With cooler temperatures setting in and winter proper right around the corner, workers around the country are facing a uniquely seasonal variety of injuries known as “cold stress.” Although cold stress is possible any time of year, cold weather along with a number of other environmental factors can expose unprepared workers to extreme bodily harm, and even death. Before it gets any colder, now is a good time for businesses to examine their cold stress prevention policies to ensure employees have the tools, knowledge, and training they need to stay warm and work safely.
Awareness and preparedness are the two critical elements of cold stress prevention. It’s important to understand how the human body maintains and regulates its temperature, and how to recognize the warning signs which develop when those systems are failing. Because a variety of factors contribute to cold stress injuries – not just extreme temperatures alone – a worker could be suffering even if it doesn’t seem all that cold outside; having the skills to spot symptoms outside of expected conditions could be crucial for someone’s survival.
Though the right conditions can put anyone at risk, there are some occupations which, by their very nature, put workers in a position to be more frequently exposed to cold weather. These occupations can include sanitation, outdoor construction, snow removal, law enforcement, and emergency response (i.e. firefighters and emergency medical crews).
Conditions (aside from low temperatures) which increase the risk of cold stress include:
Moisture or damp clothes
Time of day (specifically, how much sun warmth is present)
Dehydration and physical exhaustion
Age (your body does not regulate temperature as efficiently as you get older)
Certain health conditions such as hypertension and diabetes
Poor or ineffective clothing and personal protective equipment
Lack of training
Cold stress injuries occur when your body loses heat faster than it can produce it. Your body tries to maintain a core temperature of 98.6°F (37°C). As you are exposed to lower temperatures, your body will prioritize its heat by taking it away from your extremities and reallocating it to the vital internal organs at your core (chest, abdomen). This is why the first places you feel cold are your fingers, toes, nose, and ears. Exposed skin (especially extremities) can quickly develop cold stress ailments such as frostbite and chilblains. Once your body’s internal temperature reaches 95°F (35°C), hypothermia will begin to set in.
Moisture is the enemy. To drive the point home, that really bears repeating – moisture is the enemy. The simplest way to understand this concept is to consider our body’s primary self-cooling function: perspiration. When the body needs to cool itself down, it expels moisture through the pores. Firstly, moisture conducts heat 25 percent faster than air, carrying it from the body. Then, the heat is carried away further when the sweat evaporates. So if the human body is using moisture as a life-saving measure to remove heat, imagine how detrimental it would be if the body were already cold.
Wind isn’t much better than moisture. Your body naturally radiates heat, leaving what we’ll call a thin “heat shield” over your skin. Moving air acts as a conductor, blowing the heat shield away and forcing your body to expend precious energy in order to produce a new one. This works much in the same way as blowing on your hot soup before you eat it – the moving air cools the soup down faster. You’ve probably heard your local television weather anchors discuss “wind chill,” which is a function to describe how cold it feels after actual outside temperature and wind speeds are calculated together. The greater the wind speeds, the colder it feels.
Now that we have an idea how our bodies work in the cold, what are some ways we can protect workers from cold stress?
Dressing properly is probably the most important step you can actively take to prevent cold stress. Wear at least three layers. The inner-most layer should be made of wool (or another animal fiber), silk, or a synthetic/synthetic blend to absorb and keep moisture away. The middle layer should be animal fiber or synthetic for the insulation properties, even when wet. The outermost layer should allow for ventilation and built for protecting against wind and rain. Avoid cotton.
Engineering controls are ways for an employer to set up and design a work space to eliminate or minimize a hazard. In cold-weather situations, engineering controls can include radiant heaters, indoor heated rest areas, and even erecting barriers to protect workers from the wind.
In some areas of the country, the dead of winter comes with brutal winter chill 24 hours a day. Employers can still monitor the weather and attempt to schedule work during the warm(est) times of day.
Safe Work Practices
Promoting safe behavior during the work day can go a long way. Provide warm, sweet liquids while avoiding caffeine or other diuretics which could contribute to dehydration. No one should ever work alone; workers should be scheduled with at least one buddy, as it’s sometimes easier to recognize cold stress symptoms in others than in yourself. New employees, or those unaccustomed to working in extreme temperatures, should be acclimated slowly through gradual schedule increases and rest time decreases (start them with more frequent breaks).
Ultimately, formal training is the way to go. Never send a worker into a cold environment without the knowledge they need to keep themselves and others safe. Workers should know how to prevent and recognize cold stress illnesses, and how to address them with first aid should they appear. For more safety and training resources for cold stress prevention, visit www.safetyservicescompany.com.
The requests for topics on Oil Cleanup Safety materials have been overwhelming since the BP Disaster. We thought it would be helpful to provide a basic overview of oil cleanup safety, where to get started and what the requirements are.
First off, it’s important to remember that the gulf oil cleanup is a massive coordinated effort that cannot possibly be perfect. In addition to the dangers of exposure to crude oil, chemical additives, dispersants and cleaning chemicals, workers are forced to deal with all the standard job-site hazards such as sharp objects, falls, drowning, wildlife and heat exhaustion in the dizzying gulf summer. We do know that OSHA is taking this seriously, however. Some quick facts provided by OSHA :
OSHA Currently has more than 2,000 federal employees overseeing the efforts of 25,000 workers and 5,000+ boats.
OSHA is working with the National Institute for Occupational Safety and Health (NIOSH ) and the National Institute of Environmental Health Sciences (NIEHS) to ensure that appropriate training is provided to workers that BP is hiring to help cleanup the oil. Emphasis is placed on ensuring workers were trained in a language and vocabulary they understand. OSHA, along with NIEHS, continues to monitor this program. In response to recently received information, OSHA is in the process of increasing the training requirement for crews on vessels engaged in offshore oil recovery
OSHA personnel were deployed to the Gulf the week of April 26th. Since then OSHA personnel have been deployed to all 17 staging areas in Louisiana, Mississippi, Alabama and Florida. OSHA staff is on the ground monitoring worker safety and health and assessing whether BP is providing appropriate worker safety and health protections. In coordination with the U.S. Coast Guard, OSHA staff also board near-shore vessels doing booming, skimming operations, and in situ burning operations, and are stationed on offshore vessels for longer periods.
Every day OSHA has over 146 professionals protecting workers throughout the Gulf Region, 25 of whom are assigned solely to the Oil Response Clean up. OSHA staff is in the field and on boats to make sure BP is protecting cleanup workers from health and safety hazards. In addition, OSHA’s Health Response Team (from Salt Lake City) arrived in Louisiana on May 6th to provide technical support (for worker exposure monitoring) to OSHA response site personnel.
OSHA staff have made over 1000 site visits, covering the vessels of opportunity, staging areas, decontamination, distribution, and deployment sites.
When OSHA finds safety problems on site visits or learns about them from workers, it brings them to the attention of BP and makes sure they are corrected. OSHA also raises its concerns through the Unified Command so they are addressed across the entire response area. OSHA is ensuring that workers are provided, free of charge, appropriate personal protective equipment such as boots, gloves and other protective equipment as needed.
If you would like to get involved with oil spill cleanup, or have lost your employment due to the oil spill, we highly recommend visiting the CareerOneStop website, which is a great comprehensive resource and sponsored by the U.S. Department of Labor. Access by clicking the links below :
OSHA’s golden rule : Your employer is responsible for training you in the hazards of your job in a language that you understand BEFORE YOU BEGIN WORK. They are responsible for determining the amount and length of training based on your job duties and hazards.
OSHA’s basic training fact sheet states :
If you are doing work that does NOT involve materials contaminated by the spill, you must receive a 1.5 hour training session
If you ARE doing work cleaning up anything contaminated by the spill, you must receive a minimum of 4 hours of training which are supervised by people with more than 40 hours of Hazardous Operations training.
The company or contractor you work for is alsoresponsible for establishing safe work practices and giving you the personal protective equipment you need to do your job safely.
They are also responsible for developing a health and safety site plan and sharing it with you. The plan should have information about all the job site hazards and requirements for working safely.
Now that spring is here and the weather is warming, it’s time to get training into full swing. No, we’re not talking about baseball; we’re talking about safety training. If your business has been in winter hibernation, now is the time to get your employees in shape for the regular season.
It’s time to review your training records and see if you have any equipment operators that are due for re-certification or need to be trained on new equipment. This is a good time to schedule refresher training on the fundamentals of general safe work practices such as the use of PPE, material handling, fire prevention, and electrical safety. If there have been any changes in the types of protective equipment workers will use they will need training on them.
If your work includes using ladders or scaffolds, retrain everyone on safe climbing procedures and fall protection. Verify that employees who will be responsible for assembling, moving, and disassembling scaffolds have retained the knowledge necessary to perform that work safely.
You should also review your list first aid providers to make sure it’s current, and determine if you want to increase the number of certified personnel. Since certification or refresher, training for your responders will likely require scheduling the training with an approved organization (i.e. the Red Cross or St. John Ambulance), now is the time to contact them and either schedule a company training session or enroll employees into existing classes.
While we’re on the subject of first aid, you should take this opportunity to inspect, inventory, and replenish your first aid kits. Make sure you have enough kits of the right size for the upcoming jobs, and that all of the kit contents are there and haven’t expired or been damaged.
Scheduling training now, before it gets busy, could save you a lot of time or money later. It’s going to be a long season, make sure your team is ready to go the distance and is bringing their “A” game.
Two scaffold safety organizations have developed a concise scaffolding code of safe practices that would beneficial for employers to post at worksites, follow and instill in all applicable workers.
With enough content to fill a small poster, the code covers general guidelines as well as erection, use, and dismantling. Download it here now, and put it to use.
The rules don’t go into all systems so any manufacturer guidelines also need to be followed. Instead this is a way to reinforce basic rules that should be common sense, but can easily be broken without proper education and constant reminders.
In the general guidelines is a step to survey and correct job site hazards looking for: untamped earth fills, ditches, debris, high tension wires, and unguarded openings. In the erection section is a reminder that free standing scaffold towers need to be restrained from tipping if they vertically exceed four times the base, with a 3 to 1 ratio for other agencies such as CAL/OSHA. Dismantling guidelines remind workers to be mindful that the scaffolding isn’t made unsafe in the process, visually check planks, not accumulate excess equipment on each level, or remove ties until the level above is dismantled…
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
Other Safety School articles that examine the more academic concepts of occupational safety:
Federal OSHA regulations are simply the minimum standard. About half of the U.S. states have taken advantage of their own authority to make stricter, or additional, rules.
Maryland OSHA (MOSH) is one of the “state plan” states that administer their own “mini-OSHA.” MOSH has beefed up their regulations on everything from:
Asbestos in protective clothing
Smoking at work
Powered equipment training
Reporting toxic substances
Medical surveillance testing for lead poisoning, to
Tree care and removal
The designs for sloping, benching and support, shields, or other protective systems designed from tabulated data or a registered professional engineer need to be at the worksite while they are being constructed, according to the Federal government.
MOSH wants employers to keep those designs at the worksite even longer to include while they are being used in the larger construction project.
Asbestos in Protective Clothing
Asbestos is as useful as it is deadly, and before its carcinogenic hazards were fully known, asbestos was utilized as heat insulating protective clothing. But because asbestos protective clothing that is improperly maintained can expose employees to that hazard, Maryland has banned employers from buying, using, requiring a worker to use or even keeping any asbestos clothing at a place of employment.
Smoking at Work
Every state has its own smoking laws. Some ban smoking within 20 feet of a business’s entrance; some have exceptions for bars and restaurants – but not Maryland.
MOSH makes it clear that smoking is not allowed in any indoor place of employment, and that there must be a “No Smoking” posted at each entrance.
OSHA’s 1910.146 regulation defines confined and permit required confined spaces, with employer and employee responsibilities.
Maryland decided to eliminate some guesswork and make a rule that, with limited exceptions, requires there to be at least one other person immediately nearby when someone enters a manhole.
The exception to this rule is if the employee can go into the manhole with cables or equipment to take readings, perform housekeeping or an inspection, or complete some other safe task.
Powered Equipment Training
OSHA has specific training regulations for some heavy equipment such as: forklifts and cranes. However, for earthmoving equipment such as scrapers, loaders, tractors, bulldozers, off-highway trucks, graders and similar equipment, the training requirements are vague, and you have to refer to General Safety and Health Provisions training element, 1926.21, which requires employees are able to recognize and avoid unsafe conditions in their work environment.
For its part, Maryland, has established some training elements for what it defines as power equipment: backhoes, bulldozer, front-end loader, skid steers, gradalls, scraper pans, cranes, and hoists.
The employer must develop and carry out a program of the standards needed to safely operate power equipment including: limitations and use; rated load capacities; and special hazards.
Companies need to keep on file a written description of the program, as well as where and when employees received safety training on file.
Employers must also post applicable manufacturer specifications for power equipment, and any required operating instructions.
Reporting Toxic Chemicals
Part of OSHA’s Hazard Communication regulations includes a provision to compile a list of the hazardous materials that employees may be exposed to while at a worksite.
MOSH wants all employers to take that list, (arranged alphabetically by the common name, with the chemical name, where it can be found, and the date it was first brought to the worksite), and send it to the Maryland Department of the Environment every two years.
Lead Testing Medical Surveillance
Where an employee may be exposed to lead (e.g. lead-based paint, old houses) OSHA has a medical surveillance program to initially test employees with periodic testing against that baseline.
Some of the additional testing that Maryland requires is to carry out initial testing before any assignment to an area with airborne concentration at the action level. This is in addition to the federal testing requirement of at least every two months for the first six months, and then every six months after that.
Maryland also wants employers to test employees at the termination of employment.
Federal guidelines have a process for temporarily removing employees with elevated lead levels from the exposure site for medical protection, with follow up tests for up to 18 months until a final decision is made. Requirements after that period are not defined.
Maryland instead directs employers to obtain a medical determination and continue to provide medical removal benefits until the decision is made about whether the employee can safely return to the same work.
Tree Care and Removal
OSHA doesn’t have regulations for every job, and tree care and removal are examples. The employer often must look at the potential hazards and cobble together safe work procedures.
MOSH decided that risks of tree care (e.g. cutting, pruning, tree removal) were enough that it codified the requirements for that type of work. The requirements include regulations on fall protection, the equipment used, personal protective equipment, fire protection, traffic control, power lines, tree and brush removal, chipping, and training.
Although it’s impossible to discern exactly what led to this overturned skid steer, an experienced operator can tell you that it can be easy to upset earthmoving equipment like this. Because of the weighted back end, if you go too fast uphill or backwards downhill, and have the bucket lifted high enough to raise the center of gravity, you can pop a wheelie or roll completely over which makes having a proper earthmoving safety training kit important.
A correctly trained operator should know this.
OSHA forklift regulations explain the training required in 1910.178(l). It’s up to the employer to ensure their operators have successfully completed a training program under an instructor who has the knowledge, training, and experience to teach and evaluate the operator. Training should include formal instruction, practical training, and performance evaluations.
Truck related topics include: operating instructions, warnings, precautions, differences between the truck and an automobile, controls and instrumentation, engine operation, steering and maneuvering, visibility, attachment operation, vehicle capacity and stability, inspections and maintenance, refueling/recharging, and operating limitations.
Other applicable OHSA regulations include:
The employer shall instruct each employee in the recognition and avoidance of unsafe conditions and the regulations applicable to his work environment to control or eliminate any hazards or other exposure to illness or injury. 1926.21(b)(2)
The employer shall permit only those employees qualified by training or experience to operate equipment or machinery. 1926.20(b)(4)
Because this vehicle moves earth, it isn’t automatically regulated under the General Industry Powered Industrial Trucks regulation 1910.178 (forklifts), but instead fits under 1926.602 for Construction Material Handling Equipment. And there, operator training requirements are identical to the PIT training requirements — 1926.602(d).
Because they are so versatile, ladders can be the most incorrectly used tool at a worksite. Working with a ladder on a regular basis, you can become very familiar with the tool and learn how to get really creative with using it to reach some tough locations.
I’ve seen people “walking” while on a ladder: torquing their body to lift up the legs one side at a time to take steps down the wall, essentially using the ladder as if they are on stilts, instead of climbing off the ladder and repositioning it properly. I’ve also seen ladders on top of scaffolds and people standing on the top step without holding onto anything to reach that one last spot.
And in this photograph, this man is definitely putting himself in harm’s way by using the ladder incorrectly. But, because of what he may have gotten away with before, he may not understand the risks he’s taking or exactly what he’s doing wrong.
First off OSHA states that ladders should only be used only in the ways they are designed — 1926.1053(b)(4) — and this self-supporting ladder is designed to have all four legs on the ground.
“The ability of a ladder to sustain the loads … shall be determined by applying or transmitting the requisite load to the ladder in a downward vertical direction” 1926.1053(a)(1)(i)
“Ladder rungs, cleats, and steps shall be parallel, level, and uniformly spaced when the ladder is in position for use.” 1926.1053(a)(2)
And if you do correctly use a ladder on an unstable and level surface, then OSHA requires it to be properly secured to prevent accidental displacement. 1926.1053(b)(6)
Fall Protection 1926.501
Beyond incorrectly using the ladder, because the worker has more than a six-foot fall to the ground, he needs to be protected with some type of fall protection: a guardrail, safety net or personal fall arrest system. 1926.501(b)(1)
Instead of climbing into a harness and trying to find a good way to anchor the lifeline in, or hoping that the ladder doesn’t break from unusual stress, or one of the legs doesn’t slip, I would just put the roller on an extension pole and stay safely behind the railing to easily reach that last bit of unpainted wall.
The increasing diversity in today’s workplace is putting more and more focus on issues regarding language and literacy. A constant concern for supervisors and managers is determining whether their safety training for non-English speaking employees is adequate. In other words, do the workers really understand?
In April 2010, OSHA released a memorandum requiring all employers to offer OSHA training in a language that all employees understand. The new rules require OSHA compliance officers to monitor the effectiveness of on-site training for non-English speakers.
Do you or your supervisors know how to communicate safety training to employees whose first language may not be English? Do you understand the legal requirements for teaching these important policies?
Hispanic construction workers with limited English skills suffer more accidents on the job. Workers who don’t speak English, or have limited proficiency, can’t communicate as effectively with English-speaking supervisors, co-workers, or customers. They may also find it difficult to comprehend the requirements of their jobs, if conveyed in English.
Some employees may also not read English proficiently, and some may only be able to read very little in English or even their first language.
Unless these language and literacy issues are addressed by management, it can be difficult or perhaps impossible for some employees to work effectively and safely.
Language comprehension and compatibility issues can also complicate interaction and effective teamwork among employees.
This means training comprehension takes on even greater significance when the topic is safety. Inadequate safety training of non-English-speaking employees can result in lower productivity, more errors, and in injury or death.
How can managers be more confident non-English speakers understand safety training? Here are some things to keep in mind when it comes to training your non-English speaking workers:
Don’t assume employees can read. Although one way to assist non-English speakers is to display signs and posters in Spanish, although this is not always helpful. Employees with limited English skills may also be unable to read in their native language, meaning that written safety materials translated into another language would not be that useful. Consider conducting assessments on employee language and literacy ability in a lawful manner. If necessary, make sure you provide both written and verbal safety instruction to all employees.
Give them all of the training. Don’t shortcut training or provide non-English speaking workers with bare-minimum instruction on what needs to be done. Most jobs require some level of decision making. If workers don’t have all of the information, their ability to make correct decisions decreases and the likelihood of accidents increases.
Be aware of cultural differences. Cultural differences can create concerns regarding employee safety.
The meaning of certain colors and symbols may differ by culture
It might be considered rude to ask questions or question authority
Modes of dress may interfere with safe work practices
Recognizing these differences and taking them into account can be very important.
Think beyond Spanish. Many employers accommodate two languages, English and Spanish, but many workers speak other languages. If you have employees whose first language is neither English nor Spanish, you may need to provide them with the necessary training by using translation services (both written and verbal).
When training employees with limited English skills, take specials steps to make sure the training is effective:
Speak slowly, explain and repeat important points several times.
Choose the simplest words and avoid technical expressions. If you have to use technical terms, explain them as simply as possible.
When instructing employees who have only minimal or limited English skills, consider using a translator.
Another helpful step in training employees with limited English proficiency is to use visual aids, such as pictures and props, to supplement your words.
Encourage participation. Be patient and help employees express their thoughts and questions about the topic.
Have employees demonstrate new skills during the training session so you can verify they’ve understood.
Be sure to get feedback to confirm comprehension, and allow extra time for questions.
Give the trainees handouts in the language or languages they can understand.
Follow up on the job to make sure there have been no misunderstandings, and that employees correctly apply what they’ve learned.
Effective safety training is not just important to your company and workers, it’s a requirement. Know the needs of your employees, and find the best training solutions available.
A new clarification from OSHA on March 18, 2014 shed more light on why it is the employer’s responsibility to ensure an employee is a “qualified rigger” when working with cranes and derricks in construction.
Last year, an international association of bridge workers asked if a “qualified evaluator (third party)” that provides training and qualification for a signal person could do the same for a person who wants to be a “qualified rigger”.
OSHA’s answer was a heavily qualified yes, but on just the training. They said the qualified third party can provide the training, and an employer may consider the training and evaluation of a qualified third party evaluator in its assessment of the employee, but it is always the employer’s responsibility to decide whether that employee is a qualified rigger.
OSHA went on to explain, that although the third party may provide high-quality classroom and hands on instruction, they must be capable to work safely on the specific lift they are assigned to. This depends heavily on the type of rigging and worksite conditions and being able to recognize and resolve rigging issue at that particular worksite.
The regulation defines a “qualified rigger” as: a rigger who meets the criteria for a “qualified person”.
Which leads to a “qualified person” being: “a person who, by possession of a recognized degree, certificate, or professional standing, or who by extensive knowledge, training, and experience, successfully demonstrated the ability to solve/resolve problems relating tot he subject matter, the work, or the project.”
This distinction shows the difference in the standard between determining a qualified rigger and a qualified signal person. The regulation allows for documentation from a “qualified evaluator (third party)” to determine a qualified signal person, but determining a qualified rigger is ultimately up to the employer even though they can take into consideration outside training.
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: