Friday, December 31, 2010

Happy New Year!

All of us at Comprehensive Safety Resource wish you a prosperous and safe New Year. (Now, go check those smoke detectors since you forgot to do it in October.)

-Jason

Monday, December 20, 2010

Training Options for Safety

Employee training is a key component of any successful safety program, and OSHA requires employers in the United States to furnish it. The question then is, what is the best way to deliver it?
The traditional classroom setting, with a live instructor, is probably the most flexible method. A knowledgeable instructor can evaluate the makeup of the class and tailor the content to the specific needs of the attendees. But, work schedules, travel arrangements, and other factors may make this type impractical.
Correspondence courses are also available, where the student receives instructional material in the mail, completes it, then mails it back to the instructor for grading. I have personally never taken a correspondence course, but I imagine that the greatest drawback would be the tendency to forget about the material until it was too late to send it in. In any case, this method would require considerable self-discipline to gain any knowledge from the material. Correspondence courses are no longer widely requested.
The most common type of distance-based training now, utilizes the computer. Many different types of training are available, even OSHA 10- and 30- Hour courses in both General Industry and Construction. The availability of internet training has never been so great, and in many instances, this type of training offers several benefits over other types of instruction.
The first one, in many minds, is cost. If a company only has a few employees that need training, internet-based training may be substantially cheaper. For the traditional classroom setting, the cost of the instructor is usually about the same whether there is one student, or twenty-five. Not only does the instructor incur costs, but if the employees have to travel to attend training, the company will incur costs as well that add on to the overall expense o the training. For online training, the fee is set, usually per person, no matter where the employees are located, for larger groups, it may be possible to negotiate a reduced rate with the online training provider.
Another benefit of internet-based training is the convenience. Often work schedules, product shipments, employee vacation days, and the like conspire to make centralized classroom training difficult to accomplish. Online training, however, allows employees to progress as they have time, making the scheduling problem almost disappear. This helps insure that deadlines are still met, that projects are completed on time, and that product gets out the door. Many courses will have a time limit, but they are usually measured in weeks or months, not hours.
Location is also sometimes a factor in training. For online training, employees only need a computer with internet access. The do not have to travel to meet at a central location. This can be a huge benefit for employers that have several offices, or employees that work at remote locations. The travel costs to get all employees at the same location can be huge. Online training eliminates that.
Employers have the duty to furnish relevant training to employees, but deciding how to accomplish it can be a challenge. Online, internet-based training adds one more solution that more and more companies choose as they weigh cost with benefit.

-Jason

Monday, November 29, 2010

Deconstructing OSHA Crane Standards, Pt. 2 1926.1400

In the last post, I discussed some of the changes imposed by the new OSHA Construction Crane Standards. Operator Certification was the focus there, but there are new requirements for other employees, too.

Effective immediately with the new standards (as in, it’s already happened,) is a new requirement for signal persons. The rule now requires signalers for affected crane operations to be qualified for that operation. Signal person qualification must be documented either on paper or electronically, and be available on the jobsite. The documentation must specify the type of signaling for which the employee is qualified. (i.e. hand signals, radio signals, smoke signals, etc.)

To be considered “qualified” under the new standards, the employee must understand the types of signals in use on the jobsite, demonstrate competency in using those signals, understand the operation of the particular cranes in use, and understand the requirements of the OSHA Standard relevant to signal person qualification. Additionally, the signal person must pass both a written and a practical exam dealing with the subject. This training can be performed by a qualified third-party evaluator, or by a company’s in-house qualified evaluator. There is no accreditation required for the evaluator, they just need to be able to demonstrate that they are capable of assessing whether or not a signal person is qualified in accordance with the standard.

A signal person is required on any jobsite where the point of operation is not completely visible to the crane operator, or if the operators view is obstructed in the direction the equipment is traveling. A signal person is also required if the operator or the person handling the load deems one necessary due to site-specific safety concerns.

Riggers also need to be qualified under the new standard, but the requirements for documentation are a little less strenuous. A qualified rigger is defined as a "qualified person" who, by possession of a recognized degree, certificate, or professional standing, or who by extensive knowledge, training, and experience, has successfully demonstrated the ability to solve/resolve problems relating to rigging.

A qualified rigger is required whenever assembly or disassembly of the crane is being performed. A qualified rigger is also needed whenever employees are engaged in hooking/unhooking the load, guiding the load, or otherwise manipulating loads, and are within the fall zone of the material.

In the next post, we’ll examine some additional requirements for crane operations, especially operations near power lines. In the mean time, if you have specific questions, consult OSHA directly, or contact a private safety consultant to address your specific needs.

Jason

Monday, November 8, 2010

Deconstructing Construction Crane Standards, Pt. 1

Well, it’s November 08, 2010, and if you are covered under OSHA’s 1926 standards for Construction, and you operate just about any sort of crane, then your world has probably changed a little. After almost forty years, the Overhead Crane standards have been dramatically revised, with major changes in the training requirements for both operators and for ground personnel. Those changes went into effect this morning. We’ll explore these changes over the course of the next couple of updates.

First off, who is affected by these changes? Well, the easy part is, if you fall under OSHA’s 1910, General Industry standards, you can relax; this isn’t aimed at you. Only Construction is involved with this round of changes. The standard defines a crane for the purposes of this section as "power-operated equipment that, when used in construction, can hoist, lower and horizontally move a suspended load" [1926.1400]. That’s pretty broad, so these changes are obviously meant to have pretty sweeping impact. Some, but not all, equipment included are mobile cranes, tower cranes, crawler cranes, boom trucks, knuckleboom cranes, and cranes on barges. Also included are service trucks with a lifting device, pile drivers, and multipurpose equipment that is outfitted to hoist and lower, and horizontally move a suspended load.

Now, before everyone gets too upset, there are some exclusions. First off, there is a general exclusion for equipment with a manufacturer’s rated lifting capacity of less than 2000 pounds. Also, several types of equipment are mostly excluded; excavators, backhoes (even when used to lift suspended loads), concrete pumps, aerial lifts, tow trucks, digger derricks, gantry systems, and forklifts among them. Be sure and check 29 CFR 1926.1400(c) for detailed information on the exclusions.

Probably the biggest change involved in the new revision is the requirement for training of personnel involved in crane operations. Today, we will look at the most prominent: the operator. Beginning today, all operators of affected equipment must be certified to operate the specific equipment under their control. However, there is a four-year grace period to have the training completed, giving a real deadline of November 10, 2014. There are a few ways to comply with this standard. The first is to send operators to a nationally-accredited training program that includes practical and written tests specific to the equipment type and rating for their certification. This option may be the easiest to implement, if not necessarily the least expensive. A quick internet search for ‘crane certification’ should pull up several options, just make sure they are nationally accredited to insure compliance with the standard.

Another option is an audited employer training program. The employer may hire an independent auditor (certified by an accredited crane operator testing organization) to oversee training programs developed by the company. This option results in a certification that is not portable, so employees certified under this rule may only operate equipment while employed by that company. This option requires the employer to take an active role in training, and may be a good option if company resources permit.

There are also options to be certified by a government entity, or by the US military. In any case, certifications are valid for a maximum of five years.

We’re over 500 words into this, and we have barely scratched the surface. In the next installment, we will look at the changes that affect signalers and riggers. In the mean time, if you need additional assistance, the crane standard can be found in 29 CFR 1926.1400, and an independent safety consultant can be contacted to help determine what particular exposures your company has, and what approach would be most effective in ensuring your compliance.

-Jason

Monday, October 18, 2010

Lock It Down!

Lockout/Tagout is one of the most important tools we can employ to reduce workplace injuries and fatalities, especially among those that must service equipment as a part of their regular duties. Lockout/Tagout is, quite simply, the process of removing all hazardous energy sources from a piece of equipment, then placing a lock or tag on them to prevent them from being reenergized, either intentionally, or accidentally, until the person that installed the lock is ready.
OSHA states that compliance with the Lockout/Tagout Standard (29 CFR 1910.147) would prevent approximately 120 fatalities (that is one every three days!), and an astonishing 50,000 injuries each year in the United States. Clearly, the need for proper implementation of the process is needed. Lockout/Tagout cannot be thought of as an optional procedure, for use whenever production schedules or personal convenience allow it.
The first step in Lockout/Tagout, like most other safety topics, is to evaluate the workplace for potential hazards. Ideally, this should be done before the need to actually perform Lockout/Tagout has arisen. Employers should look at what procedures are being performed in the facility, and by whom. This will identify what level of training is necessary, and what equipment will be required to safely perform Lockout/Tagout.
The OSHA standards define different levels of responsibility when it comes to Lockout/Tagout roles. The first classification is the ‘Authorized’ employees. These are the employees that actually perform Lockout/Tagout and use it for their personal protection while servicing equipment. These employees should have the highest level of training about Lockout/Tagout, as well as the most intimate knowledge about the equipment they will be servicing.
The next level is the ‘Affected’ employees. These are employees that use the machines or equipment that is being serviced, or workers whose job requires them to be in the immediate area as equipment that is locked out. Affected employees do not perform Lockout/Tagout, nor do they perform any servicing or maintenance on the equipment that may expose them to hazards. Their main responsibility with Lockout/Tagout is to recognize when the procedure is in place, and leave it alone! They are not authorized to remove or tamper with the Lockout/Tagout procedures in place.
The next step in implementing an effective program is to identify any equipment that is served by more than one energy source. This equipment will require written Energy Control Procedures, specific to that equipment, that detail how an orderly shut-down, proper energy isolation, and verification testing should be performed. It may be necessary to consult with the manufacturer, or even hire an independent consultant to assist with getting all the steps in the right order as well as insuring proper documentation of the program. Remember, properly implementing these Energy Control Procedures should be the highest priority, since someone’s safety may be at stake.
Lockout/Tagout training should be performed so that each employee understands his role and responsibilities to the program. Annual refresher training should be performed also, just to be sure that everyone is still on the same page. This is also a good time to review the Energy Control Procedures to make sure they are still relevant, and that they still protect workers like they are designed to do.
Lockout/Tagout is not an optional program. OSHA mandates that all equipment be completely removed from its energy source before workers engage in any operation that may injure them if the equipment were to restart. Also, there is no time limit placed on the operation, so a worker clearing a jam that takes four seconds deserves the same amount of protection as one overhauling a machine that takes four weeks. In either case the equipment must be completely removed from its energy source before work can proceed. It’s the law, and it’s the right thing to do to guard worker safety.

-Jason

Monday, October 4, 2010

Is Your Forklift Program Lifting Its Own Weight?

Forklifts and other Powered Industrial Trucks are vital to industry in the United States. We rely on this equipment to lift, stack, tier, pull, and push material in a wide variety of applications. Just as we maintain the equipment itself, we must also remember to maintain the operators. While a forklift is a valuable tool when used properly, just like an automobile, it can be a deadly tool when used improperly.
Forklift accidents account for about 95,000 injuries and about 100 workplace fatalities each year; an appalling figure. Many of these incidents can be traced to operators with inadequate training. OSHA requires in 29 CFR 1910.178 that operators receive training and certification at least every three years in order to remain proficient. Awareness of this requirement is usually not a problem in large warehousing facilities, but smaller operations that have only one or two forklifts that may not even get used every day sometimes are unaware of the standard.
Some operations have a great enough need for certifications that they maintain an in-house trainer to handle certifications as needed. For other operations, that may not be practical. Private safety trainers and consultants should be able to provide this service, or the equipment supplier may be able to help arrange training.
The training must include several elements to fulfill the requirements of the standard. To begin with, it must be conducted by a qualified trainer. If the trainer is unsure of the requirements and proper operating procedures, then the students may not get the best investment of their time. The training must also include a classroom portion with a written test. This is the opportunity for the trainer to personalize the training to address the needs and unique hazards that are present at each worksite. This should include a discussion of the particular operation, as well as a discussion of the particular equipment that the workers will use onsite. The written test is useful to evaluate comprehension of the material. Keep in mind, that if workers are present who do not speak English, a trainer should be chosen who can effectively communicate in their native language. This includes having written tests that are translated as well. We want to avoid the scenario where workers who do not understand the presentation sit in the back and nod their heads because they are too afraid to let someone know they do not speak the language.
After the classroom portion of the training is over, it is time to perform the practical evaluation of the participant’s skill. They need to drive the forklift. An evaluation should be set up by the instructor that will allow her to observe the trainees go through a series of maneuvers to demonstrate their efficiency. There is no required set of motions, but each operator should have to perform motions similar to the ones they will use in the performance of duties. Observing their familiarity with the equipment, lifting, steering, braking, adjusting forks, etc., should all be a part of this section.
After the instructor is satisfied with the operators’ performances, a certification may be issued that lasts for a maximum of three years. After that time, a complete recertification must occur. A separate certification should be issued for each type of equipment the operator uses, and a separate practical evaluation performed for each type, also.
Retraining may be required if new equipment or new hazards are introduced that affect forklift operations. Retraining may also be needed if operators show that they are unable, or unwilling, to follow safe operating procedures.
Proper forklift operator certification is required under the OSHA Performance Standard, and the training is not difficult to come by. With a little involvement by the employer, and the employee, the workplace can be made that much safer, which is our ultimate goal!

-Jason

Monday, September 13, 2010

Are You Seeing Proper Protection in Your Workplace?

Selecting and using proper personal protective equipment for workers is one of the most frequently encountered issues both in Construction and General Industry. Eye protection is a key component of this issue.
Eye protection comes in many different forms, from safety glasses, to goggles, to face shields. The most important part of selecting equipment is to first identify the hazards that may be present. For example, protective equipment that is appropriate for using a power drill will be different than that appropriate to welding. The employer, under current OSHA Standards has the responsibility to assess the operations that workers perform, then decide what level of protection is appropriate. After that, the PPE must be provided to the employee, along with training that includes a discussion of how and when the equipment should be used, what its limitations are, and how to properly care for the equipment.
Safety glasses are probably the most common form of eye protection encountered among workers. Most modern safety glasses are either plastic or metal framed, have built-in side shields, and built-in brow protection. Look for ANSI Z87.1 certification on the lens or frames to easily identify glasses that meet the current requirements for strength and impact-protection. In general, safety glasses provide good low-level protection against impact from flying particles. General construction duties, demolition operations, mechanical shops, and manufacturing facilities may all benefit from the use of safety glasses. Employees who wear prescription lenses can obtain prescription safety glasses that incorporate side shields, usually for a reasonable price. Prescription glasses used as safety glasses still have to have the ANSI Z87.1 rating. It will usually be printed right on the frame of the glasses.
Safety glasses may not provide the level of protection needed for more intense operations such as grinding, abrasive blasting, or chipping. Safety glasses also provide very little protection from chemical splashes. For these types of jobs, goggles may be required. Goggles come in a few different configurations, usually based on their method of ventilation. The most protective type of goggles are unventilated. They have a seal or gasket that completely surrounds the eye to give maximum protection from flying chips, sparks, and chemical splashes. They also tend to be the most uncomfortable to wear, since they severely restrict airflow to the eyes. The next step is the indirect ventilated goggle. They usually have a series of baffled valves to let in some air, but still do a reasonably good job of protecting against chemical splashes. The final type is the direct ventilated goggle. These usually have a series of small holes in the sides of the goggles that provide the best airflow, but trade some of their ability to keep out chemical splashes. These are the best choice where the chief hazards are flying particles, chips, etc, but don’t include chemical hazards. Goggles can be purchased that will accept prescription inserts, or that are designed to fit over prescription lenses. Contact lenses should be discouraged in any operation that may contain chemical hazards.
There are other types of specialty eye protection that may be selected when appropriate. Items such as welding goggles and laser-protective eyewear should only be selected by qualified individuals who are familiar with the exact nature of the hazards involved. Consultants and manufacturers may also be a resource for more information.
Personal protective equipment is a very useful tool to prevent injury in the workplace when used properly, but it will never take the place of proper work procedures, and engineering controls. It definitely will not take the place of common sense. If a job seems too hazardous, or something just does not seem right, then we should stop and evaluate our process to see what changes can be made, or what training needs to be provided. Protective equipment is one more weapon in our arsenal to prevent workplace injuries and help insure our ultimate goal of keeping workers safe.

-Jason

Thursday, August 26, 2010

CHANGES TO OSHA TRAINING REQUIREMENTS MEAN MORE DAYS IN THE CLASSROOM

AUGUST 24, 2010 – The Occupational Safety and Health Administration (OSHA) issued a new policy to the OSHA Training Institute and to the Outreach Trainers a few days ago that could have a big impact on the way employers structure their safety training for OSHA 10 and 30 Hour classes.

The new rule limits the amount of training that may be provided each day to 7.5 hours for OSHA 10 and 30 Hour classes in both Construction and General Industry. This means that the 10 Hour Training now requires at least two days to complete rather than one long 10 hour day, and the 30 Hour training will require at least four days.

This will force some adjustment on those employers who bring in employees from multiple locations to attend this type of training, as it now requires an overnight stay, or adds an extra overnight stay to the overall cost of the training. The trainer now must cover additional expenses, and employees have additional lodging and meals.

There is no change in the total amount of required classroom hours, only to the way the hours are spaced. The total hours spent on each subject are also not changed with this ruling, but OSHA did mandate an expanded “Introduction to OSHA” training module in June.

One way employers may choose to offset the cost of the new training requirements, is to make a move toward nontraditional training formats. Probably the most common, and the easiest to manage, is online, web-based training. Employees can work at their own pace as production allows, and they only need computer access to complete the programs, eliminating the need for travel and disrupted workflow entirely. Students have six months to complete the coursework. CSR offers web-based training through its website at www.csrsafety.com for Construction and General Industry 10 and 30 Hour courses. Upon completion, students receive a standard OSHA completion card from an Authorized Outreach Instructor.

For employers that still want the personal experience of a live trainer onsite, CSR can provide an Authorized Trainer to customize the training to the specific needs of the company, and insure that relevant topics are covered. Please visit us at CSR, and we will provide you with a quote to suit your needs.

Saturday, July 10, 2010

Maritime Advisory Meeting to Focus on Shipyard Worker Hazards

OSHA will hold a Maritime Advisory Committee on Occupational Safety and Health (MACOSH) meeting July 13-14, 2010, in Long Beach, Calif. Meeting discussions will include an update on OSHA activities and their impact on maritime workers, and agenda topics such as scaffolding and fall hazards, repairing terminal equipment safely and providing workers with proper ventilation during welding operations.

MACOSH was established in 1995 to advise the Secretary of Labor on various issues related to safe and healthful work conditions in maritime industries, such as ways to increase the effectiveness of maritime safety and health standards; injury and illness prevention; use of stakeholder partnerships to improve training and outreach initiatives; and enforcement initiatives that will help improve the safety, health and working conditions of maritime workers.

The committee and workgroups will meet at the Renaissance Long Beach Hotel, 111 East Ocean Blvd., Long Beach, Calif., 90802. The Longshoring and Shipyard workgroups will meet Tuesday, July 13, 8 a.m. to 4 p.m., PDT. The committee will meet Wednesday, July 14, 8:30 a.m. to 4:30 p.m., PDT. MACOSH meetings are open to the public.

Written data or comments on MACOSH agenda items should be mailed to Vanessa Welch, Office of Maritime, OSHA, U.S. Department of Labor, Room N-3609, 200 Constitution Avenue, N.W., Washington, D.C. 20210. Materials may also be sent by facsimile to 202-693-1663. Submissions received by July 13, 2010, will be provided to committee members and will be included in the meeting record. Requests to make oral presentations to the committee may be granted as time permits.

General information inquiries should be directed to Joseph Daddura, OSHA Office of Maritime, at 202-693-2067. Individuals with disabilities wishing to attend the meeting should contact Vanessa Welch at 202-693-2080 no later than July 13, 2010, to obtain appropriate accommodations.

Under the Occupational Safety and Health Act of 1970, employers are responsible for providing safe and healthful workplaces for their employees. OSHA's role is to assure these conditions for America's working men and women by setting and enforcing standards, and providing training, education and assistance. Comprehensive Safety Resource is a nationwide provider of 10 and 40-hour training, both on-site and online. More information can be found in the links on this blog.

US Department of Labor's OSHA assistant secretary concerned some oil spill workers not receiving proper training

U.S. Assistant Secretary of Labor for Occupational Safety and Health Dr. David Michaels today issued a statement on July 7 regarding training for Gulf Coast oil spill clean-up:

"Employees hired to be supervisors in the onshore and marine cleanup are required to receive extensive training. A rigorous 40-hour program is required under OSHA's Hazardous Waste Operation and Emergency Response Standard.

"In order to meet the certifications of this 40-hour training, a combination of classroom and hands-on, applicable experience is required. This includes instruction on the makeup and risks associated with the hazardous material(s) involved, and experience with the equipment needed for the work, safety gear and local environment.

"We have received reports that some are offering this training in significantly less than 40 hours, showing video presentations and offering only limited instruction. This training cannot be shortened to anything less than 40 hours. Moreover, computer-based training, which could be offered over the Internet, can be used as part of an overall 40-hour HAZWOPER training course. However, such training alone does not meet the full course requirements.

"OSHA also recommends that the trainer-to-student ratio for this type of training be one trainer for every 30 students in the class.

"If a worker feels the training he or she received by a private company or organization does not meet the HAZWOPER training requirements, he or she may contact the closest OSHA area office to file a complaint or call 800-321-OSHA (6742) for more information."

Comprehensive Safety Resources has specialists in HAZWOPER training that have worked exhaustively in the oil and gas industry. 10 and 30-hour training programs are available both on-site and online for convenience.