ISNetworld: The Top 10 Items You Need for Compliance

ISNetworld: The Top 10 Items You Need for Compliance

Apr 1, 2024

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

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

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

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

  1. General Company Information

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

  1. Safety Policies and Procedures

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

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

  1. Written Safety Programs

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

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

  1. Training Programs

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

  1. Regulatory Data

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

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

  1. Insurance

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

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

  1. Employee and Contractor Data

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

  1.  Human Resources-Type Information

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

  1. Other Procedures — Sustainability and Cyber Security

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

  1. Individual Training

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

A Plan for Management and Completion

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

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

Other Considerations

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

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

Resources

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

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

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

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

Need Help?

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

Get Help Here

Need Help?

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

Get Help Here

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

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

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

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

  1. General Company Information

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

  1. Safety Policies and Procedures

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

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

  1. Written Safety Programs

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

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

  1. Training Programs

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

  1. Regulatory Data

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

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

  1. Insurance

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

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

  1. Employee and Contractor Data

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

  1.  Human Resources-Type Information

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

  1. Other Procedures — Sustainability and Cyber Security

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

  1. Individual Training

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

A Plan for Management and Completion

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

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

Other Considerations

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

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

Resources

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

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

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

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

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

Get Pricing
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Example General Duty Clause Citations to Look for in Your Workplace

Example General Duty Clause Citations to Look for in Your Workplace

Mar 25, 2024

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

What is the General Duty Clause?

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

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

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

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

Examples of Common General Duty Clause Citations

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

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

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

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

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Safety Inspections and Corrections

iSi’s safety auditors can help you identify and prioritize the areas where potential violations may exist.  We can also help you correct any issues that have already been found by inspectors. Contact us today!

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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 is PSM?

What is PSM?

Feb 26, 2024

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

PSM applies to

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

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

The 14 Elements of Compliance

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

 1.  Employee Participation

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

2.  Process Safety Information

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

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

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

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

3.  Process Hazard Analysis

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

Some of the items to be evaluated:

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

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

4.  Operating Procedures

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

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

5.  Training

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

6.  Contractors

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

7.  Pre-Startup Safety Review

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

8.  Mechanical Integrity

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

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

9.  Hot Work Permit

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

10.  Management of Change

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

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

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

11.  Incident Investigation

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

12.  Emergency Planning and Audits

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

13.  Compliance Audits

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

14.  Trade Secrets

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

####

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Steve Hieger
Steve Hieger

Contributing:

Steve Hieger

Consulting Services Manager

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

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OSHA Electronic Injury and Illness Reporting Due March 2

OSHA Electronic Injury and Illness Reporting Due March 2

Feb 23, 2024

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

What’s New in Electronic Reporting Standard

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

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

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

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

See Appendix A Here

See Appendix B Here

Industries Moved from Appendix A to Appendix B

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

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

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

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

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

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

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

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Safety Boots: What You Need To Know

Safety Boots: What You Need To Know

Oct 20, 2023

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

Toe Composition

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

Best Practices

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

Checking the Wear

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

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

Finding and Trying on Boots

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

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

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

Sep 22, 2023

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

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

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

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

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

The Similarities

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

Notifying Employees of the Hazards of Asbestos

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

Signage/Labels

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

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

Exposure Limits and Medical Surveillance

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

Training

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

The Differences

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

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

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

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

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

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

Questions?

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

 

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Making Changes to Equipment or Operations? Do You Need a Construction Air Permit?

Making Changes to Equipment or Operations? Do You Need a Construction Air Permit?

Mar 3, 2023

What Are Construction Air Permits and How Do We Determine If We Need One?

Whenever you plan on making changes to equipment or operations, before you ever get started, your company should always determine whether or not you will need to obtain a construction air permit from your state (or local) environmental agency.

Air Permit Regulations

The Clean Air Act sets standards to prevent significant deterioration (PSD) of the air quality for an area.  This is a federal regulation and EPA has the regulatory authority to enforce it, but it can also delegate authority to individual states by approving the state’s plans to enforce these regulations.

Air permits are required any time a company will exceed criteria for six different criteria pollutants (sulfur dioxide, carbon monoxide, particulate matter, lead, nitrous oxides, and ozone (volatile organic compounds)) or from a list of 187 hazardous air pollutants. Permits outline the emission sources at a facility and can include emission limitations, equipment maintenance requirements, and reference applicable Maximum Achievable Control Technology (MACT) standards and New Source Performance Standards (NSPS).

What Kinds of Activities May Need an Air Permit?

Some examples of equipment or processes that may produce emissions that may require an air permit may include:

  • Compressors
  • Paint Booths
  • Degassing Vessels or Lines
  • Engines
  • Generators
  • Ovens
  • Incinerators
  • Boilers

Some activities that may produce emissions to require an air permit may include:

  • Loading/Unloading Operations
  • Material Storage/Transfer
  • Painting
  • Solid Wastes
  • Tank Loading/Unloading
  • Truck Loading/Unloading
  • Valves, Vents, Vessels and Tanks
  • Wastewater Treatment
  • Welding
  • Asphalt Mixing/Rock Crushing

Operating Permits vs. Construction Permits

Air permits required for regular operations are called operating permits.  They are applicable to the entire facility.  There are different types of operating air permits based on whether or not you are located in an EPA area of nonattainment, how you much you will be emitting, and what you’ll be emitting.

Air permits can also be required for specific projects where you’re going to be making changes or additions, and these are called construction permits/approvals.  Even though the word construction is used, you don’t have to technically be doing “construction” activities.  In this instance, it means the process of making any change to an operation.  Once the change has been made, that change then becomes part of the operating permit because it becomes part of the facility operations.

Depending on the state, sometimes operating and construction permits are done at the same time to prevent time loss between making the change and getting the new operation up and running.  Some states do them separately.  Some states require construction permits be incorporated into the facility’s operating permit, and other states will issue combined construction/operating permits.

Construction Permits/Approvals

Except in limited situations, air construction permits must be received BEFORE your construction or change can commence.

Some changes to your facility that could require a construction permit include:

  • Installation of new process equipment;
  • Modification to existing process equipment;
  • Installation of or change in an emission control device;
  • Debottlenecking of a process that allows for increased production; or,
  • Increases to throughput or operating hours (if currently limited by an operating permit).

Determining If You Need a Construction Air Permit

As with operating permits, for a construction air permit one of the first things you’ll need to do is determine how this change will affect your Potential to Emit (PTE).  This is the maximum design capacity of a stationary source to emit a pollutant under its physical and operational design.  Calculate the PTE for each pollutant associated with this source.  There are several different ways to do this calculation and your state may have a preference on which one you use to determine your PTE.

Once the PTE for the project or modification has been calculated, compare it to the construction permitting thresholds.  Please note that in some cases, you may still need to have a construction air permit even if potential emissions are lower than the construction approval thresholds.  For examples, what type of equipment it is or what type of process it is may affect its status.  Check your state’s rules on what their guidelines are.

Obtaining the Permit

If your calculations tell you the project requires an air construction permit, the customary application must be submitted for approval.  If a project is going to make such a difference that it will now trigger Major Source or Major Modification thresholds, you may need to obtain a Federal Air Permit.  This is a lengthy application, and approval can take quite a long time, from several months to well over a year or two, depending on your state and the workload.  So, it’s very, very important you try to do this well ahead of the time you plan on making the change.

If you already have an operating permit, be aware that your change that you are looking at getting permitted under the construction permit may cause changes to your operating permit at the same time.  Know exactly what the conditions of your operating permit are and see how these changes will affect it so that if you are in a state which does operating and construction permits separately, you can get started on making changes to your operating permit now so that you can operate the results of the construction.

Some states have a streamlined construction permit application process for certain equipment such as emergency generators or boilers.  These applications are short and sweet and typically receive agency approval quickly.

If the project meets the exemption from air construction permitting, retain all documentation for your files.  Even if exempt from permitting, state or federal regulations may have requirements for the source, and you still may need to complete some state paperwork.

With all air permits, both construction and operating permits, once you have turned in your application, be prepared to wait.  The state agency will check for the completeness of your application and may have questions.  Once any issues have been resolved, you should receive a draft of your permit to review and comment on. If it’s not in your state’s policy to send a draft, ask for one, especially if it’s a combined operating/construction permit.

Make sure you read this draft!  You will be held to what this permit says.  Make sure everything about the permit is correct, including any equipment details, inconsistencies, unclear language, typos, etc.  Remove or clarify any ambiguities to make the conditions as broad as possible. Any errors could cause you issues later when being inspected, leading to an inspector thinking you are doing something differently than what’s allowed in the permit.

Once the draft has been approved, there may be a public notice period depending on state policy, and then after that you should receive your permit.

Please note, your construction permit could take several months to be approved, so make sure you plan accordingly.  And also remember…construction permits must be obtained BEFORE construction can be started.

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What is a Phase II Environmental Site Assessment?

What is a Phase II Environmental Site Assessment?

Feb 17, 2023

What is a Phase II?

A Phase II Environmental Site Assessment (ESA) is an in-depth procedure conducted by a environmental professional to confirm the presence or absence of suspected contaminants.

This assessment typically follows a Phase I ESA and involves more intensive methods such as soil, groundwater, or building materials sampling and laboratory analysis.

Phase II ESAs are essential when dealing with properties that may have been affected by hazardous substances. The environmental site assessment process provide a detailed understanding of the environmental conditions at a site and act as a critical tool in managing potential liabilities associated with contamination. Conducting an environmental site assessment is a staple of a companies environmental due diligence.

What’s the Difference Between a Phase I Environmental Site Assessment and Phase II Environmental Site Assessment?

While both assessments aim to evaluate potential environmental risks associated with a property, their methodologies differ significantly.

Phase I environmental site assessments are essentially a preliminary study. It involves a detailed review of historical records and a visual inspection of the property to identify potential environmental risks. This phase does not involve any physical testing or sampling.

Instead, it focuses on identifying ‘Recognized Environmental Conditions’ (RECs) that indicate the possible presence of contamination on the site.

On the other hand, a Phase II assessment is a more detailed and hands-on investigation. It is triggered when RECs are identified during the Phase I assessment. Phase II involves actual sampling and testing of soil, groundwater, or building materials to confirm if suspected contaminants exist at concentrations above regulatory limits.

When Do I Need a Limited Phase II ESA?

A Limited Phase II ESA is often required when the Phase I ESA identifies potential environmental risks, but the suspected contamination is localized to specific areas of the site.

This more focused assessment is less extensive — and thus less costly — than a full Phase II ESA but still provides valuable insight into potential environmental liabilities. It involves targeted sampling and analysis based on the findings from the Phase I ESA.

Who Pays For A Phase 2 ESA?

Typically, the party who stands to benefit from the information generated by a Phase II ESA is responsible for its cost.

This could be a prospective buyer who wants to ensure they are not acquiring contaminated property, a current property owner seeking to understand their liability, or a lender requiring assurance on the environmental status of a property before approving a loan.

In some cases, the cost may also be negotiated between the buyer and seller as part of the property transaction process.

How Long Does a Phase 2 ESA Take?

The duration of a Phase 2 ESA can vary depending on several factors. These include the size and complexity of the site, the number of samples taken, and laboratory turnaround times for sample analysis. On average, a Phase II ESA can take anywhere from a few weeks to a couple of months to complete.

How Much Does a Phase 2 Environmental Study Cost?

The cost of a Phase 2 ESA varies widely based on the scope of work required. Factors influencing the cost include the size and complexity of the site, the type and number of samples, and the analytical methods used. It can range from a few thousand dollars for a Limited Phase II ESA to tens of thousands for a more complex site.

What Is The Final Goal of a Phase 2 Assessment?

The ultimate goal of a Phase 2 Assessment is to provide a clear understanding of the environmental conditions at a site. The findings from a Phase II ESA can significantly impact property transactions, lending decisions, and redevelopment plans.

If contamination is confirmed, it may necessitate remediation under local, state, or federal regulations. By identifying these issues early, businesses can proactively manage potential liabilities and avoid unexpected costs and delays.

Conclusion:

In conclusion, a Phase II Environmental Site Assessment is a critical tool in managing environmental risks. This environmental assessment provides a detailed understanding of the recognized environmental condition at a site, helping stakeholders make informed decisions and potentially avoid significant future liabilities.

Although the process may seem daunting, it is a crucial step towards ensuring the safe and responsible use of land.

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We will take the time to understand your unique needs and develop tailored solutions that address those needs. For facilites looking for help navigating the often perplexing regulatory landscape, contact us today!

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OSHA Injury Posting Requirements

OSHA Injury Posting Requirements

Jan 30, 2023

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

Posting Injury and Illness Data

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


Electronic Submittals to OSHA

osha injury reporting recordkeeping compliance chart for 2023

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

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

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

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

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

What’s Recordable, What’s Not?

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

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Mastering the Essential EHS Audit Checklist: A Comprehensive Guide

Mastering the Essential EHS Audit Checklist: A Comprehensive Guide

Oct 16, 2022

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

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

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

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

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

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

EHS Audit Checklist Templates

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

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

Who needs to use a health and safety audit?

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

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

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

EHS Audit Software:

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

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

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

EHS Audit Management Software Benefits

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

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

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

Pre-Audit Phase

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

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

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

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

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

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

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

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

What is a health and safety audit?

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

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

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

Deficiencies and Corrective Actions

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

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

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

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Workplace Safety Audit Guides

Workplace Safety Audit Guides

Sep 19, 2022

Work Site Safety Audits

A Work Site Safety Audit is an important part of any workplace. It helps to identify potential hazards and risks, and ensures that all safety protocols are being followed. The audit includes a comprehensive review of the environment, as well as any equipment or materials used in the area. It can also include interviews with employees and other stakeholders to assess their understanding of safety policies and procedures.

Safety Audits vs. Safety Inspections: What’s the Difference?

Safety audits and safety inspections serve different purposes. Safety audits are more comprehensive and review the overall safety program of an organization, while safety inspections focus on specific worksites or processes.

Audits evaluate compliance across multiple areas such as employee training, equipment maintenance, hazardous materials management, accident investigation/reporting procedures, emergency response plans, etc., whereas inspections are conducted to ensure that existing regulations and requirements are being met in a particular area (e.g. confined space entry, machine guarding).

Safety audits provide organizations with valuable feedback on their current safety practices and allow them to identify any potential risks before they become significant issues. Inspections can help find violations quickly and lead to corrective actions when needed. Both types of assessments are important components of an effective safety management system.

3 Types of Safety Audits

There are three primary types of safety audits: administrative, environmental, and personal protective equipment (PPE). Administrative audits assess compliance with safety policies and procedures; environmental audits evaluate the physical environment for conditions that may pose a risk to personnel; and PPE audits review the effectiveness of an organization’s PPE program in providing adequate protection for workers.

All three types of safety audit provide valuable insight into the overall safety performance of a company, helping to ensure that it is meeting its commitment to providing safe working conditions.

How to conduct a safety audit?

Conducting a safety audit is an important step in improving the safety of any workplace. It allows organizations to assess their current protocols and identify areas for improvement. When conducting a safety audit, it is important to consider all potential hazards and develop safety regulations and safety procedures to eliminate or control hazards.

This can include everything from evaluating how equipment is used and maintained, to reviewing employee training programs and procedures. Additionally, health and safety audit companies should pay attention to the environment around the facility, ensuring that employees are working in safe conditions with reasonable access to emergency exits.

After identification of risk areas, action plans should be developed and implemented in order to make sure that all necessary steps have been taken in order to provide a safe working environment for everyone involved. Finally, employers should regularly review their safety audit report and audit data and make adjustments to ensure that the workplace remains safe for all workers.

By doing this, businesses can prevent major accidents from occurring and create a safer work environment for everyone. Through consistent safety audits, organizations can be sure that they are taking every measure to ensure the wellbeing of their employees.

The Steps of a Successful Safety Audit

A safety audit is an important part of any successful workplace safety program. It helps to identify risks and implement controls that protect workers and facilitate compliance with relevant legislation.

The steps involved in a successful audit include planning the review process, conducting interviews, collecting data, analyzing results, revising policies and procedures as needed, and finally reporting findings to key stakeholders. To ensure optimal results, it’s important to consult experts who have knowledge of applicable regulations and industry best practices.

With audit findings, workplaces can create safer environments for all personnel. Doing so will go a long way towards preventing accidents or injuries from occurring. Ultimately this leads to increased productivity and improved morale among employees.

The benefits of conducting regular audits are clear and there are many resources available to help employers ensure their workplace safety programs meet or exceed standards. With the right approach, any organization can benefit from a successful safety audit process.

By taking the steps necessary to conduct an effective safety audit, companies can have peace of mind that they are putting their employees first while complying with relevant laws and regulations. Additionally, an audit helps organizations identify areas of potential improvement in order to strengthen existing policies and procedures and create a more secure environment for workers.

This is essential to creating a culture of safety within any organization. Conducting regular audits helps ensure safe working conditions and ultimately better outcomes for everyone involved.

Prepare for the Audit

It is important to thoroughly prepare for an audit, as it will help ensure that the process runs smoothly. Start by gathering all relevant documents and financial statements in one place. It is also beneficial to have a checklist of items that need to be addressed during the audit.

Additionally, make sure you are aware of any applicable laws and regulations related to your industry and business operations.

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What are the Benefits of Performing a Safety Audit?

Performing a safety audit is an essential part of any workplace safety program. Regularly performing safety audits helps to identify potential risks, ensure compliance with industry standards and regulations, minimize accidents and injuries, and keep workers safe. Safety audits also help to reduce costs associated with legal fees, insurance premiums, medical expenses, lost time due to injuries or illness, and other related costs.

In addition to this financial benefit, regular safety audits can increase employee morale by demonstrating the commitment of management towards workplace safety. Overall, the benefits of performing a safety audit are clear – improved worker health and reduced potential liability for employers.

How frequently should safety audits be conducted?

When it comes to safety audits, the frequency of their execution can vary depending on a variety of factors. Generally speaking, these audits should be conducted at least once a year. However, this timeframe may need to be adjusted depending on the industry, environment and context of the business in question.

What Are the Best Practices in Conducting Safety Audits?

Safety audits are essential for any work environment, and there are best practices that should be followed when conducting them. First, safety audits should be conducted regularly to ensure all areas of the workplace are up-to-date on safety standards.

It’s also important to involve personnel who can provide a fresh perspective and spot potential hazards. Additionally, auditors should document their observations as they conduct the audit, which allows for an objective assessment of safety practices.

Finally, it’s important to take any corrective actions needed following the audit in order to ensure a safe and healthy work environment. Following these best practices can help create an effective safety audit that ensures all areas of the workplace are up-to-date on standards and that potential hazards are identified and addressed quickly.

What is a Compliance audit?

A Compliance audit is a systematic review of an organization’s policies, procedures, and operations to ensure that they are in alignment with legal and regulatory requirements. It is a comprehensive evaluation of the effectiveness of internal controls across all areas of the business.

The main goal of this audit is to identify potential risks or weaknesses in the processes so that corrective action can be taken accordingly.

Use Competent and Objective Auditors

Competent and objective auditors play an essential role in ensuring the accuracy of financial documents. Auditors are responsible for evaluating the accuracy of financial records, assessing internal controls, analyzing transactions to detect errors, and providing assurance that the financial statements present a fair view of the company’s performance.

They must have expertise in accounting principles and be able to assess potential risks with objectivity. Auditors must also be able to clearly communicate their findings and recommendations in a way that is understandable to management.

An effective auditor will use a range of different techniques, such as reviewing documents, interviewing staff, using electronic data analytics tools and performing testing procedures, to ensure accuracy and completeness of the financial records.

What Are the Key Elements of a Safety Audit?

A safety audit is an essential tool for any organization that wants to ensure the health and safety of its employees. The key elements of a safety audit are identifying potential hazards, assessing the risk associated with these hazards and determining how best to reduce or eliminate them. To do this, workers must be trained in hazard identification, risk assessment methods, and prevention techniques to control risks.

Additionally, policies and procedures must be created and enforced to reduce the chance of harm or injury occurring in the workplace. Finally, safety audits should include regular follow-up reviews to ensure that any changes have been effective in improving safety. By using a comprehensive approach to safety management through a safety audit, organizations can help protect their staff from potential hazards and prevent accidents from occurring.

What is the difference between an auditor and assessor?

The main difference between an auditor and an assessor is the purpose of their respective roles. An auditor is responsible for verifying that financial information or systems are accurate and in compliance with laws, regulations, and standards.

An assessor’s role is to measure or evaluate a system, process, project, or organization against a set of criteria. Additionally, auditors are usually outside third-party professionals, while assessors can be internal staff employed by the organization they are evaluating. Ultimately, an auditor is interested in determining the truth of a situation, while an assessor is focused on understanding how well it meets standards or criteria.

Both roles play a valuable role in ensuring that financial and operational information is accurate and meeting legal requirements.

Does OSHA require safety audits?

Yes, OSHA does require safety audits for employers to ensure that their workplaces are safe and in compliance with the Occupational Safety and Health Act (OSHA). By conducting regular safety audits, employers can identify potential hazards and take measures to reduce them.

This helps protect employees’ physical health by reducing the risk of workplace injuries, as well as their mental health by creating a positive working environment. OSHA safety audits allow employers to identify potential hazards and make sure that their workplace is in compliance with the OSHA standards, thus protecting both employees’ physical and mental well-being. Additionally, regular safety audits can help employers save on costs by reducing liability in case of an accident or injury.

Need Help?

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What Is Compliance Reporting & Why Is It Important?

What Is Compliance Reporting & Why Is It Important?

Sep 13, 2022

What is a Compliance Report?

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

Regulatory Compliance Reporting vs. Internal Compliance Reporting

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

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

Why Compliance Reporting Is Important:

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

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

What are the different types of compliance reports?

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

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

What industries are often subject to compliance reporting?

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

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

Benefits of Effective Compliance Reporting

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

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

What should a compliance report include?

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

General Data Protection Regulation (GDPR)

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

How to develop a robust compliance reporting process?

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

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

What are 3 financial reporting risks?

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

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

What is misleading reporting?

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

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

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Lithium Batteries: Safety Hazards and Their Impact on Businesses

Lithium Batteries: Safety Hazards and Their Impact on Businesses

Aug 12, 2022

More lithium and lithium-ion batteries are being used in products today and just like any material, if we understand how to use it safely, it should not pose any problem. (Note: Lithium batteries are single-use batteries and lithium-ion batteries are the rechargeable kind.)

Lithium-containing batteries, when damaged. defective or used improperly, can present a fire and/or an explosion hazard.  Small items such as a laptop can typically have 6 lithium cells in them, while an electric vehicle can use 7,000 lithium-ion cells. This change in size greatly increases the risk and effects of a fire. If an electric vehicle catches on fire in your garage, you most likely do not have a way to deal with a 3,632° F fire.

Should I Really Worry About My Battery Catching on Fire?

If your battery stays intact, and does not allow moisture to get inside, or as long as there is not an issue with overcharging where the temperature runs away, you should be fine. The issue is that lithium and water don’t like each other. In fact, in its pure form, water causes lithium to react, sometimes violently, creating sparks and lots of heat, as well as hydrogen gas.

Lithium-ion batteries are a little different than the pure form of lithium in that they are filled with a lithium compound, and not pure lithium. Because of this, the material in many batteries are not quite as active with water. But when you have 7,000 cells in one place, if one catches on fire, a chain reaction can occur that you cannot control. Also fighting that fire with water may not be the best solution when water can cause it to react more.

This can be the same for industry. Lithium-ion batteries are being used in everything from pumps and instruments, to cars and equipment, hand tools, computer servers, and so many more products. Even your wireless mouse may have lithium-ion batteries.

If you just throw that away in the trash, not only are you potentially violating waste regulations and DOT shipping regulations, you may also be creating a fire hazard for the waste removal truck the landfill that it goes to.

DOT Issues Advisory Warning for Lithium-Containing Batteries

Recently DOT has found the issue with shipping lithium-containing batteries for recycle or waste has gotten out of hand. The Pipeline Hazardous Materials and Safety Administration (PHMSA), which is the HazMat division of the DOT, has issued a safety advisory on the dangers to help people out. The advisory warns that shippers and carriers need to take extra (and sometimes different) precautions when shipping damaged, defective or recalled lithium-containing batteries.

During recent compliance inspections, DOT inspectors have been finding improperly packaged and shipped lithium-containing batteries for disposal or recycling.  Some examples include:

  • Not packaging to prevent short circuiting
  • Mixing damaged batteries with others in the same packaging for recycling/disposal
  • Shipping pallets of batteries in boxes and drums with inappropriate package identifications

From a hazardous waste perspective, EPA recommends that lithium batteries be managed under the Universal Waste regulations.

Battery Disposal Rules – for Consumers

Regular citizens should take used, damaged, defective or recalled lithium-containing batteries to recycling facilities geared for accepting them, or your local household hazardous waste collection point. Do NOT throw them away with your other garbage.  If there is an item that’s recalled that has the battery in it, follow the manufacturer’s safety instructions and disposal instructions. Pay attention to any warnings.

Find an authorized provider to ship any lithium-containing batteries because they are considered to be hazardous materials.  When the post office asks if you are shipping hazardous materials, lithium-containing batteries makes that answer yes.

Battery Shipping and Disposal Rules – for Businesses

If you are a business, there are a number of regulations you need to follow to properly deal with lithium-containing batteries.  First, they can only be shipped by ground methods, so that’s by truck, rail or vessel. Overnight shipments or any shipment that could potential go via air methods are out of the question.

There are also specific regulations and procedures you need to follow to properly package, label and ship them.  There are regulations about the type of box you send them in because those packages must have special permits for this role.   There are special labels and markings that need to go on the packages and special ways they need to be packaged. Workers who will be participating in any function of the process are required to have proper training specific to their role, and that training is required every 3 years.  Emergency response information must also be included in the package process.

Training and Consulting Resource

iSi conducts hazardous materials shipping for businesses as well as conducts training to properly ship hazardous materials via ground, air, and vessel.  If you are a business that has question about how to deal with your lithium-containing batteries or if your workers need training, contact us today!

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Keith Reissig
Keith Reissig

Contributing:

Ryan Livengood

International Hazardous Materials Logistics Manager | EHS Regulatory Trainer

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

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Personal Protective Equipment (PPE): The Basics

Personal Protective Equipment (PPE): The Basics

Jun 21, 2022

What is Personal Protective Equipment (PPE)?

PPE is essential in protecting workers from potential harm and is mandatory in many industries. Employers must provide PPE to all their employees free of charge if they are likely to be exposed to hazards during work. The different types of PPE used depend on the risk assessment carried out by the employer, which will determine the level of protection needed for each individual employee.

Common examples of PPE include safety helmets, gloves, safety goggles, ear defenders and respirators. In some cases, employers may also need to provide fire retardant clothing or specialist footwear such as steel toe capped boots.

It is important that employers follow guidelines set out by regulatory bodies when providing PPE, as failure to do so could result in serious injury or even death. It is also important that employees use the PPE provided correctly and understand the associated risks of not doing so.

What different industries require PPE?

Transportation

The most common type of PPE used by truck drivers are:

  • Safety glasses or goggles
  • Steel toe boots
  • High visibility clothing

It is important to be aware of any hazardous materials that you may come into contact with while making a delivery and to make sure that you are wearing the appropriate PPE. In some cases, full-body suits may be necessary to protect against hazardous materials.

Chemical

  • Face shields/Face mask
  • Respiratory protective equipment
  • Chemical splash goggles
  • Gloves
  • Aprons/Overalls

PPE should always be used where there is a risk of exposure or contamination of corrosive liquids. It is important to ensure that PPE is appropriate for the task, fits properly, and is maintained in good condition. To determine appropriate types of PPE, it may be necessary to have a qualified person assess the nature and extent of potential hazards.

Food

  • Gloves
  • Safety glasses
  • Face shields
  • Hairnets

PPE is an essential part of any restaurant, cafe, or bar staff’s uniform and should be worn at all times while on the job. Employees who don’t wear the right PPE can easily get injured from sharp knives or hot dishes, increasing both their risk of harm and the potential liability of their employer.

Healthcare

  • Gloves
  • Gowns
  • Eye protection
  • Disposable N95 respirators, surgical masks, face shield

PPE for healthcare workers is essential for occupational safety. The CDC (Center for Disease Control) recommends gloves, gowns, eye protection, and face shields/masks as the basic requirements for any and all healthcare workers.

Wearing PPE such as basic respiratory protection, protective clothing, a surgical mask, protective eyewear, and lab coats, when worn correctly, can significantly help prevent workplace hazards and biological hazards, thus helping protect workers and health workers.

Oil and Gas

  • Eye protection
  • Hearing protection
  • Hand/Foot protection
  • Flame-resistant clothing
  • Gas detection monitors

Essential PPE for oil and gas workers significally reduce employee exposure to physical hazards present as well as notify them on things they cannot see.

Automotive

  • Peripheral safety goggles
  • Cut-resistant gloves

Peripheral eye protection is especially important in the Automotive Industry, as liquids like fuel and oil can drip down the face, and working in dusty environments with fiberglass, or metal fragments can work their way around non-sealed safety glasses.

Sealed glasses and goggles provide the best protection against such hazards while allowing unrestricted vision to perform service tasks. Motor vehicle technicians and mechanics should always wear proper eye protection whenever doing repairs, as the risks of serious injury or permanent vision damage are simply too great to ignore.

It is also important for anyone working in an automotive environment to get regular vision exams to ensure that any issues can be caught and treated early. Cut-resistant gloves will help prevent skin damage and skin hazards.

Construction

  • Protective gloves
  • Hearing protection to prevent occupational hearing loss
  • Full face shields when cutting, grinding, or chipping
  • Goggles for chemical splashes
  • Proper respiratory equipment and protection
  • Fall protection equipment when working above 6 feet

In addition to these PPE requirements, all construction site employees must be aware of the site-specific health hazards associated with working on a construction or renovation site. Employees should know what types of hazardous substances are present and how they can protect themselves.

Appropriate PPE such as respirators, gloves, boots, and chemical protective clothing may need to be worn depending on the particular job site. Make sure that you understand all safety procedures before beginning work and follow them at all times.

It is the responsibility of each employee to take appropriate steps to protect themselves from any potential harm.

Finally, make sure that you report any unsafe conditions or practices immediately to your supervisor or the project manager in charge of the site. Safety first – always!

Manufacturing

  • Gloves
  • Hard hat
  • Goggles
  • Full-body suits
  • Face shields

When working in a manufacturing facility, it is important to wear the proper personal protective equipment (PPE) to protect yourself and protect employees around you.

This includes gloves, protective hearing gear, hard hats, goggles, respirators, and full-body suits. Wearing PPE can help protect you from various hazards in the workplace. Some facilities may require using a self contained breathing apparatus or powered air purifying respirators as well as other equipment designed for a specific purpose.

What are some examples of PPE?

Masks and Respiratory Protective Equipment

When choosing a respirator, it’s important to understand the differences between APRs and ASRs. Air-purifying respirators (APRs) filter out contaminants from the air that is breathed through them. These types of respirators are most effective when used in environments with low levels of contamination, since they are unable to protect against high concentrations of airborne contaminants. Some examples are:

Protection for the Face and Eyes

Eye and face protection is important in any workplace setting to not only protect against eye injuries, but also for ensuring optimal employee productivity. Depending on the work environment and tasks that need to be completed, there are four primary types of eyewear available to help minimize risk.

General safety goggles are designed with side shields that provide a greater area of coverage, and some models may even include a wraparound frame. They are suitable for most workplace conditions, including those with light debris or dust particles in the air. Another example of safety goggles is laser safety goggles.

Head and Shoe Protection

Wearing a hard hat with a chin strap is the best way to ensure that an employee’s head remains protected when working in hazardous situations. The chin strap will keep the hat secured and prevent it from falling off in case of a fall or other accident. Hard hats must also be inspected regularly for any cracks, dents, scratches, punctures or other signs of damage.

Damaged hard hats must be replaced immediately to ensure an employee’s safety. Employees should also check the fit of their helmet before beginning work. A well-fitting hard hat will provide maximum protection and comfort for employees working in hazardous conditions. Safety equipment can only help you if you use it properly.

Gloves

Different types of gloves include: Leather, Canvas or Metal Mesh Gloves, Fabric and Coated Fabric Gloves, Chemical- and Liquid-Resistant Gloves, and Insulating Rubber Gloves. Gloves are used in many different scenarios and provide protection against anything from infectious materials, contaminated body fluids, bloodborne pathogens, and bacterial contaminants, to physical hazards such as cuts and abrasions.

What is required for OSHA standards for PPE?

Employers should assess the workplace to determine if PPE is necessary. If it is, employers should provide employees with appropriate protective equipment and ensure its use. Employers must also make sure that the protective equipment is well-maintained and kept clean.

Additionally, employers must train employees on how to properly wear and care for their eye and face protection in order to ensure its effectiveness. Employees should also be informed about potential hazards in their work environment, as well as any limitations of the protective equipment they are using.

If an employee needs prescription lenses while wearing safety glasses, employers may have additional requirements to meet OSHA standards. It is important to note that non-prescription safety glasses do not provide adequate protection against hazardous materials.

Employers should ensure that employees who require prescription lenses have access to appropriate protective equipment and can safely perform their job duties without endangering themselves or others.

If an employer has determined that protection is necessary, they must also provide employees with a copy of OSHA’s standard 1910.133 which outlines the requirements for protection in the workplace.

This document contains detailed information on types of hazards, selection criteria, performance requirements, instructions for use and care, as well as other helpful information employers need to know when providing appropriate face protection to their employees. The World Health Organization and OSHA reiterate that employees must wear PPE and proper equipment in order to protect them properly.

Why do you and your employees need PPE?

  1. Liability

  2. Long-term issues

  3. Keep what you got!

  4. Increase quality work environments

Conclusion:

When it comes to workplace safety, personal protective equipment (PPE) is an essential piece of the puzzle. PPE protects workers against hazards in the environment that could cause physical harm or injury. Industries such as manufacturing and mining are particularly hazardous, and effective use of PPE can help prevent accidents and injuries from occurring.

To ensure maximum protection, it is important that workers always wear the correct type of PPE for the job they are doing. This could include safety glasses, gloves, hearing protection, hard hats and other items that are designed to protect against specific hazards.

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Incorporate Sustainability Action Plans Into Your Preconstruction Submittals

Incorporate Sustainability Action Plans Into Your Preconstruction Submittals

Jun 15, 2022

How to Incorporate a Sustainability Action Plans Into Your Preconstruction Submittals

A Sustainability Action Plans (SAP) is a critical part of any successful sustainable construction project and sustainable business. By creating and implementing a SAP, you can ensure that your construction project will be environmentally responsible and meet or exceed all applicable environmental sustainability standards. These action plans are designed to help both the environment and your build in the present and future. A few issues that it can aid is renewable energy, air pollution, climate change, as well as many other environmental issues. In this article, we will discuss how to incorporate Sustainability Action Plans into your preconstruction submittals.

If you’re a construction project manager, then you know that preconstruction submittals are a critical part of the process. If you are working on a federally funded project, then you have probably been asked to include Sustainability Action Plans and Sustainability eNotebooks.

Incorporating a sustainable action plan into your preconstruction submittals can be a challenge, but it’s worth the effort. Here are six tips to help you get started:

  1. Define what sustainable features are required to include in your project (ie. Sustainability performance, energy usage, etc.)
  2. Do your research on which sustainable materials are available and how they can be used (ie. recycling bins)
  3. Work with your architect and engineers to see how these materials can be incorporated into the design
  4. Make sure that the contractors you hire are aware of your sustainability goals and are willing to work with you to achieve them
  5. Be prepared to make some sacrifices – not all sustainable materials are going to meet project specifications, be prepared to clarify why they won’t work
  6. Remember that a sustainable project is an investment in the future, both for yourself and for the planet

By following these tips, you’ll be on your way to creating a more sustainable construction project!

Define what sustainable features are required to include in your project

Guiding principles and requirements for a viable project are essential and include elements of energy efficiency, bioswales, green roofs, renewable sources, and an effective waste management plan.

These guiding principles should be woven in with the initial design and planning stages of any project to ensure that it is both efficient and environmentally conscious. Any development must maintain the guiding principles set out as required by law. In addition, developing a waste management plan that can be implemented during construction and throughout the life-cycle could be beneficial from a cost perspective as well as from an environmental one.

Sustainable features should always factor into any project if you are looking to keep your operations on track, make your customers happy, and show you are a green business.

Do your research on which sustainable materials are available and how they can be used

If you’re looking to create a sustainability plan, one of the keys to success is researching and finding sustainable materials that can be used to reduce overall waste.

With a wealth of options available today, it pays off to put in the effort to find the viable and suitable sustainability initiatives that can be incorporated into your projects. Sustainable products come at various prices and have different strengths and energy efficiency profiles, so it’s important to evaluate them thoroughly for each project.

Doing your research upfront will ensure you are making informed decisions about incorporating sustainability into your operations. Time spent now creating a sustainability plan will pay off big time in the future!

Work with your architect and engineers to see how these materials can be incorporated into the design

Working with your architect and engineers is the key to successfully incorporating new materials into the design. It’s important to have a well-thought out plan for how best to use these materials so that you get the most out of them without wasting resources.

Take advantage of the insight, knowledge and experience available from your team of professionals – clearly communicate your vision and objectives, then take their advice on board to ensure a successful outcome. Time spent discussing with your architect and engineers upfront is much more profitable than trying to figure it out yourself later down the track.

Make sure that the contractors you hire are aware of your sustainability goals and are willing to work with you to achieve them

If you’re serious about sustainability, you need to make sure that the contractors you bring on have the same commitment. It’s not enough for them to just say they support your goals; they need to also be willing to put in the work and effort.

Do a thorough vetting process and make sure that any personnel working with you are willing to do their part in meeting environmental objectives. If not, it defeats the purpose of having those goals in the first place.

Don’t let anyone slip through the cracks — be vigilant and ensure contractors are up-to-speed on your sustainability plans or else keep looking until you find someone who is.

Be prepared to make some sacrifices – not all sustainable materials are going to meet project specifications, be prepared to clarify why they won’t work

Sustainable materials are integral to any project, but you’ve gotta be prepared to make some sacrifices along the way. While not all sustainable materials may meet your specifications, it’s paramount that you understand why and explain that reasoning.

Don’t expect every viable alternative to perfectly fit your criteria – compromise is the name of the game in order to ensure that our work is as future-proof as possible. Taking shortcuts here will likely come back to bite you down the road, so don’t be afraid to get into the nitty-gritty of why a particular material won’t work for your needs – it could end up being an invaluable lesson.

Remember that a sustainable project is an investment in the future, both for yourself and for the planet

When it comes to sustainability, no effort is too small. Investing in projects that are meant to minimize human damage and preserve the planet for generations to come is essential; if we don’t look out for our environment, nobody else will.

It’s a matter of personal responsibility – taking charge of our own impact on the world around us and recognizing that every action we take can have positive or negative ramifications. It may be expensive up front, but a sustainable project is an investment in both your future and the future of the planet, guaranteed to pay dividends in more ways than one.

For instance, the resources in your project specific Sustainability Action Plans can be converted directly in to a corporate level sustainability program, helping to reduce waste on future projects as well.

Sustainability is important for a number of reasons. It’s not just about being environmentally friendly or socially responsible – though that is certainly part of it. It’s also about creating a project that will be able to stand the test of time, both in terms of its physical durability and its relevance to the needs of future generations.

Developing a sustainable project can be challenging, but it’s definitely worth the effort. If you need help getting started, don’t hesitate to reach out. We’re happy to assist you in developing and implementation of a Sustainability Action Plan for your next Federal Project.

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Trailer Safety

Trailer Safety

Jun 7, 2022

Trailers are often used in the workplace — by operations personnel down to even the sales department who may move their exhibits from show to show.  The construction industry uses a lot of trailers to move equipment. 

With the summer season, our employees may be using trailers to haul boats, ATVs, campers, or extra large smoker grills.  U-Hauls can be rented by anyone for moving from house to house or to move a kid to or from college, to haul cars or other items.

Here are some trailer safety tips to help avoid a potential accident:

  • Choose the right tow vehicle and trailer for the load. Review the tow capacity and ensure it’s capable of handling the weight of the trailer and what you’re going to be towing on it.  Exceeding the capacity can severely affect handling, braking and damage your vehicle’s suspension. Check the hitch for the maximum trailer and maximum tongue weights it can safely support.
  • If you’re going to be carrying additional loads or passengers in the vehicle, check the gross vehicle weight rating issued for your vehicle and make sure the load will not exceed that rating, nor that the combination of the trailer and vehicle weights will be exceeded.
  • Make sure you have the proper hitch ball for the trailer. Incorrectly sized hitch balls are the #1 cause of trailer accidents.
  • When hauling loads, 60% of the load on the trailer should be placed on the front half of the trailer, with a tongue weight of 10-15% of the total weight that’s loaded on the trailer. Ensure weight is evenly distributed on the left and right sides of the trailer.
  • Straps are critical — broken or cheap straps can fail fast. Use ratchet straps for anything heavier than an average person and use more than one strap in case one comes loose.  The working load of the strap should be more than the weight of what you’re hauling.  For vehicles, strap vehicles at four points of the trailer corners.
  • Check your tires on both the vehicle and the trailer. Underinflation can cause rolling resistance and forces the engine to work harder and consume (now more expensive) fuel.
  • One of the most common trailer issues is lights — make sure your lights work before you leave, make sure the load doesn’t obscure them and take spare bulbs and fuses with you.
  • Check your brakes and make sure the breakaway cable is properly attached to your tow vehicle. In the event the trailer somehow disconnects from the hitch, the cable will trigger the trailer brakes.
  • Always cross safety chains so that they form a cradle for the tongue to fall down onto.
  • Adjust your mirrors so that you can have a clear view of the entire trailer, to the end.
  • Carry spare parts such as at least one trailer spare tire as well as extra wheel bearings and hubs.
  • When unhooking the trailer from the tow vehicle, use wheel chocks in front of and behind the trailer’s tires to ensure it doesn’t roll away.
  • Towing can stress your engine, so make sure your vehicle has all of its fluids to prevent overheating. Make sure your vehicle has proper levels of coolant, oil and transmission fluid.
  • Be patient when passing and take extra care when changing lanes.
  • Don’t speed and know the speed limits of the trailer and of your state/local area. Some areas have specific speeds for trailers.
  • Stop gradually when possible and allow for plenty of stopping distance between you and the vehicle in front of you. It takes longer to stop when pulling a load. Scan the road ahead to anticipate potential problems.
  • Watch out for trailer sway. High winds, large trucks, downhill grades and high speeds can lead to your trailer swaying.  If you’re not careful, it can swing like a pendulum.  Consider using a hitch stabilizer or a sway control unit to help alleviate this issue.
  • Don’t drive in if there’s no way out. It’s easy to get blocked in, so make sure there’s plenty of space to make a complete turnaround.

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What is OSHA’s National Emphasis Program on Heat Hazards?

What is OSHA’s National Emphasis Program on Heat Hazards?

Jun 2, 2022

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Heat plays a large part in how we plan our day. We often put off work that creates heat or highly strenuous tasks to a time when the weather is more conducive to our needs. However, that cannot always be done. Sometimes a task must be done on a rigid schedule or is of an emergency nature so that work cannot be put off to a later, cooler, time of day. To that end, OSHA has developed a National Emphasis Program (NEP) to give some guidance to companies on how to work in the heat and keep employees safe.


What is OSHA’s NEP on Heat Hazards?

OSHA will conduct programmed (pre-planned) inspections in targeted high-risk industries on any day that the National Weather Service has announced a heat warning or advisory for the local area.

The NEP went effective on April 8, 2022 and will remain in effect for 3 years unless canceled or extended by a superseding directive.

The NEP establishes heat priority days when the heat index is expected to be 80 degrees Fahrenheit or higher. During these days OSHA will:

  • Initiate compliance assistance in the list of targeted high-risk industries; and,
  • Inspect any alleged heat-related fatality/catastrophe, complaint or referral regardless of whether the worksite is within the list of targeted high-risk industries.


What are the Targeted High-Risk Industries?

OSHA’s NEP on heat hazards targets over 70 high-risk industries based on:

  • Bureau of Labor Statistics (BLS) on incidence rates of heat-related illnesses
  • Elevated numbers of fatalities or hospitalizations reported to OSHA
  • Highest number of heat-related General Duty Clause violations over the last 5 years

These include but are not limited to:

General Industries That are Likely to Have Heat-Related Hazards:

NAICS Code        NAICS Industry Sector Title

1121                      Cattle Ranching and Farming
1151                      Support Activities for Crop Production
2131                      Support Activities for Mining
3118                      Bakeries and Tortilla Manufacturing
3211                      Sawmills and Wood Preservation
3241                      Petroleum and Coal Products Manufacturing
3251                      Basic Chemical Manufacturing
3272                      Glass and Glass Product Manufacturing
3311                      Iron and Steel Mills and Ferroalloy Manufacturing
3314                      Nonferrous Metal (except Aluminum) Production and Processing
3315                      Foundries
3323                      Architectural and Structural Metals Manufacturing
3329                      Other Fabricated Metal Product Manufacturing
3361                      Motor Vehicle Manufacturing
3362                      Motor Vehicle Body and Trailer Manufacturing
3363                      Motor Vehicle Parts Manufacturing
3364                      Aerospace Product and Parts Manufacturing
3365                      Railroad Rolling Stock Manufacturing
3366                      Ship and Boat Building
3369                      Other Transportation Equipment Manufacturing
3371                      Household and Institutional Furniture and Kitchen Cabinet Manufacturing
4239                      Miscellaneous Durable Goods Merchant Wholesalers
4241                      Paper and Paper Product Merchant Wholesalers
4242                      Drugs and Druggists’ Sundries Merchant Wholesalers
4243                      Apparel, Piece Goods, and Notions Merchant Wholesalers
4244                      Grocery and Related Product Merchant Wholesalers
4245                      Farm Product Raw Material Merchant Wholesalers
4246                      Chemical and Allied Products Merchant Wholesalers
4247                      Petroleum and Petroleum Products Merchant Wholesalers
4248                      Beer, Wine, and Distilled Alcoholic Beverage Merchant Wholesalers
4249                      Miscellaneous Nondurable Goods Merchant Wholesalers
4413                      Automotive Parts, Accessories, and Tire Stores
4442                      Lawn and Garden Equipment and Supplies Stores
4881                      Support Activities for Air Transportation
4882                      Support Activities for Rail Transportation
4883                      Support Activities for Water Transportation
4884                      Support Activities for Road Transportation
4889                      Other Support Activities for Transportation
4921                      Couriers and Express Delivery Services
4922                      Local Messengers and Local Delivery
4931                      Warehousing and Storage
5311                      Lessors of Real Estate
5617                      Services to Buildings and Dwellings (includes landscaping services, tree removal and tree trimming services)
5621                      Waste Collection
5622                      Waste Treatment and Disposal
5629                      Remediation and Other Waste Management Services
6231                      Nursing Care Facilities (Skilled Nursing Facilities)
7211                      Traveler Accommodation
8111                      Automotive Repair and Maintenance
8113                      Commercial and Industrial Machinery and Equipment (except Automotive and Electronic) Repair and Maintenance
8114                      Personal and Household Goods Repair and Maintenance

Construction Industries That are Likely to Have Heat-Related Hazards

NAICS Code        NAICS Industry Sector Title

2361                      Residential Building Construction
2362                      Nonresidential Building Construction
2371                      Utility System Construction
2372                      Land Subdivision
2373                      Highway, Street, and Bridge Construction
2379                      Other Heavy and Civil Engineering Construction
2381                      Foundation, Structure, and Building Exterior Contractors
2382                      Building Equipment Contractors
2383                      Building Finishing Contractors
2389                      Other Specialty Trade Contractors

Industries not Included in General Industry or Construction That are Likely to Have Heat-Related Hazards

NAICS Code        NAICS Industry Sector Title

1112                      Vegetable and Melon Farming
1113                      Fruit and Tree Nut Farming
2213                      Water, Sewage and Other Systems (may be State or local jurisdiction)
4411                      Automobile Dealers
4412                      Other Motor Vehicle Dealers
4821                      Rail Transportation (may be Federal jurisdiction)
4885                      Freight Transportation Arrangement
4911                      Postal Service
5611                      Office Administrative Services
5612                      Facilities Support Services
5613                      Employment Services
5614                      Business Support Services
5616                      Investigation and Security Services
5619                      Other Support Services
6117                      Educational Support Services
7225                      Restaurants and Other Eating Places
8112                      Electronic and Precision Equipment Repair and Maintenance
9281                      National Security and International Affairs (includes Customs and Border Patrol, and Transportation Security Administration)


What Will the OSHA Auditors Be Inspecting When They Come to Your Facility?

During heat-related inspections, inspectors will:

  • Review OSHA 300 Logs and 301 Incident Reports for any entries indicating heat-related illness(es). 
  • Review any records of heat-related emergency room visits and/or ambulance transport, even if hospitalizations did not occur. This may require the use of a Medical Access Order.
  • Interview workers for symptoms of headache, dizziness, fainting, dehydration, or other conditions that may indicate heat-related illnesses, including both new employees and any employees who have recently returned to work.
  • Determine if the employer has a heat illness and injury program addressing heat exposure, considering the following:
    • Is there a written program?
    • How did the employer monitor ambient temperature(s) and levels of work exertion at the worksite?
    • Was there unlimited cool water that was easily accessible to the employees?
    • Did the employer require additional breaks for hydration?
    • Were there scheduled rest breaks?
    • Was there access to a shaded or cool area?
    • Did the employer provide time for acclimatization of new and returning workers?
    • Was a “buddy” system in place on hot days?
    • Were administrative controls used (earlier start times, and employee/job rotation) to limit heat exposures?
    • Did the employer provide training on heat illness signs, how to report signs and symptoms, first aid, how to contact emergency personnel, prevention, and the importance of hydration?
  • Document conditions relevant to heat-related hazards, including:
    • The heat index and additional weather data from that day, e.g., heat alerts from the NWS, data from the OSHA-NIOSH Heat Safety Tool App, saving a screenshot on a mobile phone or tablet. Additional information may be needed for indoor heat investigations.
    • Observe and document current conditions and those at the time the incident occurred (for unprogrammed inspections), including:
      • Observed wind speed
      • Relative humidity
      • Dry bulb temperature at the workplace and in the shaded rest area
      • Wet-bulb globe temperature at the workplace, (ensure the equipment has been properly calibrated prior to use)
      • Cloud cover (no clouds, 25%, 50%, 75%, 100%)
      • The existence of any heat advisories, warning or alerts the previous days
    • Identify activities relevant to heat-related hazards. These can include, but are not limited to:
      • Potential sources of heat-related illnesses (e.g., working in direct sunlight, a hot vehicle, or areas with hot air, near a gas engine, furnace, boiler or steam lines).
      • The use of heavy or bulky clothing or equipment, including personal protective equipment.
      • Estimate workload exertions by observing the types of job tasks performed by employees and whether those activities can be categorized as moderate, heavy or very heavy work, considering both average workload and peak workload.
      • Duration of exposure during which a worker is continuously or repeatedly performing moderate to strenuous activities.
    • OSHA believes a review of any potential heat-related hazards should be included in any programmed or unprogrammed inspection where radiant heat sources exist in indoor work areas or at outdoor work areas on heat priority days. OSHA advises inspectors to conduct compliance assistance and document it where heat-related hazards do not warrant issuing citations.
    • Inspectors can use the OSHA-NIOSH Heat Safety Tool App as a resource.

How Can You Prevent Heat Illness at Work?

Dangerous heat exposure can occur indoors or outdoors, in any season. Employers can keep workers safe by following these simple safety practices:

  • Follow the 20% Rule — on the 1st day, don’t allow employees to work more than 20% of a shift at full intensity in the heat. Increase their time by no more than 20% a day until they are used to working in the heat.
  • Provide cool drinking water – encourage workers to drink at least one cup every 20 minutes, even if they are not thirsty.
  • Rest breaks — allow workers time to recover from heat in a shady or cool location.
  • Dress for the heat — have workers wear a hat and light-colored, loose fitting, breathable clothing if possible.
  • Watch out for each other — encourage workers to monitor themselves and others for signs of heat illness.
  • Look for any signs of heat illness, including fainting, dizziness, nausea, and muscle spasms, and act quickly — when in doubt, call 911.
  • Offer training on the hazards of heat exposure and how to prevent illness.
  • Develop an Emergency Action Plan on what to do if a worker shows signs of heat-related illness.


Need Help in Getting Your Documentation in Order?

Do you need assistance in developing a formal heat illness and injury program compliant with this initiative? Do you need assistance in determining your potential heat exposures? iSi can help! Contact us today!

 

Contributing:

Keith Reissig

Industrial Hygienist | Project Manager

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

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6 Key Steps of an Effective Incident Investigation Process

6 Key Steps of an Effective Incident Investigation Process

May 2, 2022

Why Conduct Incident Investigations?

When investigating a worksite incident, it is essential to record all findings accurately and thoroughly. This includes documenting the accident scene, identifying any possible witnesses, and interviewing involved parties to verify facts. All of these steps will help employers and workers understand what happened and identify potential hazards in order to prevent future incidents from occurring.

Who should do the investigating?

It is equally important to involve managers and employees in the incident investigation. Managers can provide oversight of the process, as well as draw on their experience to identify potential contributing factors from when the incident occurred. Employees also bring valuable insight – for instance, workers may be able to identify specific unsafe practices or conditions that led up to the incident.

Six steps for successful incident investigation:

The 7 steps of investigation includes:

STEP 1 – IMMEDIATE ACTION

Once the area is safe, first aid and medical care has been given for the people involved and the scene has been preserved, a thorough investigation will begin. Evidence will be collected from multiple sources which may include CCTV tapes, photographs of the scene or other physical evidence such as samples. This evidence must be carefully documented and stored securely in accordance to local laws and regulations.

STEP 2 – PLAN THE INVESTIGATION

It is important to develop a clear plan for investigating any incident. The plan should consider the resources required, who will be involved, and how long it is expected to take. Depending on the severity or complexity of the incident, an investigation team may be necessary in order to ensure that all aspects of the case are thoroughly examined.

An accident investigation is important for any workplace incident, not only for human error but for equipment and management systems errors as well. With a proper investigation, a safety committee will need to involved or established as well as a single investigator.

STEP 3 – DATA COLLECTION

The investigation of any incident requires a thorough analysis of all available information. This might include interviewing witnesses or victims and an injured worker, reviewing documents related to the event, examining equipment or machinery that was involved in the incident and studying the incident scene.

The data collected from these sources can provide invaluable insights into what happened during the incident and help investigators determine the cause. To collect data, comb over every sequence of events and gather information regarding human errors as well as equipment errors. Weather conditions should be documented as well along with safety problems, property damage, serious injury, witness statements, near misses, work environment, other incidents, and other relevant information that will be helpful to the investigation team.

STEP 4 – DATA ANALYSIS

The root cause of an incident is typically the result of multiple failures, decisions, and processes that have been allowed to exist in an organization’s environment. To properly recognize the root cause requires a thorough investigation into the systemic factors at play.

The direct causes are more obvious, but it’s important not to overlook their connections to underlying influences. By looking closely at both direct and underlying causes, it becomes possible to identify where improvement can be made and prevent similar incidents from occurring in the future. In order to understand the data, you’ll need to review records such as inspection reports as well as review all injuries recorded, the me

STEP 5 – CORRECTIVE ACTIONS

Root cause analysis also helps organizations to recognize any potential areas for improvement, ensuring that similar incidents do not happen again in the future. By understanding and addressing the root causes of an incident, organizations can gain greater visibility into their processes and ensure long-term success.

Additionally, significant cost savings can be achieved through effective root cause analysis as it provides a valuable opportunity to review existing processes and address any deficiencies before they become costly later on. Ultimately, when used correctly, root cause analysis can help an organization get ahead of problems before they occur and reduce risks associated with them and other hazards.

Corrective actions might include personal protective equipment changes or updates due to equipment failure. Doing a ‘quick fix’ would be an example of what not to do as a corrective action. Cutting corners can cause repeat incidents and come with serious consequences.

STEP 6 – REPORTING

Once the investigation is concluded and all outstanding issues are closed out, it is important to communicate the findings so that lessons can be shared. In order to do this, organizations should use formal incident investigation reports, alerts, presentations and meeting topics.

Regular safety inspections, regular maintenance, implement corrective actions and a safety program, being sure to follow up with organizational requirements on safety and training both management and employees on safety in incidents are crucial when reporting and maintaining reporting.

Why look for the root cause?

Root Cause Analysis can be used to help organizations recognize and rectify the underlying causes of problems they may be facing. The first step in this process is to identify the negative events that are occurring and determine if any patterns or trends exist among them.

What are the steps involved in investigating an incident?

  • Secure the area
  • Plan the investigation
  • Collect all information
  • Analyze collected data
  • Find the root cause
  • Execute corrective actions
  • Document and share the results

What should I know when making the analysis and recommendations?

If your analysis is just another step of managing incidents. Be sure to allocate the appropriate resources and time to complete a full analysis in these situations:

  • When issues occur or can be expected to occur more than once
  • When an outage has or can affect many users
  • When the system isn’t functioning as designed

What is OSHA Process Safety Management Management of Change?

MOC’s (Management of Change) establish and implement written procedures to manage changes made to process chemicals, technology, equipment, procedures and facilities. OSHA’s Process Safety Management (PSM) standard requires companies to perform MOC’s when changes are made that could affect how safely a process runs.

This procedure should outline all points involved in making changes to the process, such as reviewing safety concerns, assessing risks, identifying potential hazards, selecting appropriate control measures, monitoring results, and updating records.

Which are the three types of MOC?

The three most common types of MOC are administrative, organizational, and technical.

What are the steps of MOC process?

8 Steps to a MOC Process

  1. Identify Proposed Changes.
  2. Risk Assessment.
  3. Determine if Hazards/Risks Can Be Controlled.
  4. Evaluate Making a Change.
  5. Implement Change If Safe.
  6. Pre-Startup Safety Review (PSSR)
  7. Train Workers on Change.
  8. Execute and Monitor Change.

 

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Fatigue Management

Fatigue Management

Apr 1, 2022

We’re all tired. There are so many things weighing on us — taking on more tasks and trying to keep up at work when there are not enough workers to get everything done, continuous pressure to maintain levels of service when supplies are delayed and staffing is short, COVID, Daylight Savings time, we’re approaching one of the busiest times of the year in the school calendar, you have stuff at home that’s not getting done, and on and on. When you get tired, mistakes and accidents happen.

Most adults need 7-8 hours of sleep in every 24 hours to feel well rested and without it, a sleep debt is built up. This debt may result in impaired performance, reduced alertness and higher levels of sleepiness and fatigue. A sleep debt can only be repaid with restful sleep. Fatigue contributes to accidents by impairing performance and in extreme cases causing people to fall asleep. Fatigue related “micro sleeps” are very hard to predict or prevent and can place the individual and others at risk.

According to the National Safety Council, more than 43% of workers are sleep-deprived, and fatigued worker productivity costs employers $1,200 to $3,100 per employee annually. Employees on rotating shifts are particularly vulnerable because they cannot adapt their “body clocks” to an alternative sleep pattern.

Fatigue Management Programs

More and more companies are including fatigue management in their list of safety programs.  For major manufacturers and industrial facilities that use contractor pre-qualification services like ISNetworld, Fatigue Management Programs are a requirement for contractors.

Fatigue Management Programs can be simple.  They can line out the responsibilities of supervisors, employees and the company.  They also discuss the hazards of fatigue, provide a overview of risk controls and make a plan for training.

Even if you don’t want to create a formal Fatigue Management Program, you still may want to consider including safety sessions about it to your teams.  Here are some elements you can include in your training:

Signs and Effects of Fatigue

Signs of fatigue include long eye blinks, repeated yawning, frequent blinking, bloodshot eyes, poor reaction time, slow speech, loss of energy, and an inability to concentrate.

Fatigue can result in a lack of attention, difficulty following instructions, reduced ability to think clearly, and slower response to changing circumstances.

Chronic fatigue can also lead to many different long term health issues such as high blood pressure, increased risk for diabetes and heart disease, weakened immunity, poor balance, mood changes and memory issues.

What Your Company Can Do:  Risk Controls to Consider

Rest, of course, is the most important control measure for managing fatigue. For companies, consider the following:

  • Is a ten hour or longer break between work shifts provided?
  • Are safety critical tasks planned during “circadian low” hours, 2am-6am and 2pm- 4pm?
  • Are complex tasks planned on the first or final shift of a nightshift work cycle?
  • Does the break between work shifts provide a sleep opportunity of 7 or more hours of continuous sleep?
  • Is a minimum of one break provided between each 4 hours of work with one break of sufficient length to have a meal (i.e. 30 minutes)?
  • Are more frequent short breaks allowed during strenuous activities?
  • Are on-call responsibilities limited?
  • Is ready access to drinking water provided?
  • Do Call-Out/On Call schedules provide for adequate rest before returning to a regular work shift?

What the Worker Can Do: Combating Fatigue

  • Try to maintain a consistent sleep schedule — if you’re sleeping more on days off, you’re not sleeping enough on work days. Try to go to bed and wake up at roughly the same time per day, even on the weekends.
  • Try to get a minimum of 7 hours per night
  • Don’t eat big meals close to bedtime, but if you’re hungry before bed, don’t go to bed hungry as that will affect sleep too — have a healthy snack.
  • Caffeine, nicotine and alcohol can all affect sleep patterns
  • Make your bedroom conducive to sleep — quiet, dark, not too hot or too cold
  • If you have daytime sleepiness, snoring or breathing pauses, get checked out for sleep apnea
  • Just like kids need a bedtime routine, so do you. Establish a relaxing bedtime routine and stick to it.
  • Avoid stressful activities before bedtime and don’t associate your bedroom and sleeping with anxiety
  • Don’t go to bed for sleep unless you’re truly sleepy — trying to sleep is counterproductive and can make it harder to fall asleep.
  • Avoid long naps during the day that may throw off your nighttime schedule.
  • Avoid blue light exposure at night (from electronic devices) – use glasses that block blue light or install an app that blocks it.
  • When was the last time you changed your mattress and pillow? Are they causing pain? Upgrade your bedding every 5-8 yrs.

Working together to try to incorporate just even a few of these into our lives and work days should make a real difference in workplace health and wellness — both physically and mentally.

If you need help developing a Fatigue Management written safety program, we can help.  Contact us today!

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OSHA’s Noise Regional Emphasis Program for General Industry and Construction

OSHA’s Noise Regional Emphasis Program for General Industry and Construction

Mar 24, 2022

OSHA has reissued a noise hazard regional emphasis program for Region VII.  OSHA inspectors will be conducting targeted inspections for noise for certain NAICS categories in both general industry and construction.  Even though this particular emphasis program is for Region VII (Kansas, Missouri, Iowa, and Nebraska), OSHA has noise-related regional emphasis programs in all states except for those that fall in the Western and Pacific Regions (9 and 10).

OSHA says it’s targeting workplaces with excessive noise levels in order to prevent permanent hearing loss.  They say 22 million workers are working in hazardous noise levels and 53% do not wear hearing protection.  In a NIOSH study, 52% of noise-exposed tested construction workers admitted to not wearing hearing protection, and 25% of tested workers had a hearing loss that affected their day-to-day activities. Hearing loss is an OSHA recordable injury.  Even short-term exposures can cause ringing in the ears, reduced productivity and stress.

Who Will Be Inspected?

OSHA has made a list of the NAICS codes from both general industry and construction that they have found commonly have noise hazards.  Data was gathered from a couple different sources.  First, they looked at inspections conducted between 2018 and 2020 where there were citations for noise.  They found the industries who had the most citations for these issues, and have sorted them from the most inspected group to the least inspected group.  OSHA also created the State Workers Compensation Data Profile.  This collected data of the NAICS groups that were reporting noise-related injuries and illnesses through workers compensation cases within that same time period.  These lists were combined to generate a master list of NAICS groups.

These are the NAICS groups that have been identified for the targeted inspections:

GENERAL INDUSTRY NAICS

2111:  Electric Power Generation, Transmission and Distribution
3119:  Other Food Manufacturing
3211:  Sawmills and Wood Preservation
3219:  Other Wood Product Manufacturing
3241:  Petroleum and Coal Products Manufacturing
3261:  Plastics Products Manufacturing
3315:  Foundries
3323:  Architectural and Structural Metals Manufacturing
3327:  Machine Shops; Turned Product; and Screw, Nut and Bolt Manufacturing
3328:  Coating, Engraving, Heat Treating and Allied Activities
3329:  Other Fabricated Metal Product Manufacturing
3364:  Aerospace Product and Parts Manufacturing
4239: Miscellaneous Durable Goods Merchant Wholesalers
4811:  Scheduled Air Transportation
4922:  Local Messengers and Local Delivery

CONSTRUCTION NAICS

2361:  Residential Building Construction
2362:  Nonresidential Building Construction
2372:  Land Subdivision
2373:  Highway, Street and Bridge Construction
2379:  Other Heavy and Civil Engineering Construction
2382:  Building Equipment Contractors
2383:  Building Finishing Contractors
2389:  Other Specialty Trade Contractors

Inspections – What Will OSHA Look For?

OSHA will start the inspection by reviewing programs and records, including your:

  • OSHA 300 logs for threshold hearing shifts and other health hazards
  • Noise sampling data, including past noise surveys that include sound level measurements
  • Exposure Monitoring Program
  • Hearing Conservation Program
  • Hearing conservation training records
  • Audiograms for the past 3 years
  • Records in conjunction with access to employee exposure and medical records (1910.1020)
  • Information on temporary workers so they can evaluate your program in relation to them
  • Information on PPE provided and whether it’s voluntary or required and where
  • Schematic diagram of your facility (for noise mapping) and departments where noise may be an issue
  • Union representatives will be questioned on noise and hearing conservation efforts

Inspectors Will Conduct Sampling

From there, OSHA will conduct a walk around to observe your processes and find opportunities for noise mapping.  They will take pictures of workers not wearing their hearing protection correctly, or those in noisy areas not wearing any protection at all.  They will also interview workers in areas where there are greater than 80 dba of noise found. 

Inspectors will conduct noise mapping with a sound meter and, depending on their findings, may need to conduct additional noise dosimetry on individual workers.  OSHA instructions for their inspectors advises inspectors to try to do noise dosimetry the very first day they’re there, and to get the dosimeters on the workers as soon as possible.  Only 6 or more hours are necessary to support a citation.  Thus, they may want to do dosimetry immediately to get as many hours of data as possible. However, guidance also suggests they do the dosimetry on your second shift workers if the inspection gets started later in the day. If they need additional sampling in other areas, they will come back for additional follow-up sampling for full shifts on other days.

Protect Your Company With Side-by-Side Sampling

As an employer, it’s advisable that you conduct side-by-side sampling of any noise sampling or dosimetry OSHA is conducting.  This means you would have someone conduct noise sampling alongside the inspector to assure that the samples collected are similar to what OSHA is collecting.  You can also choose to put a dosimeter on the same employees to duplicate and check noise dosimetry.  It’s your right as an employer to do this and may help in negotiations later if there are discrepancies between your results and those of OSHA’s.

iSi Can Help You Prepare and Get Your Program in Order

iSi can help you get your documentation in order in the event you are going to be inspected.  This includes:

  • Industrial hygiene audits and assessments to see where you stand with occupational health and exposure-related OSHA regulations
  • Conducting noise mapping and dosimetry so you have your required records on file
  • Developing Exposure Monitoring Programs
  • Reviewing OSHA logs for recordable hearing losses and helping you determine which hearing losses are recordable
  • Written Hearing Conservation Programs
  • Hearing conservation training
  • PPE evaluations
  • Side-by-side noise sampling during inspections
  • Safety professionals for to be onsite and assist during OSHA inspections

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What’s on OSHA’s To-Do List? OSHA Publishes Current Regulatory Agenda

What’s on OSHA’s To-Do List? OSHA Publishes Current Regulatory Agenda

Feb 25, 2022

OSHA’s regulatory agenda has been published with a list of priorities the agency is working on.  Twice a year the federal agencies publish their regulatory priorities.  These are typically listed by what stage each is currently in.  What is on OSHA’s regulatory agenda, and what changes and additions may you see coming up?

Final Rule Stage

These are the ones closest to being issued as a final rule.

Walking Working Surfaces
1910.28(b)(11)(ii), 1910.29(f)(1)

Feedback about provisions of the 2016 final rule being unclear led OSHA to work to update some formatting errors in Table D-2 and to revise language about the requirements for stair rail systems to make them clearer.

Procedures for Handling Retaliation Complaints Under Whistleblower Protection Statuses, Under the Anti-Money Laundering Act, and Under the Criminal Antitrust Anti-Retaliation Act
Multiple

These three are basically the same, laying groundwork for procedures on how to handle and investigate complaints and protect retaliation against whistleblowers.

Proposed Rule Stage

Improved Tracking of Workplace Injuries and Illnesses
1904.41

This proposed rule would require establishments already reporting OSHA 300As electronically to submit the OSHA 300 and 301 information electronically as well.  This was an original feature of the standard, but was removed in 2019.  Those who are required to report electronically are employers with 250 or more employees.

Hazcom Updates
1910.1200

The last Hazard Communication Standard incorporated the 3rd Edition of the Globally Harmonized System of Classification and Labeling of Chemicals (GHS).  GHS has been updated several times since 2012, and OSHA wants to update the standard to reflect the 7th Edition of GHS.

Amendments to the Crane and Derricks in Construction Standard
1926

  • Correct references to power line voltage for direct current (DC) voltages as well as alternating current (AC) voltages;
  • Broaden the exclusion for forklifts carrying loads under the forks from “winch or hook” to a “winch and boom”;
  • Clarify an exclusion for work activities by articulating cranes;
  • Provide 4 definitions inadvertently omitted in the final standard;
  • Replace “minimum approach distance” with “minimum clearance distance” throughout to remove ambiguity;
  • Clarify the use of demarcated boundaries for work near power lines;
  • Correct an error permitting body belts to be used as a personal fall arrest system rather than a personal fall restraint system;
  • Replace the verb “must” with “may” used in error in several provisions; correct an error in a caption on standard hand signals; and
  • Resolve an issue of “NRTL-approved” safety equipment (e.g., proximity alarms and insulating devices) that is required by the final standard, but is not yet available.

Occupational Exposure to Crystalline Silica in Construction
1926.1153(c)

OSHA wants to seek information on the effectiveness of the dust control measures currently included in Table 1.  They also want to find out if there are any other tasks or tools that would be effective to add to Table 1.  Employers who follow Table 1 correctly are not required to measure workers’ exposure to silica and are not subject to the permissible exposure limit (PEL).

 Welding in Construction Confined Spaces
1926.353

OSHA wants to amend the Welding and Cutting Standard to remove any ambiguity about the definition of a confined space.  The explanation portion of the 2015 Confined Spaces in Construction standard discusses how the welding standard and the confined spaces standard work together.  Although the confined spaces standard states that it encompasses welding activities, the welding standard does not expressly identify a definition of “confined space”.

PPE in Construction
1926.95

Clarification of requirements for the fit of PPE in construction.

Updates to Lockout/Tagout
1910.147

OSHA recognizes technological advancements in computer-based controls of hazardous energy conflict with the LOTO standard.  These controls are increasingly being used and there are consensus standards for their design.  Other countries are also accepting their use.  OSHA wants to look into harmonizing the current standard with those other countries.  There is a current RFI out which is seeking information to understand the strengths and limitations of these devices and their potential hazards to workers.

Powered Industrial Truck Design Standard Update
1910.178, 1926.602

OSHA is proposing to update the referenced ANSI standard from ANSI B56.1-1969 Safety Standard for Powered Industrial Trucks to also include the latest version of ANSI/ITSDF B56.1a-2018, Safety Standard for Low Lift and High Lift Trucks.

State Plans – Arizona and Massachusetts
1952

In the Arizona rule, OSHA is considering revoking Arizona’s State Plan because they didn’t issue an Emergency Temporary Standard for COVID within the 30 days OSHA gave them to adopt their own standard.  State Plans are required to issue regulations as strong as or stronger than federal OSHA.

Massachusetts is applying to have a State Plan applicable only to state and local government employees.

Specific Industries

Medical – Infectious Diseases
1910

This rule is meant to identify standards to protect workers in health care, emergency response, prisons, homeless shelters, drug treatment programs, medical examiners, labs, and other occupational settings where there’s a high risk of transmission of infectious diseases such as TB, MRSA, SARS, chickenpox, shingles and COVID.

Shipyard Fall Protection – Scaffolds, Ladders and Other Working Surfaces
1915.71-1915.77, subpart E

The current subpart E section of the standard is not comprehensive in its coverage of fall hazards in shipyards. OSHA issued a Request for Information and is considering updating existing standards and dividing the rulemaking into three subparts: subpart E, Stairways, Ladders and Other Access and Egress; subpart M, Fall Protection; and subpart N, Scaffolds.

Communication Tower Construction and Maintenance
1926 and 1910

Communication tower work has a high fatality rate and construction is expected to greatly increase.  OSHA has been collecting information and has determined current fall protection and personnel hoisting guidance may not adequately cover this work.  OSHA will be determining if a separate standard is needed, including covering structures that have telecommunications equipment on it or attached to them such as rooftops, buildings, water towers and billboards.

Tree Care
No Specific Reg Cited

There is no standard for tree care operations, which is a high hazard industry.  The tree care industry has petitioned to have a rule, and OSHA has collected information from affected small entities on what may be included in a potential standard.

Prerule Stage

Heat Illness Prevention in Outdoor and Indoor Work Settings
No Specific Reg Cited

This has gotten more publicity in the past few years.  In our blog in 2019 we wrote about a House bill that would require OSHA to develop a formal heat standard.  The effort and debate continues.  OSHA says that given the potentially broad scope of regulatory efforts to protect workers from heat hazards, as well as a number of technical issues and considerations with regulating this hazard (e.g., heat stress thresholds, heat acclimatization planning, exposure monitoring, medical monitoring), a Request for Information would allow them to begin a dialogue and engage with stakeholders to explore the potential for rulemaking on this topic.

Blood Lead Level for Medical Removal
1910.1025, 1926.62

OSHA is looking at reducing the trigger level for removing personnel from lead exposures.  Current levels require medical removal at 60 µg/dL in general industry, 50 µg/dL in construction and the return of employees to a former job status at below 40 µg/dL.  OSHA will be seeking public input on levels, identifying possible areas of the lead standard that need to be revised and how to improve worker protection where preventable lead exposures continue to occur.

Emergency Response
1910

Current OSHA standards don’t reflect the full range of hazards that emergency responders encounter nor the advancements in PPE, in technology, nor the major developments already being accepted by the emergency response community and consensus standards.  OSHA is considering updating these based on information gathered through a request for information and public meetings.

Process Safety Management and Prevention of Major Chemical Accidents
1910.119

OSHA has been looking at potentially modernizing the PSM standard and related standards since 2013.  Stakeholder meetings are next on the list.

Mechanical Power Presses Update
No Specific Reg Cited

The current OSHA standard is over 40 years old and does not address the use of hydraulic or pneumatic power presses or any other technological changes. OSHA previously published an Advanced Notice of Proposed Rulemaking on Mechanical Power Presses (June 2007) in which it identified several options for updating this standard.  It’s still on the list.

Prevention of Workplace Violence in Health Care and Social Assistance
No Specific Reg Cited

This has been on the list since 2017 and is related to impacts of workplace violence, prevention strategies and other information in health care and social assistance.  OSHA was petitioned for a standard preventing workplace violence in health care by a broad coalition of labor unions, and in a separate petition by the National Nurses United.  A small business study (like those conducted for specific industries) is next on the list.

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8 Key Details You Need to Know About OSHA’s Vaccination and Testing Standard

8 Key Details You Need to Know About OSHA’s Vaccination and Testing Standard

Nov 11, 2021

OSHA’s recently announced Emergency Temporary Standard (ETS) on vaccination and testing was issued on November 5, 2021, and within days it was stayed by 5th U.S. Circuit Court of Appeals. While the legality of the standard, aka 29 CFR 1910.501, remains in question, it would still be a good idea for your business to become familiar with the standard’s requirements, in the event it is allowed to continue.

Here are 8 key details of the standard you need to know:

1. 100 Employees Requirement

The ETS applies to companies with 100 or more employees. This counts 100 employees at the enterprise level, but only U.S. employees. The number is based on heads, not equivalent hours. The host employer does NOT count temporary worker hours (this goes on staffing agencies’ head counts). Determining head count starts at worker start dates of November 5, 2021 and later. If you reach 100 employees at any one time, your company will fall under the requirements throughout the life of the ETS (which is supposed to end on May 4, 2022).

2. Determining Vaccination Status

Employers must determine the vaccination status of every employee. Employers must also maintain current knowledge of the aggregate number of fully vaccinated employees and total number of employees at the workplace. If requested by OSHA or an employee, this information must be made available within 4 hours.

3. Testing

If you decide not to require vaccines for all employees, the standard allows unvaccinated employees to do weekly testing. Employers are not responsible for the costs of testing.

There is a hard 7-day limit in testing. That is, the employer must have a copy of a new COVID test result on 7th day. The employee cannot come to work on the 8th day without a test result.

Pool testing for weekly testing will be allowed. This means you can collect the same type of specimen from several people and conduct one antigen laboratory test on the combined pool of specimens (e.g., four samples may be tested together, using only the resources needed for a single test). If pooling procedures are used and a pooled test result comes back negative, then all the specimens can be presumed negative with the single test. If results come back positive, additional testing per employee to determine which one in the pool is the positive one would be required. Pool testing would reduce testing costs and results time.

4. Rules for the Unvaccinated

There is no more 6-foot distance rule when it comes to masking. All unvaccinated workers would be required to wear masks. They could only remove masks when they are alone in a closed room with the doors closed, when eating/drinking, when wearing a respirator, for identification purposes (security ID), when their job duties require seeing their mouth or when a face covering would present a serious injury or death. Unvaccinated workers who become close contacts would no longer have to be removed from the workplace.

5. Written Policy

Employers must have written policy in place that covers either mandatory vaccinations or a vaccination/testing option.

6. Training/Informing Workers About the ETS

Employers need to provide certain information to employees about the ETS and any method of information is acceptable as long as it includes the following information:

  • Information about the ETS
  • Employer policies/procedures
  • Vaccine information by providing the specific document “Key Things to Know About COVID-19 Vaccines”
  • Multiple sections of the OSH Act which protects against discrimination, reporting injuries/illnesses, retaliation, and about criminal penalties associated with knowingly supplying false information.

7. Recordkeeping

Vaccine and weekly testing records will be considered medical records which need to be maintained in a confidential manner. However, unlike other OSHA medical record requirements, vaccine and weekly testing records would only need to be maintained for the life of ETS.

8. Compliance Date

At the moment, the compliance date is December 6, 2021 for all provisions except weekly testing. The compliance date for weekly COVID testing is January 4, 2022.

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

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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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Recognize the Signs of Heat Illness

Recognize the Signs of Heat Illness

Jul 21, 2021

recognizing the signs of heat illness

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

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

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

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

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

Heat cramps bring pain or spasms to muscles.

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

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

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

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

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

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

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

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

 

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OSHA Heat Regulation

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

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drew lyon
drew lyon

Contributing:

Drew Lyon

Project Manager | Meteorologist

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

Email  |  LinkedIn

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EPA Watches TV Too – EPA Fines Renovation and Reality Shows

EPA Watches TV Too – EPA Fines Renovation and Reality Shows

Mar 26, 2021

As an EHS professional, have you ever found it hard to turn off the part of your brain that sees potential violations when you’re out and about, living your life away from the job?  Our industrial hygienists talk about seeing mold in restaurants and our safety professionals find bad staircases, exposed wires and more.  Have you ever been watching a TV show where you started wondering if they were following the rules like you have to every day?

Well EPA has been watching TV too, and has been handing out fines to some of your favorite reality shows.   

Clean Air Act Violation for Truck Show

The Discovery Channel’s Diesel Brothers reality show was fined for violations of the Clean Air Act.   The show takes diesel trucks and makes extreme modifications to them.  They have touted their trucks as “rolling coal.” 

The fine was related to trucks with non-existent or bypassed emissions systems.  

The show was exposed when a group called the Utah Physicians for a Healthy Environment purchased one of the trucks and sent it for emissions testing.  Testing found the truck was 36 times dirtier than a normal stock truck.  The physicians group filed a citizen enforcement action under the Clean Air Act, and a court case ensued.  The show was ordered to pay $761,451 to the federal government for the violation, $90,000 to the state of Utah, and the court costs for the Utah Physicians group, believed to be $1.2 million.

Home Renovation Shows in Trouble

Home renovation shows have been getting fines for violations of Toxic Substances Control Act’s (TSCA) Lead Renovation, Repair and Painting Rule (RRP Rule).

The RRP Rule pertains to firms performing renovation, repair and painting projects that disturb lead-based paint in homes, child care facilities and pre-schools built before 1978.  These companies need to be certified by EPA (or an EPA-authorized state), use certified renovators who have been trained by EPA-approved training providers, and follow lead-safe work practices.   This includes in-house maintenance staff and any outside contractors they use.

The companies responsible for producing the shows Fixer Upper, Bargain Mansions, Rehab Addict, and Texas Flip N Move have all gotten fined for violating this RRP Rule. 

Home Renovation Show Violations

Perhaps the most notable and highest fined of those listed is Chip and Joanna Gaines’ Magnolia Homes and the show Fixer Upper.  They were fined $40,000 and had to pay an additional $160,000 for lead abatement projects in high-risk homes in Waco, Texas.  This is because they violated the RRP Rule for renovations of 33 properties in the Waco area.  As another part of the settlement with EPA, they were required to implement an internal monitoring program.  They also produced a video about renovating lead-contaminated homes that was shown on their website and social media channels.  In Episode 16 of Season 5, they also featured testing an older home for lead and showed some precautions taken required by the rule.

Rehab Addict and Bargain Mansions were using unlicensed and untrained workers who were not following lead-safe practices.  These shows were fined a total of $59,000, and that includes several Kansas City-area subcontractors that Bargain Mansions used to help them.  Consequently, the violations included everyone involved.  The hosts of each show will be required to take steps to ensure compliance in the future.  They are also to educate the public about lead-based paint hazards and appropriate renovation through videos, social media postings and public events.

The most recent was Texas Flip N Move.  In addition to a fine, they have to do the same tasks as Fixer Upper did, plus use a third-party entity to conduct  lead abatement in low-income target-housing residences or child-occupied facilities within the Dallas-Fort Worth metroplex. 

Home Depot Fined for RRP Too

On the topic of RRP, just in December (2020), Home Depot, often a major sponsor for renovation shows, negotiated a nationwide settlement with EPA on violations of the RRP Rule.  Home Depot uses outside contractors to conduct home improvement work as an add-on service for its local stores.   EPA found hundreds of cases where Home Depot was sending uncertified firms to conduct renovations that fell under the certified firms and trained workers requirements.  Home Depot wasn’t keeping compliance documentation of certifications, training or use of lead-safe work practices. Contractors also weren’t passing out the required lead pamphlets to occupants. 

The fine was $20.75 million, plus an additional $750,000 to Utah, $732,000 to Massachusetts and $50,000 to Rhode Island.   Home Depot is required to implement a comprehensive, corporate-wide program to ensure its contractors are properly licensed, trained and certified to use lead-safe work practices.  Where the most serious violations occurred, they’re offering those customers testing by a certified inspector and then additional specialized lead cleaning if something is found. 

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

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

Jan 15, 2021

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

OSHA fines

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

The Violation Categories

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

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

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

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

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

Calculating Violation Amounts

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

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

Gravity Based Penalty Amounts

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

Severity + Probability = Gravity Based Penalty Amount

Here are the Gravity Based Penalty Amounts for 2021:

Gravity-based penalties for OSHA 2021


History Reductions

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

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

Good Faith Reductions

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

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

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

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

Business Size Reductions

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

Quick Fix Reductions

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

Limits of Discounts

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

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

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

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

Other Penalties

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

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

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

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

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

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

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

Jul 30, 2020

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

Guardhat

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

Some of the features include:

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

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

PIMMAP Contactless Temperature Solution

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

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

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

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

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

Tami Hadley
Tami Hadley

Contributing:

Tami Hadley

Marketing Director | Project Manager, E-Training Solutions

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

Email  |  LinkedIn

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Industrial Hygiene in Construction: Focus Four Health Hazards

Industrial Hygiene in Construction: Focus Four Health Hazards

Jul 9, 2020

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

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

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

  1. Manual Material Handling
  2. Noise
  3. Air Contaminants
  4. High Temperatures


Manual Material Handling

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

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


Noise

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

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

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


Air Contaminants

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

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

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

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

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

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


High Temperatures

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

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

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

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


In Closing

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

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

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

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Tami Hadley
Tami Hadley

Contributing:

Tami Hadley

Marketing Director | Project Manager, E-Training Solutions

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

Email  |  LinkedIn

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COVID Complaints: Will You Be Inspected by OSHA?

COVID Complaints: Will You Be Inspected by OSHA?

May 15, 2020

​Updated 5/22/2020

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

Employee Complaints

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

OSHA Puts Employers in One of 3 Risk Groups

High Risk

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

Medium Risk

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

Low Risk

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

Inspections 

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

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

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

What to Expect in an Investigation Letter

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

  • Investigate the complaint

  • Determine results and respond by a certain date

  • Provide backup documentation of your investigation

  • Provide corrective actions taken or to be taken

  • Provide backup documentation of corrective action

  • Post the letter

  • Sign a certificate that you posted the letter

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

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

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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!

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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

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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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