Safety Tidbit #2.13 - Lockout Devices

Safety Tidbit #2.13 – Lockout Devices

Source:            29CFR1910.147

                        OSHA Safety and Health Topics Page – Control of Hazardous Energy

Without getting into specific exemptions, OSHA’s Lockout-tagout standard covers the servicing and maintenance of machines and equipment in which the unexpected energization or start-up of the machines or equipment, or release of stored energy, could harm employees. I had a question recently about storage of the locks. My client wished to know when not in use, if it was okay to store the lockout devices with their keys still in. I didn’t see any reason why not and told them I would be more worried about losing the keys when not is service.

So a quick rundown about lockout devices from OSHA’s Lockout-Tagout Standard:

·      First all items necessary to secure a piece of equipment must be provided by the employer. [1910.147(c)(5)(i)]

·      Lockout devices and tagout devices shall be singularly identified; shall be the only devices(s) used for controlling energy; shall not be used for other purposes; and shall meet the following requirements:

o   Durable. [1910.147(c)(5)(ii)(A)]

§  Lockout and tagout devices shall be capable of withstanding the environment to which they are exposed for the maximum period of time that exposure is expected. [1910.147(c)(5)(ii)(A)(1)]

§  Tagout devices shall be constructed and printed so that exposure to weather conditions or wet and damp locations will not cause the tag to deteriorate or the message on the tag to become illegible. [[1910.147(c)(5)(ii)(A)(2)]

§  Tags shall not deteriorate when used in corrosive environments such as areas where acid and alkali chemicals are handled and stored. [[1910.147(c)(5)(ii)(A)(3)]

o   Standardized. Lockout and tagout devices shall be standardized within the facility in at least one of the following criteria: Color; shape; or size; and additionally, in the case of tagout devices, print and format shall be standardized. [[1910.147(c)(5)(ii)(B)]

o   Substantial - Lockout devices shall be substantial enough to prevent removal without the use of excessive force or unusual techniques, such as with the use of bolt cutters or other metal cutting tools. [1910.147(c)((5)(ii)(C)(1)]

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

Safety Tidbit #2.12 - Eyewashes - Revisited

Safety Tidbit #2.12 – Eyewashes - Revisited

Source:              OSHA Factsheet 3818-07/2015 Health Effects from Contaminated Water in Eyewash Stations

                        OSHA Safety and Health Topics Page – Eye and Face Protection

                        OSHA Eye and Face Protection eTool

So how many times have you inspected a worksite and told them they needed to install an eyewash?  According to OSHA [1910.151(c)], where the eyes or body of any person may be exposed to injurious corrosive materials, suitable facilities for quick drenching or flushing of the eyes and body shall be provided within the work area for immediate emergency use. Most of this standard makes sense since it comes from the ANSI Z358.1 consensus standard for emergency eyewashes and showers.  However, there are a few points that clients typically ask about when complying with the standard.

First, when is an eyewash necessary? We can understand injurious corrosive materials (I have heard it also referred to as- eye damaging chemicals). The easiest way is just to take a look at the Safety Data Sheet. 

Second, how much water must be provided? ANSI defines suitable facilities as capable of producing 0.4 gallons per minute of water for 15 minutes.  Therefore, the quick drench bottles are not sufficient since mathematically 0.4 GPM for 15 minutes yields approximately 7 gallons of water.  Also, the water must be tepid (60-100 degrees Fahrenheit) since we don’t want to boil or freeze their eyes.

However, I find most questions come from the part about the eyewash location “within the work is for immediate emergency use.”  Rule of thumb has always been if there is a wall, you must go through a door or have other obstacles the placement is no longer accessible for immediate emergency use. However, I received a call from a client that asked how far can it be from the work area.  ANSI specifies 10 seconds or 55 feet, so the old rule of thumb is still accurate. Their argument is that the average person can walk 55 feet in 10 seconds (Boy, I hope so).  Ultimately remember, if there are any obstacles in the workplace you are right back to square one and all bets are off.  Don't forget to think about the state of mind of the injured worker during the emergency is 55 feet too far? 

Lastly, site assessment.  Prior to installing the eyewash, be aware that water and electricity do not mix well together. So, keep an eye out for panel boxes and outlets (e.g. 36 inches from electrical panels).  Also, if installing the eyewash on an exterior wall, protect it from temperature fluxes such as freezing in the winter.

Now that you have determined where to put up your eyewash and have properly installed it you must maintain it.  The eyewash requires periodic draining and refilling (if self-contained) or flushing based on the manufacturer’s requirements to remove sediment and keep pathogens from thriving. Be sure to keep track of this maintenance.

Lastly, is training. You need to identify the eyewash to workers and they know how to get to it in an emergency. Also, teach them how to activate it and know when it is no longer serviceable. A periodic drill or exercise may reinforce how important it is to know how to get to it. Furthermore, my hope is that if a worker gets something in their eyes that a fellow worker will lend a hand and help get them to safety.

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

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

Safety Tidbit #2.11 – OSHA 300 – What Gets Recorded

Safety Tidbit #2.11 – OSHA 300 – What Gets Recorded

Source:              OSHA Recordkeeping Webpage

So, you now have more than 10 employees and you were told that you must keep an OSHA log. Probably, your first question was – “What is an OSHA log?” Well, an OSHA log is the OSHA 300 log or the log of workplace injuries and illnesses. So now, your second logical question is, and where I wish to spend a little time in this week’s Safety Tidbit, “What injuries and illnesses must be recorded on this log?”

Let’s start with the easy ones are

1. Any work-related fatality;

2. Any work-related injury or illness that

a. results in loss of consciousness,

b. day away from work,

c. restricted work, or

d. transfer to another job;

3. Any work-related diagnosed case of cancer, chronic irreversible diseases, fractured or cracked bones or teeth, and punctured eardrums.

Now the not so easy one is

Any work-related injury or illness requiring medical treatment beyond first aid.

Which begs the question - How does OSHA define first aid, right? Well, OSHA has an answer and it’s a bit lengthy (imagine that). If a workplace injury or illness results in any of the following it is considered first aid:

·       Using a non-prescription medication at nonprescription strength (for medications available in both prescription and non-prescription form, a recommendation by a physician or other licensed health care professional to use a non-prescription medication at prescription strength is considered medical treatment for recordkeeping purposes);

·       Administering tetanus immunizations (other immunizations, such as Hepatitis B vaccine or rabies vaccine, are considered medical treatment); Cleaning, flushing or soaking wounds on the surface of the skin

·       Using wound coverings such as bandages, Band-Aids™, gauze pads, etc.; or using butterfly bandages or Steri-Strips™ (other wound closing devices such as sutures, staples, etc., are considered medical treatment);

·       Using hot or cold therapy;

·       Using any non-rigid means of support, such as elastic bandages, wraps, non-rigid back belts, etc. (devices with rigid stays or other systems designed to immobilize parts of the body are considered medical treatment for recordkeeping purposes);

·       Using temporary immobilization devices while transporting an accident victim (e.g., splints, slings, neck collars, back boards, etc.). Drilling of a fingernail or toenail to relieve pressure, or draining fluid from a blister;

·       Using eye patches;

·       Removing foreign bodies from the eye using only irrigation or a cotton swab;

·       Removing splinters or foreign material from areas other than the eye by irrigation, tweezers, cotton swabs or other simple means;

·       Using finger guards;

·       Using massages (physical therapy or chiropractic treatment are considered medical treatment for recordkeeping purposes); or

·       Drinking fluids for relief of heat stress.

Bottom line, if you can’t take care of it yourself, you probably should be putting it on your OSHA 300 Log. Oh, and if this wasn’t confusing enough, there are also special recording criteria for work-related cases involving: needlesticks and sharps injuries; medical removal; hearing loss; and tuberculosis.

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

Safety Tidbit #2.10 –What’s in a Name - Safety Data Sheets

Safety Tidbit #2.10 –What’s in a Name - Safety Data Sheets

Source:            OSHA Instruction (CPL 02-02-079) Inspection Procedures for the Hazard Communication Standard (HCS 2012)

So what makes a good Safety Data Sheet? But just as importantly, what are the responsibilities of the employer with respect to the safety data sheet? I wish to take on one very small part of the pie called Hazard Communication.

I think everyone knows that the employer shall have a Safety Data Sheet (SDS) for each product in use at their site.  Many went through the arduous process of replacing their Material Safety Data Sheets (MSDSs) for SDSs as manufacturers and distributors made them available.  That was the ideal way.  However, many employers also diligently tracked down the manufacturers and distributors to request SDSs.  However, the “new” HazCom standard (HCS 2012) has been out for a little while now and I’m starting to see companies reverting back to their old habits – namely, not updating their SDSs. Unfortunately, once the employer had the correct SDS they once again put them in their SDS Book and placed the book on the shelf for all to have access.  Done – end of story – or is it…

What happens when the employer buys a new brand of the same product? Or the manufacturer changes the product or what if the manufacturer itself changes names. The named party on the SDS must be the same as the named party for the label. If there is a different company name on the SDS versus the label, the company that changed the name is responsible for both. Bottom line, the named party (manufacturer/distributer) must be the same between the label and the SDS two names need to be the same. For instance:

1. If the employer is maintaining one SDS for a particular chemical but uses that same chemical from a different manufacturer or importer without obtaining/maintaining the SDS from the new manufacturer or importer, the employer is not compliant.

2. If the SDS received from the manufacturer, importer or distributor has a different responsible party name than that on the product label, the employer must make a documented good faith effort to receive the appropriate SDS or they are not compliant.

3. Interestingly if you encounter a situation where the manufacturer, importer or distributor is providing SDSs that list a different responsible party than that on the label, referral procedures outlined in Appendix G of OSHA Enforcement Instruction must be followed.

So be wary, in today’s ever-changing business climate of company mergers and new start-ups, names can change and your client may find that their SDSs are no longer accurate. Rule of thumb – at least annually the employer should review their Hazard Communication Program which includes reviewing all of their hazardous materials and the respective SDSs.  However, reviewing the SDS for accuracy each time the client receives a new shipment allows for a proper hazard assessment and also ensures compliance with the law.

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

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/