Mon 30 Oct 2006
As you know, I usually don’t promote or endorse products on this site, but this product may be useful to anyone who has hazardous materials on-site. Employees, First Responders or anyone needing hazmat information, can simply press a button and the information about a specific hazardous material (MSDS) will be verbally given to them
Hazard Communication:
|
Sun 29 Oct 2006
Hazardous Waste Spill Reports [40 CFR 265.196]
There are several requirements for reporting releases of hazardous waste, which differ depending on whether the release came from a tank or a container, the quantity released, and whether the release came from a large or small quantity generator of hazardous waste. Moreover, some states have reporting requirements that are more stringent than the federal EPA requirements. According to 40 CFR 265.196(d), releases to the environment from hazardous waste tanks must be reported to the EPA regional office within 24 hours of detection, unless the release is less than one pound and it was immediately contained and cleaned up. However, if the release amount is at least its Reportable Quantity per 40 CFR 302.4, it must be reported immediately to the National Response Center. Reporting to the National Response Center satisfies the 40 CFR 265.196 reporting requirement. (more…)
Wed 25 Oct 2006
The Emergency Response Guidebook (ERG2004) was developed jointly by the US Department of Transportation, Transport Canada, and the Secretariat of Communications and Transportation of Mexico (SCT) for use by firefighters, police, and other emergency services personnel who may be the first to arrive at the scene of a transportation incident involving a hazardous material. It is primarily a guide to aid first responders in (1) quickly identifying the specific or generic classification of the material(s) involved in the incident, and (2) protecting themselves and the general public during this initial response phase of the incident. The ERG is updated every three to four years to accommodate new products and technology. The next version is scheduled for 2008. (more…)
Mon 23 Oct 2006
Er-Go-Nom-Ics
by Allan Kaufman, Director, The Compliance Resource Center
Er-go-nom-ics or human engineering is an applied science that coordinates Ergonomics or the design of devices, systems, and physicial working conditions with the capacities and requirements of the worker. 70% of the workers in the US think they know what the Ergonomics mean. However, only about20% actually get it right.
What do some experts say? I have taken some classes with Bill Brough of Washington Ergonomics. Bill looks at Ergonomics as an engineering problem and with and engineering solution. The Ergonomics Society defines Ergonomics as, “Ergonomics is the appliaction of scientific information concerning humans to the design of objects, systems and environment for human use.” Because of my Sports Medicine background, I look at it as a medical problem with an engineering and medical solution. There is no right or wrong answers, just different approaches to the problems.
What we do know is that Ergonomic injuries occur more often then they are reported. OSHA has a four-prong guideline under the general duty clause. The Department of Labors’s enforcement plan for Ergonomics focuses on industries and employers with known high injury and illness rates related to Ergonomic hazzards. OSHA coordinates inspections with a legal strategy designed to target prosecutable Ergonomic violations. Seroius Ergonomics hazards will be addressed using Section 5(a)(1) of the OSHA Act, often referred to as the General Duty Clause. Ergonomics inspection teams work closely with DOL attorneys and experts to successfully bring prosecutions uder the General Duty Clause.
The best was to understand your workplace’s Ergonomic issues is to get and Ergonomic audit. Whether you have and office, warehouse, or manufacturing facility, Ergonomics are often a issue, No matter how you define Er-Go-Nom-Ics, the problems can be solved.
Thu 19 Oct 2006
Emergency Eye wash stations and Emergency Showers Although the OSHA standard for eyewashes and safety showers at 29 CFR 1910.151(c) is brief, it clearly states when this equipment is necessary:
Where the eyes or body of any person may be exposed to injurious corrosive materials, suitable facilities for quick drenching or flushing of the eyes and body shall be provided within the work area for immediate emergency use.
OSHA accepts industry consensus standards, such as ANSI Z358.1 as a means of compliance with this rule.
The ANSI standard Z358.1-2004 “Emergency Eye Wash and Shower Equipment” includes the following requirements:
Eyewash squeeze bottles or personal eyewash units are considered secondary units that can supplement plumbed and self-contained stations, but cannot replace them. They are portable and permit initial first aid by providing for immediate flushing of contaminants or small particles. However, eyewash bottles are very difficult for the user to handle, especially when alone and when both eyes have been exposed. (e.g., holding the eyelids open while handling the unit is awkward). Also, one bottle cannot flush both eyes simultaneously. Since the fluid supply lasts for only a short period of time, the bottle may not able to wash the eyes sufficiently. The main purpose of secondary units is to supply immediate flushing. Once accomplished, the user should proceed immediately to a self-contained or plumbed eyewash and flush for the required flushing/ rinsing period.
Keep a copy of the safety shower or eye wash manufacturer’s instructions. Ensure that the equipment is installed, tested, maintained and used in accordance with these instructions. Also, refer to MSDSs to identify which chemicals are corrosive and how to respond to accidental overexposure. Of course, it’s best to prevent eye injuries in the first place. Click here for OSHA’s suggestions.
Wed 18 Oct 2006
Disaster Preparedness Resource Available
Employers and employees involved in cleanup and recovery efforts following natural disasters will benefit from a new “tool” developed by OSHA and the Gulf Coast Chapter of the American Society of Safety Engineers (ASSE). The 2006 Disaster Preparation Resources CD features a compilation of resources from OSHA, ASSE, the Centers for Disease Control and Prevention, and the Federal Emergency Management Agency on ensuring safe and healthful response and recovery operations. The CD will help employers review, develop and update their emergency preparedness plans. E-mail ASSE’s Sarajenie Smith at ssmith@asse.org for a copy, or call (847) 699-2929.
Mon 16 Oct 2006
Tips: Chemical Safety
As seasons change it is important to address the possible hazards associated with the chemicals, every day products, in your home as one does in the workplace. The American Society of Safety Engineers (ASSE) notes that in every home the cleaning and other chemicals that sit side by side in cupboards, the garage, the bathroom, the basement and the attic, could be extremely harmful to you and your family if you mix them or use them incorrectly.
“Working safely with chemicals in the home is really no different than working with them in the workplace,” said ASSE member Pam Ferrante, CSP, CHMM, of Pittsburgh, Pa. “Sometimes the chemicals used are more hazardous and we use larger quantities, but the safety principles are the same. We urge everyone to be cautious.” (more…)
Fri 13 Oct 2006
Staying a Step Ahead
Employees don’t just slip and fall because they are careless. Hidden risks exist at all work sites.
by Wayne Maynard and George Brogmus
Slips and falls are complex events. If you focus on just one part of the problem, such as a cracked tile or slippery floor, the risk will still exist. Instead, attack the whole problem with a systems approach that analyzes your organization and pinpoints areas needing attention.
Taking Control
Same-level slips and falls are the second-leading cause of disabling workplace injuries. They cost private industry more than $5 billion in direct costs alone each year. The indirect costs for hiring and training replacement workers, increased absenteeism, and decreased productivity are estimated to be three to five times higher. But slips and falls are not unavoidable “acts of God” due to employee carelessness or bad luck. You can control them. Here’s how.Same-level slips and falls are the second-leading cause of disabling workplace injuries. They cost private industry more than $5 billion in direct costs alone each year. The indirect costs for hiring and training replacement workers, increased absenteeism, and decreased productivity are estimated to be three to five times higher. But slips and falls are not unavoidable “acts of God” due to employee carelessness or bad luck. You can control them. Here’s how.First, secure management buy-in. Employees don’t just slip and fall because they are careless. Hidden risks exist at all work sites. You can demonstrate to managers the cost and the cause of slip-related injuries with photos of potential hazards, qualified worker observations, and slipperiness measurements from work sites. Managers often don’t realize that a leading portion of their loss comes from preventable slips and falls; by illustrating the negative impact on the bottom line and the potential positive outcome from a system approach, you will get management buy-in.
——————————————————————————–
New floor or old, you still need to adhere to a good cleaning program.
Second, assess current slip-and-fall management conditions and practices. Look at your hazard assessment processes, physical controls, and organizational factors to identify areas for improvement. Use the 11 elements listed in the image above as your guide. Each part of the process must be strong–like the links in a chain, the control process for same-level slips and falls is only as good as its weakest link. For example, slip-resistant floors and shoes can be useless if floor cleaning protocols are not implemented. And even the best cleaning protocols will be ineffective without proper employee training or reinforcement of best practices.
Implementing Your Plan
Outlined here are the 11 elements of the slips and falls management process to help get your systems approach in place:
Outlined here are the 11 elements of the slips and falls management process to help get your systems approach in place:1. Management responsibility starts with proactive prevention. Managers and supervisors must be as responsible and accountable for implementing slip-and-fall controls as everyone else. There’s no substitute for leading by example. Think of the impact it can make on employees to see, or even hear about, a CEO who personally cleaned up a spill. Management also should provide adequate funding for interventions such as proper flooring and floor treatments, lighting improvements, slip-resistant footwear, and appropriate matting. Start with this question: Do my managers take the lead and set an example for slip and fall prevention?
2. Educate and train employees on the seriousness of fall accidents. Implement “clean as you go” spill and housekeeping policies, footwear requirements, and incident reporting requirements. Use ongoing communication to reinforce your message. Teach managers about the causes of slips and falls and how to recognize, evaluate, and control hazards. Do this through technical instructions on types of floors, types of treatments or coatings, types of abrasive or grit material, chemistry of cleaning chemicals, design of slip-resistant footwear, and design of matting systems. Train maintenance employees to understand cleaning protocols, cleaning supply maintenance, and how to properly cordon off hazardous areas and place temporary warning signs as needed. Give supervisors information on hazard inspections, footwear programs, signage requirements, and incentives management and stress the importance of setting an example for “clean as you go” policies. Start with this question: Do all my employees understand the seriousness of slips and falls, as well as their role in the prevention process?
Even though you’ve armed management and employees with the proper protocol, procedures, and tools to get the job done right, you must remain vigilant.
3. Conduct frequent incident and injury surveillance. Collect, analyze, and interpret health and exposure information to stay informed and equipped to deal with accidents. Look at pre-loss incident data obtained through inspections, surveys, employee interviews, self reports, and post-loss data such as past accidents and injuries from insurance and other accident reports. Make sure employees report close-call incidents. A good guideline is the American Society for Testing and Materials ASTM F1694 Standard Guide for Composing Walkway Surface Evaluation and Incident Report Forms for Slips, Stumbles, Trips, and Falls. Start with this question: Do I know the full impact of slips trips and falls at my work site(s)?
——————————————————————————–
Focus inspections on the most common tripping hazards: floor condition, boxes, pallets, and hoses.
4. Hazard surveillance is never-ending and requires employee feedback. Have employees complete job surveys such as facility audits, supervisor interviews with workers, and hazard assessment surveys. Start with this question: Where are my slip and fall hazards?
Of course, starting with the right floor surface makes housekeeping compliance easier for everyone.
5. Floor surface selection has many steps. If you are building a new facility, have a safety professional weigh in on slip-resistant properties, contaminants expected, and transition areas. Think about the contaminants present, the floor surface’s overall slip resistance, and how the floor will hold up to pedestrian and equipment traffic. Most floor surfaces are “slip resistant” when dry but change dramatically when wet, greasy, or dirty. Focus on transitional areas, which often increase the likelihood of a slip and fall. For example, when someone walks from a carpeted floor to a glazed ceramic tile, the sudden change in slip resistance can result in a fall. Ease transition with similar slip-resistance properties between different types of flooring, especially when liquid contaminants may be present.
Remember, the slip resistance of today’s new floor may not be there tomorrow if high traffic is expected and the floor offers little durability. Don’t buy cheap materials. What seems inexpensive today may end up being more expensive in the long run if you have to replace the floor sooner than expected. Start with the question: Are your floor surfaces safe and durable?
6. The best scenario is an inherently slip-resistant floor used under the conditions for which it was designed. If you need to replace a floor but can’t, there are many treatments available to improve floor surface slip resistance, such as abrasive floor coatings, chemical etches and cleaners, carpeting and mats, floor waxes, and slip-resistant floor treatments that can be applied daily. If a floor surface is too slippery or if a high number of slips and falls occurs in an area, investigate the best treatments available to increase surface slip resistance. With extremely slippery floors, however, replacement may be the best option. Determine whether you need to replace your floor by taking slip resistance measurements when the floors are dry and wet. Start with the question: Will proper treatments enhance my floor surface safety?
New floor or old, you still need to adhere to a good cleaning program.
7. Housekeeping and maintenance require comprehensive, written instructions. Your program should:
Identify contaminants and select effective cleaners/chemicals.
Establish contaminant removal protocol.
Provide proper floor cleaning tools for specific areas to avoid cross-contamination.
Implement a floor cleaning schedule that lists specific employees and cleaning times.
Establish an inspection, maintenance and cleaning training program. Include definitions of cleaning requirements, cleaning procedures, safe handling and disposal of chemicals and solutions, emergency conditions and operations, and recordkeeping.
Inspect often all floor surfaces for wear, damage, debris, and contaminants and report needed repairs to maintenance.
Focus inspections on the most common tripping hazards: floor condition, boxes, pallets, and hoses. Floor condition tripping hazards include loose carpet, broken tiles, and other incongruities larger than ¼ inch.
Test floor surfaces to monitor slip resistance levels and determine effectiveness of the floor cleaning protocol.
Start with the question: Where is my written program for housekeeping and floor maintenance?
It is equally important to use job-appropriate footwear and mats. Not doing so may wash away your best cleaning efforts.
——————————————————————————–
Before implementing a slip-resistant footwear program, have legal counsel review the policy for potential exposures.
8. Slip-resistant footwear and policy implementation take thought. Ensure that the footwear accommodates the working environment–indoors or outdoors, types of contaminants, etc.–and the program includes a written policy for selection, purchase, reimbursement, and replacement. Before implementing a slip-resistant footwear program, have legal counsel review the policy for potential exposures. Start with the question: Is my footwear program right for my environment?
9. Dirty, worn, old mats offer little slip protection. Don’t choose your mats based on cost alone. Mats should be slip-resistant, able to adequately absorb liquids and scrape solids from shoes, long enough for the area, and have beveled edges or other features to prevent a tripping hazard. Replace mats often. For entry mats, it usually takes 10 to 12 steps (30+ feet!) of mat to absorb contaminants in snowy weather, 8 to 10 steps in rainy weather, and 6 to 8 steps in dry weather. Start with the question: Do I have quality entrance and back-of-house mats that meet the needs of the environment?
To keep your program operating smoothly, occasionally measure your floors’ slipperiness.
10. Floor “slipperiness” assessment helps identify solutions to potential hazards. Slipmeters measure floor slipperiness by determining the slip index or coefficient of friction between the shoe sole and the floor surface. Select the slipmeter you use based on the surface tested. You can use the Horizontal Pull Slipmeter (HPS) on vinyl composition tile before and after applying wax or polish. But don’t use the HPS on wet floors because it can make a floor appear more slip resistant than it is. Instead, use the Brungraber Mark II or English XL or other approved slipmeters on wet floors–especially in restaurant kitchens to determine the effectiveness of a floor cleaning protocol or the differences between various floor surface materials. Start with the question: Where is my slipmeter, and is it the right one for the job?
11. Warning signs and instructions are no guarantee for averting risky behavior, but it remains critical to use them consistently. When used properly, signs still will help some people. Better yet, if there is a full barricade around a spill, few people will climb over it. Not using warning signs and training opens you up to liability and could be considered negligence. Start with the question: Do I use warning signs or barricades to indicate the presence of hazards?
Organizational inattention, not bad luck, causes same-level slip-and-fall accidents. Implement a broad systems approach to identify, and address, your slip-and-fall hazards to really make a difference.
Wayne Maynard is Director–Ergonomics and Tribology at the Liberty Mutual Research Institute for Safety in Hopkinton, Mass. George Brogmus is Technical Director–Ergonomics for Liberty Mutual Group’s Business Market.
Tue 10 Oct 2006
OSHA’s New Fact Sheet Focuses On Fall Protection
OSHA recently released a fact sheet for employers and employees involved in working in and around aboveground storage tanks that describes how to recognize fall hazards, develop prevention priorities, and use protective equipment.
Additionally, the fact sheet highlights safe climbing practices, specialized training, and other safety and health tips. The fact sheet is a product of the Safe Tank Alliance (http://www.osha.gov/dcsp/alliances/api_nfpa/api_nfpa.html).
Fall prevention means keeping accidents from happening. Using equipment like guardrails, stair rails, travel restraint systems, safety nets, arrest systems (harnesses), self-retracting lifelines/lanyards and ladder safety devices help keep workers from falling and avoid a hard landing if they do fall.
According to the fact sheet, fall hazards in and around tanks are:
The fact sheet can be accessed (in PDF format) at http://www.api.org/ehs/health/upload/fall_prevention_factsheet.pdf.
Wed 4 Oct 2006
New Guidance To Help Small Businesses Comply With Hexavalent Chromium Requirements
On Oct. 2, OSHA released a safety and health guidance to help small businesses comply with the agency’s new hexavalent chromium(Cr(VI)) requirements for general industry, construction and shipyards.
“This new resource is aimed at helping small businesses comply with the new standards, while helping them reduce the risk to employees potentially exposed to these compounds,” said OSHA Administrator Edwin G. Foulke Jr.
The guide describes the steps that employers are required to take to protect employees from hazards associated with exposure to Cr(VI). It is divided into sections that address the major provisions of the standards, and follows the same organization as the corresponding paragraph of the standards. However, the guide provides more detail than the standards to help employers better understand the requirements.
Permissible Exposure Limits (PEL), exposure determination, regulated areas, methods of compliance, respiratory protection, protective work clothing and equipment, hygiene areas and practices, housekeeping, and medical surveillance are the major topics included in the guide.
Hexavalent chromium compounds are widely used in the chemical industry as ingredients and catalysts in pigments, metal plating and chemical synthesis. Cr(VI) also can be produced when welding on stainless steel or Cr(VI)-painted surfaces. The major health effects associated with exposure to Cr(VI) include lung cancer, nasal septum ulcerations and perforations, skin ulcerations, and allergic and irritant contact dermatitis.
The guidance can be accessed in PDF format at http://www.osha.gov/Publications/OSHA_small_entity_comp.pdf.
