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.

This time of year companies are reviewing and preparing their injuries and incidents reports in order to complete their OSHA logs, which must be posted by February 1.  OSHA recording is usually a daunting task for most, especially if you have more than 100 employees, or just a significant number of indemnity claims.  Usually, the hardest part of completing OSHA logs is mentally separating the rules of workers compensation with the recordable requirements of OSHA.  So to make it easier for you we have noted the most common mistakes below.

• Failing to check behind your TPA (Third-Party Administrator) or Insurance Company –   Tons of companies choose to let someone else handle their OSHA logs, as this is much easier than doing it yourself.  The problem is not checking their lost-time and modified-duty days.  Most workers compensation statutes require a waiting period, usually 7 days, before adjusters start counting days.  These days are usually not on the radar for most insurances companies and TPAs.  For example, a medical-only claim where the injured worker only missed two days may fall between the cracks on a TPA-completed OSHA log.
• Forgetting to include injuries that were not considered workers compensation or that was denied under workers compensation. – This is a biggie and so easy to do.  A lot of people forget that an injury does not have to be an injury compensable under workers compensation statutes to be recordable under the guidelines of OSHA. For example, heart attacks are not always compensable under workers compensation.  However, heart attacks may be recorded on the log.  You will need to report all heart attacks to OSHA and they will decide whether or not it is recordable.
• Realizing that it must be a new event -  Some employees have multiple injuries throughout the course of a year.  It is important to ensure that an employee is completely healed from an injury.  For example if your employee suffered a knee injury in 2008 and was still seeking medical treatment, another injury, while doing their normal job functions, to that same knee would not be considered a new event.
• Failing to update prior years – OSHA allows you to stop counting loss time and modified duty days at 180, if an injury is recorded in one year and the employee is still losing time.  It is critical that you update your OSHA logs for that year.  Remember, OSHA logs should be maintained for a period of 5 years.

This time of year can be very stressful, especially with the aggressive image of today’s OSHA.  The new focus on reporting injuries and incidents should not be taken lightly.  The quickest way to have OSHA show up at your door, aside from having a worker fatality, is to submit inaccurate OSHA logs.

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.

On January 5, 2010 the ASSE announced that it had completed a voluntary consensus standard dubbed “Work Zone Safety For Highway Construction.”  The ASSE has been in existence for almost 100 years, and has grown in size and stature to represent one of the most respected national safety organizations in the country.  The standard is set to be published by the American National Standards Institute (identifier A10.47-2009) and go into effect February 24, 2009.

Highway work provides many challenges to risk managers due to how exposed workers are to a wide variety of different hazards.  Most obvious is the presence of speeding cars, many of whose drivers pay little or no attention to signage warning them to slow down before entering a work zone.  This is compounded by the low visibility associated with certain outdoor work scenarios (night time, precipitation, fog) as well as the frequent use of heavy equipment which can itself seriously restrict the field of vision of both operators and workers on foot. Obviously, both day and night PPE supplies should be available.

A10.47-2009 has been designed to cover a wide range of different employment scenarios associated with highway work, and deal not just with typical construction activities such as paving, maintenance or repair, but also the often overlooked utilities activities that take place on public roadways.  Given that roughly twenty percent of all workplace fatalities in 2008 occurred on highways, and a third of those involved someone being struck by a vehicle, it is clear that highway work ranks as one of the most dangerous types of employment in the United States.

The fact that individual states often have their own policies in this area only adds to the confusion for foremen and risk managers attempting to satisfy conflicting legal requirements while still offering their workers the highest possible degree of injury protection.  The federal government’s involvement in roadwork safety balances the convenience of motorists (through the reduction of delays and the scheduling of major work to occur at night, for example) with the safety of workers, which is not always an equation that works out in favor of hazard mitigation.

Although the ASSE standard is voluntary in nature, its adoption across the country by private contractors may spur OSHA into taking longer look at whether highway work requires its own section of the federal regulatory code.

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.

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.

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.