Environmental Health and Safety Blog | EHSWire

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!

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Topics: Emilcott, OSHA, Personal Protective Equipment, health and safety, General Industry H&S, OSHA Compliance, General EHS, Construction H&S, Emergency Response, H&S Training, Compliance, worker safety, Occupational Health, Occupational Safety, Lab Safety & Electrical, emergency response training, Fire Safety, Exposure, Respiratory, Occupational Training, RPP, respirator 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)

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Topics: Emilcott, OSHA, DOT, General EHS, EPA, Emergency Response, H&S Training, Hazardous Waste Management, Hazardous Materials, Compliance, Lab Safety & Electrical, regulation, General Industry, emergency response training, Occupational Training, IATA, Resource Conservation and Recovery Act, Lab Safety, hazwaste, transportation, hazmat, generation, RCRA

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?

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Topics: Emilcott, OSHA, health and safety, General Industry H&S, OSHA Compliance, General EHS, H&S Training, Compliance, worker safety, Occupational Health, Occupational Safety, General Industry, Occupational Training

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

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

Dale Wilson, CIH, LEED AP

The US Environmental Protection Agency (EPA) ended 2010 with two announcements that impact Indoor Environmental Quality (IEQ).   The first of these announcements involves polychlorinated biphenyls (PCBs) in school environments. In their press release and guidance document , the EPA is recommending the removal of all PCB-containing fluorescent light ballasts from school buildings.  The focus is on school buildings built prior to 1979 which have not undergone a complete lighting retrofit since that time.  (Note:  In 1979, the EPA banned the use and processing of PCB.)  The EPA makes these recommendations following the detection of elevated PCB concentration in indoor air at several schools where damaged PCB -containing light fixtures were present.  According to the EPA , “PCBs have been demonstrated to cause cancer, as well as a variety of other adverse health effects on the immune system, reproductive system, nervous system, and endocrine system.”

While this announcement is directed at schools, commercial and/or residential buildings with pre-1979 fluorescent light fixtures should also consider following this guidance to prevent exposure to their building occupants.  While replacing such fixtures will improve indoor environmental quality, there is another likely benefit:  energy costs are reduced when replacing these older light fixtures with modern, energy-efficient models.   The costs of installing lighting equipment upgrades may also be offset if there is an active incentive program offered by your state government and/or local utility such as these Clean Energy programs offered by the state of New Jersey.  This type of office or plant upgrade is a quadruple “win” opportunity for companies who qualify: 

• Improve employee work conditions by enhancing their IEQ


• Reduce your operating costs


• Participate in an environmental or “green” program


• And, best of all, have some or all of the equipment paid for by an outside resource!

EPA’s second end-of-2010 announcement recommends testing for radon, as January is National Radon Action Month.   Radon is a naturally-occurring, colorless, odorless gas that can impact your building’s IEQ if mitigation measures are not in place.  Radon exposure is the leading cause of non-smoking lung cancer.  Winter months such as January are the perfect times to test for radon as doors and windows generally remain closed for extended periods of time and heating equipment is in operation potentially creating a pressure differential between the soil and the building’s interior that would promote the migration of radon into the building’s indoor air. 

To find out if your building is located in an area prone to elevated indoor radon concentrations you can view the EPA Radon Map.  Buildings located in Zone 1 counties (red colored) have the greatest potential for elevated radon, followed by Zone 2 (orange) and, finally, Zone 3 in yellow. 

Two easy ways to start 2011 off on the right foot -- follow the EPA’s recommendation by eliminating two significant and relatively easy IEQ concerns, PCBs and radon, from your building.

Have you participated in a state or federal lighting retrofit program? Did the electrical contractor find anything suspicious? How easy was the process? And, have you tested your home or office building for radon? What were the results?

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Topics: indoor air quality, health and safety, General EHS, EPA, Air Sampling, Exposure, chemicals, schools, environmental air monitoring, indoor environmental quality, radon exposure, radon, fluorescent lighting, PCB