Safety Tidbit #2.29 – They all must add up

Safety Tidbit #2.29 – They all must add up

Sources:          OSHA Injury and Illness Recordkeeping Requirements

Well, it’s that time of year again when we all must post our Summary of Injury and Illnesses from the previous year or the OSHA 300A form [1904.32(a)(5)].  If you have been maintaining your log all year long, the summary is a piece of cake. Further, if you use the cool Excel or PDF versions, that OSHA has available, the Summary is created for you. However, you must verify your 300-log’s validity [1904.32(a)(2)], and after you create the Summary you must certify it [1904.32(a)(4)].

Recently I have noticed a few misunderstandings as to how to complete the OSHA 300A form.  Namely entries in Blocks G, H, I, and J for Number of Cases and, also the entries in the Injury and Illness Types in the six blocks for M. First, easy enough, the totals of Blocks G thru J must equal the totals in the M blocks.

Second, each injury only gets counted once.  Blocks G thru J are a continuum from most severe (Block G) to least severe (Block J). I use an analogy to illustrate how this might work. Consider a worker getting bit by a spider on their hand. At first, it’s just an annoyance the worker goes home and nothing but maybe cleaning out the wound and a Band-Aid. First aid only it’s not recordable and life goes on.  About Day Three, the bite site is getting red and puffy, so the employee heads to the doctor to get it checked out. Behold, the wound is infected, and the doctor prescribes some antibiotics.  It’s recordable now, right? Agreed, however, no loss time or change in work duties (Block J). Unfortunately, the employee isn’t too reliable about taking their medicine subsequently the bite site gets worse, and the wound keeps them from doing their regular duties (Block I).

Time moves on, and the worker’s hand gets worse and red lines start up their arms. They head back to the hospital and get admitted since now they have a serious infection and possibly gangrene. Now the worker is a lost time case (Block H). Also, don’t forget, a call to OSHA will be required since the hospital admitted the employee. Unfortunately, the worker’s constitution is not very good, and they end up dying in the hospital. Now, the case is a fatality (Block G), and if OSHA hasn’t come to your company, which they probably won’t, you need to call them again to let them know the worker died. Ultimately, the injury only gets listed once on the OSHA 300A and is listed in Block G as a death.

There are many such analogies and I’m sure you have a favorite one of your own. However, I hope this analogy illustrates how one injury ultimately is recorded as one fatality on the OSHA 300A form. Even though all the days transferred to other duties (Block L) or lost (Block K) are also captured.

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

Safety Tidbit #2.28 – Is that respirator really working?

Safety Tidbit #2.28 – Is that respirator really working?

Sources:          OSHA Respirator Standard 1910.134

In the control of those occupational diseases caused by breathing air contaminated with harmful dusts, fogs, fumes, mists, gases, smokes, sprays, or vapors, the primary objective shall be to prevent atmospheric contamination. This shall be accomplished as far as feasible by accepted engineering control measures (for example, enclosure or confinement of the operation, general and local ventilation, and substitution of less toxic materials). When effective engineering controls are not feasible, or while they are being instituted, appropriate respirators shall be used pursuant to this section. [1910.134(a)(1)]

A respirator shall be provided to each employee when such equipment is necessary to protect the health of such employee. The employer shall provide the respirators which are applicable and suitable for the purpose intended. The employer shall be responsible for the establishment and maintenance of a respiratory protection program, which shall include the requirements outlined in paragraph (c) of this section. The program shall cover each employee required by this section to use a respirator. [1910.134(a)(2)] The program must include the following:

·      Procedures for selecting respirators for use in the workplace

·      Medical evaluations of employees required to use respirators

·      Fit testing procedures for tight-fitting respirators

·      Procedures for proper use of respirators in routine and reasonably foreseeable emergency situations

·      Procedures and schedules for cleaning, disinfecting, storing, inspecting, repairing, discarding, and otherwise maintaining respirators

·      Procedures to ensure adequate air quality, quantity, and flow of breathing air for atmosphere-supplying respirators

·      Training of employees in the respiratory hazards to which they are potentially exposed during routine and emergency situations

·      Training of employees in the proper use of respirators, including putting on and removing them, any limitations on their use, and their maintenance

·      Procedures for regularly evaluating the effectiveness of the program.

The employer shall select respirators from a sufficient number of respirator models and sizes so that the respirator is acceptable to, and correctly fits, the user. [1910.134(d)(1)(iv)]

[1910.134(g)] requires employers to establish and implement procedures for the proper use of respirators. These requirements include prohibiting conditions that may result in facepiece seal leakage, taking actions to ensure continued effective respirator operation throughout the work shift. For instance, the employer shall not permit respirators usage by employees who have:

·      Facial hair that comes between the sealing surface of the facepiece and the face or that interferes with valve function; or

·      Any condition that interferes with the face-to-facepiece seal or valve function.

The employer must ensure that employees perform a user seal check each time they put on the respirator. In short, once the employer determines a respirator is needed and requires its use they must ensure the workers use them properly.

My recommendation is that each time you see a respirator being used, ask the user to remove respirator, take a close look at it, then ask them to put it back on and watch what they do. Most simply, ensure the positive and negative fit checks are good or they are out of compliance with the standard and the workers are being exposed to the chemical in question.

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

Safety Tidbit #2.27 – Forklift Attachments

Safety Tidbit #2.27 – Forklift Attachments

Sources:          OSHA Powered Industrial Truck Standard (1910.178)

                        OSHA Letter of Interpretation dated April 11, 1997

On occasion, while touring job sites, I notice various attachments for use on the company forklift. I understand the need for them as they extend the use of the forklift. I have seen attachments for picking up workers to handling long rolls of product or materials. Usually, I find them tucked back in a corner, but on occasion, their use is in plain sight while I am there. On examination, the attachments appear to be well made and sturdy.  Sometimes, they are even powder coated with decals, although most attachments are homemade contraptions made for a particular application.

When I ask the employer if forklift manufacturer has approved the attachment for use with their forklift? Remember the employer is to train the worker on the safe and proper use of the forklift in accordance with the manufacturer’s requirements. Unfortunately, the typical responses include “Does it have to be?” or “We use it infrequently” or “We have not had any problems in the past.” OSHA’s Powered Industrial Truck standard [1910.178(a)(4)] states:

“Modifications and additions which affect capacity and safe operation shall not be performed by the customer or user without manufacturer's prior written approval. Capacity, operation, and maintenance instruction plates, tags, or decals shall be changed accordingly.”

Furthermore, OSHA as written several letters of interpretation about this circumstance the oldest letter is from 1997. You can imagine the reluctance of many forklift manufacturers to grant authorization to use an attachment on their forklift. I wish to share the response from the letter’s second question:

“With regard to compliance with 1910.178(a)(4), employers must seek written approval from powered industrial truck manufacturers when modifications and additions affect the capacity and safe operation. However, if no response or a negative response is received from the manufacturer, OSHA will accept a written approval of the modification/addition from a Qualified Registered Professional Engineer. A Qualified Registered Professional Engineer must perform a safety analysis and address any safety and/or structural issues contained in the manufacturer’s negative response prior to granting approval. Machine data plates must be changed accordingly.”

Another subtler point, I had a client with a personnel carrier cage made by the forklift company. It even had company logo decals on it. However, the rating for the forklift did not include personnel carrier use. In fact, the forklift the company had prohibited the specific forklift from personnel carrier use as was written right in the owner’s manual. Ultimately, if you are going to use an attachment on your forklift, get approval first.

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

Safety Tidbit #2.26 – Focus Four

Safety Tidbit #2.26 – Focus Four

Sources:           OSHA Construction Focus Four Training

 

Falls, Caught-in or Between, Struck-by, and Electrocution, the four leading killers on Construction Sites. Region 3 has started a campaign in an attempt to reign in these hazards. However, these have been the Focus Four for about ten years now. And actually, OSHA has been focusing their inspections on construction sites to those areas for nearly that long.  

Falls – any time a construction worker working six feet up requires protection from falling.  However, also, think about stairs, or any uneven walking surfaces. All can lead to falling and injury or even death.

Caught-in or Between – this could be machine guarding and getting caught in a belt or pulley system. Or, it could be a trench cave-in. Or, how about being caught between two loads of supplies moved by a forklift or a crane.

Struck-by – This hazard is sometimes similar to Caught-in or Between listed above. However, being struck by a moving vehicle, fly-debris or suspended loads are good examples. One that you might not think of as a struck-by hazard is nails from nail guns. Used extensively in residential construction.

Electrocution – Openings on junction boxes, breaks in the wiring, missing ground pins, working too closely or on electrical wires. These all seem to be obvious and easy to identify.

Easy right?! So why are these four hazards still killing workers and more so why after all this time does OSHA’s Region 3 feel it necessary to have a campaign for them?  Simple isn’t it? Workers need awareness of the hazard and a method to control the risk. No kidding, so are there ways to reduce the incidence of falls, getting caught in or between moving objects or not getting electrocuted? Sure there are! More to the point why aren’t these controls being used? Easy, everyone is in a rush to get the job done no time to pay attention to the job site. Profit! Profit! Profit! – Time is money!  

To help with this several years ago, I put together a mini site risk assessment conducted by the workers. See my Safety Tidbit #22 (back then safety brief) from December 2015 titles Take 5 – Stay Alive! I just wanted the workers to take five minutes at the start of the day, job, or task and discuss the hazards and how they were controlling it. 

Many companies pride themselves on conducting Toolbox Talks. I go onto a job site and ask about their training they show me these nicely printed sheets from all different vendors. But when I ask the workers what was on the sheet most (pretty much all of them) could not tell me. Not to mention their ability to internalize the information and realize how it may be important to them specifically.

Bottom line, construction workers are still getting killed by four common foes. We need to take 5 minutes to think about what could hurt us and how to reduce or eliminate the risk. Especially starting with these four hazards: Falls, Caught-in or Between, Struck-by, and Electrocution.

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