Compliance Services

Part of every organization’s best practices is annual safety training, not only a best practice but many of them are required by OSHA standards. While not all are required a handful of them are, and we have a list to help you find out which ones those are.

• Employee Access to Medical Records
  • Annual notification for employee access to medical records is required. As a company you’re required to inform workers of their rights to access their medical records, where they’re kept, how to obtain them and who is responsible for keeping them.
• Respiratory Protection and Fit-Testing
  • Employees wearing respirators or participating in your company’s respiratory protection program are required to receive annual training regarding respirator use, care, inspection, maintenance, limitations and other requirements.
• Hearing Protection
  • If your employees are exposed to noise at or above an 8-hour time weighted average of 85 decibels, your company is required to have a hearing conservation program.
• HAZWOPER
  • There are various levels of HAZWOPER. Those with 24 and 40 hour initial training are required to have 8 hours of training annually per year.
• Bloodborne Pathogens
  • Anyone who could have bloodborne pathogen exposure is required to have annual training and additional training whenever procedures and tasks are changed.
• Fire Extinguishers and Fire Brigades
  • If your company houses an internal fire brigade that fight fires beyond the incipient stage, all fire brigade members are to be provided with annual training. Any members who are required to conduct internal structural firefighting are to have quarterly educational sessions or training as well.
• Asbestos and Other Chemical and Substance-Specific Training
  • Employees with potential exposures to OSHA 1910.1003’s 13 carcinogens, vinyl chloride, polyvinyl chloride, inorganic arsenic, lead, cadmium, benzene, coke oven emissions, cotton dust, acrylonitrile (vinyl cyanide), ethylene oxide, formaldehyde, Methylenedianiline and 1, 3-Butadiene are required to have annual safe usage training.

Other Topics to Cover:

Mechanical Power Presses – Operators of mechanical power presses with the Presence Sensing Device Initiation (PSDI) mode on them are required to have annual operator training.

Agriculture Industry – In grain handling facilities annual training is required for workers at grain handling facilities. Topics to be covered include:

• Dust hazards
• Dust accumulation
• Ignition control and prevention
• Cleaning/clearing/housekeeping procedures
• Hot work procedures
• Preventative maintenance
• Lockout/tagout
• Bin entry
• Engulfment hazards (for those entering bins).

For other agriculture-related workplaces where employees are required to use tractors, annual training regarding rollover protective structures is required and those using farm field equipment, farmstead equipment and cotton gins are required to have safe operating and guarding training annually.

Logging Industry – Supervisors and employees in logging industry operation are required to have annual CPR training, with first aid training every 3 years.

Forklift Recertification – Because of their prevalence in industry, we thought we’d also mention that forklift recertifications are due every 3 years as is refresher training for Process Safety Management.

Lockout/Tagout – Not necessarily a training requirement, but an annual requirement nonetheless, employers are required to review their energy control procedures at least annually to ensure the procedure and the requirements of the lockout/tagout standard is being followed.

Need help with getting safety training or safety programs written? Contact 1 Stop Compliance today to start the process and talk to one of our staff members to start.

OSHA issued a compliance directive on June 30th, designed to ensure uniform inspection and enforcement procedures for its Emergency Temporary Standard to protect healthcare workers from occupational exposures to COVID-19.

The new directive provides OSHA compliance safety and health officers with guidance and procedures on how to enforce the standard’s requirements for:

• Written COVID-19 plan
• Patient/Non-employee screening and management
• Personal protective equipment
• Aerosol-generating procedures
• Physical distancing
• Physical barriers
• Cleaning and disinfecting
• Ventilation
• Employee health screening and medical management
• Vaccination
• Training
• Anti-retaliation
• Requirements at no cost
• Recordkeeping
• Reporting to OSHA

The ETS became effective June 21, 2021. Employers must comply with most provisions by July 6, 2021, and with training, ventilation, and barrier provisions by July 21, 2021.

Learn more about the COVID-19 Healthcare ETS.

Contractor pre-qualification programs give companies a way to limit the liability risks that onsite contractors can bring. If you want to work for clients who use these programs, you must pay the cost to be a member and then take the time and effort to enter your company information into the system. At first glance, ISNetworld setup can be a daunting task. To help get you prepared, we present the Top 10 items you’ll need to gather for ISNetworld compliance.

1. General Company Information

You will need to know basic information about your company such as date established, structure, addresses and contacts, special codes and numbers (NAICS, Tax ID, DUNS – SAM, etc.), number of employees, financial and project references and more.

2. Safety Policies and Procedures

You will be asked a number of questions about your safety policies. How is your safety program set up, how is it built and who’s responsible?  What’s the management structure and is company leadership involved?  Are hourly employees involved and do you have full-time safety personnel?  What training do supervisors get? Do you do audits, who does them and how often?

Also included are questions about safety meetings, training, documentation, observations, stop work policies, hazard reporting, policies for new hires, incident investigation and communication.

3. Written Safety Programs

If you’re following OSHA compliance, you should already have written safety programs for the hazards your employees can be exposed to. Depending on the services you say you provide, ISNetworld and your client will generate a list of the individual written safety programs that you need. There will be specific elements that you’ll be required to incorporate into your written programs, so it’s likely you’ll need to update your programs. Be very mindful what your revised program commits your company to. If it’s written in your program that your company will do something, you need to do it. If not, you could expose yourself to fines from OSHA for not following your own plan.

ISNetworld will ask you every 3 years to revalidate these programs to ensure they are still current.

4. Training Programs

For many of the written programs, you’ll be asked to upload corresponding training sign-ins and information from those classes, so you may need to conduct additional training on a variety of topics. Be prepared to answer questions related to what kind of training you provide to new hires and routine employees, how often and how they are documented.

5. Regulatory Data

You will need to track OSHA injury and illness data on a quarterly basis. This information is required to be input both quarterly and annually. You’ll also need 3 years of historical data. In ISNetworld you are graded on your 3-year average safety numbers and how they compare to industry standards. Thus, if you have a bad year, your grades may suffer for 3 years.

If you have commercial vehicles, you may need to enter DOT numbers and annual stats for number of drivers, miles driven, number of units, owner operators and violations. You’ll also need to enter in information about your company vehicle/driver programs and policies.

6. Insurance

Individual insurance certificates will need to be uploaded for each client, and each will have specific requirements.  Be mindful of what the insurance requirements are for each client and know ahead of time what policies you have and what that covers.  Sometimes clients will require specialized policies or varying levels of coverage for certain items that can end up costing thousands of dollars if you agree to that.  However, sometimes these things can be negotiated down, depending on what you’re going to do onsite.  It just depends on the client and the situation.

Check with your insurance company to see if they’re a member of ISNetworld. If so, you can assign them to your account and they can upload certificates and deal with the nuances and negotiations for you. You will also need to enter 3 years of experience modification rate data and upload those documents as well.

7. Employee and Contractor Data

Some clients will require you to track the number of hours that you and/or your subcontractors spent on the site each month.  These reports are required at the beginning of the month and are often required per site location.  Among the data you may need to report (depending on client requirements) will be hours spent onsite, number of employees onsite, number of miles driven, number of incidents (accidents, fires, spills), subcontractor hours, subcontractor numbers, subcontractor travel data, etc.  Some companies need to keep track of this information for PSM purposes and some like to keep track of contactor activities onsite.

8.  Human Resources-Type Information

You’ll be asked to input your drug and alcohol policies and procedures.  Some owner clients will require you to have individual employees tested for drugs and alcohol through one of their approved vendors who shares the data directly with the program so that they can see if employees are in a green “OK” status or a red status.  They may also require background checks for each employee who will come onsite as well.   You may also need to provide employee personal information separately to your client to comply with Department of Homeland Security checks as well.  Pandemic preparedness programs are required from many clients, so what are your procedures and policies with that?  Thus, you may need to pull in some of your HR department to help you accomplish some of these requirements and get some answers.

9. Other Procedures — Sustainability and Cyber Security

Within the past year we’ve seen questions pop up in ISNetworld and throughout multiple programs about our corporate sustainability and social responsibility programs.  One program (not ISNetworld) required us to write a separate written policy statement against human trafficking and a written policy on our stance on child and forced labor.  ISNetworld has also started getting into cyber security policies. There is an extensive questionnaire regarding computer systems and cyber security measures.  Several owner clients required us to develop a written cyber security program.  So besides HR personnel, you may need to bring in your IT people and anyone responsible for sustainability programs.

10. Individual Training

More and more clients are requiring individuals to do the facility-specific safety orientation training ahead of time before ever stepping onsite.  Thus, if you have a specific project that you’re getting ready for, you may need to know exactly who is going to be involved in the project so that you can assign this training to them.  This would include subcontractor employees too.  Some clients will let you do the training all at once in a group, but more and more are requiring individuals to be given separate logins so that they can complete the training themselves.  So you may need to eventually gather email addresses for individuals who may not have a company email address and budget for time for those employees to take that training.

Working as a 3^rd Party Safety Consultant provides an in-depth exposure & understanding of the OSHA regulations as they relate to our clients. In this field, we work and develop relationships with clients spanning a wide range of industries, from manufacturing & construction to agriculture and mining. The following list of regulations is the most common we have seen clients cited for over the years.

1. Fall Protection 1926.501 (Construction)
2. Hazard Communication 1910.1200
3. Scaffolding 1926.451 (Construction)
4. Respiratory Protection 1910.134.
5. Lockout/Tagout 1910.147
6. Ladders 1926.1053
7. Powered Industrial Trucks 1910.178
8. Machine Guarding 1910.212
9. Personal Protective Equipment – Eye and Face Protection 1926.102 (Construction) 1910.133 (General Industry)
10. Respirable Crystalline Silica 1926.1153 (Construction) 1910.1053 (General Industry)

Examining Your Own Work Place

This year it is time to look at your own workplace and see where solutions can be found.  These violations are very common and have been prevalent in the American workplace for a long time. This is now the 9th year in a row that Fall Protection has been the #1 most cited violation. The answers & solutions to maintaining OSHA compliance are out there, but it’s all about finding the best solution and implementing it.

Now is the Time for Change

Now is the time for change within your company’s safety culture.  With OSHA actively inspecting workplaces & job sites looking for Fall Protection and Silica violations to name a few, how can these companies make OSHA compliance a top priority?  The major step that needs to be completed is having an in-depth workplace evaluation conducted.