OSHA Considering Changes and Updates to the PSM Standard

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OSHA Updates Walk Around Rule for Inspections

Apr 19, 2024

A new final rule issued by OSHA gives employees the opportunity to designate an employee representative to accompany an inspector during OSHA inspections. The original rule, at 29 CFR 1903.8(c), allowed for employers to have a representative to accompany an inspector, now employees can designate one as well.

This new rule is a result of a 2017 court case where it was found the rule could be interpreted to allow employees to have a representative, but the rule wasn’t written that way.

What’s a Representative Do?

An example of an employer representative to accompany an OSHA inspector would be someone like iSi who provides a safety specialist to be there on behalf of the employer or provides an industrial hygienist for side-by-side sampling. Now, employees can designate a representative as well.

Employee representatives can be someone internally employed by the company, a union representative, or a non-employee third party. Third parties need to be someone “reasonably necessary” who can provide technical knowledge or practical experience about the processes and hazards of the types present in the workplace, or provide language and communication skills that facilitate the gathering of information from employees.

What Do You Need to Do?

The final rule is a right for employees, not a standard that requires employers to have any special compliance duties for. It’s up to the employees to come up with their representative and there’s no formal instructions on how they should do that. OSHA gives some suggestions on the process employees can use:

Chapter 3 of OSHA’s Field Operations Manual says in workplaces where employees are represented by a certified or recognized collective bargaining agent, the highest-ranking union official or union employee representative on-site designates who participates in the walkaround;
Employee members of an established safety committee or employees at large can designate the employee walkaround representative (per Chapter 3);
Employees can designate an authorized employee representative when they authorize them to file a complaint on their behalf;
Employees can also inform the inspector during the walkaround or during interviews that they have an authorized employee representative; or
An authorized employee representative can also inform the inspector or OSHA Area Office that they represent employees.

No set number of votes is required to designate an employee representative. It doesn’t even have to be by a majority. The person just must be authorized by more than one employee.

OSHA inspectors may determine at the complaint stage who the employee representative is based on who files the complaint or if they are represented by a labor organization. When they arrive onsite, inspectors may also ask if the employees have a designated representative or they may ask employees directly who their representative is.

Qualifications of Representatives

Inspectors have the right to question third party employee representatives on their qualifications or purpose for being there to ensure they’re making a positive contribution to a thorough and effective inspection. Third parties must be an aid in an inspection, not a distraction. Typically, one employer representative and one employee representative will be allowed during the inspection. An inspector can allow additional representatives in cases where they think it may benefit the inspection. If there is more than one employer onsite that will be affected by the inspection, they may be allowed to have their own employer and employee representative.

In cases where the employer disputes the necessity for the employee representative, and vice versa, the inspector has the final determination on who stays and who doesn’t.

Ground Rules for Inspections

All representatives will need to follow rules that all other visitors to the facility would be asked to follow regarding PPE use, confidentiality, limits on access to certain areas due to trade secrets, use of cell phones/cameras, etc. Limitations on access, however, cannot interfere with the inspection. Special requirements cannot be placed on inspection representatives. A documented Visitors Policy would be a good item to have on file at your facility to clearly state requirements for all visitors.

Representatives are not allowed to discuss matters unrelated to the inspection with the employees.

Third parties can participate in the opening conference, the inspection and the closing conference. Both employer and employee representatives are not to be present for private interviews of the employees unless the employee specifically requests their presence.

Third party representatives cannot disrupt the inspection by doing anything that’s not directly related to a fair and orderly inspection. Some examples would be preventing an inspector from taking photos, videos, or monitoring samples, preventing the inspector from privately interviewing employees, failing to always stay with the inspector, taking unauthorized photographs, handing out materials or cards, or failing to comply with any other ground rules set by the inspector.

Per the current policy, OSHA will only delay their inspection by 1 hour at the most to allow for offsite representatives to get to the facility. This applied to employer representatives and will apply to employee representatives as well.

Future Challenges to the Rule

Already it appears this rule could be facing some legal challenges. The rule was put together pretty quickly for an OSHA rule. Among the issues brough up that challengers have already voiced include the possibility of introducing union reps in non-union workplaces to solicit and campaign during work hours; attorneys may use this to conduct pre-litigation discovery in personal injury or wrongful death actions; it could bring worker advocacy groups and community organizations without safety expertise into the workplace to organize non-union employees; and, competitors or other security threats could potentially gain access to proprietary information for economic or physical harm.

Learn More

Check out the new rule here. If you have any questions, or would like to know more about the onsite employer representative services we can provide to you in your next regulatory inspection, contact us here.

Safety Inspections and Corrections

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

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Contributing:

Curtis Leiker, CSP

Certified Safety Professional | ISO 45001 and 14001 Lead Auditor

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

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OHSAS 18001 and ISO 45001: What’s the Difference?

Apr 11, 2024

Need assistance with ISO 45001? iSi can help!

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On November 27, 2017, a final version of the new International Standards Organization (ISO) 45001 standard was published, creating an official ISO standard for occupational health and safety programs.

In the early 2000s there were international standards for environmental management systems with ISO 14001, but not health and safety. Thus, a British Standard was developed, called Occupational Health and Safety Assessment Series (OHSAS) 18001.

ISO 45001 takes much of what’s already in OHSAS 18001 and adds to it, reorganizes it to match current ISO formats, and modifies some areas. If you’re already OHSAS 18001 certified, you will have a good head start on ISO 45001 certification.

ISO 45001 brings the responsibility of safety to company leadership and establishes how safety incorporates into the entire organization, rather than making it a responsibility of safety management. The standard has more detailed clauses lining out its expectations of employee involvement, requiring the documentation of results and program effectiveness, risk evaluation and considering how safety affects all affected parties, not only employees but contractors, outsourced operations, vendors, etc.

Here are just a few of the differences between the two standards:

OHSAS 18001	ISO 45001
British Standard	International Organization of Standardization Standard
Reactive planning	Proactive planning
Hazard control	Risk evaluation, reduction and prevention
Procedures are prepared	Documented results are required
Safety management personnel play leadership role	Top management plays leadership role
Company management reviews the process after development	Company leadership takes leading role to ensure it fits within the overall organization’s processes.
Safety and health is the responsibility of safety management personnel	Safety and health is the responsibility of leadership and the overall management system of the organization. External and internal issues related to the safety management system should be addressed by leadership. Workers and interested parties’ needs should be addressed and incorporated into the plan.
Employee participation consultation	Everyone, including leadership, is responsible for safety. Workers should be provided education to help identify risks and everyone should participate. Internal audits and risk assessments should be shared with all employees and non-managers should participate in internal audits, risk assessments and incident investigation.
Information and communication procedures are prepared	Information and communication documentation is required including who, what, when, the objective of the communication and was it effective?
—	Additional Elements • Outsourced processes, procurement and contractors are addressed. • Hierarchy of controls are to be used. • Procurement of goods are to be considered. • Contractor controls and communication requirements for their workers, your workers and any other affected parties are required.

iSi can help with developing ISO 45001 programs! Contact us today!

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ISNetworld: The Top 10 Items You Need for Compliance

Apr 1, 2024

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

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

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

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

General Company Information

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

Safety Policies and Procedures

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

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

Written Safety Programs

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

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

Training Programs

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

Regulatory Data

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

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

Insurance

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

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

Employee and Contractor Data

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

Human Resources-Type Information

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

Other Procedures — Sustainability and Cyber Security

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

Individual Training

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

A Plan for Management and Completion

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

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

Other Considerations

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

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

Resources

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

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

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

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

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

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Need Help?

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

Get Help Here

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

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

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

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

General Company Information

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

Safety Policies and Procedures

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

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

Written Safety Programs

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

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

Training Programs

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

Regulatory Data

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

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

Insurance

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

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

Employee and Contractor Data

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

Human Resources-Type Information

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

Other Procedures — Sustainability and Cyber Security

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

Individual Training

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

A Plan for Management and Completion

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

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

Other Considerations

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

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

Resources

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

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

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

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

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

Get Pricing

Ask a Question

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Example General Duty Clause Citations to Look for in Your Workplace

Mar 25, 2024

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

What is the General Duty Clause?

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

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

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

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

Examples of Common General Duty Clause Citations

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

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

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

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

Safety Inspections and Corrections

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

Ask for Info

Contributing:

Curtis Leiker, CSP

Certified Safety Professional | ISO 45001 and 14001 Lead Auditor

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

Questions?

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

Ask a Question

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What’s the Difference Between the HAZWOPER’s Emergency Response Plan and an Emergency Action Plan?

Mar 18, 2024

hazardous cleanup emergency

Being prepared for emergencies at your facility is vital, and having that plan communicated to your employees is even more critical. OSHA references a couple of different plans in its regulations, one is the Emergency Action Plan and then OSHA’s HAZWOPER standard mentions requirements for an Emergency Response Plan. So, what’s the difference between these two plans?

HAZWOPER emergency response team

Emergency Action Plans (EAP)

When reading the OSHA standards for Emergency Action Plans, it’s easy to be confused because they can be pretty complicated.

EAP requirements are found in 29 CFR 1910.38(a). They are part of Exit Routes and Emergency Planning in Subpart E. A number of OSHA standards require that you have an EAP, including the regulations related to Process Safety Management, Fixed Extinguishing System-General, Fire Detection Systems, Grain Handling, Ethylene Oxide, Methylenedianiline and 1,3-Butadiene.

In 29 CFR 1910.157, Portable Fire Extinguishers, there is mention of needing EAPs as an alternative to teaching your employees how to fight fires. There are a bunch of if/then conditions, but OSHA really puts it plainly in their online eTools that the only way a company wouldn’t have to have an EAP is if you have an in-house fire brigade where every employee was trained and equipped to fight fires. So basically, it doesn’t matter which regulations require EAPs, if you don’t have an in-house fire brigade where every employee is trained to fight a fire, you’re going to need an EAP.

So, Then What’s in an EAP?

This standard says that an EAP must be in writing, kept in the workplace, and available to employees for review.

At a minimum, EAPs need to include procedures for:

Reporting a fire or other emergency;
Emergency evacuation, including type and exit routes;
Employees who remain to operate in critical plant operations before they evacuate;
Accounting for all employees after evacuation;
Employees performing rescue or medical duties; and,
Name and job title of every employee who may be contacted by employees who need more information about the plan or their duties under the plan.

Employers with more than 10 employees are required to have an employee alarm system with a distinctive signal.

As an employer, you must train employees in the safe and orderly evacuation of other employees. You must review the EAP with every employee covered by the plan when they are initially assigned to a job, when that employee’s responsibilities in the plan have changed, or whenever you make any changes to the plan.

If you have 10 or fewer employees you can communicate the plan orally to employees however, it’s a good practice to still have it in writing because when you get your 11^th employee unless you’re super organized, it’s unlikely that will trigger a reminder to put your plan in writing.

HAZWOPER Emergency Response Plan

The OSHA HAZWOPER (Hazardous Waste Operations & Emergency Response) standard at 29 CFR 1910.120 goes into detail about Emergency Response Plans.

If you are going to have your employees respond to releases and spills, you are required to have an Emergency Response Plan. This also applies to employees that are dispatched to an incident such as from a fire station, fire brigade, or emergency medical service. This plan describes what the employees are expected to do in an emergency response.

If your facility intends to evacuate everyone from the danger area when there’s a release and have someone else do the emergency response portion, then you just need an Emergency Action Plan. Otherwise, if you are having employees respond, you need the Emergency Response Plan.

HAZWOPER emergency response

Emergency Response Plans need to include procedures/instructions for:

Pre-emergency planning and coordination with outside parties;
Personnel roles, lines of authority, training, and communication;
Emergency recognition and prevention;
Safe distances and places of refuge;
Site security and control;
Evacuation routes and procedures;
Decontamination;
Emergency medical treatment and first aid;
Emergency alerting and response procedures;
Critique of response and follow-up; and,
PPE and emergency equipment.

Emergency response organizations may use the local emergency response plan or the state emergency response plan or both, as part of their emergency response plan to avoid duplication. The HAZWOPER plan has also been adopted by EPA’s SARA regulations at 40 CFR 311 for state and local government employees in federal-OSHA states and their volunteers.

Other Emergency Response Plans Required

These are just two plans from a whole laundry list of emergency-related plans required by OSHA, EPA, DOT, and several other agencies. Want to learn more? Read our blog about all the other emergency plans required here.

Need Help?

If you need help determining which plans apply to you, need help writing one of these plans, or just want a review, contact us!

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PSM Compliance Audits: How Often Are They Required? What’s Involved?

Mar 17, 2024

Companies that fall under Process Safety Management (PSM) requirements because of their highly hazardous chemicals are required to recertify that they have completed an evaluation of PSM compliance.

Compliance evaluations must occur at least once every 3 years. Companies must certify that PSM compliance has been evaluated in order to verify that procedures and practices being followed are adequate and are being followed.

The audit needs to be planned ahead of time with plans for ensuring compliance, documenting findings, determining corrective actions and including field inspections of safety and health conditions and practices.

The Team

Audit team members should be chosen based on their experience, knowledge, training and familiarization with the standard. Smaller companies may be able to have teams as small as one, but larger companies like refineries with 3 or 4 processes may need a team of 5-6 people over the course of 1-2 weeks. You can use your own personnel, personnel from other plants, or consultants to conduct the audit.

The Audit

The audit should:

Make sure all PSM requirements are being followed;
Identify elements that need special attention;
Review pertinent documentation with samples large enough to ensure the audit results accurately reflect compliance;
Inspect the physical facilities to observe actual practices;
Interview all levels of plant personnel to determine awareness/knowledge of PSM requirements, safety procedures, and emergency procedures; and,
Record any deficiencies.

Report of Findings

Following the audit, a report of findings should document the results, and that should be signed by a responsible manager. This becomes the official certification. If you use an outside consultant as the auditor, the employer still needs to make that certification, not the consultant.

The report should include facts and information to support the audit did indeed determine and review compliance. It should document corrective actions required and document any findings so that they can be compared to future audits to determine trends. Additional observations discovered can also be included.

Deficiencies should be described, given milestones, tracked and assigned to affected personnel, then periodically followed up on. Anything that was logged as a deficiency where no corrective action was taken needs to have explanations on why it wasn’t followed up on.

Recordkeeping

Companies are required to keep their two most recent compliance reports on file. You do not need to turn those in to OSHA, just keep them on file and available for inspection. Some companies choose to destroy earlier reports because they tend to list more findings on them. Some companies also choose to do their reevaluations every 1-2 years for that reason as well.

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[For more about what PSM is, check out our blog “What is PSM?”]

Need help with PSM? We can help you get compliant with your 14 PSM elements, conduct or participate in your recertification audit, or help you correct findings. Check out our PSM page for more details!

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iSi and PSM

Contributing:

Curtis Leiker, CSP

Certified Safety Professional | ISO 45001 and 14001 Lead Auditor

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

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OSHA Looks to Issue “Emergency Response” Standard, But Despite Name, Will Have Little Effect on HAZWOPER

Mar 4, 2024

In January, OSHA issued a notice of proposed rulemaking to replace the existing general industry Fire Brigade standard at 1910.156 with a new broader standard called “Emergency Response.” Despite the name, the standard will still not be the same as the current HAZWOPER (Hazardous Waste Operations and Emergency Response) standard, but HAZWOPER and other related standards will see still some minor changes and additions as a result of this effort.

The New Standard

The current Fire Brigade standard applies to general industry facilities that have in-house fire brigades, industrial fire departments, and private or contract fire departments. This doesn’t include people trained to put out fires with fire extinguishers or standpipe hose systems, it’s actually for those companies with an in-house firefighting team. The new rule would include those same entities PLUS employers that provide pre-hospital emergency medical services, technical search and rescue services, or have employees that perform emergency services as their primary duties. The new standard still stays more toward fire, rescue and medical-related emergency responses, not the hazardous materials spills that HAZWOPER is related to.

The new standard will divide companies into two groups. One is “Emergency Service Organizations,” or ESOs, and the other is “Workplace Emergency Response Employers,” or WEREs.

Emergency Service Organizations pay employees, entities with volunteers, or entities that have both members and volunteers primarily to do response activities such as firefighting, EMS and technical search and rescue. ESO employees in this function will be called “responders.” The only volunteers covered in this standard are those who get significant pay or other compensation, which OSHA doesn’t believe there are many. Federal OSHA standards do not cover volunteers, but some state plans do. If you are in an OSHA state plan state, check your state’s requirements regarding volunteers.

The other group, Workplace Emergency Response Employers, are companies where the employees have other primary jobs at the site and do emergency responses infrequently. The responses still involve firefighting, emergency medical services, and/or technical search and rescue. Individuals in WEREs will be called “team members” and the group of team members will collectively be called “Workplace Emergency Response Teams.”

The point of this new standard is to bring in more up-to-date consensus standards from the National Fire Protection Association (NFPA) and to align better with the Federal Emergency Management Agency (FEMA) and its National Incident Management System (NIMS) processes. The Fire Brigades standard was written in 1980 with no significant changes, and thus is quite outdated. The new standard is also aimed to move related items from other standards and get them into one place.

There will be a number of requirements for ESOs and WEREs including written Emergency Response Plans, Facility Vulnerability Assessments, and Pre-Incident Plans. Vulnerability assessments will analyze each area of the facility to determine which areas need pre-incident plans and if the equipment, firefighting capability and PPE is sufficient to handle a potential incident there. Additional medical and physical requirements, training, equipment and PPE, post-incident analysis, and incident management system development directions will be detailed. The standard will not apply to cleanups or the aftermath of an incident, just the emergency portion.

Other Standards Affected

OSHA realizes that emergency response information is scattered throughout different parts of 1910 that need to be consolidated, and while they’re addressing emergency response, there are a number of NFPA and ANSI standards that are newer and relevant that also need to be included. As a result, OSHA is proposing to make these additional standard changes:

1910.6 Incorporation by Reference

A number of newer ANSI and NFPA standards related to emergency response, fire, medical services response, and PPE will be added.

1910.120 HAZWOPER, including Subpart H Hazardous Materials

OSHA wants to add an Appendix D to include references to new consensus standards for personal protective equipment. The specific NFPA standard referenced is NFPA 1990 – Standard for Protective Ensembles for Hazardous Materials and CBRN Operations [2022 ed]. These are standards for chemical protective suits.

Changes in standard text will include:

(q)(3)(iii) Based on the hazardous substances and/or conditions present, the individual in charge of the ICS shall implement appropriate emergency operations, and ensure that the personal protective equipment worn is appropriate for the hazards to be encountered. However, personal protective equipment shall meet, at a minimum, the criteria contained in § 1910.156(k) when worn while performing firefighting operations beyond the incipient stage for any incident.

(r) Appendices to this subpart—Hazardous Waste Operations and Emergency Response. Appendices A through E to this subpart serve as non-mandatory guidelines to assist employees and employers in complying with the appropriate requirements of this section. However, paragraph (g) of this section makes mandatory in certain circumstances the use of Level A and Level B PPE protection set forth in the appendices.

Changes to Appendix B of Subpart H will read:

Level D

—Level D protection should be used when:

The atmosphere contains no known hazard; and

Work functions preclude splashes, immersion, or the potential for unexpected inhalation of or contact with hazardous levels of any chemicals.

Note:

As stated before, combinations of personal protective equipment other than those described for Levels A, B, C, and D protection may be more appropriate and may be used to provide the proper level of protection.

As an aid in selecting suitable chemical protective clothing, it should be noted that the NFPA has developed standards on chemical protective clothing. The standards that have been adopted include:

NFPA 1990, Standard on Protective Ensembles for Hazardous Materials and CBRN Operations, [2022 ed]. (as incorporated by reference, see § 1910.6).

This standard applies documentation and performance requirements to the manufacture of chemical protective suits. Chemical protective suits meeting these requirements are labelled as compliant with the appropriate standard. It is recommended that chemical protective suits that meet these standards be used.

1910.134 Respiratory Protection, including and Subpart I Personal Protective Equipment

OSHA will be removing the definition of Interior Structural Firefighting out of the respiratory protection standard and will be moving it to the new 1910.156.

1910.155 Subpart L, Fire Protection – Scope, application and definitions

A number of definitions will be removed from this section, while others will be added.

1910.157 Portable Fire Extinguishers

There currently is no mention of the Class K fire extinguisher, so revisions and additions will include:

(c)(3) The employer shall not provide or make available in the workplace portable fire extinguishers using carbon tetrachloride, chlorobromomethane, or methyl bromide extinguishing agents.

(d)(7) The employer shall distribute portable fire extinguishers of Class K extinguishing agent for use by employees so that the travel distance from the Class K hazard area to any extinguisher is 30 feet (9.15 m) or less.

1910.158 Standpipe and Hose Systems

Facilities will be required to have fire hose connections/adapters that are compatible with your local fire department or the WERE that’s pumping water into the emergency.

(c)(2)(iii) The employer shall ensure that standpipe system inlet connections and fittings are compatible with, or adapters are provided for, the fire hose couplings used by the fire department(s) or Workplace Emergency Response Team(s) that pump water into the standpipe system through the connections or fittings.

1910.159 Automatic Sprinkler Systems

Compatible adapters and equipment will be required here as well.

(c)(12) Inlet connections. The employer shall ensure that sprinkler system inlet connections and fittings are compatible with, or adapters are provided for, the fire hose couplings used by the fire department(s) or Workplace Emergency Response Team(s) that pump water into the sprinkler system through the connections or fittings.

The Regulation and Public Comment Period

You can read more about this new standard here. Comments are being solicited until May 6, 2024. Additional stakeholder meetings may also be held upon request. iSi will keep an eye on this standard’s progress.

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Grade D Breathing Air: What Requirements Do I Have to Meet for My Breathing Air System?

Feb 27, 2024

Compressed air, either through a fixed or a portable system, can be used to supply air to employees as they perform tasks that could not be done using an air purifying respirator.

Supplied air respirators are respirators that supply the user with breathing air from a source independent of the ambient atmosphere.

First we’ll take a look at breathing air and then we’ll cover what its OSHA requirements are.

What Operations Use Supplied Breathing Air?

Supplied breathing air can be used across all industries for many different functions throughout the facility. Some of the most common include: paint booth worker

Confined Space Entry
Sand/Media Blasting Operations
Working in Paint Booths
Welding

What Are the Components of a Breathing Air System?

A simple breathing air system has four basic components.

Air Source

The air source can be from a fixed or portable compressor. This compressor can be either electric, gas or diesel powered. Another source can be from bottled or tanked air. The air source should be sized to provide a minimum of 4 cubic feet per minute (CFM), but depending on the work being done, workers may require up to 15 CFM. Typical systems operate around 10 to 12 CFM. Pay special attention to the intake area of the compressor to be sure that no gasses or vapors can be drawn into the system as they will be passed down to the employee.

Filtration

The filtration used is very important. The filtration system should be able to remove water, oil and particles, and many use a charcoal bed to remove odors and tastes. Remember to make sure the filtration system can supply the required CFM. Carbon monoxide (CO) is a special danger if the air source is not an oilless compressor and a CO monitor with alarm is then required. This alarm needs to be able to be heard by everyone connected to the air source at their point of use.

Air Distribution

The filtered air then needs to be set to the proper pressure required by the specific respirator so a regulator will be needed to drop the air pressure and not overpressure the employee’s mask. Employees are able to connect to a breathing air system via quick connect couplings, OSHA requires these couplings to be unique to the breathing air system. This ensures that employees are unable to connect a respirator to a non-breathing air system (shop air). It is also a requirement that the hose the employee uses is a maximum of 300 feet.

Respirator

The selected respirator can be of several varieties such as pressure demand or continuous flow, tight fitting face piece or loose-fitting hoods or helmets. These choices need to be made prior to the set up of the system as they can affect the design of the system. For example, if you are planning to use a continuous flow system a bottle supplied air source will not last very long.

breathing air system

What are OSHA’s Requirements for a Breathing Air System?

Breathing Air Gases Testing

The OSHA standard requires the employer provide employees using atmosphere-supplying respirators with breathing gases of high purity. To this end, OSHA has incorporated the ANSI/Compressed Gas Association Commodity Specification for Air, G-7.1 to include testing to meet the following: breathing testing

Oxygen content percentage by volume: Between 19.5% and 23.5%
Hydrocarbon (oil and particulate): maximum of 5 milligrams per cubic meter of air
Carbon monoxide: maximum of 10 parts per million by volume
Carbon dioxide: maximum of 1000 parts per million by volume
Lack of noticeable odor

This breathing air gases are also commonly referred to as Grade D breathing air. There are other grades of breathing air available that differ in oxygen content, hydrocarbons and water content that are used by fire departments and other SCBA wearers, but Grade D breathing air is the standard for industry.

While OSHA does not require breathing testing to be done on any interval, the industry standard for this testing is to be done annually for each distribution point.

Written Respiratory Protection Plan

Any company requiring employees to use respiratory protection must have a written Respiratory Protection Program that meets all the requirements of 29 CFR 1910.134.

Medical Evaluations

OSHA first requires the respirator user to be medically cleared to use a respirator. The doctor will need to know that the employee will be using a supplied air respirator so they can understand the physical requirements of the respirator being used.

Training

OSHA then requires that all respirator users be trained on how to use their respirator, the limitations of that respirator and any procedures such as when the CO alarm goes off what needs to be done.

Fit-Testing

If the respirator selected is a tight fitting facepiece, OSHA requires a fit test to ensure the facepiece provides a proper seal to the users face.

Preventative Maintenance Plan

On a system that has a CO monitor, a preventive maintenance plan needs to be established to perform calibration on the monitor. Most manufacturers require monthly calibration with a certified canister of carbon monoxide gas. Calibration dates should be documented.

Questions? Need Help?

iSi has Grade D breathing air system testing equipment and routinely conducts tests for our clients. We can also help you with the other breathing air system requirements of OSHA. Contact us today!

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Compressed air, either through a fixed or a portable system, can be used to supply air to employees as they perform tasks that could not be done using an air purifying respirator.

Supplied air respirators are respirators that supply the user with breathing air from a source independent of the ambient atmosphere.

First we’ll take a look at breathing air components, then we’ll cover its OSHA requirements.

What Operations Use Supplied Breathing Air?

Supplied breathing air can be used across all industries for many different functions throughout the facility. Some of the most common include:

Confined Space Entry
Sand/Media Blasting Operations
Working in Paint Booths
Welding

What Are the Components of a Breathing Air System?

A simple breathing air system has four basic components.

Air Source

The air source can be from a fixed or portable compressor. This compressor can be either electric, gas or diesel powered. Another source can be from bottled or tanked air. The air source should be sized to provide a minimum of 4 cubic feet per minute (CFM), but depending on the work being done, workers may require up to 15 CFM. Typical systems operate around 10 to 12 CFM. Pay special attention to the intake area of the compressor to be sure that no gasses or vapors can be drawn into the system as they will be passed down to the employee.

Filtration

The filtration used is very important. The filtration system should be able to remove water, oil and particles, and many use a charcoal bed to remove odors and tastes. Remember to make sure the filtration system can supply the required CFM. Carbon monoxide (CO) is a special danger if the air source is not an oilless compressor and a CO monitor with alarm is then required. This alarm needs to be able to be heard by everyone connected to the air source at their point of use.

Air Distribution

The filtered air then needs to be set to the proper pressure required by the specific respirator so a regulator will be needed to drop the air pressure and not overpressure the employee’s mask. Employees are able to connect to a breathing air system via quick connect couplings, OSHA requires these couplings to be unique to the breathing air system. This ensures that employees are unable to connect a respirator to a non-breathing air system (shop air). It is also a requirement that the hose the employee uses is a maximum of 300 feet.

Respirator

The selected respirator can be of several varieties such as pressure demand or continuous flow, tight fitting face piece or loose-fitting hoods or helmets. These choices need to be made prior to the set up of the system as they can affect the design of the system. For example, if you are planning to use a continuous flow system a bottle supplied air source will not last very long.

breathing air system

What are OSHA’s Requirements for a Breathing Air System?

Breathing Air Gases Testing

The OSHA standard requires the employer provide employees using atmosphere-supplying respirators with breathing gases of high purity. To this end, OSHA has incorporated the ANSI/Compressed Gas Association Commodity Specification for Air, G-7.1 to include testing to meet the following:

Oxygen content percentage by volume: Between 19.5% and 23.5%
Hydrocarbon (oil and particulate): maximum of 5 milligrams per cubic meter of air
Carbon monoxide: maximum of 10 parts per million by volume
Carbon dioxide: maximum of 1000 parts per million by volume
Lack of noticeable odor

breathing testing

This breathing air gases are also commonly referred to as Grade D breathing air. There are other grades of breathing air available that differ in oxygen content, hydrocarbons and water content that are used by fire departments and other SCBA wearers, but Grade D breathing air is the standard for industry.

While OSHA does not require breathing testing to be done on any interval, the industry standard for this testing is to be done annually for each distribution point.

Written Respiratory Protection Plan

Any company requiring employees to use respiratory protection must have a written Respiratory Protection Program that meets all the requirements of 29 CFR 1910.134.

Medical Evaluations

OSHA first requires the respirator user to be medically cleared to use a respirator. The doctor will need to know that the employee will be using a supplied air respirator so they can understand the physical requirements of the respirator being used.

Training

OSHA then requires that all respirator users be trained on how to use their respirator, the limitations of that respirator and any procedures such as when the CO alarm goes off what needs to be done.

Fit-Testing

If the respirator selected is a tight fitting facepiece, OSHA requires a fit test to ensure the facepiece provides a proper seal to the users face.

Preventative Maintenance Plan

On a system that has a CO monitor, a preventive maintenance plan needs to be established to perform calibration on the monitor. Most manufacturers require monthly calibration with a certified canister of carbon monoxide gas. Calibration dates should be documented.

Questions? Need Help?

iSi has Grade D breathing air system testing equipment and routinely conducts tests for our clients. We can also help you with the other breathing air system requirements of OSHA. Contact us today!

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Contributing:

Keith Reissig

Industrial Hygienist | Project Manager

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

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What is PSM?

Feb 26, 2024

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

PSM applies to

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

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

The 14 Elements of Compliance

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

1. Employee Participation

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

2. Process Safety Information

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

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

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

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

3. Process Hazard Analysis

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

Some of the items to be evaluated:

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

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

4. Operating Procedures

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

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

5. Training

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

6. Contractors

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

7. Pre-Startup Safety Review

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

8. Mechanical Integrity

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

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

9. Hot Work Permit

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

10. Management of Change

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

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

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

11. Incident Investigation

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

12. Emergency Planning and Audits

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

13. Compliance Audits

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

14. Trade Secrets

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

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Contributing:

Steve Hieger

Consulting Services Manager

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

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OSHA Electronic Injury and Illness Reporting Due March 2

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

Jan 25, 2024

photo depicting annual OSHA safety training requirements for industry and constuction

Annual safety training is a best management practice and is most often required when conditions in the workplace change. However, the OSHA standards don’t specifically require annual safety training for all of its topic areas, just a handful of them.

Employee Access to Medical Records

This is one of the most overlooked requirements and one of the top items which pops up in our safety compliance audits. Annual notification for employee access to medical records is required. As a company you’re required to inform workers of their rights to access their medical records, where they’re kept, how to obtain them and who is responsible for keeping them. This applies to both general industry and construction – the construction standard references the general industry standard, 1910.1020.

Respiratory Protection and Fit-Testing

Employees wearing respirators or participating in your company’s respiratory protection program are required to receive annual training regarding respirator use, care, inspection, maintenance, limitations and other requirements. In addition, employees must be fit-tested in their respirator annually. That is, each employee should be tested to ensure the seal is still fitting their face and protecting them. There are standard fit-testing procedures to use to accomplish this item. This applies to both general industry and construction and the construction standard references general industry standard 1910.134.

Hearing Protection

If your employees are exposed to noise at or above an 8-hour time weighted average of 85 decibels, your company is required to have a hearing conservation program. As part of this program, annual training is required. Ensure you post a copy of the occupational noise exposure standard in your workplace and make any and all training materials related to this available to your employees. Hearing conservation programs are required by both general industry and construction.

HAZWOPER

Employees responding to hazardous materials spills, conducting hazardous substance removals, or working at Resource Conservation and Recovery Act (RCRA) corrective action or treatment, storage, and disposal facility (TSDF) facilities are required to have hazardous waste operations and emergency response (HAZWOPER) training. There are various levels of HAZWOPER. Those with 24 and 40 hour initial training are required to have 8 hours of training annually per year. Annual training requirements for HAZWOPER can be found in 1919.120 for general industry and 1926.65 for construction.

Bloodborne Pathogens

Anyone with potential bloodborne pathogen exposure potential in general industry must have annual training and additional training whenever procedures and tasks are changed. Those who conduct first aid in construction are required to have training in hazards associated with bloodborne pathogens, as well as employees conducting maintenance activities, those collecting or separating wastes (sharps), or who could be exposed to blood or other potentially infections material as part of their job.

Fire Extinguishers and Fire Brigades

If your company provides portable fire extinguishers or other fire-fighting devices for designated employees to use in the workplace, training is required annually. For employees designated to inspect, maintain, operate or repair fixed fire extinguishing systems, annual training reviews are required. Fire fighters in shipyard operations are required to have semi-annual drills and annual training for fire watchers.

If your company houses an internal fire brigade that fight fires beyond the incipient stage, all fire brigade members are to be provided with annual training. Any members who are required to conduct internal structural firefighting are to have quarterly educational sessions or training as well.

Fire protection programs must be developed for all phases of construction and demolition jobs and, as a result, employers shall provide firefighting equipment and a trained and equipped fire fighting organization (fire brigade/group of employees that are knowledgeable, trained and skilled in the safe evacuation of employees during emergency situations and in assisting in fire fighting operations).

Confined Space Rescuers

Those who conduct confined space rescue are supposed to hold practice drills once per year. This applies to both general industry and construction.

Asbestos and Other Chemical and Substance-Specific Training

Anyone exposed to asbestos at or above permissible exposure limits are required to have annual asbestos awareness training. Maintenance personnel who may disturb asbestos within the course of their duties are also required to have annual awareness training. Those who conduct Class I through IV asbestos operations (removal activities) are also required to have annual training through the construction standards.

Employees with potential exposures to OSHA 1910.1003’s 13 carcinogens, vinyl chloride, polyvinyl chloride, inorganic arsenic, lead, cadmium, benzene, coke oven emissions, cotton dust, acrylonitrile (vinyl cyanide), ethylene oxide, formaldehyde, Methylenedianiline (MDA) and 1, 3-Butadiene are required to have annual safe usage training. Many of these are referenced individually in both the general industry and construction standards, but the construction standards will often reference the general industry standard rather than having separate rules. Construction has specific rules for cadmium, chromium, ethylene oxide, lead and MDA.

Others Worth Mentioning

Mechanical Power Presses – Operators of mechanical power presses with the Presence Sensing Device Initiation (PSDI) mode on them are required to have annual operator training.

Agriculture Industry – In grain handling facilities annual training is required for workers at grain handling facilities. Topics to be covered include dust hazards, dust accumulation, ignition control and prevention, cleaning/clearing/housekeeping procedures, hot work procedures, preventative maintenance, lockout/tagout and bin entry and engulfment hazards (for those entering bins). In other agriculture-related workplaces where employees are required to use tractors, annual training regarding rollover protective structures is required and those using farm field equipment, farmstead equipment and cotton gins are required to have safe operating and guarding training annually.

Logging Industry – Supervisors and employees in logging industry operation are required to have annual CPR training, with first aid training every 3 years.

Every 3 years – Because of their prevalence in industry, we thought we’d also mention that forklift recertifications are due every 3 years as is refresher training for Process Safety Management.

Lockout/Tagout – Not necessarily a training requirement, but an annual requirement nonetheless, employers are required to review their energy control procedures at least annually to ensure the procedure and the requirements of the lockout/tagout standard is being followed.

Environmental Training

Looking for annual EPA and environmental training? In addition to annual safety training, check out our article regarding annual environmental training requirements your company should schedule for the year.

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Environmental Training

Now that you’ve learned what safety training is required annually, learn more about what environmental training is required annually.

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State, Regional and National Safety and Environmental Conferences for 2024

Jan 22, 2024

We exhibit and speak at many different safety and environmental conferences throughout the region. What’s the schedule look like for 2024?

Here is a list of some upcoming state, regional and national safety and environmental conferences that you may want to add to your calendar. (For now, we’re listing the ones near where we have offices. )

We will work to keep this list updated as we find out changes, if any.

Central U.S. / Region VII

Region VII (KS, MO, IA, NE)

Midwest Environmental Compliance Conference (MECC)
Sept. 24-25 | Overland Park | In-Person and Online | Learn More

Region VII VPPPA Midwest Safety and Health Conference
TBD | Des Moines | Learn More

Kansas

KDHE Environmental Conference
Aug. 7-8 | Wichita | In-Person | Learn More

Kansas Safety and Health Conference
Oct. 1-2 | Wichita | In-Person| Learn More

Missouri

Mid-America Safety, Health & Environmental Conference and Expo
TBD | Springfield | In-Person | Learn More

Greater St. Louis Safety & Health Conference
Oct. 1 | St. Louis | In-Person | Learn More

Missouri Hazardous Waste Seminar
April 30 | Online | Learn More

Safety & Health Council of Western Missouri & Kansas SAFECONEXPO
May 14-16 | Lake Ozarks, MO | In-Person | Learn More

Nebraska

Nebraska Safety & Health Summit
Oct. 14 | Omaha | In-Person | Learn More

Iowa

Hawkeye on Safety
Sept. 5 | Coralville | In-Person | Learn More

Iowa Governor’s Safety & Health Conference
Oct. 29-30 | Des Moines | Altoona | Learn More

Central U.S. / Region VI

Region VI (OK, TX, NM, LA, AR)

Region VI VPPPA
April 30 – May 2 | Oklahoma City, OK | In-Person | Learn More

Oklahoma

Oklahoma Safety and Health Conference
July 24-26 | Norman | In-Person | Learn More

Environmental Federation of Oklahoma (EFO) Annual Meeting & Trade Show
Oct. 14-17 | Midwest City | In-Person | Learn More

Southeast / Region IV

Region IV (GA, AL, MS, KY, TN, NC, SC, FL)

Region IV VPPA Safety + Symposium
Aug. 25-28 | Aurora, CO | In-Person | Learn More

Georgia

Georgia Environmental Conference
Aug. 21-23 | Jekyll Island | In-Person | Learn More

Georgia Safety, Health and Environmental Conference
Sept. 4-6 | Savannah | In-Person | Learn More

Tennessee

Chattanooga Regional Manufacturers’ Association Environmental, Health and Safety Summit
TBD | Chattanooga | In-Person | Learn More

Tennessee Environmental Network Show of the South
May 15-17 | Chattanooga | In-Person | Learn More

Alabama

Alabama Governor’s Safety and Health Conference
Aug. 26-28 | Orange Beach | In-Person | Learn More

Manufacture Alabama HR, Safety & Environmental Conference
TBD | Birmingham | Learn More

North Carolina

NC Statewide Safety Conference
TBD | Learn More

Carolina Star Safety Conference
Sept. 18-20 | Greensboro | In-Person | Learn More

Eastern Carolina Safety & Health Conference
Apr. 10-12 | Atlantic Beach | Learn More

South Carolina

South Carolina Environmental Conference
Mar. 10-13 | Myrtle Beach | In-Person | Learn More

ASSP Region VI Conference
Sept. 18-20 | Virginia Beach | In-Person and Online | Learn More

NSC Southeast Regional Conference & Expo
May 14-16 | Rosemont, IL | Learn More

National Conferences

American Industrial Hygiene Conference and Expo (AIHCE) EXP 2023
May 20-22 | Columbus, OH | Learn More

American Society of Safety Professionals (ASSP) Conference and Expo
Aug. 7-9 | Denver, CO | In-Person and Online | Learn More

National Safety Council (NSC) Safety Congress
Sept. 13-19 | Orlando, FL | In-Person| Learn More

Associated General Contractors (AGC) Construction Safety, Health & Environmental Conference
July 16-18 | St. Louis, MO | In-Person | Learn More

Associated General Contractors (AGC) Construction Safety & Health Conference
Jan. 10-12 | Newport Beach, CA | In-Person | Learn More

Alliance of Hazardous Materials Professionals (AHMP) National Conference
July 14-17 | Kansas City, MO | Learn More

National Association of Environmental Professionals (NAEP) Annual Conference and Training Symposium
May 5-8 | Minneapolis, MN | Learn More

National Environmental Health Association (NEHA) Annual Education Conference & Exhibition
TBD | Spokane | In-Person and Virtual | Learn More

Which safety and environmental conferences did we miss? Let us know by emailing us here.

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2024 EPA and OSHA Compliance Deadlines

Jan 5, 2024

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

EPA/Environmental

March 1: EPCRA SARA Tier II (311 and 312)
March 1: Hazardous Waste – Biennial Reports for Large Quantity Generators
March 1 (Kansas): X-Ray Equipment Registrations (check your local state for the requirement near you)
March 31 (March 29): Greenhouse Gas Emissions Report
April 1: Air Emissions Inventory: Class I and Class II
June 1: TSCA Form U Reporting (Due every 4 years, 40 CFR 711.20)
July 1: EPCRA SARA Form R Toxic Release Inventory (313)
July 1: Mercury Inventory Report, per TSCA
July 15: Annual PCB Report, per TSCA
July 31: Voluntary Form R or Form A Revisions to TRI-MEweb
Small Quantity Hazardous Waste Generators Requirement to Update Site Notification Information Every 4 Years
Annual Supplier Notifications per EPCRA Section 313
Required Annual Environmental Training in Specific Topics

OSHA/Safety

February 1: OSHA Annual Injury and Illness Summary: Post from February 1^st through April 30^th
February 15: OSHA VPP Sites Submit Annual Injury and Illness Rates per Annual Submission Document for VPP Sites
March 2 (March 1): OSHA Electronic Injury and Illness Reporting for 2023 [Take note that more industries will be required to report this year.]
Process Safety Management
Annual Respirator Fit-Testing and Respiratory Protection Training
Annually Required or Year-Based OSHA Safety Program Reviews
- Bloodborne Pathogens Exposure Control Plan
- Lockout/Tagout Energy Control Procedures
- Permit-Required Confined Spaces Program and Cancelled Permits
- Lead Safety
- Occupational Exposure to Hazardous Chemicals in Laboratories (effectiveness of Chemical Hygiene Plan)
- Silica Exposure Control Plan’s Effectiveness
- Lead Safety
Annual Audiograms for Hearing Conservation Program
Required Annual Training in Specific Topics

DOT/Transportation

June 30 (June 28): DOT Registrations
Hazmat Refresher Training:
- DOT (Every 3 Years),
- IATA (Every 2 Years),
- IMDG (Every 3 Years),
- FAR Part 145 for Certified FAA Repair Stations (Every 2 Years)

State and Local Reporting Dates

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

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

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

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

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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?

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 Issues New National Emphasis Programs for Warehousing, Distribution Centers and Certain Retail Stores

Jul 28, 2023

OSHA’s latest National Emphasis Program (NEP) is targeting warehousing and distribution center operations, mail/postal processing and distribution centers, parcel delivery/courier services and certain retail stores with high injury rates.

An NEP is a temporary inspection emphasis based on a particular hazard that is typically targeted to specific NAICS codes where certain hazards are most prevalent or in safety areas showing a trend towards high hazards. NEP inspections can be scheduled on their own, or OSHA can tack one on at an inspection if they see something that applies. So, if OSHA is onsite to investigate a complaint and they see something that could fall under an NEP, they can inspect for that too while they are there.

Who’s Covered in this NEP and Why?

OSHA recognizes a warehousing and distribution growth boom and an increased DART rate compared to other industries. In 2011 there were 668,900 warehousing and distribution centers, and in 2021 that number was 1,713,900. DART rates and total recordables for the industries covered in this NEP were over twice that of all private industry, some were more than three times the private industry rate from 2017-2021.

These are the NAICS Codes that will fall under the NEP:

491110 Postal Service (Processing & Distribution Centers only)
492110 Couriers and Express Delivery Services
492210 Local Messengers and Local Delivery
493110 General Warehousing and Storage
493120 Refrigerated Warehousing and Storage
493130 Farm Product Warehousing and Storage
493190 Other Warehousing and Storage

The following warehouse-type retail stores are included because they have been found to have issues in loading and storage areas and have higher than average DART (Days Away; Restricted; Transfer) rates:

444110 Home Centers
444130 Hardware Stores
444190 Other Building Material Dealers
445110 Supermarkets and Other Grocery Stores
452311 Warehouse Clubs and Supercenters

This retail list will change each calendar year based on which related establishments have the highest DART rates.

What Will Inspectors Look For?

Inspectors will be looking at these program areas:

Powered Industrial Vehicles (already an emphasis program in several regions)
Material Handling and Storage
Walking-Working Surfaces
Means of Egress
Fire Protection
Heat (already a National Emphasis Program)
Ergonomic Hazards

For heat, inspectors will review injury and illness records, ask about it during worker interviews, and look for these in the walkthrough. If inspectors see exposures to heat-related hazards or if they find your NAICS code already falls under the Heat NEP, they will expand the scope of the inspection to include the Heat NEP. Read more about what that inspection entails here. Heat is a big emphasis right now with OSHA because it helps them meet their responsibilities in complying with the Presidential directive on climate change.

If inspectors see ergonomic hazards in their reviews of records, worker interviews and the walkthrough, they can also expand the scope to ergonomics and open a health inspection in addition to the safety inspection.

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iSi can help answer questions you may have about this NEP or any others, as well as conduct a mock OSHA inspection to see where you stand if OSHA were to conduct this inspection at your facility today. Contact us!

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OSHA Issues Final Rule Which Updates Electronic Injury and Illness Reporting, Adds Industries and More Requirements

Jul 21, 2023

OSHA has issued a final rule changing some of the requirements for electronic injury and illness reporting, adding some new companies and increasing some of the reporting requirements.

What’s New

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

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

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

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

See Appendix A Here

See Appendix B Here

Industries Moved from Appendix A to Appendix B

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

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

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

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

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

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

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

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

Jun 23, 2023

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

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

Seat Belts

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

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

Attachments

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

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

Legible Markings

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

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

Training

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

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

Usage

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

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

Inspections and Repairs

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

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

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

Seat Belts

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

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

Attachments

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

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

Legible Markings

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

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

Training

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

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

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

Usage

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

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

Inspections and Repairs

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

By the Numbers

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

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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.

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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.

***Haz*mat**

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.

***Haz*Com**

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.

***Haz*ardous 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.

***Haz*ardous 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.

***HAZ*WOPER**

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:

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;
Operations at treatment, storage and disposal facilities (TSD) regulated by EPA RCRA; and,
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

Apr 21, 2023

environmental-pollution-industry-exterior-daylight

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:

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.

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.

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

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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What Will Inspectors Look for in Combustible Dust Inspections?

Mar 17, 2023

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

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

How Will OSHA Determine Who Gets Inspected?

First, will you be on the target list?

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

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

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

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

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

History of Fires and Explosions

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

Safety Data Sheets (SDSs)

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

Electrical Area Classification Drawings/Documents

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

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

Dust Hazard Analysis

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

They’ll be looking at:

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

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

Control and Suppression Systems

Inspectors will be looking to ensure:

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

Sampling Results

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

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

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

Other Documentation

Inspectors will be gathering all kinds of other information including:

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

What are Some Potential Standards You Could be Cited Under?

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

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

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

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

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

General Duty Clause – Section 5(a)(1)

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

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

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

Ventilation – 29 CFR 1910.94

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

PPE – 29 CFR 1910.132(a)

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

Hazardous (Classified Locations) – 29 CFR 1910.307

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

Powered Industrial Trucks – 29 CFR 1910.178

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

Welding, Cutting and Brazing – 29 CFR 1910.252

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

Warning Signs – 29 CFR 1910.145

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

Hazard Communication – 29 CFR 1910.1200

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

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

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

Others and Specialty Standards

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

Do you need help with combustible dust? iSi can help with programs, audits and hazard assessments, sampling, PPE determinations, training and more. Contact us today!

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OSHA Updates Its Combustible Dust National Emphasis Program

Mar 10, 2023

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

What Are Combustible Dusts?

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

Some typical combustible dusts include:

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

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

Affected Industries

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

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

Through its inspections since 2007, OSHA found:

The Top 5 Industries with the Most Combustible Dust Hazards

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

The Industries With the Most Fatalities and Catastrophes:

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

New Industries Added to Appendix B to Be Inspected

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

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

Industries Removed from Appendix B

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

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

How Will OSHA Determine Who Gets Inspected?

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

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

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

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

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OSHA Injury Posting Requirements

Jan 30, 2023

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

Posting Injury and Illness Data

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

Electronic Submittals to OSHA

osha injury reporting recordkeeping compliance chart for 2023

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

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

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

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

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

What’s Recordable, What’s Not?

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

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EPA Issues Changes to 6H NESHAP for Paint Stripping & Surface Coating

Dec 1, 2022

EPA has issued Final Rule updates to 40 CFR Part 63, subpart HHHHHH, the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources. This NESHAP standard applies to companies coating miscellaneous parts/products made of metal, plastic or a combination, anyone stripping paint using methylene chloride, or conducting motor vehicle/mobile equipment refinishing.

EPA issued the changes as part of its technology review. They didn’t find any new developments in practices, processes or controls that warranted changing existing rules, but they did decide to take the opportunity to update and clarify some of the items in the current requirements.

Here is a summary of what has changed in the regulation:

Electronic Reporting

Rather than mailing reports to EPA, you will now be required to be submit electronically through the CEDRI/CDX platform. This includes initial notifications, notifications of compliance status changes, annual notification of changes reports and the report required in 40 CFR 63.11176(b).

HAP Content

EPA updated the definition of a “target HAP containing coating” to clarify that compliance is based on the hazardous air pollutant (HAP) content of the coating applied to the part, not the content purchased.

Spray Gun Cups and Liners

For spray guns with disposable cap liners, EPA amended “spray-applied coating operations” to clarify that the allowance to use spray guns outside of a spray booth is based on the volume of the spray gun cup liner, not volume of the cup itself. They also clarified that repeatedly refilling and reusing the 3.0 fl. oz. cup or cup liner, and/or using multiple liners for a single spray-applied coating operation will be considered trying to circumvent the regulation and you can be fined for this.

Exemptions Became Easier

If motor vehicle/mobile equipment spray coating operations don’t spray apply coatings that contain the target HAP, rather than the current petition for exemption process, the rule now allows companies to submit notifications to the Administrator. This process is meant to be simplified and easier. All records to support the notification shall still be kept as a backup to support the notification, but those records don’t need to be sent to the administrator.

Military Equipment: Tanks and Submarines

The NESHAP no longer applies to surface coating or paint stripping on tanks and submarines when that work is conducted onsite at military installations, NASA, or at the National Nuclear Security Administration. It also doesn’t apply when conducted offsite where military munitions or equipment are manufactured by or for the Armed Forces and that equipment is directly and exclusively used for the purposes of transporting military munitions.

OSHA Carcinogen References

EPA removed references to OSHA’s carcinogens because OSHA no longer spells out what those are. Instead, EPA will be putting in their own list. These will include target HAPs that must be counted if they’re present at 0.1% by mass or greater. All other HAPs will be counted if present at 1.0% or greater by mass.

No Non-HAP Solvents

The term “Non-HAP solvent” will be removed because there’s no requirement in the standard to use them and there is no other place where this is used.

Filter Test Method

EPA updated the spray booth filter test method to the most recent ASHRAE method, ANSI/ASHRAE Standard 52.2-2017 Method of Testing General Ventilation Air-Cleaning Devices for Removal Efficiency by Particle Size. The standard also now includes a reference to EPA Method 319-Determination of Filtration Efficiency for Paint Overspray Arrestors as an alternative method. EPA Method 319 is the same one referenced in the NESHAP for Aerospace Manufacturing and Rework to test paint spray booth filters for hexavalent chromium emissions.

For more information about changes to the rule, you can find the final rule in its entirety here.

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Chemical Hygiene Plan: What You Need To Know

Nov 25, 2022

What is a chemical hygiene plan?

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

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

What are the objectives of a chemical hygiene plan?

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

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

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

What should a chemical hygiene plan include?

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

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

What does a chemical hygiene officer do?

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

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

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

What is the OSHA chemical safety plan?

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

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

What is the OSHA laboratory standard for chemical exposure?

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

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

What are the 10 steps to chemical safety?

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

The first step to chemical safety is to identify potential hazards by reviewing the Material Safety Data Sheet (MSDS). The MSDS includes detailed information about the properties of a given chemical, including its health hazards, protective measures, and emergency response information.
The second step is to use the right personal protective equipment (PPE) when working with hazardous materials. This may include safety glasses, respirators, gloves, lab coats, and other items that are necessary for safe handling of chemicals.
Thirdly, it’s important to keep all containers of chemicals labeled and sealed properly. Labels should include the name of the chemical, concentration, date prepared, and appropriate hazard warnings.
The fourth step is to practice good housekeeping in the lab or work area by keeping all areas clean and free from debris that might contaminate products. All spilled materials must be removed from the work area as soon as possible.
The fifth step is to make sure that all employees are trained on the proper handling of chemicals in their work area. This includes understanding how to use protective equipment and safety measures to reduce exposure.
The sixth step is to provide good ventilation in the lab or work area. Poor ventilation can increase exposure to hazardous materials, so it’s important to keep areas well-ventilated.
Seventhly, emergency equipment should be readily available in case of an incident. This includes items like fire extinguishers, eye wash stations, and spill kits to contain hazardous materials.
The eighth step is to create a culture of safety by ensuring that all employees are aware of the dangers associated with handling hazardous materials. All workers should understand the proper safety procedures, and regular training should be conducted to reinforce these procedures.
The ninth step is to monitor employee exposure levels by providing personal protective equipment and conducting periodic air quality tests. This will help ensure that all workers remain safe while working with hazardous materials.
Finally, the tenth step is to document all safety measures taken in a detailed hazard assessment report. This report should include a description of the potential hazard, control measures taken to limit exposure, and any additional safety precautions that were implemented.

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

What are 4 hazardous chemicals?

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

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

What are the five rules of chemical safety?

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

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

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

What is a common hazardous chemical in healthcare?

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

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

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

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

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

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

What are 5 top laboratory hazards?

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

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

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

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

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

What are the 10 lab safety rules?

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

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

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

How often should a workplace or laboratory chemical inventory conducted?

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

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OSHA Considering Changes and Updates to the PSM Standard

Nov 17, 2022

OSHA Considering Changes and Updates to the PSM Standard

Name: iSi Environmental
Address: 215 S. Laura, Wichita, KS, 67211, US
Telephone: (316) 264-7050

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

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

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

Potential changes to PSM could include:

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

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

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

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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?

Process Safety Information
Process Hazard Analysis
Operating Procedures & Safety Procedures
Hot Work Permits
Emergency Preparedness & Emergency Shutdown Systems
Mechanical Integrity
Pre-startup Safety management
Training Management
Change Management
Incident Investigation
Contractors
Compliance Audits and Compliance evaluations
Employee Involvement and Employee Safety
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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Do you need an idea of where you stand with EPA or OSHA regulations? Do you need full-time or temporary personnel to manage the day-to-day compliance tasks? Would your employees benefit from onsite environmental training? Our team of environmental consultants, safety consultants and industrial hygienists would love to help. Call (316) 264-7050 today!