Workplace Safety & Consulting May, 2009 | SAFETY BLOG

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SAFETY HUDDLE - FALL PROTECTION SYSTEMS

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Fall Protection Systems 

When employees are exposed to heights over 6 feet above lower levels, they shall be protected from falling by guardrail systems, safety net systems, or personal fall arrest systems.  The following Heroic Safety Huddle defines the details and specific regulations pertaining to these protection systems as set forth by OSHA CFR Part 1926.502.

Guardrail Systems shall comply with the following provisions:

  • Top edge height of top rails shall be 42 inches plus or minus 3 inches above walking/working level
  • Midrails shall be installed between top rail and working surface where there is no wall or parapet at least 21 inches high
  • Screens and mesh used shall extend the entire opening from top rail to working surface
  • Intermediate members (balusters) shall be no more than 19 inches apart
  • Guardrails must be capable of withstanding 200 lbs. applied within 2 inches of the top edge in any outward or downward direction
  • When 200 lbs. is applied in downward direction, the top edge of guardrail shall not deflect below 39 inches from working surface
  • Midrails, screens, and mesh shall be capable of withstanding 150 lbs. in outward or downward direction
  • Guardrails to be surfaced to prevent injury to employees from punctures and lacerations
  • The ends of all top rails and midrails shall not extend past terminal posts
  • Steel banding or plastic banding shall not be used as top rails or midrails
  • Top rails and midrails shall be at least 1/4 inch nominal diameter or thickness
  • Wire rope top rails shall be flagged at no more than 6 ft. intervals by highly visible material
  • Guardrail systems used around holes that are used for access points shall have a gate
  • Guardrail systems used on ramps and runways shall be erected on all unprotected sides

 Safety Net Systems shall comply with the following provisions:

  • Shall be installed as close as practicable under the walking/working surface on which employees are working
  • Shall extend outward from the outermost projection of the work surface as follows:
    • 5 ft. to net (vert.) = 8 ft. from net edge to working edge (horz.)
    • 5 to 10 ft. = 10ft.
    • more than 10 ft. = 13 ft.
  • Shall be installed with sufficient clearance under net to prevent contact with surface or objects below
  • Drop test to be performed at installation, before being used as fall protection, after relocation, after major repairs, and at 6 month intervals
    • Drop test consists of dropping 400 lb. bag of sand 30 inches in diameter into net from highest working surface
  • Inspected at least once per week
    • Defective nets not to be used

 Personal Fall Arrest Systems shall comply with the following:

  • As of January 1, 1998, body belts are not acceptable as part of a personal fall arrest system
    • Only positioning systems
  • Connectors shall be drop forged, pressed, or formed steel
  • Surfaces and edges shall be smooth
  • Dee-rings and snaphooks shall have minimum tensile strength of 5,000 lbs.
  • Unless a locking-type snaphook, they shall not be engaged:
    • directly to webbing, rope or wire rope
    • to each other
    • to a Dee-ring to which another snaphook or other connector is attached
    • to a horizontal lifeline
  • Horizontal lifelines shall be designed, installed, and used in a manner which maintains a safety factor of at least two
  • Lanyards and vertical lifelines shall have a minimum breaking strength of at least 5,000 lbs.
  • Except during the construction of elevator shafts, each employee shall be attached to a separate lifeline
  • Lifelines to be protected from cuts and abrasions
  • Ropes and webbing straps used in lanyards, lifelines, body belts and harnesses shall be composed of synthetic fibers
  • Anchorages used for attachment shall be capable of supporting at least 5,000 lbs. per employee attached
  • Personal fall arrest systems, when stopping a fall, shall:
    • Limit maximum arresting force to 1800 lbs when used with a body harness
    • Be rigged such that an employee can neither free fall more than 6 ft. nor contact any lower level
    • Bring an employee to a complete stop and limit max deceleration distance an employee travels to 3.5 ft.
    • Have sufficient strength to withstand twice the potential impact energy of an employee free falling a distance of 6 ft.
    • Employee shall provide for prompt rescue of employees in the event of a fall or shall assure that employees are able to rescue themselves
    • Personal fall arrest systems shall be inspected prior to use, post damage or other deterioration, and defective components shall be removed from service
    • Shall not be attached to guardrail systems

 Be safe out there!

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FIRE SAFETY TRAINING AT WORK & AT HOME

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Fire hazards are not just limited to the workplace.  Fires in the home can be both devastating and tragic.  Americans must not only conduct fire safety trainings in the workplace, but at home with their children as well.

Workplace Fire Safety

Emergency planning is one of the most basic safety trainings conducted in the workplace.  Employers should consider establishing written emergency protocols and practicing emergency scenario drills twice a year.  Workplace emergency protocols and trainings should include the following:

  • Define evacuation procedures
    • Exits should be located on site maps throughout workplace
    • All exit signs to be illuminated for easy recognition
    • Locations, maintenance, and use of fire extinguishers should be trained on annually
      • When to fight fire vs. when to flee
    • Employee responsibilities during evacuation
      • Processes or machines that need to be turned off
      • Other employees with disabilities that may need assistance
      • Emergency contact numbers
      • Outdoor employee meeting and check-in location
    • Practice emergency evacuation drills bi-annually
  • Shelter-in-place procedures
    • Identify the most structurally sound area of the complex
    • Post signs identifying emergency shelter
    • Store an emergency band radio with extra batteries
    • Practice shelter-in-place drills bi-annually
  • Identification of special hazards
  • Invite local emergency service personnel to tour facility annually
    • Review emergency protocols, procedures, and special hazards

 The best way to protect our families from fire hazards at home is by developing a safety plan and practicing bi-annually.

Fire Safety At Home

  • Educate family members and practice fire safety tips
    • Stop, drop and roll
    • Feeling and closing doors during fire emergencies
    • Staying low to ground in smoke filled environments
    • Teach children to go to windows and await help if they cannot self extricate
    • Children should not hide or run from firefighters
    • Never play with matches, lighters, outlets, or electrical appliances
  • Change batteries in smoke detectors every time the clocks are changed (bi-annually)
  • Every floor should have a carbon monoxide detector
  • At minimum, keep a dry-chemical fire extinguisher in the kitchen
    • Optimally, every floor should have an extinguisher
    • Laundry room as well
  • Draw a floor plan of your house with your children and map out two escape routes from each floor of house
    • Outdoor meeting location should be identified
    • Outdoor meeting location should be at a neighbors front lawn or porch so neighbors can watch over children until you or help arrives
    • Discuss escape plan and bedroom layout of your house with neighbors
    • Practice escape with children twice a year
  • Fire and barbecue pits should be a minimum of twenty five feet away from structures
  • Never store flammable liquids or oily rags in house
  • Create preparations for natural disasters and other emergencies
    • Store plenty of drinking water
    • Emergency-band radio with extra batteries
    • Non-perishable foods
    • Extra blankets and first aid supplies
    • Visit the Department of Homeland Security for a detailed emergency preparation checklist

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SAFETY HUDDLE - TRENCH HAZARDS

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Identifying Trench Hazards 

Trenching and excavations are very dangerous operations in the workplace.  The greatest hazard associated with trench work is a trench cave-in.  Cave-in accidents have twice as many fatalities in comparison to all other construction accidents.  Employers and employees have to develop a detailed plan of operation, perform a hazard analysis, inspect the job site, and remain safety conscious at all times.

Identifying and understanding the many hazards present in trenching operations can prevent tragedies on a job site.  The following list comprises many trench hazards that have to be evaluated, mitigated, and abated before trench-work begins.

  • Location of underground utilities - Contractors must make an effort to notify utility owners of proposed trench work near or around the location of suspected utilities or before new trenching projects begin.
    • Ask owners for exact locations
    • Inquire of any and all hazards created by the utilities
    • Are there ways to abate or control the hazards associated with those utilities
    • If contact with utility owners cannot be made within 24 hours, proceed cautiously with trench operation
  • Inclement weather - Always obtain weather reports on a daily basis before starting any trench operations.  Severe weather can have serious effects on the stability of a trench and create deadly hazards within a matter of minutes.
    • Alert employees of impending storms, heavy rains, potential flooding, freezes/thaws and lightning
  • Soil types - Making a determination on soil type will identify specific hazards and will dictate trench protection systems and regulations.
    • Soil testing should always be conducted by a competent person trained in classifying soils
    • Always attempt to use multiple forms of testing
      • Visual Tests-identify features and characteristics of the soil.
        • If present, identify sand, gravel, silts, clays, solid rock, etc.
        • Look for fissures or cracks in soil
        • Identify standing or seeping water in soil
        • Take note of any evidence of erosion
        • Evidence that the location has been excavated before
      • Manual Tests-employ a competent person to complete manual testing via various means and instrumentation.
  • Vibrations - There are many sources of vibrations on job sites, all of which can have a great effect on the shifting or stability of trenches.  Here is a list of some common sources:
    • Construction machinery
    • Highway traffic
    • Railroad traffic
    • Pile driving operations
    • Jack hammering operations
    • Grinding and paving operations
    • Industrial operations
  • Water - Standing and flowing water can create immediate cave-in and drowning hazards.
    • Pump out any and all standing water inside of trench
    • Divert flowing water away from trenches
    • Assess adjacent structures to identify where runoff will be deposited
    • Evacuate any trenches where water is seeping through the soil
  • Adjacent structures and over-head operations
    • Assess whether or not the weight of adjacent structures will effect the stability of the trench
    • Wear appropriate PPE and construct over-head protection for employees who may be injured by falling objects
    • Determine if excavating operations will effect the stability of adjacent structures
  • Defects in protective systems - Always inspect safety equipment before utilizing.
    • Look for inadequate or weakened welds on trench boxes
    • Pneumatic lines should be assessed for air leaks and broken couplings.  Pneumatic trench jacks with leaks should never be used
    • Always use to manufacturers specifications on the equipment
    • Never exceed posted load and weight limits on equipment
  • Inexperienced employees - Anytime an employer feels that an employee is unaware of job responsibilities and company safety policies, that employee is not allowed to work in trenching operations until training has been conducted and the employer feels the employee has become competent.

 All of the previous hazards should be identified and assessed before any trench operation begins.  Take care of your employees and your company by developing detailed trenching protocols, conducting site safety inspections and implementing job-specific safety trainings.

Be safe out there!

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NEVADA PROPOSES LAW FOR WORKPLACE SAFETY IN CONSTRUCTION

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The state of Nevada has been developing a bill that would set a potential precedent for construction workers and workplace safety in the United States.  Nevada has reported a rash of construction fatalities and injuries in recent months.  The Las Vegas Strip alone has had twelve construction worker fatalities in the last eighteen months, and the entire state is reporting more deaths in the last two years than in the previous ten.  State legislators are quickly trying to alter the current trends.

Assembly Bill 148 would require all private and public construction workers in the state of Nevada to show proof of safety training to their employers.  Baseline construction workers would have to prove that they have successfully completed training in areas such as fall protection, electrical safety, walking and working surfaces, etc.  The level of training reflected in the Bill appears to be similar to topics covered in an OSHA Construction 10-Hour training.  Construction supervisors in Nevada would be required to prove that they have completed a 30-hour safety training.  Workers would have fifteen days from date of hire to show proof of training to their employers or otherwise be subject to dismissal.  The bill met no opposition from the Assembly Ways and Means Committee and was sent to the floor of the House for a vote next week.

Currently there are no states that require construction workers to have safety trainings.  There are however, states that do require safety certificates for construction employees on public projects.  Assembly Bill 148 would require proof of training on all public and private projects for any and all construction workers.  The only exception to the Bill would be state Department of Transportation employees.

In a nation plagued by liabilities and lawsuits, all eyes of the states will be on the reported results of this law.  If the fatality and injury rates for Nevada decrease, which they most certainly will, do not be surprised if other states begin to develop similar proposals.

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CAL-OSHA SHUTS DOWN CONTRACTORS FOR FAILURE TO COMPLY

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It looks as though we are not the only ones who take heat emergencies seriously in this time of year.  California's state run OSHA, also known as Cal-OSHA, on Wednesday, May 13, shut down two west coast farm contractors for failure to comply with the state's heat illness prevention program. 

California is a state that has a large agriculture-based workforce and is subject to extreme temperatures throughout the late spring and summer months.  California runs its own occupational safety and health program under what is known as a state plan program.  The safety and health of the workforce in this state is not regulated by Federal OSHA, but rather, Cal-OSHA who has their own set of occupational safety and health regulations.  States can regulate themselves under a state plan as long as their regulations are as strict or more so than Federal OSHA's standards.

Two farm labor contractors were recently shut down for failing to comply with Cal-OSHA's regulations that protect workers from heat-related illnesses.  The Jose Alfaro Labor Contractor and Estrada Farm Labor Services were both halted from doing business because they failed to provide adequate shade and water for their employees.  Also, neither of the two contractors could prove that they provided adequate training or emergency response procedures to their employees as it relates to heat emergencies.

In regards to heat illness prevention, California employers must take the following four steps to be compliant with the program:

  1. They must train all employees and managers on the subject of preventing heat illness.
  2. They must provide and encourage each employee to consume at least 1 quart of fresh water per hour.
  3. Access to shade must be provided to employees who believes that they are in need of a rest period due to heat exposure.  Adequate shaded areas must be provided to ensure 5 minute rest periods in the shade.
  4. All employers must develop and implement written policies and procedures for complying with the Cal-OSHA Heat Illness Prevention Standard.

 For more information regarding heat emergencies and heat illnesses, please read Heroic Safety's Safety Huddle on Heat Emergencies located in our safety blog archives.  Access the Safety Huddle tag.

Be safe out there.

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OSHA ACCELERATED

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President Obama's Labor Department unveiled additional funding for OSHA.  The stimulus will give OSHA an additional $51 million and will include the hiring of 160 new safety inspectors nation wide.  The increase in funding is meant to motivate OSHA to tackle issues that according to the current administration, were stalled under the previous administration.  American firms and industries should prepare themselves for a more "hands-on" regulating agency.  More money means more resources and more inspections.

On May 11, 2009, OSHA published its agenda for issues and regulations that are going to be developed and reviewed over the next year.  Some of the regulations and issues being reveiwed and developed are as follows:

Pre-Rule Stage

  • Protection of workers exposed to crystalline silica and the economic impact of implementing protection standards for employers.
  • Proposed rule for workers exposed to beryllium (a light metal that can cause lung damage).
  • Occupational exposure to diacetyl (a butter-flavoring additive linked to "popcorn lung").

Proposed Rule Stage

  • Closing of the proposed rule for cranes and derricks in construction.
  • Adding additional information on minimum approach distances for its electrical protective equipment.
  • New rules associated with working in confined spaces in construction, shipyards, and other industries.

 Long-Term Actions

  • Review of the current bloodborne pathogen standard as to how it relates to other standards and current technologies.

In January, the Obama Administration announced the withdrawal of the advance notice practice for rule-making.  This practice, which was set in place by President Bush at the end of his presidency, has been criticized by opponents who say that it delays the rule-making process by as much as two years.  The current president wants to make a statement in the workplace.  All American companies need to stay up-to-date on OSHA standards, and ensure their company safety programs are developed and in compliance.

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SAFETY HUDDLE - HEAT EMERGENCIES

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Heat Emergencies in the Workplace

It is almost time for summer.  Whether working indoors or outdoors, summer means longer days and increased temperatures in the workplace.  Now is a good time for employers and employees to review heat related emergencies and become fluent in ways to decrease the chances of heat-related accidents and injuries.

Heat Related Stressors:

  • Direct sunlight
  • Poor physical condition of employee
  • Lack of ventilation or air movement inside structures
  • High-heat operations or processes
  • Lack of hydration
  • Heavy work clothing or PPE
  • Some medicines increase risks
  • Lack of experience or tolerance to increased temperatures

Heat Related Emergencies

  1. Heat Rashes
    • Most common symptom experienced by employees in hot work environments.
    • Occurs as a result of skin that stays wet from unevaporated sweat.
      • areas commonly affected is the neck, groin, upper chest and back, under breasts, knees and elbows
    • Mitigation
      • continually seek rest and shelter in a cooler, less humid environment
      • keep all affected areas dry
      • use dusting powders to decrease wetness and increase comfort, but avoid creams and ointments
  2. Heat Cramps
    • An early indicator that the employee's core temperature is rising and not compensating properly.
    • Symptoms include muscle aches and soreness throughout the body.
    • Caused by electrolyte imbalances from perfuse sweating and lack of hydration to replenish nutrients.
    • Associated with hard physical labor in hot environments.
    • Mitigation
      • drink one cup of cool water every 15 to 20 minutes
      • consume electrolyte/carbohydrate based sports drinks at regular intervals throughout the day
      • implement regular rest breaks in cool shaded environments
  3. Heat Exhaustion
    • A progressed indicator of more serious heat related injuries.
    • Caused by a combination of excessive heat and prolonged dehydration.
    • Signs and symptoms are weakness, dizziness, nausea and severe headaches.
      • fainting and collapse are severe symptoms that can pose serious injury risks to employees
    • Mitigation
      • shelter in cool shaded areas
      • provide fluid hydration
      • apply cold packs to back of neck, groin and armpits
      • employees exhibiting symptoms of heat exhaustion should be removed from service and must rest for the remainder of the day
  4. Heat Stroke
    • A life-threatening disorder!
    • Occurs as a result of the body's inability to continually regulate temperature and the body temperature rising to critical levels.
    • Early symptoms
      • irrational behavior, lack of sweating, extreme confusion, hot and dry skin
    • Late symptoms
      • seizures or convulsions, loss of consciousness
      • death
    • Mitigation
      • call paramedics immediately
      • shelter employee in cool shaded environment
      • remove clothing
      • wet employee's body with cool water
      • apply cold packs to neck, groin, and armpits
      • hydrate conscious employee with cool water
      • employee must be seen by medical professionals

Best Work Practices

  • Provide cool beverages to employees and encourage employees to hydrate every 15 to 20 minutes.
  • In extreme temperatures, work in shifts that alternate one group resting in the shade while another group works in the heat.  Continue to alternate at tolerable working levels.
  • Expose workers to higher temperatures gradually.  Steadily acclimate employees to higher and higher temperatures and at longer periods of time.  This will increase their tolerance to working conditions.
  • Encourage employees to wear light fabrics that wick moisture away from skin and ventilate well.
  • Provide rest and recovery in cool shaded areas that may contain fans, misting devices, and hydration services.
  • Always monitor employees with chronic and acute health conditions.  Consider reassignment for higher risk employees.
  • Reschedule hot work for days when lower atmospheric temperatures will compliment high heat processes and operations.
  • Have employees trained in first aid and CPR assigned to every job site or workplace.

 

Stay cool and be safe out there!

-Heroic Safety

 

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UNDERSTANDING THE HAZARDOUS MATERIALS COMMUNICATIONS PROGRAM

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OSHA estimates that 32 million employees are exposed to hazardous chemicals each year in the United States.  Understanding OSHA's Hazard Communication (HazCom) program can be quite confusing at times.  OSHA 29 CRF Part 1910 Subpart Z states that the purpose of the program is to ensure that the hazards of all chemicals produced or imported are evaluated, and that information concerning their hazards is transmitted to employers and employees.  This transmittal is to be accomplished by means of comprehensive hazard communication programs, which are to include container labeling and other forms of warning, materials safety data sheets and employee training.

Scope and Range of HazCom

  • All hazardous chemicals as defined by OSHA that employees may be exposed to under normal workplace conditions of use or in a foreseeable emergency are covered under this standard.
    • Exemptions:
      • Hazardous substances being removed under CERCLA
      • Tobacco or tobacco products
      • Wood or wood products that will not be processed at all
      • Manufactured articles other than a fluid or particle that are formed to a specific shape during manufacturing
      • Food or alcoholic beverages which are sold, used, or prepared in a retail establishment, or intended for consumption
      • Prescription or over-the-counter drugs
      • Cosmetics
      • Consumer products where the employer can show that it is used in the workplace in a method, duration, and frequency of exposure which is not greater than experienced by consumers
      • Ionizing and non ionizing radiation
      • Biological hazards

Employer Responsibilities - 7 Standards under HazCom:

  1. Chemical inventory
  2. Labeling
  3. Material Safety Data Sheets (MSDS)
  4. Non-routine tasks
  5. Multi-employer workplace
  6. Training
  7. Hazcom plan

Chemical Handling and Maintenance:

  • Hazardous Chemical Inventory: at minimum, is a list of hazardous chemicals known to be present in the workplace.
    • It is a good idea to include the common names, trade names, chemical manufacturer, locations and quantities in the inventory.
  • Types of containers:
    • Primary- are prelabeled containers of Hazardous Chemicals (HC) that you purchase from the manufacturer or distributor.
    • Secondary- when employer transfers a HC from primary to another container to store and use smaller quantities.
    • Stationary- large permanent containers.
    • Portable- used when small amount of chemical is transferred into another container for immediate use.
  • Chemical Labeling
    • Primary container labels must contain:
      • product name
      • name and address of manufacturer
      • health effects including target organs
      • must be in English and legible
    • Secondary labeling: employee is responsible to make sure every secondary container of HC is labeled, tagged or marked with at least the following information:
      • identity of HC
      • appropriate hazard warnings, pictures, words, and/or symbols which provide at least general hazard information, which in conjunction with MSDS will provide employee with specific information on physical and health hazards
      • employees must be trained in how to read designated labeling systems
        • i.e.  NFPA, HMIS
  • HMIS - Hazardous Materials Identification System

              HMIS Label

    • health hazard (blue)  /  0-4 (4 worst or most)
    • fire hazard (red)  /  0-4
    • reactivity (yellow)  /  0-4
    • personal protective equipment (white)  /  listed
  • NFPA (National Fire Protection Association)

              NFPA Label

    • red (flammability)
    • blue (health)
    • yellow (reactivity)
    • white (special hazards)
  • There are 2 exceptions to labeling portable containers:
    • containers do not have to be labeled if employee filling container is only employee using chemical.
    • if there will be no material left in container at the end of the work shift.

Material Safety Data Sheet (MSDS):

  • Chemical manufacturers and importers must obtain or develop a MSDS for each HC they produce or import.
  • Manufacturer and importer responsibilities:
    • prepare MSDS and ensure the information is accurate
    • update MSDS when aware of new information
    • provide MSDS with the first chemical shipment or as requested by the employer
  • Distributor responsibilities:
    • ensure that MSDS's are provided to other distributors and employers with the initial product shipment or upon request
  • Employer responsibilities:
    • provide ongoing maintenance and updates of chemical MSDS
    • obtain an MSDS for each chemical if not provided with the initial product
    • make sure that all MSDS's are readily accessible during each work shift
  • Each MSDS must be in English, employer may obtain copies in other languages.
  • MSDS are not standardized, but all information described below must be present somewhere on the MSDS:
    • product information-dates, names, phone numbers, etc.
    • ingredient information-CAS #, exposure limits, etc.
    • physical and chemical characteristics
      • appearance, specific gravity, vapor pressure, etc.
    • fire and explosion data
    • fire fighting measures
    • reactivity data
    • health hazard information
    • hazard identification-acute hazards
    • first aid measures
    • precautions for safe handling and use
    • transportation information
    • labeling information

HazCom Training:

  • Who needs to be trained?
    • all full time, part time, temporary and volunteer employees
    • employer must evaluate each employee's level of knowledge with regard to chemical hazards
  • How often is training needed?
    • training at time of initial assignment
    • when new physical of health hazard is introduced
    • annual training recommended
  • What information in presented?
    • requirements of 29 CFR 1910.1200
    • any operations in an employee's work area where hazardous chemicals are present
    • methods and observations used to detect releases
    • physical and health hazards of chemicals present
    • measures of protection
    • location, availability and details of employee HazCom plan

Multi-Employer Worksites:

  • All employers hiring outside contractors must include the following in their HazCom plan:
    • the HC's employees may be exposed to
    • methods the employer will use to provide the contractors on site access to MSDS's
    • methods the employer will use to inform the contractor of precautionary measures taken to protect themselves when working around HC's.

 

 

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SAFETY HUDDLE - PPE

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Safety Huddle - PPE

The following safety huddle topic is an overview of OSHA personal protective equipment for the construction industry.  All information has been extracted from OSHA 29 CFR Part 1926, Subpart E.  This information is for informational purposes only.  Employers should always create a written policy that supports a comprehensive PPE program and conduct regular trainings specific to the safety equipment used in their workplaces.

The key to selecting the appropriate PPE is the proper identification of all hazards in a workplace that may cause harm or injury to an employee.  All PPE is listed to protect employees from very specific hazards.  Research the differences between classes of PPE and make a selection based on their rated capacities.  As an example; an employee works near a furnace operation.  You would not want to just buy shaded safety glasses.  By consulting Table E-1, you will find that the employee needs safety glasses with class 7, 8, or 9 protectors.  Always research all forms of PPE before purchasing and employing for service.

Criteria for personal protective equipment:

  • Application- protective equipment including eyes, face, head, extremities, protective clothing, respiratory devices, and protective shields and barriers shall be provided, used, and maintained in a sanitary and reliable condition wherever it is necessary by reasons of hazards of processes or environment, chemical hazards, radiological hazards, or mechanical irritants encountered in a manner capable of causing injury or impairment in the function of any part of the body through absorption, inhalation, or physical contact.
  • Employee-owned equipment- where employees provide their own equipment, the employer shall be responsible to assure its adequacy, including maintenance, and sanitation.
  • Payment for PPE- PPE shall be provided by the employer at no cost to the employee, except:
    • non-specialty safety-toe equipment and non-specialty prescription safety eyewear
    • when an employee provides their own adequate equipment that the employer permits the employee to use
    • when an employee loses or intentionally damages the equipment

Occupational Foot Protection:

  • Safety-toe footwear for employees shall meet the requirements and specifications in ANSI (American National Standards Institute) Z41.1-1967.

 Head Protection:

  • Protective helmets shall be required in areas where employees are in danger of head injury from impacts, falling or flying objects, or from electrical shock or burns.
  • Helmets shall meet requirements set forth in ANSI Z89.1-1969.
  • Helmets for employees exposed to high voltage electrical shock and shock shall meet ANSI Z89.2-1971.

Hearing Protection:

  • Use table D-2 in OSHA 29 CFR 1926, Subpart D for defining permissible occupational noise levels.
  • Always eliminate or mitigate noise hazards and limit duration of exposure to noise hazards when possible.
  • Wherever it is not feasible to reduce the noise levels or duration of exposures to those specified in Table D-2, ear protective devices shall be provided and used.
  • Ear protective devices inserted in the ear shall be fitted or determined individually by competent persons.
  • Plain cotton is not an acceptable protective device.

Eye and Face Protections:

  • Employees shall be provided with eye and face protection equipment when machines or operations present potential eye or face injury from physical, chemical, or radiation agents.
  • Eye and face protection shall meet ANSI Z87.1-1968.
  • Employees whose vision requires the use of corrective lenses in spectacles shall be protected by goggles or spectacles of the following types:
    • Spectacles whose protective lenses provide optical correction
    • Goggles that can be worn over spectacles
    • Goggles that incorporate corrective lenses mounted behind the protective lenses
  • Face and eye protection shall be kept clean and in good repair.
  • Use Table E-1 in Subpart E as a guide in the selection of face and eye protection for the hazards and operations noted.
  • Protectors shall be comfortable, fit snugly, be durable, be capable of being disinfected, and easily cleanable.

Protection Against Radiant Energy:

  • Use Table E-2 for selection of shade numbers for welding operations.
  • Use Table E-3 for selecting safety glass for laser operations.

Working Over or Near Water:

  • Employees working over or near water, where the danger of drowning exists, shall be provided with U.S. Coast Guard-approved life jackets or buoyant work vests.
  • Prior to and after each use these protective devices will be inspected for defects.
  • Ring buoys with at least 90 feet of line shall be provided and readily available for emergency rescue operations.
  • Distance between ring bouys shall not exceed 200 feet.
  • At least one lifesaving skiff shall be available for employees working near or over water.

 Refer to Subpart M for all standards pertaining to fall protection equipment.

Respirators is an extensive subject that will be addressed in a future Safety Huddle article.

All Tables and standards can be accessed at:

 

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SWINE FLU AND WORKPLACE SAFETY

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Pandemic

The word "pandemic" seems to be terrifying everyone at the moment.  We would like to remind everyone to not panic in the wake of the media coverage.  About 36,000 Americans die of typical influenza strains each year.  We currently have less than 60 confirmed cases in the U.S., and only one reported fatality.  Nevertheless, that does not mean that we do not need to think workplace safety.  Heroic Safety would like to stress personal hygiene, personal protective equipment, and thinking safety in the workplace.  The following link is the government information site for swine flu information.  Take every precaution to protect yourselves, but conduct business as usual.  Stay safe out there!

Pandemic Flu Information

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GOVERNMENT PLANS TO TARGET WORKPLACE SAFETY VIOLATORS

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OSHA has recently sent out letters to 13,500 specific employers in the United States in order to remind them that their reported illnesses and injuries in the workplace are higher than the national average.  Like they didn't know this already.  This is a prelude of things to come from government control over large companies.  It would seem logical that the fines, increased inspections, and increased medical and worker's compensation costs would remind them on a regular basis.  The Washington Post reported that OSHA is discussing the creation of a Severe Violators Inspection Program.  According to the article, OSHA plans to eventually turn up the heat on what they call "negligent companies" or companies that do not take worker safety seriously.  A similar version of this program was created in 2003, but has proved to be an OSHA failure.

On April 30, 2009, the Workforce Protection Subcommittee of the House Education and Labor Committee met in order to improve OSHA's Enhanced Enforcement Program (EEP).  The EEP was implemented in 2003 and has since proved to be a huge failure.  This program was designed to target companies that reported above average injuries and illnesses with increased inspections and stricter delegation of discipline.  OSHA has been analyzing the performance level of the EEP program and has found that since its inception, OSHA has failed to comply with program requirements in 97% of the EEP cases.  The Severe Violators Inspection Program will be a rebuild of the EEP.  They plan to re-engineer this program from the ground up, and make no mistake, they plan to enforce it.  Their plan is to concentrate attention on large companies and less targeting of smaller companies.

Proponents of the program state that there are too many large companies in the United States that do not take safety seriously and endanger their employees on a regular basis, therefore, violating the General Duty Clause to provide hazard-free work environments.  They blame the Bush Administration for the EEP's failure.  They state that the former administration was overlooking safety enforcement to protect big-business.  Skeptics state that this program will inadvertently target compliant companies that have more reportings because they report all incidents including minor injuries and illnesses.  They also state that this program will deter larger companies from reporting in order to stay clear of OSHA's radar.  It would appear that bipartisan debates have spilled over into workplace safety.

Either way we slice it, we will most certainly see increased regulation of workplace safety in the near future.  Our current administration appears to have declared war on big-business and large corporations.  Now is an excellent time to evaluate your company's safety policies, procedures, training programs, and commitment to workplace safety.  Become proactive rather than reactive. Make the changes now that will not cost you later. 

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