Proposed revisions that will change the requirements for facilities subject to the Spill Prevention, Control, and Countermeasure (SPCC) rule are expected within weeks. According to EPA, the revisions will tailor and streamline requirements to particular industry sectors and facilities subject to the rule.

EPA Administrator Stephen L. Johnson recently signed a proposed rule to amend the rule at 40 CFR part 112.

All SPCC-regulated facilities would be potentially affected by the proposed amendments, through which EPA intends to provide:

Clarity on the general secondary containment requirements,
Flexibility in the security requirements,
Flexibility in the use of industry standards to comply with integrity testing requirements,
Additional flexibility in meeting the facility diagram requirements, and
Clarification on the flexibility provided by the definition of “facility.”
Some of the other proposed changes include exemptions and a definition of loading/unloading rack.

Plan template allowed for small facilities
The changes would also streamline requirements and allow the use of an SPCC Plan template for a subset of qualified facilities known as “Tier 1” qualified facilities (i.e., with no individual oil storage container with a capacity greater than 5,000 U.S. gallons up to an aggregate of 10,000 gallons).

Until then, comply with old rule
Nothing in this proposed rule removes any regulatory requirement for owners or operators of facilities in operation before Aug. 16, 2002, to develop, implement, and maintain an SPCC plan in accordance with the SPCC regulations then in effect. These facilities are required to maintain their plans until the applicable date for revising and implementing plans under the new amendments.

Public comments on the proposed changes will be accepted for 60 days following publication in the Federal Register, which is expected within two weeks. Information about the SPCC rule proposed amendments is available at www.epa.gov/oilspill/spcc_oct07.htm

 by Allan Kaufman

President, The Compliance Resource Center

How often have you been in a training session where you are yawning, falling asleep, or just bored?  It happens more often than we think.  That’s why we really appreciate a speaker or trainer who really makes us sit up and listen.  So what makes these trainers different?  They know their audience, and they understand the principles of learning and how to motivate their audience.  They also understand the principles of learning.

There are four (4) basic principles of adult learning:

• Motivation
• Reinforcement
• Retention
• Transference

Adult Educators should understand that adults learn information differently.  Some people are VISUAL learners.  They learn by seeing or reading material.  Others learn by ORAL information they hear.  Still others respond better to KINESTHETIC or TACTILE training, where they benefit better from doing and touching.

Training should encompass all these types of learning realizing that is more interactive the training is, the greater the results.  If your training includes problems or case studies that are relevant to the students they will be more engaged.  Anytime the training directly relates to what we do we take a greater interest.  Whenever we do Hazmat training, we always find out what materials are being shipped, how they are shipped and what in what quantities.  We then incorporate this information to make the training function specific and relate that to what these employees use and do.  This always produces greater response and interest. 

One other area to consider is your PowerPoint presentation.   What is more boring than someone reading bullet point sentence after bullet point sentence?  A PowerPoint presentation should use bullet points that are short and concise.  They are a reminder or outline to help you make your points.  The old adage a picture is worth a thousand words is so true.  Use pictures or other graphics to make your presentation more interesting.  Whenever possible, a little humor keeps your audience engaged, but only if the situation is appropriate.

Trainers and/or adult educators need to be aware of their audience.  There are different types of learners and they need to feel that they are engaged into the learning process.  Anytime the learning is specific to the student they will have a greater interest.  Make sure your speak from your outline and do not read it.  I know you will find your audiences more appreciate of your presentation.  

According to 29 CFR 1910.164(c), it is the employer’s responsibility to maintain all fire-detection systems in an operable condition, except during maintenance and repair work.  You must ensure that these systems are tested and adjusted as often as necessary to maintain reliability and operating condition.

The frequency of the tests and cleaning cycle must be determined in part by facility conditions, such as dust, as well as manufacturer recommendations.  Conditions such as the amount of dust, dirt, or other particulates may vary widely from one facility to another and therefore vary the maintenance cycle.
Factory-calibrated detectors do not need to be adjusted after installation, unless recommended by the manufacturer or service representative. However, trained personnel knowledgeable in the operation and function of the system must perform testing, cleaning, and maintenance of fire-detection systems.

You must also ensure that pneumatic and hydraulic-operated detection systems installed after Jan. 1, 1981, are equipped with supervised systems.

ON Oct. 5, NOISH announced the online availability of a publication that offers recommendations to prevent injuries and deaths while working with metal ladders around overhead power lines.

A NIOSH review of the U.S. Bureau of Labor Statistics Census of Fatal Occupational Injuries data from 1992 to 2005 identified at least 154 electrocution deaths that resulted from contacting overhead power lines with portable metal ladders (excluding truck-mounted and aerial ladders). Of these 154 deaths, 36 involved a person of Hispanic origin. Although Hispanic workers accounted for 23 percent of these electrocution deaths due to ladders contacting power lines, it is estimated that they made up only 11 percent of the workforce during this period.

Employers, workers, general contractors and ladder manufacturers should take the steps outlined in the NIOSH publication to protect workers while working around overhead power lines. Many of these steps are required or suggested by OSHA regulations.

Steps employers can take include:

• Identify the location of overhead power lines as a routine part of all initial worksite surveys for jobs involving the use of ladders.
• Always note power line heights and distances from work areas on site diagrams to provide key information for site supervisors and workers.
• Avoid or limit proximity to power lines whenever possible. Consider ladder length and room for ladder staging (safely raising and lowering ladders).
• Notify the local electric utility company for assistance if work needs to be done near energized, overhead power lines.

The publication can be accessed at http://www.cdc.gov/niosh/docs/wp-solutions/2007-155.

New OSHA guidance will help employers select and use the appropriate slings when handling and moving materials. The document, Guidance on Safe Sling Use, was recently released by the agency.

“OSHA’s current general industry standard is more than 30 years old,” said Assistant Secretary of Labor for OSHA, Edwin G. Foulke Jr. “This guidance document will aid users in the safe selection and use of slings, including synthetic round slings, which are not covered in OSHA’s standard, as well as the newer grades of materials being used in alloy steel chain and wire rope slings.”

OSHA adopted its general industry sling standard on June 27, 1975, based on ANSI B30.9-1971 Slings standard. OSHA has since made only minor corrections. OSHA issued its construction industry sling standard on Feb. 9, 1979, and its sling standard for shipyards on April 20, 1982.

Improper selection or use of slings can result in sling failure or load slippage, which in turn can lead to injuries or death. OSHA accident data for the years 1994–1996 show that there were four fatalities in general industry involving the misuse or failure of slings.

OSHA intends to format the final product for use on the Web. With the document in web format, a user can quickly get information on the type of sling being used without having to look through material that is not relevant to the workplace.

It’s a beautiful fall day, crisp temperatures, leaves turning those beautiful shades of oranges, yellows and reds, and that touch of pumpkins in the air.  So what are safety managers thinking about?  They need to have all of this years training completed….soon.  They are going into the 4th quarter and need to have their budgets ready from next year.  They also need to make sure they have all of this years budget spent, so there is not too significant of a cut back for next year.

Here are some ideas that may help the process.  If you have not done all your training and have some money to spend, this is a great time to make sure it is complete.  OSHA, EPA, and DOT often first look at training records a when they come visiting. 

OSHA recommends and sometimes requires on-going training in a variety of areas. 
 ·  New employees and/or new polices and procedures require new training.
 ·  Changes in using or labeling of hazardous materials require training.
 ·  Making sure that people are re-certified in First Aid, CPR/AED. 
 ·  If you have HAZWOPER trained people, having an 8-hour refresher class.
 ·  Driver Safety Training.
 ·  Emergency Response Planning.

The US DOT requires Hazmat training if your organization ships hazardous materials by ground, air or ocean.  Employees involved in the shipping or receiving of hazardous materials MUST be trained every 3 years for ground transportation and every 2 years for air and/or ocean shipping.  Your employees require Hazmat training if your company manufacturers hazardous materials packaging,.  New employees must receive training within 90 days after employment. 
This training must include:
 1.  General Awareness Training
 2.  Function Specific Training
 3.  Safety Training
 4.  Security Awareness Training
 5.  In certain cases In-Depth Security Training

This site does not publish the fines that companies get when they are in violation of compliance.  However, a majority of these fines, lost work days, lost productivity and more, could have been avoided by spending money training the employees.

The Compliance Resource Center can do all this and more.  Whenever possible the training is customized to your organizations needs. 
HAVE A SAFE DAY!

An arc flash can happen without warning and occurs much too fast for you to react.

The heat released during an arc flash can reach as high as 35,000 degrees Fahrenheit — hotter than the surface of the sun. Large arc flashes can cause an explosion noise loud enough to cause hearing loss and injuries from being thrown back from the electrical explosion.

To better address this issue, the Electrical Safety Foundation International (ESFI) has teamed with NIOSH and the Centers for Disease Control to distribute Arc Flash Awareness, a DVD training course, available in both English and Spanish. The DVD includes basic information about arc flash awareness and contains the first hand accounts of three electrical workers who were severely injured in arc flash accidents.

Surprisingly, it has just been in recent years that the term “arc flash” has garnered much attention. Many companies have started to raise awareness about the problem. Some companies, however, do not think that arc flash is a serious concern because they have not yet had an arc flash incident.

An arc flash can result from the spontaneous failure of equipment during normal operation or from accidentally bridging two live electrical contacts with a conducting object, like a metal screwdriver or wrench. Other causes may include the improper use of electrical multimeters, poor housekeeping that allows the buildup of conductive dust, or severe corrosion that allows connections to break.

How large is the problem?
– According to CapSchell, Inc., a Chicago-based research and consulting firm that specializes in workplace injury prevention, there are five to 10 arc flash explosions every day in the United States.
– The final cost to employers and their insurers for a single, serious injury can approach $10 million. (CapSchell)
– 2,000 workers are admitted annually to burn centers for extended injury treatments caused by arc flash, according to the U.S. Department of Labor.
– A recent study from the National Institute for Occupational Safety and Health (NIOSH) determined 17,101 injuries were caused by electric arc flash burns between 1992 though 2001.

With statistics like this, companies cannot afford to ignore electrical safety issues surrounding accidental electrocution from arc flash explosions.

For more information on Arc Flash or to order a copy of the Arc Flash Awareness DVD visit the ESFI Library on the ESFI’s website, http://www.electrical-safety.org/ or call ESFI at 703-841-3229.
 

The BIG show is almost here.   The National Safety Council’s Congress & Expo is scheduled for October 15, 16, & 17 in Chicago.  This is the largest Safety & Health expo in the world.  There will be about 140 educational sessions, 32 professional development seminars, and over 800 exhibitors.  Many companies send their safety teams to attend the educational seminars and then have their annual safety meeting afterwards.  It is also a great place to network and look for jobs.  My favorite part has always been the people I have met.  Safety and Health professionals from all over the world.  Click here for a link to the keynote speakers. 

If you have the opportunity, come and check it out, you won’t be sorry.