Of primary importance is emphasis of work teams of at least two employees, as one must be available to provide CPR in the case of cardiac arrest of ventricular fibrillation.

The “269″ standard requires employers to comply with the medical services and first aid provisions in 1910.151, which requires that:

• Someone in the workplace is trained in first aid if no medical facilities exist in near proximity.
• First aid supplies are readily available.
• Quick-drenching or flushing facilities are provided for immediate emergency use where the eyes or body of a person may be exposed to injurious corrosive materials.

In addition, 1910.269(b)(2) requires that field crews have first aid kits placed in weatherproof containers if the contents of the kits could be exposed to the weather.

Inspection and availability of first aid kits. First aid kits in vehicles or at company facilities must be placed in locations where they will be readily available when needed. 1910.151, Appendix A provides guidance on first aid kit contents and how to assess the needs of the work place, including exposure to Blood Borne Pathogens. Additionally, the contents of first aid kits must be inspected at least annually to ensure that the items are useable and all required items are present in the kits (1910.269(b)(3)).

While the standard does not specifically cover documenting the results of first aid kit inspections, some companies have initiated inspection documentation procedures in which staff inspect the contents of first aid kits at regular intervals and enter the inspection date and the inspector’s initials on an inspection tag inside the kit.

Risk manager should take the time to review which employees have not had CPR training, or if their first aid kits are lacking any supplies given the possiblity they may have been used in the past. Check these things now rather than find out one of your teams was not prepared when an accident occurred. Remember the 4-minute Requirement, which states that first aid supplies or a worker trained in first aid must not be more than 4 minutes away from a shock victim’s location or all workers must be trained. This happens in the case of large facilities, or when workteams are frequently out in the field.

Review the standard and determine what action you need to take to be prepared for an incident, should it occur.

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.

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)

However, human nature being what it is, it’s also important for risk managers to prepare for instances where employees do not remember these basic precautions.  This is especially true in any industry that makes extensive use of automated machinery.  Not only are the hazards of equipment that can be turned on remotely immediately obvious, but the electrical current that is required to power these machines is also usually of a voltage that could cause serious injury should workers come into contact with an unexpectedly charged circuit.  The greatest risk of this occurring comes when maintenance or repairs are being performed, as not only does this interrupt the standard routine that most workers are used to, but it also places service personnel in the most vulnerable possible position.

It was for exactly this reason that lockout/tagout was created.  Lockout/tagout is a system of physical blocks that make it impossible to energize a switched circuit.  In this way, injuries related to either an electrical shock or the unexpected operation of a piece of machinery are avoided.  In addition to electrical gear, lockout/tagout can also be used to control hydraulic and pneumatic systems, as well as a number of other energy sources

The type of safety devices employed by a lockout/tagout system are varied.  For electrical systems, they might consist of circuit breaker lockouts which fit over the breakers in question and make them impossible to flip without unlocking, or lockouts that fit directly over wall switches to prevent accidental equipment activation.  Gas and fluid flow can be controlled via valve wheel lockouts.  For facility-wide implementation, it is possible to purchase specialized kits that are meant to provide a number of different lockout/tagout blocks designed to cover an entire system, end to end.

Of course, as with any safety system lockout/tagout only works as long as employees are educated as to how to properly implement it.  Barring an unexpected line incident, workers should never be surprised to arrive at their station and discover that its functionality has been locked out.  Instead, a training program explaining the utility of lockout/tagout, combined with a site-wide program explaining the facility’s policies is a critical aspect of this safety tool.  Written procedures that cover how equipment should be locked and unlocked, as well as who has the authorization to initiate either state are a must.  Training on these policies should not be restricted just to those who will be responsible for performing the lockouts themselves – it should be extended so that all employees who come into contact with a particular pierce of machinery are aware of the details surrounding the process.

Electrical safety programs must now be audited on a regular basis, with the frequency of those audits being determined by risk managers.  This is on top of additional arc flash hazard updates which now must be undertaken in the event that the work area in question is either renovated or otherwise modified in a major way.  Even if no changes have been recently made, every five years an arc flash analysis must be performed again in order to ensure that it is up to date. This is largely due to the fact that changes occurring elsewhere in a facility’s electrical system can impact voltages in ways that may have not been predicted in the original spec or analysis.

Training for employees working with high voltages has also been expanded and clarified in order to introduce a more comprehensive level of safety.  Anyone exposed to shock hazards must be given CPR training that is subject to annual employer certification. Equipment labeling changes have also been enacted in order to inform those workers interacting with charged circuits as to the level of personal protective equipment required in their presence, as well as the level of incident energy present in the equipment involved.  In order to remove any doubt regarding the voltages being worked on, risk managers must ensure that their employees can demonstrate a clear knowledge of how to operate voltage-detectors².  This enables them to adequately prepare for their assigned work from a safety perspective.

Furthering this trend towards clearer lines of communication regarding the presence of high voltages, contractors that could conceivably come into contact with charged circuits covered by the NFPA 70E-2009 regulations now need to informed of the risks involved by facility managers and then transmit that information to each employee working on-site. All workers, regardless of who they report to, are also now required to remain aware of any potential high voltage situations that could be encountered as a result of task changes that take their work outside its original scope¹.

On the administrative side, a further provision states that that risk managers are also responsible for documenting employee training, in order to provide an audit trail for OSHA should investigation of a safety incident be required.

Many of these new standards are common sense, and have been implemented in a number of workplaces for many years.  Be that as it may, it never hurts to have a codified set of guidelines to turn to when crafting or reviewing electrical safety policies, which is exactly what NFPA 70E-2009 provides.

The release of NFPA 70E-2009 has introduced several changes that directly impact the habits and practices of those workers who service energized electrical circuits.  In particular, several provisions have been made in order to prevent injury related to arc flash.

Arc flash is a hazard which occurs when the electricity in a system finds a low resistance path between the air and a worker or tool being used by a worker, causing current to arc across the gap and generate serious amounts of heat energy – in some instances, enough to vaporize metal.  Naturally, it is critical for a risk manager to reduce the chances of arc flash from occurring at a job site, and furthermore to protect those working with energized circuits from becoming injured in the event of an accident.

The newly updated NFPA guidelines have recognized that lower powered circuits do not pose a significant risk of arc flash, and as a result an arc flash analysis is no longer mandatory on any circuit rated at 240V or less when being fed by a transformer rated at 125 KVA or lower.  However, the wording of 70E-2009 has been updated to reflect the detail shown in the National Electric Code (NEC) relating to arc flash.  This includes defining when and where personal protective equipment (PPE) must be worn while working near a live circuit.

Risk managers are permitted – and encouraged – to install arc-resistant equipment and switchgear that prevents the possibility of current arcing to anyone working near it.  This is accomplished through the channeling of thermal energy by the equipment, and creates a safety sphere around the circuit where protective clothing is not required while the switchgear is latched and closed.  Once opened, a standard arc flash boundary is once again in effect.

A further set of changes have been made to the type of personal protective equipment that is allowed to be worn in an arc flash boundary (Hazard/Risk Category 1).  Denim pants and cotton clothing of any kind are no longer acceptable, due to the increased chance that they will cause second degree burns in an arc flash situation.  The new standard in PPE is arc-rated clothing that completely covers the entire body, including a face shield and leather or insulating gloves. The elimination of cotton’s status as a safe fabric is related to the deletion of the NFPA section that allowed flammable clothing to be worn as long as the energy levels involved did not surpass 2 cal/cm².  The end result is that hoods, coveralls, jackets and pants used in an arc flash boundary now need to be made of Nomex or other fabrics that are equally resistant to arc flash heat.

In combination, arc-resistant switchgear, properly rated PPE and greater clarity concerning which workplace situations require extra caution in terms of the possibility of an arc flash hazard should help to increase the overall safety and security of any facility where maintenance and repair work is regularly performed on energized circuits.

Electrical safety is a prime consideration of any contractor, employee or risk manager working in an industry where high voltages are a fact of life.  Whether it is on the floor of a packaging plant, perched in a cherry picker in front of a utility pole, or even installing a 220v line in a new home, electrical contractors must remain vigilant in order to avoid the kinds of serious injuries that could result from even a momentary lapse of attention near an energized circuit.

Since 1979, the Occupational Safety and Health Administration (OSHA) has teamed with the National Fire Protection Association (NFPA) to develop and maintain a safety standard aimed at protecting the health of those working with electricity, whether it be as contractors or in their day-to-day employment.  Known as NFPA 70E, the standard initially dovetailed with OSHA’s electrical safety regulations and requirements but has since then grown and expanded through seven editions, with the latest being released in 2009.

Most risk managers are intimately familiar with the previous edition of NFPA 70E, but the most recent update does call for important changes to be made in the workplace.  The new sections of the standard affect both how workers interact with the equipment they are servicing or installing as well as the types of tools and gear they use while doing their jobs. Some areas which were considered to be duplicates of requirements already provided in the National Electric Code have been removed from the standard, but more important are the additions and changes that have been made.  These will require that current risk management plans be revised and updated in order to comply with the new regulations, as well as further safeguard the lives of electrical workers in an organization.

An overview of the differences between the older NFPA 70E standard and the newest iteration reveals that the most significant changes have been made across a diverse range of safety areas.  Individual safety standards that involve dealing with arc flash hazards and personal protective equipment have been revised, as have several organizational-level practices related to training, contractor relationships, equipment labeling and overall safety program validation..  This means that risk managers must communicate the updated standard not only to individual employees and contractors present onsite, but also decision makers and management touched by the wider impact of NFPA 70E-2009’s implications at a company policy level.

Workplace safety is essentially a contract between the site manager and workers who each pledge to respect the service standards expected of each in order to keep the workplace free from any accidents or hazardous situations that could result in injury or death.  By ensuring that those involved in the maintenance and installation of onsite electrical equipment are aware of the changes made the NFPA 70E, as well as demonstrating that their organization has taken the initiative to respect the new requirements on the administrative and corporate end, risk managers can help to create as safe an environment as possible within the confines of their facility.