Environmental Health and Safety Blog | EHSWire

Capt. John DeFillippo, CHMP, EMT-B

“Every day there are more than 800,000 shipments of hazardous materials (hazmat) in trucks-usually flammable liquids, such as gasoline, or flammable gas. About 200 hazmat trucks a year are involved in fatal crashes and 5,000 in nonfatal crashes. Although these numbers are small relative to the totals of almost 5,000 trucks involved in fatal crashes and 400,000 involved in nonfatal crashes annually, the potential for human injury and property damage in hazmat crashes is much greater.”

Ralph Craft, Ph.D.
Analysis Division, Office of Information Management, US Department of Transportation

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Topics: Emilcott, DOT, General Industry H&S, General EHS, H&S Training, Hazardous Waste Management, HazCom, Hazardous Materials, Compliance, Occupational Safety, regulation, Hazard Communication Standard, Public Safety, Lab Safety

Topics: OSHA, health and safety, General Industry H&S, OSHA Compliance, General EHS, Construction H&S, EPA, Hazardous Waste Management, Compliance, worker safety, Occupational Health, Occupational Safety, TSCA & R.E.A.C.H., TSCA, reporting, Form 300, Greenhouse Gas Reporting

Paula Kaufmann, CIH

Did you know that the OSHA Illness and Injury Summary Log, 300A, is used for more than just recordkeeping at your site?  By documenting your company’s illness and injuries properly, you shape OSHA’s future initiatives!  Specifically, OSHA Summary 300A Forms are gathered by the OSHA Data Initiative (ODI) to help direct OSHA programs and measure its own performance.  

How does OSHA get this information?

OSHA gets these data from two sources:

• As part of an annual survey, the Bureau of Labor Statistics (BLS) sends injury and illness survey forms to randomly selected employers and uses the information to create the Nation's occupational injury and illness statistics.


• The OSHA Data Initiative mails its annual survey (in June) that collects data on injuries and acute illnesses attributable to work-related activities in private-sector industries from approximately 80,000 establishments in selected high hazard industries. In 2010, OSHA also collected this information from approximately 20,000 establishments in the construction industry in addition to the non-construction establishments. The Agency uses these data to calculate establishment-specific injury/illness rates, and in combination with other data sources, to target enforcement and compliance assistance activities. Traditionally, OSHA collects data from the establishments that meet the following categories, but as we saw in 2010, OSHA can expand these criteria.
  
  
  
  • Non-construction industries with 40 or more employees are chosen randomly
  
  
  • Non-respondents in the previous collection year
  
  
  • Site with an inspection or consultation visit for performance measurement
  
  
  • DART rate (days away from work, restriction or transfer) of 7.0 or higher in previous data collection
  
  
  
  

Does the data really help OSHA?

Now that OSHA has the data from BLS and the ODI, the Agency uses the information to

• Calculate and establish specific injury and illness incidence rates


• Develop targeted intervention programs (i.e., inspections and enforcement action)


• Assist inspectors so that they can direct their efforts to the higher incidents hazards that are hurting workers.


• Measure the success of agency efforts to reduce the number of workplace injuries and illnesses in select high-hazard industries


• Provide the base data for the BLS Annual Survey of Occupational Injuries and Illnesses, the Nation's primary source of occupational injury and illness data.

What is your role?

Be a savvy and educated reporter of your company’s illness and injury information. Understanding the OSHA 300 log reporting requirements will ensure an accurate portrayal of worker health and safety as well as maintaining OSHA compliance. Can you answer the following questions?

• How do I complete the OSHA 300 Log and Form 301?


• Am I required to post an OSHA Form 300A ? How do I know if I am exempt? 


• What is classified as a work-related illness or injury? 


• How do I fill the forms in correctly without over-reporting?


• Do I have to fill in the form if I have no recordable injuries or illnesses in the previous year? What are the rules for posting?


• Once the form is filled in and submitted, if requested by BLS or OSHA, are there other legal requirements I should know?

Not convinced that recordkeeping is important?

Besides providing a visible record of worker safety benchmarks and improvements (or worse, tragedies and reversals), establishments that are requested to but fail to submit a completed data collection form may be subject to OSHA enforcement actions, including the issuance of a citation and assessment of penalties!  So, take the time understand OSHA’s reporting requirements and implement them correctly – it affects your company and the nation’s workers.

If you need assistance with OSHA recordkeeping, Emilcott offers a variety of ways to help your business stay in compliance from a webinar-based course that outlines the rules and regulations to the development of complete health and safety plans. Or, if you have an OSHA recordkeeping question, just ask us!

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Topics: Emilcott, OSHA, health and safety, General Industry H&S, OSHA Compliance, General EHS, Construction H&S, Compliance, worker safety, Occupational Health, Occupational Safety, Webinar, reporting, regulation, Medical Records, BLS, Bureau of Labor Statistics

By Chuck Peruffo

It was a few days before Christmas and I was working outdoors as an Industrial Hygiene Technician on a construction project.  This is the first time in my life I have worked at such cold temperatures as I have been a Lab Rat most of my career.   Not being “climate adjusted”, I was bundled up like Ralphie’s little brother, Randy, from A Christmas Story.   As I kept one eye on my meters and the other eye trained on the excavator in front of me, the wind started to pick up.  The clouds of dust coming off the road shouted “dust control needed” even before I checked the numbers on the dust monitors.

Dust control is an important way to keep what’s in the ground out of the air and out of your lungs.  The standard method for controlling dust is to spray water on the ground. This practice works fine until your water truck freezes solid.  So, what do you do when Jack Frost is nipping at your nose and the dust is flying in the air?  Your solution for dust control is to make up a solution of water and a chemical such as magnesium chloride hexahydrate (“Mag flake”).  

Mag flake or Mag brine has long been used to control dust on rural roads.  Mag flake can be mixed directly into your water truck.  A bit of a disclaimer:  although Mag brine is less corrosive that sodium chloride, make sure the water truck tank vessel can handle the solution by noting the material of manufacture and then consulting a corrosion guide. And, it is good practice to flush the tank truck with clean water after use.

Some manufacturers sell Mag brine at up to a 33% solution for dust control. That translates into more than 2 ½ tons of Magnesium Chloride in a 2000 gallon water truck which is fine for dust control on rural roads that aren’t sprayed often but may be too concentrated for a construction site application. 

At Emilcott, we have found a solution to meet the challenge of frozen water.  Roughly, a 50 pound bag of magnesium chloride added to a 2000 gallon water truck lowers the freezing temperature by 0.3°F.  So, to have a liquid wetting agent for effective dust control when the temperature is around 25°F, we add 1500 pounds of magnesium chloride into a 2000 gallon water truck or about a 0.9% Mag brine solution.  And, now we have our “solution” to keep the dust out of the air!

Here’s the formula and factors Emilcott uses to determine how much magnesium chloride we need to add to the water truck to get the right, wet solution:

∆T = i * K_f * m

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Topics: health and safety, dust control, General EHS, Construction H&S, Hazardous Waste Management, Compliance, worker safety, Occupational Health, Occupational Safety, Air Sampling, environmental air monitoring, magnesium chloride, mag brine, mag flake, magnesium chloride hexahydrate

Laurie de Laski

Having spent a large part of the last 25 years as an EHS professional developing and implementing Health and Safety Plans in a wide variety of industries, I was pleased to see that companies are requesting contractors and service providers to be prequalified for safety during the bidding process.  Conceptually, prequalification for safety should “raise the safety bar” and, companies with a well-developed safety plan should be rewarded for their proactive ethos with a competitive edge in the marketplace.  At Emilcott we have seen this really happen! Highly competitive project opportunities open up for clients that have genuinely adopted a top to bottom buy-in on the importance and value of safety. And, of course, they also experience measurable drops in both injury and insurance rates based on their safety performance.

Is the safety prequalification process good?

To have the “win-win”, the safety programs required for the project must be appropriate for the bidding contractor’s scope of work.  And, these safety programs need to be adopted, implemented and enforced. So, in order to make the prequalification process manageable for the companies writing the scope of work and the bidding contractors, an industry of on-line safety verification companies has evolved. While helping the contracting companies organize their bid processes, this on-line verification is very one-size fits all and focuses heavily on written programs, which may not be applicable to the scope of work.  This all or nothing approach leaves me wondering if on-line verification actually does raise the bar or just rubber-stamps paper safety programs.

Here’s the process “in theory”…

Contractors must have written safety programs that meet the requirements of the client.  The programs are submitted on-line and reviewed by the verification company.  Programs meeting the specifications are passed; those that don’t pass are requested to be updated.  This practice sounds likes a good idea, however,

• Many times contractors are required to write safety plans for equipment and operations outside the scope of their operations.


• The contractors spend a significant amount of time inputting the information to the website with no guarantee of being accepted. 


• Many of the bidding contractors are small businesses without the support or money to handle the overhead costs associated with maintaining their entries in the safety verification website.

For a quick safety program, click here!

Don't have the time to develop a safety plan? Don’t know what you’re missing? Under the gun to qualify for a lucrative project?  Don’t worry!

A large number of on-line “safety” specialists are available to help contractors meet the prequalification safety requirements! They advertise the development of company-specific safety programs that will meet the verification requirements at a very low cost, and some will include on-line input on behalf of the contractor and guarantee that they will pass.  One organization guaranteed approval in 72 hours!

Wait a minute…what problem does this solve? These companies offer to “customize” the safety plan by including the contractor’s company name and logo.  These cookie-cutter programs may meet verification requirements, but don’t appear to be customized for the contractor operations or the protection of the workers.  My sense is that there is no effort to actually develop a program that would be implemented by the contractor.  In conclusion, this “click here” approach does not raise the safety bar – it merely creates the illusion of a safety culture.

So, does safety prequalification work?

While health and safety program verification using this broad, sweeping approach may reduce the client’s liability, it doesn’t automatically improve safety performance.  In addition, the contractor may not be aware that they are creating a huge liability if they don’t implement their own safety program. In fact, OSHA will fine heavily for injuries that occur due to the lack of compliance with their stated safety plan.  Criminal penalties are also a possibility since the contractor could be considered negligent in not implementing or enforcing the procedures.

Where should we go from here?

The Requirements - Companies should require contractors to maintain only the safety programs that apply to the scope of work.  Requiring extensive safety programs for hazards the contractor is not likely to encounter devalues the safety culture for both the site and the contractor.

The Contractor Safety Programs - Contractors need to honestly implement programs that apply to their scope of work; understand the intent of the specific safety programs by learning the requirements of the regulations, provide employee training, and foster a culture of safety awareness with their employees.

The Verification Process – Be clear about the REAL goal of the process. If the objectives are truly to reduce accidents, improve safety, and make sure that everyone goes home at night, then old fashioned site health and safety inspections are what should be required.  Seeing how people work is the best way to make improvements in safety!

Do you think that the on-line safety verification process actually make a difference or is worth the time and expense?  Have you worked on a project where the on-line verification process develop and promoted a safe work environment, or like me, do you doubt they make a positive impact at all?

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Topics: Personal Protective Equipment, health and safety, General Industry H&S, General EHS, Construction H&S, H&S Training, Compliance, worker safety, Occupational Health, Occupational Safety, Occupational Training, safety plan, health and safety plan, safety prequalification, on-line verification

Capt. John DeFillippo, CHMP, EMT-B

The health effects from airborne hazards are a frequent topic in many health and safety courses, especially in hazardous substance and hazardous waste training.  This is because so many of these exposures may not show up as health problems for decades! Consider asbestos. While it’s not harmful to the touch, inhalation can be fatal, but it can take 25-30 years before asbestosis or mesothelioma can develop. Both are chronic and often deadly diseases of the lungs.

The lungs are amazing. It surprises most people to learn that the lungs have the largest surface area of any body organ -- about 80 times more area than the skin, or about the size of a tennis court!  As we breathe, our lungs are in constant contact with the outside world and that is a lot of contact area. They need to be protected.

Over three million American workers are required to wear respirators to protect themselves from hazardous airborne contaminants.  Not surprisingly, OSHA has some pretty strict rules when it comes to protecting our lungs . Despite this , it is estimated that more than half of the respirators worn are not worn in accordance with OSHA Standard 29 CFR 1910.134

Did you know that…

• If workers are wearing respirators, a written program is required?


• A medical evaluation is required for anyone who wears a respirator?


• A fit test of each respirator worn must be conducted initially AND annually?


• The workplace must be evaluated to determine the hazard so that the proper respirator (there are many) can be selected?


• These rules, and others, apply to what many people refer to as “dust masks”?

Proper respirator usage training is also required. Why? Because wearing the wrong type, wrong size, or an improperly fitted respirator can be more dangerous than not wearing one at all. For example:

1. Wearing a filtering respirator in an O₂-deficient atmosphere, or the wrong cartridge, can mislead you to believe that you are protected…when you are not!


2. A mask with even the slightest poor fit allows contaminates in and may actually increase exposure levels.


3. Not everyone can wear a respirator. Because a respirator restricts your breathing, people with certain medical conditions can be seriously harmed by wearing them. This is why being medically cleared prior to use is so important, and required.

Not complying with the rules designed for occupational safety can be costly… and not just in fines and penalties. Too many workers have destroyed their health by failing to protect their delicate, vital lungs. And, it’s not just at work. Working around the home and yard can also present respiratory dangers, too. If you are not sure that you need more than a “dust mask” ask someone who can help.

Have you been properly trained to use your respirator and fit-tested to make sure it is actually stopping hazards from reaching your lungs?Are you confident that you are using your respirator properly and that the respirator that you have selected is the best for the contaminants you are exposed to?  How about the person next to you - are they in compliance?  Hopefully you and your workmates can answerYES! to these questions. If you have any questions about respiratory protection, please ask me!

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Topics: OSHA, indoor air quality, Personal Protective Equipment, General Industry H&S, General EHS, Construction H&S, Emergency Response, Homeland Security, H&S Training, Hazardous Waste Management, Hazardous Materials, Compliance, worker safety, Occupational Health, Occupational Safety, Lab Safety & Electrical, emergency response training, Fire Safety, environmental air monitoring, Respiratory, Occupational Training

Carrie Bettinger - CSP, CHMM

It’s a windy, rainy day in northern New Jersey today and, as I drive through my town, I see the sanitation trucks are out to collect garbage and paper recyclables as early as they can before everything is soaked.  My town roads are basically paved horse trails so imagine narrow, winding roads with lots of sharp curves with a posted speed limit of 25 MPH.  So why is one of the garbage trucks going about 35MPH on one of these roads with a soaking wet worker standing on the truck’s rear platform clinging with a death grip to the side?  Is it that important to get the garbage in as fast as possible?  Why is the worker not in the truck if they are not making stops?  Does one of these workers have to die before this sanitation company takes steps to stop these stupid and unsafe acts?

As an experienced Safety Professional, I’m trained to recognize compliance-driven and non-compliance "best practice" occupational safety violations.  However, what does it take to change laws and habits that affect workers and citizens?  In our society and legal system it seems that, yes, someone (or many) has to tragically die before change and regulation are considered.

Let’s review some of our history:

1911:  The Triangle Shirtwaist Factory Fire in New York resulted in 146 worker deaths due to locked escape routes leading to local then nationwide Life Safety Laws.

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Topics: OSHA, health and safety, General Industry H&S, General EHS, Construction H&S, Chemical Safety Board, Compliance, worker safety, Occupational Safety, Occupational Training, Lab Safety, Safety Training in Spanish, water safety

Bruce Groves - CIH

In July, David Michaels, Assistant Secretary of Labor for Occupational Safety and Health, published a memo to his staff at OSHA highlighting several new approaches that OSHA is using (or planning to use) in its effort to protect workers.  Dr. Michaels is building on the progress of his predecessors and reinforcing some of the weak links in the system created both by Congress and former administrations. In his recent letter, Dr. Michaels reviews some legacy issues that limit OSHA-influence in creating safer workplaces such as

• OSHA has only 2,000 inspectors responsible for the health and safety of 130 million workers at 7 million worksites


• OSHA fines are too small to have an adequate deterrent effect


• OSHA standards provide limited protection to whistleblowers from retaliation


• OSHA occupational exposure standards have been established for only a small percentage of chemicals used in US workplaces (most of those are based on out-of-date science) with a slow and resource-intensive standard-setting process

Dr. Michaels states that OSHA needs to transform how it addresses workplace hazards, and in its relationship to employers and workers. As such he outlines a new strategy that is a clear shift from recent years indicating that there is a “new sheriff in town” and business (ALL businesses) should take heed.  Here are some of my extrapolations and thoughts regarding 6 of these transformational items -- consider how they will affect your business or workplace.

1.       Stronger Enforcement:  Some Employers Need Incentives to Do the Right Thing

OSHA will have more and bigger sticks.  OSHA is redirecting resources to conduct inspections of high risk industries and tasks including ergonomics.

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Topics: Emilcott, OSHA, indoor air quality, health and safety, General Industry H&S, General EHS, Construction H&S, H&S Training, Compliance, worker safety, Occupational Health, Occupational Safety, Lab Safety & Electrical, emergency response training, Occupational Training, Safety Training in Spanish, water safety, small business

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