From the OSHA announcement:

Based on the most recent investigation, OSHA has issued 15 willful citations with proposed penalties totaling $1,050,000, alleging that 15 pieces of electrical equipment were unsafe to use in the tank wash area due to the presence of flammable and combustible vapors. Two additional willful citations with proposed penalties totaling $125,000 have been issued. One alleges that CES failed to ventilate tanks in which employees were working, exposing the workers to toxic atmospheric hazards. The other alleges that CES stored flammable and reactive chemicals together, which posed fire and explosion hazards.

In addition, OSHA has issued 54 serious violations with proposed penalties totaling $302,500. These include allegations that CES failed to implement all aspects of the process safety management standard; provide proper respiratory protection, confined space rescue equipment and adequate fall protection; properly install and maintain boiler equipment; implement an emergency response plan, and adequate energy control procedures; train powered industrial truck operators; guard and to anchor machinery adequately; store compressed gas cylinders safely; and label hazardous chemicals.

It’s astonishing to me that a series of incidents occurred within a short time-frame without the company taking the steps to prevent them after the first incident. It strikes me of either willful arrogance towards, or complete ignorance of, OSHA standards. I can see a company makes a mistake that causes an incident that results in a fatality, but I can’t understand how a complete review of safety procedures and standards as well as thorough inspections of all equipment used in their most hazardous areas doesn’t take place after the FIRST event. With all the confined space testing and safety equipment available there really isn’t an excuse for workers not to be protected in a hazardous atmosphere.  The cost of implementing a safety procedure plan, as well as providing the correct equipment would be much less than the cost of the lives lost, the families destroyed, the downtime, the fines, and the lawsuits that will follow.

Take note management.

A clean room presents a particular type of spill control issue that also ties in to the need to protect the environment in question from external contaminants.  Quite simply, the floor of a clean room, whether the room is used to put together computer components or  perform lab work with biological organisms or chemicals needs to be protected in order to maintain the integrity of the workspace.  Since the possibility of floor contamination is double-edged – it can come from above (spills from the workbench) or from outside (tracked in dirt and foreign substances from elsewhere), a solution that can control both of these potential vectors is required.

Tacky mats offer a unique opportunity to meet each of these challenges head-on.  These simple mats resemble regular floor mats, and are meant to be installed underfoot in areas where workers are most likely to stand.  This can include on the interior side of a door way or underneath each individual work station throughout a room.  Tacky mats such as those manufactured by CleanTeam are composed of a series of special layers which use an adhesive to pry any foreign substances from the footwear of workers.  All that has to be done is for an employee to stand on the mat, and then the simple act of lifting the feet does the rest.  These mats can also can catch any fallen substances that may have escaped the counter top, preventing them from being tracked throughout the room.

These mats are absorbent, and once the top layer has taken in as much contamination as it can hold, it can be peeled back to reveal a fresh layer underneath.  Available in a range of different sizes, the mats also come in 30 or 60 layer versions.

For taking care of spills on top of a work surface, clean room wipes are an excellent option.  Unlike standard paper towels or rags, clean room wipes are sterilized and offer low lint and anti-static properties in order to interact as safely as possible with electronics and chemical / biological materials.  Some wipes, such as the Lymtech Validated series are guaranteed to be sterile through the application of gamma radiation in order to take out even the toughest of microorganisms that could be lurking between the sheets of lesser wipes.  Available from a variety of different manufacturers, such as Lymtech and Kimberly Clark, there are clean room wipes custom suited to a variety of different lab applications.

Modern safety equipment allows risk managers to avoid this type of shadow from hanging over their facility through the use of can disposal systems.  These self-contained units not only depressurize aerosol cans, but they also allow for the safe and concentrated storage of their contents.  Can disposal devices such as Justrite’s Aerosolv line mount to any 55 gallon drum and require no external power source.  Using a simple hand press, the device pierces any 200 series, 300 series or 6 ounce aerosol can and then captures both the remaining liquid inside as well as any hydrocarbons or foul odors that might be present.  The latter are filtered through activated carbon in order to cleanse the can’s contents completely.

Once the can is empty, it can be recycled in the same way as any other metal.  Not only does this device reduce the risk of an explosion or fire at a facility, but it also encourages a more eco-conscious mindset thanks to the ability to transform waste into recyclable material.  In fact, Justrite claims that 100 punctured cans represents 25 lbs of metal that can be used again, and 10 cubic feet of waste that won’t be taking up space in a landfill.

A further benefit of this type of aerosol disposal system is that it allows for the mitigation of chemical hazards by transforming the storage medium for aerosolized liquids from weak and thin canister to sturdy 55 gallon drums.  A single drum can accept the contents of as many as 4,000 emptied aerosol cans.  Depending on how heavy your can usage is, this can radically reduce the amount of room required to store this type of hazardous waste as well as increase the security of that storage.

When disposing of aerosolized chemicals in this fashion, it’s important to keep in mind what types of substances you will be mixing together in the new storage drum.  Your safety policy should include strict guidelines regarding the segregation of potentially reactive chemicals.  Workers should be properly trained in how to identify and manage different aerosols in order to prevent the creation of a potentially dangerous chemical soup.

Making a presentation at the workshop was new OSHA Assistant Secretary David Michaels, who outlined a series of five issues that the Administration intends to follow through on when handling the safety questions surrounding green jobs.  Michaels made the point that while ecologically-conscious jobs are generally seen by the public as safer than traditional industrial positions, whether due to the use of fewer caustic chemicals or a lower degree of mechanization, the reality is often different.  Green building techniques and renovations still expose workers to construction industry hazards, for example, and wind and solar power generation pose potential dangers through high voltage currents and large scale equipment use.

The Assistant Secretary proposed to bring OSHA standards and worker safety more in line with the present and future of green industry in a number of different ways that he described as ‘Green Reform Principles.’  The first of these is to encourage employers and employees to work together when assessing workplace hazards and coming up with solutions and protections.  Not only would this allow workers to become more engaged in a decision-making process that directly impacts their well-being, but it also offers managers a real-world viewpoint on the efficacy of certain safety interventions.

Next, OSHA plans to update their chemical safety standards, an initiative which is already underway through planned changes to the Hazard Communication Standards.  Michaels stated that OSHA’s current chemical safety platform is rooted in science that is almost five decades old, and that through collaboration with the European Community’s safety officials and re-thinking OSHA’s somewhat passive approach to the dangers posed by chemicals, the Administration may be able to identify thousands of new substances which pose a threat to worker health.

The third Green Reform Principle is somewhat vague, in that it asks whether it might be better to completely redesign the workflow and standards of specific industries instead of updating older methodologies.  Michaels did not offer much in the way of explanation as to what exactly this could mean to established businesses, and it will most likely stand out as the most controversial of the five Principles in the coming months.  Principle four marks a commitment to more rapid and better informed rulemaking, while the fifth and final Principle once again echoed OSHA concerns about giving workers a more powerful role in workplace safety decisions.

While these five points on OSHA’s future role in green industry are commendable, the Administration will need to fully flesh them out before their potential impact can be properly assessed.  The generalized way that the Principles were described, especially towards the end of the list, also indicates that perhaps they will be applied across more than just those businesses who claim to be operating in an environmentally-friendly sector of the economy.

Those who put their health on the line to save the lives of others can find themselves dealing with accident victims who have been stricken as a result of contamination with hazardous substances.  Clearly, protecting the safety of emergency medical personnel and rescue workers as they try to do their jobs is important enough that risk managers responsible for EMS (emergency medical services) teams need to develop clear policies for handling these types of situations.

The Occupational Safety and Health Administration (OSHA) has recently released a document entitled “Best Practices for Protecting EMS Responders During Treatment and Transport of Victims of Hazardous Substance Releases.”  The aim is to provide guidance to risk managers interested in a comprehensive safety strategy for dealing with these types of difficult health services scenarios.

Much of the guide focuses on concrete measures that can be taken to ensure that EMS personnel are not placing themselves at risk when performing medical interventions on exposed victims.  A significant component of the OSHA document focuses on training workers to be able to recognize hazardous situations as quickly as possible, in order to lessen their chances of dangerous exposure.  Situational awareness is a key tenet of keeping medical personnel safe.  Furthering this theme, OSHA describes several different pieces of equipment which can be used to detect the presence of otherwise odorless, tasteless and invisible contaminants which could be present at the scene of an emergency.  These include radiation, chemical agents and biological hazards and toxic street drugs such as methamphetamine, which can be found in labs in concentrations high enough to cause serious injury.

The document also describes the types of personal protective equipment (PPE) that can be helpful in reducing the dangers posed by hazardous substances, and on training emergency workers in how to properly use this type of gear.  PPE related to hazardous materials can include anything from gloves and respiratory masks to full on containment suits with respirators, depending upon the severity of the incident being responded to.  PPE becomes especially relevant when making contact with victims, as it is possible for certain types of contaminants to actually permeate the bodies of those who require medical treatment.

The latter can create a dangerous situation when transporting a patient, as they may spread the hazardous substance in question simply by touch or even exhaling.  Not only do EMS workers need to be able to protect themselves from this possibility, but those present in hospital emergency rooms must also be safeguarded against accidental exposure once contaminated patients have been admitted into a ward.  A clear policy for handling these types of accidents is a critical component of any EMS risk management portfolio.

This is one of the reasons why the Occupational Safety and Health Administration (OSHA) publishes their yearly list of the 10 most often-cited safety violations from the past 12 months.  The list represents the sections of federal workplace safety code that have been the focus of the greatest number of citations on the part of OSHA inspectors.

Naturally, the specific violations listed by OSHA tend to gather around industries which are on average more dangerous towards worker health than others.  In the top five are scaffolding violations and fall protection violations (construction industry), citations for respiratory protection (chemical and mechanical industries), and lockout/tagout citations (heavy industry, mechanical industries).  However, sitting at number three on the list is hazard communication, a section of the standard which applies to every single workplace across the country.  The fact that over the past year there were 6,378 violations of the hazard communication sections of the safety code indicates that risk managers and employers are still not doing all that they can when it comes to training and preparing their workers for the dangers that are present on a job site.

Also alarming from OSHA’s perspective was the revelation that 81 percent of the citations stemmed from willful violations or violations of a serious nature.  This has lead the agency to draw the conclusion that many of the accidents that occur in workplaces across the country are completely preventable, and are often the result of companies attempting to save a few dollars by gambling with the health of their employees.

The full list of the top 10 OSHA standard violations is as follows:

1. Scaffolding, General – 9,093 violations
2. Fall Protection – 6,771 violations
3. Hazard Communication – 6,378 violations
4. Respiratory Protection – 3,803 violations
5. Lockout/Tagout – 3,321 violations
6. Electrical, Wiring – 3,079 violations
7. Ladders – 3,072 violations
8. Powered Industrial Trucks – 2,993 violations
9. Electrical, General – 2,556 violations
10. Machine Guarding – 2,364 violations

The list of the standards cited most often by OSHA break down along similar lines:

1. Scaffolding, general requirements, construction (29 CFR 1926.451)
2. Fall protection, construction (29 CFR 1926.501)
3. Hazard communication standard, general industry (29 CFR 1910.1200)
4. Respiratory protection, general industry (29 CFR 1910.134)
5. Control of hazardous energy (lockout/tagout), general industry
6. Ladders, construction (29 CFR 1926.1053)
7. Powered industrial trucks, general industry (29 CFR 1910.178)
8. Electrical, wiring methods, components and equipment, general industry (29 CFR 1910.305)
9. Electrical systems design, general requirements, general industry (29 CFR 1910.303)
10. Fall protection, training requirements (29 CFR 1926.503)

Tight spaces can threaten the health of workers in a number of ways.  The first is the lack of oxygen that is often a feature of enclosed areas.  While the airways leading into and out of the space might not be completely sealed off, this sometimes only provides the illusion that airflow is sufficient to replenish the area with oxygen.  Once inside the structure, it can be difficult for workers to detect the effects of oxygen deprivation until it is too late.  These often include a disconnected feeling that makes it difficult to concentrate on even simple tasks, as well as short term memory issues and eventually a loss of consciousness.

Enclosed spaces can also harm workers thanks to the residues or gasses that have been left behind by the prior contents of the space.  This is particularly common in the shipping industry, where welders are usually asked to make repairs inside the empty hulls of tankers which have been host to crude oil or other types of chemicals.  Even though the upper areas of the tank might be clear of any toxic gases, the heavy nature of some of these vapors can often concentrate towards the bottom of a tank where they can overcome a worker far quicker than the oxygen starvation listed above.

There are several methods that can be used in order to make this type of work as safe as possible.  The first is to never go into an unknown enclosed area without proper breathing apparatus.  If there has been no recent air quality monitoring or data available regarding the space, it must be assumed that they are potentially dangerous.  In fact, the Occupational Safety and Health Administration (OSHA) requires that enclosed spaces be tested for oxygen content and the presence of any potentially harmful gases before workers are allowed to enter.  Supplied air respirators from Allegro and 3-M can provide a steady supply of oxygen in a situation where conditions are borderline or too risky to work based on atmospheric oxygen content.

It also goes without saying that employees should never enter an enclosed space, whether to work or test the air quality, without first notifying a third party as to their intentions.  Having someone on the outside who is aware of how long you have been gone and where you are located can often be the difference between life and death in an oxygen-poor environment.  If possible, regular contact with outside personnel should be maintained, in order to provide external monitoring of a worker’s reaction times and responses for evidence of potential oxygen deprivation

There are some basic safety preparedness steps that can be taken across the board on a university campus that can help even general staff deal with a large number of the potential incidents that could occur within a student body.  Chief amongst these is the distribution of adequate and up to date first aid supplies.  First aid can often mean the difference between serious injury and a minor incident, especially if responders are able to intervene effectively with the correct tools for the job.  In fact, United States Department of Labor regulations specifically state that first aid is required at any facility in the United States – universities being no exception.

University first aid kits and other first aid equipment can be broken down based on a number of factors.  First, it must be determined how large of a kit is required for a given situation.  In areas where crowds are common, such as a football field, gymnasium or even an auditorium, the potential for a greater number of injuries as the result of an accident should be addressed with a bulk first aid kit. For those scenarios such as labs or classrooms where the potential number of accident victims is smaller, then individual or 10 person kits might be sufficient.

Keep in mind that if a university lab is working with caustic chemicals, beyond the requirement for a first aid kit there is also the need to install an eyewash station – or at the very least, make portable eyewash equipment available.  More advanced university labs are also likely to need clean room supplies in order to protect both the health of students and staff as well as ensure the purity of experiment results through the prevention of accidental environmental contamination.  Depending upon the extent of the work being performed, clean rooms could require tacky mats, special disinfecting wipes or even body suits with supplied air respirators.  At a minimum, a biosecurity kit which can rapidly clean and disinfect a person’s body should they be exposed to a harmful contaminant must be within arm’s reach of any potentially hazardous experiment or activity.

Universities, like any corporation, are responsible for the safety of their employees.  Unlike most companies, they are also charged with protecting the health of thousands of students.  A cohesive campus safety policy must take into account all of the activities that take place inside its borders on a daily basis.

The storage of potentially hazardous materials falls under this type of risk mitigation.  Keeping workers safe from the dangers posed by certain types of chemicals, gases or other items means more than just restricting access.  It involves understanding the nature of the materials themselves, the situations in which they could possibly become harmful, and the regulatory statues that have been set up to reduce the chances of an accident occurring.

The Occupational Safety and Health Administration has recently published a Direct Final Rule regarding the acetylene industry that addresses outdated guidelines surrounding the use, storage and transportation of cylinders containing this volatile gas.  With an eye towards becoming law effective November 2009, the revised guidelines are meant to increase the safety of workers who regularly come into contact with acetylene.

The new rules make it clear that risk managers are expected to have their workplaces conform to the Compressed Gas Association Pamphlet G-1-2003, Acetylene.   A key proviso of this pamphlet changes the conditions in which acetylene cylinders can be stored.  Previously, it was not uncommon for cylinders to be transported from site to site in enclosed spaces, be they car trunks, sealed trucks or perhaps even in crates.  Facilities were also allowed to store acetylene cylinders in unventilated lockers, closets, drawers or small storage rooms.  These habits dated back to 1966, when acetylene storage guidelines were last updated.

This latter practice is no longer allowed, due to the explosion and fire danger posed by possible gas buildup from leaking cylinders.  In order to prevent this type of accident from occurring, a new requirement that acetylene cylinders be stored in well-ventilated lockers or cabinets has been put into place.  Examples of the acceptable type of cylinder storage units include Justrite aluminum cylinder lockers, which feature an open grille design and numerous configurations to allow for horizontal, vertical or combined storage.  The aluminum construction also makes the lockers resistant to corrosion, making them suitable for use on outdoor sites where theft of cylinders is a concern.

Fire-resistant safety cabinets are no longer appropriate for acetylene cylinder storage.  Although these units may seem to provide protection against possible explosion, their air-tight confines can actually contribute towards the buildup of dangerous escaped gas pressures, increasing risks despite their sturdy construction.  The volatility and instability of acetylene gas means that no chances should be taken during storage.  The updated OSHA guidelines should improve worker safety across a wide variety of industries, in particular those where large-scale welding is a common occurrence.

Musculoskeletal injuries associated with compressed gas cylinders have a number of sources – all of which are preventable with proper training and safety policies in the workplace.  Cylinders can weigh well over 60 lbs, which makes them particularly dangerous should they fall from their assigned storage shelves.  Unfortunately, workers are often tempted to catch a falling cylinder, especially if it has rolled off of a table or transportation cart.  This can result in broken bones, torn ligaments or worse, and employees should be taught to never intervene in the event of a falling cylinder.  Likewise, storage and transportation of compressed natural gas canisters should be done so that they are in an upright position and secured so that they cannot move in any direction.  This reduces the chances that they will roll or tumble if jostled.

The pressures contained within a CG canister can also pose a threat if the cylinders in question are not treated with caution while being handled.  The cylinder cap can often seem like a useful handhold during lifting, but as they are not designed to handle this type of stress, often times they snap off.  This can cause the cap to launch into the face of the worker moving the canister, often at speeds fast enough to cause serious injury.  The potential discharge of toxic or otherwise dangerous gases associated with cap loss creates a secondary health threat in this situation.

Other scenarios where gas pressure becomes a significant issue include moving cylinders from one temperature extreme to another – common during wintertime – as well as using heat to dislodge canisters which have become mired in snow or ice as a result of being stored outdoors.  Contents which are kept under pressure should never be exposed to any device which could cause internal temperatures to rise rapidly, especially in comparison with their external environment, as this could lead to an explosion and the possibility of the cylinder becoming a damaging projectile.

The strength of a steel cylinder is reassuring, but it can also make workers drop their guard during the handling or moving process.  Making assumptions about the safety compressed gases based on the containers they are held in is the type of attitude which can lead to serious injury.  Always make sure that caps are secure, valves are recent, and that containers are not riddled with dents or other signs of abuse that might indicate that replacement is necessary.  Treating CG canisters with the respect they deserve is the least dangerous course of action when handling these commonly found workplace hazards.