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OSHA Recordkeeping: What do I do with this 300 Log?

2012-01-13T09:53:00.000-06:00

Well, a new year is upon us (at least if you follow the Gregorian calendar) and since the bustle of the winter holidays is mostly past, it’s probably time to start thinking about your required OSHA recordkeeping duties, if you haven’t done it already.

One of the many elements of worker safety that the OSH Act established is a requirement for employers with more than ten employees to keep records of employee work-related injuries and illnesses. There are some exempted industries (mostly retail and service occupations), and they can be found on the OSHA website. This recording system is most commonly known by the name of the form itself – the OSHA 300 Log.

Ideally, employers will keep track of the 300 Log throughout the year; adding log entries within the specified seven days required by OSHA, but even if you let it slip, it is not too late to get started. Firstly you must determine whether or not an injury or illness is recordable. In general, it’s pretty safe to say that if an injury or illness requires more than first aid to treat, then it must be recorded. If an employee loses consciousness, has restricted or light duty, or misses days from work, it must also be recorded. There are some exceptions and clarification to this, and they can be found in the applicable OSHA standard, or you might wish to enlist the help of a safety consultant to assist in the process.
After injuries or illnesses are reported by employees, the employer must make a record of the incident with certain pertinent details. The ‘OSHA 301: Injury and Illness Incident Report,’ may be used for this purpose, but employers may use alternate forms, (often provided by insurance carriers, or the like) as long as they contain the same information. Incident Report forms should be completed as soon as practical after the report of an injury or illness, so relevant details are not forgotten or omitted.

The next step is to simply fill out the OSHA 300 Log form. It is a pretty self-explanatory form that will require, among other things that you enter the injured employee’s name, job title, date of injury, location of injury, and description of the injury. Then, if the employee lost time or had restricted duty days (or both) you add up the number of days and record it in the appropriate blanks on the form. Even if the company had no work-related injuries, there is still a requirement to keep a log for that year. This form is then kept on record, for at least five calendar years. Incidentally, the forms may be maintained electronically, and is available as an Excel or .PDF file here.

The part of the process that is especially important at this time of year is to fill out the Summary Log, or 300A Log, for the previous year, so it can be posted for employees to view. (The 300 Log is never posted, as it contains personal medical information.) This is one of the employer duties under the OSH Act, and employers may be cited for failing to post the relevant information. It is required to be posted in a conspicuous place between February 1st and April 30th. The 300A Log just lists the total number of injuries and illnesses, and the total number of days away from work, and the total number of restricted duty days. A company officer (or the highest-ranking manager at a location) must then sign the form to validate it before it gets posted.

Remember, January 1st starts a new year for workplace injuries and illnesses, so if your company had a great year last year, keep up the good work! Remember, though, even if there were no reportable injuries or illnesses, the 300 and 300A Logs must still be maintained and posted as required. They will just contain a bunch of zeroes! If there is some room for improvement, then get the training and information you need to resolve to make this year better. Numerous resources exist to get companies the information they need to keep employees safe at work, and decrease costs related to injuries and illnesses on the jobsite, so get the help you need to make 2012 the safest year in your company's history.

-Jason

Occupational Lead Exposure

2011-12-06T09:38:00.000-06:00

   It’s been a while! We hope everyone is enjoying a safe, winter holiday season. I thought I would take a brief look a lead exposure in the workplace.
   Lead is a metal element with the chemical symbol Pb, (from the Latin plumbum, the same root word as plumbing) that is classified as one of the heavy metals. Unlike some other metals, such as iron, zinc, and copper, it has no known function in human biology, and is considered a major toxic metal. Lead is used in a wide variety of industrial applications, including from the production of solder, batteries, bullets, and various alloys, such as linotype.
   In humans, lead functions primarily as a neurotoxin, affecting the nervous system, although it can affect the blood, gastrointestinal system, and others. It has a particularly drastic effect on young children. A direct correlation has been established between lead exposure and IQ loss in young children. Lead can cross the placental barrier to a developing fetus, if the mother’s blood level is elevated. Children also spend more time crawling around on the floor, exposed to dust and paint chips that can contain lead, putting them at more risk of lead poisoning.
   In adults, lead is most commonly seen as an occupational exposure. Workers engaged in processes that use lead can experience symptoms related to the exposure, if proper protective measures are not observed. Lead was a common component in paints and pigments in the past, and so any workers that have to disturb these coatings are also at risk. Abdominal pain, insomnia, personality changes, and unusual taste in the mouth, kidney failure, and headache are some common symptoms, but the route of exposure, as well as the dose, will determine the exact symptoms, due to the fact that lead can inhibit the function of many different body systems.
   The first step for any employer that may have lead exposure to its employees is to perform an assessment of the workplace to determine what types of protective measures are appropriate. Part of this assessment may include having the air sampled to see if lead is present in the air that employees are breathing. It may be necessary to test employees periodically, if lead is a potential problem. Blood tests are usually used to detect short-term exposure to lead. Chronic exposure usually leads to lead deposition in the bones. Periodic retesting is a common requirement in facilities that use or generate lead as a normal part of business. After the hazard assessment is performed, then engineering controls, such as ventilation, work practice controls, or personal protective equipment, (especially respiratory protection) can be implemented to ensure worker safety. Employees will also need to be trained to understand the hazards, and to make sure that they know how to protect themselves.
   Lead exposure in the workplace is a large subject, and this is just a very brief overview, but the problem is easily addressable if the employer takes and active approach in protecting worker safety. The consequences for ignoring the problem, however, can be quite severe, and can lead to extreme illness, or death.

- Jason

Have a safe Labor Day...

2011-09-05T12:04:00.000-05:00

...from all of us at Comprehensive Safety Resource. A holiday where, according to my seven-year-old, we celebrate how we got our freedom by taking breaks at work.

-Jason

Developing Emergency Action Plans

2011-08-15T08:19:00.000-05:00

   Emergencies, by definition, happen unexpectedly, and may take many forms. OSHA requires employers to review the workplace for likely sources of emergency, and develop controls to protect their employees.
   In general, an emergency can be thought of as any unplanned event that can cause injury or illness to employees, visitors, or the general public. Events that disrupt business, harm the company’s financial standing, or public image, may also be included. Weather-related emergencies, fire, and natural disaster are probably the most common hazards encountered, but chemical releases and terrorist activities may also need to be considered.
   I know I must sound like a broken record, but, of course, the first step is for the employer to evaluate the workplace for likely hazards. Many resources are available to assist, including information from government agencies, insurance carriers, and independent consultants. This step is crucial to developing a meaningful Emergency Action Plan. Wholesale coping of plans from the internet or other companies, will usually leave the employer with a plan that does not effectively address the realistic hazards they may face. For example if an employer is situated on the coast, and hurricane response plan may be needed, but it would be a waste of resources for a company located in the Midwest.
   After the hazards have been identified, then the employer can develop controls and response plans to safeguard employees and assets. OSHA requires that the plan include:
1) Emergency escape procedures and emergency escape route assignments;
2) Procedures to be followed by employees who remain to operate critical plant operations before they evacuate;
3) Procedures to account for all employees after emergency evacuation has been completed;
4) Rescue and medical duties for those employees who are to perform them;
5) The preferred means of reporting fires and other emergencies; and
6) Names or regular job titles of persons or departments who can be contacted for further information or explanation of duties under the plan.
   Both the General Industry and Construction regulations require that the plan be a written document that is available for employee review. There is an exception for employers with ten or fewer employees. In this case the plan may does not have to be written, and may be communicated to employees orally.
   After an effective plan is implemented, then employees must receive training on the contents of the plan that will affect their safety. This training should be a part of new-hire orientation so that employees are protected from the moment they begin their jobs. Employees must receive retraining if the plan changes, if they move to a different position with different hazards, and at least annually, thereafter.
   Protecting employees in the event of an emergency is a requirement under OSHA standards, and is the duty of the employer. With effective analysis of the potential hazards, and effective communication to the affected employees, the employer can maintain compliance with the standard, and protect employees, which is the ultimate goal.

-Jason

Heat-Related Disorders

2011-07-25T08:32:00.001-05:00

   I was hoping that in the couple of weeks since the last blog, that the weather would have cooled off, and heat stress would no longer be a relevant topic. That did not occur, and I didn’t seriously expect it to. We will, then, take a closer look at some of the specific ways that heat can affect employees on the job. Heat effects can range from fairly minor to life-threatening, and prevention of all of them is preferable to treating them. Recognizing that hazards exist in the workplace is the first step, and understanding a little more about the more dangerous conditions will help to identify the hazards.
   The effect most of us are the most familiar with is probably sunburn. Sunburn is mainly caused by ultraviolet radiation which is most intense between 10:00 AM and 4:00 PM. Workers who must be exposed to the sun during these hours should be encouraged to wear loose-fitting, but long-sleeved shirts and long pants to minimize the amount of bare skin exposed. Wide-brimmed hats will help reduce exposure to the face and ears. Topical sunscreens may also be used, although OSHA does not require the employer to furnish them {29 CFR 1910.132(h)(4)(iii)}. Most sunburns are fairly minor in nature, and may be treated with topical anesthetics, but more severe examples are possible, with blistering, and the subsequent risk of infection possible. Ultraviolet radiation is also strongly linked with chronic conditions such as skin cancer, cataracts, and macular degeneration, so do not ignore the hazards.
   Heat exhaustion occurs when the body’s cooling mechanisms begin to fail to cope with heat being generated and heat being absorbed. It can develop over a period of several days of working in hot environments without sufficient hydration, electrolyte replenishment, and rest. In high heat, it can also develop more rapidly. Symptoms of heart exhaustion include fatigue, heavy sweating, muscle cramps, dizziness, and fainting. Treatment should include moving an affected employee to a cool environment, giving cool beverages (no alcohol, and preferably no caffeine) and encouraging effective rest cycles. If heat exhaustion is not treated, it can become more severe and lead to heat stroke, so take the warning signs seriously.
   Heat stroke occurs when cooling mechanisms break down, and fail to regulate body temperature. The body’s core temperature begins to rise, and in extreme cases, may reach 106 degrees within ten to fifteen minutes. Heat stroke is life-threatening, and should be treated as a medical emergency (as in, call 911!) Death or permanent disability is possible. Symptoms of heat stroke may include hot, dry skin, with no sweating, severe headache, dizziness, and unconsciousness. While emergency responders are being summoned, try to cool the victim as quickly as possible. Spraying with water, immersing in a pool, or sponging water over the victim will all help. Do not try to give liquids to a victim of heat stroke.
   Heat-related disorders can be prevented in the workplace through the use of hazard recognition followed by effective employee training. Of course, follow-up is important to ensure that policies and procedures are being followed, and that they effectively control the hazard. Working in the heat is a requirement for many workers, but it can be done efficiently, and without undue risk, if handled responsibly.

-Jason

Heat Stress Prevention

2011-07-11T11:26:00.000-05:00

   With the forecast calling for another in a long line of over-100 degree days, and while listening to my air conditioner warm up for its daily struggle, I thought I would share a few thoughts on heat stress.
   Heat stress, of varying severity, occurs when the body becomes unable to effectively maintain its temperature, approximately 98.6 degrees Fahrenheit. Every person will react differently to working in the heat, and a wide variety of causal factors can come into play. A person’s age, general health, nutrition, and degree of acclimatization will make a difference, as will medications, smoking, and alcohol use. It is important to train employees to recognize the signs, symptoms, and treatment of heat-related disorders, so they will be better equipped to recognize them in themselves and co-workers.
   The body will react to heat by dilating blood vessels in order to move more blood to the skin, carrying heat away from the body. You cannot move cold in; you can only take heat away. Sweating is a mechanism that is also triggered in order to take advantage of the evaporation process in carrying away heat. If this process works correctly, the body temperature will remain stable. If the process cannot keep up with the amount of heat being generated or absorbed, the body will experience heat stress.
   The best way to manage heat stress is through prevention, and one of the best methods is to ensure proper hydration. Maintaining the fluid level in the body is crucial to the process of heat removal. If there is not enough blood to move heat to the skin surface, then the mechanism will break down, so maintaining fluid levels is critical. Thirst should not be relied upon in hot weather to judge water needs. Instead, employees should drink water regularly throughout the workday, every ten to twenty minutes. OSHA standards require that employers provide an adequate supply of drinking water in the workplace. If portable containers are used, then they must be clearly labeled, with a tight-fitting lid, equipped with a spigot, and used for no other purpose. In other words, employees may not keep their lunches, soft-drinks, whatever, inside the water container. OSHA also prohibits shared or common drinking cups. If disposable cups are used, then there must be a place to throw them away near the water cooler.
   Sports drinks (that have copyrighted names I won’t use here) may also be provided to employees, but the standard only requires water. In all cases, employees should be discouraged from drinking excessive quantities of caffeinated beverages. Soft drinks, coffee, tea, and energy drinks are diuretics, and may actually contribute to dehydration. Excessive alcohol use off-duty (and, on-duty, too, I suppose!) will also make it difficult for employees to stay hydrated on the job. If the body starts out depleted at the beginning of the day, then it is already struggling against a deficit, and will have a much harder time maintaining fluid levels.
   As employees work in hot conditions, they will begin to acclimatize, and their bodies will become more efficient at maintaining their core temperatures. Encouraging proper rest breaks, good hydration, and effective recovery off-duty will help to ensure that heat-related illnesses will be kept to a minimum. If you are not sure about your exposure, or the best prevention methods available to you, numerous resources exist to get the answers you need. The OSHA website has good information, and you can always contact a specialist in your area. Next time, we will look at the various forms of heat stress, and their treatment.

Jason

Permit-Required Confined Space Personnel

2011-07-05T10:23:00.000-05:00

   Last time, we took a look at confined spaces, and I wanted to explore it a little further in this post.
   Once the employer has determined that a space meets all the requirements in the OSHA standard for Permit-Required Confined Spaces, a few roles have to be filled if employees intend to enter the space. The Permit itself will also contain the names of the relevant employees. Training must be provided to designated employees prior to the entry.
   The first designated employee will be the Entrant. Entrants are the employees that will perform whatever task is required in the confined space. The authorized entrants are the only employees that may enter the confined space during normal (non-rescue) operations. They should be aware of the relevant hazards to the confined space, as well as the task they intend to perform. They must also stay in contact with the Attendant while they perform their tasks in the confined space. Communication methods will vary, depending on the exact nature of the space, but the main requirement is that the attendant must be able to effectively communicate emergency information back and forth with the entrants.
   Next on the list is the Attendant. The attendant is an employee stationed outside a permit-required confined space to convey information to and from the entrants. The attendant must also be aware of the exact nature of the hazards that may be present in the confined space. The attendant may not perform any task that interferes with his primary role as the attendant, but may perform ancillary tasks such as air-monitoring or passing tools back and forth to the entrants. The attendant has the main authority to evacuate the confined space if a threat is detected, so, again, effective communication is paramount. The attendant will also be in the best position to summon emergency help if it becomes necessary. The attendant must not enter the confined space for any reason, and may not leave the space unless properly relieved by another attendant.
   The last role that must be designated by the employer is that of the Entry Supervisor. The entry supervisor is the person responsible for coordinating the entry. This is the employee that will make sure that the permit is properly filled-out, that attendant and entrants are designated, and assume responsibility for ensuring that procedures related to the entry are followed. The entry supervisor’s duties are mostly administrative in nature, and this employee may not be physically on the jobsite where the entry occurs. The attendant and the entry supervisor might even be designated as the same person. The entry supervisor, like the attendant may not enter the confined space, although either may perform non-entry rescue.
   Through effective hazard recognition and reduction techniques, entry into permit-required confined spaces may be made safely and efficiently. Training and detailed programs and procedures are also required both for regulatory compliance, and employee safety. Employers who demonstrate dedication to these practices benefit from reduced injuries and related costs.

-Jason

Confined Space Training

2011-05-23T08:33:00.000-05:00

   One of the more common training types our company has been asked to perform over the last year or so, has been Confined Space Training. Requests come from very diverse sources; from an oil refinery in the Bahamas, to a slaughterhouse outside of Amarillo, TX. (I’ll leave you to guess which of those I taught personally, and which I didn’t!) The one thing they all have in common, is the fact that they recognized the need for confined space training, and understood that OSHA requires employers to provide relevant training to employees exposed to hazards on the job.
   The first part of the process is to determine if employees will be exposed to confined spaces on the job. Even if employees will not actually enter the confined spaces onsite, awareness training regarding the hazards may still be needed. Under OSHA guidelines, a confined space:
“(1) Is large enough and so configured that an employee can bodily enter and perform assigned work; and
(2) Has limited or restricted means for entry or exit (for example, tanks, vessels, silos, storage bins, hoppers, vaults, and pits are spaces that may have limited means of entry.); and
(3) Is not designed for continuous employee occupancy.” - 29 CFR 1910.146(b)
   A wide range of spaces may fit this description on a given jobsite, so it is important for each employer to assess the worksite to identify these confined spaces. Then next step is to determine if any of the confined spaces qualify as ‘Permit- Required Confined Spaces.’ Basically, if the confined space contains, or has the potential to contain, some other serious hazard (such as bad air, engulfment hazards, etc.) then it becomes a Permit space. You can consult OSHA’s 1910.146 standard for further guidance, or engage a safety consultant to help audit your particular jobsite and needs.
   Either way, once the types of confined spaces have been identified, employers must provide training to employees to make them aware of potential hazards on the jobsite. The training should be relevant to the jobsite, and specific enough to address the controls and procedures that will be used on the jobsite. The type of rescue to be used will also play a key role in the extent of the training, because employers wishing to maintain their own onsite rescue teams must also train those teams in the proper use of additional equipment as well as provide practical exercises annually to retain proficiency.
   Confined Spaces can be deadly. About 65% of fatalities in confined spaces occur because of bad air, and of those incidents, almost 100% have no air monitoring equipment or powered ventilation. Approximately 60% of deaths in confined spaces are would-be rescuers who lack the proper training to effectively assist a coworker, and about 29% of fatalities are supervisors. All of these statistics point to one thing: a lack of awareness of the hazards of confined spaces that could be mitigated through proper assessment of the workplace, and effective training of employees. Both easily addressed with the resources available to employers.
   Stay tuned, and we will look at Permit-Required Spaces more closely in the future.
-Jason

Comprehensive Safety Resource is on Facebook

2011-05-06T16:56:00.000-05:00

You can follow Comprehensive Safety Resource on Facebook, HERE.

-Jason

Hazard Communication and Chemical Safety

2011-05-02T09:34:00.000-05:00

The Hazard Communication Standards, also known as the ‘Right-to Know’ standards are in place to ensure that workers have access to the information they need to safely work with chemicals in the workplace. Prior to implementation of the Hazcom standards, workers in America did not always have complete information about the chemicals around them, and as a result, many got sick, and many died from exposure to hazardous substances on the job. OSHA’s 1910.1200 addresses this issue.
Exposure to chemicals in the workplace can have greatly varied effects, depending on several variables, including relative toxicity, concentration of the chemical, time in contact, and route of entry. Personal factors such as age, general health, nutrition, and previous exposure can all take a role. Effects of chemicals be acute or chronic. In acute exposure, the effects of a chemical are noted immediately after exposure. Consider flooding a room with ammonia gas: people in the room would notice immediately, and begin coughing, experiencing burning in the eyes, and other immediate effects. Chronic effects are long-term effects that are not noted until months or years after the exposure. Amphibole asbestos exposure, for example, would produce no immediate effects in the body, and it would only be after years that the effects would begin to show.
One of the key aspects of the program, then, is that employers must furnish information about potential chemical hazards to employees, and this is done in several important ways. The first one is assessment of the hazards. Employers must audit the workplace in order to note what chemicals are in use, and what types of protections are required for employees. Then, the employer must communicate the hazards and the control methods to employees in training classes held on an annual basis. There are many resources available to help employers evaluate their workplace and determine effective hazard controls; OSHA, chemical manufacturers, chemical labels, trade magazines, safety consultants, and material safety data sheets can all provide valuable insight.
Material safety data sheets (MSDS) are informational documents provided by the chemical manufacturer or importer that describe the chemical’s physical characteristics, fire/explosion data, and health effects, among other things. Employers must catalog an MSDS for all chemicals in the workplace, (with a few exceptions) and make the MSDS’s available to employees at all times. The MSDS book must also be reviewed annually to ensure that it remains current, and that all chemicals in the workplace have a corresponding sheet.
Chemical safety in the workplace is an important part of any overall safety program. The elements of Hazcom are easy to implement, and with proper practices and quality training, incidents involving chemicals can be lessened, and injuries and illnesses can be greatly reduced.

-Jason

Managing OSHA Inspections

2011-03-14T11:14:00.000-05:00

Employers of every size and type must comply with the regulations of the Occupational Safety and Health Act (OSHA). While some of the provisions of the Act may seem burdensome, worker safety should be the highest priority, so it is in your best interests to comply as fully as possible with all applicable OSHA standards.

No matter how careful you are, there is always a chance that an OSHA official will conduct an inspection of the facility or jobsite. The following steps offer a guideline for what actions you should take when an inspection is made:

1. Review the Compliance Officer’s (CO's) credentials and determine the reason for the inspection, and whether or not you wish to allow it. Calling 1 (800) 321-OSHA will enable you to verify the inspector’s information.

2. Contact Comprehensive Safety Resource toll-free at (855) 215- 2736 to speak to one of our experienced occupational safety consultants regarding your situation.

3. Determine the CO's intended scope for the inspection, including: records to be reviewed, areas to be examined, tests to be conducted, and employees to be interviewed. Resolve any objections you have before continuing the inspection.

4. A manager or experienced company official should accompany the inspector at all times, especially during the walk-around phase of the inspection. It is beneficial to have the safety director or a safety consultant present, as well. Ensure that only the agreed upon areas are examined. Make note of all items reviewed by the inspector and any comments he or she makes.

5. If the CO points out a potential violation, record the precise circumstances of the condition, including the length of time the condition existed, names of exposed employees, potential for injury, and any facts ignored by the CO. When possible, make immediate corrections to the hazards and make note of the corrections, as well as documenting the abated area with a photograph. Always demonstrate a good faith effort to protect employees’ safety and health.

6. If possible, duplicate any photos and/or tests made by the CO. At a minimum, record the procedures and details used by the CO.

7. The Closing Conference will be used to discuss preliminary findings. This is the easiest time to correct misunderstandings.

INSPECTION DO’s

Tell the Truth

1 Promptly provide statutorily required documents/records

2 Take notes on everything the inspector says or examines

3 Take measurements and make drawings, or photograph them (if OSHA does)

4 Keep a record of employee interviews

5 Ask the inspector to explain perceived violations and look up applicable standard

INSPECTION DON’T’S

1 LIE
2 Admit knowledge of violations
3 Tell workers not to talk to OSHA
4 Agree that a violation exists
5 Provide non-statutorily required documents
6 Guess or speculate

WHEN THE CITATIONS ARRIVE

1. Read them carefully. Look for the assigned abatement dates. If you plan to contest, do it now.
2. Post the citations at or near each worksite involved for a minimum of three days or until the citations are abated.
3. Abate all citations within the prescribed period.
4. Address each citation formally in a response letter due to OSHA no later than the last assigned abatement date. Mail it as soon as possible.
5. Get ready for the next inspection. An OSHA follow-up inspection is possible.

APPEALING CITATIONS

Once the inspection is completed, OSHA has six months to issue citations, although they are typically issued much sooner. If citations are made, you will have 15 working days - beginning the day you receive the citations - to file a Notice of Contest appealing the citations. The Notice should be filed with Area Director of your local OSHA office. If there is any possibility that you may contest the citations, you should file the Notice. Failure to file the Notice in a timely fashion may result in losing any right to contest the citations. Contact Comprehensive Safety Resource, L.P. for assistance in appealing your citation. If you decide not to appeal, the Notice can be dropped without penalty prior to the hearing.

-Jason

Preparing for OSHA Inspections

2011-02-21T09:19:00.000-06:00

The Occupational Safety and Health Administration (OSHA) is tasked with ensuring safety for workers in the United States. It is in your best interests to comply as fully as possible with all applicable OSHA standards. By implementing a preventative occupational safety and health program we achieve a number of valuable results.

By taking steps to reduce the incidence of employee injuries and illnesses, employers show employees that they care for their welfare. If properly communicated to employees, a good program can lead to increased loyalty, job satisfaction and productivity and to decreased turnover.

To secure a safe work place and fight rising costs associated with injuries ad illnesses, your defense is a good offense. By instituting a comprehensive safety program and by preparing yourselves in the event that an OSHA inspection does occur, you can strengthen your business both financially and productively.

It is helpful to know some of the common forms of documentation OSHA requests during inspections so that they can be prepared ahead of time for maximum benefit and compliance. Consider enlisting outside help if any of these areas are deficient a your workplace.

1. Safety Program – A written safety program is the cornerstone to any effective workplace safety plan. The program should be specific to the employer, and address hazards that are particular to the worksite. The program should be reviewed periodically to be sure that it addresses hazards in the workplace in a meaningful way. There are resources available to help prepare an effective document, so you should resist the urge to adopt a program from another company, or to copy a program from the internet.

2. Recordkeeping – Each employer with ten or more employees must keep records regarding workplace injuries and illnesses. These are commonly referred to by their form number – the 300 Logs. Employers must keep logs up to date with any injuries and illnesses that meet the criteria set forth in the standard. At the end of each calendar year, the information must be compiled into the Summary (300A) Log and posted conspicuously in February, March, and April. Summary logs must be posted at each jobsite that lasts longer than one year. The logs must also be archived for at least five years.

3. Training – It is incumbent on the employer to provide training to employees regarding the safe performance of their duties. Although documentation for most types of training is not strictly required by the standards, it is a very good practice to retain documentation for any training that employees receive, including dates, topics, and attendees. Be especially aware of the requirements for specialized training like, powered industrial trucks, crane certifications, respirator use, hearing protection, etc. If you are not sure if your workplace requires specialized training, contact Comprehensive Safety Resource to schedule an audit of your jobsite.

4. Hazard Communication – Each employer must keep copies of Material Safety Data Sheets for most chemicals in use in the workplace available to employees. It is important that MSDS’s are reviewed at least annually to ensure that they are up to date and accurate.

No matter how careful we are, there is always a chance that an OSHA official will conduct an inspection of the facility or jobsite. OSHA may carry out an inspection for any of the following five reasons, in order of priority:

1. Imminent Danger – If there is a report of a condition with a high probability of causing death or serious physical harm, an inspection will be initiated.

2. A catastrophe or fatality - If an employment-related fatality or an accident that results in the hospitalization of three or more of your employees occurs, you must report it to OSHA within 8 hours. In this case, OSHA is required to make an inspection.

3. An employee complaint - Generally, OSHA will limit its inspection to the condition(s) alleged in the complaint. At your request, OSHA must provide you with a copy of this complaint, although the employee's name will not be included.

4. Targeted Industry Program investigation - Each year, OSHA selects several industries with high rates of injuries and targets them for increased levels of inspections.

5. General Inspections - Area OSHA offices randomly inspect employers within their jurisdictions.

By preparing the required documentation and training employees in the safe execution of their tasks, you can elevate safety, reduce injury, and increase the chance of a favorable outcome to an OSHA inspection.

Jason

Untangling Extension Cord Usage

2011-02-02T08:43:00.000-06:00

Extension cords are a common sight on both Construction and General Industry jobsites. When used properly, they provide convenience and flexibility. Improperly used, they pose serious health and physical hazards to the work.

When using extension cords, the first step is to ensure that the cord chosen is appropriate for the task. Both the General Industry and the Construction standards require that only ‘hard service’ or ‘junior hard-service’ cords may be used on the jobsite. In practical terms, this means the cord type should be SO or SJ. The type will be embossed on the outside cable jacket, so make sure it contains those letters. Flat-style extension cords, like the ones commonly used to connect decorative, holiday lighting are not approved for use at work.

The next step is to make sure that the cord has the appropriate current-carrying capacity to safely connect the load. Check the tool or appliance for its amperage-rating, then select a cord that has conductors large enough for the application. Consult the manufacturer, or consult with a qualified person if there is any question about the appropriate size.

The cord must be inspected before use to determine that it is safe to put in operation. Some examples of inspection points are the strain relief, making sure the prongs are in good condition, and checking the cable jacket for any burns, cuts, or abrasions that could affect the integrity of the insulation. Employees must receive training from the employer regarding the safe use of extension cords on the jobsite, and regarding the inspection process that is required. It is never a bad idea to document the inspections. If the cord is in any way deficient, then it must be removed from service and replaced or repaired by a qualified worker.

Lastly, the cord must be used in a safe manner. This includes making sure the cord is not damaged while in use. Employers should take care to see that cords are not subject to physical hazards on the jobsite such as sharp corners, having doors and windows closed on them, and heat damage from welding, cutting, or brazing operations on the jobsite. Cords should also be routed in such a way as to reduce the trip hazard they can cause. When the work is finished, the cord should be rolled up and stored safely.

Cords may not be used as a substitute for the fixed wiring of a structure, so make sure that extension cords are only used in a temporary fashion. Choose the right cord for the task, inspect them before use, and repair or replace any damaged cords. These steps will help reduce shock and physical hazards associated with extension cord use on the jobsite.

-Jason

Deconstructing OSHA Crane Standards, Pt. 3 1926.1400

2011-01-17T09:39:00.001-06:00

A few weeks ago, I posted a couple of articles about the Construction Crane Standards that went into effect in November of 2010. I would like to address one more important change that is included in the update; the new requirements for working around power lines.

The basic requirement before the change was that workers had to stay at least ten feet away from energized overhead electrical lines. This proved over the years to not always be sufficient, so the new standard has some different requirements. First, the competent person has to evaluate the jobsite and determine if any part of the equipment, load line, or load can come within 20 feet of a power line. If so, then there are three options for controlling the hazard that may be exercised.

Option one is the simplest where practical, and provides the most protection. The employer simply confirms with the utility owner or operator that the conductors have been deenergized, and visibly grounded at the jobsite. Requirements for uninterrupted electricity may preclude this solution.

Option two is to ensure that no part of the assembly comes within 20 feet of the line. This will also require ‘encroachment prevention procedures’ outlined in the standard. These procedures will require a planning meeting with all employees on the jobsite, nonconductive tag lines, and at least one other prevention measure. The additional measure may include spotters, proximity alarms, or elevated warning lines. Consult the OSHA Standards for clarification, and a Safety Consultant or industry organization if you still have questions.

Option three allows the employer to determine the voltage the power lines are operating at, then consult a table published in the standard to determine the appropriate clearance to maintain from the equipment. Voltages over 350kV will require more than 20 feet of clearance. Option three also requires the additional encroachment prevention procedures as option two.

The standard also requires training for all employees that may be exposed to these hazards, and like most of the training required by OSHA, it must be provided by the employer at no charge, and before the work actually commences. Documentation of the training is a good idea, too.

Ensuring that equipment stays clear of energized power lines on any jobsite should, obviously, be a priority, and complying with the new requirements in the OSHA Construction Crane Standard is one more tool employers have to protect worker safety.

-Jason

Happy New Year!

2010-12-31T12:58:00.000-06:00

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

Training Options for Safety

2010-12-20T07:57:00.000-06:00

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

Deconstructing OSHA Crane Standards, Pt. 2 1926.1400

2010-11-29T09:44:00.000-06:00

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

Deconstructing Construction Crane Standards, Pt. 1

2010-11-08T09:03:00.001-06:00

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

Lock It Down!

2010-10-18T09:20:00.000-05:00

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

Is Your Forklift Program Lifting Its Own Weight?

2010-10-04T10:03:00.000-05:00

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

Are You Seeing Proper Protection in Your Workplace?

2010-09-13T10:04:00.000-05:00

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

CHANGES TO OSHA TRAINING REQUIREMENTS MEAN MORE DAYS IN THE CLASSROOM

2010-08-26T06:52:00.000-05:00

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.

Maritime Advisory Meeting to Focus on Shipyard Worker Hazards

2010-07-10T16:50:00.000-05:00

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

2010-07-10T12:21:00.000-05:00

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.