First, you should understand that the GHS is broken down into three major components: physical hazards, health and environmental hazards, and hazard communication. The physical hazards and health and environmental hazards components revolve around testing chemicals in order to classify the type of hazards associated with the chemical or chemicals that make up the product. The greatest changes will be seen in the hazard communication component.

Next, you need to evaluate the target audience that you will fit into under the GHS.  Currently, the 4 main audiences for the GHS are transport, workplace, consumer, and agriculture.  Once, you realize where you fit, and some companies may fit into more than one sector, you can start to see what you need for compliance.

Within the transportation sector, it is projected that the pictograms used in the GHS will be used on containers carrying dangerous chemicals.  However, other aspects of GHS such as signal words will not be adopted. The workplace sector is expected to adopt the type of labels that will display signal words, hazards statements, and symbols.  As well as, revised training for employees.  The consumer sector will see risk based labels that incorporate the signal words, hazards statements, and symbols.  The agriculture sector will see about the same type of adoption to the GHS that the workplace sector will see. Prominent HazCom display is a must as well.

Companies should also realize that the adoption of GHS will also demand changes to Materials Safety Data Sheets (MSDS), and training.  The impact to business finances is difficult to quantify, but hopefully will be considered by OSHA before a final decision is reached. However, the benefits should also be weighed.  It is expected that companies will find it easier to do business in other countries; there will be a greater pool for training resources; and, training will be focused on understanding and comprehension.

If you are interested in getting more information on the UN’s Globally Harmonized System and getting ahead of the game, you should visit OSHA’s guide to the GHS at http://www.osha.gov/dsg/hazcom/ghs.html#2.3.

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.

There are two primary issues which can lead to an accident due to the presence of rain.  The first is the water itself, which poses a threat in several ways.  Water can cling to almost any surface, making it slippery to the touch and underfoot.  This viscosity is even more pronounced should rain water mix with any chemicals or oils that may be on the ground or on a piece of equipment, making it harder to hold on to power tools, vehicle controls or even remain upright in certain situations.  Water can also soak through the clothing worn by workers and cause their body temperatures to drop, which over the course a shift can lead to severe health risks such as frostbite or even pneumonia.  Simply put, wet clothes can significantly accelerate the negative health impact of cold weather.

The second, less commonly associated risk presented by rain is low visibility, particularly when operating heavy equipment.  Whether rain is heavy or even just a gentle mist, the lack of light brought about by storm clouds almost always drops the distance at which workers can see each other.  This problem can be exacerbated when moving in and out of artificially illuminated spaces, such as an indoor warehouse and a much dimmer stock or lumber yard.

Fortunately, risk managers have a large number of options when it comes to mitigating these particular safety concerns.  Many levels of rainwear targeted towards an industrial application are available on the market, ranging from full rain suits such as the River City Dominator, which offers .42 mm of PVC and nylon protection from the elements, to lightweight options such as Zodiac .10 mm PVC rain suits.  The latter are particularly useful for workers who may only occasionally require protection from the wet, as their small form factor makes them convenient for transport out into isolated areas when rain might be in the forecast.  Simpler solutions, such as hooded raincoats and slush boots designed to provide cleated rubber grip on slippery surfaces are also available and should be considered the bare minimum for outdoor workers in a rainy climate.

With regards to visibility, industry-oriented rainwear is almost always available in high contrast or reflective colors such as yellow or bright green, with the option of reflective materials wrapped around them in order to stand out against even the darkest backdrops.  It is important to train workers to keep their rain gear as clean as possible in order to avoid masking its reflective qualities.  In particular, employees who must often inspect typically grimy areas such as sewers, waste collection facilities or those who service outdoor machinery should be aware of the need to regularly clean their rain suits.  If cleaning is not feasible on-site, then fresh rain protection should be made available for each shift in order to maintain the highest possible safety standard.

However, there are other considerations to make when planning for welding to occur within a facility or job site.  Not only should the worker directly involved in the welding be afforded the proper tools and training to perform his or her job safely, but the surrounding area and all other employees should also benefit from the same level of protection.  This means taking into consideration a number of different factors that can impact the security of a welding site.

To begin with, any area where welding is planned to occur should be well marked so as to ensure that any workers who might be sharing the same space – whether as a result of performing their own tasks, or while in transit – are aware of the activity that is taking place.  This is especially important with regards to repair work that might be performed in an area where welding is out of the ordinary.  Not only does this fight through the sense of routine that can cause people to be blind to items they do not customarily encounter during their day to day responsibilities, but it also alerts them to the presence of heat and sparks which could interact negatively with any volatile substances being transported.

The latter concern can be expanded to include the effect of sparks and heat on the immediate environment.  Obviously, a shower of fire is an unwelcome proposition in almost any working situation, but in areas where combustible dust, chemical vapors or sensitive electronics are also present it can easily spell disaster.  This is part of the reason why the Occupational Safety and Health Administration (OSHA) requires that some type of shielding be used to separate a welder’s work area from the rest of the facility or job site.

This shielding often takes the form of a heavy curtain that is draped around the welder’s equipment and the items being worked on.  The advantage of a curtain is that it can be easily adapted to the shape and size of the work area, and it can also be placed over delicate gear in order to add an extra degree of protection from sparking.  Some curtains, such as those available from Wilson are manufactured in such a way as to be transparent.  Made of a special type of vinyl, they protect the eyes of passersby from the potentially harmful light frequencies produced by certain types of welding but they also allow for employees to know if a worker or equipment is present behind the curtain.  In addition, they promote the ability of light to pass through into the work area and improve the visibility of the welder, which can be critical in situations where a workspace is too cramped for supplementary lighting to be introduced.

Welding curtains are a simple, yet effective method for ensuring the safety of welders, other workers and the environment around them without having to resort to disruptive shut downs or take chances with the effects of sparking or excess heat.

At the meeting company officials were able to present sufficient evidence to OSHA inspectors that showed extensive training was conducted on the “cherry picker” that crushed 27-year-old Jorge Leandro-Ramirez, an employee operating the equipment back on April 29. OSHA acknowledges that the accident occurred in spite of, not because of lack of, training.

Employers should be encouraged that accurate record-keeping and reporting, as well as robust training programs, provide some help in defending your company when disasters occur. A review of all training programs and policies should be performed to make sure they do the job of protecting workers.

To be fair, the current standard dates back to the early 70s and there have been numerous advances in technology and industry practices since then.  Designed to take aim at the leading causes of crane and derrick related fatalities and injuries related to equipment malfunctions. Two studies were used to as a basis for aspects of the proposal “Crane-Related Fatalities in the Construction Industry,” by J.E. Beavers, et al, and “Crane-Related Deaths in the U.S. Construction Industry,” by A. Suruda, et al.  According to Suruda, the top 5 causes of fatalities from crane related incidents are electrocution, crane assembly or disassembly, boom buckling or collapse, crane overturn, and rigging failure.

Here are a few of the ways in which the Oct. 08 proposal would combat the major hazards outlined in both the Beavers and Suruda studies.

• Unless ground conditions are firm, drained, and sufficiently graded, equipment would be prohibited from being assembled or used.
• The “controlling entity,” normally either the employer owning the property or primary contractor would be responsible for prepping ground conditions before cranes could be assembled or used.
• Employees would be prohibited from standing under an equipment (crane, boom, etc) while pins are being removed unless employer could demonstrate a restraint that would prohibit equipment from falling on an employee.
• The proposal also covers electrocution hazards, overhead protective covers to be attached to guardrails; care to be taken, and the need for a signal person to relay signals of hazards.

It should be noted that these are just a few of the proposed in changes in the Oct. 08 final register for the cranes and derricks standard.  OSHA will still be taking into consideration the comments from these proposed changes and any new data that may impact the safety and health of workers.  At the time that the proposal was issued, the cost of complying with the changes represented less than 1% of revenues for each of the industries affected.

The agenda released pointed to a final rule date being issued around July of 2010.  If you use cranes and derricks, now is the time to review the Oct. 08 proposed standard and any new industry changes that have occurred since then.  The new standard is coming be ready.

References

Proposed Rule: Cranes and Derricks in Construction; http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=FEDERAL_REGISTER&p_id=21169;

Accessed November 7, 2009.

Analysts have pointed to a variety of reasons such as the economy, longer life expectancy, and rebellious nature of baby boomers that combine to keep older workers in the labor market.  Yet, the most pressing of all is the impending “brain drain” that is feared by most industries.  This is the idea that when the seniors and baby boomers retire, they will be taking with them precious knowledge that their younger counter parts simply do not possess.

So as employers look for new ways to “court” older workers, considering changes that could keep senior staff safe and healthy should be at the top of the list.  Before, making needless changes you should ask yourself the following questions:

Are you familiar with the physical needs of your senior staff?

Before making any changes, you need to be sure you are fully aware of the needs of your senior staff.  This will allow you to target changes for maximum effectiveness.  For example, redesign the workspace of senior staff that is constantly walking around the facility or standing at a line may be less effective than installing anti fatigue matting.

Is your safety equipment really safe for your senior staff?

This may seem like a stupid question, but think about it. While the weight of standard equipment doesn’t seem to bother your 20 somethings, it may be a huge stress to the joints and muscles of your senior staff.  And, the last thing you want is for your staff to have to choose between safety and comfort, regardless of their age.  So, consider ergonomic and light weight safety gear and equipment for your senior staff.

For a small business these changes, while helpful, may seem a bit expensive. So, if you are looking for simpler changes, consider the suggestions below:

• The 18 inch rule – designing work spaces to prevent the need for senior staff to reach for any objects or tasks that is greater than 18 inches away.
• Ten minute time outs – encouraging senior staff in positions that require repetitive motions to take 10 minute breaks to reposition or stretch a little throughout their work day.
• Shoe slip-ons – providing anti-slip shoe slip-ons to senior staff that spend a lot of time walking on slippery floors, such as those that are hardwood or tiles, especially during bad weather.
• Back/knee supports – providing additional back and knee supports to senior staff to reduce the stress placed on joints and muscles throughout their work day.

Keeping senior staff happy is a high priority for many business owners today.  So, it should come as no surprise that the best place to start is by increasing the measures taken to keep them safe.

Concentrating on OSHA’s regulatory efforts in terms of altering or strengthening their current policies, there are a few areas where risk managers can expect to see changes in the coming months.  A proposed rule from the Administration in January of 2010 will update regulations concerning the recordkeeping of musculoskeletal injuries, with the aim of altering the current OSHA 300 Injury and Illness Log to be better able to track them.  The end goal is to produce clearer statistics concerning this persistent workplace injury for both OSHA and the Bureau of Labor Statistics.

OSHA is also looking to bring to a conclusion a project which has concentrated on creating a common system for communicating information about potentially hazardous chemicals.  Dubbed the Global Harmonization System of Classification and Labeling of Chemicals (GHS), it will serve as the new standard to which OSHA’s current Hazard Communication Standard (HCS) will conform.  The hope is that a more information rich and specific system will improve the utility of material safety data sheets.  This initiative is planned to begin the hearing process at the end of March 2010.

The final regulatory change which doesn’t stem from a specific industry issue is with regards to Subparts D and I dealing with Walking and Working Surfaces.  Focusing outside the construction industry, the changes planned to be made by this proposal – which will also be released to the public in March 2010 – will be sweeping enough to prevent as many as 20 deaths a year from falls, trips and other related workplace accidents.  OSHA also hopes to be able to reduce up to 3,500 serious injuries that occur along the same lines.

While the latter two initiatives are somewhat more directed towards certain areas of the working world, the changes to musculoskeletal injury reporting affect everyone.  Not only will employers be held more accountable when it comes to accurately describing this class of injury in an incident report, but it also points to future changes to be made by OSHA as a result of the critical statement released earlier this year outlining how many businesses fail to file the necessary paperwork with the Administration following an accident.  The Injury and Illness Log change is likely just the tip of the iceberg in terms of OSHA tightening their grip on injury reporting standards.

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.

• Start bi-annual or quarterly physical testing.  Most employers do a fit test upon hire.  However, as the working population ages, employers find themselves digesting unrelated medical injuries that increase the severity of workers’ compensation claim.
• Do not take requests lightly.  Supervisors and managers need to be trained to not dismiss any request for the repair of equipment or for additional safety gear.
• Ensure that all employees use safety equipment and follow safety precautions.  More often than not seasoned employees have their own way of doing things. And although, their way may be quicker, odds are good they are not safer.

You are probably wondering why review safety strategies that are based on logic.  Well these tactics are designed to reduce injuries through prevention without increasing costs.  And you will need those cost savings because an increase in costs should be anticipated.

• Your compensation costs are going to rise, due to an increase in workers compensation claims.  OSHA has started aggressively pursuing companies for under-reporting.  Expect new guidelines to surface regarding what types of injuries should be reported, forcing companies to count more accidents as compensation claims.
• An increase in claims will usually lead to an increase in a company’s experience modification, which will in effect a company’s workers compensation premium for at least 3 years.
• Your compliance costs will probably increase.  The expected new director of OSHA, David Michaels, is well known for promoting ergonomics.  Plus, with his views on musculoskeletal injuries, the entire industry is anticipating an ergonomics standard.  Since ergonomics has been more of a recommendation instead of a requirement, most companies will need to spend money in order to comply with any ergonomics standard.

Businesses seem to be holding their breath, but the key to any safety issue is prevention.  The direction of OSHA has many in the industry terrified.  Still, staying a head of the game on prevention will give you one less thing to worry about.