What OSHA Says About Using Online Safety Training Courses

Nov 21, 2019

OSHA's opinion on online safety training

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

Now…on to the article.

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

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

OSHA’s Opinion of Online Safety Training

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

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

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

Ability to Ask Questions

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

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

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

Where to Find These Interpretations

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

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

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

Aug 29, 2019

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Robot Safety Evaluations

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

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

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

Laser Guided Vehicles

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

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

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

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

Demolition Robots

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

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

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

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

NIOSH is Looking for Case Studies

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

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

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The 3 Most Important Elements of a Good Safety Program

Aug 14, 2019

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

Management Leadership

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

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

Worker Participation

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

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

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

Finding and Fixing Hazards

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

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

So How Do You Get It All Accomplished?

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

For example, iSi can assist with:

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

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The Importance of Professional Organizations and Conferences to Your EHS Compliance

Oct 12, 2018

About the Author: Tami Hadley, iSi’s Marketing Director, has been involved in numerous professional organizations as a member and leader and has served on conference planning committees for over 23 years.

Fall is a busy time for iSi as there are a number of environmental, health and safety (EHS) conferences and professional organizations we’re involved in. At a recent conference, I was reminded how important getting out to these events can be to an EHS professional’s job.

Although EHS professional groups and conferences have one big difference, that being the frequency in which they are held, they are quite similar in their advantages.

Stay Current on Regulations

Although you may subscribe to the Federal Register, blogs and newsletters, how often do you read them? Are you looking at all of them all the time? Do your sources encompass all aspects of EHS compliance that your company is required to follow?

It’s super easy to miss something. Professional groups and conferences allow you direct access to new information and discussion about upcoming regulations. Often the regulators themselves will be the speakers and will give you some extra insight into new regulations, what has changed and why, what’s on the horizon, and what the compliance nuances are. The regulators are also there to answer your questions.

Meet People Who Have the Same Issues You Do

One of the most valuable things about conferences and meetings are the people you’ll meet. At your company you may be the only person responsible for EHS, and perhaps that can be a lonely feeling sometimes. However, you are not alone. There others in your area who are in the same boat as you are. They can help and give you advice.

Besides commiserating with you, they can give you ideas on how to solve issues, can tell you what works for them, and who the good vendors are. I’ve seen people share templates and programs with each other, visit each other’s facilities, discuss what’s working for them, and share training classes with each other.

Connecting and Recruiting

Making connections can be very valuable. One of the number one keys to making a connection is bringing value and sharing value because what you are able to give often comes back to you multiple times over. Goodwill begets goodwill. The people that you meet can introduce you to people they know who may be able to give you information or recommend a solution or a vendor. It’s the old adage, it’s not what you know but who you know.

Are you looking for good employees to help you at your facility? These events are great for determining potential candidates and seeing who the most respected and knowledgeable professionals in the area are. You may not need someone now, but having an idea of who is in the area and having them know you will save you a ton of time later. Conversely, it’s a chance for you to highlight your expertise as well. If you are new to the industry or to your job, a group like this can expose you to a lot of different topics and help you learn a lot of things you may not get otherwise.

Unplugging is a Good Thing

Besides the list of tasks we’re expected to accomplish each day, we are inundated by phone calls, emails, texts, persons coming by, fires to put out, etc. The day-to-day grind can really get in the way of continuing education. How many times have you been in a training class at your site and have gotten pulled out for some reason, or have been watching a webinar at your desk only to get interrupted by someone coming in your office or calling you?

Getting offsite for a day or two, or even for a lunch or a breakfast, sets aside a time for you to get your focus back onto learning something new. Even if the speaker doesn’t teach you something new, the time away to immerse yourself in the topic may jolt some new ideas because you’ve had the time to unplug from the clutter and focus on the topic at hand.

It’s OK to Sit by a Vendor

Don’t discount the value of vendors and suppliers. Sure, it’s most likely they are there to make connections, but these people can be some of your biggest sources of information and intelligence in all things EHS. Vendors and suppliers will often have some of the latest and greatest in compliance technologies, methods, best practices, products, apps, etc. You may not need them now, but having them there gives you an idea of who you can call when you need something.

Vendors can also tell you a lot about what companies like yours are doing, how problems have been solved by others and what is going on in the industry. It’s also their job to know who the EHS people are in your area and so they can also be great connectors for you. They go to a variety of events, so you may learn about other specialty groups and conferences and opportunities you didn’t already know about.

List of Organizations

I want to be a valuable connection for you, so below is a list of professional organizations which focus on EHS issues and may have chapters in your area. In addition to these organizations, look for other local groups in your area which are not affiliated with national chapters. There are a lot of them out there.

For conferences, I’ve seen that almost every state has a safety conference and an environmental conference. Sometimes they are combined or sometimes they are conducted within other conferences.

I can give you some specific ideas for groups and events in and around the areas in which iSi has offices: Kansas (state of Kansas and Kansas City area), Oklahoma, Georgia and surrounding states. Contact me and let me know which area(s) you’re interested in and I’ll get back with you with some ideas. In the meantime, here are some national organizations with chapters all across the U.S.:

American Society of Safety Professionals (ASSP)

American Industrial Hygiene Association (AIHA)

Alliance of Hazardous Materials Professionals (AHMP)

National Safety Council (NSC)

Air and Waste Management Association (AWMA)

Which national EHS organizations am I missing? Let me know and I’ll add them to this article!

Did we miss a national EHS group? Are you looking for groups and conferences in your area? Contact us today!

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Overheul to Discuss Link Between Safety Prequalification and Sales

Sep 28, 2018

Photo of James Overheul from iSi Environmental

James Overheul
iSi Manager of Safety & Industrial Hygiene

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

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

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

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

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

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

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iSi Discusses Safety at Petroleum Packaging Council National Meeting

Mar 5, 2018

James Overheul
iSi Project Manager

iSi Project Manager James Overheul presented “Manufacturing Plant Safety and the Downstream Impact on Sales” at this year’s Petroleum Packaging Council national conference and tradeshow.

Company safety and injury statistics are increasingly becoming a tool for companies when choosing the vendors and suppliers they want to work with. Safety is now looked at in pre-qualification reviews, annual contract updates, in publically-available data, and in other locations. Now more than ever, your company’s safety record can affect your bottom line not only from the impact of worker’s compensation, but in being chosen as a supplier in the first place. In this presentation, James explains what manufacturers need to look for, which statistics are most important and what they can do to improve their record.

This year’s Petroleum Packaging Council was in Tampa, Florida from March 4-6.

If you’d like to book one of iSi’s safety or environmental professionals for an upcoming conference, seminar or event, email us or give us a call at (888) 264-7050.

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

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Ensure Safety Incentives Promote the Positive

Mar 25, 2017

OSHA Electronic Reporting Rule Adds Language About Disincentivising Employees From Reporting

Another piece put with OSHA’s recent final rule regarding electronic injury/illness submittals was some additional language and safeguards to protect workers from deterrence in reporting injuries.

Ensure your safety incentive and discipline programs do not deter or discourage employees from reporting injuries and illnesses. OSHA still will allow incentive programs, but want to make sure employers know that they must be structured in a way that does NOT discourage workers from reporting injuries.

Incentive programs which withhold or deny a benefit because an employee reported an injury are illegal. These could include those which disqualify or withhold rewards from the person reporting or a whole group of workers if an injury is reported. Discipline programs which punish workers who report injuries regardless of fault is also not allowed, as is making the reporting process so cumbersome and/or filled with paperwork that it becomes easier for the employee not to do it. OSHA says you can still have incentive programs, but instead, opt for positive incentive programs which promote worker participation in safety-related activities.

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