Environmental Health and Safety Blog | EHSWire

Dian Cucchisi, PhD, CHMM

“Man is it hot out here.” As the site HSO (Health and Safety Officer), we hear and utter those words quite frequently during the summer. Working outside in 90 degree temperatures with high humidity levels is anything but comfortable. Who doesn’t look forward to the end of the work day when you can escape to an air conditioned environment with a cold drink or jump into the pool?

It’s not just unpleasant -- working in hot, humid temperatures can be very dangerous.  If you don’t take extra care to rest and hydrate you can subject yourself to heat cramps, heat exhaustion, and the deadly heat stroke. So what can you do to protect yourself in hot, outdoor conditions while continuing to work. 

As an experienced Health and Safety professional and working on construction and hazardous waste sites, I make an extra effort to see to it that there is plenty of water and electrolyte drink on hand before the work day begins. Throughout the day, I check on workers to see if any are exhibiting heat-related symptoms. Frequent breaks in a cool, shaded location and hydration (whether you feel thirsty or not) with water and electrolyte drinks are your first and best defenses against heat-related illnesses.

It’s not just construction workers that need to aware of the affect of heat as they work – anyone subjected to a continuous, hot working environment should keep heat-related illness prevention in mind. One of my most memorable projects was a cleanup of an abandoned chicken processing plant in the height of summer heat. The owner had walked away from the plant after the power had been cut off due to non-payment of the bills and there were several tons of chicken in various stages of processing in the freezers. Of course when the power gets cut, the freezers do not remain cold for very long. The odor caused by the decomposing chickens created quite a challenge for determining the proper personal protective equipment. Ultimately, the work on this project was performed in Level B (supplied air respiratory protection) with PVC suits as our protective clothing to block permeation of the odor. 

Prevention of heat-related illnesses for the cleanup workers was a one of the focuses in our pre-project planning as the project began in July and continued through summer into the early fall.  Because of the hot, humid temperatures and the heat-retaining PPE, we set a limit of 45 minutes for a group of workers who were then relieved after that time period by another group of workers. The first group would go through the decontamination process followed by a shower and rest in an area where we had assembled a tent to provide shade.  Despite the challenges, we made it through this hot and truly disgusting project without any workers suffering from heat-related illness. In fact, this long-term and highly publicized remediation project was inspected by OSHA where portions of the project layout and performance were videotaped for use in OSHA training “How-To’s!”

Symptoms of Heat-related Illness

These indicators can, but do not have to, begin in progression starting with heat rash, heat cramps, heat syncope, heat exhaustion, and heat stroke.

Heat rash is a skin irritation caused by excessive sweating during hot, humid weather.  In high humidity, the sweat does not evaporate quickly from your skin’s surface, and as clothing rubs against the wet skin, irritation can develop resulting in a rash.

Heat cramps are involuntary muscle spasms within the large muscles of your body.  Heat cramps typically occur in the thigh, core, and arm muscles.

Heat syncope is a fainting or dizziness episode that can occur as a result of dehydration or lack of acclimation.

Heat exhaustion is the body’s response to loss of water and salt usually as a result of excessive sweating.  Symptoms include heavy sweating, extreme weakness or fatigue, dizziness, clammy moist skin, muscle cramps, elevated temperature, and fast, shallow breathing.

Heat stroke is a medical emergency.  As the body temperature rises, the sweating mechanism fails and the body is not able to cool down and control its temperature And, beware, this severe reaction can happy quickly:  the body temperature can rise to 106 degrees within 10 to 15 minutes!  Without emergency treatment, heat stroke can cause death or permanent disability.  Symptoms of heat stroke include hot, dry skin or profuse sweating, hallucinations, throbbing headache, high body temperature, confusion/dizziness, and slurred speech.

What should you do if you start to experience any of these symptoms?

First of all, take a break. Move to a cool, shaded area and drink plenty of non-alcoholic, caffeine-free liquids.  If possible take a cool shower or dip an article of clothing in cool water and place on your body.  If you are suffering from heat rash do not apply wet clothing – instead dry off and remain in a cool area until the sweating ceases.  Resume work only after your body has cooled to normal temperature.

It is very important for Supervisors and Health and Safety Officers to keep a close watch on workers especially on hot, humid days and to allow them (as well as require them) to take frequent breaks.  Workers exhibiting any of the symptoms listed above should be removed from the work area and instructed to take a break in a cool, shaded area and to drink water or an electrolyte drink.

How do you “keep your cool” on hot, humid days?

Lee Scott Bishop, CIH, MPH

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

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

For workers employed by a mid-sized contracting group or a small crew engaged in house painting or outside repairs, OSHA has published a new directive which mandates the use of fall protection for all residential construction workers at heights of 6 feet off of the ground. The Occupational Safety and Health Administration’s (OSHA) Fall Protection Policy for Residential Construction went into effect on June 16, 2011. Employers engaged in residential construction are required to follow the provisions of 29CFR1926.501(b)(13) which states:

"Residential construction." Each employee engaged in residential construction activities 6 feet (1.8 m) or more above lower levels shall be protected by guardrail systems, safety net system, or personal fall arrest system unless another provision in paragraph (b) of this section provides for an alternative fall protection measure. Exception: When the employer can demonstrate that it is infeasible or creates a greater hazard to use these systems, the employer shall develop and implement a fall protection plan which meets the requirements of paragraph (k) of 1926.502.

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

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

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

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


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


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


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


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


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

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

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

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

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

• For Fall Protection Standards for States with OSHA-approved State Plans, please visit http://www.osha.gov/dcsp/osp/statestandards.html. 


• If you have further questions OSHA can be scheduled for On-site Consultation by accessing http://www.osha.gov/dcsp/smallbusiness/consult.html.


• To submit an information inquiry by Electronic Mail Form, follow the directions at http://www.osha.gov/ecor_form.html.


• To contact OSHA by Phone, dial 1-800-321-OSHA (6742) Toll Free in the U.S.


• Finally, you can write to OSHA at:

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

Paula Kaufmann, CIH

It happens every summer at hospitals and clinics across the country…first-year and advanced residents and fellows start a new training-at-work year. As part of the infection control strategies at these healthcare facilities, respiratory protection training and fit testing campaigns move into full gear to ensure that everyone is covered (literally and figuratively). It is almost like the return of migrating birds as second, third and fourth-year residents and current fellows flock into queues for respirator use training, fit testing and, often, medical clearance for respirator use.

Providing these invaluable respirator program services en masse is a challenge for the infectious disease and industrial hygiene and EHS departments at hospitals and other healthcare facilities. Nationwide, according to the National Resident Matching Program (NRMP), more than 25,000 residents and fellows will begin their new assignments in July!  Without interfering with patient care or hospital services, they all must be medically cleared, trained and fit tested for the site’s selected respiratory equipment (sometimes 2 or 3 different manufacturers or styles) prior to stepping foot on the hospital floor.  If you add nursing and other healthcare staff requiring an annual fit test in June or July, within a 4-6 week mid-summer period respiratory protection program departments at large teaching hospitals must provide OSHA-mandated support to 800 to 1000 (or more!) residents and fellows.  Planning is imperative and cooperation from the medical staff makes the process smoother for everyone.

Do You “Fit” this Fit Test Profile?

In a recent campaign processing hundreds of medical staff, Emilcott provided support to the infectious disease and EHS fit testing teams at a regional teaching hospital.  The fit test campaign coordinators orchestrated this event with military precision.  It was well- planned and appropriately staffed.  However, with so many folks donning respirators and fit test hoods, the lines were long and we encountered an array of challenging and uneducated attitudes.  Here are some of our favorite responses:

• “I’m a third-year resident, I don’t have to be clean shaven to get fit tested.” (He was promptly handed a shaving kit.)


• “What do you mean “I” failed? Is this graded? Oh, I see, the respirator failed, not me!”


• “I never wear those respirators, so can you make it quick.”


• “I know how to wear that.” (As the respirator was put on upside down…)


• “I don’t think I can work with this [fit test] hood on every day!”

And, some real doozies during the 7-step qualitative fit test exercises:

• “Just tell me, what is the “right” answer! Should I taste the Bitrex® or not?” (We sent this doctor to be quantitatively fit tested.)


• “Isn’t this a bit excessive?” Followed by “Oh, now I think I can taste it!”


• “Can’t you use that sweet stuff?  I like that better than this bitter taste.”


• “This respirator fit okay last year … why can I taste the bitter flavor now?”


• “This process didn’t take this long at the last hospital I worked, you must be doing it wrong.” 


• And, drum roll please, from an Infectious Disease Fellow, “Thank you for making us go through each step of the fit test procedure, it’s really important!”

As a Certified Industrial Hygienist, my challenge is to convey the why, how and when of respirator use (according to OSHA Respirator Standard training and fit testing requirements) to anyone on my watch – even when my target audience consists of impatient, high achieving and time-pressed medical professionals. In an odd role reversal, I’m doing the life saving…using occupational health and safety standards to protect their bodies as they do their jobs.

When Are Healthcare Providers Required to Use Respirators?

The Centers for Disease Control and Prevention (CDC) indicates the use of respirators for protection from infectious respiratory aerosols specifically those from patients with active tuberculosis and influenza.  

• The CDC “TB Elimination: Respiratory Protection in Health-Care Settings Fact Sheet” specifies that particulate filter respirators certified by National Institute for Occupational Safety and Health (NIOSH) be used for protection against airborne M. tuberculosis including
  
  
  
  • Non-powered respirators with N95, N99, N100, R95, R99, R100, P95, P99, and P100 filters (including disposable respirators); and
  
  
  • Powered air-purifying respirators (PAPRs) with high-efficiency filters
  
  
  
  


•  The Department of Health and Human Services “Interim Guidance on Planning for the Use of Surgical Masks and Respirators in Health Care Settings during an Influenza Pandemic” emphasizes that respirator use is a critical component of a system of infection control practices to prevent the spread of infection between infected and non-infected persons. Respirator use is indicated as follows
  
  
  
  • N95 (or higher) respirators should be worn during medical activities that have a high likelihood of generating infectious respiratory aerosols, for which respirators (not surgical masks) offer the most appropriate protection for health care personnel.
  
  
  • N95 respirators are also prudent for health care personnel during other direct patient care activities (e.g., examination, bathing, feeding) and for support staff who may have direct contact with pandemic influenza patients.
  
  
  
  

 High Velocity Fit Testing

Another comprehensive qualitative fit test (QLFT) campaign at a large teaching hospital in New York City was scheduled across a broad span of times, crossing many days and weeks to accommodate the schedules of rounds, staff, patients and Human Resources. Emilcott’s fit testing team became considerably more efficient this year by switching to the TSI Qfit to generate the test atmospheres. One touch of a button on these pump-driven nebulizers produces the equivalent of 5 bulb nebulizer compressions and uses quick, pop-on cartridges containing the challenge solutions. The easy and consistent delivery system of the nebulizers enabled us to focus our attention on the respirator user and the respirator fit.

Fit testing of course confirms (or not) the match of each face to the selected respirator. For respirator users who were unable to taste either Bitrex® or Saccharin during sensitivity testing; could not clear the taste of Bitrex® after wearing a poor fitting respirator; or, were extremely uncomfortable wearing the fit test hood, we supplemented the QLFT with quantitative fit testing (QNFT) to ensure an accurate respirator fit test. Staff that did not pass both the QLFT and QNFT with any standard-issue respirator was forwarded to the Respiratory Therapy department for personal respirator attention. In our estimation, more than 1000 staffers, new and seasoned, passed through our fit testing process in a matter of days!

Respiratory Protection is Smart

It is important for medical staff – new or seasoned - to know when and why they are required to wear respiratory protection – the training is an essential part of the OSHA Respirator Standard. While the attitudes we encounter during fit testing at hospitals often include dismay over a failure or impatience and ungraciousness, we do our best to educate each person as they roll through the lines. Many times, the mere mention of antibiotic-resistant TB exposure or gentle reassurance that a failed fit test is not the same as a failed biology test, can shift a nurse or doctor’s perspective. What was a nuisance can quickly turn into a better comprehension of their occupational risk and personal responsibility to protect their health. As for the others? As OSHA mandates, there’s always next year.

As a health and safety professional, have you encountered any resistance to respirator fit testing? How have you responded? As a healthcare provider, what do you think about fit testing? Do you take it seriously? Does your employer?

By John Defillippo, CHMP

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 manufacturer’s 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 MSDS’s 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, you’ll 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, don’t 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, you’ll see added benefits like prevention of property damage, reduced insurance claims and costs, and, of course, your company will not be cited for OSHA’s third most-common violation!

Have you found any chemicals in your workplace that you didn’t 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…”?

By Eileen Lucier

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

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

Injury, Illness and Death Facts You Should Know

Slips, Trips, and Falls….

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


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


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


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


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

How can slips, trips, and falls be prevented?

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

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


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


• Fall prevention and protection
  
  
  
  • Provide appropriate fall arrest systems
  
  
  
  


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


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

Don’t Slip Up on Safety!

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

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

Has it happened to you?

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

Peter Borbas

As a resident of New Jersey, I have noticed more ticks this spring than I can personally remember in the past few years. Maybe it’s because I have been in the field more (I’m a Professional Land Surveyor) or my dog is covering more acreage in the woods. At work, in the field (literally FIELDS), I am more apt to be using white Tyvek with built-in booties to keep as many ticks off of me as possible; when I am at home I like wearing light colored clothes with my pants tucked into my socks. Folks in my company spray their clothes with Permanone, a Permethrin-based tick repellent and insecticide. This and a lot more information about keeping ticks off of you and inspecting for them is in the CDC’s “ Tick Management Handbook.” What scares me the most are the ticks that I don’t find, not the ones I do find. My life seems like one endless tick check!

Many of you already know my experiences with Lyme disease and have a seen  how Lyme has affected our family. Based on my own experiences, I tell anyone who ever has any symptoms of Lyme to get to a Lyme and vector borne disease specialist immediately.

I recently had a huge surprise; one of my children who has been treated for Lyme three times over twelve years, after spending the past year seeing many different kinds of specialists to figure out what was causing her nausea, fatigue and headaches, was diagnosed with Lyme again (or is it still?) by a Lyme and vector-borne disease specialist. Other types of doctors did not identify the source of her ailments. Once again I have seen the value of spending out of pocket money on expert and specialized doctors when my insurance company and general practitioners has told us something else.

Be aware; know the symptoms of Lyme and co-infectors. Pay attention daily to the health and behaviors of your coworkers, family and friends!  Do not let money be a barrier to getting to the appropriate diagnosis and treatment

For more information on protecting yourself from Lyme disease and understanding the symptoms to get the correct treatment, I recommend the following resources (shown here in alphabetical order):

• American Lyme Disease Foundation


• Columbia University Medical Center - The Lyme and Tick-borne Diseases Research Center


• IGeneX, Inc. - A specialty immunology laboratory and research facility


• International Lyme and Associated Diseases Society


• Lyme Disease Association, Inc


• Lyme Disease Foundation


• Lyme Disease Help


• Turn the Corner Foundation

About Our Guest Blogger: Peter Borbas is a Professional Land Surveyor and project planner; he is the Owner/President of Borbas Surveying and Mapping, LLC

by Paula Kaufmann

Has anyone ever asked you why OSHA requires extensive procedure and safety control training for crane operators and assistants?  What about why is it really necessary to take time to provide crane safety awareness training to workers working “around cranes” even though it is not required by OSHA? Well, READ THESE recent news headlines (and follow the links for more information)!

“Crane Falls Against Financial District Building” 

Failure to secure crane properly before leaving the site for at the end of the workday. (March 26, 2010)

by Paula Kaufmann

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

Here is a snapshot of the revisions:

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


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


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


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


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


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


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


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


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


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

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

by 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!