Category: Hospitality

NEAR MISS REPORTING

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Near miss reporting is a fundamental piece of a strong safety culture. While OSHA doesn’t require near miss reporting, companies capturing that information can gain insight into potential problem areas. Understanding the difference between incidents, near misses, and accidents is important when developing a comprehensive safety meeting topics.

An Incident is an unplanned, undesired event that hinders completion of a task and usually causes injury, illness, or property damage. The terms “unplanned and undesired” don’t mean unpreventable, nor do they mean that you can’t prepare for them. Analysis and planning are how we prepare for serious incidents that may occur, and how we take action to eliminate them.

A near miss is defined as an incident that could have resulted in injury, illness, or property damage, but didn’t. Near misses, also known as ‘close calls’, should really be near hits.

The definition of accident is similar to that of incident, but implies that the occurrence was unpreventable. An accident, using this definition, contradicts the basic concepts of a safety program, which is to find and fix hazards, and prevent incidents. If we accept that accidents have no cause, that means they are unpreventable, and they will happen again.

Training employees on the importance of reporting near misses not only will raise their awareness of potential hazards; it moves your safety program from a purely reactive mode toward a more proactive effort. Near misses are often a precursor to more serious incidents, and may be a warning that procedures and practices need to be examined.

The reporting and investigation of near misses can be instrumental in preventing injuries. Near misses are really a zero-cost learning opportunity, because it signals a potential problem without resulting in injury or loss.

If your current safety program doesn’t include the mandatory reporting of near misses, perhaps it should. Consider implementing near miss reporting the next time you review your safety program, which you should do annually. This commitment to continuous improvement will demonstrate the importance of safety to your company to all employees.

Life doesn’t always give us warning signs, but when it does, we should heed them. Having an internal near miss reporting and investigation procedure as part of your safety program is heeding one of those signs. Being able to anticipate and avoid incidents is far less costly than reacting to one. An ounce of prevention could be worth someone’s life.

Prepare for an OSHA Inspection

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Planning for an OSHA inspection with the proper safety meeting topics is good business. Take these 5 steps to prepare for a surprise worksite inspection and you’ll also have a solid foundation of safe work practices.

1. Take part in a Voluntary Protection Program. 

When you apply to have OSHA’s safety and health professionals evaluate the worksite, anything they find that needs to be fixed won’t result in a compliance citation as long as it is put right.

2. Make sure you and every other employer understands their responsibilities when it comes to the hazards at each worksite. 

Known as the “three Cs”, OSHA can cite employers if they: create the hazard, have control of the worksite, or are responsible to correct the hazard. This means different employers can be cited for the same hazard based on their responsibility for it.

3. Establish your rights.

Ask why the OSHA inspector is at your worksite because they need a legitimate reason. This probable cause can be: reported cases, complaints, targeted inspections or expressed points of emphasis, planned inspections, and even a compliance officer seeing a violation from the street.

Ask for a copy of the complaint/reason before they begin the inspection.

You have the right to restrict an inspection to the scope of the reason they are there. This could be a fatality, reported incident, or complaint. But be aware that anything the inspector sees during that inspection is fair game.

4. Know that OSHA can ask any employees questions in a private interview.

So the employer should make sure every employee can explain they know how to be safe at the worksite.

This also means they don’t have to answer any questions. If it’s the end of a long work day, and they have arranged a carpool, or if they are just shy they don’t have to answer any questions. Just don’t tell the workers you don’t want them to answer any questions, it’s their right to decide if they want to or not.

5. Managers will receive extra scrutiny, so train them up.

Whoever is responsible for the safety of others must know how to ensure it, including being aware of the hazards and the safe ways to mitigate them. The threshold for what OSHA considers a manager is low and includes: working lead, acting foreman, and competent person.

Other Safety School articles that examine the more academic concepts of occupational safety:

  • OSHA Inspections
  • Contact Release Training for NFPA 70E 2015
  • Scaffolding Code of Safe Practices
  • Emergency Response Plans for Permit Required Confined Spaces
  • Spotlighting the Importance of Checklists
  • Details of a Fully Developed Emergency Action Plan
  • The Six Guiding Principles of an Industrial Hygienist
  • Exactly How Does A Safety Manual Protect Your Company in an Inspection?
  • Who Is Covered (Or Not) By OSHA

SNOW REMOVAL

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Every year workers are killed or seriously injured while performing snow or ice removal from the rooftops of commercial, residential, and other building structures. Snow removal operations are often performed under extreme weather conditions by workers who may have little experience or training on the hazards of the job which is why having a safety manual can become very important.

Snow removal may be necessary to prevent overloading and collapse or for construction or repair of decking or roofs. Workers often climb directly onto the roofs or structures and use shovels, snow rakes, or snow blowers to remove ice and snow. Other times these operations are done from aerial lifts used to access roofs and apply de-icing materials, or from ground level using ladders and snow rakes.

Hazards

Falls are the most common cause of worker fatalities and injuries during rooftop snow removal. Workers can fall off roofs, through skylights, or from ladders and aerial lifts.
In addition to falls, workers removing snow, face other significant hazards including:

  • Injuries from using snow blowers and other mechanized equipment
  • Collapses or tip-overs of aerial lifts
  • Becoming engulfed by falling snow
  • Being shocked/electrocuted from contacting power lines or using damaged extension cords
  • Frostbite or hypothermia
  • Musculoskeletal injuries

OSHA requires that employers plan and use the safe work practices to protect workers during snow removal activities. Before snow starts to accumulate, think about what will be needed to remove snow from roofs or other elevated surfaces safely:

  • Can the snow be removed without workers going onto the roof?
  • Are there any hazards on the roof that could become hidden by the snow and will need to be marked so that workers can see them (skylights, roof drains, vents, etc.)?
  • How to remove snow based on the building’s layout to prevent unbalanced loading?
  • Determine the maximum load limit the roof can handle, and compare that to the estimated combined weight of the snow, the removal equipment, and workers on the roof
  • What tools, equipment, PPE, clothing, and footwear will workers need?
  • What training will workers need?
  • How will snow removal equipment be moved to the roof?
  • How will you protect workers and others on the ground from the snow and ice being removed?

Remove Snow Without Going on the Roof

Whenever possible, use methods to clear ice and snow that don’t require workers to go on the roof, such as using ladders to apply de-icing materials or using snow rakes or draglines from the ground.

Use Required Fall Protection

Falls cause most of the deaths and severe injuries that occur during snow removal operations. OSHA requires employers to evaluate and protect workers from fall hazards when working at heights of 4 feet or more above a lower level (1910.23), 6 feet, or more for construction work (1926.501).

If workers must access roofs and other elevated surfaces to clear snow:

  • Train them on fall hazards and the proper use of fall protection equipment,
  • Ensure all workers use their fall protection equipment when removing snow in areas that are not adequately guarded
  • Have workers put on their fall protection equipment before accessing the roof
  • Have a written rescue plan in case a fallen worker becomes caught by a fall protection system
  • Remove or mark rooftop or landscaping features that could present trip or fall hazards

Ground Workers

Workers at ground level removing snow from the roof, and bystanders, can become trapped under snow falling from roofs and suffocate. Snow being removed for a roof can be dangerous. One cubic foot of dry snow weighs about seven pounds, while a cubic foot of wet snow weighs anywhere from 12 to 18 pounds. To protect personnel from removed snow:

  • Identify a safe work zone in the area where snow is being removed to keep the public back 10 feet from where snow is expected to fall
  • Instruct workers to wear eye and head protection when removing snow and ice.
  • Instruct workers using snow rakes and draglines to remove only small amounts of snow at a time.

Effective planning and preparation can protect workers and the public from injuries during snow removal work.

WINTER WALKING

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This winter has been one of the worst for much of the U.S., with near-record snow, ice, and many other weather hazards. Walking in winter weather can be particularly dangerous.
Snow is bad enough, but ice and icy conditions can present a far greater hazard to your health. Snow is easy to see, remove, and does provide some traction. Ice, on the other hand, can be hard to see and dangerous, especially if you’re on foot.
The last thing you want to do is fight the weather, get to work, park your car, and then injure yourself when you get there. Slipping and falling on parking lot and sidewalk ice injuries in are common, and can cause serious injuries. Broken arms, wrists, and hips are far too common in snowy and icy conditions.

Here are some general tips to help companies and employees stay safe when conditions are icy:

  • Employers should clear snow and ice from walking surfaces and spread deicer as quickly as possible after a storm.
  • Employees should wear footwear that has good traction and insulation. Avoid wearing boots or shoes with smooth leather or plastic soles and heels. You should always wear shoes or boots made of non-slip rubber or neoprene with grooved soles when walking on snow and ice.
  • Wear a heavy, bulky coat that will cushion you if you should fall.
  • Wear a bright colored or reflective clothing so drivers can see you.
  • Keep warm, but make sure you can hear what’s going on around you.
  • During the day, wear sunglasses to help you see better and avoid hazards.

Walk like a penguin

In cold temperatures, assume that all wet, dark areas on pavement and sidewalks are slippery and icy. A thin layer of moisture can freeze on cold surfaces, forming a nearly invisible layer of black ice that can look like a wet spot on the pavement.

Walk in designated walkways whenever possible. Taking shortcuts over snow piles and other frozen areas can be dangerous. Avoid walking in the street if at all possible, icy streets are slippery for cars too, and they’re much more difficult to stop.

  • When walking on ice, angle your feet out, like a penguin, this will increase your center of gravity.
  • Lean slightly forward and walk flat-footed to keep your center of gravity directly over your feet.
  • Taking short steps will help you keep your balance
  • Extend your arms out to your sides to maintain balance. If you must carry a load, try not to carry too much; leave your hands and arms free to balance yourself.
  • If you do carry something, carry it in your dominant hand. This can help prevent you from using your dominant hand break your fall, and avoid injuring your hand, wrist, or arm.
  • Keep your hands out of your pockets. Putting your hands in your pockets while walking may keep them warm, but it decreases your center of gravity, balance, and increases your chances of slipping and falling.
  • Watch where you’re walking, focus on the path in front of you, and take your time
  • When walking on stairs always use the hand-railings and plant your feet firmly on each step.
  • It’s easy to lose your balance when getting into or out of your car, use the vehicle to help support yourself.
  • Look at the ground while you’re walking, don’t end up slipping on ice that we could have seen if we had been looking.

Walking on a slippery floor can be just as dangerous as walking on ice. Keep these tips in mind when entering a building:

  • Melting ice or water on the floor can make it slippery.
  • Watch for floors and stairs that may be wet and slippery, walk carefully by outer doors.
  • Determine the best path to take to get to your destination and take a little extra time to get there
  • Be sure to use floor mats when entering a building to remove moisture from the soles of your shoes – this will help protect you, and others, from having to walk on wet or slippery surfaces

Winter weather can be irritating enough without adding injury to the equation.

AVOID HOLIDAY HORRORS

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As the holidays approach, anticipation and apprehension grows around the “Company Holiday Parties.” While these gatherings provide excellent opportunities to relax, network with co-workers, and hone your interpersonal skills, they also come with risks. Whether you’re employer or employee, here are some tips that could help you avoid holiday horrors, avoid regrettable incidents, result in career suicide, or worse.

ALCOHOL

Holiday parties often include alcohol, and this is frequently a source of problems. It loosens tongues and inhibitions, and frequently leads to other troubles. Consider the following suggestions when planning or attending a company gathering.

As an Employer:

Decide if you’re going to serve alcohol; If you do, it’s a good idea to have a hosted bar where professionals can monitor employees alcohol intake. A simple way to control alcohol consumption is to issue drink tickets to attendees to help limit intake.

You can also consider having a non-alcoholic party. Having a more family oriented party theme or a breakfast or lunchtime gathering are good ways to do this. While excluding alcohol at a company event may not be popular with the guests, it greatly reduces any potential liabilities.

If you’re offering drinks you should also provide food. This helps reduce the amount of drinks consumed, and limits their effects.

As an Employee:

Know your limits and pace yourself. Even though it may be after hours and offsite, it’s still a company event and you should conduct yourself as you would at work.
Keep in mind at the end of the party; you’ll still need to get home safely.
Approach this social meeting as an opportunity to build work relationships and get to know co-workers better. It’s not the time to release pent up frustrations or animosities.

DANGEROUS OR ILLEGAL ACTIVITIES

As an Employer:

It’s best to assume that unintended or undesired activities will occur, and be prepared for them. Be alert for signs of intoxication or sexual harassment. As mention before alcohol lowers inhibitions and may cause normally mild mannered, reserve people to do things that could result in legal actions later.

As an Employee:

Keep in mind that your workplace isn’t a dating service. Just because a co-worker is pleasant and smiles at you doesn’t mean they want to have a personal relationship. Don’t say or do anything that you’ll regret later, or that could damage a good working relationship.
Don’t bring your own party to the party. Anticipating that the party is going to “be lame”, doesn’t justify bringing your own supplies to it. People may bring their own quantities of alcohol or illegal drugs to the event in order to “spice it up.” Just as in the workplace it’s your responsibility to report any of these activities you see.

EXPECTATIONS

Holiday parties are a great way to celebrate a successful and productive year, and possibly recognize top achievers, but they can also be stress creators.

As an Employer:

Some of your best workers may not be social animals, so don’t make the party mandatory. Some employees may choose not to attend for a variety of reasons such as religion or other commitments. You never want to give the impression that attendance, or lack thereof, will have any impact on someone’s career.

As an Employee:

Remember, even though the party is a company-sponsored event, it’s not the time to talk shop or ask your boss for a raise. These are topic you should save for the workplace.
Use your time at the party to get to know others better. It’s an opportunity to find co-workers who have similar interests or hobbies.
As you prepare for holidays, you tend to focus your attention on family and friends. Allocating some time toward staff and co-workers can not only improve the atmosphere in the workplace, it can prove enlightening and increase your understanding and appreciation for everyone there. Remember these tips to make sure your holidays are safe and happy.

Safety School: Spotlighting the Importance of Checklists

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Do you consider workplace checklists an important part of ensuring all necessary safe work procedures are consistently followed? Or do you consider a checklist a slow, tedious, and largely unnecessary procedure for work you already know how to do?

Here are two interesting accounts where checklists have been used to great effect. One is a matter of history that changed an industry, and the other occurred much more recently, demonstrating that there can be human resistance to following demonstrably better procedures.

Boeing B-17 and the First Checklist

On a B-17 test flight, in 1935, the aircraft stalled on takeoff because the elevator lock was accidentally left on, and pitch control didn’t work. Three men were injured, and two later died.

Because this new airplane was much more complicated to fly, it was determined that even experienced pilots would need a checklist. Instead of relying on memory every time, a checklist would ensure that all necessary steps were completed to keep the airplane safely in the air. Because of this simple, new process, Boeing was able to get the government to mass produce the B-17, and it went on to be a very successful asset for the United States in World War II.

Believe it or not, Boeing’s checklist is considered the first. Certainly, checklists are a very common practice in aviation today, where a focus on safety requires numerous variables to be checked before every flight. There are more than 25,000 daily commercial flights in the U.S. each day.

Hospital Checklist Slashes Infection Rates

In 2003, Dr. Peter J. Pronovost established a simple, five-step checklist to be followed every time a common catheter (central venous catheter) was inserted at 108 intensive-care units in Michigan. Over 18 months, catheter-related infection rates dropped from 4% to 0, saving 1,500 lives and nearly $200 million.

As you can see, the checklist is as simple as it gets:

  1. Wash hands with soap.
  2. Clean patient’s skin with chlorhexidine antiseptic.
  3. Put sterile drapes over the entire patient.
  4. Wear a sterile mask, hat, gown and gloves.
  5. Put a sterile dressing over the catheter site.

According to Dr. Pronovost, he wanted to change behavior, which he says is the biggest opportunity to improve health care. Still hospitals lag in implementing similar checklists. However in the news, the CDC procedures where health care workers who may come into contact with Ebola patients will have another person guide them through the step by step process of putting on and removing PPE amounts to a checklist.

Some reasons people resist using checklists include:

  • Experts such as doctors don’t want to be monitored by others
  • Experts want to have the freedom to act as they see fit
  • Standardized tasks are associated with bureaucracy, and more paperwork
  • There is a focus on new medical procedures rather than ensuring current ones are enforced

Checklists in the Workplace

So, looking at these two examples, can you see where workplace safety can benefit from following a checklist? Anywhere a series of steps has to be followed correctly every time, a checklist can be implemented to make sure everything has been covered and nothing is missed.

Here are a few places where creating a checklist may be helpful:

  • Making sure a first-aid kit is fully stocked with necessary materials
  • Daily and monthly inspections of vehicles such as: forklifts, cranes, and ladders
  • Annual workplace inspections
  • PPE maintenance and repair schedules
  • Required monthly and quarterly fire-extinguisher inspections
  • Equipment inspection and repair schedules
  • Start-up and shutdown procedures
  • Established lockout/tagout procedures

Other Safety School articles that examine the more academic concepts of occupational safety:

  • OSHA Inspections
  • Contact Release Training for NFPA 70E 2015
  • Scaffolding Code of Safe Practices
  • Emergency Response Plans for Permit Required Confined Spaces
  • Spotlighting the Importance of Checklists
  • Details of a Fully Developed Emergency Action Plan
  • The Six Guiding Principles of an Industrial Hygienist
  • Exactly How Does A Safety Manual Protect Your Company in an Inspection?
  • Who Is Covered (Or Not) By OSHA

Safety School: Details of a Fully Developed Emergency Action Plan

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Just like a Job Hazard Assessment (JHA) is a way to develop every day employee safe work practices, an Emergency Action Plan (EAP) is planning for possible workplace emergencies. And like a JHA, the EAP has a series of cornerstones – development, authority, training, and maintenance – to build upon and is specific to the workplace while having some recognizable commonalities (e.g. evacuation plan, shelter in place, and fire prevention).

Don’t assume that all workers will make the safe choice in the face of an emergency.

A trash fire may be something an employee may try to put out on his own but without the training to know when its past the incipient stage where it can easily be put out they can put themselves and others in danger by delaying warning everyone else.

EAP Cornerstones

That’s why it’s important to take the time to develop a plan that writes out what employees should do in each possible emergency. Use the workers experience to get a first-hand opinion of what the hazards and worst case scenarios are and possible responses.

Part of every EAP is identifying everybody’s responsibility including the person whose job it is to execute an EAP and evacuation procedures. The coordinator’s authority includes deciding there is an emergency, activating and overseeing emergencies procedures and contacting other emergency services such as the police or fire department.

Ensuring employees are trained in all elements of the EAP that affect them is another important component. They may need to know: their responsibilities, workplace hazards, possible notifications, response procedures such as evacuating or sheltering, location of available emergency equipment, and anything they need to shut down.

In order to be considered current any assessment or plan has to be maintained. Maintenance can mean: regular reviews; updates that incorporate new workplace conditions, equipment, or materials; information to outside emergency responders, evacuation drills, and ongoing training for new and current employees.

Common Elements

No matter how unique or safe the workplace is, it is going to include common elements such as: an evacuation procedure, shelter in place procedure, and a fire prevention plan. If an office has a workplace violence situation where a disgruntled current or former employee go to work threatening violence it may be necessary to evacuate the building getting the employees to a safer location while alerting the police. There are also situations where that same office, located in an industrial park where a rail line travels nearby, may want to have an interior room where all employees will have to report to and shelter-in-place because a car has derailed nearby and is leaking hazardous material.

Fire Prevention Plan

Every EAP needs a fire prevention plan that at least meets the OSHA requirements detailed in 29 CFR 1910.39. Think of a fire prevention plan as a compact EAP with its own four components: required lists, maintenance and control procedures, assigned responsibilities, and providing training. The required lists include identifying: major fire hazards, hazardous material handling and storage procedures, ignition sources and how to control them, and the needed fire protection equipment provided for the hazards. Control procedures include housekeeping to prevent the accumulation of flammable or combustible materials. Elements that need to be regularly maintained are the safeguards on heat producing equipment so that combustible materials don’t ignite. And just like the larger EAP, every employee needs to know their responsibilities and who has the authority to assign them. Fire prevention plan specific responsibilities include maintaining equipment to prevent ignition, and who controls the fuel sources. Fire prevention training must have the potential fire hazards and how the worker will protect themselves.

Additional Resources

There are ways to get even more specific guidance on creating an EAP than this survey. For example, OSHA provides instruction and checklists to help businesses get started, and OSHA state plans may provide additional state specific guidance and other consensus standard establishing organizations that even OSHA defers to on specific criteria like the National Fire Protection Association (NFPA) and the American National Standards Institute (ANSI) can be referenced.

Other Safety School articles that examine the more academic concepts of occupational safety:

  • OSHA Inspections
  • Contact Release Training for NFPA 70E 2015
  • Scaffolding Code of Safe Practices
  • Emergency Response Plans for Permit Required Confined Spaces
  • Spotlighting the Importance of Checklists
  • Details of a Fully Developed Emergency Action Plan
  • The Six Guiding Principles of an Industrial Hygienist
  • Exactly How Does A Safety Manual Protect Your Company in an Inspection?
  • Who Is Covered (Or Not) By OSHA

INJURY REPORTING

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The U.S. Department of Labor’s Occupational Safety and Health Administration today announced a revision of 29 CFR 1904.39 Injury reporting. The change requires most employers to notify OSHA when an employee is killed, or suffers an injury requiring hospitalization, an amputation, or loss of an eye on the job.
The rule change also updates the list of employers partially exempt from OSHA record-keeping requirements. These new requirements take effect on January 1, 2015 for workplaces governed by Federal OSHA. State plan states will have 6 months following this time to revise their rules to be at least as rigorous as the federal regulation.
The key elements of the rule revision are:
• Reports of amputation and eye loss have been added to reports of hospitalization, and the time requirement has been changed to 24 hours (Amputations do not include avulsions, enucleations, deglovings, scalpings, severed ears, or broken or hipped teeth.)

OSHA also now allows three methods of reporting:

  • By phone or in person to nearest OSHA office (current method)
  • By toll free number to Federal OSHA hotline (to be used if the nearest office is closed)
  • By electronic submission using a fatality/injury/illness reporting application that will be located on OSHA’s website.

The reporting application will include mandatory fields for the required information. If the report does not include the required information, the reporting application will not accept the report. The mandatory fields are:

  • The establishment name
  • Where the incident occurred
  • When the incident occurred
  • The type of incident (i.e., fatality, in-patient hospitalization, amputation, or loss of an eye)
  • The number of injured employees
  • The names of the injured employees
  • The employer’s contact name and phone number
  • A brief description of the incident

It’s important to remember that even though companies with ten (10) or fewer employees, and those considered “partially exempt”, are not required to keep OSHA injury and illness logs (300 and 301) they must still report all injuries or illnesses that meet OSHA definitions in a timely manner.

A Case Study Clarifying How To Decide It’s a Workplace Injury

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Imagine the following situation and ask yourself if you know exactly why or why not the employer should log the injury as work related.

An employee, while walking up 80 feet of steps at work, had their left knee suddenly “pop” and couldn’t place weight on it, requiring first aid. After being taken to a hospital, the employee was diagnosed with a strained/sprained knee.

Then, four days later, a second physician says the knee condition is non-occupational — citing the exception in 1904.5(b)(2)(ii) that says employers don’t need to report an injury that happened solely from a non-work related event, even if the symptoms occurred while at work — because there were no obvious aggravating factors at the workplace that contributed to the knee injury.

This was the situation put to OSHA that they addressed February 2014 in a clarification of its recordkeeping regulations: 1904.5 Determination of Work-relatedness” and 1904.7 General Recording Criteria”.

OSHA first made it clear it is the employer’s responsibility to make the correct decision whether a specific injury or illness is work related, even though the employer may use the guidance of a health care professional.

Also, a work event doesn’t have to be the only, or even main, cause of a work injury. The injury doesn’t even have to be caused by a unique or “out-of-the-normal” event like a fall.

Question: Is walking up 80 feet of steps at work an identifiable event or exposure, even without a slip, trip, or fall?

OSHA Response: Yes, normal body movements like walking, bending down or sneezing can be an event that makes it related to work if these actions can be identified as the cause of an injury.

 Question: If a physician determines the injury is a reoccurrence and not a new case, is the employer relieved from the requirement to determine the injury is recordable?

OSHA Response: 1904.6(b)(3) says employers must follow the health care professional’s determination of whether an injury is a new case or reoccurrence, but that’s when the employee has a recorded similar workplace injury. Without any previous OSHA recorded left knee injuries, the employee’s case is new and a health care professional’s evaluation isn’t necessary.

Question: If two health care professionals come to different conclusions about whether an employee’s injury is work related, do you use the first one or second one?

OSHA Response: OSHA’s recordkeeping regulation allows advice from multiple health care professionals to determine if an injury or illness is work-related. But it is the employer’s responsibility to make the correct decision.

When two or more health care professionals make conflicting determinations, the employer must base its decision on the most authoritative — best documented, best reasoned, or most persuasive — evidence or recommendation — 1904.6(b)(3).

2014 Interpretations

In addition to creating new and updating current regulations, OSHA publishes interpretations and answers to questions about existing rules. Here is what has been released in 2014:

  • Construction’s Electrical Power Regulations Final Rule
  • Cranes and Derricks Near Power Lines
  • Recordkeeping for Multiple Business Establishments
  • How to Decide It’s a Workplace Injury
  • Safety Data Sheet (SDS) Reporting of Petroleum Streams
  • Combustible Dust Labeling Requirements in Hazard Communication Standard (HCS)
  • OSHA Definition of A HNOC Clarified for the HCS
  • General Duty Clause Covers All Impalement Hazards
  • Employer Responsible for Determining Qualified Rigger Status

OSHA Definition of a HNOC Clarified For The HCS

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On March 4, 2014 OSHA released an open letter to the American Petroleum Institute clarifying how they interpret the Hazard Communication Standard (HCS) regarding Hazards Not Otherwise Classified (HNOC).

A HNOC Is

From the official definition, a HNOC is a negative physical or health effect that doesn’t fit the HCS categories.

A negative effect has to occur from workplace exposure to a chemical causing material health impairment or functioning. Employees must be free from negative effects even if regularly exposed to the chemical.

The criteria for classifying a negative health effect is the weight of evidence as described in Appendix A. All available information will be considered together using expert judgment. Also important is the quality of the data, with a precedence on good quality human data, routes of exposure, and positive and negative results.

A HNOC Is Not

If there is a physical or health hazard that fits the HCS category, but is less than the stated cut-off value or concentration it is not a HNOC.

Also categories of GHS Hazards not adopted by OSHA – like acute toxicity – are also not an HNOC.

Furthermore, OSHA considers “physical effect” in the definition to be impairment of health or function caused by a chemical’s hazards in normal conditions or foreseeable emergencies. This means scalds by an exposure to chemicals at high temperature or slipping on a spilled liquid chemical does not make those hazards a HNOC.

For example, OSHA does not consider water a HNOC because an employee may be scalded by boiling water, get hypothermia from being in cold water, slip in a puddle, or be knocked down by water sprayed at high pressure.

A HNOC is also not a pyrophoric gas, simple asphyxiate or combustible dust because they have intentionally been added to the “hazard chemical” definition.

HNOC Labelling Requirements

There are no Safety Data Sheet (SDS) label requirements for a HNOC, and such information does not have to be physically separate, but must not cause confusion with the required information.

On the label, the only two signal words that may be used are “danger” and “warning” and the correct signal word for a HNOC must be used.

Because a HNOC is determined through the hazard classification process, that information can be included under the required sections.

2014 Interpretations

In addition to creating new and updating current regulations, OSHA publishes interpretations and answers to questions about existing rules. Here is what has been released in 2014:

  • Construction’s Electrical Power Regulations Final Rule
  • Cranes and Derricks Near Power Lines
  • Recordkeeping for Multiple Business Establishments
  • How to Decide It’s a Workplace Injury
  • Safety Data Sheet (SDS) Reporting of Petroleum Streams
  • Combustible Dust Labeling Requirements in Hazard Communication Standard (HCS)
  • OSHA Definition of A HNOC Clarified for the HCS
  • General Duty Clause Covers All Impalement Hazards
  • Employer Responsible for Determining Qualified Rigger Status