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Environmental Health and Safety Blog | EHSWire

Be Sure You Use the Proper PPE...or ELSE!

Posted by Shivi Kakar

Oct 16, 2011 11:02:04 PM

Ed Pearl

If you have a giant stack of the best personal protective equipment (PPE), but don’t use it, or just as important, don’t use it properly, are you trying to become an OSHA statistic? Knowing how to protect yourself from occupational hazards is a critical part of your job.

A Real Life PPE Correction

A few years ago, I was taking my annual HazWOPER 8-Hour Refresher class and a fellow student shared his story about PPE.
Part of his job was to open and close valves that allowed aviation fuels to flow to pumps used to fill airplane fuel tanks. As most of these valves were in confined space vaults without proper ventilation, he was often exposed to fuel vapors. After complaining about the headaches and dizziness that he was experiencing, his employer had him fit tested for a respirator. However, even with the proper-fitting respirator, he still had the same symptoms of overexposure.

Why didn’t the respirator control the exposure?  As a health and safety professional, the answer was obvious to me! I asked him, “What type of cartridge are you using?”
His reply, “I am using what was given to me.” Two days later he called me to tell me that he had been given HEPA filters – the WRONG cartridge for his petroleum vapors.

Instead he should have been using organic vapor cartridges. Without correction, this COULD have been become a very dangerous problem – just because of the wrong cartridge in the right respirator.

Proper Protection: Where Do You Start?

A perfect place to start understanding how to protect yourself is to know what you are dealing with on the job.

  1. What are the potential hazards? Is there more than one? Not sure? Ask questions! Make sure that you understand the hazards and risk before you are satisfied?

  2. Are there chemicals? Read material safety data sheets (MSDS) which have standardized information required by OSHA. MSDSs for all chemicals at your worksite must be made available by your employer for your review.  So that you, the worker, can read about the chemical hazards’ AND methods of protection. It’s the law!

  3. Review your job duties and PPE with your job site safety officer or a health and safety professional.

Proper Protection:  A Quiz

Q: If a person is working with an acid and they are wearing cloth gloves, who are they protecting?

A: Nobody!  The proper glove is a “chemical resistant” polymer for protection from acids (usually a neoprene or polyvinyl chloride (PVC) glove). Depending on the risk of splash, this worker may also need goggles, a face shield, and chemical resistant garments (apron, or partial or full body protection).

Q: If a worker is welding and only wearing a face shield designed for grinding, are they properly protected?

A: Absolutely not! The proper protection for a welder includes a welding shield equipped with filter lenses that have a shade number appropriate for the welding operation

Q: What happens when you wear a respirator that is not properly fitted?

A: You are potentially letting in the very substance you are SUPPOSED to be protecting yourself from! OSHA mandates that all required use respirators be tested for proper fit using “fit test” procedures detailed in the OSHA Respirator standard (1910.134).

The point is, there is the right PPE for the job…know what it is, and use it correctly!

Proper Protection:  Personal Responsibility

Today, information is at our fingertips on ALL subjects including PPE. Take the time to hunt around and find the information you need to properly protect yourself. There are all types of online courses and local resources including those provided by unions and insurance companies that welcome your questions and interest. Whether it’s the Internet or real, live health and safety professionals, ask questions to ensure that your PPE is right for you and the hazards you encounter.  If you find out that don’t have the proper PPE, don’t do the job or you’ll eventually become an OSHA statistic – or worse!
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Topics: OSHA, Personal Protective Equipment, General Industry H&S, OSHA Compliance, General EHS, Construction H&S, H&S Training, cartridge, construction, respirator

Heads Up! A quick look at hard hats…

Posted by Shivi Kakar

Oct 2, 2011 11:01:02 PM

By John Defillippo, CHMP

It makes sense, if you are injured in the head at work – you weren’t wearing a hard hat!

In 1980, Bureau of Labor Statistics (BLS) conducted a survey that indicated that about 80% of the workers sustaining traumatic head injuries each year do not wear head protection. Most of those injured were performing their normal jobs at their regular worksites with 70% indicating that they had had no instruction concerning hard hats. With this information, OSHA started the process to revise the PPE (personal protective equipment) standards and in 1994, the current version of the OSHA PPE standards was published.

So let’s move through time to the present – 30 years after the BLS survey… in 2010 OSHA handed out over $ 1.2 million in proposed penalties for about 2,000 head protection violations ( 29 CFR 1926.100 and 29 CFR 1910.135 ).  Most of these violations were for workers failing to wear hard hats when required.

When are hard hats required to be worn?

The Simple Answer:  If you are working where ANYTHING MIGHT fall, drop, fly, splash, or land on your head OR your head could come into contact with ANYTHING that MIGHT injure you, like moving equipment, chemicals or electricity, you need to be correctly wearing a properly fitting, ANSI-approved hardhat.

All hard hats should have an ANSI certification label on the inside of the hard hat’s shell. This label will clearly identify what type and class standards it was designed to meet. If this label is missing or cannot be read it should be replaced. Hard hats are classified according to the specific impact and electrical performance requirements they meet.  The details are specified in ANSI Z89.1-2009, American National Standard for Personal Protection—Protective Headwear for Industrial Workers.

Wearing them correctly means in accordance with the manufacturer’s recommendations. Not backwards (unless specifically so designed) and no hats underneath (except a proper hardhat liner).  A hard hat works by the shell deflecting the blow and absorbing shock and distributing the force of the impact over the suspension system. Wear it backwards or wearing hats (especially baseball caps) or carrying something inside is a really bad idea as it can adversely affect the way it works. Any stickers on the hat must be removable so the hard hat can be inspected and no paint is allowed.

If you are an employer you must determine if and when hard hats are required, provide the correct type and enforce their use.

All hard hats don’t protect our heads from all hazards!

How do you choose the right hard hat?  Do you need protection from just impact or do you also need protection from electrical hazards as well?

Impact Protection

Type I Hard Hats

Type I hard hats are intended to reduce the force of impact resulting for a blow to the top of the head only.

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Topics: OSHA, Personal Protective Equipment, General Industry H&S, OSHA Compliance, General EHS, Construction H&S, H&S Training, construction, class, electrical hazard, protective headwear, impact, ANSI, head protection, hard hat

Indoor Air Quality in Healthcare Facilities During Construction and Renovation

Posted by Shivi Kakar

Sep 25, 2011 11:49:48 PM

Daniel Senatus

A construction and renovation project within any facility creates a range of situations which can release debris, pollutants and contaminants that can impact the indoor air quality. These contaminants may be transported to other areas via HVAC systems, personnel coming and going through encapsulation barriers, and other factors that can subsequently affect people beyond the project area. Consideration of the effect upon indoor air quality is particularly important in healthcare settings when performing construction or renovation projects. Under these conditions, patients and other people with existing health problems that are in the hospital for treatment are at increased risk of contracting nosocomial infections.

Planning and Administrative Controls

All hospital construction projects must go through an Infection Control Risk Assessment (ICRA) to determine the impact of the project on patient care. The ICRA process is usually lead by the Infection Control staff with additional input from the construction company, engineering, and safety managers. See ICRA Sample here.

Advance planning by all project managers, combined with proactive communication efforts, can successfully allay concerns during and after construction activities. Healthcare facilities must consider other factors that may be a potential hazard as a result of the project and then determine the controls that must be put in place to mitigate them. Other critical factors include knowing what areas will be unusable for the extent of the project, and the time of day that will minimize disruption of services (which is variable depending upon whether it is an ambulatory or inpatient facility). It makes sense that most construction in hospitals should be done in a part of the hospital that is not operational or is vacant.

Hazards to Consider

PM (Particulate Matter)

Construction and demolition activities may introduce particulate matter such as dusts and fibers into an environment. Most concerning is respirable dust; these are dust particles that are small enough to bypass the body’s natural defense and clearance systems (mucous, cilia) and not trigger the coughing reflex which is the body’s way of removing mucous and foreign material from the lungs and upper airway passages. Once these particles get deep in the lungs, they are more likely to be retained and can lead to a whole host of health issues including altered lung function, lung cancer, and even heart problems later on.
Biological Hazards

Construction and demolition of materials may contribute to the release of and exposure to a variety of microorganisms: fungi (Aspergillus, Candida, etc.), bacteria, and medical waste. There is also a good chance that animal droppings, insect parts and standing water may be encountered when breaking into areas not normally accessed. Building materials that are constantly damp or wet may serve as breeding grounds for microorganisms. Workers can come into contact with bodily fluids and bloodborne pathogens originating from leaking medical equipment (suction lines, etc).

According to OSHA “ bloodborne pathogens are infectious organisms present in blood that can cause diseases in humans. These pathogens include, but are not limited to Hepatitis B, Hepatitis C and HIV (Human Immunodeficiency Virus), the virus that causes AIDS.”  Hepatitis B and C are of the most concern in the healthcare construction and renovation setting because they can survive outside of the body for up to a week in the right conditions. Construction activities can make these microorganisms airborne, affecting the indoor air quality and posing a threat to workers and immunocompromised patients.

Engineering Controls

Typically these are implemented as part of the Infection Control Risk Assessment (ICRA).

Create a containment barrier with fire-rated 6 MIL polyethylene sheeting around the source and isolate it from other areas of the building so that there is no recirculation of air from the work area into other spaces. HVAC intakes within the containment should be sealed to isolate the containment from general ventilation. Create a second barrier directly outside of the containment barrier (this is considered the “dirty” area) with a sticky mat on the floor, this is where used PPE (personal protective equipment) can be discarded. Create a third barrier (clean area) where clean PPE can be stored; this will actually be the space between the dirty area and the occupied spaces. High traffic zippers should be used on all openings and sticky mats should extend six feet from the clean containment entrance to the occupied areas. These mats should be replaced daily or whenever they look dirty, whichever comes first.
Air Cleaning and Negative Pressure

Use NAM (Negative Air Machines) with HEPA (High Efficiency Particulate Air) filters inside the enclosure. Filters should be changed as needed. Create a negative pressure environment so that lower pressure inside the containment pulls outside air in and prevents the contaminated air from escaping. The NAM should be on prior to construction being started and stay on for the duration of the project whether construction is going on or not. A micro-manometer can be used to verify that negative pressure is established and maintained.
Dust Monitoring and Microbial Sampling

Continuous dust monitoring outside of the area can help determine the success of the control measures put in place. This can be accomplished using direct reading instrumentation that is equipped with alarms which notify personnel when dust is escaping from the enclosure so that corrective action can be implemented before patients and staff are impacted.

Collecting surface and air samples to evaluate microbiological impacts can also aid in establishing additional preventive measures to protect health and safety of patients and staff.

PPE (Personal Protective Equipment)

Prophylaxes and PPE

Construction in certain places in a hospital can increase a construction worker’s chance of being exposed to contaminated waste and bodily fluids. It is good practice to inoculate personnel with the Hepatitis B vaccine in addition to PPE if there is enough time before the project (4 to 5 months) or if the construction company does a lot of work in functioning hospitals. The vaccine is given in a three dose series to reach immunity:

  • Dose #1 – Initial dose

  • Dose #2 – 30 days after dose #1

  • Dose #3 – 4 months after dose #2

All PPE selected for construction use at any healthcare facility must be “appropriate” for the task at hand. OSHA 1910.1030(d)(3)(i) states that personal protective equipment will be considered "appropriate" only if it does not permit blood or other potentially infectious materials to pass through to or reach the employee's work clothes, street clothes, undergarments, skin, eyes, mouth, or other mucous membranes under normal conditions of use and for the duration of time which the protective equipment will be used.

In damp areas or places with medical waste or other contaminated fluids, liquid-resistant Tyvek suits, gloves, shoe covers, respirators/N95 masks, and goggles should be worn. All PPE must be discarded before exiting the containment area.


Post-construction cleanup in healthcare facilities is the final stage but is just as important as any other phase. A combination of damp wiping and HEPA vacuums should be used to clean all dusty surfaces. After all trash, dirt, and debris have been removed, wet rags should be used to wipe down all areas within the containment and other areas immediately surrounding it.

Removal of trash may require that the trash be wiped down and clean and/or placed in a covered cart for transport away from the construction site to the waste dumpster so as not to spread contamination in sensitive areas. The renovated or constructed area should be in a sanitary condition before it is turned over to hospital staff. A careful inspection and testing program can aid in documenting the level of cleanliness.

Planning and Partnership

Construction in any healthcare facility is a necessity – whether it is a long-awaited and carefully planned renovation or a response to an urgent problem within the building envelope. In either case, protecting the health and safety of patients and caregivers in the facility and the construction workers can be achieved through planning, communication, and a thorough knowledge of indoor environmental quality (IEQ) and industrial hygiene (IH) procedures and best practices. The success of the project is also dependent upon the partnership of the medical staff, management personnel and all the outside resources that will address the problem and ensure that the construction is completed without creating any additional health issues.

If you have any questions about construction or renovation at a healthcare facility or clinic, please comment below or c ontact us and an Emilcott IEQ specialist will respond.

References and Further Reading

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Topics: indoor air quality, Personal Protective Equipment, Renovation, General Industry H&S, OSHA Compliance, General EHS, Construction H&S, Emergency Response, Air Monitoring, construction, respirable dust, remodel, ICRA, protect, biological hazards, health and safeety, containment, particulates, hospitals, sampling, demoliton, healthcare

343 + 2 = Changes in NYC Asbestos Regulations

Posted by Shivi Kakar

Aug 29, 2011 7:22:05 AM

Dale Wilson, CIH, LEED AP, Sr. Project Manager

"343" is a symbol of great sadness to members of the FDNY and their families as 343 is the number of FDNY firefighters who died on September 11, 2001. That staggering figure is remembered quite readily when recalling the events of that day and during the remembrances that have followed.  However, almost six years later, the lives of two additional NY firefighters were claimed during the demolition of the 9/11-damaged Deutsche Bank Building.

The 41-story Deutsche Bank Building stood adjacent to the World Trade Center and was severely damaged by falling debris and smoke when the Twin Towers collapsed. The damage to the skyscraper was so extensive that it had to be demolished. However, as the federal EPA requires, before it could be demolished, all asbestos-containing materials needed to be removed.

By August 18, 2007, demolition was well underway and the building now stood at only 26 stories tall.  Around 3:40 pm, a massive seven-alarm fire broke out as a result of a discarded cigarette in the asbestos decontamination unit on the 17 th floor.  The building had not been inspected by the Fire Department since March, when it should have been inspected every 15 days.  As a result, a crucial but inoperable fire standpipe forced firefighters to raise hoses up from the street to combat the flames.   Inside the building, three firefighters struggled to pull a hose through the deconstructed building. Only one of these men survived. The configuration of the asbestos abatement added to the difficulty of fighting a fire in an already structurally-compromised building.

The National Institute for Occupational Safety and Health (NIOSH), an institute within the Centers for Disease Control and Prevention (CDC), completed a description and evaluation of the incident as part of their fire fighter fatality investigation. Several items stand out from the asbestos abatement as contributors to the fire:

  • White plastic sheeting was used to partition the floor area into separate zones.  All these partitions created maze-like conditions for the firefighters.

  • Numerous zones were under negative pressure, as required for asbestos abatement, possibly drawing smoke and fire into localized areas.

  • Stairwell doors were blocked by wooded hatch covers as part of the construction of the asbestos containments.

  • Plastic sheeting, construction debris, and exposed lumber in partitions provided additional fuel.

These contributing conditions created by the asbestos abatement project have been recognized by several authorities, and in an effort to maximize safety, New York City enacted a number of new laws to ensure that asbestos abatement projects are conducted safely.  These laws impact the ways that asbestos projects are filed, approved and inspected, and involve new levels of cooperation among the agencies that oversee asbestos and construction safety:  the NYC Department of Environmental Protection (NYC DEP), the Department of Buildings (DOB) and the Fire Department (FDNY).  Most notably, the NYC DEP created the Asbestos -Technical Review Unit (A-TRU) to ensure that asbestos abatement is conducted safely and a new process for filing for asbestos permits called Asbestos Reporting and Tracking System (ARTS).

ARTS enables applicants to submit applications and/or receive approvals (or objections) electronically.  During the application process, applicants are asked questions to identify if

  • the building’s fire protection systems (e.g., fire alarm or sprinkler system) will be turned off as a result of the abatement work,

  • abatement work will result in blocked or compromised egress or whether any components of the fire protection system are going to be removed as part of the abatement

  • abatement work entails removal of passive fire protection (e.g., fire resistance rated walls, sprayed on fireproofing, or smoke dampers)

If there is an impact to any of these fire protection items then a comprehensive Work Place Safety Plan must be developed for the project indicating abatement containment areas and systems, obstructed and temporary exits, tenant protection and a description of any measures that will be taken to mitigate compromised fire protection systems or means of egress. As a final item intended to promote life safety during abatement projects, the asbestos supervisor must inspect exits daily to ensure that there are no exterior blockages or impediments to exiting. If any blockages or impediments are identified, work must stop until the blockage has been removed.  Essentially, deconstruction and asbestos-abatement work cannot compromise the safety of workers and firefighters.

As Carrie Bettinger noted in a past EHSWire blog, “ In our society and legal system it seems that, yes, someone (or many) has to tragically die before change and regulation are considered.” In this case, the tragedy was 343+2. Hopefully the A-TRU process and increased oversight from NYC DEP, DOB, and FDNY will prevent another similar tragedy from occurring.

Postscript:  The last of the Deutsche Bank tower criminal trials were completed in July, 2011. More information can be found at
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Topics: indoor air quality, health and safety, Construction H&S, EPA, Emergency Response, Homeland Security, H&S Training, worker safety, regulation, construction, emergency response training, demolition, 9/11, Work Place Safety Plan, asbestos, September 11, Deutsche Bank NYC, A-TRU, 9-11, Fire Safety

Fall Protection for Residential Workers – New Standards and New Tools to Help with Understanding Compliance Requirements

Posted by Shivi Kakar

Jul 23, 2011 11:51:15 PM

Lee Scott Bishop, CIH, MPH

Have you ever driven by a crew constructing a new house or installing a new roof?  Have you noticed a guardrail system in place to keep workers from falling when working on the upper levels?  Or have you seen a personal fall arrest systemsthat will lock and hold a falling worker like a seatbelt in your car?  Most likely you have not seen either of these fall protection systems in place for residential projects!

Nearly one residential construction worker dies each workday as a result of falls.  OSHA believes that no job is worth a life.  Dr. David Michaels, Assistant Secretary of Labor for OSHA has said “ Fatalities from falls are the number one cause of workplace deaths in construction.”  “ We cannot tolerate workers getting killed in residential construction when effective means are readily available to prevent those deaths

For workers employed by a mid-sized contracting group or a small crew engaged in house painting or outside repairs, OSHA has published a new directive which mandates the use of fall protection for all residential construction workers at heights of 6 feet off of the ground. The Occupational Safety and Health Administration’s (OSHA) Fall Protection Policy for Residential Construction went into effect on June 16, 2011. Employers engaged in residential construction are required to follow the provisions of 29CFR1926.501(b)(13) which states:
"Residential construction." Each employee engaged in residential construction activities 6 feet (1.8 m) or more above lower levels shall be protected by guardrail systems, safety net system, or personal fall arrest system unless another provision in paragraph (b) of this section provides for an alternative fall protection measure. Exception: When the employer can demonstrate that it is infeasible or creates a greater hazard to use these systems, the employer shall develop and implement a fall protection plan which meets the requirements of paragraph (k) of 1926.502.

Note: There is a presumption that it is feasible and will not create a greater hazard to implement at least one of the above-listed fall protection systems. Accordingly, the employer has the burden of establishing that it is appropriate to implement a fall protection plan which complies with 1926.502(k) for a particular workplace situation, in lieu of implementing any of those systems.

This is not a new Standard.  Previous to 6/16/11, the existing policy directive (which was never intended to be a permanent solution) allowed residential construction employers to follow alternative fall protection methods instead of using conventional fall protection, like safety nets, personal fall arrest or guardrail systems.  OSHA INSTRUCTION DIRECTIVE NUMBER STD 03-11-002, Compliance Guidance for Residential Construction has replaced that policy.  The Agency is also reviewing all letters of interpretation that referenced the cancelled directive.  This new directive neither creates new legal obligations nor alters existing obligations created by OSHA standards or the Occupational Safety and Health Act.  The new policy directive merely implements the Standard as originally intended.

While sharing the procedures and equipment available to employers and in use in the industry, OSHA itemizes other forms of protection against falls such as

  • 1926.501(b)(2)(ii) - Controlled access zones and control lines - leading edge applications.

  • 1926.501(b)(4)(i) and (ii) - Covers - falling through holes.

  • 1926.501(b)(5) - Positioning devices - face of formwork or reinforcing steel.

  • 1926.501(b)(7)(i) and (ii) - Barricades, fences and covers - falling into excavations.

  • 1926.501(b)(8)(i) - Equipment guards - falling into dangerous equipment.

  • 1926.501(b)(10) - Warning line system and safety monitoring system - roofing work on low-slope (4:12 or less) roofs.  Or, on roofs 50-feet (15.25 m) or less in width, the use of a safety monitoring system without a warning line system is permitted.

The Directive/Standard requires training of workers, by the employer, so they can recognize potential hazard areas and are familiar to the resources they can implement to protect themselves from those hazards.  Trained workers receive certification which must be updated when the tools used change.  There is an option for the employer to find this Standard “not feasible”.  However, this avenue requires a written Fall Prevention Plan which is site specific, approved by a “qualified person”, kept up-to-date, and kept on the premises where the work is being conducted, and addresses all of the requirements found in section K of the standard.

OSHA further allows fall protection elements not covered in the “501” Standard such as Scaffolds, Ladders, and Aerial lifts which can be found covered in 29 CFR 1926.453.

Information for this blog was obtained from  This presentation is an excellent resource for identifying acceptable fall protection options.  Pictures portray each type of protection as well as Bakers and Perry scaffolds; wall bracket, or top plate, scaffold system; Pump-jack Scaffold; and other options such as Extensible Boom Aerial Lifts.

So, if you are a residential contractor who needs fall protection, what’s the next step for you?  First, be aware that if you ignore the OSHA compliance laws, you are still accountable (ignorance is no excuse!).    OSHA has developed a dedicated and easy-to-understandOSHA Construction webpage with  a variety of comprehensive residential fall protection compliance assistance and guidance materials at  For more information and research

U.S. Department of Labor
Occupational Safety & Health Administration
Directorate of Construction – Room N-3468
200 Constitution Avenue
Washington, D.C. 20210

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Topics: OSHA, OSHA Compliance, General EHS, Construction H&S, H&S Training, Compliance, construction, safety, residential, fall, fall protection, workers

TMI: Is there such a thing as Too Much Information for environmental monitoring?

Posted by Shivi Kakar

Jun 20, 2011 7:25:00 AM

by Barbara Alves

It’s funny, let’s face it. Someone shares some tawdry detail about their personal life and we wince. TMI…please just keep it to yourself! We chuckle or shake our heads. In reality, information equals power. The more we know, the better decisions we can make. If we have only half the important details, we will make weak decisions.

Let’s use some history to drive this home. Although the Allied Forces ultimately won WWII, overconfidence from the D-Day invasion and the quickness with which the Allies pushed the Germans eastward across France, caused Eisenhower to underestimate the tactical abilities and determination of Hitler’s army. This resulted in the disastrous Operation Market-Garden in the Netherlands and the Battle of the Bulge in the Ardennes. Because of lack of current data in the Market-Garden strategy, the Allies were not in Berlin by the end of 1944 as they expected. Instead, by December of 1944 the Germans had broken through into the Allies' line of advance in the Ardennes and caught us ill-prepared. Poor intelligence cost tens of thousands of lives.

This is perhaps one of the most dramatic examples of “not enough information”, but it makes the point. Amazingly, with the communication capabilities of today’s wireless, cellular, Internet and other “instantaneous” technologies, many choose NOT to use this power to gather all the project information that they can get. Like an ostrich with it head in the sand, if they don’t know something, they feel that they don’t have to react or worse, be held accountable. This “ignorance is bliss” type of decision-making is often the primary reason people make the choice to NOT implement real-time environmental monitoring on construction and remediation sites. “If we don’t know that it’s dangerous, than it must be ok, right?” Sounds crazy, but it’s true!

Using a modern and proactive approach, technology is available (right now) to continuously retrieve important and fluctuating intelligence about environmental field conditions. The information is gathered and immediately transmitted wirelessly to smart phones, PDAs, PC and laptops – all accessible by the Internet for all authorized viewers. And the data keeps rolling in throughout the project’s life cycle. What power!  To be able to make an immediate decision (or better yet, a correction) from a remote location and save time, expense, and ultimately, human health.

And what about the ability to review, store and retrieve project environmental data, which was collected over a period of time, for comparison or trending?  Super powerful! This can only result in better planning. Adding better decision-making abilities to better planning capabilities should ultimately result in doing a better job, a cleaner site and healthier workers. Who wouldn’t want that?  So the real question is, if an environmental monitoring system is NOT collecting reliable, real-time data, aren’t you really just making anecdotal decisions based on guesstimates instead of a foundation of actual data?

Many historians feel that Eisenhower’s planning of Operation Market-Garden was anecdotal because it was based on what the Allied Forces experienced coming out of Normandy. It was certainly wrong. Historians also believe that what turned the war around was the unbelievable ability our forces had to assess the real-time intelligence they gathered as they were “living in the field of battle” to make tactical decisions and outsmart the enemy.

If real-time, reliable data is available to help you make good, solid decisions, get it and use it. You will do a better job and make fewer mistakes. Information is power and you can NEVER have too much of it.  How have you used TMI to develop a better project or framework?
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Topics: indoor air quality, General Industry H&S, General EHS, Construction H&S, Emergency Response, Air Monitoring, Hazardous Waste Management, Air Sampling, construction, remediation, technology, environmental monitoring, environmental air monitoring, Respiratory, perimeter monitoring, air montoring

Expensive, damaging and possibly fatal…the truth about occupational slips, trips and falls!

Posted by Shivi Kakar

Jun 13, 2011 3:00:40 AM

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….

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?
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Topics: health and safety, General Industry H&S, OSHA Compliance, General EHS, Construction H&S, Emergency Response, H&S Training, Compliance, worker safety, Occupational Safety, Lab Safety & Electrical, construction, General Industry, Fire Safety, fall protection, trips, slips

May 2011 was Busy for OSHA

Posted by Shivi Kakar

May 31, 2011 6:18:05 AM

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!)

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?
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Topics: OSHA, General Industry H&S, OSHA Compliance, General EHS, Construction H&S, Compliance, worker safety, reporting, regulation, construction, fall protection, federal register, log, standards, musculoskeletal disorder

10-hr OSHA Outreach Training for the Construction Industry Most Popular

Posted by Shivi Kakar

Apr 26, 2011 2:21:46 AM

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?
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Topics: OSHA, OSHA Compliance, Construction H&S, Compliance, worker safety, construction, Occupational Training, outreach training

OSHA Raises the Bar with Outreach Training Programs

Posted by Shivi Kakar

Apr 24, 2011 2:48:10 PM

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?
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Topics: OSHA, General Industry H&S, OSHA Compliance, General EHS, Construction H&S, H&S Training, Compliance, construction, General Industry, Occupational Training, outreach training

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