TSCA: Toxic Substance Control Act and HAZWOPER

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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

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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.

Annual Third Party Safety Audits

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At least annually, all companies should have a third party safety audit. These audits are important to ensure compliance with all OSHA standards and to help guarantee conformity with the specific requirements of any additional certifications the company has received. Third party safety audits are also a great way for a new company to establish a safety program or for companies going through changes to ensure their safety program remains compliant. And the costs of these audits are negligible when compared to the costs associated with an OSHA audit or on the job injuries because proper policies are not in place.

A good third party audit will help you ensure compliance with all aspects of safety regulations. Auditors who only focus on certain areas of your business may be great for specific projects, but are not going to help you ensure companywide compliance, and should not be used for annual auditing purposes. Instead, it is important to find an auditing firm that will conduct a true “wall to wall” inspection of the entire facility. The auditing team should be able to review your current plan and compare it with your facility to see what is missing, and where you are noncompliant. An audit team should also review all accident investigations to ensure there are no undocumented hazards.

For more information on annual third party safety audits and how they can help your business stay compliant, please contact us. If you have anything to add about the benefits of annual third party safety audits, please leave a comment.

What is a Safety and Health Management System?

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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.

Hearing Conservation

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When thinking of workplace hazards, things like arc flash or lockout tagout are usually what come to mind. But noise can be equally dangerous, leading to long term hearing problems from both short and long term exposure to high noise areas. Unfortunately, many companies do not track the sound output in their facility, leaving their employees vulnerable to the effects of noise exposure.

If your business does have high noise areas, it is important to review OSHA Standard 1910.95, which regulates noise exposure and safety procedures. OSHA created a very clear table which lays out exactly what does and does not constitute a high noise area, and then sets up pretty clear guidelines as to how you must protect your employees. If you fall within the guidelines set, it is imperative you create a hearing conservation procedure for your employees.

Some companies need to reduce their noise exposure, others need to limit the length of time employees are exposed to noise, and still others need to utilize personal protective equipment to protect their staff. Whatever your requirement, your responsibility does not stop here. After you create a safe environment, you need to ensure employees have not had any negative impact from noise exposure and you must monitor your employees at least annually through audiometric testing. Any significant changes in hearing must be reported and followed up on.

If you have any questions about noise exposure and hearing conservation, including having your facility evaluated, having a conservation plan created, or having your facility audited, please contact us. And if you have anything to add about hearing conservation, please leave a comment.

Evacuation Plan Requirements

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Evacuation plans are an important part of any Emergency Action Plan. In the event of a serious emergency, your staff needs to have a clear and defined path out of the facility, with adequate predetermined routes to exits, and exits which are capable of withstanding a number of potential emergencies. In addition, your staff needs to know the evacuation routes, and the routes need to be posted throughout your facility, so that employees can simply look at a sign to find the fastest way out from anywhere in your place of business.

Not only are these requirements for a safe workplace, they are also requirements determined by OSHA. OSHA set Standard 1910.36 and Standard 1910.37 as a way to gauge whether your business is safe in the event evacuation is required. Unfortunately, there is a lot of gray area in the standards given how many different layouts a building can have. It is for this reason we generally recommend any evacuation plan be reviewed by a professional firm who specializes in safety and OSHA regulations.

But even after you have created an approved evacuation plan, it is important to be sure you print acceptable evacuation plan placards and have them installed throughout your facility. This crucial step is often overlooked by employers, and can be dangerous in an emergency situation.

If you have any questions about evacuation plans, including how to create one, how to account for changes in your work space, and how to print and install them, please contact us. And if you have anything to add about the requirements for evacuation plans, please leave a comment.

Ventilation

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For companies who use abrasive blasting, ventilation must be of key concern. This is partially because OSHA aggressively regulates and monitors it through Standard 1910.94, and partially because abrasive blasting is so dangerous to your employees. Luckily, if you follow the guidelines set forth in Standard 1910.94, you and your employees should be safe from harm.

This standard covers a lot. It covers the full operation from beginning to end, as well as all ventilation parameters, including air purification methods, minimum exhaust obligations, personal protective equipment, and a whole host of other specific details based upon the type of blasting and the abrasive used.

When analyzing your work environment, it is important to start by looking at the location where you are blasting. Is it large enough for the type of blasting you plan to do? Does it have access to adequate ventilation, and if not can the ventilation systems be added? Is there access to external exhaust systems? Once you have ensured that these answers are properly answered (meaning they all meet OSHA’s requirements), you can begin to think about the actual blasting you are doing. Are you doing the blasting you started doing, or have you changed along the way? If you have changed, you need to consider what changed, was it the method or the abrasive, and what steps have since been taken to ensure the area is safe.

After the blasting and the location are well in hand, you can finally consider your purification methods. This can be through proper personal protective equipment for some types of blasting, or through dust collectors and heavy duty exhaust systems for others. Ensure you have the correct plan in place and that it is being followed by your employees through appropriate training.

If you have any questions about this process, or if you would like an accurate audit of your practices, please contact us. And if you have anything to add about ensuring adequate ventilation for abrasive blasting, please leave a comment.

OSHA 1910.132 Personal Protective Equipment

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While one of the simplest items to ensure compliance with in any safety and health management system, personal protective equipment is one of the most common issues during an audit. Whether outdated, worn beyond the minimum safety requirements, or improperly used, personal protective equipment that is not up to code can have devastating effects on both employers and employees. One of the main reasons people have so much trouble with personal protective equipment is that guidelines are scattered among a number of different standards, encompassing everything from confined spaces to lockout tagout. In addition, there is also Standard 1910.132, which lays out the minimum requirements for any personal protective equipment to be OSHA compliant.

One of the primary issues business owners have with the standards is the vagueness which surrounds 1910.132 and the extreme rigidity of individual standards. For instance, in 1910.132(c), OSHA states: “All personal protective equipment shall be of safe design and construction for the work to be performed.” But this extremely indistinct requirement is clarified dozens of times within other standards, meaning a company can be in compliance with 1910.132 but not in compliance with another standard. And while this seems a rather simple issue to fix, it can be difficult to go back through every single glove, helmet, and apron to ensure that they are all always being used in the right way at exactly the right time.

Thankfully, there are companies who specialize in OSHA compliance. And these companies are an excellent resource for business owners worried that they are out of compliance or worried that they might be misusing a piece of equipment. To get more information on safety audits and personal protective equipment, please contact us. And if you have anything to add about personal protective equipment, please leave a comment.

Lockout Tagout Procedures

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One of the most important safety topics to ensure compliance with is lockout tagout. This crucial topic is of significant importance to OSHA, as well as your staff, as a lockout tagout error can cause significant harm or fatality. To help you create a safe work environment, OSHA created Standard 1910.147 which governs lockout tagout procedures and controls.

Standard 1910.147 “covers the servicing and maintenance of machines and equipment in which the unexpected energization or start up of the machines or equipment, or release of stored energy, could harm employees. This standard establishes minimum performance requirements for the control of such hazardous energy.” (1910.147 (a)(1)(i)) So, this standard sets minimum requirements for establishing a safety plan relating to your lockout tagout hazards. But after establishing an adequate lockout tagout procedure, it is important to ensure these procedures are properly maintained.

This can become a serious challenge over time as machines are changed in and out, and as the minimum requirements set forth in Standard 1910.147 are changed. To monitor these changes, most companies either place the burden on the safety team or they hire a professional to take care of the monitoring. And while it might seem less expensive to simply add this burden onto the safety team’s workload, overloading a safety team can lead to a dangerous work environment. It is never a good idea to take a chance on safety, especially in relation to lockout tagout. Fortunately, with Factory Solution, a fully automated and customizable monitoring system, ensuring your workplace is up to code for lockout tagout is as simple as a button click.

If you have any questions about the benefits of computerized lockout tagout monitoring, or about getting your lockout tagout procedures up to code, please contact us. And if you have anything to add about lockout tagout, please leave a comment.

Arc Flash Monitoring

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The potential dangers to employees from arc flash are real, and arc flash analysis and monitoring can be an audit nightmare for business owners. OSHA leans on NFPA 70E to guide their requirements on arc flash analysis and monitoring, which means business owners must do the same. Given the complicated nature of NFPA 70E, however, many business owners rely solely on IEEE 1584 to govern their arc flash procedures. Unfortunately IEEE 1584 is incomplete, and is only intended as a supplement to, rather than a replacement of, NFPA 70E.

When setting arc flash procedures, it is usually advised to contact a professional who has done this before and understands the intricacies of arc flash and NFPA 70E. And many companies do. But what most companies do not do is continue to evaluate their arc flash needs on a regular basis. At the very least, there should be a unit who is tasked with ensuring the arc flash policies in place are still up to code and relevant.

For starters, all machines need to be checked and included in the arc flash analysis. After analysis, all machines need to be properly labeled with acceptable signage and the employees need to be trained. And that is where most companies, unfortunately, stop; they are arc flash compliant, have a trained staff, and perhaps have a basic plan in place to train new hires. But without ongoing maintenance and self auditing, any company runs the risk of falling out of compliance, which is why we recommend at least an annual third party safety audit to ensure arc flash compliance.

For more information on arc flash analysis or annual audits, please contact us. And if you have anything to add about the importance of arc flash maintenance, please leave a comment.