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.

Several hazardous materials – specifically, how they are handled in the workplace and how to control employee exposure to them – will fall under more intense scrutiny.  Crystalline silica, which is essentially the dust produced by a wide variety of different industrial, manufacturing and construction operations will be subject to a new rulemaking that will change current exposure limits.  It will also institute additional regulations concerning worker protections from exposure to the dust.  OSHA hopes to make their intentions known with a Notice of Proposed Rulemaking to be issued in July, 2010.

Two other substances will also be dealt with in the spring and fall of that same year.  In March, the metal beryllium will be the focus of a peer review its health effects and overall risk with regards to permissible exposure limits and worker protections.  The dust or fumes emitted by this metal can in some cases result in an immune disease that eventually brings forth a host of unpleasant and debilitating symptoms that may take as long as 30 years post-exposure to develop.  Then, in October diacetyl will take its turn undergoing the same analysis.  A food additive most commonly found in butter-flavored microwave popcorn, there have been several concerns regarding its possible respiratory impact on workers when inhaled over a long period of time.  Specifically, OSHA will examine a disease called bronchiolitis obliterans linked to the chemical.

Combustible dust, which has grabbed headlines over the past few years due to several spectacular and fatal explosions at a number of facilities in the United States, is set to gain its own standard from the Administration.  The process is already well underway, and the goal is for OSHA to gather what regulations they currently have on the books related to combustible dust hazards and combine them with additional research and information in order to complete a general standard and prevent future tragedies.  Crane and derrick safety will also see similarly sweeping standards changes in the summer of 2010 when a new final rule is issued.  In an industry where almost 100 lives are lost each year in workplace accidents, OSHA is working quickly to update safety regulations which were first implemented in 1971 and rarely altered since.

The final component of the Fall 2009 agenda addresses infectious diseases which have an airborne vector, otherwise known as the H1N1 initiative.  OSHA is looking to expand the epidemic response guidelines that were heavily publicized in August and September of 2009 through a Request for Information that will focus on how healthcare workers can better protect themselves from not just influenza but all other types of illness which can be easily transmitted through the air.  The formal Request will take place in March of next year, and it is hoped that the effort will be able to head off an increasingly large number of reported sick workers on the front lines of American’s healthcare industry.

After the H1N1 reports on ways to combat the virus, many healthcare organizations are realizing that it may be time to consider respirators.  Typically, healthcare organizations are known for using surgical masks.  Yet, respirators offer greater protection for staff and patients.  If you are considering respirators for staff within the healthcare industry, it is important to identify the differences that make respirators more effective than surgical masks.  The key differences are detailed below.

The Design

Surgical masks are designed to protect the wearer from large splatters, meaning fluids such as blood. Tiny splatters such as spittle from sneezes are not effectively contained by surgical masks. Since, surgical masks are not equipped with filters airborne particles are allowed to move from patient to wearer freely, and vice versa.   Respirators on the other hand are designed to protect the wearer from all splatter and airborne particles coming from the patient and the patient from the same coming from the wearer.

Ability to Combat Viruses

Unlike surgical masks, respirators have a built in filter, preventing airborne particles, such as viruses, or spittle from being inhaled or expelled by the wearer.  However, it is important to note that the effectiveness of a respirator depends on its standard. Although there are a few standards that are accepted by OSHA, the current industry standard for respirators is N-95.  These respirators are designed to filter out 95% of particles that attempt to enter the respirators’ filter.  Surgical masks are ill equipped to prevent the transmission of airborne particles.

Standards

Respirators are constantly being improved upon new standards emerge as new risks are uncovered.  So, unlike surgical masks, respirators will continually be able to combat the spread of new viruses.  Plus, OSHA regulations guide the design of respirators.  Letting you know that you are providing your staff with the best possible protection.

The Fit

The idea behind respirators is that they create an air tight seal, eliminating the wearer from breathing in or being exposed to any air before it passes through the filter.  Although surgical masks are tied tightly around the face, the tying of surgical masks do not foster an air tight seal.

Initially, healthcare organizations could argue the inexpensiveness of surgical masks, and the mass need within their facilities made surgical masks a more attractive option.  But, with disposable respirators, those points are no longer holding water.  Not to mention, the incorporation of durable materials and nose bridge designs, make choosing respirators a no-brainer.  The fact is respirators keep your staff safer, at a comparable price.

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

• In every task, wet methods, such as wet cutting, wet grinding, manual spraying, and freezing are considered the most effective in each area.  The idea is that by wetting dust; it becomes too heavy to achieve the airborne state that can cause life threatening injuries.
• Vacuum Dust Collection systems or VDCs were next on the list.  Although the jury is still out on this method.  The guide described two conflicting studies on VDC systems.  Still for certain task, such as using a handheld saw OSHA gave tips on what to look for in the a good VDC kit.
• Ventilation Booths were also mentioned, but not as emphasized as the other methods. As OSHA acknowledged that you would need to play around with the different elements of your booth to achieve maximum protection.
• It is unanimous, that using a fan as a primary method for controlling dust is ineffective method.  Although, it can be used as a supplement to another more primary.

OSHA also noted that simpler things, such as employee repositioning or using a smaller grinder wheel can aid in controlling dust.  The guide goes further to stress the importance of distinguishing the difference between visible dusts versus the respiratory dust; stating that visible dust should not be a gauge of how well silica and respiratory dust is being controlled.

Although specific tasks such as using handsaws, jackhammers, and similar tools were detailed, OSHA detailed the various common construction duties or “housekeeping,” activities could easily stir up dust at a worksite.  Please note that this is not a complete list, but dust can become airborne due to things such as:

• Dry sweeping
• Dumping bags of raw material
• Emptying vacuums
• Using blowers or compressed air for cleaning
• Driving over debris

The guide focused on controlling silica exposure by reducing the dust in a construction worksite.  Yet, OSHA acknowledged the fact that some employees and some jobs will require the use of respirators.  Employers need to be providing either half-piece or full-faced NIOSH approved respirators that are properly fit for specific employees; or, disposable respirators that are designed with an N, R. or P 95 filter.  On worksites where respirators are required or used, a written respiratory protection program should be implemented.

For more information the guide is available for print at the OSHA website, www.OSHA.gov

References:

Controlling Silica Exposures in Construction; http://www.osha.gov/Publications/3362silica-exposures.pdf; Accessed September 23, 2009.

There are several ways that working with grain can make for dangerous conditions, and the hazards are not limited to the agricultural sector.  Transportation and grain storage activities are also implicated in a significant portion of the accidents listed as occurring each year.  The leading causes of death related to grain handling are threefold: falls in silos, at storage facilities or while moving through grain containers themselves, suffocation as a result of sinking into containers of loose grain or being smothered by falling grain, and becoming entangled in the machinery that is used in grain processing.  Additional hazards faced by workers exposed to grain include fire and the risk of dust explosions.

Fortunately, there are simple steps that risk managers can take to reduce the chance that these tragedies will occur.  Preventing workers from walking through grain containers piled higher than their waists can help to reduce the chance of asphyxiation as the result of being pulled under by the effects of unstable bridging or the swirling action of a bottom-emptying container.  This also includes not allowing workers to enter into bins they may believe to be empty or bins which may feature a portion of piled and stuck grain.  The installation of railings and the clearing of staircases and ladders of any loose grain particles can have a positive effect on the rate of falls in the workplace, and the instigation of strict policies concerning machine servicing and use of guards over exposed machine components can reduce the chances of fatal entanglement.

When it comes to fires and explosions, all employees working at a grain storage or processing facility are required to be familiar with an emergency action plan which is specifically put together to prevent and handle any fire-related incidents that could occur.  The plan must also provide for dust management in order to prevent accumulation which could ignite in the confined spaces of the facility itself.

Employees should be also be educated as to the risks posed by modern silos which have been designed so as to limit the amount of oxygen which enters them.  If these silos are not sealed properly, or if seals have not been maintained, then their compromised airtight construction can lead to a situation where a fire can burn at a low level, unnoticed until a door is opened or additional oxygen is introduced in a rush.  The resulting explosion or fire can be quite severe.  If employees suspect that a silo is damaged, or that a silo’s contents may be smoldering, they should not attempt to access the silo or douse the blaze themselves.  Instead, they should await professional firefighters in order to prevent increasing oxygen flow to a potentially lethal level.

Evaluating the potential for these factors to come together in a workplace has to take into account not only typical business processes, but also any unexpected events which could introduce new factors into the mix.  Since there are 5 elements in the dust explosion formula, a work environment where at least three are present at any given time presents the risk that an accident on the site could add in the missing ingredients.  Consider the idea of a warehouse where barrels of dust-producing materials are kept.  While stored, the barrels themselves may present no particular danger.  However, should a shelving unit collapse, causing barrels to fall and split open, a considerable amount of hazardous dust could be thrown into the air where it could easily be ignited by the engine of a passing forklift – or perhaps even sparks produced by the further collapse of the shelving.

While the above situation may seem overly elaborate, it serves to demonstrate that it is unlikely that any areas of a production facility remain “explosion hazard free.”  The key when evaluating risks is to determine the degree of danger that they pose and then plan accordingly.  If one part of a building or production floor is known to offer an increased risk of dust explosion, then workers can be trained in how to mitigate the chances of an incident occurring, as well as how to respond should one present itself.  This should be on top of the general dust explosion training that all workers need to undergo when employed in an industry that produces dangerous amounts of explosive dust.

Risk managers can divide facility evaluation across a few different criteria.  It is of course important to study the Materials Safety Data Sheets of all chemicals and materials present during business in order to determine if they pose a dust explosion hazard.  Keeping track of where these materials are stored and how they are transported is also key.  Next, any processes which generate large amounts of dust, or even small amounts that could accumulate over time need to be identified.  Hidden areas, such as crevices behind machines which could accumulate dust unnoticed must be noted, along with any open areas which may have dust tracked into them, or which may provide for the slow air saturation of dangerous dust particles.  Finally activities which push dust into the air – ventilation equipment, saws, vehicle exhausts – need to be accounted for, along with the varied sources of ignition that are typically scattered around a modern facility.

In order to ensure that risk managers are fully updated as to the potential for disaster that dust explosions hold, as well as how this danger can be properly mitigated, the Occupational Safety and Health Administration (OSHA) released a new publication in 2009 on the topic.  Entitled Hazard Communication Guidance for Combustible Dusts, the document focuses specifically on chemical manufacturers and importers, and offers guidance on how they can reduce the chances of a catastrophic dust explosion in other industries.

One of the primary points made by the publication is that ignorance of risk is a primary contributing factor when it comes to dust explosion hazards.  It is difficult for precautions to be taken if employees are not informed that the dust-producing materials that they are working with warrant such caution.  OSHA has discovered that 41% of the Material Safety Data Sheets (MSDS) associated with materials known to be dust explosion risks fail to mention this critical information.  Unfortunately, analysis has revealed that dust explosion information is poorly conveyed in almost every MSDS.

OSHA’s Hazard Communication Standard (HCS) can be put to good use in the proper identification of chemicals which post a dust explosion risk.  HCS requires that chemical manufacturers undertake hazard determination and evaluation of the products they generate, and follow that with appropriate MSDS updating in order to reflect the evidence gathered during the evaluation phase.  Manufacturers must consider both standard and non-standard use of their products, especially with regards to processing after they have reached end of life status,  Recycling or processing can easily create explosive dust from materials which are considered safe in their “shipped” form, and this must be noted on their related MSDS.

A material’s MSDS should be as verbose as possible concerning the explosion risks it poses.  While a simple “explosion hazard” warning is better than nothing at all, a detailed explanation of the circumstances under which ignition of dust could occur greatly improves the chances that it will be handled safely.  This explanation can include tips on storage and transportation, as well as specific information regarding what types of dust accumulation are the most common and which pose the greatest threat.  Since the act of merely sweeping a layer of dust from the area surrounding a spilled container can be enough to cause a hazardous situation, it is far better for chemical manufacturers to err on the side of providing too much information than it is for them to assume that workers interacting with a material will automatically be aware of the dangers it poses.