Safety Tidbit 4.24 - It's Time to Post the 300A but Why?

Safety Tidbit 4.24 – It’s Time to Post the 300A but Why?

Reference:       OSHA Recordkeeping Standard 1904

                        1/25/2019 Amendment for electronic tracking of injuries and illnesses

Well, it’s that time again. If you have 11 or more employees (full and part-time) at any time during the year [1904.1(a)] you must record certain injuries and illnesses.  Now, you may be in an industry that is partially exempt from keeping the records if your industry is listed in Appendix A of 1904 Subpart B. Many of these industries are considered “low risk” as they have a low incidence of injury. But that is the topic for a future Safety Tidbit.

So you have established that your company must keep the records and therefore you must post a summary of activity. However, first, you must review the OSHA 300 Log to verify that the entries are complete and accurate, and correct any deficiencies identified [1904.32(a)(1)]. Second, you create an annual summary of injuries and illnesses recorded on the OSHA 300 Log [1904.32(a)(2)]. And third, you must certify the summary as accurate by signing it.

First question: Who must certify the annual summary to ensure it is accurate and take responsibility for the injuries that happened during the previous year?  OSHA requires one of the following sign the summary [1904.32(b)(4)(i-iv)]:

·      an owner of the company (only if the company is a sole proprietorship or partnership)

·      an officer of the corporation

·      the highest-ranking company official working at the establishment

·      the immediate supervisor of the highest-ranking company official working at the establishment.

Second question: Why must the Summary be posted from February 1 until April 30^th? You must post a copy of the annual summary in each establishment in a conspicuous place or places where notices to employees are customarily posted. You must ensure that the posted annual summary is not altered, defaced or covered by other material [1904.32(b)(5)].  Ultimately, posting is to allow sufficient time for all employees to review the summary, ensure its accuracy, and make corrections if necessary.

Note: On 1/25/2019, OSHA published a Final Rule to amend its recordkeeping regulation to remove the requirement to electronically submit to OSHA information from the OSHA Form 300 (Log of Work-Related Injuries and Illnesses) and OSHA Form 301 (Injury and Illness Incident Report) for establishments with 250 or more employees that are required to routinely keep injury and illness records. Covered establishments are only required to electronically submit information from the OSHA Form 300A (Summary of Work-Related Injuries and Illnesses). The requirement to keep and maintain OSHA Forms 300, 300A, and 301 for five years is not changed by this Final Rule.

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

P.S. If you have a new safety or health question, please let me know.

Safety Tidbit 4.23 – ACGIH TLVs – What they are not

Safety Tidbit 4.23 – ACGIH TLVs – What they are not

Reference: ACGIH TLV/BEI Guidelines - Overview

Industrial hygienists routinely reference the Threshold Limit Values when evaluating air contaminants in the workplace. But what are these TLVs?  ACGIH states:

 “TLVs^® and BEIs^® are health-based values established by committees that review existing published and peer-reviewed literature in various scientific disciplines (e.g., industrial hygiene, toxicology, occupational medicine, and epidemiology). Since TLVs^® and BEIs^® are based solely on health factors, there is no consideration given to economic or technical feasibility.”

Furthermore, the TLVs represent the opinion of the scientific community which has reviewed the data described in the ACGIH’s documentation publications, that exposure at or below the level of the TLV^® or BEI^® does not create an unreasonable risk of disease or injury.  Ultimately, industrial hygienists are strongly warned to only use the TLVs^® and BEIs^® as a part of their consideration when evaluating specific workplace situations and conditions.

So, what are the TLVs not?

a.     The TLVs are not a fine line between safe and dangerous conditions and therefore are not a common denominator for safety.

b.     Not proof of injury when exposure is at or above the TLV. Many workers will have no ill effects if exposed to the level of the TLV. The TLV is meant to protect nearly all workers.

c.     Not to be used as air pollution values where the source of the contaminant may be from a continuous, uninterrupted source. TLVs are designed for workplace situations.

d.     No legal standards as neither economic nor technologic feasibility are taken into consideration. They are purely determined based on health effects and the available data.

Ultimately, the TLVs “refer to airborne concentrations of chemical substances and represent conditions under which it is believed that nearly all workers may be repeatedly exposed, day after day, over a working lifetime, without adverse health effects.”

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

P.S. If you have a new safety or health question, please let me know.

Safety Tidbit 4.22 - Penalties Get a Raise

Safety Tidbit 4.22 – Penalties Get a Raise

Reference: https://www.osha.gov/penalties/

In the midst of the longest Federal government shutdown OSHA’s penalties get a cost of living increase. There’s something to be said for automating regulatory processes. Patrick Kapust, the new acting Director of OSHA’s Directorate of Enforcement Programs, sent the OSHA Regional Directors a memo Wednesday outlining the new penalty values effective immediately.

The cost-of-living adjustment multiplier for 2019, based on the Consumer Price Index for All Urban Consumers (CPI-U) for the month of October 2018, not seasonally adjusted, is 1.02522. To compute the 2019 annual adjustment, the Department multiplied the most recent penalty amount for each applicable penalty by the multiplier, 1.02522, and rounded to the nearest dollar.

The adjustment factor of 1.02552 will remain consistent across the minimum and maximum penalties set forth in the OSH Act and FOM. For example, OSHA's current maximum penalty for a Serious violation is $12,934.00; following the application of the adjustment factor ($12,934.00 x 1.02522), the new maximum penalty for a Serious violation will be $13,260.00.

On November 2, 2015, Congress enacted the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015, Public Law 114-74, sec. 701 (Inflation Adjustment Act), which further amended the Federal Civil Penalties Inflation Adjustment Act of 1990 as previously amended by the 1996 Debt Collection Improvement Act (collectively, the "Prior Inflation Adjustment Act"), to improve the effectiveness of civil monetary penalties and to maintain their deterrent effect. The Inflation Adjustment Act required agencies to: (1) Adjust the level of civil monetary penalties with an initial "catch-up" adjustment through an interim final rule (IFR); and (2) make subsequent annual adjustments for inflation, no later than January 15 of each year.

Bottomline, if you wish to work without the guard on the machine or are missing a guardrail it may cost you a lot more than their replacement costs.  Be diligent and tour your workspaces to ensure your controls, practices, or personal equipment are installed, followed, or used appropriately.

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

P.S. If you have a new safety or health question, please let me know.

Safety Tidbit 4.21 - Obsolete Fire Extinguishers

Safety Tidbit 4.21 – Obsolete Fire Extinguishers

Reference: NFPA 10 Standard for Portable Fire Extinguishers 2018

A colleague asked me which fire extinguishers are no longer permitted to be serviced. He understood there had been a recent change but wasn’t sure about the change. The NFPA updated its standard for Portable Fire Extinguishers and is available for purchase via their website.

Driven by inconsistencies in piping sizing and sprinkler spacing requirements for the installation of sprinkler systems, a group of fire insurance representatives met in Boston to attempt to resolve these issues.  Now the National Fire Protection Association (NFPA) is a nonprofit organization, which was established in 1896, devoted to eliminating death, injury, property and economic loss due to fire, electrical and related hazards.

The NFPA has several types of fire extinguishers it considers obsolete and recommends they be removed from service. A few, listed below, have been obsolete for some time:

1. Soda Acid

2. Chemical foam

3. Cartridge-operated water

4. Cartridge-operated loaded stream

However, to answer my colleague’s question there was a subtle change made to the dry chemical stored-pressure extinguishers (paragraph 4.4.1). Previously, if these extinguishers were “manufactured prior to October 1984, they were be removed from service at the next 6-year maintenance interval for the next hydrotest whichever came first.”

The newest edition of the standard states “ Dry chemical stored-pressure extinguishers with an indicated manufacturing date of 1984 or prior  shall be removed from service.”  Therefore, all of 1984 is included and they are to be removed from service immediately instead of the next service date.

I recommend if you have these types of extinguishers at your facility that you review their manufacturing date and remove the ones that are older than 1984.

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

P.S. If you have a new safety or health question, please let me know.

Safety Tidbit 4.20 – Cold Weather Safety – Weather Terms

Safety Tidbit 4.20 – Cold Weather Safety – Weather Terms

Reference: OSHA Cold Weather Safety Webpage

The holidays are finishing up, the kids are all back in school, and we’re all back to the grind. It’s January and winter here in Pennsylvania is just getting started. About this same time last year, I published a Safety Tidbit on Cold Weather Safety geared mainly for workers working outdoors. This time, I’d like to take a step back and look at the weather in general. I want to give the terms used by weather stations as published by the National Oceanic and Atmospheric Administration (NOAA).

Blizzard Warning: Issued for sustained or gusty winds of 35 mph or more, and falling or blowing snow creating visibilities at or below 1/4 mile; these conditions should persist for at least 3 hours.

Wind Chill Advisory: Issued when wind chill temperatures are expected to be a significant inconvenience to life with prolonged exposure, and, if caution is not exercised, could lead to hazardous exposure.

Wind Chill Warning: Issued when wind chill temperatures are expected to be hazardous to life within several minutes of exposure.

Winter Storm Warning: Issued when hazardous winter weather in the form of heavy snow, blizzard conditions, heavy freezing rain, or heavy sleet is imminent or occurring. Winter Storm Warnings are usually issued 12 to 24 hours before the event is expected to begin.

Winter Storm Watch: Alerts the public to the possibility of a blizzard, heavy snow, heavy freezing rain, or heavy sleet. Winter Storm Watches are usually issued 12 to 48 hours before the beginning of a Winter Storm.

Winter Weather Advisories: Issued for accumulations of snow, freezing rain, freezing drizzle, and sleet which will cause significant inconveniences and, if caution is not exercised, could lead to life-threatening situations.

By giving you the terms used by the weather folks, you can better decide how to prepare and protect yourself and your workers. Whether you’re playing, driving, or working in it knowing the environmental condition outside is an excellent first step towards safety.

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

P.S. If you have a new safety or health question, please let me know.

Safety Tidbit 4.19 – Crowd Safety

Safety Tidbit 4.19 – Crowd Safety

Reference: Simple Insights – State Farm Insurance

It’s the end of the year, and I know many people are going to events like concerts, bowl games, or even New York City to ring in the new year. Personally, I hate large gatherings and feel a bit claustrophobic when I can’t move about freely. Although, I do like a good concert when one of my favorite classic rock bands is playing. I saw Styx in Hershey PA this past summer.

For this week’s Safety Tidbit, I decided to look around to see what the experts out there may have to say about crowds and individual safety. I found that State Farm published “25 Ways to Stay Safer in Large Crowds” and thought I would share several of their ways with you today.

 

1. Prevent injury

·      Make sure you know where the exits are.

·      Consider leaving if the crowd seems to be getting out of control.

·      Walk around crowds rather than pushing through them.

2. Avoid illness

·      Make sure your vaccinations are up-to-date.

·      Wash your hands often, especially before and after eating or using the restroom.

·      Avoid sitting or standing near individuals who appear sick.

3. Deter pickpockets

·      Carry important items in your front pockets.

·      Wrap a rubber band around your wallet so it's more difficult to remove from your pocket.

·      Choose a purse with zipper, button, or clasp closures, and a strap that hangs across your body.

4. Stick together

·      Keep a diligent eye on your children.

·      Before leaving the house, take a photo of your child with a camera or phone. If you become separated, you will have an up-to-date photo of your child and what he or she is wearing to give to officials.

·      Remind younger children to avoid strangers, and help them identify police officers or officials to go to when lost.

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

P.S. If you have a new safety or health question, please let me know.

Safety Tidbit 4.18 - Twelve Days of Safety

Safety Tidbit 4.18 – Twelve Days of Safety

Reference: National Safety Council – The Twelve Days of Safety

Well it’s the holiday season again! The time of getting together with friends and family and having some good cheer. It is also a time for many accidents. The National Safety Council has compiled a nice infographic (https://www.nsc.org/home-safety/tools-resources/seasonal-safety/winter/infographic) using the twelve days of Christmas theme. I would like to share their points with you in this week’s Safety Tidbit.

1.     Never use lighted candles near trees or bows. Make sure candles have a stable base.

2.     Keep poisonous plants (e.g., poinsettias) out of reach of children and pets.

3.     Keep trees away from fireplaces, radiators and other heat sources. Don’t burn your tree in the fireplace.

4.     Make sure your tree has a stable platform.

5.     Choose an artificial tree that is marked fire resistant.

6.     If using a natural tree, make sure it is well watered.

7.     Check holiday lights for fraying, bare spots, gaps in the insulation or excessive kinking in the wire. Don’t overload your electrical circuits.

8.     Turn off all tree lights and decorations when not in use.

9.     When putting up decorations, properly use a step stool or ladder to reach high places. Don’t stand on chairs or other furniture.

10.  Designate a sober driver.

11.  When preparing a meal, wash hands, utensils, sink and anything else touching raw meat.

12.  Reheat leftovers to at least 165 degrees F.

One last one item is driving safely. This was the topic of an earlier Safety Tidbit, however I believe it warrants another mention. Traveling spikes during this time of year and many folks choose to travel by car. Automobiles have the highest death rate. If you are going to travel by car be prepared and ensure your family’s safety.

Be safe this season and have a great holiday. Enjoy your time with your family and friends and we’ll see you next year!

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

P.S. If you have a new safety or health question, please let me know.