iSi’s Top 12 General Industry Safety Audit Findings

iSi’s Top 12 General Industry Safety Audit Findings

Safety regulations are enforced by OSHA, and in some states such as California and Indiana, by a state safety agency. How do you make sure you have your bases covered? A safety audit can determine your current status and what your vulnerabilities are. iSi’s general industry safety audits are conducted like a mock OSHA inspection for the 29 CFR 1910 general industry regulations. There is a wall-to-wall walkthrough, a records review of written programs, training programs, and past inspections, and interviews with employees.

Some of the below cited items start in the OSHA regulations, but detailed actions are prescribed by other regulations such as the National Fire Protection Association (NFPA) or American National Standards Institute (ANSI) Standards. Others are based on items we see our clients cited for in OSHA inspections which we have added to our audits.

The following are our top 12 specific findings we see most when we do our general industry safety audit.

12. Safety Showers and Eyewash Stations

Facility safety showers and eyewash stations are not being inspected on a regular basis.  1910.151(c) discusses suitable facilities, but ANSI standard Z358.1-2014 specifies weekly visual inspections of both showers and eyewash stations.

11. Lifting Slings

We find that often there is no formal program in place to conduct a periodic inspection of all lifting slings. This must be conducted annually. 1910.184 includes guidance on the use of slings and item (d) covers inspections.

10.  Machines

At number 10 is fixed machines. We find fixed machines are not securely mounted to the floor or the bench top to prevent them from “walking.” 1910.212 is the standard for all machines and machine guarding. Item (b) covers the anchoring requirements.

9.  Personal Protective Equipment (PPE)

PPE evaluations and hazard assessments must be conducted for each task. We find that these are either not conducted or not documented. The potential for workplace hazards must first be assessed and if PPE is needed, PPE must be selected, communication decisions must be communicated to affected employees and PPE must be fitted to each employee.

A written certification must be created which identifies the workplace evaluated, the person certifying the evaluation, the date the assessment was conducted, and signification that the document is a certification of hazard assessment.

These rules are found in 1910.132(d).

8. Fire Extinguishers

Are your fire extinguishers mounted too high, not mounted at all or are they blocked from access? 1910.157(c) is the standard which covers this issue.

7.  Emergency Lighting

Emergency lighting, in many locations, is not being tested every 30 days for 30 seconds or for 1.5 hours annually. Lighting can be found in Subpart E, Means of Egress, Maintenance, Safeguards, and Operational Features for Exit Routes, 1910.37(a)(4) and the NFPA 101 Life Safety Code 7.9.3.1.

6.  Lamps

We find that lamps less than 8 feet from the floor are not protected from accidental contact. Lamps need to be guarded and protected from accidental contact. This can be found in 1910.305(a)(2)(ix). Although a particular height requirement is not specified in this regulation, you should consider the reach of your tallest employees and length of the parts and/or tools being used in the area.

5.  Forklifts 

We see many issues with forklifts. The most common issue we find with forklifts no documentation of daily inspections, or no inspections being conducted. However, more recently we have been seeing issues with employees not wearing seatbelts, controls where the labeling has worn off, the use of non-factory attachments, and not updating data plates, tags and decals with revised capacity, and operation and maintenance data. Forklift standards are found in 1910.178.

4.  Grinder Wheels 

Machine guarding issues are a common item we see. One of the most prevalent ones relates to grinder wheels. The gap between the grinder wheels and the work rest plate should not be more than the maximum allowed 1/8 inch. The adjustable tongue guards shouldn’t be more than the maximum allowed 1/4 inch from the tongue guard. These regulations can be found in Subpart O, Abrasive Wheel Machinery, 1910.215(a)(4) and (b)(9).

3.  Electrical Panels 

With electrical panels, we often see the minimum required areas of clear space around the panels is not being maintained. Sufficient access must be maintained for safe operation, access, and maintenance. The rules, including a distance chart to help you determine proper clearances can be found in Subpart S, 1910.303(g).

2.  Hazard Communication

Within the hazard communication (hazcom) standard, there are requirements for secondary containers. We find many secondary containers of hazardous chemicals are not labeled correctly or have illegible writing on them. The regulation comes under the “labeling” section of 1910.1200. All containers, either primary or secondary, need to be labeled and contain product identifier and words, pictures, symbols or a combination of them. Portable containers, that is, containers you transfer chemicals to and intend for immediate use are not covered by this requirement.

1.  Access to Medical Records

The number one item we find in our audits relates to access to medical records. Employees are required to receive information on their access to medical records. This is required initially upon hire, and then annually thereafter. The regulations can be found in 1910.120(g)(1). Included with this requirement is notifying employees the existence, location and availability of records covered by 1910.120, the person responsible for maintaining and providing access to records, and each employer’s rights to access those records. As an employer, you need to keep a copy of 1910.120 and its appendices and make copies readily available, upon request, to employees.

This information can be covered within your annual training classes, or can be a written notice of information in an email, or a memo that is posted with your OSHA logs and other OSHA-required notices. The important part is that you document that you completed this requirement and how.

Where Do You Go From Here?

iSi can help you get a baseline on your safety compliance status by conducting a walkthrough. From there, we will create a matrix of issues we see with the corresponding regulatory standard. We can also help you prioritize the ones which are most critical to be taken care of.

Request a quote for a general industry safety audit today! Need more information about these issues?  Contact us at (888) 264-7050 or email us!

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Warehouse Inspection Checklist

Warehouse Inspection Checklist

Why is warehouse safety important?

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

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

How to use a warehouse safety checklist?

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

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

What should be checked during warehouse safety inspections?

Forklifts:

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

Docks and Dock doors

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

Material Storage

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

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

Charging Station

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

Chemicals

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

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

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

Person lifting or handling

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

Security System

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

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

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

Fencing

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

Employees

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

What are the most common warehouse safety hazards?

Fire Safety

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

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

Falls

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

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

Heavy machinery

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

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

Trip hazards

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

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

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

Overexertion

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

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

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

Falling objects

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

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

Lack of Awareness

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

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

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

How do warehouse inspections work?

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

Conclusion:

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

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

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

Where Do You Go From Here?

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

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Sustainability Software

Sustainability Software

Sustainability software is a powerful tool for businesses and organizations that are looking to become more sustainable and reduce their carbon footprint. This type of software collects data on energy usage, waste disposal, water consumption, and other environmental factors in order to measure the sustainability performance of an organization or business.

It can provide detailed reports showing which areas need improvement as well as suggest ways to reduce emissions and optimize resource use. By collecting this data, companies can set goals and reach them with greater accuracy and efficiency than ever before.

With sustainability programs, organizations have the power to make a real difference in the world around them while also saving money in the long run by reducing their energy costs. In short, it’s a win-win proposition for everyone involved.

Sustainability software is an important tool in the fight against climate change. By taking a more holistic view of sustainability, companies can make decisions that will benefit everyone – from individuals to corporations, and even entire nations.

The data provided by these solutions helps organizations and businesses understand where they stand with regards to their ESG goals and objectives, while also providing them with the tools they need to achieve their desired results. With the right software in place, organizations are well on their way towards making sustainable progress for years to come.

What is Sustainability Software?

Sustainability software is a type of technology that helps organizations reduce their environmental footprint. It provides tools and resources for companies to track, monitor, and improve the sustainability performance of their operations. By utilizing data-driven insights, businesses can make informed decisions about how to reduce waste, increase energy efficiency, and ultimately create a sustainable future.

Sustainability software also helps organizations stay in compliance with regulatory bodies by providing visibility into their current eco-friendly initiatives. With this kind of software available, it’s never been easier for businesses to make meaningful changes toward creating a more sustainable world.

10 sustainability management software providers to consider:

  1. IBM

  2. Metrio

  3. Microsoft

  4. FigBytes

  5. Ecometrica

  6. Benchmark Digital Partners

  7. Diligent ESG

  8. OneTrust

  9. Persefoni

  10. SAP

Sustainability and ESG Data & Reporting

Sustainability data and ESG (Environmental, Social, and Governance) data are an increasingly important part of corporate responsibility. Companies are now under pressure to demonstrate their commitment to upholding the highest standards of ethical conduct in all of their operations. As a result, sustainability reporting and ESG reporting have become key components of effective corporate governance.

Companies must be able to clearly articulate the steps they are taking to reduce their environmental impact, address issues related to employee welfare, or improve governance structures. By doing so, companies can help ensure that stakeholders have faith in their commitment to responsible business practices and set themselves up for long-term success, especially with ESG and sustainability reporting.

Not only does this type of reporting help ensure that a company is adhering to best practices but it also helps them stand out in the market and attract more customers. In today’s globalized economy, businesses must prioritize sustainability reporting and ESG reporting if they want to thrive in an ever-changing landscape. These should act as your company’s reporting solutions which will generate reports that drive data reliability and sustainability goals.

Key features in sustainability management software

Sustainability management software is designed to help businesses and organizations track, measure, and manage their sustainability efforts. The key features in this type of software include data collection capabilities, reporting metrics tools, visualization dashboards, risk analysis tools, and integration with other systems.

Data collection allows organizations to collate information from numerous sources including internal business operations, external environmental sources, and more. Reporting metrics provide insights into the organization’s sustainability performance and how it can be improved.

Visualization dashboards allow users to easily comprehend complex data in an interactive format. Risk analysis tools offer more sophisticated insights into potential risks associated with a business or organization.

Lastly, integration with other systems allows for seamless integration of various data sources and a unified view of sustainability performance. With all these features, organizations can better understand the impacts of their sustainability initiatives and how to improve them.

Benefits From Professional Sustainability Management Solutions

Leading sustainability software providers can help businesses achieve their environmental and social objectives, as well as reduce costs. These solutions provide businesses with tools to improve their efficiency and reduce energy consumption, thus reducing their carbon emissions and overall carbon footprint.

Additionally, by understanding the impacts of their operations and taking appropriate action, businesses are able to increase the value of their products or services more sustainably. Furthermore, sustainability management solutions can help businesses with their public relations, as they demonstrate a commitment to social responsibility.

With Metrio sustainability reporting software, you can easily collect, analyze, disclose, report and communicate your ESG data. Our software enables organizations to compare and save data in a centralized platform, enabling better decision-making and improved corporate sustainability performance.

Finally, by understanding the current and potential impacts of their operations, businesses can create positive relationships with stakeholders by implementing responsible strategies for long-term sustainability which ultimately empowers organizations.

Sustainability Progress – The Need is High, But Progress is Slow

Sustainability Progress is an integral part of achieving a more sustainable global future. It involves making changes to our lifestyles, businesses, and communities that promote environmental responsibility and long-term economic growth.

Through setting and monitoring progress goals with specific targets, companies can track their own performance while demonstrating commitment to corporate sustainability objectives. Stakeholders are able to assess and evaluate a company’s commitments to sustainability, enabling better decision-making and improved corporate transparency.

Net-Zero Emissions Targets are a Top Priority

Net-Zero Emissions is an important concept in the global effort to reduce greenhouse gas emissions and prevent further climate change. This goal seeks to achieve a balance between releasing carbon into the atmosphere and removing it from the atmosphere by using strategies such as renewable energy production, carbon accounting, energy efficiency measures, and carbon capture and storage technologies. This can help campnys measure and manage their portfolio exposure to climate risks and financed emissions as they navigate the risks and opportunities in the net-zero transition.

The ultimate aim is for society to reach a point where the level of greenhouse gas emissions released is equal to the amount that is taken out, thus creating a cycle of zero net emissions. Emissions management software can help achieve this goal.

Tackle your Scope 3 Challenge

As with any challenge, the first step to success is understanding the problem. When it comes to tackling Scope 3 emissions, this means gaining an in-depth knowledge of your business’s sources of emissions and the different strategies you can use for reducing them. Once you have a clear picture of what needs to be done, you can start mapping out your Scope 3 emissions reduction plan, taking into account all of the relevant stakeholders and resources.

Ultimately, as part of a good sustainability strategy, you’ll need to develop a comprehensive action plan for reducing emissions, based on the best practices for energy efficiency and low-carbon operations. Setting targets and timelines will help you stay focused and motivated towards achieving your goals.

Finally, consider how you can collaborate with other companies in order to share expertise and resources, which will make it easier to reduce emissions across your entire supply chain. With careful planning and commitment, you can make strides towards meeting your Scope 3 emission reduction objectives.

Are you ready to start your Corporate Sustainability journey?

Our team of experts can help you with whatever compliance issues you may be facing. Whether it is understanding the complexities of a given regulation or recognizing where your company needs to improve, we have the necessary skills and experience to provide assistance. We will take the time to understand your unique needs and develop tailored solutions that address those needs. For facilites looking for help navigating the often perplexing regulatory landscape, contact us today!

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Health and Safety Checklist: What You Need To Know

Health and Safety Checklist: What You Need To Know

What is a safety checklist?

Safety inspection checklists are an important part of any safety inspection program. By using a safety checklist, safety professionals can identify potential hazards in the workplace and take steps to mitigate those hazards.

Each workplace has its own set of unique hazards, and it is essential that health and safety professionals be able to select the appropriate checklist for their specific workplace in order to ensure full compliance with all applicable safety standards.

There are a wide variety of OSHA-approved checklists available for use by safety professionals, and each checklist is designed for a specific industry or application. Some of the most common types of checklists include: chemical processing, electrical work, construction, maritime operations, and agricultural operations.

What should be included in safety inspection checklists?

Housekeeping inspection:

Maintaining a clean and healthy work environment is essential for the safety of employees. A housekeeping inspection checklist can help employers ensure that their workplace health is up to code with regard to health and safety regulations.

The checklist contains a variety of items related to cleanliness, sanitization and personal protection practices, which can be applied to a range of industries. Professionals may use the checklist to maintain a particular level of health regulation on their work site. The housekeeping inspection checklist may be especially helpful for those professionals working in food services, healthcare and manufacturing industries.

Self-inspection for general industry:

Safety checklists are a critical component in any workplace for any company. No matter what industry you work in, it’s important to have a safety checklist to make sure you are adhering to all the necessary safety standards. In some industries, such as construction, there are more regulations in place that dictate what safety measures must be taken.

However, in other industries, such as general industry, there may be less regulation and workers may not be as familiar with safety best practices. That’s why it’s important for every workplace to have their own self-inspection checklist tailored to their specific industry.

One great resource for creating a self-inspection checklist is the General Industry Safety Standards Checklist from OSHA. This checklist includes a wide variety of items that should be checked for safety compliance in general industry workplaces. Some of the items are similar to those found on the construction self-inspection checklist, but there are many more general items included as well. Having this comprehensive list available can help professionals ensure that their workplace is safe for employees.

Self-inspection for construction:

Construction workers have one of the most dangerous jobs in the world. Every day, they face potential injuries from heavy equipment, falling objects, and hazardous materials. In order to minimize these risks, construction companies have safety protocols in place that employees are required to follow. A large part of following safety protocol is having a well-organized and comprehensive safety checklist.

The purpose of this safety checklist is to provide a comprehensive overview of all the items that should be considered when implementing a health and safety plan for a construction site. Not every item on this list will apply to every work site; instead, it is meant as a general guide for safety management on construction projects. Some of the topics covered by this checklist include: personal protective equipment (PPE), first aid kits and supplies, fire prevention, and chemical handling.

Each section of the document contains specific details about what needs to be done in order for employees working on the construction area to stay safe. It is important for both management and employees alike to familiarize themselves with this checklist so that everyone understands their role in keeping everyone safe while on the job site.

Personal protective equipment (PPE) inspection:

The PPE inspection checklists are comprehensive resource that can help professionals identify potential hazards in the workplace. The checklist contains a variety of items, including those that relate to compliance with providing, maintaining, using and updating equipment that protect employees from occupational hazards such as safety glasses, gloves, and suits for proper ventilation.

While many industries use the PPE safety inspection checklist in conjunction with others, it is an important tool for workplaces looking to provide employees with additional protection from potential risks.

Electrical inspection:

It’s no secret that electrical safety is a critical issue in many industries. In fact, electrical accidents are one of the leading causes of workplace fatalities in the United States. The electrical inspection checklist is a valuable resource for professionals in any field who want to ensure the safety of their employees and coworkers.

The electrical inspection checklist pdf includes organization, exposure, consistency, any potential explosive, hazardous substances and chemicals. Some of the most important items on the list include guidelines for proper storage of materials and ensuring that electrical infrastructure is up to code and having fire extinguishers on hand. By following these guidelines, professionals can rest assured knowing that they have done everything possible to create a safe work environment.

Truck safety inspection:

It’s no secret that vehicular accidents can cause serious delays, not to mention fatalities. What may be less known is the fact that many of these accidents could be mitigated with a simple safety inspection checklist.

Professionals in transportation and supply management industries can use this checklist to maintain the safety of long-haul and delivery vehicles. The checklist includes items that relate to the evaluation and maintenance of a vehicle’s viability and condition, which may help identify potential mechanical issues for repair and maintenance. Ultimately, this may mitigate accidents, incidents, and transportation delays.

Fall protection:

The Fall Protection Safety Inspection Checklist is a comprehensive document that covers all the necessary items related to fall protection. The checklist can be used by professionals in various industries, but is especially beneficial for construction workers who navigate high scaffolding and elevated structures on a daily basis.

The checklist contains specific sections for Fall Arrest Systems, Fall Restraint Systems, Fall Prevention Plans, and more. Each section includes a variety of tasks or steps that should be completed in order to ensure safety. Areas to focus on are floors, stairs, platforms, storage in facilities, and more.

What is a risk assessment?

Risk assessments are critical process in ensuring the safety of people, property, and the environment. By identifying hazards and assessing the risks associated with them, Risk assessors can develop mitigation plans to control or eliminate potential dangers. While Risk assessment is often thought of in terms of industrial or workplace safety, it is also an important tool for personal safety and security.

What are the 5 things a risk assessment should include?

  1. Identifying hazards and potential hazards
  2. Assess all risks including situational
  3. How to control and manage the risk
  4. Record your findings and outcomes
  5. Review and maintain controls

What are safety records?

‘Safety records’ or reports are documented occurrences of the safety management processes and activities, safety recommendations, related remedial actions and their follow-up.

What type of records are required for health and safety checklist?

OSHA Form 300, OSHA Form 300A, and OSHA Form 301.

Conclusion:

Inspections are important. It is widely accepted that safety checklists are an important part of any safety inspection program. A well-constructed safety checklist can help safety professionals identify potential hazards in the workplace and take steps to mitigate hazards. However, not all workplaces are the same, and it is essential that health and safety professionals be able to select the appropriate checklist for their specific workplace in order to ensure full compliance with all applicable safety standards.

How can we help you?

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

Call (316) 264-7050 today!

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Personal Protective Equipment (PPE): The Basics

Personal Protective Equipment (PPE): The Basics

What is Personal Protective Equipment (PPE)?

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

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

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

What different industries require PPE?

Transportation

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

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

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

Chemical

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

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

Food

  • Gloves
  • Safety glasses
  • Face shields
  • Hairnets

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

Healthcare

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

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

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

Oil and Gas

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

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

Automotive

  • Peripheral safety goggles
  • Cut-resistant gloves

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

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

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

Construction

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

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

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

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

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

Manufacturing

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

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

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

What are some examples of PPE?

Masks and Respiratory Protective Equipment

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

Protection for the Face and Eyes

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

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

Head and Shoe Protection

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

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

Gloves

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

What is required for OSHA standards for PPE?

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

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

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

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

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

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

Why do you and your employees need PPE?

  1. Liability

  2. Long-term issues

  3. Keep what you got!

  4. Increase quality work environments

Conclusion:

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

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

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Laboratory Safety Checklist

Laboratory Safety Checklist

What You Need To Know:

What is a safety audit checklist?

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

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

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

What should be included in a lab safety checklist?

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

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

What are the 5 major areas of lab safety?

Cuts:

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

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

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

Toxic fumes:

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

Skin Absorption of Chemicals:

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

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

Explosions and fires:

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

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

Chemical or thermal burns:

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

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

What are the major overlooked lab safety issues and hazards?

Ergonomic safety:

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

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

Laboratory waste disposal:

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

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

Dress code safety:

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

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

Proper labels:

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

Record of an incident:

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

Conclusion:

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

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Trailer Safety

Trailer Safety

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

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

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

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

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

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

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


What is OSHA’s NEP on Heat Hazards?

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

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

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

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


What are the Targeted High-Risk Industries?

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

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

These include but are not limited to:

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

NAICS Code        NAICS Industry Sector Title

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

Construction Industries That are Likely to Have Heat-Related Hazards

NAICS Code        NAICS Industry Sector Title

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

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

NAICS Code        NAICS Industry Sector Title

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


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

During heat-related inspections, inspectors will:

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

How Can You Prevent Heat Illness at Work?

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

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


Need Help in Getting Your Documentation in Order?

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

 

Contributing:

Keith Reissig

Industrial Hygienist | Project Manager

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

Email  |  LinkedIn

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Fall Protection for General Industry

Fall Protection for General Industry

OSHA annually has a Stand Down for Falls in Construction.  If your company is not in construction, but in general industry, this is a good time to review fall protection issues at your own facility.  Falls can occur anytime you have workers at heights regardless of the type of work they are doing.  Here are some tips to remember for general industry:

  • In general industry, the rule for fall protection is that it’s needed when you’re at or above 4 ft. or when someone is working over hazardous machines or equipment.
  • When using scissor at 4 ft. or above, fall protection is needed. Even at lower heights, guardrails may be used, but still leave the potential for falling.  It’s a best practice to wear fall protection when using these machines and these machines have secure anchor points already ready to go for use.
  • Use fall protection any time you’re using an aerial lift.
  • Know your calculations on distance to know how to choose the right length of lanyard to protect your workers in a fall. You need to account for the fall, deceleration distance, harness elongation, swing hazards, the length of the D-ring to the bottom of the feet and a safety factor distance above the ground.
  • Have a rescue plan to prevent suspension trauma and teach workers what they need to do to keep their blood circulating while suspended until help arrives. It only takes 5 minutes for them to become lightheaded, nauseous or unconscious.
  • Only use anchorage points that have been designed to be so and have been certified to meet or exceed OSHA regulations. Engineered anchor point systems typically exceed regulations and are a safe option.  Do NOT use bad anchor points such as vents, stand pipes, railings, guardrails, air vents/ductwork, fixed ladders, skylights, light fixtures, electrical conduits, or air conditioning units.
  • Use of ladders create fall injuries. Know how to properly use a ladder, keep 3 points of contact at all times, check ladders for damage, and set them on a solid, stable base.
  • When was the last time you inspected your fall equipment? Make sure you are visually inspecting it before use and then conducting additional documented annual inspections.  If ANYTHING looks odd, remove it from use.
  • Have your workers been trained in fall hazards? They must be trained prior to being exposed to that hazard, must understand the training and be retrained any time they exhibit inadequacies in knowledge or use of fall protection systems or equipment.

Below are some fall protection-related resources you can draw upon:

Toolbox Topic Material from the National Safety Council

OSHA’s Fall Protection Pagehttps://www.osha.gov/fall-protection

Example Training Resources for Falls in General Industry

This Week’s OSHA’s National Safety Stand Down to Prevent Falls in Construction

If you need help with fall protection safety compliance, contact us today!

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6 Key Steps of an Effective Incident Investigation Process

6 Key Steps of an Effective Incident Investigation Process

Why Conduct Incident Investigations?

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

Who should do the investigating?

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

Six steps for successful incident investigation:

The 7 steps of investigation includes:

STEP 1 – IMMEDIATE ACTION

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

STEP 2 – PLAN THE INVESTIGATION

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

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

STEP 3 – DATA COLLECTION

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

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

STEP 4 – DATA ANALYSIS

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

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

STEP 5 – CORRECTIVE ACTIONS

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

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

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

STEP 6 – REPORTING

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

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

Why look for the root cause?

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

What are the steps involved in investigating an incident?

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

What should I know when making the analysis and recommendations?

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

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

What is OSHA Process Safety Management Management of Change?

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

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

Which are the three types of MOC?

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

What are the steps of MOC process?

8 Steps to a MOC Process

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

 

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

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

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

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

Who Will Be Inspected?

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

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

GENERAL INDUSTRY NAICS

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

CONSTRUCTION NAICS

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

Inspections – What Will OSHA Look For?

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

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

Inspectors Will Conduct Sampling

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

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

Protect Your Company With Side-by-Side Sampling

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

iSi Can Help You Prepare and Get Your Program in Order

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

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

Contact us today for a quote!

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

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

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

Final Rule Stage

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

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

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

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

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

Proposed Rule Stage

Improved Tracking of Workplace Injuries and Illnesses
1904.41

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

Hazcom Updates
1910.1200

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

Amendments to the Crane and Derricks in Construction Standard
1926

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

Occupational Exposure to Crystalline Silica in Construction
1926.1153(c)

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

 Welding in Construction Confined Spaces
1926.353

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

PPE in Construction
1926.95

Clarification of requirements for the fit of PPE in construction.

Updates to Lockout/Tagout
1910.147

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

Powered Industrial Truck Design Standard Update
1910.178, 1926.602

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

State Plans – Arizona and Massachusetts
1952

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

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

Specific Industries

Medical – Infectious Diseases
1910

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

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

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

Communication Tower Construction and Maintenance
1926 and 1910

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

Tree Care
No Specific Reg Cited

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

Prerule Stage

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

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

Blood Lead Level for Medical Removal
1910.1025, 1926.62

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

Emergency Response
1910

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

Process Safety Management and Prevention of Major Chemical Accidents
1910.119

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

Mechanical Power Presses Update
No Specific Reg Cited

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

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

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

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The Top 5 Respiratory Protection Issues Cited by OSHA in 2021

The Top 5 Respiratory Protection Issues Cited by OSHA in 2021

The list of the most cited OSHA standards is out for 2021.  As you may know, the list contains the same issues each year, usually just in a different order.  Fall protection in construction is number one for the 11th year in a row. Hazard communication, usually towards the top of the list, surprisingly fell to 5th.   Respiratory protection in general industry is the new overall number two for this year, and the top issue found in general industry.

So what are the issues most commonly cited for respiratory protection?   

1. 1910.134(e)(1) Medical Evaluations

The most commonly cited relates to medical evaluations. Employers are to provide medical evaluations to determine the employee’s ability to use a respirator, before fit-testing and before they’re required to use the respirator in the workplace. 

There is a medical questionnaire in Appendix C that you can choose to use, or you can choose to do a medical examination instead as long as the examination contains the same information found in the questionnaire.  As an employer, you cannot look at the answers, and must provide employees with instructions on how to deliver or send the completed questionnaire to a physician or other licensed health care professional (PLHCP) for review. 

Seasonal and temporary workers are required to have evaluations if their jobs require respirator use.  Those workers who voluntary choose to wear dust masks (after you’ve determined there is no hazard in that area) are not required to have medical evaluations but must be made aware of the limitations of the dust mask as outlined in Appendix D of the standard.

2.  1910.134(f)(2) Fit Testing

Employers are to ensure employees wearing tight-fitting facepiece respirators are fit-tested:

  1. Before use
  2. Whenever a different respiratory facepiece is used (size, model, make, style)
  3. Annually

Fit-testing is done qualitatively or quantitatively.  Qualitative fit-testing uses items such as saccharine, Bittrex, banana oil or irritant smoke to determine protection.  It relies on the person being tested’s ability to sense odor or irritants. Qualitative fit testing is only for half-face, full-face and N95 filtering facepiece respirators that have an Assigned Protection Factor (APF) of 10.

Quantitative respirator fit-testing uses a machine to measure pressure loss inside the mask or to count quantities of particles to calculate a fit factor.  Quantitative testing is considered more accurate than qualitative fit-testing.  Quantitative fit-testing must be conducted for respirators requiring an APF over 10.  Full-face tight fitting respirators that are quantitatively tested have an APF of 50 .

3.  1910.134(c)(1) Written Program

In any workplace where there is respirator use, there needs to be a written program with site-specific procedures. The program is to be administered by a “suitably trained” program administrator.  Whenever conditions in the workplace changes, the program should be updated.  If you have people voluntarily wearing respirators, you still are required to have a program.

The program is to contain the following elements:

  • Procedures for selecting respirators;
  • Medical evaluations of employees required to use respirators;
  • Fit testing procedures for tight-fitting respirators;
  • Procedures for proper use of respirators in routine and reasonably foreseeable emergency situations;
  • Procedures and schedules for cleaning, disinfecting, storing, inspecting, repairing, discarding, and otherwise maintaining respirators;
  • Procedures to ensure adequate air quality, quantity, and flow of breathing air for atmosphere-supplying respirators;
  • Training of employees in the respiratory hazards to which they are potentially exposed during routine and emergency situations;
  • Training of employees in the proper use of respirators, including putting on (donning) and removing them (doffing), any limitations on their use, and their maintenance; and
  • Procedures for regularly evaluating the effectiveness of the program.

Annual reviews are not required, but reviews should be done periodically in accordance with the complexity and factors of your hazards, types of respirators used, and worker experience using them. Workplace changes are an automatic trigger for updates.  For instance, if your workplace conditions change such as different exposure amounts or types, if you change respirators, or change fit-testing protocols, an update would be necessary.

In your review, employees should be questioned on factors affecting their performance such as difficulty in breathing, limits of motion, impacts to vision/hearing/communication, discomfort and if they have any concerns on effectiveness.

4.  1910.134(k)(1) Training

Employers need to make sure employees can demonstrate their knowledge of the following:

  • Why the respirator is necessary
  • How proper fit, usage and maintenance can compromise its protective effect
  • Limitations and capabilities of a respirator
  • How to use it in an emergency
  • What to do if it malfunctions
  • How to inspect, don, doff and check its seals
  • How to properly clean, disinfect and store the equipment
  • How to recognize medical signs and symptoms that may limit or prevent the respirator’s effectiveness; and,
  • The general requirements of this section of the standard.

Employees need to be trained BEFORE using a respirator in the workplace, and ANNUALLY (within 12 months). Training needs to include the above elements each year. Besides the annual training requirement, retraining is required whenever there are changes in the workplace, when you see the employee has inadequacies in his/her knowledge or use of it, or any other case in which it looks like the employee would benefit from retraining.

To determine the employee’s understanding, you can ask the employee in writing or orally about the information and observe their hands-on use of respirators.

5.  1910.134(d)(1) General Requirements

The general requirements are the general rules for selection of respirators. That is, it is the employer’s duty to:

  1. Select appropriate respirators based on the hazards to which they’re exposed and the workplace factors that will affect them such as temperature/humidity, need for unimpeded vision, need for communication with other workers, usage in conjunction with other PPE, amount of time to be worn, etc.

  2. Select NIOSH-certified respirators and use them in compliance with the conditions of that certification. So don’t use parts for one brand on a different brand of respirators and for airline respirators use in accordance with operating procedures and hose specifications.
  3. Evaluate the respiratory hazards of the workplace. This includes quantifying exposures, identifying the contaminant’s chemical and physical form. You must do an analysis to determine if respirators are needed.  If it’s not possible to identity or estimate, the atmosphere should be considered to be IDLH, or immediately dangerous to life or health.
  4. Select respirators in a sufficient number of models and sizes so that they are acceptable and correctly fit. Not everyone’s face is the same.  We’ve found in fit-testing that not only are there size variances between people, but some just cannot successfully fit test in certain brands and shapes of respirators.

Need Help?  Have Questions?

After reviewing these 5, does your program have all of these bases covered? 

If you have questions, or need help shoring up your respiratory protection program, iSi is here to help!  We can write or review your written programs, help you determine workplace exposures, help with sampling plans, help with respirator selection, and conduct training. Contact us today!

Need Help?

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Keith Reissig
Keith Reissig

Contributing:

Ryan Livengood

International Hazardous Materials Logistics Manager | EHS Regulatory Trainer

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

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

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

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

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

1. 100 Employees Requirement

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

2. Determining Vaccination Status

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

3. Testing

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

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

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

4. Rules for the Unvaccinated

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

5. Written Policy

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

6. Training/Informing Workers About the ETS

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

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

7. Recordkeeping

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

8. Compliance Date

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

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

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Curtis Leiker, CSP
Curtis Leiker, CSP

Contributing:

Curtis Leiker, CSP

Certified Safety Professional |  ISO 45001 and 14001 Lead Auditor

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

Email  |  LinkedIn

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Health Hazard OSHA Regional Emphasis Program Looks at Industrial Hygiene-Related Issues

Health Hazard OSHA Regional Emphasis Program Looks at Industrial Hygiene-Related Issues

OSHA has issued a new regional emphasis program for its Region VII states (Kansas, Iowa, Missouri and Nebraska) that is targeting industries considered to be in the Top 50 for creating worker health hazards.  Called, “Top 50 Workplace – Health Hazard,” some of the other OSHA regions have similar emphasis programs, or more targeted programs.  Region VII didn’t have a mechanism to inspect for health hazards, so they created this one.

Effective and Enforcement Dates

It is effective October 1, 2021 through September 30, 2026.  Enforcement begins January 4, 2022.

What is This About?

This regional emphasis program is related to industrial hygiene.  Industrial hygiene deals with worker occupational health and tests the exposures workers have to potential health hazards. Besides protecting workers from safety injuries, OSHA’s goal is to protect workers from health hazards too.  Many health hazards are longer term issues that cannot be found by just looking at a company’s injury/illness data.

Exposures to certain substances may not cause health issues and cancer for a number of years.  For example, health issues from asbestos exposure may not arise for 15-50 years after exposure, formaldehyde 2-15 years, benzene 1-10 years, hexavalent chromium 20 years and nickel 13-24 years.

OSHA looked at inspection data from the past 3 years and ranked types of companies by the number of serious violations.  They narrowed that list to the Top 50 by NAICS code.  From there, they’re putting all the companies that fall within that list into a random picker to develop their first inspection list.  All of the companies on that list will be inspected before a new list is generated.  If all the companies on the list are not inspected within 3 years, then they’ll carry over to the new list.  OSHA will generate a new target list every 3 years at a minimum.

What Will Be Inspected?

By knowing what OSHA will be looking for, you’ll have an idea of what you need to do and the procedures to have in place in order to be ready.  Inspectors will ask to see your company’s:

  • Exposure monitoring* program;
  • Exposure monitoring records;
  • OSHA 300 logs to identify threshold hearing shifts, skin disorders, respiratory conditions, poisonings and other illnesses;
  • Safety and health programs for ventilation, occupational noise exposure, nonionizing radiation, hazardous materials from Subpart H, PPE, permit-required confined spaces, medical services and first aid, toxic and hazardous substances from Subpart Z and Hazcom; and,
  • Your programs for temporary employees. OSHA sees temps as more vulnerable to these types of hazards. And then,
  • After the records review, OSHA will conduct a comprehensive walk around of your facility and will be looking for areas where they can conduct occupational exposure sampling to run the tests themselves. That testing will occur as soon as possible. This includes wipe sampling, full-shift and short term monitoring and area sampling.  Note: If OSHA shows up for this type of inspection, make sure you do side-by-side sampling with them so that if there are any discrepancies, you’ll be able to point them out.

*Exposure monitoring includes sampling for your employees’ exposure to various health hazards found in your facility.  This could be chemicals and substances such as asbestos, heavy metals, and formaldehyde, solvents and paints, hazardous dusts, welding fumes, noise, vibration, temperature, ventilation and particulates.

Remember that there is a number of OSHA emphasis programs already set in place. If your company is the target of one of them they can happen any time OSHA is already onsite for something else.  In the directive for this health hazard emphasis, they mention that if you fall under multiple emphasis areas, they’ll stack them and do them all at once in one comprehensive inspection.  In Region VII, there’s already a regional noise and respiratory hazards emphasis program.  Also in this region there’s a powered industrial truck emphasis so just having a forklift onsite could start the ball rolling on an inspection.

OSHA’s Goals – The Inspections’ Report Card

Knowing OSHA’s goals with these inspections can give you additional insight into what their inspectors will be looking for.  Each regional office is required to file a report on their efforts with this emphasis, and in it, they’ll be looking to prove their worth on these efforts, and how their staff helped improve overall workplace health.  Some of the data goals include:

  • Total number of health hazards abated;
  • Total number of overexposures identified;
  • Total number of personal air monitoring samples conducted (full shift, short-term, area samples);
  • Total number of wipe samples taken;
  • Total number of noise samples conducted;
  • Total number of workers removed from health hazards;
  • Total number of workers found overexposed to each substance found in 1910.1000-1910.1029; and,
  • Total number of safety hazards abated/workers removed from safety hazards (that they found at the same time they were there doing the health inspection).

The Top 50

This is the list of the Top 50 NAICS code industries who will be inspected.

What’s Next?

Is your company on this list and what do you need to do in order to be ready if your name is drawn?

iSi can help you get ready with program development, exposure monitoring plans and strategies, onsite exposure monitoring and onsite representation during the inspection.  Learn more about industrial hygiene here, or contact us today!

 

Is Your Company on the List?

We can help with the needed IH monitoring plan, onsite sampling and other assistance.  Contact us today!

Curtis Leiker, CSP
Curtis Leiker, CSP

Contributing:

Curtis Leiker, CSP

Certified Safety Professional |  ISO 45001 and 14001 Lead Auditor

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

Email  |  LinkedIn

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Recognize the Signs of Heat Illness

Recognize the Signs of Heat Illness

recognizing the signs of heat illness

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

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

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

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

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

Heat cramps bring pain or spasms to muscles.

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

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

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

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

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

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

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

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

 

OSHA Heat Regulation

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

drew lyon
drew lyon

Contributing:

Drew Lyon

Project Manager | Meteorologist

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

Email  |  LinkedIn

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Annual DOT Registrations Due July 1

Annual DOT Registrations Due July 1

If your company ships hazardous waste or hazardous materials in certain types and/or quantities, you are be required to register with the Department of Transportation (DOT) annually.

Who Needs to Be Registered With DOT?

DOT registrations are required for companies or individuals shipping the following items:

  • A quantity of hazardous material/waste that requires placarding.
  • A hazardous material (including hazardous wastes) in a bulk packaging having a capacity equal to or greater than 3,500 gallons for liquids or gases or more than 468 cubic feet for solids.
  • A shipment in other than a bulk packaging of 5,000 pounds gross weight or more of one class of hazardous materials (including hazardous wastes) for which placarding of a vehicle, rail car, or freight container is required for that class.
  • A highway route controlled quantity of a Class 7 (radioactive) material by highway, rail, air, or water.
  • More than 55 pounds of a Division 1.1, 1.2, or 1.3 (explosive) material by motor vehicle, rail car, or freight container.
  • More than 1 liter/1.06 quarts per package of a “material extremely toxic by inhalation.”

State and federal agencies, Indian tribes, farmers, and individual truck drivers are exempt from registration. Government contractors must register, as do any farmers who transport hazardous materials not used in farming or truck drivers who aren’t driving a truck already registered by a motor carrier.

How Do You Get Registered With the DOT?

DOT registrations are conducted online or you can fill out a form and mail it in. There will be a fee for registration. Registration fees are determined by your company’s size, that is, whether or not you are considered to be a small business by the U.S. Small Business Administration. You will need to know your company’s primary NAICS code. Once you determine your NAICS code, you’ll be able to determine if you meet the small business size standard. Fees can range from $275/year for a small business to $2,600 for a large business, with slight discounts for registering for up to 3 years at a time.

Your company cannot transport hazardous materials until registered. If your company has failed to register for any previous years, you will need to register for any missed years and pay for those as well.

What is Required for DOT Registration Recordkeeping?

Once registered, you’ll receive a Hazardous Materials Certificate of Registration. This will have your DOT registration number, year, date issued, and expiration date. Those who register online can choose to print out their certificate, or have one mailed. Copies of your registration forms and certificate must be kept on file for 3 years and may be asked for during an inspection. Any trucks, truck tractors, or vessels must have a copy of this certificate or another document with your current DOT registration number on it.

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OSHA Proposes Changes to Hazcom Standard

OSHA Proposes Changes to Hazcom Standard

UPDATE:  OSHA has announced an informal public hearing for Sept. 21.  If you’d like to testify or question witnesses, submit your notice by June 18.

OSHA has announced it’s planning on making changes to its Hazcom Standard (29 CFR 1910.1200) and they are soliciting your comments, due by May 19.

OSHA’s changes are to help align the standard with Global Harmonization Standard (GHS) Revisions 7 and 8.  OSHA is also wanting to correct issues it’s found since the last update in 2012 and to make the standard more in line with related federal agencies such as DOT and international trading partners such as Canada.

Here are the items currently up for comment:

 Relabeling Containers and “Released for Shipment” Dates

Right now the standard says that once a chemical manufacturer, importer, distributor or employer knows there is hazard information changes significant enough to affect the SDS, the SDS needs to be updated.  Labels must be revised within 6 months and containers shipped thereafter must have that information on its labels.

OSHA is proposing chemicals released for shipment and awaiting future distribution wouldn’t need to be physically relabeled to incorporate that new information.  Instead, the chemical manufacturer/importer will still need to provide an updated label for each individual container with each shipment. This would help containers with long distribution cycles.  This also reduces the chemical exposure and ergonomic hazards for workers who would be going in and actually physically relabeling containers.

As a result of this, labels on shipped containers will be required to note the date the chemical is released for shipment.  The standard will specifically call out chemicals released for shipment and awaiting further distribution as part of the no relabeling requirement, so they’ll need a date on them to meet that requirement.

Bulk Shipments

Labels for bulk shipments can be placed on the immediate container, or you will be able to transmit them with the shipping papers or bills of lading electronically as long as there’s a printed version available to the people on the receiving end of the shipment.

Changes to bulk shipments are an effort to facilitate inter-agency cooperation with DOT.

Labeling for Small Containers

Labels for small containers less than or equal to 100 mL must include just the product identifier, pictogram, signal word, chemical manufacturer’s name and phone number, and a statement that the full label info for the hazardous chemical is provided on the immediate outer package.  This will be applicable for those containers where it’s not feasible to use pull-out labels, fold back labels or tags with the full information on them.

There will be no labeling requirements for containers less than or equal to 3 mL if the manufacturer, importer, or distributor can demonstrate that any label would interfere with the normal use of the container.  A product identifier that can be identified and linked with the full label info on the immediate outer package would be required on that small container.  OSHA uses an example that a glass vial could be etched with the product identifier instead of needing the label.

Immediate outer packaging would then need to include the full label information, and a statement indicating when not in use, the small containers inside must be stored in this outer packaging that has the label on it.

Trade Secrets

Allow manufacturers, importers and employers to now withhold a chemical concentration range as a trade secret.  Use prescriptive concentration ranges instead of actual concentration or concentration range when they’re claimed as a trade secret.  This change is categorized as help to better work with trading partners as this is something that Canada does.

OSHA wants to know from commenters if this is something that you have worked with and does this give enough information downstream for manufacturers to conduct hazard classifications and protect workers.

 SDS Terminology

A terminology change will replace the word “design” with “stored.”  This will allow SDSs to be stored in a way that covers groups of hazardous chemicals in a work area. They believe the word “designed” is confusing because now SDSs have specific design requirements (16 section format) so they don’t want anyone redesigning an SDS for groups of chemicals in a work area.

Appendix D Changes

  • Changing Section 2 of the SDSs to emphasize that hazards identified under normal conditions of use that result from a chemical reaction must appear on the SDS, even though the hazards don’t need to be listed on the label. This would be a reorganization of the info on the SDS.
  • The Hazcom Standard currently requires SDS Section 3 to include chemical name and concentration/concentration ranges of all ingredients classified as health hazards. OSHA wants to know if this should be expanded to include not only the health hazard classified chemicals, but all classified chemicals such as physical hazard chemicals to help manufacturers better understand hazard potentials when handling these chemicals. This would be similar to what the REACH regulations require in Europe.
  • OSHA would also like to hear comments about using electronic labels, RFID and QR codes on chemical packaging as a form of communicating hazards fully and in real-time. If your company is using electronic labeling, they’d like to know what kind of system you’re using and what benefits you’ve been able to see from it.

Other Appendix Changes

  • Considering revisions in the Skin Corrosion/Irritation section to expand non-animal testing, recognizing in vitro test methods, and reorganizing that chapter. (Appendix A)
  • Adding a new hazard class for desensitized explosives (Appendix B)
  • Adding hazard categories for unstable gases and pyrophoric gases in the Flammable Gasses class and nonflammable aerosols in the Aerosols class (Appendix B)
  • Making editorial, clarifying and reorganizing changes and using more standard language in line with GHS Revision 8. (Appendix C)
  • Requiring prioritization of certain precautionary statements related to medical response. Currently some of the medical response statements give options such as call poison control center or call a doctor or choose between medical advice vs. medical attention.   This can lead to confusion on which choice is best, so they want to standardize that with the best option. (Appendix C)

Definitions and Terminology

  • In the SDS section, a terminology change will replace the word “design” with “stored.” This will allow SDSs to be stored in a way that covers groups of hazardous chemicals in a work area. They believe the word “designed” is confusing because now SDSs have specific design requirements (16 section format) so they don’t want anyone redesigning an SDS for groups of chemicals in a work area.
  • Adding definitions for Combustible Dust, Bulk Shipments, Immediate Outer Packaging, Released for Shipment and Physician or Other Licensed Health Care Professional
  • Revising definitions of a Gas, Liquid and a Solid to align with GHS Revision 7
  • Revise the definition of a hazardous chemical to delete the reference to pyrophoric gases because those will now be a physical hazard in the Flammable Gas hazard class

Training Required

OSHA believes in its economic impact analysis that training updates will be minimal and only apply to certain types of employees.  OSHA says that additional HAZCOM training will be needed to alert those who work with impacted aerosols, desensitized explosives, nonflammable gasses not under pressure, and flammable gasses about the changes in the SDSs.  Those where labels may change may require some additional training and instruction on what to do such as with bulk packagings and small containers.

How Often Should There be Changes?

OSHA is soliciting feedback on how often changes should be made to the Hazcom Standard.  GHS is updated every 2 years. OSHA wants to stay current with GHS revisions.  Only the European Union has updated their guidelines in less time than OSHA (2016) while other countries have only said they planned on it, but haven’t done anything yet.

OSHA would like to know if they should install a regular schedule of updating every 4 years, every 2 revisions of the GHS, or if they should wait until there are significant changes before doing any updates.

Where Can You Make Comments?

You may submit comments identified by Docket No. OSHA-2019-0001, electronically at http://www.regulations.gov, which is the Federal e-Rulemaking Portal.  Formal comments were due in May 2021, however, If you’d like to question witnesses or testify at OSHA’s informal hearing on September 21, 2021, submit your request by June 18, 2021 to the regulations.gov site.

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5 Ways OSHA’s Top 10 Can Make Your Safety Job Easier

5 Ways OSHA’s Top 10 Can Make Your Safety Job Easier

5 Ways OSHA’s Top 10 Can Make Your Safety Job Easier

Getting Value Out of the “Same Old List”

OSHA’s Top 10 Violations for 2020 have been announced.  So what!   OSHA’s Top 10 hasn’t changed much in the past 5 or 6 years and most of the time it’s the same violations with the order switched around.  The only “exciting” part is to see if a newcomer violation got on list.  The list still didn’t even really change in a pandemic year either.

Well as un-newsworthy as this is, believe it or not, the annual confirmation that it’s the same stuff can actually make your job easier.

First, What’s on the List?

Below is a list of the Top 10 OSHA Violations for 2020

  1. Fall Protection – General Requirements (1926.501): 5,424 violations
  2. Hazard Communication (1910.1200): 3,199 violations
  3. Respiratory Protection (1910.134): 2,649 violations
  4. Scaffolding (1926.451): 2,538 violations
  5. Ladders (1926.1053): 2,129 violations
  6. Lockout/Tagout (1910.147): 2,065 violations
  7. Powered Industrial Trucks (1910.178): 1,932 violations
  8. Fall Protection – Training Requirements (1926.503): 1,621 violations
  9. Eye and Face Protection (1926.102): 1,369 violations
  10. Machine Guarding (1910.212): 1,313 violations

Respiratory protection moved 2 spots up the list this year along with eye and face protection up one spot as well.  Ladders moved up a spot too.  Your top 2 violations were the typical fall protection and hazcom.

Well…It’s the Top 10 for a Reason

First, companies continue to have problems with these issues.  Many of them can be affected by employee behaviors such as how they choose to wear (or not wear) their PPE, conducting (or not) inspections, using (or not) injury saving controls, and situational awareness pitfalls.  As a result, some of these are going to be easier to come across on any given day.

Next, these top 10 may also be considered the low hanging fruit of inspections.  If these are the most common violations, then you could surmise inspectors are going to be looking at these.  Further proof comes from OSHA’s national, regional and local emphasis programs.  Emphasis programs allow an inspector to add to their investigation. For example, if you are having an inspection related to an employee complaint for respirators and there is an emphasis program in your area for powered industrial vehicles, OSHA inspectors can broaden their inspection if they see a forklift in your building.

A check of OSHA’s current emphasis programs includes items from the top 10.  Out of 10 OSHA regions, there are emphasis programs for:

  • Amputations (including machine guarding) – National Emphasis
  • Falls – 9 Regions
  • Powered Industrial Vehicles – 5 Regions
  • Electrical – 2 regions
  • Respirators – 1 region
  • Construction Worksites – 10 regions

Make Your Job Easier Tip 1:  Break it Down

The top 10 have specific standard references with them and from there we can see it’s a mix of general industry and construction standards.  All 10 areas of safety are important.  However, if you break the list down by the standard your company typically operates under, your focus areas are nearly cut in half and this becomes much more manageable. 

General Industry-Related ViolationsConstruction Industry-Related Violations
Hazard CommunicationFall Protection – General Requirements
Lockout-TagoutHazard Communication**
Respiratory ProtectionScaffolding
Powered Industrial TrucksLadders
Machine GuardingFall Protection – Training
Face and Eye Protection

**The 1926 standard for hazard communication refers to the 1910 standard.

Make Your Job Easier Tip 2:  Instant Safety Topics!

Dealing with the immediate site-specific injury-causing issues should always be your first focus.  However, you likely have safety committees, employee safety briefings, toolbox meetings, newsletters to write, safety emails to send, etc.  The shortened list can now be easy go-to topics. 

Get your co-workers and safety teams talking about them.  As mentioned before, some of these items are going to be related to their behaviors and decisions anyway.  Head off the top 10 one person at a time and don’t feel bad if you need to continue to cover them.  The world of sales tells us that most people need to hear about something 7 times before it sticks.

Make Your Job Easier Tip 3:  Get Your Documentation in Order

A number of these areas have specific training and/or inspection requirements.  Document, document, document! 

For training, keep records of who took training, when training was conducted, who the trainer was and what the content of the training included.

For inspections, find a way to document these and have a process in place for taking equipment which fails out of service. This will be important information for you during an inspection and can go a long way in staying away from the top 10.

Make Your Job Easier Tip 4:  Incorporate These Into Your Walkthroughs

If you’re not doing so already, set aside a little bit of time each week to conduct a safety walkthrough and incorporate these items into your checklist.  Routine walkthroughs will allow you to keep up on what’s going on at your site, gives you a chance to correct deficiencies, and gives you an opportunity to take advantage of teachable moments to the workers in those areas.  Get your employees involved in inspecting their workplace.  Have them be on the lookout for these same issues in walkthroughs and peer-to-peer observations.

Make Your Job Easier Tip 5:  Get Help

You are not Superman/Superwoman.  There are too many tasks, crises, and other forces that can get in the way of getting it all accomplished. A good manager needs a supporting cast.  If you can get someone at your company to help you with tasks, that would be great.  However, if you cannot, consider getting an outside company or safety professional to help. Consultants like iSi are here for a reason.  We have people on-staff who have been in your position and have experience with the regulations.  We can often do what needs to be done (and done correctly) in a fraction of the time it would take for you to do it, or for you to train someone else internally to do it.  This can be as simple as getting help a writing program or conducting training.  It could be having an audit done to see where you stand on compliance or a bigger project such as revamping a safety program or day-to-day onsite assistance.

In Conclusion

Use the data from the Top 10 as your instant to-do list.  If you can tackle the items that pertain to you, you can help do your part in avoiding those common fines and maybe shaking up the list for next year.

Need Help?

Need help with any of OSHA’s Top 10 issues, or anything else in the safety field?  We can help with checklists, audits, programs, training & more!

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

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

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

OSHA fines

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

The Violation Categories

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

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

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

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

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

Calculating Violation Amounts

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

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

Gravity Based Penalty Amounts

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

Severity + Probability = Gravity Based Penalty Amount

Here are the Gravity Based Penalty Amounts for 2021:

Gravity-based penalties for OSHA 2021


History Reductions

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

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

Good Faith Reductions

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

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

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

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

Business Size Reductions

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

Quick Fix Reductions

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

Limits of Discounts

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

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

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

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

Other Penalties

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

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

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

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

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

Safety Management Programs

You can score deductions with a safety and health management system.  We can help you develop one, or at least help with the pieces. 

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iSi Finds Success With Virtual EHS and ISO Compliance Audits

iSi Finds Success With Virtual EHS and ISO Compliance Audits

The COVID-19 pandemic really threw a curveball at all businesses, forcing them to think differently about how to provide services and products to their customers.  Although the pandemic has been a major disruption, something good has come out of it for iSi.  We’ve been forced to think outside of the box to develop alternatives to business as usual.  In some cases it’s made us more efficient and has worked out nicely for our clients too.   One such success story at iSi has been virtual audits.

Traditional Audit Tactics Out the Window

Business disruptions unfortunately don’t disrupt environmental, health and safety (EHS) compliance obligations.  Businesses still need to ensure they’re complying with EPA and OSHA regulations correctly, and for those companies who are requirements to achieve ISO Certification, those requirements still go forth.

iSi conducts several different types of audits, from records reviews, to facility walkthroughs, to a combination of the two, to ISO standards-based audits.  Traditional EHS and ISO audits often have involved travel to facilities to spend one or more days onsite.  With COVID, travel to and from different locations has been reduced, discouraged, and even forbidden in certain locations without quarantine.  Many of our client sites have been closed to outside visitors either completely, front doors are locked, and in some instances entry has been limited to a contractor approval process.  Interviewees are working on limited schedules, or working from home, making traditional methods that much more difficult.

Records Reviews

With travel affected, we needed to find an alternative to being onsite.  Records reviews were the first and best items in our process to start with virtually.  Clients can scan and upload records for reviews.  Over the past year, iSi has implemented a new Enterprise Resource Planning (ERP) System, allowing us to improve multiple processes throughout the company including project management, document storage, web conferencing, online training, digital file transfer, electronic billing, and more, and so we’re set up to do a lot of different things electronically.  iSi and its clients can upload and review documents back and forth electronically with a lot of ease.

Walkthroughs and Interviews

Although walkthroughs are a very valuable piece to our audits, we find that we can use alternatives here too.  iSi has HD smart glasses so that our client can literally be our eyes onsite. The glasses have camera, video, and communications capabilities so that the client can record a walkthrough through the glasses and still communicate back and forth with our auditor remotely.  Even better, they are safety rated so that they can be used as safety glasses in industrial facilities.  In lieu of the glasses, clients can also record videos of certain areas of their facilities, conduct live streaming videos, or take photos for our auditors to inspect.

The pandemic has forced us all to get more familiar with video conferencing software.  Interviews and discussions can be done remotely through video conferencing.  This has allowed us to still get to know our clients and has given us the chance to discuss important topics or answer questions, just as if we were sitting there side by side.

We’ve also been able to give clients guidance on how to use certain pieces of equipment by giving visual demonstrations on camera and providing step-by-step instructions.

ISO Audits

Virtual audits have been most seamless for our ISO projects.  For example, iSi recently conducted a third-party ISO internal audit for a worldwide aircraft components manufacturer to identify existing EHS Management System conformance to the ISO 14001:2015 and ISO 45001:2018 standards.

iSi reviewed the corporate EHS management system and the corporate office’s EHS management system. These systems were compared against the ISO standard, legal/regulatory standards, internal policies and procedures, and customer needs.

The audit was completed virtually through Microsoft® Teams, a communication and collaboration platform. Employee interviews were done through video meetings, and documents were reviewed through screen sharing and e-mail.  Management interviews were conducted virtually and over the phone with the corporate CEO, Investor Relations, and Senior Leadership such as the Executive Vice President and Human Resources, as well as various environmental and safety committees.

All the while, iSi’s auditor remained at our headquarters in Wichita, Kansas while conducting the audit at the client’s facility in Connecticut.

Following the audit, a report of findings and deficiencies was prepared and these reports were all delivered electronically.

iSi was able to conduct a very comprehensive ISO audit for this client, covering topics such as

  • External and Internal Issues
  • EHS Policies, Procedures, Objectives Compliance Obligations
  • Current Processes
  • Leadership Commitment, Culture and Management Roles
  • Employee Participation and Worker Needs
  • Available Resources
  • Internal and External Communication Systems and Evaluation Processes
  • Continual Improvement Efforts
  • Organizational Roles and Responsibilities
  • Reporting
  • Conformance to Regulatory and ISO Standards
  • and More

The Future of Virtual Audits

Although we don’t think we’ll be doing virtual audits exclusively from now on, we do see the benefits of this new alternative.  It’s allowed us to become more organized and more in tune with the electronic resources we have at our disposal.  It’s also saved our auditors a ton of time in not having to travel far distances, instead reinvesting that time into the project itself.  This, in turn, also have been a cost savings and a time savings for our clients too.

In our business, there’s nothing like the interpersonal relationships that are built between our teams and our clients throughout a project.  However, virtual audits has still allowed us to develop these and haven’t gotten in the way as much as one may think they would.

The efficiencies learned and gained are bound to help future projects going forward.  Perhaps these experiences have shown us there will be less need in the future to be onsite for those visual audits or walkthroughs, while the other parts of the audit will be done remotely, saving time and efforts for both parties.

Time will tell what the future of audits will look like, but at iSi we are happy that we have found something positive to take away from this crazy time.

Visit Our Audits Page!

Learn more about our audits and what we can provide!

Contact Us for Your Next Audit!

Our audit team can help your company too – either in-person or virtually!  Where does your compliance stand?  Let’s get the conversation started!

Curtis Leiker, CSP
Curtis Leiker, CSP

Contributing:

Curtis Leiker, CSP

Certified Safety Professional |  ISO 45001 and 14001 Lead Auditor

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

Email  |  LinkedIn

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Ototoxicity – When Chemicals (yes, chemicals) Cause Hearing Loss

Ototoxicity – When Chemicals (yes, chemicals) Cause Hearing Loss

Need Help?

Let iSi help you determine what to do about ototoxic chemicals and noise exposures at your facility!

The effects of chemical exposures in the workplace has been highly documented.  Chemicals can affect you when you breathe them in, ingest them, inject them or absorb them through your skin.  However, did you know that chemicals can cause hearing loss too?

What is Ototoxicity?

Chemicals which can contribute to hearing loss are called “ototoxicants” and the hearing loss itself is considered to be “ototoxicity.”  Ototoxic chemicals reach the inner ear, connected pathways and nerve fibers through the blood stream or through the ear’s hair cells.  Hearing losses can range from sound distortion to the inability to detect two sounds with similar frequencies to inabilities to detect time gaps between sounds or localize sound.

The problem increases when there is a noise exposure combined with the exposure to an ototoxicant.  Ototoxic chemicals make a bigger impact on noise exposure, especially impulse noise.  Ototoxic chemicals plus noise becomes worse than just the noise alone or the chemical alone.   The noise levels do not even need to be above OSHA’s Permissible Exposure Limit (PEL) standards.  It’s the combination of the two which causes the greatest damage.

Which Chemicals Are Considered Ototoxic?

  • Pharmaceuticals: aspirin, some antibiotics, NSAIDs, loop diuretics
  • Tobacco smoke
  • Solvents, degreasers and paints containing toluene, p-xylene, styrene, ethylbenzene, methylstyrene, trichlorethylene, carbon disulfide, n-propylbenzene or n-hexane
  • Carbon monoxide
  • Hydrogen cyanide
  • Nitriles: 3-butenenitrile, cis-2-pentenenitrile, acrylonitrile, cis-crotononitrile and 3,3’-iminodipropionitrile
  • Metals and compounds: mercury, lead, organic tin and germanium dioxide
  • Pesticides: pyrethroids, hexachlorobenzene, insecticides or organophosphates
  • Some limited research has also speculated arsenic, cadmium, halogenated hydrocarbons, bromates, alkylic compounds and manganese may also affect ototoxicity

Which Industries or Operations May be Affected?

  • Manufacturing
  • Construction
  • Printing
  • Painting
  • Fueling vehicles and aircrafts
  • Firefighting
  • Weapons firing (Military)
  • Pesticide spraying

How Do You Test for Otoxicity?

Determining whether you have the potential for this condition is primary.  First, conduct a risk assessment to determine if your operations could be affected. 

Check the Toxological Information section of the chemical’s Safety Data Sheet (SDS Section 11) to see if the chemical is considered a neurotoxicant.  If there is nothing listed in this section, often other clues can be found in the SDS such as general toxicity, nephrotoxicity or if the chemical produces reactive free radicals.

From there, exposure limits and thresholds are dependent on different factors such as the chemical itself, exposure routes, concentration, duration, noise exposure and individual risk factors such as age.  Workplace sampling will be able to help you quantify your exposures. 

Audiogram tests can show early onset of hearing impairments and threshold shifts.   However, they cannot tell you the difference between whether the impairment is noise-related or ototoxic-related.  If you have complaints of hearing loss, investigate whether ototoxicity could be a factor.

The American Conference of Governmental Industrial Hygienists (ACGIH) recommends periodic audiograms for those who have noise exposures combined with carbon monoxide, hydrogen cyanide lead and solvent mixtures.  When there’s not a noise exposure, ACGIH still recommends audiograms be used when workers have the potential to be exposed to ethylbenzene, styrene, toluene or xylene.

PPE and Training Requirements

Make sure you reduce the effects of ototoxic chemicals in your workplace either through controls such as isolation, limiting exposures, or eliminating unnecessary tasks, or through the use of PPE.  Conduct your PPE assessment per OSHA rules.  You may need to include proper hearing protection, as well as PPE which can prevent inhalation (respirators), or absorption through the skin (chemical gloves, arm sleeves, aprons).

If you have a potential for ototoxic chemical exposure, this also needs to be included in your Hazard Communication (HAZCOM) training. 

Does This Affect You?

Do you have the potential for ototoxicity in your workplace?  iSi can help you make that determination, conduct your risk assessment, and/or quantify your exposures through sampling.  Contact us today!

Keith Reissig
Keith Reissig

Contributing:

Ryan Livengood

International Hazardous Materials Logistics Manager | EHS Regulatory Trainer

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

Email 

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2020 ERG – Emergency Response Guidebook Updates

2020 ERG – Emergency Response Guidebook Updates

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The new 2020 version of the Emergency Response Guidebook (ERG) is finally out, and hard copies are now available.  The ERG is published every 4 years.

What is the ERG?

The ERG contains emergency response information and is a handbook used by emergency and hazardous materials incident responders, truck drivers, railroad personnel, pipeline personnel, pilots, police and firefighters.  It is written and updated by four separate international agencies:

  • U.S. Department of Transportation’s Pipeline and Hazardous Materials Safety Administration (PHMSA)
  • Transport Canada’s Canadian Transportation Emergency Centre (CANUTEC)
  • Argentina’s Chemistry Information Center for Emergencies (CIQUIME)
  • Mexico’s Secretariat of Communications and Transport

iSi uses the ERG in our HAZWOPER training as well as our DOT Hazardous Materials Transportation, Hazardous Waste Management and RCRA Refresher classes.  This is because handling emergency spills are a component of all of these classes.

Updates

The four agencies have been working on this latest version since 2017.  In 2018, all of the agencies solicited input from their public through calls for comment, listening sessions, online surveys, and articles.  From these solicitations, 100 comments were gleaned to be considered for incorporation and DOT held a public meeting as well.  Since then, sub-groups worked on the updates.

Here is a list of the planned changes and items that were up for review within each section of the book. The agencies will:

White Pages [General Information, Instructions, Recommendations, Guidance]

      • Review content for use of plain language;
      • Improved quality of illustrations in charts for railcar and road trailer identification;
      • Add new lithium battery markings;
      • New terms in the glossary section;
      • Add a decontamination section; and,
      • Add basic information about heat induced tears (HIT).

Orange Pages [Response Guides]

      • Comprehensively review of all materials and their assignments in the orange pages by FEMA/NFA, with certain items up for review in 2020 while others will be reviewed before the 2024 version;
      • Distances in the Public Safety section are now in the Evacuation Section;
      • Created a new “How to Use the Orange Guide Pages” section;
      • Guide 121 Gases – inert was merged with Guide 120 Gases – inert (including refrigerated liquids);
      • Added CAUTION sentences for specific materials;
      • Clarify sentences;
      • Address inhalation concerns for petroleum crude oil (UN1267) in Guide 128; and,
      • Reevaluate radioactive materials guides with radiological/nuclear regulatory agencies.

Yellow/Blue Pages [Materials in ID/Name of Material Order]

      • Add or remove UN numbers to align with United Nations Model regulations and North American regulations;
      • Remove UN numbers for chemical warfare agents;
      • Reevaluated guide assignments for some materials; and,
      • Review polymerization hazards for certain materials.

Green Pages [Isolation and Protective Action Distances]

      • Add distances for new Poison Inhalation Hazard/Toxic Inhalation Hazard materials added by regulations;
      • Revise Table 2 introduction;
      • Add container capacities to Table 3;
      • Make a new border to differentiate between Tables 1, 2 and 3; and,
      • Argonne National Laboratory will update the Chemical Accident Statistical Risk Assessment Model (CASRAM) with outcomes from field and lab experiments.

Where Can the Current ERG Be Found?

A free PDF version of the current Emergency Response Guidebook is available online on the PHMSA website. There’s also a mobile app for the guide available for both Android and iPhone devices.    If you’d like to purchase a hard copy for your use, check out the iSi online store.

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Industrial Hygiene in Construction: Focus Four Health Hazards

Industrial Hygiene in Construction: Focus Four Health Hazards

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

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

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

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


Manual Material Handling

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

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


Noise

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

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

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


Air Contaminants

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

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

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

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

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

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


High Temperatures

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

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

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

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


In Closing

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

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

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

Worker & Area Sampling

Let iSi’s industrial hygiene team help you determine what your workplace exposures are. Contact us today!

Tami Hadley
Tami Hadley

Contributing:

Tami Hadley

Marketing Director | Project Manager, E-Training Solutions

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

Email  |  LinkedIn

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Safety News Briefs: OSHA 300 Public, Tyvek Shortages, New Respirator Posters

Safety News Briefs: OSHA 300 Public, Tyvek Shortages, New Respirator Posters

Here are a few recent headlines from the world of safety:

Federal Judge Rules OSHA 300 Info is Not Confidential

A federal judge in the U.S. District Court for Northern California has ruled that OSHA injury and illness log information is not confidential.  The ruling comes as a part of a lawsuit where news organization the Center for Investigative Reporting made a Freedom of Information Act (FOIA) request to OSHA for records and OSHA denied the claim under FOIA exemptions for “law enforcement” and “trade secrets”.

The judge ruled that because employers are required to post this information annually and keep it on file for up to 5 years so that current and former employees can review them, these employees can freely share this information.  Thus, it’s readily observable and can be made public anyway.

The Center for Investigative Reporting was pleased with the ruling, saying that it would help keep the “dangerous” employers accountable and encourage them to improve safety while giving workers a better understanding of the risks involved in the job.

MSA Warns of Shortage of White Tychem, Tyvek 

Personal protective equipment company MSA Safety has issued a notice regarding a shortage of the white DuPont Tychem hoods used for powered air purifying respirators.  DuPont notified MSA that there would be shortages of white Tyvek, including Tychem, materials until early 2021.

MSA will be substituting white hoods with yellow Tychem hoods.  They say that the yellow Tychem is just as protective as the white.  However, some companies have policies requiring the white, and those policies may need to be altered for a while until the supply is restored.

Respirator Posters Available in 16 Languages

OSHA’s poster “Seven Steps to Correctly Wear a Respirator at Work” has now been published in 16 different languages.  These include English, Spanish, Arabic, Brazilian Portuguese, Chinese (Simplified and Traditional), French Creole, Hmong, Korean, Kunama, Polish, Russian, Somali, Tagalog, Thai and Vietnamese.

As many manufacturing safety managers know, most OSHA documents and posters are not printed in this many varieties, so this is a great time to get these for your workplace.  Find all of these for download at https://www.osha.gov/news/newsreleases/national/06152020-0.

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iSi Summer Safety Toolbox: Staying Hydrated

iSi Summer Safety Toolbox: Staying Hydrated

hydration safety toolbox

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

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

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

It’s every person’s duty to watch out for themselves and their teammates. Providing cold water for your team is beneficial during hot days, as is having a first aid kit. If you have a first aid kit, kudos! If you don’t have a first aid kit, now is the time to get one. A few beneficial items to add to your first aid kit would be cold packs, cooling towels, electrolyte/salt tablets, or electrolyte powder drink mix. There are also specific first aid kits that can be purchased that include heat-stress care items.

Some symptoms of dehydration include:

  • Extreme thirst
  • Less frequent urination or dark colored urine
    Decreased sweating
  • Muscle cramps
  • Nausea, dizziness or confusion
  • Fatigue

If you’re a supervisor who would like some ideas on a heat safety plan or have questions on where to find quality first aid kits, contact us!

drew lyon
drew lyon

Contributing:

Drew Lyon

Project Manager | Meteorologist

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

Email  |  LinkedIn

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COVID-19: A Potential OSHA Recordable Illness

COVID-19: A Potential OSHA Recordable Illness

UPDATED 5/22/20

Recently published guidance from OSHA clarifies that workplace-contracted COVID-19 can be a recordable illness.  That is, a recordable if it was contracted as a result of work duties.

Illnesses such as the flu and colds have always been, and continue to be, exempt from recordable illnesses recordkeeping.  However, COVID-19 is NOT exempt from being a recordable, even though it contains some of the same symptoms as the flu and cold.

When COVID is Recordable

Use the following guidelines when determining if a case of COVID 19 is a recordable illness:

  • Is confirmed as a coronavirus illness,
  • Falls under one or more of the typical recording criteria such as medical treatment beyond first aid, hospitalization, or days away from work, and
  • Is work related as defined by 29 CFR 1904.5.

Determining if it’s work related will take some investigation on your part as there’s a possibility that exposures can occur outside of work as well. OSHA expects employers to make reasonable efforts, based on the evidence available to make that determination.  A best practice is to ensure you have documentation of your investigation, including all the steps you took to come to your findings, and what led you to choose why to count or not count that illness.

Like with other recording requirements, companies with 10 or fewer do not need to make a recording unless it is work related and results in a hospitalization, amputation, loss of an eye or a fatality.

Have a Plan

Some workplaces and worker tasks are considered to have a higher risk for employee exposure.  Most workplaces will have a low exposure risk.  Those in healthcare, death care, airline, border protection, solid waste management and wastewater treatment are considered to be in the high risk category.  Workers who are required to work within 6 feet of each other would fall in the medium risk exposure level because the virus is spread through person-to-person droplet contact within that 6-foot range.

As a result, OSHA says it is important for workplaces to take measures to prevent the spread of COVID-19 and have a plan for dealing with it.  OSHA’s guidance specifically says there is currently no standard that covers COVID-19, but it would fall under the General Duty Clause that requires employers to provide workers with “…a place of employment which is free from recognized hazards that are causing or likely to cause death or serious physical harm.”  They also mention the PPE standards (1910 Subpart I) which covers usage of gloves, eye protection, face protection and respirators and the Bloodborne Pathogens standard (29 CFR 1910.1030) which covers exposures to body fluids and blood.

Respirator Usage

Depending on work tasks and potential exposures, workers may need to wear masks, goggles, face shields, and/or respirators.  In the guidance document, OSHA says that workers, including those who work within 6 feet of patients known to be, or suspected of being, infected and those performing aerosol-generating procedures, need to use filtering facepiece or better respirators.  Remember that if your workers are wearing respirators, you must have a comprehensive respiratory protection program that has its own complete set of requirements.  You can find the respirator standards at 1910.134.

Hierarchy of Controls

OSHA’s guide contains ideas for identifying and isolating sick people, where appropriate.   OSHA also draws on the Hierarchy of Controls, just as it does for all other safety concerns.  For example:

Engineering Controls

  • High-efficiency air filters
  • Increased ventilation rates
  • Negative pressure ventilation in areas where aerosols are generated

Administrative Controls

  • Encouraging sick workers to stay home
  • Virtual or teleconferenced meetings rather than face-to-face
  • Alternating days or extra shifts to reduce the number of employees in the building, increasing work distances
  • Discontinuing non-essential travel
  • Emergency communication plans
  • Worker training

Safe Work Practices

  • Promote personal hygiene with tissues, no-touch trash cans, hand soap, alcohol rubs and wipes, disinfectants and disposable towels
  • Required regular hand washing or alcohol hand rubs, especially after removing PPE
  • Post handwashing signs in restrooms

PPE

  • Select based on hazard to the worker
  • Ensure proper fit and refit
  • Consistent and proper wear
  • Regular inspections
  • Regular cleaning, maintenance and repair
  • Proper storage and disposal

OSHA says PPE recommendations are likely to change depending on location, current PPE effectiveness and the nature of the job, so check in with OSHA and the CDC website for updates on recommended PPE.

Resource Links

OSHA has a dedicated webpage covering COVID-19 and they have published a guidance document in conjunction with the Department of Health and Human Services.  Both of these address measures on how to protect workplaces and workers at low, medium and high exposure risks and those who work in the specifically targeted high risk industries above.  Below are links to resources for COVID-19 planning and information:

OSHA and DHHS Guidance on Preparing Workplaces for COVID-19

OSHA COVID-19 Website

CDC COVID-19 Website

EPA’s List of Registered Antimicrobial Products for Use Against Novel Coronavirus SARS-CoV-2, the Cause of COVID-19

Need Help? Have Questions?

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COVID Complaints: Will You Be Inspected by OSHA?

COVID Complaints: Will You Be Inspected by OSHA?

​Updated 5/22/2020

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

Employee Complaints

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

OSHA Puts Employers in One of 3 Risk Groups

High Risk

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

Medium Risk

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

Low Risk

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

Inspections 

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

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

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

What to Expect in an Investigation Letter

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

  • Investigate the complaint
  • Determine results and respond by a certain date

  • Provide backup documentation of your investigation

  • Provide corrective actions taken or to be taken

  • Provide backup documentation of corrective action

  • Post the letter

  • Sign a certificate that you posted the letter

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

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

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12 Tasks for Safety Managers Working From Home

12 Tasks for Safety Managers Working From Home

Many in the U.S. are under stay at home orders, encouraged to work from home where possible. Although many manufacturing facilities are considered essential and still open, safety managers and their support staff do not always need to be onsite. With your routine disrupted, this may actually be a great time to accomplish safety projects that your normally crazy busy days do not allow you to do. Here are 12 ideas for tasks that safety managers working from home can do themselves, or can assign to their safety team members to keeping teams busy and productive during this time:

1. Develop Your Pandemic Plan

What better time than now to develop a plan for dealing with a pandemic? What actions did your company take? What has worked and what didn’t?  As a contractor, a number of clients have asked to see our plan.  What will you do about your own vendors and contractors next time? What about visitors? Read our article on pandemic preparedness plans to get some ideas on how to get started.

2. Review/Develop Cleaning Procedures

The events of the past month have shown a spotlight on the way we handle the spread of germs from person to person.  What are your procedures for cleaning and disinfecting respirators? What about your other personal protective equipment? What are the proper protocols? How often should they be cleaned? What cleaning products are EPA-approved and most effective on the PPEs’ materials?

3. Review Your Emergency Plans

We are entering wild weather months of spring and summer. How would your company deal with the effects of tornadoes, floods, wildfires, hurricanes, hail storms, high wind events, heat waves, etc.? What are your business continuity plans if one of these events would occur at your facility? How would you be affected? Electricity powers the lights, your computers, and your machines. What would you do about electrical service interruptions? Did you know that there are EPA regulations for emergency power generators? What other regulations would come into play?

4. Review Your Written Safety Programs

Written safety programs need to be reviewed on a regular basis, and some of them actually have OSHA rules about how often they are to be reviewed. Take a look at all of your plans. What do they commit you to doing, and is your company doing what it says you are supposed to be doing? Who else in your company is affected by these programs and needs to review and be aware of what they require? Remember that if it’s in writing that your company will do it, you will be held to that in a regulatory inspection. Are your programs compliant with OSHA standards?

Are you missing a plan? Visit SafetyPlans.com to purchase one you can edit and expand upon.

5. Take Advantage of Web Conferencing for Safety Training

Many companies have been using web conferencing software to hold online meetings or to just check in with each other. Take this time to get some of your general safety training out of the way. You could do weekly toolbox meetings or even longer sessions. Just make sure that you document what was held, on what date, who was the trainer, and who attended. You could even take a screenshot of the online attendees list, or a screenshot of the webcams of the persons in attendance to add to your documentation.   iSi can help you facilitate/setup this training, request more info here.

6. Spruce Up Your Training Materials

Speaking of training, now’s a good time to look at the training materials you’re using and consider giving it a refresh. Is the training still current and within the regs? Are the people in your videos dressed like characters from the 80s? At the very least, does your Powerpoint need a new look and some new pictures?

7. Write your RFPs

What services and products will you be needing for the rest of the year? Does your procurement/purchasing department require you to help them develop solicitations? Now would be a great time to knock out scope of work development, writing descriptions of what you’re going to need and developing the criteria for what information you want to see back from your vendors’ responses. Instead of waiting later when the RFP will go out, do this part now because you know you’re likely to be swamped later and won’t have the time to put much thought into it.

8. Get Quotes for Services and Products

If you already know the products and services you’re going to need, even if it’s later in the year, go ahead and approach your vendors now. It’s likely they’re working from home too, and with business slowing for everyone, now is a good time for them to work on pricing and proposals. With the uncertainty in the business climate, you may even get better pricing if you ask for it now than you would later when business will be catching up. Make sure you let them know what time frame you’re going to need it, and then ask vendors if they’ll hold that pricing until then. Get a quote from iSi.

9. Develop a Presentation for a Local Organization or Conference

Local safety organizations, safety conferences and civic groups are ALWAYS looking for speakers and presentations. The most popular highlight real-world safety management ideas, tell stories on how you have solved a problem that other EHS managers likely have faced, or just share how handle a particular part of compliance. For civic groups, use your knowledge of general safety principles and find a topic that may apply to all types of businesses and business owners. Speaking to a group or professional event is also a great way to get publicity for your company and yourself as a professional in the community.

Read our article The Importance of EHS Organizations and Conferences to Your EHS Compliance.

10. Research Products and Services That Will Make You More Efficient

Once everyone is back to work, it’s likely your budget will be strained, labor may be stretched, and you’ll have to do more in order to catch up. Now is a good time to find products or services that will help make you more efficient and save money in the long run. Try out new software, get samples of products, and find resources that can give you assistance to help you make up for gaps in staffing. Now is the time to round up the tools for your toolbox that you may need to use later.

11. Permit Reviews

If you have them stored electronically, take a look at completed lockout/tagout and confined space entry permits. Were the requirements of the permits fully executed and documented

12. Clean Up Your Email

How many times have you gotten the notice that your email boxes are full and it has been at the worst time you could’ve gotten that message? Go through your inbox and delete what you do not need anymore and read what you may have missed. Don’t forget to go through your sent items too. If you find you are not making much headway in creating space, sort your messages by size. This will allow you to uncover those emails with the 50 MB attachments that you don’t need anymore.

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Tami Hadley
Tami Hadley

Contributing:

Tami Hadley

Marketing Director | Project Manager, E-Training Solutions

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

Email  |  LinkedIn

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Electronic EHS Training: Maintain Certifications, Complete Requirements Now

Electronic EHS Training: Maintain Certifications, Complete Requirements Now

With stay-at-home orders mandated in many states, counties and cities across the U.S. due to the COVID-19 breakout, business operations have been dramatically affected – including environmental, health and safety training (EHS training).  Unless otherwise noted by regulatory agencies, compliance requirements are still required to be followed.  To help our clients stay compliant for the duties they’re performing iSi has electronic training options to help you make sure you maintain your certifications. 

With many business operations disrupted, this may actually be a very good time to get your required training taken care of for the year.

Viewing Options — How It Works

iSi can provide electronic EHS training in a number of ways.  One interactive option is our live instructor-led training that’s given through web conferencing.  Our online system allows for students to view slides and the instructor, ask questions both via audio and privately in a questions window, chat with other students in a chat room, respond to polls, download handouts, and take notes within the system that they can have emailed to them.  This provides interactive learning and because it’s live, questions can still be asked of the instructor. 

Need to watch at your convenience? iSi also has the ability to record presentations through the system and provide you a link so that your workers can watch on their own time.  These two options may be the best for training conducted now, but we provide longer term solutions such as slides with voiceover that can be used at your own schedule, produced videos, and even online modules with tests that can be imported into your learning management system.

March and April Scheduled Classes Moved Online

We currently have moved our scheduled March and April DOT and RCRA training classes online in order to help those registered stay certified.  DOT is especially strict about letting workers sign off on hazardous materials shipments past training deadlines, as it’s forbidden.  We have the following classes available for registration:

DOT Refresher:  March 27
DOT (Initial Training):  April 23-24
RCRA Hazardous Waste Management Refresher:  April 17

Our asbestos classes were not able to be moved to online methods due to our licensing requirements with the state of Missouri.  They do not allow electronic training alternatives.

Other Classes Available

iSi can provide a variety of other electronic EHS training classes covering OSHA general safety, EPA compliance, and DOT, IATA and IMDG hazmat shipping.  Contact us today to see how we can help you and maybe take care of some of your EHS training over the next few weeks. 

Complete Your EHS Training Now

Which courses can we prepare for you?  Contact us today!

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