Recognize the Signs of Heat Illness

Jul 21, 2021

Hot working conditions can bring increased risks of heat illness, especially when heat-producing equipment is used.

OSHA has added an item in its Spring Regulatory Agenda called “Heat Illness Prevention in Outdoor and Indoor Work Settings” to start the wheels in motion for a potential heat-related regulation. Right now it’s only in the Request for Information stage, but congressional members and public citizens have been petitioning for a standard for a while. Some state plan states have already included heat-related rules in their standards.

Heat is the leading weather-related killer. The most important thing to remember about a person suffering from heat illness is to get them out of the heat ASAP. Take them to a shaded or air-conditioned area. A running vehicle with air conditioning works if no shaded area is available. Always stay with a victim of heat illness until medical personnel arrive. Be aware of yourself and your team for any symptoms and take the appropriate action immediately.

Heat rash can appear on skin as small or large clusters of red bumps.

What to do:
- Get to a cool, dry place.
- Keep rash dry; use powder to soothe.

Heat cramps bring pain or spasms to muscles.

What to do:
- Halt physical activity until cramps go away.
- Get to a cool place.
- Drink water or electrolyte drink.
Seek medical attention if the victim:
- Has cramps lasting longer than 1 hour.
- Has heart problems.
- Is on a low-sodium diet.

Heat exhaustion occurs when the body’s temperature can’t cool down. Think of this as a situation where extreme conditions exhaust the body. It is severe and can occur in one day or over multiple days when in a consistently hot environment.

Watch for:
- Heavy sweating
- Cold, clammy, pale skin
- Fast and weak pulse
- Nausea or vomiting
- Headache
- Weakness or tiredness
- Dizziness
- Fainting
- Muscle cramps
What to do:
- Get to a cool place.
- Loosen clothing.
- Sip water; do not chug.
- Place cool cloths or cold packs under arms or on neck.
Seek medical attention if the victim:
- Is vomiting.
- Experiences worsening symptoms.
- Experiences symptoms lasting longer than 1 hour.

Heat stroke occurs when body temperature is excessively high. Think of this as a situation that causes the body to stroke or seize up completely. This is a serious medical emergency that can cause shock, brain damage, organ failure, and death. It could be caused by heat exhaustion that was not properly treated.

Watch for:
- Red, hot, dry skin (no sweating)
- Fast and strong pulse
- Nausea
- Throbbing headache
- High body temperature
- Dizziness or confusion
- Slurred speech
- Losing consciousness
- Seizures
What to do:
- Call 911 – follow their advice.
- Get to a cool place.
- Loosen clothing.
- Place cool cloths or cold packs under arms or on neck.
- Do not provide anything to drink.

Dehydration can be a common cause of heat illness. Maintaining hydration is important, even if you don’t feel thirsty. Drinking water or electrolyte drinks are highly preferred to sugary and heavily caffeinated drinks. OSHA recommends drinking small amounts of cool water often before getting thirsty; 4 cups every hour during heat index values between 103°F – 115°F. Another recommendation is not to exceed 12 quarts of water per day.

An important reminder is that every person and situation is different. Some people require more water than others. These intake amounts depend on several things including the type of work being done, how much you’re sweating, and your personal risk factors. Don’t chug a large amount of water in the morning and call it good for the day; the important thing is maintaining hydration. You don’t flood your vegetable garden once at the beginning of the month and neglect it the rest of the month. If you do, you probably don’t have much of a harvest.

It’s the supervisor’s duty to have a plan in place during days of extreme heat. If possible, rescheduling a job to a cooler day or even a cooler part of the day could make a difference. Getting a job done on time is important, as is maintaining client satisfaction. However, no part of a job is worth risking the health and safety of your team and clients should understand that.

OSHA Heat Regulation

Monitor OSHA’s progress on a potential heat illness prevention standard here.

Rule Info

Contributing:

Drew Lyon

Project Manager | Meteorologist

Drew Lyon’s experience and training encompasses environmental reporting, day-to-day EHS compliance assistance at manufacturing facilities, wastewater compliance, hazardous waste management, environmental field sampling and safety. She is also a meteorologist, providing weather-related guidance to clients and our team.

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Which Emergency Response Plans are You Required to Develop for Your Facility?

Jul 8, 2021

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In a review of environmental and safety regulations, you will find quite a few references to developing emergency response plans or emergency response procedures. Each one has its own purpose and its own requirements.

The following is a list of the most commonly required emergency plans, along with their standards reference and a brief description of each. Which ones apply to you?

EPA

Spill Prevention, Control and Countermeasures **[40 CFR 112]**

These plans, aka SPCC Plans, cover all types of oils, including petroleum, fuel oil, sludge, vegetable oils, mineral oils and synthetic oils. If your facility has the capacity aboveground of 1,320 gallons or more or underground capacity of 42,000 gallons or more, you quality for this regulation. Read more about SPCC Plans here.

Facility Response Plans **[40 CFR 112]**

If you have over 42,000 gallons of oils and are transferring them over water to/from vessels, or if you have over 1,000,000 gallons and meet certain criteria, you are required to additionally have a Facility Response Plan, or FRP. Both the SPCC and FRP are plans from the Federal Water Pollution Control Act.

**Risk Management Plans [40 CFR 68]**

Risk Management Plans, or RMPs, come from the Clean Air Act. These are for facilities such as chemical manufacturers, water treatment plants, cold storage facilities, and COOPs that store regulated substances in quantities greater than listed thresholds.

**Hazardous Waste Contingency Plans [40 CFR 262]**

A part of the RCRA hazardous waste regulations, these plans apply to both small and large quantity generators. The term “contingency plan” is only for large quantity generators. Small quantity generators don’t have a similar cool term but they still need to develop emergency procedures.

OSHA

**Emergency Action Plans [29 CFR 1910.138]**

Emergency Action plans are specifically mentioned in the regulations related to confined spaces, bloodborne pathogens, fire protection, lab safety, and medical services/first aid.

At a minimum, emergency action plans (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.

**HAZWOPER Emergency Response Plans [29 CFR 1910.120]**

If your company has employees assigned to respond to releases of hazardous substances at any location, at their regular work location, or from a duty station such as a fire department, fire brigade, or emergency medical service, you are required to have an emergency response plan for this. 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.

**Process Safety Emergency Planning [29 CFR 1910.119]**

Workplaces subject to OSHA’s Process Safety Management standard are required to have emergency plans. These plans are not much different than the requirements of the EAPs, but it adds in requirements for small releases. Learn more about Process Safety Management here.

**Fire Prevention Plans [29 CFR 1910.39]**

When an OSHA standard requires a fire prevention plan, the requirements for the plan can be found in this standard. Some of these include standards for portable fire extinguishers, ethylene oxide, methylenedianiline and 1.3-butadiene.

OSHA Emergency Plan References for Specific Substances

The following OSHA standards for specific chemicals/materials reference emergency procedures:

13 Carcinogens [29 CFR 1910.1003(e)(4)(ii)] – Specific emergency procedures prescribed, posted, and employees shall be familiarized with their terms and rehearsed;
Vinyl chloride [29 CFR 1910.1017(i)] – A written operational plan for emergency situations shall be developed for each facility storing, handling, or otherwise using vinyl chloride as a liquid or compressed gas;
Beryllium [29 CFR 1910.1024(m)(4)(ii)] – Written exposure control plan which includes emergency procedures is required;
Cadmium [29 CFR 1910.1027(h)] – Written plan required for dealing with substantial releases of airborne cadmium.
1,2-dibromo-3-chloropropane [29 CFR 1910.1044(i)(1)(i)] – A written plan for emergency situations shall be developed for each workplace in which DBCP is present;
Acrylonitrile [29 CFR 1910.1045(i)(1)(i)] – A written plan for emergency situations shall be developed for each workplace where liquid AN is present. Appropriate portions of the plan shall be implemented in the event of an emergency;
Ethylene oxide [29 CFR 1910.1047(h)(1)(i)] – A written plan for emergency situations shall be developed for each workplace where there is a possibility of an emergency. Appropriate portions of the plan shall be implemented in the event of an emergency;
Formaldehyde [29 CFR 1910.1048(n)(4)(i)] – Must have written training materials available and within those training materials is a review of emergency procedures including the specific duties or assignments of each employee in the event of an emergency;
Methylenedianiline [29 CFR 1910.1050(d)(1)(i)] – A written plan for emergency situations shall be developed for each workplace where there is a possibility of an emergency. Appropriate portions of the plan shall be implemented in the event of an emergency; and,
1,3-Butadiene [29 CFR 1910.1051(j)] – Emergency situations. Written plan. A written plan for emergency situations shall be developed, or an existing plan shall be modified, to contain the applicable elements specified in 29 CFR 1910.38 and 29 CFR 1910.39, “Emergency action plans” and “Fire prevention plans,” respectively, and in 29 CFR 1910.120, “Hazardous Waste Operations and Emergency Response,” for each workplace where there is the possibility of an emergency.

Other Agencies’ Emergency Response Plans

There are a number of other agencies that require emergency plans or procedures depending on what you are doing or what you have onsite.

Department of Transportation Research and Special Programs Administration (RSPA) Pipeline Response Plan [49 CFR Part 194] – For onshore oil pipelines that could discharge oil into or on any navigable waters of the U.S. or adjoining shorelines;
Coast Guard Facility Response Plan [33 CFR 154, Subpart F] – For marine transportation-related facilities that could discharge oil into or on navigable waters, shorelines or exclusive economic zones.
Department of the Interior Minerals Management Service Facility Response Plan [30 CFR Part 254] – For owners or operators of oil handling, storage or transportation facilities located seaward of the coast line;
FEMA Emergency Operation Plan [44 CFR Part 302] – For jurisdictions receiving emergency management performance grants by FEMA;
Federal Radiological Emergency Response Plan [10 CFR Part 50] – Related to potential accidents involving nuclear material; and,
State-specific plans.

A Combined Plan to Satisfy Multiple Requirements

As a company, you may need to prepare a number of these plans, and some of them can have the same overlapping requirements. Having multiple plans could be a nightmare to keep track of if your facility was required to have several. Seeing this, a collection of agencies forming the National Response Team developed a guidance for a “one plan” option.

The National Response Team, or NRT, is made up of EPA, OSHA, the Coast Guard, the Minerals Management Service, and DOT’s RSPA. EPA is the chair of the NRT. They issued guidance for Integrated Contingency Plans, or ICPs.

ICPs apply to oils and non-radiological hazardous substances. You can make one ICP that can covers all of the following emergency response plans into one plan.

SPCC Plan
EPA Facility Response Plan
EPA Risk Management Plan
Hazardous Waste Contingency Plan
OSHA Emergency Action Plan
OSHA HAZWOPER
OSHA Process Safety Emergency Plan
DOT Pipeline Response Plan
Coast Guard Facility Response Plan
Minerals Management Service Facility Response Plan

This helps consolidate the overlap, but you will need to make sure you include all of the elements that are required in these plans. The NRT suggests that you also incorporate your state and local-specific emergency response procedures into this plan as well. You are still free to hold separate plans, but the NRT has provided this option to help you demonstrate compliance.

Where Do You Go for More Info?

We will be breaking all of these different plans out and explaining them further in future blog posts.

In the meantime, if you have questions, need help sorting through which plans you need, need assistance in pulling something together or consolidating your current plans into an ICP, iSi can help. Not only can we help determine the plans you need, but we can write them, organize them and double check them for you too. Contact us today for more information and a price quote!

The following is a list of the most commonly required emergency plans, along with their standards reference and a brief description of each. Which ones apply to you?

EPA

Spill Prevention, Control and Countermeasures **[40 CFR 112]**

Facility Response Plans **[40 CFR 112]**

**Risk Management Plans [40 CFR 68]**

**Hazardous Waste Contingency Plans [40 CFR 262]**

OSHA

**Emergency Action Plans [29 CFR 1910.138]**

Emergency Action plans are specifically mentioned in the regulations related to confined spaces, bloodborne pathogens, fire protection, lab safety, and medical services/first aid.

At a minimum, emergency action plans (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.

**HAZWOPER Emergency Response Plans [29 CFR 1910.120]**

**Process Safety Emergency Planning [29 CFR 1910.119]**

**Fire Prevention Plans [29 CFR 1910.39]**

OSHA Emergency Plan References for Specific Substances

The following OSHA standards for specific chemicals/materials reference emergency procedures:

13 Carcinogens [29 CFR 1910.1003(e)(4)(ii)] – Specific emergency procedures prescribed, posted, and employees shall be familiarized with their terms and rehearsed;
Vinyl chloride [29 CFR 1910.1017(i)] – A written operational plan for emergency situations shall be developed for each facility storing, handling, or otherwise using vinyl chloride as a liquid or compressed gas;
Beryllium [29 CFR 1910.1024(m)(4)(ii)] – Written exposure control plan which includes emergency procedures is required;
Cadmium [29 CFR 1910.1027(h)] – Written plan required for dealing with substantial releases of airborne cadmium.
1,2-dibromo-3-chloropropane [29 CFR 1910.1044(i)(1)(i)] – A written plan for emergency situations shall be developed for each workplace in which DBCP is present;
Acrylonitrile [29 CFR 1910.1045(i)(1)(i)] – A written plan for emergency situations shall be developed for each workplace where liquid AN is present. Appropriate portions of the plan shall be implemented in the event of an emergency;
Ethylene oxide [29 CFR 1910.1047(h)(1)(i)] – A written plan for emergency situations shall be developed for each workplace where there is a possibility of an emergency. Appropriate portions of the plan shall be implemented in the event of an emergency;
Formaldehyde [29 CFR 1910.1048(n)(4)(i)] – Must have written training materials available and within those training materials is a review of emergency procedures including the specific duties or assignments of each employee in the event of an emergency;
Methylenedianiline [29 CFR 1910.1050(d)(1)(i)] – A written plan for emergency situations shall be developed for each workplace where there is a possibility of an emergency. Appropriate portions of the plan shall be implemented in the event of an emergency; and,
1,3-Butadiene [29 CFR 1910.1051(j)] – Emergency situations. Written plan. A written plan for emergency situations shall be developed, or an existing plan shall be modified, to contain the applicable elements specified in 29 CFR 1910.38 and 29 CFR 1910.39, “Emergency action plans” and “Fire prevention plans,” respectively, and in 29 CFR 1910.120, “Hazardous Waste Operations and Emergency Response,” for each workplace where there is the possibility of an emergency.

Other Agencies’ Emergency Response Plans

There are a number of other agencies that require emergency plans or procedures depending on what you are doing or what you have onsite.

Department of Transportation Research and Special Programs Administration (RSPA) Pipeline Response Plan [49 CFR Part 194] – For onshore oil pipelines that could discharge oil into or on any navigable waters of the U.S. or adjoining shorelines;
Coast Guard Facility Response Plan [33 CFR 154, Subpart F] – For marine transportation-related facilities that could discharge oil into or on navigable waters, shorelines or exclusive economic zones.
Department of the Interior Minerals Management Service Facility Response Plan [30 CFR Part 254] – For owners or operators of oil handling, storage or transportation facilities located seaward of the coast line;
FEMA Emergency Operation Plan [44 CFR Part 302] – For jurisdictions receiving emergency management performance grants by FEMA;
Federal Radiological Emergency Response Plan [10 CFR Part 50] – Related to potential accidents involving nuclear material; and,
State-specific plans.

A Combined Plan to Satisfy Multiple Requirements

ICPs apply to oils and non-radiological hazardous substances. You can make one ICP that can covers all of the following emergency response plans into one plan.

SPCC Plan
EPA Facility Response Plan
EPA Risk Management Plan
Hazardous Waste Contingency Plan
OSHA Emergency Action Plan
OSHA HAZWOPER
OSHA Process Safety Emergency Plan
DOT Pipeline Response Plan
Coast Guard Facility Response Plan
Minerals Management Service Facility Response Plan

Where Do You Go for More Info?

We will be breaking all of these different plans out and explaining them further in future blog posts.

Download a PDF Summary

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Contributing:

Curtis Leiker, CSP

Certified Safety Professional | ISO 45001 and 14001 Lead Auditor

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

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OSHA Issues Emergency Standard for COVID

Jun 10, 2021

UPDATE 6/10/21:

OSHA has issued an emergency temporary standard for Covid-19, but it will only apply to healthcare workers. For all other industries, there is new updated guidance related to unvaccinated and otherwise at-risk workers.

Emergency Temporary Standard

The new standard, 1910.502, applies to settings where any employee provides healthcare services or healthcare support services. This includes “This includes employees in hospitals, nursing homes, and assisted living facilities; emergency responders; home healthcare workers; and employees in ambulatory care facilities where suspected or confirmed COVID-19 patients are treated.” It does not apply to those providing first aid only.

More details about the requirements can be found at https://www.osha.gov/coronavirus/ets.

Employer Guidance for Protecting At-Risk Workers

According to OSHA, “Unless otherwise required by federal, state, local, tribal, or territorial laws, rules, and regulations, most employers no longer need to take steps to protect their fully vaccinated workers who are not otherwise at-risk from COVID-19 exposure.” Their new guidance is to ensure employers focus their efforts on unvaccinated or otherwise at-risk workers in their workplaces (or well-defined portions of workplaces).

Some elements include:

Granting Paid Time Off for Vaccinations
Instruct Workers Who Have Become a Close Contact of an Infected Person, or Have Symptoms Themselves to Stay Home
Physical Distancing for Unvaccinated Workers
Provide Masks for Unvaccinated Workers and Suggest Unvaccinated Customers, Visitors, or Guests Wear Face Coverings
Provide Covid-19 Policies and Procedures in Languages Employees Will Understand
Maintain Ventilation Systems
Record and Report Work-Related Covid Infections and Deaths per 29 CFR 1904
Implement Retaliation Protections

Employers must continue to follow mandatory OSHA standards that apply to ensure workers are protected from infection, including:

Requirements for PPE (29 CFR 1910, Subpart I (e.g., 1910.132 and 133))
Respiratory Protection (29 CFR 1910.134)
Sanitation (29 CFR 1910.141)
Protection from Bloodborne Pathogens: (29 CFR 1910.1030)
Employee Access to Medical and Exposure Records (29 CFR 1910.1020).
Where the Emergency Temporary Standard does not apply, employers are required under the General Duty Clause, Section 5(a)(1) of the OSH Act, to provide a safe and healthful workplace free from recognized hazards that are causing or likely to cause death or serious physical harm .

More information on this guidance can be found at: https://www.osha.gov/coronavirus/safework.

UPDATE 1/21/21:

President Biden signed an Executive Order on Thursday, Jan. 21, 2021 that requires the following:

Within 2 weeks (by Feb. 4, 2021), OSHA is required to:
- OSHA and MSHA are required to determine if an emergency temporary standard is necessary. If so, it will be due by Mar. 15, 2021. Although the date has passed, it’s been reported that OSHA has alerted the U.S. Chamber of Commerce that one has been drafted and they just need additional time to finish it and get it reviewed.
- Issue guidance to employers on workplace safety during the COVID pandemic. This guidance was issued Feb. 1. It includes stronger language including outlining the components of a prevention program. Check out the new guidance here.
OSHA is required to review its enforcement efforts and identify any short-term and long-term changes to be made.
A National Emphasis Program on COVID-19 in the workplace is required to be developed. This was released March 15. Check out the details HERE.
OSHA is to work with state plan states to make sure they have similar COVID plans in place, and for those who don’t have a state plan, work with state and local officials to make sure they have plans in place to protect public employees.
The Secretaries of Labor, Health and Human Services, Transportation, Energy and Agriculture need to work to identify that workers not covered under OSHA in their respective categories are protected.

What’s an OSHA Emergency Temporary Standard?

Under certain limited conditions, OSHA is authorized to set emergency temporary standards that take effect immediately and are in effect until superseded by a permanent standard. OSHA must determine that workers are in grave danger due to exposure to toxic substances, new hazards, or agents determined to be toxic or physically harmful where an emergency standard is needed to protect them. OSHA publishes the emergency temporary standard in the Federal Register, where it also serves as a proposed permanent standard. It’s subject to the usual procedure for adopting a permanent standard except that a final ruling should be made within six months. The validity of an emergency temporary standard may be challenged in an appropriate U.S. Court of Appeals.

What May Employers Be Required to Develop in a Federal Emergency Standard for COVID?

In total, 14 states have adopted comprehensive COVID-19 worker protections through executive order and/or their state OSHA programs.

Currently, there are 4 states – California, Virginia, Michigan and Oregon – that have issued a state-specific OSHA emergency standards through their state plans. There are common themes between the policies of these 4 states and they have pulled items from each other. These items would likely become a part of a federal emergency standard:

Conducting a Workplace Assessment

This would include identifying employee tasks, work environment, presence of the virus, number of employees, facility size, working distances, duration and frequency of exposure, and hazards encountered.

Develop an Exposure Control Plan

This would include designating an on-site COVID coordinator, providing free face coverings and requiring their use, signage, social distancing, barriers, remote working, prohibiting sick employees access to facility, enhanced cleanings for positive cases, employee screenings, and notification of positive cases.

Implement Controls

This includes maximizing current ventilation systems, installing barriers, partitions, and airborne infection isolation rooms.

Training Employees

Training would need to be specific to the place of employment. Included would be reviewing control measures, proper use of PPE, how to report symptoms or positive cases, how to report unsafe working conditions, and an overview of the COVID-19 virus, symptoms, and means of transmission.

Maintain Records of Training, Screenings, and Notifications

This would include employee training, employee and visitor screenings, notifications as required to individuals and Health Departments.

How Often Have Emergency Standards Been Used Before?

OSHA has used emergency temporary standards 9 times. The last time they were used was in 1983 for asbestos. OSHA’s first emergency standard was also created for asbestos, and others have been created mostly for chemicals, including 12 different carcinogens, benzene and vinyl chloride. Most standards have been challenged in court, and although there have been a few that have been vacated, most have remained in place.

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iSi will be monitoring developments with federal OSHA emergency standard for COVID and will update this article, or provide additional information in our blog as information continues to develop regarding this issue.

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Contributing:

Curtis Leiker, CSP

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Annual DOT Registrations Due July 1

Jun 9, 2021

If your company ships hazardous waste or hazardous materials in certain types and/or quantities, you are be required to register with the Department of Transportation (DOT) annually.

Who Needs to Be Registered With DOT?

DOT registrations are required for companies or individuals shipping the following items:

A quantity of hazardous material/waste that requires placarding.
A hazardous material (including hazardous wastes) in a bulk packaging having a capacity equal to or greater than 3,500 gallons for liquids or gases or more than 468 cubic feet for solids.
A shipment in other than a bulk packaging of 5,000 pounds gross weight or more of one class of hazardous materials (including hazardous wastes) for which placarding of a vehicle, rail car, or freight container is required for that class.
A highway route controlled quantity of a Class 7 (radioactive) material by highway, rail, air, or water.
More than 55 pounds of a Division 1.1, 1.2, or 1.3 (explosive) material by motor vehicle, rail car, or freight container.
More than 1 liter/1.06 quarts per package of a “material extremely toxic by inhalation.”

State and federal agencies, Indian tribes, farmers, and individual truck drivers are exempt from registration. Government contractors must register, as do any farmers who transport hazardous materials not used in farming or truck drivers who aren’t driving a truck already registered by a motor carrier.

How Do You Get Registered With the DOT?

DOT registrations are conducted online or you can fill out a form and mail it in. There will be a fee for registration. Registration fees are determined by your company’s size, that is, whether or not you are considered to be a small business by the U.S. Small Business Administration. You will need to know your company’s primary NAICS code. Once you determine your NAICS code, you’ll be able to determine if you meet the small business size standard. Fees can range from $275/year for a small business to $2,600 for a large business, with slight discounts for registering for up to 3 years at a time.

Your company cannot transport hazardous materials until registered. If your company has failed to register for any previous years, you will need to register for any missed years and pay for those as well.

What is Required for DOT Registration Recordkeeping?

Once registered, you’ll receive a Hazardous Materials Certificate of Registration. This will have your DOT registration number, year, date issued, and expiration date. Those who register online can choose to print out their certificate, or have one mailed. Copies of your registration forms and certificate must be kept on file for 3 years and may be asked for during an inspection. Any trucks, truck tractors, or vessels must have a copy of this certificate or another document with your current DOT registration number on it.

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Sometimes You Really Need to Listen to the Voices in Your Head

Jun 3, 2021

At iSi, the office and marketing/sales teams get involved in safety too, and one of the things we do is we each get a week to share a personal safety experience. This is what I plan to share this month during my turn, and I hope you can take something away from it, especially as we head into National Safety Month this month. – Tami Hadley

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Usually when someone talks about the voices in their head, it’s kind of a joke, or played off as a negative thing. However, sometimes those voices can tell you good things that you actually need to listen to. There was one important time I wish I had listened to the voices that were trying to help keep me safe, but didn’t.

In late June of 2001, 20 years ago this month, my sister-friend and I were seriously scalded in a kitchen accident. My friend used to think homemade was the way to go. Six kids later she thinks a little differently, but back then that’s the way it was. She was canning green beans from her garden and she had one of the old-time pressure cookers from the 70s. She hadn’t used it much, and I certainly didn’t know anything about it.

One night when I was visiting, she was wanting to get the beans canned. Her husband usually took care of the pressure cooker part but he was gone that night. She had seen him do it, so she decided she would do it herself. When it was time to take the jars out, she couldn’t get the lid of the cooker off. Earlier that evening, the lid was really hard to get on, and so it made sense that it would be hard to get it off. She enlisted my help. I’m a helper…sure I’ll help. We stood over the stove and started trying to muscle the lid off, and it wasn’t moving.

We paused for a moment. In that pause, later we both discovered when discussing the event, that a voice in our heads was saying to each of us “Wait a minute, maybe this isn’t a good idea.” However, we both are get ‘er done types and there were a lot of other things to get done that night, so we proceeded. What we proceeded into was pressurized scalding water going everywhere. We had missed a step – depressurizing the cooker.

The water flew everywhere. Scalding water covered my head, face, arms, hands, chest, stomach and upper thighs. She got it all over her arms, legs and feet. After being temporarily blinded, I ran to the bathroom sink for the cool water, and she went to the kitchen sink. Besides the extreme pain, I knew it was bad when I looked in the mirror and saw a huge piece of skin on my nose falling off and my face beginning to swell. I found out later that the boiled water remaining on my clothes was continuing to burn me. I kept them on until I was convinced to strip down in the ambulance. Well, not until I made them shut the door, and make my cop friend who was working that night, go away.

I ended up spending the night in the burn unit with second degree burns over 30% of my body and my friend had second and third degree burns. The nurses in the emergency room had a real good time with me after learning I worked for a safety consulting company. They made all the medical personnel who came in the emergency room ask me where I worked so I could relay the irony of the situation.

It was a long, painful July for the both of us and it took us about a month for full recovery. We both still have scars, especially on our arms. I tell her it’s like a tattoo to remind us of what we went through and what we should/shouldn’t do. We are extremely fortunate and blessed it didn’t do any other long lasting scarring damage besides that.

If we would have listened to those voices in our heads, we could’ve stopped this accident from happening.

Please relay to your teams that it is OK to stop and listen to those voices in your head when something does not seem right. It’s ok to take a moment to rethink something before you do it. Nothing is too important or needs to be completed so quickly that you can’t take a moment to rethink it, especially when it comes to your safety.

Some safety lessons I took away from this ordeal…

It’s OK to listen to the voices when it comes to your safety.
If you’re scalded, remove the clothing that has the hot water on it to prevent continual burning. A lot of my most painful injuries was a result of this.
Scalding burns larger than 3 inches or that cover more than one area of your body need medical attention.
Run cool or lukewarm water (not cold) over the area but don’t submerge yourself in it or you could lose body heat.
If you’re going to use a pressure cooker, buy the ones with the best safety features and won’t let you take the lid off until you depressurize it. My friend did bravely “get back up on the horse” and used that old cooker again, but more safely. I still refuse to be in the same room with it.
Always be familiar with the proper procedures for using something – don’t rely on only doing it by sight or watching someone else – you may miss something very important.

What’s your safety story? Do you use personal safety stories in your safety programs? How is it working? Let us know!

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Contributing:

Tami Hadley

Marketing Director | Project Manager, E-Training Solutions

Tami has been with iSi for over 24 years. During this time, she has enjoyed helping promote regulations compliance awareness and education through her involvement with iSi Training and through leadership roles with industry conferences and professional organizations.

Email | LinkedIn

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iSi Summer Safety Series: Grilling Safety

May 27, 2021

Summer here and so is grilling season. Well, it’s always grilling season in some places, but Summer is the time of year when it’s most conducted. According to NFPA, 64% of all households own a grill or a smoker, and gas grills are the biggest culprit to fires. 10,600 home fires are started by grills each year. On average 19,700 patients go to the emergency room each year because of grill injuries, 9,500 of those being thermal burns. Here are some grilling safety tips to share with your co-workers, friends and family members.

Grill outside and away from any structures

Charcoal and gas grills are designed for outdoor use only. However, NFPA reports that more than one-quarter (27%) of home fires started by outdoor grills began in a courtyard, terrace or patio, and 29% started on an exterior balcony or open porch. Pay attention to overhanging tree branches when you set up your grill.

Make sure your grill is stable

Only set up your grill on a flat surface and make sure the grill can’t be tipped over. Consider using a grill pad or splatter mat underneath your grill to protect your deck or patio.

Keep your grill clean

Remove grease or fat buildup from both the grill and the tray below the grill. If you are using a charcoal grill, allow the coals to completely cool off before disposing of them in a metal container.

Check for propane leaks on your gas grill

Before the season’s first barbecue, check the gas tank hose for leaks by applying a light soap and water solution to the hose and then turning on the gas. If there is a propane leak, the solution will bubble. Other signs of a propane leak include the smell of gas near the barbecue or a flame that won’t light.

If the flame goes out, wait to re-light

If you are using a gas grill and the flame goes out, turn the grill and the gas off, then wait at least five minutes to re-light it.

Take care around the grill

Never leave a lit grill unattended. Don’t allow kids or pets to play near the grill. Never try to move a lit or hot grill, and remember the grill will stay hot for at least an hour after use.

Be careful with charcoal starter fluid

If you use a charcoal grill, only use charcoal starter fluid. If the fire starts to go out, don’t add any starter fluid or any other flammable liquids to the fire. Consider using a charcoal chimney starter, which uses newspaper to start the fire instead of starter fluid.

Wear the right clothing

Clothing can easily catch fire, so be sure your shirt tails, sleeves or apron strings don’t dangle over the grill.

Be ready to put out the fire

Have baking soda on hand to control a grease fire and a fire extinguisher nearby for other fires. If you don’t have a fire extinguisher, keep a bucket of sand next to the grill. Never use water to put out grease fire.

These easy-to-follow tips will help you and your family enjoy a safe summer barbecuing season.

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Go Orange for Work Zone Safety & Struck-By Hazard Awareness Week

Apr 22, 2021

With spring and summer, along with the barbeques, pool parties and vacation days that come with warm weather, so does one other inevitability: road construction. The week of April 26-30, 2021 is National Work Zone Awareness Week. Road construction occurs all throughout the year, but tends to start ramping up in the warmer spring and summer months. So now is a good time to review some good safety practices on construction zone safety.

Work zones separate construction activities and construction workers from traffic, allowing both to work in harmony. However, construction zones create a different traffic pattern and can sometimes be confusing areas. On top of that, there are workers and machinery moving about. Speed reduction areas, delays for pilot cars, and even route changes can affect our time schedules too.

According to the U.S. Department of Transportation, 2019 fatalities rose 11% from 2018.

There were 762 fatal crashes in work zones, 324 on arterial roads and 287 on the interstates
There were 842 fatalities in work zones, 690 of those fatalities were drivers and passengers
Of the fatal crashes, 33% were commercial motor vehicles
31% of fatalities involved speed
24% of fatalities were rear-end collisions

National Work Zone Awareness Week Events and Materials and Go Orange

You are encouraged to participate in Go Orange Day on Wednesday April 28, 2021 and wear orange to spread the message of work zone safety with your friends, family, coworkers and community. There are a ton of resources out there to share with your workers as part of your weekly safety messages and meetings. Here are some links to some sites for national and state event information and resources you can download:

National WorkZone Safety Information Clearinghouse (National and State Site Links)

Download a Flyer to Share with Your Workers from the National Work Zone Week Site

Download iSi’s 1-page Safety Toolbox Flyer With Safety Tips to Share With Your Team

National Work Zone Awareness Week Website

Participate – National Work Zone Awareness Event Tool Kit

Struck-By National Stand-Down Week

Along with National Work Zone Awareness Week, NIOSH’s National Occupational Research Agenda’s (NORA) Construction Sector Council is promoting the National Stand-Down to Prevent Struck-By Incidents. Struck-by hazards have been OSHA’s leading cause of death and non-fatal injuries since 1992.

NORA will be hosting 2 webinars on Monday April 26. One is about cranes and lifting and the other is preventing struck-by incidents. To register, download this flyer about the event.

You can also find a wide variety of training materials, infographics and other resources on struck by hazards here on the Center for Construction Research and Training Website.

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OSHA Proposes Changes to Hazcom Standard

Mar 19, 2021

UPDATE: OSHA has announced an informal public hearing for Sept. 21. If you’d like to testify or question witnesses, submit your notice by June 18.

OSHA has announced it’s planning on making changes to its Hazcom Standard (29 CFR 1910.1200) and they are soliciting your comments, due by May 19.

OSHA’s changes are to help align the standard with Global Harmonization Standard (GHS) Revisions 7 and 8. OSHA is also wanting to correct issues it’s found since the last update in 2012 and to make the standard more in line with related federal agencies such as DOT and international trading partners such as Canada.

Here are the items currently up for comment:

Relabeling Containers and “Released for Shipment” Dates

Right now the standard says that once a chemical manufacturer, importer, distributor or employer knows there is hazard information changes significant enough to affect the SDS, the SDS needs to be updated. Labels must be revised within 6 months and containers shipped thereafter must have that information on its labels.

OSHA is proposing chemicals released for shipment and awaiting future distribution wouldn’t need to be physically relabeled to incorporate that new information. Instead, the chemical manufacturer/importer will still need to provide an updated label for each individual container with each shipment. This would help containers with long distribution cycles. This also reduces the chemical exposure and ergonomic hazards for workers who would be going in and actually physically relabeling containers.

As a result of this, labels on shipped containers will be required to note the date the chemical is released for shipment. The standard will specifically call out chemicals released for shipment and awaiting further distribution as part of the no relabeling requirement, so they’ll need a date on them to meet that requirement.

Bulk Shipments

Labels for bulk shipments can be placed on the immediate container, or you will be able to transmit them with the shipping papers or bills of lading electronically as long as there’s a printed version available to the people on the receiving end of the shipment.

Changes to bulk shipments are an effort to facilitate inter-agency cooperation with DOT.

Labeling for Small Containers

Labels for small containers less than or equal to 100 mL must include just the product identifier, pictogram, signal word, chemical manufacturer’s name and phone number, and a statement that the full label info for the hazardous chemical is provided on the immediate outer package. This will be applicable for those containers where it’s not feasible to use pull-out labels, fold back labels or tags with the full information on them.

There will be no labeling requirements for containers less than or equal to 3 mL if the manufacturer, importer, or distributor can demonstrate that any label would interfere with the normal use of the container. A product identifier that can be identified and linked with the full label info on the immediate outer package would be required on that small container. OSHA uses an example that a glass vial could be etched with the product identifier instead of needing the label.

Immediate outer packaging would then need to include the full label information, and a statement indicating when not in use, the small containers inside must be stored in this outer packaging that has the label on it.

Trade Secrets

Allow manufacturers, importers and employers to now withhold a chemical concentration range as a trade secret. Use prescriptive concentration ranges instead of actual concentration or concentration range when they’re claimed as a trade secret. This change is categorized as help to better work with trading partners as this is something that Canada does.

OSHA wants to know from commenters if this is something that you have worked with and does this give enough information downstream for manufacturers to conduct hazard classifications and protect workers.

SDS Terminology

A terminology change will replace the word “design” with “stored.” This will allow SDSs to be stored in a way that covers groups of hazardous chemicals in a work area. They believe the word “designed” is confusing because now SDSs have specific design requirements (16 section format) so they don’t want anyone redesigning an SDS for groups of chemicals in a work area.

Appendix D Changes

Changing Section 2 of the SDSs to emphasize that hazards identified under normal conditions of use that result from a chemical reaction must appear on the SDS, even though the hazards don’t need to be listed on the label. This would be a reorganization of the info on the SDS.
The Hazcom Standard currently requires SDS Section 3 to include chemical name and concentration/concentration ranges of all ingredients classified as health hazards. OSHA wants to know if this should be expanded to include not only the health hazard classified chemicals, but all classified chemicals such as physical hazard chemicals to help manufacturers better understand hazard potentials when handling these chemicals. This would be similar to what the REACH regulations require in Europe.
OSHA would also like to hear comments about using electronic labels, RFID and QR codes on chemical packaging as a form of communicating hazards fully and in real-time. If your company is using electronic labeling, they’d like to know what kind of system you’re using and what benefits you’ve been able to see from it.

Other Appendix Changes

Considering revisions in the Skin Corrosion/Irritation section to expand non-animal testing, recognizing in vitro test methods, and reorganizing that chapter. (Appendix A)
Adding a new hazard class for desensitized explosives (Appendix B)
Adding hazard categories for unstable gases and pyrophoric gases in the Flammable Gasses class and nonflammable aerosols in the Aerosols class (Appendix B)
Making editorial, clarifying and reorganizing changes and using more standard language in line with GHS Revision 8. (Appendix C)
Requiring prioritization of certain precautionary statements related to medical response. Currently some of the medical response statements give options such as call poison control center or call a doctor or choose between medical advice vs. medical attention. This can lead to confusion on which choice is best, so they want to standardize that with the best option. (Appendix C)

Definitions and Terminology

In the SDS section, a terminology change will replace the word “design” with “stored.” This will allow SDSs to be stored in a way that covers groups of hazardous chemicals in a work area. They believe the word “designed” is confusing because now SDSs have specific design requirements (16 section format) so they don’t want anyone redesigning an SDS for groups of chemicals in a work area.
Adding definitions for Combustible Dust, Bulk Shipments, Immediate Outer Packaging, Released for Shipment and Physician or Other Licensed Health Care Professional
Revising definitions of a Gas, Liquid and a Solid to align with GHS Revision 7
Revise the definition of a hazardous chemical to delete the reference to pyrophoric gases because those will now be a physical hazard in the Flammable Gas hazard class

Training Required

OSHA believes in its economic impact analysis that training updates will be minimal and only apply to certain types of employees. OSHA says that additional HAZCOM training will be needed to alert those who work with impacted aerosols, desensitized explosives, nonflammable gasses not under pressure, and flammable gasses about the changes in the SDSs. Those where labels may change may require some additional training and instruction on what to do such as with bulk packagings and small containers.

How Often Should There be Changes?

OSHA is soliciting feedback on how often changes should be made to the Hazcom Standard. GHS is updated every 2 years. OSHA wants to stay current with GHS revisions. Only the European Union has updated their guidelines in less time than OSHA (2016) while other countries have only said they planned on it, but haven’t done anything yet.

OSHA would like to know if they should install a regular schedule of updating every 4 years, every 2 revisions of the GHS, or if they should wait until there are significant changes before doing any updates.

Where Can You Make Comments?

You may submit comments identified by Docket No. OSHA-2019-0001, electronically at http://www.regulations.gov, which is the Federal e-Rulemaking Portal. Formal comments were due in May 2021, however, If you’d like to question witnesses or testify at OSHA’s informal hearing on September 21, 2021, submit your request by June 18, 2021 to the regulations.gov site.

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5 Ways OSHA’s Top 10 Can Make Your Safety Job Easier

Mar 4, 2021

5 Ways OSHA’s Top 10 Can Make Your Safety Job Easier

Getting Value Out of the “Same Old List”

OSHA’s Top 10 Violations for 2020 have been announced. So what! OSHA’s Top 10 hasn’t changed much in the past 5 or 6 years and most of the time it’s the same violations with the order switched around. The only “exciting” part is to see if a newcomer violation got on list. The list still didn’t even really change in a pandemic year either.

Well as un-newsworthy as this is, believe it or not, the annual confirmation that it’s the same stuff can actually make your job easier.

First, What’s on the List?

Below is a list of the Top 10 OSHA Violations for 2020

Fall Protection – General Requirements (1926.501): 5,424 violations
Hazard Communication (1910.1200): 3,199 violations
Respiratory Protection (1910.134): 2,649 violations
Scaffolding (1926.451): 2,538 violations
Ladders (1926.1053): 2,129 violations
Lockout/Tagout (1910.147): 2,065 violations
Powered Industrial Trucks (1910.178): 1,932 violations
Fall Protection – Training Requirements (1926.503): 1,621 violations
Eye and Face Protection (1926.102): 1,369 violations
Machine Guarding (1910.212): 1,313 violations

Respiratory protection moved 2 spots up the list this year along with eye and face protection up one spot as well. Ladders moved up a spot too. Your top 2 violations were the typical fall protection and hazcom.

Well…It’s the Top 10 for a Reason

First, companies continue to have problems with these issues. Many of them can be affected by employee behaviors such as how they choose to wear (or not wear) their PPE, conducting (or not) inspections, using (or not) injury saving controls, and situational awareness pitfalls. As a result, some of these are going to be easier to come across on any given day.

Next, these top 10 may also be considered the low hanging fruit of inspections. If these are the most common violations, then you could surmise inspectors are going to be looking at these. Further proof comes from OSHA’s national, regional and local emphasis programs. Emphasis programs allow an inspector to add to their investigation. For example, if you are having an inspection related to an employee complaint for respirators and there is an emphasis program in your area for powered industrial vehicles, OSHA inspectors can broaden their inspection if they see a forklift in your building.

A check of OSHA’s current emphasis programs includes items from the top 10. Out of 10 OSHA regions, there are emphasis programs for:

Amputations (including machine guarding) – National Emphasis
Falls – 9 Regions
Powered Industrial Vehicles – 5 Regions
Electrical – 2 regions
Respirators – 1 region
Construction Worksites – 10 regions

Make Your Job Easier Tip 1: Break it Down

The top 10 have specific standard references with them and from there we can see it’s a mix of general industry and construction standards. All 10 areas of safety are important. However, if you break the list down by the standard your company typically operates under, your focus areas are nearly cut in half and this becomes much more manageable.

General Industry-Related Violations	Construction Industry-Related Violations
Hazard Communication	Fall Protection – General Requirements
Lockout-Tagout	Hazard Communication**
Respiratory Protection	Scaffolding
Powered Industrial Trucks	Ladders
Machine Guarding	Fall Protection – Training
	Face and Eye Protection

**The 1926 standard for hazard communication refers to the 1910 standard.

Make Your Job Easier Tip 2: Instant Safety Topics!

Dealing with the immediate site-specific injury-causing issues should always be your first focus. However, you likely have safety committees, employee safety briefings, toolbox meetings, newsletters to write, safety emails to send, etc. The shortened list can now be easy go-to topics.

Get your co-workers and safety teams talking about them. As mentioned before, some of these items are going to be related to their behaviors and decisions anyway. Head off the top 10 one person at a time and don’t feel bad if you need to continue to cover them. The world of sales tells us that most people need to hear about something 7 times before it sticks.

Make Your Job Easier Tip 3: Get Your Documentation in Order

A number of these areas have specific training and/or inspection requirements. Document, document, document!

For training, keep records of who took training, when training was conducted, who the trainer was and what the content of the training included.

For inspections, find a way to document these and have a process in place for taking equipment which fails out of service. This will be important information for you during an inspection and can go a long way in staying away from the top 10.

Make Your Job Easier Tip 4: Incorporate These Into Your Walkthroughs

If you’re not doing so already, set aside a little bit of time each week to conduct a safety walkthrough and incorporate these items into your checklist. Routine walkthroughs will allow you to keep up on what’s going on at your site, gives you a chance to correct deficiencies, and gives you an opportunity to take advantage of teachable moments to the workers in those areas. Get your employees involved in inspecting their workplace. Have them be on the lookout for these same issues in walkthroughs and peer-to-peer observations.

Make Your Job Easier Tip 5: Get Help

You are not Superman/Superwoman. There are too many tasks, crises, and other forces that can get in the way of getting it all accomplished. A good manager needs a supporting cast. If you can get someone at your company to help you with tasks, that would be great. However, if you cannot, consider getting an outside company or safety professional to help. Consultants like iSi are here for a reason. We have people on-staff who have been in your position and have experience with the regulations. We can often do what needs to be done (and done correctly) in a fraction of the time it would take for you to do it, or for you to train someone else internally to do it. This can be as simple as getting help a writing program or conducting training. It could be having an audit done to see where you stand on compliance or a bigger project such as revamping a safety program or day-to-day onsite assistance.

In Conclusion

Use the data from the Top 10 as your instant to-do list. If you can tackle the items that pertain to you, you can help do your part in avoiding those common fines and maybe shaking up the list for next year.

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Explaining How OSHA Fines are Calculated, as OSHA Raises Penalty Prices for 2021

Jan 15, 2021

OSHA has raised its maximum and minimum penalty dollar amounts with a cost of living adjustment. These new rates go into effect January 15, 2021:

OSHA fines

There are maximum and minimum amounts, but most fall somewhere in between. So how are OSHA fines calculated?

The Violation Categories

Serious violations are considered high, medium or low severity. Other-Than-Serious violations are minimal severity.

Willful violations are cited when employers knowingly fail to comply or when they act with indifference to employee safety.

Repeated violations occur when an employer has been previously cited for the same or substantially similar condition. For serious violations, these are ones that have been a part of OSHA’s regionwide inspection history where an OSHA Notice was issued within the past 5 years. For other-than-serious violations, it’s for those where the establishment being inspected received an OSHA Notice within the past 5 years.

The Posting Requirements violation is issued when you fail to follow through on your requirement to post your OSHA Notice at or near the place where each violation occurred for 3 working days, or until the hazard is abated (whichever is longer).

Failure to Abate violations occur when you receive a Notice of Unsafe or Unhealthful Working Conditions and a follow-up inspection finds that you did not do your required posting, did not correct the violation and/or did not adequately protect employees and make appropriate progress in correcting the hazard before the abatement date that was listed on your notice.

Calculating Violation Amounts

There are a number of factors that actually can determine how much your penalty will be. There are four major categories of factors that go into the calculation:

Gravity of violation
History of violations
Good faith efforts of the employer
Business size

Gravity Based Penalty Amounts

First, the gravity of the violation is calculated. The Gravity Based Penalty (GBP) Amount looks at the level of severity (low, medium and high) and the probability, that is likelihood an injury or illness will occur (greater or lesser).

Severity + Probability = Gravity Based Penalty Amount

Here are the Gravity Based Penalty Amounts for 2021:

Gravity-based penalties for OSHA 2021

History Reductions

Combined or grouped violations can be considered one citation item. Multiple violations of the same standard can also be combined into one citation item. Expect the one with the highest gravity factor (severity or probability) to be used to determine the GBP.

A 10% reduction in penalty costs can be given to companies who have been inspected by OSHA and have had no serious, willful, repeat or failure-to-abate violations. If your company hasn’t been inspected within 5 years, you’re not eligible for this discount. If you’ve had a serious high gravity citation that became a final order, you could actually see a 10% increase in your costs.

Good Faith Reductions

A maximum discount of 25% can be given for good faith efforts. The maximum 25% discount requires you to have a written health and safety management system. This would include a system outlining:

Management commitment and employee involvement
Hazard identification worksite analyses
Hazard prevention and control measures
Safety and health training
Addressing needs of workers less than 18 years old (if applicable)
Addressing needs of workers who speak limited or no English (if applicable)

A 15% reduction may be given if the employer has a documented and effective safety and health management system with only incidental deficiencies.

Good faith discounts will NOT be given for high gravity, willful, repeated, and failure to abate violations, or if you’ve reported a fatality, inpatient hospitalization, amputation or an eye loss.

Business Size Reductions

A maximum 70% reduction can be gained based on your company size. OSHA wanted to create a scale where they could minimize the impact to small businesses. This reduction applies to businesses with 250 or less employees total nationwide. Companies with 1-10 employees can get the 70% reduction, 11-25 employees a 60% reduction, 26-100 is 30%, and 101-250 is 10%.

Quick Fix Reductions

If you’re able to make an immediate correction to an individual violation and that correction is 1) permanent or substantial (e.g., not just moving someone out of the way), 2) not blatantly obvious (e.g., wearing a hard hat or safety glasses), and 3) not a high gravity serious/willful/repeat/failure to abate violation, you can get a 15% Quick Fix reduction. This one is applied after the good faith and history adjustments are made.

Limits of Discounts

Different discounts can be rescinded or altered depending on the circumstance or type of violation.

Repeated violations will only be reduced for size. Repeated violations can actually have their penalties increased, and those increases are also based on size.

Willful violations are only eligible for a size and history discount. Willful violations have their own size chart of reduction percentages.

Serious violations classified as higher severity/greater probability are only eligible for the size and history.

Other Penalties

OSHA has additional calculation guidelines for a number of other circumstances including:

Unabated violations;
Daily penalty multipliers;
Partial abatements;
Violation-by-violation egregious penalties;
Multi-employer worksites;
Federal Agency significant cases;
Failure to post citations;
Failure to notify authorized employees of an advance notice of inspection;
Injury and illness reporting and recordkeeping;
Failure to provide access to medical and exposure records;
Failure to notify and tag; and,
Failing to certify abatement.

You can find all of the details about these penalties and reductions in OSHA’s Field Operations Manual section on penalties.

2021 adjustments and rates can be found in OSHA’s Enforcement Memo dated January 8, 2021.

If you find yourself needing help sorting these out, or if you’d like to get started on a safety and health management system to get started on a potential good faith discount, contact us!

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Ototoxicity – When Chemicals (yes, chemicals) Cause Hearing Loss

Nov 19, 2020

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The effects of chemical exposures in the workplace has been highly documented. Chemicals can affect you when you breathe them in, ingest them, inject them or absorb them through your skin. However, did you know that chemicals can cause hearing loss too?

What is Ototoxicity?

Chemicals which can contribute to hearing loss are called “ototoxicants” and the hearing loss itself is considered to be “ototoxicity.” Ototoxic chemicals reach the inner ear, connected pathways and nerve fibers through the blood stream or through the ear’s hair cells. Hearing losses can range from sound distortion to the inability to detect two sounds with similar frequencies to inabilities to detect time gaps between sounds or localize sound.

The problem increases when there is a noise exposure combined with the exposure to an ototoxicant. Ototoxic chemicals make a bigger impact on noise exposure, especially impulse noise. Ototoxic chemicals plus noise becomes worse than just the noise alone or the chemical alone. The noise levels do not even need to be above OSHA’s Permissible Exposure Limit (PEL) standards. It’s the combination of the two which causes the greatest damage.

Which Chemicals Are Considered Ototoxic?

Pharmaceuticals: aspirin, some antibiotics, NSAIDs, loop diuretics
Tobacco smoke
Solvents, degreasers and paints containing toluene, p-xylene, styrene, ethylbenzene, methylstyrene, trichlorethylene, carbon disulfide, n-propylbenzene or n-hexane
Carbon monoxide
Hydrogen cyanide
Nitriles: 3-butenenitrile, cis-2-pentenenitrile, acrylonitrile, cis-crotononitrile and 3,3’-iminodipropionitrile
Metals and compounds: mercury, lead, organic tin and germanium dioxide
Pesticides: pyrethroids, hexachlorobenzene, insecticides or organophosphates
Some limited research has also speculated arsenic, cadmium, halogenated hydrocarbons, bromates, alkylic compounds and manganese may also affect ototoxicity

Which Industries or Operations May be Affected?

Manufacturing
Construction
Printing
Painting
Fueling vehicles and aircrafts
Firefighting
Weapons firing (Military)
Pesticide spraying

How Do You Test for Otoxicity?

Determining whether you have the potential for this condition is primary. First, conduct a risk assessment to determine if your operations could be affected.

Check the Toxological Information section of the chemical’s Safety Data Sheet (SDS Section 11) to see if the chemical is considered a neurotoxicant. If there is nothing listed in this section, often other clues can be found in the SDS such as general toxicity, nephrotoxicity or if the chemical produces reactive free radicals.

From there, exposure limits and thresholds are dependent on different factors such as the chemical itself, exposure routes, concentration, duration, noise exposure and individual risk factors such as age. Workplace sampling will be able to help you quantify your exposures.

Audiogram tests can show early onset of hearing impairments and threshold shifts. However, they cannot tell you the difference between whether the impairment is noise-related or ototoxic-related. If you have complaints of hearing loss, investigate whether ototoxicity could be a factor.

The American Conference of Governmental Industrial Hygienists (ACGIH) recommends periodic audiograms for those who have noise exposures combined with carbon monoxide, hydrogen cyanide lead and solvent mixtures. When there’s not a noise exposure, ACGIH still recommends audiograms be used when workers have the potential to be exposed to ethylbenzene, styrene, toluene or xylene.

PPE and Training Requirements

Make sure you reduce the effects of ototoxic chemicals in your workplace either through controls such as isolation, limiting exposures, or eliminating unnecessary tasks, or through the use of PPE. Conduct your PPE assessment per OSHA rules. You may need to include proper hearing protection, as well as PPE which can prevent inhalation (respirators), or absorption through the skin (chemical gloves, arm sleeves, aprons).

If you have a potential for ototoxic chemical exposure, this also needs to be included in your Hazard Communication (HAZCOM) training.

Does This Affect You?

Do you have the potential for ototoxicity in your workplace? iSi can help you make that determination, conduct your risk assessment, and/or quantify your exposures through sampling. Contact us today!

Contributing:

Ryan Livengood

International Hazardous Materials Logistics Manager | EHS Regulatory Trainer

As a former corporate environmental, health and safety manager, Ryan has a vast experience in working with both environmental and safety compliance issues in multiple states. His specialties include national and international dangerous goods transportation, hazardous waste, environmental compliance, industrial hygiene and safety compliance. He is also an ISO 14001 Lead Auditor.

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2020 ERG – Emergency Response Guidebook Updates

Oct 28, 2020

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The new 2020 version of the Emergency Response Guidebook (ERG) is finally out, and hard copies are now available. The ERG is published every 4 years.

What is the ERG?

The ERG contains emergency response information and is a handbook used by emergency and hazardous materials incident responders, truck drivers, railroad personnel, pipeline personnel, pilots, police and firefighters. It is written and updated by four separate international agencies:

U.S. Department of Transportation’s Pipeline and Hazardous Materials Safety Administration (PHMSA)
Transport Canada’s Canadian Transportation Emergency Centre (CANUTEC)
Argentina’s Chemistry Information Center for Emergencies (CIQUIME)
Mexico’s Secretariat of Communications and Transport

iSi uses the ERG in our HAZWOPER training as well as our DOT Hazardous Materials Transportation, Hazardous Waste Management and RCRA Refresher classes. This is because handling emergency spills are a component of all of these classes.

Updates

The four agencies have been working on this latest version since 2017. In 2018, all of the agencies solicited input from their public through calls for comment, listening sessions, online surveys, and articles. From these solicitations, 100 comments were gleaned to be considered for incorporation and DOT held a public meeting as well. Since then, sub-groups worked on the updates.

Here is a list of the planned changes and items that were up for review within each section of the book. The agencies will:

White Pages [General Information, Instructions, Recommendations, Guidance]

- - Review content for use of plain language;
  - Improved quality of illustrations in charts for railcar and road trailer identification;
  - Add new lithium battery markings;
  - New terms in the glossary section;
  - Add a decontamination section; and,
  - Add basic information about heat induced tears (HIT).

Orange Pages [Response Guides]

- - Comprehensively review of all materials and their assignments in the orange pages by FEMA/NFA, with certain items up for review in 2020 while others will be reviewed before the 2024 version;
  - Distances in the Public Safety section are now in the Evacuation Section;
  - Created a new “How to Use the Orange Guide Pages” section;
  - Guide 121 Gases – inert was merged with Guide 120 Gases – inert (including refrigerated liquids);
  - Added CAUTION sentences for specific materials;
  - Clarify sentences;
  - Address inhalation concerns for petroleum crude oil (UN1267) in Guide 128; and,
  - Reevaluate radioactive materials guides with radiological/nuclear regulatory agencies.

Yellow/Blue Pages [Materials in ID/Name of Material Order]

- - Add or remove UN numbers to align with United Nations Model regulations and North American regulations;
  - Remove UN numbers for chemical warfare agents;
  - Reevaluated guide assignments for some materials; and,
  - Review polymerization hazards for certain materials.

Green Pages [Isolation and Protective Action Distances]

- - Add distances for new Poison Inhalation Hazard/Toxic Inhalation Hazard materials added by regulations;
  - Revise Table 2 introduction;
  - Add container capacities to Table 3;
  - Make a new border to differentiate between Tables 1, 2 and 3; and,
  - Argonne National Laboratory will update the Chemical Accident Statistical Risk Assessment Model (CASRAM) with outcomes from field and lab experiments.

Where Can the Current ERG Be Found?

A free PDF version of the current Emergency Response Guidebook is available online on the PHMSA website. There’s also a mobile app for the guide available for both Android and iPhone devices. If you’d like to purchase a hard copy for your use, check out the iSi online store.

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It’s “Basic” Environmental and Safety Training with iSi’s EHS Bootcamp Virtual Seminar

Aug 20, 2020

More About EHS Bootcamp

Visit our EHS Bootcamp website to learn more about the agenda and to register!

Bootcamp Site

Starting out, every day as an EHS professional felt overwhelming. I started at this company doing one thing, but I inherited EHS duties somewhere along the way. I didn’t have any formal training and I was wearing so many hats that I didn’t have a lot of time to search out training opportunities anyway. Over the years I was able to sift through the complex language of the regs, enough to identify what we needed to do to stay compliant. However, I always wished there was a course available to help weave through the madness.

— Many EHS Professionals We Meet

Does this sound familiar? We have worked with hundreds of EHS (environmental, health and safety) professionals over the years, and this is a story we hear all of the time. Very few people go to college to become an EHS professional, but somehow they end up being one. Safety regulations have a lot of standards to wade through and sometimes they tell you what you are required to do, or what they think you should do. Environmental regulations can be a whole other animal, with lots of arms and legs and elbows and teeth. In many cases available training is either pinpointed on a specific topic or is very generalized.

That’s why iSi has developed our EHS Bootcamp.

What’s an EHS Bootcamp?

Our bootcamps deliver overview and compliance information about specific regulatory topic areas in 45 min-1 hour increments. Within these sessions we explain what the reg is about, why it’s important, what the documentation requirements are and any other items you need to know about it.

We feel our EHS Bootcamps will be good for those who are new to the industry, those who have been in it a while and need a refresher, and those who deal with EHS regulations only on a limited basis.

September 24 EHS Bootcamp

Our first ever EHS Bootcamp will be online on September 24. We will have 2 tracks…an environmental track and a safety track with new topics every hour. You can choose the sessions you want to attend as they happen. So if you take care of both environmental and safety duties, you can choose from a mix of both sessions.

As an introduction, we’re offering this event for of only $100 per ticket! So if you have a conference that you were going to attend this fall that has been cancelled, think about attending this one!

Site-Specific EHS Bootcamps

We have many more presentations built and envision providing custom bootcamps to be held for individual companies. If this is something you’d like to see at your company, email us for more information.

We hope that our EHS Bootcamp will help you hone your professional skills and point out compliance issues you weren’t aware of.

Agenda

Check out the agenda below for our September 24 event!

EHS BOOTCAMP AGENDA — SEPTEMBER 24, 2020

All times listed in Central Time

}

9:00am – 10:00am

Environmental Track: Hazardous Waste

Safety Track: Regulatory Inspection Process

}

10:00am – 11:00am

Environmental Track: Clean Air Act/Air Permitting

Safety Track: Chemical Inventory for Hazcom

}

11:00am – Noon

Environmental Track: Stormwater

Safety Track: Injury Reporting and Worker’s Compensation

}

Noon - 1:00 pm

General Session:
ISO Certification: More About ISO 14001 and the New ISO 45001

}

1:00pm – 2:00pm

Environmental Track: Spills: SPCC and Contingency Plans

Safety Track: PSM and RMP

}

2:00pm – 3:00pm

Environmental Track: Wastewater

Safety Track: Electrical Safety

}

3:00pm – 4:00pm

Environmental Track: EPCRA and Emergency Planning

Safety Track: Developing an Industrial Hygiene Plan

}

4:00pm – 5:00pm

Environmental Track: DHS Chemicals of Interest

Safety Track: OSHA Emergency Action Plans

Contributing:

Marc Mason

Strategic Channel Manager

Marc is the leader of our sales and marketing team, and as a member of iSi’s family ownership group, he has been around iSi pretty much all of his life. Besides business development efforts, Marc works with iSi’s departments and our clients to help find and implement new technologies for better efficiencies and client benefit.

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Workplace Safety Technology: T-Mobile for Business Adds 4G LTE HardHat and Contactless Temperature Device

Jul 30, 2020

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T-Mobile for Business has added two new workplace safety technology products geared to make workplaces safer. Each one also has features to help provide solutions related to recent concerns with workplace health. The first product is a “smart” hard hat by Guardhat. The other is a contactless temperature device for people entering crowded or confined spaces. Both devices will take advantage of T-Mobile’s 4G LTE connectivity.

Guardhat

Guardhat utilizes sensors that let you know where the worker is at all times and what conditions they are working in order to analyze that data. It also allows for audio and video communications so that you can see what they see and communicate back and forth with a central control center.

Some of the features include:

Location: Geofencing sensors track where Guardhat wearers are at, at all times. Persons at a central control center can see where they are on a map. Wearers can be alerted when they’re getting too close to hazards such as moving equipment, lockout/tagout areas, working areas like trenches or equipment drop zones and other dangers. Sensors can be placed on all types of equipment and other assets so it can be tracked as well.
Communications: Guardhat wearers can communicate with the control center through voice and video capabilities.
Environment Monitoring: The hat will sense gases, noise, temperature and pressure issues and sound an alert until the worker gets to a safe location. Persons at the control center will be able to use the camera on the hat and the locating sensors to help guide the worker to safety, if needed.
Physical Monitoring: The hat monitors vital stats and if it senses something is medically wrong with a worker wearing one, it will send an alert to other Guardhat users in the area and then will contact emergency medical services.
Fall Detection: The hat will sense when a worker has fallen and will alert other wearers in the area as well as emergency services.
Social Distancing: Location sensors can also be setup to ensure workers are working 6 feet from each other for social distancing purposes.

Guardhat is good for workers in areas with a number of hazards around them as well as workers who work alone in isolated areas.

PIMMAP Contactless Temperature Solution

The PIMMAP Contactless Temperature Solution is an 8-inch HD tablet that is an infrared camera and contactless temperature sensor. It can be mounted to stands, kiosks or stations in places like schools, offices, arenas, factories, stores, hospitals, etc.

A person will stand in front of the device and it will use its infrared camera and facial recognition features to take temperatures at accuracy readings +/- 0.36 degrees F. Facial recognition technology will also scan for signs of fatigue, watery eyes, and other flu-like symptoms.

Readings can be taken from 3-5 feet from the device and can scan 40 persons per minute. An alert will come up on the screen if the temperature is too high.

The data for the device can be transferred to cloud servers and they can send push notifications. They can also be worked on and troubleshot remotely. If there’s no internet access where the device is located, it has its own 4G LTE router.

To learn more about these workplace safety technology devices, check out T-Mobile’s news release about them here.

Contributing:

Tami Hadley

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Update: 2020 Final Rule Adds to and Clarifies OSHA Beryllium Standard

Jul 23, 2020

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OSHA’s beryllium exposure standard for general industry, construction and maritime has been in place since May 2018, with various enforcement dates for different requirements. Included below are the major highlights of the standard as well as 2020 Final Rule updates due to become effective on September 14, 2020.

There are a number of requirements for companies with potential beryllium exposures. Do these apply to your company?

What is Beryllium?

Beryllium is a lightweight but strong metal used in aerospace, telecommunications, information technology, defense, medical, and nuclear industries. It can be found in various items such as brake systems, missile parts, guidance systems, welding, alloys in dental crowns and bridges, laser devices, heat shields, computer parts, x-rays, golf clubs, bicycles and more. Exposure to beryllium comes through inhalation and through contact.

What’s Required in OSHA’s Beryllium Exposure Standard?

Exposure Assessments and Limits

If your workers are expected to be exposed to beryllium, you must conduct an exposure assessment using performance or scheduled monitoring methods. There are standards for exposures:

Permissible exposure limit (PEL) to 0.2 micrograms per cubic meter, averaged over 8 hours;
A short-term exposure limit (STEL) of 2.0 micrograms per cubic meter over a 15 minute sampling period; and,
An action level of 0.1 micrograms per cubic meter, calculated as an 8-hour time weighted average.

NEW (2020) The definitions of a confirmed positive case (including a clarification of time requirements for abnormal or borderline test results) have been updated.

Written Exposure Control Plan

If workers will be exposed to beryllium, companies must prepare a written exposure control plan. It doesn’t matter if you’re over the above limits – if you have the potential exposure, you need a written plan. The plan must include a list of operations and job titles affected, procedures for minimizing cross contamination and keeping surfaces clean, required engineering controls/practices to be used, respiratory protection methods, required personal protective equipment (PPE), and procedures for handling contaminated PPE, clothing and respirators. The plan must be reviewed annually, updated as required, and available for employee review.

PPE

Companies must provide respiratory protection where exposure cannot be controlled and personal protective equipment separate from street clothing must be provided to limit skin contact. For protective clothing, change rooms and showers are to be provided and used. These rooms and showers must be in place by March 11, 2019. There are specific rules for PPE

NEW (2020) OSHA did not intend for beryllium-related PPE to be worn in areas outside of beryllium work areas. Thus, it’s important for employers to determine what their beryllium work areas are, that is, where is there a potential for dermal contact and airborne impact and then act accordingly with PPE. Employees who could reasonably be expected to have airborne exposure to and/or skin contact with soluble beryllium, beryllium solutions, or visible beryllium dust, fumes, or mists in concentrations of 0.1 percent by weight or more would be the ones affected. OSHA also didn’t intend for PPE to be changed out after each individual work task and didn’t intended that residue be completely eliminated before entering eating and drinking areas, it needs to be “as free as practicable.” They’ve made some word changes to clarify this.

Beryllium Work Areas

Engineering and work practice controls such as ventilation changes or enclosure must be developed to prevent excessive beryllium from becoming airborne. Engineering controls are due by March 10, 2020. In the meantime, beryllium work areas must be marked and have limited access. In construction, a competent person must be designated to mark these areas.

NEW (2020) Some minor changes have been made in the Housekeeping section for disposal, recycling and reuse. The rule’s requirements for disposal, recycling, and reuse do not apply to intra-plant transfers; more detail has been given as to what constitutes an appropriate enclosure; materials bound for disposal can be cleaned; and some minor wording changes have been made to this section and other sections to make them easier to understand.

Medical Monitoring

Companies with beryllium exposures must offer medical exams to affected workers. If a worker has a beryllium-related disease, companies must offer additional workplace accommodations for the worker to protect themself from additional exposure.

NEW (2020) OSHA has made clarifications regarding the specific timing on when employers are to have employees who may have been exposed to beryllium in an emergency get medical exams taken, depending on when their last exam was or if they’ve ever had one. In another update, because exams at Chronic Beryllium Disease (CBD) Diagnostic Centers may take more than 30 days, OSHA has allowed for the initial consultations to be done within 30 days (including virtual/phone consultations) and then full evaluations within a reasonable time. The employer must also be sure the employee is offered any tests deemed sufficient by the examining physician at the CBD testing center, and if not offered there, they should be allowed to be performed at a separate location mutually agreed upon by employer and employee.

Worker Training

Affected workers must be trained in the hazards of beryllium. This must be done separately from Hazard Communication training and be specific to beryllium.

NEW (2020) Just as PPE pertains to those in beryllium areas, so does training. Those are employees working in beryllium work areas and any other employees who may not be working directly with a beryllium-generating process, but who may reasonably be expected to have airborne exposure to and/or skin contact in concentrations of 0.1 percent by weight or more.

Recordkeeping

NEW (2020) In recordkeeping requirements throughout the standard, all references to collecting social security numbers have been removed.

Other 2020 Changes

Dermal and Airborne Contact, but Not Everybody: Just like PPE and training have been clarified it’s only for those working in or could be reasonably affected by beryllium, medical monitoring, wash facilities and change rooms are also subject just to those persons who could be exposed. References to dermal contact have been updated to also encompass airborne contact, but this change also helps narrow the requirements so that they don’t have to be in place for everyone in the facility.
Check out the complete 2020 final rule revisions and explanations in the Federal Register HERE.

Does This Apply to You? We Can Help You Find Out

Are your workers exposed to beryllium? What are your exposures, which work areas of your company are affected, and do you have the necessary protections in place? Let iSi conduct your monitoring to check. We can also help you with plans, PPE recommendations and training. Contact us today!

Contributing:

Keith Reissig

Industrial Hygienist | Project Manager

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

Email | LinkedIn

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Industrial Hygiene in Construction: Focus Four Health Hazards

Jul 9, 2020

Recently the American Industrial Hygiene Association (AIHA) published results of its study of construction occupations and workers across 32 states regarding construction worker health.

For several years, there has been an OSHA Focus Four emphasis on physical safety (Falls, Electrocutions, Struck-By and Caught-In-Between). However, at construction worksites, the focus on industrial hygiene in construction and worker health has consistently lagged behind. Besides Focus Four and equipment and tool safety, companies focus on zero injuries. Health hazard exposures are just as common and can be harder to see because some may not arise until they become chronic.

As a result, AIHA has published a guidance document on a new Focus Four for Construction HEALTH Hazards including:

Manual Material Handling
Noise
Air Contaminants
High Temperatures

Manual Material Handling

Manual material handling is strenuous work that can cause overexertion. Repeated work day after day, vibration from tools and equipment or awkward positioning can cause musculoskeletal disorders (MSDs) such as back strains and sprains; arm and hand injuries; elbow and shoulder issues; and knee disorders. There are not many medical remedies for MSDs other than pain killers which can lead to opioid addictions. Disabilities and early retirement can also arise. MSDs are not cheap from a worker’s compensation perspective, taking 50% of all worker’s comp costs in construction.

AIHA says reducing these hazards will not only lower your costs, but help you retain your most experienced workers, help attract new employees, keep employees productive as they age and increase roles for women in the trades.

Noise

Exposures to noise can create either temporary or permanent hearing loss and other problems like tinnitus (ringing in the ears), sleep disturbance, impairment of balance, hypertension and cardiovascular disease. AIHA says a rule of thumb to use is that if you need to raise your voice to talk with someone an arm’s length away, the noise level will be over your 85 decibel limit. There are also many apps for your phone that can give an approximate noise level reading. Just remember these are not calibrated and can be off by several decibels. Those exposures at 85 decibels will cause damage over time, but construction tools and activities at 130-140 decibels will cause instant damage.

AIHA says hearing loss is the most common workplace illness in the U.S., and there is no cure for hearing loss or tinnitus.

Make sure you know what your noise exposures measurements are , know how to properly select and use hearing protection, communicate noise hazards, conduct hearing tests annually, train employees and include information about noise off the job. Better yet, find ways wherever possible to reduce noise exposures.

Air Contaminants

Air contaminants can include dusts, metal fumes, gases, vapors, solvents, and exhaust. Odors are not always present, and those who “get used to the smell” may not know their overexposures to it. For some contaminants, the fact that you can smell them means you’re already overexposed.

Contaminants can be inhaled or absorbed. Inhalation causes damage to the nose, throat and lungs causing damage and potential for asthma, breathing difficulties, lung scarring, COPD and lung cancer. Absorption can cause blood, nervous system and organ damage.

This is another health hazard that may not be seen right away, but can arise later in an employee’s life, affecting quality of life.

This hazard can be reduced by pre-planning, determining:

Hazards of material to be used – what does the SDS say?
Amount used?
Duration used?
How will it be dispersed?
Confinement/enclosures used?
Controls used?
Ventilation and exhaust planned?
What PPE is needed?
Are respirators needed and do you have a proper respiratory protection program in place?
What are the occupational exposure limits allowed?

AIHA cautions that just because a task will be done for a short amount of time doesn’t lessen the hazard.

High Temperatures

Construction workers are susceptible to heat exposures due to the nature and location of their work. Often things like PPE will add to the potential for problems.

Heat exposures play with the body’s ability to think clearly and act normally, so the worker may not speak up. That’s why it’s important for all workers, supervisors and foremen to be aware of the signs and symptoms of heat-related illnesses.

Proper training and planning ahead will help prevent major issues. Make sure you look at things like:

Heat index
Experience and acclimation of worker (new or temp workers?)
How much work will be in direct sun?
Confined spaces
Additional heat sources (radiant heat/welding)
Physical workload
PPE to be used
Insulation and heat shields
Ventilation
Work schedules
Hydration, shade and break areas

In Closing

Although this article focuses on the construction worker, there is a lot that general industry workplaces can learn from this information too.

For more information about the Focus Four Health Hazards, check out the AIHA guidance document.

iSi’s team of industrial hygienists can help you with these issues and take care of the workplace and employee sampling that’s needed in several of these hazards. Contact us today with your questions or to get a price quote.

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Contributing:

Tami Hadley

Email | LinkedIn

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EPA Adds 1-BP to Clean Air Act Hazardous Air Pollutants List

Jun 25, 2020

EPA has added 1-bromopropane (1-BP), aka n-propyl bromide, to its list of hazardous air pollutants under the Clean Air Act. This is the first time since 1990 that EPA has added a chemical to the list from a petition request.

The CAS number for 1-BP is 106-94-5.

How is 1-BP Used?

1-BP is found in products for the following applications:

Adhesive sprays
Solvent sprays for asphalt production, aircraft maintenance, and synthetic fiber manufacturing
Vapor and immersion degreasers for cleaning plastics, metals, electronic components and optical components
Dry cleaning
Spot removers
Coin cleaners
Paintable mold release products
Automotive refrigerant flushes
Lubricants

Which EPA Compliance Obligations Will This Affect?

Since the change is part of the Clean Air Act, you will need to take note that this will affect the following EPA reports and permits:

SARA 313, Form R Toxic Release Inventory
Air Emissions Permits
EPCRA Tier II Report

You should also now start tracking the quantities purchased and used to help you with these reports.

What is the Hazard?

1-BP can be inhaled as a vapor or mists of spray and can also be absorbed through skin contact. It is colorless with a sweet odor. It can cause irritation of the eyes, nose and throat, and can damage the nervous system. Women of childbearing age are cautioned that prolonged exposure can cause developmental and reproductive effects. Extreme cases can cause kidney and liver issues as well as neurological issues such as dizziness, loss of consciousness, slurred speech, confusion, twitching and difficulty walking.

Some people have experienced symptoms with use as little as 2 days, but most cases have effects after long-term exposure.

Make Sure You Know Your Exposures

If your company is using products with 1-BP, please make sure you are conducting industrial hygiene sampling of your employees and their usage of 1-BP to identify what their exposures are. The American Conference of Governmental Industrial Hygienist’s (ACGIH) threshold limit value for 1-BP is a very low 0.1 ppm, so any exposures over that will require respiratory protection.

iSi has conducted 1-BP sampling for two of our clients within the past year. Each were using vapor degreasers with 1-BP in them. Exposures measured at 3.74 ppm for one company and 49.5 ppm for another. These were very well above the recommended 0.1 ppm and each company needed to change protocols to get the exposures down.

PPE and Administrative Controls

Besides respiratory protection when limits are over the thresholds, both EPA and OSHA recommend usage of chemical protective gloves/clothing and eye protection when handling 1-BP.

OSHA has specific recommendations for eliminating the hazard altogether through isolation, ventilation and other engineering controls. Some administrative controls they recommend include reducing both the time and number of workers exposed to the chemical, purchasing and storing the least amount possible and keeping containers closed between use.

Because of the hazard, there are other products now on the market that can be used for the same functions that do not have 1-BP in them.

Get 1-BP fact sheets on the EPA website here and on the OSHA website here to learn more.

Questions?

If your company is using 1-BP and you have questions on how it will affect your compliance reporting and tracking obligations, we can help! Email us or contact us by phone.

1-BP Assistance

If you need help determining how this new rule will affect your air reporting, or if you need 1-BP exposure sampling to see where you stand, contact us today!

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Safety News Briefs: OSHA 300 Public, Tyvek Shortages, New Respirator Posters

Jun 19, 2020

Here are a few recent headlines from the world of safety:

Federal Judge Rules OSHA 300 Info is Not Confidential

A federal judge in the U.S. District Court for Northern California has ruled that OSHA injury and illness log information is not confidential. The ruling comes as a part of a lawsuit where news organization the Center for Investigative Reporting made a Freedom of Information Act (FOIA) request to OSHA for records and OSHA denied the claim under FOIA exemptions for “law enforcement” and “trade secrets”.

The judge ruled that because employers are required to post this information annually and keep it on file for up to 5 years so that current and former employees can review them, these employees can freely share this information. Thus, it’s readily observable and can be made public anyway.

The Center for Investigative Reporting was pleased with the ruling, saying that it would help keep the “dangerous” employers accountable and encourage them to improve safety while giving workers a better understanding of the risks involved in the job.

MSA Warns of Shortage of White Tychem, Tyvek

Personal protective equipment company MSA Safety has issued a notice regarding a shortage of the white DuPont Tychem hoods used for powered air purifying respirators. DuPont notified MSA that there would be shortages of white Tyvek, including Tychem, materials until early 2021.

MSA will be substituting white hoods with yellow Tychem hoods. They say that the yellow Tychem is just as protective as the white. However, some companies have policies requiring the white, and those policies may need to be altered for a while until the supply is restored.

Respirator Posters Available in 16 Languages

OSHA’s poster “Seven Steps to Correctly Wear a Respirator at Work” has now been published in 16 different languages. These include English, Spanish, Arabic, Brazilian Portuguese, Chinese (Simplified and Traditional), French Creole, Hmong, Korean, Kunama, Polish, Russian, Somali, Tagalog, Thai and Vietnamese.

As many manufacturing safety managers know, most OSHA documents and posters are not printed in this many varieties, so this is a great time to get these for your workplace. Find all of these for download at https://www.osha.gov/news/newsreleases/national/06152020-0.

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iSi Summer Safety Toolbox: Staying Hydrated

Jun 10, 2020

It’s every person’s duty to watch out for themselves and their teammates. Providing cold water for your team is beneficial during hot days, as is having a first aid kit. If you have a first aid kit, kudos! If you don’t have a first aid kit, now is the time to get one. A few beneficial items to add to your first aid kit would be cold packs, cooling towels, electrolyte/salt tablets, or electrolyte powder drink mix. There are also specific first aid kits that can be purchased that include heat-stress care items.

Some symptoms of dehydration include:

Extreme thirst
Less frequent urination or dark colored urine
Decreased sweating
Muscle cramps
Nausea, dizziness or confusion
Fatigue

If you’re a supervisor who would like some ideas on a heat safety plan or have questions on where to find quality first aid kits, contact us!

Contributing:

Drew Lyon

Email | LinkedIn

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How UV Lighting Can be Used as a Disinfectant for Your Facility

May 28, 2020

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UV Light for Your HVAC

iSi can now provide disinfecting UV lighting for your HVAC system. UV light installations kill protein encased viruses, bacteria and mold.

Learn More!

UV lighting can be used as another tool in your safety and environmental arsenal to make your workplace safer and healthier. But how does it work?

What is UVGI?

Ultraviolet Germicidal Irradiation, or UVGI, is a technology that goes back to the 1930’s with studies showing that ultraviolet light has the ability to kill or inactivate airborne microorganisms. These studies showed that an optimal wavelength of 265 nanometers (nm) was able to provide the largest reduction in airborne microorganisms. This was found to be very close to the wavelength produced by low-pressure mercury vapor lamps (254 nm).

Ultraviolet light can be broken down into 4 different bands:

UV-V: 10-200 nm
UV-C: 200-280 nm
UV-B: 280-315 nm
UV-A: 315-400 nm

The sun emits the full spectrum of ultraviolet light but only UV-A & UV-B make it to the surface. The others are filtered out by the Earth’s atmosphere. The UV-C band is the most effective at attacking the harmful microorganisms, so it needs to be generated artificially.

UV light spectrum

How does UVGI work?

UV-C wavelengths are readily absorbed by the DNA and RNA of microorganisms such as germs and mold. When absorbed, UV damages their DNA or RNA structure, preventing the microorganism from replicating. The magnitude of their reduction is affected by their resistance to UVGI, the quantity of UV energy delivered, and the type specific microorganism being irradiated.

Wall-mounted UV light system.

Disinfecting light is delivered in two common methods. The first is by placing light units, either with or without fans, near the top of a room close to the air vents in order to clean the air as it circulates the room.

The second method is to place the unit directly into the heating and air conditioning (HVAC) system. This second method places the light in a location where the room occupants are not directly exposed to the light, and if placed correctly, can have an added advantage of cleaning the HVAC coils and drip pan to improve the efficiency of the HVAC system.

UV light for HVAC system.

The design and placement of these different systems are governed by the American Society of Heating, Refrigerating, and Air-Conditioning Engineers (ASHRAE) which has published many documents on the subject.

UV Safety Considerations

UV-C band light is a safer band than the UV-A and UV-B that we deal with in nature. We have always been taught to apply sunscreen and wear sunglasses to protect ourselves from the burns we receive when outside. Due to the shorter wavelengths UV-C will only penetrate the outer skin layers and along the surface of the eye. It will not give you the severe sun burn the longer wavelengths will. It will cause a reddening and slight irritation of the skin and an painful itching sensation that will last a few days in the eye so slight protection is required if you are directly exposed to the light from these units.

UV Lighting for Your HVAC Units

iSi is now providing the second method UV germicidal lighting, the one for your HVAC system. Our units are customized to your specific HVAC system and area to be disinfected. Learn more about this service and get a quote here.

Contributing:

Ryan Livengood

International Hazardous Materials Logistics Manager | EHS Regulatory Trainer

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COVID-19: A Potential OSHA Recordable Illness

May 20, 2020

UPDATED 5/22/20

Recently published guidance from OSHA clarifies that workplace-contracted COVID-19 can be a recordable illness. That is, a recordable if it was contracted as a result of work duties.

Illnesses such as the flu and colds have always been, and continue to be, exempt from recordable illnesses recordkeeping. However, COVID-19 is NOT exempt from being a recordable, even though it contains some of the same symptoms as the flu and cold.

When COVID is Recordable

Use the following guidelines when determining if a case of COVID 19 is a recordable illness:

Is confirmed as a coronavirus illness,
Falls under one or more of the typical recording criteria such as medical treatment beyond first aid, hospitalization, or days away from work, and
Is work related as defined by 29 CFR 1904.5.

Determining if it’s work related will take some investigation on your part as there’s a possibility that exposures can occur outside of work as well. OSHA expects employers to make reasonable efforts, based on the evidence available to make that determination. A best practice is to ensure you have documentation of your investigation, including all the steps you took to come to your findings, and what led you to choose why to count or not count that illness.

Like with other recording requirements, companies with 10 or fewer do not need to make a recording unless it is work related and results in a hospitalization, amputation, loss of an eye or a fatality.

Have a Plan

Some workplaces and worker tasks are considered to have a higher risk for employee exposure. Most workplaces will have a low exposure risk. Those in healthcare, death care, airline, border protection, solid waste management and wastewater treatment are considered to be in the high risk category. Workers who are required to work within 6 feet of each other would fall in the medium risk exposure level because the virus is spread through person-to-person droplet contact within that 6-foot range.

As a result, OSHA says it is important for workplaces to take measures to prevent the spread of COVID-19 and have a plan for dealing with it. OSHA’s guidance specifically says there is currently no standard that covers COVID-19, but it would fall under the General Duty Clause that requires employers to provide workers with “…a place of employment which is free from recognized hazards that are causing or likely to cause death or serious physical harm.” They also mention the PPE standards (1910 Subpart I) which covers usage of gloves, eye protection, face protection and respirators and the Bloodborne Pathogens standard (29 CFR 1910.1030) which covers exposures to body fluids and blood.

Respirator Usage

Depending on work tasks and potential exposures, workers may need to wear masks, goggles, face shields, and/or respirators. In the guidance document, OSHA says that workers, including those who work within 6 feet of patients known to be, or suspected of being, infected and those performing aerosol-generating procedures, need to use filtering facepiece or better respirators. Remember that if your workers are wearing respirators, you must have a comprehensive respiratory protection program that has its own complete set of requirements. You can find the respirator standards at 1910.134.

Hierarchy of Controls

OSHA’s guide contains ideas for identifying and isolating sick people, where appropriate. OSHA also draws on the Hierarchy of Controls, just as it does for all other safety concerns. For example:

Engineering Controls

High-efficiency air filters
Increased ventilation rates
Negative pressure ventilation in areas where aerosols are generated

Administrative Controls

Encouraging sick workers to stay home
Virtual or teleconferenced meetings rather than face-to-face
Alternating days or extra shifts to reduce the number of employees in the building, increasing work distances
Discontinuing non-essential travel
Emergency communication plans
Worker training

Safe Work Practices

Promote personal hygiene with tissues, no-touch trash cans, hand soap, alcohol rubs and wipes, disinfectants and disposable towels
Required regular hand washing or alcohol hand rubs, especially after removing PPE
Post handwashing signs in restrooms

PPE

Select based on hazard to the worker
Ensure proper fit and refit
Consistent and proper wear
Regular inspections
Regular cleaning, maintenance and repair
Proper storage and disposal

OSHA says PPE recommendations are likely to change depending on location, current PPE effectiveness and the nature of the job, so check in with OSHA and the CDC website for updates on recommended PPE.

Resource Links

OSHA has a dedicated webpage covering COVID-19 and they have published a guidance document in conjunction with the Department of Health and Human Services. Both of these address measures on how to protect workplaces and workers at low, medium and high exposure risks and those who work in the specifically targeted high risk industries above. Below are links to resources for COVID-19 planning and information:

OSHA and DHHS Guidance on Preparing Workplaces for COVID-19

OSHA COVID-19 Website

CDC COVID-19 Website

EPA’s List of Registered Antimicrobial Products for Use Against Novel Coronavirus SARS-CoV-2, the Cause of COVID-19

Need Help? Have Questions?

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COVID Complaints: Will You Be Inspected by OSHA?

May 15, 2020

Updated 5/22/2020

With tensions somewhat high about the COVID-19 pandemic, OSHA has experienced quite an increase in the number of whistleblower complaints from workers. As a result, OSHA has published some enforcement guidance to their inspectors on how to handle these complaints.

Employee Complaints

OSHA complaints over the past few months have centered mostly on two issues. One, a lack of PPE such as respirators, gloves, gowns, etc. The other is on the lack of training a company may have given their employees on the standards and COVID in the workplace.

OSHA Puts Employers in One of 3 Risk Groups

High Risk

These are medical-related facilities with a high risk of coming into contact with the virus. These could include hospitals, emergency rooms, medical centers, nursing homes, postmortem facilities, or labs.

Medium Risk

These facilities have high contact with the general public or are densely staffed so that it would be difficult to maintain a 6 ft. distance. Facilities with contact with international travelers would also fall into this group. Some examples would be airports, high retail, schools, and any other business tightly crowded.

Low Risk

These facilities have little contact with the general public and don’t provide a lot of frequent close contact where it’s not a problem to maintain a 6 ft. distance.

Inspections

Originally, only the High Risk category of facilities were planned for inspection unless something drastic happened in one of the other facilities, such as a COVID-related fatality. This is because the resources of OSHA are limited and there was a concern by OSHA to keep inspectors safe and healthy themselves.

However, there was backlash to this policy from union and industry groups, prompting OSHA to modify it to add the possibility of conducting inspections at other facilities. Starting May 26, 2020, inspections will be determined based on the following:

In geographic areas experiencing sustained elevated community transmission or a resurgence in community transmission priority will be given to high risk facilities mentioned above. Priority will also be given to workplaces with high numbers of complaints or known COVID-19 cases.
- Where resources are not available, OSHA will initiate the inspection remotely with the understanding that an inspection will be conducted onsite when the resource becomes available.
- OSHA will develop a program to conduct monitoring inspections from a random sampling of fatality or imminent danger cases where inspections were not conducted because of low resources.
- Use non-formal/fax/rapid response investigation in industries where doing so can address the relevant hazard(s).
In geographic areas where community spread of COVID-19 has significantly decreased:
- Fatalities and imminent danger exposures related to COVID-19 cases will be prioritized.
- OSHA will use non-formal/fax or rapid response investigations (send a letter) when possible to ensure effective use of resources, especially in medium and low risk facilities. However, it’s up to the Area Director’s discretion to conduct an onsite inspection in these cases.

What to Expect in an Investigation Letter

OSHA will inform you of the complaint that has been made, and it will be your company’s responsibility to:

Investigate the complaint
Determine results and respond by a certain date
Provide backup documentation of your investigation
Provide corrective actions taken or to be taken
Provide backup documentation of corrective action
Post the letter
Sign a certificate that you posted the letter

If you do not respond to the letter, then you may get inspected. The employee who made the complaint, requesting OSHA do an inspection will receive a copy of OSHA’s letter to you and will be advised of your response.

For more details, check out the inspector enforcement memorandum on OSHA’s website.

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Return to Work Building Issues: Stagnant Water

May 1, 2020

Legionnaires, Heavy Metals Among the Hazards That Could Affect Your Building’s Water System Safety

As we all prepare to return to work, we may find additional hazards lurking in our buildings if they have been closed up or have had limited occupancy due to stay at home orders. Building water systems that have been sitting stagnant can have depleted disinfectant levels. This leads to increased bacteria and biofilm levels inside the system. It can also show increased levels of corrosion products such as iron, lead and copper depending on what your pipes are made from.

Water System Safety: Environmental and Safety Hazards of Stagnant Water

As water sits unused in pipes, the disinfectant normally found in water (typically chlorine, but check with your water service to see what they are using) depletes to a point where a biofilm forms inside the pipe. This biofilm then grows and when the system is turned on water droplets can become airborne and inhaled causing many illnesses that can affect the lungs such as Legionnaires’ disease. Water that has sat in pipes also increases the amount of corrosion products from the piping itself and can lead to increased levels of metals in the water, depending on what your plumbing is made from. These increased levels can be ingested from various sources within a company such as drinking fountains, ice machines, plumbed coffee systems, water softeners, improperly maintained water heaters, on demand water heaters and dishwashers.

Water System Safety: Have a Plan to Deal With the Stagnant Water

Before buildings are reopened, a plan should be established to flush out the contaminates in your building’s entire water system. This flush should go all the way back to the main line from the municipality. You may need the assistance of a plumber or water engineer to properly determine the size and length of the pipes so the proper volume of the water system can be calculated.

Once known, the volume will then determine the length of time the system will need to flow. In some cases, this could require over an hour of water flow. Be sure to pay special attention to any dead spaces in both the hot and cold-water systems. Remember, this water can be contaminated with bacteria that may cause respiratory issues and the hot water may be hot enough to cause burns so be sure to include proper safety equipment in the plan if doing large scale flushing.

Water System Safety: Clearance Testing

Once the system has been flushed, testing can be done on the water to determine if it meets the standards established by the Environmental Protection Agency (EPA) for Primary Drinking Water. Those standards can be found at https://www.epa.gov/ground-water-and-drinking-water/national-primary-drinking-water-regulations. If you are interested in the USEPA’s Lead and Copper Rule a Quick Reference Guide can be found at https://nepis.epa.gov/Exe/ZyPDF.cgi?Dockey=60001N8P.txt.

If you need assistance in determining the safety of your buildings water system, please contact iSi.

Contributing:

Keith Reissig

Email | LinkedIn

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Bleach Safety

Apr 24, 2020

With the spread of COVID-19, businesses and households are looking for ways to clean and sanitize surfaces, and bleach is one of those cleaners that experts have deemed acceptable. Before you begin, please review these bleach safety tips to ensure you and your workers are protected:

Uses for Bleach

Bleach can disinfect which means it is effective at killing most bacteria, fungus and viruses but the surface needs to be clean of dirt and grime beforehand. If needed clean the surface with soap and water before disinfecting.

Cleaning refers to the removal of dirt and impurities, including germs, from surfaces. Cleaning alone does not kill germs. But by removing the germs, it decreases their number and therefore any risk of spreading infection.

Disinfecting works by using chemicals to kill germs on surfaces. This process does not necessarily clean dirty surfaces or remove germs. But killing germs remaining on a surface after cleaning further reduces any risk of spreading infection.

The Centers for Disease Control & Prevention (CDC) recommends the following concentrations for disinfection of hard surfaces:

5 tablespoons (1/3rd cup) bleach per gallon of water
4 teaspoons bleach per quart of water

Remember to always add bleach to water and not water to bleach.

Personal Protective Equipment

Bleach is a corrosive, meaning it will burn skin, so it needs to be kept off skin and out of eyes. So always wear the following when mixing and using bleach.

Nitrile gloves
Safety glasses or chemical goggles
Long sleeves
Pants
Covered shoes

Always wash your hands with soap and water after working with any chemical but especially before eating, drinking or smoking.

First Aid

Eyes: Hold the eye open and rinse slowly and gently with water for 15 to 20 minutes, or for the time the manufacturer recommends. Remove contact lenses, if present, and continue rinsing the eye. Call a poison control center, emergency services, or a doctor.
Skin: Remove the contaminated clothing. Rinse the skin immediately with plenty of water for 15 to 20 minutes, or for the time the manufacturer recommends.
Inhaled/breathed in: Move the person to fresh air. If breathing is affected, call a poison control center, emergency services, or doctor.
Swallowed: Call a poison control center, emergency services, or doctor. Do not try to get the person to vomit unless told to do so specifically by a medical professional. Do not give anything by mouth to an unconscious person.

When providing first aid or when helping another person, be careful not to come into contact with the bleach yourself. Use protective clothing when necessary.

Hazards of Mixing Bleach

Don’t mix bleach with ammonia, acids, or other cleaners. Mixing bleach with common cleaning products can cause serious injuries. Be sure to always read the product label before using a cleaning product.

iSi works with companies to help them with safety and industrial hygiene issues. Contact us if you have questions about industrial cleaning issues, using bleach or any other industrial disinfectant.

Contributing:

Keith Reissig

Email | LinkedIn

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12 Tasks for Safety Managers Working From Home

Apr 16, 2020

Many in the U.S. are under stay at home orders, encouraged to work from home where possible. Although many manufacturing facilities are considered essential and still open, safety managers and their support staff do not always need to be onsite. With your routine disrupted, this may actually be a great time to accomplish safety projects that your normally crazy busy days do not allow you to do. Here are 12 ideas for tasks that safety managers working from home can do themselves, or can assign to their safety team members to keeping teams busy and productive during this time:

1. Develop Your Pandemic Plan

What better time than now to develop a plan for dealing with a pandemic? What actions did your company take? What has worked and what didn’t? As a contractor, a number of clients have asked to see our plan. What will you do about your own vendors and contractors next time? What about visitors? Read our article on pandemic preparedness plans to get some ideas on how to get started.

2. Review/Develop Cleaning Procedures

The events of the past month have shown a spotlight on the way we handle the spread of germs from person to person. What are your procedures for cleaning and disinfecting respirators? What about your other personal protective equipment? What are the proper protocols? How often should they be cleaned? What cleaning products are EPA-approved and most effective on the PPEs’ materials?

3. Review Your Emergency Plans

We are entering wild weather months of spring and summer. How would your company deal with the effects of tornadoes, floods, wildfires, hurricanes, hail storms, high wind events, heat waves, etc.? What are your business continuity plans if one of these events would occur at your facility? How would you be affected? Electricity powers the lights, your computers, and your machines. What would you do about electrical service interruptions? Did you know that there are EPA regulations for emergency power generators? What other regulations would come into play?

4. Review Your Written Safety Programs

Written safety programs need to be reviewed on a regular basis, and some of them actually have OSHA rules about how often they are to be reviewed. Take a look at all of your plans. What do they commit you to doing, and is your company doing what it says you are supposed to be doing? Who else in your company is affected by these programs and needs to review and be aware of what they require? Remember that if it’s in writing that your company will do it, you will be held to that in a regulatory inspection. Are your programs compliant with OSHA standards?

Are you missing a plan? Visit SafetyPlans.com to purchase one you can edit and expand upon.

5. Take Advantage of Web Conferencing for Safety Training

Many companies have been using web conferencing software to hold online meetings or to just check in with each other. Take this time to get some of your general safety training out of the way. You could do weekly toolbox meetings or even longer sessions. Just make sure that you document what was held, on what date, who was the trainer, and who attended. You could even take a screenshot of the online attendees list, or a screenshot of the webcams of the persons in attendance to add to your documentation. iSi can help you facilitate/setup this training, request more info here.

6. Spruce Up Your Training Materials

Speaking of training, now’s a good time to look at the training materials you’re using and consider giving it a refresh. Is the training still current and within the regs? Are the people in your videos dressed like characters from the 80s? At the very least, does your Powerpoint need a new look and some new pictures?

7. Write your RFPs

What services and products will you be needing for the rest of the year? Does your procurement/purchasing department require you to help them develop solicitations? Now would be a great time to knock out scope of work development, writing descriptions of what you’re going to need and developing the criteria for what information you want to see back from your vendors’ responses. Instead of waiting later when the RFP will go out, do this part now because you know you’re likely to be swamped later and won’t have the time to put much thought into it.

8. Get Quotes for Services and Products

If you already know the products and services you’re going to need, even if it’s later in the year, go ahead and approach your vendors now. It’s likely they’re working from home too, and with business slowing for everyone, now is a good time for them to work on pricing and proposals. With the uncertainty in the business climate, you may even get better pricing if you ask for it now than you would later when business will be catching up. Make sure you let them know what time frame you’re going to need it, and then ask vendors if they’ll hold that pricing until then. Get a quote from iSi.

9. Develop a Presentation for a Local Organization or Conference

Local safety organizations, safety conferences and civic groups are ALWAYS looking for speakers and presentations. The most popular highlight real-world safety management ideas, tell stories on how you have solved a problem that other EHS managers likely have faced, or just share how handle a particular part of compliance. For civic groups, use your knowledge of general safety principles and find a topic that may apply to all types of businesses and business owners. Speaking to a group or professional event is also a great way to get publicity for your company and yourself as a professional in the community.

Read our article The Importance of EHS Organizations and Conferences to Your EHS Compliance.

10. Research Products and Services That Will Make You More Efficient

Once everyone is back to work, it’s likely your budget will be strained, labor may be stretched, and you’ll have to do more in order to catch up. Now is a good time to find products or services that will help make you more efficient and save money in the long run. Try out new software, get samples of products, and find resources that can give you assistance to help you make up for gaps in staffing. Now is the time to round up the tools for your toolbox that you may need to use later.

11. Permit Reviews

If you have them stored electronically, take a look at completed lockout/tagout and confined space entry permits. Were the requirements of the permits fully executed and documented

12. Clean Up Your Email

How many times have you gotten the notice that your email boxes are full and it has been at the worst time you could’ve gotten that message? Go through your inbox and delete what you do not need anymore and read what you may have missed. Don’t forget to go through your sent items too. If you find you are not making much headway in creating space, sort your messages by size. This will allow you to uncover those emails with the 50 MB attachments that you don’t need anymore.

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Contributing:

Tami Hadley

Email | LinkedIn

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Creating a Pandemic Preparedness Plan for ISNetworld or for ANY Company

Apr 13, 2020

If you are a contractor to large refineries and manufacturers like we are, you are likely a member of one or more safety oversight companies like ISNetworld. Recently clients have been asking contractors to upload a Pandemic Preparedness Plan for ISNetworld, in response to the COVID-19 outbreak. Other non-ISNetworld clients may have also been doing the same, or you as a safety professional may have been thinking about what your company should develop. Using ISNetworld’s program questionnaire can help any company determine what should be included in a plan and give a place to start.

The following are the topics covered by the questionnaire for the current Pandemic Preparedness Plan for ISNetworld. Even if ISNetworld doesn’t apply to you, this may give you some ideas for best practices:

1. Assignment of Ownership

Who is going to be in charge of carrying out the plan? Who is on that team and how is it decided?

2. Hand Washing Facilities, Cleansers and Other Hygiene Items

What hand washing facilities will be available to your employees? What other sanitizing products will be available (i.e., hand sanitizers, disposable towels, etc.). In this section you could also cover personal protective materials to be provided as well.

3. Periodic Training

Periodic training should be conducted regarding illness prevention and spread of disease. It should also communicate your policies regarding illness. At what frequency will they be conducted, and who will do (or be responsible for) that training.

4. Work From Home Policy

What is your company policy regarding working from home, or staying at home when an employee is ill or taking care of an ill family member.

5. Continuance of Operations

What is your company’s strategy for continuing operations if a large percentage of your staff becomes ill? What’s your plan for maintaining operations during quarantine or stay at home orders?

6. Immunizations

Does your company encourage employees to get proper immunizations?

7. Communications

How are employee and internal communications conducted?

8. Gatherings

Does your company limit large or crowded gatherings during outbreaks or increased disease levels? What does that look like?

9. Cleaning

What is your strategy for cleaning workplace surfaces and equipment?

10. Reviews and Testing

How will this plan be tested? How often will it be reviewed? Who is responsible for doing so?

11. Lessons Learned

What is your process for implementing lessons learned? How will that be done, and who will do it?

Writing the Plan

Hopefully this gives you a start on creating your own Pandemic Plan. If you do not have the time nor the labor right now to do this, let us help! We have written these Pandemic Preparedness Plans for ISNetworld compliance and for our own company. Contact us today for pricing!

Save Time With Our Template!

If you need help getting started, we have a template plan for you to purchase for $100. Click below to buy and download this Microsoft Word document now.

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The Importance of Understanding the REAL Ramifications of Disinfecting Your Workplace

Mar 20, 2020

With all things COVID-19 impacting our businesses, researching immediate actions to understand their impacts is critical. Some companies may feel the pressure and immediate need to “clean” everything. However, it’s important to know which cleaning compounds work in what situations, the impact to the materials they’ll be cleaning, their composition, the application methods required by the label and the potential hazards they may cause those workers applying them and working around them.

Most businesses are considering decontamination strategies where it makes sense. In some cases, this might be at the janitorial level, and in other cases, it might be more of an industrial solution involving the production floor, manufacturing processes and even potential products that need to be disinfected/sanitized.

EPA-Approved Products

Some definitions to understand:

Cleaning is the removal of dirts, soils and impurities from the surface.

Sanitizing is meant to reduce, not kill, the occurrence and growth of bacteria, viruses and fungi (typically reduces bacteria on a surface by 99.9%).

Disinfecting a surface will “kill” the microscopic organisms as claimed on the label of a particular product. … The minimum level of effectiveness in a modern-day disinfectant is 100 percent kill greater-than 6-log reduction of an organism.

Both sanitizers and disinfectants are regulated by EPA. In order to substantiate their claims, testing is required to prove their function, and this would be the EPA certification. There are several pre-defined criteria that pertain to how they perform, at what concentration and conditions, what “bugs” they kill, how fast they work, etc. EPA registrations take time, often years. Companies can subregister under an existing formulation. That means they are using an already certified formula.

How Will What You Are Cleaning Be Affected?

All cleaners do not work with all materials. With the desire to decontaminate everything, one important item to consider is what you are actually “cleaning.” There are numerous products that are EPA-certified, and some will be on the acidic side. Others (most commonly) will be on the alkaline side, and even a few will be neutral. Their contents may include: hydrogen peroxide, quaternary amines, surfactants, acids, bases, etc.

Recently iSi evaluated a solution for disinfecting aluminum surfaces. With softer metals such as aluminum and copper, the possibility of corrosion or discoloration is much higher with certain disinfectants.

Most of your harder metals (steel, stainless, alloys) are unlikely to be affected.

These soft metal materials can be found in food processing plants, automotive, aerospace and other industries. Thus, it is important to know ahead of time what the results of using the cleaner will be.

Also, please make sure you’re applying the disinfectant per the product’s label and directions. Do not vary from those directions. Variances in application methods from what the label says may alter the effectiveness of the disinfectant, cause damage to materials, and may make you non-compliant with regulatory guidelines.

How Will the Person Doing the Disinfecting Be Affected?

Make sure you know exactly what’s in the cleaners to be used. Most importantly, get their Safety Data Sheets (SDSs) and really read them and analyze them.

How will its usage affect the person who will be applying it?
What kind of personal protective equipment will be needed?
Do you have that personal protective equipment on hand? With national shortages, do you even have a way to get ahold of it?
How will it affect the atmosphere and air quality of the areas it will be used in?
What does the overall tone of it say about the type of person and qualifications needed to apply it? Is it really something you’d be comfortable having janitorial staff work with, or does it need to be someone with a greater level of hazardous materials training?
Do you have the staff on hand (right now) to take care of this?
What is your overall risk?

Unfortunately some SDSs can be vague, confusing, and can even contradict themselves. So please be very careful and make sure you have a firm grasp on what you’re dealing with.

We Can Help Take Care of It

iSi has been pulled into some research gathering for current clients, and also has been providing onsite personnel for others. We have people on-staff to help you with researching and figuring out your requirements. We deal with confusing and contradicting SDSs every day and have the proper staff of safety and chemistry personnel on hand to work through them. We also have an entire team of hazardous materials and safety trained and experienced industrial cleaning technicians ready to support you.

Give us a call, email us, or send us a message through social media and we will get back with you to see how we can help.

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Machine Guarding Real Focus of Renewed OSHA Emphasis Program

Feb 6, 2020

OSHA has updated and renewed its National Emphasis Program on amputations in manufacturing facilities. With this emphasis, OSHA will be targeting manufacturers and industrial facilities, with a focus on machine guarding and lockout-tagout.

Who’s On the List?

Machine guarding and lockout-tagout are annual residents on OSHA’s top 10 list of violations and cause amputations and injuries each year. OSHA has had amputations on its national emphasis since before 2015, but they’ve updated it with a new list of potential NAICS codes to target based on data from 2015 to 2018. OSHA is going to target industries with higher rates of machine guarding and lockout-tagout violations, higher rates of related incidents, higher rates of amputations, those with amputations within the past 5 years, and those with machine-related injuries or fatalities. They’ve developed a target list of around 130 targeted NAICS codes.

Companies with less than 10 employees will not be on the target list, even if their NAICS code matches.

Please remember that as with all OSHA emphasis programs, if OSHA is onsite for another inspection, they can add this to their scope.

What Will Be Looked At?

In addition to reviewing 4 years of OSHA logs, they will be inspecting your machinery and equipment, looking for hazard potentials in:

Pinch, Nip and Shear Points
Cutting Actions
Setup and Operation
Clearing Jams or Upsets
Making Adjustments When Operating
Cleaning/Greasing/Oiling
Scheduled and Unscheduled Maintenance
During the Lockout-Tagout Process

Machine guarding is used to protect both the operator and everyone else who could come in contact with a machine. Any machine, part, function or process that can cause injury must be safeguarded.

The best way to ensure you are ready for an inspection is to make sure you’re compliant with the following standards. These will be the ones used by inspectors as they’re the ones that have the greater potential to cause amputations:

1910 Subpart J – General Environmental Controls

1910.147 Control of Hazardous Energy (Lockout-Tagout)

1910 Subpart O – Machine and Machine Guarding

1910.212              General Requirements
1910.213              Woodworking Machinery Requirements
1910.217              Mechanical Power Presses
1910.219              Mechanical Power Transmission

Inspection Start Date

As with all new and revised emphasis programs, there will be a 90-day period where OSHA will provide outreach efforts to alert the industry about the changes before starting targeted inspections. This puts targeted inspections starting around March 10, 2020.

More Information

For more information, check out the OSHA inspector directive here, which also includes the affected list of NAICS codes.

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Potential Employer Requirements in an OSHA Emergency Standard for COVID

Jan 26, 2020

UPDATE:

President Biden signed an Executive Order on Thursday, Jan. 21, 2021 that requires the following:

Within 2 weeks (by Feb. 4, 2021), OSHA is required to:
- Issue guidance to employers on workplace safety during the COVID pandemic.
- OSHA and MSHA are required to determine if an emergency temporary standard is necessary. If so, it will be due by Mar. 15, 2021.
OSHA is required to review its enforcement efforts and identify any short-term and long-term changes to be made.
A National Emphasis Program on COVID-19 in the workplace is required to be developed.
OSHA is to work with state plan states to make sure they have similar COVID plans in place, and for those who don’t have a state plan, work with state and local officials to make sure they have plans in place to protect public employees.
The Secretaries of Labor, Health and Human Services, Transportation, Energy and Agriculture need to work to identify that workers not covered under OSHA in their respective categories are protected.

What’s an OSHA Emergency Temporary Standard?

What May Employers Be Required to Develop in a Federal Standard?

In total, 14 states have adopted comprehensive COVID-19 worker protections through executive order and/or their state OSHA programs.

Conducting a Workplace Assessment

Develop an Exposure Control Plan

Implement Controls

This includes maximizing current ventilation systems, installing barriers, partitions, and airborne infection isolation rooms.

Training Employees

Maintain Records of Training, Screenings, and Notifications

This would include employee training, employee and visitor screenings, notifications as required to individuals and Health Departments.

How Often Have Emergency Standards Been Used Before?

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iSi will be monitoring developments with federal OSHA and will update this article, or provide additional information in our blog as information continues to develop regarding this issue.

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Contributing:

Curtis Leiker, CSP

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What OSHA Says About Using Online Safety Training Courses

Nov 21, 2019

OSHA's opinion on online safety training

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OK, OK, before anyone has a chance to say “of course you’re going to write THIS article,” we want to make it clear that although iSi may be known for the face-to-face classes we hold at our offices and onsite at client facilities, we DO write and produce online and computer-based training modules. Thus, we are in favor of training in all forms, including online. Online and computer-based classes can be a great tool for your training program, especially in places where there is high turnover, multiple shifts, or high numbers of employees at the facility.

Now…on to the article.

Recently, an OSHA interpretation letter was published that asked the question:

Are online training programs acceptable for compliance with OSHA’s worker training requirements?

OSHA’s Opinion of Online Safety Training

The response from OSHA said that although online safety training can be a valuable part of your training program, you cannot use it by itself to meet OSHA requirements unless it contains hands-on interactive elements. OSHA says that training requires a mastery of the material that would include safe uses of tools and equipment. The students must be able to interact with the proper equipment and tools. This benefits not only the new student, but is a good refresher for those who are more skilled and also allows a qualified instructor to make sure the student has mastered the skill.

The interpretation letter references a previous letter published in 1994 that mentions HAZWOPER (Hazardous Waste Operations and Emergency Response) as an example. In HAZWOPER, hands-on use of personal protective equipment is very important. Training should include how to don and doff the PPE and include a way to ensure the student is comfortable doing so and is doing it correctly. The information also needs to be able to somewhat be tailored to the student’s situation. OSHA adds that this hands-on training needs to be conducted in a non-hazardous location as well.

This would also be the case for any powered industrial vehicle training. In each of those courses, there is a classroom portion about the hazards that could be done online. However, specific hands-on training with the actual equipment, whether that be a forklift, a scissor lift, a tug that pulls an airplane, etc., needs to be conducted in a hands-on fashion with the student operating the equipment and an instructor evaluating his/her performance and providing guidance.

Ability to Ask Questions

Another requirement to be meet OSHA standards is the student must be able to ask questions of an instructor. Some of the topics may be unfamiliar, and OSHA values the student’s ability to ask questions and receive them in a timely manner. They say that not having this interaction impedes the student’s ability to comprehend the material and retain it.

OSHA suggests that to take care of this requirement, a way to ask questions should be built into the program. They mention a hotline number could be used, but you may also be able to use email or chat.

Regardless of what you use, the contact needs to go directly to a qualified trainer and the responses need to come back in a timely fashion.

Where to Find These Interpretations

To review these OSHA interpretation letters regarding online safety training, read the one from 2019 here, and the one from 1994 here.

Are you using online safety training for your company and now need to rethink how you’re administering it based on OSHA’s guidance? Let iSi help you! Contact us today for guidance, hands-on assistance, or customized online training modules that can be imported into your company’s learning management system.

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Contributing:

Drew Lyon

EPA

Spill Prevention, Control and Countermeasures [40 CFR 112]

Facility Response Plans [40 CFR 112]

Risk Management Plans [40 CFR 68]

Hazardous Waste Contingency Plans [40 CFR 262]

OSHA

Emergency Action Plans [29 CFR 1910.138]

HAZWOPER Emergency Response Plans [29 CFR 1910.120]

Process Safety Emergency Planning [29 CFR 1910.119]

Fire Prevention Plans [29 CFR 1910.39]

OSHA Emergency Plan References for Specific Substances

Other Agencies’ Emergency Response Plans

A Combined Plan to Satisfy Multiple Requirements

Where Do You Go for More Info?

EPA

Spill Prevention, Control and Countermeasures [40 CFR 112]

Facility Response Plans [40 CFR 112]

Risk Management Plans [40 CFR 68]

Hazardous Waste Contingency Plans [40 CFR 262]

OSHA

Emergency Action Plans [29 CFR 1910.138]

HAZWOPER Emergency Response Plans [29 CFR 1910.120]

Process Safety Emergency Planning [29 CFR 1910.119]

Fire Prevention Plans [29 CFR 1910.39]

OSHA Emergency Plan References for Specific Substances

Other Agencies’ Emergency Response Plans

A Combined Plan to Satisfy Multiple Requirements

Where Do You Go for More Info?

Contributing:

Curtis Leiker, CSP

UPDATE 6/10/21:

UPDATE 1/21/21:

Contributing:

Curtis Leiker, CSP

Contributing:

Tami Hadley

5 Ways OSHA’s Top 10 Can Make Your Safety Job Easier

Contributing:

Ryan Livengood

What is the ERG?

Updates

White Pages [General Information, Instructions, Recommendations, Guidance]

Orange Pages [Response Guides]

Yellow/Blue Pages [Materials in ID/Name of Material Order]

Green Pages [Isolation and Protective Action Distances]

Where Can the Current ERG Be Found?

EHS BOOTCAMP AGENDA — SEPTEMBER 24, 2020

9:00am – 10:00am

Environmental Track: Hazardous Waste

Safety Track: Regulatory Inspection Process

10:00am – 11:00am

Environmental Track: Clean Air Act/Air Permitting

Safety Track: Chemical Inventory for Hazcom

11:00am – Noon

Environmental Track: Stormwater

Safety Track: Injury Reporting and Worker’s Compensation

Noon - 1:00 pm

General Session: ISO Certification: More About ISO 14001 and the New ISO 45001

Spill Prevention, Control and Countermeasures **[40 CFR 112]**

Facility Response Plans **[40 CFR 112]**

**Risk Management Plans [40 CFR 68]**

**Hazardous Waste Contingency Plans [40 CFR 262]**

**Emergency Action Plans [29 CFR 1910.138]**

**HAZWOPER Emergency Response Plans [29 CFR 1910.120]**

**Process Safety Emergency Planning [29 CFR 1910.119]**

**Fire Prevention Plans [29 CFR 1910.39]**

Spill Prevention, Control and Countermeasures **[40 CFR 112]**

Facility Response Plans **[40 CFR 112]**

**Risk Management Plans [40 CFR 68]**

**Hazardous Waste Contingency Plans [40 CFR 262]**

**Emergency Action Plans [29 CFR 1910.138]**

**HAZWOPER Emergency Response Plans [29 CFR 1910.120]**

**Process Safety Emergency Planning [29 CFR 1910.119]**

**Fire Prevention Plans [29 CFR 1910.39]**

General Session:
ISO Certification: More About ISO 14001 and the New ISO 45001