Safety Tidbit 4.06 – Mobile Stairs

 

Reference:       OSHA 1910.23(e) Mobile Ladder Stands and Platforms

                       

OSHA defines a mobile ladder as “a mobile, fixed-height, self-supporting ladder that usually consists of wheels or casters on a rigid base and steps leading to a top step. A mobile ladder stand also may have handrails and is designed for use by one employee at a time.”

Mobile ladders are used to reach items at various heights and can be a couple of feet to more than 20 feet tall. Warehouses whether a dedicated warehouse or just the stock area of the company are common habitats for these convenient stairs. They are much more secure than ladders but do have the drawback of being fairly large and requiring their own space for storage. However, you see them in many places. I recently spotted on in Lowes. Well not really spotted so much as I could not get around it in the aisle that I was heading down. Interestingly, a Lowe’s Associate was getting ready to use the stair, so I stopped and let her get the item she wished and just watched her work (which as an IH you know I love to do!). 

She finished wheeling the mobile stair into position and ascended the mobile stair. She was retrieving an item from the top shelf about twelve feet up. As she climbed the stairs, they shifted slightly which made her grab the handrails to steady herself. Another associate that was helping her walked over and locked the caster wheels to keep it from moving. As she got all the way to the top (about 8 feet) and twisted to retrieve the item she was looking for off of the rack the stairs rocked slightly. This, again, caused the associate to grab the handrail to steady herself. Luckily, she had not yet retrieved the item and had both hands to steady herself. The second associate grabbed hold of the mobile stairs to steady it. The first associate pulled the item from the rack and then walked down the stairs with a box requiring both hands to carry and that she could not see around. Once successfully down both associates walked away leaving the mobile stairs there to be used again and never thinking about the close call the associate had with falling off the mobile stair. 

I walked over to the mobile stair once they departed. I looked it over and found that one of the rubber feet at the bottom of the stair was missing. There were no identifying marks on the mobile stair to enable it to be tracked and periodically inspected. I reported my observations to the “duty” manager in hopes they will remove the stair from service until it can get properly fixed. OSHA’s standard on mobile platforms 1910.23(e)(1)(viii) states  that the employer must ensure that no mobile ladder stand, or platform moves when an employee is on it.

I think they have some room for improvement in the safety and health program. I was disheartened that the associates did not even consider that the one nearly got injured retrieving an insignificant piece of merchandise.

Hope this was helpful and thank you 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 4.05 - Is it a carcinogen?

Safety Tidbit 4.05 – Is it a carcinogen?

 

Reference:       OSHA Hazard Communication 1910.1200

                        National Toxicology Program (NTP)

                        International Agency for Research on Cancer (IARC)

                       

I recently asked the question “What are the two primary sources you should use to determine if a substance you are working with is a carcinogen?” This was in reference to OSHA’s Hazard Communication Standard. Many folks responded that they would look on the Safety Data Sheet (SDS). Which made me feel good that they both knew what an SDS was and that that information was in the document.  But when pushed further and I asked how does the manufacturer of the chemical know to classify their chemical as a carcinogen?  We need to dig a little deeper into the Hazard Communication Standard.

Appendix A of the OSHA Hazard Communication Standard (1910.1200) is a mandatory appendix to assist manufacturers with classifying the hazards of their chemicals.  Section A.6 deals with Carcinogenicity. In paragraph A.6.2.1 OSHA states “ For the purpose of classification for carcinogenicity, substances are allocated to one of two categories based on strength of evidence and additional weight of evidence considerations. In certain instances, route-specific classification may be warranted.” So,  the answer to my question might be a) strength of evidence and b) weight of evidence.

OSHA goes on to define both items but then says in A.6.2.5.1 “These factors can be viewed as either increasing or decreasing the level of concern for human carcinogenicity. The relative emphasis accorded to each factor depends upon the amount and coherence of evidence bearing on each. Generally, there is a requirement for more complete information to decrease than to increase the level of concern. Additional considerations should be used in evaluating the tumor findings and the other factors in a case-by-case manner.” In other words, more information is better but how much is enough?

This is close but not quite what I am looking for. Going back to my original question what two primary sources can be used to determine if a substance is a carcinogen?” At the very end of the section, OSHA says, in lieu of manufacturers doing their own testing to determine if their chemical should be classified as a carcinogen they can use two sources:

o   National Toxicology Program (NTP), "Report on Carcinogens" (latest edition);

o   International Agency for Research on Cancer (IARC) "Monographs on the Evaluation of Carcinogenic Risks to Humans" (latest editions)

Hope this was helpful and thank you 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 4.04 - Emergency Preparedness

Safety Tidbit 4.04 – Emergency Preparedness

 

Reference:       NFPA Fire Prevention Week

                        OSHA Emergency Preparedness and Response Webpage

As Hurricane Florence hits the Carolinas and Fire Prevention Week is less than a month away (October 7-13, 2018), I thought it a good time to reflect on what we can do at work to be better prepared for emergencies.

Putting together a comprehensive emergency action plan (EAP) involves conducting a hazard assessment to determine what, if any, physical or chemical hazards inside or from outside the workplaces could cause an emergency. The plan should describe how workers will respond to different types of emergencies. Ensure you consider specific worksite layouts, structural features, and emergency systems. If you have more than one worksite, each site should have an emergency action plan.

An EAP is intended to communicate and coordinate everyone’s actions (employer and worker) during workplace emergencies and is recommended for all employers. Well-developed emergency plans and proper training (i.e., so that workers understand their roles and responsibilities within the plan) will help you keep your workers healthy and prevent injuries and property damage during emergencies. A poorly prepared plan may lead to a disorganized evacuation or emergency response, resulting in confusion, injury, illness, and/or property damage.

OSHA requires, at a minimum your Emergency Action Plan must include: 

•  A preferred method and/or procedures for reporting fires and other emergencies (29 CFR 1910.38(c)(1) and 29 CFR 1926.35(b)(5))

• Emergency escape procedures and route assignments, such as floor plans, workplace maps, and safe or refuge areas (29 CFR 1910.38(c)(2) and 29 CFR 1926.35(b)(1))

• Procedures to account for all workers after an evacuation, such as designating an assembly location (e.g., a safe/refuge area) (29 CFR 1910.38(b)(4) and 29 CFR 1926.35(b)(3))
• Names, titles, departments, and telephone numbers of individuals both within and outside the company to contact for additional information or explanation of duties and responsibilities under the emergency plan (29 CFR 1910.38(c)(6) and 29 CFR 1926.35(b)(6))
• Procedures for workers who remain to perform or shut down critical plant operations, operate fire extinguishers, or perform other essential services that cannot be shut down for every emergency alarm before evacuating (29 CFR 1910.38(c)(3) and 29 CFR 1926.35(b)(2)); and
• Rescue and medical duties for any workers designated to perform them (29 CFR 1910.38(c)(5) and 29 CFR 1926.35(b)(4)).

Hope this was helpful and thank you 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 4.03 - Let's Get This Party (Program) Started

Safety Tidbit 4.03 – Let’s get this party (program) started

 

Reference:       OSHA - 10 Ways to Get Your Program Started

 

The main goal of safety and health programs is to prevent workplace injuries, illnesses, and deaths. However, getting started is always the hardest part. Below are 10 ways to help you get your program started:

1. Establish safety and health as a core value. Tell your workers that making sure they finish the day and go home safely is the way you do business. Assure them that you will work with them to find and fix any hazards that could injure them or make them sick.
2. Lead by example. Practice safe behaviors yourself and make safety part of your daily conversations with workers.
3. Implement a reporting system. Develop and communicate a simple procedure for workers to report any injuries, illnesses, incidents (including near misses/close calls), hazards, or safety and health concerns, without fear of retaliation. Include an option for reporting hazards or concerns anonymously.
4. Provide training. Train workers on how to identify and control hazards in the workplace, as well as report injuries, illnesses, and near misses.
5. Conduct inspections. Inspect the workplace with workers and ask them to identify any activity, piece of equipment, or materials that concern them. Use checklists to help identify problems.
6. Collect hazard control ideas. Ask workers for ideas on improvements and follow up on their suggestions. Provide them time during work hours, if necessary, to research solutions.
7. Implement hazard controls. Assign workers the task of choosing, implementing, and evaluating the solutions they come up with.
8. Address emergencies. Identify foreseeable emergency scenarios and develop instructions on what to do in each case. Meet to discuss these procedures and post them in a visible location in the workplace.
9. Seek input on workplace changes. Before making significant changes to the workplace, work organization, equipment, or materials, consult with workers to identify potential safety or health issues.
10. Make improvements. Set aside a regular time to discuss safety and health issues, with the goal of identifying ways to improve the program.

Hope this was helpful and thank you 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 4.02 - A 5A1 Refesher

Safety Tidbit 4.02 – A 5A1 Refresher

Reference:        The OSHAct

                        OSHA Field Operations Manual

Under Section 5(a)(1), Duties, of the OSH Act, it states:

“Each employer -- shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees.”

This is the “general duty” under which OSHA may cite employers for recognized hazards for which a standard may not currently exist. This is the one that strikes fear into many employers as they may not realize a particular circumstance or material is hazardous. For instance, in the past year, OSHA’s Pittsburgh Area has issued thirteen citations using Section 5(a)(1) or the General Duty Clause as justification.

However, for OSHA to use the General Duty Clause four key items must be proved:

1.     The employer failed to keep the workplace free of a hazard to which employees of that employer were exposed;

2.     The hazard was recognized;

3.     The hazard was causing or was likely to cause death or serious physical harm; and

4.     There was a feasible and useful method to correct the hazard.

Number Two is the one that may be hardest for OSHA to prove “was the hazard recognizable?” In the OSHA Field Operations Manual, recognition is split into three main sources Employer Recognition, Industry Recognition, or “Common-sense” Recognition.

Employer recognition is easy. If the employer points out the problem or has operating procedures that say how a job is to be safely completed and it was not being done that way. Then that fits for employer recognition.

Secondly, industries commonly develop and publish methods to safely perform various tasks so that every company can take advantage of the lesson learned. National examples of industries might include the American National Standards Institute (ANSI).

Lastly, is “common-sense” recognition. Hazard recognition can still be established if a hazardous condition is so obvious that any reasonable person would have recognized it. OSHA says this form of recognition is to be used in flagrant or obvious cases.

An example given by OSHA:

“In a general industry situation, courts have held that any reasonable person would recognize that it is hazardous to use an unenclosed chute to dump bricks into an alleyway 26 feet below where unwarned employees worked.”

Bottomline, OSHA can and do use the General Duty Clause to cite hazards. However, they must do a lot more investigation. Conversely, as Safety and Health professionals we must be vigilant in our learning to keep abreast of ever emerging industry knowledge of occupational hazards.

Hope this was helpful and thank you 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 4.01 - Flood Safety

Safety Tidbit 4.01 – Flood Safety

Reference:        NOAA Significant Climate Anomalies and Events for July 2018

                        Weather.gov Turn around Don’t Drown

We have had more than our fair share of rain this summer. Areas in Western Pennsylvania typically average between 3.3 and 5.1 inches of rain during July. According to NOAA, For Pennsylvania, July goes on the record as the wettest with 176% the average precipitation. Yes, we had rain day in and day out but, more importantly, we had short periods of extreme downpours. It is at these times we can get caught out in cars getting groceries are picking up the kids. Ultimately, we must get home but getting there could be the most dangerous thing we do.

Each year, more deaths occur due to flooding than from any other thunderstorm related hazard. The Centers for Disease Control and Prevention report that over half of all flood-related drownings occur when a vehicle is driven into hazardous flood water. The next highest percentage of flood-related deaths is due to walking into or near flood waters. People underestimate the force and power of water. Many of the deaths occur in cars swept downstream. Many of these drownings are preventable. Never drive around the barriers blocking a flooded road. The road may have collapsed under that water.  A mere 6 inches of fast-moving flood water can knock over an adult. It takes just 12 inches of rushing water to carry away most cars, and just 2 feet of rushing water can carry away SUVs and trucks. It is NEVER safe to drive or walk into flood waters.

The National Weather Service issues various precautionary statements in the press as storms are tracked. Below are their definitions and what they recommend you do for each:

·       Flash Flood Warning: Take Action! A Flash Flood Warning is issued when a flash flood is imminent or occurring. If you are in a flood-prone area move immediately to high ground. A flash flood is a sudden violent flood that can take from minutes to hours to develop. It is even possible to experience a flash flood in areas not immediately receiving rain.

·       Flood Warning: Take Action! A Flood Warning is issued when the hazardous weather event is imminent or already happening. A Flood Warning is issued when flooding is imminent or occurring.

·       Flood Watch: Be Prepared: A Flood Watch is issued when conditions are favorable for a specific hazardous weather event to occur. A Flood Watch is issued when conditions are favorable for flooding. It does not mean flooding will occur, but it is possible.

·       Flood Advisory: Be Aware: A Flood Advisory is issued when a specific weather event that is forecast to occur may become a nuisance. A Flood Advisory is issued when flooding is not expected to be severe enough to issue a warning. However, it may cause significant inconvenience, and if caution is not exercised, it could lead to situations that may threaten life and/or property.

Hope this was helpful and thank you 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 3.50 - OSHA Consultation Program

Safety Tidbit 3.50 – OSHA Consultation Program

Reference:       OSHA Fact Sheet – The OSHA Consultation Program

Benefits of the OSHA On-site Consultation Program – An Economic Analysis

This is my 150^th Safety Tidbit! Tomorrow I embark on a new chapter of my career, mentoring a new generation of professionals as I begin teaching at IUP. Before, however, I wish to pause and reflect on a well-kept secret (which shouldn’t be a secret at all!). For the past five and half years, I have worked in Pennsylvania’s OSHA Consultation Program. Throughout the Commonwealth, the Program helps small employers keep their workers safe and healthy.

The program is administered by IUP for the state government using well-trained professionals (in PA, all consultants are nationally credentialed as either a Certified Industrial Hygienist (CIH) or a Certified Safety Professional (CSP) and many have a graduate degree).  Its mission is to help employers identify hazards in the workplace, providing kinds of assistance available to reduce the hazards, and giving detailed findings with recommendations. They also provide training and education, air sampling or noise dosimetry. In short, the Program gives small businesses peace of mind that they’re protecting their workers enabling each of them to go home to their families at the end of each workday.

A couple things about the Program. It does not issue penalties and it strictly maintains confidentiality of the client. In Pennsylvania, the program performs more than 600 visits to employers each year.

In an OSHA Working Paper dated August 1, 2018, researchers reviewed the economic benefits of the State Consultation program based on a hazards removed approach. The study showed the benefits of the program to the national economy to be $1.55 Billion annually. I ask you to spread the word and let small businesses know they have a resource that truly wants to help them. As this is completely voluntary, employers just need to request their services. (https://www.iup.edu/pa-oshaconsultation/request/)

Hope this was helpful and thank you 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.