$69,058 in Penalties to Goodyear Tire & Rubber Co. for Endangering Employees

The U.S. Department of Labor’s Occupational Safety and Health Administration (OSHA) issued seven serious citations against Goodyear Tire & Rubber Co. for exposing its employees to burn, hazardous energy, amputation, and caught-in safety hazards. The company faces proposed penalties of $69,058.

OSHA investigators inspected Goodyear’s Social Circle facility in August 2017, and found that the company failed to provide effective personal protective equipment to employees exposed to burn hazards; did not provide procedures for controlling hazardous energy during equipment maintenance operations; and exposed employees to burns from heated tire treads, and caught-in hazards from unguarded machines.

“Our inspection found multiple safety deficiencies that put employees at risk of serious injury or death,” said OSHA Area Office Director William Fulcher, in Atlanta. “Potential workplace hazards must be assessed and eliminated to ensure employees are afforded a safe work environment.”

The company has 15 business days from receipt of its citations and penalties to comply, request an informal conference with OSHA’s area director, or contest the findings before the independent Occupational Safety and Health Review Commission.

Under the Occupational Safety and Health Act of 1970, employers are responsible for providing safe and healthful workplaces for their employees.

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Top 10 Items You Need for ISN Compliance

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.

  1. 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.

  1. 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.

  1. 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.

  1. 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.

  1. 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.

  1. 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.

  1.  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.

  1. 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.

  1. 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.

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6 Things You Should Know Before Hiring A Safety Consultant

In today’s marketplace, there is no shortage of “consultants” willing to share their advice for a fee.  But when it comes to your worker’s safety, there are a few things you should know about him or her before you write them a check.

  1. Academic Qualifications – Academic qualifications are important and, as a result, degree programs in safety have become more prevalent in the last decade.  But just because your prospective consultant has a degree in safety doesn’t mean they are a good fit for your company. Of greater relevance is “real-world” experience and results. Look for consultants who have both education and experience.
  2. Professional Organizations & Memberships – This is another potentially confusing area for the average business owner / decision-maker. While some organizations and professional safety designations such as ASSE and CSP are highly reputable and require documented credentials for membership, many are latecomers with questionable standards.  Look for certifications that don’t just require the candidate to sit through a class or pay an application fee to receive a credential.
  3. On-the-Job Experience – Look for evidence that the consultant has previously dealt with problems similar to yours through their previous work history. A capable safety consultant can easily transition among many different industries in applying sound principles of safety management.  Does their experience indicate satisfactory knowledge of both the technical aspects of safety management as well as the “human” factors?
  4. Clients & References– Who are their clients? Are they known to you? Are they established companies? Don’t hesitate to ask for contact names and phone numbers for current (and former) clients. Avoid placing undue weight on any single recommendation. Seek a balanced, overall assessment of the previous work. A great indicator of a valuable safety consultant is when a former employer becomes a current client.
  5. Will they solve your problem? – Certainly, there are never any guarantees. In fact, one should be extremely wary of the safety consultant who “guarantees” that his work will produce a given dollar result.  Explain your problem thoroughly and listen closely to the answers. Do the answers appear to match your needs? Do they speak plain English or do they frequently fall into jargon? If you can’t understand what they’re saying, what good is their advice? Anyone can recite passages from OSHA Standards. The true skill is in understanding and applying them to a client’s individual circumstances.  A competent consultant will explain safety requirements in everyday language and be able to clearly communicate the ways that compliance can benefit your business.
  6. Finally, Insurance – The professional safety consultant cares enough about his business (and the client’s) to protect it with, at a minimum, $1,000,000 of professional liability and $1,000,000 of general liability coverage. He will willingly produce certificates of insurance as evidence of this.  Please note that legitimate certificates are sent directly from the insurance carrier to the client, NOT provided by the consultant. Anyone with a copy machine and a bottle of “white-out” can phony-up certificates of insurance.
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OSHA and ISEA Partner to Protect Workers’ Safety and Health

OSHA and the International Safety Equipment Association (ISEA) today signed an alliance to provide members, employers, and employees with information on how to properly select, use, maintain, and store personal protective and safety equipment.

During the two-year agreement, participants will also share information on developments in national consensus standards for personal protective and safety equipment.

ISEA is a non-profit trade association for protective equipment and technology that helps employees work safely in hazardous environments. The association has partnered with OSHA to share information on Agency campaigns, such as the National Stand-Down to Prevent Falls in ConstructionHeat Illness Prevention, and Safe + Sound Week. ISEA also donated personal protective equipment for workers and volunteers during cleanup efforts following hurricanes in Texas and Puerto Rico.

Through its Alliance Program, OSHA fosters collaborative relationships with groups committed to worker safety and health, such as trade and professional organizations, unions, consulates, faith- and community-based organizations, businesses, and educational institutions, to prevent workplace fatalities, injuries, and illnesses. Alliance partners help OSHA reach targeted audiences, such as employers and workers in high-hazard industries, and give them better access to workplace safety and health tools and information.

Under the Occupational Safety and Health Act of 1970, employers are responsible for providing safe and healthful workplaces for their employees. OSHA’s role is to ensure these conditions for America’s working men and women by setting and enforcing standards, and providing training, education and assistance.

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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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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.


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.


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.


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.


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?


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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Hiring A Safety Consultant For Your ISNetworld® Compliance

If you are looking for help with ISNetworld® compliance, hiring a safety consultant may feel necessary. 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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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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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.


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


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




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.



  • 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.



  • 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.


  • 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


  • 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.




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.



  • 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.



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 Do I Maintain my ISNetworld Certifications?

Managing your ISNetworld® membership will require time and money.  This FREE blog will allow you to prepare and budget your time to effectively help you control your ISNetworld® certification and stay in ISNetworld® compliance. In this blog, we will take you through the grand scale of things to show you what lies ahead.

By now you know that compliance requires time and meticulous attention to detail.  So, whether you gained ISNetworld® compliance and accomplished your certification yourself or decided your time is best spent in busy day-to-day obligations and decided ISNetworld® compliance is quicker if you hire a safety compliance consultant. You still need to be prepared for what lies ahead.

Starting with the basics to keep your company ISNetworld® certified and in compliance include monthly and yearly updates /statistics  as follows;

Monthly updates required by ISNetworld® clients.

  1. Site Tracker®-monthly man-hours, number of employees.

ISNetworld® compliance include yearly updates for;

  1. Certificate of Insurance for Each client
  2. Experience Modification Rate (EMR)
  3. OSHA 300, OSHA 300A logs

Throughout the year you will be required to upload and comply with additional ISNetworld® compliance client requirements.

  1. Client-specific documents – acknowledging site-specific and company-wide sub-contractor conformance.
  2. Additional MSQ® questions.
  3. Additional ISNetworld® safety programs (RAVS®)
  4. Additional ISNetworld® safety training T-RAVS®
  5. Operator Qualification (OQ)
  6. ISNetworld® safety training

However, if you are using your ISNetworld® certification to its full potential meaning, you diligently market your certification to potential clients then there is additional ISNetworld® compliance upon a new client connection in which you will incur as follows;

  1. MSQ®
  2. ISNetworld® safety programs (RAVS®)
  3. ISNetworld® safety training T-RAVS®
  4. Certificate of Insurance for Each client

We hope we have helped and would love to hear from you! You can chat with us online or call 866-399-4593 our friendly customer care team is ready to assist you.

1 Stop Compliance is more than just ISNetworld® compliance if you wish to expand your customer base beyond ISNetworld® we can assist you with your other pre-qualification systems Avetta, PEC Safety, Gold Shovel Standard, BROWZ, Veriforce, CQN, CCS, or Complyworks.

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