In a recent letter to the U.S. Occupational Safety and Health Administration (OSHA) on the proposed “Walking-Working Surfaces and Personal Protective Equipment” rule (29 CFR, Part 1910), the American Society of Safety Engineers (ASSE) urged OSHA to utilize existing fall standards and the voluntary consensus standards process widely used in industry as it develops the new rule.

ASSE believes the process and the end users would be better served if standards such as the American National Standards Institute (ANSI) ANSI/ASSE Z359 Fall Arrest Code as well as the ANSI/ASSE A1264.1-2007 Safety Requirements for Workplace Walking/Working Surfaces and Their Access; Workplace Floor, Wall and Roof Openings; Stairs and Guardrails Systems standards were utilized in developing the OSHA rule.

A voluntary consensus standard is a documented agreement, established by a consensus of subject matter experts and approved by a recognized body that provides rules, guidelines or characteristics to ensure that materials, products, processes and services are fit for their purpose. Voluntary consensus standards developed by industry in accordance with ANSI’s procedures for due process, openness and consensus are often subsequently adopted by the government as part of the regulatory framework. Currently, ASSE is secretariat for 11 standards projects overseeing several committees made up of subject matter experts.

In his August 19 letter to Assistant Secretary of Labor for OSHA David Michaels, ASSE president Darryl C. Hill, Ph.D., CSP, said, “ASSE’s members are most concerned with several inconsistencies between the proposed rule and relevant consensus standards. We believe OSHA has been given a responsibility to utilize consensus standards like Z359 and A1264 by Congress in Public Law 104-113, ‘The National Technology Transfer and Advancement Act of 1995’ and through the Office of Management and Budget’s Circular A-119, ‘Federal Participation in the Development and Use of Voluntary Consensus Standards and in the Conformity Assessment Activities’.

“We understand the agency’s responsibilities in developing a standard are more complex than simply mirroring consensus standards and that its current ability to update references to consensus standards is inadequate, but we believe the ANSI/ASSE Z359 and the ANSI/ASSE A1264.1-2007 standards developed by subject matter experts should be used in developing this rule revision,” Hill said. “ASSE supports the performance-oriented approach that would set a general requirement coupled with a non-mandatory appendix of appropriate national consensus standards proposed in OSHA’s rulemaking, ‘Updating OSHA Standards Based on National Consensus Standards; Personal Protective Equipment’. We urge OSHA to move that proposal forward, especially when it comes to enhancing workplace safety and health.”

ASSE stated its overall appreciation for OSHA’s effort in this rulemaking to be consistent with the approaches to fall protection reflected in current national voluntary consensus standards and that some of the concerns ASSE raised earlier in the rulemaking process have been addressed.

However, there are concerns. Hill commented on several specific topics that ASSE’s members believed OSHA had not gone far enough in addressing in the rule including body belts for work positioning devices; the hierarchy of controls in Z359; fall protection on rolling stock and motor vehicles; fall protection for employees standing or climbing on stacked materials; qualified climbers; qualified person inspecting walking/working surfaces; trigger heights; training; competent person; body belts; snaphooks; personal fall protection systems; the deceleration distance requirement; the conversion factor; and, positioning systems.

“While ASSE’s members have various concerns about the current proposed rule, we do commend OSHA for its efforts to advance this rulemaking and offer whatever assistance our members or the Z359 and A1264 committees can provide to help ensure a positive outcome,” Hill concluded.

Founded in 1911, the Des Plaines, Ill.-based ASSE is the oldest safety society and is committed to protecting people, property and the environment. Its 32,000 occupational safety, health and environmental professional members manage, supervise, research and consult on safety, health, transportation and environmental issues in all industries, government, labor and education. For more information, go to www.asse.org.

“Injury and illness prevention programs are a better approach than safety incentive programs,” said OSHA Assistant Secretary David Michaels in his American Society of Safety Engineers webinar in May. “Already, workers have lots of incentives to work safely. We don’t need incentives. We need strong safety and health programs.”

Given this perspective, OSHA’s accelerated effort to adopt an Injury and Illness Prevention Program (I2P2) standard makes sense. Once adopted, the standard would require all U.S. employers to have company I2P2s, something that, incredibly, is not required under current regulations. Michaels said he wants the standard in place within three years, a lightning pace if judged by OSHA’s past standard adoption performance.

Through its effort to require injury and illness prevention programs at all work sites, OSHA hopes to bring much added focus to the question of what constitutes an effective safety and health program. The basic purpose of an I2P2 is identification and assessment of hazards and the institution of prevention measures. Good data collection is one aspect; so is worker involvement and top-management attention. Training is also critical.

“Safe work is more important than reporting,” said Michaels, who stressed that employers’ drive for low, reported injury and illness rates has corrupted the data and masked the extent of the nation’s workplace safety and health problems. “We want programs that reward workers for working safely, identifying hazards and abating them. A good I2P2 is a better approach than an incentive program.”

During June, OSHA convened three sessions to receive public comment on its proposed I2P2 standard. The LHSFNA participated and is working with the Building and Construction Trades Department of the AFL-CIO to develop an I2P2 rule specific to the construction industry. Eventually, the key components of a solid safety program will be codified in the new standard.

Michaels also urged companies to use government safety consultation services that are provided at the state level, and he praised Voluntary Protection Program (VPP) companies that strongly pursue safety programs and safe workplaces. He advised all companies to develop I2P2s and to engage their workers and supervisors in the process.

The LHSFNA’s Occupational Health and Safety Division provides support to LIUNA signatory employers who want help developing company- and site-specific safety programs. It can be reached at 202-628-5465

OSHA defines I2P2 programs as management systems that are designed to help employers reduce workplace injuries and illnesses “through a systematic process that proactively addresses workplace safety and health hazards.” In 1989, OSHA implemented an I2P2 program that encouraged employers to voluntarily implement a safety and health protocol and programs. During the Clinton administration, OSHA attempted to promulgate a regulatory requirement that employers implement I2P2 programs, but the effort stalled due to opposition from employers. OSHA dropped the effort from its agenda in 2002, but the Obama administration has indicated that an I2P2 rule is a high priority. Current OSHA Assistant Secretary David Michaels has spoken frequently of his determination to implement a final rule on I2P2 in the near future.

Stakeholders at the June 29 meeting discussed four general topic areas: possible regulatory approaches, the scope and application of the rule, organization of the rule, and the economic impacts of the rule. Organized labor was bullish on the notion of implementing an I2P2 requirement, while employers were mostly opposed to a new mandate. In general, employers expressed concern over requiring firms to implement an I2P2 system rather than relying upon a voluntary system. Small business representatives were particularly vocal about the burden of an I2P2 requirement and urged that any such rule permit flexibility or carve out exemptions based upon size or injury rate. Additionally, many employers requested that an I2P2 rule should consider employees’ behavior and overall wellness and the impact of those factors on risk and injury. During the meeting, a recommendation was made that the proposed rule contain a section on employee duties to complement the employer duties. Finally, employers in attendance urged OSHA to ensure that any I2P2 regulation would not be overly prescriptive and that it address only those areas of workplace safety that have been proven quantitatively to benefit from specific health and safety management protocols.

Several steps remain before an I2P2 rule could be finalized; indeed, a proposed rule has not even been drafted. The June 29 meeting marked the third of five I2P2 stakeholder meetings scheduled for 2010; previous meetings took place on June 3 in East Brunswick, N.J., and on June 10 in Dallas, Tex. The remaining meetings will be held on July 20 in Washington, D.C., and on August 3 in Sacramento, Calif.

Once the stakeholder meetings have been completed, OSHA must proceed through the regular rulemaking process, which involves drafting a proposed rule, publishing it in the Federal Register, permitting public comment, and responding to public comment before a Final Rule is issued. Since the regulation impacts small businesses, OSHA must include one additional step as part of the review process: In coordination with the Small Business Administration (SBA), OSHA must also establish a Small Business Regulatory Enforcement Fairness Act (SBREFA) panel that includes small business representatives impacted by the proposed rule. The panel will review the regulatory language and preliminary government analysis of the regulation’s impact before producing a report that will be published along with the rule. SBREFA also requires that all rules reviewed by a panel are subject to Congressional review.

If a stranger passed out on the sidewalk in front of you, how likely would you be to administer mouth-to-mouth?

In our age of no-touch faucets in public bathrooms and special disinfectant wipes for grocery store carts, you wouldn’t be alone if you say you might hesitate.

Happily, two new studies conclude that when it comes to CPR, pressing rhythmically on the chest with your hands is enough to save a life.

No mouth-to-mouth required.

The American Heart Association, which has been promoting hands-only CPR for two years, hopes that bystanders will feel less apprehensive and more likely to act if faced with an emergency.

Studies indicate that fear of doing something wrong, more so than catching something, makes many would-be-heroes freeze. And people may have has good reason to fear doing something wrong when practicing traditional mouth-to-mouth CPR.

The traditional method is a bit complicated, and one study showed that those who did attempt it often didn’t do it very well. For starters, the victim’s head has to be tilted back, the airway cleared, the nose pinched and the mouth completely covered with the rescuer’s.

There are many opportunities for air to escape, and some experts believe that some bystanders perform mouth-to-mouth so poorly that the interruption reduces blood flow.

Yet the aim of CPR is to do some of the mechanical work of the heart by forcing at least some blood and oxygen to the brain and other vital organs, which is why chest compressions work.

The only cases in which mouth-to-mouth seems to make a difference is when the victim is a child, or in cases of adults who have stopped breathing because of choking, drowning or other respiratory problems.

WASHINGTON - A proposed rule to align the Occupational Safety and Health Administration’s Hazard Communication Standard (HCS) with provisions of the United Nations Globally Harmonized System of Classification and Labelling of Chemicals (GHS) will be published in the September 30 Federal Register.

The current HCS requires chemical manufacturers and importers to evaluate the hazards of the chemicals they produce or import and provide information to subsequent users. The current standard requires all employers to have a hazard communication program for workers exposed to hazardous chemicals. The program includes materials such as container labels, safety data sheets, and employee training.  A number of countries, including the United States, international organizations and stakeholders participated in developing the GHS to address inconsistencies in hazard classification and communications. The GHS was developed to provide a single, harmonized system to classify chemicals, labels and safety data sheets with the primary benefit of increasing the quality and consistency of information provided to workers, employers and chemical users. Under the GHS, labels would include signal words, pictograms, and hazard and precautionary statements. Additionally, information on safety data sheets would be presented in a designated order.

The proposal to align the hazard communication standard with the GHS will improve the consistency and effectiveness of hazard communications and reduce chemical-related injuries, illnesses and fatalities,” said acting Assistant Secretary of Labor for OSHA Jordan Barab. “Following the GHS approach will increase workplace safety, facilitate international trade in chemicals, and generate cost savings from production efficiencies for firms that manufacture and use hazardous chemicals.”

Under the Occupational Safety and Health Act of 1970, OSHA’s role is to promote safe and healthful working conditions for America’s men and women by setting and enforcing standards and providing training, outreach, and education. For more information, visit www.osha.gov.


OSHA requires you to train employees to prevent lockout/tagout (LO/TO) accidents in the workplace (1910.147). This standard covers the servicing and maintenance of machines and equipment in which the unexpected energization or start up of the machines or equipment, or release of stored energy could cause injury to employees. This standard establishes minimum performance requirements for the control of such hazardous energy.

Employees must be trained in accordance with 1910.147(c)(7) . Here are 5 areas which are considered a must part of any Lockout/Tagout training program.

1. Failure to stop equipment. Sure, this sounds like common sense, but there’s much more involved. Some workers value productivity above safety and others feel that their age or experience with equipment make them immune from risk. “Taking the trouble” to properly safeguard energized equipment is essential in all cases.

2. Failure to disconnect from the power source. When working with and around electric equipment, some workers believe that simply operating the on/off switch will ensure their safety. They ignore the fact that the switch may be defective or that power may find its way through a short circuit or other source.

3. Failure to drain residual energy. There’s a reason that televisions carry warnings about trying to open the case even if the set is disconnected. That’s because many electrical devices store power in a capacitor or battery. Even unplugged, the risk remains. A compressed spring, hot pipe, pressurized tank, or heavy object hanging overhead can store energy even when the initial source of power is disconnected.

4. Accidental restart of machinery. Even if an employee knows how to shut down equipment before working on it, his or her co-workers may not. In too many instances, unknowing employees cause injury to their co-workers.

5. Failure to clear work areas before restarting. Restarting machinery must be performed as carefully as shutting it down and locking it out. A repair tool left in the works can fly out, or a restart while a co-worker remains in the path of danger represents as great a hazard as not locking out the machine at all.

Speeding is one of the primary factors leading to vehicle crashes. In 2008, 31% of all fatal crashes were speeding-related. The estimated economic cost to society for speeding related crashes is $40.4 billion per year.

Driving at higher speeds reduces the ability of drivers to avoid obstacles or react to sudden changes in the roadway environment and increases crash severity. The pervasiveness of speeding behavior is reflected in a recent national survey that showed that approximately 75% of all drivers reported speeding in the past month. Since most drivers often do not see speeding as risky or dangerous behavior, it is imperative that

NHTSA gain a better understanding of the motivations for speeding behaviors in order to develop and refine effective interventions and countermeasures.

NHTSA proposes to conduct follow-up focus groups with 72 participants from an earlier on-road instrumented vehicle data collection conducted in Seattle, WA and College Station, TX.

Focus group recruitment will be based on participants’ speeding patterns in the on-road data. The focus groups will contribute to a better understanding of speeding and speeders, a more accurate taxonomy of high/low speed driver subgroups, and a better understanding of the motives, attitudes and habits of these subgroups. The focus groups will explore speed choices and speeding behaviors and the factors that influence them, beliefs and attitudes toward speeding, reactions to and discussions about specific driving scenarios, and individual/group responses to various speeding countermeasures. The focus groups are expected to provide data relevant to descriptions of key motivations, attitudes, normative commitment to law, driving habits relevant to speeding and speeding

countermeasures; descriptions of countermeasures with the greatest likely benefits; implementation issues and concerns associated with the countermeasures; and key advantages and disadvantages associated with various countermeasures.

Affected Public: NHTSA plans to conduct six focus group sessions, three in Seattle, WA and three in College Station, TX. Each focus group will consist of 8–12 participants and last approximately 80 minutes. Participants will be recruited by e-mail or telephone based on their driving behaviors in the earlier on-road phase of the study and their demographic characteristics. Participation by all respondents would be voluntary and confidential.

Estimated Total Annual Burden: The total estimated annual burden is between 64 and 96 hours, depending on the number of participants (range 8–12) in each group. The respondents would not incur any reporting cost from the information collection. The respondents also would not incur any record keeping burden or record keeping cost from the information collection.

Comments are invited on the following:

(i) Whether the proposed collection of information is necessary for the proper performance of the functions of the agency, including whether the information will have practical utility;

(ii) The accuracy of the agency’s estimate of the burden of the proposed information collection;

(iii) Ways to enhance the quality, utility, and clarity of the information to be collected; and

(iv) Ways to minimize the burden of the collection of information on respondents, including the use of automated collection techniques or other forms of information technology.

A comment to OMB is most effective if OMB receives it within 30 days of publication.

No one knows how or when a disaster will strike. But everyone should be prepared. A disaster is a sudden event that causes great harm to people and property. The disaster might be severe weather, such as a hurricane or a tornado. Or it might be a flood, an earthquake, or a volcano.

Disasters can also be caused by people. A large fire might threaten an entire community.

Chemicals might spill from a truck. A terrorist attack might threaten air, water, or personal safety. Being prepared starts with having a conversation. Household members need to talk about the kinds of things that can happen where you live. Develop a family communication plan and assemble disaster supply kits that are stored in an identified place in the home. If a disaster does strike, go to an inside room of your home, or to the room with the fewest windows. Bring your disaster supply kit with you. Listen to a battery-powered radio for news and instructions.

Sometimes household members are away from home during a disaster. Or emergency officials might advise you to leave your home. In either case, you and your loved ones will need a place to meet. Pick a friend or relative’s house outside your neighborhood. Be sure to pick this place before a disaster strikes so you can be prepared. Also, memorize the phone number of a relative that lives out of state. Use it if you become separated from your loved ones. Let that relative know where you are so your loved ones can find you.

Your communication plan should include:

Places in and out of your town, where you and your family could meet.

Phone numbers of in-town contacts.

An address and phone number of someone out of town (this could be a friend or relative).

You can write this information on a card that each family member keeps with them. Help your children feel safe.

Discuss and learn together about the different types of weather that can affect your area.

Tell your children that you or another grownup will be there to help if something happens. Talk about how a relief worker, firefighter, police officer, teacher, neighbor or doctor might help.

Put a list of emergency numbers by each telephone in your home. Tell you children what each number is for. You should also list the work and cell phone numbers of family members.

FEMA has a site, www.Ready.gov which is devoted to emergency planning.  FEMA’s motto is:

  1. Get a Kit
  2. Make a Plan
  3. Be Informed

There are many disasters happening throughout the US.  BE PREPARED!

Leadership in Energy & Environmental Design (LEED) is an internationally recognized green building certification system, providing third-party verification that a building or community was designed and built using strategies aimed at improving performance across all the metrics that matter most: energy savings, water efficiency, CO2 emissions reduction, improved indoor environmental quality, and stewardship of resources and sensitivity to their impacts.

Developed by the U.S. Green Building Council (USGBC), LEED provides building owners and operators a concise framework for identifying and implementing practical and measurable green building design, construction, operations and maintenance solutions.

LEED addresses both commercial and residential building types. It works throughout the building lifecycle – design and construction, operations and maintenance, tenant fitout, and significant retrofit. And LEED for Neighborhood Development extends the benefits of LEED beyond the building footprint into the neighborhood it serves.

Since its inception in 1998, U.S. Green Building council(citation LEED for existing buildings v2.0 reference guide page pg 11) has grown to encompass more than 14,000 projects in the United States and 30 countries covering 1.062 billion square feet (99 km²) of development area. The hallmark of LEED is that it is an open and transparent process where the technical criteria proposed by USGBC members are publicly reviewed for approval by the almost 20,000 member organizations that currently constitute the USGBC.

The Green Building Certification Institute (GBCI) was established by USGBC to provide a series of exams to allow individuals to become accredited for their knowledge of the LEED rating system. This is recognized through either the LEED Accredited Professional(LEED AP) or LEED Green Associate (LEED GA) designation. GBCI also provides third-party certification for projects pursuing LEED.

The development of LEED began in 1993 and was spearheaded by Natural Resources Defense Council (NRDC) senior scientist Robert Watson who, as Founding Chairman of the LEED Steering Committee (until 2006) led a broad-based consensus process that included non-profit organizations, government agencies, architects, engineers developers, builders, product manufacturers and other industry leaders. Early LEED committee members also included USGBC co-founder Mike Italiano, architects Bill Reed and Sandy Mendler, builder Gerard Heiber, builder Myron Kibbe and engineer Richard Bourne; engineers Tom Paladino and Lynn Barker co-chaired the LEED technical committee in 1996.

In 1998 the LEED 1.0 pilot program was released; during the pilot period extensive revisions were made and by March 2000 LEED 2.0 was released to the marketplace.

LEED has grown from one standard for new construction to a comprehensive system of six standards covering all aspects of the development and construction process. LEED also has grown from six volunteers on one committee to more than 200 volunteers on nearly 20 committees and over 200 professional staff in Washington, DC. LEED was created to accomplish the following:

  • Define “green building” by establishing a common standard of measurement
  • Promote integrated, whole-building design practices
  • Recognize environmental leadership in the building industry
  • Stimulate green competition
  • Raise consumer awareness of green building benefits
  • Transform the building market

Green Building Council members, representing every sector of the building industry, developed and continue to refine LEED. The rating systems address eight major areas:

  • Location and Planning
  • Sustainable Sites
  • Water Efficiency
  • Energy and Atmosphere
  • Materials and Resources
  • Indoor Environmental Quality
  • Innovation and Design Process
  • Regional Priority

The Rating System

LEED has evolved since its original inception in 1998 to more accurately represent and incorporate emerging green building technologies. LEED NCv1.0 was a pilot version. These projects helped inform the USGBC of the requirements for such a rating system, and this knowledge was incorporated into LEED NCv2.0. LEED NCv2.2 was released in 2005. Today, LEED consists of a suite of nine rating systems for the design, construction and operation of buildings, homes and neighborhoods. Five overarching categories correspond to the specialties available under the LEED Accredited Professional program. That suite currently consists of:

Green Building Design & Construction

  • LEED for New Construction and Major Renovations
  • LEED for Core & Shell Development
  • LEED for Schools
  • LEED for Retail New Construction (planned 2010)

Green Interior Design & Construction

  • LEED for Commercial Interiors
  • LEED for Retail Interiors (planned 2010)

Green Building Operations & Maintenance

  • LEED for Existing Buildings: Operations & Maintenance

Green Neighborhood Development

  • LEED for Neighborhood Development

Green Home Design and Construction

  • LEED for Homes

In 2003, the Canada Green Building Council received permission to create its own version of LEED based upon LEED-NC 2.0, now called LEED Canada-NC v1.0.

LEED also forms the basis for other sustainability rating systems such as the Environmental Protection Agency’s Labs21.

After four years of development, aligning credits across all LEED rating systems and weighting credits based on environmental priority, USGBC launched LEED v3, which consists of a new continuous development process, a new version of LEED Online, a revised third-party certification program and a new suite of rating systems known as LEED 2009. In response to concerns that LEED’s requirements are cumbersome and difficult to learn, in 2009 USGBC supported the development by BuildingGreen, LLC of LEEDuser, a third-party resource that contains tips and guidance, written by professionals in the field, on applying LEED credits and the LEED certification process.

In LEED 2009 there are 100 possible base points plus an additional 6 points for Innovation in Design and 4 points for Regional Priority. Buildings can qualify for four levels of certification:

  • Certified - 40 - 49 points
  • Silver - 50 - 59 points
  • Gold - 60 - 79 points
  • Platinum - 80 points and above

During my time in the military, I spent a lot of time working in the hospital ER.  Each year right around July 4th, we always had injuries when children and adults mishandled fireworks.  Burns, eye injures, missing or partly missing fingers and every once in a while something more serious.  The article below comes from kidshealth.org.  I hope you will follow their advise

With warm weather and family events, the Fourth of July can be a fun time with great memories. But before your family celebrates, make sure everyone knows about fireworks safety.

If not handled properly, fireworks can cause burn and eye injuries in kids and adults. In 2003, six deaths were linked to fireworks and hospital emergency departments treated 9,300 fireworks injuries.

The best way to protect your family is not to use any fireworks at home — period. Attend public fireworks displays, and leave the lighting to the professionals.

Lighting fireworks at home isn’t even legal in many areas, so if you still want to use them, be sure to check with your local police department first. If they’re legal where you live, keep these safety tips in mind:

  • Kids should never play with fireworks. Things like firecrackers, rockets, and sparklers are just too dangerous. If you give kids sparklers, make sure they keep them outside and away from the face, clothing, and hair. Sparklers can reach 1,800° Fahrenheit (982° Celsius) — hot enough to melt gold.
  • Buy only legal fireworks (legal fireworks have a label with the manufacturer’s name and directions; illegal ones are unlabeled), and store them in a cool, dry place. Illegal fireworks usually go by the names M-80, M100, blockbuster, or quarterpounder. These explosives were banned in 1966, but still account for many fireworks injuries.
  • Never try to make your own fireworks.
  • Always use fireworks outside and have a bucket of water and a hose nearby in case of accidents.
  • Steer clear of others — fireworks have been known to backfire or shoot off in the wrong direction. Never throw or point fireworks at someone, even in jest.
  • Don’t hold fireworks in your hand or have any part of your body over them while lighting. Wear some sort of eye protection, and avoid carrying fireworks in your pocket — the friction could set them off.
  • Point fireworks away from homes, and keep away from brush and leaves and flammable substances. The National Fire Protection Association estimates that local fire departments respond to more 50,000 fires caused by fireworks each year.
  • Light one firework at a time (not in glass or metal containers), and never relight a dud.
  • Don’t allow kids to pick up pieces of fireworks after an event. Some may still be ignited and can explode at any time.
  • Soak all fireworks in a bucket of water before throwing them in the trash can.
  • Think about your pet. Animals have sensitive ears and can be extremely frightened or stressed on the Fourth of July. Keep pets indoors to reduce the risk that they’ll run loose or get injured.

If a child is injured by fireworks, immediately go to a doctor or hospital. If an eye injury occurs, don’t allow your child to touch or rub it, as this may cause even more damage. Also, don’t flush the eye out with water or attempt to put any ointment on it. Instead, cut out the bottom of a paper cup, place it around the eye, and immediately seek medical attention — your child’s eyesight may depend on it. If it’s a burn, remove clothing from the burned area and run cool, not cold, water over the burn (do not use ice). Call your doctor immediately.

Fireworks are meant to be enjoyed, but you’ll enjoy them much more knowing your family is safe. Take extra precautions this Fourth of July and your holiday will be a blast!

OSHA Steps Up Enforcement of Worker Training Requirements

OSHA will step up enforcement of worker training requirements, especially for non-English speaking workers, according to a recent announcement from Secretary of Labor Hilda Solis. She announced a number of major new OSHA enforcement initiatives during her April 14 speech at the National Action Summit for Latino Worker Health and Safety. OSHA currently requires that training provisions under OSHA standards be provided in a language or a form workers can understand. OSHA has already developed a training language policy. OSHA further requires that its compliance officers check and verify that workers have received the training required by OSHA standards. The Agency will expand upon this and effective on April 28—Workers Memorial Day—Secretary Solis explained, “OSHA will also assure that its Compliance Officers check and verify not only that the training has been provided, but that it was provided in a format that the workers being trained can understand.”

Trainers need to find ways to hurdle language barriers. While English is a second language for an increasing percentage of the workforce, employers are still obligated to make sure Hispanic worker training and other immigrant worker training is understood by employees. It’s not enough to make a presentation if you know that members of your audience may not be able to comprehend or use the information effectively. The Occupational Safety and Health Administration (OSHA), Department of Labor (DOL), and other government agencies are keenly aware of this.

Following are some commonsense tips for Spanish worker training:

  • Establish companywide safety policies for bilingual training supported by top management.
  • Hire supervisors who are bilingual.
  • Provide signage (safety guidelines, emergency evacuation, warnings) in Spanish and include diagrams or symbols.
  • Pair new employees with bilingual veteran employees who comply with safety and health guidelines.
  • Conduct periodic jobsite visits and work with employees in the field.
  • Follow up formal training with demonstrations, then have employees demonstrate to one another.
  • Conduct safety meetings and toolbox talks to reinforce formal training

OSHA’s Training Language Policy

According to OSHA’s training standards policy statement, if an employee does not speak or comprehend English, instruction must be provided by the employer in a language the employee can understand. Similarly, if the employee’s vocabulary is limited, the training must account for that limitation. According to OSHA, an employer’s responsibility to provide employees with safety information and training doesn’t go away because an employee can’t understand standard English-language training programs. When that is the case, employers must inform and train these workers in a language they can understand.

The policy directs OSHA compliance inspectors to determine whether workplace instructions regarding job duties are given in a language other than English. If so, they will also need to provide safety and health training to employees in the same manner. If a reasonable person would conclude that the employer had not conveyed the training to its employees in a manner they were capable of understanding, the violation may be cited by the inspector as serious.

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