The United States Department of Occupational Health and Safety (OSHA) recently released a white paper affirming their belief that requiring all employers to maintain an Injury Illness Prevention Program (I2P2) will lead to both a decrease in occupational injuries and death and a cost savings for employers.

To substantiate these claims the paper pulls from multiple studies to illustrate the cost of workplace injury and effectiveness of I2P2 programs.

Highlighted studies pointing to the cost of injury, death and illness include a study by the Liberty Mutual Research Institute stating the most disabling workplace injuries in 2008 cost employers $53 billion.

A second study by the National Academy of Social Insurance (NASI), estimates the annual workers’ compensation benefits paid for all compensable injuries and illnesses in 2009 at $58 billion (National Academy of Social Insurance, 2011). NASI further reports the total costs paid by employers for workers’ compensation increased from $60 billion in 2000 to $74 billion in 2009.

In terms of savings OSHA both looked at independent studies and examined the injury and illness prevention programs in eight states where the state had either required a program or provided incentives or requirements through its workers’ compensation programs.

In researching state programs OSHA found reductions in injury and illness from 9 to 60 percent by implementing an I2P2.

A few examples of state programs and their effectiveness include:

• Alaska which experienced a 17.4 percent decline injuries after requiring an I2P2
• California which experienced a 19 percent decline in injuries after requiring an I2P2
• Colorado which employers witnessed cumulative annual reduction in accidents of 23 percent and a cumulative reduction in accident costs between 58 and 62 percent.
• Hawaii which witnessed a net reduction in injuries and illnesses of 20.7 percent.

Currently thirty-four states require or encourage employers to implement I2P2 programs.

The basic elements of these programs are management leadership, worker participation, hazard identification and assessment, hazard prevention and control, education and training, and program evaluation and improvement.

Each element is important in ensuring the success of the overall program, and the elements are interrelated and interdependent.

OSHA began working on requiring employers to maintain an I2P2 in 2010. However, OSHA Director David Michaels told a house subcommittee in November 2011 that he was unable to provide a timeline for future activity on I2P2. Considering that some of the pushback from Congress has surrounded the I2P2 proposal in particular, the standard’s progress may depend on the as-yet undecided federal FY 2012 budget.

If you would like more information on purchasing an I2P2 program call 877-201-8923.

Read OSHA’s entire white paper below.

 
 
OSHAwhite Paper January 2012 Safety Manual

“Oh I’m a general contractor so it’s the subcontractor’s responsibility.” “I’m a subcontractor so it’s the general contractor’s responsibility.”

One of the common myths involving a general and subcontractor is safety is the other person’s responsibility.

OSHA has decided everybody is responsible for safety. If you have a jobsite you have to be compliant with a safety program, have safety training and materials.

As a subcontractor, you are the one that is going to be responsible to OSHA, the one that gets a lawsuit if someone who gets a paycheck from you gets hurt. It is up to you to make sure you have the documentation and safety program in place.

If a roofer gets electrocuted on a job, whose fault is it? First the roofing company is responsible for their own employee’s safety. Also, the electrical contractor may be in fault if it was his violation. And then the general contractor is also responsible for the entire jobsite.

The most current OSHA Field Operations Manual (FOM) – released April 22, 2011 – states, “On multi-employer worksites (in all industry sectors), more than one employer may be cited for a hazardous condition that violates an OSHA standard.” (CPL 02-00-124, Multi-Employer Citation Policy)

On a multi-employer worksite, the inspector first determines what category the employer fits into. Did the employer create, expose, fail to correct or have control over the hazardous situation. An employer may have multiple roles, and several employers can be cited at once.

The Creating Employer –

The Creating Employer is the employer that caused a hazardous condition violating an OSHA standard.

Even if the employees exposed are those of other employers, the contractor that caused the problem can be cited.

The Exposing Employer –

The Exposing Employer is one whose own employees are exposed to the hazard and, (1) knew of the hazardous condition or failed to exercise reasonable diligence to discover the condition, and (2) failed to take steps consistent with its authority to protect its employees.

In short, the Exposing Employer must correct the hazard if it has the authority to. If the employer does not have the authority then it must ask the creating/controlling employer to correct it, inform its own employees and take reasonable alternative protective measures. In extreme circumstances of imminent danger, the exposing employer must remove its employees from the job.

For example, if there are no guardrails around a permanent hole in an area the Exposing Employer’s workers are, the Exposing Employer must install guardrails if it is allowed to do so. If not it must ask the employer authorized to install the guardrails, but also take reasonable alternative steps such as
providing fall protection to its employees regardless of when or if the hazard is corrected.

The Correcting Employer –

The Correcting Employer is responsible for correcting a hazard on the same worksite as the exposing employer. This usually occurs where an employer is responsible for installing or maintaining particular safety and health equipment or devices.

The Correcting Employer must exercise reasonable care in preventing and discovering violations and meet obligations of correcting the hazard.

The Controlling Employer –

The Controlling Employer is the worksite’s general supervisor, has the power to correct safety and health violations or require others to correct them. A controlling employer must exercise reasonable care to prevent and detect violations on the site.

The National Hearing Conservation Association is urging the Occupational Safety and Health Administration to reconsider the defining of “feasible” engineering and administrative controls to mitigate occupational noise.

“The United States currently lags behind many industrialized nations in the implementation of effective noise controls.  There appears to be a misconception that 29 CFR 1910.95 (current regulation) provides reasonable intervention to adequately protect noise exposed workers.  In fact, these very interventions are based upon dated and often discredited methods for assessing the risk of permanent hearing damage from exposure to noxious levels of noise on the job,” said NHCA President Timothy Rink in a letter to OSHA.

Currently, OSHA noise regulations state employers must institute feasible administrative or engineering controls to reduce occupational noise to acceptable levels. The code also states that personal protection equipment may be used in conjunction with these controls when administrative and engineering controls are not 100 percent effective.

Despite the code stating the agency’s preference to administrative and engineering controls, OSHA’s enforcement policy on the requirements it to only issue citations for a lack of administrative or administrative controls when they would cost less to have in place than proper PPE and a hearing loss prevention program.

To change the enforcement of policy, OSHA introduced a docket last year calling for feasible in the code to be defined as “capable of being implemented” and to create an enforcement policy stressing the importance of hearing protection measures.

The proposal tabled by OSHA in January amid concerns of its cost implications to employers

“Hearing loss caused by excessive noise levels remains a serious occupational health problem in this country.” proposal OSHA Administrator Dr. David Michaels said.  “However, it is clear from the concerns raised about this proposal that addressing this problem requires much more public outreach and many more resources than we had originally anticipated. We are sensitive to the possible costs associated with improving worker protection and have decided to suspend work on this proposed modification while we study other approaches to abating workplace noise hazards.”

NHCA thinks the tabling of the measure is a mistake.

“The apparent reason for not enforcing the noise control requirements as specified in the original standard was the argument that a hearing conservation program could as effectively protect noise exposed workers at a much lower cost than designing and implementing noise control measures,” Rink said. “While an effective hearing conservation program may achieve this objective for some workers, a program designed to comply with the minimal requirements of the hearing conservation amendment to the noise standard may not.”

Rink continued stating that while concerns regarding economic feasibility are valid, recent assessments of the cost of hearing conservation programs versus noise controls indicate that noise controls may provide return on investment (ROI) within a matter of years.

Rinks statements came in a four-page letter he crafted to OSHA outlying the need for mandatory administrative and engineering controls to mitigate occupational noise.

Click here to view the entire letter.

 

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We’ve heard so much about window washers falling from buildings and construction workers injuring themselves with collapsing cranes. Yesterday, another fatality happened; but this time it involved a forklift.

A Rudco Products employee got pinned against a trash compactor when his co-worker lost control of a forklift. Julio A. Rivera, 37, was immediately brought to the South Jersey Healthcare Regional Medical Center after the accident. He was pronounced dead soon after.

The incident above is just one among more than 100 forklift-related fatalities every year, as estimated by OSHA. That’s not all. The administration also said that nearly 95,000 serious injuries happen every year because of unsafe forklift operations.

Being crushed between a forklift and another surface is actually 2^nd among the primary causes of forklift-related injuries and deaths. The first one is vehicle-tip over’s while the third to sixth are the following, respectively:

• Getting struck by the vehicle
• Getting hit by falling material from a dropped load
• Falling from a platform to the forks
• Running the forklift off a loading dock, ramp, or other surface

Training and Inspection

Safe forklift operation all starts with a well-trained driver. After undergoing complete training, drivers must be re-evaluated every 3 years. They should be re-trained if they meet an accident, have near misses, or get re-assigned to different equipment or workplace.

Before operating a forklift, a driver must make sure that it’s in good condition. Even if the vehicle is new, you must not skip this procedure. After all, even forklifts can get damaged after only days of operation.

Photo by LaRae

You must perform the following steps to ensure that there’s nothing wrong with the forklift:

• Check above your head for any obstructions.
• Inspect vent caps for clogs and forks for cracks or bends.
• Examine if battery and fire extinguisher are fully charged and secured.
• Test the horn to ensure that it’s loud enough to be heard throughout the workplace.
• Check if the vehicle makes strange sounds.
• Check if floor brakes and pedals work smoothly.
• Make sure gearshift and clutch shifts without jerking.
• Check if lights and gauges of the dash control panel work properly.

Guidelines in Forklift Operations

When loading a forklift, make sure you don’t go beyond its recommended load capacity. Always position the load based on the suggested load center. When inserting the fork into the pallet, the forklift must always be in a standing position.

When traveling in a forklift or operating it, DO…

• use your seatbelt
• keep your head, arms, hands, legs, and feet inside the vehicle
• keep to the right in 2-way traffic
• slow down if there are people and other vehicles before you of if the surface is wet or slippery
• slow down when turning
• slow down and sound the horn at corners, blind curves or other places where visibility is obstructed.
• keep the load as low as possible
• ensure that the forks are tilted back
• use caution when driving or operating around ladders and scaffolding
• use more caution in a construction site since no lines or marked paths are available unlike in a warehouse
• keep a safe distance from edges of ramps, docks and platforms

NEVER…

• Allow anyone to stand or pass under raised forks, whether they’re loaded or empty
• Allow anyone to use the forks as a man lift
• Tilt the load forward while the load is raised or the vehicle is moving down hill
• Allow stunt driving or horse play on or around the forklift
• Run over loose objects like scrap material or debris
• Drive sideways/across slopes
• Go near open trenches
• Drive over makeshift bridges

Remember, as with any equipment in your workplace, proper operations of a forklift require right training and procedures. It’s important that the employer and employees work hand in hand in making sure that safety is not compromised on the job. Be safe out there, everyone!

Helpful Links:

Forklift eTool : New OSHA Release
Forklift Safety
Darwin Awards Winner of 2000 – Death While Filming a Safety Video
25 Safety Tips for Steel and Pipes