The Occupational Safety and Health Administration’s (OSHA) recordkeeping requirements have been in place since 1971 (29 Code of Federal Regulations CFR Part 1904). The requirements were updated in 2002 to make it easier for employers to comply. OSHA has again updated the recordkeeping rule for 2015 to include two key changes.Read More
Environmental Health and Safety Blog | EHSWire
Topics: OSHA, OSHA Recordkeeping regulation (29 CFR 1904), health and safety, OSHA Compliance, Occupational Health, health hazards, occupational health and safety, reporting, Medical Records, OSHA Injury and Illness Recordkeeping and Reportin, OSHA 300A Annual Recordkeeping Summary Form, incident investigation
Schools are out and many organizations bolster their staffs with temporary or seasonal help. The Occupational Safety and Health Administration (OSHA) and the American Staffing Association recently signed an alliance to work together to further protect temporary employees from workplace hazards. OSHA has been monitoring and reporting on the state of temporary worker safety through its National Advisory Committee on Occupational Safety and Health's (NACOSH) Temporary Worker workgroup very closely as this sector has grown. ASA, founded in 1966, serves as the voice of the U.S. staffing and recruiting industry. With more than 1,600 members, ASA advances the interests of staffing and recruiting firms through advocacy, public relations and education.
I have seen no less than 20 emails inviting me to webinars that will help me get my house in order for all the changes coming with the OSHA Hazard Communication Standard this year. From the tone of these emails, it would seem like the sky is falling! You know what? The sky is not falling … although there is work to be done to implement the changes.
OSHA has a reasonable timeline for compliance and with planning, we can get through this with ease! Here’s our take on the issue …
On first glance, the changes seem monumental …
- 90,000 workplaces = the number of sites that produce hazardous chemicals in the US. HazCom 2012 requires these manufacturers to.
- Modify the hazard classification for chemicals they produce
- Create new labels to highlight these hazards
- Draft and distribute revised Material Safety Data Sheets (now referred to as Safety Data Sheets)
- 43 million US workers = the number of workers in the 5 million facilities that will be notified of the new physical and health hazard classifications for the chemicals in their workplaces by new labels and Safety Data Sheets communicating these hazards.
- $201 million a year = the cost OSHA estimates to roll out HazCom 2012 for the entire United States. OSHA lists yearly program element costs as follows:
- $22.5 million for chemical hazards classification based on the GHS criteria and revising safety data sheets and labels to meet new format and content requirements
- $24.1 million for printing packaging and labels for hazardous chemicals in color
- $95.4 million for employee training about the new warning symbols and the revised safety data sheet format under GHS
- $59 million a year for management to become familiar with the new GHS system and to engage in other management-related activities as may be necessary for industry's adoption of GHS
Let’s look at the actual tasks each organization has to accomplish for compliance:
With a plan … these tasks are quite doable!
- Chemical Users: Continue to update safety data sheets when new ones become available, provide training on the new label elements and SDS format and update hazard communication programs if new hazards are identified.
- Chemical Producers: Review hazard information for all chemicals produced or imported, classify chemicals according to the new classification criteria, and update labels and safety data sheets.
OSHA’s HazCom 2012 Compliance Timeline …
|December 1, 2013
|June 1, 2015
|June 1, 2016
On April 25, Emilcott will be presenting a HazCom 2012 Webinar for anyone interested. Our approach—let’s not try to alarm everyone, but let’s provide a basic understanding of the changes made to the standard and a simple plan of action for employers to meet the regulatory requirements within the specified time frames. Would you like to join us?
Register here: OSHA HazCom 2012: A Simple Plan for Compliance
At the heart of this research lies an examination of several different types of workers, including nurses, police officers, truck drivers, manufacturing laborers, and white collar workers. Of particular importance to these sleep loss and sleep deprivation studies are those who perform shift work and have night-time work schedules.
Of high interest is the effect of occupational stress and health of police officers studied in Buffalo, New York. Statistically important health issues include tiredness due to lack of quality sleep, especially among those officers who work night shifts, and who report less than six hours of sleep a night. In addition, risk of injury is greater to the night shift workers, because of these unnatural sleep and work schedules
There are several research studies that are either ongoing or have been completed regarding sleep deprivation in truck drivers, manufacturing workers, and even white collar workers. Large amounts of data collected (from long-haul truck drivers especially) show a wide array of sleep disorders, including sleep apnea, fatigue and the overall lowered safety expectations from drivers who do not get enough quality sleep.
Another group being studied is American nurses, especially pregnant female nurses. In collaboration with the Harvard Nurses' Health Study, results are showing that an increased number of adverse reproductive outcomes and menstrual cycle abnormalities can be attributed to shift work; especially those studied who work a night shift.
In relation to the sleep deprivation and sleep loss health issues such as fatigue, depression, headaches, malaise, and reproductive issues, the studies point out that work hours that are too long for good health can actually attribute to the decline of healthy white blood cells, which are the first line of defense against such devastating diseases as cancer and autoimmune disorders.
In an effort to stem the adverse health effects and potential safety issues inherent in shift workers and those who work too many hours, NIOSH scientists are seeking development and training programs for managers and workers in several different fields of employ, including those mentioned above. They hope to raise awareness of the problems, encourage healthy sleep habits, and foster a healthier management style that would see more reasonable hours for workers. The dissemination of this information is being brought about through workplace posters, websites, webinars, online training courses, and public service announcements.
Topics: Emilcott, NIOSH, health and safety, General Industry H&S, General EHS, Sleep and Work Schedules, National Institute for Occupational Safety and Hea, Sleep loss, worker safety, Sleep Deprivation
Secretary of Labor Solis and Assistant Secretary Dr. Michaels provided a press release conference call this morning where they indicated that the new standard will reduce injuries to employees, reduce costs for employers and allow US manufacturers to be more competitive in a global market.
There were a few questions regarding combustible dust and unclassified hazards, which are now labeled as Hazards NOC (not otherwise classified). Combustible dust will be classified as such and will not be placed in the Hazards NOC category. A number of compliance dates were specified including employee training to be completed by December 1, 2013 and full compliance by June 2016.
OSHA launched its new website on HazCom 2012 today. It provides guidance on compliance and frequently asked questions regarding the new standard.
Now that the final rule is released, look for an Emilcott Free Webinar, HazCom 2012 made Simple
At Emilcott, 2011 was a successful year where we were able to tackle new projects, serve our clients and continue to respond to current industry issues in the environmental, health and safety field. Though we have had many great memories from 2011, we would like to mention some of the things that stood out most in our business for 2011.
Hurricane Irene the immense and powerful Atlantic hurricane that left a path of destruction and devastation was something that definitely stands out in 2011. We remember this event not only because of the wreckage caused by the storm, but also because of the after effects. The staff at Emilcott recognized the importance of addressing the legacy of water intrusion and the promise of mold after the storm and stressed to clients the importance of timing to address how to respond to this problem, as well as the importance of selecting the proper remediation technique along with an EHS mold expert and Emilcotts mold remediation strategy. (Read more: Hurricane Irene Leaves a Legacy of Water Intrusion and the Promise of Mold)
Energy Sector Emilcott has been thrilled to be able to participate in many different initiatives within the energy sector. Regionally important to the growth of our economy, the ongoing infrastructure improvements have given us substantial health and safety support work. In EHSWire during 2011 we addressed many occupational hazards as Occupational Heat-related Illnesses where we went over the symptoms that workers may experience, as well as what should be done if someone does experience these symptoms. Besides dealing with working conditions such as heat, Emilcott also provided information on the truths about occupational slips, trips and falls which ended up costing American businesses $13.67 billion in workers compensation costs in 2008. Adhering to proper safety protocols and preventing injuries is something that benefits businesses and their workers. OSHA provides a Walking/Working Surfaces Safety and Health Topic page which provides links to all the applicable standards.
With issues such as heat affecting the health of workers to preventing injuries on job sites, Emilcott has seen our fair share of mishaps. Being able to share our experiences and knowledge with others never gets old. From teaching someone the hazards about working near a crane, or things you should do when working in certain environments, Emilcott has always tried keeping people in the loop. We even have a 10-Hour Construction Industry Outreach Training Course based on the requirements established by OSHA which is a very hands-on and interactive class that we recommend to avoid a future work related issue. (Read more: Work Near a CRANE? Learn the Hazards!)
9/11 Tenth Anniversary focused the changes that have occurred since 9/11/2001 such as the new precautions that have taken place on the American Chemical Security issue. The DHS (the Department of Homeland Security) has been increasing their focus on utilities and chemical facilities which may become targets for terrorist activities and the DHS Chemical Facility Anti-Terrorism Standard (CFATS) now requires completing and submitting a Top Screen analysis to the DHS.
The James Zadroga Act , which was authorized to broaden, renew funding and extend benefits to Ground Zero workers whose death was a result of exposure, is of great significance and has put new emphasis on the importance of proper real-time environmental site monitoring. New technologies are available to protect site workers and the public from exposure to hazardous substances such as those from the collapse of the WTC towers. (Read more: 9/11 Tenth Anniversary Focuses on American Chemical Security)
Toxic Substance Control Act (TSCA) was of major importance not only to Emilcott, but also to facilities who are manufacturers or importers of chemicals in amounts of 25,000 pounds or greater. With so many questions regarding TSCA and the changes, Emilcott decided to put on a free webinar along with posting a number of blogs that answered many of the concerns our clients had. Emilcott was able to use its expertise and help many clients with TSCA compliance questions and concerns regarding the developments of IUR reporting and reporting obligations in 2011 for the calendar year 2010. (Read more: August 2011 Update on the TSCA IUR-now-CDR Rule)
Though Emilcott has had many remarkable memories of 2011, we felt these 4 really left an impression on our business. Emilcott is privileged to know that we were able to assist our clients in many different businesses not only in 2011, but throughout our history. Emilcott looks forward to a productive 2012 and we are excited to see what this year has in store for us.
Do you have any environmental, health or safety concerns for 2012? If so, please share them with us below!
"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 buildings 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 http://www.nytimes.com/2011/07/07/nyregion/final-defendant-is-acquitted-in-deutsche-bank-fire-trial.html.
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
Its summertime again... time for barbeques, bathing suits, and sunscreen. We all know we should protect ourselves from the sun damage to skin, eyes, and possible skin cancer. I remember as a child the only available sun lotion was 2, 4, and 8, and it was considered healthy to get a little red. A result of that latent exposure to the sun was Melanoma that killed my sister at age 47.
When asked about potential occupational overexposure to sunshine, I had to ask:
- Is there more to know about protecting workers from sun exposure?
- What are the regulations and occupational exposure recommendations for exposure to ultraviolet (UV) radiation?
Here are some answers .
It is well established that UV light is the part of sunlight that causes sunburn. UV light is a type of non-ionizing radiation with very high energy, which is why it can cause tissue damage. So, it follows that one should protect themselves from overexposure to this commonplace yet risky energy source.
What do the government regulators and research institutions recommend?
The only reference in the Occupational Safety and Health Administration (OSHA) standards to UV radiation regards eye protection from UV radiation generated by welding arcs. OSHA does have an informational webpage titled Protecting Yourself in the Sun.
The American Conference of Governmental Industrial Hygienists (ACGIH) has a recommended standard for employee exposure to UV radiation; however, this standard relies on measurement of the UV exposure and is intended for indoor/manmade sources of UV radiation.
The National Institute of Occupational Safety and Health (NIOSH) Workplace Safety and Health Topics webpage, UV Radiation, is devoted to providing information to workers and employers regarding the risks, health hazards, and recommended control methods for reducing the risks of sunburn and skin cancer from sun exposure. NIOSH recommends the following for protection from occupational exposure to UV radiation:
- Wear sunscreen with a minimum of SPF 15.
- SPF refers to the amount of time that persons will be protected from a burn. An SPF of 15 will allow a person to stay out in the sun 15 times longer than they normally would be able to stay without burning. The SPF rating applies to skin reddening and protection against UVB exposure.
- SPF does not refer to protection against UVA. Products containing Mexoryl, Parsol 1789, titanium dioxide, zinc oxide, or avobenzone block UVA rays.
- Sunscreen performance is affected by wind, humidity, perspiration, and proper application.
- Old sunscreens should be thrown away because they lose their potency after 1-2 years.
- Sunscreens should be liberally applied (a minimum of 1 ounce) at least 20 minutes before sun exposure.
- Special attention should be given to covering the ears, scalp, lips, neck, tops of feet, and backs of hands.
- Sunscreens should be reapplied at least every 2 hours and each time a person gets out of the water or perspires heavily.
- Some sunscreens may also lose efficacy when applied with insect repellents, necessitating more frequent application when the two products are used together.
- Follow the application directions on the sunscreen bottle.
- Another effective way to prevent sunburn is by wearing appropriate clothing.
- Dark clothing with a tight weave is more protective than light-colored, loosely woven clothing.
- High-SPF clothing has been developed to provide more protection for those with photosensitive skin or a history of skin cancer.
- Workers should also wear wide-brimmed hats and sunglasses with almost 100% UV protection and with side panels to prevent excessive sun exposure to the eyes.
The International Commission on Non-Ionizing Radiation Protection (ICNIRP) and World Health Organization (WHO) published a recommendation paper Protecting Workers from Ultraviolet Radiation, 14/2007. This document addresses both natural and manmade UV sources. It provides an interesting risk matrix based on latitude, work conditions, work environment and clothing and makes recommendations for additional protection based on the combination of these factors. The book is comprehensive and full of interesting facts for anyone interested in diving in. For example, dark sunglasses without the dark side shields (or wrap-around design) will allow a substantial amount of UV exposure to the eyes. This is because when wearing sunglasses the pupil and eyelids open proportionally to the darkness of the sunglass then the light exposure comes in from the sides!
Occupational health programs for outdoor workers at risk from UV exposure include the classic industrial hygiene elements:
Do you have hazardous chemicals in your workplace? If you think the answer is no, are you sure?
OSHA defines a hazardous chemical as one that presents either a physical or a health hazard. Many common and readily available products such as paints, cleaners, and other materials found in the workplace meet this definition. In fact, last year OSHA issued over 6,300 violations to companies that failed to comply with this standard. As we noted in a previous blog, non-compliance with the Hazard Communication standard was the third-largest source of OSHA violations in 2009 and 2010!
If you are an employer, you have a legal obligation to provide a workplace that is free of recognized hazards and to communicate any hazards present to those in the workplace. In 1985, OSHA established the Hazard Communication Standard ( 1910.1200) to ensure, in part, that all workers have the "right-to-know" about the hazardous chemicals in their workplace.
Essentially, employees have a Right-to-Know about any hazardous substances that they may come into contact with at work and how to protect themselves from adverse affects. Employees, for their part, have a responsibility to follow directions and work safely by using products for their intended purpose and in accordance with the manufacturers instructions to reduce risk and chance of exposure. This is where the Hazard Communication Standard kicks in, as all workplace information about hazardous substances needs to be in a Written Hazard Communication Program. This "HazCom" program must contain
- A list of all hazardous chemicals in the workplace and a Material Safety Data Sheets (MSDS) for each chemical (or product) on that list
- All employees must have access to that list and the MSDSs during their work shift
- Methods to communicate hazards of these chemicals to employees, on-site contractors and visitors such as signs and labels
- Records showing that all employees have been properly trained to understand the hazards, read the MSDSs and understand labeling and signs.
In addition to the federal OSHA requirements for labeling, the State of New Jersey has specific labeling requirements for all vessels, piping and containers that contain hazardous chemicals.
So, do you have hazardous chemicals in your workplace? Are you rethinking your answer?
If you have products that arrive with an MSDS, and you have not implemented a written HazCom Program, youll need to get a program in place to be OSHA compliant. If you have been following the standard, consider the following:
- Are you keeping up with its requirements?
- When was the last time your HazCom Program was reviewed?
- Is your hazardous chemical list and MSDS collection up-to-date?
- Do you know what OSHA considers Hazardous?
- Is every hazardous chemical container labeled properly even the transfer containers?
- Are ALL your employees trained about the workings of your HazCom program and the hazards of each chemical in their workplace?
Now do you know the answer? Or, do you have more questions?
If you are confused or intimidated, dont worry. A great resource is the Institute of Hazardous Materials Managers which certifies individuals as Hazardous Materials Managers (CHMM) and Hazardous Materials Practitioners (CHMP). These trained professionals must demonstrate various levels of knowledge, expertise, and excellence in the management of hazardous materials. And, there are EHS (Environmental, Health and Safety) experts like Emilcott everywhere their job is to help companies stay in compliance with state and federal regulations while protecting employees. No matter what resource you find, just ask if they are experienced in developing Hazardous Communication programs. Not only will workers stay health and safety, youll see added benefits like prevention of property damage, reduced insurance claims and costs, and, of course, your company will not be cited for OSHAs third most-common violation!
Have you found any chemicals in your workplace that you didnt know are hazardous? Does your right-to-know increase your job comfort level or concern you? And, have you carefully reviewed the company HazCom plan so that you understand what to do if ?
Topics: OSHA, health and safety, General Industry H&S, OSHA Compliance, General EHS, H&S Training, Hazardous Waste Management, HazCom, Compliance, regulation, General Industry, emergency response training, Exposure, hazardous chemicals, chemicals, MSDS, Hazard Communication Standard
Slips, trips, and falls arent at the top of anyones 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 Americas 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. Thats 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. OSHAs 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
- 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
- Provide properly rated ladders
- Maintain ladders in good condition
- Walking and working surfaces
- Provide worker training for
- Slip, trip, and fall hazards
- Ladder use
- Personal fall arrest systems
- Provide worker training for
Dont Slip Up on Safety!
Bruising, twisting or breaking a bone makes your work life and personal life extra challenging its 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 youre working on the job, theres 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. Dont 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?
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