Safety Tidbit #2.21 - Manganese

Safety Tidbit #2.21 - Manganese

Sources:          (a) Periodic Table – Manganese

                        (b) OSHA Manganese data page

Manganese is the fifth most abundant metal in the Earth’s crust. Manganese in the form of the black ore pyrolucite (manganese dioxide, MnO2) was used by the pre-historic cave painters of the Lascaux region of France around 30,000 years ago.

Manganese is a mineral naturally occurring in our bodies in slight amounts. The symptoms of manganese deficiency include high blood pressure, heart ailments, muscular contraction, bone malformation, high cholesterol, poor eyesight, hearing trouble, severe memory loss, shivers, and tremors.

Steel contains about 1% manganese, to increase the strength and also improve workability and resistance to wear. However, Manganese steel contains about 13% manganese. This steel is incredibly strong and used for railway tracks, safes, rifle barrels and prison bars.

Welding on steel can generate significant airborne levels of manganese fume. OSHA has set the ceiling limit of 5 mg/m3. A ceiling limit is that level that no worker should be exposed above at any time during the work day. However, getting instantaneous readings for manganese is very difficult. The American Conference of Governmental Industrial Hygienists recommends an 8-hour time-weighted average exposure level of 0.02 mg/m³ in the respirable fraction and 0.1 mg/m³ in the inhalable fraction of the particles.

Metal fume fever is a temporary condition caused by inhaling manganese fumes. Symptoms typically include chills, fever, upset stomach, vomiting, dryness of the throat, cough, weakness, and achiness. Manganism is a condition that occurs after exposure to toxic levels of manganese. Symptoms tend to mimic Parkinson's Disease and include gait disturbances, clumsiness, tremors, speech disorders, and psychological disturbances.

Although manganese is an essential mineral for our bodies, we don’t do well when we inhale it. Welding is the most common task where there is manganese exposure so industrial hygiene sampling must include manganese in the analysis. Standard control mechanisms include reducing the amount of time spent welding, adequate general ventilation but more importantly removing the fume at the point of generation by using portable (or installed) fume extraction systems.

Lastly, an employer must train all workers with potential manganese exposure as to the effects of the manganese on their bodies, how exposure occurs, and what precautions are necessary to ensure their safety.

I hope this information was helpful and thanks for reading my Safety Tidbits ~ Bryan

Safety Tidbit #2.20 - New Requirements for Stepladders or Just Common Sense?

Safety Tidbit #2.20 – New Requirements for Stepladders or Just Common Sense?

Sources:          (a) Update General Industry Fall Protection Standard – Regulatory Text

                        (b) Common sense

On November 18, 2016, OSHA published the new standard for Walking-Working Surfaces and Fall Protection in the Federal Register.  As most of you know, I am not a fan of ladders, and I was reminded of this on a job site this week. I also believe it is import to inspect your ladders before each use.  When you read the requirements for portable ladders below asked yourself is this requirement really just common sense?

For all ladders OSHA’s new 1910.23 standard requires the following:

•       Wooden ladders are not coated with any material that may obscure structural defects

•       Metal ladders are made with corrosion-resistant material or protected against corrosion

•       Ladder surfaces are free of puncture and laceration hazards

•       Ladders are used only for the purposes for which they were designed

•       Ladders are inspected before initial use in each work shift, and more frequently as necessary, to identify any visible defects that could cause employee injury (my personal favorite!)

•       Any ladder with structural or other defects is immediately tagged “Dangerous: Do Not Use” and removed from service until repaired or replaced

•       Each employee faces the ladder when climbing up or down it

•       Each employee uses at least one hand to grasp the ladder when climbing up and down it

•       No employee carries any object or load that could cause the employee to lose balance and fall while climbing up or down the ladder

More specifically, for portable ladders the following additional items:

•       Rungs and steps of portable metal ladders are corrugated, knurled, dimpled, coated with skid-resistant material, or otherwise treated to minimize the possibility of slipping

•       Each stepladder or combination ladder used in a stepladder mode is equipped with a metal spreader or locking device that securely holds the front and back sections in an open position while the ladder is in use

•       Ladders are not loaded beyond the maximum intended load;

·      Note to paragraph (c)(3):  The maximum intended load, as defined in §1910.21(b), includes the total load (weight and force) of the employee and all tools, equipment, and materials being carried.

•       Ladders are used only on stable and level surfaces unless they are secured or stabilized to prevent accidental displacement

•       No portable single rail ladders are used

•       No ladder is moved, shifted, or extended while an employee is on it

•       Ladders placed in locations such as passageways, doorways, or driveways where they can be displaced by other activities or traffic:

·      Are secured to prevent accidental displacement; or

·      Are guarded by a temporary barricade, such as a row of traffic cones or caution tape, to keep the activities or traffic away from the ladder

•       The cap (if equipped) and top step of a stepladder are not used as steps

•       Portable ladders used on slippery surfaces are secured and stabilized

•       The top of a non-self-supporting ladder is placed so that both side rails are supported, unless the ladder is equipped with a single support attachment

•       Portable ladders used to gain access to an upper landing surface have side rails that extend at least 3 feet (0.9 m) above the upper landing surface (see Figure D-1of this section)

•       Ladders and ladder sections are not tied or fastened together to provide added length unless they are specifically designed for such use

•       Ladders are not placed on boxes, barrels, or other unstable bases to obtain additional height.

I think you will agree many of the items listed above are just plain common sense. However, the key element, which OSHA nestled in the middle of their list but I recommend your ladder safety program put it right at the top INSPECT ALL LADDERS BEFORE USE. You can then list all inspection items afterward.

I hope this information was helpful and thanks for reading my Safety Tidbits ~ Bryan

Safety Tidbit #2.19 - How Many OSHA 300 Logs

Safety Tidbit #2.19 – How Many OSHA 300 Logs?

Sources:           29 CFR 1904.46

I received an email from a colleague asking about recordkeeping. He asked how many OSHA 300 logs does his client need to keep?  The employer takes care of the elderly and has two main campuses. He further stated that with the same NAICS could they get away with two, one for each campus?

Campus #1 includes physical buildings for each of the following:

·      Independent Living Apartment Building and Villas– has its own Executive Director & team;

·      Village Square (Personal Care/Residential Care) with skilled nursing, and Independent Living Apartments & Cottages – has its own Executive Directors & teams and the same building has a license for personal care with its own Executive Directors & teams

·      Home (Corporate Office) (Corporate, Maintenance, Grounds, Transportation, Human Resources, Information Technology)

·      Marketing Office – clerical and sales

Campus #2 is a few miles away from campus #1 and includes one physical building:

·      Nursing Center, Personal Care, Residential Care, Elder Day (adult day care) – 2 Executive Directors & staff (I one for independent living and skilled care, then the other for personal care).

So how many 300 logs should they maintain (two, five or seven)?

The basic recordkeeping requirement is that you must keep a separate OSHA 300 Log for each establishment that is expected to be in operation for one year or longer. And OSHA’s Recordkeeping regulations define an establishment as “An establishment is a single physical location where business is conducted or where services or industrial operations are performed. For activities where employees do not work at a single physical location, such as construction; transportation; communications, electric, gas and sanitary services; and similar operations, the establishment is represented by main or branch offices, terminals, stations, etc. that either supervise such activities or are the base from which personnel carry out these activities.” Clearly the latter part of the definition does not apply to this situation. However, the first part of the definition does and therefore, it appears that five logs are in order here as there are five discrete mailing addresses and buildings.

However, 1904.46(1) provides some clarity (or does it??). Can one business location include two or more establishments? Normally, one business location has only one establishment. Under limited conditions, the employer may consider two or more separate businesses that share a single location to be separate establishments. An employer may divide one location into two or more establishments only when:

                        i.         Each of the establishments represents a distinctly separate business;

                       ii.         Each business is engaged in a different economic activity;

                     iii.         No one industry description in the Standard Industrial Classification Manual (now NAICS) applies to the joint activities of the establishments; and

                     iv.         Separate reports are routinely prepared for each establishment on the number of employees, their wages and salaries, sales or receipts, and other business information.

This part doesn’t really help. According to the 2012 North American Industrial Classification system (NAICS) which is the system we are currently using a few NAICS are possible:

            Skilled Nursing Facilities                    623110

            Assisted living with skilled nursing    623311

            Assisted living without nursing          623312

So that brings our total number of OSHA Logs to seven since it appears we need to split out two of the facilities that have two discrete businesses.

However, OSHA tries to clarify yet again. 1904.46(2) Can an establishment include more than one physical location? Yes, but only under certain conditions. An employer may combine two or more physical locations into a single establishment only when:

                        i.         The employer operates the locations as a single business operation under common management;

                       ii.         The locations are all located in close proximity to each other; and

                     iii.         The employer keeps one set of business records for the locations, such as records on the number of employees, their wages and salaries, sales or receipts, and other kinds of business information. For example, one manufacturing establishment might include the main plant, a warehouse a few blocks away, and an administrative services building across the street.

Given our scenario, the company appears to be under one common management with operations directed based on the level of nursing care needed. Therefore, I would agree that two logs (Campus #1 and Campus #2) should be sufficient. Remember the primary purpose of the OSHA 300 Log is to track and trend injuries and illnesses that happen in the workplace.

Hope this information was helpful and thanks for reading my Safety Tidbits ~ Bryan

Safety Tidbit #2.18 – Holiday Safety

Safety Tidbit #2.18 – Holiday Safety

Sources:           National Safety Council – Enjoy a Safe Holiday Season

Well, Thanksgiving is over, and many of you are pulling your decorations out and getting into the holiday spirit. Unfortunately, Black Friday claimed three lives in 2016, two in Wal-Mart parking lots and one at a Mall in New Jersey. I don’t wish to put a damper on a beautiful time of year. However, I did want to reinforce a few hazards that the National Safety Council has published:

Turkey Fryers

• Set up the fryer more than 10 feet from the house and keep children away
• Find flat ground; the oil must be even and steady to ensure safety
• Use a thawed and dry turkey; any water will cause the oil to bubble furiously and spill over
• Fryer lid and handle can become very hot and cause burns
• Have a fire extinguisher ready at all times

Candles and Fireplaces

• Never leave burning candles unattended or sleep in a room with a lit candle
• Keep candles out of reach of children
• Make sure candles are on stable surfaces
• Don't burn candles near trees, curtains or any other flammable items
• Don't burn trees, wreaths or wrapping paper in the fireplace
• Check and clean the chimney and fireplace area at least once a year

Safe Gifts

• Select gifts for older adults that are not heavy or awkward to handle
• Be aware of dangers associated with coin lithium batteries; of particular concern is the ingestion of button batteries
• For answers to more of your holiday toy safety questions, check out this Consumer Product Safety Commission blog
• See which toys have been recalled

Travel Safely

• Use a designated driver to ensure guests make it home safely after a holiday party; alcohol, over-the-counter or illegal drugs all cause impairment
• Make sure every person in the vehicle is properly buckled up no matter how long or short the distance being traveled
• Put that cell phone away; distracted driving causes one-quarter of all crashes
• Make sure the vehicle is properly maintained, and keep an emergency kit with you
• Be prepared for heavy traffic, and possibly heavy snow

Hope this information was helpful and thanks for reading my Safety Tidbits ~ Bryan

Safety Tidbit #2.17 – How long were they out?

Safety Tidbit #2.17 – How long were they out?

Sources:           OSHA Injury and Illness Recordkeeping and Reporting Requirements

                        OSHA Recordkeeping Regulations (1904)

We all are aware of recent changes to OSHA’s recordkeeping standards. Such as, starting in 2015, you need to inform OSHA of any death within 8 hours (or within that work-shift), hospitalization of any employee, amputation or loss of an eye within 24 hours. However, I had a question the other day about keeping track of days away from work. This question was complicated since the end of the year is drawing near. So, I wish to take a step back. And give the scenario that a worker is hurt today and is now off work.

First, remember we record calendar days, not work days. So holidays, weekends, and workdays all count the same [1904.7(b)(3)(iv)]. Ultimately, however, you only have to keep track of 180 days. So if the injury has a long-term rehabilitation then the total time is capped at 180 days [1904.7(b)(3)(vii)]. If the worker retires or otherwise leaves the company during their rehabilitation time for a reason unrelated to the injury, then the count stops when they are no longer an employee. Although, if the employee leaves due to the injury, then you must estimate the total number of days away or restricted and enter that value on the 300 log [1904.7(b)(3)(viii)].

So, what happens when the injury occurs at the end of the year and they are still off work going into the following year? Well, you need to estimate the number of days they will be off or restricted and put that value on the 300 log [1904.7(b)(3)(ix)]. Then once they are back to work and you have a definitive count on the days you need to update the 300 log accordingly and ensure you make a note on the log to jog your memory. This helps if you are ever asked why the value was changed. Again, this only goes up to the cap of 180 days and you only record each injury or illness once and track the total days away and restricted time on the log for the year the injury occurred.

Hope this was helpful and thanks for reading my Safety Tidbits ~ Bryan

Safety Tidbit #2.16 – A Little Bit on Hazardous Chemical Labeling

Safety Tidbit #2.16 – A Little Bit on Hazardous Chemical Labeling

Sources:           OSHA Hazard Communication Standard

                        OSHA’s Hazard Communication Webpage

In almost every workplace that I visit, I find unlabeled containers of hazardous materials. OSHA’s Hazard Communication Standard requires the employer to label, tag or mark each container of hazardous chemicals in the workplace. [1910.1200(f)(6)] They don’t care how big or small the container, it has to labeled, tagged or marked. Also, OSHA prohibits the employer from defacing or removing any labels and if they do they must immediately relabel it. [1910.1200(f)(9)]

However, two exemptions that come into play, first, if the hazardous chemicals are transferred from a labeled container, and are intended only for the immediate use of the employee who performs the transfer. [1910.1200(f)(8)] Make sure it’s for immediate use, though. If the container is left somewhere then you are out of compliance, or, if more than one person is around the chemical, then you need to label the container. Second, and this one is a bit longer, the employer may use signs, placards, process sheets, batch tickets, operating procedures, or other such written materials instead of affixing labels to individual stationary process containers. So long as the alternative method identifies the containers to which it is applicable and conveys the same information as the label. [1910.1200(f)(7)] The employer must ensure the written materials are “readily accessible” to the employees in their work area throughout each work shift. The proof is in the pudding for this part, reality, can the employee explain what the hazards are in the container? If so, then you’re golden! If not, label it.

So what is required to be on the label? Well you’re not going to like this but here goes:

•       Product identifier

•       Signal word

•       Hazard statement(s)

•       Pictogram(s)

•       Precautionary statement(s) and,

•       Name, address, and telephone number of the chemical manufacturer, importer, or another responsible party

Furthermore, the employer shall ensure that workplace labels or other forms of warning are legible, in English, and prominently displayed on the container, or readily available in the work area throughout each work shift. Employers having employees who speak other languages may add the information in their language to the material presented, as long as the information is presented in English as well. [1910.1200(f)(10)]

Lastly, chemical manufacturers, importers, distributors, or employers who become newly aware of any significant information regarding the hazards of a chemical shall revise the labels. The revision must be done within six months of becoming aware of the new information. [1910.1200(f)(11)]

Hope this was helpful and thanks for reading my Safety Tidbits ~ Bryan

Safety Tidbit #2.15 - Tuberculosis and PPD

Safety Tidbit #2.15 – Tuberculosis and PPD

Source:            OSHA Safety and Health Topics Page - Tuberculosis

                        OSHA Instruction – Enforcement Procedures and Scheduling for Occupational Exposure to Tuberculosis

In 2010, a total of 11,182 tuberculosis (TB) cases were reported in the United States. If you work in one of the following types of facilities you are at risk of Tuberculosis exposure: Inpatient Medical Facilities, Outpatient settings, or some other nontraditional facility.

·      Inpatient settings include: Patient rooms, emergency departments, intensive care units, surgical units, laboratories, laboratory procedure areas, bronchoscopy suites, sputum induction or inhalation/respiratory therapy rooms, autopsy suites, and embalming rooms.

·      Outpatient settings include: TB treatment facilities, medical offices, ambulatory-care settings, dialysis units, and dental-care settings.

·      Nontraditional facility-based settings include: Emergency medical service (EMS) facilities, medical settings in correctional facilities, long-term care settings (e.g., hospices, skilled nursing facilities), drug treatment centers, and homeless shelters.

These facilities must have a TB Exposure Control Plan. One important part of the TB Exposure Control Plan is Medical surveillance and the need for periodic screening (e.g., Purified Protein Derivative (PPD) or TB Skin Test (TST) or blood analysis for M. tuberculosis (BAMT)). The periodicity of screening is based on the risk potential for disease transmission (low, medium or ongoing).

In low risk settings, annual screening is not necessary; however, if an exposure to a person with, or specimen containing, TB occurs, the employer should provide screening and update the risk assessment in accord with the 2005 CDC Guidelines

In medium risk settings, screening should be provided at least every year. In setting where there is the potential for ongoing transmission, workers should be tested every 8-10 weeks until a determination is made that there is no more an ongoing transmission potential. At which point, the classification moves to medium and annual screening is accomplished.

Training of employees with exposure potential is required so they understand the risks posed of undiagnosed individuals and the control procedures to be followed. Since most of the facilities with TB exposure potential already fall under OSHA’s Bloodborne Pathogens standard incorporating TB Exposure Control into the required annual BBP training is convenient.   

Hope this was helpful and thanks for reading my Safety Tidbits ~ Bryan

Safety Tidbit #2.14 - Steel-toed shoes Yes or No?

Safety Tidbit #2.14 – Steel-toed shoes Yes or No?

Source:            OSHA 29CFR1910.136 Foot Protection

                        OSHA 29CFR1910.132 Personal Protective Equipment

The Bureau of Labor Statistics reported 5% of all recordable injuries were related to the feet and I am sure all of you fielded the question: “Does OSHA require steel-toed shoes for my workplace?” And the answer being “yes” and “no.”  However, to really answer the question, we need to take a step back. OSHA requires the employer to assess the workplace to determine if hazards are present, or are likely to be present, which necessitate the use of personal protective equipment (PPE). [1910.132(d)(1)] Furthermore, the employer must certify, in writing, that the assessment has been performed and note the date and the workplace evaluated. [1910.132(d)(2)] Meaning the employer followed a systematic procedure which includes intentional thinking about the hazard and how to minimize its effect on the worker.  In this case through the use of the last line of defense or personal protective equipment.  Note: I’m not going to discuss actually reducing or getting rid of the hazard using any one of the other control measures in the Hierarchy of Control toolbox.

So back to the client’s question: Does OSHA require steel-toes shoes in my workplace?  Well there are approximately 18.2 million businesses in the United States.  So OSHA won’t actually say if steel-toed shoes are required in your particular workplace also they don’t prescribe personal protective equipment necessary based on type of workplace again because of potential variability. However, they do say that when working in areas where there is a danger of foot injuries or rolling objects, or objects piercing the sole the employer shall ensure that each affected employee uses protective footwear [1910.136(a)].

So when you assessed the workplace and the operations performed in the workplace and you identified the potential for your employees to injure their feet, your answer is “yes” and you need to require some sort of protective footwear.  Furthermore, if, upon closer inspection, you identified that the danger to your employees’ feet involved crushing possibly by a rollover or from dropping items on their feet then you need to require steel-toed shoes. Actually, more correctly you need to require shoes meeting the American National Standards Institute (ANSI) American National Standard for Personal Protection—Protective Footwear ANSI Z41-1999 and ASTM F2413-05 Standard Specification for Performance Requirements for Protective Footwear.

Last note, make sure you check your employees’ shoes periodically to ensure they are in good repair and will work in accordance with the ANSI and ASTM specifications as designed by the manufacturer.  You are responsible to train your employees on proper use and care of their personal protective equipment.

Hope this was helpful and thanks for reading my Safety Tidbits ~ Bryan