Potential Employer Requirements in an OSHA Emergency Standard for COVID

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:

  1. 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.
  2.  OSHA is required to review its enforcement efforts and identify any short-term and long-term changes to be made.
  3.  A National Emphasis Program on COVID-19 in the workplace is required to be developed.
  4.  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.
  5. 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OSHA is authorized to set emergency temporary standards that take effect immediately and are in effect until superseded by a permanent standard.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 Standard?

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 and will update this article, or provide additional information in our blog as information continues to develop regarding this issue.

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Short lead times for OSHA indicate the potential for a short lead time for employers to get program elements in place.  Our team of safety and industrial hygiene professionals are here to help with the things you may not have time to develop.  Let’s get the conversation started!

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Curtis Leiker, CSP
Curtis Leiker, CSP

Contributing:

Curtis Leiker, CSP

Certified Safety Professional |  ISO 45001 and 14001 Lead Auditor

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

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What OSHA Says About Using Online Safety Training Courses

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.

Do you need assistance in administering your safety training programs?  Let us help – contact us today!

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OSHA’s New Weighted System for Inspection Priorities

OSHA’s New Weighted System for Inspection Priorities

Oct 31, 2019

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OSHA’s fiscal year has started and with the new year comes a new system for weighting their priorities for inspections. This OSHA inspection weighting system is aimed to help them track inspection activity and give regional administrators a guide for prioritizing resources.

Inspection weighting has been around since 2015. Prior to that, OSHA would use numbers of inspections completed to count activity. This led to some inspectors loading up on shorter inspections in order to gain quantity while not giving as much credit to those who were doing the long, complex inspections. So, in 2015, a weighting system based on time of completion was developed. However, OSHA found that this was not as ideal as needed either.

The new system factors in agency priorities, inspection impact, and the most hazardous workplaces and operations. Each category of inspection is assigned a numerical value. The most time intensive, complex and high priority inspections gain the most points.

The following is the new points system, from highest value inspection to least value inspection. The points are listed in terms of Enforcement Units, or EUs.

1. Group A: High-Priority, Time-Intense, Complex Cases [7 EUs]

  • Criminal Cases
  • Significant Cases

2. Group B: High-Priority Hazards, More Complex Than Average [5 EUs]

  • Fatalities and Catastrophes
  • Chemical Plant National Emphasis Program Inspections
  • Process Safety Management Inspections

3. Group C: Focus Four Emphasis Program [3 EUs]

  • Caught-In Hazards (trenching, equipment operations, oil & gas)
  • Electrical Hazards (overhead power lines, electrical wiring methods)
  • Fall Hazards (scaffolds, elevated walking and working surfaces)
  • Struck-By Hazards (highway work zones, material handling, landscaping)

4. Group D: Programmed and National Emphasis Program Inspections [2 EUs]

  • Amputation Hazards
  • Combustible Dust
  • Ergonomics
  • Federal Agency Inspections
  • Heat Hazards
  • Non-PEL Overexposures
  • Workplace Violence
  • Permit Required Confined Space Hazards
  • Personal Occupational Exposure Sampling
  • Site-Specific Targeting

5. Other Regional/Local Emphasis Programs Not Already Covered (2-3 EUs)

6. Group E: All Other Inspections Not Listed (1 EU)

Phone/fax/email investigations (e.g., complaints) and rapid response investigations earn “activity points.” Each one of these earn 1 activity unit for every 9 completed, so the equivalent of 1/9 EU. Additional enforcement support activities such as responses to Freedom of Information Act requests, electronic correspondence responses, state plan monitoring and interventions have not gotten units assigned yet.

OSHA has weighted their compliance assistance activities as well.  This is the hierarchy from most important to least: 1. Voluntary Protection Program (VPP) evaluations, 2. OSHA Strategic Partnerships activities, 3. OSHA Alliances activities, and 4. Compliance Assistance activities such as making presentations and staffing informational booths.

Please note, that OSHA can and will still add on any program area to an inspection if they are already at your facility for another issue.

How would your facility do if it was inspected by OSHA tomorrow? Let iSi help you find out! We can conduct safety audits and mock/test run inspections and then help you prioritize the list starting with your most critical. Contact us for a price quote!

Where does your facility stand on OSHA compliance? Schedule iSi for a mock OSHA inspection, audit or walkthrough!

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OSHA’s New Quantitative Fit-Testing Protocols Aim to Save Time & Effort

OSHA’s New Quantitative Fit-Testing Protocols Aim to Save Time & Effort

Oct 18, 2019

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OSHA has added two new fit testing protocols for quantitative respirator fit-testing.  The two new protocols are actually modifications of the current ambient aerosol CNC protocols for full-facepiece, half-mask elastomeric, and filtering facepiece respirators.  These modifications cut in half the number of steps required, also making them faster to conduct.

There are two types of manufacturers of quantitative fit-testing machines which are most popular, the Portacount by TSI and a controlled negative pressure (CNP) machine by Occupational Health Dynamics, or OHD.   The changes in the protocols affect TSI’s PortaCount-type machines.

 Quantitative Fit Testing vs. Qualitative Fit Testing

Qualitative fit-testing uses items such as saccharine or irritant smoke to determine protection.  It relies on the person being tested’s ability to sense odor or irritants.  Qualitative fit testing is only for half-face and N95 filtering facepiece respirators that have an APF of 10.

Quantitative respirator fit-testing uses a machine to measure pressure loss inside the mask or to count quantities of particles to calculate a fit factor. 

Quantitative testing is considered more accurate than qualitative fit-testing.  Quantitative fit-testing must be conducted for respirators requiring an Assigned Protection Factor (APF) over 10.  Full-face tight fitting respirators have an APF of 50 and thus need to be quantitatively fit-tested.

The New Protocols

OSHA based their new protocols on the results of three different studies.  After consideration and comment, 4 of the 8 exercises were removed or changed. 

These include the grimace exercise, normal breathing, and deep breathing.  The grimace exercise was often found to shift the fit of the mask while the breathing exercises were considered exercises that rarely affected fit factor.  For full facepiece and half-mask respirators, talking was eliminated in favor of jogging-in-place, a new exercise.   

Additional changes were made to the number of sets and the duration.   OSHA anticipates 5 minutes can be shaved from each fit-test with the new protocols.

PortaCount Upgrades Needed

If you have PortaCount Models 8030, 8038, 8040 or 8048, you will need a software upgrade that you can download from the TSI website.  You can also have the update uploaded when you send in your machine for its annual service.  PortaCount Model 8020 or 8028 users will only be able to use the original 8-step protocols.   If you have a machine manufactured by another company which uses the same protocols, you will need to check with your manufacturer if the machine you’re using requires an update.

Link to the New Protocols

For more information about the specific protocols, visit the revised Appendix A of the standard.

iSi can help you determine your facility’s respirator needs then provide the personnel to help accomplish tasks — Contact us today!

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Robot Safety: NIOSH Develops Program to Study Robot-Related Injuries

Robot Safety: NIOSH Develops Program to Study Robot-Related Injuries

Aug 29, 2019

Robot Safety Evaluations

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With the increased use in robotic technology, NIOSH has been looking into the safety impact of working alongside these machines.  While robots can help reduce workplace injuries by replacing workers in some types of hazardous work conditions, the use of robots may create their own set of hazards.

The National Institute for Occupational Safety and Health (NIOSH) has a Center for Occupational Robotics Research, and more specifically, a special program called the Fatality Assessment and Control Evaluation (FACE) Program.  Through the FACE program, NIOSH is conducting robot safety surveillance, targeted investigations, and prevention activities.  The program is conducting in-depth investigations of robot-related deaths. The FACE program is currently operated in 7 states through local state health or labor agencies. 

Recently the Washington State FACE Program issued recommendations for safety actions for two separate types of robots: laser guided vehicles and remote controlled demolition machines.

 Laser Guided Vehicles

In one case, NIOSH investigated a death at a water bottling company where a worker was crushed.  At the facility, each vehicle had safety sensors to detect objects or workers in the vehicle’s path.  An alarm would sound when an obstruction was present, and the vehicles would stop moving until the obstruction was removed. 

The worker heard an alarm sound on one of the vehicles indicating sensors detected an object in its path.  He attempted to remove a piece of plastic that likely tore off a pallet.  Before removing the plastic and reaching under the forks, the worker had not cut the power to the machine.  He also had not heeded label warnings to stay clear of the forks.  Investigators believe that when he removed the plastic obstruction, he was positioned outside the path of the sensor.  The vehicle resumed operation, the forks came down, and the worker was crushed. 

FACE recommends the following safety practices to prevent injury from laser guided vehicles:

  • Incorporate manufacturer safety requirements into written company safety procedures for automated guided industrial vehicles;
  • Train workers about the specific hazards and safety requirements associated with automated guided industrial vehicles; and,
  • Emphasize workers are expected to follow required safety procedures every time, and ensure compliance through periodic refresher training and spot checks.

Demolition Robots

FACE investigated two cases where workers were severely injured by demolition robots.  In the first case, a worker was using a machine that had a wire connected to a remote control the worker wore on his waist. When the worker attempted to move the machine’s power cable, he bumped the remote control against the machine, pinning him between the machine and the wall. 

In another case, a worker broke his foot when operating a machine to chip concrete.  He was in a tight spot between an excavation wall and the machine.  When he tried to apply more force on the machine to chip the concrete, the machine shifted and the outrigger came down on his foot.

As a result, FACE has developed recommendations for demolition robot safety:

  • Prepare a job hazard analysis with operators for each new job to identify and control hazards. Use the manufacturer’s safety instructions to establish the risk zone for the specific machine, attachment, and task;
  • Always stay outside the risk zone when the machine is in operation, and do not enter until the machine is put into emergency stop mode or de-energized;
  • Consider using a proximity warning system, such as those based on radio frequency identification (RFID), to maintain a safe worker-to-machine distance;
  • Train operators to manage power cables and to continually monitor the process for hazards and redefine the risk zone;
  • Ensure operators always read and follow manufacturer’s provided safety instructions; and,
  • Consider using a spotter to assist the operator.

NIOSH is Looking for Case Studies

NIOSH’s Center for Occupational Robotics Research, and its FACE programs are looking for other instances where robotics technology has contributed to injuries.  Through their research, they hope to develop additional safety programs and guidance to help companies keep workers safe.  If you know of a related incident, NIOSH would like to hear from you for an anonymous investigation.  You can find more about them at https://www.cdc.gov/niosh/topics/robotics/aboutthecenter.html.

We have worked with companies that use laser guided vehicles and other technology.  Let us assist you too — Contact us today!

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The 3 Most Important Elements of a Good Safety Program

The 3 Most Important Elements of a Good Safety Program

Aug 14, 2019

OSHA’s Safe + Sound Week this week gives us a chance to take a look at company safety programs, what makes them successful and what elements need to be a part of them. OSHA identifies the following three main elements of an effective safety and health program.

Management Leadership

Successful programs all begin with management commitment. Management commitment is often the strong foundation to the program, and without it, all other efforts don’t have nearly the same chance for success. Management commitment shows workers that safety is an important part of the business’s success. In turn, it shows workers that efforts workers make will be valued in the long run.

There are a number of ways management can show their commitment besides financial and resource support. They can factor safety into plans and decisions of the company from construction/renovations to process changes to company policies. Management can also establish rewards and recognition programs for safety participation and achievements as well as making safety a daily part of conversations. At every company event or meeting, a moment can be made available for safety. Safety goals, expectations, achievements, and even the incidents and near misses need to be highlighted through company communication channels.

Worker Participation

Workers are the ones who are exposed to safety issues on a daily basis. They have the knowledge of the hazards they encounter on the job. Safety programs which involve worker ideas and contributions and then follow through on those assist in giving employees ownership and investment into the safety effort. Genuine worker participation efforts need to ensure workers feel comfortable about speaking up when issues are found or injuries happen.

You can encourage worker participation through involving them in program design elements, job hazard analyses, site inspections and incident investigations. Programs which allow workers to assess the safety of themselves and those around them are helpful, as are tools for reporting near misses and incidences of good safety practices.

At iSi we have required Peer to Peer evaluations where workers evaluate safe/unsafe actions of their co-workers. Those who are being evaluated are kept anonymous so there’s no fear of someone “getting in trouble” for not following a safety protocol. We’ve found that the ones who are doing the evaluation tend to get more out of it than the person being evaluated because the act of finding and assessing safety brings more attention to determining what’s the correct safety behavior. The discussions between workers during the evaluations are some of the most valuable for alerting to a potential hazard, enforcing good behavior, and opening up a dialogue for finding ways to make daily work safer.

Finding and Fixing Hazards

When both management and workers are participating, good momentum comes when issues are fixed and resolved. OSHA says that most fixes are reactive, that is, they’re a result of something happening whether it be a response to an incident or a new regulation coming out. However, a strong safety program finds issues and resolves them before they become an issue. The workplace is ever changing, so safety issues may arise where you least expect. Considering safety implications in any workplace change is important.

Take a look into your incidents and determine what is the root cause of those? Are you continually having the same issues in your near misses? What are the injuries in your OSHA 300 logs? Is there a correlation? If there are similarities, then you have a place to start. Involve workers and solicit their ideas in how to make those operations safer. Is there a way to do things differently with minimal efforts and investments? Use the hierarchy of controls when determining solutions. Is there a way to remove the hazard completely? Are the controls you currently have in place working or do they need to have some reevaluation?

So How Do You Get It All Accomplished?

A good safety program like this doesn’t happen overnight and it will take the participation of everyone in your company to make it happen. There are a lot of pieces that will need to be accomplished. Consider using iSi as a resource for getting some of these pieces completed. We have assisted hundreds of companies with their safety programs and have been involved in strengthening safety cultures and putting program elements in place. Not only can iSi be an extra set of hands, but sometimes in developing programs, an experienced third-party to lend ideas or even serve as a mediator can be helpful.

For example, iSi can assist with:

  • Safety Committee and Safety Culture Development
  • Site Audits and Inspections to Help You Gain a Baseline Checklist to Start From
  • Occupational Exposure Monitoring to Get an Idea on Where You Stand
  • Written Safety Program Development Through SafetyPlans.com
  • Job Hazard Analyses
  • Emergency Action Plans
  • Employee Perception Surveys
  • Worker Training

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

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Self-Retracting Lifelines Under Recall

Self-Retracting Lifelines Under Recall

Aug 8, 2019

U

Fall Equipment Inspections

iSi conducts required routine fall protection equipment inspections for our clients companies.  Let us give you that 3rd party eye, and get this task off your to-do list.

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If your company uses DBI-SALA self-retracting lifelines, you may be subject to a recall.  3M has issued a stop use recall on the DBI-SALA Twin-Leg Nano-Lok edge and the Twin-Leg Nano-Lok Wrap self-retracting lifelines.  If you have any of these, stop using them immediately and take them out of service.  All models manufactured since 2013 are affected.

Although no injuries have occurred yet, 3M has found that the energy absorbers may not properly deploy, which could result in serious injury or death.

What are Self-Retracting Lifelines?

Self-retracting lifelines are part of a fall protection system. They are placed above a worker’s head and work much like seat belts do.  They pull out and retract, but when tugged or a force is applied, an internal mechanism acts as a brake to shorten the distance of a fall.  Both of the affected DBI-SALA models are used to connect two self-retracting lifelines under the D-ring of a fall protection harness.  The edge model anchors at foot level and the Wrap Back wraps around the anchor. 

I’m Affected by the Recall – Now What?

If you have one of these models, you can either return it to 3M to be fixed, repaired, or replaced at 3M’s expense.  If 3M has not been able to determine a fix or a certified solution for your particular model, you may choose to send it back for a $200 refund. Once repair solutions are determined, and model SKU numbers have been certified, the cash option will not be available.  As of August 8, 2019, 3M has only found a fix for the edge model, not the Wrap-Back. 

For the edge model, 3M announced a fix had been certified to ANSI standard Z359.14 about 2 weeks after the recall notice.  Once the unit has been repaired, it will have a green checkmark on the front label.  This fix will only be available in regions that recognize the ANSI standard as a regulatory certification.  If you are located in an area where additional certifications are required for fall protection devices, 3M will be working to receive those certifications.

3M specifies that until it can fix your Nano-Lok edge models, none of its other twin-leg self-retracting lifelines are approved for use over sharp edges or abrasive edges.  That was the key feature of the edge model.

Get the Recall Notice

To learn more about this recall and to see if your model numbers are affected, check out the recall website at https://www.nanolokedgerecall.com/.

Required Fall Equipment Inspections

When was the last time you had your fall protection devices inspected?  Did you know iSi conducts the required routine fall equipment inspections for a number of our clients?  Let us give you a different pair of eyes in inspection, and help you check this requirement off your to-do list!  Contact us today!

When was the last time you inspected your fall protection equipment?  Let us do that for you — Contact us today!

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House Bill Would Require OSHA to Develop Formal Heat Standard – Let the Debate Begin

House Bill Would Require OSHA to Develop Formal Heat Standard – Let the Debate Begin

Jul 19, 2019

A new bill introduced in the U.S. House of Representatives would require OSHA to establish heat exposure rules for both indoor and outdoor workplaces.

Called the Asuncion Valdivia Heat Illness and Fatality Prevention Act, it would require OSHA to issue a formal heat protection standard.  The bill was introduced on July 10 by U.S. House Representatives Judy Chu and Raul Grijalva, with 27 co-sponsors.  The Act is named for a farm worker who died from heat exposure.  Chu led the effort to get a similar law passed in the state of California.

The Bill and Standard Requirements

The current bill would require a federal standard as strict as any state law.  As a result, requirements would include:

  • Set exposure limits and limitations on how long workers can be exposed to heat.
  • Written heat-illness prevention programs including:
    • Engineering controls such as local exhaust ventilation, shielding from radiant surfaces, insulation of hot surface, evaporative coolers, fans and mist coolers, updating air conditioning systems, natural ventilation;
    • Administrative controls such as rotating work schedules, scheduling work earlier or later in the day, and work rest schedules;
    • PPE such as water-cooled garments, air cooled garments, reflective clothing, cooling vests; and,
    • Emergency response plans.
  • Workers would have paid breaks in cool spaces and access to water.
  • Employees would be allowed to acclimatize to the heat.
  • Employers would be required to train workers in heat-stress symptoms and responding to them.

If passed, the new OSHA heat standard would need to be in place within 2 years.  If the for some reason the standard wasn’t finalized by then, an interim standard would need to be created for finalization in another 2 years.

How Does OSHA Handle Heat Now?

Currently heat-related injuries and illnesses are cited under the General Duty Clause.  In June, a Georgia company was cited $21,311 for a worker who was hospitalized with heat exhaustion.  In January it cited the U.S. Postal Service $149,664 for a worker who died from a heat-related episode.  Many states and OSHA state-plan states have also developed their own rules.

House Committee Testimony – Let the Debate Begin

The bill has been introduced the House Committee on Education and Labor.  In a hearing of that committee on July 11, in addition to the testimony of Chu and Grijalva, other supporters ranging from an occupational health and safety professor, an organizer with a warehouse advocacy center, an occupational medical doctor, and a representative of the United Farm Workers of America gave testimony in support of the bill.   

However, a labor representative from California Farm Bureau federation, a safety and health representative of Associated General Contractors and other House committee members had some questions about the standard.

Congressman Ben Cline said that while it’s certainly a serious and important issue, he questioned if the bill was taking a one-size fits all solution.  He questioned if it would be overly burdensome to apply a federal standard to all areas of the country when there are different levels of heat and different levels of heat-related illness between states.  Cline said that a one-size fits all approach becomes much more complicated when it’s applied to different industries where the workplace may change from one place to another, such as in truck driving.  He also pointed out that in 2012, OSHA had considered a heat illness standard.  However, the effort was cancelled because OSHA found having one overall standard for this issue had many complications and opportunities for ineffectiveness.

Congressman Bradley Byrne questioned if it was possible to make a federal regulation flexible enough to both be effective and fit different workplaces, workers, and scenarios. He said that anything developed needs to have many stakeholders involved, from OSHA to employers to employees.  If the regulations are too onerous, employees may not want to do what they need to do to comply.  To get everyone involved, it will take time to develop, and the 2-year timeline for a federal regulation is incredibly short compared to the 15 years it took the state of California to bring together stakeholders to develop a similar but state regulation.  Byrne pointed out that OSHA already has a mechanism to enforce heat standards, and also cited the 2012 OSHA decision to cancel heat regulations in favor of enforcement and education. He said he’d like to hear from OSHA as they’re the ones who will be forced to implement such a standard in only 2 years, considering they had tried before and then had decided against it.  Byrne said Congress needs to be very careful when passing laws like this because of the unintended consequences that can come out of it. 

Watch the house committee meeting below:

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OSHA Updates 14 Standards

OSHA Updates 14 Standards

Jul 11, 2019

As part of the President’s Executive Order for agencies to improve regulations and conduct regulatory reviews, OSHA has been working on reviewing their standards to remove outdated, duplicate, and inconsistent parts of their standards.  The latest round of reviews and updates, called Standards Improvement Project – Phase IV, will go into effect on July 15, 2019 and it updates 14 different OSHA standards at a projected $6.1 million/year savings. 

Updates range from clarifications and deletions, to updates for current technology, to good news for cats.

Social Security Numbers
29 CFR Parts 1910, 1915, 1926

OSHA is eliminating the requirement to collect worker social security numbers in 19 of its standards.  Any social security numbers already collected on previous forms can remain on those forms, and if employers want to continue to collect numbers, they may do so.

 

Medical Services and First Aid
29 CFR 1926.50

Current standards require posting of physician, hospital and ambulance phone numbers where 911 service is not available.  At the time, 911 was a relatively new concept, but many of today’s 911 services for landlines can pinpoint the caller’s location.  If your area has landline auto-location for 911, you no longer have to post the additional information.

However, the auto-location feature isn’t always available for cell phones in remote locations.  The new rule requires employers, in areas where 911 auto-location for wireless phones is not available, to post the latitude and longitude of the current location in a conspicuous place so that emergency services may locate the worksite.  Employers are also to ensure that the communication system they are relying on to use to report an emergency is working and is effective.  

 

Medical Surveillance Requirements
29 CFR part 1910, subpart Z

Employers will no longer be required to conduct periodic chest x-rays of their employees for lung cancer purposes.  This is a requirement in asbestos, cadmium, coke emissions, inorganic arsenic, and acrylonitrile standards.  Medical data has been found that periodic x-rays don’t make much of a difference in reducing lung cancer.  However, periodic x-rays are still required for asbestosis determinations, and initial baseline x-rays are still required as well.  Digital radiographs will be allowed as well as different sizes of x-ray films.

 

Occupational Hearing Loss
29 CFR 1904.10

The recordkeeping rule now clarifies physicians must use the standards of 29 CFR 1904.05 to make the determination if a hearing loss is work-related.  Previously, employers have been able to not record hearing loss as an injury when a physician determines the loss was NOT work related. However, no guidance was given for physicians in that determination.  A cross-reference from 1904.05 will be added to 1904.10 to help make that determination.  Get more info on iSi’s work area noise surveys & sampling.

 

Cotton Dust
29 CFR 1910.1043

The technology of pulmonary function testing has come a long way since 1978. OSHA will be updating the pulmonary function testing guidelines.  More info on iSi’s worker sampling protocol development.

 

Lifelines
29 CFR 1926.104

OSHA is changing the minimum breaking strength of lifelines from 5,400 lbs. to 5,000 lbs. to align with the most recent ANSI/ASSE standards.

 

Process Safety Management (PSM)
29 CFR 1926.64

Rather than having a separate PSM standard for construction, this standard will now reference the general industry standard 1910.119.

 

Coke Oven Emissions
29 CFR 1926.1129

OSHA has determined coke oven emissions does pertain to construction work, and will be deleting the standard.  Any construction worker exposures to coke oven emissions will fall under the General Duty Clause.

 

Signs, Signals and Barriers
29 CFR 1926, Subpart G

Employers will now be required to comply with the 2009 version of the Manual on Uniform Traffic Control Devices to better align with DOT’s requirements.  OSHA feels the newest version adds better safety controls. These included high visibility safety apparel, stop/slow signage (not just hand signals), the use of automated flagger assistance devices, and crashworthy temporary traffic barriers and lane channelization. Confusing language will be removed from the traffic signs section, and the barricades and definitions sections will be deleted because they’re duplicates.

 

Materials Handling and Storage
29 CFR 1926.250

Currently, posting of maximum safe load limits of floors in storage areas is required.  However, in residential buildings, heavy materials are not placed in areas above floor or slab on grade.  Thus, this requirement no longer applies to construction of “single-family residential structures and wood-framed multi-family residential structures.”  iSi’s safety assistance services

 

Underground Construction
29 CFR 1926.800

Mobile diesel-powered equipment used in “other than gassy operations” must now meet the most current MSHA requirements of 30 CFR Part 7, Subpart E.

 

Occupational Health and Environmental Controls, Gases, Vapors, Fumes, Dusts and Mists
29 CFR 1926.55

“Threshold limit values” will change to “permissible exposure limits” and references to ACGIH standards will be removed.  OSHA is also cleaning up phrases such as “shall be avoided”, deleting the terms “inhalation, ingestion, skin absorption, or contact”, will change Appendix A to Tables 1 and 2, and will correct inconsistent and errant table headings, footnotes, cross references and asterisks.  iSi’s workplace sampling program development services

 

Shipyards
29 CFR 1915.80

Feral cats will no longer be considered vermin and thus, no longer a health and safety hazard.

 

Rollover Protective Structures, Overhead Protection
29 CFR 1926, Subpart W

OSHA is removing test procedures and performance requirements and replacing them with the current standards of ISO 3471: 2008.  They will also be making some other technical error revisions.

 

 For more details about each change, read the Federal Register notice here.

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LOTO Standard Also on OSHA’s Update List

LOTO Standard Also on OSHA’s Update List

May 23, 2019

Recently we featured that OSHA was soliciting information on powered industrial vehicles to determine the need for an updated standard.  Now OSHA is soliciting information on the lockout-tagout (LOTO) standard.  The current LOTO standard was published in 1989.  

The focus of OSHA’s efforts with LOTO centers on control circuit devices.  The LOTO standard requires energy-isolating devices to be used to control energy during servicing and maintenance of machines and equipment.  In the current standard, control circuit devices cannot be used for this purpose.  However, OSHA says it “recognizes recent technological advances may have improved the safety of control circuit-type devices.”

Since 2016, OSHA has granted variances in compliance to several companies who have been able to prove that the control circuit devices they were using could be a safe alternative.  During an evaluation of a recent variance request, OSHA decided that the time had come and the potential technology was available to consider if there was a basis to allow these devices in certain circumstances. Also, their own research has shown that these devices aren’t typically used in short servicing tasks of a machine and don’t require an extensive disassembly of the machine or entrance into it. As a result, OSHA wants feedback from the public and industry about this.

OSHA is requesting information on:

  • How employers have been using control circuit devices
  • Information about the types of circuitry and safety procedures being used;
  • Limitations of their use, to determine under what other conditions control circuit-type devices could be used safely;
  • Use and limitations of using industry consensus standards for LOTO such as ANSI/ASSPP Z244.1;
  • How the evolution of robotics technology such as collaborative robotics, robotics that move freely, or robotic devices that can be worn by workers has affected risks of worker exposure to hazardous energy;
  • The anticipated economic benefits, impacts, and other offsets that would occur if the standards were updated, such as benefits to productivity or reduction of injuries vs. costs of new equipment, servicing, or need for new training.

LOTO and electrical-related issues are found to be among OSHA’s Top 10 violations each year.  The agency is accepting comments electronically until August 18, 2019 at regulations.gov and from there, OSHA will be making a determination of what actions, if any, needs to be taken.  More information can be found here.

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Is an OSHA Updated Forklift Standard on the Horizon?

Is an OSHA Updated Forklift Standard on the Horizon?

Apr 4, 2019

OSHA is soliciting information on powered industrial vehicles to determine the need for an updated standard.  The current standard was written in 1971, based on industry data from 1969.  OSHA realizes that national consensus standards have been updated several times and rule updates may be needed.

The term “powered industrial vehicle” refers to forklifts, fork and lift trucks, tractors, motorized hand trucks and other specialized industrial trucks that have an electrical or combustion engine.

OSHA is requesting information on:

  • Types, Age and Usage of Powered Industrial Vehicles in the Workplace
  • Maintenance and Retrofitting
  • How to Regulate Older Trucks
  • Types of Accidents and Injuries in Operating
  • Costs and Benefit of Retrofitting With Safety Features

The agency is accepting comments electronically until June 10, 2019 at regulations.gov and from there, OSHA will be making a determination of what actions, if any, needs to be taken.

Powered industrial vehicle incidents are among OSHA’s Top 10 each year, and a number of OSHA regions currently have emphasis programs dedicated to them as well.  Emphasis programs dictate that if an inspector sees a powered industrial vehicle while onsite for any other issue, the inspector can automatically include your powered industrial vehicles in the scope of the inspection. 

There are a number of common regulatory issues with powered industrial vehicles, mainly forklifts, that you need to be aware of to ensure compliance before your next inspection.  Check out our previous blog article, Forklift Top 6: Common OSHA Compliance Pitfalls for Powered Industrial Trucks

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Many OSHA regional emphasis programs include forklifts.  Is your program compliant and ready for inspection? Let us help!

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Methylene Chloride Banned for Consumer Use, Industry Use Continues

Methylene Chloride Banned for Consumer Use, Industry Use Continues

Mar 29, 2019

Update:  As of November 23, 2019 it is now against the law for any person or retailer to sell or distribute paint removal products containing methylene chloride for consumer use, including online sales.

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EPA has issued a final rule to ban the use of methylene chloride for consumer use.  This rule applies to the manufacture, import, process, and distribution of methylene chloride for consumer use.  Industrial use, for now, is still allowed.

Methylene Chloride, also known as dichloromethane, is a key ingredient used in paint strippers.  It also can be found in some acrylic cements for hobbyists.

EPA has been evaluating high-hazard chemicals through the Toxic Substances Control Act, or TSCA.  EPA found the hazards associated with the methylene chloride to be an unreasonable risk.  The fumes are heavier than air and can stay in an unventilated area for several hours.  The fumes can rapidly cause dizziness, loss of consciousness, and death due to nervous system depression.

Retailers have 180 days after the rule finalization to be in compliance.  However, many retailers made pledges to stop selling it long before the rule was finalized.  Lowes, Home Depot, AutoZone, PPG and Sherwin Williams agreed to stop selling methylene chloride-containing products by the end of 2018.  Walmart agreed to stop selling products online and in stores by the end of February 2019 and Amazon targeted March 2019.  Ace Hardware is targeting the end of July 2019.

Industrial Usage Continues

In industry, methylene chloride is used not only as a paint stripper, but for general cleaning, automotive care, bath tub refinishing, metal cleaning and degreasing, lubrication, pharmaceutical manufacturing, and lithography.

EPA is still allowing usage in industry in industry at this time, but are is soliciting public comment for future rulemaking which may include training requirements, limited access rules, and/or certification.

On the employee protection side, methylene chloride usage in industry is also subject to OSHA’s Methylene Chloride Standard.  This standard lines out specific requirements for usage, medical surveillance, respiratory protection, training, hygiene facilities, protective clothing, recordkeeping, and control measures.

Occupational Exposures

Which chemicals are your facility using and have you determined all of your employee exposure responsibilities?  Let us help!

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Why Get a Third-Party Safety Plan Review?

Why Get a Third-Party Safety Plan Review?

Mar 9, 2019

Picture of a person conducting a third-party safety plan review
After you complete your safety plan, you will have the option for a third-party review. What is a third-party safety plan review and why would you need one?

In 2017 alone, OSHA handed out over 3,600 citations related to programs. Safety plans are an important part of a company’s overall safety program and provide a handbook for how the company handles a particular safety issue. It’s one of the very first things that a compliance officer will ask to see when he/she arrives onsite, so they are a very visible part of your compliance efforts. Not only are they important to have, but how thorough and correct they are is just as important. This is where third-party reviews come in.

Third-party reviews can …

Give You Another Set of Eyes, Experienced Eyes

Our third-party reviewers are safety managers who have been working with OSHA regulations, safety plans and safety compliance for a number of years. Many of our reviewers are former environmental, health and safety managers themselves. As safety consultants, they are now working for various types of companies, from small to large, throughout multiple industries and multiple locations. They have seen both the successes and pitfalls of safety plans and routinely represent clients during regulatory inspections while safety plans are being reviewed. Their firsthand experience can be a benefit for you.

Make Sure All Elements Are Covered

OSHA regulations typically specify which components need to be included, and a reviewer will be able to check for these areas and ensure they’re covered completely.

Help Give You Ideas To Strengthen Your Plan (or Determine Where You May Be Over Committing)

Programs generated from SafetyPlans.com provide a substantial basis for compliance, but there can be certain site-specific and facility-specific processes you may need to add to your plan. Our reviewers have prepared hundreds of custom safety plans and can give ideas on which areas may need to be strengthened or where more details could be added. Conversely, they’ll be able to spot the instances where you may be including information above and beyond what’s required and be able to review with the implications overcommitting on certain compliance activities on your plan.

Provide an Extra Level of Credibility

Having an unbiased, experienced third-party review may provide additional level of credibility to help show regulators that your company wants to make the extra effort to be complete. From our experience, success with OSHA inspections and visits can be boosted by attitude towards compliance. Any time your company can show a sincere effort to do all you can to be compliant, it will appear very favorably for your company to the regulator.

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Centrifugal Pump Machine Guarding Issue Solved

Centrifugal Pump Machine Guarding Issue Solved

Feb 28, 2019

If your company has a centrifugal pump, you may have a machine guarding issue issue at risk for violation.   There is an exposed part of the machine that many manufacturers do not make guards for because the seals in this area are important for accessibility, maintenance, and operational purposes.  Below is an easy solution to fix this issue to make it machine guarding compliant and accessible at the same time.

OSHA Standard 1910.219(c)(2) provides details regarding horizontal shafting requirements.  Among those is that no one should be able to reach a finger into the machine.  Most pump manufacturers provide guards for the pump coupling, that is, the component that connects the power source to the pump.  However, guards are not typically provided for the space between the bearing frame and the casing (frame adapter).  In this space, the rotating shaft is exposed, and the packing gland or mechanical seal is located. This space is often inspected to determine if the packing gland or mechanical seal is leaking.  Placing a typical guard over this area prevents important monitoring functions.

A simple solution to this problem is to cover the frame adapter with plastic mesh and secure it with an extension spring.  The plastic mesh and extension spring come in many materials of construction to assure compatibility with the fluid being pumped. Plastic mesh or netting enables inspection of the packing gland or seal and is easily removed for maintenance. The plastic mesh can be cut, without difficulty, to fit each specific pump application.  As it is plastic rather than metal, the instances of being cut and injured on jagged edges are also removed.

In our experience, OSHA inspectors have been taking a look at these areas in their machine guarding audits.  To learn more about this machine guarding issue, contact us and we can assist!

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Centrifugal Pump Without a Guard

centrifugal pump with machine guarding issue

Centrifugal Pump Without a Guard

centrifugal pump with machine guarding issue

Centrifugal Pump With a Guard

centrifugal pump with machine guarding

Centrifugal Pump With a Guard

centrifugal pump with machine guarding

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OSHA Electronic Injuries and Illnesses Reporting Rules Change

OSHA Electronic Injuries and Illnesses Reporting Rules Change

Feb 1, 2019

OSHA electronic reporting of injuries and illnesses rules have undergone another change, and this time it’s to account for worker privacy.  The new final rule was published in the Federal Register on January 25, 2019 and is effective February 25, 2019.

What Has Changed?

Employers with more than 250 employees were to begin including OSHA Forms 300 and 301 with their electronic submittals starting in 2019.  These forms name the particular workers affected, along with the body parts injured, date of birth, date of hire, address, and treatment.  This information could have made it to the online, searchable database, compromising sensitive employee information.

The new rule removes this requirement in order to protect worker privacy.  Employers with more than 250 employees are still required to submit their 300As.

In addition, OSHA is requiring employers to submit their Employer Identification Numbers with their electronic submissions.  OSHA feels this new requirement will help better organize and track submissions and avoid duplications.

Below is a revised table of requirements.  Are you required to submit OSHA electronic reports?  If you have questions, please contact us!

osha reporting requirements

Click here for a list of NAICS Codes covered industries applicable to this regulation.

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Snakes as an Indoor Air Quality Issue: iSi’s Memorable Projects

Snakes as an Indoor Air Quality Issue: iSi’s Memorable Projects

Dec 6, 2018

At iSi we get the opportunity to come across all types of industrial hygiene and indoor air quality projects.  One of our most memorable ones involved something that isn’t typically thought of as a indoor air quality problem:  snakes!

In Chapman, Kansas, employees at a 1930s office building were complaining about an unpleasant odor in the building. The employees suspected that the odor was coming from snakes that were nesting in and around the building.

chapman snakesIn the spring and fall over the past several years, employees frequently caught snakes in the building. The snakes often poked their heads out from the ductwork and slid over toes at work stations. The snakes were confirmed to be black racers, which produce a distinctive odor when they are disturbed or active. Some settling asphalt near the building provided a place for the snakes to den, and some snakes found paths which allowed them to enter the building. With winter approaching, the snakes had no reason to leave once inside the building.

iSi’s Industrial Hygienist, Constance Timmons, met with a local wildlife biologist from Kansas State University to do a walkthrough evaluation of the building to gather background information. With the indoor air quality information that they gathered, Constance and the wildlife biologist determined that the odor was in fact due to snakes.

Although the odor was not a health hazard, iSi recommended ways to prevent the snakes from re-entering the building in the spring such as using snake traps; a drift fence between the building and the field, consisting of silt about an inch deep; and using pea gravel as a filler around the building because it does not support tunnels.

Indoor air quality project and snakesFor ongoing snake control, iSi recommended placing glue traps along the inside walls of the building, making sure that the traps are not adjacent to standing pipes. A snake is able to wrap around the pipe and leverage itself off the trap. Also, turning up the heat in the building may increase the capture of snakes on the glue traps because they are not able to hibernate when they are so warm. Building personnel were advised that, if they chose to relocate the snakes, to release them at least two miles from the building during any season but winter. Racers have a home range of 25-50 acres, and would find their way back if not released far enough away.

In the 2 days after our visit, the employees were able to catch over 23 snakes!

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Semiannual Regulatory Priorities Set by EPA and OSHA

Semiannual Regulatory Priorities Set by EPA and OSHA

Oct 26, 2018

Twice a year each of the President’s cabinets and executive agencies submits a regulatory agenda for the upcoming months.  It’s a list of priorities and which regulatory areas they intend to focus on.  The following items were listed as priorities in EPA’s agenda and in the OSHA portion of the Department of Labor’s agenda.

EPA – Air Quality

  • New Source Review and Title V Permitting – EPA hopes to simplify the New Source Review process (preconstruction air permits). There are two memos EPA wants to make law.  The first is EPA won’t second guess preconstruction analysis that complies with procedural requirements.  The other is the rescinding of the “once in always in” rule. A rule change will allow companies who are major sources to become area sources if their potential to emit falls below thresholds, reducing regulatory requirements.
  • Electric Utility Greenhouse Gas Rules – Recently EPA proposed a new rule for greenhouse gas emissions called the Affordable Clean Energy Rule. They will continue to look at this alternative approach to the Clean Power Plan Rule.
  • Oil and Gas New Source Performance Standards – EPA has been reviewing the rule including regulation of greenhouse gases through emissions limits on methane. A proposal for public comment will be issued.
  • Safer Affordable Fuel-Efficient Vehicles Rule – EPA will hold public hearings on their August 2018 proposal to amend and establish new Corporate Average Fuel Economy and greenhouse gas emissions standards for passenger cars and light trucks for model years 2021-2026.

EPA – Water Quality

  • National Primary Drinking Water Regulations for Lead and Copper and Perchlorate – EPA will be looking at the lead and copper drinking water rule in order to clarify, reduce complexity, modernize and strengthen it to make it more effective and enforceable. They will also be working on drafting a regulation for regulating perchlorate in drinking water.
  • Peak Flows Management – EPA will be updating permitting regulations for publicly owned treatment works that have separate sanitary sewer systems to deal with the excess wastewater collection that comes with wet weather.
  • “Waters of the U.S.” – EPA will be working on step 2 in the redefining of the term waters of the United States with a reevaluation of the definition, including redefining the term “navigable waters”.
  • Clean Water Act Section 404(c) – EPA will update the regulations concerning its authority in the permitting of dredged and fill material discharges. In reducing its power to veto a permit for any reason, it hopes to help increase predictability and certainty for the U.S. Army Corps of Engineers, landowners, investors, and businesses.
  • Steam Electric Power Generating Point Sources – EPA will publish a notice of proposed rulemaking for reconsideration of the Steam Electric Effluent Limitations Guidelines rule.

EPA – Waste and Land Contamination

  • Per- and Polyfluoroalkyl Substances – The use of these chemicals have been prevalent in a wide variety of items such as stain resistant fabrics and carpets, cosmetics and fire-fighting foam. EPA is set to designate them as hazardous substances and is yet to determine which mechanism to use, whether it be CERCLA or the Clean Water Act.
  • Accidental Release Prevention Regulations Under Clean Air Act – EPA has proposed changes to the Risk Management Plan rule to better coordinate with OSHA and DOT rules, lessen security concerns of sharing information with local emergency planning and response organizations and ease the economic burden caused by some provisions. In the next few months, public comment will be solicited on rule changes.
  • Disposal of Coal Combustion Residues from Electric Utilities – EPA is planning to modify the final rule on disposal of coal combustion residual (CCR) as solid waste and will be amending certain performance standards to give additional flexibility to states.

EPA – Chemical Safety

  • TSCA Amendments – 2016 TSCA amendments require EPA to evaluate existing chemicals for health risks to vulnerable groups and workers who daily use them. This action will be funded by user fees from chemical manufacturers and processors when they submit test data for EPA review, manufacture or use a new chemical, or process one subject to risk evaluation.  These fees will go into effect in 2019.  Also, EPA is on a deadline to do risk evaluations and issue any new proposed rules for persistent, bioaccumulative and toxic (PBT) chemicals by June 2019.
  • Lead Dust Hazards – EPA has proposed strengthening lead hazard standards on dust from floors and window sills in child-occupied facilities. Final action will be June 2019.
  • Pesticide Safety – EPA is considering changes to Certification of Pesticide Applicators regulations from 2017 and agricultural Worker Protection Standard regulations from 2015.

OSHA

  • Electronic Reporting – After requiring certain employers to submit OSHA recordkeeping information to a website which would provide publicly available data, OSHA realized it couldn’t guarantee that personally identifiable information from the 300 and 301 logs wouldn’t be published. Thus, OSHA is proposing to change the Improved Tracking of Workplace Injuries and Illnesses Rule to just include the OSHA 300A summary data.
  • Beryllium – After revising the beryllium standard, OSHA realized exposure in shipyards and construction was limited to a few operations so some of the provisions required within the standard wouldn’t improve worker protection and could be redundant with other standards. OSHA will be working to revise the rule.
  • Standards Improvement Project (SIP) – OSHA will be working on Phase IV of their SIP. SIPs are used by OSHA to fix standards to correct errors, update technical references, account for new technologies and practices, delete duplicate information and fix inconsistent information.  SIPs can affect one or a number of standards.  For example, items for SIP IV include removing the requirement to put social security numbers on records and allowing for storing digital copies of x-rays rather than on film only.

Want more details?  Read the full regulatory agenda for EPA here and for OSHA here.

Want us to write an article in more detail about any of these issues?  Email our team and let us know what you’d like to see!

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OSHA’s Ammonium Regional Emphasis Program

OSHA’s Ammonium Regional Emphasis Program

Oct 4, 2018

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OSHA has announced it has developed a regional emphasis program for ammonium starting October 1, 2018.

Who is Affected?

The emphasis program targets fertilizer grade ammonium nitrate and agricultural anhydrous ammonium.  Both create a significant hazard of fire and explosion and are toxic to those who handle them.  Companies who store, mix, blend, and distribute these products will be targeted in this program.

Ammonium nitrate storage issues came into prominence with the 2013 West Fertilizer facility explosion.   This regional emphasis program was a recommendation of the Chemical Safety Board’s report following the incident.

Which States are Included?

The regional emphasis includes particular states from OSHA Region VI and OSHA Region VII.  These include Oklahoma, Texas, Arkansas and Louisiana from Region VI and Kansas, Missouri and Nebraska from Region VII.

What is the Enforcement Date?

Affected companies will have 90 days from October 1st to get their compliance activities in order before OSHA starts issuing penalties, roughly until the end of the year.   Storage of ammonium nitrate falls under 29 CFR 1910.109(i), and storage and handling of anhydrous ammonia falls under 29 CFR 1910.111.  There are other OSHA regulations and requirements which apply to the handling of these chemicals.

What’s Next?

If your company will be affected by this OSHA ammonium regional emphasis program, iSi can help you determine what you need to do to comply and be ready for any upcoming inspection.  If you don’t know if you are affected or not, we can help you make that determination.  Contact us today for pricing, or fill out our online form!

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Overheul to Discuss Link Between Safety Prequalification and Sales

Overheul to Discuss Link Between Safety Prequalification and Sales

Sep 28, 2018

Photo of James Overheul from iSi Environmental

James Overheul
iSi Manager of Safety & Industrial Hygiene

iSi’s Manager of Safety and Industrial Hygiene, James Overheul will be presenting “The Safety Prequalification: Where Sales and Safety Meet” at the 69th Annual Kansas Safety and Health Conference.

In recent years, you may have seen an influx of companies requiring safety data to be included within vendor prequalification documentation. Some companies use online programs such as ISNetworld and Avetta, and others have their own programs. These programs can be used to weed out vendors on the basis of safety performance, causing a bad safety record to affect your ability to do business. James will discuss the common safety statistics used in grading, methods for improving performance, and ideas on how to use these programs to boost safety support from upper management.

James will also be participating as a panelist in the open forum question and answer general session “Learning From Each Other, An Interactive Panel Discussion.”

This year’s Kansas Safety and Health Conference will be in Wichita on October 2-3, 2018.

If you’d like to see this presentation, or another safety or environmental-related presentation at your next conference, seminar or event, please email us or give us a call at (888) 264-7050.

Your company’s safety record can affect your business bottom line.  Let iSi help you find the gaps in your program! 

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Who Regulates Hazmat Shipments?

Who Regulates Hazmat Shipments?

Sep 21, 2018

In the environmental and safety world, it’s pretty simple to determine who’s the regulatory authority. For safety, in most cases it’s OSHA, and if you’re in a “state plan” state or if you’re a public entity, your state has an additional safety regulatory agency. For environmental issues, it’s EPA and for many states there is an additional state agency which covers environmental regulations plus you have municipal environmental rules. However, when it comes to shipping hazardous materials, it gets a little more complicated.

In the U.S., the shipment of hazardous materials is covered by federal regulation 49 CFR. 49 CFR addresses the shipment of hazardous materials by ground, air and vessel. The Department of Transportation (DOT) is responsible for enforcing 49 CFR.

DOT contains a variety of agencies which are responsible for ensuring specific parts of 49 CFR are being followed:

  • Pipeline and Hazardous Materials Security Administration (PHMSA);
  • Federal Aviation Administration (FAA);
  • Federal Motor Carrier Safety Administration (FMCSA); and,
  • Federal Railroad Administration (FRA).

In addition to the federal agencies, there are additional state agencies with the authority to enforce DOT regulations. For example, this could be your state’s department of transportation and additional agencies which govern the highway patrol, rail lines or pipelines. Thus, you could receive inspections from a variety of state officials and highway patrol in additional to the federal agencies.

If there was one arm of DOT which takes the lead in hazardous materials, it’s PHMSA. PHMSA’s focus is safe shipments and it creates and publicizes regulations. Thus, if you wanted to learn new information about shipping hazardous materials, start with PHMSA.

When it comes to air and vessel shipments, you’ll find that although 49 CFR has rules regarding these types of shipments, in parts, 49 CFR defers to two other agencies, the International Air Transport Association (IATA) and the International Maritime Organization who publishes the International Dangerous Goods Code (IMDG). These are international organizations, as the shipment of hazardous materials will often cross country boundaries via ocean or air. Thus, when you’re required to have training, you need the training of both 49 CFR and IATA or IMDG. IMDG can also be applicable to shipments within in the U.S. when shipping to Hawaii, Alaska or Puerto Rico.

Radioactive materials shipments are regulated under the U.S. Nuclear Regulatory Commission (NRC).

Both OSHA and EPA mention and defer to DOT within its regulations. Thus, you need to be aware AND trained in both the regulations of OSHA/EPA and DOT when dealing with environmental or safety issues.

49 CFR regulations can become very confusing. If you need help determining which regulations apply to you and how you need to ship your hazardous materials, contact us and we’d be happy to help!

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OSHA Compliance and Temporary Workers: Who’s Responsible?

OSHA Compliance and Temporary Workers: Who’s Responsible?

Jul 19, 2018

When it comes to temporary workers, who’s responsible for OSHA compliance?  Is it the host employer or the staffing agency?

Overall it’s the responsibility of both parties to ensure OSHA standards are being followed and workers are being protected. As a general rule, OSHA tends to lean towards site-specific issues being handled by the host and general issues be handled by the agency.

Communication

OSHA stresses the importance of communication between both the host and the agency and recommends responsibilities be clearly lined out in any contractual language before the working relationship between both companies begins. OSHA will be reviewing any contract between the host and the staffing agency to see where the responsibilities lie.

Staffing agencies are responsible for learning the potential hazards their temporary employees may encounter at the worksite. Agencies should determine what conditions exist, what hazards could be encountered, and how to protect employees. OSHA says that agencies need not have experts in safety and health on staff, however, they should receive training in hazard identification or employ the assistance of a third-party consultant to help them with those identifications. Ignorance of the regulations, or belief that one party or the other is responsible without it in writing will not be taken as a proper excuse by OSHA.

Recordkeeping and Reporting

Both parties are responsible for ensuring employees are involved in the recordkeeping system and that proper records are kept. Both parties are also responsible for making sure employees know how and where to report work-related injuries and illnesses. Neither can discourage employees from reporting an injury. When an injury does occur, the party who finds out first should report it to the other and then both the host and the staffing agency are to work together to investigate the cause.

When it comes to annual reporting, the employer who is supervising the employee on a day-to-day basis is the one who records the injuries/illnesses on their 300 logs.  OSHA says this is most often the host employer.

Training

Both companies are responsible for training. Staffing agencies must communicate the training that their employees already have to the host, and both the agency and the host must ensure the employees have the adequate training to do the job. The contract between the two parties should line out who’s responsible for which training.  As a rule of thumb, OSHA says that generic safety training would be the responsibility of the staffing agency and site-specific training would be the responsibility of the host site. Any training to temporary employees conducted by the host must be the same as training given to full-time employees.

PPE and Written Plans

It’s the responsibility of both parties to ensure the proper PPE is worn and provided. Neither can require the employee to purchase it themselves, that is, PPE will need to be provided to the employees. The parties can decide in their contract who’s responsible for purchase and assignment, but in examples from some of the OSHA’s guidance documents in these issues, the host employer will most likely be responsible for dictating what is proper PPE. This is because the host employer is already required to evaluate the workplace for exposure levels, have control over the processes and equipment that produce these hazards, and will be conducting surveillance of the areas. The staffing agency is responsible for knowing what those hazards are and how the employees are being protected.

Each party is required to have OSHA-required written plans when workers will be exposed to certain hazards. Example written safety plans required would include bloodborne pathogens, hearing conservation, hazcom, respiratory protection, lockout-tagout and other hazard-specific plans such hexavalent chromium or the new silica standards. The focus of each plan would be slightly different for each party, but a plan must be on file for each.

More Guidance

OSHA has a dedicated site to these issues, along with some good guidance documents for how to handle some regulations such as respiratory protection, industrial truck training, bloodborne pathogens, hazcom and more here. This site also gives examples of OSHA violations and which party was cited for which element.

Some of these issues, such as respiratory protection which has a number of requirements including medical considerations, can become tricky to navigate so please feel free to contact iSi for help in sorting out these issues.

Need Help?

Are you a host site trying to determine what you need to do?  Are you a staffing agency who needs help determining what you need to learn to comply?  Contact iSi and we can help!

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How can we help make your compliance experience with temporary workers go smoother?  Contact us today!

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Watch iSi’s Free Webinar Covering OSHA’s General Industry Silica Regulation

Watch iSi’s Free Webinar Covering OSHA’s General Industry Silica Regulation

Jun 28, 2018

A photo of a worker is potentially exposed to OSHA's general industry silica standard.

Webinar

Watch our webinar to determine how these regulations apply to your organization.

Watch Now

OSHA’s general industry silica standard went into effect on June 23, 2018.  iSi recorded a webinar on Friday, June 22, 2018 which covered:

  • Elements of the New Standard
  • Exposure Sampling Requirements and Compliance
  • Dust Controls
  • Respiratory Protection Implications
  • Medical Implications
  • and More!

This webinar is free — click here to watch it now!

Is your company affected?  Check out our previous blog article “Is Your Company Affected by the New General Industry Silica Standard?” to see if your industry could be a target.

We have also summarized some of the requirements of the new standard here.

Need help sorting out these new silica requirements? Let iSi help!

Request Pricing for Silica Assistance
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OSHA Electronic Injury Reporting Due by July 1

OSHA Electronic Injury Reporting Due by July 1

Jun 20, 2018

Electronic injury and illness reporting is required annually by July 1st for select companies depending on size and industry.  What gets reported is also dependent on size, that is, companies with 250 or more employees submit the 300, 300A and 301 while companies with 20-249 employees submit only the 300A.  The following table summarizes the requirements for electronic reporting.  Immediately after the table is a link to the NAICS industry codes which are included in the requirements.

A table describing who is required to participate in OSHA electronic injury reporting.

Click here for a list of NAICS Codes covered industries applicable to this regulation.

How to Report

Injuries and illnesses will need to be completed through OSHA’s Injury Tracking Application website.   If you are in an OSHA-approved state program such as California, Maryland, Minnesota, South Carolina, Utah, Washington, and Wyoming, you are not required to participate in electronic reporting.

For those who do need to report, you’ll be able to enter your data through three different methods.

First, you can enter data in manually through a web form.

If you have multiple records and multiple establishments, the second option allows you to upload a database file to the system.  It will need to be saved as a csv file.  You can create csv files from Microsoft Excel spreadsheets.  OSHA has csv templates on their site, but these templates are more or less a list of the column names for your spreadsheet and examples of what needs to go into each.

The third option is for those of you who use automated recordkeeping systems.  For those systems, OSHA will have the ability for you to transmit that data electronically through an application programming interface (API).

If you need help submitting, or help in determining if you need to, please contact us and we’ll be happy to help you.

 

How can iSi help your company with OSHA recordkeeping?

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OSHA Delays Enforcement of Certain Portions of Beryllium Standard

OSHA Delays Enforcement of Certain Portions of Beryllium Standard

May 18, 2018

OSHA has made some changes to enforcement dates for its beryllium standard.  Some portions are being enforced as of May 11, 2018, some have been moved to December 12, 2018, and for construction and shipyards, some provisions may never be enforced.

These are the parts of the standards which are currently being enforced as of May 11, 2018:

  • Permissible Exposure Limits in the general industry, construction, and shipyard standards.
  • General industry exposure assessment requirements;
  • General industry respiratory protection requirements;
  • General industry medical surveillance and medical removal provisions;
  • General industry requirements for changing rooms beginning March 11, 2019; and,
  • General industry requirements for engineering controls on March 10, 2020.

Moved to December 12, 2018:

  • Everything else in the general industry standard not listed above.

As for the remaining requirements from the construction and maritime industries, OSHA says with the exception of the permissible exposure limits, it will not enforce any other provisions until further notice.  [OSHA’s full announcement].

If your company produces products containing beryllium, you need to determine your exposure levels and follow guidelines set forth by the new beryllium standard.  Learn more about what these guidelines are in our previous blog post “Beryllium: What You Need to Know About OSHA’s Newest Exposure Standard”.

 

Need Help?

iSi can help determine if the regulation applies to you and help you comply with the standard!
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What's In the Beryllium Standard?

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Is Your Company Affected by the New Silica General Industry Standard?

Is Your Company Affected by the New Silica General Industry Standard?

May 17, 2018

OSHA’s silica general industry standard will be enforced starting June 23, 2018.  Is your company affected by this new standard?

Silica can be found in a number of materials.  Silica is a fine particle which is a respiratory hazard.  Which industries are affected by silica, what products contain silica and which tasks generate silica exposures?  See the list below:

  • Use of Industrial Sand in Production
  • Abrasive Sand Blasting
  • Paint and Coating Production
  • Chemical Production
  • Metal Casting and Production
  • Foundry Work
  • Glass
  • Pottery
  • Ceramic
  • Porcelain Products
  • Dental Products
  • Brick
  • Artificial Stone
  • Concrete
  • Asphalt Roofing
  • Jewelry
  • Clay Products
  • Ready-Mix Concrete
  • Refractory Products
  • Refractory Furnace Installation
  • Railroad Transport
  • Filtration and Water Production

(Source: OSHA’s silica guidance and the National Industrial Sand Association)

If your company produces any of these products, you need to determine your exposure levels and follow guidelines set forth by the new silica standard.  Learn more about what these guidelines are in our previous blog post “OSHA’s Silica Rule for General Industry.”

Need Help?

iSi can help determine if the regulation applies to you and help you comply with the standard!
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Let iSi help you pull together your beryllium compliance program!

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Which Industries Are Affected by OSHA’s Beryllium Standard?

Which Industries Are Affected by OSHA’s Beryllium Standard?

May 3, 2018

OSHA started enforcing certain provisions of its new beryllium standard starting May 11, 2018.  Is your company affected by this new standard?

Beryllium is a lightweight but strong metal and exposures to beryllium occurs through inhalation or contact when making products containing beryllium.  Which industries are affected by beryllium and what products contain beryllium?  See the list below:

  • Aerospace (aircraft braking systems, engines, satellites, space telescope)
  • Automotive (anti- lock brake systems, ignitions)
  • Ceramic manufacturing (rocket covers, semiconductor chips)
  • Defense (components for  nuclear weapons, missile parts, guidance systems, optical systems)
  • Dental labs (alloys in crowns, bridges, and dental plates)
  • Electronics (x- rays, computer parts, telecommunication parts, automotive parts)
  • Energy (microwave devices, relays)
  • Medicine (laser devices, electro-medical devices, X-ray windows)
  • Nuclear energy (heat shields, reactors)
  • Sporting goods (golf clubs, bicycles)
  • Telecommunications (optical systems, wireless base stations)

(Source: OSHA’s beryllium information site)

If your company produces any of these products, you need to determine your exposure levels and follow guidelines set forth by the new beryllium standard.  Learn more about what these guidelines are in our previous blog post “Beryllium: What You Need to Know About OSHA’s Newest Exposure Standard”.

Need Help?

iSi can help determine if the regulation applies to you and help you comply with the standard!
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Let iSi help you pull together your beryllium compliance program!

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National Safety Council: OSHA Budget Gives Clues to Regulatory Agenda

National Safety Council: OSHA Budget Gives Clues to Regulatory Agenda

Feb 22, 2018

The National Safety Council (NSC) has reviewed OSHA’s Fiscal Year 2019 budget and within its budget justification section, NSC has found a number of items which give an insight into what will be OSHA priorities starting this fall through next year.  They include:

  • Revisions to fit-testing procedures;
  • Revisions to the recordkeeping rule;
  • Updated Hazard Communication Standard;
  • Final Rule on Beryllium for General Industry;
  • Crane operator certification revisions to the Cranes and Derrick Standard;
  • Including ANSI Consensus standards in the Powered Industrial Truck Section;
  • Standards improvements and educational material development; and,
  • Additional employees for enforcement, outreach and the Voluntary Protection Program.

President Trump’s budget proposal would eliminate the Chemical Safety Board and the Susan Harwood Training Grant Program.  OSHA’s budget justification seeks to keep the Chemical Safety Board and emphasizes its importance to preventing loss of life and injuries from chemical accidents.  With the money from the elimination of the Susan Harwood Training Grant, they would like to use that in other ways to develop training materials to reach large audiences.

Read more about the NSC’s research here:

Regulatory Agenda
Cuts to CSB and Harwood Grant

 

How can iSi help your company with OSHA compliance? Check us out!

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OSHA’s Silica Rule for General Industry

OSHA’s Silica Rule for General Industry

Feb 11, 2018

The OSHA silica rule for general industry/maritime is more geared toward proving silica exposures are occurring below certain levels and thus there is more of a sampling focus.

Exposure Sampling

Employers must conduct exposure monitoring for silica if the potential for exposure could be at or above an action level of 25 µm3 (micrograms per cubic meter of air), averaged over an 8-hour day.  The maximum limit, also known as the permissible exposure limit (PEL) is 50 µm3, averaged over an 8-hour day (the old PEL was 100 µm3). If your workers’ exposures are above the PEL, your company must take measures to protect workers from exposure.

Affected employees must be notified, in writing, of assessment results and what’s being done to control exposures.  If results are above the action level but below the PEL, sampling will need to occur every 6 months until exposures are below the action level for 2 consecutive measurements.  If results are above the PEL, sampling will need to occur every 3 months until exposures are below the action level for 2 consecutive measurements.

Unless the potential for silica exposure is 0%, if there’s even a slight potential for silica exposures, it’s best to conduct the sampling to know exactly what your exposure levels are for documentation purposes. Documentation of your exposure assessment is very important for your recordkeeping files and shows due diligence with the standard.

Anytime a process or change occurs in the facility, monitoring must be conducted again.

Other Requirements

  • Dust Controls — Dust controls need to be used to protect workers from exposures above the PEL. In most cases, wet methods and ventilation can be used to aid in this.  Again, your exposure sampling will be able to tell you how well your dust controls are working.
  • Respirators — When dust controls don’t keep exposures below the PEL, respirators are required.
  • Medical Exams — Medical exams including chest X-rays and lung function tests must be offered to workers exposed at or above the action level (25 µm3) for 30 or more days per year. These must be offered every 3 years.
  • Warning Signs — Warning signs must be posted at entrances to areas where exposures above the PEL may occur.

Compliance Deadlines

Employers must comply with all requirements of the standard by June 23, 2018 with some exceptions for medical surveillance and hydraulic fracturing.

Medical surveillance for those exposed above the PEL (50 µm3) for 30 or more days must be offered to employees starting June 23, 2018.  Medical surveillance for those exposed above the action level (25 µm3) for 30 or more days starting June 23, 2020.

Hydraulic fracturing operations in the oil and gas industry must implement their engineering controls to limit exposures to the new PEL by June 23, 2021.  Significant efforts are currently being made to develop effective dust control technologies specifically for this industry.  Many of these are in development and have demonstrated promise.  Although some are commercially available, many are still in development and those available now have not been widely implemented yet.  The potential effectiveness of these controls is why OSHA has given some extra time for this industry for development and implementation.

Now What?  How Can iSi Help You With This Standard?

iSi is here to help your company comply with this new standard. We can assist with:

  • Compliance Determinations, Audits and Checklists – Helping you determine if this standard applies to you, evaluating your site for exposure potential, determining areas needing warning signs or restricted access, and making a compliance checklist for you
  • Exposure Sampling – Sampling your facility or construction sites for exposure levels, arranging for lab analysis of samples, preparing documentation for recordkeeping, and preparing your written employee notices
  • Written Program Development – Preparing your exposure control plan or respiratory protection program
  • Training – Silica training and respiratory protection training
  • Respirator Fit-Testing – Annual respirator fit-testing (after your medical surveillance is complete)
  • Answering Questions – Our safety and industrial hygiene experts on-staff can help you with any other questions you may have.

Contact us today with questions or pricing requests.

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Resources

Here are some helpful resources for silica in general industry:

The Regs
OSHA Compliance Guide
Write a Simple Silica Plan

 

 

 

 

Need assistance in sorting out these silica changes?  Let us help!

Request More Info on Silica Compliance
iSi's OSHA Compliance Services
Request Pricing for Silica Compliance Assistance
Prepare Silica Written Plans
OSHA’s Silica Rule for General Industry

Watch iSi’s Free Webinar on Silica in Construction

Jan 1, 2018

Webinar

Watch our free webinar on the construction silica standard.

Watch Webinar

OSHA’s silica in construction standard goes into effect on September 23, 2017.  iSi recorded a webinar to cover the following aspects of the standard:

  • Elements of the New Standard
  • Exposure Sampling Requirements and Compliance
  • Engineering and Equipment Controls Overview
  • Respiratory Protection
  • Housekeeping
  • Medical Surveillance
  • Training Requirements

This webinar is free – click here to go to it.  If you have questions or need help with silica issues afterwards, please contact us!

 

OSHA’s silica in construction standard goes into effect on September 23, 2017.  iSi recorded a webinar to cover the following aspects of the standard:

  • Elements of the New Standard
  • Exposure Sampling Requirements and Compliance
  • Engineering and Equipment Controls Overview
  • Respiratory Protection
  • Housekeeping
  • Medical Surveillance
  • Training Requirements

This webinar is free – click here to go to it.  If you have questions or need help with silica issues afterwards, please contact us!

 

Webinar

Watch our webinar to determine how these regulations apply to your organization.

Watch Webinar

Need help sorting out these new silica requirements? Let iSi help!

Request Pricing for Silica Assistance
Write an Easy Silica Plan
Request More Info About Silica

Changes Coming to OSHA’s Electronic Injury Reporting Rule

Changes Coming to OSHA’s Electronic Injury Reporting Rule

Nov 9, 2017

The deadline to submit your injuries and illnesses for 2016 electronically through the new OSHA Injury Tracking Application website is December 1.  However, recent actions by OSHA suggest this rule has the potential to look differently next year.

In January, a lawsuit against the rule was filed in the U.S. District Court for the Western District of Oklahoma. The court stayed its ruling to allow OSHA to review the rule. As a condition of the stay, the court required OSHA to file status reports with the court. In the final status report recently issued, OSHA acknowledged they had reviewed the rule, have drafted regulatory text, summaries and explanations for proposed changes, and their economists are currently working on the economic impact analysis of the proposed changes.

Thus, the electronic recordkeeping rule is likely to be changed, but there are no indications of what will be changed or when. The two most contentious parts of the rule have been making injury/illness data for each company publicly available online and additional anti-retaliation rules which affect certain types of employee safety incentive programs and post-accident drug testing procedures.  There is some thought that both of these previsions may be altered or removed from the rule.

In the meantime, if your company is required to submit electronically, the rule stands as-is and you will need to get your data uploaded by December 1.   Who is required to submit electronically?  Check out our previous blog describing which companies are affected and what the process for submitting electronically entails.  Need help with the data upload or sorting this all out?  Contact us today!

 

Need help with OSHA recordkeeping issues? Let us help!

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