Environmental Health and Safety Blog | EHSWire

By Eileen Lucier

Slips, trips, and falls aren’t at the top of anyone’s “most glamorous” EHS topics list.  Many people perceive slips, trips, and falls as minor incidents resulting solely from either carelessness or clumsiness. In fact, losing your footing is the basis for basic comedic art (ever watch “The Three Stooges” or “America’s Funniest Home Videos”?)  

Quite the opposite -- slips, trips, and falls are a very costly and serious worker safety issue. In 2008, these incidents cost American businesses a staggering $13.67 billion in direct workers compensation costs. That’s more than any other cause and more than the combined cost of the third through sixth ranked causes. 

Injury, Illness and Death Facts You Should Know

Slips, Trips, and Falls….

• Result in back injuries, strains, sprains, bruises, broken bones, concussions, and even death!


• Cause 15% of all accidental deaths, and are second only to motor vehicles as a cause of fatalities.


• Were the fourth leading cause of fatal work injuries in 2008 (13.4%, or 700 out of 5,214 fatalities).


• Rank as the second leading cause of disabling occupational injury.


• Are the third leading cause of all occupational injuries/illnesses (21.8%) and injuries/illnesses resulting in days away from work (21.4%).

How can slips, trips, and falls be prevented?

As with most safety hazards, slip, trip, and fall hazards can be minimized with a combination of good work practices, proper use of appropriate equipment, proper facility and equipment maintenance, and worker training. OSHA’s Walking/Working Surfaces - Safety and Health Topic page provides links to all the applicable standards. Some basic preventive practices include:

• Good housekeeping
  
  
  
  • Keep floors clean, dry, and sanitary
  
  
  • Clean up spills promptly
  
  
  • Keep aisles and walkways free of obstructions and clutter
  
  
  
  


• Footwear
  
  
  
  • Fit properly
  
  
  • Require slip-resistant foot in areas prone to wet or slippery conditions
  
  
  
  


• Fall prevention and protection
  
  
  
  • Provide appropriate fall arrest systems
  
  
  
  


• Facilities and equipment
  
  
  
  • Walking and working surfaces
    
    
    
    • Floor surfaces should not be slippery or uneven
    
    
    • Install non-slip flooring in areas prone to wet or slippery conditions
    
    
    • Maintain floors in good condition
    
    
    • Equip elevated working surfaces and stairways with guardrails
    
    
    • Protect floor holes such as drains with grates or covers
    
    
    • Promptly remove ice and snow from walkways, parking lots, etc.
    
    
    • Adequate lighting
    
    
    • Ladders
      
      
      
      • Provide properly rated ladders
      
      
      • Maintain ladders in good condition
      
      
      
      
    
    
    
    
  
  
  
  


• Training
  
  
  
  • Provide worker training for
    
    
    
    • Slip, trip, and fall hazards
    
    
    • Ladder use
    
    
    • Personal fall arrest systems
    
    
    
    
  
  
  
  

Don’t Slip Up on Safety!

Bruising, twisting or breaking a bone makes your work life and personal life extra challenging – it’s worth it to take a few minutes to prevent the accident from ever happening. On TV and in the movies, slips and other footing mishaps are carefully orchestrated with hidden padding, stunt doubles, some great camera tricks, and, of course, an endless supply of retakes. When you’re working on the job, there’s only one chance! 

Using the tips listed above, take a look around your workplace to see if it meets the criteria to prevent slips, trips and falls.  Don’t forget to look at your own feet to see that you are properly dressed for the environment and job duties. If you see a situation that is unsafe or could potentially be a slip, trip and fall hot spot, make sure you point it out to your coworkers and safety officer so that a permanent solution can be found.

Has it happened to you?

Have you experienced a slip, trip or fall on the job?  Could it have been prevented? What was the outcome for you and your company?

Paula Kaufmann, CIH

As an occupational and safety professional, I’ve noticed that the Occupational Safety and Health Administration (OSHA) has been busy over the last few weeks!  The following is a summary of highlights of interest to Emilcott clients.  Did any of these catch your attention?

Highlight #1: Up-to-Date OSHA Standards

Announcement of a final rule to help keep OSHA standards up-to-date and better enable employers to comply with their regulatory obligation. The concept should allow OSHA to easily remove outdated requirements, streamline and simplify standards without reducing employee protection. The rule is to be published soon in the Federal Register:  OSHA Standards Improvement Project-Phase III final rule.

Benefit to employers:  OSHA estimates that the final rule will result in annual cost savings to employers exceeding $43 million. Now that’s an improvement to cheer about!

In the news release, OSHA stated that there will not be any NEW requirements set by this rule, so employers will be able to comply with it immediately. (However, it seems that there will be modifications...Emilcott will be keeping a lookout for those and post an update below or as a new EHSWire post.)  Here are some examples listed in the news release on this rule:

• Respiratory Protection
  
  
  
  • Aligning air cylinder testing requirements for self-contained breathing apparatuses with U.S. Department of Transportation regulations
  
  
  • Clarifying that the provisions of Appendix D, which contains information for employees using respirators when not required under the standard, are mandatory if the employee chooses to use a respirator.
  
  
  
  


• Sanitation
  
  
  
  • Defining “potable water” to meet the current Environmental Protection Agency
  
  
  
  


• Access to Exposure and Medical Records
  
  
  
  • Deleting a number of requirements for employers to transmit exposure and medical records to NIOSH
  
  
  
  


• Slings
  
  
  
  • Requiring that employers use only slings marked with manufacturers' loading information
  
  
  
  

Highlight #2: OSHA Injury and Illness Logs - Musculoskeletal Disorders (“MSD”)

Reopening the public record on proposed record-keeping rule to add work-related musculoskeletal disorders column.  This keeps popping up!

• In January of  2010, OSHA proposed to revise its Occupational Injury and Illness Recording and Reporting Requirements regulation to restore a column to the OSHA 300 log that employers would have to check if an incident they already have recorded under existing rules is an MSD.  


• On January 25, 2011, OSHA withdrew this proposed revision.


• On May 17, 2011, OSHA reopens the public record on a proposed rule.

Highlight #3: A Survey of Private Sector Employees

Launch of a targeted employer survey to collect information that would improve the development of future rules, compliance assistance and outreach efforts.

• The survey will be sent to private sector employers of all sizes and across all industries under OSHA's jurisdiction. Questions include whether respondents already have a safety management system, whether they perform annual inspections, who manages safety at their establishments and what kinds of hazards they encounter at their facilities. Participation in the survey is voluntary.

Highlight #4: Fall Protection for Residential Construction Workers

Online presentation about fall protection specifically designed for residential construction workers. (This is really great as residential construction crews frequently overlook safety – just look at all the roofers walking around the top of your neighborhood homes!)

• The presentation describes safety methods for preventing injuries and deaths from falls, and explains techniques currently used by employers during various stages of construction. These techniques involve the use of conventional fall protection systems including safety nets, guardrails, and personal fall arrest systems such as body harnesses, lanyards and lifelines.


• The presentation is among a series of guidance materials on OSHA's Residential Fall Protection Web page.

On a personal note, my son is currently volunteering as a roofer on a Habitat for Humanity home construction site … he informs me that he is wearing fall protection and the roof has anchor points! 

So, can you tell that Emilcott is pretty excited about these changes? Instead of putting the onus on employers to become more aware of OSHA, OSHA is streamlining existing rules to match other government agencies (radical!), listening to employers before leaping into new regulations, and looking at alternative messaging techniques to market segments that frequently fall in the cracks.

If you’re interested in what’s happening at OSHA, just take a look at the loooooong list of May press releases…Are there any highlights that you think important to you or American businesses? Any predictions for June?

Paula Kaufmann, CIH

We have some news on this year’s TSCA IUR Form U submission.  Well, it really isn’t information about the requirements – but we do know that this year’s Form U submission period will not be June 1 to September 30.  It will most likely be later this year.  So, we all can move that task to another segment of the calendar year!

More Information

On May 11, 2011, the EPA issued a Federal Register Notice amending the Toxic Substances Control Act (TSCA) Inventory Update Reporting (IUR) regulations by delaying  the June 1 to September 30 submission period for the 2011 Form U reports.  The notice indicated that this delay will not alter the timing of subsequent submission periods (e.g., the submission period from June 1, 2016 to September 30, 2016).  This is an interesting statement as one of the changes included in the proposed IUR Rule is a change of the reporting period cycle to every four (4) years from the current five (5) year cycle.

The EPA is delaying the submission period because the proposed IUR modifications rule has not yet been finalized.  EPA expects to have the final version of the changes to the IUR reporting requirements in the near future. The revised 2011 submission period will be announced with the publication of the final IUR modification rule. 

How does this delay what the EPA rule refers to as a “suspension” affect what needs to be done for the 2010 reporting period?  It seems that the EPA will mandate a new submission period but it is not clear when this will be during 2011.

• We are assuming that the reporting period will remain as the 2010 calendar year. 


• Our next assumption, or guess, is that the Form U submission period will shift to September 1 to December 31, but that will require that the final rule on the IUR modifications be published very soon.

“Food” for Thought…

As recently as March 4, 2011, representatives from the American Petroleum Institute (API) met with the EPA presenting concerns about several aspects of the proposed IUR modifications rule.  One topic the API presented was that when the last set of revisions of the IUR was finalized in 2003 with the next reporting period was extended by one year shifting from 2004 to 2005 with Form U submission in 2006.  During 2004 and 2005, the EPA held many workshops and issued clarification and guidance documents.

And, for now, we wait for the Final Rule and hope that the data we have all collected for the 2010 reporting period will be adequate.  Emilcott's recommendations for what to do while we wait are in my January blog:  “ TSCA IUR Update – What Are the Changes ?”. Essentially, we are advising our clients to proceed with the collection of 2010 inventory data with a threshold of 25,000 lbs.  Here are a couple of items to keep on your radar:

• Be sure your list of manufactured chemicals is complete.  Your list should be based on all chemical processes and imported materials received at the site and not just on the products.


• When calculating individual substance volumes – include imported mixtures with those manufactured at the site aggregating all mixtures containing that substance. 

...And, Emilcott will continue to keep you posted!

What to do if you need help or have questions?

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.  

Please give me a call at 1-800-886-3645 or write a comment below if you have any questions or additional information to contribute.

by Paula Kaufmann

In the August 13, 2010 TSCA Inventory Update Reporting Modifications - Proposed Rule, the EPA anticipated the promulgation of the final rule by the Spring of 2011.  Spring arrived 3 weeks ago, and the final IUR Reporting Modification rule has not been published.  As such, the reporting modifications and specific reporting period have not been finalized.  In addition, the Agency has not released a test version of the revised Form U electronic reporting software.  It is possible that the Agency will change the proposed 2011 submission period (June 1 – September 30) to another 4–month period later in 2011.

EPA's intended final rule was sent to the White House Office of Management and Budget (OMB) on January 20, 2011.  Since the beginning of February, OMB has held meetings with the American Chemistry Council, the Society of Chemical Manufacturers and Affiliates Inc. (SOCMA), the Small Business Administration, the National Mining Association, and associations that represent companies that must comply with the regulations.

So -- once again, the question is “now what to do?”

As mentioned in my January blog “ TSCA IUR Update – What Are the Changes ?” we are advising Emilcott clients to proceed with the collection of 2010 inventory data with a threshold of 25,000 lbs.  Here are a couple of items to keep on your radar:

• Be sure your list of manufactured chemicals is complete.  Your list should be based on all chemical processes and imported materials received at the site and not just on the products.


• When calculating individual substance volumes – include imported mixtures with those manufactured at the site aggregating all mixtures containing that substance. 

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!

by Paula Kaufmann

In 2010, 782,000 students nationwide attended OSHA Outreach Training courses with an 11% increase in students attending the 10-hr Construction Industry Training -- the highest attendance of all courses offered. What is the driving force for the high and rising class attendance? Bids for construction projects with both public and private funding now require that employees of contracting companies complete and pass the OSHA Outreach in Construction courses to reduce project liability and cost. 

What is Construction Industry Outreach Training?

The OSHA Outreach Training Program for the Construction Industry teaches construction workers  how to identify safety and health hazards and how to avoid and prevent these hazards and injuries with the “ Focus Four Hazards” of falls, caught-in or between, struck-by, and electrocution. The training also covers workers’ rights to a safe workplace, employer responsibilities, and how to file a complaint to OSHA. The Standards applicable to the Construction Industry are contained in Section 29 of the Code of Regulations, Part 1926. 

Who Should Attend a 10-hour Construction Industry Training Course?

Workers must complete the OSHA 10-hr Construction Industry Training Course to work on any publicly-funded construction project in Connecticut, Massachusetts, Missouri, Nevada, New Hampshire, New York, and Rhode Island.  Nevada also requires those with supervisory or safety responsibilities complete the 30-hr course.

Many private companies are adding this training to their bid requirements as well! Why?  This course is an excellent introduction to health and safety programs for workers new to construction or when it is time to create a paradigm shift in attitudes about safety. Although the OSHA 10-hour Construction Industry course is designed for entry-level construction workers, many organizations include ALL their site personnel in this training because EVERYONE is responsible for safety.

OSHA, government and private contractors, and insurance providers recognize the completion card as an indication of the importance of safety and health for both the individual and the organization.  In fact, Workers’ Compensation insurance providers often will reduce rates for companies that recognize training as part of their Health and Safety Program and include this essential training to their staff.

Emilcott’s OSHA 10-Hour Construction Industry Course

Based on the requirements established by OSHA, Emilcott’s 10-hour Construction course provides important information about the recognition, avoidance, abatement, and prevention of safety and health hazards in workplaces in the construction industry. This training assumes no prior training nor requires any prerequisite training.  Much of the Emilcott Training Institute’s 10-hr Construction Industry course is interactive and hands-on to ensure that key health and safety concepts are retained .  More importantly,  our courses are taught by instructors with real-world experience. Credentials and certifications provide a way to verify competency in particular fields but real-world experience should not be discounted. It’s one thing to talk about trenching hazards, it’s quite another to actually work around them. This experience allows Emilcott trainers to put the material in perspective and help students make the connection between theory and practice.

Quality Training Makes a Difference

With twenty-five years of consulting experience with all types of companies, projects, work sites and hazards, we universally find that the  OSHA Outreach Courses for both Construction and General Industry help everyone at the site “get it” when it comes to site safety!  When part of an implemented Health and Safety Plan, the education provided by quality OSHA Outreach courses has helped our clients reduce their accident incident rates AND insurance rates! 

Do you have examples of the OSHA Outreach Training raising the bar of safety at your site? Is there something you’ve learned in an OSHA Outreach Training Course (Construction or General Industry) that has helped you on the job?

by Paula Kaufmann

On April 15, OSHA announced revisions to the Outreach Training Programs as part of a continuous improvement program. Effective immediately, these new requirements apply to both the trainers and training materials.  The Assistant Secretary of Labor for OSHA, Dr. David Michaels, explained the announcement by stating, " These revisions will serve to tighten the program controls to ensure the best training is provided to the worker participants. Trainer reliability will be enhanced and classes will focus more on fulfilling students' needs for safety and health training."

Here is a snapshot of the revisions:

• The "program guidelines" are now defined as “program requirements" (translation: must be done).


• Separate procedures are provided for each of the Outreach Training Programs, Construction, General Industry, Maritime, and Disaster Site Worker. 


• A trainer Code of Conduct and a Statement of Compliance requires each trainer to verify that the training they conduct will be in accordance with the Outreach Training Program requirements and procedures.


• Classroom size is now limited to a maximum of 40 students.


• Only translators with safety and health experience can be used.


• Videos can be used for only 25 percent of the training period.


• OSHA course completion cards must be provided directly to the students within 90 days of class completion.


• All construction classes are required to include four hours on Focus Four Hazards.


• All 30-hour classes must include two hours on Managing Safety and Health.


• The new requirements and procedures also integrate recent requirements which require training classes to last a maximum of 7½ hours per day and include a new two-hour Introduction to OSHA training module.

The effect of these changes is higher quality OSHA training offered by authorized training groups because, in theory, a better trained worker is a safer worker. As you reviewed the changes to the training program and trainers, what do you think the effect will be? Do you think that the revisions will improve worker safety or are just another paperwork high jump for employers and training institutions?

By Don Hoeschele, MS, CHMM

In an age where we are reliant on modern technology as a part of our job, it is difficult to imagine not being able to use your cell phone or access the Internet because of topography.  As the Field Safety Manager for a 300-mile electric power transmission power line construction project, one of my first tasks was to address the question “How do you make communication possible across 275 miles of relatively unpopulated, harsh mountainous territory”?  Specifically, I had to meet OSHA’s requirements for communication:  29 CFR 1926.35 “Employee Emergency Action Plans” and 29 CFR 1926.50 “Medical Services and First Aid”.  

For a project health and safety administrator, it is vital to be able to communicate with your team members and with outside resources. How do you keep tabs on who is where and what is happening? How do you find if something has gone wrong or someone needs help?  In fact, these are the reasons that OSHA implemented the Standards listed above – life and death situations may depend upon it!

On this particular project, numerous construction crews were working at different, extremely remote locations with a distance of several miles between each work crew. While the power line tower construction and electric line-stringing companies included requirements for an eventual end-to-end 2-way radio system, the system was not available for at least the first year of the project. And, since cell phones and the average two-way radio systems were not able to be consistently or reliably available to meet the communication needs required for this project, I needed to find an alternative. 

After digging around and countless meetings, calls, and trips to all kinds of communications companies, we settled on a resourceful, cost-conscious and effective method of communicating between the crews, safety personnel, surveyors and managers. The end result was a creative mix of new technologies:

• Cell phone signal boosters in each vehicle in the field


• GPS SPOT locator units for each  crew


• New technology satellite phones for work crews heading into the most remote locations.  

The vendor that built these systems also owned many of the frequencies needed for an end-to-end two-way radio system that would reach across the 275-mile project location.

Of course, the system’s effectiveness had to be proven – we were relying on it! So, I spent hours deep in the mountains field testing the equipment in some of the most remote project locations I have ever seen. Luckily, I was helped by some of the project team members who had spent a great deal of time in this area. Experience also helps communication!

This project had unusual difficulties – a big, remote, mountainous and unpopulated area – that could have thwarted OSHA’s communication requirements.  At any time, it would have been easy to throw in the towel, cross our fingers or perhaps put together a patched-together system and hope it worked.  However, with some tenacious ingenuity and a confidence that a reliable health and safety communication system could be found, we were able to overcome the almost overwhelming challenges and put an effective field communication system into place.

Have you been faced with challenges to provide adequate communication systems for your employees?  What has made a job site seem almost impossible to conquer? What did you do to overcome those challenges?

by Paula Kaufmann

What’s the job of a Respiratory Protection Program (RPP) Administrator? 

This individual is officially listed in the site’s written Respiratory Protection Program and is accountable and responsible for the day-to-day operation of the program. Some of those “day-to-day” tasks include

• Maintaining the site Respiratory Protection Program


• Assessing the workplace for potential respiratory hazards


• Defining worker exposure for these hazards


• Selecting appropriate respirators to provide protection from defined hazards


• Ensuring
  
  
  
  • Medical evaluations are conducted of employees required to wear respirators PRIOR to fit testing
  
  
  • Respirators are fit tested for all required users
  
  
  • Proper use of respirators during routine and emergency operations
  
  
  • Respirators are appropriately cleaned, disinfected, stored, inspected, repaired, discarded, and maintained
  
  
  • Adequate air quality air is supplied if supplied air respirators are used.
  
  
  • Respirator users are trained in respiratory hazards, and the proper use and maintenance of respirators
  
  
  • Periodical evaluation of the Respiratory Protection Program implementation
  
  
  • Workers who voluntarily wear respirators (excluding filtering facepieces) comply with the medical evaluation, and cleaning, storing and maintenance requirements of the standard
  
  
  • All voluntary-use respirator users understand Appendix D of the standard
  
  
  
  

Yes, these incessant and critical health and safety tasks can be quite overwhelming!  What’s the big deal? For the company or job site or administrator who does not understand why a qualified and empowered RPP Administrator is a big deal, here is a triple-play of Top 5 facts that illustrate the importance of qualified training for Respiratory Protection Program Administrators!

Top 5 OSHA Violation!

Did you know that the Respiratory Protection Standard was in the Top 5 most frequently cited standards by OSHA compliance officers last year?  Why be a part of that statistic?  More about 2010’s Top 10 cited violations can be found in a recent EHSwire blog by Emilcott’s Sarah Damaskos.

Top 5 Reasons YOU need to be “Qualified”

1. Workers at your site are required to wear respirators for protection from respiratory hazards – and you selected these respirators.


2. You train respirator users on how to put on and take off their respirator – along with the limitations on their use, and their maintenance.


3. Implementation of the site respiratory protection program (which you wrote) is just another one of your jobs!


4. Airline (atmosphere-supplying) respirators are used at your site – and you make sure that an adequate air supply, quantity, and flow of breathing air is available.


5. You coordinate the medical evaluation of employees who must use respirators.

Top 5 OSHA Compliance Indicators!

If you get a visit from an OSHA Compliance Safety and Health Officer, they review these essential factors to help determine if the Respiratory Protection Program Administrator is “Qualified”:

1. The written Respiratory Protection Program and interviews with the program administrator reveal an understanding of the familiarity with the respirator standard, site respiratory hazards, and the use of the respirators in the workplace.


2. Respiratory fit testing is conducting annually or at assignment and the program administrator maintains.


3. Hazardous airborne contaminants that employees may inhale have been identified.  Reasonable estimates of employee exposures were used in determining the appropriate respirator for employees to use.


4. Recent changes in the workplace such as new processes have been evaluated for necessary respiratory program changes


5. The program administrator keeps a written assessment of the program operations and implements changes that may be considered as efforts toward improvement.

How to Become a Qualified RPP Administrator

Focused, hands-on training with experienced health and safety instructors can make the difference for a Respiratory Protection Program Administrator – clarifying the waters by understanding the objectives of the law and how it applies to each work site!

As Health and Safety consultants to many types of companies, Emilcott staff are on job sites each day and see health and safety violations such respirators perched on foreheads or tissues jammed in the sides to ensure a bitter fit. Are these problems an employee violation or a company-wide result of not understanding the importance of a competent Administrator who can develop, maintain and enforce a respirator protection program that reduces occupation risk?

In these cases, we conduct urgent and immediate on-site RPP Administrator training that often includes high level managers to ensure that there is a top to bottom understanding of the importance of proper respirator usage. In addition to our private training, the Emilcott Training Institute offers public enrollment Respiratory Protection Program Administrator training courses in two formats:  an intense 3-hour course with a small class size and an in-depth two-day course.  In both classes, students learn the level of information required for their sites and are taught by an experienced H&S instructor that can answer questions. 

So if you are unfamiliar with your required duties as an RPP Administrator or you want a better understanding of how to encourage better respirator usage by your site personnel, look around for an effective RPP Administrator training class. Once complete and in practice, you should dicover aTop 5 list that looks more like this:

1. OSHA respirator inspection passed without any problems, fines or additional action.


2. Site personnel actively wear their respirators – the way that they are supposed to!


3. Site workers reinforce the importance of respirator use to their colleagues (even when you’re not around)!


4. Managers understand the need for respirator use and support related site activities such as testing of hazardous airborne contaminants.


5. Written assessments of program changes are treated as a necessity for business to move forward rather than resented.

You ARE a Qualified Respiratory Protection Program Administrator!

Carrie Bettinger, CHMM, CSP

As a Certified Hazardous Materials Manager (CHMM) and a Certified Safety Professional (CSP) I often make recommendations to our “General Industry” clients in an effort to lift their game with dealing with hazardous waste.  There are multiple layers of compliance issues related to hazardous waste handling, and, as with most regulations, a little education (TRAINING!!) goes a long way in understanding the game plan!  The intention of this blog is to provide a brief discussion of the key regulations and their associated training requirements.

The Rules

The U.S. Environmental Protection Agency (EPA) has very strict guidelines regarding the generation, transportation, treatment, storage  and disposal of Hazardous Waste, which “ General Industry” businesses (schools, colleges; hospitals; trucking/freight companies; manufacturer; laboratories; …well, just about everyone) needs to know!

OSHA uses the term "general industry" to refer to all industries not included in agriculture, construction or maritime. General industries are regulated by OSHA's general industry standards, directives, and standard interpretations.

Give me an R! Give me a C ! Give me an R! Give me an A! What’s that spell?!  HAZARDOUS WASTE!

The Resource Conservation and Recovery Act (RCRA) appeared on the environmental scene in 1976 after Congress decided that people shouldn’t be building homes on top of highly hazardous waste dumps or Farmer Joe shouldn’t have a side business of burying industrial waste on the family farm.   RCRA is a complex law with lots of parts and many industries are affected by its components.  In addition to being complex, the text of the Act with all of its parts and sections is hard to follow.  My primary technical focus tends to be on the Generators of Hazardous Waste (40 CFR Part 262) . RCRA Training requirements for generators can be found in 40 CFR 262.34(a)(4) which conveniently (NOT) refers you to look at 40 CFR 265.16 on Personnel Training.

But the EPA’s RCRA law is not the only player when it comes to the game of shipping hazardous waste off your site.  The other major player is the Department of Transportation (DOT), and its Hazardous Materials shipping training requirements are found in 49 CFR Part 172, Subpart H.   The International Air  Transport Association (IATA) has rules for the air transport of hazardous materials ( http://www.iata.org/) including training requirements.

To simplify, RCRA is all about Hazardous WASTE and the DOT and IATA rules kick in when you’re dealing with hazardous MATERIALS, and guess what hazardous waste is?  That’s right it’s hazardous materials in DOT and IATA eyes.  For those who generate or ship Hazardous Waste, compliance for with EPA RCRA and DOT /IATA rules starts with required and effective training.

The Required Training

So, if you generate hazardous waste and you need to get it off your site, here is a brief summary of the training employees who either generate or handle hazardous waste should have -- per both EPA and DOT/IATA.

All employees at sites that generate hazardous waste need to be trained in how to:

• Properly identify what qualifies as regulated “Hazardous Waste” per federal (EPA) or your state requirements.


• Know where to properly dispose of any hazardous waste you may generate (I will give you a hint:   It’s NOT down the sink drain!).


• Know how to handle and dispose of highly hazardous waste (very toxic, reactive or explosive) to prevent injuries, and who to contact for questions or emergencies.

Employees who are designated as responsible for the management and control of this hazardous waste need additional training. And, depending on the size of the facility, it is prudent to provide this training to a backup employee or two. This additional training includes how to

• Properly label containers


• Implement accumulation area requirements and time-on-site limits


• Inspect hazardous waste accumulation areas for leaking or damaged containers or other problems


• Complete Hazardous Waste shipping manifests


• Ensure proper shipping methods and a qualified transporter are used


• Develop site-specific procedures


• Know and implement emergency procedures and site contingency plans

Refresher Training

A common point of confusion is when refresher training is needed for employees.  The DOT and EPA have two separate requirements:

• The EPA requires annual refresher training for their regulations.


• The DOT requires refresher training every 3 years for their regulations.

And, companies must ensure training for new employees or those newly assigned to the role within 6 months of their new post to be in compliance with both RCRA and DOT regulations .

The Bottom Line

We can all help to ensure clean air, clean soil and clean water in our neighborhoods by understanding and following federal and state hazardous waste/hazardous materials regulations. When accidents happen (and they do), labeling, manifests, emergency plans – everything that DOT/IATA and RCRA training develops for your company – are vital in the cleanup of the environment and protection of employee and public health and safety.

For more information or questions regarding how to handle hazardous waste or where to obtain training, please comment below or contact Emilcott.  As part of  The Emilcott Training Institute, we offer private hazardous communication, hazardous materials and hazardous waste training specific to company or site needs. We also offer public classes for both DOT/IATA and RCRA:

• 4-hour Introduction to RCRA Compliance (40 CFR 260-273)


• 4-hour Introduction to DOT/IATA Compliance (49 CFR 172.704 & DGR 1.5.0)

Martha Hernandez

When it comes to training, OSHA takes it seriously. With good reason:  training keeps workers safe and reduces incidents.  Many OSHA standards specifically require the employer to train employees in the safety and health aspects of their jobs. Other OSHA standards require the employer to make sure that only certified, competent, or qualified workers are assigned specific tasks--meaning that they have had special previous training.  OSHA compliance officers look to see that employers have provided appropriate training to their employees.  

In an effort to improve the consistency of the quality and content of health and safety training, OSHA has developed a series of “Outreach” training programs.  OSHA Outreach training focuses on segments of labor in the business sectors of General Industry and Construction and Maritime Industries. The courses are either 10 or 30 hours in duration with strict agenda guidelines containing focused and topical material, and must be taught by instructors that have extensive training and are approved to deliver the instruction.  The instructors or “Authorized Providers” must attend OSHA train-the-trainer courses, adhere to rigorous standards, and are subject to unannounced audits by OSHA at any time.  Over 3.2 million workers have participated in this type of training over the last 5 years!

In today’s blog we will look at the General Industry Outreach Training.

What is General Industry Outreach Training?

“General Industry” is defined by OSHA as any industry not directly involved with agriculture, construction, and maritime industries.  The standards applicable to General Industry are contained in Section 29 of the Code of Regulations, Part 1910.  As a result of the broad “General Industry” definition, one of the most popular OSHA Outreach courses is the 10-hr General Industry Training  which teaches safety and health hazard recognition and prevention.   OSHA Outreach training focuses on segments of labor in the business sectors of General Industry and Construction and Maritime Industries.

Who Should Attend a 10-hour General Industry Training Course?

The OSHA 10-hour General Industry course is designed for plant superintendents and engineers, floor foremen, safety professionals, project managers, and any other personnel responsible for workplace safety. Indeed, many organizations include all their plant personnel in this training because EVERYONE is responsible for safety. This course is an excellent introduction to health and safety programs for new employees or when it is time to create a paradigm shift in attitudes about safety at a facility.  The General Industry course can help line management get “safety religion”!  In fact, OSHA recognizes the completion card as an indication of the importance of safety and health at an organization.  Workers’ Compensation insurance providers often will reduce rates for companies that provide this training to their staff.

Emilcott’s OSHA 10-Hour General Industry Course

Based on the firm guidelines provided by OSHA, Emilcott’s 10-hour General Industry course provides important information about how OSHA is involved in the general industry community and how employees can recognize and control common workplace hazards. The training focuses on recognizing and controlling hazards found in the industrial workplace. It assumes no prior training nor requires prerequisite training. Much of our 10-hr General Industry course is interactive and hands-on.  More importantly, our courses are taught by instructors with real-world experience. Credentials and certifications provide a way to verify competency in particular fields but real-world experience should not be discounted. It’s one thing to talk about electrical hazards, it’s quite another to actually work around them. This experience allows our trainers to put the material in perspective and helps students make the connection between theory and practice.

Quality Training Makes a Difference

We have found that the OSHA Outreach Courses for both Construction and General Industry help site management really “get it” when it comes to site safety!  This training has given new life to existing safety programs and initiatives at our client sites.  Have you seen safety training make a difference is program compliance at your sites?