The Importance of Facility Safety Inspections

Mock OSHA Facility Inspections Save Worker Lives & Millions in Lost Profit

When an explosion occurred in a plant in Corrigan, Texas, severely burning a man, it took four years for the courts to make their decision. When they did, the verdict was staggering.  The court awarded the plaintiff $39.7 million for pain and suffering.

It was April 26, 2014 when Ralph Figgs’ life changed forever. He was working at a Georgia-Pacific plant when a dust collection system failed, causing the explosion that permanently injured Figgs, killed two of his fellow workers, and injured several others.

In all, three companies were held at fault. Along with Georgia-Pacific, a company called Aircon Inc., which designed and installed the dust collection unit, as well as GreCon Inc., the company that manufactures the spark suppression system, were held liable for the accident.

Just some of the issues that arose during the trial were failure to perform proper safety inspections as well as employees not being properly trained in emergency procedures concerning the dust collection system.

 

Why Companies Need to Prioritize Proactive “Mock” OSHA Inspections

Facility safety inspections are a vital component in preventing workplace injury, illness and even death.

Thorough inspections by qualified safety personnel help identify potential hazards before an accident occurs and corrective action can become the difference between life and death. By heading off problems before they arise, not only does it create a safer work environment for employees, but it also can save the company from financial ruin.

Our qualified inspectors know what to look for and where something is most likely to develop into unsafe or unhealthy conditions because of stress, wear, impact, vibration, heat, corrosion, chemical reaction, ventilation or misuse.

In addition to work areas, locker rooms, rest areas, storage rooms, and parking lots are included during the inspection as these are places where workers have a tendency to let their guard down, sometimes resulting in debilitating slip-and-fall scenarios, among other accidents.

It is also important to not only inspect the equipment, but also to observe how the worker interacts with the equipment during the workday.

A good safety inspection doesn’t necessarily mean a stop in production as many times the inspector will observe a normal work day. Often the inspector will share concerns and questions with workers who use the equipment every day, creating a collaboration to arrive at the best course of action.

 

Set up a Mock OSHA Inspection with Certified Safety Professionals

For companies that are subjected to periodic OSHA inspections that can result in hefty fines when something isn’t up to code, having a pre-inspection done by us can also be an invaluable tool.

Failure to conduct forklift inspections, fire extinguisher inspections, having tripping hazards (slips/trips/falls), poor housekeeping, missing protective guards, blocked emergency exits and more can add up to large violations.

But by listening to the concerns of supervisors and employees, learning more about job tasks and goals, identifying potential problems and putting a plan in place to address the continued safety of employees, the long-term health and success of a company can be ensured.

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Beat The Heat – A Brief Heat Illness Prevention Review

Summer is here, and with it – HEAT! Forty-five people died from heat related injuries in the US in 2015, according to the National Weather Service. Some companies simply prefer to close when temperatures get high, but closing is not an option for every business, so it is important to know how to beat the heat! 

Heat related illness includes four major categories:

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Heat Stroke

Heat Stroke is by far, the most dangerous stage of heat related illness. Heat Stroke is a medical emergency that may result in death! Call 911 immediately if you witness any signs of heat stroke.

Heat Stroke may occur as a result of other, heat related illnesses progressing, and is usually a result of prolonged exposure to high temperatures.

Symptoms of Heat Stroke include:

  • Confusion
  • Fainting
  • Seizures
  • Excessive sweating or red, hot dry skin
  • Very high body temperature
  • Dizzyness
  • Nausea & Vomiting
  • Rapid Heartbeat
  • Lack of sweating despite the heat
  • Extreme headache

Those affected by heat stroke may also experience seizures and unconsciousness.

First Aid for Heat Stroke

Call 911

  • Place the worker in a shady, cool area
  • Loosen clothing and remove the outer layer
  • Fan the worker if possible
  • Place ice / cold packs in their armpits to help lower internal body temperature.
  • Use cool water, cold compresses, ice and any other cold item available
  • Be sure to stay with the worker until help arrives – do not leave the worker alone if at all possible.

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Heat Exhaustion

Heat exhaustion comes as the result of prolonged exposure to high temperatures. Whether working indoors or outside – precautions should be taken to avoid heat exhaustion.

  • Symptoms of heat exhaustion include:
  • Heavy sweating
  • Faintness
  • Dizzyness
  • Fatigue
  • Weak, rapid pulse
  • Low blood pressure upon standing
  • Muscle cramps
  • Nausea
  • Headache
  • Cool, moist skin with goose bumps when in the heat

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Heat Cramps

Heat cramps are a result of prolonged use of muscles in high temperatures. A lack of salt, and imbalance in electrolytes are believed to be a catalyst for muscle cramps.

Heat cramps present with muscle spasms that are painful, involuntary, brief, intermittent but they normally go away on their own.

Listen to your body. Heat cramps is your body’s way of telling you that you need to cool down. If you, or someone working near you begin to experience signs and symptoms of heat cramps, take the following action:

  • Rest in shady, cool area
  • Drink a sports drink to replace electrolytes
  • Consume salt by drinking a salt solution, or by taking salt tablets
  • Drink cool water
  • Wait a few hours to resume strenuous work
  • Seek medical attention if cramps do not go away

  Salt Solution TIP: Mix 1/4 to 1/2 teaspoons of table salt in a quart of water.

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Heat Rash

Heat rash is often the very first sign that your body may be overheating.

 

Look out for:

Clusters of red bumps on skin

Check the neck, upper chest and folds of skin for spots that look like a rash.

If you, or someone working near you experience symptoms of heat rash, take the following steps to cool down:

  • Try to work in a cooler, less humid environment when possible
  • Keep the affected area dry

Water, Rest and Shade may be the most important aspects of staying safe while working in the heat.

Summer is here, and with it – HEAT! Forty-five people died from heat related injuries in the US in 2015, according to the National Weather Service. Some companies simply prefer to close when temperatures get high, but closing is not an option for every business, so it is important to know how to beat the heat! 

Heat related illness includes four major categories:

____________________________________________________________________

Heat Stroke

Heat Stroke is by far, the most dangerous stage of heat related illness. Heat Stroke is a medical emergency that may result in death! Call 911 immediately if you witness any signs of heat stroke.

Heat Stroke may occur as a result of other, heat related illnesses progressing, and is usually a result of prolonged exposure to high temperatures.

Symptoms of Heat Stroke include:

  • Confusion
  • Fainting
  • Seizures
  • Excessive sweating or red, hot dry skin
  • Very high body temperature
  • Dizzyness
  • Nausea & Vomiting
  • Rapid Heartbeat
  • Lack of sweating despite the heat
  • Extreme headache

Those affected by heat stroke may also experience seizures and unconsciousness.

First Aid for Heat Stroke

Call 911

  • Place the worker in a shady, cool area
  • Loosen clothing and remove the outer layer
  • Fan the worker if possible
  • Place ice / cold packs in their armpits to help lower internal body temperature.
  • Use cool water, cold compresses, ice and any other cold item available
  • Be sure to stay with the worker until help arrives – do not leave the worker alone if at all possible.

____________________________________________________________________

Heat Exhaustion

Heat exhaustion comes as the result of prolonged exposure to high temperatures. Whether working indoors or outside – precautions should be taken to avoid heat exhaustion.

  • Symptoms of heat exhaustion include:
  • Heavy sweating
  • Faintness
  • Dizzyness
  • Fatigue
  • Weak, rapid pulse
  • Low blood pressure upon standing
  • Muscle cramps
  • Nausea
  • Headache
  • Cool, moist skin with goose bumps when in the heat

___________________________________________________________________

Heat Cramps

Heat cramps are a result of prolonged use of muscles in high temperatures. A lack of salt, and imbalance in electrolytes are believed to be a catalyst for muscle cramps.

Heat cramps present with muscle spasms that are painful, involuntary, brief, intermittent but they normally go away on their own.

Listen to your body. Heat cramps is your body’s way of telling you that you need to cool down. If you, or someone working near you begin to experience signs and symptoms of heat cramps, take the following action:

  • Rest in shady, cool area
  • Drink a sports drink to replace electrolytes
  • Consume salt by drinking a salt solution, or by taking salt tablets
  • Drink cool water
  • Wait a few hours to resume strenuous work
  • Seek medical attention if cramps do not go away

 

  Salt Solution TIP: Mix 1/4 to 1/2 teaspoons of table salt in a quart of water.

___________________________________________________________________

Heat Rash

Heat rash is often the very first sign that your body may be overheating.

Look out for:

Clusters of red bumps on skin

Check the neck, upper chest and folds of skin for spots that look like a rash.

If you, or someone working near you experience symptoms of heat rash, take the following steps to cool down:

  • Try to work in a cooler, less humid environment when possible
  • Keep the affected area dry

Water, Rest and Shade may be the most important aspects of staying safe while working in the heat.

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OSHA Requirements Guide for Employers

What Does OSHA Require From Employers?

If you have ever visited OSHA’s website, you know there is so much information posted regarding the different safety and health requirements employers must follow in order to keep their employees safe on the job. We are going to breakdown the key rules and regulations starting with the top 3 basic duties for employers.

Three Key Elements:

  1. Compliance with OSHA laws.
  2. Provide a workplace free from serious recognized hazards.
  3. Examine workplace conditions to ensure compliance.

The foundation of a successful safety program is compliance with OSHA laws. Part of the LSCI approach is to stress the importance of creating a good safety culture at your workplace.

Why Comply With OSHA’s Regulations?

  1. Ethical: Employers should feel a moral obligation to keep their employees safe on the job. “We don’t want anyone to get hurt, do we?”
  2. Legal: The obvious reason for employers to comply with OSHA regulations is because it’s the law. “We want to comply with the law, don’t we?”
  3. Business:  It costs less to be pro-active vs. reactive. “We want to minimize expenses and maximize profits, right?”

If you’re a safety professional trying to convince upper management of the benefits of investing in a safety program, check out our Business Case for Safety e-book or call one of our consultants at 888-403-6026.

OSHA’s General Duty Clause

Every employer should be familiar with OSHA’s General Duty Clause because it really is all encompassing. OSHA can issue a citation for any safety hazard under the General Duty Clause even if it is not specifically spelled out somewhere else in the regulations. It requires employers to protect employees from any safety hazard they may encounter, including those that aren’t specifically listed in OSHA’s regulations.

(a) Each employer —

(1) shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees;

(2) shall comply with occupational safety and health standards promulgated under this Act.

(b) Each employee shall comply with occupational safety and health standards and all rules, regulations, and orders issued pursuant to this Act which are applicable to his own actions and conduct.

  • Comply with OSHA’s standards.

  • Post the free OSHA workplace poster and encourage employees to read it.

  • Provide a workplace free from serious recognized hazards.

  • Conduct hazard assessments.

  • Maintain up to date written safety and health programs including procedures.

  • Employers must provide safety training in a language and vocabulary workers can understand.

  • Provide access to Safety Data Sheets (SDS) when employees use hazardous chemicals.

  • Train employees on what chemicals they are exposed to.

  • Use and maintain safe tools and equipment.

  • Provide warnings of potential hazards including signs.

  • Report all work-related fatalities within 8 hours to OSHA.

  • Employers with more than 10 employees must keep records of work-related injuries and illnesses.

  • Post the recordkeeping 300A form from February 1 to April 30 each year in a prominent location at your workplace.

  • Submit electronic injury and illness records if your workplace is required.

  • Provide access to employee medical records and exposure records to employees or their authorized representatives.

  • Do not discriminate against employees who exercise their rights under the Act. See OSHA’s “Whistleblower Protection” webpage.

  • Post OSHA citations at or near the work area involved. Each citation must remain posted until the violation has been corrected, or for three working days, whichever is longer. Post abatement verification documents or tags.

  • Correct cited violations by the deadline set in the OSHA citation and submit required abatement verification documentation.

A successful safety program needs to be nurtured.

Top 10 Reasons to Partner With an Award Winning OSHA Consulting Firm

OSHA compliance does not need to be confusing or take up every moment of your day. The advantages of having a third party safety consulting company by your side include:

  1. Professional consultants with various certifications and qualifications that know OSHA’s rules and regulations.
  2. Have a hazard assessment conducted without having any citations issued.
  3. Get a safety and health training delivered on just the topics you need.
  4. It is cheaper than hiring a full time safety person or can provide assistance to an overloaded safety manager.
  5. Shows your employees that you truly care about their safety and well-being which will boost morale!
  6. Gives you the peace of mind knowing you have experienced support available and shows OSHA that you are operating in good faith.
  7. Issues safety and health news alerts and OSHA regulation changes.
  8. Helps create a safer workplace for your employees and builds a safety culture.
  9. Will help to prevents or reduce accidents, injuries and potential OSHA citations.
  10. OSHA can offer employers a “good faith” discount for hiring a safety company.

First, strive to meet OSHA’s requirements. Then, work to maintain them. Next, go beyond the safety standards!

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Slips, Trips & Falls – Causes and Prevention

29 CFR 1910 Subpart D

According to the US Department of Labor, over 17% of all disabling occupational injuries results from a fall, making falls one of the most frequently reported workplace incident. In fact, 15% of all accidental deaths that occur in general industry are a result of a slip, trip or fall.

A slip can be defined as too little friction or traction between feet (footwear) and a walking/working surface, resulting in loss of balance. The typical result of this loss of balance, is a fall.

OSHA places falls into two separate categories: Fall at the same level, and fall to a lower level. Falls that occur at the same level occur when a worker falls into or against objects above the same surface. Falls to a lower area is when a worker falls below their current walking/working surface.

Causes

Slips may occur because of the following:

Liquid spills on smooth floors or walking surfaces such as water, grease, mud, oil food, bodily fluids and other wet material is one cause of slips and falls. However, don’t think that just because there are no liquid spills, that the surface is slip-free; dry product spills often contribute to slips as falls as well as wet conditions. For example, smooth walking surfaces where dust, powder, dry granules, wood shavings, plastic wrapping or other dry material connect is likely to create an equally dangerous slip potential. Wet and dusty conditions are not the only reasons for slips; transitioning from one surface to another surface is another often causes slips as well. Be sure to train your workers to be careful when transitioning from carpeted floors to vinyl or other smooth surfaces – especially when they are carrying tools and materials.
Some other common causes of slips are:

  • Highly polished floors such as granite, marble and ceramic tile.
  • Sloped walking surfaces
  • Loose, unanchored rugs or mats
  • Loose floorboards or shifting tiles
  • Ramps & gang planks without skid or slip-resistant surfaces
  • Metal surfaces
  • Dockboards & dock plates
  • Sidewalk & road covers
  • Mounting & dismounting vehicles & equipment
  • Climbing ladders
  • Loose, irregular surfaces such as gravel
  • Sloped and uneven terrain
  • Tree leaves, pine needles and other natural plant debris

 

Trips often occur because of:

  • Uneven walking surfaces
  • Damaged steps
  • Debris accumulation
  • Various waste materials
  • Cables, chords, tools and materials
  • Protruding objects
  • Sidewalk / curb drop
  • Opened drawers / doors
  • Clutter, obstacles in aisles, walkway and work area
  • Sudden changes in elevation
  • Unmarked steps or ramps
  • Rumpled carpets, mats or rugs
  • Carpets with curled edges
  • Thresholds
  • Gaps
  • Irregularities in walking surfaces
  • Missing or uneven brick pavers or floor tiles

 

What if every one of the previously listed risk factors were non-existent, would the workforce be completely free of slips, trips and fall hazards? NO!

Human element is the one, unmeasurable, and unpredictable risk factor that must be considered when developing a training plan. For example, a worker walking on a perfectly even and perfectly stable working surface, who is carrying a generator that weighs 200 pounds, is at greater risk of slipping and falling than if he was walking on the same surface, and carrying nothing.

 

Human Risk Factors Include:

  • Age
  • Fatigue
  • Lack of physical fitness
  • Stress or illness
  • Intoxication (alcohol, drugs & prescriptions)
  • Carrying heavy objects or two many
  • Rushing
  • Situational Awareness – PAY ATTENTION

 

Environmental Conditions:

  • Poor lighting
  • Rain, sleet, snow and other bad weather
  • Poor housekeeping
  • Improper cleaning methods
  • Inadequate signage

 

Prevention Rules

Ladders

Just like any tool, or piece of equipment used on worksites, ladders must be inspected frequently for damage or defects – once you are on the ladder, it is too late. Always inspect the ladder PRIOR TO USE – InspectInspect and Inspectsome more! Here are some specific notes about ladder safety, and how you can stay safe while using ladders.

  • Never use the top of a ladder as a step, or platform
  • Never place a ladder in front of a door unless the door is locked, blocked or guarded
  • Immediately remove any ladder that is damaged or defective
  • Make sure the ladder is maintained and in good condition at all times!
  • Make sure that locks, and wheels are functioning properly and be sure to lubricate them often.
  • Don’t forget to check the safety feet and other auxiliary equipment.
  • Fiberglass framed ladders are notorious for splinters – be sure that all parts are free from splinters and that it has no sharp edges

20 FOOT MAX – for Stepladders

30 FOOT MAX – for Stepladders

 

 

Stairs

Handrails and railings must be present on the open sides of all exposed stairways and stair platforms, and handrails must be provided on at least one side of closed stairways preferable on the right side descending.

Stairway platforms cannot be less than the width of a stairway and a minimum of 30 inches in length measured in the direction of travel.

Stair treads must be reasonably slip-resistant and the nosing shall be of nonslip finish.

Stairs must have uniform rise height and tread width on any flight of stairs including any foundation structure used as one or more treads of the stairs.

Fixed stairs must have a minimum width of 22 inches.

 

Railings

  • Standard railing system consists of a top rail, intermediate rail and posts.
  • Railings have a vertical height of 42 inches nominal from the upper surface of the top rail to the floor.
  • The top rail is smooth surfaced.
  • Be sure that the end of the rail does not create a hazard with sharp edges or other uneven protrusions.
  • Stair railings may not be more than 34 inches nor less than 30 inches from the upper surface of the top rail to surface of tread in line with face or riser at forward edge of tread.

 

The following specifications must be followed for wood and pipe railings:

  • Posts must be at least 2 by 4
  • Posts must be less than, or equal to 6 feet
  • Rails must be at least 2 by 4
  • Pipe railings must be at least 1 ½ inches nominal diameter
  • Posts may not be spaced more than 8 feet on centers.

Structural Steel Railings must adhere to the following specifications:

  • Posts, top and intermediate rails 2 by 2 3/8 inch angles
  • Posts may not be spaced more than 8 feet on centers
  • When constructing railings, the completed structure must be capable of holding a load of 200 pounds applied in any direction at any point on the top rail.
  • Railing Toeboards – Standard toeboards are 4 inches nominal in vertical height, be securely fastened, not more than ¼-inch clearance above floor level. Openings may not be over 1 inch.
  • Where material is piled to such height that a standard toeboard does not provide protection, paneling from floor to intermediate rail, or to top rail shall be provided.

 

Stairways

  • Every flight of stairs having four or more risers shall be equipped with standard stair railings or standard handrails.

 

Open-Sided Floors

  • Every open-sided floor or platform 4 feet or more guarded on all open sides except where there is entrance to a ramp, stairway or fixed ladder.
  • Railings shall be provided with a toeboard wherever: persons can pass, moving machinery exists, or where there is equipment with which falling materials could create a hazard, beneath the open sides.
  • All open sided floors, walkways, platforms, or runways above or adjacent to dangerous equipment, guarded with a standard railing and toe board.

 

Wall Openings                     

  • Wall openings from which there is a drop of more than 4 feet must be guarded by a rail, roller, picket fence, half door or equivalent barrier.

 

Floor Openings

  • Whenever workers must feed material into any hatchway or chute opening, protection shall be provided to prevent a person from falling through the opening.
  • Every stairway floor opening must be guarded by a standard railing
  • Employer must ensure that railing is provided on all exposed sides, except at the stairway entrance.
  • Ladder way floor openings and platforms must be guarded by a standard railing with a standard toeboard on all exposed sides, except at the opening’s entrance, with the passage through the railing either provided with a swinging gate or so offset that a person cannot walk directly into the opening.
  • Pits and trapdoor floor openings must be guarded by a floor opening cover of standard strength and construction.
  • While the cover is not in place, the pit or the trap opening constantly attended by someone or protected on all exposed sides by removable standard railings.
  • Every temporary floor openings must have standard railings, or shall be constantly attended by someone.
  • All floor holes that a person could accidentally walk into must be guarded by either a standard railing with standard toeboard on all exposed sides, or a floor hole cover of standard strength and construction. While the cover is not in place, the floor hole shall be constantly attended by someone or shall be protected by a removable standard railing.

Aisles

  • Permanent aisles and passageways shall be appropriately marked.
  • Sufficient safe clearance must be maintained where mechanical handling equipment is used.
  • Aisles and passageways must be kept clear and in good repair.
  • There may be no obstruction across or in aisles that could create a hazard

Housekeeping

  • All places of employment must be kept clean, orderly and in a sanitary condition.
  • Workrooms must be kept clean and dry
  • Platforms, mats, or other dry standing places must be provided for wet process work areas.

 

 

Prevention Tips

Slips occur when an unintended or unexpected change in the contact between the worker’s feet and the walking surface. Good housekeeping, shoe selection, walking surface maintenance and employee preparedness all play an important role in slip / fall prevention.

We have listed some industry best practices below to help you remain vigilant and free of falls in the workplace; we hope that our advice helps to raise awareness for slips, trips and fall injuries, and we hope that we help to people stay safe.

 

 

Housekeeping

Slips, Trips & Falls – Public Enemy No.1

Companies who practice good housekeeping have slip and fall injuries than the ones who pay less attention to maintaining a clean and safe walking / working environment.

 

Your company can reduce slips and falls by following the following best practices:

  • Clean all spills immediately.
  • Mark spills and wet areas immediately with wet floor signage – block off area with caution tape if necessary.
  • Keep floor free of debris (sweep and mop frequently)
  • Mop floors during low traffic times, or when workers are on break to allow proper drying time.
  • Remove obstacles from walkways
  • Keep walkways free from clutter (including tools and jobsite materials)
  • Rugs & Carpeting – make sure edges that do not lay flat are taped down
  • Cabinets & Doors – keep doors closed at all times
  • Cables that cross walkways must be covered at all times
  • Working areas and walkways must be kept well lit
  • Replace faulty switches and burnt-out light bulbs immediately – improper lighting conditions may contribute to existing hazards and may prevent workers from noticing slip and trip hazards.

The most advanced flooring systems and the best non-slip shoes will not prevent slips and falls if good housekeeping practices are not a part of the culture. Maintaining a clean and tidy workplace should become such a routine practice, that cleaning becomes second nature. Every team member must participate in the advancement of good housekeeping.

 

Flooring

  • Improperly maintained walking surfaces have the potential to cause slips and falls despite the best housekeeping habits. The following measures can be taken to add an additional level of protection against slips and falls.
  • Recoat or replace flooring
  • Install non-slip mats
  • Install pressure-sensitive abrasive strips or abrasive filled paint-on coating and metal or synthetic decking.

 

Footwear

Some work environments are slippery by nature, so extra care must be taken to prevent slips. For example, work environments that are oily or wet, or where workers spend considerable time outdoors have a reputation for being more slippery.

There is no shoe that works best for every scenario, so you should pay close attention to the nature of your specific workplace – and be sure to check the manufacture’s recommendation for what shoe is best for your particular workplace.

 

You can also reduce the risk of slipping on wet floor by:

  • Taking your time while walking
  • Pay attention to where you are going
  • Make wide turns at corners
  • Walk with your feel pointed slightly out
  • Adjust your cadence for the condition.

 

You can reduce the risk of tripping by:

  • Keep walking area free from debris, tools and materials
  • Keep flooring in good condition
  • Make sure the work area is well-lit
  • Be sure not to carry items that are too bulky or too heavy

Delayed Compliance Dates:

Although the final rule became effective on January 17, 2017, but some parts of the final rule have a delayed, or phased-in, compliance dates.

May 17, 2017 – Training workers on fall and equipment hazards

November 20, 2017 – Inspection and certification of permanent building achorages

November 19, 2018 – Installation of fall protection (personal fall arrest systems, ladder safety systems, cages, wells) on existing fixed ladders (over 24 feet) that do not have any fall protection

November 19, 2018 –Installation of ladder safety or personal fall arrest systems on new fixed ladders (over 24 feet) and replacement ladders/ladder sections

November 18, 2036 – Installation of ladder safety systems or personal fall arrest systems on all fixed ladders (over 24 feet)

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How To Start A Workplace Safety Program

So you’re wondering how to start a workplace safety program at your company and not sure where to begin?  Building an effective health and safety program for the first time is a major undertaking, so it’s important to gain some perspective and understanding of the basic requirements and challenges you’re likely to face along the way, so we’ve created this blog post in hopes of helping you do just that!  Think of this article as an “Introduction to OSHA Compliance 101.”

With that said, let’s get on with it…

High Hazard Industries:

Let’s begin by making sure that your company needs a workplace safety program, because not every company does.  To make a long story short, any company who’s operations exposes their employees to workplace health or safety hazards must take steps to mitigate those hazards by developing and managing a workplace safety program.   Here’s a brief list of common industries that just about always have workplace health and safety hazards:  manufacturing, construction, industrial services, warehousing/distribution, healthcare and even certain retail businesses.

If your company is in one of these industries, then there’s a very high probability that you’ll need to develop and manage an OSHA compliance program and the rest of this blog post describes the fundamentals of what that means.

Workplace Health & Safety Hazards:

So what exactly are workplace health and safety hazards?  Unfortunately, there’s a wide range of health and safety hazards that if not properly managed, can result in serious employee injuries, illnesses and in extreme cases can even lead to death.

Safety Hazards:

Some of the more common safety hazards include falls from heights, struck-by and caught-between, accidental release of hazardous energy (electrical and mechanical), unguarded machinery, chemical burns, fires, and even workplace violence.

Health Hazards:

In addition to these safety hazards, there’s also a long list of health hazards that must be managed too.  These include exposures to toxic chemicals & metals and/or other contaminants such as dust or bodily fluids that can lead to serious health problems.  Then there’s potential exposure to excessive noise levels which can result in hearing loss over time.

So there you have it, we’re off to a good start:  if your company is in a high hazard industry which exposes your employees to potentially harmful health and safety hazards, then you’ll need to develop a workplace heath and safety program to help protect your employees from those hazards.

Sounds great, but what exactly does that mean and how do you do that?

Controlling Hazards:

Ok, so let’s try to simplify things a little.  Think of a workplace safety program as nothing more than a set of “controls” which are put into place to help protect employees from the potential harm posed by workplace health and safety hazards.

Actually, there’s a recommended hierarchy of health and safety controls as follows:

  • Elimination: The best option is to eliminate the hazard if at all possible. for example,  a company could scrap an old and damaged forklift that is no longer safe to operate.
  • Substitution: Substitute the hazard with something less hazardous. For example, a company could replace a hazardous chemical with a non-hazardous chemical.
  • Engineering controls: Machine guards to protect from pinch points, rotating parts, etc.
  • Administrative controls: Use of safety policies and procedures, employee safety training, rotating employees to reduce excessive exposure to loud noises etc.
  • Personal protective equipment: Safety glasses, hard hats, steel toed boots.

Notice that PPE (Personal Protective Equipment) is at the bottom of the list.  PPE should be considered the last line of defense only after all other control options have been considered.

There’s much more to learn about this subject, but this should give you a good idea of what health and safety controls consist of.  Again, each of these controls are intended to help mitigate the risks associated with workplace health and safety hazards.

OSHA Compliance:

In order to help employers manage health and safety issues, the Occupational Safety & Health Administration, or OSHA, has developed a series of Standards, each of which is designed to address most of the major hazards that exist in the workplace.  For example, there’s a standard for fall hazards (Fall Protection), chemical hazards (Hazard Communication), noise hazards (Hearing Conservation), respiratory hazards (Respiratory Protection), forklifts (Powered Industrial Trucks) and even standards to address toxic metals like lead.  Each of these standards contain and specify various controls which are intended to help mitigate specific health or safety hazards.

Think of OSHA compliance as a “prevention program” which mandates that impacted employers manage these standards, and their associated controls, to help prevent workplace injuries and illnesses.

Let me give an example of an actual OSHA standard to help illustrate the point.  The OSHA standard which addresses chemical safety, is called Hazard Communication (don’t ask me where they got this name, because I have no idea!).  The standard addresses all of the various hazards posed by chemicals, including burns, fires, health impacts, etc.  The primary controls included in this standard are as follows:

  • Safety Data Sheets, aka SDS’s (formerly known as MSDSs) which spell out all of the hazards associated which every chemical known to man.
  • Labeling: Manufacturers and employers must properly label chemical containers in order to communicate the hazards associated with the chemical (fire, burns, toxicity, etc.).
  • Employee Training: The primary purpose of training is to educate workers on how to read and understand SDSs, safely handle chemicals, properly label chemical containers and how to dawn and doff Personal Protective Equipment.
  • Personal Protective Equipment (“PPE”) needed to protect workers from chemical hazards such burns, inhalation, etc. PPE includes things like gloves, safety glasses, respirators, etc.

The idea being that if an employer implements and manages all elements and controls included in the Hazard Communication standard, then their employees should then be protected from the various hazards presented by the chemicals they use.  Of course no standard is perfect, nor are people, so there’s obviously no guarantee that all future chemical injuries will be prevented, but at least the basic hazards and risks have been addressed.

Keep in mind that OSHA hasn’t developed standards to address ALL workplace health and safety hazards, only the most common and risky ones.  For all other hazards, OSHA has a “catch- all” called the General Duty Clause which basically states that employers must identify and control any other recognized hazards, in order to protect their employees from potential harm.  A simple example might be tearing down an old, wind damaged shade awning that employees stand under for smoking breaks, because the employer realizes that it could collapse at any time.

More on OSHA Compliance:

It’s worth pointing out that OSHA standards are only designed to address “baseline” hazards and risks, and that many of their standards and laws were developed way back in the early 1970’s and haven’t been updated since.  As a result, companies are always advised to go “over and above” OSHA standards by referencing and following guidance from other more up to date health and safety agencies such as National Safety Council, ANSI, etc.   Having said that, it’s tough enough for most small businesses to achieve OSHA compliance, so it’s always best to start there, and then worry about going “over and above” later down the road.

It’s also worth pointing out that OSHA standards are Federal laws that all impacted employers must follow or face the consequences.  Companies who fail to do so face major fines and penalties that can run into the $tens and even $hundreds of thousands of dollars, and  potential criminal liabilities if employees get killed as a result of employer negligence.

Which OSHA Standards Apply to Your Company?

At this point, you might be wondering how to determine which OSHA standards apply to your operations?  And this question leads us to revealing the first major step that any company needs to take in order to begin the process of implementing an OSHA health and safety compliance program.  And that first step is to conduct a health and safety audit or assessment of your company to: 1) determine which workplace hazards are present in your operations, which will then 2) determine which OSHA Standards apply to your business.

Ideally, the end result of a solid health and safety compliance assessment will provide a “roadmap to compliance” which spells out exactly what a company needs to do in order to achieve and manage their OSHA compliance requirements.

Correcting Health & Safety Hazards:

A good, comprehensive OSHA compliance audit not only identifies all relevant hazards, but also itemizes all violations and recommended corrective actions for each.  These corrective actions will include reference to relevant OSHA standards and the specific controls and elements that are required to abate the violation such as engineering controls, written procedures, training, testing, PPE, etc.. The audit would also address other “administrative” deficiencies and requirements such as record keeping (ie: OSHA 300 logs) and reporting requirements.

Typically, the first step after completing a health and safety audit is correcting any and all physical hazards identified in the workplace, since these often pose the greatest immediate risk to employees.  These hazards include things like machine guarding issues, faulty extension cords, defective ladders, unlabeled chemical containers, lack of fall protection, etc.

Your Health & Safety Manual:

While correcting these physical hazards, it’s a good idea to begin working on the next major project which is developing your customized health and safety manual.  This document will contain all of the specific OSHA standards which apply to the company as well as assigning key roles, etc.  This document essentially becomes the company’s “safety bible” and spells out exactly what the company needs to do in order to implement and manage their workplace safety program.

To give you a better idea of what a safety manual might contain, let’s take a typical manufacturing company as an example.  Such a manual might contain the following standards:  Hazard Communication, Ladders, Personal Protective Equipment, Lockout/Tagout, Respiratory Protection, Emergency Action Plan, Fall Protection, Cranes and Hoists, Hearing Conservation, Powered Industrial Trucks and maybe more.

On a related note, many companies make the mistake of downloading a generic safety manual which will normally contain information and standards that don’t necessarily apply to that business.  Again, the manual must be customized to your company’s specific operations and hazards!

More on Employee Safety Training:

This blog post wouldn’t be complete without taking a closer look at OSHA health and safety training requirements because this is one of the toughest requirements to comply with, especially for small businesses.

Again, just about all OSHA standards contain employee training requirements designed to help make employees aware of workplace health and safety hazards and how to avoid and manage them.  Conducting effective and comprehensive training is essential to the success of any workplace safety program, yet it’s one of the toughest controls to manage and therefore one of the most commonly cited violations.

Why is health and safety training so tough to manage?

  • Training must be customized to your operations: Many companies make the mistake of using generic videos or on-line resources.  Technically this is a violation of OSHA standards, because training must be customized to address the specific hazards present in a company’s operations.
  • Trainer must be competent: Companies who are serious about managing OSHA compliance will conduct live training sessions using competent trainers who understand the technical aspects of each standard, can engage their employees, and can answer employee questions. Many companies make the mistake of tasking managers and supervisors who lack the qualifications and experience to adequately train employees, which often ends up being a waste of time.
  • Training is time consuming: most training topics take between 30-60 minutes to properly train, and some topics take much longer.  Many companies make the mistake of believing that 10-15 minute “tailgate topics” are sufficient to meet OSHA standards, but they’re not.
  • Frequency requirements: OSHA requirements that some topics only be trained once, but many have annual training requirements. Even though not all topics are required to be trained annually, OSHA recommends that all topics be trained annually.
  • Employee turnover: Since most companies have employee turnover issues, and since OSHA requires that all impacted employees get trained, training becomes a never ending process for most companies.

Add it all up, and it’s clear that OSHA training is an expensive and inconvenient undertaking.  And if all of these challenges aren’t tough enough to deal with, employers must also commit to pulling employees off the production line to get trained.  This results in added payroll costs, production delays and other related disruptions.

Summary: Managing OSHA Compliance Is A Never Ending Process

Never forget that each of OSHA’s standards contain an extensive list of controls and elements that employers must implement and manage on an ongoing basis.  These controls include ongoing employee training, conducting evacuation drills, developing equipment specific LOTO procedures, conducting and documenting hazard assessments, health testing and the list goes on.  Many companies make the mistake of drafting their health and safety manual only to put it on the shelf to collect dust. Remember, this is your companies “safety bible” and spells out exactly what now needs to be managed on an ongoing basis in order to maintain OSHA compliance.

In addition to the requirements we’ve already discussed, the company must manage additional “administrative requirements” including their OSHA 300 logs (injury and illness records), record keeping and reporting requirements, as well as conducting routine inspections to identify and correct physical hazards which have a nasty way of popping up over and over again.  The company must also manage an internal enforcement program to ensure that employees follow safety rules, such as wearing PPE.

Risks & Liabilities For Failing To Manage OSHA Compliance:

It’s a lot to keep up with, but failure isn’t an option.  These are Federal laws that impacted companies must follow or risk major risks and liabilities including serious employee injuries, surprise OSHA inspections that can result in fines and penalties that can run into the $tens or even $hundreds of thousands of dollars, criminal liabilities if a fatality occurs as a result of employer negligence ($250,000 fine and up to 6 months of jail time), and then there are civil liabilities that can result in $multi-million settlements if an employee get seriously injured as a result of employer negligence.

Companies who fail to manage workplace safety face additional liabilities & risks including lost money, lost business, higher insurance costs, damaged company reputation & PR nightmares, legal costs, increased employee turnover, embarrassment and more.  It’s estimated that US companies lose $140 billion every year in combined direct and indirect costs associated with workplace injuries and illnesses.

What Now?

If you’re feeling a bit overwhelmed and confused at this point, don’t feel bad because you’re definitely not alone especially if you own or work for a small business.  Small companies are at greatest risk because they almost always lack the time, money, resources and internal expertise needed to manage all of the complicated aspects of OSHA compliance.

Like any major project, it’s best to map out your plan, assign key roles and then take it one step at a time through to completion.  As we stated earlier, the first step is to conduct a health and safety assessment of your workplace to determine which health and safety hazards exist and therefore which OSHA standards will apply to your company and safety program.  This isn’t necessarily as easy as it sounds, and requires an experienced and qualified professional to get it done correctly.

We specialize in helping small companies manage environmental, health and safety compliance. 

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Hiring A Safety Consultant For Your ISNetworld® Compliance

If you are looking for help with ISNetworld® compliance, a quick google search will yield the names of numerous companies offering downloadable safety programs and monitoring services to assist you. But how do you know if these companies are qualified to help you with both ISNetworld® and OSHA safety requirements? And how do you choose one among the many choices?

Here are some tips and red flags to look out for:

  1. Avoid ISNetworld® consultants who only provide cookie cutter, downloadable safety programs and no real safety advice.   Although a cheap downloadable program may solve your ISNetworld® compliance problem in the short run, it is not enough.  A professional safety consultant will provide customized safety plans that fit your company’s operations and will advise you on implementation so that the ultimate goal of a clean safety record for your company is achieved.  If you are audited, the cookie cutter plan that was never implemented will not be sufficient to keep your company in compliance, so it’s best to do it right the first time.
  2. Make sure you understand the scope of the services to be provided.  There are many levels of ISNetworld® consulting available in the market place.  Some companies just provide data maintenance and document processing services, which means that they simply take care of drafting cookie-cutter safety programs and uploading them into ISNetworld® for you.  Monitoring of your information is usually available for a quarterly or annual fee.  Other companies will offer enhanced safety services on a monthly or quarterly basis (for example, safety meetings, OSHA representation,  and accident investigations), and some will offer turn-key, full service safety management services for your company.  Make sure you understand what you are getting when you sign on with your consultant, and that they are qualified to provide the level of support your company needs.
  3. Check your potential consultant’s references and reputation.  Referrals from your industry peers are a great source of names of potential consultants, as well as local safety organizations, such as your local chapter of the American Association of Safety Engineers.  If you are unsure, don’t hesitate to ask for client names and references. Your ISNetworld® compliance grade directly impacts your company’s bottom line, so make sure the consultant you are hiring is competent.
  4. Remember that safety management is about more than just your ISNetworld® compliance. A good safety consultant can help you understand and comply with OSHA requirements, improve your safety record, and maintain your company’s reputation as a safe company to do business with and work for.
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Hurricane Planning as Part of Emergency Action Plan

Hurricane Planning is essential to an organization’s emergency action plan. There are five hurricane categories cleverly nicknamed: Cat-1, Cat-2, and so forth. Likewise, there are five hurricane planning categories: prepare, train, respond, recover and learn. Let us journey through those categories in an effort to achieve success with our organization’s continuity of operations.

Prepare

An emergency action plan (EAP) is essential for an organization to respond to any emergency. Does your plan account for hurricanes? Does your organization reside in a geographical area prone to such natural disasters? Proper preparation for natural disasters, such as hurricanes, is a way for your organization to be more proactive towards a safer and healthier workplace. One step to proper preparation is to hold a discussion. Gather your managers, supervisors, and front-line employees to discuss your current plan and check for any necessary additions, changes, or updates needed. How about a chain of communication? Do you have emergency contact information for every employee? How is this information stored? Electronic records can fall victim to power outages while written documents can fall victim to flood waters.

From the CEO to your front-line employees, your chain of communication should be solid and not run the risk of being blown away by catastrophic winds. How about your first aid kits, emergency supplies, and fire extinguishers? Some organizations operate on a 24/7 schedule and, in the event of a natural disaster, would have plans to maintain operations during the event. These plans must include securing the essential necessities for your essential personnel.

Train

Any hurricane action plan is potentially a notorious paperweight if your organization does not take the time to practice the plan with drills or scenario discussions. If your organization has alarm systems – test them. If your organization has automated call or text services – test them, too. Hands-on training will allow your organization to succeed on so many levels, not the least of which will empower your employees to practice new skills and find ways to continuously improve overall. You must remember that employees have their own way of learning. Avoid forcing complicated topics that can destroy an employee’s confidence and above all – destroy your organization’s overall success.

Respond

A hurricane watch indicates storm effects within 48 hours while a hurricane warning indicates storm effects within 36 hours. Unlike other natural disasters, hurricanes are predictable, trackable, and give organizations enough time to respond to the recognized hazards associated with weathering a storm. Organizations should monitor reliable weather information for the latest details. When a hurricane is imminent in your area, organizations should begin securing their facilities and bringing outdoor objects indoors.

Non-essential personnel need to remain at home until it is safe to travel back to work. Essential personnel, especially those who will have to remain on site during a storm, should check their emergency supply kits. Three to five days is key. Three to five days is the amount of supplies you need per employee. Water, food, clothing, and toiletries top the list and should be able to survive a power failure. First aid kits, flashlights, radio, extra batteries, full tank of gas in your vehicle, and extra cash should not be missed. These supplies will reassure essential personnel that their hard work to keep operations going will not fail and business as usual will return sooner rather than later. Once the storm passes, the recovery process follows and organizations need to be ready for a new storm.

Recover

The storm has passed and your facility and surrounding neighbors are without power, covered in fallen trees or worse, and drowning in contaminated flood waters – what next? Keep monitoring reliable weather information for the latest details. Hurricanes tend to strike when the heat is on, so when the power is off, your organization needs to take the necessary precautions against heat-related health problems. Employees exposed to excessive heat can quickly suffer from heat exhaustion or a heat stroke. Employees should stay hydrated and rest frequently. Your organization should recognize the hazard of carbon monoxide (CO) poisoning if portable generators are put in place. CO is a colorless, odorless, toxic gas and employees have died from CO poisoning because their generator lacked ventilation needed to avoid tragedy.

Employees should use flashlights, instead of candles, to avoid potential fire hazards. Fallen trees are often dealt with by chain saws. Personal protective equipment and proper procedures are essential for the safety and health of employees involved in chain saw operations. Flooding is especially imminent for those organizations further inland. Health hazards from water contamination, electrical hazards from underground or downed power lines, and safety hazards from wading through flood waters are all associated with flooding. Employees should keep away from flood waters.

Now that power has been restored, debris has been cleared, and flooding has receded – what next? Your facility is up and running, but has your organization returned to normalcy? Coping after a traumatic event and recognizing signs of distress are essential during the recovery process. Your ‘Continuity of Operations Plan’ should include ensuring that every employee’s safety and health is closely monitored.

Every employee needs to take care of themselves, avoid excessive media coverage, and know they can ask for help. Organizations should recognize common signs of distress, such as: energy changes, concentration difficulties, and appetite changes. Recovery can take days, weeks, months, or even years. The emotional toll of hurricanes can easily be overwhelming. Organizations and their employees are on the journey together, so let’s be there for each other. We prepared, responded, and recovered from the storm. What did we learn to survive again?

Learn

Any well executed plan deserves to be reviewed, scrutinized and revised accordingly by any successful organization. Gather your managers, supervisors, and front-line employees again to discuss your plan’s successes and failures. Organizations should consider presenting their findings to their entire workforce. A company lunch or dinner event is a great way to bring everyone together both socially and responsibly. Involving employees everywhere in the learning process will result in the entire organization’s ability to survive the next storm.

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5 Tips to Prevent Workplace Slips, Trips, and Falls

According the US Department of Labor slips, trips and falls account for the majority of accidents that occur within general industry. Typically these types of accidents occur due to a loss of traction between ones shoe and the walking surface or when inadvertent contact with a fixed movable object occurs which may lead to a fall. Most slip, trip and fall incidents are preventable with general precautions and safety measures.

Here are five tips to prevent workplace slips, trips and falls:

  1. Create Good Housekeeping Practices—Plan ahead and know what needs to be done and who is going to be doing what in particular work areas, assign responsibilities, and implement a program that establishes good housekeeping procedures as part of daily routines.
  1. Reduce Wet or Slippery Surfaces–Traction on outdoor surfaces can change considerably when weather conditions change. Such conditions can then affect indoor surfaces as moisture is tracked in by pedestrian traffic. Traction control procedures should be constantly monitored for their effectiveness.
  1. Create and Maintain Proper Lighting—Poor lighting in work areas is associated with an in increase in incidents so always use proper illumination in walkways, stairways, ramps, hallways, basements, construction areas and dock areas and always keep areas around light switches clear and accessible. Repair fixtures, switches, and cords immediately if they malfunction.
  1. Wear Proper Shoes—The shoes employees wear can play a big part in preventing falls. Employees should be expected to wear footwear that is appropriate for the duties they perform.
  1. Control Individual Behavior—Employees should make all efforts to stay alert and pay attention to their actions and their surroundings. Taking shortcuts, not watching where one is going, using a cell phone, carrying materials which obstructs the vision, wearing sunglasses in low-light areas, not using designated walkways and speed are common elements in many on-the-job injuries.
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Consequences of Failure To Manage OSHA & Environmental

Failure To Manage OSHA & Environmental Compliance Could Destroy Your Business

Many people will read the title of this video (Non Compliance Could Destroy Your Business) and think “that’s ridiculous, how could non-compliance possibly destroy a business?”  If you’re one of these people, and especially if you’re a small business owner, then maybe you should think again…..

As I explained in part 1 of this 3 part video series which explores the major compliance risks facing small businesses, most small companies who are impacted by EHS regulations really struggle to manage them due to the lack of expertise, time, money and resources that is so prevalent with small companies.

Most small business owners are aware of this challenge, but what many don’t understand are the significant risks and liabilities that that this situation can create not only for their business, but sometimes for them personally if something goes wrong.

These risks and liabilities are major and can include regulatory fines and penalties, from agencies like OSHA, EPA and TCEQ, that can run into the $tens or even $hundreds of thousands of dollars (for example, did you know that the average OSHA inspection results in a $30 – $80,000 fine?), and sometimes civil and even criminal liabilities for the business owner if it can be proven that the owner was negligent in managing their environmental, health and safety compliance requirements.  Criminal negligence can result in civil judgements that can run into the $millions of dollars and even jail time.

It’s not hard to imagine how these situations could potentially destroy a business……

The other major thing that many business owners don’t understand is that these kinds of situations happen every single day across the country, when employees get seriously injured or even killed on the job, or when regulators show up in the lobby unannounced.

Unfortunately throughout my career I’ve witnessed these kinds of devastating scenarios playout with associates who I’ve known personally.  I saw a client go to jail for failing to manage hazardous waste management regulations, another face a multi-million civil lawsuit after a subcontractor was killed, and many face huge regulatory fines and penalties.

My point is that these situations are more common than you think, and could happen to you tomorrow if your company is out of compliance and you put your head in the sand and keep putting-off action.

The good news is that the situation is far from hopeless, and there are simple steps that you can take today to get back on track and on the road towards compliance.  Checkout this video to learn more about these risks and more importantly, what steps you can take today to manage and reduce them.  Push the play button before it’s too late!

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