Safety Tidbit 3.23 - Earbuds a.k.a. Hearing Protection?

Safety Tidbit 3.23 – Earbuds a.k.a. Hearing Protection?

Reference: OSHA Occupational Noise Exposure Standard

                        Letter of Interpretation dated April 14, 1987

How many of you have kids that listen to their music, games, television using headphones or new-fangled earbuds? And they can’t hear you yelling at them when you’re standing right next to them. Or, you see folks commuting to work wearing headphones to drown out the rest of the world? Well OSHA requires employers to make hearing protection available when a worker’s 8-hour time-weighted average (TWA) noise exposure is 85 decibels or higher (and mandate its use at 90 decibels). Furthermore, the employer is always fighting with the worker to use personal protective equipment (PPE) so why not just let them wear the earbuds or headphones?

As the employer, you must evaluate your workplace for hazards and ensure you are protecting your workers from what was identified, in this case, noise. Next, if you can’t eliminate the hazard, you can use PPE. However, you also need to ensure the PPE will adequately protect the worker. Although the earbuds or other headphones may appear to reduce the noise level, check to see if the manufacturer tested them and consequently gives a noise reduction rating (NRR) based on the EPA’s methodology for evaluating hearing protection. I bet the manufacturer does not provide an NRR. Therefore, you have no way to know how much protection the earbuds provide.  Even most of the commercially available noise-canceling headphones do not have an NRR on them so are not considered hearing protection.

Lastly, the earbuds become a source of noise (e.g., music) directly into the worker’s ears which is entirely unregulated, uncontrolled, and ultimately, unknown by the employer. So, although OSHA does not have a regulation that forbids the use of headphones in the workplace, if you evaluate your work environment and their use could present a hazard (i.e., impeding communication, warning signals, etc.) then you as the employer must regulate their use.

So, the bottom line, you can permit music in your workplace, however, use a radio with speakers so that you can monitor and control the amount of sound produced.

Hope this was helpful and thanks for reading my Safety Tidbits! Comments and questions are always welcome. ~ Bryan

P.S. If you have an interesting safety or health question please let me know.

Safety Tidbit 3.22 - Voluntary Use

Safety Tidbit 3.22 – Voluntary Use

Reference: OSHA Respiratory Protection Standard

Have you heard an employer say? “They are voluntarily wearing those respirators. I don’t have anything to do with them.” If your answer is yes, you’re not alone. Apparently, if a respirator is necessary (because engineering controls are inadequate or still being implemented), then the employer must provide one that is adequate for the purpose and maintain a comprehensive respiratory protection program. However, what happens when there isn’t any reason to wear a respirator because the airborne concentrations are below established workplace levels (e.g., PEL, TLV, REL, WEEL, etc.) but the worker still wants to wear a respirator? Well, the employer still has quite a bit of responsibility.

OSHA states that “an employer may provide respirators at the request of employees or permit employees to use their own respirators if the employer determines that such respirator use will not in itself create a hazard.(emphasis added) If the employer determines that any voluntary respirator use is permissible, the employer shall provide the respirator users with the information contained in Appendix D to this section ("Information for Employees Using Respirators When Not Required Under the Standard").” [1910.134(c)(2)(i)]

Additionally, the employer must “establish and implement those elements of a written respiratory protection program necessary to ensure that any employee using a respirator voluntarily is medically able to use that respirator, and that the respirator is cleaned, stored, and maintained so that its use does not present a health hazard to the user.” [1910.134(c)(2)(ii)]

Ultimately, if the only respirators used are filtering facepieces (dust masks) on a voluntary basis, then the employer does not need to have a written respirator program. Unfortunately, I find that the employer is only using dust masks but has not assessed the workplace adequately to know what the exposure levels are for her workers. A “gut feeling” is not an adequate hazard assessment.

Remember, that respirators are a potential hazard unto themselves. Therefore, workers must be medically qualified before they are required or permitted to use a respirator. More importantly, if the respirator is not needed why go through the hassle and expense of having them in the first place. Educate the workers on the perceived hazards and the abatement measures implemented such as engineering controls or work practices.

Hope this was helpful and thanks for reading my Safety Tidbits! Comments and questions are always welcome. ~ Bryan

P.S. If you have an interesting safety or health question please let me know.

Safety Tidbit 3.21 - Temporary Workers

Safety Tidbit 3.21 – Temporary Workers

Reference: OSHA – Protecting Temporary Workers

                        The Economist – Daily Chart – July 18, 2016

AMERICA’S temporary help industry first emerged after the second world war, when companies like Manpower and Kelly Girl Service began “renting out” office workers on a short-term basis. In those early years, temps numbered in the hundreds of thousands. Today, the industry employs some 2.9m people, over 2% of America’s total workforce. Since the country’s economic recovery began in 2009, temporary employment has been responsible for nearly one in ten net new jobs. But as temping has grown, the quality of the jobs it provides has deteriorated.

OSHA recommends that the temporary staffing agency and the host employer set out their respective responsibilities for compliance with applicable OSHA standards in their contract. Including such terms in a contract will ensure that each employer complies with all relevant regulatory requirements, thereby avoiding confusion as to the employer's obligations.

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.

Hope this was helpful and thanks for reading my Safety Tidbits! Comments and questions are always welcome. ~ Bryan

P.S. If you have an interesting safety or health question please let me know.

Safety Tidbit 3.20 - Cold Weather Safety

Safety Tidbit 3.20 – Cold Weather Safety

Reference: OSHA Tips to Protect Workers in the Cold

                        OSHA Cold Stress Guide

As we continue in one the longest sub-freezing stretch since 1989, we need to remember our friends that work outside and review some cold weather safety. Prolonged exposure to freezing or cold temperatures may cause serious health problems such as trench foot, frostbite and hypothermia. In extreme cases, including cold water immersion, exposure can lead to death. Danger signs include uncontrolled shivering, slurred speech, clumsy movements, fatigue and confused behavior. If these signs are observed, call for emergency help.

How to Protect Workers

• Recognize the environmental and workplace conditions that may be dangerous.
• Learn the signs and symptoms of cold-induced illnesses and injuries and what to do to help workers.
• Train workers about cold-induced illnesses and injuries.
• Require workers to wear proper clothing for cold, wet and windy conditions, including layers that can be adjusted to changing conditions.
• Be sure workers in extreme conditions take a frequent short break in warm dry shelters to allow their bodies to warm up.
• Try to schedule work for the warmest part of the day.
• Avoid exhaustion or fatigue because energy is needed to keep muscles warm.
• Use the buddy system - work in pairs so that one worker can recognize danger signs.
• Drink warm, sweet beverages (sugar water, sports-type drinks) and avoid drinks with caffeine (coffee, tea, sodas or hot chocolate) or alcohol.
• Eat warm, high-calorie foods such as hot pasta dishes.
• Remember, workers face increased risks when they take certain medications, are in poor physical condition or suffer from illnesses such as diabetes, hypertension or cardiovascular disease.

Supervisors and managers: Make sure to follow-up on your folks at frequent intervals to ensure they are okay.

Hope this was helpful and thanks for reading my Safety Tidbits! Comments and questions are always welcome. ~ Bryan

P.S. If you have an interesting safety or health question please let me know.