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.

Safety News to Your Inbox

We email out our latest environmental, health and safety blog articles each week.  Don’t miss out on important compliance news and regulation changes. Sign up today!

Questions?

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

Receive News to Your Inbox

We send our articles by email whenever we add a new one.  Don’t miss out!  Sign up for our blog today.

Request a Quote

iSi can provide assistance in this area. How can we help?  Ask us for a price quote.

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

Questions?

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

Receive News to Your Inbox

We send our articles by email whenever we add a new one.  Don’t miss out!  Sign up for our blog today.

Request a Quote

iSi can provide assistance in this area. How can we help?  Ask us for a price quote.

How UV Lighting Can be Used as a Disinfectant for Your Facility

How UV Lighting Can be Used as a Disinfectant for Your Facility

UV Light for Your HVAC

iSi can now provide disinfecting UV lighting for your HVAC system. UV light installations kill protein encased viruses, bacteria and mold.

UV lighting can be used as another tool in your safety and environmental arsenal to make your workplace safer and healthier.  But how does it work?

What is UVGI?

Ultraviolet Germicidal Irradiation, or UVGI, is a technology that goes back to the 1930’s with studies showing that ultraviolet light has the ability to kill or inactivate airborne microorganisms. These studies showed that an optimal wavelength of 265 nanometers (nm) was able to provide the largest reduction in airborne microorganisms. This was found to be very close to the wavelength produced by low-pressure mercury vapor lamps (254 nm).

Ultraviolet light can be broken down into 4 different bands:

  • UV-V: 10-200 nm
  • UV-C: 200-280 nm
  • UV-B: 280-315 nm
  • UV-A: 315-400 nm

The sun emits the full spectrum of ultraviolet light but only UV-A & UV-B make it to the surface.  The others are filtered out by the Earth’s atmosphere.  The UV-C band is the most effective at attacking the harmful microorganisms, so it needs to be generated artificially.

UV light spectrum

How does UVGI work?

UV-C wavelengths are readily absorbed by the DNA and RNA of microorganisms such as germs and mold.  When absorbed, UV damages their DNA or RNA structure, preventing the microorganism from replicating. The magnitude of their reduction is affected by their resistance to UVGI, the quantity of UV energy delivered, and the type specific microorganism being irradiated.

UV light

Wall-mounted UV light system.

Disinfecting light is delivered in two common methods. The first is by placing light units, either with or without fans, near the top of a room close to the air vents in order to clean the air as it circulates the room.

The second method is to place the unit directly into the heating and air conditioning (HVAC) system. This second method places the light in a location where the room occupants are not directly exposed to the light, and if placed correctly, can have an added advantage of cleaning the HVAC coils and drip pan to improve the efficiency of the HVAC system.

iSi light frame

UV light for HVAC system.

The design and placement of these different systems are governed by the American Society of Heating, Refrigerating, and Air-Conditioning Engineers (ASHRAE) which has published many documents on the subject.

UV Safety Considerations

UV-C band light is a safer band than the UV-A and UV-B that we deal with in nature. We have always been taught to apply sunscreen and wear sunglasses to protect ourselves from the burns we receive when outside. Due to the shorter wavelengths UV-C will only penetrate the outer skin layers and along the surface of the eye. It will not give you the severe sun burn the longer wavelengths will. It will cause a reddening and slight irritation of the skin and an painful itching sensation that will last a few days in the eye so slight protection is required if you are directly exposed to the light from these units.

UV Lighting for Your HVAC Units

iSi is now providing the second method UV germicidal lighting, the one for your HVAC system.  Our units are customized to your specific HVAC system and area to be disinfected.  Learn more about this service and get a quote here.

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 

Questions?

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

Receive News to Your Inbox

We send our articles by email whenever we add a new one.  Don’t miss out!  Sign up for our blog today.

Request a Quote

iSi can provide assistance in this area. How can we help?  Ask us for a price quote.

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.

Return to Work

Check out our new Return to Work resource page for related articles and services!  

Questions?

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

Receive News to Your Inbox

We send our articles by email whenever we add a new one.  Don’t miss out!  Sign up for our blog today.

Request a Quote

iSi can provide assistance in this area. How can we help?  Ask us for a price quote.

Return to Work Building Issues: Stagnant Water

Return to Work Building Issues: Stagnant Water

Legionnaires, Heavy Metals Among the Hazards That Could Affect Your Building’s Water System Safety

As we all prepare to return to work, we may find additional hazards lurking in our buildings if they have been closed up or have had limited occupancy due to stay at home orders. Building water systems that have been sitting stagnant can have depleted disinfectant levels. This leads to increased bacteria and biofilm levels inside the system. It can also show increased levels of corrosion products such as iron, lead and copper depending on what your pipes are made from.

Water System Safety:  Environmental and Safety Hazards of Stagnant Water

As water sits unused in pipes, the disinfectant normally found in water (typically chlorine, but check with your water service to see what they are using) depletes to a point where a biofilm forms inside the pipe. This biofilm then grows and when the system is turned on water droplets can become airborne and inhaled causing many illnesses that can affect the lungs such as Legionnaires’ disease. Water that has sat in pipes also increases the amount of corrosion products from the piping itself and can lead to increased levels of metals in the water, depending on what your plumbing is made from. These increased levels can be ingested from various sources within a company such as drinking fountains, ice machines, plumbed coffee systems, water softeners, improperly maintained water heaters, on demand water heaters and dishwashers.

Water System Safety:  Have a Plan to Deal With the Stagnant Water dirty water in faucet

Before buildings are reopened, a plan should be established to flush out the contaminates in your building’s entire water system. This flush should go all the way back to the main line from the municipality. You may need the assistance of a plumber or water engineer to properly determine the size and length of the pipes so the proper volume of the water system can be calculated.

Once known, the volume will then determine the length of time the system will need to flow. In some cases, this could require over an hour of water flow. Be sure to pay special attention to any dead spaces in both the hot and cold-water systems. Remember, this water can be contaminated with bacteria that may cause respiratory issues and the hot water may be hot enough to cause burns so be sure to include proper safety equipment in the plan if doing large scale flushing.

Water System Safety:  Clearance Testing

Once the system has been flushed, testing can be done on the water to determine if it meets the standards established by the Environmental Protection Agency (EPA) for Primary Drinking Water. Those standards can be found at https://www.epa.gov/ground-water-and-drinking-water/national-primary-drinking-water-regulations. If you are interested in the USEPA’s Lead and Copper Rule a Quick Reference Guide can be found at https://nepis.epa.gov/Exe/ZyPDF.cgi?Dockey=60001N8P.txt.

If you need assistance in determining the safety of your buildings water system, please contact iSi.

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

Questions?

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

Receive News to Your Inbox

We send our articles by email whenever we add a new one.  Don’t miss out!  Sign up for our blog today.

Request a Quote

iSi can provide assistance in this area. How can we help?  Ask us for a price quote.

Bleach Safety

Bleach Safety

With the spread of COVID-19, businesses and households are looking for ways to clean and sanitize surfaces, and bleach is one of those cleaners that experts have deemed acceptable.  Before you begin, please review these bleach safety tips to ensure you and your workers are protected:​

Uses for Bleach

Bleach can disinfect which means it is effective at killing most bacteria, fungus and viruses but the surface needs to be clean of dirt and grime beforehand. If needed clean the surface with soap and water before disinfecting.

Cleaning refers to the removal of dirt and impurities, including germs, from surfaces. Cleaning alone does not kill germs. But by removing the germs, it decreases their number and therefore any risk of spreading infection.

Disinfecting works by using chemicals to kill germs on surfaces. This process does not necessarily clean dirty surfaces or remove germs. But killing germs remaining on a surface after cleaning further reduces any risk of spreading infection.

The Centers for Disease Control & Prevention (CDC) recommends the following concentrations for disinfection of hard surfaces:

  • 5 tablespoons (1/3rd cup) bleach per gallon of water
  • 4 teaspoons bleach per quart of water

Remember to always add bleach to water and not water to bleach.

Personal Protective Equipment 

Bleach is a corrosive, meaning it will burn skin, so it needs to be kept off skin and out of eyes. So always wear the following when mixing and using bleach.

  • Nitrile gloves
  • Safety glasses or chemical goggles
  • Long sleeves
  • Pants
  • Covered shoes

Always wash your hands with soap and water after working with any chemical but especially before eating, drinking or smoking.

First Aid

  • Eyes: Hold the eye open and rinse slowly and gently with water for 15 to 20 minutes, or for the time the manufacturer recommends. Remove contact lenses, if present, and continue rinsing the eye. Call a poison control center, emergency services, or a doctor.
  • Skin: Remove the contaminated clothing. Rinse the skin immediately with plenty of water for 15 to 20 minutes, or for the time the manufacturer recommends.
  • Inhaled/breathed in: Move the person to fresh air. If breathing is affected, call a poison control center, emergency services, or doctor.
  • Swallowed: Call a poison control center, emergency services, or doctor. Do not try to get the person to vomit unless told to do so specifically by a medical professional. Do not give anything by mouth to an unconscious person.

When providing first aid or when helping another person, be careful not to come into contact with the bleach yourself. Use protective clothing when necessary.

Hazards of Mixing Bleach

Don’t mix bleach with ammonia, acids, or other cleaners. Mixing bleach with common cleaning products can cause serious injuries. Be sure to always read the product label before using a cleaning product.

iSi works with companies to help them with safety and industrial hygiene issues.  Contact us if you have questions about industrial cleaning issues, using bleach or any other industrial disinfectant.

dont combine these bleach products

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

Questions?

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

Receive News to Your Inbox

We send our articles by email whenever we add a new one.  Don’t miss out!  Sign up for our blog today.

Request a Quote

iSi can provide assistance in this area. How can we help?  Ask us for a price quote.

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.

News to Your Inbox

Receive a copy of our blog post each week via email!  Sign up 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

Questions?

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

Receive News to Your Inbox

We send our articles by email whenever we add a new one.  Don’t miss out!  Sign up for our blog today.

Request a Quote

iSi can provide assistance in this area. How can we help?  Ask us for a price quote.

Creating a Pandemic Preparedness Plan for ISNetworld or for ANY Company

Creating a Pandemic Preparedness Plan for ISNetworld or for ANY Company

If you are a contractor to large refineries and manufacturers like we are, you are likely a member of one or more safety oversight companies like ISNetworld. Recently clients have been asking contractors to upload a Pandemic Preparedness Plan for ISNetworld, in response to the COVID-19 outbreak. Other non-ISNetworld clients may have also been doing the same, or you as a safety professional may have been thinking about what your company should develop. Using ISNetworld’s program questionnaire can help any company determine what should be included in a plan and give a place to start.

The following are the topics covered by the questionnaire for the current Pandemic Preparedness Plan for ISNetworld. Even if ISNetworld doesn’t apply to you, this may give you some ideas for best practices:

1.  Assignment of Ownership

Who is going to be in charge of carrying out the plan? Who is on that team and how is it decided?

2.  Hand Washing Facilities, Cleansers and Other Hygiene Items

What hand washing facilities will be available to your employees? What other sanitizing products will be available (i.e., hand sanitizers, disposable towels, etc.). In this section you could also cover personal protective materials to be provided as well.

3.  Periodic Training

Periodic training should be conducted regarding illness prevention and spread of disease. It should also communicate your policies regarding illness. At what frequency will they be conducted, and who will do (or be responsible for) that training.

4.  Work From Home Policy

What is your company policy regarding working from home, or staying at home when an employee is ill or taking care of an ill family member.

5.  Continuance of Operations

What is your company’s strategy for continuing operations if a large percentage of your staff becomes ill? What’s your plan for maintaining operations during quarantine or stay at home orders?

6.  Immunizations

Does your company encourage employees to get proper immunizations? 

7.  Communications

How are employee and internal communications conducted? 

8.  Gatherings

Does your company limit large or crowded gatherings during outbreaks or increased disease levels? What does that look like?

9.  Cleaning

What is your strategy for cleaning workplace surfaces and equipment?  

10.  Reviews and Testing

How will this plan be tested? How often will it be reviewed? Who is responsible for doing so?

11.  Lessons Learned

What is your process for implementing lessons learned? How will that be done, and who will do it?

Writing the Plan

Hopefully this gives you a start on creating your own Pandemic Plan. If you do not have the time nor the labor right now to do this, let us help! We have written these Pandemic Preparedness Plans for ISNetworld compliance and for our own company.  Contact us today for pricing!

Save Time With Our Template!

If you need help getting started, we have a template plan for you to purchase for $100.  Click below to buy and download this Microsoft Word document now.

Questions?

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

Receive News to Your Inbox

We send our articles by email whenever we add a new one.  Don’t miss out!  Sign up for our blog today.

Request a Quote

iSi can provide assistance in this area. How can we help?  Ask us for a price quote.

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!

Questions?

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

Receive News to Your Inbox

We send our articles by email whenever we add a new one.  Don’t miss out!  Sign up for our blog today.

Request a Quote

iSi can provide assistance in this area. How can we help?  Ask us for a price quote.

The Importance of Understanding the REAL Ramifications of Disinfecting Your Workplace

The Importance of Understanding the REAL Ramifications of Disinfecting Your Workplace

With all things COVID-19 impacting our businesses, researching immediate actions to understand their impacts is critical. Some companies may feel the pressure and immediate need to “clean” everything. However, it’s important to know which cleaning compounds work in what situations, the impact to the materials they’ll be cleaning, their composition, the application methods required by the label and the potential hazards they may cause those workers applying them and working around them.

Most businesses are considering decontamination strategies where it makes sense. In some cases, this might be at the janitorial level, and in other cases, it might be more of an industrial solution involving the production floor, manufacturing processes and even potential products that need to be disinfected/sanitized.

EPA-Approved Products

Some definitions to understand:

Cleaning is the removal of dirts, soils and impurities from the surface.

Sanitizing is meant to reduce, not kill, the occurrence and growth of bacteria, viruses and fungi (typically reduces bacteria on a surface by 99.9%).

Disinfecting a surface will “kill” the microscopic organisms as claimed on the label of a particular product. … The minimum level of effectiveness in a modern-day disinfectant is 100 percent kill greater-than 6-log reduction of an organism.

Both sanitizers and disinfectants are regulated by EPA. In order to substantiate their claims, testing is required to prove their function, and this would be the EPA certification. There are several pre-defined criteria that pertain to how they perform, at what concentration and conditions, what “bugs” they kill, how fast they work, etc. EPA registrations take time, often years. Companies can subregister under an existing formulation. That means they are using an already certified formula.

How Will What You Are Cleaning Be Affected?

All cleaners do not work with all materials. With the desire to decontaminate everything, one important item to consider is what you are actually “cleaning.” There are numerous products that are EPA-certified, and some will be on the acidic side. Others (most commonly) will be on the alkaline side, and even a few will be neutral. Their contents may include: hydrogen peroxide, quaternary amines, surfactants, acids, bases, etc.

Recently iSi evaluated a solution for disinfecting aluminum surfaces. With softer metals such as aluminum and copper, the possibility of corrosion or discoloration is much higher with certain disinfectants.

Most of your harder metals (steel, stainless, alloys) are unlikely to be affected.

These soft metal materials can be found in food processing plants, automotive, aerospace and other industries. Thus, it is important to know ahead of time what the results of using the cleaner will be.

Also, please make sure you’re applying the disinfectant per the product’s label and directions. Do not vary from those directions.  Variances in application methods from what the label says may alter the effectiveness of the disinfectant, cause damage to materials, and may make you non-compliant with regulatory guidelines.

How Will the Person Doing the Disinfecting Be Affected?

Make sure you know exactly what’s in the cleaners to be used. Most importantly, get their Safety Data Sheets (SDSs) and really read them and analyze them.

  • How will its usage affect the person who will be applying it?
  • What kind of personal protective equipment will be needed?
  • Do you have that personal protective equipment on hand? With national shortages, do you even have a way to get ahold of it?
  • How will it affect the atmosphere and air quality of the areas it will be used in?
  • What does the overall tone of it say about the type of person and qualifications needed to apply it? Is it really something you’d be comfortable having janitorial staff work with, or does it need to be someone with a greater level of hazardous materials training?
  • Do you have the staff on hand (right now) to take care of this?
  • What is your overall risk?

Unfortunately some SDSs can be vague, confusing, and can even contradict themselves. So please be very careful and make sure you have a firm grasp on what you’re dealing with.

We Can Help Take Care of It

iSi has been pulled into some research gathering for current clients, and also has been providing onsite personnel for others. We have people on-staff to help you with researching and figuring out your requirements. We deal with confusing and contradicting SDSs every day and have the proper staff of safety and chemistry personnel on hand to work through them. We also have an entire team of hazardous materials and safety trained and experienced industrial cleaning technicians ready to support you.

Give us a call, email us, or send us a message through social media and we will get back with you to see how we can help.

Need Help?

Do you need help with understanding the ramifications of a disinfectant?  We can help!

Questions?

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

Receive News to Your Inbox

We send our articles by email whenever we add a new one.  Don’t miss out!  Sign up for our blog today.

Request a Quote

iSi can provide assistance in this area. How can we help?  Ask us for a price quote.

Machine Guarding Real Focus of Renewed OSHA Emphasis Program

Machine Guarding Real Focus of Renewed OSHA Emphasis Program

OSHA has updated and renewed its National Emphasis Program on amputations in manufacturing facilities.  With this emphasis, OSHA will be targeting manufacturers and industrial facilities, with a focus on machine guarding and lockout-tagout.

Who’s On the List?

Machine guarding and lockout-tagout are annual residents on OSHA’s top 10 list of violations and cause amputations and injuries each year.  OSHA has had amputations on its national emphasis since before 2015, but they’ve updated it with a new list of potential NAICS codes to target based on data from 2015 to 2018.  OSHA is going to target industries with higher rates of machine guarding and lockout-tagout violations, higher rates of related incidents, higher rates of amputations, those with amputations within the past 5 years, and those with machine-related injuries or fatalities.  They’ve developed a target list of around 130 targeted NAICS codes.

Companies with less than 10 employees will not be on the target list, even if their NAICS code matches.

Please remember that as with all OSHA emphasis programs, if OSHA is onsite for another inspection, they can add this to their scope. 

What Will Be Looked At?

In addition to reviewing 4 years of OSHA logs, they will be inspecting your machinery and equipment, looking for hazard potentials in:

  • Pinch, Nip and Shear Points
  • Cutting Actions
  • Setup and Operation
  • Clearing Jams or Upsets
  • Making Adjustments When Operating
  • Cleaning/Greasing/Oiling
  • Scheduled and Unscheduled Maintenance
  • During the Lockout-Tagout Process

Machine guarding is used to protect both the operator and everyone else who could come in contact with a machine.  Any machine, part, function or process that can cause injury must be safeguarded.

The best way to ensure you are ready for an inspection is to make sure you’re compliant with the following standards.  These will be the ones used by inspectors as they’re the ones that have the greater potential to cause amputations:

1910 Subpart J – General Environmental Controls

1910.147              Control of Hazardous Energy (Lockout-Tagout)

1910 Subpart O – Machine and Machine Guarding

1910.212              General Requirements
1910.213              Woodworking Machinery Requirements
1910.217              Mechanical Power Presses
1910.219              Mechanical Power Transmission

Inspection Start Date

As with all new and revised emphasis programs, there will be a 90-day period where OSHA will provide outreach efforts to alert the industry about the changes before starting targeted inspections.  This puts targeted inspections starting around March 10, 2020.

More Information

For more information, check out the OSHA inspector directive here, which also includes the affected list of NAICS codes.

Need Help?

iSi has conducted a number of machine guarding audits for manufacturers.  Let us provide one for you today!

Questions?

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

Receive News to Your Inbox

We send our articles by email whenever we add a new one.  Don’t miss out!  Sign up for our blog today.

Request a Quote

iSi can provide assistance in this area. How can we help?  Ask us for a price quote.

Potential Employer Requirements in an OSHA Emergency Standard for COVID

Potential Employer Requirements in an OSHA Emergency Standard for COVID

UPDATE: 

President Biden signed an Executive Order on Thursday, Jan. 21, 2021 that requires the following:

  1. Within 2 weeks (by Feb. 4, 2021), OSHA is required to:
    • Issue guidance to employers on workplace safety during the COVID pandemic.
    • OSHA and MSHA are required to determine if an emergency temporary standard is necessary.  If so, it will be due by Mar. 15, 2021.
  2.  OSHA is required to review its enforcement efforts and identify any short-term and long-term changes to be made.
  3.  A National Emphasis Program on COVID-19 in the workplace is required to be developed.
  4.  OSHA is to work with state plan states to make sure they have similar COVID plans in place, and for those who don’t have a state plan, work with state and local officials to make sure they have plans in place to protect public employees.
  5. The Secretaries of Labor, Health and Human Services, Transportation, Energy and Agriculture need to work to identify that workers not covered under OSHA in their respective categories are protected.

What’s an OSHA Emergency Temporary Standard?

Under certain limited conditions, OSHA is authorized to set emergency temporary standards that take effect immediately and are in effect until superseded by a permanent standard. OSHA must determine that workers are in grave danger due to exposure to toxic substances, new hazards, or agents determined to be toxic or physically harmful where an emergency standard is needed to protect them.  OSHA publishes the emergency temporary standard in the Federal Register, where it also serves as a proposed permanent standard. It’s subject to the usual procedure for adopting a permanent standard except that a final ruling should be made within six months. The validity of an emergency temporary standard may be challenged in an appropriate U.S. Court of Appeals.

What May Employers Be Required to Develop in a Federal Standard?

In total, 14 states have adopted comprehensive COVID-19 worker protections through executive order and/or their state OSHA programs. 

Currently, there are 4 states – California, Virginia, Michigan and Oregon – that have issued a state-specific OSHA emergency standards through their state plans.  There are common themes between the policies of these 4 states and they have pulled items from each other.  These items would likely become a part of a federal emergency standard:

Conducting a Workplace Assessment

This would include identifying employee tasks, work environment, presence of the virus, number of employees, facility size, working distances, duration and frequency of exposure, and hazards encountered.

Develop an Exposure Control Plan

This would include designating an on-site COVID coordinator, providing free face coverings and requiring their use, signage, social distancing, barriers, remote working, prohibiting sick employees access to facility, enhanced cleanings for positive cases, employee screenings, and notification of positive cases.

Implement Controls 

This includes maximizing current ventilation systems, installing barriers, partitions, and airborne infection isolation rooms.

Training Employees 

Training would need to be specific to the place of employment.  Included would be reviewing control measures, proper use of PPE, how to report symptoms or positive cases, how to report unsafe working conditions, and an overview of the COVID-19 virus, symptoms, and means of transmission.

Maintain Records of Training, Screenings, and Notifications

This would include employee training, employee and visitor screenings, notifications as required to individuals and Health Departments.

How Often Have Emergency Standards Been Used Before?

OSHA has used emergency temporary standards 9 times.  The last time they were used was in 1983 for asbestos.  OSHA’s first emergency standard was also created for asbestos, and others have been created mostly for chemicals, including 12 different carcinogens, benzene and vinyl chloride.  Most standards have been challenged in court, and although there have been a few that have been vacated, most have remained in place.

###

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

We're Here to Help If You Need It

Short lead times for OSHA indicate the potential for a short lead time for employers to get program elements in place.  Our team of safety and industrial hygiene professionals are here to help with the things you may not have time to develop.  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

Questions?

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

Receive News to Your Inbox

We send our articles by email whenever we add a new one.  Don’t miss out!  Sign up for our blog today.

Request a Quote

iSi can provide assistance in this area. How can we help?  Ask us for a price quote.

What OSHA Says About Using Online Safety Training Courses

What OSHA Says About Using Online Safety Training Courses

OSHA's opinion on online safety training

Stay Informed!

News to your inbox! We cover OSHA, EPA and DOT regulations news & best practices each week.  Subscribe to our blog today!

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

Now…on to the article.

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

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

OSHA’s Opinion of Online Safety Training

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

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

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

Ability to Ask Questions

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

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

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

Where to Find These Interpretations

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

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

Do you need assistance in administering your safety training programs?  Let us help – contact us today!

OSHA’s New Weighted System for Inspection Priorities

OSHA’s New Weighted System for Inspection Priorities

Stay Informed!

News to your inbox! We cover OSHA, EPA and DOT regulations news & best practices each week.  Subscribe to our blog today!

OSHA’s fiscal year has started and with the new year comes a new system for weighting their priorities for inspections. This OSHA inspection weighting system is aimed to help them track inspection activity and give regional administrators a guide for prioritizing resources.

Inspection weighting has been around since 2015. Prior to that, OSHA would use numbers of inspections completed to count activity. This led to some inspectors loading up on shorter inspections in order to gain quantity while not giving as much credit to those who were doing the long, complex inspections. So, in 2015, a weighting system based on time of completion was developed. However, OSHA found that this was not as ideal as needed either.

The new system factors in agency priorities, inspection impact, and the most hazardous workplaces and operations. Each category of inspection is assigned a numerical value. The most time intensive, complex and high priority inspections gain the most points.

The following is the new points system, from highest value inspection to least value inspection. The points are listed in terms of Enforcement Units, or EUs.

1. Group A: High-Priority, Time-Intense, Complex Cases [7 EUs]

  • Criminal Cases
  • Significant Cases

2. Group B: High-Priority Hazards, More Complex Than Average [5 EUs]

  • Fatalities and Catastrophes
  • Chemical Plant National Emphasis Program Inspections
  • Process Safety Management Inspections

3. Group C: Focus Four Emphasis Program [3 EUs]

  • Caught-In Hazards (trenching, equipment operations, oil & gas)
  • Electrical Hazards (overhead power lines, electrical wiring methods)
  • Fall Hazards (scaffolds, elevated walking and working surfaces)
  • Struck-By Hazards (highway work zones, material handling, landscaping)

4. Group D: Programmed and National Emphasis Program Inspections [2 EUs]

  • Amputation Hazards
  • Combustible Dust
  • Ergonomics
  • Federal Agency Inspections
  • Heat Hazards
  • Non-PEL Overexposures
  • Workplace Violence
  • Permit Required Confined Space Hazards
  • Personal Occupational Exposure Sampling
  • Site-Specific Targeting

5. Other Regional/Local Emphasis Programs Not Already Covered (2-3 EUs)

6. Group E: All Other Inspections Not Listed (1 EU)

Phone/fax/email investigations (e.g., complaints) and rapid response investigations earn “activity points.” Each one of these earn 1 activity unit for every 9 completed, so the equivalent of 1/9 EU. Additional enforcement support activities such as responses to Freedom of Information Act requests, electronic correspondence responses, state plan monitoring and interventions have not gotten units assigned yet.

OSHA has weighted their compliance assistance activities as well.  This is the hierarchy from most important to least: 1. Voluntary Protection Program (VPP) evaluations, 2. OSHA Strategic Partnerships activities, 3. OSHA Alliances activities, and 4. Compliance Assistance activities such as making presentations and staffing informational booths.

Please note, that OSHA can and will still add on any program area to an inspection if they are already at your facility for another issue.

How would your facility do if it was inspected by OSHA tomorrow? Let iSi help you find out! We can conduct safety audits and mock/test run inspections and then help you prioritize the list starting with your most critical. Contact us for a price quote!

Where does your facility stand on OSHA compliance? Schedule iSi for a mock OSHA inspection, audit or walkthrough!

OSHA’s New Quantitative Fit-Testing Protocols Aim to Save Time & Effort

OSHA’s New Quantitative Fit-Testing Protocols Aim to Save Time & Effort

Respiratory Protection Assistance

iSi conducts both quantitative and qualitative fit-testing and can help you determine what your facility’s needs are for respiratory protection.  Contact us today!

OSHA has added two new fit testing protocols for quantitative respirator fit-testing.  The two new protocols are actually modifications of the current ambient aerosol CNC protocols for full-facepiece, half-mask elastomeric, and filtering facepiece respirators.  These modifications cut in half the number of steps required, also making them faster to conduct.

There are two types of manufacturers of quantitative fit-testing machines which are most popular, the Portacount by TSI and a controlled negative pressure (CNP) machine by Occupational Health Dynamics, or OHD.   The changes in the protocols affect TSI’s PortaCount-type machines.

 Quantitative Fit Testing vs. Qualitative Fit Testing

Qualitative fit-testing uses items such as saccharine 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 and N95 filtering facepiece respirators that have an 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 Assigned Protection Factor (APF) over 10.  Full-face tight fitting respirators have an APF of 50 and thus need to be quantitatively fit-tested.

The New Protocols

OSHA based their new protocols on the results of three different studies.  After consideration and comment, 4 of the 8 exercises were removed or changed. 

These include the grimace exercise, normal breathing, and deep breathing.  The grimace exercise was often found to shift the fit of the mask while the breathing exercises were considered exercises that rarely affected fit factor.  For full facepiece and half-mask respirators, talking was eliminated in favor of jogging-in-place, a new exercise.   

Additional changes were made to the number of sets and the duration.   OSHA anticipates 5 minutes can be shaved from each fit-test with the new protocols.

PortaCount Upgrades Needed

If you have PortaCount Models 8030, 8038, 8040 or 8048, you will need a software upgrade that you can download from the TSI website.  You can also have the update uploaded when you send in your machine for its annual service.  PortaCount Model 8020 or 8028 users will only be able to use the original 8-step protocols.   If you have a machine manufactured by another company which uses the same protocols, you will need to check with your manufacturer if the machine you’re using requires an update.

Link to the New Protocols

For more information about the specific protocols, visit the revised Appendix A of the standard.

iSi can help you determine your facility’s respirator needs then provide the personnel to help accomplish tasks — Contact us today!

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

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

Robot Safety Evaluations

iSi has provided safety assistance to companies utilizing laser guided vehicles.  Let us help you with hazard evaluations, training and related issues.

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

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

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

 Laser Guided Vehicles

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

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

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

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

Demolition Robots

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

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

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

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

NIOSH is Looking for Case Studies

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

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

The 3 Most Important Elements of a Good Safety Program

The 3 Most Important Elements of a Good Safety Program

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

Management Leadership

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

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

Worker Participation

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

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

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

Finding and Fixing Hazards

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

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

So How Do You Get It All Accomplished?

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

For example, iSi can assist with:

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

Need Help?

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

iSi can be an extra hand to help you accomplish your safety program goals.  Contact us today!

Self-Retracting Lifelines Under Recall

Self-Retracting Lifelines Under Recall

Fall Equipment Inspections

iSi conducts required routine fall protection equipment inspections for our clients companies.  Let us give you that 3rd party eye, and get this task off your to-do list.

If your company uses DBI-SALA self-retracting lifelines, you may be subject to a recall.  3M has issued a stop use recall on the DBI-SALA Twin-Leg Nano-Lok edge and the Twin-Leg Nano-Lok Wrap self-retracting lifelines.  If you have any of these, stop using them immediately and take them out of service.  All models manufactured since 2013 are affected.

Although no injuries have occurred yet, 3M has found that the energy absorbers may not properly deploy, which could result in serious injury or death.

What are Self-Retracting Lifelines?

Self-retracting lifelines are part of a fall protection system. They are placed above a worker’s head and work much like seat belts do.  They pull out and retract, but when tugged or a force is applied, an internal mechanism acts as a brake to shorten the distance of a fall.  Both of the affected DBI-SALA models are used to connect two self-retracting lifelines under the D-ring of a fall protection harness.  The edge model anchors at foot level and the Wrap Back wraps around the anchor. 

I’m Affected by the Recall – Now What?

If you have one of these models, you can either return it to 3M to be fixed, repaired, or replaced at 3M’s expense.  If 3M has not been able to determine a fix or a certified solution for your particular model, you may choose to send it back for a $200 refund. Once repair solutions are determined, and model SKU numbers have been certified, the cash option will not be available.  As of August 8, 2019, 3M has only found a fix for the edge model, not the Wrap-Back. 

For the edge model, 3M announced a fix had been certified to ANSI standard Z359.14 about 2 weeks after the recall notice.  Once the unit has been repaired, it will have a green checkmark on the front label.  This fix will only be available in regions that recognize the ANSI standard as a regulatory certification.  If you are located in an area where additional certifications are required for fall protection devices, 3M will be working to receive those certifications.

3M specifies that until it can fix your Nano-Lok edge models, none of its other twin-leg self-retracting lifelines are approved for use over sharp edges or abrasive edges.  That was the key feature of the edge model.

Get the Recall Notice

To learn more about this recall and to see if your model numbers are affected, check out the recall website at https://www.nanolokedgerecall.com/.

Required Fall Equipment Inspections

When was the last time you had your fall protection devices inspected?  Did you know iSi conducts the required routine fall equipment inspections for a number of our clients?  Let us give you a different pair of eyes in inspection, and help you check this requirement off your to-do list!  Contact us today!

When was the last time you inspected your fall protection equipment?  Let us do that for you — Contact us today!

House Bill Would Require OSHA to Develop Formal Heat Standard – Let the Debate Begin

House Bill Would Require OSHA to Develop Formal Heat Standard – Let the Debate Begin

A new bill introduced in the U.S. House of Representatives would require OSHA to establish heat exposure rules for both indoor and outdoor workplaces.

Called the Asuncion Valdivia Heat Illness and Fatality Prevention Act, it would require OSHA to issue a formal heat protection standard.  The bill was introduced on July 10 by U.S. House Representatives Judy Chu and Raul Grijalva, with 27 co-sponsors.  The Act is named for a farm worker who died from heat exposure.  Chu led the effort to get a similar law passed in the state of California.

The Bill and Standard Requirements

The current bill would require a federal standard as strict as any state law.  As a result, requirements would include:

  • Set exposure limits and limitations on how long workers can be exposed to heat.
  • Written heat-illness prevention programs including:
    • Engineering controls such as local exhaust ventilation, shielding from radiant surfaces, insulation of hot surface, evaporative coolers, fans and mist coolers, updating air conditioning systems, natural ventilation;
    • Administrative controls such as rotating work schedules, scheduling work earlier or later in the day, and work rest schedules;
    • PPE such as water-cooled garments, air cooled garments, reflective clothing, cooling vests; and,
    • Emergency response plans.
  • Workers would have paid breaks in cool spaces and access to water.
  • Employees would be allowed to acclimatize to the heat.
  • Employers would be required to train workers in heat-stress symptoms and responding to them.

If passed, the new OSHA heat standard would need to be in place within 2 years.  If the for some reason the standard wasn’t finalized by then, an interim standard would need to be created for finalization in another 2 years.

How Does OSHA Handle Heat Now?

Currently heat-related injuries and illnesses are cited under the General Duty Clause.  In June, a Georgia company was cited $21,311 for a worker who was hospitalized with heat exhaustion.  In January it cited the U.S. Postal Service $149,664 for a worker who died from a heat-related episode.  Many states and OSHA state-plan states have also developed their own rules.

House Committee Testimony – Let the Debate Begin

The bill has been introduced the House Committee on Education and Labor.  In a hearing of that committee on July 11, in addition to the testimony of Chu and Grijalva, other supporters ranging from an occupational health and safety professor, an organizer with a warehouse advocacy center, an occupational medical doctor, and a representative of the United Farm Workers of America gave testimony in support of the bill.   

However, a labor representative from California Farm Bureau federation, a safety and health representative of Associated General Contractors and other House committee members had some questions about the standard.

Congressman Ben Cline said that while it’s certainly a serious and important issue, he questioned if the bill was taking a one-size fits all solution.  He questioned if it would be overly burdensome to apply a federal standard to all areas of the country when there are different levels of heat and different levels of heat-related illness between states.  Cline said that a one-size fits all approach becomes much more complicated when it’s applied to different industries where the workplace may change from one place to another, such as in truck driving.  He also pointed out that in 2012, OSHA had considered a heat illness standard.  However, the effort was cancelled because OSHA found having one overall standard for this issue had many complications and opportunities for ineffectiveness.

Congressman Bradley Byrne questioned if it was possible to make a federal regulation flexible enough to both be effective and fit different workplaces, workers, and scenarios. He said that anything developed needs to have many stakeholders involved, from OSHA to employers to employees.  If the regulations are too onerous, employees may not want to do what they need to do to comply.  To get everyone involved, it will take time to develop, and the 2-year timeline for a federal regulation is incredibly short compared to the 15 years it took the state of California to bring together stakeholders to develop a similar but state regulation.  Byrne pointed out that OSHA already has a mechanism to enforce heat standards, and also cited the 2012 OSHA decision to cancel heat regulations in favor of enforcement and education. He said he’d like to hear from OSHA as they’re the ones who will be forced to implement such a standard in only 2 years, considering they had tried before and then had decided against it.  Byrne said Congress needs to be very careful when passing laws like this because of the unintended consequences that can come out of it. 

Watch the house committee meeting below:

Stay Informed!

News to your inbox! We cover OSHA, EPA and DOT regulations news & best practices each week.  Subscribe to our blog today!

iSi can help you with workplace safety issues, programs & training — Contact us today!

OSHA Updates 14 Standards

OSHA Updates 14 Standards

As part of the President’s Executive Order for agencies to improve regulations and conduct regulatory reviews, OSHA has been working on reviewing their standards to remove outdated, duplicate, and inconsistent parts of their standards.  The latest round of reviews and updates, called Standards Improvement Project – Phase IV, will go into effect on July 15, 2019 and it updates 14 different OSHA standards at a projected $6.1 million/year savings. 

Updates range from clarifications and deletions, to updates for current technology, to good news for cats.

Social Security Numbers
29 CFR Parts 1910, 1915, 1926

OSHA is eliminating the requirement to collect worker social security numbers in 19 of its standards.  Any social security numbers already collected on previous forms can remain on those forms, and if employers want to continue to collect numbers, they may do so.

 

Medical Services and First Aid
29 CFR 1926.50

Current standards require posting of physician, hospital and ambulance phone numbers where 911 service is not available.  At the time, 911 was a relatively new concept, but many of today’s 911 services for landlines can pinpoint the caller’s location.  If your area has landline auto-location for 911, you no longer have to post the additional information.

However, the auto-location feature isn’t always available for cell phones in remote locations.  The new rule requires employers, in areas where 911 auto-location for wireless phones is not available, to post the latitude and longitude of the current location in a conspicuous place so that emergency services may locate the worksite.  Employers are also to ensure that the communication system they are relying on to use to report an emergency is working and is effective.  

 

Medical Surveillance Requirements
29 CFR part 1910, subpart Z

Employers will no longer be required to conduct periodic chest x-rays of their employees for lung cancer purposes.  This is a requirement in asbestos, cadmium, coke emissions, inorganic arsenic, and acrylonitrile standards.  Medical data has been found that periodic x-rays don’t make much of a difference in reducing lung cancer.  However, periodic x-rays are still required for asbestosis determinations, and initial baseline x-rays are still required as well.  Digital radiographs will be allowed as well as different sizes of x-ray films.

 

Occupational Hearing Loss
29 CFR 1904.10

The recordkeeping rule now clarifies physicians must use the standards of 29 CFR 1904.05 to make the determination if a hearing loss is work-related.  Previously, employers have been able to not record hearing loss as an injury when a physician determines the loss was NOT work related. However, no guidance was given for physicians in that determination.  A cross-reference from 1904.05 will be added to 1904.10 to help make that determination.  Get more info on iSi’s work area noise surveys & sampling.

 

Cotton Dust
29 CFR 1910.1043

The technology of pulmonary function testing has come a long way since 1978. OSHA will be updating the pulmonary function testing guidelines.  More info on iSi’s worker sampling protocol development.

 

Lifelines
29 CFR 1926.104

OSHA is changing the minimum breaking strength of lifelines from 5,400 lbs. to 5,000 lbs. to align with the most recent ANSI/ASSE standards.

 

Process Safety Management (PSM)
29 CFR 1926.64

Rather than having a separate PSM standard for construction, this standard will now reference the general industry standard 1910.119.

 

Coke Oven Emissions
29 CFR 1926.1129

OSHA has determined coke oven emissions does pertain to construction work, and will be deleting the standard.  Any construction worker exposures to coke oven emissions will fall under the General Duty Clause.

 

Signs, Signals and Barriers
29 CFR 1926, Subpart G

Employers will now be required to comply with the 2009 version of the Manual on Uniform Traffic Control Devices to better align with DOT’s requirements.  OSHA feels the newest version adds better safety controls. These included high visibility safety apparel, stop/slow signage (not just hand signals), the use of automated flagger assistance devices, and crashworthy temporary traffic barriers and lane channelization. Confusing language will be removed from the traffic signs section, and the barricades and definitions sections will be deleted because they’re duplicates.

 

Materials Handling and Storage
29 CFR 1926.250

Currently, posting of maximum safe load limits of floors in storage areas is required.  However, in residential buildings, heavy materials are not placed in areas above floor or slab on grade.  Thus, this requirement no longer applies to construction of “single-family residential structures and wood-framed multi-family residential structures.”  iSi’s safety assistance services

 

Underground Construction
29 CFR 1926.800

Mobile diesel-powered equipment used in “other than gassy operations” must now meet the most current MSHA requirements of 30 CFR Part 7, Subpart E.

 

Occupational Health and Environmental Controls, Gases, Vapors, Fumes, Dusts and Mists
29 CFR 1926.55

“Threshold limit values” will change to “permissible exposure limits” and references to ACGIH standards will be removed.  OSHA is also cleaning up phrases such as “shall be avoided”, deleting the terms “inhalation, ingestion, skin absorption, or contact”, will change Appendix A to Tables 1 and 2, and will correct inconsistent and errant table headings, footnotes, cross references and asterisks.  iSi’s workplace sampling program development services

 

Shipyards
29 CFR 1915.80

Feral cats will no longer be considered vermin and thus, no longer a health and safety hazard.

 

Rollover Protective Structures, Overhead Protection
29 CFR 1926, Subpart W

OSHA is removing test procedures and performance requirements and replacing them with the current standards of ISO 3471: 2008.  They will also be making some other technical error revisions.

 

 For more details about each change, read the Federal Register notice here.

iSi can help you determine which of these safety and industrial hygiene issues will affect you — Contact us today!

LOTO Standard Also on OSHA’s Update List

LOTO Standard Also on OSHA’s Update List

Recently we featured that OSHA was soliciting information on powered industrial vehicles to determine the need for an updated standard.  Now OSHA is soliciting information on the lockout-tagout (LOTO) standard.  The current LOTO standard was published in 1989.  

The focus of OSHA’s efforts with LOTO centers on control circuit devices.  The LOTO standard requires energy-isolating devices to be used to control energy during servicing and maintenance of machines and equipment.  In the current standard, control circuit devices cannot be used for this purpose.  However, OSHA says it “recognizes recent technological advances may have improved the safety of control circuit-type devices.”

Since 2016, OSHA has granted variances in compliance to several companies who have been able to prove that the control circuit devices they were using could be a safe alternative.  During an evaluation of a recent variance request, OSHA decided that the time had come and the potential technology was available to consider if there was a basis to allow these devices in certain circumstances. Also, their own research has shown that these devices aren’t typically used in short servicing tasks of a machine and don’t require an extensive disassembly of the machine or entrance into it. As a result, OSHA wants feedback from the public and industry about this.

OSHA is requesting information on:

  • How employers have been using control circuit devices
  • Information about the types of circuitry and safety procedures being used;
  • Limitations of their use, to determine under what other conditions control circuit-type devices could be used safely;
  • Use and limitations of using industry consensus standards for LOTO such as ANSI/ASSPP Z244.1;
  • How the evolution of robotics technology such as collaborative robotics, robotics that move freely, or robotic devices that can be worn by workers has affected risks of worker exposure to hazardous energy;
  • The anticipated economic benefits, impacts, and other offsets that would occur if the standards were updated, such as benefits to productivity or reduction of injuries vs. costs of new equipment, servicing, or need for new training.

LOTO and electrical-related issues are found to be among OSHA’s Top 10 violations each year.  The agency is accepting comments electronically until August 18, 2019 at regulations.gov and from there, OSHA will be making a determination of what actions, if any, needs to be taken.  More information can be found here.

Temporary Personnel

iSi can provide temporary and part-time personnel to help fill in at your company in times of vacations, maternity leaves, as a stop-gap between hires, or for special projects.

iSi can help you with lockout-tagout compliance issues — Contact us today!

Is an OSHA Updated Forklift Standard on the Horizon?

Is an OSHA Updated Forklift Standard on the Horizon?

OSHA is soliciting information on powered industrial vehicles to determine the need for an updated standard.  The current standard was written in 1971, based on industry data from 1969.  OSHA realizes that national consensus standards have been updated several times and rule updates may be needed.

The term “powered industrial vehicle” refers to forklifts, fork and lift trucks, tractors, motorized hand trucks and other specialized industrial trucks that have an electrical or combustion engine.

OSHA is requesting information on:

  • Types, Age and Usage of Powered Industrial Vehicles in the Workplace
  • Maintenance and Retrofitting
  • How to Regulate Older Trucks
  • Types of Accidents and Injuries in Operating
  • Costs and Benefit of Retrofitting With Safety Features

The agency is accepting comments electronically until June 10, 2019 at regulations.gov and from there, OSHA will be making a determination of what actions, if any, needs to be taken.

Powered industrial vehicle incidents are among OSHA’s Top 10 each year, and a number of OSHA regions currently have emphasis programs dedicated to them as well.  Emphasis programs dictate that if an inspector sees a powered industrial vehicle while onsite for any other issue, the inspector can automatically include your powered industrial vehicles in the scope of the inspection. 

There are a number of common regulatory issues with powered industrial vehicles, mainly forklifts, that you need to be aware of to ensure compliance before your next inspection.  Check out our previous blog article, Forklift Top 6: Common OSHA Compliance Pitfalls for Powered Industrial Trucks

Are Your Forklifts Compliant?

Many OSHA regional emphasis programs include forklifts.  Is your program compliant and ready for inspection? Let us help!

iSi can help you with powered industrial vehicle compliance & training — Contact us today!

Centrifugal Pump Machine Guarding Issue Solved

Centrifugal Pump Machine Guarding Issue Solved

If your company has a centrifugal pump, you may have a machine guarding issue issue at risk for violation.   There is an exposed part of the machine that many manufacturers do not make guards for because the seals in this area are important for accessibility, maintenance, and operational purposes.  Below is an easy solution to fix this issue to make it machine guarding compliant and accessible at the same time.

OSHA Standard 1910.219(c)(2) provides details regarding horizontal shafting requirements.  Among those is that no one should be able to reach a finger into the machine.  Most pump manufacturers provide guards for the pump coupling, that is, the component that connects the power source to the pump.  However, guards are not typically provided for the space between the bearing frame and the casing (frame adapter).  In this space, the rotating shaft is exposed, and the packing gland or mechanical seal is located. This space is often inspected to determine if the packing gland or mechanical seal is leaking.  Placing a typical guard over this area prevents important monitoring functions.

A simple solution to this problem is to cover the frame adapter with plastic mesh and secure it with an extension spring.  The plastic mesh and extension spring come in many materials of construction to assure compatibility with the fluid being pumped. Plastic mesh or netting enables inspection of the packing gland or seal and is easily removed for maintenance. The plastic mesh can be cut, without difficulty, to fit each specific pump application.  As it is plastic rather than metal, the instances of being cut and injured on jagged edges are also removed.

In our experience, OSHA inspectors have been taking a look at these areas in their machine guarding audits.  To learn more about this machine guarding issue, contact us and we can assist!

Need Help?

Need help with machine guarding or an assessment of where you stand? 

Centrifugal Pump Without a Guard

centrifugal pump with machine guarding issue

Centrifugal Pump Without a Guard

centrifugal pump with machine guarding issue

Centrifugal Pump With a Guard

centrifugal pump with machine guarding

Centrifugal Pump With a Guard

centrifugal pump with machine guarding

iSi can help you with machine guarding issues and audits — Contact us today!

OSHA Electronic Injuries and Illnesses Reporting Rules Change

OSHA Electronic Injuries and Illnesses Reporting Rules Change

OSHA electronic reporting of injuries and illnesses rules have undergone another change, and this time it’s to account for worker privacy.  The new final rule was published in the Federal Register on January 25, 2019 and is effective February 25, 2019.

What Has Changed?

Employers with more than 250 employees were to begin including OSHA Forms 300 and 301 with their electronic submittals starting in 2019.  These forms name the particular workers affected, along with the body parts injured, date of birth, date of hire, address, and treatment.  This information could have made it to the online, searchable database, compromising sensitive employee information.

The new rule removes this requirement in order to protect worker privacy.  Employers with more than 250 employees are still required to submit their 300As.

In addition, OSHA is requiring employers to submit their Employer Identification Numbers with their electronic submissions.  OSHA feels this new requirement will help better organize and track submissions and avoid duplications.

Below is a revised table of requirements.  Are you required to submit OSHA electronic reports?  If you have questions, please contact us!

osha reporting requirements

Need Help?

Need an extra hand to get your safety issues covered? How about policies/programs developed or training conducted?

iSi can help with your safety compliance issues — Contact us today!

OSHA’s Ammonium Regional Emphasis Program

OSHA’s Ammonium Regional Emphasis Program

Need Help?

iSi can help you determine what you need to do to get ready for enforcement.

OSHA has announced it has developed a regional emphasis program for ammonium starting October 1, 2018.

Who is Affected?

The emphasis program targets fertilizer grade ammonium nitrate and agricultural anhydrous ammonium.  Both create a significant hazard of fire and explosion and are toxic to those who handle them.  Companies who store, mix, blend, and distribute these products will be targeted in this program.

Ammonium nitrate storage issues came into prominence with the 2013 West Fertilizer facility explosion.   This regional emphasis program was a recommendation of the Chemical Safety Board’s report following the incident.

Which States are Included?

The regional emphasis includes particular states from OSHA Region VI and OSHA Region VII.  These include Oklahoma, Texas, Arkansas and Louisiana from Region VI and Kansas, Missouri and Nebraska from Region VII.

What is the Enforcement Date?

Affected companies will have 90 days from October 1st to get their compliance activities in order before OSHA starts issuing penalties, roughly until the end of the year.   Storage of ammonium nitrate falls under 29 CFR 1910.109(i), and storage and handling of anhydrous ammonia falls under 29 CFR 1910.111.  There are other OSHA regulations and requirements which apply to the handling of these chemicals.

What’s Next?

If your company will be affected by this OSHA ammonium regional emphasis program, iSi can help you determine what you need to do to comply and be ready for any upcoming inspection.  If you don’t know if you are affected or not, we can help you make that determination.  Contact us today for pricing, or fill out our online form!

Let iSi help you determine you ammonium compliance elements!

Overheul to Discuss Link Between Safety Prequalification and Sales

Overheul to Discuss Link Between Safety Prequalification and Sales

Photo of James Overheul from iSi Environmental

James Overheul
iSi Manager of Safety & Industrial Hygiene

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

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

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

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

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

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

Livengood to Cover Identifying Industrial Hygiene Issues

Livengood to Cover Identifying Industrial Hygiene Issues

ryan livengood

Ryan Livengood, iSi Project Manager

iSi Project Manager Ryan Livengood will be presenting “How Can I Tell If I Have an Industrial Hygiene Issue and What Do I Need to Look For?” at the 69th Annual Kansas Safety and Health Conference.

The term industrial hygiene (IH) covers a wide variety of issues found in your workplace. Even seasoned safety professionals can overlook areas of concern. Which kinds of typical industrial operations trigger potential issues? How can you tell if you need sampling? In this presentation, Ryan will cover these topics plus give specific examples of operations with their corresponding potential IH issue as well as examples of typical sampling events.

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

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

Do you have an industrial hygiene issue at your facility? Do you need help determining what you need to sample for?  Let iSi help!

OSHA Compliance and Temporary Workers: Who’s Responsible?

OSHA Compliance and Temporary Workers: Who’s Responsible?

When it comes to temporary workers, who’s responsible for OSHA compliance?  Is it the host employer or the staffing agency?

Overall it’s the responsibility of both parties to ensure OSHA standards are being followed and workers are being protected. As a general rule, OSHA tends to lean towards site-specific issues being handled by the host and general issues be handled by the agency.

Communication

OSHA stresses the importance of communication between both the host and the agency and recommends responsibilities be clearly lined out in any contractual language before the working relationship between both companies begins. OSHA will be reviewing any contract between the host and the staffing agency to see where the responsibilities lie.

Staffing agencies are responsible for learning the potential hazards their temporary employees may encounter at the worksite. Agencies should determine what conditions exist, what hazards could be encountered, and how to protect employees. OSHA says that agencies need not have experts in safety and health on staff, however, they should receive training in hazard identification or employ the assistance of a third-party consultant to help them with those identifications. Ignorance of the regulations, or belief that one party or the other is responsible without it in writing will not be taken as a proper excuse by OSHA.

Recordkeeping and Reporting

Both parties are responsible for ensuring employees are involved in the recordkeeping system and that proper records are kept. Both parties are also responsible for making sure employees know how and where to report work-related injuries and illnesses. Neither can discourage employees from reporting an injury. When an injury does occur, the party who finds out first should report it to the other and then both the host and the staffing agency are to work together to investigate the cause.

When it comes to annual reporting, the employer who is supervising the employee on a day-to-day basis is the one who records the injuries/illnesses on their 300 logs.  OSHA says this is most often the host employer.

Training

Both companies are responsible for training. Staffing agencies must communicate the training that their employees already have to the host, and both the agency and the host must ensure the employees have the adequate training to do the job. The contract between the two parties should line out who’s responsible for which training.  As a rule of thumb, OSHA says that generic safety training would be the responsibility of the staffing agency and site-specific training would be the responsibility of the host site. Any training to temporary employees conducted by the host must be the same as training given to full-time employees.

PPE and Written Plans

It’s the responsibility of both parties to ensure the proper PPE is worn and provided. Neither can require the employee to purchase it themselves, that is, PPE will need to be provided to the employees. The parties can decide in their contract who’s responsible for purchase and assignment, but in examples from some of the OSHA’s guidance documents in these issues, the host employer will most likely be responsible for dictating what is proper PPE. This is because the host employer is already required to evaluate the workplace for exposure levels, have control over the processes and equipment that produce these hazards, and will be conducting surveillance of the areas. The staffing agency is responsible for knowing what those hazards are and how the employees are being protected.

Each party is required to have OSHA-required written plans when workers will be exposed to certain hazards. Example written safety plans required would include bloodborne pathogens, hearing conservation, hazcom, respiratory protection, lockout-tagout and other hazard-specific plans such hexavalent chromium or the new silica standards. The focus of each plan would be slightly different for each party, but a plan must be on file for each.

More Guidance

OSHA has a dedicated site to these issues, along with some good guidance documents for how to handle some regulations such as respiratory protection, industrial truck training, bloodborne pathogens, hazcom and more here. This site also gives examples of OSHA violations and which party was cited for which element.

Some of these issues, such as respiratory protection which has a number of requirements including medical considerations, can become tricky to navigate so please feel free to contact iSi for help in sorting out these issues.

Need Help?

Are you a host site trying to determine what you need to do?  Are you a staffing agency who needs help determining what you need to learn to comply?  Contact iSi and we can help!

How can we help make your compliance experience with temporary workers go smoother?  Contact us today!

Watch iSi’s Free Webinar Covering OSHA’s General Industry Silica Regulation

Watch iSi’s Free Webinar Covering OSHA’s General Industry Silica Regulation

A photo of a worker is potentially exposed to OSHA's general industry silica standard.

Webinar

Watch our webinar to determine how these regulations apply to your organization.

OSHA’s general industry silica standard went into effect on June 23, 2018.  iSi recorded a webinar on Friday, June 22, 2018 which covered:

  • Elements of the New Standard
  • Exposure Sampling Requirements and Compliance
  • Dust Controls
  • Respiratory Protection Implications
  • Medical Implications
  • and More!

This webinar is free — click here to watch it now!

Is your company affected?  Check out our previous blog article “Is Your Company Affected by the New General Industry Silica Standard?” to see if your industry could be a target.

We have also summarized some of the requirements of the new standard here.

OSHA Electronic Injury Reporting Due by July 1

OSHA Electronic Injury Reporting Due by July 1

Electronic injury and illness reporting is required annually by July 1st for select companies depending on size and industry.  What gets reported is also dependent on size, that is, companies with 250 or more employees submit the 300, 300A and 301 while companies with 20-249 employees submit only the 300A.  The following table summarizes the requirements for electronic reporting.  Immediately after the table is a link to the NAICS industry codes which are included in the requirements.

A table describing who is required to participate in OSHA electronic injury reporting.

Click here for a list of NAICS Codes covered industries applicable to this regulation.

How to Report

Injuries and illnesses will need to be completed through OSHA’s Injury Tracking Application website.   If you are in an OSHA-approved state program such as California, Maryland, Minnesota, South Carolina, Utah, Washington, and Wyoming, you are not required to participate in electronic reporting.

For those who do need to report, you’ll be able to enter your data through three different methods.

First, you can enter data in manually through a web form.

If you have multiple records and multiple establishments, the second option allows you to upload a database file to the system.  It will need to be saved as a csv file.  You can create csv files from Microsoft Excel spreadsheets.  OSHA has csv templates on their site, but these templates are more or less a list of the column names for your spreadsheet and examples of what needs to go into each.

The third option is for those of you who use automated recordkeeping systems.  For those systems, OSHA will have the ability for you to transmit that data electronically through an application programming interface (API).

If you need help submitting, or help in determining if you need to, please contact us and we’ll be happy to help you.

 

How can iSi help your company with OSHA recordkeeping?

Pin It on Pinterest