Thursday, May 30, 2013

Is Your Facility a Death Trap?

6 Ways Small Breaches in Electrical Safety Have Shocking Results


At first it may appear that most commercial facilities are fairly safe. You’ll find OSHA-compliant safety signage, well-marked exits, clear pathways, adequate floor marking, and even a pretty good safety training program in place. But a silent killer lurks at every industrial and office facility, and every year, ignorance of its danger costs hundreds of workers their lives. In fact, industry’s systemic failure to address this hazard results in three of OSHA’s top 10 safety violations every year.
Electricity is the lifeblood that makes industry possible, powering everything from desk lamps to giant machines. Because it is so reliable and ubiquitous, workers—even trained electricians—often take it for granted. Electricity is an instant killer: One tenth of an amp of electricity traveling through a human being for only two seconds is enough to kill. Electrocution isn’t the only hazard, however. OSHA’s regulations concerning use and wiring of electricity are also designed to prevent fires that can result from faulty wiring.
The OSHA regulations related to electricity that most employers are cited for are 29 CFR 1910.147 (Lockout/Tagout), 29 CFR 1910.303 (Electrical General Requirements) and 29 CFR 1910.305 (Electrical Wiring Methods). Let’s put on our compliance officer’s hat and go over six typical electrical hazards. We bet that if you do a thorough review of your facility, you’ll find at least one problem to correct.

1. Extension Cord/Power Strip Issues

For starters, extension cords are meant for temporary use only. OSHA compliance officers commonly cite for this issue. “If it is obvious it has been there for an extended period of time they can cite it as temporary wiring in place of permanent,” said safety consultant Jonathan Brown, of Advanced Safety & Health in Louisville, KY. What’s the threshold between temporary and permanent? Ninety days, and only for temporary holiday décor such as lights. Here are some other extension cord issues:
  • Damaged cords: Knicks, cracks, frays, and shorts can render a cord useless or worse, an electrocution hazard. Destroy damaged cords and purchase new ones. Running them through walls or across walkways damages them. Try stringing them overhead.
  • Daisy-chaining extension cords and power strips: Plugging one extension cord or power strip into another reduces the wattage capacity of each cord and creates a fire hazard. Now that surge-protected power strips with cable lengths of 10-25 feet are commonly available, the need to daisy-chain is eliminated. If you need additional electricity, hire an electrician to install power outlets where they are needed.

2. Amateur Wiring/Grounding Issues

Electricity is simply too dangerous to trust to amateurs. Cutting off the grounding plug to a power or extension cord or splicing together a couple of cords might seem harmless, but doing so can have lethal consequences to an always-unsuspecting worker. Case in point: A Chinese immigrant restaurant owner and his wife were refurbishing their new restaurant, and he had replaced the electrical cord to a glass-fronted cooler by splicing a 10/2 wire to a one-foot length of extension cord plugged into a wall receptacle. He never saw the ground wire on the 10/2 cord come loose and when he contacted the metal frame of the cooler and an adjacent metal stove, he was electrocuted.
In another case, a 20-year-old lifeguard at a large apartment complex was electrocuted when he entered the pump house to adjust the chlorine pump. Tragically, the metal pump motor housing had become energized with 220 volts—it wasn’t grounded properly, and hadn’t been approved for wet locations such as the pump house.

3. Inaccurate Labeling

 

It’s critical that electrical circuits are accurately labeled, and that switches, cabinets, arc flash hazards, etc. leave no room for confusion. How accurate and easy to read is the labeling on your facility’s electrical panels?
The story of a 32-year old maintenance worker illustrates this point: He had been asked to change a broken metal halide bulb in a ceiling fixture and had taken several precautions, including studying the “as-built” plans so that he could de-energize the circuit. However, the plans were not accurate and he was electrocuted when he used an uninsulated tool to remove the broken bulb. He had turned off a breaker, but it was mislabeled and the circuit was still energized.
Labeling switches and other components is critical too. A 43-year-old man testing the insulation on a conduit coil was electrocuted because of a faulty cable repair. However, a coworker was unable to de-energize the coil tester because the power switch was not labeled.

4. Openings in Electrical Enclosures

All the unused openings in an electrical panel have to be closed, including unused slots for breakers and knock-outs. If the opening isn’t replaced with a blank, a shock hazard exists if someone places a finger into an open slot.

5. Lack of Training and Electrical Safety Program

Nearly every electrocution or electrical burn suffered by workers could have been prevented had they been properly trained and followed standard operating procedures.
NFPA 70E (Article 110) and OSHA both spell out training requirements for electrical workers. The standards mandate that electrical workers are considered “qualified” when they know how to use a voltage detector and have specific knowledge and skills. According to these standards, employers must provide a documented electrical safety program that spells out safe work practices for employees. In addition, employees must be periodically retrained and the safety program audited for effectiveness.

6. Look! Up in the Sky!

Many electrocutions occur as a result of contacting overhead power lines. Whenever starting an electrical job, conduct a hazard analysis that takes into account location of nearby power lines. Poles, pipes, ladders, and other lengthy items held aloft are tall enough to convey a deadly jolt to a hapless worker.

10 Tips for Safe Electricity

  1. Always use a licensed, bonded electrician for any electrical work in your facility.
  2. If you have not tested your circuitry, have it analyzed for safety and thoroughly labeled.
  3. Treat all conductors as dangerous until they are locked and tagged out.
  4. Regularly inspect all electrical tools.
  5. Use ground fault circuit interrupters (GFCIs) and overcurrent protection devices.
  6. Review your electrical safety program.
  7. Avoid using ungrounded home appliances and overuse of extension cords in the office environment.
  8. Have fire extinguishers rated for electrical fires easily accessible.
  9. Use non-conductive ladders when doing electrical work.
  10. Never allow workers to do electrical work without the proper personal protective equipment (PPE).

Carrots and Sticks: Do Safety Incentive Programs Really Work?

OSHA Ruling Puts Safety Incentive Programs in the Spotlight


On April 9, the General Accounting Office (GAO) released a study of workplace safety incentive programs that found little evidence that they affect safety one way or the other. However, the GAO recommended that OSHA make a ruling on incentive programs, and OSHA’s subsequent recommendation was to regard certain kinds of safety programs as impediments to worker health. Was this the correct approach? Let’s look at some different kinds of safety incentives and see what works.

Rate-Based Safety Programs—The Carrot

We’ve all seen variations on the sign at a manufacturer or warehouse stating, “126 days without an injury.” This is usually indicative of a rate-based safety program, which offers rewards for low injury rates. Often the whole staff or a particular team is given a pizza party or some other reward for not getting injured on the job. Many safety experts believe there could be an unintended effect: pressuring employees not to report the injuries they do get for fear of negative consequences. OSHA’s recommendation targets rate-based safety programs based on the likelihood of this unintended outcome. 

Behavior-Based Safety Programs—The Stick

 “Behavior-based safety” was coined in the late 1970s and became the rallying cry for new safety programs that staged observers to notice both the at-risk and safe work habits and provide feedback. In behavior-based safety, reports of worker behavior are compiled, trends noticed, and recommendations made. However, many believe these programs have evolved into a “blame the worker” approach that erodes morale and is costly to implement. An oft-cited criticism of behavior-based safety programs is that all too often they focus on changing the behavior of workers, when in fact the system that causes the behavior is left unaddressed. Many safety experts also believe behavior-based safety programs are enacted as a “silver bullet” by management as a substitute for a true culture of safety. OSHA’s recommendation validates behavior-based safety programs.

True Safety Culture—the Approach that Works

Differences between Positive and Negative Safety Culture

Positive Safety Culture
Negative Safety Culture
Safety is an asset.
Safety is a liability.
Workers want to work safely.
Workers can’t be trusted.
Evaluate the entire system first.
Evaluate the worker first.
Workers know how to improve systems.
Workers’ ideas will cost us money.
Address hazards immediately.
Enact workarounds and hope no one gets hurt.
People/Safety more important than production.
Production more important than people/safety.
Employees rewarded for good safety ideas.
Employees are disciplined using safety rules.
Communication is encouraged between all levels.
Fear or intimidation inhibits open communication.
Well-being is valued (people over appearance).
Safety record is valued (appearance over people).
Management plays by the same safety rules.
Management is above the rules. 
Companies with truly exceptional safety records take a different approach from that of rate-based safety incentive programs or typical behavior-based safety programs. Such companies, such as OSHA VPP Star-certified organizations, build a true culture of safety by involving management at the highest level of the company, the workers at the lowest end of the pay scale, and everyone in-between. Safety culture recognizes that both the keys to safety and the impediments to safety are primarily cultural, which is to say that the company’s core values drive safety.

Executive Buy-In

The most critical component of a positive safety culture is the complete buy-in by management. If senior management allows unsafe conditions to persist in a workplace, a belief is created that unsafe conditions are acceptable and that there is something more important than people and their safety. Conversely, if safety is seen as a dominant value in the company, employees will prioritize it.

How to Achieve Executive Buy-In

Appeal to bottom line: When approaching executives with safety data and initiatives, calculate and demonstrate time lost because of injury/illness as well as increased workers’ comp premiums as direct costs against productivity and profit margin.
Appeal to line managers: When meeting with line management, ask how safety can benefit their individual business objectives. It’s important to demonstrate that safety initiatives are an asset that will benefit them rather than hinder them.
Get a second opinion: Often, it takes an outside assessment to gain credibility. The company safety officer may seem biased, but it’s hard to argue with the report of a paid consultant or data provided by employee climate surveys or sensing sessions.
Use what already works: It may work to bring safety and health objectives into business structures that are already found to be effective, rather than creating new structures that must be learned and bought into.

Employee Buy-In

Once management has bought into the value of a top-notch occupational health and safety program, it’s their job to make sure the message gets out—both in word and in deed. Posting safety slogans on the lunchroom wall does not equal good safety communication.

How to Achieve Employee Buy-In

Give authority to the safety committee: The safety committee, which is made up of both management and employees, must be authorized to enact changes and make expenditures to improve and elevate safety.
Give employees a voice: Put a structure in place that ensures that every single safety idea, report of an incident, or report of a near miss is heard by management, given careful consideration, and responded to directly. Thanking the employees who do so is effective, and it should be emphatically communicated that no employee will be penalized in any way for reporting an issue. It is illegal to do so.  
Deputize the “true believers”:  Find representatives from management and employee ranks who are passionate about safety, and involve them in safety problem solving, the safety committee, safety training, and other tasks that allow them to make a difference.
Reinforce the message: Use job hazard analyses to discover the hazardous ways your workers do their jobs, and use the information to provide adequate training on how to perform their tasks safely. In addition, use safety signs and labels throughout the facility to underscore necessary work processes and precautions.
Address the system: Change work processes and any other factors that motivate employees to take shortcuts or engage in any risky behavior. There must be no penalty for doing something the safe way, even if it takes more time. This cannot be emphasized enough.
Solve ergonomic problems: Part of safety training is teaching workers how to use their bodies properly. Not only does this include the “heavy lifters,” but also those who sit at desks all day. Providing ergonomic assessments and equipment for optimal desk posture lets office workers know that their safety is taken seriously too.
Reward with recognition: The best recognition employees can receive is the acknowledgement from management and peers that they are doing a good job by being safe. This works better than pizza parties, T-shirts, and trophies.

Oregon Energy Company Gets Safety’s 'Gold Medal,' Sharply Reduces Injuries

Covanta Marion's Eileen Tanner Explains How to Be a Safety 'Star'

Workplace safety is a lot like sports.
On one side of the spectrum are the “fans” who play a game every so often but spend most of their time watching sports on the TV. On the other side of the spectrum are the Olympians. The difference: Olympians wake up every day and eat, drink, and think their sport.
Workplace safety works the same way. Some companies “talk a good game,” and others go for the gold medal—eating, drinking, and thinking safety. For those employers, OSHA’s Voluntary Protection Program (VPP) is the equivalent of the Olympic Games, and Star designation is the gold medal. “Olympian” organizations like Delta Airlines, Coca Cola, GE, U.S. Postal Service, Georgia Pacific, L.L. Bean, and many others have seen such benefits as improved worker retention, higher productivity, better morale, and lower workers’ comp rates as a result of their participation in the program, which brings employees and management together with OSHA to improve safety culture and practices.

Profile of a Safety Star: Covanta Marion

Located in Brooks, Oregon, just a few miles north of Salem, Covanta Marion’s Energy from Waste (EfW) facility has been processing waste for county residents since 1987. Its 39 employees process 550 tons of waste per day and generate 13.1 megawatts of renewable energy using complicated and dangerous machinery. The Covanta Marion EfW plant is one of several VPP-designated plants operated by the parent company, Covanta Energy.
VPP “Star” status (the highest VPP accomplishment) was awarded to Covanta Marion in 2009, and safety performance has only improved: In 2008 the company’s Total Case Incident Rate (TCIR) per 100 workers was 2.91 and Days Away, Restricted and/or Transfer Rate (DART) per 100 workers was 1.79. By 2012 both rates were sharply reduced to 0.77 and 0.46.
Eileen Tanner, safety specialist at Covanta Marion, was an active participant in fulfilling the rigorous VPP program requirements. DuraNews recently had the chance to ask Eileen about what it takes to be a VPP Star.
DuraNews: How did Covanta Marion prepare for VPP?
Eileen Tanner--Covanta Marion
Eileen Tanner

Tanner: Covanta Marion was in OSHA’s SHARP (Safety and Health Achievement Recognition Program) for three years, at which time we were also preparing for VPP certification. We graduated from SHARP and received VPP Star recognition on the same day. The final year in SHARP was devoted to the application process, responding to all of the VPP elements. We worked with Oregon OSHA consultants as well as our corporate consultants in preparing for VPP. This meant going above and beyond OSHA regulations to achieve a world-class safety program, which is what VPP is all about. Every aspect of plant safety was reviewed, deemed in compliance and/or improved upon. It took every facility employee to make this happen.
DN: How did Covanta Marion go “above and beyond?”
Tanner: We found issues where we didn’t think there were any and collaboratively came up with workable solutions to correct them. We looked at safety as a whole and not just the pieces. If an issue was identified then we had to ask ourselves why—as in, why was it there, why was it allowed, why hadn’t it been identified previously, why wasn’t it fixed, etc. to address all the reasons and not just simply fix something and move onto the next thing.
DN: What was the key element of Covanta’s success?
Tanner: It was the collaboration of employees and management working for the same goal. Employees own the program and have submitted numerous safety improvement projects and suggestions. That being said, management support is vital, from our president and CEO to line managers. Managers fully believe in protecting our most important asset—our employees. We’ve had full financial and moral support from upper management in going through the process. With 42 VPP sites, it’s obvious that safety is a major priority for Covanta Energy. 
Typical VPP Improvement
  • Days Away Restricted or Transferred rates at 52 percent below industry average
  • Reduced workers’ comp costs
  • Better communication between management and employees
DN: What were some of the major initiatives Covanta completed to achieve VPP?
Tanner: Working on the hopper cameras previously required an employee to work from a ladder above the feed chutes, which created not only a fall hazard but a potential engulfment hazard. We ended up cutting a hole in the charging deck wall to the plant interior grated walkway and installing the camera on swing arms. Employees can now work on cameras without being subjected to a fall hazard. An employee received an “Excellence” award for this suggestion.
We engineered and installed a fall protection system for working on the gear boxes at the cooling tower.
A new feed chute cover used during boiler maintenance now has a fan installed in it to move air through the boiler, ensuring that there’s good ventilation for employees working inside, while preventing anyone or anything from entering the feed chute.
DN: What were some of the smaller improvements you made?
Tanner: We installed toe-boards on swing gates to prevent materials from falling to lower levels. We welded non-skid treads on all fixed ladders. And we installed hooks around the facility for suspending cords and hoses. This kept them out of walkways where they had become tripping hazards.
DN: What role does visual communication play at the Covanta Marion plant?
Tanner: Almost everything in this facility has a sign or a label.  All piping, fill lines, some equipment, etc.  Also, warning, caution, and danger signage is used for various hazards such as confined spaces, acid, caustic, tipping floor rules, etc.
DN: What advice do you have for companies looking to improve their safety record?
Tanner: There shouldn’t be any overlooked aspects when it comes to safety. At Covanta, we employ safety procedures and jobsite analyses (JSAs) for direction. All businesses must, at a minimum, review their entire facility and processes, identify which regulations apply, and be in compliance at all times. Of course, you need to let the employees lead and have total buy-in from management.

OSHA’s General Duty Clause: What Every Employer Needs to Know

And What It Means to Be a “Hazardology” Student


"Each employer shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees."—29 U.S.C. § 654, 5(a)
Imagine OSHA’s standards as a toolbox full of tools meant to address workplace hazards. It’s a large collection with specialized tools to work with such well-known issues as scaffolding, safety signs and labels, arc flash, and hazardous materials—the equivalent of OSHA’s socket wrenches, screwdrivers, saws, and drill bits. But as every handyman knows, a set of pliers is the most versatile tool in the box.
OSHA’s set of pliers is the General Duty Clause (29 U.S.C. § 654). And just like a set of pliers, the General Duty Clause (GDC) can be used to do the job where other tools don’t quite fit. For the GDC to be invoked in a citation, the following must all be true:
  • There must be a hazard.
  • The hazard must be recognized.
  • The hazard causes or is likely to cause serious harm or death.
  • The hazard must be correctable.
Those criteria cover almost every hazard you can think of, although most hazards are already covered by specific OSHA standards. In OSHA’s reasoning, if there’s a correctable, recognized hazard and only if there’s not a specific code addressing the hazard, then it’s time to get the pliers.

Recognition Is Key

The phrase that most industry-watchers pay attention to in the General Duty Clause is “recognized hazard.” What is a recognized hazard, and what is not?
First, let’s look at what’s notrecognized. OSHA considers terrorist attacks non-recognizable. A large sinkhole that suddently enveloped part or all of a building without any warning might be considered non-recognizable. Hazards that are commonly recognized in one industry (e.g., the chemical manufacturing industry), that are unheard of in another (e.g., a retail clothing store) might be considered not recognized at the clothing store.

Your Hazards Are All Recognizable

… for practical purposes, anyway. OSHA’s communication over the past few years has stressed hazard awareness, and the agency has published information aimed at helping employers predict or recognize hazards, such as combustible dust or increased exposure levels certain chemicals.
According to OSHA, the following are indicators that your company has recognition of a hazard:
  • Written or oral statements made by management or employees during or before an OSHA inspection
  • Any written documentation acknowledging the existence of a specific hazard
  • Prior inspections or citations related to the hazard
  • Employee complaints about the hazard
  • Actions taken to address the hazard, if those actions failed to adequately abate the hazard
In addition, OSHA considers recognizable any hazard that has been recognized within the employer’s industry, or governed by that industry’s standards. In essence, OSHA is saying that if others in your industry know about the hazard, then it’s your job to know about it, too.
Some indicators of industry recognition include:
  • Studies about the hazard published by industry, union, insurance, or government groups
  • Published standards within the industry pertaining to the hazard

Dumping Bricks off the Roof? Really?

In addition, OSHA applies a “common sense” metric to whether or not a hazard is recognizable under the GDC. The agency’s revised Field Operator’s Manual (2009) specifies this form of recognition only in “flagrant or obvious cases,” such as using an unenclosed chute to dump bricks 26 feet down to an alleyway where unwarned employees are working. 
Sounds good, right? It is. The more hazards can be recognized and measures taken to reduce them, the fewer the workplace injuries.

The Flipside of Hazard Recognition

Since practically any hazard your employees face is considered “recognized,” it should be apparent that you need to be a student of “hazardology”—the study of all the hazards possible within your industry and your facility. Otherwise you may be endangering your employees with hazards that run afoul of the General Duty Clause.

Become a Hazardology Expert

Here are some ways to bone up on your hazardology: 
  • Get a tutor: Try bringing in a safety consultant or industrial hygienist to do a safety inspection. By asking questions and addressing the findings, you will increase your expertise substantially. Your workers’ comp insurer may be able to send one of their own experts.
  • Talk to the professor: OSHA’s Consultation Program—completely separate from its enforcement program, will send an OSHA-approved consultant to your business for a safety consultation, no citations issued. Geared toward businesses of 250 employees or fewer at a single site, or less than 500 company-wide, the program offers no-cost safety consultation with the main stipulation being that you must address the hazards. You can also qualify for the coveted Safety and Health Achievement Recognition Program (SHARP).
  • Do your homework: Subscribing to (and actually reading!) industry publications will shed light on what other businesses in your industry are dealing with.
  • Research the codes: Not just OSHA codes, but NFPA, ASME, ANSI, and others as they relate to your business.
  • Listen to your employees: Your “boots on the ground” workers often know better than anyone the hazards they face. Do everything possible to ensure open lines of communication, never allowing an employee to suffer negative consequences when reporting a hazard—even a big one that would be costly to remedy.

Danger on the farm

Common agricultural hazards and how visual communication can help


For many of us who live in cities, food-producing farms are an abstraction, evoking imagery of green pastures or rows of crops, a red barn, a grain silo and placid animals. The reality is far different: heavy lifting, machinery use, hazardous materials (pesticides and other chemicals) and driving on rough terrain are the reality for the typical farmer and farm worker. It may surprise many non-farmers to learn that the hazards found in agriculture are related to many common hazards found in general industry. The difference is that it often takes an ambulance longer to reach the injured farm worker.
Kevin Pfau
Kevin Pfau
DuraNews recently caught up with Kevin Pfau, senior safety management consultant at SAIF Corporation, a major workers’ comp fund in Oregon, to ask him about farm safety. Kevin teaches about 20 agricultural safety seminars throughout Oregon every year and understands better than most the everyday hazards faced by farmers and farm workers.


DuraNews: The U.S. Bureau of Labor reported that farming was the fourth deadliest profession in 2011, with more than 41 deaths per million workers. Based on your experience, what are the most common lethal hazards?
Kevin Pfau: There are many. Immediately I think of equipment hazards, especially machinery entanglements and tractor overturns. Grain bin entrapments are also responsible for many deaths. Electrocution is quick and deadly hazard, often caused by tall equipment like grain augers, tractors with front-end loaders, forklifts and large combines that come into contact with overhead lines. And farm animal incidents, such as falling off horses or getting charged by dairy bulls, can also cause fatalities.
DN: What are some of the most overlooked agricultural hazards, and how can they be avoided?
KP: I know of an incident where a squirrel was hiding in an irrigation pipe and the farmer was helping a worker shake it out. Unfortunately the pipes were stacked right under a power line. The worker was electrocuted and died; the farmer was injured. Give power lines their proper respect and always use pre-planned routes that avoid power lines when moving equipment.
 With respect to livestock, dairy bulls may be very expensive but they need to be put down once they become aggressive. They will attack and kill with the slightest provocation.
Tractor overturns are the leading cause of agricultural deaths in the U.S., but fatalities would be reduced by 71 percent if all tractors in the U.S. had roll-over protective structures (ROPS). My family’s onion farm is a case in point. Due to the low profit margins, and my family’s resistance to buying anything new when the old tractor still worked, we used older model tractors without rollover protection for decades. We were lucky nothing happened. Older models should be used for light loads on level terrain by experienced operators.
Another often-overlooked hazard is ATV use. Quads are a high risk way to move people. In many cases quads are used when pick-up trucks or RTVs (ATVs with rollover protection) would be much safer choices. Especially when younger drivers are involved.
DN: With respect to visual communication (signs and labels), what are some of the most important ways they can be employed at some of the farms you’ve seen?
KP: The most important signs are ones that are placed as an instructive reminder on or near serious hazards. For example, adhesive labels on forklifts could read, “No riders.” Other ideas: “Forklift only,” “Pinch-point,” “Apply parking brake” or “Slow: High-traffic area.” GHS*-aligned Hazcom labels with pictograms are also very important when dealing with pesticides or other hazardous materials. Instructive signage should be duplicated in Spanish at farms that employ Spanish-speakers.
DN: If visual communication is an underused safety tool, why is that?
KP: Inconvenience and cost. When farmers understand the importance of proper signage and labeling requirements, and when these signs are made readily available, however, they prove to be popular.
DN: Can you point to any particular agricultural tragedy that could have been avoided if proper visual communication were implemented?
KP: I visited with an employee who used a propane-powered forklift to organize bins in a cold storage room. After first suffering from a severe headache, he lost consciousness and was rushed to the emergency room where he was treated for carbon monoxide poisoning. He almost lost his life. Six months later, this same type of incident occurred with another employee. Only after the second incident did the employer provide training and install the sign: “Warning: No propane forklift in cooler.”
* GHS: The United Nations’ Globally Harmonized System (GHS) for the Identification and Labeling of Hazardous Materials requires a label with signal word, pictograms, hazard statements and precautionary statements.
Try the DuraLabel Toro for any labeling task on the farm, in the field, or in the warehouse. The Toro has a 3.5-hour continuous-print battery life and requires no computer or outside power source to operate.

OSHA training: What every employer should know

Perhaps the most overlooked aspect of industrial safety is the need for proper training of workers and supervisors. OSHA addresses this need through a series of regulations—many industry-specific—and coursework through OSHA Outreach designed to help safety sink in.
OSHA Outreach courses are either 10 hours (for entry-level workers) or 30 hours (for supervisors or others with safety responsibilities). Content is delivered by independent trainers who meet OSHA’s requirements. Some courses are conducted in a classroom environment and many courses are taught online.
According to OSHA, employers should provide training not as a blanket solution to all safety and health issues, because engineering controls, proper OSHA-compliant safety signage and hazard abatement can make the need for training in certain subjects unnecessary. But some training and education are always required. 
DuraNews recently spoke with Mark Moran, author of The OSHA Answer Book (now in its 11thedition), to ask him about OSHA training.
DuraNews: Does OSHA require that every employee be trained?
MM: OSHA’s General Duty Clause, to some extent, requires training for all jobs where a lack of training can lead to injuries. However, in certain cases, employers must provide adequate training before an employee begins a job, as is the case with operating a forklift. Some jobs require workers to be certified, competent or qualified to do a job. Construction, maritime, agriculture and general industry workers have specific requirements.
OSHA expects companies to produce written proof of a training program that addresses all aspects of safety, including fire safety, hazard communication and disaster plans. Dates, sign-in sheets and names must be recorded and kept for each training session provided. 
DN: Why go with OSHA training instead of providing the training yourself?
Mark Moran: OSHA doesn’t insist companies take their training, but is very insistent employees are trained sufficiently. Some larger companies have the capacity for that—some even have their own training departments—but few are set up to provide 10- or 30-hour training. If an OSHA safety inspection occurs, the real question is “Was this employee properly trained?” and not “Did this employee receive our training.” With the authorized instructor, the assumption is that the training is thoroughly adequate, and there’s an official record that the training was done, should the training program ever be called into question by OSHA or the courts.
DN: What about companies that can’t afford in-depth training?
MM: Smaller companies generally won’t get audited by OSHA unless there’s a specific complaint or other specific safety problem that comes to light. So they can make the mistake of skipping training (and hope OSHA never knocks) or they can provide OSHA-accredited online training to their employees. If the company has resources for it, they can provide on-the-job training that fully addresses all risks and hazards present in their workplace.
DN: What are some of the specific risks that result from cutting corners?
MM: First of all, workers are placed at risk. Say your company works with hazardous materials but fails to adequately educate every employee about the health risks of every single chemical in the facility. An employee who has respiratory issues could open a container and suddenly find herself in the midst of a full-blown asthma attack. Had she known of the hazard beforehand, she would have informed her supervisor that she couldn’t be exposed to that material.
Secondly, there’s risk the company could be sued. If an employee can demonstrate he or she was not properly trained, that creates a great liability—a potential game-changer for a small business. And certainly workers’ comp claims can cause premiums to rise.
Large and mid-sized companies face those risks as well, plus they're much more likely to be visited by OSHA and receive a citation.
DN: What kind of fines are we talking about here?
MM: It’s considered a “serious violation” and could bring fines anywhere from $1,000 to $100,000, depending upon whether an employee was seriously hurt as a result of negligence in training.
DN: What do employers need to know about educating non-English-speaking or undereducated employees? 
MM: Per OSHA, employees who receive job instruction in a foreign language must receive any Hazard Communication Standard information (or any safety information, for that matter) tailored to their language and literacy level. Courts have backed OSHA up on this.
DN: What are some of the most popular OSHA training courses?
MM: OSHA has annual or refresher requirements for several subjects, including bloodborne pathogens, asbestos, several chemicals and hazardous materials, grain handling, CPR, respiratory and even hearing protection. There are some annual agricultural training requirements like tractor rollover protective systems, machine guarding and cotton dust.  This is by no means a complete list! But the annual requirement courses would probably be the most popular.
DN: So let’s say I’m an employer deciding whether to put my employees in a classroom course or in online training. How should I decide?
MM: Time and money are your two main considerations. Can you afford to take a team out of production and put them in class for a few days? Will the training offer enough value to actually prevent injuries and other mishaps, more than the online training? If so, go with the classroom course. Can you find or design adequate online training, and do you think your workforce will really learn what’s needed from it? Then go with online. You may well find that you can offer a combination of both. Weigh the liability of inadequate training against whatever it costs in time and money to have a properly trained workforce.
Mark Moran
Mark Moran
30% OFF THE OSHA ANSWER BOOK: Mark Moran is making this time-saving book available to all recipients of DuraNews at a special discounted price. DuraNews subscribers can purchase The OSHA Answer Book (11th edition) at a special price of $39.95, a $20 discount. Contact Moran and Associates at 904-375-9422.
Mark Moran is certified by the U.S. Department of Labor as an accredited instructor in compliance with OSHA requirements. He is president of Moran Associates, a management consulting firm that specializes in occupational safety and health.
Interested in educating yourself about OSHA's sign compliance standards? Request ourOSHA Safety Sign Best Practice Guide today.

The Top 10 Safety Fails of 2012

…and 10 ways to succeed in 2013

Every October at the National Safety Council's Congress & Expo, OSHA releases its top 10 safety violations based on the preceding fiscal year. Because the same 10 “usual suspects” tend to populate the list every year—albeit in a different order—it’s evident there’s something about these issues that compels many companies to avoid complying. It’s a repeating theme with few variations.
2012
2011
Citation and statute
No. of citations
Citation
No. of citations
1.
Fall protection (1926.501)
7,250
Fall protection
7,139
2.
Hazard communication (1910.1200)
4,696
Scaffolding
7,069
3.
Scaffolding (1926.451)
3,814
Hazard communication
6,358
4.
Respiratory protection (1910.134)
2,371
Respiratory protection
3,944
5.
Ladders (1926.1053)
2,310
Lockout/Tagout
3,639
6.
Machine guarding (1910.212)
2,097
Electrical wiring methods
3,584
7.
Powered industrial trucks (1910.178)
1,993
Powered industrial trucks
3,432
8.
Electrical wiring methods (1910.305)
1,744
Ladders
3,244
9.
Lockout/Tagout (1910.147)
1,572
Electrical system design
2,863
10.
Electrical general requirements (1910.303)
1,332
Machine guarding
2,556

No one sees it coming
…except the OSHA inspector—and that safety-conscious employee who brought it up once, the employee who cut his hand and didn’t mention it and that other employee who had a near miss. In other words, plenty of people see the possibility of a workplace injury happening. But too often, it’s only after a company is cited or someone is seriously hurt that management realizes they’ve put safety on the back burner for too long.
Back on the front burner
Companies that view safety as not only the right thing to do, but also an effective productivity tool, retain their best employees. They also have fewer worker absences and lower workers’ comp premiums than those that treat safety as a burden. Prioritizing safety at your company may seem like a difficult expense, but the price of a serious injury (both psychologically and monetarily) is much higher for all parties—injured workers, their co-workers, family and employer. So if you are ready to put safety on the front burner of your company, here are 10 ways to get started (and avoid these common safety fails). Note that the statutes listed in the table provided above include much more information; following the suggestions below doesn’t ensure full compliance with OSHA’s statutes.  
1. Fall protection: According to OSHA, fall protection should be provided at elevations of four feet in general industry workplaces, five feet in shipyards, six feet in the construction industry and eight feet in longshoring operations. If you have employees working or walking alongside elevated open-sided walkways or platforms, the edge of that walkway/platform must include a guardrail system and toe-board. Avoid having any “unprotected sides and edges” in your work environment. On construction sites a safety net or some kind of personal fall arrest system must be used.
2. Hazard communication: The adoption of the GHS-aligned HazCom 2012 standard means a lot of big changes, so read the rule in its entirety. Provide your employees with information and training on all hazardous chemicals in their work area at the time of their initial assignment, and whenever a new chemical hazard the employees have previously not been trained on is introduced into their work area. Replace MSDS sheets with GHS-compliant Safety Data Sheets (SDSs) and use GHS/HazCom 2012-compliant labels for all containers. Read the article (LINK) in this edition of DuraNews and request our freeHCS/HazCom 2012 Labeling Best Practice Guide to help you make the transition.
3. Scaffolding (construction): The construction scaffolding rule has standards relating to scaffold design, inspection and fall protection, all of which save lives when observed. It’s important to remember that workers must have proper fall protection when they are on raised surfaces; this can mean guardrails, personal fall arrest systems or a combination of both. Note that there are also different requirements for fall protection depending on the type of scaffold.
4. Respiratory protection: Have dust, fog, fumes, mist, gasses, smokes, sprays or vapors? Then according to OSHA you must provide the appropriate respirator to each employee as part of a respiratory protection program administered by a “suitably trained program administrator.” The program must include worksite-specific procedures for required respirator use.
5. Ladders: Make sure your ladders are compliant with this rule, which covers both fixed and portable ladders. Common issues include non-parallel positioning relative to landings, too much or too little space between rungs, inadequate landing size and ladder bases more than 12 inches off the ground. Ladder capacity and conductivity are also addressed in this rule.
6. Machine guarding: Machine guards protect workers’ limbs, skin and eyes from nip points, rotating parts, flying chips and sparks. Guards may include barrier guards, two-hand tripping devices and electronic safety devices. Go through all work areas where there are power tools, stationary machinery with moving parts, etc., and ensure there is an appropriate buffer between the worker and any moving parts and projectile fragments. Be sure to check out the article on machine guarding in this issue of DuraNews.
7. Powered industrial trucks: This rule addresses several potential disasters. If you ensure that your forklifts and other industrial trucks are in top mechanical order, and that your operators are all trained and certified to operate the vehicles safely, you will have satisfied two of the main requirements, but read the whole statute for the big picture.
8. Electrical wiring methods: Grounding of electrical equipment, wiring and insulation and temporary wiring and splicing are all subject to this rule. Violations frequently occur when wiring is sloppy or when temporary wiring is used as if it were permanent. Trusting all your wiring to a licensed, bonded electrician and avoiding the permanent use of extension cords will help you avoid electric shock, fire hazards and other problems.
9. Lockout/tagout: If you have machinery or equipment that can unexpectedly energize, start up or release stored energy, you need to have a lockout/tagout program designed to protect workers from being in the wrong place at the wrong time when the machine starts to move. Use professional-grade lockout and tagout supplies; obtain full participation from authorized employees and educate others who could be affected by the program.
10.  Electrical general requirements: Avoid using consumer-rated appliances in a commercial work environment; most aren’t grounded, nor are they intended for continuous operation. Using indoor-rated electrical receptacles outside as well as having exposed electrical wiring, unguarded receptacles and unguarded fluorescent lighting are all grounds for citation because of the fire and electrocution hazards they pose. To be OSHA-compliant, leave wiring to the pros and leave the consumer-rated appliances at home.
Graphic Products offers several products to help employers promote safety and compliance and avoid many of these common safety fails. Besides HazCom and  GHS labels, Graphic Products offers personal protective equipment; OSHA-compliant danger, warning and caution labels and Lockout/Tagout supplies.