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Proposed Changes to the Silica Standard

Silica Standard Proposed Changes

Millions of workers are exposed to respirable crystalline silica every day, many of whom are exposed to levels greater than OSHA’s proposed permissible exposure limit (PEL). Overexposure to silica levels causes thousands of illnesses and hundreds of deaths every year. The current PELs were adopted 40 years ago and are not sufficiently protecting workers. OSHA has proposed a new rule that is estimated to save 700 lives and prevent over 1000 new silicosis cases every year. OSHA’s proposal includes two different standards- one for general industry and maritime employment, and one for construction.

The requirements for the proposed general industry & maritime, and construction silica standards are as follows:

(“OSHA’s Proposed Crystalline Silica Rule: Construction.” OSHA’s Proposed Crystalline Silica Rule: Construction. US DOL OSHA, Aug. 2013. Web. 21 Oct. 2013.
“OSHA’s Proposed Crystalline Silica Rule: General Industry and Maritime.” OSHA’s Proposed Crystalline Silica Rule: General Industry and Maritime. US DOL OSHA, Aug. 2013. Web. 21 Oct. 2013.)

While this is not a final rule yet (comments on the rule are being accepted until 12/11/13), there are some things that you can do now to protect yourself and your workers who may be exposed to crystalline silica:


This information is provided as a service to you by Compliance Consultants, Inc.

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Take Safety Home: Are CFLs Safe for Your Home?

CFLs Safe

Most of us have at least a few CFL, or compact fluorescent bulbs, in our homes. CFLs are considered to be an environmental and efficient choice for our homes. They use about 75% less energy than a standard bulb, and they last about ten times as long. But, are CFLs safe to be used in your home?

For the most part, CFL use is safe and is not harmful to use in your home on a daily basis. And CFL’s are great for the environment when they are handled properly and disposed of properly. However, the bulbs contain a small amount of mercury, which is a toxic metal which can build up in our bodies and persists in the environment.

The mercury in the bulbs only escapes when they break. Do not drop or handle the bulb roughly. Be careful when removing the bulb from its packaging, installing it, or replacing it. Always screw and unscrew the light bulb by its base (not the glass), and never forcefully twist the CFL into a light socket.

When a fluorescent bulb breaks in your home, some of this mercury is released as mercury vapor. To minimize exposure to mercury vapor, EPA and NFPA recommend the following cleanup and disposal steps:

Before Clean-up

Open a window and turn off forced-air heating or air conditioning. Everyone should leave the room, including pets.

Clean-up

Scoop up the glass fragments and powder rather than sweeping or vacuuming, which can spread the mercury around. Use tape to pick up remaining glass fragments or powder. Wipe the area clean with a damp paper towel or wet wipes.

Disposal of Clean-up Materials

Dispose of the broken bulb through your local household hazardous waste program or recycling program. Where such programs are not available, place all cleanup materials outside the house in a trash container area for the next normal trash pickup, then wash your hands.

Continue to air out the room for several hours where the bulb was broken and leave the heating or air conditioning system off.

When a CFL burns out and is still intact, it should be disposed of properly through your local household hazardous waste program or recycling program. Visit epa.gov/cfl/cflrecycling or earth911.orgto find local recycling options.


This information is provided as a service to you by Compliance Consultants, Inc.

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OSHA’s Top 10 Violations of 2013

OSHA Top 10 Violations 2013

OSHA announced the 2013 most frequently cited standards at this year’s National Safety Council Congress & Expo. For the second year in a row, fall protection tops the list.

  1. 1926.501 – Fall Protection, 8,241 violations
  2. 1910.1200 – Hazard Communication, 6,156 violations
  3. 1926.451 – Scaffolding, 5,423 violations
  4. 1910.134 – Respiratory Protection, 3,879 violations
  5. 1910.305 – Electrical, Wiring Methods, 3,452 violations
  6. 1910.178 – Powered Industrial Trucks, 3,340 violations
  7. 1926.1053 – Ladders, 3,311 violations
  8. 1910.147 – Lockout/Tagout, 3,254 violations
  9. 1910.303 – Electrical, General Requirements, 2,745 violations
  10. 1910.212 – Machine Guarding, 2,701 violations

The OSHA top 10 violations 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.


This information is provided as a service to you by Compliance Consultants, Inc.

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Could Your Construction Site Be an Attractive Nuisance?

Attractive Nuisance Construction Site

Attractive nuisances can be more than just a nuisance if you find yourself faced with a lawsuit due to one. Cornell University Law School defines the attractive nuisance doctrine as:

“A doctrine in tort law under which a landowner may be liable for injuries to children who trespass on land if the injury results from a hazardous object or condition on the land that is likely to attract children who are unable to appreciate the risk posed by the object or condition.” (“Attractive Nuisance Doctrine.” LII. Cornell University Law School, 19 Aug. 2010. Web. 08 Oct. 2013.)

In other words, if a curious child were to trespass onto a jobsite and injure themselves, you could be held liable. In Pennsylvania and in other states, there are some conditions to this. In order to be held liable the following conditions must be met: the landowner must be able to foresee that children could trespass; the landowner knows, or should know, of the potential dangers; the child is young enough to not fully understand the danger; the cost to eliminate the hazard wouldn’t be an excessive burden; and the landowner doesn’t take any reasonable precautions to eliminate the hazard.

Common attractive nuisances include swimming pools, railroad tracks, farm equipment, trampolines, cell phone towers, and of course, construction sites. The big yellow machinery, the giant piles of stone and dirt, the holes and pits, all these make a construction site a large playground for unwitting children.

So how can you protect yourself from an attractive nuisance lawsuit? (Perhaps the more important question is how can you protect inquisitive children from construction site hazards?) The best plan is to analyze your jobsites, and determine where children are likely to get in trouble. Here are some common ways to prevent any accidents:

This list is certainly not exhaustive and shouldn’t replace proper legal advice, but by taking these simple precautions, you could avoid a catastrophe in which you could be held legally responsible.


This information is provided as a service to you by Compliance Consultants, Inc.

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Safety on Demolition Sites

Demolition Safety

Earlier this year, a tragedy occurred in Philadelphia when an unsupported wall at a demolition site fell onto an occupied Salvation Army store. Sadly, six were killed and 13 injured. Numerous investigations were immediately started to find out exactly what happened that day and to find ways to ensure it doesn’t happen again. City policy and law makers scrambled to beef up the requirements for obtaining a demolition permit. And earlier in October five bills were introduced that incorporate most of the recommendations of the Special Investigating Committee on Demolition Practices.

In summary, the bills (which are subject to change) are as follows:

  1. Demolition permits would be separate from building/construction permits. Increased training for L&I code officials would also be required.
  2. A licensed site safety monitor would be required at every construction or demolition site.
  3. Demolition contractors would have to have a valid demolition license.
  4. Fire departments could issue stop work orders if a site is deemed unsafe.
  5. Contractors would be required to provide a site safety plan to L&I before beginning. L&I officials would have to review the plan and ensure a safety zone surrounds demolition areas. In addition, mechanical equipment used for demolition would be prohibited when a structure is physically connected to another structure that is not to be demolished. (Packel, Dan. “Demolition Legislation Introduced In Philly City Council.” Law360. Law360, 03 Oct. 2013. Web. 21 Oct. 2013.)

The Committee expects action on these bills by the end of the year in order to budget for them properly next year. Demolition contractors should begin beefing up their safety programs and practices now if they haven’t already begun to do so. A book could be written on all the possible ways to make demolition sites safer, but we’ll attempt to highlight some of the more important issues here that all contractors should be complying with in order to provide a safe worksite for employees and the public:


This information is provided as a service to you by Compliance Consultants, Inc.

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Take Safety Home: Grilling Safety

Grilling Safety

Summer is just about to kick off, so let’s take a moment to talk about grilling safety. The two biggest concerns when it comes to grilling and safety are burns and fires. Before firing up the BBQ this weekend, make sure you take into account these important safety tips:

General Grilling Safety

Charcoal Grills

Propane Grills

Have a fun and safe Memorial Day weekend!


This information is provided as a service to you by Compliance Consultants, Inc.

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Working with Wet Concrete

Wet Concrete

Concrete can be hazardous in all its forms: powder, liquid, and solid; but for now, let’s focus on concrete when it’s wet. Why is it important to worry about safety when it comes to wet concrete? Because concrete is one of the most widely used construction materials there is, which means there are an untold number of workers who are exposed to these hazards on a daily basis. The biggest hazards include skin irritation, severe chemical burns, and serious eye irritation. Concrete can be safe when used appropriately and with the safety precautions that we’ll discuss here.

Wet cement (an ingredient in concrete) is caustic, abrasive and drying, so protect your skin. Wear appropriate PPE such as tall rubber boots, pants, waterproof gloves and long-sleeved shirts. While this PPE is great at protecting your skin, it needs to be used with common sense. Many times concrete can get trapped against the skin by falling into boots or gloves or when pants/shirts get soaked by concrete. This continuous contact with wet cement can cause severe chemical burns. If concrete comes into contact with your skin, it’s important to immediately wash off with clean water and replace any wet clothing or PPE. Don’t wait! Wet concrete left against the skin can cause third-degree burns and take many months to heal.

Other Safety Tips

Here are some other safety tips to keep in mind when working with wet concrete:

Wet Concrete First Aid

It’s important to understand that you may not experience any acute symptoms right away if wet concrete touches your skin. But if you don’t wash the area as soon as possible with cold, clean water, you could end up with a serious burn. If a burning sensation continues or worsens even after you’ve flushed the area with water, seek medical attention. If wet concrete splashes into your eyes, flush them continuously with clean water for at least 15 minutes and then go to the hospital.


This information is provided as a service to you by Compliance Consultants, Inc.

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Take Safety Home: Household Electronics Disposal

Household Electronics Recycling

If you’re like most people, you probably have a box full of old household electronics and have no idea what to do with them. Should you donate or recycle? Do you know what you need to do before you donate or recycle your personal electronics?

Donating used (but still operating) electronics for reuse extends the lives of valuable products and keeps them out of the waste stream for a longer period of time. By donating your used household electronics, you allow schools, nonprofit organizations, and lower-income families to obtain equipment that they otherwise could not afford.

However, before donating your computer or other electronics, make sure the equipment is reusable. A donation organization may have limited or in many cases no resources to diagnose and repair hardware. A functional, working system—especially with monitor, wiring, and software licenses—is a lot more useful and requires less upgrading than a nonworking, incomplete computer. Also, be sure to delete all personal information.

If donating your electronics is not an option, then recycle them. Manufacturers and retailers offer several options to recycle electronics. Electronics recyclers provide comprehensive recycling operations. Some of the commodities that can be extracted from electronic equipment — in particular, steel, aluminum, gold, silver, titanium, copper, nickel, plastic, and glass — are used as valuable raw material in the manufacture of new products. Remember, donating or recycling your used household electronics is a win-win situation. You dispose of your unwanted items and in doing so, you’re protecting the environment and providing help to those in need!

On a similar and important note, PA residents, as of January 24, 2013, are no longer allowed to throw away electronic devices with other municipal waste. They must take them to an electronics recycling center, leave them for curbside pickup if the community offers an electronics collection program, or use an approved mail-back or buy-back program.

Helpful Links for Household Electronics Disposal:


This information is provided as a service to you by Compliance Consultants, Inc.

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Residential Construction Fall Protection Update

Residential Construction Fall Protection

Time is up for residential construction companies when it comes to fall protection. As of March 15, 2013, residential construction companies are now fully responsible for and will be held accountable for complying with the requirements of the residential construction fall protection rule set forth in 29 CFR 1926.501(b)(13).

Back in June of 2011, OSHA issued a directive that rescinded the old Interim Fall Protection Compliance Guidelines for Residential Construction (STD 03-00-001) and would force residential construction companies to comply with 29 CFR 1926.501(b)(13). OSHA decided to implement a phase-in period to allow additional time for residential construction companies to come into compliance with the new requirements. The deadline for that phase-in period was March 15th and OSHA will now fully enforce any fall protection infractions.

The rule requires residential construction companies to provide employees working 6 feet or more above a lower level with a guardrail, safety net or personal fall arrest system. The directive does allow some alternatives in particular cases as outlined under 1926.501(b). Other methods, such as slide guard systems or safety monitors can still be used if you can demonstrate that it is impractical to comply with the provisions of the standard, or if it creates a greater hazard. However, those systems have to be part of a written, site-specific fall protection plan that meets the requirements of 1926.502(k) (fall protection plans).

The new directive (STD 03-11-002) includes a definition for the term “residential construction”: if the end use of the building is a home or dwelling and is constructed using traditional wood frame construction materials and methods, it is considered “residential construction”. However, the limited use of steel I-beams to help support wood framing does not disqualify a structure from being considered residential construction.

Unbelievably, residential falls accounted for nearly 29 percent of all construction fall fatalities from 2005 to 2009. This just isn’t acceptable, especially when we know that the means to protect them from falls is readily available.

Helpful Links for Residential Construction Fall Protection:


This information is provided as a service to you by Compliance Consultants, Inc.

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Employer Distracted Driving Policies

distracted driving policies

Imagine a scenario in which a certain work-related behavior puts your employees at a 4 times greater risk of injury. Would you ignore that behavior? When employers allow or encourage cell phone use by their employees in vehicles, that is essentially what they are doing. Consider this:

All these facts are just a technical way to say that having and enforcing company-wide distracted driving policies makes sense!

Where do you begin? The first step is to create the policy itself. Make it a part of your overall health and safety program. In order to reduce risk of injury and minimize liability, the best safety practice is to enforce a total ban. This includes the use of handheld and hands-free devices (brain research shows that just holding a conversation can decrease your driving effectiveness). It should apply to all employees, all company vehicles, all company-issued cell phones, and all company communication in vehicles, regardless of ownership. By instituting a total ban, there will be no confusion as to what’s allowed and what isn’t. You’ll also want to determine how you will enforce the policy and what the repercussions are for employees who break the rules.

The next step is to educate your employees. There will likely be some resistance to the new policy. Listen to what they have to say and respond appropriately. Explain your reasoning for instituting this change and provide information and resources to help them understand the importance of your distracted driving policy. Ensure that all employees receive a copy of the new policy and that they sign and return a copy to you.

And finally, you have to implement the policy. Some things you can do to help employees adhere to the policy are:

Many people will tell you that there are plenty of distractions for drivers (changing the radio station, putting on make-up, eating, etc.); so why should we make such a big deal over cell phones in cars? The answer is that because of the sheer prevalence of cell phones, the risk is that much greater: there are now more cell phone policies in the US than there are people living in the US. People also spend a greater amount of time using cell phones in their cars. The NSC states, “The combination of high risk and high exposure makes cell phone use while driving a top distraction.” There are very few good excuses left when it comes to instituting a company-wide cell-phone policy, so get started on yours today.

Helpful Links for Distracted Driving Policies:


This information is provided as a service to you by Compliance Consultants, Inc.

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The Basics of Community RTK – SARA Title III – Tier II Reporting

hazardous chemicals

The Emergency Planning and Community Right to Know Act (EPCRA), which is also called SARA Title III, was enacted in October of 1986. It allows states and local emergency planning committees to remain informed in the case of an emergency with regard to hazardous substances. If there were ever any kind of spill or other emergency situation at facilities that retain hazardous substances, local responders would be prepared to handle the situation. This information is made public so that citizens can remain informed in matters that may affect them, hence the term Community Right to Know.

Anyone who is covered by the OSHA Hazard Communication Standard and stores hazardous chemicals or Extremely Hazardous Substances in certain quantities must submit a report. Even if you don’t currently have hazardous substances on site, a report must be filed if they were on site within the past year in amounts greater than the allowable threshold. A hazardous chemical (i.e. motor oil, antifreeze, diesel, gasoline, etc.) is any product that presents any kind of physical or health hazard to the user. A list of Extremely Hazardous Substances (i.e. ammonia, sulfuric acid, chlorine, etc.) can be found on EPA’s website.

Tier II reports must be filed by March 1st for the previous calendar year. Reports need to be filed annually. Tier II reports are required by Federal law, and must be submitted to your Local Emergency Planning Committee (LEPC), State Emergency Reporting Commission (SERC), and the local fire department. Check your state requirements to find out which report to file and how to file (some want you to file online, others want paper forms submitted).

It makes sense to comply with SARA Title III Regulations. If there were ever any kind of emergency situation at your facility involving hazardous chemicals, local emergency responders would know how to respond because of the information you provided them with. And fines can be extremely hefty for not complying with the reporting requirements.

One final note: in July of 2012, EPA published a final rule which will become effective on January 1, 2014. This rule revised the chemical reporting section of the Tier I and Tier II reporting forms. For this year, you can use the old forms, but next year (reporting year 2013, due by March 1, 2014) you will need to use the revised forms.

This information is provided as a service to you by Compliance Consultants, Inc.

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Injury & Illness Reporting & Recordkeeping

trench cave in

OSHA requires that certain companies report workplace-related injuries and illnesses that occur throughout the year. This might seem a little overwhelming at first. “Do I have to report?” “How do I report?” “What kinds of injuries have to be reported?” “What am I required to do with the report?” Let’s try to clear up some of the confusion.

All companies covered by the OSH Act are required to orally report to OSHA any fatalities or multiple-person (3 or more) hospitalizations due to a work-related incident within 8 hours by telephone or in person. You can contact your local area office or call OSHA’s toll free central phone number: (800) 321-6742. There are only two exemptions from OSHA’s Recordkeeping Regulation (29 CFR 1904). If you have fewer than 10 employees all year long or are listed as a partially exempt industry (certain low hazard industries such as retail, service, financial, real estate, etc.) you don’t have to keep injury and illness records. Everyone else is required to.

If you’re required to keep records you’ll want to familiarize yourself with the following OSHA forms:

These forms can be found here.

The types of incidents you have to report are any injuries or illnesses that can be considered directly work-related. OSHA defines work-related as “an event or exposure in the work environment [which] caused or contributed to the condition. In addition, if an event or exposure in the work environment significantly aggravated a pre-existing injury or illness, this is also considered work-related.” Reportable injuries and illnesses include those which result in death, days away from work, restricted work or transfer to another job, loss of consciousness or medical treatment beyond first aid. Even if an injury or illness does not meet those requirements but is diagnosed by a health care professional as significant and work-related, you need to report it.

You are required to post the Form 300A Summary of Work-Related Injuries and Illnesses prominently in your workplace from February 1st through April 30th for the previous calendar year. The forms do not get submitted to OSHA unless they specifically ask you for them. You may also receive a request from the Bureau of Labor Statistics (BLS) for your injury and illness information with which you must comply. In addition, if an OSHA inspector is completing a health and safety inspection of your workplace, they may ask for your records and you must provide them. Keep copies of all your records for at least 5 years.

It should be noted that OSHA has proposed changes to the Injury and Illness Recordkeeping Requirements. These proposed changes have not taken effect yet; they are still reviewing comments on the new rule. Some of the proposed changes are: using the NAICS rather than SIC, reporting all in-patient hospitalizations (rather than multiple) within 8 hours, and reporting all work-related amputations within 24 hours.

Finally, it’s important to keep up with these reporting requirements and analyze the information to institute changes that are needed in your workplace to improve the overall health and safety of the company and its most valuable asset, your employees.

This information is provided as a service to you by Compliance Consultants, Inc.

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Take Safety Home: Shoveling Snow

woman shoveling snow

As the temperatures start dropping and the cold air sets in, it’s a sure sign that winter is here and there is a good chance that we will be dealing with snow soon. To some of us snow removal is just another household task, but……… it really involves a lot of bending and heavy lifting. It’s important to think about how to safely shovel snow to avoid injuring yourself. If you are over the age of 40, or not used to exercise, you need to be careful. Research indicates that many times heart attacks are linked to individuals who shoveled snow after heavy snowfalls.

Here are some tips to help us all safely shovel our snow this winter season. Wear light, layered, water-repellent clothing, this will provide both ventilation and insulation. Wear a hat, gloves and warm socks. Avoid falls by wearing boots that have slip resistant soles. Choose a smaller sized shovel – remember – the bigger the shovel, the more snow you have to lift. Lift with your legs, not your shoulders or back. Don’t try to fling snow long distances. Don’t reach too far with heavy snow on your shovel and avoid twisting your body when dumping snow. Instead, move your whole body. Pace yourself, take frequent breaks and drink plenty of water. If you experience any shortness of breath, heavy sweating or any pain, this is your body’s way of telling you something is wrong and you need to STOP! If this task is overwhelming to you, consider asking a neighborhood kid to shovel, buy or rent a snow blower, or have a snow removal company that you are comfortable with ready to go; it will definitely be money well spent. Let’s keep safe this winter season.

This information is provided as a service to you by Compliance Consultants, Inc.

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Carbon Monoxide Dangers

forklift carbon monoxide

Carbon Monoxide (CO) is a dangerous and sometimes fatal gas that many workers can be exposed to. This dangerous gas displaces oxygen in your blood stream, depriving your brain, heart and other major organs of the oxygen they need. Because it is colorless and odorless, it is virtually undetectable without the use of an alarm.

Some of the most common producers of CO are internal combustion engines, portable generators, concrete cutting saws, space heaters, vehicles, forklifts, industrial equipment, and some appliances. The symptoms of CO poisoning are tightness across the chest, headache, fatigue, drowsiness, nausea, dizziness, and rapid breathing. If prolonged exposure occurs, symptoms will worsen and can lead to vomiting, muscle weakness and loss of consciousness. If you suspect you’ve been exposed to carbon monoxide, immediately move to an area with fresh air. If symptoms are severe, call 911 and administer 100% oxygen to the victim. Perform CPR if necessary. Do not attempt a rescue in an area where CO levels are dangerously high unless you are trained to do so and use a self-contained breathing apparatus (SCBA).

To prevent CO from building up in your workplace, follow these safety tips:

This information is provided as a service to you by Compliance Consultants, Inc.

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Now’s the Time for Safety Training!

Training

Why should you provide training for your employees?

Training is an important component to any safety program. A proper training program allows your employees to work safely knowing the risks and hazards that are present at the jobsite and how they should deal with them. In addition, regular employee training makes financial sense too. Fewer workplace accidents decreases lost time, and reduces workers compensation claims, not to mention a decrease in your chances of getting fined by OSHA for unsafe work practices.

OSHA requires that all construction and general industry employees be trained to do their jobs in a competent and safe manner. According to OSHA’s Safety and Health Regulations for Construction, “The employer shall instruct each employee in the recognition and avoidance of unsafe conditions and the regulations applicable to his work environment to control or eliminate any hazards or other exposure to illness or injury.” In other words: employers are responsible for training employees in safe work practices that are applicable to their workplace.

The most obvious reason for providing training for your employees is simply to keep them safe. By training your employees, you increase the chances that they’ll return home to their families unharmed at the end of each workday. Employees will know that you care about their well-being and in turn, you’ll see an increase in worker productivity.

What kind of training should you provide?

There are a number of different kinds of trainings out there that might be applicable to your workplace. The first thing you’ll need to do is determine what hazards your employees deal with on any given day. The processes that they go through and equipment or materials they use on a regular basis will drive the training program you implement. You may also want to talk with your employees and find out the areas they think training would be beneficial to them.

The idea is to provide your employees with safe practices that apply specifically to what they do. Here is a list of common training topics that you may want to incorporate into your safety training program. A number of these topics appeared on OSHA’s Top Ten list of Most Frequently Cited Standards for 2012.

Why is now a good time to train your employees?

The winter months are considered “down time” for many construction companies and other related industries. This provides an excellent opportunity to gain your employees undivided attention. The holidays are soon passed and the busy spring and summer seasons are just around the corner. The New Year is also a great time to impress upon your employees your resolution to promote a culture of safety in the workplace. Let them know that you take their safety seriously and plan to commit to it throughout the entire year, beginning now with proper training.

Why is the economy a poor excuse to skimp on training?

“I’m sorry that your husband is out of commission for months, Mrs. Smith, but I couldn’t afford to properly train him on how to use that forklift.” Would you want to have that conversation? Unfortunately, that is the attitude that many employers take when it comes to safety. The economy is bad right now, true. However it’s still not a good excuse. The OSHA fines, the injuries (maybe fatalities), the downtime, the workers’ comp costs, the increased insurance premiums, the stain on your good reputation, and loss of employee morale and productivity are not worth the risk of saving some money right now. An ignorant employee is a dangerous employee. You can’t afford ignorance in your workplace. A safety training program will pay off in more ways than you can imagine. Skimping is just not worth the risk.

This information is provided as a service to you by Compliance Consultants, Inc.

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OSHA’s FY 2012 Top Ten Safety Violations

OSHA has issued their top 10 violations for the 2012 fiscal year. Once again, fall protection tops the list. Hazard Communication and scaffolding round out the top three. The other violations have also made the list in years past. This is a great time to look at your company’s safety programs and policies. If you feel you’re lacking in any of these areas, please call CCI; we can help!

Top 10 Most Cited Standards:

  1. Fall protection
  2. Hazard Communication
  3. Scaffolding
  4. Respiratory Protection
  5. Control of Hazardous Energy (lockout/tagout)
  6. Powered Industrial Trucks
  7. Ladders
  8. Electrical, wiring methods
  9. Machines
  10. Electrical systems design

Top 10 Standards with the Highest Penalties:

  1. Fall protection
  2. Scaffolding
  3. Control of Hazardous Energy (lockout/tagout)
  4. Machines
  5. Ladders
  6. Powered Industrial Trucks
  7. Excavations
  8. Hazard Communication
  9. Electrical, wiring methods
  10. Electrical systems design

This information was taken from OSHA’s website HERE.

Helpful Links:

This information is provided as a service to you by Compliance Consultants, Inc.

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Training for GHS Implementation

On March 26th of 2012, OSHA finalized the new Hazard Communication standard which adopts the Globally Harmonized System of Classification and Labeling of Chemicals, or the GHS for short. One of the first steps in adopting the changes of the new rule is to properly train all of your employees. Every employee who works with or around hazardous chemicals in the workplace is required to be trained, even if they’ve had Hazard Communication training in the past. That’s right – every single employee must be trained again!

Two of the biggest changes to the HazCom standard that will affect employees are new labeling requirements and a new safety data sheet format. Therefore, the training you provide your employees with should focus on these. In addition to these two major elements, training should include the fundamentals of the Hazard Communication program, the requirements under the new standard, and a review of the hazards they may come into contact with at their place of work. You should also pay close attention to any new Safety Data Sheets that come in with your chemical shipments. Under the new classification system, there may be newly identified physical or health hazards that employees will need to be trained on.

Training on the new label elements and the new safety data sheet format must be completed by December 1, 2013. However, it wouldn’t hurt to complete the training sooner rather than later. Many chemical manufacturers are already using the new safety data sheet format and labels. Employees need to understand how to properly read and understand the labels and safety data sheets before they can work with those chemicals. Hazard Communication routinely shows up on OSHA’s most cited list. Make sure you avoid being fined by providing training on GHS implementation as soon as possible!

This information is provided as a service to you by Compliance Consultants, Inc.

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Ladder Inspections

Ladders are more dangerous than you might think. In 2010, 20% of all fatal falls occurred from ladders (Bureau of Labor Statistics). Ladders should always be inspected prior to any work taking place. Check OSHA Standards for the type of ladder you are using and use only UL-approved ladders.

We have listed a few things to look for when inspecting your ladder that if implemented, will help to keep you safe:

Any ladder that has any type of defect or slipping hazard should immediately be marked “Do Not Use” and removed from the workplace until proper repairs are made.

This information is provided as a service to you by Compliance Consultants, Inc.

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Take Safety Home: Trick-or-Treat Safety

Halloween night is fast approaching but before you send your children out to go Trick-or-Treating, please remember a few safety tips that will help to keep your family safe:

Wishing everyone a happy, safe, and fun Halloween!

This information is provided as a service to you by Compliance Consultants, Inc.

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Excavation and Trench Safety

Excavation and trench work is some of the most dangerous work in the construction industry. The hazards are many: falls, falling objects, hazardous atmospheres, and trench collapse to name a few. Here are some basic protective measures to keep you and others safe when working in and around trenches and excavations.

Always plan for safety ahead of time. Decide what protective measures you will put in place. Trenches greater than 5 feet in depth will need a protective system in place such as sloping, benching, shoring or a trench box. This will depend on the type of soil you are digging in; a competent person must determine the soil type. Spoil piles and other materials should always be kept at least 2 feet from the edge of the excavation and a means of access or egress must be placed every 25 feet laterally. Before digging, call 811 and have all underground utilities identified and marked.

When working in a trench or excavation, always wear appropriate PPE, especially hard hats. A competent person should monitor the atmosphere to ensure there are no hazards present. Keep heavy equipment away from the trench to ensure the walls are not weakened by the heavy weight. Be aware of trench failure warning signs such as cracking, sagging, or bulging of the trench walls or bubbling on the floor of the trench. If you see any of these signs immediately leave the trench and alert other workers. Be especially aware of these types of signs after wet weather and in the spring and winter months when water levels are at their highest.

This is not a comprehensive guide to working in trenches and excavations. Before working in any kind of trench or excavation, you should receive complete safety training for the hazards you may encounter in the work you are doing.

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Online Training: What You Need to Know

Online Training

Online training courses and the number of people who utilize them have grown in number significantly in the past 5-10 years. Safety training is mandatory for all employees, but the quality of the training is something that must be addressed. Sending employees to the computer to quickly and easily complete a training course just to satisfy requirements is not good enough. The employer has to be responsible for choosing quality training that will ensure the safety of the employees in the workplace. Here are a few tips for choosing a quality online training program:

FYI: Online OSHA-Authorized Outreach Training – Back in January of this year, OSHA announced that only a handful of providers would be able to deliver OSHA-Authorized Outreach Training in an online format. The reason for doing this was because many online trainers were providing subpar training and still issuing official OSHA wallet cards. Many workers were getting their cards but unwittingly were still not properly trained in the hazards of their workplace. OSHA realized it had to step in and provide more regulation for this kind of training. After a competitive application process, OSHA announced only 10 training providers that are now authorized to offer official OSHA Outreach training and the official OSHA 10 or 30 Hour cards.

Anyone interested in taking these courses needs to be aware that there are still courses being offered online that are not OSHA-approved and you will NOT receive an official OSHA wallet card. Many of these providers will tell you that you will receive a 10-hour card or 30-hour card or a “state-recognized OSHA card”, however these are not the official OSHA cards. If you need an official OSHA card to get onto a jobsite or satisfy specific training requirements for your company, make sure you are only buying your online training from one of the providers approved by OSHA. Many of the selected providers are not able to offer all of the online training courses yet. They are in the process of revising the training programs and they should be available later this year. Many of the sites we visited offered the 10 and/or 30-hour Construction courses but not the General Industry courses.

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Construction Start-Up Safety Checklist

Construction Start-Up Safety

The amount of safety-related items needed at a construction site before work begins can be overwhelming. We’ve put together a list of some of the most common documentation, programs, paperwork and materials that are necessary in order to comply with federal, state, and local requirements. These things should be kept on the jobsite, unless otherwise noted.

Every company and jobsite is unique! So when using this list, please add any additional safety items needed, to help keep your site compliant.

If you’d like to download a PDF version of this checklist to use at your jobsite, click here.

Programs/Documentation/Notices

Blank Forms/Paperwork

Employee Materials/Equipment

Jobsite Materials/Equipment





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Take Safety Home: Fireworks Safety

Fireworks Safety

The Fourth of July & Fireworks go hand in hand, but before your family celebrates, make sure everyone knows about fireworks safety. Lighting fireworks at home is not legal in many areas, so check with your local police department first! The safest way to enjoy fireworks is to attend a public display conducted in your area, by a trained professional.

Did you know that even sparklers can leave a third degree burn? ALWAYS use sparklers outside. Never go near any leftover fireworks; there is a chance that they may still be active and hot. If injured by fireworks, immediately go to the hospital. If an eye injury occurs, touching the eye or rubbing it may cause more damage. Don’t flush the eye out with water or attempt to put any ointment on it. Instead, cut out the bottom of a paper cup, place it around the eye, and immediately seek medical attention — your eyesight may depend on it. If it’s a burn, remove clothing from the burned area and run cool, not cold, water over the burn (do not use ice). Call your doctor immediately.

Lastly, don’t forget that animals become frightened and scared on the Fourth of July because of the lights and noise from the fireworks. It is best to keep your pets indoors, away from all the activities. Let’s enjoy this holiday and keep our families and animals safe!

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Emergency Action Plans

Emergency Action Plans

Emergency Action Plans are an important aspect of safety at your workplace and they’re required to be written and available if you have more than 10 employees (otherwise, an oral plan communicated to employees will suffice). The Emergency Action Plan (EAP) could mean the difference between chaos and order during an actual emergency. Remember that an EAP is only as good as your employees’ knowledge and practice of it, so be sure to train employees and practice the plan regularly!

According to OSHA’s standard, 29 CFR 1910.38, an emergency action plan must include the following:

In addition, an employee alarm system, a way for employees to be made aware of an emergency, must also be in place. Some additional items can be found in the EAP to supplement the required elements. These include: an evacuation plot plan (including evacuation routes, assembly areas, fire extinguisher and first aid kit locations, MSDS manual locations, etc.), an emergency phone list, directions to the nearest hospital(s), a clear chain of command and the responsibilities of each member in the chain, emergency evacuation or shelter-in-place drill procedures, and a list of all employees who must be accounted for in the event of an evacuation.

The EAP should be reviewed with all new hires and whenever an employee is assigned a new or different responsibility under the plan. Whenever significant changes are required to be made to the plan, the changes should be reviewed with all employees. EAP content should be reviewed at least annually and changes made if necessary. All employees should have access to the Emergency Action Plan.





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Dealing with an OSHA Inspection: Before, During, and After

If OSHA knocked on your door today, how would you feel? Would you be terrified or confident? The simple truth is, no one wants to deal with an OSHA inspection. But if you are prepared and knowledgeable, it could mean the difference between terror and confidence. What follows is a simple explanation of what you can expect from an OSHA inspection (before, during, and after) and some tips for how to be prepared.

Before

How do you know if OSHA will inspect your workplace? Most likely, you will not receive any advance notice that an inspection is going to occur. OSHA prioritizes their inspections in the following way:

  1. Imminent danger
  2. Fatality/Catastrophe
  3. Complaints/Referrals
  4. Programmed Inspections

If you’ve had a recent accident, have had previous citations, or if you know you are one of OSHA’s targeted industries (high-hazard industries or National Emphasis Program), you should assume that you’ll be hearing from OSHA sooner, rather than later. However, we’ve known OSHA inspectors to stop by construction jobsites just because they happen to be driving by. Again, knowledge and preparation are your best defense.

When an OSHA inspector arrives, they are required to show you their credentials. During the opening conference, they’ll also tell you why the inspection is being completed, the focus or scope of the inspection and any procedures for the inspection. Be sure management is present before the inspection begins.

During

During the inspection, the compliance officer will walk around the areas of the facility that fall under the scope of their investigation. They should only visit the locations that were discussed during the opening conference. Don’t offer to take the inspector on a complete tour of the facility unless you are absolutely sure they won’t find any additional violations.

A company representative should accompany the inspector during the walkthrough. Be sure to take notes and pictures just as the inspector will. Answer any questions posed by the inspector, but do not offer any additional information. If simple violations are pointed out by the inspector, correct them immediately. You may still be cited for these violations, but a quick correction shows good faith on your part. OSHA is required to protect any information that is considered a trade secret. If you have any materials/processes that are trade secrets, let the inspector know.

Be sure to have any documentation ready that the compliance officer will need. Most likely they will want to see the past few years’ worth of OSHA 300 logs (you should have at least 5 years’ worth on file) and your Hazard Communication program. In addition, they will ask to see any other programs or documentation related to the purpose of their visit. They will also want to see the required OSHA poster on the employee or safety bulletin board.

Your overall attitude towards the inspection and inspector will make a difference in the outcome of the inspection. Be cooperative and realize that the inspector is just doing his/her job. Show the inspector that you are genuinely committed to safety in your workplace.

After

After the walkthrough, the inspector will conduct the closing conference. He or she will explain their findings and give you an idea of what citations you can expect. Your options and path forward will be explained to you. Citations and proposed penalties are issued within 6 months of the inspection. These citations fall under the following categories (includes approximate penalty amounts):

Failure to Abate penalties of up to $7,000/day can be assessed if you fail to fix any violations by the abatement date. Penalty amounts are determined based on the gravity of the violation, the size of the business, whether the company has a history of violations, and the company’s good faith to safety.

After you’ve received the letter explaining the citations and proposed penalties, you can ask the area officer for an informal conference to contest violations, attempt to reduce penalty amounts, and/or extend abatement dates. You’ll be expected to make a presentation and describe why you are seeking these changes. Employee or union representatives are allowed to be at the informal conference. Most likely you will be able to reach a settlement here, but if not and if you still want to contest the citations, you are required to file Notice of Contest within 15 days. Your case is then sent on to a formal review board, the Occupational Safety and Health Review Commission.

Being Prepared

There are a number of things which you can do to “lessen the pain” of an OSHA inspection. Make sure you have a plan in place and train all employees in what to do when OSHA comes knocking. Know who will accompany the compliance officer throughout the workplace. Make sure employees know what to do if management is not on site at the time of the inspection. Practice your plan regularly.

The number one, most important thing you can do to be prepared for an OSHA inspection is to have a culture of safety in your workplace. If you have a health and safety program in place and it’s instituted in all areas and at all times, then you will have very little to worry about when OSHA arrives. Practice and be confident in the safety plan you’ve instituted. Look at an OSHA inspection as an opportunity to display your commitment to safety to the OSHA inspector, but also to your employees as well. Safety is always worth it! You may not look forward to an OSHA inspection, but by being knowledgeable and prepared, you can at least feel confident, rather than terrified!





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