Sometimes You Really Need to Listen to the Voices in Your Head

Sometimes You Really Need to Listen to the Voices in Your Head

At iSi, the office and marketing/sales teams get involved in safety too, and one of the things we do is we each get a week to share a personal safety experience.  This is what I plan to share this month during my turn, and I hope you can take something away from it, especially as we head into National Safety Month this month.  – Tami Hadley

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Usually when someone talks about the voices in their head, it’s kind of a joke, or played off as a negative thing.  However, sometimes those voices can tell you good things that you actually need to listen to.  There was one important time I wish I had listened to the voices that were trying to help keep me safe, but didn’t.

In late June of 2001, 20 years ago this month, my sister-friend and I were seriously scalded in a kitchen accident.  My friend used to think homemade was the way to go.  Six kids later she thinks a little differently, but back then that’s the way it was.  She was canning green beans from her garden and she had one of the old-time pressure cookers from the 70s.  She hadn’t used it much, and I certainly didn’t know anything about it.

One night when I was visiting, she was wanting to get the beans canned.  Her husband usually took care of the pressure cooker part but he was gone that night.  She had seen him do it, so she decided she would do it herself.   When it was time to take the jars out, she couldn’t get the lid of the cooker off.  Earlier that evening, the lid was really hard to get on, and so it made sense that it would be hard to get it off.  She enlisted my help.  I’m a helper…sure I’ll help.  We stood over the stove and started trying to muscle the lid off, and it wasn’t moving.

We paused for a moment.  In that pause, later we both discovered when discussing the event, that a voice in our heads was saying to each of us “Wait a minute, maybe this isn’t a good idea.”  However, we both are get ‘er done types and there were a lot of other things to get done that night, so we proceeded.  What we proceeded into was pressurized scalding water going everywhere.  We had missed a step – depressurizing the cooker.

The water flew everywhere.  Scalding water covered my head, face, arms, hands, chest, stomach and upper thighs.  She got it all over her arms, legs and feet.  After being temporarily blinded, I ran to the bathroom sink for the cool water, and she went to the kitchen sink.  Besides the extreme pain, I knew it was bad when I looked in the mirror and saw a huge piece of skin on my nose falling off and my face beginning to swell.  I found out later that the boiled water remaining on my clothes was continuing to burn me.  I kept them on until I was convinced to strip down in the ambulance.  Well, not until I made them shut the door, and make my cop friend who was working that night, go away.

I ended up spending the night in the burn unit with second degree burns over 30% of my body and my friend had second and third degree burns.  The nurses in the emergency room had a real good time with me after learning I worked for a safety consulting company.  They made all the medical personnel who came in the emergency room ask me where I worked so I could relay the irony of the situation.

It was a long, painful July for the both of us and it took us about a month for full recovery.  We both still have scars, especially on our arms.  I tell her it’s like a tattoo to remind us of what we went through and what we should/shouldn’t do.  We are extremely fortunate and blessed it didn’t do any other long lasting scarring damage besides that.

If we would have listened to those voices in our heads, we could’ve stopped this accident from happening. 

Please relay to your teams that it is OK to stop and listen to those voices in your head when something does not seem right.  It’s ok to take a moment to rethink something before you do it.  Nothing is too important or needs to be completed so quickly that you can’t take a moment to rethink it, especially when it comes to your safety.

Some safety lessons I took away from this ordeal…

  1. It’s OK to listen to the voices when it comes to your safety.
  2. If you’re scalded, remove the clothing that has the hot water on it to prevent continual burning. A lot of my most painful injuries was a result of this.
  3. Scalding burns larger than 3 inches or that cover more than one area of your body need medical attention.
  4. Run cool or lukewarm water (not cold) over the area but don’t submerge yourself in it or you could lose body heat.
  5. If you’re going to use a pressure cooker, buy the ones with the best safety features and won’t let you take the lid off until you depressurize it. My friend did bravely “get back up on the horse” and used that old cooker again, but more safely.  I still refuse to be in the same room with it.
  6. Always be familiar with the proper procedures for using something – don’t rely on only doing it by sight or watching someone else – you may miss something very important.

What’s your safety story?  Do you use personal safety stories in your safety programs?  How is it working?  Let us know!

 

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Tami Hadley
Tami Hadley

Contributing:

Tami Hadley

Marketing Director | Project Manager, E-Training Solutions

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

Email  |  LinkedIn

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iSi Summer Safety Series:  Grilling Safety

iSi Summer Safety Series: Grilling Safety

photo representing grilling safety

Summer here and so is grilling season.  Well, it’s always grilling season in some places, but Summer is the time of year when it’s most conducted.  According to NFPA, 64% of all households own a grill or a smoker, and gas grills are the biggest culprit to fires.  10,600 home fires are started by grills each year.  On average 19,700 patients go to the emergency room each year because of grill injuries, 9,500 of those being thermal burns.   Here are some grilling safety tips to share with your co-workers, friends and family members.

  1.  Grill outside and away from any structures

Charcoal and gas grills are designed for outdoor use only. However, NFPA reports that more than one-quarter (27%) of home fires started by outdoor grills began in a courtyard, terrace or patio, and 29% started on an exterior balcony or open porch. Pay attention to overhanging tree branches when you set up your grill.

  1.  Make sure your grill is stable

Only set up your grill on a flat surface and make sure the grill can’t be tipped over. Consider using a grill pad or splatter mat underneath your grill to protect your deck or patio.

  1.  Keep your grill clean

Remove grease or fat buildup from both the grill and the tray below the grill. If you are using a charcoal grill, allow the coals to completely cool off before disposing of them in a metal container.

  1.  Check for propane leaks on your gas grill

Before the season’s first barbecue, check the gas tank hose for leaks by applying a light soap and water solution to the hose and then turning on the gas. If there is a propane leak, the solution will bubble. Other signs of a propane leak include the smell of gas near the barbecue or a flame that won’t light.

  1.  If the flame goes out, wait to re-light

If you are using a gas grill and the flame goes out, turn the grill and the gas off, then wait at least five minutes to re-light it.

  1.  Take care around the grill

Never leave a lit grill unattended. Don’t allow kids or pets to play near the grill. Never try to move a lit or hot grill, and remember the grill will stay hot for at least an hour after use.

  1.  Be careful with charcoal starter fluid

If you use a charcoal grill, only use charcoal starter fluid. If the fire starts to go out, don’t add any starter fluid or any other flammable liquids to the fire. Consider using a charcoal chimney starter, which uses newspaper to start the fire instead of starter fluid.

  1.  Wear the right clothing

Clothing can easily catch fire, so be sure your shirt tails, sleeves or apron strings don’t dangle over the grill.

  1.  Be ready to put out the fire

Have baking soda on hand to control a grease fire and a fire extinguisher nearby for other fires. If you don’t have a fire extinguisher, keep a bucket of sand next to the grill. Never use water to put out grease fire.

These easy-to-follow tips will help you and your family enjoy a safe summer barbecuing season.

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Go Orange for Work Zone Safety & Struck-By Hazard Awareness Week

Go Orange for Work Zone Safety & Struck-By Hazard Awareness Week

With spring and summer, along with the barbeques, pool parties and vacation days that come with warm weather, so does one other inevitability:  road construction.  The week of April 26-30, 2021 is National Work Zone Awareness Week.  Road construction occurs all throughout the year, but tends to start ramping up in the warmer spring and summer months.  So now is a good time to review some good safety practices on construction zone safety.

Work zones separate construction activities and construction workers from traffic, allowing both to work in harmony.  However, construction zones create a different traffic pattern and can sometimes be confusing areas.  On top of that, there are workers and machinery moving about.  Speed reduction areas, delays for pilot cars, and even route changes can affect our time schedules too.

According to the U.S. Department of Transportation, 2019 fatalities rose 11% from 2018.

  • There were 762 fatal crashes in work zones, 324 on arterial roads and 287 on the interstates
  • There were 842 fatalities in work zones, 690 of those fatalities were drivers and passengers
  • Of the fatal crashes, 33% were commercial motor vehicles
  • 31% of fatalities involved speed
  • 24% of fatalities were rear-end collisions

National Work Zone Awareness Week Events and Materials and Go Orange

You are encouraged to participate in Go Orange Day on Wednesday April 28, 2021 and wear orange to spread the message of work zone safety with your friends, family, coworkers and community.  There are a ton of resources out there to share with your workers as part of your weekly safety messages and meetings.  Here are some links to some sites for national and state event information and resources you can download:

National WorkZone Safety Information Clearinghouse (National and State Site Links)

Download a Flyer to Share with Your Workers from the National Work Zone Week Site

Download iSi’s 1-page Safety Toolbox Flyer With Safety Tips to Share With Your Team 

National Work Zone Awareness Week Website

Participate – National Work Zone Awareness Event Tool Kit

Struck-By National Stand-Down Week

Along with National Work Zone Awareness Week, NIOSH’s National Occupational Research Agenda’s (NORA) Construction Sector Council is promoting the National Stand-Down to Prevent Struck-By Incidents.  Struck-by hazards have been OSHA’s leading cause of death and non-fatal injuries since 1992.

NORA will be hosting 2 webinars on Monday April 26.  One is about cranes and lifting and the other is preventing struck-by incidents.  To register, download this flyer about the event.

You can also find a wide variety of training materials, infographics and other resources on struck by hazards here on the Center for Construction Research and Training Website.

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If your company would like assistance with creating toolbox topic presentations/materials or new employee training, contact us for a price quote!

 

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OSHA Proposes Changes to Hazcom Standard

OSHA Proposes Changes to Hazcom Standard

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

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

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

Here are the items currently up for comment:

 Relabeling Containers and “Released for Shipment” Dates

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

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

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

Bulk Shipments

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

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

Labeling for Small Containers

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

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

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

Trade Secrets

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

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

 SDS Terminology

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

Appendix D Changes

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

Other Appendix Changes

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

Definitions and Terminology

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

Training Required

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

How Often Should There be Changes?

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

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

Where Can You Make Comments?

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

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

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

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

Getting Value Out of the “Same Old List”

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

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

First, What’s on the List?

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

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

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

Well…It’s the Top 10 for a Reason

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

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

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

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

Make Your Job Easier Tip 1:  Break it Down

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

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

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

Make Your Job Easier Tip 2:  Instant Safety Topics!

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

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

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

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

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

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

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

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

Make Your Job Easier Tip 5:  Get Help

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

In Conclusion

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

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

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

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

OSHA fines

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

The Violation Categories

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

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

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

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

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

Calculating Violation Amounts

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

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

Gravity Based Penalty Amounts

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

Severity + Probability = Gravity Based Penalty Amount

Here are the Gravity Based Penalty Amounts for 2021:

Gravity-based penalties for OSHA 2021


History Reductions

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

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

Good Faith Reductions

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

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

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

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

Business Size Reductions

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

Quick Fix Reductions

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

Limits of Discounts

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

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

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

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

Other Penalties

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

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

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

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

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

Safety Management Programs

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

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

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

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

What is Ototoxicity?

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

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

Which Chemicals Are Considered Ototoxic?

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

Which Industries or Operations May be Affected?

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

How Do You Test for Otoxicity?

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

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

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

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

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

PPE and Training Requirements

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

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

Does This Affect You?

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

Keith Reissig
Keith Reissig

Contributing:

Ryan Livengood

International Hazardous Materials Logistics Manager | EHS Regulatory Trainer

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

Email 

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Workplace Safety Technology: T-Mobile for Business Adds 4G LTE HardHat and Contactless Temperature Device

Workplace Safety Technology: T-Mobile for Business Adds 4G LTE HardHat and Contactless Temperature Device

EHS Technology Solutions

iSi can help you find safety and environmental technology solutions to make your job easier.  Contact us today! 

T-Mobile for Business has added two new workplace safety technology products geared to make workplaces safer.  Each one also has features to help provide solutions related to recent concerns with workplace health.  The first product is a “smart” hard hat by Guardhat.  The other is a contactless temperature device for people entering crowded or confined spaces.  Both devices will take advantage of T-Mobile’s 4G LTE connectivity.

Guardhat

Guardhat utilizes sensors that let you know where the worker is at all times and what conditions they are working in order to analyze that data.  It also allows for audio and video communications so that you can see what they see and communicate back and forth with a central control center.

Some of the features include:

  • Location: Geofencing sensors track where Guardhat wearers are at, at all times.  Persons at a central control center can see where they are on a map.  Wearers can be alerted when they’re getting too close to hazards such as moving equipment, lockout/tagout areas, working areas like trenches or equipment drop zones and other dangers.   Sensors can be placed on all types of equipment and other assets so it can be tracked as well.
  • Communications: Guardhat wearers can communicate with the control center through voice and video capabilities.
  • Environment Monitoring: The hat will sense gases, noise, temperature and pressure issues and sound an alert until the worker gets to a safe location.   Persons at the control center will be able to use the camera on the hat and the locating sensors to help guide the worker to safety, if needed.
  • Physical Monitoring: The hat monitors vital stats and if it senses something is medically wrong with a worker wearing one, it will send an alert to other Guardhat users in the area and then will contact emergency medical services.
  • Fall Detection: The hat will sense when a worker has fallen and will alert other wearers in the area as well as emergency services.
  • Social Distancing: Location sensors can also be setup to ensure workers are working 6 feet from each other for social distancing purposes.

Guardhat is good for workers in areas with a number of hazards around them as well as workers who work alone in isolated areas.

PIMMAP Contactless Temperature Solution

The PIMMAP Contactless Temperature Solution is an 8-inch HD tablet that is an infrared camera and contactless temperature sensor.   It can be mounted to stands, kiosks or stations in places like schools, offices, arenas, factories, stores, hospitals, etc.

A person will stand in front of the device and it will use its infrared camera and facial recognition features to take temperatures at accuracy readings +/- 0.36 degrees F.   Facial recognition technology will also scan for signs of fatigue, watery eyes, and other flu-like symptoms.

Readings can be taken from 3-5 feet from the device and can scan 40 persons per minute.  An alert will come up on the screen if the temperature is too high.

The data for the device can be transferred to cloud servers and they can send push notifications.  They can also be worked on and troubleshot remotely.  If there’s no internet access where the device is located, it has its own 4G LTE router.

To learn more about these workplace safety technology devices, check out T-Mobile’s news release about them here.

Tami Hadley
Tami Hadley

Contributing:

Tami Hadley

Marketing Director | Project Manager, E-Training Solutions

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

Email  |  LinkedIn

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Industrial Hygiene in Construction: Focus Four Health Hazards

Industrial Hygiene in Construction: Focus Four Health Hazards

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

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

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

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


Manual Material Handling

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

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


Noise

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

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

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


Air Contaminants

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

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

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

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

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

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


High Temperatures

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

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

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

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


In Closing

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

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

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

Worker & Area Sampling

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

Tami Hadley
Tami Hadley

Contributing:

Tami Hadley

Marketing Director | Project Manager, E-Training Solutions

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

Email  |  LinkedIn

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

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

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

Federal Judge Rules OSHA 300 Info is Not Confidential

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

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

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

MSA Warns of Shortage of White Tychem, Tyvek 

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

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

Respirator Posters Available in 16 Languages

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

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

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iSi Summer Safety Toolbox: Staying Hydrated

iSi Summer Safety Toolbox: Staying Hydrated

hydration safety toolbox

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

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

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

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

Some symptoms of dehydration include:

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

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

drew lyon
drew lyon

Contributing:

Drew Lyon

Project Manager | Meteorologist

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

Email  |  LinkedIn

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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 

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COVID Complaints: Will You Be Inspected by OSHA?

COVID Complaints: Will You Be Inspected by OSHA?

​Updated 5/22/2020

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

Employee Complaints

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

OSHA Puts Employers in One of 3 Risk Groups

High Risk

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

Medium Risk

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

Low Risk

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

Inspections 

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

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

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

What to Expect in an Investigation Letter

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

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

  • Provide backup documentation of your investigation

  • Provide corrective actions taken or to be taken

  • Provide backup documentation of corrective action

  • Post the letter

  • Sign a certificate that you posted the letter

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

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

Return to Work

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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

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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?

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12 Tasks for Safety Managers Working From Home

12 Tasks for Safety Managers Working From Home

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

1. Develop Your Pandemic Plan

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

2. Review/Develop Cleaning Procedures

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

3. Review Your Emergency Plans

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

4. Review Your Written Safety Programs

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

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

5. Take Advantage of Web Conferencing for Safety Training

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

6. Spruce Up Your Training Materials

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

7. Write your RFPs

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

8. Get Quotes for Services and Products

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

9. Develop a Presentation for a Local Organization or Conference

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

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

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

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

11. Permit Reviews

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

12. Clean Up Your Email

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

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Tami Hadley
Tami Hadley

Contributing:

Tami Hadley

Marketing Director | Project Manager, E-Training Solutions

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

Email  |  LinkedIn

Questions?

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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?

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Electronic EHS Training: Maintain Certifications, Complete Requirements Now

Electronic EHS Training: Maintain Certifications, Complete Requirements Now

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

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

Viewing Options — How It Works

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

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

March and April Scheduled Classes Moved Online

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

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

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

Other Classes Available

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

Complete Your EHS Training Now

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

Questions?

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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!

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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?

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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

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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

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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:

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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!

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