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.

Do you think a health hazard exists in your workplace? Do any of the following stories resemble situations at your workplace?

• A factory worker was feeling numbness and tingling in her fingers. She learned that three coworkers had the same problem, and two had headaches while at work but not over the weekend. Some workers said the air at work smelled bad. Their supervisor noticed the smell but didn’t think it was anything to worry about.
• A manager noticed that employees in one work area had more skin rashes in the past year than the year before. He wanted to know why, but didn’t know what to do.
• A work crew was putting cement tiles on a roof. They were working outside, but the air seemed dusty. The saws used to cut the tiles were noisy. Someone told them that this work was dangerous and they should have it checked out.

At no cost to employers or employees, or their representatives, the NIOSH Health Hazard Evaluation (HHE) program may be able to help with problems like these. This site lets you know about the program and how to ask for NIOSH help. It also has links to reports from thousands of HHEs done by NIOSH.

What is a Health Hazard Evaluation?

An HHE is a study of a workplace. It is done to learn whether workers are exposed to hazardous materials or harmful conditions. On the basis of the information you provide, NIOSH responds to an HHE request in one of the following ways:

• NIOSH staff responds in writing with helpful information or a referral to a more appropriate agency.
• NIOSH staff calls to discuss the problems and how they might be solved.

NIOSH staff visits the workplace. When this happens, they will meet with the employer and the employee representatives to discuss the issues. They will tour the workplace. They may review records about exposure and health, interview or survey employees, measure exposures, and do medical testing. These activities may happen during one or more visits. At the end of this evaluation, NIOSH will provide a written report to the employer and to the employee representatives. This can take from a few months to a few years, depending on the type of evaluation.

Who Can Request an HHE?

Private sector and Federal workplaces

An employee can request an HHE if he or she is currently an employee at the workplace of concern and has the signatures of two other employees. If the workplace has three or fewer employees, the signature of only one employee is enough.

An officer of a labor union that represents employees for collective bargaining can request an HHE.

Any management official may request an HHE on behalf of the employer.

For anyone who submits a request, NIOSH will not reveal to the employer the names of the persons who made the request if they indicate this on the request form

State or local government workplaces

When the workplace is part of a State or local government, NIOSH authority is more limited than for the private and Federal sectors. The cooperation of the employer may be necessary before NIOSH can do an evaluation.

Should you request an HHE?

When there is concern about a health hazard in a workplace, you can request an HHE, file a complaint with the Occupational Safety and Health Administration (OSHA), or request help from the OSHA Consultative Service. Some things to consider for each of these options are listed below.

1. When to request an HHE from NIOSH

You are an employee, employee representative, or employer and the following apply:

• Employees have an illness from an unknown cause.
• Employees are exposed to an agent or working condition that is not regulated by OSHA.
• Employees experience adverse health effects from exposure to a regulated or unregulated agent or working condition, even though the permissible exposure limit is not being exceeded.
• Medical or epidemiological investigations are needed to evaluate the hazard.
• The incidence of a particular disease or injury is higher than expected in a group of employees.
• The exposure is to a new or previously unrecognized hazard.
• The hazard seems to result from the combined effects of several agents.

2. When to request help from the OSHA Consultation Program (http://www.osha.gov/dcsp/smallbusiness/consult.html):

You are a small business owner and you want:

• assistance in recognizing hazards in your workplace.
• suggestions or options for correcting safety and health issues.
• assistance in developing or maintaining an effective safety and health program.
• to reduce workers compensation cost and improve employee morale..

The OSHA On-site Consultation Program:

• is a free service.
• is delivered by state (and territorial) governments using well-trained safety and health professionals.
• is separate from enforcement.
• is confidential. The company’s name, and any other identifying information provided about the workplace, plus any unsafe or unhealthful working conditions that the consultant uncovers, will not routinely be reported to OSHA enforcement personnel.
• does not issue and citations, penalties, or fines.
• will provide you a confidential, written report that summarizes the consultant’s findings.
• requires the correction of hazards identified by the consultant(s).
• under specific circumstances, employers with exemplary safety and health programs can be recommend for recognition and provided with an exclusion from general schedule inspections.

3. When to file a complaint with OSHA (www.osha.gov/as/opa/worker/index.html):

You are an employee and the following situations apply*:

• Immediate enforcement by a regulatory agency is needed.
• Employees want the employer to comply with existing health and safety standards.
• The hazard is well recognized.
• An OSHA standard is known to adequately protect employees from the hazard.

* [Employers in the Federal sector may wish to explore the services available through the Division of Federal Occupational Health (DFOH), which maintains an office in each Federal region. State and local government employers may be eligible for help under the OSHA Consultation Program operating in their State. The State or local health department may also be able to help with occupational safety and health issues.]

How Does NIOSH Respond to an HHE Request?

NIOSH logs in each request for an HHE and generally sends a letter to the person making the request. Most often this happens within a few weeks.When NIOSH decides to send information or make a referral to another agency, usually a letter is sent within 4–6 weeks.

When NIOSH decides that telephone consultation or a workplace visit is needed, a project officer is assigned. Usually, within 4–6 weeks, the project officer contacts the person who sent in the request. When the request is made by an employee or union, NIOSH also contacts the employer to let them know about the request and to arrange for a site visit. Typically, NIOSH does not conduct surprise visits.

What protections are provided for employees who request and participate in HHE investigations?

Confidentiality

If desired and noted on the HHE request form, NIOSH will not reveal to the employer the names of the persons who made the request. Personal information from records, questionnaires, interviews with NIOSH investigators, and individual medical results will be safeguarded in accordance with provisions of the Privacy Act.

Anti-discrimination Provisions

The Occupational Safety and Health Act and the Federal Mine Safety and Health Act forbid employers from retaliating or punishing employees for making HHE requests or cooperating with NIOSH investigators (see Section 11(c) of the Occupational Safety and Health Act or Section 105(c) of the Mine Safety and Health Act). The enforcement of these anti-discrimination provisions is the responsibility of the U.S. Department of Labor. If discrimination is suspected, contact the nearest OSHA or MSHA office immediately.

Procedural Rights of NIOSH and Employee or Employee Representatives

There are 7 legal rights of NIOSH and employees or employee representatives that NIOSH considers non-negotiable:

• NIOSH and its representatives have the right to enter the workplace to conduct HHE investigations.
• NIOSH and its representatives have the right to access information and records maintained by the employer that are pertinent to the HHE investigation.
• NIOSH and employees (including management employees) have the right to private and confidential interviews.
• Employee representatives, including an employee requestor and a representative of any union representing the affected employees, have the right to accompany NIOSH investigators during the initial inspection of any workplace to be evaluated.(NIOSH investigators may have additional employee representatives accompany them if necessary to aid in the investigation.)
• Employee representatives have the right to participate in an opening and closing conference with NIOSH investigators at the start and conclusion of a NIOSH investigation at the workplace.
• Employees have the right to wear NIOSH sampling devices and participate in medical tests when offered or requested by NIOSH. (This also applies to management employees.)
• Employees have the right to read or obtain copies of all HHE interim and final reports. (The employer is required to post the final report in the workplace for 30 days, or supply a list of names and addresses of affected employees so that NIOSH can mail the report directly to them.)

Procedural Rights of the Employer

Regardless of who submitted the request for an HHE, employers have the following rights during HHE investigations:

• To obtain a copy of the HHE request (excluding the identity of confidential requestors and any accompanying information of a personal nature.)
• To obtain verbal accounts from NIOSH investigators concerning plans, procedures, and findings at conferences at the beginning and conclusion of NIOSH visits to the workplace.
• To accompany NIOSH investigators during the initial inspection of the workplace to be investigated.
• To observe NIOSH investigative procedures during the HHE, except for certain confidential NIOSH-employee interactions, such as private interviews and medical test procedures.
• To identify, at the start of the investigation, information that is considered trade secret, and to have that information safeguarded by NIOSH unless NIOSH follows procedures outlined in 42 CFR 85.7(b) to remove the trade secret designation from such information. (These procedures provide an opportunity for the employer to defend the trade secret designation.)
• To require that NIOSH officers comply with all safety and health rules in the workplace, and conduct the investigations in a manner that does not unreasonably disrupt operations.

Role of the Employee Representative

The local, national, or international union may submit an HHE request on behalf of employees it represents. Two employees may authorize a third employee to submit an HHE request on their behalf.

The employee representative has the following rights:

• To accompany NIOSH investigators on the initial inspection of the workplace.
• To convey to the NIOSH investigators, privately if requested, additional information related to the HHE request.
• To participate in the opening and closing conferences.
• To receive copies of all interim and final reports

How Are HHE Results Reported?

NIOSH reports its findings and recommendations to employers, employees, and employee representatives. Verbal reports are normally provided to employer and employee representatives during a closing conference at the conclusion of a site visit, and by telephone. Often, results are only preliminary or incomplete at that time. Written interim reports are sometimes provided while an investigation is still in progress.

When all the information and data have been analyzed, NIOSH issues a report of its final determination, giving findings and recommendations. Copies of this report are sent to the requestor, the employer, employee representatives, OSHA, and other appropriate agencies.

The employer is required to post the final report in a place accessible to employees from all areas evaluated (alternatively, the employer may give NIOSH names and addresses of affected employees to permit NIOSH to mail the report to each affected employee.) Although NIOSH has no authority to force the employer to adopt its recommendations, experience has shown that most employers attempt to address any problems identified in the HHE report.

By What Authority Does NIOSH Conduct HHEs?

In private sector workplaces, NIOSH is supported by the following:

• The Law

Section 20(a)(6) of the Occupational Safety and Health Act (Public Law 91-596, 91st Congress, S.2193, December 29, 1970), 29 USC 669 (a)(6), authorizes the Secretary of Health and Human Services (delegated to NIOSH), “following a written request by any employer or authorized representative of employees, to determine whether any substance normally found in the place of employment has potentially toxic effects in such concentrations as used or found.” Section 501(a) of the Federal Mine Safety Act of 1977 authorizes NIOSH, “upon the written request of any mine operator or authorized representative of miners, to evaluate potentially hazardous or toxic effects of substances, physical agents, or equipment found or used in mines.”

• Federal Regulations

The regulations governing NIOSH procedures for conducting HHEs are published in Title 42, Code of Federal Regulations, Part 85; Requests for Health Hazard Evaluations (42 CFR 85).

In Federal agency workplaces, NIOSH is supported by the following:

• The Law

Section 19 of the Occupational Safety and Health Act (29 USC 668) requires the head of each Federal agency to “establish and maintain an effective and comprehensive occupational safety and health program.”

• Executive Order

Executive Order 12196 of February 26, 1980, “Occupational Safety and Health Programs for Federal Employees.”

• Federal Regulations

Title 29, Code of Federal Regulations, Part 1960; Basic Program Elements for Federal Employees Occupational Safety and Health

Programs and Related Matters (29 CFR 1960). Section 1960.35 of these regulations describes the procedures for requesting HHEs in Federal agency workplaces.  NIOSH follows the procedures outlined in the regulations governing HHEs (42 CFR 85) when evaluating Federal agency workplaces.

In other government agency workplaces, NIOSH is supported by the following:

• The Law

Section 18 of the Occupational Safety and Health Act (29 USC 667) permits OSHA to approve a plan under which the State assumes responsibility for developing and enforcing occupational safety and health standards. Section 18(c)(6) requires that such a plan, to be approved, must contain satisfactory assurances that the State will “establish and maintain an effective and comprehensive occupational safety and health program applicable to all employees of public agencies of the State and its political subdivisions.” Although approved State plans do not ordinarily extend the right to request HHEs to State employees and employers, the State agency charged with carrying out this plan has right-of-access to State and local government workplaces, and could request technical assistance from NIOSH in evaluating the workplaces.

• Federal Regulations

In cases where NIOSH responds to requests to evaluate State or local government workplaces, the procedures outlined in 42 CFR 85 are followed.

Occupational Medicine Rotation Program

The NIOSH Health Hazard Evaluation and Technical Assistance Branch provides hands-on, one- and two-month workplace training opportunities to Medical Residents. Residents join staff on a combination of workplace and epidemiologic investigations, public inquiries, health and safety assessments on today’s health and safety topics and learn to plan and conduct worksite health evaluations. Residents gain understanding of the role and function of CDC/NIOSH regarding occupational health research and service.

First aid in the era of biohazards

by Lisa J. Burns, Q.S.S.P.

10 best practices to keep responders safe

Everyone sees the need for trained responders, first-aid kits and automated external defibrillators at the workplace. But what about the simple cut that bleeds enough to require a gauze bandage? Does the responder — or just a nearby helpful employee — see the need to wear disposable gloves? Bloodborne pathogens and other biohazards command little attention from most people, yet can cause critical illnesses and sometimes eventual death.

Defining the danger
Bloodborne pathogens are microorganisms (bacteria or viruses) carried in the blood that can be transmitted and cause disease in other people. Hepatitis B Virus (HBV) and Human Immunodeficiency Virus (HIV) are two examples that are addressed by the OSHA Bloodborne Pathogen standard 29 CFR 1910.1030. Malaria and syphilis also are caused by bloodborne pathogens. Other body fluids also may transmit these and other diseases.

Infectious disease such as the H1N1 flu virus is a workplace concern that employers must address.

Transmission
Unbroken skin generally acts as a barrier to bloodborne pathogens. However, microorganisms can enter through any damaged or broken skin such as acne, sunburn, blisters, open sores, cuts or abrasions. They also may be transmitted through mucous membranes, including those of the eyes, nose or mouth.

Infectious diseases such as the H1N1 flu virus are primarily transmitted through airborne body fluids emitted with coughs and sneezes, and breathed in by others in the immediate vicinity. They also are transmitted when a hand used to cover the mouth then touches faucets, doorknobs and other surfaces from which it is later picked up by others.

OSHA first-aid regulations
Emergency medical services and first aid that general industry employers must provide are described in OSHA standard 29 CFR 1910.151. The standard recommends kits and supplies that are compliant with the minimum guidelines established by the American National Standards Institute (ANSI) in Z308.1-2009. It also incorporates other standards and measures by reference, such as 29 CFR 1910.1030, which deals with bloodborne pathogens.

OSHA’s 29 CFR 1910.1030 standard requires limiting employee exposure to blood and other potentially infectious materials. It specifies that training and personal protective equipment must be provided for employees who can be “reasonably anticipated” to face possible contact with blood or other potentially infectious materials on the job.

The standard, issued in 1991, was updated in 2001 in response to the Needlestick Safety and Prevention Act, and can be found at http://www.osha.gov, along with FAQs and various letters of interpretation issued over the years since then.

Best practices
Following the best PPE practices recommended below will help keep first responders safe from bloodborne pathogens and other infectious material.

1. “Universal precautions.” Treat every situation as potentially dangerous. OSHA’s universal precautions require that all human blood or other potentially infectious materials be considered hazardous.

2. Hand protection. Before donning gloves, cover any cuts or sores on your own hands with a bandage. Inspect the gloves and if the material is thin, doubleglove to provide another layer of protection. Do not use torn or punctured gloves, no matter how miniscule the damage might be. When removing used gloves, pull them off from the cuff, turning them inside out so the outside of the gloves do not touch your bare skin. Dispose of them in a designated biohazard bag. Immediately scrub your hands thoroughly, including under nails — and any other potentially contaminated skin — with nonabrasive soap and running water at hand-washing facilities that employers must provide in readily accessible areas.

3. Eye and face protection. While providing first aid or other medical assistance as well as working in labs or while cleaning up a spill, there may be a risk of splashing or vaporization of contaminated fluids. Use goggles to protect against transmission of pathogens through your eye membranes. Use a face shield in addition to goggles to protect against splashes to your nose and mouth.

4. Body protection. In some cases, you may need to wear aprons or body shields to protect your clothing and keep blood or other contaminated fluids from soaking through to your skin. Wear shoe covers to avoid contamination of your footwear.

5. Clean up. For clean-up of blood or other body fluids from sick or injured employees, use gloves and, depending on the situation, some or all of the above-mentioned PPE. In addition, you should have available a small shovel and scraper, appropriate absorbent materials, biohazard bags, ties, germicidal towelettes — and for large areas, a mop or sponge and bucket with a solution of 1/4 cup bleach to 1 gallon of water. Some manufacturers supply complete biohazard clean-up kits that contain all the necessary supplies, including special absorbent materials that deodorize as well as bind the hazardous body substances together.

6. Deposit waste. Once clean-up is complete, deposit the waste material first in a labeled, red biohazard bag and tie it tightly. Use germicidal towelettes or bleach solution to clean the contaminated area. Then put the first bag into a second biohazard bag, and add the used towelettes or sponges, your shoe covers, gown, face mask with eye shield and, lastly gloves in the same bag, and seal it with a tie. Discard the red bag in an appropriate container for infected solid waste as required by local regulations.

7. Sharps. For any broken glass or other sharp material, use a broom with shovel or dustpan, and deposit them in appropriate boxes. Never touch them with your gloved or ungloved hands and do not put them in a biohazard bag.

8. Decontamination. Finally, wipe your hands with antiseptic hand wipes that provide rapid bactericidal action and allow them to air dry. Next, go to the nearest handwashing area and wash your hands and all potentially exposed skin thoroughly with non-abrasive soap and running water.

9. Equipment decontamination. A person trained in the appropriate procedures must decontaminate and sterilize all non-disposable equipment and tools used, such as mops, buckets and re-usable gloves, as soon as possible.

No complacency
Factory or construction site, chemical, plastics or food and beverage processing plant — no matter what the workplace — there should be no toleration of complacency when there is potential for exposure to bloodborne pathogens and other infectious disease. The effects of exposure may not be immediate, but there is a definite potential for serious illness and eventual death.

Lisa J. Burns, Q.S.S.P. Lisa is associate product manager-personal protection- Americas at North by Honeywell. She is a member of the International Safety Equipment Association and a Qualified Safety Sales Professional. Lisa can be reached at (401) 275-2608 or by e-mail at Lisa.J.Burns@Honeywell.com.

A Confined Space Safety Policy can be divided into 9 sections.
This article briefly describes the nine parts of a comprehensive yet efficient confined space safety program.

1 - Purpose - The confined space safety policy states the requirements for the identification and safe entry into both permit required and non-permit required confined spaces.  The policy applies to areas of the workplace not designed for continuous occupancy and containing recognized serious safety or health hazards.
2 - Reference - OSHA 29 CFR 1910.146
3 - Scope - Applicable to all of the business’s employees, visitors and contractors.
4 - Administration - Variable, but generally administration of the confined space policy is by safety coordinators, supervisors, engineers and other trained managerial staff.
5 - Definitions - Can be standard, see: OSHA, Occupational Safety and Health Act
6 - Descriptions -

Confined Space is an area/space where an employee: - has limited openings for entry and egress; - can bodily enter and which is large enough to perform assigned work; - could be engulfed by bulk materials; - is not intended to continuously occupy.
Non-Permit Required Confined Space is a confined space neither containing nor having the potential to contain any hazard.
Permit Required Confined Space is a confined space with: - a hazardous atmosphere or potential for it; - material that could engulf an entrant; - converging/tapering walls/floors that could entrap or asphyxiate; - a recognized hazard.
Procedures Followed For All Permit Required Confined Space Entry
- - Permit
- - Issuance - By the supervisor, mandatory for the employee, one shift in duration.
- - Cancellation - At shift end or on job completion.
- - Retention - Must be reviewed and kept. -
- - Alternate Entry/Space Reclassification - Specific ref: OSHA 29 CFR 1910.146 (c)(5)/(c)(7)
- - Pre-Entry Briefing - By permit issuing entry supervisor.
- - Contractor Notification - Outside contractor adheres to procedures - compliance must be assured.
- - Lighting Requirements - Natural, auxiliary, emergency.
- - Special Tools and Equipment - Intrinsically safe in flammable or combustible atmosphere.
- - Preparation and Hazard Control - Preventing engulfment, burns. Lockout/tagout procedures.
- - Assuring adequate ventilation.
- - Pre-Entry Atmospheric Testing - Includes employee training with testing equipment.
- - Monitor Calibration and Testing
- - Field and Manufacturer Testing.
- - Attendant Duties - Mandatory for permit required confined space entry, no other duties.
- - Entry Supervisor Duties - Trained and authorized entry supervisor.
- - Safety Equipment - PPE, non-entry rescue, rescue, general.
- - Equipment Inspection - Per manufacturer’s recommendation.
- - Handling Problems
- - Rescue and Emergency Services - Documented, available, trained, equipped.
- - Summoning Rescue Services Procedure

7 - Responsibilities - Employees and Entry Supervisor - Safety Coordinators - Supervisors - Contractors
8 - Training - Initial - Refresher - Annual
9 - Revision - Annually by Safety Coordinators

These are the nine parts of a Confined Space Safety Policy.
Fleshed out details of just such a policy can be read at Confined Space Safety Policy

Every employer has a responsibility to make sure all employees have a safe and stable work environment. These employees should have access to safety equipment and information at anytime they are on the jobsite. These employees should be able to go to their superiors with fears or concerns about safety without fear of termination or retaliation. In order to accommodate employees in such a fashion, we have compiled a short and condensed version of what an employer of the construction industry should have documented and in place for emergencies or for an OSHA inspection.

Management Commitment to Safety and Health

Employers and managers should lead by example. If your employee sees a superior taking safety seriously, they will too! Assign Safety and Health Responsibilities to employees. If you involve and rotate employee responsibilities, everyone will feel important and compliant. Give the assigned employees to correct minor issues. When a subordinate is give a little more power than their position requires, they are more likely to do what it takes to keep earning your trust and respect.

Assure your employees that they may voice their concerns regarding safety without any repercussions. These employees are the front line guys and they often see the danger in a position before a manager does. Listen to what they have to say and respect their position on safety. Most state laws protect whistleblowers, so check your states regulations. Inform employees of any hazards that you are aware of. Again, it is the employer’s responsibility to safeguard their employees, so keep the lines of communication open. If you are sharing a worksite with other companies or their employees, it is your responsibility to communicate any known hazards to them. Share a safe workplace. Post the OSHA state or Federal poster where all can see it. Employees have a right to know the law.

Hazard Identification and Determination

Carefully evaluate all operations, procedures, facilities, and equipment to identify hazards to employees and others. Monitor exposure levels of noise, air quality, heat, electricity, silica or dust, and moisture. Set aside time to do routine inspections. If you create a habit of safety awareness, you will create a timeless good habit. If you have an accident, conduct an investigation. The best way to prevent history from repeating itself it to identify and address the factors that caused the accident to begin with.

Do a PPE assessment. For every position within construction, evaluate the potential dangers associated with that assignment, then create a list of personal protection equipment that should be worn while performing these tasks. Determine if it goes beyond simple protection and what precautions should be taken. Document all of your findings.

Hazard Elimination and Control

Inspect and ensure all machines and tools are in proper working order with relevant standards. Develop positive practices with workplace safety and health so that it becomes second nature. Housekeeping is a must. Jobsites should be free of debris and cleaned up daily to ensure the safety of others.

Emergency Response Planning

Develop emergency response plans for your jobsite. If you are in an industry where your jobsite changes frequently, you still need to have a response plan. These do not have to elaborate, but clear enough to communicate what needs to be done in case of an emergency. Have an emergency route to evacuate injured employees. If your jobsite is in a new development area that the emergency response team may not have access too, have in a convenient location that is easily accessible by all employees. Use established landmarks and turn by turn directions. Have a list of all the jobsite emergency contact information including any pre-existing medical conditions and allergies that emergency personnel may need to know.

Training

Employers should train employees to recognize hazards and unsafe working conditions and how to avoid them. Employers need to provide training on safe work practices, safe operation of machinery, and equipment, and how to recognize when things are not safe. Access ladders, stairways, confined space, and enclosed space entry hazards are all subjects that need to be trained and documented.

Recordkeeping

You must record and post injuries and fatalities. This is otherwise known as the 300-log. Maintain medical records and exposure records for all employees and past employees. You must maintain all appropriate documents and tags for abatement purposes. If you do not have these items, it could mean hefty fines.

I recently attended the 20th Chicagoland Safety and Health Conference.  During the day I asked as many safety professionals as possible what was the #1 incident on their OSHA 300 log.  To a person the response was Slips, Trips and Falls (STF).  Because this is one of the most common incidents I thought it would be good to revisit an old article published on this site about 2 years ago.  I hope you find this interesting and useful.

Employees don’t just slip and fall because they are careless. Hidden risks exist at all work sites.  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.

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Do you ship or receive any materials considered hazardous by the US DOT (49 CFR 172.101)?  If so, you MUST have a security plan (49 CFR part 172.800) which includes security awareness training to all who load, unload or have some responsibility putting the hazardous materials in commerce.  This might include the person in the office who fills out the shipping papers, or the forklift driver who unloads the truck in your loading bay.  Everyone involved with the process must be trained. 

The DOT has become more active fining companies and organizations for not having a security plan and not doing the training.  Large or small, profit or not-for-profit, it doesn’t matter.  Security awareness training is now considered one of the 5 parts of HAZMAT training.  the 5 parts include: General Awareness, Function-Specific, Safety, Security Awareness, and Security In-Depth (if you need and have a security plan as classified by (49CFR 172.800(b)(1-7). If your hazardous materials fall under this last part, then you must do a full security plan including a assessment and training.  The plan needs to be in writing and available to all who are affected.

The Compliance Resource Center can help you do a security assessment, write a security plan and customize hazmat training specificly for your company.  All of our HAZMAT training is customize for the hazardous materials you ship or receive.  You employees get ALL the training required by the US DOT Pipline and Hazardous Materials Safety Adminsitration.  DOT Hazmat training for ground is required every 3 years and for air and/or ocean every 2 years. 

In the construction industry, the Occupational Health and Safety Administration (OSHA) requires fall protection there is any risk of a worker falling from an elevation of 6 ft. or more. A personal fall arrest system is a system designed to “arrest” an employee in a fall from a working level. A personal fall arrest system contains three parts: anchorage connector, body wear, and connecting device.

The first part of a personal fall arrest system, the anchorage connector, is used to join the connecting device to an anchorage point, or tie-off point. The anchorage must be capable of supporting 5,000 pounds of force per worker, as required by OSHA, and the anchorage point must be high enough so that the worker will not make contact with the lower level in the event of a fall.

The next part of a personal fall arrest system is the body harness. The body harness is a series of straps which is designed to distribute the fall arrest forces throughout the parts of a falling worker’s body. A body harness is the only acceptable form of body wear to be used as part of a fall arrest system; the use of a body belt for fall arrest was prohibited as of January 1, 1998.

The connecting device, the third and final part of a fall arrest system, is the device which connects the body harness to the anchorage point. Commonly used connecting devices are shock-absorbing lanyards, fall limiters, and self-retracting lifelines. To determine the proper type of connecting device that should be used, the potential fall distance must be calculated. Factors such as the type of work being performed and the work environment should also be taken into consideration when selecting a proper connecting device.

Before a fall arrest system is used, it should be inspected for mildew, wear, damage, and/or other deterioration. Defective components should be removed if the strength or function of the component has been diminished. If a fall has occurred, the fall arrest system should not be used again until it has been inspected.

All workers should be trained to safely and properly use a fall arrest system. Worker training should include proper anchoring techniques, estimation of free-fall and total fall distances, and inspection of the system.

This article was written by Justin Rogers, The Lombardi Law Firm  West Des Moines, Iowa.

It is interesting that in the 29CFR 1910, there are 2 parts that have similar, yet vastly different relationships.  Both parts deal with hazardous materials but the difference is only one (1) zero or is it?  1910 part 120 is the regulation for hazardous waste operations and emergency response, and 1910.1200 is the compliance regulation for hazardous communications. 

Hazardous communications almost always is in the top 5 of most frequently cited standards of OSHA violations.  The most common citation is for failing to have a written program 1910.1200(e) and failure to train employees 1910.1200(h).

So what does this mean?  Employers are required to have an updated MSDS (Material Safety Data Sheet) book on ALL hazardous chemicals/materials in the workplace.  The book should be available to all employees who work with these hazardous materials.  Each time a new or changed hazardous material enters the workplace the MSDS book should be updated.  In addition, all hazardous materials must be properly labeled with a similar 3 or 4 part hazardous label similar to the ones seen above.  Some labels include proper PPE (personnel protective equipment) to be worn when working with this hazardous material.

Another key part of the Hazardous Communication standard is the training.  The training 1910.1200(h)(3) shall include at least:

• Methods and observations to detect the presence or release of a hazardous material in the work area.
• Physical and health hazards of hazardous materials in work area
• Measures take for protection.
• Information including how to use the hazardous labels, MSDS sheets and where employees can get information.

To avoid compliance issues with the Hazcom standard, start with a hazardous materials audit and develop you policies and procedures.  Next write a Hazcom program that includes training, and then do the training.  Remember, every time a hazardous material changes or is introduced into the workplace, or a new employee is put into that environment you must train or retrain all involved.  Avoid the problems and avoid the fines.  Write the program and do the training.

Last April, The Compliance Resource Center reported that NIOSH, OSHA and NHCA (National Hearing Conservation Assoication), recently signed and agreement  to help prevent work-related hearing loss.
Now researchers at NIOSH’s Pittsburgh Research Laboratory have developed QuickFitWeb, an online tool to allow users to check their hearing protection in a minute or less. The site notes that ear muffs, ear plugs, and other hearing protection devices can reduce the risk of hearing loss, but only if the wearer gets a good fit and wears them properly. The NIOSH sound player tool allows users to perform a quick test of whether they are getting at least a minimal 15 decibel (dB) level of protection.

The test sounds are bands of random noise with a center frequency of 1000 Hz. This is the same type of sound used in standard hearing protector ratings including the “American National Standard Methods for Measuring the Real-Ear Attenuation of Hearing Protectors” (ANSI S12.6). Both tracks are the same, but the second track is 15 decibels (dB) louder than the first. Most hearing protectors will block or “attenuate” sound by more than 15 dB if they are the right size and shape to fit the ears and are worn correctly. A sound that is barely audible at a worker’s threshold of hearing without hearing protection should be inaudible though hearing protection even if it’s boosted by 15 dB.

To use the tool, visit www.cdc.gov/niosh/mining/topics/hearingloss/quickfitweb.htm.