Confined Space Program

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An average of almost 2 workers per week die from confined space accidents. Most of these fatalities occur as a result of oxygen deficiency or the inhalation of toxic substances. In 2013, these two accident types accounted for 91% of all confined space accidents. With a properly developed confined space program, every single one of those fatalities could have been avoided.

When developing a confined space program, you need to first review OSHA Standard 1910.146. Standard 1910.146 sets the minimum safety requirements for all things confined spaces. It defines what a confined space is, defines in what situations a permit entry system is required, what to do in the event a hazardous atmosphere is present in the confined space, and how to properly maintain the space.

With the definitions and directions from Standard 1910.146 in mind, it is time to create your confined space program. In order to do this, you will first need to assess your facility to determine how many confined spaces you have. From there, you need to assess the individual spaces and, based upon the requirements set in Standard 1910.146, determine if a permit entry system is required, or if there are any special circumstances surrounding your spaces.

From there, you need to create procedures which take into account personal protective equipment, signage, a permit entry system (if applicable), a toxic substance plan (if applicable), and what your rescue plan is in the event of an emergency. Finally, you want to ensure your plan is able to adapt to future changes, meaning that you have someone monitoring Standard 1910.146 in case of updates and that you have provisions for how to add additional regulations should additional confined spaces or changes to your current confined spaces need to be accounted for.

If you have any questions about creating or updating a confined space program, please contact us. If you have anything to add about how to create a confined space program, please leave a message.

OSHA Compliant Lockout Tagout Procedures

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Creating OSHA compliant lockout tagout procedures can be more difficult than it originally seems. We have worked with many clients who initially planned on creating their own lockout tagout procedures, only to get halfway through the project and need to reach out for help.

So whenever we are advising a client who needs new lockout tagout procedures, we make several recommendations. Number one, let a qualified lockout tagout expert create the procedures, but make sure you are involved in the process. This way, you will understand how lockout tagout works, why your procedures are created in the way they are, and you will be more able to properly enforce the procedures.

Number two, learn OSHA Standard 1910.147. Whether a client ultimately decides to work with us or try it alone, it is important they understand the standard, at least superficially. But the more you understand the standard, the more effectively you can monitor your procedures and enforce they are being followed.

And number three, have a plan in place to monitor and update the procedures. If there is nothing in place to help you prepare for the future, there could be issues down the line if regulations or your business change. One of the easiest ways to monitor and update your system is with software which is designed to survey and audit your lockout tagout procedures. This type of software allows you to make changes or updates to your existing procedures while maintaining your compliance.

If you have any questions about creating or maintaining lockout tagout procedures, please contact us. If you have anything to add about OSHA compliant lockout tagout procedures, please leave a comment.

OSHA Increasing Focus on Tower Safety

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Last week, OSHA issued a statement regarding the surge in cell tower fatalities. In 2013, there were 13 fatalities related to cell towers; that number is more than the two prior years combined. In the first five weeks of 2014, there have already been 4 fatalities. As a result of this increase in fatalities, OSHA is collaborating with the National Association of Tower Erectors to make certain all employers in the industry understand their role in employee safety for those employees who work on cell towers.

“Tower worker deaths cannot be the price we pay for increased wireless communication,” said Dr. David Michaels, assistant secretary of labor for occupational safety and health. “Employers and cell tower owners and operators must do everything possible to stop these senseless, preventable tragedies.”

The majority of fatalities over the last two years have come from falls. In order to help ensure employees are aware of current best practices and industry standards, they have created a new website, which will feature all information including regulatory changes. Many of the fatalities were preventable, but due to poor safety procedures and a lack of training, these individuals died.

If your business works with cell phone towers in any capacity, it is critical that you continue to follow the news regarding these updates. It might also be a prudent time to have your safety and health management system audited, to ensure you are in compliance.

If you have any questions about this release from OSHA or about third party safety audits, please contact us. If you have anything to add about OSHA’s increased focus on tower safety, please leave a comment.

OSHA Accident Prevention Signs and Tags

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The US Department of Labor’s Occupational Safety and Health Administration places a heavy value on accident preventions signs and tags. All signs and tags must be properly created, have appropriate lettering and colors, and follow standard hazard definitions. In order to assist business owners in creating proper signage, OSHA created Standard 1910.145.

Standard 1910.145 defines what a sign is; when a sign is needed; which signs are needed in which circumstances; what design must be present on the sign; how to apply the signs; and any parameters of the sign, including size, shape, and corner type. OSHA further defines specific sign types, such as “danger” signs, “caution” signs, “biohazard” signs, etc. OSHA also defines several emblems and figures within the standard.

Because OSHA takes such a narrow view to signs and their design, it is important to make sure all of your signs are up to code, and to have a plan in place for the constant review of existing signs, and replacement of signs as they get old, as they can fall out of compliance with age. To help in the review process, it is usually advisable to have regular third party audits of your safety signs, to ensure slowly aging signs have not gone unnoticed by employees who see these signs multiple times a day.

To help with the replacement of outdated or damaged signs, it is advisable to purchase new signs from a qualified OSHA expert. We have a store where you can buy any sign you need, and rest assured knowing we guarantee it is OSHA compliant.

If you have any further questions about OSHA accident prevention signs and tags, or if you need to have your facility audited, please contact us. If you have anything to add about these signs and tags, please leave a comment.

Creating an Evacuation Plan

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Properly created evacuation plans will account for a number of potential emergency conditions. These conditions should be both internal and external, and should consider OSHA Standard 1910.36 and Standard 1910.37. These standards guide you in creating the actual evacuation plan and in maintaining the evacuation routes. Simply pointing employees to the nearest exit will not suffice in a true emergency.

Standard 1910.36 specifically discusses the design and construction requirements for exit routes. This standard covers the number of exits required, the number of paths to said exits which are required, the types of exit doors which must be used, and what types of materials must be used in the construction of exit doors and routes. Based upon your facility and your needs, this standard can help you to ensure you create a truly effective evacuation plan.

Standard 1910.37 discusses the maintenance, safeguards, and operational features for exit routes. This standard sets the guidelines for maintaining the routes established in the evacuation plan. It covers everything from lighting and paint to door maintenance and what to do in the event construction is being done to the evacuation route. So where Standard 1910.36 will help you establish your evacuation plan on paper, Standard 1910.37 will help you to maintain these evacuation routes in the event of a real emergency.

If you have not recently reviewed your evacuation plan or if you do not have a true plan in place, it might be time to have a qualified third party firm review your plans. If you have any questions about evacuation plan reviews or creating a new evacuation plan, please contact us. If you have anything to add about creating an effective evacuation plan, please leave a comment.

Creating Effective Lockout Tagout Procedures

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Creating effective lockout tagout procedures is more of an art than a science. You need to be able to effectively navigate OSHA Standard 1910.147; properly audit your machinery, taking all potential variables into account; create a coherent procedure with this information; and account for future business and regulatory changes. And if you do all of this correctly, your procedures are only good for the time in which your business remains exactly the same; once one variable changes, the procedures need to be updated to reflect the change.

Because of the difficulties with creating effective lockout tagout procedures, most employers rely on qualified third party lockout tagout specialists to create their procedures. A qualified individual who dedicates himself to understanding the lockout tagout regulations can easily assess most facilities and create unique procedures based upon that facility’s needs relatively quickly.

In addition, a qualified lockout tagout specialist will create procedures which account for change. There will be room for change built into the procedures and a plan will be in place for how to account for those changes. Changes can be accounted for in a number of ways, but ensuring there is some plan in place is crucial when hiring a lockout tagout specialist to assist you in creating your procedures.

If you have any questions pertaining to the creation of effective lockout tagout procedures or updating lockout tagout procedures, please contact us. If you have anything to add about the importance of devising a plan for change in lockout tagout procedures, please leave a comment.

OSHA Considering Extending Crane Operator Certification Requirements

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On August 9, 2010, the Occupational Safety and Health Administration issued a final standard in relation to cranes and derricks used in construction work. This standard established new requirements for crane operators working on construction sites. In order to meet these new requirements, crane operators would be required to meet one of four certification or qualification requirements by Nov. 10, 2014. OSHA is now looking to extend that date by 3 years to Nov. 10, 2017.

OSHA has proposed this rule change in order to appropriately and effectively respond to inquiries and complaints lodged by several parties. OSHA does not want a rule change to go in effect while the rule change is still being discussed and does not want to create a negative impact upon the construction industry. There have already been three stakeholder meetings on this issue, and the final date to submit comments on the rule change is March 12, 2014.

What this means for you, is that if your company uses cranes or derricks, you need to keep a close eye on this situation. If you have not already scheduled your crane operators for certification, it is still a good idea to get that process started, as this rule change has not yet been approved. And even if the extension is passed, these operators will still need to be certified in 2017.

If you would like more information on how this rule specifically impacts you and your business, please contact us. And if you have anything to add about the new crane operator certification requirements, please leave a comment.

Compressed Gases

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Compressed gases are utilized across many industries. These gases can come in all types, and can be held in containers of all sizes. For this reason, it can be difficult for a company to properly develop a safety plan pertaining to compressed gases and their storage.

Because of this inherent difficulty, OSHA created Standard 1910.101, which sets minimum requirements for the use, transportation, and storage of compressed gases. In addition, this standard sets guidelines for safety relief devices which must be included on the compressed gas containers.

Unfortunately, OSHA largely hands the issue off to the Department of Transportation and the Compressed Gas Association. For issues pertaining to the storage, transportation, and use of compressed gases, business owners are sent to the Department of Transportation’s Hazardous Materials Regulation (49 CFR parts 171-179 and 14 CFR part 103). This regulation, in turn, covers all hazardous materials, and requires cross-referencing for different compressed gases and different containers.

OSHA then directs readers to the Compressed Gas Association Pamphlets S-1.1-1963 and 1965 addenda and S-1.2-1963 for any questions pertaining to the required safety relief devices for compressed gas containers.

So to initially establish a compressed gases safety program, you must review multiple sources. Then, to ensure continued compliance, you must continually review these multiple sources.

To streamline that process, it is often easier to simply work with a third party occupational safety and health auditing firm which can keep you abreast of regulatory changes while helping to ensure your safety plan is compliant.

For more information on compressed gas storage, use, or transit, please contact us. If you have anything else to add about compressed gases or their related regulations, please leave a comment.

Effective Lockout Tagout (LOTO) Monitoring

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If you have ever had to create lockout tagout procedures for your company, you know that there are a number of ways to do this. If you have any experience in the field, you can do it yourself, you can do it with the help of online quick guides, you can do it as a partnership with a qualified third party firm, or you can hire a firm to handle the whole process for you. And while each of these options have their benefits and pitfalls, each has a subset of companies for which it makes sense.

The same could be said for lockout tagout monitoring. After effective lockout tagout procedures have been created, it is important for regular and ongoing monitoring of those procedures to ensure they remain accurate, applicable, and up to code. Some companies utilize their safety and health team to monitor their procedures, others hire third parties to handle that responsibilities, and still others form a partnership with a lockout tagout auditing firm to jointly monitor and update their lockout tagout procedures.

And while each of these methods can be right for the right company, it is important to look into every option available to you, especially the option which allows you to partner with an experienced lockout tagout firm. Through our Factory Solutions Software, you have full control over your procedures, allowing you to customize and update your procedures in real time, but also allowing us to oversee your procedures, and guide you when needed.

If you have any questions about how to effectively monitor your lockout tagout procedures or about our Factory Solutions Software, please contact us. If you have anything to add about effective lockout tagout monitoring, please leave a comment.

OSHA Fines Solvay Specialty Polymers $77,000

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On February 6, 2014, the Occupational Safety and Health Administration cited Solvay Specialty Polymers for 12 violations, and proposed $77,000 in fines for said violations. These violations centered around exposing workers to chemical hazards from solvents and came after an investigation of the company’s plant in Marietta, Ohio.

“The plant needs to ensure all equipment and processes receive the proper evaluation and scrutiny before the use of these highly hazardous chemicals. Workers must be trained to handle these chemicals safely,” said Deborah Zubaty, OSHA’s area director in Columbus. “Process safety management programs are designed to prevent the catastrophic release of highly hazardous chemicals and to prevent workers from being exposed to these harmful chemicals.”

Eleven serious and one repeat violation were issued. The repeat violation was issued for failing to follow recognized good engineering practices. The eleven serious violations were all related to OSHA’s Process Safety Management Standard. The Process Safety Management Standard is a detailed set of requirements and procedures which address hazards that are associated with hazardous chemicals.

If you own a company that uses hazardous chemicals and you have not recently ensured you are up to code with the safety management standard, it might be a good time to have your safety and health management system audited by a professional third party auditing firm. OSHA is constantly auditing companies, searching for violations; third party audits can go a long way in protecting your company.

If you have any questions about OSHA’s Process Safety Management Standard or about third party audits, please contact us. If you have anything to add about either of these topics, please leave a comment.