Category: Oil and Gas

HEARING LOSS PREVENTION

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Occupational hearing loss affects millions of workers across the country. This type of injury can severely limit an individual’s ability to function normally, and reduces their quality of life. Businesses can expect to see a negative impact on productivity and profit as well as an increase in lost-time and workers’ compensation claims, leading to numerous additional hidden costs. Not only is it in your best interest to limit noise exposure in order to protect your bottom line, it is your duty and responsibility to provide your employees with a safe and healthful workplace.

How Does The Ear Work?

Sound begins by hitting the outer ear. When this happens, vibrations move towards and touch the ear drum, which transmits them to the middle and inner ear. Once at the middle ear, three bones (the malleus, the stapes, and the incus – also known as the hammer, stirrup, and anvil, respectively), take the vibrations and amplify them towards the inner ear. Within the middle ear, the cochlea, a spiral-shaped section of the ear filled with fluid and hair-lined cells, take the vibrations and translate them into nerve pulses by way of movement of the microscopic hairs. This translation becomes the sound we hear. When extremely loud noise makes its way into the cochlea, these hairs can be damaged or destroyed, resulting in hearing loss.

Measuring Noise Exposure

When measuring noise, we observe unites of sound pressure levels called decibels (dB). This term originated in the early 20th century based on measuring telephony power in the United States, through the Bell system of companies. A decibel is one tenth of a bel, named after Alexander Graham Bell. The version of the measurement we use for occupational noise exposure is the A-weighted version (dBA), which gives less weight to very low and very high noise frequencies has a stronger correlation with noise-related hearing damage. Decibels are further measured on a logarithmic scale, meaning that a small difference in the number of decibels corresponds with a massive difference in actual noise, and thereby potential for hearing loss. Dangerous decibel levels require monitoring, planning, and controls to keep noise from causing worker injury. Any noise with a decibel measurement over 85 dbA is considered hazardous.

What Kind of Damage Can You Expect?

Workers exposed to high levels of noise can expect the potential for permanent hearing loss, even if the exposure is infrequent. Hearing lost in this way is irreparable; there are currently no surgical or auxiliary options available today which can repair loss caused by damaged or destroyed cochlear hair cells. Singular incidents of extreme noise exposure may also lead to short-term hearing loss or changes in hearing (e.g. an individual may feel like their ears are plugged, or hear a persistent ringing). While often temporary to a matter of minutes or hours, frequent exposure can easily lead to these symptoms being permanent. Furthermore, those with noise-related hearing loss may be unable to understand speech or recognize sounds at higher frequencies.

Physiological damage aside, excessive noise can also increase stress in afflicted individuals, both physically and psychologically. It can inhibit the ability to communicate effectively, and increase the potential for dangerous incidents by making it difficult to concentrate or hear important safety or warning alarms and signals.

Controls

Engineering Controls

Engineering controls are the most preferred option in any hazard-mitigation hierarchy. They essentially involve eliminating a hazard altogether through displacement, replacement, installations, or other physical changes. Where noise is concerned, engineering controls take the source of noise and either eliminate it or, somewhere along its path, intercept it and reduce it below hazardous levels before it reaches the worker. Examples include selecting equipment which generates less noise as the same efficiency, installing barriers such as walls or insulation between the source and the worker, maintaining noise-generating equipment (e.g. proper lubrication) to eliminate preventable noise, and isolating the noise altogether.

Administrative Controls

Administrative controls involve modifying procedures, schedules, or behaviors in order to reduce hazard exposure as much as possible. These controls fall just below engineering controls in terms of effectiveness and desirability. Some examples of administrative controls which can reduce noise exposure include scheduling workers in limited, short shifts to work in noisy situations, positioning work at a long distance from loud noise sources, providing quiet rest areas for reprieve and relief, and scheduling work which generates excessive noise while the fewest workers possible are on site.

Personal Protective Equipment

Although personal protective equipment (PPE) is the least effective control method for mitigating hazards, it should always be used in conjunction with the others. Workers involved in operations where noise levels are above 85 dBA should wear ear plugs or other noise-reducing or –cancelling devices, so long as they don’t interfere with the worker’s ability to work safely and communicate properly.

Hearing Conservation Programs

Developing a thorough, comprehensive hearing conservation program is essential in any business’ efforts to prevent hearing loss, protect existing hearing, and convey crucial information to workers in the form of knowledge and training. Employees from the top down need to know how to operate a workplace in such a way that everyone involved with noisy work is properly safeguarded. Employers need to measure and monitor noise levels in the work place, give workers access to hearing exams, and provide workers with necessary PPE and training.

Workplaces with strong hearing conservation programs see more productivity and fewer losses through injuries and lost-time claims. To learn how Safety Services Company can assist you with creating such a program, or perfecting an existing one, visit www.safetyservicescompany.com.

 

 

6 New Things You Must Know About ISNetworld®

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Contractor Management

What is ISNetworld?

Bringing any third party auditor account to a 100% score can be a daunting and time consuming task. Understanding the 6 Common Questions about ISNetworld is our way of giving you a piece of free advice and hopefully aid you in effectively maintaining your account. However, we know this requires time, money, and close attention. But the benefits of properly utilizing a third party auditor more than outweigh the cons!  Read on to find out: What is ISNetworld?

1.    What are RAVS?

RAVS stands for the Review and Verification Services section of your account. Here, you upload your safety program. Generally, most accounts can have anywhere from 16-40 programs that need to be custom written and submitted for review. We are experts at creating these programs and have the most experience with clients on ISNetworld. With our industry knowledge, we customize each program for your company to comply with your ISNetworld account. Safety Services Company can take care of all of your RAVS needs, call our RAVS Compliance experts now.

2.   What are T-RAVS Then?

T-RAVS is the training portion associated with the Review and Verification Service for ISNetworld. Safety Services Company can help you, every step of the way, with your T-RAVS. We can provide you with the forms, guidance on the best way to train your workers, and we upload the documentation to ISNetworld. Contact us now for a FREE consultation.

3.   Wait, MSQ What?

This is very similar to pre-qualification questionnaires some of the many owner clients may have sent you before you started working for them. The MSQ however is composed of over 2300+ questions that go over your work industry, safety programs, OSHA statistics, DOT, certifications, Drug & Alcohol, and many other components. This Questionnaire is completed to best reflect your business and how it measures up to the standards set by your client. Our industry experts have extensive knowledge in completing these questionnaires based on the types of work you perform. Get Started Now so we work with you to meet you client’s requirements and expectations establishing a well-documented MSQ that properly reflects your company.

4.    How do we train Employees on ISNetworld?

It is critical that your workers understand the minimum legislative requirements regarding the safety issues in the areas they work. ISNetworld and your upstream clients want to increase the level of safety and decrease the occurrence of accidents. The ISNetworld RAVS process is a facilitator to that. Safety Services Company is available to assist you with the field implementation of any new policy, Contact one of our Training Experts today.

5.   I received an ISNetworld Letter?

This suddenly lands in your mailbox, “We are pleased to announce (COMPANY) has recently established a business relationship with ISNetworld to further enhance our contractor/supplier management program. As a result of this action, contractors/suppliers and their subcontractors performing services for (COMPANY YOU WANT TO KEEP WORKING FOR) are required to become subscribers to ISNetworld.”

What is ISNetWorld? We know there can be many questions as to why you received this letter and what happens from here. After receiving your ISNetworld® Letter we are here to help you through the process of getting ISNetworld® compliant!

6.   How fast can you get me compliant with ISNetworld?

If you would do all of the ISNetworld compliance by yourself we highly recommend hiring a full-time employee to take care of it, alternative you can take advantage of Safety Services Companies Compliance Service Specialists that are trained to maintain your ISNetworld account for you 24/7 saving you time, money and resources. Finally, use your account to its full capacity – be safe, and make more money!

What is ISNetworld? We know. Call (888) 998-6430 today to speak with one of our safety solutions experts.

*Safety Services Company is an independently owned company, specializing in compliance with Third-Party Prequalification Providers such as ISNetworld®, PEC Premier®, Avetta®/PICS®, Complyworks® and CQN®. Safety Services Company is in no way sponsored or affiliated with ISNetworld®, PEC Premier®, or Avetta®/PICS Auditing®. ISN®, ISNetworld®, RAVS® , SSQ®, PQF® are registered trademarks of ISN Software Corporation®, PEC Premier®, and Avetta®/PICS Auditing®.

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

Industrial Hacking

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Digital thieves are constantly looking for data to steal whether it’s personal information, financial records, and intellectual property, whatever they can get. They may use this data to steal money, corporate information, or disrupt your business. Your task is to do all you can to protect your network, computers, mobile devices, and data from their attacks.

In December 2014, a German steel mill suffered following a cyber-attack on the plant’s network. The attackers were able to gain access to the plant’s office network and then its production systems.

The problem stemmed from a lack of security protocols that would have separated the office networks and production networks. This raises the question that if it was so easy to attack an industrial target then how easy would it be to attack some other industrial system? Nuclear plants come to mind, but items such as water purification and power distribution systems are also potential targets.

HOW SERIOUS IS THE PROBLEM?
The problem may not seem as serious as what happened at the NSA, or as personally invasive as government spying, it is every bit as serious as those, even to the point of compromising national or corporate security.

A growing number of industrial control systems are exposed to external and relatively uncontrolled access for things like remote upgrades and remote monitoring. This accessibility means that many of these systems, especially in the oil, gas, and petroleum industries, are visible to hackers. When this ease of access is combined with the use of easily targeted, and often archaic or unpatched operating systems, it’s a recipe for disaster.

Even with internal measures being taken, there are still many ways to compromise company networks. According to a National Security Agency report, it’s estimated that cybercrime costs American businesses about $114 billion a year, with another $250 billion lost in stolen intellectual property. Of all of the attack cases reported to the Department of Homeland Security last year, energy companies were targeted in 41% of the time.

WHAT’S THE ANSWER?

Here are some things you can do to protect your business:
1. Conduct a security audit.
Know what parts of your business are vulnerable or what data you have that needs to be protected. Work with a professional to audit your entire information infrastructure to determine what you need to do to prevent hackers from accessing your network.
2. Make staff aware of their role in security.
Your employees are your front line of defense when it comes to security. Even though hackers can access your network remotely and siphon off data, vigilant employees can ensure that human error is minimalized.
3. Use strong passwords.
Many people use simple passwords that are easy for hackers to guess. When we have complicated passwords, a simple “dictionary attack can’t happen. Don’t write passwords down; commit them to memory.
4. Encrypt your data.
Encryption is a great security tool to use in case your data is stolen. For example, if your hard disk is stolen or you lose your thumb drive, whoever has it won’t be able to access the data if it’s encrypted.
5. Back up.
Security is important, but if your data isn’t backed up, it can be lost. Back-up your data regularly, and test the backup to ensure that your data can be recovered.
6. Have security policies.
It’s one thing to ask employees to work securely, but you also need to have clear and simple policies for them to follow to ensure that they are working in a secure environment. Insist that all notebooks or laptops connected to the company network have security software.
7. Protect your mobile work force.
Your sales team of 10 years ago is probably nothing like your team of today. With the increased use of mobile devices, more of your employees are working away from the office, and away from your network security. They are operating “unprotected” on your customers’ networks, public networks, or other free networks. You need to ensure that their mobile technology is as secure as possible.
8. Implement a multiple-security-technology solution.
Viruses that corrupt data are not the only security threat. Hackers become more sophisticated every day, and it is critical to have multiple layers of security technology on all your different devices. This multiple security will block attacks on your network and/or alert you to a problem.

Securing your business’s data is not easy, but by implementing some simple solutions, you can ensure that when hackers sniff around your network or computers, they will move on, because hacking into your infrastructure is not worth the trouble. One of the most important things you can do is to educate your employees in security best practices and ensure that they know how important their role is in securing business data.

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

Safety School: Principles of Industrial Hygiene

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Principles of Industrial Hygiene

An Industrial Hygienist (IH) is a safety expert whose three main jobs are to anticipate hazards, evaluate the worksite for risks, and work out the best way to control them. Do you need an IH at your worksite, and if you do, are they operating ethically according to these guiding principles?

1. Follow Recognized Scientific Principles.

Industrial Hygienists shall practice their profession following recognized scientific principles with the realization that the lives, health, and well-being of people may depend upon their professional judgment and that they are obligated to protect the health and well-being of people.

  • Base conclusions on principles and practices that protect employees health and safety.
  • Do not deceive, falsify, misrepresent, or leave out facts.

2. Provide Guidance Based on Facts.

Industrial Hygienists shall counsel affected parties factually regarding potential health risks and precautions necessary to avoid adverse health effects.

  • Gather facts on potential hazards from trusted sources
  • Review the known information
  • Take the necessary steps to communicate the risks to affected parties: management, clients, employees, subcontractors, and other employers at the worksite

3. Keep Employee and Company Information Confidential

Industrial Hygienists shall keep confidential personal and business information obtained during the exercise of industrial hygiene activities, except when required by law or overriding health and safety considerations.

  • Relate necessary information to protect worker health and safety
  • Notify employer, client or appropriate authority when overruled judgment may endanger someone’s health and safety.
  • Obtain the information owner’s unambiguous authorization before releasing confidential personal or business information, except where a law or regulation requires its release.

4. Prevent Conflicts of Interest

Industrial Hygienists shall avoid circumstances where a compromise of professional judgment or conflict of interest may arise.

  • Immediately disclose potential conflicts of interest to affected parties
  • Don’t accept financial benefits from anyone who may want to influence a decision
  • Do not offer valuable considerations to get a job
  • Warn employers when you think a project will not successfully improve conditions
  • Do not accept work that hinders ability to finish current jobs
  • Always resolve conflicts in a way that protects the health of affected parties

5. Stay Within Your Expertise

Industrial Hygienists shall perform services only in the areas of their competence.

  • Only carry out jobs when properly qualified – through education, training, or experience – or have sufficient qualified assistance
  • Earn the necessary qualifications required by federal, state and local regulatory agencies before starting related work
  • Only attach or authorize the use of their seal, stamp or signature when the document is prepared by them or someone directly under their control

6. Uphold the Integrity of the Profession

Industrial Hygienists shall act responsibly to uphold the integrity of their profession.

  • Don’t do anything that will discredit the profession
  • Don’t lie to the public
  • Do not connect your name to a person or firm that you believe is being dishonest
  • Don’t lie about your education, experience or credentials
  • Don’t promote expertise or services in a way that misrepresents or leaves out a fact needed to keep the statement from being untrue
  • Do not allow employees or employers to misrepresent your professional background, expertise or services

We have complete OSHA compliant safety solutions for all your needs. Call (888) 247-6136 today to speak with one of our highly skilled safety experts.

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.

Policy Of Cranes and Derricks near Power Lines to Stay until Rule Can Be Changed

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Because no proximity alarm or insulating link/device has been developed that meets a Nationally Recognized Testing Laboratory (NRTL) standard for cranes or derricks working near power lines – a requirement of the current standard – OSHA is making a temporary enforcement policy that has been in effect from July 26, 2012 to November 8, 2013, permanent until it changes the rule to address the unavailability of the required equipment.

This enforcement policy is effective April 30, 2014 and will continue until further notice.

The policy states that a crane or derrick may use a proximity alarm and an insulating link/device along with another measure.

Additional measures include:

  • A dedicated spotter that is positioned to gauge clearance distance with visual aids like line of site landmarks and can give timely information to the operator through direct communication.
  • Range control warning device
  • A Range of movement limiting device that prevents encroachment
  • An elevated warning line visible to the operator

Also an employer may use an insulating link/device manufactured on any date with additional protections such as adequately insulated gloves. The current regulation as it is written puts the cut-off date of non NRTL devices at November 8, 2011.

As they start the rulemaking policy for a permanent solution, OSHA will follow this temporary policy for:

  • Proximity alarm use under 1926.1407-Power line safety (up to 350 kV) assembly and disassembly
  • Proximity alarm and insulating link use under 1926.1408 power line safety (up to 350 kV) equipment operations
  • Proximity alarm and insulating link use under 1926.1409 power line safety (over 350 kV) through 1926.1407 and 1926.1408
  • Insulating link/device use under 1926.1410 power line safety (all voltages) equipment operations closer than the Table A zone.

When the Cranes and Derricks in Construction regulation went into effect on November 8, 2011, OSHA expected there to eventually be proximity alarm or insulating link devices that pass NRTL requirements, but because that did not happen OSHA created the temporary policy on July 2012 to last until November 8, 2013. But that deadline has come and went, so the current interpretation will now be practiced indefinitely while OSHA starts the process of changing the current rule.

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

Clarifying OSHA Recordkeeping Regulations for Multiple Businesses

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Contractor Earl Has Several Ongoing Jobs, What Should He Do?

The OSHA Recordkeeping regulation requires employers keep a record of serious injuries and illnesses using the OSHA 300 Log. And although it sounds simple enough, the particulars of which employees are covered, how many separate logs need to be used, and what types of injuries are serious enough to be reported can get complicated enough that OSHA updates their Frequently Asked Questions (FAQ) and Letters of Interpretation (LOI) websites. Contractor Earl has several ongoing jobs, what should he do?

In February 2014, OSHA answered several questions from a business asking for more details about the requirement to keep a separate OSHA 300 Log for multiple business establishments, 1904.30.

1904.30 Multiple Business Establishments

The basic requirements start with the idea that each establishment expected to be working for at least one year must have its own separate OSHA 300 Log. One OSHA 300 Log can be kept for all shorter-term establishments. The records can be kept at headquarters if information of an injury can be logged within seven days, and the records can be quickly sent to the establishment.

Every employee must be linked to an establishment. Also, if an employee is injured while at a different establishment, the record must be logged where the injury occurred. If an employee is injured away from a company establishment, the case must be logged where the employee normally works.

FAQs

Question: For a company that has employees working at many locations controlled and operated by clients, does that company need to have a separate OSHA 300 log for each client site?

OSHA Response: If the company has a continuous presence at a client’s site, like an office at the job site for at least one year they need to maintain an OSHA 300 log.

Question: When the company has to keep OSHA 300 logs, can they keep them at headquarters?

OSHA Response: Yes, Section 1904.30(b)(2) allows that if the company can produce copies of injury and illness forms when permitted access is requested.

Question: Where should the company record employee injuries at a remote location not associated with a company building or a client’s site?

OSHA Response: To make sure all employees are included in a company’s records, injuries at remote locations must be recorded at the home establishment that employee is linked to. If an employee works at several locations, making one establishment impractical, they should be linked to a general OSHA 300 log for short-term establishments.

Question: Does posting the OSHA 300-A Summary Form electronically for all employers to review satisfy OSHA’s posting requirements?

OSHA Response: A hard copy of that form must be posted conspicuously at each establishment where notices are normally posted.

Question: Where does the company with several locations post the annual summary?

OSHA Response: Post the annual summary at the employee’s home establishment.

Interpretations

In addition to creating new and updating current regulations, OSHA publishes interpretations and answers to questions about existing rules.

  • 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

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