Environmental Health and Safety Blog | EHSWire

Capt. John DeFillippo, CHMP, EMT-B

Every organization develops a “safety culture”, be it good or bad. It is immediately observable to anyone who cares to look, and more people are – particularly prospective clients and business partners.  When evaluating vendors and business partners, companies with strong safety cultures will steer clear of doing business with companies with poor safety records; the risks and exposures are too great.  In addition to the obvious reasons of possible injury or death to workers or the public, there is the potential for serious damage to a company’s image and reputation should their vendor or subcontractor have an incident or accident.  We’ve all heard some of the stories recently in the news; reporters will highlight a major construction accident and all the players are named, regardless of their culpability.

Government agencies also use strong criteria to evaluate potential vendors. The State of New York has severely tightened up its safety and health requirements following the series of construction accidents that have plagued NYC in recent years.

A company can develop a comprehensive health and safety programs. It can post attention-getting signs and posters warning workers of hazards. It can also provide all manner of safety and personal protective equipment and conduct training for employees. These measures are good, but as soon as a supervisor or company owner walks onto a site ignoring the PPE requirements, all this good goes out the window. “Do as I say, not as I do” is not the way lead. The rules must to apply to all, without exception. Even more importantly, owners and managers should set a proper example. Professional experience has shown me that when management creates and “lives” a proactive safety culture, it will get the best results. It’s the front-line managers and supervisors that make the difference.

And it’s a never ending task. Maybe your company has a few workers who constantly violate the safety rules without any real consequences or discipline. The message being sent is pretty clear: the company doesn’t take safety seriously. Most people realize that the rules are there for a reason; their protection and it’s the law.  However, there will always be a small percentage of people that just don’t get it. Without enforcement of the policies, there is not only the risk of worker injury, but an erosion of the “safety culture” of the organization and a negative impact on morale. Plus, it is the employer and management who will be responsible for any fines or penalties handed out as well as increased insurance premiums, particularly workman’s compensation. Often, they are found personally responsible. Why would anyone risk this?

The point is that paying lip service to safety won’t fly anymore -- proactive is best. There are all kinds of resources to help your company succeed. OSHA even offers free services:    http://www.osha.gov/dcsp/smallbusiness/consult.html and http://www.osha.gov/dte/outreach/construction_generalindustry/index.html.  You may also get help from a trade or professional association that you belong to. Health and safety consulting services from companies like Emilcott who are experienced in honing in on risk and compliance can be a great investment to shift your company onto the right track.

Have you ever worked for a company that has an ineffective or sham health and safety policy? How did it make you or fellow employees feel? Was there a tipping point event that made them switch to being proactive and how did they implement a new, comprehensive program (that worked)?

Image Credit:  www.lumaxart.com

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Topics: Personal Protective Equipment, health and safety, General Industry H&S, 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, Occupational Training, Safety Culture, Leadership

Paula Kaufmann, CIH

I just read an article in the New York Times ( Hazards: Watch Where You Point That Laser) about a 15-year boy who bought a laser pointer on the Internet.  He selected this particular model as the light was supposed to be powerful enough pop balloons and burn holes in fabric.  And, it was all he had hoped for and more.  He popped balloons from a distance and burnt holes in his sister’s sneakers.  However, he literally got burned by the “and more” features of his new toy. Tragically, he shined the pointer in a mirror and the light beam reflected back onto one of his eyes causing major damage. 

My first thought was, “How stupid was that”.  My second thought was more balanced, “I guess he wasn’t properly trained or didn’t read the instructions”.  I’ve been told by loved ones that I can be a bit intrusive (if not annoying) with my unconscious monitoring of unsafe behavior in my constant role of “health and safety inspector”.  So be it!  According to the Home Safety Council, every year there are millions of preventable home-related incidents and accidents “ that result in nearly 20,000 deaths and 21 million medical visits”.  

Here are some examples of what I consider stupid (or let’s say shortsighted) actions -- some at work, some at home. Yes, I make these observations all the time to family and friends and, as you can imagine, that can be a bit trying for them but I feel it’s worth the price.

• Using an electric lawn mower on a damp lawn with damaged extension cords repaired with electrical tape AND with the ground prong clipped. Worse yet – asking my child to use this dangerous setup!


• Removing the guard from a circular saw.


• Cutting overhead branches without wearing a hard hat or eye protection.


• Smoking a cigarette, cigar or pipe while filling a car with gas. Worse yet – a gas station attendants smoking cigarettes while pumping gas.


• Construction or utility workers using a jack hammer on a concrete sidewalk and not wearing safety glasses or hearing protection while wearing a hard hat.


• Police directing traffic without wearing a traffic safety vest. Worse yet – doing this after dark in a dark uniform without white gloves.


• Mowing the lawn in sandals and shorts without eye protection while listening to music at full volume (using earphones not noise reducing hearing protection).


• Eating snacks while removing paint from old furniture or woodwork in a house built before WW I, which makes the lead content highly probable.  Worse yet – having your kids help you while you dry sweep or use a regular household vacuum to “clean up” the area.


• Utility worker serving as a confined space watch (at the ground level of an underground manway) talking (and laughing) on a cell phone and drinking coffee (usually about 10 feet from the manway).


• Nail salon workers wearing dust masks while applying acrylics to customers’ nails -- dust masks don’t reduce exposure to the chemicals used during acrylic application. Worse yet - acrylic nail services happening in a tiny storefront with limited ventilation.


• Being “careful” when installing an electrical light by shutting off the switch to the power but not the circuit breaker to the line.


• Applying insect repellant from an aerosol can while sitting by a bonfire.


• Removing a bicycle helmet as soon as your mom can’t see you as it is just too hot to protect your brain.

And, finally, one of my favorite tales is the time that I was away from home on a business trip, and while I was gone, my husband renovated my home office space.  He did a beautiful job, but when I asked him why he went through the effort to surprise me, he said “It is so much easier to get work done when the OSHA inspector is not home”.  I just wish I could have given him a citation.

If you’re interested in home safety, September – National Preparedness Month -- is a good time to begin.  You can start with a visit the website of the Home Safety Council® (HSC), a national nonprofit organization dedicated to preventing home-related injuries. You’ll  find dozens of tips, stories and videos and information about Safety Saturday (September 25) at participating Lowe’s stores.

What are some of your favorite observations of “stupid” health and safety practices outside of the work environment? And, if you’re a health and safety professional, how do you balance maintaining a safe home life without driving your friends and family crazy?

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Topics: health and safety, General Industry H&S, General EHS, Emergency Response, worker safety, Occupational Safety, emergency response training, Fire Safety, Public Safety, water safety, industrial hygiene, home safety

Dian Cucchisi, PhD, CHMM

Environmental Health and Safety Professionals are often faced with questions that do not seem to have black and white answers, but, in reality, regulatory requirements are not that gray.  A common question: When do the requirements for 29 CFR 1910.120 and 29 CFR 1926.65 (OSHA’s Hazardous Waste Operations and Emergency Response regulations) apply?  The challenge for EHS professionals is to communicate to workers the distinction between what are considered environmental health risks and the risks to human health, and to clarify the difference of the word “hazardous” as used by various environmental protection agencies and Occupational Safety and Health Administration (OSHA).

The Environmental Protection Agency (EPA) and the state environmental protection agencies have standards for soil and groundwater “cleanliness” for residential and non-residential properties.  Soil or groundwater in exceedence of those standards needs to be remediated (usually by removal), but to add to the confusion, sometimes when soil and/or groundwater is removed from the site and transported to a disposal facility it may not fall into the EPA’s definition for hazardous waste.  So here lies the misunderstanding; if it is not classified as “hazardous waste” by the EPA, people often make the determination that it is not considered hazardous to workers and, therefore, it is not necessary to take measures to protect the workers’ health and safety.

When it comes to worker safety and the risks to human health, we must look at the requirements provided by OSHA.   OSHA is focused on exposure potential and the resulting hazard assessment evaluation to workers from the chemicals that may be encountered when working in areas with potentially contaminated soil and/or groundwater.  If the chemicals present are regulated by OSHA with a Permissible Exposure Limit (exposure based on an 8-hour average), the employer is required to conduct exposure assessments and air monitoring to determine potential risks to the workers onsite.  It also requires that workers are protected from these potential exposures through either engineering controls or personal protective equipments (such as tyvek, gloves and respirators).

 There is also a need to protect the workers and meet all the other applicable OSHA standards that mitigate health and safety risks to workers on this site.   Such required protection would include: 

• developing a site-specific health and safety plan,


• training workers in chemical hazards and controls,


• conducting environmental monitoring to determine exposure,


• instituting controls (PPE and Engineering) to protect from exposure potential,


• clean up (decontamination).and a number of other procedures.  

It is surprising and frustrating that this issue is still debated, but if it is, doesn’t it make sense to use the guidelines in these standards to clarify? We are talking about human health and the regulations are clear about the requirements for worker training and personal protection when dealing with chemical contamination.  You can use the environmental classifications to determine how to treat the situation, but you must look to OSHA to protect the workers as they are doing it.

Have you ever had workplace confusion regarding environmental risk and hazardous to human health? If so, I'd like to hear about your situation and how you resolved it.

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Topics: OSHA, DOT, health and safety, General Industry H&S, Construction H&S, EPA, Hazardous Waste Management, Hazardous Materials, Compliance, worker safety, Occupational Health, Occupational Safety

By Don Hoeschele, MS, CHMM

The U.S. Chemical Safety Board (CSB) recently approved recommendations to the Occupational Safety and Health Administration (OSHA), the National Fire Protection Association (NFPA) and other organizations to help prevent explosions and fires during pipe cleaning and purging operations.  As recently as February 7, 2010 at the Kleen Energy power plant in Middletown, CT, an explosion caused six fatalities and numerous injuries during the cleaning of a natural gas pipe system. Another similar explosion occurred at the ConAgra Foods Slim Jim plant in Garner, NC on June 9, 2009 and caused the death of four workers. In both instances, an operation termed “natural gas blow” was utilized to force natural gas under pressure through a piping system during construction and prior to startup of the plant’s turbines to rid the pipe system of non-natural gas impurities and debris. The gas was vented to the ambient atmosphere at open pipe ends less than 20 feet from the ground, and in worker areas where the gas easily found a source of ignition.  It seems that common sense would lead one to never vent natural gas near sources of ignition.

• At Kleen Energy the potential ignition sources included electrical power to the building, welders actively working and diesel-fueled heaters running in the vicinity.


• Approximately TWO MILLION cubic feet of natural gas were released at Kleen Energy on February 7, 2010 during the “natural gas blow”, enough natural gas, according to the CSB, to provide heating and cooking fuel to the average American home every day for more than 25 years.

The CSB determined that no specific federal workplace safety standard exists that would prohibit the intentional release of natural gas into the workplace. Yes, I was shocked when I read that, too! Eighteen urgent recommendations were provided and voted on by the CSB to prevent future disasters. Some of the recommendations include – Prohibiting the use of natural gas for pipe cleaning and using alternatives such as compressed air, steam and other chemical substitutes, and upgrading the current gas safety standards for general industry and construction that are considered by the CSB to contain “significant gaps” that threaten the safety of workers at such facilities.

In February 2010, the CSB issued a safety bulletin titled “ Seven Key Lessons to Prevent Worker Deaths During Hot Work In and Around Tanks”.  This bulletin highlights another gap in the OSHA standards, “While the OSHA standard prohibits hot work in an explosive atmosphere, it does not explicitly require the use of a combustible gas detector”. 

It is an unfortunate fact that such regulatory “gaps” can be found in many industries. We are reminded of these gaps while reading of disasters such as these, or more currently, watching the daily updates of oil washing ashore in the Gulf of Mexico.  It is certainly welcome news that these CSB draft recommendations were quickly approved without amendments to help prevent future explosions during pipe cleaning operations.

Do you know of other examples of what would seem to be ‘common sense’ safety measures that are not utilized because “this is the way we have always done it” wins over common sense?

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Topics: OSHA, health and safety, General Industry H&S, Emergency Response, Chemical Safety Board, Hazardous Materials, Compliance, worker safety, emergency response training, Fire Safety, NFPA

Tom Carlson, PE, Sr. Project Manager

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Topics: OSHA, indoor air quality, Personal Protective Equipment, health and safety, Construction H&S, EPA, Hazardous Waste Management, Hazardous Materials, Compliance, worker safety, Occupational Health, Occupational Safety, Air Sampling, environmental air monitoring, Respiratory, Public Safety

John Quatermas - EHS Consultant

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Topics: Personal Protective Equipment, health and safety, General Industry H&S, Construction H&S, H&S Training, Respiratory, water safety

Dian Cucchisi, PhD, CHMM

The Bhopal Disaster has been in the news again with the eight former company executives getting convicted of negligence.     A court in the Indian city of Bhopal returned the verdict on June 7, 2010, more than 25 years after the incident. 

What was the Bhopal Disaster?

For those of us old enough to remember, the words “Bhopal, India” brings to mind the very tragic events of December 2, 1984.  On that day a Union Carbide facility had an accidental release of approximately 40 tons of methyl isocyanate, a chemical used in pesticides.  The chemical plume killed 3,000 people and left an estimated 500,000 people with long-term, damaging health effects.  Amnesty International reports that approximately 15,000 people died in the subsequent years as a result of this incident.  As a result the Union Carbide Bhopal accident is often considered the world's worst industrial disaster.

And then a smaller, but similar event occurred in the USA…

In August 1985 a Union Carbide facility located in Institute, West Virginia experienced an accidental release of toxic chemicals causing more than 100 residents of the area to seek medical treatment.

US Regulators Respond to Community Concerns

In response to these incidents and the growing concern by the American public that this could happen in their backyard, regulatory agencies enacted laws for facilities that manufacture, store, or use certain chemicals above designated threshold quantities.

In 1986 the United States Congress passed the Emergency Planning and Community Right to Know Act (EPCRA). The law requires facilities to annually report the quantities of “extremely hazardous substances” to the facility’s state and the Local Emergency Planning Committee (LEPC).  This information is available to any member of the public upon request to the LEPC.

In late 1985, the Occupational Safety and Health Administration (OSHA) created the Hazard Communication Standard (HCS) (29 CFR 1910.1200) also known as “Right to Know.”  The HCS requires manufacturers and distributors of hazardous materials to communicate to employees the hazards of the chemicals in their workplace by providing Material Safety Data Sheets (MSDS) and ensure that hazardous materials are labeled according to certain requirements.

The Clean Air Act was amended by Congress in 1990, including some regulatory changes intending to create safer workplaces and mitigate the risk of a Bhopal-like disaster in the US, such as:

• Charging the EPA and OSHA with more authority over the chemical industry.
  
  
  
  • OSHA created the Process Safety Management Standard (29 CFR 1910.119), a program that looks in depth at process technologies, procedures and management practices.
  
  
  • The EPA codified Chemical Accident Prevention Provisions (40 CFR Part 68) which requires facilities to conduct a hazard assessment, develop a prevention program, and implement a risk management plan.
  
  
  • Other laws that regulate the use of hazardous materials were enhanced.  These include the Toxic Substance Control Act (TSCA); the Resource, Conservation and Recovery Act (RCRA); and the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA).
  
  
  
  


• Creating the U.S. Chemical Safety and Hazard Investigation Board (CSB). 

The Senate legislative history states: "The principal role of the new chemical safety board is to investigate accidents to determine the conditions and circumstances which led up to the event and to identify the cause or causes so that similar events might be prevented." Congress gave the CSB a unique statutory mission and provided in law that no other agency or executive branch official may direct the activities of the Board. Congress directed that the CSB's investigative function be completely independent of the rulemaking, inspection, and enforcement authorities of EPA and OSHA. The CSB became operational in January 1998.  

Accidents in the U.S. STILL OCCUR

In spite of this, accidents continue to happen.  In 2002, the Chemical Safety and Hazard Investigation Board (CSB) examined 167 chemical accidents that occurred between 1980 and 2001.  More than half of those accidents involved chemicals not covered by the regulations mentioned above.  The CSB recommended that the EPA and OSHA expand their regulations.  The Agencies did not agree with the recommendation stating they feel the best approach is worker education.  In 2004, OSHA formed an alliance with the EPA, the American Chemistry Council (ACC), and others to develop and provide worker education on chemical reactivity hazards. 

How do you feel about the expansion of regulations to include chemicals currently not covered by regulations designed to prevent accidents and reduce health risk?

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Topics: OSHA, health and safety, General Industry H&S, EPA, Emergency Response, H&S Training, Compliance, TSCA & R.E.A.C.H., Air Sampling, emergency response training, Exposure, environmental air monitoring, Respiratory, Public Safety

Capt. John DeFillippo, CHMP, EMT-B

These are tough economic times and businesses are looking to cut costs and save money. A disturbing trend I have noticed is the willingness of many companies to make cuts in safety programs and employee training in a misguided attempt to improve the bottom line.

Trained workers are safer workers.  The facts bear this out. Shortsighted statements I’ve heard include; “We don’t have problems in that area, so we’re cutting back on training.”, when the training was most likely the reason for the lack of problems.

Often, it is difficult to see how beneficial training can be until you experience the effects of its absence. Negative indications show themselves in higher EMRs, increased workman’s compensation claims, lost production time, and property damage. Only companies actively tracking and trending incidents are likely to realize this. (By the way, such companies would also be the ones least likely to make such cuts in the first place!)

It takes just one serious incident resulting in injuries to quickly eliminate any savings associated with cutting programs and training.  What’s more, most health and safety training is required by regulations, so there is also the risk of fines for non-compliance. These can be hefty and since most companies don’t budget for them, they become an extraordinary cost – right off the bottom line!

At Emilcott, we have seen firsthand the effects that result from a lack of training.  Recently, we were hired by a client who laid-off their safety director a couple years prior.  After starting our work, we informed the client of numerous safety violations throughout their organization. These appeared to be a direct result of the lapse in proper safety training – since they no longer had a safety director to oversee their program.  Through the Emilcott Training Institute, our client was able to receive the training needed to avoid these safety violations – and keep their employees safe and on the job. However, in their attempt to save money, the client ended up spending more in a short period of time just to catch up.

Making drastic H&S budget cuts just never pay off.  As experienced health and safety consultants, we work with our clients to offer solutions when budgets get tight:

• Outsource until you can hire again – we have provided EHS professionals at our clients’ sites for just this purpose for both short and long term requirements.


• Prioritize your H&S needs – consider the total reduction in your workforce or operations to determine where you can pull back and where you cannot.


• Take advantage of training courses open to the public – it may no longer be economically sound to run a training course in-house, but don’t lapse on required courses.


• Take advantage of FREE resources – many consultants provide lots of free info and OSHA will provide all types of assistance at no cost. As an example, Emicott offers a comprehensive Free Training Needs Assessment at www.emilcott.com!


• Pool resources – look toward your industry’s professional organizations or neighboring companies to share services. Maybe a part-time Safety Director is better than none at all.


• Ask a professional – put together a plan and a program to get you through the lean times

Has your company adjusted their health and safety program for leaner times?

Have you seen a direct effect and how are you compensating?

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Topics: OSHA, health and safety, General Industry H&S, Construction H&S, Emergency Response, H&S Training, Compliance, worker safety, Occupational Health, Occupational Safety, Fire Safety, Occupational Training, Lab Safety, Safety Training in Spanish

Capt. John DeFillippo, CHMP, EMT-B

Does your company have employees that work on, near or over water? Hazardous waste site and emergency response workers, those in the construction trades, surveyors and bridge inspection/repair crews are but a few occupations where this applies. OSHA regulations (29 CFR 1926.106 for example) cover the safety of such workers including training and protective equipment requirements. Other federal and state (USCG and TSA) regulations may also apply to your operation. For example, if you are working over water, such as bridge work, you must have a rescue skiff at the ready, with trained personnel to operate it, in case someone falls in. Working at piers, refineries or other marine facilities may entail very specific security requirements.

Water can be unforgiving of carelessness. As a veteran of the U.S. Coast Guard, an EMT and a licensed captain working in the marine salvage industry, I’ve seen plenty of tragedies on the water. Nearly all were avoidable. Here are some essential questions to help you assess your water safety knowledge:

• Is everyone wearing personal flotation devices? Are they the right type, worn correctly, and U.S. Coast Guard approved?


• What is the water temperature? In April in the mid-Atlantic region, the water is about 45 degrees F which means you can last about 15 minutes before hypothermia sets in.


• Do you understand the risk of hypothermia? Even if the water is at 80 degrees F, it’s the same as being in air of 42 degrees F. And, water removes heat from the body 25 times faster than air of the same temperature.


• Does everybody know how to swim? What to do if caught in a current? Will they know to swim parallel to the shore or go with it until you out of it? You can't swim against a current, even a gentle one, for very long, so don’t try.


• If someone does fall in, what’s the plan? Formulating a plan when you hear the splash is too late! Having the proper rescue equipment and understanding how to use it is essential.


• Who is trained in CPR and Basic First Aid? Knowing what to do in an emergency saves lives! Too many would-be rescuers become victims themselves, so leave water rescue to those who have the training and tools.


• Is the boat operator trained? Employers who would never think of allowing an untrained person to operate a crane often have no problem letting someone without proper training operate a boat on a navigable waterway. Many states, including New Jersey, now require all operators of power-driven vessels to take an approved Safe Boating Course. Fines can be steep and may get the vessel impounded.

The Emilcott Training Institute offers many training programs that can help keep workers safe, including an 8-hour Water Safety and Boating Basics that is approved by the NJ State Police and recognized in several other states as well. Fall Protection, Water Safety and Red Cross CPR and Basic First Aid are also offered in-house or on-site. If you have ANY questions about water safety at work, give Emilcott a call or comment below.

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Topics: OSHA, Personal Protective Equipment, health and safety, General Industry H&S, Construction H&S, Emergency Response, H&S Training, worker safety, Occupational Safety, emergency response training, Occupational Training, water safety, Water Response Plan

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tp://ehswire.com/writers/">John DeFillippo, CHMP

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Topics: health and safety, General Industry H&S, Construction H&S, worker safety, Occupational Health, Public Safety