Environmental Health and Safety Blog | EHSWire

by Paula Kaufmann

I have attended some incredibly mind-numbing courses over my lifetime.  The worst course ever was in high school American History when we were “taught” about the FDR Years (1933-45) from an endless series of film strips with audio from a synchronized record. Recently, I attended a full-day, on-demand technical class that immediately transported back to that American History lesson. Needless to say, this comparison does not reflect well for this recent course.

I find I don’t take away much from a course that does not engage me. This could be because the topic is inherently dull, the material is presented in a monotonous or non-engaging manner, or I simply can’t connect with the material or the instructor.  I’ve often joked that I am easily entertained (after all, I am a chemist by training!), but dull, monotonous and distant often leave me with zero recall of the main points, and the details, well, those never seem to penetrate my numb mind!

On-line or Classroom HazWOPER?

In a previous EHSWire blog, Vijay Chintamaneni noted, “ When evaluating the courses based on their published description, Online Training and Instructor Led Training (ILT) may look the same, so it is wise to understand the benefits and drawbacks of both before making a final decision. This is especially important for occupational health and safety training.”

So, when I am asked for my thoughts on whether to attend an on-line or instructor-led HazWOPER training class, my immediate response is clear!  It is CRITICAL to actually learn what is taught in these classes not just fulfill the OSHA requirement.  Why? These workers will be working on a HAZARDOUS WASTE SITE, and the knowledge learned in a HazWOPER class allows them to appropriately protect themselves. Students in a HazWOPER class must be engaged in this particular occupational learning as the material is inherently dry and dull.  The best way to imprint essential HazWOPER components such as risk assessment, hazard information, team emergency response and the practical learning, is from discussion, hands-on and group exercises.  

Training experts insist that hands-on training is the best way to learn!

Consider these situations the next time you consider online training to meet your HazWOPER requirements:

• Would you SCUBA dive in the Florida Keys after completely an on-line SCUBA diving lesson (without ever handling the equipment on land or even in a pool)?


• When you call 911 – would you trust an emergency responder that recently received CPR training on-line  without any practice or instructor guidance?


• Would you lend your car to a friend who just learned to drive by completing an on-line driving class?


• If folks need to be trained to work as a team with a command/response structure – how successful can team training be when individuals are trained in isolation?


• How many other things do you do while you are “attending” an online course?


• Do you really want the guy next to you at the hazardous site to be responsible for your health after taking critical health and safety training…online?

Why the Emilcott Training Institute? Because you will LEARN and be prepared!!

Emilcott offers quality HazWOPER health and safety training that prepares workers for the real world by keeping them engaged and interested in the materials! Our HazWOPER instruction combines classroom knowledge with interactive, hands-on activities, respirator fit-testing, individual and group activities, and a simulated, outdoor hazardous waste operation complete with “what if” scenarios and instructor guidance.

• The Emilcott 40-hour HazWOPER mock drill is chock full of “what if” scenarios such as unidentified hazards, nosy neighbors, health and safety incidents, decontamination exercises, use of instruments, and more.


• We film our mock drill and then evaluate the results in class.


• We have taught thousands of HazWOPER training classes – many of them for the US Armed Forces in the states and Europe.


• Our 8-hour Site Supervisor course concentrates on group exercises and managerial experience to reinforce essential skills needed to ensure the health and safety of the crew while getting project work completed without incident.


• We interview our students to ensure that the materials presented are as applicable to their job function as possible.


• Our annual 8-hour Refresher is revised each year to ensure well-rounded exposure for our repeat students.


• We train students, but we do not pass students who don’t qualify!

What is the importance of a good instructor?

Emilcott HazWOPER instructors are field-experienced health and safety professionals who have seen it all!  In fact many of our instructors have been working on hazardous waste sites and training for over 25 years. Emilcott instructors consist of

• EHS Specialists


• Certified Industrial Hygienists (CIH)


• Certified Safety Professionals (CSP)


• Certified Hazardous Materials Managers (CHMM)

As HazWOPER instructors, their job is to review the OSHA-required materials in such a way that students can remember the materials and apply them to their job.  Through a variety of media, discussions and exercises Emilcott ensures that our 24-hour, 40-hour or 8-hour HazWOPER class is as practical and hands-on as possible!

Understand Yourself and the Impact of Effective Training

As a CIH consultant with a family and other obligations, it is always a challenge for me to squeeze in occupational training. After all, time spent learning does compete with project work, and there are only so many hours in the week!  With such a tight schedule, sitting in on a webinar or other type of on-demand learning is easier to squeeze into my schedule. Conversely, I also know that attending a course in a classroom with a qualified instructor is a far better option for learning and applying critical health and safety information that I will need on the job. As a result, whenever I have the option between online or instructor-led, especially for a dreaded or boring topic, the best option is to block out the time for classroom learning; my distractions are reduced, my attendance and alertness is required and, now that I’ve set aside the time, my focus is on learning the most and maximize the opportunity. 

Have you ever taken an online, technical course? What were some of the distracting activities you did while “learning”? My personal favorites are cleaning up my email or wallet! Have you ever taken a technical course for multiple days and walked out of it remembering almost next to nothing and thinking, “Oh, that was a waste!” Has that experience affected your training selection process?

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Topics: Emilcott, OSHA, health and safety, General Industry H&S, OSHA Compliance, General EHS, Construction H&S, H&S Training, Hazardous Waste Management, Compliance, Occupational Health, Occupational Safety, class, Occupational Training, HazWOPER, training

Genya Mallach - CSP

As part of a standard, pre-work permit inspection by the local township, it was discovered the exterior of a church (and local pre-school) had been painted with lead-based paint!  Unfortunately, the estimates to remove and repaint the church were far beyond the church’s budget. At the acrimonious and finger-pointing church review meeting, a voice suddenly called out, “I’ll take care of it for half the cost of the lowest estimate!” Salvation!

However, when the contractor began the job, he learned that the cost of removal and repainting would be much more than he expected. In a panic, he did not remove the old paint and, to save materials cost, he diluted the new paint by 50% with water!

After the job was completed, a joyous church service was held to honor the contractor. In the midst of the service, a thunderstorm broke out and the congregants began to notice that the paint was literally washing off the building. The bewildered minister raised his arms and called out, “Oh, Lord, what are we to do?"  In reply, a booming voice from above called out, “Re-paint! Re-paint!”

I suppose the EPA heard this story as well because, on April 22, 2008, the EPA issued a rule requiring the use of lead-safe practices when engaging in renovation and painting projects that disturb lead-based paint in homes, child care facilities, and schools built before 1978. Under the rule, beginning April 22, 2010, contractors must be certified and must follow specific work practices to prevent lead contamination. Individuals can become certified renovators by taking an eight-hour training course from an EPA-approved training provider.

This rule applies to all renovations performed for compensation in “target housing” (housing constructed prior to 1978, except housing for the elderly or persons with disabilities --unless a child of less than 6 years of age resides or is expected to reside) and child-occupied facilities, except for the following:

1. Renovations in target housing or child-occupied facilities in which a written determination has been made by an inspector or risk assessor that the components affected by the renovation are free of paint or other surface coatings that contain lead equal to or in excess of 1.0 milligrams/per square centimeter (mg/cm2) or 0.5% by weight, where the firm performing the renovation has obtained a copy of the determination.


2. Renovations in target housing or child-occupied facilities in which a certified renovator, using an EPA recognized test kit and following the kit manufacturer's instructions, has tested each component affected by the renovation and determined that the components are free of paint or other surface coatings that contain lead equal to or in excess of 1.0 mg/cm2 or 0.5% by weight.

Lead poisonings in an office or domestic setting are mostly caused by exposure to lead dust. Here are a few facts:

• Lead dust settles quickly on floors, window sills and other surfaces.


• Paint repair can generate lots of lead dust.


• Broom sweep won't clean up lead dust.


• Lead-contaminated dust is invisible to the naked eye.


• Initially, lead poisoning can be hard to detect — even people who seem healthy can have high blood levels of lead. Signs and symptoms usually don't appear until dangerous amounts have accumulated.


• Lead usually targets the oxygen-carrying protein in red blood cells (hemoglobin) first. In time, it attacks the nervous system.

BEFORE conducting any renovations on older buildings, it's important to understand the hazards that may be discovered as construction continues. Determining if the interior or exterior paint contains lead, if any materials of construction contain asbestos, and if water intrusion has occurred anywhere in the building during its lifetime (wet building materials are a food source for mold) is the first step toward creating a healthier building.

Emilcott regularly assists clients who face building environment investigations such as indoor environmental quality, asbestos and lead management, microbial contamination and vapor intrusion. Our EHS staff work with building managers to quickly learn how their buildings operate, diagnose conditions, complete inspections of building systems, interview occupants, and advise on the best course of action to ensure that the building is a safe place to live, work or play.

Interested in reading more on keeping buildings healthy? Other EHSWire blog posts about building environments include:

• Water Damage – How to Minimize Mold and Costs 


• 10 Items You Need To Know About Water and Mold Damage In A Commercial Building


• The EPA’s New Year’s Resolutions: Replace PCB-Containing Light Fixtures in Schools and Radon Testing in January


• Vapor Intrusion Air Sampling…Getting the Big Picture

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Topics: Emilcott, health and safety, General EHS, Construction H&S, EPA, H&S Training, Compliance, worker safety, Air Sampling, Mold, asbestos, Exposure, environmental air monitoring, Respiratory, lead, lead-based paint

Capt. John DeFillippo, CHMP, EMT-B

“Every day there are more than 800,000 shipments of hazardous materials (hazmat) in trucks-usually flammable liquids, such as gasoline, or flammable gas. About 200 hazmat trucks a year are involved in fatal crashes and 5,000 in nonfatal crashes. Although these numbers are small relative to the totals of almost 5,000 trucks involved in fatal crashes and 400,000 involved in nonfatal crashes annually, the potential for human injury and property damage in hazmat crashes is much greater.”

Ralph Craft, Ph.D.
Analysis Division, Office of Information Management, US Department of Transportation

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Topics: Emilcott, DOT, General Industry H&S, General EHS, H&S Training, Hazardous Waste Management, HazCom, Hazardous Materials, Compliance, Occupational Safety, regulation, Hazard Communication Standard, Public Safety, Lab Safety

Topics: OSHA, health and safety, General Industry H&S, OSHA Compliance, General EHS, Construction H&S, EPA, Hazardous Waste Management, Compliance, worker safety, Occupational Health, Occupational Safety, TSCA & R.E.A.C.H., TSCA, reporting, Form 300, Greenhouse Gas Reporting

Paula Kaufmann, CIH

Did you know that the OSHA Illness and Injury Summary Log, 300A, is used for more than just recordkeeping at your site?  By documenting your company’s illness and injuries properly, you shape OSHA’s future initiatives!  Specifically, OSHA Summary 300A Forms are gathered by the OSHA Data Initiative (ODI) to help direct OSHA programs and measure its own performance.  

How does OSHA get this information?

OSHA gets these data from two sources:

• As part of an annual survey, the Bureau of Labor Statistics (BLS) sends injury and illness survey forms to randomly selected employers and uses the information to create the Nation's occupational injury and illness statistics.


• The OSHA Data Initiative mails its annual survey (in June) that collects data on injuries and acute illnesses attributable to work-related activities in private-sector industries from approximately 80,000 establishments in selected high hazard industries. In 2010, OSHA also collected this information from approximately 20,000 establishments in the construction industry in addition to the non-construction establishments. The Agency uses these data to calculate establishment-specific injury/illness rates, and in combination with other data sources, to target enforcement and compliance assistance activities. Traditionally, OSHA collects data from the establishments that meet the following categories, but as we saw in 2010, OSHA can expand these criteria.
  
  
  
  • Non-construction industries with 40 or more employees are chosen randomly
  
  
  • Non-respondents in the previous collection year
  
  
  • Site with an inspection or consultation visit for performance measurement
  
  
  • DART rate (days away from work, restriction or transfer) of 7.0 or higher in previous data collection
  
  
  
  

Does the data really help OSHA?

Now that OSHA has the data from BLS and the ODI, the Agency uses the information to

• Calculate and establish specific injury and illness incidence rates


• Develop targeted intervention programs (i.e., inspections and enforcement action)


• Assist inspectors so that they can direct their efforts to the higher incidents hazards that are hurting workers.


• Measure the success of agency efforts to reduce the number of workplace injuries and illnesses in select high-hazard industries


• Provide the base data for the BLS Annual Survey of Occupational Injuries and Illnesses, the Nation's primary source of occupational injury and illness data.

What is your role?

Be a savvy and educated reporter of your company’s illness and injury information. Understanding the OSHA 300 log reporting requirements will ensure an accurate portrayal of worker health and safety as well as maintaining OSHA compliance. Can you answer the following questions?

• How do I complete the OSHA 300 Log and Form 301?


• Am I required to post an OSHA Form 300A ? How do I know if I am exempt? 


• What is classified as a work-related illness or injury? 


• How do I fill the forms in correctly without over-reporting?


• Do I have to fill in the form if I have no recordable injuries or illnesses in the previous year? What are the rules for posting?


• Once the form is filled in and submitted, if requested by BLS or OSHA, are there other legal requirements I should know?

Not convinced that recordkeeping is important?

Besides providing a visible record of worker safety benchmarks and improvements (or worse, tragedies and reversals), establishments that are requested to but fail to submit a completed data collection form may be subject to OSHA enforcement actions, including the issuance of a citation and assessment of penalties!  So, take the time understand OSHA’s reporting requirements and implement them correctly – it affects your company and the nation’s workers.

If you need assistance with OSHA recordkeeping, Emilcott offers a variety of ways to help your business stay in compliance from a webinar-based course that outlines the rules and regulations to the development of complete health and safety plans. Or, if you have an OSHA recordkeeping question, just ask us!

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Topics: Emilcott, OSHA, health and safety, General Industry H&S, OSHA Compliance, General EHS, Construction H&S, Compliance, worker safety, Occupational Health, Occupational Safety, Webinar, reporting, regulation, Medical Records, BLS, Bureau of Labor Statistics

Paula Kaufmann, CIH

It’s time for an update on the EPA’s proposed changes to the Inventory Update Reporting Rule.  As of January 24, 2011, the EPA has been silent as to what changes will be included in the final rule.  A list of the proposed changes is presented on the Emilcott EHSWire.com blog: “ EPA Proposed Changes to the TSCA Inventory Update Rule ” .  

The EPA has stated that the Agency “expects to finalize the modifications to the chemical information reporting rule in time for the next reporting period, scheduled for June 1 - Sept. 30, 2011. EPA will make the electronic reporting software and associated guidance materials available before the start of the submission period.”  If you’re like me, “expects to finalize” is not very helpful for planning purposes or for engendering confidence.

Pull out the professional crystal ball!

As someone who has been working with the EPA for a long time, I am “reading between the regulatory lines” to forecast that the final rule will be published in April.  I’ve based this guess on information provided at the EPA's November webinar that introduced the new, electronic TSCA Reporting Tool, e-IURweb:

• During the question and answer period  an EPA representative said that the final rule should be published in the Spring 2011-- at least 30 days prior to the start of the reporting period.  So… if the reporting period starts on June 1, then I expect the final rule to be published by May 1st at the latest.


• The electronic tool designers said that a test version of the tool would be available for industry testing in April 2011.  (Emilcott will be posting a blog about this new tool in the next few weeks.)

What to do while we wait for the final rule to be published?

We are advising Emilcott clients to proceed with the collection of 2010 inventory data with a threshold of 25,000 lbs.  Additional data that may be needed for the 2011 reporting are listed below.  Depending upon how you gather your information, you may want to request this along with the import or manufacturing volume information.

• Production volumes at or above 25,000 lbs directly exported and not domestically processed or used.


• All quantities of substances subject to rules and orders in the following sections:
  
  
  
  • Section 5(a)(2) Significant New Use Rules (SNURs)
  
  
  • Section 5(b)(4) Chemicals of concern to EPA
  
  
  • Section 6 Prohibitions for chemicals with unreasonable risks
  
  
  • Section 5(e) Requirements or restrictions on chemical production or use
  
  
  • Section 5(f) Chemical with an unreasonable risk
  
  
  
  

What to do if you need help?

If you need assistance related to the TSCA New Chemicals regulatory requirements or the potential changes due to the Inventory Update Reporting Rule, Emilcott can guide you through the reporting. We can also help you navigate the maze of  reporting a potential Form U violation from prior filing years to the EPA (See http://www.emilcott.com/services/svcenvcompliance.asp).  As more information becomes available from the EPA regarding the IUR and as testing of the electronic tool begins, Emilcott will keep you up-to-date via EHSWire and our “Regulatory Updates” Newsletter. If you have any TSCA IUR questions or concerns, feel free to contact Emilcott or post your question below!

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Topics: EPA, Compliance, TSCA & R.E.A.C.H., TSCA, Toxic Substance Control Act, IUR, chemical manufacturer, chemicals, Public Safety, reporting tool, Toxics Release Inventory, inventory update rule

By Chuck Peruffo

It was a few days before Christmas and I was working outdoors as an Industrial Hygiene Technician on a construction project.  This is the first time in my life I have worked at such cold temperatures as I have been a Lab Rat most of my career.   Not being “climate adjusted”, I was bundled up like Ralphie’s little brother, Randy, from A Christmas Story.   As I kept one eye on my meters and the other eye trained on the excavator in front of me, the wind started to pick up.  The clouds of dust coming off the road shouted “dust control needed” even before I checked the numbers on the dust monitors.

Dust control is an important way to keep what’s in the ground out of the air and out of your lungs.  The standard method for controlling dust is to spray water on the ground. This practice works fine until your water truck freezes solid.  So, what do you do when Jack Frost is nipping at your nose and the dust is flying in the air?  Your solution for dust control is to make up a solution of water and a chemical such as magnesium chloride hexahydrate (“Mag flake”).  

Mag flake or Mag brine has long been used to control dust on rural roads.  Mag flake can be mixed directly into your water truck.  A bit of a disclaimer:  although Mag brine is less corrosive that sodium chloride, make sure the water truck tank vessel can handle the solution by noting the material of manufacture and then consulting a corrosion guide. And, it is good practice to flush the tank truck with clean water after use.

Some manufacturers sell Mag brine at up to a 33% solution for dust control. That translates into more than 2 ½ tons of Magnesium Chloride in a 2000 gallon water truck which is fine for dust control on rural roads that aren’t sprayed often but may be too concentrated for a construction site application. 

At Emilcott, we have found a solution to meet the challenge of frozen water.  Roughly, a 50 pound bag of magnesium chloride added to a 2000 gallon water truck lowers the freezing temperature by 0.3°F.  So, to have a liquid wetting agent for effective dust control when the temperature is around 25°F, we add 1500 pounds of magnesium chloride into a 2000 gallon water truck or about a 0.9% Mag brine solution.  And, now we have our “solution” to keep the dust out of the air!

Here’s the formula and factors Emilcott uses to determine how much magnesium chloride we need to add to the water truck to get the right, wet solution:

∆T = i * K_f * m

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Topics: health and safety, dust control, General EHS, Construction H&S, Hazardous Waste Management, Compliance, worker safety, Occupational Health, Occupational Safety, Air Sampling, environmental air monitoring, magnesium chloride, mag brine, mag flake, magnesium chloride hexahydrate

Laurie de Laski

Having spent a large part of the last 25 years as an EHS professional developing and implementing Health and Safety Plans in a wide variety of industries, I was pleased to see that companies are requesting contractors and service providers to be prequalified for safety during the bidding process.  Conceptually, prequalification for safety should “raise the safety bar” and, companies with a well-developed safety plan should be rewarded for their proactive ethos with a competitive edge in the marketplace.  At Emilcott we have seen this really happen! Highly competitive project opportunities open up for clients that have genuinely adopted a top to bottom buy-in on the importance and value of safety. And, of course, they also experience measurable drops in both injury and insurance rates based on their safety performance.

Is the safety prequalification process good?

To have the “win-win”, the safety programs required for the project must be appropriate for the bidding contractor’s scope of work.  And, these safety programs need to be adopted, implemented and enforced. So, in order to make the prequalification process manageable for the companies writing the scope of work and the bidding contractors, an industry of on-line safety verification companies has evolved. While helping the contracting companies organize their bid processes, this on-line verification is very one-size fits all and focuses heavily on written programs, which may not be applicable to the scope of work.  This all or nothing approach leaves me wondering if on-line verification actually does raise the bar or just rubber-stamps paper safety programs.

Here’s the process “in theory”…

Contractors must have written safety programs that meet the requirements of the client.  The programs are submitted on-line and reviewed by the verification company.  Programs meeting the specifications are passed; those that don’t pass are requested to be updated.  This practice sounds likes a good idea, however,

• Many times contractors are required to write safety plans for equipment and operations outside the scope of their operations.


• The contractors spend a significant amount of time inputting the information to the website with no guarantee of being accepted. 


• Many of the bidding contractors are small businesses without the support or money to handle the overhead costs associated with maintaining their entries in the safety verification website.

For a quick safety program, click here!

Don't have the time to develop a safety plan? Don’t know what you’re missing? Under the gun to qualify for a lucrative project?  Don’t worry!

A large number of on-line “safety” specialists are available to help contractors meet the prequalification safety requirements! They advertise the development of company-specific safety programs that will meet the verification requirements at a very low cost, and some will include on-line input on behalf of the contractor and guarantee that they will pass.  One organization guaranteed approval in 72 hours!

Wait a minute…what problem does this solve? These companies offer to “customize” the safety plan by including the contractor’s company name and logo.  These cookie-cutter programs may meet verification requirements, but don’t appear to be customized for the contractor operations or the protection of the workers.  My sense is that there is no effort to actually develop a program that would be implemented by the contractor.  In conclusion, this “click here” approach does not raise the safety bar – it merely creates the illusion of a safety culture.

So, does safety prequalification work?

While health and safety program verification using this broad, sweeping approach may reduce the client’s liability, it doesn’t automatically improve safety performance.  In addition, the contractor may not be aware that they are creating a huge liability if they don’t implement their own safety program. In fact, OSHA will fine heavily for injuries that occur due to the lack of compliance with their stated safety plan.  Criminal penalties are also a possibility since the contractor could be considered negligent in not implementing or enforcing the procedures.

Where should we go from here?

The Requirements - Companies should require contractors to maintain only the safety programs that apply to the scope of work.  Requiring extensive safety programs for hazards the contractor is not likely to encounter devalues the safety culture for both the site and the contractor.

The Contractor Safety Programs - Contractors need to honestly implement programs that apply to their scope of work; understand the intent of the specific safety programs by learning the requirements of the regulations, provide employee training, and foster a culture of safety awareness with their employees.

The Verification Process – Be clear about the REAL goal of the process. If the objectives are truly to reduce accidents, improve safety, and make sure that everyone goes home at night, then old fashioned site health and safety inspections are what should be required.  Seeing how people work is the best way to make improvements in safety!

Do you think that the on-line safety verification process actually make a difference or is worth the time and expense?  Have you worked on a project where the on-line verification process develop and promoted a safe work environment, or like me, do you doubt they make a positive impact at all?

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Topics: Personal Protective Equipment, health and safety, General Industry H&S, General EHS, Construction H&S, H&S Training, Compliance, worker safety, Occupational Health, Occupational Safety, Occupational Training, safety plan, health and safety plan, safety prequalification, on-line verification

Sarah Stibbe Damaskos



Did you know that, in fiscal year 2010, OSHA issued approximately 94,000 citations?  Using this data, OSHA has recently released its Annual Top 10 list of Most Cited Violations.  OSHA releases this list every year – why? Paula Kaufmann, a CIH at Emilcott, thinks OSHA is telling us where we need to focus!  Use it as a warning or indicator that that OSHA is monitoring these trends and will be targeting companies most likely to have employees working with these hazards. 

At Emilcott, we provide health and safety guidance and support for hundreds of clients that range in size from small, family-owned businesses to Fortune 100 companies with facilities throughout the world. Our EHS consulting work familiarizes us with all types of facilities and a wide range of health and safety issues. One common thread brings these different companies and industries together:  when they embrace a company-wide safety culture they reduce their risks. So, when we look at the categories and the sheer volume of violations (47,000!) that support OSHA’s Top 10, we know that the solution for every violation is universal:   safety training and commitment to creating a safe work environment with management leadership and employee involvement! With a top to bottom buy-in on the importance and value of safety, occupational hazards are observed, analyzed and prevented.  We have seen injury (and insurance) rates drop for our clients that have genuinely adopted this approach.  Some clients have even won highly competitive projects with their safety performance making the winning difference!

Let’s get back to this year's Top 10 categories. From year to years this lists stays virtually the same, but what we strive for, as occupational health and safety professionals, is a reduction in the number of incidents (and violations). 

Under the Occupational Safety and Health Act of 1970, employers are responsible for providing safe and healthful workplaces for their employees.  As we review just the top 5 violations of 2010, consider if your company is providing adequate training and support to create a safe and healthful workplace for you.  Do you work in a culture of safety? What can you do to make your workplace safer for yourself and your coworkers?  Does your company understand the complete cost of ignoring occupational safety practices? 

1)  Scaffolding (OSHA 29 CFR 1926.454)

Training Solution:   At a minimum – Scaffolding awareness, approximately 2-3 hours of training investment. 

Learn More:  “ When OSHA revised its scaffolds standard in 1996, BLS [Bureau of Labor Statistics] studies showed that 25% of workers injured in scaffold accidents had received no scaffold safety training, and 77% of scaffolds were not equipped with guardrails. OSHA estimates that informed employers and workers, in compliance with correct safety standards, can save as many as 50 lives and prevent 4,500 accidents every year. In a recent BLS study, 72 percent of workers injured in scaffold accidents attributed the accident either to the planking or support giving way, or to the employee slipping or being struck by a falling object.”

2)  Fall Protection (OSHA 29 CFR 1926.503 & 1926.1060)

Training Solution:  OSHA requires training for anyone working on elevated surfaces, an approximate 2-4 hour training investment per person  This includes above excavations!  There is a requirement for Competent Person as well (to ensure that everyone is following the requirements and the equipment is appropriate).

Safety Violations Cost:  “ The U.S. Department of Labor's Occupational Safety and Health Administration has cited, a residential roofing contractor in Belleville, for violations in connection with fall hazards. Proposed penalties total $106,400.”

 3)  Hazard Communication (OSHA 29 CFR 1910.1200 & 1926.59)

Training Solution:  OSHA requires employers to provide employees with effective information and training on hazardous chemicals in their work area.  This means an initial training (1 to 2 hours) and follow-up training when new chemical hazards are brought onsite or when employees have new job tasks involving new chemical hazards.  Maintaining an accurate, up-to-date list of substances and a Material Safety Data Sheet (MSDS) for each substance  are also required.

Learn More:  Find out more about Hazard Communication here and, as global harmonization moves forward, talk to your health and safety staff about new developments or subscribe to updates from this OSHA site. 

Safety Violations Story: Young Workers:  Robert

4)  Respiratory Protection (OSHA 29 CFR 1910.134 & 1926.103)

Training Solution:  All employees who are required to wear respiratory protection, including filtering face pieces, must be properly trained how to use and care for a respirator-- this takes about 1 hour. Medical Clearance and Respirator Fit-test is also required, as is the assignment of a Respiratory Protection Program Administrator who should be properly trained in this task (about 8 hours).

Learn More:  Why Proper Respirator Protection Lets You Breathe Longer (and Breathe Easy)

5)  Ladders (OSHA 29 CFR 1910.26)

Training Solution:  Employees should be trained to properly use ladders and to recognize the hazards from falls while using ladders and stairways. This is generally a 30-minute training investment and can be part of regularly scheduled Tool Box Talks. OSHA also requires Ladder Inspection Program to remove and destroy defective ladders.

Learn More: “ OSHA rules apply to all stairways and ladders used in construction, alteration, repair, painting, decorating and demolition of worksites covered by OSHA’s construction safety and health standards” and this quick guide to portable ladder-related falls”.

So, are you concerned that you could be caught, written up and fined by OSHA due to safety violations?  Then, you need the Emilcott Training Needs Assessment Tool!  It’s free and is designed to help you determine which employees need health and safety training to meet regulatory compliance specific to your operation.

Here’s a final interesting  statistic:  According to OSHA, an effective safety and health program forms the basis of good worker protection and can save time and money—about $4 for every dollar spent—and increase productivity and reduce worker injuries, illnesses and related workers’ compensation costs.  Now that’s an investment that makes sense to your workforce and your wallet (and keeps you off OSHA’s top 10)!

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Topics: Emilcott, OSHA, General Industry H&S, General EHS, Construction H&S, H&S Training, Compliance, worker safety, Safety Training in Spanish

by: Capt. John DeFillippo, CHMP, EMT-B

When some of us head to the “office” the decisions we make about what to wear go way beyond fashion…our very lives could depend on our wardrobe choices. For many workers, Personal Protective Equipment, or PPE, protects them from slight and serious workplace injuries or illnesses resulting from contact with chemical, radiological, physical, electrical, mechanical, or other hazards. Here’s a rough guide to occupational “Dress for Success” (and survival!).

Let’s start with the head.

A properly fitting, ANSI-rated hard hat will do more than protect you from falling stuff. They’re rated to provide protection against electric and chemical hazards as well. By the way, you have to wear your hard hat correctly if you want it to protect your noggin:  Do not wear it backwards. Do not wear another hat underneath (except a proper hardhat liner).  Any stickers have to be removable so that the hard hat can be inspected for integrity.

Next, Move Down to the Eyes

According to OSHA, Not all eye protection is the same. Start by looking at the ANSI-89 rating on the specs. Does the rating match your job function?  And, don’t let style issues affect your decision whether or not to wear them. Safety glasses used to be big, unattractive, and were often uncomfortable. Not anymore! There are styles and sizes for everybody and most “well-dressed” workers have at least two pair:  sunglasses and clear. Keep in mind that eye injuries, including permanent blindness, occur on the job every day. According to OSHA, “ eye injuries alone cost more than $300 million per year in lost production time, medical expenses, and worker compensation”. Don’t let it happen to you.

Face Protection

OSHA considers face protection separate from eye protection - one is never a substitute for the other. This OSHA powerpoint is a great overview of eye and face protection requirements. Find out if your job (grinding and pressure washing for example) requires a face shield.

Don’t Forget Your Ears!

Your hearing is a delicate tool that, once damaged, cannot be repaired. Did you know that most cases of hearing loss in the US are the result of occupational exposure? Hearing protection, like respiratory protection, can get a little complicated so if you’re confused, ask an expert. EHS experts like Emilcott can perform quantitative noise analysis and provide best recommendations to protect hearing for your worksite. To start, a good rule of thumb is that if you need to raise your voice in normal conversation, you probably should be wearing hearing protection.

Body Protection

Protection for the body varies greatly depending on the hazard(s) encountered. At a minimum,   make sure you can be seen! High visibility garments are required by OSHA and DOT when working around traffic and are a good idea all the time.

Last (But Not Least), Your Feet

Safety footwear is required by OSHA if your feet are subject to injury. They also must be ANSI- approved -- look for the markings on the shoe or boot to be sure. 

The Final Word

Keep these points in mind the next time you get dressed for work:

• While individual PPE items may not go “out of style”, they do go out of date. Check your gear to make sure it’s still within the expiration date.

• Once your PPE has protected you from an injury, replace it.  It did its job and you don’t know how it will hold up a second time.

•  And, finally, get the good stuff. Those cheap boots may seem like a bargain until your feet start hurting.

By the way, the Dress for Survival list above, with the exception of respirators (a blog in itself!), is considered “minimum PPE” on most sites. You need proper protection for each body part just to get in.  Don’t know what to use?  For every job, there are specific OSHA requirements that are designed to keep you safe – your health and safety office or EHS group should be a resource for information as well as monitoring the worksite for safety needs. 

Does your company keep employees protected by dressing them in the appropriate safety PPE?  Have you ever done a self-evaluation, head to toe, of what you are wearing and if it adequately protects you from the job hazards that you may encounter?  Has your safety clothing ever protected you and how?

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Topics: OSHA, indoor air quality, Personal Protective Equipment, health and safety, General Industry H&S, General EHS, Construction H&S, Emergency Response, H&S Training, Hazardous Waste Management, Compliance, worker safety, Occupational Health, Fire Safety