Training


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.


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.

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.

What are hazmat package markings? By definition, markings can be a descriptive name, UN identification number (some are on placards or orange panels), instructions, cautions, weight, and package specification. Markings can also be UN marks (such as UN package identification code), or any combination required by the regulations on the outer packaging of hazardous materials. Marking on the outside of packages communicates the presence of the hazardous materials inside.

Unless there’s an exception in the regulations, a package is required to have markings displayed on the outside. When markings are required, there are also certain rules on how the marking has to be maintained (such as durability and legibility), minimum size requirements and times when the display for certain markings may be prohibited for bulk packages. Even the hazardous material itself may require an additional marking, such as a material that is poisonous by inhalation. The regulations also dictate how the marking has to appear on the packaging or transport vehicle, so make sure you consult the regulations on marking display. After all, it wouldn’t do any good to place a marking on the bottom of the package where nobody can see it right?

When determining whether or not a package has to marked and what kind of markings have to be on the package itself, it’s important that the hazmat shipping papers are looked at. Again, this re-emphasizes the importance of well prepared shipping papers. If shipping papers are prepared wrong it can start an avalanche of other violations! If you put the wrong UN identification number on the shipping papers, then you may have the wrong identification number on the package. So now you have two violations on an  inspection report – a shipping papers violation and a marking violation. If the transport vehicle itself was required to be marked with the UN number, and it’s marked wrong, that vehicle may be placed out of service.

Once you’ve looked at the shipping papers, take a close look at the quantity to determine whether you’re hauling a bulk or non-bulk amount of hazmat. If the material meets the definition of non bulk, then the general requirements of 172.301 (non bulk requirements) will apply. If the hazmat meets the definition of bulk, then the requirements for bulk packages in 172.302 will apply. Keep in mind that these are just the basic requirements for bulk and non bulk markings, and there may be more requirements that apply to the package.

Remember when marking hazmat packages, what the markings are for – to warn others of the danger inside that package. Make sure you take your time and get the markings right, others are depending on you!

Many companies and their employees regard safety training as requirement and not a culture.  ”Why do I have to sit through this training (weekly, monthly or yearly)?”  is a question often asked the safety trainer.

To make sure that the training program is accomplishing its goals, an evaluation of the training can be valuable. Training should have, as one of its critical components, a method of measuring the effectiveness of the training. A plan for evaluating the training session(s), whether written or thought-out by the employer, should be developed when the course objectives and content are developed. It should not be delayed until the training has been completed. Evaluation will help employers or supervisors determine the amount of learning achieved and whether an employee’s performance has improved on the job. Among the methods of evaluating training are:

1. Student opinion. Questionnaires or informal discussions with employees can help employers determine the relevance and appropriateness of the training program;

2. Supervisors’ observations. Supervisors are in good positions to observe an employee’s performance both before and after the training and note improvements or changes; and

3. Workplace improvements. The ultimate success of a training program may be changes throughout the workplace that result in reduced injury or accident rates.

However it is conducted, an evaluation of training can give employers the information necessary to decide whether or not the employees achieved the desired results, and whether the training session should be offered again at some future date.

Improving the Program

If, after evaluation, it is clear that the training did not give the employees the level of knowledge and skill that was expected, then it may be necessary to revise the training program or provide periodic retraining. At this point, asking questions of employees and of those who conducted the training may be of some help. Among the questions that could be asked are:

1. Were parts of the content already known and, therefore, unnecessary?

2. What material was confusing or distracting?

3. Was anything missing from the program?

4. What did the employees learn, and what did they fail to learn?

It may be necessary to repeat steps in the training process, that is, to return to the first steps and retrace one’s way through the training process. As the program is evaluated, the employer should ask:

1. If a job analysis was conducted, was it accurate?

2. Was any critical feature of the job overlooked?

3. Were the important gaps in knowledge and skill included?

4. Was material already known by the employees intentionally omitted?

5. Were the instructional objectives presented clearly and concretely?

6. Did the objectives state the level of acceptable performance that was expected of employees?

7. Did the learning activity simulate the actual job?

8. Was the learning activity appropriate for the kinds of knowledge and skills required on the job?

9. When the training was presented, was the organization of the material and its meaning made clear?

10. Were the employees motivated to learn?

11. Were the employees allowed to participate actively in the training process?

12. Was the employer’s evaluation of the program thorough?

A critical examination of the steps in the training process will help employers to determine where course revision is necessary.

The Hazardous Waste Operations and Emergency Response Standard (HAZWOPER) applies to five distinct groups of employers and their employees. These include any employees who are exposed or potentially exposed to hazardous substances — including hazardous waste — and who are engaged in one of the following operations:

clean-up operations — required by a governmental body, whether federal, state, local, or other involving hazardous substances — that are conducted at uncontrolled hazardous waste sites;

corrective actions involving clean-up operations at sites covered by the Resource Conservation and Recovery Act of 1976 (RCRA) as amended (42 U.S.C. 6901 et seq.);

voluntary clean-up operations at sites recognized by federal, state, local, or other governmental body as uncontrolled hazardous waste sites;

operations involving hazardous wastes that are conducted at treatment, storage, and disposal facilities regulated by Title 40 Code of Federal Regulations Parts 264 and 265 pursuant to RCRA, or by agencies under agreement with U.S. Environmental Protection Agency to implement RCRA regulations; and

emergency response operations for releases of, or substantial threats of releases of, hazardous substances regardless of the location of the hazard.

(More information can be found in osha documents as specified by 1910.120 and 1926.65)

OSHA has authorized several specific HAZMAT training courses know has the hazwoper training courses.These courses are comprised of the 40 hour hazwoper, 24 hour hazwoper and the 8 hour hazwoper refresher course.

Many OSHA authorized sites like OSHAu.co offer hazwoper training courses online.These courses can be administered in self-paced, downloadable modules which allow the student to complete the required training at their leisure.Online training also provides employers with the benefit of allowing their employees to take the required training from any internet-based computer eliminating travel costs and while maintaining productivity. The benefits of online training are realized through increased safety and health of employees and an increased protection of our environment and it’s resources.

The Compliance Resource Center has reported that both the domestic hazardous materials transportation regulations and international rules for shipping batteries have undergone significant changes over the past two years.  All batteries, alkaline, lithium, lead, nickel metal hydride, carbon zinc, etc., or battery powered products are subject to 49 CFR 173.21(c) in the U.S. hazardous materials regulations.   Many batteries that were previously unregulated or under-regulated must now be thoroughly evaluated to determine hazard potential. Detailed packaging and communication standards must be followed under. 

Adding complexity to the issue is the fact that shipping requirements vary greatly, depending on the mode of transport and the type of battery.  Battery shipping regulations affect a wide array of industries from manufacturers and part suppliers to freight forwarders and distributors.  Regardless of whether a lithium or lithium ion cell or battery qualifies for the exceptions in the regulations, shippers must still comply with requirements of 49 CFR 173.21(c). That is, the cells and batteries must be securely packaged and offered for transportation in a manner that prevents the dangerous evolution of heat and short circuits.

Both FedEx and UPS will refuse to accept packages not meeting FedEx, Government or IATA requirements.

Slips Trips and Falls2.pngSlips, Trips and Falls happen everywhere.  These hazards have much more potential to cause harm in a healthcare setting, where patients are not well and people are in a hurry.  Haste is the number 1 cause of Slips, Trips and Falls.  Here are some helpfuls hints to think of.

Potential Hazard
Employee exposure to wet floors or spills and clutter that can lead to slips/trips/falls and other possible injuries.  
Possible Solutions:

  • Keep floors clean and dry [29 CFR 1910.22(a)(2)]. In addition to being a slip hazard, continually wet surfaces promote the growth of mold, fungi, and bacteria, that can cause infections.
  • Provide warning signs for wet floor areas [29 CFR 1910.145(c)(2)].
  • Where wet processes are used, maintain drainage and provide false floors, platforms, mats, or other dry standing places where practicable, or provide appropriate waterproof footgear [29 CFR 1910.141(a)(3)(ii)].
  • Walking/Working Surfaces Standard requires [29 CFR 1910.22(a)(1)]: Keep all places of employment clean and orderly and in a sanitary condition.
  • Keep aisles and passageways clear and in good repair, with no obstruction across or in aisles that could create a hazard [29 CFR 1910.22(b)(1)]. Provide floor plugs for equipment, so power cords need not run across pathways.
  • Keep exits free from obstruction. Access to exits must remain clear of obstructions at all times [29 CFR 1910.36(b)(4)].

Other Recommended Good Work Practices:

  • Ensure spills are reported and cleaned up immediately.
    Use no-skid waxes and surfaces coated with grit to create non-slip surfaces in slippery areas such as toilet and shower areas.
  • Use waterproof footgear to decrease slip/fall hazards.
  • Use only properly maintained ladders to reach items. Do not use stools, chairs, or boxes as substitutes for ladders.
  • Re-lay or stretch carpets that bulge or have become bunched to prevent tripping hazards.
  • Aisles and passageways should be sufficiently wide for easy movement and should be kept clear at all times. Temporary electrical cords that cross aisles should be taped or anchored to the floor.
  • Eliminate cluttered or obstructed work areas.
  • Nurses station countertops or medication carts should be free of sharp, square corners.
  • Use prudent housekeeping procedures such as cleaning only one side of a passageway at a time, and provide good lighting for all halls and stairwells, to help reduce accidents.
  • Provide adequate lighting especially during night hours. You can use flashlights or low-level lighting when entering patient rooms.
  • Instruct workers to use the handrail on stairs, to avoid undue speed, and to maintain an unobstructed view of the stairs ahead of them even if that means requesting help to manage a bulky load.
  • Eliminate uneven floor surfaces.
  • Promote safe work in cramped working spaces. Avoid awkward positions, and use equipment that makes lifts less awkward. 
     

Respirator21.pngOSHA is proposing to add two PortaCount® quantitative fit-testing protocols to its Respiratory Protection Standard (29 CFR 1910.134); the proposed protocols would apply to employers in general industry, shipyard employment, and the construction industry. The first of the two proposed protocols consists of the eight fit-testing exercises described in Part I.A.14 of Appendix A of the Respiratory Protection Standard, except each exercise would last 30 seconds instead of the currently required 60 seconds.\1\ The second proposed protocol would eliminate two of the eight fit-testing exercises, and each of the remaining six exercises would last 40 seconds; in addition, this proposed protocol would increase the current minimum pass-fail fit-testing criterion from a fit factor of 100 to 200 for half masks, and from 500 to 1,000 for full facepieces.

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.

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