Safety Tidbit #2.9 - Medical Surveillance

Safety Tidbit #2.9 – Medical Surveillance

Source:            OSHA’s Clinicians Webpage

                        ACGIH Webpage

As an industrial hygienist, I routinely get questions from clients asking what medical surveillance should their employees be enrolled in. The more frustrating question comes from physicians asking a slightly different question “What is required for this employee’s medical surveillance?” Well, medical surveillance should happen before, during, and after employment. As for the clinicians’ question about what is required, well that depends on the hazard.

First, Pre-employment: I recommend to all of my clients that they should conduct medical examination prior to hiring any new employees.  Yes, you can ask if the employee has any disabilities or they may even request special accommodations due to their physical disability as per ADA requirements. However, a pre-employment physical identifies any underlying health conditions that the particular job may exacerbate. Also, the pre-employment physical ensures the worker can perform the necessary physical demands of the position. And lastly, the physical gives the status of the employee’s health upon hire. This can be very helpful down the road to establishing causality of an occupational disease or injury.

The second are the periodical examinations. This is what the clinicians are really curious about. OSHA as put together a nice website specifically for Clinicians and also a publication Screening and Surveillance: A Guide to OSHA Standards. These are very helpful for the clinicians to ensure they are doing the minimum medical surveillance requirements of the individual OSHA Standards. Most clinicians, like us consultants, know there are many more hazards out there than what OSHA has regulations for and wish to have more information. So, using the Clinicians web page is a good start, however, I further recommend they look to the American Conference of Governmental Industrial Hygienists to their Threshold Limit Values (TLVs) and Biological Exposure Indices (BEIs). Specifically, the BEIs are medical testing that can be performed routinely to evaluate if an employee has suffered occupational exposure to a hazardous agent or check the effectiveness of personal protective equipment. The testing could be the amount of a chemical in the expired breath or it could be as complicated as a particular threshold of a metabolite in the urine or blood directly after the completion of the work shift.

And lastly, to complete the employee’s career a termination physical should be accomplished. Similar to the pre-employment physical, the termination physical gives a snapshot of the employee’s physical condition at the end of service.

Ultimately, each employee is being paid to perform a service for their employer. They are not paid to degrade their health nor to give up a limb or eye. We all age, so let nature’s course degrade our health and not artificially inflate the process with poor working conditions.

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

Safety Tidbit #2.8 - Protecting Temporary Workers

Safety Tidbit #2.8 – Protecting Temporary Workers

Source:            OSHA’s Protecting Temporary Workers webpage

Both staffing agencies and host employers share in their responsibilities to protect temporary workers and if properly coordinated, these workers should be getting double the safety oversight and hopefully great protection. Unfortunately, I have had several clients over the past few months that were unaware of their responsibilities for their temporary employees.  Furthermore, I had a couple of temporary agencies that were also ignorant of their responsibilities for the health and safety of their workers. However, I have to do a shout-out to OneSource Staffing as I think they do an excellent job of working with host employers understanding the work conditions. They also have a safety person on staff for that purpose.

From OSHA’s webpage on Temporary Workers - a key concept is that each employer should consider the hazards it is in a position to prevent and correct, and in a position to comply with OSHA standards. For example: staffing agencies might provide general safety and health training, and host employers provide specific training tailored to the particular workplace equipment/hazards.

• The key is communication between the agency and the host to ensure that the necessary protections are provided.
• Staffing agencies have a duty to inquire into the conditions of their workers' assigned workplaces. They must ensure that they are sending workers to a safe workplace.
• Ignorance of hazards is not an excuse.
• Staffing agencies need not become experts on specific workplace hazards, but they should determine what conditions exist at their client (host) agencies, what hazards may be encountered, and how best to ensure protection for the temporary workers.
• The staffing agency has the duty to inquire and verify that the host has fulfilled its responsibilities for a safe workplace.
• And, just as important: Host employers must treat temporary workers like any other workers in terms of training and safety and health protections.
•  

Ultimately, OSHA may cite either or both entities for violations so each must be diligent in identifying the hazards workers (temporary or otherwise) exposed to and ensure each person is fully trained and protected while performing their job.  We as consultants can go a long way to educating the employer and to aid them in working with staffing agencies to provide qualified employees.

Remember, each person is entitled to go home whole at the end of each day.

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

http://safety-tidbits.blogspot.com/

Safety Tidbit #2.7 – Emergency Alarm Systems

Safety Tidbit #2.7 – Emergency Alarm Systems

Source:            29CFR1910.38 Emergency Action Plans

29CFR1910.165 Employee Alarm Systems

OSHA Evacuation Plans and Procedures eTool

I received a call from a client yesterday asking for guidance on alarms for use in their business to let workers know to evacuate.  I quickly answered the question by pointing to OSHA’s 1910.38 on Emergency Action Plans (EAP) and said that not all areas are candidates for audible alarms.  He mentioned about using an industrial shredder to grind and recycle plastic in one particular work area.  I explained that a visual signal might be more appropriate in that space.  He was satisfied, and we hung up from each other.  Upon further reflection, I realized that I only gave him half of the OSHA standards neglecting 1910.165, specifically on alarm systems altogether. So to make up for my oversight I used his question as the topic for this week’s Safety Tidbit.

We are all aware that OSHA requires a written emergency action plan in the workplace, and available to employees for review. With the proviso that employers with 10 or fewer employees may communicate their plan orally. The minimum requirements for an EAP are:

•    Procedures for reporting a fire or other emergency

•    Procedures for emergency evacuation, including type of evacuation and exit route assignments

•    Procedures for employees to follow who remain to operate critical plant operations before they evacuate

•    Procedures to account for all employees after evacuation

•    Procedures for employees performing rescue or medical duties

•    List of employees responsible for the emergency plan

All these items are crucial. However, they don’t make a difference if the workers actually can’t tell when they need to evacuate or take emergency action.  Therefore, it is in 1910.38(d) that we get to the “how” of the matter. This section requires an employer to have and maintain an employee alarm system. The employee alarm system must use a distinctive signal for each purpose and comply with the requirements in 1910.165 which, leads us to Part II of my answer that I initially neglected to tell my client.

As stated in OSHA’s 1910.165, the employee alarm system shall provide a warning for necessary emergency action as called for in the company's emergency action plan, or for reaction time for safe escape of employees from the workplace or the immediate work area, or both.

Ultimately, employees must be able to perceive the alarm above ambient noise or light levels in the affected areas of the workplace, which was what I was describing to my client in the grinder room where the ambient noise can reach 105 decibels. Interestingly, OSHA mentions physical devices which may be used to alert those employees who would not otherwise be able to recognize the audible or visual alarm. Furthermore, the alarm shall be distinctive and recognizable as a signal to evacuate the work area or to perform actions designated under the emergency action plan. For more information, please check out OSHA’s eTool on Evacuation Plans and Procedures.

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

http://safety-tidbits.blogspot.com/

Safety Tidbit #2.6 - Fall Protection - Construction

Safety Tidbit #2.6 – Fall Protection - Construction

Source:            OSHA’s Fall Prevention Campaign website

I recently visited a job site of a roofer and as I pulled up one of the workers was sitting, working on the edge of the roof with on leg draped over the edge (25 feet) and the other leg straight out in front of him. Before I introduced myself, I asked the company owner (who was standing right there) what the worker was doing and to please get him down.  Luckily the worker successfully stood back up (at the very edge of the roof) with his back to the ground and walked towards the peak of the roof. They both looked at me like I was crazy. This cavalier attitude amongst roofers must stop!

Thirty-five percent of the more than 800 fatalities that occurred on construction sites in 2013 were due to falls. The thing to remember is that all of these deaths are avoidable. OSHA’s mantra, with which I completely agree, is just three words: Plan – Provide – Train. 

Plan – When bidding a job look at the hazards that are involved, specifically falls and PLAN a method to protect your workers from the hazards. OSHA’s Fall Prevention Campaign talks about ladders and Personal Fall Arrest Systems (PFAS) as means to protect your workers. I say ladders are inherently dangerous (remember Safety Tidbit #5?). If you are working with your hands from a ladder how do you keep three points of contact with the ladder? Furthermore, PFASs are just personal protective equipment. Therefore, they are only as good as how well they are being used by the worker. If the harness is on but not secured is it doing any good? Or, if the harness is on but the anchorage point is faulty? Same result – Injury or death. We need to plan to provide safety measures that reduce the hazard and reduce the use of PPE (and ladders).

Provide – OSHA says on construction sites above six feet and you have a hazardous condition.  Six feet is a political number. How many of you have heard of or investigated injuries and/or deaths after falls from much lower heights?  It’s a political number because the typical scaffold is how tall, 5 feet? In other words, just below the magical 6 feet number. Now OSHA’s web page does say for the employer to provide the right equipment, ladders, scaffolds, and “safety gear.” I assume they mean PFASs as safety gear. But yes, once you decide on how to protect your workers from fall hazards ensure they have the right equipment which is in good repair.

Train – This is the mortar which holds the planning, equipment, and the usage together.  Train you workers on the proper care and usage of the equipment (ladders, lifts, scaffolds, PFASs, etc.). OSHA’s Fall Prevention Campaign website makes a brief entry about training on hazard recognition. But the way they wrote the paragraph it comes across as ensuring the workers know how to recognize when safety equipment is not properly installed or used.  I push back a bit further and say let’s ensure the workers can recognize the fall hazard, to begin with. Remember my opening scenario, neither the worker nor the owner recognized the fall hazard of a worker at the edge of the roof with one leg dangling over. 

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

http://safety-tidbits.blogspot.com/

Safety Tidbit #2.5 – I can’t see you

Safety Tidbit #2.5 – I can’t see you

Source:            OSHA Letter of Interpretation August 5, 2009.

                        National Work Zone Safety website

Well it’s Labor Day and many schools are back in session.  Which means, the days are growing shorter or at least the daylight hours in a given day are less. And to continue the logic, our evenings are becoming darker. I wish to talk about Hi-Visibility vests. They are becoming more common as you see them on all construction sites and anyone that works on the roadways.  This is mainly due to The Federal Highway Administration’s Manual on Uniform Traffic Control Devices or MUTCD which requires the use of high-visibility apparel because of the significant danger of being struck by vehicular traffic.  This goes for all people that way work (or play) on or near the highway. It is difficult enough to see people on or near the road but when you compound it with low light are the glare from a setting sun, visibility is even more difficult.

According to the Federal Highway Administration’s 2006 Worker Visibility Rule, high-visibility safety apparel is defined as “personal protective safety clothing that is intended to provide conspicuity [to make readily visible] during both daytime and nighttime usage, and that meets the Performance Class 2 or 3 requirements of the ANSI/ ISEA 107-2004 publication entitled ‘American National Standard for High-Visibility Safety Apparel and Headwear.’”

The use of high-visibility safety apparel allows motorists and equipment operators to see workers distinctly, reducing the risk of worker injury or fatality. And like many of OSHA’s Construction safety regulations, MUTCD also requires that selection of the apparel be made by a competent person designated by the employer. However, as consultants we need to be aware of condition of the High-Visibility PPE. The PPE must be inspected routinely looking if it has become faded, torn, dirty, soiled, worn, or defaced. PPE used daily might only have a service life expectancy of approximately 6 months, although if worn infrequently may have a useful service life of up to 3 years. Therefore, if you see High-Visibility clothing in ill repair or very dirty you should make the employer aware of OSHA’s PPE standard (1910.132 and 1926.95) that require PPE to be maintained in a clean, sanitary and reliable condition.

Performance Class 1

·      Background material equals 217 inches

·      Retroreflective or combined performance material with background material equals 155 inches

·      Combined-performance material used without background material equals 310 inches

Performance Class 2 – (Mowing, inspection, Adopt-a-Highway)

·      Background material equals 755 inches

·      Retroreflective or combined performance material with background material equals 201 inches

Performance Class 3 – (Nighttime, high-speed roadways, urban or high crash areas)

·      Background material equals 1,240 inches

·      Retroreflective or combined performance material with background material equals 310 inches

Performance Class E – (worn with Class 2 or 3 to become an ensemble)

• Background material equals 465 inches
• Retroreflective or combined performance material with background material equals 108 inches

Public Safety Apparel (Fire service, EMS, law enforcement)

·      Background material equals 450 inches

·      Retroreflective or combined performance material with background material equals 201 inches

So, when do most of us get outside to exercise and when are the kids able to play? In the evenings since our days are spent at work and the kids are in school (I hope). Let’s think about being seen while we are out getting our exercise because the roads are a dangerous place to be.

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

http://safety-tidbits.blogspot.com/