Medical Services and First Aid

Standard 1910.151 was created by OSHA as a way to ensure employees have access to basic first aid supplies and required medical help, should they be injured on the job. Basic first aid supplies can help to prevent a minor injury from becoming serious, and a serious injury from become life threatening. And in any medical event, access to help from qualified medical professionals can severely increase an employee’s chance of a full and speedy recovery.

The primary medical response should come from local first responders who can bring an injured person to a local infirmary, clinic, or hospital in near proximity to the workplace. If there is no readily available infirmary, clinic, or hospital, then a company is required to train an individual who can properly use first aid supplies. Regardless of the need for this individual, a company is always required to have “adequate” first aid supplies readily available, should they be needed.

As with many other OSHA Standards, 1910.151 leaves a lot of room for interpretation. For instance, what constitutes “basic first aid supplies?” And how many of these items would be enough? In order answer these questions properly and to make sure that your business is appropriately up to code, we usually recommend a third party safety audit. With an audit, an auditor can review your current processes and watch your team, to ensure that your process is adequate and your team is properly following it.

For more information on OSHA Standard 1910.151, please contact us. If you have anything to add about medical services and first aid, please leave a comment.

TSCA: Toxic Substance Control Act and HAZWOPER

The Toxic Substance Control Act (TSCA), initiated by congress in 1976, was enacted to regulate the introduction of new or already existing chemicals. Unfortunately, this act did little to protect citizens from harmful chemicals, as the Environmental Protection Agency (EPA), a body already stretched thin, was tasked with determining whether or not the new chemicals pose, “unreasonable risk of injury to health or the environment.” If the EPA does not find justification to block the sale of the new chemical within 90 days, the chemical goes on the market, with no other checks. Of the more than 62,000 chemicals currently on the market, less than 200 were actually tested by the EPA, and only 4 have been blocked since 1990.

Clearly, there are potentially dangerous chemicals being used on a daily basis at work. This is why, in 1990, OSHA instituted Standard 1910.120, Hazardous Waste Operations and Emergency Response. OSHA has no authority to limit which legally sold chemicals can be used by companies, and it would be almost impossible for a company to have each and every product tested by a third party for their long term health risks, but HAZWOPER is a great way for a company to ensure safety in the work force. And since it is legally required per OSHA standards, it is important to ensure you are properly following all of the requirements.

If you have any questions about HAZWOPER in general, or the plan which you have put in place for your company, please contact us. And if you have anything to add about the importance of HAZWOPER, please leave a comment.

Monitoring Software for Lockout Tagout

The lockout tagout procedures described in OSHA Standard 1910.147 are difficult to establish and even more difficult to sustain. They are extremely complicated and are specific to each and every company; there are no “quick guides” to lockout tagout and following a plan which ensures compliance for another company will almost surely put your company out of compliance.

Lockout tagout is so complicated because it is crucially important for workplace safety. A lapse in lockout tagout can cause immediate harm and is often fatal. In order to become compliant and remain compliant, a company needs to define a procedure library and identify all energy isolation points. Then, all machines will need specific visual placards installed, detailing what hazards are present and in what circumstances. Finally, these placards need to be updated anytime anything changes at your company, as your lockout tagout needs are likely to change.

Fortunately, there is software now available which can help you establish your procedures, determine appropriate libraries, and update everything quickly and in real time. With this software, you can turn your safety team’s attention away from lockout tagout to other tasks, freeing up manpower while still ensuring compliance. This software is fully scalable and every change or update is documented, saving you tremendous time and energy in keeping the files organized.

The benefits of utilizing software for lockout tagout monitoring are incredible, and if you would like more information on our product, please contact us. If you have anything to add about lockout tagout monitoring, please leave a comment.

What is a Safety and Health Management System?

There is a lot of discussion around Safety and Health Management Systems; how they can help you, why you need them, how they help you stay compliant with OSHA, and so on, but there is not as much information around what a Safety and Health Management System actually is. And in order to truly appreciate all of the benefits of a Safety and Health Management System, you need to understand what a Safety and Health Management System actually is.

A Safety and Health Management System is just a centralized system that a business creates to oversee all safety regulations in place at that company. When done properly, these systems allow management to quickly and effectively monitor employee utilization of policy and allow third party auditors to quickly review all safety and health policies and procedures, to ensure they all remain up to code. Instead of a disorganized system which can take excessive time to review and can leave policies unreviewed and unaccounted for, a safety and Health Management System simplifies the entire safety and health process.

Additionally, when OSHA updates Standards or when new hazards become present at your facility, it easy to update policies and track changes. A properly created Safety and Health Management System is fully customizable and designed uniquely for your business. This level of detail allows for easy changes based upon the nature of your business.

If you have any questions about Safety and Health Management Systems or how one could help your business, please contact us. And if you have anything to add about what a Safety and Health Management System is, please leave a comment.

Welding, Cutting, and Brazing (29CFR1910.252)

There are a lot of industries which require at least occasional welding, cutting, or brazing. And for these industries, OSHA ensures safety is maintained through Standard 1910.252. This standard is an overview of all safety requirements surrounding these dangerous procedures, however by following these guidelines, welding, cutting, and brazing can be effectively performed without risk to your employees.

The first, and most serious, guideline listed surrounds fire prevention and protection. OSHA prefaces the discussion of fire prevention practices by citing NFPA Standard 51B,1962, which is the basis for this OSHA standard. It then goes on to state that all fire hazards must be removed from the vicinity, guards must be used if these items can not be removed, and that there are a number of special precautions which must be followed in various unique circumstances. It is also important to seal openings in the floor below work zones, ensure sprinkler systems are functioning properly, and have adequate fire extinguishing materials present. Finally, you need to employ fire watchers in a number of situations where a fire or the spread of flames may be more likely.

OSHA also looks at the individual performing the welding, cutting, or brazing. OSHA sets forth a series of requirements surrounding personal protective equipment, focusing on various types of equipment in different situations. This is everything from eyewear to self ventilators, with a large number of specific regulations specifying which eye protection is required, down to the specific lenses and hand shields.

Finally, OSHA requires that adequate ventilation is available. Whether this is through self contained ventilators or ventilation systems, your safety team needs to have a ventilation plan in place. If you do not have a compliant ventilation plan in place, it might be time to consider hiring a professional firm to help you develop your plan.

If you need any help in deciphering Standard 1910.252, or if you have any other specific questions, please contact us. And if you have any pointers for staying within OSHA’s guidelines without impairing your daily welding, cutting, or brazing operations, please leave a comment.

Walkways (29CFR1910.22)

There are a number of standards set forth by OSHA which cover the “walking-working surfaces” of a place of employment. Previously, we covered the general requirements of Walking Working Surfaces and the specific requirements surrounding Guarding Floor and Wall Openings. Additionally, OSHA created Standard 1910.22 which discusses general housekeeping and maintenance for floors, specifically areas considered aisles or passageways.

The primary objective of this standard is to ensure the floors your employees walk across are clean and unobstructed, and that no surfaces are over encumbered by items heavier than they are approved to handle. The first piece to this surrounds keeping areas orderly and sanitary. So, don’t leave obstructions all over the floor to trip your employees, and if you work with hazardous materials, don’t leave them a mess on the floor. Also, keep your floors clean, allow for drainage if necessary, and properly sign areas that are slippery.

Next, you need to make sure you mark all aisles and passageways, provide guardrails if there is a hazard nearby, and allow safe clearance should mechanical handling equipment be used in close proximity. Once you have met these criteria, you need to ensure you maintain these areas and keep them in good repair with no obstructions.

Finally, you need to ensure you have proper marking plates in place denoting the allowable loads for various surfaces throughout your building. These limitations are to be determined by a building official and need to be maintained. It is also important to follow these weight guidelines, because it can be a serious hazard should a support give out from excessive weight.

By following these steps, you will have a safer workplace that is OSHA compliant. If you are having trouble finding ways to bring your facility up to code, or if you have any specific questions about this standard, please contact us so we can help. And if you would like to add anything on this subject, please leave a comment.

Stairways (29CFR1926.1052)

Most facilities utilize stairways in one way or another for daily or occasional business purposes. This can be stairs between floors, stairs to a storage basement or storage attic, or stairs out of the back loading dock of a warehouse. Regardless of why there are stairs, or how often they are used, if there are stairs in your facility, then they must be up to code as per OSHA Standard 1926.1052.

Whether your staircase is temporary or permanent, under construction or in use, this standard must be consulted before any changes are made, and at least annually during audits to ensure stairways remain safe for employees and customers. This standard regulates the size of steps, the height of steps, the dimensions of landings, the angle of the stairway, the material used to create the stairways, doors and gates on a stairway, the condition of the stairway, stairways under construction, stair-rails, and handrails. Stairways must be kept clear of clutter and debris, as well as “hazardous projections, such as nails.” There must be adequate treads, and all steps and landings must be filled with concrete or at least covered by a hard, solid, wooden plank. All materials used in stair construction must be solid, firm materials, and must ensure safety. All steps must be of uniform height, width, and depth. And don’t forget to hang proper signage as applicable.

If, after reading this brief synopsis, you have any questions about the stairways in your facility, or about any remodeling projects you are planning which involve stairways, please contact us to get more information on this important OSHA standard. And if you have anything to add about this topic, please leave a comment.

Portable Tools and Equipment (29CFR1910.241)

As we discussed a few weeks ago, hand tools and equipment are used in nearly every field. And while 1910.242 discusses the safe use of these tools, it does not define what these tools actually are. So to avoid confusion, OSHA also created Standard 1910.241, which clarifies and defines what is, and is not, a hand and portable powered tool or other hand-held equipment as well as what the potential safety risks are with certain types of tools. Understanding these definitions can help any business owner determine how to properly regulate their tools and machinery.

This standard discusses and defines explosive-actuated fastening tools, abrasive wheels, and jacks, as well as all of the potential hazards and safety precautions which can be taken. For some tools, the classification is quite obvious, but for others it may not be clear if these standards are applicable. To help you determine if your tools are governed by these standards, you can either refer back to the standards, and attempt to determine if your tools fit their classifications without qualifying for an exemption to a different class, or you can contact a professional, who can help you classify each of your tools. Either way you decide to classify your equipment, it is also important to remember to include these tools in your annual third party safety audits.

If you have any questions about this standard, or how to properly classify your portable and hand powered tools and equipment, please contact us so that we can help you to better understand these definitions and what you need to do with each different class of tool. If you have anything to add about hand and portable powered tools, please leave a comment.

Handling Materials (29 CFR 1910.176)

If you work in an industry which requires the use of mechanical handling equipment, then OSHA Standard 1910.176 is surely a concern for you. Or, at least, it should be. This standard was established by OSHA to govern the proper use of mechanical handling equipment, the storage of materials, and the maintenance of the storage locations. It sets very broad requirements and expects you, as the business owner, to ensure you are in compliance.

First, “Where mechanical handling equipment is used, sufficient safe clearances shall be allowed for aisles, at loading docks, through doorways and wherever turns or passage must be made. Aisles and passageways shall be kept clear and in good repair, with no obstruction across or in aisles that could create a hazard. Permanent aisles and passageways shall be appropriately marked.” (1910.176[a]) As you can see from this, ensuring aisles and passageways are clear is an important part of this standard. No equipment or mechanical handling equipment may block aisles and passageways, and permanent aisles and passageways need to be kept clear and properly marked with adequate signage. If you are unsure of what constitutes “adequate,” you might consider hiring a third party to audit your facility, to ensure you are in compliance.

It is also important to remember that the storage and maintenance of materials must not cause a hazard. This means that items stacked upon each other must be properly secured. The location where the materials are held must be kept cure of accumulating materials which can create hazards from tripping, fire, explosion, or pest harborage. Finally, proper signage must be used to mark clearance limits as applicable.

If any of this seems like a potential concern for you and your business, please contact us so we can you ensure you are compliant. And if you have anything to add about Standard 1910.176, please leave a comment.

Walking and working surfaces

In 2011, The U.S. Bureau of Labor Statistics reported that 7.5% of all recordable injuries and illnesses and 14.4 % of all fatal injuries in the private industries involved slips, trips and falls. These statistics are second only to motor vehicles as a cause of fatalities. The National Safety Council’s Injury Facts 2009 edition estimated the average cost of lost time injury was about $43,000 per incident. Slips trips and falls cost the U.S. economy 10’s of billions of dollars annually.

The general duty clause of the Occupational Health and Safety Act mandates that “Each employer shall furnish to each of his employees employment and a place of employment which are free from recognized hazards…” OSHA established 1910.21-27 standards to address the safety concerns of walking and working surfaces in the workplace. In compliance with these standards, employers are expected to keep all places of employment, floors, passageways, stairways, and storerooms clean, orderly, in sanitary condition and free from any health and safety hazard.

Floors should be kept clean and dry as far as possible. Employers are required to maintain drainage, platforms, mats or other dray standing places where wet processes are used. Every workplace floor and passageway should be free from protruding nails, splinters, holes, or loose boards to facilitate cleaning.

Aisles and passageways should have sufficient safe clearances for mechanical equipment and should be marked appropriately. Covers and guardrails should be provided where necessary to protect from the hazards of open pits, tanks, ditches, etc. Loads should never exceed the approved structural load of the building floor. Maximum load should be marked and affixed in the appropriate areas.

Every stairway with four or more risers, floor openings measuring 12 inches or more in their least dimension, ladder-ways, skylight or manhole floor openings, all should be guarded by standard railing. Winding stairs should be equipped with handrail offset to prevent walking on all portions of the treads having width less than 6 inches.

All ladders are required to be free from damage and rungs free from grease and oil. The foot of the ladder should be positioned no more than one-quarter of their working length from the top to prevent slippage. Ladders should not be placed on boxes, barrels, or in places where it could block doorways. Ladders should be used only for their intended purpose not as platforms, runways, or scaffolds.

There is no silver bullet solution to slips trips and falls. It takes a proactive management to clean the clutter, create a safety culture, and train and make employees aware and part of the safety program.

Employees should avoid wearing loose shirts and dragging pants. Employees are expected to wear appropriate footwear and be trained to report any unsafe condition such as: uneven surface, worn tiles, loose mats or rugs, hose or chords in the walkways, cracks, holes, missing hole covers, missing guardrail, spilled coffee, oil leak, etc. Employees should be part of the hazard control process.

Many tripping hazards are housekeeping items. Hoses and chords across walkways are continual hazard. Rerouting or using protectors reduce these hazards dramatically. Cleaning spills and leaks right after they occur or reporting unsafe conditions as soon as they are observed should become the practice and concern of every employee.

A workplace safety program should include pre-shift inspections of all work areas to ensure no slip trip and fall hazards exist. Waste containers and spill cleanup materials should be easily accessible. Work areas should be well lit and any burnt lights should be replaced without any delay.

Comply with OSHA for a safer workplace.