Back to Work Safety

Back to Work Safety

Jan 2, 2025

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

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

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

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

Seasonal Distractions

Dec 6, 2024

The holidays are a busy time for most of us and with that comes a lot of distraction, stress, fatigue and loss of focus. These are all things that can negatively affect our safety.

Holiday Distractions:

It’s important to be aware that these conditions may be occurring not only with ourselves, but with our co-workers:
• Pressures to finish projects by the end of the year or before a vacation/shut down;
• Stress from the financial impact the holidays can have on some of us;
• Stress from feeling there’s not enough time to “get it all done”;
• Rushing to get things accomplished so we can go home;
• Family commitments, evening events, parties to attend or get ready for;
• The effects of working longer hours for overtime pay or to accomplish tasks (stress, lack of sleep); and,
• And sometimes the holidays are a very hard and depressing time for some, so there are co-workers dealing with emotional stress generated by the season.

All of these can cause us to lose focus and overlook hazards we may normally catch.

How to Better Cope With Them:

• Be mindful that this is a time that all of us can lose focus, so if you find your mind wandering, stop and refocus on your task. Be on the lookout for your co-workers and help each other stay on task. When we lose focus is when safety hazards are missed and accidents occur.
• Don’t rush or cut corners, this can lead to mistakes and the need to redo work which will cause you twice the time and effort.
• When moving from task to task, take 4 seconds to stop and survey the hazards around you
• Plan, plan, plan! If you come up with a plan and/or a schedule to get your personal and work tasks accomplished (and the sooner you do it) the less likely you’ll be as stressed about what needs to be done.
• Prioritize both at work and at home. What has to be done, and what can wait until after the holidays? What can you take off your list? And then, what can you scale back on at home? Some people want the holidays to be perfect, but do they really need to be perfect? Sometimes taking one more thing off your list will make a big difference in reducing stress.
• Make sure you’re eating right. You need to feed that engine that’s needed to keep you going to get your stuff done.
• Stick to the same sleep schedule and make sure you’re getting enough sleep. Lack of sleep will cause you to be less focused and more stressed.
• Take it easy on the alcohol.
• Be extra mindful for housekeeping. Sometimes visual clutter can cause mental clutter. Plus ensuring proper housekeeping will also remove hazards that could cause issues if you or your coworkers are not paying close attention.
• The holidays can be a sad and depressing time for some, so be on the lookout for your coworkers. If you are the one feeling depressed, seek a counselor to help or talk to someone about it. If you see a colleague having struggles, let their supervisor know and be there for each other.
• Don’t forget to breathe! Take deep breaths to calm and refocus. Take slow, deep breaths. Inhale, count to 3 slowly and gradually exhale. Do this for 4-5 repetitions to help you feel more relaxed.

 

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Compressed Air Safety

Compressed Air Safety

Aug 7, 2024

Compressed air is used in a multitude of applications in industry — pneumatic tools and equipment, pumps, valves, tires, robotic arms, conveyors, packaging machines, some welding operations, metal cutting, surface preparation, breathing air, natural gas extraction, ventilation systems, pipeline inspection, aeration, agitation, and more. You may think because “it’s just air”, that compressed air is harmless. It’s actually the opposite.

Why Do Safety Policies Tell You to Never Use Compressed Air to Blow Down Your Clothes?

Never use air to clean your clothes, never blow compressed air on yourself, and never blow compressed air at someone else. When compressed air hits your skin, the air can be forced into your tissues through the skin and cause an air bubble in your blood stream. This air bubble can be fatal if it reaches the very small blood vessels of your heart, lungs or brain. Your clothes are not strong enough to protect you. Air blown in your mouth at only 5 psi can rupture your esophagus or lungs.

PPE

• Always wear eye protection when using compressed air. Besides the fact that it only takes 12 psi to blow your eye out of its socket, flying particles can damage your eyes. Wear safety glasses with side shields or a face shield.
• Air compressors, impact tools and other compressed air equipment can be loud and damaging to your hearing. Wear ear protection while using.
• Gloves and safety boots are preferred.

Hoses

• Make sure your hoses are rated to meet the maximum operating pressure of the equipment.
• Keep hoses off the floor/ground where they can trip someone or become damaged by moving equipment, doors or dropped items. If they’re on a self-retracting reel, keep them reeled when not in use. If you don’t have a reel, keep them coiled (without kinks) and hang it over a broad support—not a hook or nail.
• Keep sharp objects away at a distance so they won’t rub on the hose. Don’t wedge hoses in corners or hang them around machines.
• If a hose gets stuck, don’t pull/yank on it until it becomes free. Go to the point where it’s stuck and guide it.
• Inspect hoses on a regular basis for weak points, cuts, frayed covers and other damage. Replace when needed. Weak points of the hose may swell up like a balloon and burst or thrash about dangerously. Before using, make sure connections are properly sealed and there isn’t damage to fittings or the hose itself.
• If a hose bursts and starts to thrash, get out of the way of it and shut off the air supply at its source.

Other

• OSHA’s limit for compressed gasses is 30 psi. Nozzles with relief holes on the tip are often used as a way to comply with the standard and to prevent over pressure if the nozzle were to become dead ended. Never remove the tip off the nozzle or use damaged nozzles where the tip isn’t maintaining the proper opening. This is one of the main inspection items we find regarding compressed air in audits.
• Never used a compressed-air tool or piece of equipment without the proper training, knowledge of the limitations of the equipment, and where the air supply shutoff is located. Air shutoffs should be located as near as possible to the point of operation.
• Besides the hoses, inspect other components of your compressed air systems on a regular basis. This may include air receiver tanks, distribution lines, pressure regulation devices and compressors.
• Only use qualified personnel to conduct maintenance on compressed air devices.
• When conducting maintenance, ensure lockout/tagout procedures are used.
• Unless a pneumatic tool has a quick disconnect plug, before it’s disconnected turn off the air supply and bleed the tool of air

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Supreme Court’s Overruling of Chevron Deference Will Change How Regulations are Written and Interpreted

Supreme Court’s Overruling of Chevron Deference Will Change How Regulations are Written and Interpreted

Jul 19, 2024

On June 28, in the Supreme Court case Loper Bright Enterprises v. Raimondo, a doctrine established in 1984 called the “Chevron deference” was overturned and will no longer be used when it comes to courts interpreting the meanings of regulations when there are ambiguities with them.  

The Chevron deference, named for Chevron USA, Inc. v. Natural Resources Defense Council, Inc. said that when there are ambiguities in an agency’s regulation, courts must defer to the agency to determine what’s meant by the regulation for that particular item being challenged.  With this ruling, courts will now have to independently interpret the regulation and determine what the best meaning of Congress was for that regulation.  Courts will get to use multiple sources to determine what the regulation means, not just what the agency who enforces it says it means.

The Reasoning for the Overturn

The court found the Chevron deference was inconsistent with the Administrative Procedures Act (APA).  This is the federal rule for how a regulation is written, how it’s entered into law, and how courts are to review actions by those agencies.  Chief Justice John Roberts wrote that the APA directs courts to “decide legal questions by applying their own judgment” and “makes clear that agency interpretations of statutes — like agency interpretations of the Constitution — are not entitled to deference.”  He also said the Chevron deference “allows agencies to change course even when Congress has given them no power to do so.” 

Justice Clarence Thomas also pointed out that the Chevron deference not only was inconsistent with the APA, but it also was inconsistent with the Constitution’s division of power.  This ruling keeps the power for interpretation in the hands of the Judicial Branch rather than deferring and giving the executive branch powers not given to it.

Justice Neil Gorsuch wrote, “all today’s decision means is that, going forward, federal courts will do exactly as this Court has since 2016, exactly as it did before the mid-1980s, and exactly as it had done since the founding: resolve cases and controversies without any systemic bias in the government’s favor.”

Going Forward

The ruling also pointed out that just because a case used Chevron deference in the past, that wasn’t going to be a special justification to use for overturning it.  The Chevron deference has been used 18,000 times.  However, it’s predicted most regulations, especially those with long standing, will remain intact unless challenged for a different reason. 

However, we’ll likely see much more dramatic changes in how new regulations are written. 

Congress will retain the ability to delegate authority to federal agencies but will now need to clearly define the scope of that authority and give explicit directions in new regulations.  Broad, vague grants of authority will not be in the agency’s favor going forward.  We’re likely to see more clear and detailed statutory language.  We may also find that agencies start updating existing regulations to shore up the language in them.  Justifications will need to be clearer and need to give both their purpose AND their statutory basis.

In the Immediate Future

As a result of this case, we anticipate agencies may want to flex their authority by trying to assert current regulations.  Because current regulations need to be challenged for something other than the Chevron deference, it may be harder to challenge current regs.  

Another scenario is that agencies may also want to purposely try to get their regulations challenged just so that they know where they stand legally. As a result, we may see more inspections.  

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Summer Safety

Summer Safety

Jun 28, 2024

We talk about the holiday season being a big time of distraction when one is focused on a bunch of other things where safety may not always be top of mind. However, the summer can be a big distraction too.  There’s a lot of things that we do in our non-work lives during the summer that can get us hurt and affect our job.  Besides being outside in the nicer weather and longer daylight in the evenings, there are other day and evening functions, weekend outings, and family vacations.  There’s additional outside work to be done such as yardwork, grilling or playing outside in the weather. The following are areas of summer safety you need to be on the lookout for.

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Grilling

Grill outside, away from structures. Make sure your grill is stable on a flat surface so that it can’t be tipped over. Keep the grill clean and wait for it to cool before you clean it. Check for propane leaks on your gas grill, and if you’re using charcoal, wait for the coals to completely cool before you dispose of them. Always dispose coals into a metal container. If the flame goes out on your grill, turn off the grill AND turn off the gas, then wait 5 min. before relighting. If you use a charcoal grill, only use charcoal starter fluid. If the fire starts to go out, don’t add any starter fluid or any other flammable liquids to the fire.

Mowing and Weed Trimming

On riding mowers, put the mower into neutral before startup and shutdown and make sure the transmission is out of gear and the mower blade clutch is disengaged before startup. Disengage the blade when you’re riding over pavement, sidewalks, and gravel. Keep the mower in gear and slow down when working on slopes and avoid mowing on slopes of angles of more than 15 degrees. Remove the key when not using the mower. Stay 5 ft. away from ditches, embankments, retaining walls, culverts or similar where you could roll over. Never remove roll over protection devices. If mowing near bodies of water, establish a safety zone to make sure you stay at a safe distance.

For walk-behind mowers, rotary blades underneath the mower can rotate at 200 mph. Keep your hands and feet away from the blade area when it’s running. Never remove installed safety guards such as directional flaps or shielded discharge outlets or bypass safety shut down devices such as clutch handles or switches that stop the blade as soon as you let go. Mow back and forth along the side of a steep hill, never up and down the slope.

Did you know that 1/3 of emergency room injuries from weed trimmers are eye-related, so wear your safety glasses. Bring the engine to speed before cutting. Cut away from yourself and when not cutting, run the engine at idle speed. Some types of trimmers may let out more string than you think and cause it to strike you unexpectedly so monitor string length. Before refueling a gas-powered trimmer, place it on the ground and allow the engine to cool. Keep people and pets at least 60 ft. away and stop if you’re approached. Use both hands when operating.

Before servicing your mower or your trimmer, always unplug an electric tool or shut down a gas-powered machine/tool before servicing, cleaning, inspecting, or adjusting it. Use the proper fuel and oil  and be careful when always refuel when the engine is cool.  Don’t service a gas-powered engine inside a storage shed as you could be overcome by carbon monoxide. Turn the power off and disconnect spark plug wires before cleaning, inspecting, and servicing and never touch the spark plug with your hand or a tool when the mower is operating.

Poison Ivy, Oak and Sumac

Get familiar with the difference between these plants and how to spot them.  Remember, leaves of three, let them be! For rashes use a cold compress, calamine lotion, non-prescription hydrocortisone cream, or an antihistamine to ease itching.  You can also use other non-traditional treatments such as wrap dipped in apple cider vinegar.  Call your doctor if the rash is near your eyes or covers a large part of your body.

Bees, Wasps, Spiders, Ants, Ticks, etc.

Before performing work in an area, take a site survey to look for any hazards including bees and wasps. Avoid attracting them by wearing light colored clothes and avoid perfumes or cologne.  Do not swat and wave wildly when they approach, instead use a gentle pushing or brushing motion to deter them.  Wear long sleeves and pants and be cautious about walking in high grass or brush, a good hangout for ticks.   Watch where you walk, stand and sit.  Fire ants like to mound under tall grass and brush.  Before picking something up, kick it before you pick it.

Bicycles and Scooters

Make sure you wear helmets and use other safety gear when riding such as high visibility or reflective clothing, shoes (not flip flops or sandals).  Make sure your bikes don’t have broken reflectors and make sure the light works.  Check tires for air and bring extra safety equipment such as a first aid kit and extra tires  if you’re going to do trail riding .  Make sure your wheels, seat and handlebars are tight and that your brakes work.

Swimming

Never swim alone, and always supervise children. Open water prevents a number of different hazards that pools don’t. These include limited visibility, depth changes, uneven surfaces, unknown objects that can be stepped on, and currents and undertow. Enter the water feet first to prevent head injury. This includes using water slides. Never dive into water that’s less than 8 ft. deep. Be on the lookout for maintenance issues around the swim area. Be alert of wet floors, sharp edges, broken glass, exposed bolts, broken ladders, broken railings and clear markings of water depth. If you find yourself struggling or accidentally fall in, float to live. Try not to panic as calmness will save you. Lean back and use your arms and legs to keep you afloat with gentle movements. Once you’re calm your breathing is controlled, then call for help or swim to safety. Don’t let your dog swim without supervision. While many dogs know how to swim, some can easily tire out.

Pulling Trailers

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.  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.  Check your tires on both the vehicle and the trailer and make sure your lights work before you leave.  Take spare bulbs and fuses with you.  Check your brakes and make sure the breakaway cable is properly attached to your tow vehicle.  Carry spare parts such as at least one trailer spare tire as well as extra wheel bearings and hubs.

Camping

Make your camp before dark and learn the terrain while it’s still light. Give yourself 2 hours of daylight for setup. Take a good flashlight, check your equipment that it’s in good working order before you leave and pack emergency signaling devices, emergency supplies and a first aid kit. Think about your footing and be alert to slippery areas. Watch for low hanging branches and take extra caution near cliffs, outcroppings, hills, and water edges. No matter how clear a stream looks, it’s likely to contain waterborne parasites & microorganisms, so pack your own water. Make sure your fires are always attended, cannot be spread laterally or vertically (used a grill or stone surface) and drown it with water to put it out. Embers buried deep in the pile can reignite later. Be cautious when using a propane stove. Tents should be flame retardant and far enough away from the campfire. Wear sunscreen, hats, sunglasses and drink plenty of water. Pack carbohydrate-energy bars, granola candy or fruit for instant energy on your hikes.

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Severe Weather — Tornadoes

Severe Weather — Tornadoes

May 10, 2024

Tornadoes are violent storms that don’t only strike in the traditional “Tornado Alley” region of the U.S. The southeastern part of the U.S. is starting to experience many more tornadoes over the past few years. Tornadoes can strike anywhere, including places like California, Arizona, Michigan, Pennsylvania, Virginia and New York.

Watch vs. Warning vs. Emergency

A Tornado Watch will be issued when conditions are favorable for severe thunderstorms to become tornadoes and thus you should stay alert and be prepared for changing conditions. A Tornado Warning means a tornado has been sighted or there’s a strong indication that one may develop at any time within the warning box area. A Tornado Emergency is the highest and rarest of warnings. A Tornado
Emergency means a tornado is in progress and will have significant impact to human life with catastrophic destruction to property.

What to Do

It’s critical you have a plan and that everyone knows what the plan is, whether it be at work or at home. What is the plan at work? What is the plan at home? Do your children know what to do if they are home alone? Make sure all of your communication devices are charged before the action is scheduled to begin in your area.

If you’re outside, get inside. It’s not time for photo shoots. There will be plenty others, including chasers, who will get that footage for you. Put on sturdy shoes and take blankets, helmets, and whatever else you can find to protect your head. Put as many barriers between you and the windows and the potential of flying debris as you can.

At Home

Head to the lowest floor. Being completely underground is best, but if that’s not possible, get to the lowest floor and towards the middle of the building. Smaller rooms are good. Stay away from doors, windows which may shatter, and outside walls which may collapse on you. Bathrooms that don’t have windows or outside walls are good because they are typically small and the plumbing adds some structural strength to the room. You can also choose to go under staircases, into closets (shut the door and cover up) and in hallways if you close the doors. In apartments, ground level clubhouses and laundry rooms often provide a good place to go if you live on upper floors. If you live in a mobile home, evacuate! Mobile homes can not stand up to even the smallest EF-1 tornado. It will get rolled over. For this reason, mobile home owners need to be extra vigilant of watches, and have a definite tornado plan ready to execute when needed.

Public Places

If you’re away from home, what do you do? In hotels and motels, review posted safety instructions along with fire exits when you check in. Hallways may be in the hotel’s plan for where to go in case of tornadoes, but make sure they don’t have doors and windows on either end. This makes them a wind tunnel for debris to fly through. Interior bathrooms and closets may be a better option.
In other public places like malls, stores, gas stations, and restaurants, stay inside and put as many walls between you and the outside as possible. Get to the lowest floor, get down and cover up with whatever you have to protect your head and body from flying debris. Don’t leave in your car! Sturdy buildings will protect you better.

Outdoor Activities—Campgrounds, Festivals, RV Parks, Sporting Events

Event planners should convey the plan for taking cover. This makes it all the more important for you to be weather aware! Before checking into an RV Park or campground, learn if there are storm shelters available and where they are located.

On the Road

Vehicles are amongst the last places you want to be in a tornado, so it’s critical you pay attention to weather conditions. If you can delay your trip, do so, but if not, make sure you monitor local radio stations or NOAA weather radio broadcasts, and know ahead of time where you are located. Weather warnings are issued by county, so know which counties you will be in. There are hundreds of weather apps that will track your location and send you alerts and notifications when you are in a watch or warning, even letting you know when lightning or heavy rain is near your area. The chances of being swept up in a tornado are much less than being affected by all the other severe weather that comes with them. Severe thunderstorms can produce large and damaging hail to break your windows, straight line winds that could topple you, and heavy rain to cause flash flooding which may sweep you off the road.

Stop and find a building to seek shelter in. If you’re stuck in traffic, you may need to seek shelter in a ditch, ravine or culvert as the last resort. Despite that very popular video which showed the TV reporter and the family who parked under an overpass and hid up under its girders as the tornado passed over, don’t ever do that! Powerful winds will kick up dangerous debris and send it flying up underneath the bridge like a wind tunnel.

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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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The One Where You Must Post the Whole Standard

The One Where You Must Post the Whole Standard

Oct 13, 2023

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

A Unique Requirement

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

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

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

Updates to the Rule

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

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

Citations

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

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

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

Where Do You Stand on Noise?

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

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

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

Sep 22, 2023

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

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

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

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

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

The Similarities

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

Notifying Employees of the Hazards of Asbestos

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

Signage/Labels

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

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

Exposure Limits and Medical Surveillance

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

Training

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

The Differences

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

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

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

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

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

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

Questions?

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

 

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OSHA’s Heat-Related Hazards National Emphasis Program

OSHA’s Heat-Related Hazards National Emphasis Program

Jun 16, 2023

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

What’s an NEP?

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

OSHA’s Heat Hazard NEP

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

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

Which Companies Are Affected?

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

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

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

What Triggers an Inspection for this NEP?

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

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

What Will Inspectors Look For?

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

Which Standards Will Get Cited?

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

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

A New Standard on the Horizon

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

What’s in a Heat Illness Prevention Program?

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

Need Assistance?

iSi can help you with your heat-related programs, training, PPE evaluations and worker exposure monitoring.  Contact us today!

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What the Haz?

What the Haz?

May 19, 2023

A Deeper Dive Into the “Haz” Words in OSHA, EPA and DOT and Where They Can Crossover

Every once in a while, we will get a call from someone looking for “Hazmat” training.   To you, the word hazmat may mean one thing, but we guarantee to someone else it probably means something completely different.

iSi’s mission is to help companies navigate compliance with EPA, OSHA and DOT regulations.  Once you start familiarizing yourself with those regulations, you will find that the definition of hazmat can be different for different agencies and different situations.   You will also see that there are a number of words that include “haz” that can creep into the picture and be used interchangeably.  An even deeper dive will show that each agency will either make up their own definition or borrow from one another.

Each Agency Has Its Own Focus

Regulations and their definitions are typically written in the perspective of the focus of the agency.  Each agency has its own role to play in the workplace and how they use their haz words will often be reflective of that.

  • OSHA – OSHA’s focus is safe and healthful working conditions for workers
  • EPA – EPA’s focus is on human health and the condition of the environment
  • DOT – DOT’s focus is on the safe, efficient, sustainable and equitable movement of people and goods

Once you know the perspective for each, that will help you be able to better understand regulations when they crossover or refer to one another.

Hazmat

Hazmat is a shortened version of “hazardous materials.”  Each agency refers to hazardous materials a little differently.

In OSHA, the term hazmat can refer to hazardous materials or hazmat teams.  OSHA says a hazardous material is something that can be a health hazard or a physical hazard.  However, a hazmat team is an organized group of employees who perform work to handle and control spills or leaks of hazardous substances.  Individually trained members of the hazmat team are called hazardous materials technicians.  Later we’ll look at the OSHA HAZWOPER standard where many of these definitions are found.

To DOT, hazmat means “a substance or material capable of posing an unreasonable risk to health, safety, and property when transported in commerce…”  It also can include hazardous substances, hazardous wastes, marine pollutants, elevated temperature materials, materials listed in the Hazardous Materials Table, and materials meeting their criteria for hazard classes and divisions. The term Hazmat employee in the regulations are those persons who package or prepare, physically transport, load, unload, design or makes packages for, fills out paperwork for or ensures the safe transportation of hazardous materials.

To EPA, a hazardous material is any item or chemical which can cause harm to people, plants, or animals when released by spilling, leaking, pumping, pouring, emitting, emptying, discharging, injecting, escaping, leaching, dumping or disposing into the environment.

From the definitions, you can see that OSHA was focused on people, DOT was focused on transportation and EPA was focused on the environment.

HazCom

Another shortened haz word is HazCom.  This is short for the OSHA Hazard Communication Standard.  This standard is all about hazardous chemicals, that is, any chemicals that are a physical or health hazard. The HazCom Standard deals with Safety Data Sheets (SDS), labeling, markings, training and more.

EPA’s Emergency Planning and Community Right to Know Act, or EPCRA, regulations refer to OSHA’s hazardous chemicals when it comes to which chemicals apply to the EPCRA regulation.  Those which fall under the HazCom standard and have SDSs associated with them are included in EPCRA reporting requirements.  Some companies also refer to HazCom training by the term Employee Right to Know training.

Hazardous Waste

Another haz is hazardous waste. The term hazardous waste comes from EPA’s Resource Conservation and Recovery Act (RCRA) hazardous waste regulations.  There’s a lengthy determination process one must go through to even determine if something can be defined to be a hazardous waste.  You’ll see all of those criteria and the roadmap in the definition of hazardous waste at 40 CFR 261.2.

EPA’s website says, “Simply defined, a hazardous waste is a waste with properties that make it dangerous or capable of having a harmful effect on human health or the environment. Hazardous waste is generated from many sources, ranging from industrial manufacturing process wastes to batteries and may come in many forms, including liquids, solids gases, and sludges.”

Hazardous waste must be discarded and must be a solid waste.  To be a solid waste, it must be a material that has been abandoned, recycled, is inherently waste-like or is a military munition.

Once you determine that it’s discarded and a solid waste, there are another set of questions to ask to make the determination if a waste is hazardous or not.  This process is quite important and is required to be completed and documented for each of your wastes.

OSHA mentions hazardous waste in their HAZWOPER standard, calling hazardous waste anything that’s found to be a hazardous waste by the EPA definition or anything that DOT calls a hazardous waste in their definition.

In DOT regulations, DOT says hazardous waste is defined under EPA’s definition and that to ship hazardous waste a hazardous waste manifest is required.  Hazardous waste is a hazardous material that is regulated for transportation. So when a vendor comes to pick up your hazardous waste, your company is the one technically shipping it and are therefore subject to all of the DOT hazmat regulations the same as if you were shipping any other hazardous material.

Hazardous Substances

All 3 agencies use the term hazardous substance.

In EPA, a hazardous substance is “Any substance, other than oil, which, when discharged in any quantities into waters of the U.S., presents an imminent and substantial danger to the public health or welfare, including but not limited to fish, shellfish, wildlife, shorelines and beaches (Section 311 of the Clean Water Act); identified by EPA as the pollutants listed under 40 CFR Part 116.”  Hazardous substances are referred to in the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA, aka Superfund), the Clean Water Act (CWA), the Clean Air Act (CAA), the RCRA hazardous waste regulations, and the Toxic Substances Control Act (TSCA).

OSHA makes it easy.  They say a hazardous substance is whatever EPA CERCLA says it is, whatever DOT says are hazardous materials, whatever EPA says a hazardous waste is, or any other biological or disease-causing agent that could lead to things like death, disease, behavioral abnormalities, cancer, genetic mutation, physiological malfunctions or physical deformations in such persons or their offspring.

DOT says a hazardous substance is a hazardous material when that material is listed in their Appendix A and when its single package exceeds the reportable quantity listed in the Appendix. They also have other considerations if it’s a mixture or solution or a radionuclide.

HAZWOPER

And finally, there’s HAZWOPER.  Although it’s one of our more popularly discussed haz words, we left this for the end because this regulation actually uses all of the haz words in one place and seems to be one standard that incorporates so many different requirements from all 3 agencies within it.

HAZWOPER stands for Hazardous Waste Operations and Emergency Response.  HAZWOPER is found in the 1910 General Industry Standards under Subpart H, Hazardous Materials.  An identical copy can be found under a different subpart in the 1926 Construction Standards.

There are 3 main pieces or goals to HAZWOPER:

  1. Rules for conducting cleanup operations at sites determined to be EPA RCRA hazardous waste cleanup sites, cleanup operations at sites contaminated by hazardous substances on uncontrolled hazardous waste sites that EPA or another government agency have required to be cleaned up, or conducting voluntary cleanups at those same types of uncontrolled waste sites;
  2. Operations at treatment, storage and disposal facilities (TSD) regulated by EPA RCRA; and,
  3. Emergency response to releases of hazardous substances at any facility, any location.

Being an OSHA regulation, HAZWOPER is all about protecting the worker and the public during the cleanup, so all the guidance centers around preparing for and safely cleaning up hazardous substances.

The regulation mentions the term Hazmat teams in relation to those responding to the emergency responses found in part 3 of the standard.

HAZWOPER says any materials cleaned up and containerized into drums must meet appropriate regulatory requirements for DOT transportation, RCRA hazardous waste and OSHA safety regulations.  Waste must be transported per DOT regulations while self-contained breathing apparatuses used by workers to protect themselves during work are to comply with DOT standards.

The DOT’s Emergency Response Guidebook is mentioned and often consulted for emergency response information and guidance.

If a company has prepared a contingency plan per EPA requirements and that plan includes emergency response information, the company can use that contingency plan as part of its emergency response plan so that efforts are not duplicated.

On the EPA side, because OSHA regulations don’t apply to local and state governments, EPA has adopted the HAZWOPER standard into 40 CFR 311 to apply to those local and state governments and any of those not covered by a state OSHA-approved plan.

Also in EPA, emergency spills trigger a whole host of reporting requirements as well as emergency response plans and training to protect the environment from hazardous waste spills, oil spills, pipeline leaks and chemical releases to water, air or land.

Conclusion

This is not an exhaustive list of haz references or examples where all 3 agencies cross over, but hopefully it gave you an idea of how these terms and the rules related to them can be so different in some cases, but so intertwined in others.  The haz words used can differ depending on the situation.

So, if you call us asking for hazmat training, you’re likely to get a lot of questions from us about your end goal.

What haz words have you come across?  What examples did we miss?  We’ll be posting this on our Facebook, LinkedIn, Twitter and Instagram pages.  We’d love to hear from you!  

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CSB Issues Safety Alert Regarding Emergency Pressure Relief Systems

CSB Issues Safety Alert Regarding Emergency Pressure Relief Systems

Apr 21, 2023

The Chemical Safety Board (CSB) has issued a safety alert regarding emergency pressure relief systems as the agency is continuing to see them playing their part in major chemical incidents.

Who is the CSB?

The CSB is an independent federal agency who investigates the root causes of chemical incidents at industrial sites such as chemical plants, refineries, and manufacturing facilities.  They are not a regulatory agency, but their teams of investigators make recommendations to OSHA and EPA, industry groups and the facilities they investigate.

In addition to investigation reports and root cause analyses, CSB issues safety videos on both their website and YouTube that summarize the important findings from their investigations in order to help prevent similar accidents from reoccurring.

Emergency Pressure Relief System Issues

In its investigations, CSB is continuing to find issues with the safety of emergency pressure relief systems.  In several of their investigations these systems were found to be discharging toxic or flammable materials to areas which were not safe for workers or the public.

Emergency pressure relief systems are devices installed on storage tanks, silos, vessels and processing plant equipment to help relieve the excessive pressure caused by fire, process failure, equipment failure or some other change in condition. The pressure relief device is supposed to prevent the equipment it’s installed on from rupturing or exploding.

One of the most well-known accidents involving an emergency pressure relief system was the Union Carbide disaster in Bhopal, India in the 1980s.  A runaway reaction generated high pressure conditions in a storage tank and a methyl isocyanate cloud escaped from the pressure relief system, killing 3,800 people, and injuring or creating long-term illnesses for tens of thousands.

Three Key CSB Suggestions

CSB recommends that rather than discharge into the air or back into the plant, emergency relief systems should discharge to a flare or a scrubber system.

CSB offers three key lessons from its findings:

  1. Follow Existing Good Practice Guidance

Use API 521, Pressure-relieving and Depressuring Systems as a standard guidance. CSB says this document “…addresses many concerns about releasing flammable vapors directly into the atmosphere and generally requires using inherently safer alternatives for toxic release scenarios or when the potential exists for a flammable vapor cloud.”

CSB also recommends documents published by the Center for Chemical Process Safety (CCPS) called Guidelines for Pressure-relief and Effluent Handling Systems and Safe Design and Operation of Process Vents and Emission Control Systems as well as viewing American Institute of Chemical Engineers (AIChE) presentations and courses on Venting and Emergency Relief.

  1. Evaluate Whether the Atmosphere is the Appropriate Discharge Location or if There May Be Safer Alternatives

CSB typically recommends flaring is safer than atmospheric vent stacks when venting flammable vapor into the atmosphere.  Something like flammable hydrocarbons can cause a fire or a vapor cloud explosion when they are vented into the atmosphere.  CSB recognizes flaring is safer, but does allow for venting into the atmosphere in special cases, especially when that venting will not put workers or the public at risk.

  1. Ensure Hazardous Chemicals Vented Into the Atmosphere Discharge to a Safe Location

Where are the discharge points on your emergency pressure relief systems?  Are they at areas where they can harm workers within its proximity at ground level or on walkways or platforms?   Are they near building intakes?  If your company is subject to Process Safety Management (PSM) requirements, CSB says the required periodic reviews would be a good time to evaluate these issues as well as other audits or incident investigations.

Read the Report

Find CSB’s report, along with four case studies and their resulting recommendations at https://www.csb.gov/assets/1/6/csb_eprs_alert.pdf.

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

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

Mar 31, 2023

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

Instance-by-Instance Citations

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

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

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

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

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

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

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

Grouping Penalties

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

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

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

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

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

OSHA Fines Increased

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

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Process Safety Management (PSM) Compliance Audit: What You Need To Know

Process Safety Management (PSM) Compliance Audit: What You Need To Know

Oct 30, 2022

Organizations that handle highly hazardous chemicals must have a comprehensive safety management program to ensure their employees, contractors, and members of the public are protected from potentially catastrophic incidents.

Organizations should regularly audit their operations to identify any potential gaps or areas of improvement in their safety management program.

What does PSM stand for?

PSM stands for Process Safety Management.

The Process Safety Management system should include policies and procedures for identifying, evaluating, controlling, and monitoring all risks associated with working with these materials.

It should also include training on safe work practices as well as emergency preparedness and response plans to ensure that personnel are adequately trained and equipped to handle emergencies and unexpected releases with hazards involved.

What is a PSM audit?

A PSM audit assists companies in determining whether they are doing what is required for compliance against OSHA’s PSM mandate.

An audit of Process Safety Management compliance is an important and necessary step for companies to ensure they are meeting OSHA’s regulations and guidelines.

These audits help identify any gaps in PSM implementation or areas where further training may be needed, enabling organizations to take corrective action quickly.

How often is a PSM audit required?

Recommended, once every three years.

The process safety management audit must include an audit of the PSM program that covers all components, including management commitment and employee participation, process safety information, process hazard analysis, operating procedures, training programs, contractor selection/management, pre-startup safety review procedures, mechanical integrity of equipment associated with the process systems being used by the company and incident investigation.

What is the OSHA standard for PSM?

OSHA developed the Process Safety Management (PSM) standard (issued in 1992) designed to prevent catastrophic events, such as explosions and releases of toxic substances, from occurring by requiring employers to identify and assess the risks associated with the hazardous materials and processes.

Employers must also develop safe operating procedures for activities that involve these chemicals or processes, as well as provide training for employees on proper use of equipment and safe work practices. In addition, employers must implement an emergency response plan and monitor the safety system to ensure that it remains effective.

The Osha’s process safety management applies to processes involving threshold quantities of flammable liquids and gasses (10,000 lbs) as well as 137 listed highly hazardous chemicals. It also covers the manufacturing of explosives. Osha PSM requirements and safety programs help maintain safe and healthy workplaces.

Occupational safety, emergency procedures and emergency planning are just a few ways Osha is assisting companies protect the safety and health of their employees.

What are 4 areas that a compliance audit examines?

The 4 areas compliance audits examine are compliance preparations, security policies and procedures, user access controls, and risk management procedures.

An effective audit is essential to any organization’s success. It helps ensure that the organization adheres to all applicable regulations and best practices, protects its assets, reduces risk, and maintains the trust of its stakeholders.

The audit should assess an organization’s compliance standards, policies and procedures, access controls, security measures, written procedures, user activity monitoring systems, and incident response plans.

It should also identify any areas where the organization may be failing to meet its obligations, and provide recommendations for improvement. A successful audit will enable an enterprise to better protect itself against legal, financial, and reputational risks.

Additionally, a thorough audit can help ensure that the organization remains compliant with all applicable laws and regulations.

What are the 14 Process Safety Management (PSM) elements?

  1. Process Safety Information
  2. Process Hazard Analysis
  3. Operating Procedures & Safety Procedures
  4. Hot Work Permits
  5. Emergency Preparedness & Emergency Shutdown Systems
  6. Mechanical Integrity
  7. Pre-startup Safety management
  8. Training Management
  9. Change Management
  10. Incident Investigation
  11. Contractors
  12. Compliance Audits and Compliance evaluations
  13. Employee Involvement and Employee Safety
  14. Trade Secrets

Companies can use these 14 elements to determine and analyze data in near real-time to automatically identify potential hazards before they become a problem.

This allows them to quickly respond and address problems before any harm is done, mitigating the risk of a catastrophic event.

In addition, automation can be used to streamline process safety operations, providing more accurate and timely data to improve decision-making.

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Warehouse Inspection Checklist

Warehouse Inspection Checklist

Jul 22, 2022

Why is warehouse safety important?

Warehouse managers have a difficult job. Not only do they need to keep their facility running smoothly, they need to ensure the safety of their workers, and facilitate warehouse operations.

According to the Occupational Safety and Health Administration (OSHA), warehouse managers face a number of potential hazards in their workplace, including unsafe use of a forklift, improper stacking, and unsatisfactory fire safety provisions. These line items plus many more will be included in an osha inspection.

How to use a warehouse safety checklist?

Maintaining compliance with industry safety standards is critical for any business, but can be especially difficult for small businesses. One way to ensure compliance especially before a company is required to do a formal safety audit is to use safety inspection checklists that are compliant with OSHA standards. iSi offers a checklist free of charge to help companies start their compliance journey.

Additionally, using pre-written checklists can help reduce the amount of time spent on safety inspections, allowing business owners to focus on their core operations. Finding a warehouse safety checklist is the first step to this process.

What should be checked during warehouse safety inspections?

Forklifts:

In any warehouse, forklift accidents are a major concern that can facilitate numerous hazards. Forklift operators need to be properly trained and aware of potential safety risks, especially while loading docks. In order to avoid injuries, it is important to maintain haulage equipment, make sure it is in good working order, never exceed 5 mph outside or in a warehouse, examine the area before driving a forklift, and perform regular checks on all equipment.

Docks and Dock doors

Injuries can occur when warehouse employees are struck by items or equipment falling from the dock or while loading dock doors, when the forklift runs off the dock, or when employees engage in “dock jumping.” It is important for the safety of workers to drive slowly, never go in reverse, and wear a hard hat. Ladders and stairs should meet OSHA’s guidelines, and “dock jumping” should be prohibited.

Material Storage

A good item to examine on the warehouse safety checklist is material storage. Warehouses are often dangerous places to work, as the slightest mistake can lead to a worker being injured. In order to keep workers safe, it is important that warehouses implement safety measures to prevent falls and other injuries from occurring. One such way to prevent falls and protect employees is by positioning items evenly throughout the warehouse and on storage racks.

This means that when workers walk through the warehouse, they will not have to navigate around large piles of boxes or other items. This is important for the safety of the workers. Placing heavier loads in lower distances will also help to keep workers safe, as it will be easier for them to maintain their balance when carrying heavy objects. Implementing these simple safety measures can help keep your workers safe and injury-free.

Charging Station

In the warehouse, one of the most important safety steps you can take is to identify hazards and know how to prevent them. According to OSHA, there are a number of things that you can add to your warehouse safety inspection checklist to maintain warehouse safety, including banning smoking and open flames, keeping an adequate inventory of fire extinguishers, and properly positioning forklifts before charging.

Chemicals

In order to be compliant with local, state, and federal regulations, it is important for warehouses to have safety data sheets (SDSs) on hand. SDSs are documents that contain all the relevant information about hazardous materials and chemicals, including its hazards, proper storage and handling, first-aid and firefighting measures, toxicological information, and more.

For warehouses that store hazardous chemicals, it is especially important to be up to date with all regulations. This is because hazardous materials and chemicals can pose a danger to employees if not handled properly. In order to prevent accidents, employees will need regular training and management should preform regular inspections.

Warehouses should make sure they have up-to-date SDSs for all of their chemicals. Having these documents on hand will help ensure a safe work environment and the warehouse is in good standing with all regulations.

Person lifting or handling

For employees who are performing regular lifting and handling of heavy objects, quick is not safe. Most cases of back pain are caused by strain or injury to the muscles, ligaments, or discs in the back. The good news is that these injuries can often be prevented by using proper lifting techniques as well as storing heavy or cumbersome items preoprly on storage racks.

Security System

As technology advances, more and more businesses are turning to warehouse security systems to protect their investments. With the installation of alarms and surveillance cameras near all access points, business owners can rest easy knowing that their facilities are under 24/7 monitoring. While there are many companies that offer these services, it is important to do your research before selecting a provider.

One of the first things you will want to consider when hiring a security company is their experience in servicing storage areas and other sensitive locations. It is also important to look at the quality of their equipment. In addition, the company should offer cloud storage so that you can access videos from anywhere at any time.

Finally, be sure to ask about the company’s customer service policies. You should expect 24/7 support in case of an emergency.

Fencing

Most people know that fences provide a layer of security by keeping unauthorized individuals out of a designated area. What many people don’t realize, however, is that fences also need to be routinely inspected in order to ensure they are still structurally sound and haven’t been compromised. Just as you would perform maintenance on your car or home, it’s important to inspect your fence on a regular basis and identify safety hazards to prevent any unwanted access or damage from happening.

Employees

Employees that can identify when something doesn’t seem right can be your best protection against potential security breakdowns. This should be a part of your hazard communication. Security breaches can happen anywhere, at any time, so it’s important to have a plan in place for how to handle them. That means having employees who are alert and paying attention to their surroundings, and who know what to do if something seems suspicious.

What are the most common warehouse safety hazards?

Fire Safety

A warehouse is a large, open space where goods are stored and processed. Because of the nature of their work, warehouses pose a unique fire risk. In order to ensure that your warehouse is as safe as possible in the event of a fire, it is important to take some precautions.

The most important thing you can do is make sure that your warehouse is well-marked with clear exit signs and that there are adequate fire extinguishers available. You should also store flammable materials in a safe place and make sure that wires are properly insulated. Having proper emergency exits, fire exits, and fire alarms can and will save lives as well as products.

Falls

It’s no secret that safety is of utmost importance in the workplace. Every employee should be aware of the proper safety protocols to follow in case of an emergency. In addition, it’s important to take measures to ensure the safety of employees while they are working.

This may include using safety railings, harnesses, and other protective devices. It’s also beneficial to cordon off uneven or damaged areas while repairs are being made.

Heavy machinery

Heavy equipment is often essential to completing construction or other tasks. However, working with this equipment can be dangerous if not done properly. It is important that you take the necessary precautions to ensure your safety and the safety of those around you when using heavy equipment. All vehicles

Some tips to keep in mind are: being aware of your surroundings, safely entering and exiting equipment, sustaining communication with other workers, using appropriate spotter signals, creating buffer zones, and workers knowing when to stop so that they are not in a dangerous situation.

Trip hazards

It’s no secret that the warehouse industry is a dangerous one. Every year, workers in a warehouse are injured and killed on the job because of common hazards. In an effort to reduce these numbers, it’s important for employers to be aware of the most common warehouse safety hazards and take steps to correct them.

One of the most common types of accidents in a warehouse is a slip or trip. This can be caused by many things, such as poor lighting, loose materials on the floor, spills, or uneven flooring.

To avoid these accidents, it’s important for employers to take steps to improve visibility and make sure that all surfaces are even and free of hazards. Implementing hazard signs and caution tape can also help increase awareness among workers.

Overexertion

What are overexertion injuries? For example, injuries caused by lifting, pushing, pulling, holding, carrying, or throwing objects all fall under the category of overexertion.

To help prevent overexertion-related accidents, your workers must receive proper safety training. In particular, learning how to lift and carry objects without injury is a vital part of warehouse worker training.

Carrying heavy items improperly can result in a number of different types of injuries: back strains and sprains, hernias, neck strains and sprains, shoulder strains and sprains. Injuries like these can keep your workers off the job for weeks or even months at a time. That’s why it’s so important to make sure your workers know how to safely lift and carry boxes and other items in the warehouse setting.

Falling objects

Working in a warehouse almost guarantees that some materials will be stacked on racks above everyone’s heads. Hard hats, hard hats, hard hats… is the number one thing every person should be wearing to prevent injury. Therefore, it’s possible for items to fall from those racks and cause injuries or get lost in the flue space. In order to prevent these things from happening, a safety protocol should be put into place.

That protocol should include the use of a safety harness, regular inspections of the racks, and employee training on how to properly stack materials.

Lack of Awareness

The biggest hazard in warehouse safety is lack of awareness. When you go through your warehouse safety checklists make sure your warehouse workers, co-workers, and managers are practicing situational awareness.

To help maintain this level of awareness, your team should know all current regulations and latest regulations as well as provide effective training to all workers. When you provide training make sure to include hazard communication with warehouse workers and take preventive measures to keep everyone safe.

If an incident arises, take immediate corrective actions and safety procedures, create reports of the incident and leave the warehouse in good condition.

How do warehouse inspections work?

Warehouse safety inspections, also known as warehouse audits, are an important part of maintaining a safe and efficient working environment in a warehouse setting for warehouse staff. By following a set of documented processes, employers can ensure employee safety, protect inventory from theft or damage, and optimize workflows and procedures. A warehouse safety checklist can help to guide warehouse workers through the necessary steps to complete an effective inspection. Inspections is a warehousing industry standard.

Conclusion:

Having a warehouse is an important part of any business, and it’s essential to make sure they are functioning properly. A warehouse inspection checklist can help you do just that.

A good inspection checklist will cover all the key areas of a warehouse, from the inventory to the security systems. It should also be customized to your specific needs, so that you can be sure nothing is missed.

A well-executed warehouse inspection can help you identify any potential problems before they become serious issues. It can also help you ensure that your warehouse is running as efficiently as possible, which can save you time and money in the long run.

Where Do You Go From Here?

iSi can help you get a baseline on your environmental compliance responsibilities and help you prioritize the ones which are most critical to be taken care of.  Request a quote for an environmental audit today!  Need more information about these issues?  Contact us at (888) 264-7050 or email us!

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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.

How Can We Help? Ask a Question or Request Info or Pricing

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Laboratory Safety Checklist

Laboratory Safety Checklist

Jun 9, 2022

What You Need To Know:

What is a safety audit checklist?

A safety audit checklist is a document used by companies to ensure their workspaces are compliant with industry health and safety standards.

The purpose of a safety audit checklist is twofold: first, to ensure that all areas of potential danger have been identified and addressed; and second, to provide a record of due diligence in the event of an accident or injury.

Many companies use safety audit checklists as part of their regular safety program, while others only implement them in response to an incident.

What should be included in a lab safety checklist?

Lab safety is of utmost importance in any laboratory setting. A lab safety checklist helps to identify and minimize chemical, biological, physical and radioactive hazards present in a laboratory facility.

It helps ensure that the laboratory complies with environmental standards to prevent overexposure to hazardous chemicals, injuries and respiratory-related illnesses or fatalities.

What are the 5 major areas of lab safety?

Cuts:

Laboratory accidents are one of the most common types of workplace accidents. In severe cases, nerves and tendons may be severed.

Often, these injuries occur as a result of attempting to force a cork or rubber stopper into a piece of glass tubing, thermometer or distilling flask thus the result can be broken glass.

To prevent this accident from occurring, workers should make a proper-sized hole, lubricate the cork or stopper, and use gentle pressure with rotation on the glass portion along with any removal of broken glass after an incident.

Toxic fumes:

Chemical fumes can be extremely dangerous, and it is important to take the necessary precautions when working with them especially while working inside. Fumes can cause serious health problems if they are inhaled, so it is important to make sure there is proper ventilation in the lab and to maintain a safe distance when pouring chemicals. Fumes can also be an environmental health issue.

Skin Absorption of Chemicals:

It is important to be aware of the physical injuries that can occur in the laboratory. Chemicals can cause burns, and even if they are not corrosive, exposure can cause allergic reactions or other problems if absorbed by the skin. This can cause acute or immediate effect on the person.

Remember that gloves may be permeable to certain chemical reagents – even without visible deterioration – so trade out any gloves that have come into contact with such chemicals for a new pair immediately. Never touch your face or eyes until your hands are clean of all chemicals or solvents.

Explosions and fires:

In a lab, it is important to be aware of the dangers of flammable liquids. Vapors can travel long distances and may ignite if they reach a flame or spark. Be sure to keep a fire extinguisher on hand and ensure each individual in the laboratory knows its exact location to prevent fires from spreading.

The appropriate personal protective equipment (PPE), like a flame-resistant (FR) lab coat, should also be worn.

Chemical or thermal burns:

Chemicals are an important part of laboratory work. They can be used to create reactions or to purify substances. However, they also can be dangerous if not handled correctly. Burns, chemical spills, and unsafe laboratory conditions are all potential hazards and you should immediately report any incident with you chemical or thermal burns.

It is therefore important to exercise caution when working with chemicals and to always wear the appropriate personal protective equipment (PPE).

What are the major overlooked lab safety issues and hazards?

Ergonomic safety:

Musculoskeletal disorders or MSDs are a serious problem in the workplace, and they can be caused by many different things.

One of the most common causes is repetitive awkward postures, which can occur when employees are not properly trained on ergonomics safety. This type of injury can lead to discomfort and loss of productivity, and it is important for employers to take steps to prevent them.

Laboratory waste disposal:

One of the most important aspects of ensuring a safe and healthy work environment is properly managing hazardous waste. Improper disposal of these materials can have serious consequences for both employees and the environment.

Pathogenic diseases and chemical reactions are just two examples of the many dangers posed by hazardous waste if it is not handled correctly. By implementing a comprehensive waste management program, employers can mitigate many of these risks.

Dress code safety:

Proper dress codes can be overlooked when trying to protect students and protect employees. In order to maintain a safe laboratory environment, adding the dress code to the daily lab checklist is a must.

Employees must ensure all safety equipment including goggles, face shields, safety gloves, body, and respiratory protection are in good condition before entering the laboratory.

Proper labels:

Labels are an important part of, not only general safety but also laboratory safety. Putting a proper label on gas cylinders or any substance that is harmful will ensure compliance and meet laboratory standards which will eliminate lab risks.

Record of an incident:

Another overlooked issue that should be on the lab maintenance checklist is proper record-keeping. You should be keeping records of the following: Damaged equipment, equipment malfunction, toxic contamination, radioactive materials leaked, chemical exposures, chemical spills, laboratory cleanliness, maintenance of labs, and any other issues along with the person responsible.

Conclusion:

Laboratory safety, chemical safety, biological safety, radiation safety, and general safety begin with a proper checklist. Starting with regular self inspections can help tremendously but don’t shy away from outside help if you feel you need it. Safety officers and safety consultants can help you with basic requirements for you laboratories, maintain laboratory health, help you achieve a good inspection checklist, cultivate emergency procedures, and ultimately prevent laboratory risks to help you avoid unwanted legal action again your company. Following tips safety consultants provide is paramount. Maintaining a lab, keep it in peak condition, and keeping employees safe is always the utmost priority.

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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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