CCI Celebrates 25 Years!
Compliance Consultants, Inc. (CCI) is celebrating its 25th anniversary!
CCI was founded by Michael J. Cunningham, Sr. in 1987. CCI started with the belief that every working man and woman has the right to come home safe after a day of work. Based on this belief, CCI has created a wide array of health, safety and environmental consulting services that will help keep your employees out of harm’s way and keep your company compliant with regulations. The goal of CCI is to ensure that our clients stay in good standing with all local, state and federal government regulations involving workplace safety, hygiene and environmental concerns.
Our success over the past 25 years has grown steadily due to the loyalty of our clients who helped get us here. They have allowed us the opportunity to implement and properly maintain various safety programs and services and provide proper training when needed to keep their workplace safe and free from injuries. These relationships have been built on quality, integrity and trust. It is with great enthusiasm that we continue assisting facilities throughout the tri-state area in an effort to maintain a safe and healthy workplace for all!
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Looking at the GHS: How to be Prepared
If not this month, at some point this quarter, we can expect to see OSHA’s final rule on aligning the Hazard Communication Standard (HCS) with the UN’s Globally Harmonized System of Classification and Labeling of Chemicals (GHS) published in the Federal Register. If you haven’t heard of it yet, the GHS is basically a way to align, or harmonize, the way chemical hazards are classified, labeled and communicated to others across all nations that participate with the GHS. The main benefit is that everyone involved in the life cycle of a chemical, from producer to consumer, and everyone in between, will be able to easily understand the hazards posed by the chemical, thus reducing accidents and illnesses and increasing overall safety. But what changes can be expected and how can you be prepared for them?
The first and most important step to take is to educate yourself. Hopefully, you’re already familiar with the requirements of the current HCS and only need to learn the differences between the two. The major differences lie in three areas:
- Chemical Classification
- Safety Data Sheets (SDS) and
- Labeling
Chemical Classification
Appendices A and B of the new standard describe in detail the classification system being used for health and physical hazards respectively. Chemicals will have a chemical class based on the health and physical hazards and also a chemical category, based on the types of hazards associated with that class. Hazard categories can be presented in either text or numerical form. For instance under the class Gases Under Pressure, the hazard categories are listed as compressed gas, liquefied gas, dissolved gas or refrigerated liquefied gas. On the other hand, under the class Flammable Liquids, hazard categories are in numerical order from 1-4, 1 being the most hazardous and 4 being the least. (Please note how this differs from the NFPA/HMIS numbering that many are used to where 1 is the least hazardous and 4 is the most.) Once manufacturers or importers have classified the chemical the next step is communication. Chemical hazards are communicated through Safety Data Sheets (SDS) and labels, created and provided by the manufacturer.
Safety Data Sheets
While the old Material Safety Data Sheet (MSDS) had to have 12 sections that could be organized in any way, the new SDS has 16 sections that must be presented in a specific order. As of right now, sections 12-15 (ecological information, disposal considerations, transport information, and regulatory information) are not mandatory as they do not fall under OSHA’s jurisdiction. We may see changes on this later as EPA and DOT regulations are aligned with the GHS.
Labeling
Label requirements are very specific under the GHS. All labels are required to have the following parts: a product identifier (the name of the chemical as seen on the SDS), signal word (Warning or Danger), a hazard statement (i.e. fatal if swallowed, harmful if inhaled), a pictogram (one of eight standard symbols), and precautionary statements (special prevention, response, storage, and disposal considerations). This information must be provided for each hazard class and associated hazard category. While it is the job of the manufacturer to provide these labels, in the end it falls on the employer to ensure that the labels are available, legible, and prominently displayed. Not all retailers are required to have labels and SDS for chemicals they are not using themselves. If the vendor does not provide a SDS or label for the chemical, it is the employer’s responsibility to contact the manufacturer and obtain these documents.
It is imperative that all companies that keep hazardous chemicals on site, have a current Written Hazard Communication Program available, Safety Data Sheets readily available for all chemicals on site and labels prominently displayed on chemical containers. Even more important? Understanding the information contained in the written program, SDS, and on the label and making sure employees understand it too. And this brings us to training.
Training
OSHA is requiring that all employees be trained on the changes happening with the GHS/HCS within 2 years of the final rule being published in the federal register. However, the time to start training is as soon as employees begin to see changes taking place and are affected as a result of the new regulation. Employees must be trained on Safety Data Sheets, labels, and the specific hazards they can reasonably be expected to encounter as a result of their job responsibilities.
This article is not meant to be comprehensive. Think of it more as a way to get your foot in the door. It’s a short synopsis so you have some idea of what you’re getting into when you go to OSHA’s website and delve into all the very specific requirements of the GHS. The most important thing you can do to prepare for the GHS is to educate yourself and your employees.
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OSHA’s Top 10 Violations of 2011
The following were the top 10 most frequently cited OSHA violations in the fiscal year 2011. Over the years, the list tends to categorize the same issues, some change in numerical order, but for the most part, the violations listed are ones that are familiar to us. (Click on the link to see the OSHA standard.)
- 1926.451 – Scaffolding
- 1926.501 – Fall Protection
- 1910.1200 – Hazard Communication
- 1910.134 – Respiratory Protection
- 1910.147 – Lockout/Tagout
- 1910.305 – Electrical, Wiring Methods
- 1910.178 – Powered Industrial Trucks
- 1926.1053 – Ladders
- 1910.303 – Electrical, General Requirements
- 1910.212 – Machine Guarding
This list should be used as a guide to help determine where improvements can be made in your workplace to help keep your employees safe. You can avoid injuries and illnesses by reviewing the standards on this list and making sure you are in compliance with OSHA regulations and following all required safe work practices.
Remember, OSHA publishes these violations so employers can take the necessary steps to find and fix these most commonly cited hazards and/or violations before OSHA pays your facility a visit! OSHA violations can be costly– both in money, and in safety. Let’s be proactive when it comes to employees’ workplace safety and help reduce the number of incidents that occur.
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Safe Temporary Heat on Construction Jobsites
Many of the safety requirements for temporary heat may seem like common sense, but our safety consultants often see obvious safety hazards while safety consultant or the local fire department to determine the requirements that would be specific to your jobsite and location.
Spaces where heaters are used must be well-ventilated. Install CO detectors in the area to detect any buildup of carbon monoxide. Heaters cannot be left running when a jobsite is unattended. If heaters must be run overnight, fire watch personnel must be present. Keep all flammable and combustible materials away from the heater. Do not lay coats or other flammable materials over or near a heater. LP gas cylinders must be stored outside in an upright position and secured so they don’t fall over. Protect the cylinders from mobile equipment moving in the area and post No Smoking signs in the storage area. Do not allow mobile equipment to drive over flexible fuel lines. When the heater(s) are not being used, shut off the LP gas supply at the cylinder valve. A fire extinguisher must be kept nearby in case of an emergency.
While all of these tips will help ensure the safe use of a temporary heating device, it is necessary that all employees working in the area where these devices are used are trained in the hazards and safety requirements. A toolbox talk on these devices is recommended before they are put into use.
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Top 10 Tips for a Successful Training Program
So you’ve come to the realization that your company must provide safety training for its employees. Good for you; that’s half the battle! Wondering where to start? Here are our Top Ten Tips for implementing a successful training program:
- Assess Your Needs: You need to know the safety hazards your employees are exposed to. Some may be obvious, others not so much. Ask your employees what topics they need to be trained on. They’ll likely have great ideas and also be more willing to buy-in to the training. A formal workplace hazard analysis can also provide topics that need to be covered.
- Applicable & Practical: Be sure the training is specific to the workplace and to the jobs that your employees are doing. There’s no sense training workers on topics that they can’t take back and immediately put to use.
- Interactive: People learn better when they’re doing, rather than being talked at. If students are sitting for hours at a time listening to an instructor drone on and on, they’re tuning out. (Think “Bueller, Bueller…”) Training should be hands-on whenever possible. Students should also be able to ask questions throughout and receive thoughtful, quality answers.
- Classroom Learning: Studies show that classroom training is the best way for people to learn. Online training can be useful, and sometimes necessary, but whenever possible opt for classroom training for a better learning experience.
- Experienced Instructors: You’ll want to look for instructors that have a good balance between training experience and real-world experience. A good trainer should engage students and understand their needs.
- Consistency: If you’re outsourcing your training needs, try to build a relationship with the company you choose. This allows students to develop trust in the trainer, and the trainer to better understand your company and its goals. It’s also helpful if the company knows the ins and outs of your safety program.
- Frequency: If your employees are trained once every few years, you can be sure they’re not thinking about safety on a daily basis. Annual refresher trainings are a minimum. Additionally, an inexpensive way to keep safety on the minds of your workers is to implement a weekly toolbox training program.
- Take Safety Beyond the Classroom: Create a safety culture! Recognize employees who put what they’ve learned to use. Institute a simple reward system for employees who are caught doing tasks the safe way rather than the quick or easy way. Post training certificates with students’ names on them in the workplace. Think of simple ways to show your appreciation of their safe work practices.
- Documentation: Always keep documentation of the trainings that have been completed and the employees who were present. This will help when it comes to insurance audits and surprise OSHA visits.
- Assess and Review: This works two ways – employees should be asked to demonstrate their learning, and trainers should be assessed by students as to the quality of the training they received. Make changes to the program whenever necessary.

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Scaffolds Consistently Top OSHA’s Most Cited List
Scaffolding continues to be one of the top 10 most frequently cited standards of worksites by OSHA. Scaffolds are defined as “any temporary elevated work platform and its supporting structure used for supporting workers, materials, or equipment.” Knowing and following the rules and regulations when working on a scaffold can save your life.
The following tips will certainly help before you construct and get on a scaffold. Make sure you are properly trained in the design and operation of scaffolding. Before each work shift and after any occurrence that could affect the structural integrity of your scaffold, make sure a competent person has inspected it for defects. OSHA defines a competent person as “one who is capable of identifying existing and predictable hazards in the surroundings or working conditions, which are unsanitary, hazardous to employees, and who has authorization to take prompt corrective measures to eliminate them.”
Follow all the proper procedures for scaffold preparation. Know and respect the load capacity. Always make sure your scaffold is properly secured. Use guardrails (top, mid and bottom rails). Wear fall protection AT ALL TIMES. There isn’t much room on a scaffold so always keep the platform free of obstructions. Secure tools and equipment so they don’t fall below and injure another person. Scaffolds and platforms must be perfectly level to minimize the risk of workers falling off.
Of utmost importance, use all the appropriate PPE. This includes head protection, non-slip protective footwear and fall protection equipment. “Think Safety” certainly applies when doing any type of scaffolding work.
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Take Safety Home: Fire Prevention Week 2011
Fire Prevention Week 2011 starts October 9th and the theme this year is “Protect Your Family From Fire”. According to the NFPA this year’s theme focuses on how to protect your family from fire by planning ahead and integrating simple things into your everyday life.
Does your family know what to do in an emergency situation, such as a house fire? How about preventing a house fire? Does your family have a Home Fire Safety Plan?
If not, you can visit the NFPA website at http://www.firepreventionweek.org for information on the leading causes of home fires, how to protect your home and family with life-saving technologies, and the importance of home escape planning. The website also provides a downloadable Family Fire Safety Checklist and a Home Fire Escape Plan Grid to help you and your family develop a home fire escape plan. However it’s not enough to just develop your plan; it is important that your family practice your escape plan at least twice a year.
Remember that working smoke alarms, home fire sprinklers, a home fire escape plan and identifying potential hazards are all important parts of a home fire safety plan and will protect your family from a fire.
For fire prevention tips for the workplace and jobsite, please click here.
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Lightning Safety for Outdoor Workers
Outdoor workers deal with many safety hazards, but one of the most unpredictable and deadly is Mother Nature. There are a few precautions that workers and employers can take when they know a storm is approaching:
- Employers should have a plan in place that explains to workers the safety procedures that should be followed when storm events are expected to happen.
- Pay close attention to weather reports. Try downloading an app for your smartphone that will alert you to severe weather headed your way. React immediately.
- If you hear thunder, lightning is roughly 6-8 miles away. Seek shelter immediately.
- Good examples of shelter are substantial buildings, fully enclosed metal vehicles with the windows up, trees or bushes of uniform height. Try to get to low ground; lightning typically strikes tall objects.
- Poor examples of shelter include heavy and road machinery, single tall trees, water, open areas, light or electrical poles, and metal objects.
- If you feel your hair stand on end or hear crackling noises, you are within the electrical field of the lightning. Remove all metal objects, including hats, place your feet together, duck your head, and crouch down low with your hands covering your ears.
- Wait at least 30 minutes from the last lightning or thunder strike before resuming work activities. Stay alert because the storm may not be completely over.
- If a coworker is struck by lightning, they do not carry an electric charge so it’s safe for you to help them immediately.
Here are some other wet weather safe practices: (Some of these pointers are for rain storms only. If lightning is likely, the above advice takes precedence.)
- Reorganize work so that tasks are available that can be completed out of the weather.
- Be aware of your surroundings. Watch foot placement and keep an eye out for falling objects, slipping equipment, etc.
- Make sure all electrical equipment is safe and kept out of water.
- Erect temporary structures out of the rain using tarpaulins.
- Minimize the amount of work to be done at heights. Use fall protection when height work is necessary.
- Wear waterproof clothing in the rain, including shoes or boots that have slip-resistant bottoms. Continue to wear hardhats.
- Take extra precautions when driving around the jobsite in wet weather.
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3 Month Phase-In Period for Residential Construction Fall Protection Rule
OSHA’s new Residential Construction Fall Protection directive, which became effective on June 16, 2011, will not be fully enforced until September 16, 2011. OSHA hopes this three month phase-in period will give residential construction companies the time they need to get in compliance. However, this is not necessarily a three-month free pass.
If a residential construction or roofing company is inspected during this 3-month period and is not in compliance with the old directive (STD 03-00-001), citations will be issued. However, if the company is found to be in compliance with the old directive, no citations will be issued. Instead, OSHA will send the company a hazard alert letter explaining how they can come into compliance with the new directive. If the company is inspected again after receiving the hazard alert letter and has not come into compliance with the new directive, citations will be issued.
For some time, workers involved in residential construction did not have to meet the same strict standards that other industries did regarding fall protection. The Interim Fall Protection Compliance Guidelines for Residential Construction (STD 03-00-001) allowed residential construction companies to use alternative ways of protecting their workers from falls. However, OSHA determined that there was no viable reason for residential construction companies to not provide standard measures of fall protection for their workers. The new Residential Construction Fall Protection directive requires residential construction companies to provide employees working 6 feet or more above a lower level with guardrail, safety net or personal fall arrest systems. (The directive does allow some alternatives in particular cases.)
According to the U.S. Bureau of Labor Statistics, since 2005, 34% of all construction fatalities are a result of falls. Hopefully there will be a drastic reduction in those numbers, and more workers returning home safely at day’s end, with the enforcement of this new rule.
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Combustible Dust Rule Stalls – How to Stay Safe Now
In 2009, OSHA issued an Advanced Notice of Proposed Rulemaking for a Combustible Dust standard based on a recommendation by the U.S. Chemical Safety Board which found 119 workers were killed and 718 injured by combustible dust explosions between 1980 and 2005. Despite the fact that combustible dust hazards are still prevalent (in June, a Kentucky-based wood working company saw two workers injured in a combustible dust explosion that sent flames more than 50 feet into the air.) the ComDust rule is continuing to get bogged down by statutory and legal burdens. The Unified Regulatory Agenda which was just published July 7, 2011, shows that the SBREFA review (the next step in the rulemaking process) has been pushed back 8 months.
Although (and because) it may be some time before we see a final rule, companies that are at risk for combustible dust hazards should take the responsibility to protect their workers now. OSHA has a Safety and Health Topics page on their website (see link below) which has information that may be helpful in preventing a combustible dust explosion at your facility. Some of the most important things you can do are to:
- Educate yourself about combustible dust.
- Complete a hazard assessment to find any and all factors that could contribute to an explosion.
- Implement a hazardous dust identification, testing, housekeeping and control program to minimize dust accumulation throughout the facility.
- Identify and control all ignition sources.
- Have an Emergency Action Plan in place.
- Educate employees of the dangers of combustible dust and the practices you’ve implemented to keep them safe.
For more information on Combustible Dust hazards and how to mitigate them, check out these links:
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Take Safety Home: Button Batteries and Children
Button batteries can be found in several of our household products and many children’s toys and games. Do we realize the dangers our children are being exposed to? These tiny batteries are just the sort of thing a curious child might swallow. They can become lodged in a child’s throat or intestine and can release hydroxide which can cause chemical burns or even death. Most times, parents aren’t even aware that their child has swallowed a battery because symptoms may start out with a mild fever and upset stomach which many physicians relate to common childhood illnesses.
Recently, the U.S. Senate Committee on Commerce, Science, and Transportation has introduced a bill that would make it harder for children to access button cell batteries, significantly reducing the risk of ingestion. Under the proposed Button Cell Battery Safety Act of 2011, the Consumer Product Safety Commission would create two sets of standards for producing button cell batteries. The first standard would secure button cell battery compartments to prevent access by children. The second would mandate that warning labels be placed on battery packaging, in any literature that is included with the product, and where feasible, on the product itself. Let’s be a step ahead when it comes to our kids’ safety!
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Electrical Safety: AEGCP vs. GFCI
Accidents involving electricity are common on construction jobsites. What can you do to prevent electrical injuries? There are two options: using ground-fault circuit interrupters (GFCIs) or an assured equipment-grounding conductor program (AEGCP).
So, what is the difference between the two?
A GFCI will detect an imbalance between the energized conductor and the return neutral conductor. An imbalance occurs, for instance, when the current leaks from a tool through the body of a person who is grounded. At this point, the GFCI would trip and immediately stop the flow. GFCIs are available as portable devices or can be installed in a circuit. This is essentially a hardware requirement.
When a GFCI cannot be used due to design or because it creates a greater hazard by interrupting power for temporary wiring methods or extension cord sets providing power to portable electric tools, then a documented Assured Equipment-Grounding Conductor Program (AEGCP) is required to be maintained and implemented.
An AEGCP is a written company procedure that requires periodic testing of all equipment-grounding conductors of cord sets and of those connected to receptacles to ensure no faults will occur. The company must keep records of the continuity and terminal connection tests. Moreover, a designated competent person must continuously enforce the AEGCP at the site.
Here are some links from OSHA’s website that might be useful in helping you meet all electrical safety requirements:
- Construction e-Tool: Electrical Incidents
- Construction e-Tool: Assured Equipment Grounding Conductor Program
- Construction e-Tool: Ground-Fault Circuit Interrupters (GFCI)
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Preventing Heat Illness for Outdoor Workers
As the high heat of summer quickly descends upon us, it’s important to take the time to review heat-related illnesses and how to prevent them. The NOAA’s National Weather Service describes four types of heat-induced disorders. We’ll describe each disorder and then provide you with some tips for preventing these heat-related illnesses.
Heat Illness Symptoms
- SUNBURN: Most likely we’ve all felt the pain of a sunburn and hopefully by now everyone is aware of the danger of skin cancer. A severe sunburn can also cause swelling, blistering, fever, and headache.
- HEAT CRAMPS: Heat cramps are just what they sound like. As your body temperature rises, your muscles can cramp up. Normally this occurs in the leg and abdomen muscles and is accompanied by heavy sweating.
- HEAT EXHAUSTION/STRESS: Heat exhaustion or stress is characterized by one or more of the following: profuse sweating, dizziness and fainting, pale, cold and clammy skin, fatigue, intense headaches and nausea.
- HEAT STROKE: Heat stroke is a severe condition. Seek immediate medical care if you notice any of the following symptoms in yourself or others: excessive body temperature (over 106°), red, dry skin (sweating has ceased), disorientation and altered behavior.
Prevention Tips:
- Whenever possible, move your work to a shaded area. If not, take frequent breaks in shaded areas.
- Always wear sunscreen that blocks both UVA and UVB rays and has a SPF of at least 15. Reapply every two hours.
- Keep your shirt on while working.
- Stay hydrated!
- Wear lightweight, light-colored, breathable clothing.
- Do not drink alcohol and limit your consumption of caffeinated beverages.
- If possible, avoid working outside during the hottest time of the day, normally between 11AM and 4PM. Or try scheduling heavy duty work for the cooler hours of the day.
Helpful Heat Safety Links:
- OSHA’s Campaign to Prevent Heat Illness in Outdoor Workers – OSHA’s webpage dedicated to providing employers and employees with more information on how to beat the heat.
- National Weather Service Heat Safety Page
The NOAA published this Heat Index Chart to help you understand how humidity affects the heat your body feels:
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Take Safety Home: Hazardous Waste
Disposing of household chemicals safely means that they must be disposed of in a way that will not harm people or the environment. Many everyday household products and materials contain a wide range of chemicals, some of which pose a serious threat to our health and the environment. Cleaning products, home improvement products, car care and maintenance products and any product labeled toxic, flammable or corrosive are all common hazardous products in our homes. We need to educate ourselves to minimize usage of these hazardous products. We should be using nontoxic alternatives whenever possible.
Household chemicals should never be poured down the drain, or into the soil because of the possibility of contaminating our water systems or the ground. Many local communities host collection events for Household Hazardous Waste (HHW). Make sure to bring your products and materials in the original containers with labels intact so they can be correctly identified and disposed of properly. If any of your containers are leaking, wrap them in newspaper and place them in a plastic bag. Make sure all lids and caps are tightly secured. Place your items in a box when transporting them and cushion them with newspaper as a filler. If you have any chemicals that will react with one another, make sure you place them in separate parts of your vehicle. Make it a point to call your community to see when they will be holding their next event and what materials they accept.
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How to Comply with the New OSHA Crane Standard
According to OSHA, when working with cranes, the four main causes of worker death and injury are electrocution, crushed by parts of the equipment, struck-by the equipment/load, and falls. The requirements of the new standard is expected to prevent 22 fatalities and 175 non-fatal injuries each year. Here are just a few of the major requirements that you must comply with if you are operating a crane on your jobsite(s):
Ground conditions should be firm, drained, and graded, and sufficient to support the weight of the crane. The controlling entity should make you aware of any hazards, such as voids or utilities.
The A/D (assembly/disassembly) director must be a competent person and a qualified person; or a competent person assisted by a qualified person. These terms are fully explained in the standard. Generally, manufacturer instructions should be used during assembly/disassembly procedures; however, a qualified person can develop employer procedures so long as they meet all safety requirements. If outriggers and stabilizers are to be used they must be fully extended. The A/D director must complete a thorough inspection of the assembled crane before it is used. Tower cranes must also have a pre-assembly inspection completed and documented. A qualified rigger must be used for rigging operations during assembly/disassembly and other activities when workers must be in the fall zone to handle a load. When using synthetic slings, the manufacturers’ instructions/procedures must always be followed.
One of the more significant changes to the standard is the requirement that all crane operators be certified no later than November 10, 2014. Certification requires a written examination and practical exam to be carried out by an accredited third-party testing organization. Employers must pay for the certification of their crane operators.
A signal person would be required if the point of operation is not in full view of the operator, the view of direction of travel is obstructed, or if there are other safety concerns. The signal person must be qualified by either a third-party organization or the employer and documentation must be available.
Inspections of the crane and related equipment must be completed and documented monthly by a competent person. Keep inspection documents for at least 3 months. In addition, an annual inspection must be completed by a qualified person or third-party crane inspection company. Proper documentation should be kept for at least 12 months.
One of the best things an employer can do is to be sure that everyone involved in the assembly, disassembly, rigging and operation of a crane is properly trained, qualified and/or certified to do the work properly and safely for the type of loads and lifts that are required by the job.
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Jobsite Safety Inspections: A Simple Path to Safety
One of the first steps in keeping your workplace safe and free of hazards is to have Facility and/or Jobsite Safety & Health Inspections completed on a regular basis. The person performing the inspection should be someone who is specially trained in health and safety. These trained specialists have the experience and expertise to recognize existing and potential threats to your employees that may exist throughout your facility. Workplace jobsite inspections are a cost-effective way to help you eliminate situations that put your employees in immediate danger, thereby preventing work-related catastrophes and fatalities.
There are many aspects to a safety and health jobsite inspection. Inspectors look for posting of mandatory jobsite notices, fire safety, safety maintenance hazards, chemical hazards, and machine equipment hazards to mention just a few. Ongoing jobsite safety inspections will develop a useful and practical analysis of safety issues at your facility. A written inspection report can help keep you on track with workplace circumstances that need immediate attention to keep work areas safe and injury free. Completed written inspection reports can also be used to refer back to, to see if previous unsafe conditions were dealt with. Each inspection report should list a recommended corrective action that should take place in a timely manner. Remember, the best defense against loss and injury is a thorough understanding of all the risks and potential hazards within your company.
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PPE Enforcement in General Industry
In February, OSHA released the Enforcement Guidance for Personal Protective Equipment in General Industry, a directive that provides OSHA inspectors with support in assessing the requirements set forth by OSHA’s PPE standards (29 CFR 1910 Subpart I). Although this guidance is aimed at OSHA Compliance Safety and Health Officers, it provides valuable information for general industry employers in meeting the PPE requirements as well.
One of the most significant recent changes to the PPE regulations is the requirement for employers to pay for the PPE their employees need. This means that the employer must provide, at no cost, any PPE that is required by the standard to keep employees safe from the hazards they may encounter while working. There are certain exceptions, including, non-specialty safety-toe protective footwear, non-specialty prescription safety eye wear, metatarsal shoes, everyday or ordinary clothing, any PPE that is lost or intentionally damaged by the employee, employee-owned PPE, or personalized or upgraded PPE. The Enforcement Guidance directive provides detailed explanations of all exceptions to the rule.
One important requirement of the General Industry PPE standard explicitly states that a hazard assessment must be performed and a written certification of the assessment provided (29 CFR 1910.132(d)). The hazard assessment is a means for determining what hazards employees can be expected to come across and the PPE and engineering controls that will be used to protect employees from those hazards. PPE is one of the most basic ways for you to keep your employees safe while they work for you. If you haven’t already done so, complete a hazard assessment at your facility and make sure your employees have the PPE they need to stay safe!
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Winter Safety on Construction Sites
Construction doesn’t take a break in the winter so it’s important at this time of year to think about the additional hazards that are present at jobsites due to winter weather and the corresponding safety precautions that need to be taken. Cold temperatures, wet weather, and frigid winds can take a drastic toll on the human body. Brush up on your knowledge of cold weather maladies such as frost bite, hypothermia and trench foot. OSHA provides a Cold Stress Card that describes how to prevent and treat these serious illnesses.
Pay special attention during the winter months at your construction site to avoid safety hazards. Take time throughout the day, every day, to walk through the jobsite and look for hazards created by snow and ice. Keep an eye on walkways, work platforms, scaffolds, stairs and ladders. Carefully remove icicles, especially if temperatures are beginning to warm. If this isn’t possible, rope off the area under the icicles until they are no longer a hazard. When removing snow, don’t allow piles to get too high and block the view of workers in the area.
Portable heaters are necessary at times, however they can be very dangerous if not used appropriately. Have heaters inspected prior to the heating season to make sure they work properly; have repairs made if necessary. Place the heater on a sturdy, fire-resistant surface and make sure hoses are protected from damage and excessive heat. The area where the heater is being used must be properly ventilated to allow excess fumes to escape. Keep combustible materials 10-15 feet away from heaters. Propane and other flammable gas cylinders must be stored upright and chained.
Most importantly, use common sense when working outdoors during the winter months. Take care of yourself and those around you.
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Mobile Equipment: Refueling, Maintenance & Storage
Recently, there has been an increasing trend in the number of mobile equipment safety violations. Here are some tips on proper refueling, maintenance & storage of mobile equipment:
Refueling
- Shut off and cool the engine prior to fueling.
- Ensure the fueling area is well ventilated.
- Do not smoke while refueling. Keep open flames and sparks away from the area. Discharge any static electricity prior to refueling. Know where fire extinguishers are located.
- Ground the funnel or fuel nozzle against the filler neck.
- Never use gasoline or diesel fuel for cleaning purposes.
Maintenance
- Maintain cleanliness. Keep the cab free of trash and debris. Make sure windows, mirrors and lights are kept clean. All walking surfaces, ladder rungs, stairs, and handholds should be kept free of mud, oil, snow and ice. Remove or secure loose materials and tools.
- Only designated maintenance personnel should perform maintenance on mobile equipment.
- Follow the manufacturers’ instructions for preventative maintenance.
- Always lock out and tag out equipment prior to servicing.
Storage
- Park the equipment in a safe, level location. Do not park in mud.
- Put the vehicle in park and set the brake.
- Lower all hydraulic equipment such as buckets, loaders, etc.
- Let the engine cool by idling for a few minutes.
- Turn the engine off and remove the keys.
- Dismount using the three-point contact rule.
- Chock the wheels.
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Take Safety Home: Drinking & Driving
Despite all of the warnings, public awareness & educational programs, stiffer penalties for violations, and efforts by our law enforcement agencies to crack down on offenders, every day people are arrested for driving while under the influence. Every state has now lowered the legal blood alcohol concentration (BAC) limits. For drivers age 21 and older it is now 0.08 %. All states have also passed zero tolerance laws which prohibit drivers under 21 from having any measurable amount of alcohol in their blood system. Each state has an Implied Consent Law, which means that if you have a driver’s license, you must consent to submitting to a chemical test if properly asked by police.
There are things we can do to avoid letting ourselves or our family & friends get behind the wheel after any alcohol consumption.
- Always pick a designated driver before going out.
- If you are hosting a party where alcohol is being served, have the numbers of taxi services at hand for your guests.
- Take the car keys from someone who has been drinking.
- If you see someone on the road who you believe is drunk, report the car along with its description & location to the police.
- Out drinking and don’t have the number for a cab company? Install the Cab4Me app on your smart phone. It will find the closest cab company to your location and provide you with the phone number.
- Follow manufacturer’s instructions. Do not override electrical, hydraulic, or mechanical safety devices.
- Unless permitted by the manufacturer, never move equipment with workers in an elevated platform.
- Always inspect equipment and ensure lift platform chains or doors are closed before operating.
- Cones or signs should be present if working near traffic.
- All non-electrical workers should be at least 10 feet from overhead power lines.
- OSHA requires a full-body harness or a positioning device on bucket trucks or boom-supported lifts in order to prevent falls. If there is an anchorage inside the bucket, OSHA will accept a positioning device (belt) with a short lanyard.
- Make sure brakes are set. When on an incline, use wheel chocks.
- Outriggers should be used when provided.
- Ensure the load limit of the equipment is not exceeded—take the weight of the operator, tools, and materials into consideration too.
- Assume all power lines, wires, or other conductors are energized.
- Always read the label and follow product instructions carefully.
- Lock up or restrict access to household chemicals.
- Close product containers fully when finished or if you’re interrupted during use.
- Always keep chemicals in their original containers.
- Remove children and pets from the area where dangerous chemicals are being used.
- Always use the safest product possible. Look for the Designed for the Environment label as seen here.
- Post the Poison Control hotline number near all phones or program it into your cell phone: 1-800-222-1222.
- Do not enter permit-required confined spaces without being trained and without having a permit to enter.
- Review, understand and follow employer’s procedures before entering permit-required confined spaces and know how and when to exit.
- Before entry, identify any physical hazards.
- Before and during entry, test and monitor for oxygen content, flammability, toxicity or explosive hazards as necessary.
- Use employer’s fall protection, rescue, air monitoring, ventilation, lighting and communication equipment according to entry procedures.
- Maintain contact at all times with a trained attendant either visually, via phone, or by two-way radio. This monitoring system enables the attendant and entry supervisor to order you to evacuate and to alert appropriately trained rescue personnel to rescue entrants when needed.
- OSHA 10-Hour Outreach Training for Construction
- OSHA 30-Hour Outreach Training for Construction
- OSHA 10-Hour Outreach Training for General Industry
- OSHA 30-Hour Outreach Training for General Industry
- OSHA 510 – Occupational Safety and Health Standards for the Construction Industry
- OSHA 511 – Occupational Safety and Health Standards for General Industry
- Limit the volume of your iPod to 60 decibels.
- Try to limit listening to no more than 60 minutes a day.
- Replace standard earbuds with noise-cancelling headphones or canalphones that block out background noise, so you can hear music better at lower volumes.
- Place candles where they will not be knocked down.
- If possible, use battery-operated candles.
- In homes with small children, avoid decorations that are sharp or breakable.
- Decorations that have small removable parts should be kept out of the reach of children. Don’t use small decorations that resemble candy or food.
- Never use lighted candles on trees or near other evergreens
- Immediately remove or throw away all wrapping paper, bags, ribbons, etc. after opening gifts.
- Make sure artificial trees are labeled “Fire Resistant”.
- If purchasing a live tree, look for freshness. Needles should be green and are hard to pull from branches.
- Keep live and artificial trees away from fireplaces, radiators, vents and portable heaters. Do not set trees up in the way of traffic or in front of doorways.
- Do not allow the tree to dry out. Water it regularly. Cut off a few inches from the bottom of the trunk before setting up. This allows for better water absorption.
- Check all lights (even new sets) to be sure all bulbs work and there are no frayed wires, broken sockets or loose connections.
- All outdoor lights should be approved for outdoor use. Do not use “Indoor Use Only” lights outside.
- Plug all outdoor electric decorations into GFCI circuits to avoid potential shocks.
- Turn off all lights before you go to bed or leave the house.
- Select toys to suit the age, abilities, skills and interest level of the intended child.
- Read all toy instructions carefully before allowing children to play with new toys.
- Avoid giving children younger than 10 toys that have to be plugged in. Instead buy battery-operated toys.
- Children under three can choke on small parts contained in toys. Do not give a child under the age of three a toy with parts smaller than 1 1/4 inches round or 2 1/4 inches long.
- Fully cook meats and poultry to avoid food poisoning. Thoroughly wash raw vegetables and fruit.
- Wash your hands frequently when preparing food.
- Always keep raw foods and cooked foods separate and use separate utensils when preparing them.
- Always thaw meat in the refrigerator, not on the countertop.
- Do not leave foods that require refrigeration out for more than 2 hours.
- Before lighting any fire, remove all greens, boughs, papers and other decorations from the area.
- Check to make sure the flue is open.
- Do not burn wrapping papers in the fireplace!
- A list of all major fire hazards, proper handling and storage procedures for hazardous materials, potential ignition sources and their control, and the type of fire protection equipment necessary to control each major hazard
- Procedures to control accumulations of flammable and combustible waste materials
- Procedures for regular maintenance of safeguards installed on heat-producing equipment to prevent the accidental ignition of combustible materials
- The name or job title of employees responsible for maintaining equipment to prevent or control sources of ignition or fires
- The name or job title of employees responsible for the control of fuel source hazards
- Be sure fire extinguishers are available throughout the facility or jobsite and are wall-mounted.
- Fire extinguishers need to be inspected each month. The tags should be dated and initialed after each inspection. Assign someone within the company this task.
- In addition, fire extinguishers must be hydrostatically tested every five or twelve years (depending on the type of fire extinguisher) or whenever there is evidence of corrosion of mechanical injury.
- Immediately get rid of or repair spliced or damaged electrical cords.
- Only use UL-approved, self-closing cans for storing gasoline.
- Flammable and combustible materials should be stored in appropriate containers and properly marked.
- Compressed gas cylinders must be chained up when not in use. Oxygen and acetylene cylinders should be stored separately.
- No smoking signs should be prominently displayed in areas where combustible materials are used or stored.
- Test smoke and fire alarms at least once a month. Replace batteries at least once a year. Regularly check alarms for dust, dirt and other particulates that could interfere with the proper functioning of the system.
- A scaffold must be capable of supporting its own weight plus four times the maximum intended load.
- Erect scaffolds on solid footing. Unstable objects, such as barrels, boxes, loose bricks etc., must not be used to support scaffolds or planks.
- When erecting, moving, dismantling or altering scaffolds, a competent person must be present to supervise. Competent persons must also inspect scaffolds before use and regularly throughout use.
- All scaffolds that are 10 feet or more above a lower level should be equipped with guardrails, midrails and toeboards. If guardrails are not installed, use a personal fall arrest system.
- Immediately repair or replace any damaged scaffold accessories.
- Platforms must be tightly planked on all working levels.
- Use ladders, steps, or ramps to access levels that are 2 feet or more above the lower level.
- Scaffolds must be kept at least 10 feet from electric power lines at all times.
- Always wear a hardhat!
- Do not work on scaffolds unless you have been properly trained to do so!
- Have all employees received job-appropriate training? Are training documents kept onsite?
- Have all subcontractor employees received appropriate training? Has the subcontractor supplied training documents?
- Is proper PPE supplied and worn at all times?
- Are appropriate signs and workplace notices posted throughout the site?
- Are fire extinguishers wall-mounted throughout the site? Are all inspection tags current?
- Are first-aid kits wall-mounted? Are they an appropriate size for the number of employees onsite? Are they well-stocked?
- Is a Hazard Communication Program provided and explained to all employees?
- Is the worksite kept clean of all slip, trip and fall hazards? Are trash cans/dumpsters provided onsite and emptied regularly?
- Are all hand and power tools in good working condition and used properly?
- Are all holes or openings covered securely and marked?
- Is scaffolding constructed appropriately with guardrails at proper heights? Are all parts in good condition and used properly?
- Never dive into shallow water or water where the bottom is not visible.
- Never use alcohol or drugs while swimming or boating.
- Never leave children unattended near a water source, even for a few seconds.
- Gates around pools should be self-closing and self-latching. Latches should be out of the reach of small children.
- For above-ground pools, steps and ladders should be secured when in use and removed when the pool is not in use.
- Never swim alone, no matter how good of a swimmer you are.
- Do not attempt to jump in and save a drowning victim unless properly trained and certified in lifesaving practices such as CPR. Call 911 for help.
- Get out of the water and move away from any water source if a thunderstorm is imminent.
- Wear foot protection to prevent cuts and abrasions.
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The Importance of Machine Guarding
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Machine guarding is basically guarding or protecting machine parts that are the most dangerous. Any machine part, function, or process which may cause injury must be safeguarded. Machine guarding reduces the likelihood that an accident will occur because of things like mechanical failure, human error, electrical failure, or poor design. Using a machine safely, to avoid a potential injury, entails many factors. There are many different types of machine safeguards. The type of guard that has to be used depends on the machine and the hazards it can pose. Before using any equipment the operator should be trained in how to use the safeguards, where the safeguards are located, the kind of protection they provide and which hazards they protect against. Operators need to know how and under what circumstances guards can be removed and they should be able to identify when guards are damaged, missing or inadequate. Machine guarding helps to prevent amputations, lacerations, crushing injuries and abrasions. Without such guarding, the resulting injury can be severe or even fatal. There’s never a good reason to remove a guard on a machine that you’re using, even if you think you can work faster without it. Guards are there to protect you! |
This belt drive is missing its protective guard and could cause an injury. |
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OSHA Outreach Training Program
The Occupational Safety & Health Administration (OSHA) requires companies to provide adequate training for all their employees in the recognition and avoidance of any unsafe conditions applicable to their scope of work. OSHA’s Outreach Training Program is a great way to be sure your employees are receiving the training they need. When you enroll your employees in a 10 or 30 hour course in either construction or general industry they are taught to recognize, control and prevent safety and health hazards. They will receive training on a number of different required topics, but there are also topics that you can choose from to customize the course to fit your company’s needs. A growing number of states are even requiring their workers to have their 10 and/or 30 hour training completion cards as a prerequisite to work.
You can be sure that your employees are receiving quality safety and health training that they will bring back to work with them. OSHA has stringent requirements for their Outreach trainers who must be certified and meet specific experience and educational requirements. Online training, which also meets OSHA’s standards, is available if classroom training isn’t possible.
Training is one of the best things you can do to take care of your company and its employees. Take the time to think about how well your employees are trained in safety matters. Could they benefit from a 10 or 30 hour course in construction or general industry safety and health?
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Take Safety Home: Preparing for the Heating Season
Fall is upon us and it’s time to start thinking about what we can do to prepare for the cold weather. One important preparation is being sure that your home and heater are ready.
Make sure that your home is properly weatherized. Caulking, sealing and weather-stripping around all of your windows, outside doors, or where plumbing, duct work and electrical wiring penetrate exterior walls, floors or ceilings can add up to big savings on your heating bill.
If you have a fireplace, your chimney and fireplace should be inspected by a chimney service before you use it for the season, and should be cleaned if necessary. Cleaning is important because chimney flues that become lined with creosote are a fire hazard.
It’s also important to have your heating unit inspected and serviced each year before you use it. Make sure to change or clean your furnace’s filters regularly. Having your heater serviced will keep it performing optimally.
During combustion your furnace creates Carbon Monoxide, a colorless, odorless gas that can be deadly. Normally the CO produced by the combustion is exhausted up the chimney and out of your home. However, a furnace that is not working properly can leave CO in your home. You can protect yourself from CO poisoning by installing a CO detector in your furnace room.
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Proposed Amendments to SPCC Compliance Dates
The Spill Prevention, Control, and Countermeasure (SPCC) rule requires companies to implement procedures for proper storage of fuels and oils to prevent spills, control measures to prevent a spill from expanding beyond secondary containment, and countermeasures to contain, clean up and mitigate the effects of a spill if it were to occur.
In July of this year, EPA once again proposed to extend the compliance dates for SPCC plans for certain facilities. The new proposed date of November 10, 2011, is exactly one year from the current compliance date of November 10, 2010. EPA feels that this extension will permit facilities that pose a lower threat the additional time they need to fully understand all the previous amendments and/or revisions to the SPCC rules, thereby allowing adequate time to make all the appropriate changes to be in compliance.
The new proposed extension rule states that your SPCC plan should be reviewed and the appropriate amendments implemented into the SPCC plan no later than Nov. 10, 2011. This proposed ruling states that after Nov. 10, 2011 a facility (excluding production facilities) have an SPCC plan in place before beginning their operations, (production facilities are required to have an SPCC in place within six months after beginning operations). These proposed amendments will not remove any regulatory requirements for owners or operators of production facilities in operation before Aug. 16, 2002. You are still required to abide by the regulations in effect then. However, the Nov. 10, 2010 compliance date ruling still holds firm for a drilling, production or workover facility, including a mobile or portable facility, located offshore or with an offshore component or an onshore facility that is required to have and submit facility response plans.
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Ergonomics in the Workplace
A musculoskeletal disorder is pain felt in a person’s muscles, bones, joints, ligaments, nerves, and tendons. This is usually caused by the type of work one is doing or their work environment. According to the Bureau of Labor Statistics, in 1999 there were over 600,000 workers that suffered serious workplace injuries which were caused by overexertion and repetitive motion. In their January 2001 report on Musculoskeletal Disorders and the Workplace, the National Academy of Sciences (NAS) and Institute of Medicine (IOM) indicated that there were 1 million serious work-related ergonomic injuries per year.
The purpose of the science of ergonomics is to be able to accommodate the worker with the best-fit working conditions related to the expectations of their particular job. You must first clarify what working conditions could pose a musculoskeletal disorder risk for your industry and provide recommendations and solutions to alleviate those risks.
For example, there are many working conditions that can pose a risk of musculoskeletal disorder in the construction industry. Construction is believed to be one of the top hazardous industries in the United States. Back injuries are one of the leading complaints, as well as pain in the shoulders, neck, arms, and hands. About 32% of claims are from material handling incidents. Construction injuries and/or complaints can be a result of lifting, working in confined areas, carrying heavy objects, and repetitive motions. In order to alleviate such hazards, an employer must always re-evaluate how the work is done and the working conditions and come up with ways to improve the system. If an employer is successful in making this work, they can assure a higher productivity level, happier employees, and fewer injuries and illnesses in the workplace.
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OSHA’s Severe Violator Enforcement Directive
In an effort to address urgent safety and health problems facing Americans in the workplace, OSHA implemented a new Severe Violator Enforcement Program (SVEP) and is increasing civil penalty amounts. The SVEP directive became effective June 18th. The directive focuses its sights on employers who consistently fail to meet their obligations under the OSH Act.
The Severe Violator Enforcement Program will help OSHA concentrate its efforts on noncompliant employers who commit willful, repeated or failure-to-abate violations in the following categories: a fatality or catastrophe situation; in industry operations or processes that expose workers to severe occupational hazards and those identified as “High-Emphasis Hazards” (including fall hazards, amputations, combustible dust, crystalline silica, excavation/trenching, and lead); exposing employees to hazards related to the potential release of a highly hazardous chemical; and all egregious enforcement actions.
The directive also establishes procedures and enforcement actions including increased inspections. Mandatory follow-up inspections are required of a workplace found in violation, as are inspections of other worksites of the same company that may have similar deficiencies.
Last year, OSHA determined that current penalty amounts were too low to have an adequate preventive effect. Several changes to the penalty calculation system are being made. The changes will increase the overall dollar amount of all penalties. OSHA feels that the inspections and penalties must be large enough to discourage employers from cutting corners or underfunding safety programs to save a few dollars. OSHA hopes the SVEP will provide a greater deterrent and further encourage employers to furnish safe and healthy workplaces for their employees.
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The Importance of Jobsite Housekeeping
Good housekeeping should be a primary concern of all. Poor housekeeping can lead to increased accidents for your employees. Not only is this an obvious safety problem but it also reflects poorly on your company, implying that the project is poorly managed and your company lacks professionalism. Learning the habit of good housekeeping takes practice.
Do your part by storing needed materials neatly in a central location, away from walkways. Keep work areas and adjacent walkways and stairs clean and orderly. Be sure that all combustible materials are disposed of properly to prevent the possibility of fires. Always clean up spills immediately using appropriate procedures and PPE. Make it a habit to remove or bend over all nails protruding from scrap lumber to protect against puncture wounds. Sharp-edged and pointed tools should be stored in such a way as to prevent injuries.
Keep air compressor hoses and extension cords out of walkways to prevent tripping. Coil hoses and cables when not in use. Place trash cans strategically throughout the jobsite so that employees will throw away refuse appropriately. Never stack or pile materials in front of exits, fire extinguishers or sprinklers. Do not clean dusty areas with an air compressor; instead, use a vacuum, sweeping compound or wet mop. Clean up should be done throughout the day, not just at the end of a shift!
If you remember these tips you will promote safety in the workplace, improve performance, and protect your employees and the public. Good housekeeping just makes good sense!
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Take Safety Home: Ticks
In the United States, ticks are the leading carrier of disease to humans. Tick-related illnesses are most common from April through September. Many diseases can be transmitted by ticks, including Lyme Disease. The initial symptoms of Lyme Disease include flu-like symptoms and a red, circular rash that grows.
To avoid tick bites, always wear long pants tucked into socks or boots when working, hiking or playing in wooded areas. It may also help to wear light-colored clothing so that ticks can be seen easily and brushed off before they bite. Use insect repellant that specifically repels ticks. As soon as you come inside, check yourself thoroughly for ticks.
To properly remove a tick, use tweezers. Always make sure your hands are protected with gloves in order to prevent further infection. Flip the tick over on its back; grasp it firmly as close to the skin as possible, and pull gently until it is removed. Some commonly used methods of removing a tick (hot match, gasoline, etc.) may cause additional injury to oneself. If any parts of the tick remain in your skin, it increases the chance for infection. Flush the tick down the toilet immediately; do not crush it.
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Hexavalent Chromium Rule Now Effective
On June 15, 2010 OSHA’s final rule on hexavalent chromium [Cr(VI)] became effective. This rule requires employers to notify employees of any exposure to hexavalent chromium, as opposed to the previous provision in the standard which only required notification of exposure to levels over the permissible exposure limit (PEL).
Hexavalent chromium is a carcinogen. Exposure to high concentrations or for prolonged periods of time can cause lung cancer, and damage to the nose, throat and respiratory tract. It can also cause irritation to the skin and eyes if direct contact is made in high concentrations. Occupational exposure to Cr(VI) can occur when working with products that contain chromates, such as certain pigments, dyes and powders. Chrome electroplating and welding or hotwork with stainless steel are also common ways of being exposed to the chemical.
Engineering and work practice controls, such as proper ventilation, should be used to minimize exposure to hexavalent chromium. If such measures are not enough to lower levels, PPE and a respiratory protection program should be instituted to protect employees. These measures only need to be in place if Cr(VI) levels are above the PEL (5 µg/m³), however the final rule states that all employees must be notified if they are exposed to hexavalent chromium in any amount.
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Aerial Lift Safety
If proper aerial lift safety is not followed at all times it could result in a fatality – a fall, electrocution, collapse or tip over. All employees who operate aerial lifts (also boom-supported aerial platforms, including cherry pickers or bucket trucks) should be properly trained to be sure they are always safe while using this equipment. Other safe practices include:
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Take Safety Home: Household Chemicals
The American Association of Poison Control Centers estimates that approximately 90% of poisonings occur in the home. Household chemicals and pesticides are responsible for these incidents. Some common household chemicals are cleaning products, medicines, health or beauty care products, pet shampoos, automotive chemicals (anti-freeze, windshield washer fluid, etc.), insect repellents, swimming pool chemicals, rodent poisons, and weed killers. To prevent a poisoning in your home:
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Confined Spaces in Construction Proposed Rule under Analysis
Fatalities and injuries constantly occur among construction workers who, during the course of their jobs, are required to enter confined spaces. The OSHA Confined Spaces in Construction proposed rule was issued Nov. 28, 2007, but has not yet been finalized. Comments on the rule are currently under analysis.
Under the proposed rule, employers would first determine whether there is a confined space at a job site. If there is a confined space, the employer would determine if there are existing or potential hazards in the space. If there are such hazards, the employer then would classify the space according to the physical and atmospheric hazards found in it. The four classifications are: Isolated-Hazard Confined Space, Controlled-Atmosphere Confined Space, Permit-Required Confined Space, and Continuous System-Permit-Required Confined Space. The proposed requirements for each type of confined space are tailored to control the different types of hazards.
In the meantime, remember these guidelines when working around a confined space:
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EPA Lead-Based Paint Law is Effective April 22, 2010
The Lead-Based Paint Renovation, Repair and Painting Program Rule that goes into effect on April 22nd will require contractors that disturb lead-based paint in homes, child care facilities and schools, built before 1978 to be certified by EPA and follow specific work practices to prevent lead contamination. These practices apply to maintenance or renovation activities where six square feet or more of painted surfaces for interior projects or more than twenty square feet of painted surfaces for exterior projects are disturbed.
Under the EPA’s new rule, firms must become certified and pay a fee before completing any work on the types of facilities listed above. Firms will be required to educate the owners and occupants of the facility prior to beginning any renovation work. The EPA has provided a pamphlet, “Renovate Right”, which can be handed out to help satisfy this requirement. Individuals conducting lead-based paint activities must comply with lead-safe work practices, examples of which include containment of the work area and proper cleanup and disposal of lead-based materials. All employees of accredited firms will need to be trained in and must follow proper lead-safe work practices.
Penalties for non-compliance are stiff; $37,500 is the maximum penalty the EPA could assess per day, per violation. Companies that fail to comply will be prohibited from advertising the services for which they are uncertified.
The rule is not aimed at slamming those on jobsites but rather protecting those in the homes and buildings being renovated. Young children, in particular, are at high risk, and the levels that can affect them are alarming.
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Upcoming SPCC Presentation
CCI, in affiliation with the Contractors Association Of Eastern Pennsylvania (CAEP), will be presenting a Safety/Environmental Meeting that will cover the most current updated SPCC Regulations. The meeting will be held on February 11, 2010 at 10:00 am. The meeting is being held at the CAEP Office located at 1500 Walnut Street, Suite 1105 in Philadelphia, PA. This meeting is open to all Safety or Environmental Managers, Directors, Coordinators, Officers, Engineers and any other personnel who have these functions as a job responsibility. If you or someone from your organization is interested in attending, please call Brandon Sterling at 215-546-4555 for more detailed information.
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CCI Now Offers Online Training!
CCI understands that it can be difficult to get your employees the training they need and to keep them working on the many jobs you have. Online training is the perfect way to make sure your employees get the training that is required! Employees can work from home on their own computers or during office hours, whichever is more convenient. They can also work at their own pace, which provides flexibility in case an important job comes up that has to be taken care of immediately. And CCI offers some of the best prices out there for OSHA-authorized online training!
CCI provides 6 online courses that are OSHA-approved and meet OSHA training requirements:
(click on links below for more information)
Be sure all your employees get their official OSHA wallet card and certificate of completion.
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What to Expect from OSHA in 2010

The year 2009 saw great changes in the leadership of the Department of Labor. Immediately after being elected, President Obama nominated Hilda Solis to be the Secretary of Labor. Her nomination was confirmed on February 24th and was followed shortly thereafter by the appointment of Jordan Barab as the Deputy Assistant Secretary of Labor for OSHA. These two were known for their slogan, “There’s a new sheriff in town”, forewarning businesses of the new, more aggressive stance OSHA would be taking to ensure worker safety. On December 3rd, the US Senate confirmed David Michaels as the new Assistant Secretary of Labor for OSHA. With these three key players in place, we can be sure to expect major changes in how worker safety is dealt with across the country. Already we’ve seen a number of goals outlined by the new administration, but evidence of stricter enforcement can be seen too. The number of OSHA inspectors has begun to climb and we’ve seen a record-breaking citation handed out to BP Products in Texas: $87,430,000 for not complying with a 2005 settlement with OSHA.
In 2010 we can expect to see greater enforcement and more regulatory action. On the enforcement side, you’ll notice more OSHA inspectors, more inspections, more citations and higher penalties. The regulatory agenda recently outlined by Solis and Barab is very aggressive. Just a few of the topics that will be addressed this new year are: airborne infectious diseases, OSHA 300 injury and illness log changes, cranes and derricks, combustible dust, and a new hazard communication standard, all of which are in various stages of rulemaking. Any one of these changes could affect millions of workers. It’s safe to say that businesses need to look at their safety programs carefully and make sure they are measuring up to the high standards being set by the Obama administration.
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EPA to Regulate Water Pollution on Construction Sites
On December 1, 2009, the U.S. Environmental Protection Agency (EPA) published effluent limitations guidelines and new source performance standards to control the discharge of pollutants from construction sites. Construction site owners must monitor, report and comply with this final rule set by EPA to help reduce water pollution from their construction sites.
Construction activities, like clearing, excavating and grading, can significantly disturb soil and sediment. If that soil is not managed correctly it can easily be washed off of the construction site during storms and pollute nearby water bodies. The rule requires certain construction site owners and operators to sample stormwater discharges and comply with a numeric standard for the pollutant turbidity in these discharges. The limitation is 280 NTU (nephelometric turbidity units). This is the first time that EPA has imposed national monitoring requirements and enforceable numeric limitations on construction site stormwater discharges.
The regulation is effective on February 1, 2010. After this date, all permits issued by EPA or states must incorporate the final rule requirements. Beginning on August 1, 2011 all sites that disturb 20 or more acres of land at one time are required to comply with the turbidity limitation. On February 2, 2014 the limitation applies to all construction sites disturbing 10 or more acres of land at one time.
The benefits from lessening discharges of sediment and turbidity include enhanced water clarity, safe-guarding our drinking water supplies, improvements in water environments, and it can also reduce the need for dredging navigational channels and reservoirs.
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Take Safety Home: iPods and Hearing Safety

Personal digital music is one of today’s hottest trends. Everywhere people sport the telltale white “earbuds” of the biggest musical trend of all: the iPod. However, the iPod generation may be losing their hearing, without even knowing it.
Two factors contribute to iPod-related, noise-induced hearing loss: volume and duration. Users turn the volume up to dangerous levels, often to cover background noise. Noise-induced hearing loss happens when loud sounds stress and damage delicate hair cells in the inner ear. If exposed to loud noises for a long time hair cells can die, producing permanent hearing loss. Remember, the effects of noise exposure are cumulative over your life.
The National Institute of Health notes that prolonged exposure to sounds over 85 decibels can cause hearing loss. The typical iPod can generate sound volume at a level of 100-130 decibels. Here are a few steps to protect yourself from hearing loss:
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New Hazard Communication Standard Proposed
OSHA is proposing to modify the Hazard Communication Standard to be in alignment with the provisions of the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). The sole purpose of the GHS is to increase the consistency of information given to all chemical users by adopting a standardized approach to hazard classification, labels, and safety data. It is intended to increase safety in the workplace and make international trade in chemicals easier.
If this modification takes place, Safety Data Sheets (SDS) will have a specified format with 16 sections. Chemical manufacturers and importers will have to provide a label that includes a signal word, pictogram, and hazard statement for each hazard class and category. This will allow workers, employers, and all chemical users to understand even the most basic chemical information without any language restrictions.
Although no date has been specified for this final ruling, it is expected to move rather quickly. Once it becomes effective, there will be a 3-year transition period. This will allow chemical manufacturers and importers time to switch to the new format and allow time for training employees so they become familiar with the new system. Until this ruling becomes final, employers are expected to comply with either OSHA’s existing Hazard Communication Standard or the proposed ruling.
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Holiday Safety Tips
Here are some safety tips for you to think about this holiday season as you enjoy time with your family and friends:
Decorations:
Trees:
Lights:
Toy Safety:
Food Safety:
Fireplaces:
Have a safe and happy holiday season!
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This information is provided as a service to you by Compliance Consultants, Inc.
This information was compiled from the American Academy of Pediatrics website.
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PA Safety Conference, October 19-20, 2009
The annual Pennsylvania Governor’s Occupational Safety and Health Conference is a two-day event being held at the Hershey Lodge and Convention Center in Hershey, PA to address workplace safety and health issues. This year’s keynote speakers are Bruce Wilkinson, Lt. Col. Phillip S. Martin, and Jordan Barab, acting assistant secretary for OSHA. Online registration and more information about the conference can be found here.
Look for Compliance Consultants, Inc. in the exhibit area. We’ll be there to provide you with information on how we can help your company make safety a priority. There will be free giveaways and contests too!
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Fire Prevention Week!
Stay Fire Smart! Don’t Get Burned!
Fire Prevention Week was first established in 1922 to commemorate the Great Chicago Fire of 1871. Since then, the National Fire Protection Association has educated the public on the very serious dangers of fire. This year’s theme is “Stay Fire Smart! Don’t Get Burned!” with the emphasis on burn awareness and prevention as well as fire prevention. This is a great time of year to look at the fire prevention practices and plans in your company, as well as those in your own home.
If your company has more than 10 employees, you need to have a written fire prevention plan that is kept in the workplace and is made available to employees. According to OSHA, a fire prevention plan should include the following:
Our safety consultants see a number of fire hazards on a regular basis during their onsite safety inspections. Some of their recommendations include:
For more information on Fire Prevention Week and other fire related safety information visit the NFPA website.
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Do You Have a Workplace Safety Committee?
A workplace safety committee is a key element to achieving continuous improvement in safety. The purpose of a safety committee is to regularly bring workers and management together in a cooperative effort to promote safety and health on a daily basis. A safety committee assists the employer by making recommendations for change regarding occupational safety and health issues that directly affect the company.
The benefits of having a safety committee include a reduction in the number of workplace injuries and illnesses, a reduction in the hidden costs associated with injuries and illnesses, and an increase in employee safety awareness. Employees are also more likely to work safely because they are more invested in the implementation of company safety policies.
The specific functions of a safety committee are to detect hazards, analyze and solve problems and assist in safety management. Monthly safety meetings are an excellent way to keep everyone up to speed on what regulations they need to be aware of and what is changing or going unnoticed in the workplace. A workplace safety committee that has set goals, functions and duties and meets routinely ensures that your facility is a safer environment for all your employees. Creating a safety committee is a great first step towards providing a work environment that is safe.
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Take Safety Home: Cell Phones and Driving
Although we all know that everyone leads busy lives these days, the use of a cell phone while driving is very dangerous. Sending text messages while driving is even more unsafe. Statistics prove that a driver using a cell phone is four times more likely to get into an accident than someone who chooses not to.
In the City of Philadelphia and the State of New Jersey, the use of cell phones while driving is not allowed unless you are using a hands-free device to talk. Texting is prohibited! A proposal for a similar ban across Pennsylvania and many other states is being considered. The PA State Department of Transportation reported that 1,241 crashes in 2006 involved drivers that were using hand-held phones compared to 60 crashes in which drivers used hands-free devices or headphones. That number is significantly high.
Did you know that the number one source of driver inattention is the use of a wireless device? Think of safety first and don’t risk your life or the life of others by talking or texting on a cell phone. If you must make an important call or send an urgent message, pull over to a safe spot or park before doing so. Otherwise, keep your cell phones turned off while driving!
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What Businesses Need to Know About Swine Flu
The words “swine flu”, “H1N1”, and “vaccine” seem to be on everyone’s lips these days. Hopefully at this point we all know that the best defenses against this newest strain of flu are covering our mouths when coughing or sneezing and washing our hands regularly; but what should businesses be doing to prepare for this flu season? Is your business prepared to handle flu outbreaks, mass absenteeism, and disrupted supply chains?
Business owners need to plan now for possible disruptions in their normal flow of operations due to illness. The most basic recommendations from the CDC describe how to prevent large numbers of absences: Develop policies that allow sick workers to stay home or to work from home. Determine how to handle workers who need to stay home to take care of young children who are sick or were sent home due to school closures. Encourage all employees to receive both the seasonal flu and H1N1 vaccines. Provide hand sanitizer, antibacterial soap, tissues, and other materials in the workplace that promote a hygienic atmosphere.
A pandemic flu plan should not only outline preventive measures, but it should also plan proactively in case of mass absenteeism. Plans should identify employees and business functions that are essential to maintaining business operations. Develop contingency plans in case there are disruptions. Cross-training employees may be helpful to ensure fundamental knowledge is transferred and the business continues to run smoothly. Temporary workers can also be hired.
Any plans and policies that are put into place should be effectively communicated to all employees. Planning and staying informed will help businesses stay afloat during a severe pandemic.
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Scaffolds:
How to Lower Risks and Increase Safe Practices
The Bureau of Labor Statistics’ Census of Fatal Occupational Injuries reported that 68 people were killed in 2008 by falling from scaffolds. Also in 2008, scaffolding was the most commonly cited violation in the country by OSHA inspectors. The most common causes of injuries and fatalities are the planking or support giving way, or the employee slipping or being struck by a falling object. These hazards can and will occur when scaffolds are not erected or used properly.
These hazards can be controlled by using common sense and complying with the following OSHA standards:
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OSHA Inspections of Stimulus-Funded Projects

Construction, infrastructure, and green energy projects that are being funded through the American Recovery and Reinvestment Act, as well as manufacturing industries that support those projects can expect to hear OSHA knocking on their doors soon. Part of the funds that the Department of Labor’s Occupational Safety and Health Administration received have been earmarked for enforcement. This means that OSHA will be hiring more compliance officers in order to keep up with the increased number of inspections that are expected to be completed. Many of those inspections will be focused on stimulus-funded projects.
Rather than inspecting individual companies, OSHA compliance officers will be inspecting entire job sites including any and all subcontractors that may be working at the time of the inspection. This is a welcome change as it will certainly improve the overall safety culture at the jobsite rather than focusing on the safety practices of an individual employer.
While many contractors are already concerned about the safety of their employees, now is the time for them to look at the overall safety of the jobsite and to hold subcontractors responsible for contributing to that safety. Some things contractors may want to take another look at:
This is just a short list of what contractors must think of on a daily basis to ensure the safety of their employees, in addition to all of their other responsibilities. It may seem like a lot is to be expected but when you think of the alternative – employees rushed to hospitals, not coming home to their families at the end of the day, fatal accidents – there really is no other option. OSHA feels the same way. At a recent ceremony to remember fallen workers, Secretary of Labor, Hilda Solis, stated, “As we dedicate the building of this monument to fallen workers, we rededicate ourselves to defending and enforcing the right that every man and woman deserves a safe and healthful working environment.”
Those who are working on stimulus-funded projects need to make safety a priority, not only because OSHA may be knocking on your door, but also because it’s the right thing to do for your workers.
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Final Rule: SPCC Compliance Dates
On June 19, 2009, EPA published a final rule in the Federal Register regarding the compliance dates for the December 2008 Spill Prevention Control and Countermeasure Rule. The date by which facilities must amend or prepare and implement their SPCC plans is now November 10, 2010. All previous compliance dates should be disregarded. The EPA feels that the extended compliance date will allow facility owners and operators the time to fully understand all of the amendments that have been made to the SPCC rule since 2002.
For more information on the SPCC ammendments that will take effect next year, please review CCI’s SPCC Presentation, however all compliance dates in the presentation should be disregarded. All compliance dates are now November 10, 2010 for all facilities affected by this rule.
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Beating the Heat: Occupational Workers Exposed to Environmental Heat
The summer months are an important time to recall the dangers that extreme heat causes for those men and women who work outdoors. According to the Bureau of Labor Statistics, between 1992 and 2007, a total of 461 worker deaths occurred due to exposure to environmental heat. The illnesses that extreme heat exposure can inflict upon those in the agricultural, construction and roofing industries, to name a few, can and should be avoided.
Heat stress and heat stroke are two heat-related illnesses that occupational workers need to be aware of. Heat stress is characterized by one or more of the following: profuse sweating, dizziness and fainting, fatigue, intense headaches and nausea. Heat stroke is characterized by excessive body temperature (over 103°), red, dry skin (sweating has ceased), disorientation and altered behavior. If these symptoms are recognized in a fellow worker, call 911 immediately and remove the person to a cool or air-conditioned area.
Skin cancer is another illness that needs to be addressed. Whether it is summer or not, if the sun is shining you are in danger of being exposed to harmful UVA and UVB rays that cause skin cancer. If you work outside wear a sunscreen that has an SPF of at least 15.
Some common sense practices can help occupational workers avoid the dangers of sun and heat exposure. These include staying hydrated throughout the day (avoid caffeinated and alcoholic beverages), taking frequent breaks in the shade or air conditioning if possible, wearing light-colored clothing that allows your skin to breathe, blocking out direct sunlight, and wearing sunscreen and sunglasses that provide UV protection.
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Take Safety Home: Swimming Safely
Tragic water accidents happen quickly. The most common reason for aquatic mishaps is a lack of safety knowledge. Follow these tips to prevent injury:
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