OSHA Electronic Injury and Illness Reporting Due March 2

OSHA Electronic Injury and Illness Reporting Due March 2

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 Safety Training Requirements Should You Add to Your Calendar?

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

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

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
TBD | Manhattan | 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
TBD | St. Louis | In-Person | Learn More

Missouri Water Seminar
TBD | Online | Learn More

Missouri Air Seminar
TBD | 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
TBD | 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

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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2024 EPA and OSHA Compliance Deadlines

2024 EPA and OSHA Compliance Deadlines

It’s a new reporting year and time to plan for reporting and compliance deadlines from 2023’s activities and for the new year.  Mark your calendars with these environmental and safety reporting deadlines and other to-do tasks for 2024:

EPA/Environmental

 

OSHA/Safety

 

DOT/Transportation

State and Local Reporting Dates

There are other environmental and/or safety reports you must complete, but due dates may vary according to your state and local regulations or when your permits or reports were first completed.  Some examples include:

  • Title V Air Permits (Semi-Annual Compliance Certifications)
  • Hazardous Waste Reports
  • Wastewater Discharge Certifications and Monitoring Reports
  • Aboveground and Underground Storage Tank Registrations
  • Groundwater Monitoring Reports
  • Air MACT Certifications, Deviation Reports and Summary Reports
  • Stormwater Reports, Inspections and Sampling
  • Boiler Reports
  • X-Ray Equipment Registrations

Stay tuned to our blog for any updates or notices of new regulations.

Because environmental and safety regulations vary from state to state, city to city, there may be additional requirements for your company which are not listed above.  If you need assistance in determining which of these apply to you, or assistance with completing these reports and permits, iSi would love to help!  Please contact us for more information and pricing.

 

 

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Christmas Safety

Christmas Safety

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

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

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

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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Safety Boots: What You Need To Know

Safety Boots: What You Need To Know

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

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?

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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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

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

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.

Need Advice?

If you need help navigating this standard, or have questions about it, contact us today!

 

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iSi Summer Toolbox Topics:  Fireworks Safety

iSi Summer Toolbox Topics: Fireworks Safety

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! 

 

Questions?

Does this apply to your company?  Do you have questions?  Contact us!

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Forklift Top 6: Common OSHA Compliance Pitfalls for Powered Industrial Trucks

Forklift Top 6: Common OSHA Compliance Pitfalls for Powered Industrial Trucks

We have been seeing more and more issues regarding OSHA powered industrial trucks (forklift) compliance. OSHA currently has a number of powered industrial trucks local and regional inspection emphasis programs in several states. This means if you have an OSHA inspection, it’s likely they’ll look at your powered industrial trucks program while they are there, even if the inspection wasn’t initially for that.

The following are 6 areas where our safety consultants are finding compliance pitfalls.  Below this list is a graphic which shows some examples of fines you may be facing if these issues are found at your facility.

Seat Belts

Although not explicitly stated in the standard, seat belts must be worn by workers operating a powered industrial truck. In a letter of interpretation, OSHA says that they would cite this issue under the OSH Act 5(a)(1). This act requires employers to protect employees from serious and recognized hazards.

ASME standards require powered industrial trucks manufactured after 1992 to have a restraint device such as a seat belt to protect the employee in case of tip over. If yours doesn’t have one, OSHA advises you contact the manufacturer to determine the best way to have one installed. If at any time the manufacturer contacted your company to let you know of a retrofit program for your powered industrial truck, you can be cited for not doing so.

Attachments

You cannot add any non-factory attachments to your truck without the manufacturer’s written approval. There are, however, some cases in which professional engineers can make these determinations with extensive safety study.

Once you do use attachments, all data plates, tags and decals need to be updated with revised capacity, operation and maintenance data. Anytime you do use attachments, when there is no load, the operator still needs to treat the forklift as partially loaded.

Legible Markings

It is very important that every control, nameplate and marking be visible and legible. If something has worn off or fallen off, you need to find a way to re-label that item so it can be read and identified. For example, a client received a fine of $4,700 for a forklift lever which wasn’t marked.

Make sure your aisleways and walkways are clearly marked so pedestrians know where to expect trucks will be operating, and ensure you have adequate lighting.

Training

Training must be provided before anyone is to use the truck. Initial training must include both instructional training (classroom, video, etc.), practical training (hands-on demonstration), and an evaluation of how the employee is performing in the workplace. Refresher training, that is, a reevaluation of the operator’s performance must be conducted every 3 years.

In addition to the triennial requirements, refresher training shall be provided to the operator when the operator has been observed to operate the vehicle in an unsafe manner; the operator has been involved in an accident or near-miss incident; the operator has received an evaluation that reveals he/she is not operating the truck safely; or a condition in the workplace changes in a manner that could affect safe operation of the truck. It is important to note that the standard does not take into account whether or not the operator was at fault in accident or near-miss incident. Refresher training is also required when the operator is assigned to drive a different type of truck. An example of this would be a sit-down forklift vs. a stand-up forklift vs. an all-terrain forklift.

Usage

Make sure you know the contents of the atmospheres in which your forklifts will be operating. You are required by OSHA to know what your occupational exposures are anyway, however, only certain types of forklifts can be safely used in areas contaminated by certain chemicals and materials. The standard goes into great detail on which types of forklifts can be used in certain areas.

A forklift is considered unattended when the driver is 25 ft. away or more or it is out of their view. Thus, when the truck is unattended, the load should be fully lowered, controls neutralized, power off, and brakes set. If the driver is within 25 ft. and the forklift is still visible, they must follow all of these procedures except for turning off the forklift.

Inspections and Repairs

Inspections must be conducted daily and when the forklift is used around the clock, inspections must be conducted after each shift. If it’s found that there are any defects, issues with overheating, unsafe conditions or other repairs needed, the forklift must be taken out of service until those can be corrected.

Need Help?

Need assistance with your OSHA compliance tasks?  How can we make compliance easier for you?

We have been seeing more and more issues regarding OSHA powered industrial trucks (forklift) compliance. OSHA currently has powered industrial trucks local and regional emphasis programs in a number of states. This means if you have an OSHA inspection, it’s likely they’ll look at your powered industrial trucks program while they are there, even if the inspection wasn’t initially for that.

The following are 6 areas where compliance pitfalls are seen.  Below this list is a graphic which shows some examples of fines you may be facing if these issues are found at your facility.

Seat Belts

Although not explicitly stated in the standard, seat belts must be worn by workers operating a powered industrial truck. In a letter of interpretation, OSHA says that they would cite this issue under the OSH Act 5(a)(1). This act requires employers to protect employees from serious and recognized hazards.

ASME standards require powered industrial trucks manufactured after 1992 to have a restraint device such as a seat belt to protect the employee in case of tip over. If yours doesn’t have one, OSHA advises you contact the manufacturer to determine the best way to have one installed. If at any time the manufacturer contacted your company to let you know of a retrofit program for your powered industrial truck, you can be cited for not doing so.

Attachments

You cannot add any non-factory attachments to your truck without the manufacturer’s written approval. There are, however, some cases in which professional engineers can make these determinations with extensive safety study.

Once you do use attachments, all data plates, tags and decals need to be updated with revised capacity, operation and maintenance data. Anytime you do use attachments, when there is no load, the operator still needs to treat the forklift as partially loaded.

Legible Markings

It is very important that every control, nameplate and marking be visible and legible. If something has worn off or fallen off, you need to find a way to re-label that item so it can be read and identified. For example, a client received a fine of $4,700 for a forklift lever which wasn’t marked.

Make sure your aisleways and walkways are clearly marked so pedestrians know where to expect trucks will be operating, and ensure you have adequate lighting.

Training

Training must be provided before anyone is to use the truck. Initial training must include both instructional training (classroom, video, etc.), practical training (hands-on demonstration), and an evaluation of how the employee is performing in the workplace. Refresher training, that is, a reevaluation of the operator’s performance must be conducted every 3 years.

In addition to the triennial requirements, refresher training shall be provided to the operator when the operator has been observed to operate the vehicle in an unsafe manner; the operator has been involved in an accident or near-miss incident; the operator has received an evaluation that reveals he/she is not operating the truck safely; or a condition in the workplace changes in a manner that could affect safe operation of the truck. It is important to note that the standard does not take into account whether or not the operator was at fault in accident or near-miss incident.

Refresher training is also required when the operator is assigned to drive a different type of truck. An example of this would be a sit-down forklift vs. a stand-up forklift vs. an all-terrain forklift.

Usage

Make sure you know the contents of the atmospheres in which your forklifts will be operating. You are required by OSHA to know what your occupational exposures are anyway, however, only certain types of forklifts can be safely used in areas contaminated by certain chemicals and materials. The standard goes into great detail on which types of forklifts can be used in certain areas.

A forklift is considered unattended when the driver is 25 ft. away or more or it is out of their view. Thus, when the truck is unattended, the load should be fully lowered, controls neutralized, power off, and brakes set. If the driver is within 25 ft. and the forklift is still visible, they must follow all of these procedures except for turning off the forklift.

Inspections and Repairs

Inspections must be conducted daily and when the forklift is used around the clock, inspections must be conducted after each shift. If it’s found that there are any defects, issues with overheating, unsafe conditions or other repairs needed, the forklift must be taken out of service until those can be corrected.

By the Numbers

The following are examples of forklift-related fines levied to companies across the U.S. Please keep in mind that they are subjective, depending on severity and situation. For many of these, the costs listed were the final negotiated fine. In most cases, the fine was originally double the amount shown, then negotiated down.

forklift violation example

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OSHA’s Heat-Related Hazards National Emphasis Program

OSHA’s Heat-Related Hazards National Emphasis Program

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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OSHA Memo to Affect Way Agency Issues Certain Penalties, With Potential for Significant Increases

OSHA Memo to Affect Way Agency Issues Certain Penalties, With Potential for Significant Increases

OSHA’s Director of Enforcement and Director of Construction have joined together to issue two memos to its Regional Administrators and State Plan Designees to alert them on how to interpret penalties in certain cases.

Instance-by-Instance Citations

First, the memo “Application of Instance-by-Instance Penalty Adjustments” adds more circumstances in which these types of penalties can be charged.  Instance-by-Instance penalties are fines for every single instance that the violation occurs, such as penalties by machine, by entry, by location, or by employee.

The memo says that high-gravity serious violations of the following standards can now be subject to Instance-by-Instance penalties:

  • Fall Protection
  • Trenching
  • Machine Guarding
  • Respiratory Protection
  • Permit-Required Confined Spaces
  • Lockout/Tagout
  • Other-than-serious violations of the recordkeeping standard

Only those standards that have text which allows for violations of individualized duties rather than general course of conduct can be used to find incident-by-incident penalties.  For example, if machines are missing guards or if employees do not put lockout/tagout devices on each energy isolating device, you could be fined per instance because they are needed on each machine.

Memo guidance says discretion can be used for Instance-by-Instance penalties when penalty adjustments don’t advance the deterrent goal.  The following factors are to be considered:

  • Willful, repeat, or failure to abate violations within the past five years where that classification is current;
  • Failure to report a fatality, inpatient hospitalization, amputation, or loss of an eye;
  • The proposed citations are related to a fatality/catastrophe; or
  • The proposed recordkeeping citations are related to injury or illness(es) that occurred as a result of a serious hazard.

Penalty evidence and justification must be documented and the Regional Office of the Solicitor must be consulted before these will be issued.

Grouping Penalties

Next, the memo “Exercising Discretion When Not to Group Violations” reminds Regional Administrators and Area Directors that they have the discretion to NOT group violations together in instances where it could help create a deterrent.  Grouping is allowed when:

  • Two or more serious or other-than-serious violations are so closely related they constitute a single hazardous condition (then they are grouped based on the most serious item);
  • Two or more violations are found which, if considered individually, represent other-than-serious violations but together could create a substantial probability of death or serious physical harm (then the violations are grouped as a serious violation); and,
  • When several other-than-serious violations are found (then they are grouped to create a high gravity other-than serious violation).

The memo is reminding that violations don’t have to be grouped if it doesn’t elevate the gravity/classification of the citation when the evidence could allow for multiple citations.  That is, if OSHA can find evidence that the violations could have different abatement methods, if each one could have resulted in death or serious harm, or if each violation condition could expose workers to different hazards, then they can charge each violation separately without grouping them.

In addition, guidance in the OSHA Field Operations Manual says violations are not to be grouped when:

  • Violations are found in separate inspections on more than one day;
  • The same violations are found at multiple sites, but at different locations. If your company is inspected at different branches/locations/sites and you violate the same standard at each place, then you are fined separately at each place;
  • Separate sections of the General Duty Clause are violated. Separate sections of the General Duty Clause cannot be grouped together, but a General Duty Clause section can be grouped with a related regulation; and,
  • Violations are so egregious that they trigger OSHA’s Instance-by-Instance Penalties.

OSHA Fines Increased

Dollar amounts on OSHA fines also were increased at the beginning of the year.  The maximum penalty amounts in 2023 are $15,625 per violation for serious, other-than-serious, posting requirement, and failure to abate violations, and $156,259 per violation for willful and repeat violations. This is an increase in 7.5%, which is the biggest year to year increase since 2016.

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What Will Inspectors Look for in Combustible Dust Inspections?

What Will Inspectors Look for in Combustible Dust Inspections?

We recently discussed in this blog OSHA’s revised Combustible Dust National Emphasis Program.  Along with that revision OSHA’s shared its instructions to inspectors on what how to conduct the inspection, what to look for, how to build a case for a citation and which standards they could cite in a citation.

In this article, we’ll list out exactly what an inspector will be looking for if they arrive to your site for a combustible dust inspection, the information you’ll need to provide, and which standards you can be cited under.  There is no official OSHA combustible dust standard, so inspection instructions can help serve as a guidance to help you determine what you need to have in place not only to do well in an inspection, but to keep your people safe.

How Will OSHA Determine Who Gets Inspected?

First, will you be on the target list?

The NAICS codes who are likely to have combustible dust hazards are gathered together on Appendix B of the emphasis program.  OSHA will pull a list of all companies who qualify and generate a random order list.  Each company will be assigned a number and OSHA inspectors who have had specialized training in combustible dust hazards will be assigned to conduct inspections. This list will remain active for 3 years before a new one is generated. Between 2013 and 2017, OSHA conducted approximately 500-600 per year between programmed (planned) and unplanned inspections.

Your company can be deleted off the list if you have been inspected within the past 5 fiscal years, were inspected for combustible dust hazards and no citations were issued, or if you were inspected for combustible dust hazards, was cited but a follow-up inspection verified you did abate the hazards. Also, if you are a VPP or SHARP company, you can be deleted off the list.

If you’re not on the list for programmed inspections, you can still be inspected if there has been a complaint or if you have had a fatality or catastrophic incident related to combustible dust.

What Will Inspectors Be Looking for in a Combustible Dust Inspection?

This is the list of items that OSHA will be evaluating and the potential documentation they will be looking for:

  1. History of Fires and Explosions

Inspectors will be determining if your plant has a history of fires, flash fires, deflagrations of process vessels and inside buildings, and explosions of vessels.  They’ll be conducting employee interviews, looking at OSHA logs, looking at insurance claims, accessing local fire department records, and conducting onsite visual inspections to look at the condition of your equipment.  They’ll be placing special attention to discoloration, bulging, repairs and missing/damaged pieces or appendages of your equipment.

  1. Safety Data Sheets (SDSs)

Inspectors will go through your SDSs, looking for combustible dusts.

  1. Electrical Area Classification Drawings/Documents

Inspectors will be looking at your classification documents to find areas marked Class II, Division 1 or 2 to ensure electrical equipment is approved for that hazardous location.

You are required to have these drawings per 29 CFR 1910.307, which is the Hazardous (Classified) Locations Standard.

  1. Dust Hazard Analysis

Inspectors have been instructed to do a dust hazard analysis toward the end of the inspection to help them in determining your citation, rather than at the beginning of the inspection to determine the scope.  This analysis includes observations of all areas of the facility for accumulation issues to determine overall potential for fire, flash fire or explosion.

They’ll be looking at:

  • Horizontal structures
  • Conduits and pipe racks
  • Cable trays
  • Floors
  • Above suspended ceilings
  • On or around equipment, especially on elevated horizontal surfaces

They will be taking measurements of depth, determining physical area sizes, and may be bringing cameras and video cameras on poles to help take photos of high places.

  1. Control and Suppression Systems

Inspectors will be looking to ensure:

  • Dust collectors and dust handling equipment has explosion prevention/suppression systems and deflagration propagation prevention devices;
  • Dust systems that return clean air to buildings have proper protections;
  • There are no hazardous levels of combustible dust accumulations outside of equipment;
  • Number and sizes of horizontal surfaces are minimized and designed to prevent dust accumulation;
  • Equipment that produces, transports, stores or handles dust (mixers, silos, mills, ducts, dust collectors, etc.) are designed and maintained to prevent dust leakage/escape/clouds;
  • Material transport systems (conveyors, elevators) are designed to prevent dust leakage/escape/clouds;
  • The method of cleaning and the tools you use to clean are proper. Are you using specialized vacuums to clean up combustible dusts, what are you doing to clean up dust, and if you use compressed air is it under 30 psi with the right chip guards and PPE?
  • Electrical equipment and lights are proper for use in those areas;
  • Powered industrial trucks are approved for use in those locations;
  • Hot work, welding, cutting and grinding is not performed in those areas;
  • Ductwork from dust generation, handling and collecting systems is conductive, bonded and properly grounded to dissipate static accumulation;
  • Maintenance of mechanical equipment is conducted to prevent generation of heat and sparks;
  • Process systems have magnetic separators and/or tramp metal separators installed;
  • Your ductwork has proper transport velocity to prevent accumulation in the ducts and that ducts have inspection and cleanout ports/hatches;
  • Housekeeping procedures are in place; and,
  • You have ignition control programs for:
    • Hot work and hot surfaces
    • Bearings
    • Self-heating materials
    • Open flames
    • Fuel-fired equipment
    • Heated process equipment
    • Heated air
    • Frictional sparks
    • Impact sparks
    • Electrical equipment
    • Electrostatics or other similar sources in dust handling equipment.
  1. Sampling Results

Inspectors will be collecting dust samples from each area they believe has a potential for a combustible dust hazard.  This could be from elevated surfaces, horizontal surfaces as high overhead as possible, floors and equipment surfaces, dust collection equipment and within process equipment.  They are not allowed to enter into your confined spaces, but they can use a non-spark producing scope or scoop on an extension pole to collect their sample.

Samples will be sent to the OSHA Salt Lake Technical Center which has specialized knowledge and experience with combustible dust hazards.

A good practice with all OSHA inspections is to make sure you conduct your own side-by-side sampling, that is, you sample what they sample and get your own independent results.  Be advised, combustible dust samples are going to be considerably more expensive samples to have analyzed by a laboratory than other types of materials.

  1. Other Documentation

Inspectors will be gathering all kinds of other information including:

  • How your equipment is connected and how the process flows;
  • Piping and process diagrams;
  • They’ll take photographs, videos and make diagrams or sketches documenting extent and depth of dust and condition of equipment;
  • Room dimensions;
  • Engineering controls used;
  • Design information, make, model, serial numbers of dust collectors;
  • Date of installation and operator manuals for dust collection system;
  • Dirty and clean size/volumes for dust collection system;
  • Warning signs and alerts on equipment regarding combustible dust;
  • External ignition sources; and,
  • Internal ignition sources.

What are Some Potential Standards You Could be Cited Under?

OSHA does not have its own dedicated combustible dust standard, but it can use a wide variety of other standards to cite you for these hazards.  These include:

Housekeeping Standard (Non-Storage Areas) – 29 CFR 1910.22

A little dust here and there wouldn’t be enough.  You can be cited under this standard if you have a visible volume of combustible dust in the workplace.  This is where that dust hazard analysis comes in.  They will use their measurements and observations for extent, depth and calculations of area.  If you have dust everywhere and it’s pretty significant, expect a violation of this standard.

Housekeeping Standard (Storage Areas) – 29 CFR 1910.176(c)

This is from the Handling Materials – General standard which says that storage areas need to be free from accumulation of materials that constitute hazards including explosion and fire.

General Duty Clause – Section 5(a)(1)

As with a lot of other cases, usually there’s always something within the tried-and-true General Duty Clause that could be included. In this case it will be related to the dust collection system or your dryers, mixers, material storage, bucket elevators and mills.  In addition to reviewing your safety and maintenance manuals, inspectors may do some research into your industry to find potentials for combustible dust hazards and also use NFPA 65 or other NFPA standards to find issues.

Some ideas for citations under the General Duty Clause listed for inspectors in their inspection guidance include:

  • Problems with dust collectors;
  • Ductwork-related problems;
  • Improperly designed deflagration venting;
  • Unprotected processing and material handling equipment (no deflagration suppression); and,
  • Improperly designed or maintained blowers, collection systems and exhaust systems used at sawmills.

Ventilation – 29 CFR 1910.94

Paragraph (a) of this standard deals with abrasive blasting including fire and explosion hazards.  If your ventilation equipment is not constructed in accordance to NFPA 91 and 68, then you can be cited here.

PPE – 29 CFR 1910.132(a)

If employees are not wearing FR (flame-resistant) clothing around combustible dust areas where they could receive burn injuries from flash fires, you can be cited under the PPE standard.

Hazardous (Classified Locations) – 29 CFR 1910.307

This is in the Electrical Subpart S area of the standards.  If sample results show you have combustible dust in a Class II area and it’s not safe for it to be there, you would be cited under this one.  They can also cite Class I and III electrical-related issues here too if they find them along the way.

Powered Industrial Trucks – 29 CFR 1910.178

If you have a forklift that’s not rated an EX (explosion proof) in the area where there’s combustible dust, you can be cited here.  Also be aware that many jurisdictions still have Powered Industrial Truck emphasis programs so they can conduct an additional separate inspection regarding your trucks while they are there for combustible dusts.

Welding, Cutting and Brazing – 29 CFR 1910.252

Under the general requirements, if you are conducting cutting and welding in explosive atmospheres, you can be cited here.

Warning Signs – 29 CFR 1910.145

This comes from the standard for Specifications for Accident Prevention Signs and Tags under Subpart J, General Environmental Controls.  If you have safety instruction signs missing from equipment or missing from entrances where there are explosive atmospheres, expect a citation here.

Hazard Communication – 29 CFR 1910.1200

Did you know that combustible dust is considered a hazardous chemical?  This needs to be incorporated into your hazcom program.   All equipment containing combustible dusts, including drums and containers used to collect dusts from dust collectors and cyclones must be properly labeled just like any other hazcom container.

You should also document notifying and training employees on its hazards.

SDSs are now supposed to include combustible dust as a not otherwise classified hazard with the signal word “warning” and the hazard statement “may form combustible dust concentrations in the air.”

Others and Specialty Standards

  • Means of Egress – 29 CFR Subpart E
  • Portable Fire Extinguishers – 29 CFR 1910.157 (no emergency action plan or fire prevention plan)
  • Fire Brigades – 29 CFR 1910.156
  • Spray Finishing – 29 CFR 1910.107
  • Bakery Equipment – 29 CFR 1910.263
  • Sawmills – 29 CFR 1910.265
  • Pulp and Paper Mills – 29 CFR 1910.261

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OSHA Updates Its Combustible Dust National Emphasis Program

OSHA Updates Its Combustible Dust National Emphasis Program

In 2007, after a number of combustible dust incidents, OSHA issued its National Emphasis Program on Combustible Dusts.  After years of inspections and gained knowledge about combustible dusts in industry, OSHA maintains this National Emphasis Program is now updating it to better target those industries they are finding are having the most issues.

What Are Combustible Dusts?

Combustible dusts are organic or metal dusts ground into very small particles, fibers,  flakes, chips, or chunks which makes them more likely to cause fire, flash fire, deflagration and explosion hazards.  They can be found in process equipment, dust collectors, electrical equipment, and all around the building.

Some typical combustible dusts include:

  • Metal dusts like aluminum, magnesium and iron
  • Wood dusts
  • Coal, carbon and carbon black
  • Plastic dusts, phenolic resins and additives
  • Rubber dust
  • Biosolids
  • Organic dusts like sugar, flour, paper, soap and dried blood
  • Textile dusts

Grain handling dusts are also combustible, however, due to the incidents and explosions involving grain handling facilities, they have their own emphasis program.  The combustible dust emphasis program looks at all other dusts or those facilities that may not qualify to be inspected under the grain handling emphasis.

Affected Industries

The combustible dust emphasis program has listed quite a few NAICS codes targeted for programmed inspections in its Appendix B.  Some of these include:

  • Wood products
  • Forest and furniture
  • Chemicals
  • Metal processing
  • Agriculture and food (human and animal)
  • Rubber and Tire
  • Paper products
  • Textiles
  • 3-D printing
  • Pharmaceuticals
  • Wastewater treatment
  • Recycling
  • Coal dust handling and processing

Through its inspections since 2007, OSHA found:

The Top 5 Industries with the Most Combustible Dust Hazards

  • Farm suppliers
  • Institutional furniture manufacturers
  • Metal window and door manufacturers
  • Sheet metal work
  • Furniture and upholstery repair

The Industries With the Most Fatalities and Catastrophes:

  • Animal food manufacturing
  • Sawmills and lumber production
  • Wood manufacturing and processing
  • Agriculture processing

New Industries Added to Appendix B to Be Inspected

Through inspection data it was found that certain industries needed to be added to Appendix B because they were more likely to have combustible dust hazards or the number of combustible dust-related fatalities or catastrophes had went up.  These include:

  • Commercial bakeries
  • Printing ink manufacturing
  • Cut stock, resawing lumber, and planing
  • Leather and hide tanning and finishing
  • Truss manufacturing
  • Grain and field bean merchant wholesalers

Industries Removed from Appendix B

Those industries that OSHA found were less likely to have combustible dust hazards or who had low incidents and violations were removed from Appendix B and are no longer on the target list for programmed inspections.  These include:

  • Fossil fuel electric power generation
  • Cookie and cracker manufacturing
  • Pharmaceutical preparation manufacturing
  • Unlaminated plastic profile shape manufacturing
  • Noncurrent carrying wire device manufacturing
  • Blind and shade manufacturing

How Will OSHA Determine Who Gets Inspected?

OSHA will pull a list of all companies whose NAICS codes fall under those listed in Appendix B to generate a random number list.  Each company will be assigned a number and OSHA inspectors who have had specialized training in combustible dust hazards will be assigned to conduct inspections. This list will remain active for 3 years before a new one is generated. Between 2013 and 2017, OSHA conducted approximately 500-600 per year between programmed (planned) and unplanned inspections.

Your company can be deleted off the list if you have been inspected within the past 5 fiscal years, were inspected for combustible dust hazards and no citations were issued, or if you were inspected for combustible dust hazards and were cited but a follow-up inspection verified you did abate the hazards. If you are a VPP or SHARP company, you also will be deleted off the list.

Even if you’re not on the list for programmed inspections or in Appendix B, you can still be inspected if there has been a complaint or if you have had a fatality or catastrophic incident related to combustible dust.

There is no OSHA combustible dust standard, so what will an inspector be looking for when they come onsite for one of these inspections?  Stay tuned for our next blog article, “What Will Inspectors be Looking for in Combustible Dust Inspections?”

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OSHA Injury Posting Requirements

OSHA Injury Posting Requirements

It’s that time of year again when employers need to post and submit last year’s injury and illness data.  Here is a list of timeframes and more information about which companies this affects:

Posting Injury and Illness Data

All employers who are required to maintain OSHA logs must post a copy of their OSHA 300A log from February 1 through April 30.  This needs to be placed in a common area where an employee can easily see it.  Make sure you have a company executive sign and certify it before posting.


Electronic Submittals to OSHA

osha injury reporting recordkeeping compliance chart for 2023

Employers with more than 250 employees and employers with 20-249 employees under certain NAICS codes are required to submit their 300As to OSHA’s Injury Tracking Application (ITA) website.  Here’s a list of those special industries covered by the recordkeeping rule:  Covered Industries.

In order to post to the website, you’ll need two separate accounts.  First is an account with the Injury Tracking Application website.  The other, new as of October 2022, you’ll have to have an account at Login.gov, a secure website the federal government uses for many different applications.   You need to make sure you use the same email address for both so that the records can be connected.

Information can be manually uploaded, uploaded via a CSV file (available as a template from the OSHA ITA website), or transmit it electronically through an API.

If your company has multiple locations, or establishments as they are referred to, you need to report for each establishment, but can use the same ITA account to do it.  A third party can help do this for you, but accuracy and completeness of data is still your company’s responsibility.

Even if you have 0 recordables, you still need to report, and if you miss the March 2 deadline, you can still submit at any time of the year.  Just be aware you’re not compliant until you do.  If you submit early and find out there was an injury last year that became recordable, they would like for you to update the information, but it’s not required.

What’s Recordable, What’s Not?

If you have questions or need help in determining what’s recordable and what’s not, iSi can help.  We can advise on a case-by-case basis, and we have conducted presentations that cover some of the trickier examples that we can provide through our training program.  Contact us for pricing on either of those.

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Chemical Hygiene Plan: What You Need To Know

Chemical Hygiene Plan: What You Need To Know

What is a chemical hygiene plan?

A Chemical Hygiene Plan (CHP) is a written document required by the Occupational Safety and Health Administration (OSHA). It outlines specific safety procedures that workers must follow while working with hazardous chemicals, in order to minimize risk of exposure to potentially dangerous substances.

The CHP covers topics such as personal protective equipment, engineering controls, safe work practices, health and hygiene, medical surveillance, chemical labeling and storage, spill response plans, hazardous waste disposal and more. It is important to have a comprehensive and up-to-date CHP in place as it ensures that workers are aware of the hazards associated with their job duties and how to protect themselves against them.

What are the objectives of a chemical hygiene plan?

A Chemical Hygiene Plan (CHP) is an organized and comprehensive plan designed to protect laboratory workers from the potential health hazards posed by hazardous chemicals in the work environment. It outlines safety protocols for working with hazardous materials, identifies any special procedures or precautions that need to be taken when dealing with them, and provides guidance on how to safely handle common laboratory operations such as waste disposal and emergency response.

A CHP establishes the safety procedures that must be followed in order to ensure that laboratory personnel are adequately protected from hazardous chemical exposure, while also ensuring compliance with relevant laws and regulations.

The main objectives of a CHP include minimizing employee exposure to hazardous chemicals, reducing the potential for accidental spills or exposures, identifying appropriate personal protective equipment (PPE) for each type of operation, and providing training for personnel on the appropriate use of hazardous materials.

What should a chemical hygiene plan include?

A CHP should include a written policy outlining the responsibilities of personnel, recommendation on protective clothing and equipment, training requirements for workers, methods for labeling and storing chemicals, emergency procedures in case of spills or other incidents, and equipment maintenance protocols.

In addition, the CHP should document any hazardous chemical exposures that have occurred. By following these guidelines, workplaces can ensure that personnel are adequately protected from exposure to hazardous substances and minimize the risk of injury or illness due to chemical use.

What does a chemical hygiene officer do?

A Chemical Hygiene Officer (CHO) is an important role in any organization that works with hazardous chemicals. Their primary responsibility is to ensure the safety of personnel and protect the environment by designing and implementing chemical safety programs, policies, standards, and procedures.

The chemical hygiene officers also oversee compliance with all applicable laws related to health and safety in the workplace. They are responsible for monitoring chemical use, storage, and disposal; performing safety audits; conducting safety training; and providing expert advice on safe chemical handling practices.

In addition to these core duties, the CHO may coordinate with other departments such as Human Resources and Environmental Health & Safety in order to ensure compliance across the organization and present health and safety requirements.

What is the OSHA chemical safety plan?

The OSHA Chemical Safety Plan is a set of steps that employers must take to ensure the safety and health of their workers, as well as the workplace itself, when handling hazardous chemicals. It outlines the preventive measures that employers should implement in order to protect employees from exposure to hazardous materials.

This plan includes training for workers on proper handling and storage of chemicals; personal protective equipment (PPE); emergency response plans; and other safety measures. Proper implementation of the OSHA Chemical Safety Plan can help to reduce incidents and injuries caused by hazardous chemicals, as well as ensure a safe environment for all employees. The plan also serves to keep businesses compliant with federal regulations set forth by the Occupational Safety and Health Administration.

What is the OSHA laboratory standard for chemical exposure?

The Occupational Safety and Health Administration (OSHA) sets a standard for chemical exposure and protective laboratory practices in the workplace. This includes keeping employees safe from any kind of hazardous chemical, whether it be by inhalation, ingestion or skin contact. OSHA enforces this standard through its Hazard Communication Standard, which requires employers to provide workers with information about the chemicals they use, including proper storage, labeling and handling instructions.

The OSHA lab standard also sets limits on the amount of exposure an employee can have to certain chemicals, ensuring that workers remain safe from any potential harm. To make sure these standards are met, employers must provide adequate training and ensure that employees follow safety protocols when working with hazardous materials.

What are the 10 steps to chemical safety?

Chemical safety is an important part of any workplace environment. Knowing and understanding the 10 steps to chemical safety can help ensure that all employees are safe while handling hazardous materials.

  1. The first step to chemical safety is to identify potential hazards by reviewing the Material Safety Data Sheet (MSDS). The MSDS includes detailed information about the properties of a given chemical, including its health hazards, protective measures, and emergency response information.

  2. The second step is to use the right personal protective equipment (PPE) when working with hazardous materials. This may include safety glasses, respirators, gloves, lab coats, and other items that are necessary for safe handling of chemicals.

  3. Thirdly, it’s important to keep all containers of chemicals labeled and sealed properly. Labels should include the name of the chemical, concentration, date prepared, and appropriate hazard warnings.

  4. The fourth step is to practice good housekeeping in the lab or work area by keeping all areas clean and free from debris that might contaminate products. All spilled materials must be removed from the work area as soon as possible.

  5. The fifth step is to make sure that all employees are trained on the proper handling of chemicals in their work area. This includes understanding how to use protective equipment and safety measures to reduce exposure.

  6. The sixth step is to provide good ventilation in the lab or work area. Poor ventilation can increase exposure to hazardous materials, so it’s important to keep areas well-ventilated.

  7. Seventhly, emergency equipment should be readily available in case of an incident. This includes items like fire extinguishers, eye wash stations, and spill kits to contain hazardous materials.

  8. The eighth step is to create a culture of safety by ensuring that all employees are aware of the dangers associated with handling hazardous materials. All workers should understand the proper safety procedures, and regular training should be conducted to reinforce these procedures.

  9. The ninth step is to monitor employee exposure levels by providing personal protective equipment and conducting periodic air quality tests. This will help ensure that all workers remain safe while working with hazardous materials.

  10. Finally, the tenth step is to document all safety measures taken in a detailed hazard assessment report. This report should include a description of the potential hazard, control measures taken to limit exposure, and any additional safety precautions that were implemented.

By following these 10 steps to chemical safety, employers can ensure that their employees remain safe while handling hazardous materials in the workplace.

What are 4 hazardous chemicals?

Chemical safety is an important topic in any work environment, as exposure to hazardous chemicals can have serious effects on a person’s health and wellbeing. To protect workers and customers alike, it is essential that businesses identify the potential risks associated with their products or services, and take steps to minimize them. One way to do this is by identifying the four main classes of hazardous chemicals: corrosives, flammables, oxidizers, and toxic materials.

Corrosives are substances that can cause severe damage to the skin or eyes upon contact. These can include acids, alkalis, and other caustic materials. Flammables are extremely combustible liquids or gases that can ignite easily and burn rapidly under certain conditions. Oxidizers are substances that can cause rapid or spontaneous combustion when they come into contact with flammable materials. Finally, toxic materials are substances that can cause chronic or acute health problems if ingested, inhaled, or absorbed through the skin.

What are the five rules of chemical safety?

Chemical safety is a critical part of all standard operating procedures. It helps ensure the safety and health of personnel, as well as protects equipment and materials from potential hazards. There are five basic rules of chemical safety that must be followed in order to minimize risk and maintain a safe working environment.

  • Read the labels and material safety data sheets (MSDSs) for any chemicals that you plan to use. Be sure to understand the hazards of each chemical as well as the proper disposal or storage requirements.
  • Wear the appropriate protective clothing and equipment when working with dangerous chemicals. This includes gloves, goggles, and an apron or lab coat. Additionally, it is important to ensure that your work area is well-ventilated.
  • Never mix chemicals, even if they are similar. This can lead to unpredictable and potentially hazardous reactions.
  • Store chemicals properly in order to prevent spills or other accidents. Always follow the manufacturers’ instructions regarding recommended storage temperatures and containers.
  • Always clean up any spills immediately and properly dispose of all chemicals after use. This includes cleaning any equipment or surfaces that may have been exposed to hazardous materials.

Adhering to these five basic rules of chemical safety can help ensure a safe working environment for everyone in your laboratory.

What is a common hazardous chemical in healthcare?

Healthcare workers are exposed to all kinds of hazardous substances. These can range from pesticides used in the garden, to chemical cleaners used in bathrooms and kitchens, to toxic drugs and medicines. One of the most common hazardous chemicals found in healthcare is formaldehyde.

Formaldehyde is a colorless, odorless gas that has many industrial uses such as preserving specimens for research laboratories and embalming. It can also be found in some furniture, carpets, cleaning supplies and even cosmetics.

In healthcare settings, formaldehyde is often used as a disinfectant to prevent the spread of infections. Exposure to high levels of formaldehyde can cause respiratory irritation, headaches and nausea. Healthcare workers must take extra precautions to protect themselves from exposure by wearing personal protective equipment such as respirators, eye protection and gloves.

Additionally, employers should use ventilation systems to reduce exposure levels in the workplace. By following these simple steps, healthcare workers can help protect themselves from dangerous chemical hazards and potentially hazardous chemicals.

Another hazardous chemical that is often found in healthcare is ethylene oxide. Ethylene oxide is a colorless gas with a sweet odor and bitter taste. It is used in healthcare as a sterilizing agent for medical equipment and supplies.

However, exposure to high levels of ethylene oxide can cause skin irritation, headaches and dizziness. Healthcare workers must take precautions to protect themselves from any potential health risks associated with this chemical by wearing protective clothing such as respirators, masks and gloves when handling ethylene oxide. Proper chemical hygiene training and a chemical hygiene plan are crucial for employee safety.

What are 5 top laboratory hazards?

Laboratories are places for experimentation and research, but they can also be dangerous. Understanding the potential hazards that exist in a laboratory is essential to ensure safety. The five top laboratory hazards include chemical exposure, fire, radiation, biological agents, and electrical shock.

Chemical exposure is a significant hazard in any laboratory situation due to the use of hazardous materials such as acids, solvents, and other hazardous compounds. It is important to wear the appropriate protective gear such as safety glasses, gloves, and an apron when working with chemicals to reduce potential exposure.

Fire can cause serious damage in any laboratory setting due to the presence of volatile materials. Laboratories should be equipped with fire extinguishers and personnel should be trained on how to use them. In addition, flammable materials should be stored in proper containers and away from direct sources of heat.

Radiation is a potential hazard in laboratories that use radioactive materials or radiation-generating devices such as X-ray machines. It is important for personnel using these devices to wear protective gear such as lead aprons and glasses, and follow safety protocols.

Biological agents can also be a hazard in certain laboratory settings. It is important to wear protective clothing when working with biological materials and to practice proper hygiene such as washing hands regularly and avoiding contact with eyes, nose, or mouth. Additionally, it’s important to dispose of infectious waste properly and use safe disposal methods for sharp objects such as needles.

What are the 10 lab safety rules?

It is important to understand the 10 lab safety rules in order to ensure a safe and productive laboratory environment. The 10 lab safety rules are:

  1. Wear proper protective gear – including clothing, eye protection, and gloves – whenever handling chemicals or working with equipment that generates heat, sparks, and open flames.
  2. Read labels carefully before using any chemical or equipment.
  3. Follow the instructions provided and adhere to safety protocols in the lab and laboratory safety manual.
  4. Keep chemicals away from sources of heat, ignition, and open flames.
  5. Know how to properly handle and dispose of hazardous materials according to safety protocol.
  6. Know the location of emergency exits, fire extinguishers, spill kits, eyewash stations, and first aid kits.
  7. Never work alone in the lab; always ensure that someone else is present in case of an emergency.
  8. Do not touch or taste any chemicals without permission from a qualified supervisor.
  9. Report any accidents or spills to your supervisor immediately.
  10. Clean up all equipment and materials after use and before leaving the laboratory with prior approval.

Adhering to these 10 lab safety rules is essential for ensuring a safe and productive workplace in any laboratory setting. Always be aware of the potential hazards and use caution when handling hazardous materials or working with dangerous equipment.

How often should a workplace or laboratory chemical inventory conducted?

It is important to conduct a workplace or laboratory chemical inventory at least once a year. This helps to ensure that all chemicals stored onsite are accounted for, and any expired or unwanted materials can be safely disposed of. Additionally, employers should update the list as soon as a new container of hazardous material is received.

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OSHA Considering Changes and Updates to the PSM Standard

OSHA Considering Changes and Updates to the PSM Standard

OSHA Considering Changes and Updates to the PSM Standard

 

OSHA has been accepting comments on several proposed changes to its Process Safety Management, or PSM standard.

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 hasn’t been updated since its creation in 1992.  OSHA has been reevaluating PSM, and EPA has been similarly been reevaluating their Risk Management Plan, or RMP standard since the 2013 West, Texas fertilizer storage facility explosion.  Just like the difference between OSHA and EPA, PSM is meant to protect workers while RMP is meant to protect the environment.

Potential changes to PSM could include:

  • Clarifying the exemption for atmospheric storage tanks;
  • Strengthening employee participation and stop work authority;
  • Requiring the development of written procedures for all elements specified in the standard, identification of records required by the standard, and a records retention policy (previously referred to as “Written PSM Management Systems”);
  • Including oil-well and gas-well drilling and servicing as part of the standard and resuming enforcement for oil and gas production facilities;
  • Expanding coverage and requirements for reactive chemical hazards;
  • Updating and expanding the list of highly hazardous chemicals in Appendix A;
  • Requiring continuous updating of collected information (paragraph (d));
  • Requiring formal resolution of Process Hazard Analysis team recommendations that are not utilized;
  • Better defining what critical equipment means, what equipment deficiencies are, and expanding paragraph (j) to cover the mechanical integrity of critical equipment;
  • Clarifying the scope of the retail facilities exemption;
  • Defining the limits of a PSM-covered process;
  • Better defining recognized and generally accepted as good engineering practices (RAGAGEP) and requiring evaluations of any updates to them;
  • Requiring safer technology and alternatives analysis;
  • Requiring consideration of natural disasters and extreme temperatures;
  • Amending paragraph (k) of the Explosives and Blasting Agents Standard to cover dismantling and disposal of explosives and pyrotechnics;
  • Clarifying that paragraph (l) covers organizational changes;
  • Amending paragraph (m) to require root cause analysis;
  • Requiring coordination of emergency planning with local emergency-response authorities;
  • Requiring third-party compliance audits; and,
  • Including requirements for employers to develop a system for periodic review of and necessary revisions to their PSM management systems (previously referred to as “Evaluation and Corrective Action”).

This action is currently in the comments stage, and stakeholder meetings were held in October 2022 with comments accepted through mid-November 2022.  We will keep you updated when anything final is published.

Do you need help with PSM?  Does this apply to you?  iSi can help!  Contact us today for more information.

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Hazmat Employee Training Requirements Every Employer Must Know

Hazmat Employee Training Requirements Every Employer Must Know

What does HAZMAT stand for?

Hazmat stands for HAZardous MATerials, and is a term commonly used to refer to materials that could be dangerous to people, the environment or property. These types of materials may include explosives, flammable liquids, radioactive substances and infectious agents.

It is important for individuals who handle, dispose, and transport hazardous materials to have the proper training and certifications in order to ensure the safety of themselves, others and the environment. Hazmat personnel must also be aware of any applicable laws regarding the transportation and handling of haz materials in order to stay compliant with regulations.

The term is used across multiple industries, including healthcare, construction, manufacturing and mining. The HAZMAT designation can help save lives and reduce potential damage from hazardous materials.

What defines a hazmat employee?

A hazmat employee is any person who is responsible for the transport, storage, and handling of hazardous materials in accordance with all applicable laws and regulations. Hazmat employees must be trained to recognize and respond to hazards posed by hazardous materials they may encounter on the job.

They must also possess knowledge about safe practices related to identification, packaging, labeling, documentation, shipping papers, and emergency response. In order to ensure safety, hazmat employees must pass tests regarding hazardous materials regulations and complete refresher courses on a regular basis.

Furthermore, they are expected to follow all applicable laws and regulations to the letter in order to protect public health and the environment. By having an accurate understanding of what it takes to be a responsible hazmat employee, businesses can ensure that their operations remain safe and in compliance.

Hazmat Training Requirements:

Hazmat training is an important part of safety and awareness for anyone who works with potentially hazardous materials or substances. The US Department of Transportation (DOT) requires that all hazmat personnel receive specialized hazardous materials transportation safety training before they are allowed to handle such materials, as well as periodic retraining every three years.

This includes general awareness/familiarization training, transporting hazardous material training, in depth security training, safety training, function-specific training, security training and in-depth safety training. All employees with hazardous materials responsibilities must have the necessary knowledge and skills to safely handle these materials and be knowledgeable about the applicable regulations.

Hazardous Materials Handler certification is also required for any personnel involved in packaging, labeling, marking or loading of hazardous material shipments.

What are the required categories of hazmat employee training?

The four required categories of hazardous materials employee training include: General Awareness/Familiarization, Function-Specific Training, Safety Training and Security Awareness. All employees who handle hazmat must understand basic safety rules and procedures related to the hazardous materials they handle, as well as emergency response protocols that could arise should an incident occur.

Additionally, personnel involved in loading and unloading operations must understand applicable regulations to ensure safe, secure and compliant operations. Function-specific training is also mandatory for employees who perform activities related to the identification, packaging, labeling, marking, handling, storage and transportation of hazardous materials.

How often do hazmat employees need to be trained?

Hazmat employees are required to complete initial training within 90 days of hire and annually thereafter. Initial training must include topics such as hazard recognition, basic containment principles, emergency response, proper handling and storage of haz materials, and personal protection equipment.

Hazmat employees should also receive additional training whenever there is a change in job duties or when they are exposed to new hazards.

Hazmat Employee Training (49 CFR 172.704)

Hazmat employee training (49 CFR 172.704) is an important part of the hazardous materials transportation regulations mandated by the U.S. Department of Transportation.

Hazmat training must be completed by all employees involved in transporting dangerous goods and hazardous materials, including those who prepare shipments, load/unload, package, mark/label containers or placards, provide emergency response information, and perform any related duties.

Training must include instruction in the applicable regulations, safety precautions, emergency response procedures, how to recognize and respond to haz materials incidents, and other related topics as necessary. Hazardous materials employee training must be provided before initial job assignment and at least once every three years thereafter.

Employers are responsible for ensuring that hazmat employees remain qualified and are knowledgeable about the haz materials they handle. Hazmat employee training is an important factor in ensuring the safe transportation of hazardous materials and preventing accidents related to their transportation.

Is proof of training required?

When it comes to the question of whether proof of training is required for Hazmat Employees, the answer depends on the severity and potential hazards associated with the job. Generally, employers must provide proof that their employees are knowledgeable about hazardous materials regulations and understand how to safely handle haz materials before they can be allowed access to any facilities where hazardous materials may be stored or used.

This proof can take the form of certificate programs, refresher courses, or a written test. Additionally, employers may need to show that their employees have participated in emergency response drills and are knowledgeable about proper procedures for responding to spills and other haz materials incidents. In some cases, additional safety protocols such as wearing personal protective equipment and maintaining adequate ventilation may also be required.

Security Awareness Training (49 CFR 172.704(a)(4))

Security Awareness Training is an important part of any organization’s security plan. As mandated by the Transportation Security Administration (TSA), 49 CFR 172.704(a)(4) requires all personnel who work in regulated environments to complete appropriate training prior to performing their duties.

This training helps ensure that employees are aware of their roles and responsibilities when it comes to safeguarding sensitive information. Additionally, security awareness training helps to ensure that personnel are familiar with the threats and vulnerabilities associated with their role, as well as how to appropriately respond in the event of a breach or other security incident.

This type of safety training is an essential element of any organization’s overall security strategy and should not be overlooked.

The Importance of Hazardous Materials Training

Hazardous materials training is incredibly important for workers who are exposed to hazardous substances. It helps to ensure that they have the right knowledge and understanding of safe and proper methods of handling, transporting, storing, and disposing of such potentially dangerous materials.

Hazardous material trainings can also help prevent accidents or other incidents involving haz materials from occurring by equipping workers with the skills to identify hazardous materials, assess the risks associated with them, and take appropriate steps to mitigate those risks.

Ultimately, hazardous material training is essential for protecting workers and the environment by providing a good understanding of the potential dangers that could be encountered while working with these substances.

It is also important for employers to provide regular hazmaterials trainings in order to stay up-to-date with the latest regulations and safety protocols concerning hazardous materials. By doing so, employers can ensure that their workers are properly informed about how to handle these materials correctly and safely.

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Our team of environmental consultants, safety consultants and industrial hygienists would love to help. Call (316) 264-7050 today!

 

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Mastering the Essential EHS Audit Checklist: A Comprehensive Guide

Mastering the Essential EHS Audit Checklist: A Comprehensive Guide

When it comes to environmental health and safety (EHS) audits, having a comprehensive checklist is essential. Audits are designed to show the effectiveness of an organization’s existing EHS management system as well as identify any areas that need improvement. A good audit will be comprehensive in scope and include elements such as environmental compliance, risk assessment, occupational safety, air quality monitoring, and emergency preparedness.

The challenge for many organizations is creating or finding an EHS audit checklist that covers all the necessary elements. To help get you started, we’ve put together a comprehensive guide to mastering the essential EHS audit checklist. This guide will provide you with everything you need to know about best practices and key components of successful EHS audits.

First, you’ll want to make sure that your EHS audit checklist is aligned with the organization’s goals and objectives. A comprehensive checklist should include all of the basic elements that are required by law or identified within the scope of an organization’s operations. This includes ensuring compliance with national and local environmental regulations, assessing workplace safety risks, monitoring air quality on site, and preparing for emergency situations.

Next, you’ll need to consider how often audits will be conducted. Depending on the size and complexity of the organization’s operations, this could range from once a year to multiple times per year. It may also be necessary to conduct periodic follow-up audits in order to ensure that any changes or improvements made since the last audit are still in place.

Finally, when conducting an audit it’s important to document everything that is found. This includes any potential hazards and exposures, compliance issues, and recommendations for improvement. Having a comprehensive audit report is essential for making sure that all corrective actions are properly implemented and tracked over time.

By following the above steps and having a detailed EHS Audit checklist in place, you can ensure that your organization is meeting all of the necessary standards for environmental health and safety. With the proper preparation and planning, you can have confidence that your audits will yield accurate results and provide you with the actionable insights needed to make improvements where necessary.

EHS Audit Checklist Templates

EHS audit checklists are an invaluable tool for organizations to ensure their health and safety processes are in line with industry standards. They help organizations identify potential risks, areas of improvement, and areas that need additional attention. EHS audit checklist templates provide a consistent structure for conducting audits and allow the organization to easily evaluate compliance across multiple departments and locations.

With the use of these templates, organizations can quickly identify which areas require further action or review. In addition, using an EHS audit checklist template ensures that all essential elements required for a successful safety program are included in the assessment process. This helps to ensure that any issues identified during the audit can be addressed in a timely fashion and prevents any unnecessary delays that could put workers at risk.

Who needs to use a health and safety audit?

A health and safety audit is necessary for any workplace, no matter the size or industry. It is important to make all employees aware of what measures need to be taken to reduce risks in the workplace.

Employers and business owners should use audit findings to ensure that their employees are safe from potential hazards. Additionally, supervisors and managers should also regularly monitor the implementation of safety protocols as part of a comprehensive risk management plan. The ultimate goal is to create an environment where everyone can work productively with minimal risks and hazard exposure. This includes providing appropriate protective gear for all employees as well as have all employees trained on safety policies.

By conducting regular audits, employers not only make sure their workers are well protected but also demonstrate good corporate citizenship towards regulatory authorities. Furthermore, these reviews may help identify areas of improvement so that effective preventive measures can be put in place. In sum, anyone with a stake in the safety and well-being of employees should incorporate health and safety audits into their overall risk management strategy.

EHS Audit Software:

EHS Audit Software is an essential tool for Environmental Health and Safety (EHS) professionals to monitor and ensure compliance with regulations. It automates the auditing process, providing insight into risk areas and helping organizations improve their processes.

EHS Management Software provides a comprehensive interface to facilitate efficient data collection, tracking and reporting of regulatory compliance-related activities. This makes it easier to identify deficiencies in safety protocols, quickly address potential hazards, and take proactive steps to mitigate future risks.

With the help of this software, organizations can ensure that they provide a safe workplace environment for all employees while minimizing both environmental impacts and financial costs associated with non-compliance.

EHS Audit Management Software Benefits

EHS Audit Management Software Benefits provides organizations with powerful tools to streamline their environmental, health and safety auditing processes. It helps them save time and resources while ensuring compliance with local regulations, industry standards, and best practices.

The software allows for automatic scheduling of audits and tracking of results, which can help identify gaps in safety protocols more quickly. This ultimately helps to reduce the risk of accidents, environmental damage, and costly fines. With centralized data storage and reporting capabilities, it also enables organizations to track their compliance progress over time, enabling them to continually strive for excellence in safety.

EHS Audit Management Software Benefits is a powerful tool that can help organizations protect their employees, customers, and environment while ensuring compliance with all relevant regulations.

Pre-Audit Phase

The Pre-EHS Audit Phase or audit planning is an important part of the overall Environmental, Health & Safety (EHS) audit process. During this phase, a company will assess its current EHS operations and compliance in order to identify any areas that may present possible risks or noncompliance issues.

This helps ensure the organization meets all applicable regulations and safety requirements, and helps reduce potential liability risks when an EHS auditor arrives. During the Pre-EHS Audit Phase, organizations often review their compliance records and processes, evaluate current systems, develop new procedures and protocols as needed, and produce a detailed report of findings.

This helps ensure the organization is properly prepared for the actual EHS audit itself. The Pre-EHS Audit Phase is essential to ensuring organizational safety and compliance with all applicable laws and regulations.

An effective Pre-EHS Audit Phase also helps an organization identify potential risks and areas of improvement before the actual audit begins. Through this assessment, organizations can develop specific strategies to improve their safety and compliance operations going forward, as well as develop plans for problems that may arise during the EHS audit itself.

What should be included in a health and safety audit checklist?

A health and safety audit checklist should include items that are relevant to the particular work environment being audited. This can vary depending on whether the workplace is an office, factory, warehouse, or other premises.

Generally, items that should be included in a health and safety audit checklist would be physical hazards such as trip/slip risks, poor lighting conditions, inadequate ventilation, and hazardous substances. Additionally, potential health risks such as noise levels, temperature/humidity levels, ergonomics, and the availability of safety wear should be considered.

All employees should also have access to first-aid kits and emergency procedures in case of accidents or incidents. Finally, employers should consider if necessary protective measures are in place to protect employees from violence or harassment. By including these items in a health and safety audit checklist, employers can ensure that their workplace is safe and compliant with relevant regulations.

What is a health and safety audit?

A health and safety audit is an independent assessment of a workplace to assess how well it complies with relevant laws, regulations, and industry standards. It evaluates existing practices and procedures in the workplace to make sure they are working properly and efficiently.

The aim of a health and safety audit is to identify any potential hazards or risks that could lead to injury or illness, as well as any areas where improvement is needed. A health and safety audit can help organizations meet their legal obligations and ensure the workplace remains safe and healthy for everyone.

It can also provide important data that can be used to develop effective strategies to reduce accidents, incidents, and other risks in the workplace.

Deficiencies and Corrective Actions

EHS corrective actions are an important part of creating a safe and healthy working environment. These corrective steps involve identifying workplace health and safety hazards, addressing the risks associated with those hazards, and taking steps to eliminate or mitigate any potential harm to workers and the environment caused by these hazards.

Corrective actions can include changing procedures, providing additional training, implementing new rules or regulations, or carrying out engineering modifications to equipment and machinery.

It’s important for employers to take corrective steps in order to protect their workforce, comply with regulations, and ensure a safe working environment. By taking corrective actions, employers can reduce the risk of injury and illness caused by workplace hazards.

Need Help?

Our team of experts can help you with whatever compliance issues you may be facing. Whether it is understanding the complexities of a given regulation or recognizing where your company needs to improve, we have the necessary skills and experience to provide assistance. We will take the time to understand your unique needs and develop tailored solutions that address those needs. For facilities looking for help navigating the often perplexing regulatory landscape, contact us today!

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Health and Safety Consultants

Health and Safety Consultants

Consultants provide essential services to businesses, organizations, and individuals. They help ensure workplace safety by providing advice on health and safety regulations and policies, developing risk assessments, inspecting equipment or premises for safety hazards, conducting staff training sessions and developing emergency response plans.

These are knowledgeable in areas such as occupational health and safety regulation compliance, industrial hygiene principles, ergonomics, hazardous material management, fire protection engineering, accident investigations, construction site hazard recognition and more. Their expertise helps mitigate the risk of injury or illness within a work environment.

Additionally they can assist organizations in meeting all legal requirements for health & safety legislation in their respective countries or regions. Ultimately their work helps protect workers from potential hazards that may arise from working conditions.

Furthermore, safety consultants and safety professionals can provide a valuable service to businesses looking to expand or introduce new processes or practices. They can provide advice on the best practices for their particular industry, as well as how to best implement them with minimal risk of disruption to the operations.

Ultimately, this helps make sure that employees are working in an environment where their safety is paramount. Engaging with a qualified Health and Safety Consultant is essential for ensuring that an organization meets its legal obligations in terms of health and safety regulations and requirements.

Additionally, it allows companies to minimize risks, create a safe work environment for their staff, and ultimately protect their reputation should an incident occur.

OSHA Compliance Solutions

OSHA Compliance Solutions is a comprehensive suite of tools and services designed to help businesses stay in compliance with all applicable Occupational Safety and Health Administration (OSHA) regulations. The service includes access to the most up-to-date federal and state information, as well as an online library of safety training materials, safety programs, safety manuals, instructional videos, and other resources for your safety manager to use.

With these tools, businesses can easily create compliant work environments that protect employees from safety risks and injury. Additionally, OSHA Compliance Solutions can recommend a safety consulting company in which offers consulting services and technical assistance to further support companies’ compliance efforts.

These services include onsite visits for inspections or consultations, as well as identify workplace hazards and provide recommendations for corrective action plans when necessary. Your company will also be presented safety data sheets from these experienced safety professionals. OSHA Compliance Solutions helps businesses ensure their workplaces are safe, efficient, and in compliance with federal and regulations.

OSHA Training Solutions

OSHA Training Solutions is an industry leader in occupational safety and health training. With expertise on a wide range of topics related to workplace safety, OSHA Training Solutions provides comprehensive training courses, both online and in-person, to help employers meet their safety and health compliance requirements.

Their courses are designed to cover topics such as ergonomics, fall protection, hazardous materials handling, risk assessment, health programs, machine guarding, fire safety and more. They also offer a vast selection of online resources that provide easy access to up-to-date information on the ever changing regulations governing workplace safety. OSHA Training Solutions is committed to providing outstanding customer service and quality training solutions to ensure that workers stay safe while on the job.

With their commitment to excellence and dedication to helping employers protect their workforce from injury or illness, OSHA Training Solutions has become an industry leader in occupational safety and health training.

OSHA Compliance Evaluations

OSHA Compliance Evaluations are conducted in order to assess the safety and health conditions of a workplace and ensure that it is compliant with federal standards. During such evaluations, an inspector will look for potential hazards review company policies and procedures, inspect work areas, and verify compliance with OSHA regulations.

These evaluations also serve as an opportunity for employers to address any existing or potential safety risks before they become larger issues. Ultimately, OSHA Compliance Evaluations make workplaces safer places by identifying and preventing potentially dangerous situations.

Additionally, these evaluations can help employers save costs associated with employee injury or illness due to unsafe working conditions. By conducting assessments regularly, companies can protect the health and well-being of their workers while also avoiding violations of regulatory standards.

OSHA Inspection Guidance

The Occupational Safety and Health Administration (OSHA) provides inspection guidance to ensure compliance with federal safety standards. During OSHA inspections, OSHA inspectors conduct workplace inspections to assess compliance with safety regulations and identify any potential hazards that could cause harm to workers.

Inspectors may also speak with employers and employees during the inspection process in order to gather more information on working conditions. The inspector will then issue a report which includes recommendations for improvements or corrections based on their findings, along with a citation of violations if any were found. Employers must take the necessary steps to address the concerns raised in the report in order to come into full compliance with all applicable regulations.

By providing timely guidance and enforcement, OSHA helps keep workplaces safe from injury and illness, protecting both employers and employees.

Written OSHA Program Preparation

Written OSHA Program Preparation is an important part of any workplace safety program. It involves the development and implementation of policies and procedures for keeping workers safe from potential hazards. This includes identifying and addressing potential safety issues, training employees on safe practices, documenting all safety measures, and regularly auditing the system to ensure amenability with federal regulations. Taking these proactive steps helps to protect workers and create a safer work environment.

By setting up an effective written OSHA program, employers can ensure that their workplace is compliant with all applicable laws and regulations, while also protecting the safety and wellbeing of their employees. Written programs provide a roadmap for achieving workplace safety goals as well as creating an environment where employees understand the risks associated with their work and feel empowered to take action for protecting themselves and their colleagues.

Safety Data Sheet Preparation

A Safety Data Sheet (SDS) is a key document required by all employers to ensure the safety of workers in hazardous working conditions. SDSs are prepared to provide information about the properties of a particular substance or mixture, including its health and safety hazards, protective measures for handling, storing, using and disposing of it safely.

SDSs also include details on how to respond in case of an emergency involving the product. Preparation of SDSs requires knowledge of hazardous substances as well as knowledge of composition, toxicology and occupational health. Since many hazardous materials can exist in a number of different forms, it is important to ensure that the SDS accurately reflects the particular product’s characteristics. Furthermore, information must be regularly updated in line with changes in legislation and any new or revised hazard assessment data.

Health and Safety Program (HSP) Development

Health and Safety Program (HSP) Development is a comprehensive process that involves identifying potential risks, developing strategies to reduce risks and implementing those strategies in the workplace. A successful HSP requires proper planning, training, assessment and reporting of safety issues. The goal of HSP development is to protect workers from injury or illness associated with their job duties.

Emergency Response Plans

Emergency response plans are important to have in place for any organization, as they help to outline the steps that should be taken in the event of an emergency. These plans should include information about how to respond and evacuate a building safely, who is responsible for different aspects of the plan, and how to contact emergency services. This response plans should also consider potential risks, such as natural disasters or hazardous materials spills, and outline procedures for responding effectively.

Having a well-developed emergency response plan helps ensure employees are safe during an emergency situation, while also preventing costly damages if an incident occurs. Additionally, proper training on these plans allows staff members to become familiar with their roles so they can act quickly in the face of danger.

On-Site Health and Safety Management

On-site health and safety management is an essential part of any successful business. Effective management of workplace safety can help reduce risks, minimize injury and illness, protect employees’ rights to a safe work environment, and ensure that businesses meet all applicable safety regulations.

An effective on-site health and safety management system should include procedures for identifying hazards in the workplace, setting standards for worker protection, providing training for workers on how to safely conduct their job duties, responding quickly to reported or observed unsafe conditions or practices, conducting periodic inspections of the facility for potential hazards, and maintaining records documenting compliance with OSHA regulations.

LOTO Procedure Development

LOTO (Lock Out/Tag Out) Procedure Development is an essential element of workplace safety. Properly designed and implemented LOTO Procedures help to ensure that hazardous sources of energy are effectively isolated from equipment, thus preventing potential injuries or damages.

When creating a LOTO Procedure, it is important to accurately identify all potentially hazardous sources of energy, determine the proper type of lockout device needed for each source, and develop step-by-step instructions on how to properly de-energize and lock out the machine. Additionally, procedures should be regularly reviewed and updated as necessary in order to ensure they remain up-to-date and effective.

By following these steps in the development process, businesses can greatly reduce their risk exposure while also protecting their employees from potential hazards.

For more detailed information, businesses should consult OSHA regulations on LOTO Procedure Development as well as their own corporate safety policies. With the proper development and implementation of LOTO Procedures, businesses can ensure a safe and secure workplace environment while also adhering to all relevant safety regulations.

By investing in the proper protocols and procedures upfront, businesses can make sure that they are providing their employees with the necessary protection against hazardous energy sources. This is an important step toward ensuring a safe work environment for everyone involved.

Need Help?

Our team of experts can help you with whatever compliance issues you may be facing. Whether it is understanding the complexities of a given regulation or recognizing where your company needs to improve, we have the necessary skills and experience to provide assistance. We will take the time to understand your unique needs and develop tailored solutions that address those needs. For facilites looking for help navigating the often perplexing regulatory landscape, contact us today!

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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?

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.

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Fit Testing Questions Answered

Fit Testing Questions Answered

Once you conduct an evaluation to determine what type of respirator your workers will be required to use to protect them from the contaminants around them (that is, what type, Assigned Protection Factor (APF) needed, what filters and/or cartridges are required, etc.), there are three general steps that come next: a medical evaluation to ensure they’re medically capable of wearing one, fit testing to determine which size most comfortably and accurately fits, and training.  In this blog, we dive into the fit testing side.

Respirator fit testing is conducted on tight-fitting respirators to make sure the respirator gets a good seal on the employee’s face so that no contaminants will leak into the mask.  They may not always be the most comfortable or convenient things to wear, but fit testing finds a balance of comfort and protection at the same time.

Qualitative or Quantitative?  What’s the Difference?

Fit-testing methods are referred to as qualitative or quantitative.

In qualitative fit-testing, once the person being fit tested has his/her mask on, the tester introduces items such as saccharine, Bittrex, banana oil or irritant smoke near the mask to see if the person can smell or sense it.  This method relies on the worker’s ability to sense odor or irritants. NIOSH currently doesn’t recommend irritant smoke for fit-testing.  Qualitative fit testing is only for half-face, full-face and N95 filtering facepiece respirators that have an APF of 10.  An APF is the level of protection the respirator will provide if it’s functioning and wore correctly.  For example, an APF of 10 means the user can expect to inhale no more than one tenth of the contaminant present. Qualitative fit-testing is easy, fast and fairly inexpensive.  It’s considered to be only a pass or fail type of test.

Quantitative respirator fit-testing uses a machine to measure pressure loss inside the mask or to count quantities of particles to calculate a fit factor.  Quantitative testing is considered more accurate than qualitative fit-testing.  Quantitative fit-testing must be conducted for respirators requiring an APF over 10.  Full-face tight fitting respirators that are quantitatively tested have an APF of 50.  An APF of 50 means the user can expect to inhale no more than one fiftieth of the contaminant present.

​When Do I Need to Fit-Test Someone?

Employers are to ensure employees wearing tight-fitting facepiece respirators are fit-tested:

  1. Before use
  2. Whenever a different respiratory facepiece is used (size, model, make, style)
  3. Annually

Why is Fit-Testing Required Each Year?

A study published by NIOSH has affirmed the need for OSHA’s annual requirement for fit-testing for filtering facepiece respirators and other tight-fitting respirators.

In its study, NIOSH followed 229 subjects over three years’ time, making fit and physical characteristic measurements every 6 months. It was found that after one year, 10% of the subjects had changes in fit. In two years it was 20%, and in the third year, it was up to 26%. OSHA’s intended threshold for fit changes, when it made its rules in 1998, was 7% annually.

NIOSH also found that subjects who had lost 20 or more pounds had respirator fit changes. The greater the weight loss, the higher the chance that the respirator fit changed. Thus, NIOSH recommends those persons who lose 20 or more pounds get priority fit-test scheduling, even it is less than a year since their last fit-test.

In addition to weight loss and gain, other events such as dental changes, facial scarring and cosmetic surgery can affect respirator fit as well.

Note: NIOSH’s study can be found at: https://blogs.cdc.gov/niosh-science-blog/2016/01/05/fit-testing/

What Difference Does Respirator Brand Make in Fit Testing?

Different brands also fit differently, so a size a worker may wear in one mask may not be the same size in another brand.  If the person wears glasses, hearing protection or other items around their head during the job, they must wear them during the fit test.

What Facial Hair is Acceptable in a Fit-Test?

Beards and facial hair on men are back in style, but beards and respirators do not get along.  Certain kinds and lengths of facial hair including beards, sideburns, some mustaches, and even a day or two of stubble can interfere with the seal.  According to NIOSH, presence of facial hair under the seal causes 20 to 100 times more leakage.  Gases, vapors and particles will take the path of least resistance and will flow right through the hair into the mask and into the lungs.

Our Physician is Booked Now, Can I Go Ahead and Do the Fit Test Before I Get My Respirator Physical?

No!  Respirator physicals (medical evaluations) need to be done before the fit test to ensure the person getting tested is even medically qualified to wear one.  Wearing a respirator can put a strain on the heart and lungs and it is very important that an employee has been evaluated by a medical professional to prevent causing any damage to the employee.

How Often is Respirator Training Required?

Respiratory protection training is required ANNUALLY, that is, within 12 months.  Doing this training around the same time as the physical and the fit testing can help reinforce proper care techniques for the respirator.  This training should cover how to properly don (put on) and doff (take off) them, their limitations and capabilities, why a respirator is needed, how to use them in an emergency or when they malfunction, how to inspect and remove the seals, how to clean and store it properly, how to recognize medical signs and symptoms that may limit or prevent its effective use, and the general requirements of the respiratory protection standard.

Additional training shall be conducted if there are any changes in your workplace, changes in respirator that would make previous training obsolete and when a worker’s actions show additional training is required to ensure their safe use.

What Documentation Do I Need to Keep?

Once you’ve had someone fit tested, you need to ensure you maintain records of the fit test.  The documentation needs to include:

  • The name of the person tested,
  • Type of test conducted
  • Specific make, model, style and size of respirator tested
  • Date of the test
  • Pass/fail results for qualitative fit testing, or the fit factor and strip chart recording from a quantitative fit test
  • A written copy of your Respirator Protection Program

Where Can I Find the Requirements for Fit-Testing? 

OSHA governs the usage of respirators and sets forth its standards in 29 CFR 1910.134 for general industry, and for construction, standard 29 CFR 1926.103 references back to the general industry standard, saying its requirements are identical.  The specific protocols and instructions on how to conduct a fit test are in Appendix A of that standard.

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SMETA Audits

SMETA Audits

SMETA AUDIT: What you need to know

What is a Smeta audit?

SMETA or Sedex Members Ethical Trade Audit is the leading global ethical audit and assurance methodology that helps companies to assess their suppliers’ performance against a set of criteria.

It covers labor, health & safety, environmental and ethics standards which are all important for responsible business practices. SMETA audits provide companies with an objective evaluation of supplier operations and highlight any areas for improvement. This helps

What are the 4 pillars of Smeta audit?

  1. Labor Standards

  2. Health and Safety

  3. Business Ethics

  4. Environmental Assessment

The 4-pillar SMETA audit, developed by the Sedex organization, is a globally accepted audit system used to assess a company’s ethical and sustainability practices. It requires organizations to adopt business practices beyond traditional labor standards in order to ensure that their operations are socially responsible.

The two mandatory pillars of the audit are Labor Standards and Health & Safety. Two additional pillars – Business Ethics and Environment – were introduced to further strengthen the social responsibility aspect of the audit.

Business Ethics encompasses areas such as anti-corruption, bribery, data protection, human trafficking prevention, gifts & entertainment and whistleblowing policy. These measures protect companies against unethical practices which can have serious reputational consequences for an organization if left unchecked. Ethical trading initiative and responsible business practice for all company’s is a necessity.

The Environmental pillar focuses on environmental management, renewable energy, efficient use of resources and waste minimization. Companies must demonstrate that they are taking all possible steps to minimize their impact on the environment and meet the expectations of society such as implementing sustainable business practices.

The 4-pillar SMETA audit is an effective way for companies to review their current practices around labor standards, health & safety, business ethics and environment. It provides a comprehensive view into a company’s social responsibility policies ensuring that operations are ethical, responsible and sustainable in the long run.

By completing this audit successfully, organizations can ensure that their products or services adhere to high levels of quality while also meeting sustainability benchmarks. This helps them build trust with partners, customers and other stakeholders while demonstrating corporate social responsibility.

How long is a Smeta audit valid for?

The SMETA audit report is a valuable tool for businesses to assess their ethical practices and ensure that their performance meets the highest standards. However, the validity of the audit report can vary depending on what timeframe the client decides upon.

Most clients opt for an annual audit cycle and set one year as the period of validity for the SMETA audit report.

How do I get a SMETA audit?

If you’re looking to complete a SMETA audit, the first step is registering and having an active account on the Sedex platform. With the right membership, your business can easily access the resources needed to successfully complete a SMETA audit.

What is the difference between Smeta audits and Sedex?

  1. Sedex is the name of the organization

  2. SMETA is the name of an audit methodology

Sedex’s SMETA audit methodology is widely regarded as the gold standard in ethical supply chain auditing. It is used by Sedex members and their suppliers to help them identify areas for improvement and ensure compliance with local laws, global standards, and corporate responsibility policies.

The audit consists of four sections (Labour Standards; Health & Safety; Environment; Business Ethics) that together provide a comprehensive view of supplier operations. Through SMETA audits, companies can identify and address potential risks in their supply chainsa as well as global supply chains quickly and efficiently.

By addressing any issues they find in their audits, companies can demonstrate commitment to responsible sourcing practices and mitigate business risk.

SMETA audits are conducted on-site by experienced auditors who assess the performance of suppliers in each of the four sections. During the audit, auditors review documents, interview staff, conduct physical inspections, and observe work practices to provide a comprehensive view of supplier operations. After the audit is complete, Sedex will provide a report that summarizes the findings and recommendations for improvement.

Who can conduct Smeta audit?

A SMETA audit will be conducted by an independent third-party auditor. The auditor will analyze the company’s management systems and practices, to ensure that they adhere to the ETI Base Code and local laws. The auditors will review internal policies, management processes, employee training records, and other documents related to labor rights and standards.

In addition, the auditor will observe activities in the workplace such as working hours, working conditions, fire safety regulations, payment of wages, etc., in order to identify any areas of potential non-compliance with ethical trading standards.

After the audit is complete, a report is generated which includes an assessment of compliance with ETI Base Code requirements. Companies who have passed an independent third-party audit typically can demonstrate that their workforce is protected under international labor rights and standards. This provides a degree of assurance to customers and other stakeholders that the company is committed to ethical trading practices.

The audit process helps companies identify areas for improvement, as well as provides an opportunity to address any malpractices that may exist in their supply chain as well as the global supply chain. It also ensures that companies are held accountable for their labor and work standards, helping them build trust with stakeholders and create a positive public image for the business. Furthermore, the successful completion of a audit can open up new opportunities for companies looking to do business abroad by demonstrating compliance with international labor rights and standards.

Conclusion:

SMETA audits, developed by Sedex Global, have become one of the most widely accepted ethical audit methods in the world. It is a comprehensive auditing system that provides an internationally recognized standard for assessing working practices within your supply chain. SMETA is based on four pillars: labor standards (including human rights), health and safety, environment, and business ethics.

The aim of this audit is to ensure compliance with any applicable laws and regulations as well as industry-accepted best practice standards including those related to CSR performance and sustainability initiatives. The audit helps you identify any potential risks or areas where improvement can be made in order to meet these standards and stay compliant with laws or regulations.

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What Is Compliance Reporting & Why Is It Important?

What Is Compliance Reporting & Why Is It Important?

What is a Compliance Report?

A Compliance Report is a document that details the adherence to laws and regulations in a particular organization or industry. It outlines the measures taken by an entity to ensure that it is in compliance with all applicable rules and regulations. It can include information on audits performed, corrective action taken when violations are found, and the overall effectiveness of an entity’s compliance program. The report can be used by internal stakeholders to assess the company’s level of compliance, as well as by external stakeholders to ensure that the company is meeting all requirements. In the entire compliance process, compliance Reports are essential for any business or industry seeking to protect itself from liability and ensure its operations are compliant with industry best practices.

Regulatory Compliance Reporting vs. Internal Compliance Reporting

Regulatory compliance reporting and internal compliance reporting are both important parts of a business’s operations. Regulatory compliance reporting is the process by which organizations report data to various government agencies and other third parties, while internal compliance reporting is used to track an organization’s own policies and procedures. Regulatory compliance reports are required for certain industries, such as banking, healthcare, and finance, and must adhere to certain government regulations. Internal compliance reports are used within an organization in order to track it’s own internal procedures and ensure that they are being followed.

Both types of reporting can help a business stay organized and on top of their compliance obligations. However, it is important to remember that regulatory compliance reports must always be up-to-date and accurate in order to avoid potential fines or other legal repercussions. Internal compliance reports, while important, are not subject to the same regulations and can be used as a way to ensure that an organization’s policies are being properly followed. A thorough compliance report is important to a successful business, and understanding the differences between them is essential.

Why Compliance Reporting Is Important:

Compliance reporting is an essential part of any modern business. It ensures that organizations are abiding by the laws and regulations in place to protect consumers, workers, investors, and the environment. Compliance reporting allows companies to demonstrate their commitment to safety and sustainability, while also giving them a competitive edge in the marketplace. Additionally, it helps organizations identify potential risks before they become significant issues.

Compliance reports also provide stakeholders with a clear understanding of the company’s operations and performance and can be used to determine whether further action is necessary. Ultimately, compliance reporting helps organizations stay in line with government regulations while ensuring that their reporting practices are ethical and responsible.

What are the different types of compliance reports?

Compliance reports made by a compliance officer are documents that organizations use to document their adherence to regulations and laws. They provide insight into the procedures and processes in place to ensure legal compliance. There are many different types of compliance reports, including financial statement audits, environmental health and safety (EHS) audits, information security assessments, privacy impact assessments, and more.

Depending on the industry or type of organization, there may be additional types of compliance reports that are reviewed and issued. Companies with a well-documented compliance program should make sure that all types of compliance reports are up-to-date and accurate. By doing so, they can minimize the risk of non-compliance and any potential legal penalties.

What industries are often subject to compliance reporting?

Compliance reporting is a requirement for many industries, including but not limited to financial services, healthcare, and government agencies. Financial service providers are typically subject to compliance regulations related to banking and investing practices, while healthcare organizations must adhere to strict laws surrounding patient privacy and security. Government entities have their own set of rules that need to be followed in order to comply with local or federal laws.

All of these industries must adhere to certain standards in order to remain compliant with the law and protect consumer interests. Compliance reporting is also important for companies that handle sensitive data, such as customer information or confidential employee records. By adhering to compliance regulations, businesses can ensure their data is properly protected and not used for any malicious purposes. Additionally, it helps them remain transparent and accountable when it comes to how they use customer information. Compliance reporting is an important part of making sure businesses are operating fairly and ethically.

Benefits of Effective Compliance Reporting

Effective compliance reporting offers many benefits to businesses and organizations. Compliance reporting helps companies stay abreast of regulations in their industry and keep up with the constantly changing legal landscape. Having effectual compliance reporting also ensures that organizations are in line with local, state, and federal laws. It also allows for greater transparency, better communication between management and employees, and improved risk management.

With compliance reporting, businesses are better able to identify areas of risk and then take action accordingly. Additionally, effectual compliance reporting and compliance initiatives can help protect an organization from legal liability and minimize the risk of costly fines or penalties. By taking the time to develop a comprehensive compliance program, organizations benefit from increased efficiency, improved customer satisfaction, and higher employee morale.

What should a compliance report include?

A compliance report should include a summary of the organization’s activities to ensure it meets legal obligations, regulatory requirements, and contractual obligations. It should identify any current or potential gaps in compliance and provide recommendations to mitigate risks. The report should also highlight any changes that may have occurred since the last reporting period that could affect compliance. Additionally, the report should assess the effectiveness of existing processes and procedures and recommend actions to improve them, as well as describe any corrective actions taken in response to non-compliances.

General Data Protection Regulation (GDPR)

The General Data Protection Regulation (GDPR) is an important piece of European Union legislation that sets out strict data protection rules for businesses. It provides a framework for individuals to have control over their personal data, and gives them the right to access, delete, or amend this information at any time. The GDPR also requires organizations to inform people about how their information will be used, how long it will be used and who it may be shared with. Furthermore, it imposes strict rules on organizations to ensure that they protect the data of their customers. With these measures in place, organizations can build greater trust in their services by demonstrating a commitment to respecting people’s privacy.

How to develop a robust compliance reporting process?

The development of a robust reporting process is essential for any organization that needs to comply with the law and adhere to internal policies. Such a process should include the regular review of existing compliance procedures, training on those procedures, adequate communication channels, and periodic audits or assessments. Additionally, organizations need to ensure they have sufficient resources in place to monitor all aspects of their compliance processes and report any non-compliance.

This should include a system of tracking changes in regulations or other requirements that could affect compliance, as well as procedures for reporting instances of non-compliance to the appropriate authorities. Finally, organizations or your chief compliance officer must invest in continual learning and development of their staff to ensure they are up-to-date on the latest compliance regulations and can effectively communicate them within the organization.

What are 3 financial reporting risks?

Financial reporting risks refer to the uncertainty that investors and creditors may face when trying to assess the performance of an entity. The risk of inaccurate reporting can arise from a variety of sources, including accounting errors, fraud, misstatements or omissions in documents and financial statements, inadequate internal control mechanisms, or incorrect assessment of market conditions. The three main financial reporting risks are 1) accuracy risk, 2) materiality risk, and 3) fraud risk.

Accuracy risk pertains to the possibility of accounting errors or incorrect statements made in financial documents. Materiality risk involves the potential for disclosures not being properly defined or presented in a meaningful way by management that could lead to an inaccurate assessment. Lastly, fraud risk is associated with intentional misstatements or omissions which are made to mislead investors or creditors. It is important to understand these financial reporting risks in order to make the right investment decisions and ensure a successful understanding of an entity’s performance.

What is misleading reporting?

Misleading compliance reporting is a practice where organizations act as if they are following applicable laws and regulations, but do not actually meet the required standards. Compliance reports aim to assess whether an organization has taken measures to ensure that it is adhering to pertinent legal rules and regulations. Unfortunately, there are cases in which these reports can be inaccurate or even deliberately misleading about the level of compliance achieved by the organization. In these cases, organizations may be falsely representing their compliance efforts to stakeholders, regulators, and other interested parties.

Misleading reporting can have serious repercussions, including legal ramifications and financial losses due to failure to meet standards or false representation. It is important for companies to ensure that all compliance-related information is accurate and up-to-date, to avoid any such issues. Failure to do so can result in significant penalties and other sanctions. Therefore, organizations must take measures to ensure that all compliance-related information is accurate and up-to-date in order to maintain an accurate record of their compliance efforts.

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EHS Software for Healthcare

EHS Software for Healthcare

What is EHS healthcare?

EHS healthcare is a type of healthcare that focuses on the environmental, health and safety aspects of an individual’s wellbeing. It encompasses a wide range of preventive and proactive approaches to ensure individuals stay healthy both in and out of the workplace. With this type of healthcare, emphasis is placed on a comprehensive risk assessment to identify potential hazards or risks associated with a particular area, such as air quality, water supply, hazardous materials and other environmental factors.

Additionally, the goal of EHS healthcare is to provide educational resources to individuals in order to empower them with knowledge on how best to stay safe and healthy in their environment. Furthermore, EHS healthcare includes activities such as monitoring and responding to health-related incidents, performing safety drills and inspections, providing instruction on health topics, and preparing safety plans. Ultimately, this type of healthcare helps people stay safe and healthy while living in a potentially hazardous environment.

What does EHS stand for?

EHS stands for Environment, Health and Safety. It is an important acronym in the corporate world as it emphasizes the importance of protecting people and the environment through a set of policies, procedures and regulations. EHS promotes a safe workplace for employees and visitors, as well as a healthy environment to live and work in.

These measures help reduce risks associated with potential accidents or incidents. Additionally, they help ensure compliance with local, state and federal regulations, which can help a business avoid costly fines. Ultimately, EHS creates a safer and healthier environment for everyone.

What are the EHS standards?

The EHS (Environment, Health & Safety) standards are guidelines and regulations that aim to ensure the safety and well-being of workers, customers, and communities in a given environment. They cover areas such as hazardous materials management, process safety management, emergency response planning, air pollution control and monitoring, noise control and monitoring, waste management practices, occupational health and safety programs, and much more.

Organizations that follow these standards are able to reduce the risk of accidents, increase productivity, and better protect their workers from potential harm. EHS standards are designed to be comprehensive and flexible; they can be tailored to the needs of any particular organization or industry, making them an effective tool for creating a safe working environment.

What is a the purpose of the EHS management system?

The purpose of an Environmental, Health & Safety (EHS) management system is to ensure that organizations are aware of and comply with relevant environmental, health and safety laws, regulations and standards. It also helps organizations perform risk assessments to identify risks associated with their operations and develop strategies to mitigate those risks.

EHS management systems also provide a framework for the development of policies and procedures that ensure the health and safety of employees and minimizes potential impacts on the environment. Ultimately, EHS management systems help organizations protect their people, assets, and reputation while remaining compliant with relevant laws and regulations.

Furthermore, an effective EHS management system can provide a competitive advantage to organizations by giving them an edge in terms of demonstrating their commitment to environmental responsibility.

Environmental, Health, and Safety for Healthcare

Healthcare facilities must adhere to strict Environmental, Health, and Safety (EHS) standards in order to ensure the safety of their employees, customers, and visitors. These standards include ongoing training for staff on hazardous materials management, waste disposal, air quality monitoring and control, proper handling of medical waste and hazardous chemicals, as well as emergency preparedness protocols.

Facilities are also required to comply with local, state, and federal regulations regarding air quality, water quality, hazardous materials management, indoor air quality, and noise levels. By adhering to EHS standards in healthcare settings, providers are able to protect their patients from potential harm caused by environmental factors.

5 Top Safety Risks in the Pharmaceutical Industry

The pharmaceutical industry is an incredibly complex and regulated environment, and safety risks for workers are abundant. From hazardous chemicals to dangerous manufacturing processes, the risks must be managed vigilantly.

The five top safety risks in the pharmaceutical industry include exposure to hazardous materials, inadequate ventilation systems, improper handling of biohazardous waste, machine-related injuries, and slips or falls on wet surfaces. Exposure to hazardous materials can have serious health consequences for workers, so safety protocols must be strictly followed.

Inadequate ventilation systems can lead to a buildup of dangerous gases and particulate matter, negatively impacting the health of those working in manufacturing plants. Improper handling of biohazardous waste can also pose a serious risk by contaminating environments with disease-causing agents.

What is the Personal Protective Equipment (PPE) in the Pharmaceutical Industry?

Personal Protective Equipment (PPE) in the Pharmaceutical Industry is a set of safety gear used by workers to minimize potential harm and exposure to dangerous materials. PPE can include items such as gloves, masks, respirators, ear plugs, protective clothing and glasses/goggles.

Depending on the type of job or task being performed, different types of PPE may be required. For instance, a worker operating in a sterile environment might be asked to wear a face mask or respirator while handling hazardous chemicals. PPE is designed to both protect the user and patient and reduce the risk of contamination from one job site to another.

By implementing proper safety protocols, such as wearing appropriate protective clothing and equipment, workers can help ensure safe working environments that are free of potential hazards. It is important for employers to provide workers with the proper PPE so they can do their jobs safely and effectively.

Environmental Compliance in Healthcare

Environmental compliance in healthcare is a critical issue. Healthcare organizations must take steps to ensure that their practices and operations are not only legal, but also adhere to sustainability principles. This includes proper handling of hazardous materials, waste management, and energy efficiency. Healthcare facilities must comply with laws governing air, water, and land pollution as well as safety standards for employees and visitors.

Additionally, healthcare organizations must develop and implement an environmental management system to track and manage their environmental performance. By ensuring compliance with environmental regulations, healthcare facilities can contribute to local communities by protecting the environment and public health. Thus, proper environmental compliance is essential for all healthcare organizations.

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