggers hazardous materials regulations.

Just like in DOT regulations for ground shipments and IATA regulations for air shipments, goods loaded into the containers must be packaged in certified packages that have design qualification reports for them.  Special IMDG dangerous goods paperwork called a Dangerous Goods Transport Document is also needed to accompany the shipment and all packages and the container need to be labeled and placarded accordingly. 

Even if you use a third-party to handle this for you, it’s still your company’s responsibility to make sure they are complying with the rules as you are the shipper and it’s your company who will be dealing with the regulators and with potentially unhappy customers the further the goods are delayed.

Training Requirements

If IMDG applies to your operations, the following personnel need to have training upon employment or assignment to hazardous materials duties:

Anyone who…

  • Classifies and/or identifies the proper shipping names of dangerous goods (hazardous materials);
  • Packs dangerous goods;
  • Marks, labels or placards dangerous goods;
  • Load/unload dangerous goods;
  • Prepare transportation documents;
  • Offers or accepts dangerous goods for transport;
  • Handles, loads or unloads dangerous goods into or from ships;
  • Prepares dangerous goods loading/stowage plans;
  • Carries dangerous goods in transport;
  • Enforces, surveys or inspects dangerous goods for compliance; and is,
  • Otherwise involved as determined by a competent authority.

As with other hazardous materials training, students are required to have general awareness, safety, and function-specific training.  Refreshers are required every 3 years.

Does this requirement apply to your company?  iSi has regularly scheduled IMDG courses and can provide them onsite on your own schedule, at your own convenience.  Check here for our course schedule or contact us here for more information and pricing for an onsite class at your facility!

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Safety Boots: What You Need To Know

Safety Boots: What You Need To Know

Oct 20, 2023

Many types of jobs require the use of boots for safety purposes.  Some jobs just need regular boots while others require steel or composite toes.

Toe Composition

Steel toe boots have a steel cap over the toe to prevent your feet from being crushed by objects falling on them or rolling over them.  Composite toe boots can have toes made of Kevlar, carbon fiber, fiberglass or carbon nanocomposites (composite cylinders arranged in beehive pattern mixed with fiber resin).  Composite toes don’t conduct heat, cold, nor electricity, and are thicker but lighter weight than a steel toed boot.  They are not as impact-resistant. There are also alloy toe boots such as aluminum or titanium.  These are a little less protective but lighter weight than steel toe boots.  They can be a little more expensive as well.

Best Practices

  • Always buy boots that meet ASTM standards for impact and compression and always buy the types of boots your company recommends or requires. Your company has conducted formal PPE assessments to determine the safest types of boots for the work you do.
  • Always wear the proper socks. Moisture wicking socks are better than cotton socks because cotton socks will tend to create moisture  leading to uncomfortableness, foot pain and faster damage to the inside of your boots.
  • Keep the insides of your boots dry and maintain the waterproofing on the outsides of them.
  • Remove mud, dirt, clay, and gunk—they’ll dry out the leather.
  • You can increase the life span of your boots by using premade orthotic insoles.

Checking the Wear

Worn out boots not only are uncomfortable, but they are unsafe.  Not replacing them when they’re worn out can cause foot/back/leg pain, foot stress and ingrown toenails and can increase your chances of falling, especially in slippery environments. Check for wear by looking at:

  • Soles, outsides of the heels, and balls of the shoe for wear. Are soles separating?  Sole separation can cause instability, reduce shock absorption and let moisture or chemicals in.
  • Tears, holes, cracks and external damage—Damage like this can make them less electrical and chemical resistant and more susceptible to foot punctures
  • Internal damage-Look at the inside, the tongue and look for the stitching. Torn insulation can let in moisture and chemicals. The instep shouldn’t be bunching up.

Finding and Trying on Boots

  • Wear the socks you’ll be wearing with the boots when you try them on
  • Your heel shouldn’t come up out of the boot or rub on the back. It shouldn’t move more than a quarter of an inch. As leather conforms to your foot, it will mold to your heel and slight slippage will reduce.
  • You should have an inch of room in your toes but your toes shouldn’t slide forward when you walk.
  • The boot should be secure on the sides and top of your foot but not be painful.
  • Make sure the inner stitching nor the tongue rub on your foot.
  • When trying them on put them through their paces because you want to make sure they’re right for you: walk, run, hop, do knee raises, stand in place, flex your foot, and carefully roll your ankles and stand on the sides of your foot to test ankle support. If you have red spots on your feet after trying them on, those are the places where the shoe will rub.
  • Always try on boots on both of your feet. Your feet change sizes throughout the day, so try boots on in the afternoon when your feet tend to be bigger.
  • If your feet are two different sizes, purchase the boot to fit your larger foot and wear a heel insert for your smaller foot.
  • If you have flat feet, taller boots with stronger insoles may fit better.
  • Boot companies traditionally have you order 1/2 size smaller than your sneaker size. For steel toe boots, you may need to order the same size as your sneaker size, or even a 1/2 size larger than your normal shoe size. If you wear thick socks, the larger boot sizes will be needed to accommodate those.

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The One Where You Must Post the Whole Standard

The One Where You Must Post the Whole Standard

Oct 13, 2023

iSi’s consulting team recently provided a presentation to the annual Kansas Safety and Health Conference about OSHA’s top poorly written regulations.  We gave the audience a chance to vote at the end and one of the top vote getters was found in standard 1910.95.  This is the occupational noise exposure standard.  More specifically, 1910.95(l)(1).

A Unique Requirement

The noise exposure standard aims to protect workers against the effects of noise exposure when sound levels exceed a certain scale pictured in the standard.  This is also where instructions on the rules for and how to develop a Hearing Conservation Program can be found.  Section K of the standard discusses the importance of training, what topics need to be covered, and the requirement that the training be repeated annually.

In the next section we find something very unique.  Section L covers access to information and training materials.  The very first requirement states “The employer shall make available to affected employees or their representatives copies of this standard and shall also post a copy in the workplace.”  What??  A copy of the standard?  Post a copy of the entire standard?

Yes, it means what it says.  This is the only standard OSHA has that requires you to take a copy of the standard and post it.  OSHA feels it’s important that in addition to training, employees have the chance to read the standard on their own without having to ask for it.  It must be centrally posted and at no charge.

Updates to the Rule

This rule was written in 1983 and has not been updated since then.  OSHA held firm on its stance in an interpretation letter written in 1988 from someone questioning posting the whole thing, but in 2016 OSHA decided to become a little more user friendly.  In 2016 someone sent OSHA a letter requesting electronic posting.  OSHA’s answer said they realized the internet was not around in the 80s, and thus, declared that with this letter, they were updating the policy to allow for electronic posting, but only under these certain conditions:

  • Your Hearing Conservation training program covers specific information to your employees on where and how to access the entire standard electronically;
  • The link you provide to employees does not go to a generic web page such as to your company’s website, a folder on your intranet or Sharepoint, or the home page for OSHA. It must go to the exact standard located here; and,
  • Computers must be located in all affected employees’ work areas so that they can have access to the standard at any time without having to request access to a computer or without having to ask for assistance on where to find it electronically.

Citations

It may be low risk that you’ll get fined for just this item unless the inspector has a special place in their heart for this standard.  However, it IS likely that it becomes an easy tack-on citation along with other citations of the noise exposure standard.

For example, in the state of Tennessee, this item is one of the most often items cited for this standard, but so are:

  • Lack of training or lack of training program;
  • Did not administer a continuing hearing conservation program when workplace noise levels indicated it was required;
  • Lack of a monitoring program when information indicated the exposure levels may equal or exceed the limits;
  • No audiometric testing program or audiometric testing;
  • Did not establish a baseline audiogram within 6 months of an employee’s first exposure at or above the action level; and
  • Not giving employees the opportunity to select their hearing protectors from a variety of suitable hearing protectors provided by the employer.

Where Do You Stand on Noise?

When was the last time you had your workplace AND your workers tested for noise exposure?  iSi conducts noise sampling, helps write programs, provides training and much more assistance for noise exposure issues.  Contact us today!

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What’s the Difference Between OSHA’s General Industry and Construction Standards on Asbestos?

What’s the Difference Between OSHA’s General Industry and Construction Standards on Asbestos?

Sep 22, 2023

With so many entities regulating asbestos – EPA to OSHA to State Governments to even City and County Governments – we see a lot of confusion.  These regulations cross over and intertwine with each other and it’s sometimes difficult to remember which rule is required by which agency.  In this article, we will tackle OSHA’s side.

OSHA has two separate regulations regarding asbestos.  The General Industry Standard is at 29 CFR 1910.1001 and the Construction Standard is at 29 CFR 1926.1101. Unlike other regulations that are shared between 1910 and 1926, these are NOT a carbon copy of each other.

Which One is For You?  Well….It Depends.

In many standards, a company follows either the standard in 1910 or the standard in 1926 based on what type of facility you are.  If you’re a manufacturer, fixed facility, traditionally the 1910 general industry standard applies to you.  If you’re a construction company who moves from site to site, the 1926 construction standards typically apply to you.  However, for asbestos regulations, the one that applies to you depends on what’s going on at your site and what your workers are doing.

A general rule of thumb is daily management of asbestos at your facility falls under the general industry standards.  When you are intentionally disturbing asbestos, then you follow the construction standards.  So a “general industry” facility could be subject to both the general industry and the construction standards if they have a renovation going on.  It’s important that you know the difference between the two distinctions.

The Similarities

We’ll first take a look at the similarities between the two standards.  Remember that OSHA’s goal is the safety of the worker so regulations are focused on worker protection.

Notifying Employees of the Hazards of Asbestos

Both regulations require that you notify workers of the hazards of asbestos and you can do this for everyone through your compliance activities for the hazard communication standard or you can do it through separate training.  This includes informing workers of the presence and location of asbestos in their workplace as well as the health hazards caused by asbestos.  Housekeeping personnel are required to be notified of asbestos-containing areas they could be cleaning.  Outside contractors and project bidders who could work in areas where asbestos could be disturbed are required to be notified where it is.  If asbestos is to be disturbed, such as a removal projects for a renovation, those people working in areas adjacent to those work areas are to be notified of the project.  Tenants of buildings are required to be notified by the owner of the building.

Signage/Labels

Warning signs are to be posted on regulated areas where removal is being conducted or asbestos is being disturbed.

Warning labels should be on raw materials, mixtures, scrap, waste, debris, bagged protective clothing, and other products containing asbestos fibers, or be placed on their containers. Entrances to mechanical rooms or mechanical areas where employees could be exposed should have labels attached where they will clearly be noticed by employees.

Exposure Limits and Medical Surveillance

Each standard sets limits for the amount of asbestos a worker can be exposed to.  If there’s the potential that a worker will be exposed past the limits in the standards, then respiratory protection is required and certain PPE is as well.  If that limit is exceeded, then the worker also needs to be placed in a medical surveillance program to monitor the health effects of their potential exposure.

Training

Each standard lines out required training. The level of training required depends on what the worker will be doing and whether or not they’ll be disturbing asbestos.  Training could range from an awareness class to a full week of intense training.  Most asbestos training is required to be repeated annually.

The Differences

General industry standards have a section on suggested work practices for housekeeping personnel to follow, but the construction industry standard dives into detailed work practices for those personnel intentionally disturbing asbestos-containing materials to follow.

In the construction standard is where we find the terms Class I, Class II, Class III and Class IV work.  The specific practices that workers are to follow are spelled out in detail for each class of work.

Class I work is for workers at the highest risk of exposure.  These are the one who will be removing friable asbestos materials.  Friable asbestos materials are those that when dry, can be easily crumbled or pulverized to powder by hand, making the potential for its fibers to be released even greater.  Class I work is the large-scale abatements of thermal systems insulation from pipes, boilers, tanks and ducts as well as removal of sprayed-on insulation, “popcorn ceiling” texture or acoustical plaster and vinyl floor covering.   This work requires specialized asbestos removal/abatement training of up to 40 hours with annual refreshers.

Class II work is the removal of non-friable asbestos.  Non-friable asbestos cannot be easily crumbled or pulverized to powder by hand and its asbestos fibers are usually bonded into other materials. If a non-friable material remains in good condition, it poses little hazard. Because of its strength, incidental contact will not usually release a fiber.  Class II work includes removal of vinyl asbestos floor tile, lay-in ceiling tile, Transite roofing panels, window glazing, asbestos siding and any non-friable materials.  This work requires specialized asbestos removal training that can vary from full 40 hour courses to specialized training for the specific material to be removed.

Class III work is the intentional disturbing of asbestos for repair and maintenance of other items.  For instance, if one needed to cut away a small amount of asbestos to fix a leaky pipe or to potentially disturb some asbestos in order to access an electrical panel for repair, that would fall under this class of work.  This type of work can often be done by in-house maintenance personnel or even maintenance contractors.  However, it’s still an intentional disturbance and so the workers who do these activities are required to take specialized asbestos removal training as well.  Class III work only allows workers to remove a certain quantity of material before it crosses the line and become Class I or II abatement work.  Specialized training to remove these small quantities is required, typically a 16-hour initial class with annual refresher training.

Class IV work is for those who will be conducting maintenance and custodial activities after a removal is completed, that is, cleaning up after Class I, II or III work.  This level has its own specific training requirements with specific content requirements.

Questions?

Asbestos regulations can be hard to interpret and confusing as actually 4 entities can get involved in regulating it: EPA, OSHA, State Governments and City/County Governments.  If you have any questions regarding this article or asbestos in general, contact us.

 

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EPA Looks to Add Air Emissions Reporting Items

EPA Looks to Add Air Emissions Reporting Items

Aug 18, 2023

EPA has announced a several changes to its Air Emissions Reporting Rule, or AERR that would make reporting of hazardous air pollutants (HAPs) consistent from state to state, add electronic reporting of stack tests, decrease and standardize emissions thresholds, create earlier reporting deadlines, and add new point sources to reporting requirements.

All of the changes EPA is considering making is to help the agency comply with the presidential commitment to enhance environmental justice by gathering more detailed location-specific information.

HAP Reporting

Per the AERR, industry is already required to report emissions of common or criteria pollutants and the pollutants that form them, called precursors.  Right now, the federal rule doesn’t require HAP reporting, but some states require reporting and voluntarily give this information to EPA.  Not all states do, and not all Indian lands do either.  For the ones that do, the rules can vary greatly from state to state.

The new rule would make HAP reporting standard for all facilities in all states who are:

  • Major sources per Clean Air Act operating permits;
  • Non-major sources who were in a certain industry emitting HAPS at or above a certain threshold;
  • Indian lands; and,
  • Offshore deep water ports.

Facilities would also be required to provide other details and data about HAPs from their stack test and performance evaluations.  EPA would like these to be reported electronically through the Consolidated Emissions Data Reporting Interface (CERDI).

To help states find a way to make reporting this data to EPA be more streamlined without the need to create their own separate data collection programs, EPA would like for states to develop procedures to have industry use the online Combined Air Emissions Reporting System, or CAERS system.  CAERS is already in use for reporting National Emissions Inventories and Toxic Release Inventories (TRI).  EPA even hopes to work towards eventually using CAERS to gather Greenhouse Gas Reporting (GHG) data and incorporate the CERDI as well.

The new rule would start in 2027.  This is because states have told EPA it can take two to three years for them to change their air emissions regulations.  EPA also says time it can take states to migrate from their current systems to CAERS could be one to three years as well.

Shorter Deadlines

The proposed rule looks to make states work faster to get this data to EPA.  Right now, states have 12 months after the end of the reporting period to turn in inventory data.  That is, the reporting period ends on December 31, and EPA has until December 31of the following year to turn it in to EPA after receiving it from industry much earlier than that. Starting in 2027, state inventory data would be due to EPA by September 30 and starting in 2030, data would be due by May 31.

Many states already turn in their collected inventory data sooner than that 12-month deadline, but shortening the due dates may force all states to go to electronic systems and may cause some of them to move up due dates for industry.

If EPA’s goals of using CAERS for multiple emissions reports, EPA speculates the possibility arises industry may eventually see one consolidated deadline for all reports rather than the current tiered deadlines of GHG reports due March 31, some air emissions reports due May 31 and TRI reports due July 1.  Another possibility to help alleviate stress in the deadlines in this case would be for industry to potentially report some data directly to EPA rather than go through the state.

EPA is currently seeking comments about the timing of the phase in deadlines and EPA wants feedback on these potential scenarios.

Standardized Emissions Thresholds

Under the current AERR rule, states report data on criteria pollutants and precursors that exceed certain thresholds.  The thresholds are setup to be different each year over a triennial cycle. That is, they are higher in the first two years and then lower in the third year.  On that third year, more facilities end up qualifying for reporting.  The new rule would make the threshold the same each year.  That would be the lower year 3 emissions threshold, causing more facilities to need to report every year.  HAP thresholds would be the same each year as well.

Small Generating Unit Emissions Data Included

Some facilities use small generating units to help meet demand on high electricity demand days or use them to supplement their own electricity.  EPA wants to make these a new source reporting requirement, taking daily data such as fuel use or heat input.  EPA says that when facilities use a number of these at one time, the units can significantly add to ozone formation through emitting of nitrogen oxides and particulate matter.

Currently, emissions for these are reported as an annual, not daily, emissions value and only if they’re located at a point source.  If they’re not located at a point source, they aren’t tracked at all.  The new rule would track all of them at all facilities.

Prescribed Fire Data

The proposed rule would also add the requirement for state, local and tribal forestry agencies to report daily activities associated with prescribed fires on state, tribe, private, or military lands.  This would include fires affecting more than 50 acres where there is forest canopy present (understory fire) or where there is little forest canopy like a grassland or oak woodland fire (broadcast fire), or pile burns of 25 acres or more.

Agricultural fires, land clearance fires and construction fires would not be included.

Comments Period

The public is invited to comment on the proposed rule up until October 18, 2023.  You can find the entire rule HERE.

Need Help Sorting This Out?

If you have questions about air emissions reporting in general, anything discussed in this article or this proposed rule, or need help getting your environmental reporting taken care of, we’re here to help!  Contact iSi today!

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Does this new change pertain to your company? Our team can help you figure it out and can help with other air compliance issues.

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OSHA Issues New National Emphasis Programs for Warehousing, Distribution Centers and Certain Retail Stores

OSHA Issues New National Emphasis Programs for Warehousing, Distribution Centers and Certain Retail Stores

Jul 28, 2023

OSHA’s latest National Emphasis Program (NEP) is targeting warehousing and distribution center operations, mail/postal processing and distribution centers, parcel delivery/courier services and certain retail stores with high injury rates.

An NEP is a temporary inspection emphasis based on a particular hazard that is typically targeted to specific NAICS codes where certain hazards are most prevalent or in safety areas showing a trend towards high hazards.  NEP inspections can be scheduled on their own, or OSHA can tack one on at an inspection if they see something that applies. So, if OSHA is onsite to investigate a complaint and they see something that could fall under an NEP, they can inspect for that too while they are there.

Who’s Covered in this NEP and Why?

OSHA recognizes a warehousing and distribution growth boom and an increased DART rate compared to other industries.  In 2011 there were 668,900 warehousing and distribution centers, and in 2021 that number was 1,713,900.  DART rates and total recordables for the industries covered in this NEP were over twice that of all private industry, some were more than three times the private industry rate from 2017-2021.

These are the NAICS Codes that will fall under the NEP:

  • 491110 Postal Service (Processing & Distribution Centers only)
  • 492110 Couriers and Express Delivery Services
  • 492210 Local Messengers and Local Delivery
  • 493110 General Warehousing and Storage
  • 493120 Refrigerated Warehousing and Storage
  • 493130 Farm Product Warehousing and Storage
  • 493190 Other Warehousing and Storage

The following warehouse-type retail stores are included because they have been found to have issues in loading and storage areas and have higher than average DART (Days Away; Restricted; Transfer) rates:

  • 444110 Home Centers
  • 444130 Hardware Stores
  • 444190 Other Building Material Dealers
  • 445110 Supermarkets and Other Grocery Stores
  • 452311 Warehouse Clubs and Supercenters

This retail list will change each calendar year based on which related establishments have the highest DART rates.

What Will Inspectors Look For?

Inspectors will be looking at these program areas:

  • Powered Industrial Vehicles (already an emphasis program in several regions)
  • Material Handling and Storage
  • Walking-Working Surfaces
  • Means of Egress
  • Fire Protection
  • Heat (already a National Emphasis Program)
  • Ergonomic Hazards

For heat, inspectors will review injury and illness records, ask about it during worker interviews, and look for these in the walkthrough.  If inspectors see exposures to heat-related hazards or if they find your NAICS code already falls under the Heat NEP, they will expand the scope of the inspection to include the Heat NEP.   Read more about what that inspection entails here.  Heat is a big emphasis right now with OSHA because it helps them meet their responsibilities in complying with the Presidential directive on climate change.

If inspectors see ergonomic hazards in their reviews of records, worker interviews and the walkthrough, they can also expand the scope to ergonomics and open a health inspection in addition to the safety inspection.

Read the full NEP documentation here.

Questions?  Need Assistance?

iSi can help answer questions you may have about this NEP or any others, as well as conduct a mock OSHA inspection to see where you stand if OSHA were to conduct this inspection at your facility today.  Contact us!

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OSHA Issues Final Rule Which Updates Electronic Injury and Illness Reporting, Adds Industries and More Requirements

OSHA Issues Final Rule Which Updates Electronic Injury and Illness Reporting, Adds Industries and More Requirements

Jul 21, 2023

OSHA has issued a final rule changing some of the requirements for electronic injury and illness reporting, adding some new companies and increasing some of the reporting requirements.

What’s New

Companies with 20-249 employees whose NAICS codes were listed on Appendix A of the standard were required to submit their 300A electronically.  This has not changed, however a new appendix, Appendix B, has been created for companies with 100 or more employees.  This will require many more industries to report electronically.  In addition to submitting the 300A, the 100+ employee companies who fall under Appendix B will also need to submit their 300 and 301 forms.

As with 300A information, data from the 300 and 301 logs will be published on the OSHA website.  Personally identifiable information from the 301, such as fields 1, 2, 6 and 7: employee name, employee address, physician name, and treatment facility name and address will not be collected.

The rules have not changed for all companies with 250 or more employees.  All companies, regardless of NAICS code, will need to submit their 300A forms.  Those with 19 or fewer employees will still not be required to report.

Another change includes making inclusion of your company’s legal name required.  Right now, only the Tax Identification number is required.

See Appendix A Here

See Appendix B Here

Industries Moved from Appendix A to Appendix B

Some NAICS codes were moved from Appendix A to Appendix B due to increased fatalities or increases in DART (Days Away; Restricted; Transfer) rates.  Those companies with 20-249 employees who had been submitting only the 300A will now be required to submit the 300 and 301.  These include:

  • NAICS 1133-Logging
  • NAICS 1142-Hunting and Trapping
  • NAICS 3379-Other Furniture Related Product Manufacturing
  • NAICS 4239-Miscellaneous Durable Goods Merchant Wholesalers
  • NAICS 4853-Taxi and Limousine Service
  • NAICS 4889-Other Support Activities for Transportation

Why They Are Requiring the 300 and 301 Log for Some Industries

Besides finding additional industry data on increased injuries, DART rate and fatalities, OSHA’s intent is to collect more accurate and detailed information for injuries and illnesses to help ultimately make workplaces safer.  The detailed information is meant to help make statistics more accurate and to help identify trends that are relevant to industries and types of workers.  The only time OSHA was able to get detailed information was through inspections.  The type of data they will be gathering allows for different kinds of statistical analyses and to help determine where initiatives are successful, are failing, or need to be developed.

OSHA sees gathering 300 and 301 information as a benefit not only to themselves, but by posting it online it can be beneficial information to industries, employers, employees, safety consultants like iSi, and to the general public.

Some examples of this that they used in their final rule document include:

  • 300A information only tells how many of each type of incident on that form are occurring. Now they will be able to see the different kinds of injuries and what they are.  For example, “respiratory conditions” could mean as a result of chemical exposure, COVID, TB, or Legionnaires.
  • Now data can be pulled by roles within any type of company. For example, injuries for nurses aides vs. nurses vs. doctors in medical facilities.
  • The Presidential directive on climate change has OSHA them focused on heat hazards. The new information will help them figure out what kinds of injuries and illnesses are attributed to heat.
  • This will help give employers another resource to consult besides industry groups and insurance to benchmark themselves against others in their industry. For example, the state of Michigan independently researched and found that bath refinishing contractors had 13 deaths in the span of 12 yrs.  From that information, they found it was because of the chemical strippers that were being used. As a result, safety guidance and training was sent to those companies to help improve safety and to alert them of those hazards in order to reduce the deaths.
  • Another employer in New York researched all injuries from their multiple worksites and found that there had been 11,000 lost workdays because of ladders. To reduce those numbers, they increased training in that area, making injuries drop to close to none.  With publicly available information, research like that can be done by multiple parties to help find ways to strengthen workplace safety.

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iSi Summer Toolbox Topics: Fireworks Safety

iSi Summer Toolbox Topics: Fireworks Safety

Jun 29, 2023

isi fireworks safety
Download Article in Shareable Safety Sheet

One of the favorite events of the 4th of July holiday for many people is shooting fireworks.  Contrary to what we may have seen and done in our teenage years, fireworks can actually be pretty dangerous.  Here are some tips to remember and share for a safe holiday:

  • Know your local laws regarding the use of fireworks such as where you are allowed to shoot them, which types are not allowed and at what times you can shoot them.
  • If you’re not allowed to shoot them in your home area and need to go across city or county lines, make sure you have the permission of the owner of where you’re going to shoot them.

The Setup

  • Always use fireworks OUTSIDE within a clear area. Stay way from buildings and vehicles.
  • Stay away from trees, bushes, and other dry vegetation.
  • Adults should supervise all firework activities.
  • Alcohol and fireworks do not mix.  Save your alcohol for after the show.
  • Always have a bucket of water and a water hose nearby.

Shooting the Fireworks

  • Before you begin, know your fireworks: read the caution labels and performance descriptions before igniting.
  • Wear safety glasses when shooting fireworks.
  • Light one firework at a time and then quickly move away.
  • Sparklers look harmless, but they can burn at 2000 degrees and quickly ignite clothing. Make sure anyone using them has their shoes on and that they hold them out away from their clothes and skin.
  • Never relight a “dud” firework.  Wait 20 minutes and then soak it in a bucket of water.
  • Never carry fireworks in your POCKET or shoot them into METAL or GLASS containers.
  • Old fireworks can be a safety hazard—make sure they haven’t gotten wet and that the fuse is intact before using.

Disposal

  • Smoldering fireworks can cause a fire in a trash can.
  • Soak used and dud fireworks in a bucket of water for at least 20 minutes, or overnight which is even better.
  • If you find old fireworks that are damaged or you don’t want to light them, don’t just throw them away. Soak them in a bucket of water until fully wet.
  • Wrap the wet fireworks in Ziploc bags, trash bags or plastic wrap so they won’t dry out—especially the unused ones that still contain the explosives within them. Dry fireworks can become unstable.

Fireworks and Pets

  • Don’t bring your pets to a fireworks display, even a small one.
  • If fireworks are being used near your home, put your pet in a safe, interior room to avoid exposure to the sound.
  • Treat toys filled with their favorites such as pumpkin, peanut butter or applesauce may be a good distraction to keep their minds busy.
  • Make sure your pet has an identification tag, in case it runs off during a fireworks display.

We hope you have a safe and wonderful Independence Day holiday!

.One of the favorite events of the 4th of July holiday for many people is shooting fireworks.  Contrary to what we may have seen and done in our teenage years, fireworks can actually be pretty dangerous.  Here are some tips to remember and share for a safe holiday:

  • Know your local laws regarding the use of fireworks such as where you are allowed to shoot them, which types are not allowed and at what times you can shoot them.
  • If you’re not allowed to shoot them in your home area and need to go across city or county lines, make sure you have the permission of the owner of where you’re going to shoot them.

The Setup

  • Always use fireworks OUTSIDE within a clear area. Stay way from buildings and vehicles.
  • Stay away from trees, bushes, and other dry vegetation.
  • Adults should supervise all firework activities. 
  • Alcohol and fireworks do not mix.  Save your alcohol for after the show.
  • Always have a bucket of water and a water hose nearby.

Shooting the Fireworks

  • Before you begin, know your fireworks: read the caution labels and performance descriptions before igniting.
  • Wear safety glasses when shooting fireworks.
  • Light one firework at a time and then quickly move away.
  • Sparklers look harmless, but they can burn at 2000 degrees and quickly ignite clothing. Make sure anyone using them has their shoes on and that they hold them out away from their clothes and skin.
  • Never relight a “dud” firework.  Wait 20 minutes and then soak it in a bucket of water.
  • Never carry fireworks in your POCKET or shoot them into METAL or GLASS containers.
  • Old fireworks can be a safety hazard—make sure they haven’t gotten wet and that the fuse is intact before using.

Disposal

  • Smoldering fireworks can cause a fire in a trash can.
  • Soak used and dud fireworks in a bucket of water for at least 20 minutes, or overnight which is even better. 
  • If you find old fireworks that are damaged or you don’t want to light them, don’t just throw them away. Soak them in a bucket of water until fully wet.
  • Wrap the wet fireworks in Ziploc bags, trash bags or plastic wrap so they won’t dry out—especially the unused ones that still contain the explosives within them. Dry fireworks can become unstable.

Fireworks and Pets

  • Don’t bring your pets to a fireworks display, even a small one.
  • If fireworks are being used near your home, put your pet in a safe, interior room to avoid exposure to the sound.
  • Treat toys filled with their favorites such as pumpkin, peanut butter or applesauce may be a good distraction to keep their minds busy.
  • Make sure your pet has an identification tag, in case it runs off during a fireworks display.

We hope you have a safe and wonderful Independence Day holiday! 

 

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OSHA’s Heat-Related Hazards National Emphasis Program

OSHA’s Heat-Related Hazards National Emphasis Program

Jun 16, 2023

OSHA has issued a new NEP on heat-related hazards. In this article, we’ll discuss what it includes, which companies will be targeted and what OSHA inspectors will be looking for in their inspections.

What’s an NEP?

A National Emphasis Program, or NEP, is a temporary inspection emphasis based on a particular hazard that is typically are targeted to specific industry groups or NAICS codes where those hazards are most prevalent.  Companies within those NAICS codes are randomly chosen for these inspections and others can be chosen because of past violations or certain circumstances.  NEP inspections can be scheduled on their own, or companies can have them added to other OSHA inspections. For example, if someone at your facility has complained to OSHA about one hazard, OSHA can conduct an inspection on that complaint issue and then if they see something else onsite that’s covered by an NEP or a regional or local emphasis program, they can inspect for that too while they are there.

OSHA’s Heat Hazard NEP

The heat NEP covers both indoor and outdoor heat hazards.  OSHA has had heat initiatives and heat awareness campaigns since 2021 and there has been debate in Congress about having a heat standard.  This NEP is also a response to President Biden’s Executive Order to “Tackle the Climate Crisis at Home and Abroad.”  The Secretary of Labor developed a Climate Action Plan with a goal of reducing heat-related illnesses and this is one of the ways they are going about that.

For purposes of measurement, OSHA considers a heat priority day to be one when the temperature is 80° F or higher.  Programmed, targeted NEP inspections will be conducted on days when the National Weather Service has issued a heat advisory or warning, including a Heat Advisory, Heat Wave, Excessive Heat Outlook, Excessive Heat Watch and an Excessive Heat Warning.

Which Companies Are Affected?

Of course, construction companies whose workers work out in the heat are affected.  There are other non-construction companies who have been targeted as well as other industries who can be targeted at your OSHA Area Office’s discretion.

The list was too long to include in this article, but you can find a PDF copy of that here.

Farming is included on this list, however farms with 10 or less employees (not counting family members who work on the farm), who have stayed at or below that number for the past 12 months, and have not had any temporary labor camps in the past 12 months will be exempt from the NEP.

What Triggers an Inspection for this NEP?

You can end up on the inspection list for this in several different ways:

  • You have a heat-illness related fatality, or have had a heat-illness related fatality that OSHA would like to follow up on;
  • There’s an employee complaint about heat-illness hazards;
  • Your company operates under one of the NAICS codes from the target list, you have been picked by OSHA’s random number generator and it’s a day when the National Weather Service has issued a heat alert;
  • OSHA inspectors are already onsite, and they find a heat-related illness on OSHA 300 logs, observe hazardous heat conditions, an employee brings a heat-related hazard to the attention of the inspector, or it’s a heat priority day. Inspectors have been encouraged to ask about your heat-illness prevention program on heat priority days;
  • OSHA previously cited you for a lack of a heat-illness prevention program and you still haven’t implemented one; or,
  • Your company has been added to the list by your Area Office based on a referral by another agency such as the Wage and Hour Division, the EPA, or the U.S. Department of Agriculture, they saw a media report about your company which shows there may be a heat issue onsite, or from the Area Office consulting other reference directories to find potential companies to inspect.

What Will Inspectors Look For?

  • Records Review – Inspectors will look at your OSHA 300 Logs and 301 Incident Reports for any entries indicating heat-related illnesses and will review any records of heat-related emergency room visits and/or ambulance transports even if there were no hospitalizations.
  • Employee Interviews – Interviews of current employees, new employees and employees who were away from the worksite and recently returned to work will be conducted. Inspectors will be asking for symptoms of headache, dizziness, fainting, dehydration or other conditions that may indicate heat-related illness.
  • Program Review – Next the inspector will look at your program. First, do you even have a written program? How do you monitor ambient temperatures and levels of work exertion at the worksite? Are you conducting calculations using a particular method suggested by NIOSH or ACGIH?  Is there unlimited cool water that’s easily accessible and are you requiring additional hydration and rest breaks?  Is there access to shade?  What do you do to acclimatize new and returning workers? Do you have a buddy system for hot days?  What kinds of administrative controls are used?  Is work scheduled during cooler periods of the day?  Do you have a screening program to identify health hazards? What does your training program contain?
  • Documentation of Conditions – The inspector is to document any conditions they find relevant to heat hazards such as heat index, heat alerts, information they get from the OSHA-NIOSH Heat Safety Tool App and/or Wet Bulb Globe Temperature (WGBT) measurements. If they are there because of an incident, they’ll be looking at current conditions such as wind speed, relative humidity, dry bulb temperatures both at the workplace and in the shaded rest areas, WGBT, percentage of cloud cover and heat alerts.
  • Observation of Heat-Related Hazards – Inspectors will be looking for potential sources of heat-related hazards such as exposure to sun, hot air or hot equipment. What PPE is being used, that is, it bulky and heavy or does is deflect heat?  What tasks are being conducted and what’s the level of exertion being used to conduct those?  How long are employees conducting these tasks and how long are they continuously conducting moderate to strenuous activities?

Which Standards Will Get Cited?

Most citations for these inspections will fall under the General Duty Clause.  Other citations that could be tacked on, depending on the findings, could include:

  • Recordkeeping – If the employee became unconscious or needed oxygen and it wasn’t recorded you could be cited here.
  • Sanitation – Regulations in 1910.141 and 1926.51 specify your company is required to provide cool, potable water.
  • Construction Safety Training and Education – Under 1926.20 and 1926.21, construction companies are required to have a safety and health program.

A New Standard on the Horizon

OSHA has a standard called Heat Illness Prevention in Outdoor and Indoor Work Settings already in the Prerule stage.  They have passed the comment stages from their Advanced Notice of Proposed Rulemaking and are scheduled to next go to the Small Business Regulatory Enforcement Fairness study.  In the meantime, there are several states with their own heat illness rules.  In the state of California there are already requirements for outdoor workers, and the California legislature asked Cal-OSHA back in 2016 to come up with a standard for indoor workers.  They have been working on that and are expected to have something in 2024.  What’s caused the delay is the issue of determining the exact thresholds that can be feasible for all industries since so many indoor workplaces can be different.

What’s in a Heat Illness Prevention Program?

Stay tuned here to our blog for our upcoming article featuring OSHA’s suggestions for what should be included in your heat-illness prevention program.

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