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OSHA Considers Good Faith Efforts in Pandemic

From the start of this world-wide pandemic, employers have faced challenging times trying to keep up with the safety of their employees, as well as OSHA regulations.  With business being closed, travel restrictions, and shelter-in-place requirements, people who normally provide training or audits, inspections, and other industrial hygiene services may be limited.  Employee training may also be lacking during this time due to other restrictions.

The April 16, 2020 OSHA Enforcement Memo stated:

“For example, the American College of Occupational and Environmental Medicine issued a recommendation that occupational spirometry testing be suspended because of concerns about spreading droplets containing the COVID-19 virus during spirometry maneuvers.  In addition, the Council for Accreditation in Occupational Hearing Conservation issued a recommendation that audiometric evaluations be suspended until normal operations have resumed, in order to minimize the risk to healthcare workers and conserve personal protective equipment. “

What Happens if You’re Inspected?

If an OSHA official were to show up at your site, don’t panic.  During their inspection, the workplace will be assessed for efforts to comply with standards that require annual or recurring audits, training, or other assessments.  The compliance officer will determine whether the employer has made good faith efforts to be in compliance with applicable OSHA standards.   If there are situations where compliance simply was not possible, it is the employer’s responsibility to ensure that employees were not exposed to hazards where they were not properly trained.  Another element of the evaluation will be looking to see if all options were exhausted to try and comply with applicable standards. Was virtual training an option?  Were engineering or administrative controls used?  If training was scheduled, was it rescheduled?

The memo also stated:

“In instances where an employer is unable to comply with OSHA-mandated training, audit, assessment, inspection, or testing requirements because local authorities required the workplace to close, the employer should demonstrate a good faith attempt to meet the applicable requirements as soon as possible following the re-opening of the workplace. “

When Could You be Cited?

If an employer cannot show any efforts to have complied with the standard, a citation may be issued.  However, if the effort was made to comply, the area officer will take the detailed notes and documentation of all efforts made into consideration during their decision to cite a violation.

Are Corrective Actions Needed?

The answer is yes!  Once normal activities resume, OSHA will conduct a monitoring inspection from a random sample where violations may have been noted but not actually cited.  OSHA states, “To accommodate this, CSHOs shall enter the code N-10-ABATEMENT DEFERRED in the OSHA Information System to denote such cases.  Additional guidance on monitoring will be provided at a later date.”  This is in effect immediately and will be until further notice.

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Why Get a Third-Party Safety Plan Review?

After you complete your safety plan, you will have the option for a third-party review. What is a third-party safety plan review and why would you need one?

Last year, OSHA citations given numbered over 3,600 related to programs. Safety plans are an important part of a company’s overall safety program and provide a handbook for how the company handles a particular safety issue. It’s one of the very first things that a compliance officer will ask to see when he/she arrives onsite, so they are a very visible part of your compliance efforts. Not only are they important to have, but how thorough and correct they are is just as important. This is where third-party reviews come in.

As a Third-party review 1 Stop Compliance can:

  • Give You Another Set of Eyes, With Experienced Eyes
  • Make Sure All Elements Are Covered
  • Help Give You Ideas To Strengthen Your Plan (or Determine Where You May Be Over Committing)
  • Provide an Extra Level of Credibility

Having an unbiased, experienced third-party review may provide additional level of credibility to help show regulators that your company wants to make the extra effort to be complete. From our experience, success with OSHA inspections and visits can be boosted by attitude towards compliance. Any time your company can show a sincere effort to do all you can to be compliant, it will appear very favorably for your company to the regulator.

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3 Elements of a Good Safety Program

OSHA identifies the following three main elements of an effective safety and health program.

Management Leadership

Successful programs all begin with management commitment.

There are a number of ways management can show their commitment besides financial and resource support. They can factor safety into plans and decisions of the company from construction/renovations to process changes to company policies. Management can also establish rewards and recognition programs for safety participation and achievements as well as making safety a daily part of conversations. At every company event or meeting, a moment can be made available for safety. Safety goals, expectations, achievements, and even the incidents and near misses need to be highlighted through company communication channels.

Worker Participation

Genuine worker participation efforts need to ensure workers feel comfortable about speaking up when issues are found or injuries happen.

You can encourage worker participation through involving them in program design elements, job hazard analyses, site inspections and incident investigations. Programs which allow workers to assess the safety of themselves and those around them are helpful, as are tools for reporting near misses and incidences of good safety practices.

Finding and Fixing Hazards

A strong safety program finds issues and resolves them before they become an issue.

Take a look into your incidents and determine what is the root cause of those? Are you continually having the same issues in your near misses? What are the injuries in your OSHA 300 logs? Is there a correlation? If there are similarities, then you have a place to start. Involve workers and solicit their ideas in how to make those operations safer. Is there a way to do things differently with minimal efforts and investments? Use the hierarchy of controls when determining solutions. Is there a way to remove the hazard completely? Are the controls you currently have in place working or do they need to have some reevaluation?

So How Do You Get It All Accomplished?

There are a lot of pieces that will need to be accomplished. Consider using 1 Stop Compliance as a resource for getting some of these pieces completed.

We have assisted hundreds of companies with their safety programs and have been involved in strengthening safety cultures and putting program elements in place. Not only can iSi be an extra set of hands, but sometimes in developing programs, an experienced third-party to lend ideas or even serve as a mediator can be helpful.

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5 Things to Look at When Hiring a Safety Compliance Consultant

You have decided to become members of a safety compliance system! No matter which safety compliance system you chose, ISNetworld® (ISN®), Avetta, PEC Safety, BROWZ, Gold Shovel Standard, or Veriforce, you chose correctly.  Most likely you chose the safety compliance system for one of two reasons: first, you were required to become members and become compliant in order to keep working for your client, or two, you are being proactive and preparing your company to qualify for work for a hiring client.  Regardless of your intent, you are on the right path! And by now you probably figured out this is a big task for a busy individual like yourself.  So, has the thought of hiring for compliance help crossed your mind? If so, you probably asked yourself where do I start and what do I look for in a consultant?  Your time is precious you have a lot to complete and people to keep safe.

Your quick guide to hiring the right consultant for your compliance assistant the first time around is within your reach.

  1. Financially acceptable- be don’t break the bank! Be careful! There is a wide range of pricing for exactly the same compliance service.  DO YOUR RESEARCH.  Get several quotes from safety service compliance companies.
  2. Personal Experience- Find a compliance consultant who knows ISNetworld®, Avetta, PEC, BROWZ, Gold Shovel Standard, or Complyworks.
  3. Quick turnaround- safety compliance services who have streamlined their processes are going to provide you with a quick turnaround. So find one who can work with your needs.
  4. Get a contractual agreement – just as any legitimate business your safety compliance consultant should supply you with contract/Master Service Agreement.
  5. Communication- many safety service companies overlook this critical element.  But in relation to the sensitivity involved in the ISNetworld®, Avetta, PEC Safety, BROWZ, Gold Shovel Standard, or Complyworks accounts, it is crucial to have your safety compliance consultant communicate with you and act in your best interest.  A good safety compliance consultant will troubleshoot your lower grades on a periodical basis and stay in communication with you to commit to a game plan in increasing your grades.

Ultimately seek out a Safety compliance consultant that is on top of your accounts and available to your calls.  They should be capable of assisting you in growing your business through your ISNetworld®, Avetta, PEC Safety, BROWZ, Gold Shovel Standard, or Complyworks.

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How OSHA Fines are Calculated

There are maximum and minimum amounts, but most fall somewhere in between.  Let’s look at how OSHA fines are calculated.

The Violation Categories

Serious violations are considered high, medium or low severity.  Other-Than-Serious violations are minimal severity.

Willful violations are cited when employers knowingly fail to comply or when they act with indifference to employee safety.

Repeated violations occur when an employer has been previously cited for the same or substantially similar condition.  For serious violations, these are ones that have been a part of OSHA’s regionwide inspection history where an OSHA Notice was issued within the past 5 years.  For other-than-serious violations, it’s for those where the establishment being inspected received an OSHA Notice within the past 5 years.

The Posting Requirements violation is issued when you fail to follow through on your requirement to post your OSHA Notice at or near the place where each violation occurred for 3 working days, or until the hazard is abated (whichever is longer).

Failure to Abate violations occur when you receive a Notice of Unsafe or Unhealthful Working Conditions and a follow-up inspection finds that you did not do your required posting, did not correct the violation and/or did not adequately protect employees and make appropriate progress in correcting the hazard before the abatement date that was listed on your notice.

Calculating Violation Amounts

There are a number of factors that actually can determine how much your penalty will be.  There are four major categories of factors that go into the calculation:

  • Gravity of violation
  • History of violations
  • Good faith efforts of the employer
  • Business size

Gravity Based Penalty Amounts

First, the gravity of the violation is calculated.  The Gravity Based Penalty (GBP) Amount looks at the level of severity (low, medium and high) and the probability, that is likelihood an injury or illness will occur (greater or lesser).

Severity + Probability = Gravity Based Penalty Amount

History Reductions

Combined or grouped violations can be considered one citation item. Multiple violations of the same standard can also be combined into one citation item.  Expect the one with the highest gravity factor (severity or probability) to be used to determine the GBP.

A 10% reduction in penalty costs can be given to companies who have been inspected by OSHA and have had no serious, willful, repeat or failure-to-abate violations.  If your company hasn’t been inspected within 5 years, you’re not eligible for this discount.  If you’ve had a serious high gravity citation that became a final order, you could actually see a 10% increase in your costs.

Good Faith Reductions

A maximum discount of 25% can be given for good faith efforts.  The maximum 25% discount requires you to have a written health and safety management system.  This would include a system outlining:

  • Management commitment and employee involvement
  • Hazard identification worksite analyses
  • Hazard prevention and control measures
  • Safety and health training
  • Addressing needs of workers less than 18 years old (if applicable)
  • Addressing needs of workers who speak limited or no English (if applicable)

A 15% reduction may be given if the employer has a documented and effective safety and health management system with only incidental deficiencies.

Good faith discounts will NOT be given for high gravity, willful, repeated, and failure to abate violations, or if you’ve reported a fatality, inpatient hospitalization, amputation or an eye loss.

Business Size Reductions

A maximum 70% reduction can be gained based on your company size.  OSHA wanted to create a scale where they could minimize the impact to small businesses.  This reduction applies to businesses with 250 or less employees total nationwide.   Companies with 1-10 employees can get the 70% reduction, 11-25 employees a 60% reduction, 26-100 is 30%, and 101-250 is 10%.

Quick Fix Reductions

If you’re able to make an immediate correction to an individual violation and that correction is 1) permanent or substantial (e.g., not just moving someone out of the way), 2) not blatantly obvious (e.g., wearing a hard hat or safety glasses), and 3) not a high gravity serious/willful/repeat/failure to abate violation, you can get a 15% Quick Fix reduction.  This one is applied after the good faith and history adjustments are made.

Limits of Discounts

Different discounts can be rescinded or altered depending on the circumstance or type of violation.

Repeated violations will only be reduced for size.  Repeated violations can actually have their penalties increased, and those increases are also based on size.

Willful violations are only eligible for a size and history discount.  Willful violations have their own size chart of reduction percentages.

Serious violations classified as higher severity/greater probability are only eligible for the size and history.

Other Penalties

OSHA has additional calculation guidelines for a number of other circumstances including:

  • Unabated violations;
  • Daily penalty multipliers;
  • Partial abatements;
  • Violation-by-violation egregious penalties;
  • Multi-employer worksites;
  • Federal Agency significant cases;
  • Failure to post citations;
  • Failure to notify authorized employees of an advance notice of inspection;
  • Injury and illness reporting and recordkeeping;
  • Failure to provide access to medical and exposure records;
  • Failure to notify and tag; and,
  • Failing to certify abatement.

You can find all of the details about these penalties and reductions in OSHA’s Field Operations Manual section on penalties.

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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:

____________________________________________________________________

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.

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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What to Know About ISNetworld RAVS

ISNetworld® will be reviewing all of your information with a fine-tooth comb to make it easy on yourself and them by implementing these easy steps to assist in expediting the review process.

  • RAVS® safety programs can easily be created for first-time approval.

Implement the following steps to first time RAVS® safety compliance.

We suggest you create the majority of the RAVS® programs that ISNetworld® requires for your Hiring Client.  Although some Hiring Clients will allow a variance on some of these programs, this will need to be taken up directly with your Hiring Client. However, since these RAVS® safety programs are dictated by your Hiring Client as being streamlined for all of their sub-contractors we suggest you go ahead and create these programs.  Following the steps below will enable you to easily create and gain approval.

Simplicity is key! An Ideal ISNetworld RAVS safety program is under 10 pages

  1. Evidence – each question asked by ISN® within your RAVS® safety program.
  2. Customize – address your full company name within the RAVS® safety program.
  3. Include the training sheet specific to each program within the RAVS® safety program.
  4. Insert page numbers.
  5. Insert your company name within the footer.
  1. Next is where your hard work creating the simplistic RAVS® safety program pays off.  The United States Questionnaire MSQ® is user-friendly so go through the questionnaire and answer the questions about your safety program – identify the page number in which each question being asked is addressed within.
  1. Review– once your account documents are submitted the review process begins and depending on the documents being review it will take anywhere from 2 days to 2 weeks to complete the review.  Your Hiring Client has the power to authorize a speedier review so contact your hiring client to see if they would mint calling ISN® to request expediting the review.

After review- Troubleshoot your grade- once your grade has been determined after the review take a closer look at your grading components and review the gap report in ISN® This will show you exactly what areas in your safety program that are affecting your grade. There are some components in ISNetworld® you cannot control and need to be discussed and troubleshot with your Hiring Client

The ISN® grading components weigh differently on general areas of concern for your Hiring Client. Go through the gap report one by one and incorporate any areas you left void or where you marked as ‘No’ – these areas are clearly important to your ISNetworld® Client. Changing an answer may incur more RAVS® safety programs to be created.

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1 Stop Attends iiAR EXPO 2019

1 Stop Compliance attended the annual IIAR Natural Refrigeration Conference & Heavy Equipment Expo in Phoenix, AZ, which featured technical and efficiency education programs, as well as over 150 exhibitors on site.

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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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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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