Training - part 2 of 2.

As we covered in Part 1, OSHA requires training at two times.  The “initial assignment” part is simple: employers should train employees before they begin to work.  Most employers off an orientation session to show new employees where to park, how to report work hours and what to do if they are ill.  The orientation is a good time to conduct basic safety training.  Show new employees how to recognize hazards and what work rules apply regarding PPE and other safety requirements.

The second time training is mandated is when changes occur.  Generally, if the employee is assigned to a different location or task, training is required to inform the employee of new hazards.  If new hazards are introduced, the employee must be trained to deal with the new perils.  Finally, if new safety standards are applied, the worker must be made aware of the new requirements for compliance.

Sometimes special training is required.  Workers may be assigned a task that requires special skills such as welding or machining or acting as a First Responder, reacting to various emergencies.  The law is not exactly clear on the requirements for training workers for these special tasks other than requiring that the worker be competent.

Specific training required for operators of cranes, forklifts, trucks and other equipment under the class called PIV – Powered Industrial Vehicles.  If the vehicle is to be operated on public roads, licensing by the proper authority is required. Training content for operating vehicles within a company facility is not spelled out.  An operator of a PIV is not required to learn a specific set of skills.  All that is required is that the employer be certain the operator is capable and competent.  Good policy is for a company to have their PIV operators trained and tested, then issue Operator Licenses that can be revoked when violations occur.  An incompetent PIV operator can do a lot of damage to facilities and products.  They can harm many people if he/she does not know what they are doing.

A good training plan defines who is to be trained, the content and schedule of the training.  OSHA frequently looks for training plans and records on their inspections.

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Spotted.

On 12 May, we posted an article about OSHA’s General Duty Clause.  In that post we included a picture of a work site where we listed several violations.  The Spotted posts are now a regular feature of our blogs.

We took the following picture while out running errands.  Two young men were removing the sign of a store which had closed.  We called the company they worked for, the manager said that the company had a solid safety plan and that all workers were required to sign a document promising to follow company safety standards. 

Violations:

1. Failure to wear proper Fall Protection.  Federal law requires employees working at more than six feet (6’) above the lower level to wear PFAS – Personal Fall Arrest System.  A PFAS consists of an Anchor, Lanyard and Harness.

2. Failure to wear proper PPE – personal Protective Equipment.  In this case, Hard Hats would be required because there is a clear hazard overhead.

Presumably, these men have loved ones who would like to have them return safely at the end of every day.  Their health and lives are at risk because their employer has failed to enforce rules written to protect them.

Every day, men and women go to work putting their health and lives in the hands of an employer.  Every day in the U.S., 15 of these workers are killed, leaving a family and friends behind.

Nearly every time we go out, we spot workers in danger.  When we can get a picture we plan to post it here as a Spotted feature.

See hundreds of work-pictures at SafetyPhoto.

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Update: Fall Protection For Residential Builders.

This article is a follow-up to our original post on 10May:  Fall protection for Residential Builders.  Portions in bold added 11 June 2011,

On Thursday, 9 June 2011, 7 days before enforcement of the new Fall Protection For Residential Builders directive begins, following intense lobbying by the NAHB and lawsuits filed to prevent enforcement, OSHA has issued a Trade Release easing the rules for 90 days. 

Fact is that men are dying from falls off of roofs because they are not protected.  The cost to train workers and provide PFAS (personal fall arrest systems: anchors, lanyards, harnesses) is minimal and sure to save lives.  If you or someone you know is building or remodelling a home, insist they protect their workers with Fall Protection.

The three month phase-in period runs 16 June - 15 September 2011. During this time, if the employer is in full compliance with the old directive (STD 03-00-001), OSHA will not issue citations, but will instead issue a hazard alert letter informing the employer of the feasible methods they can use to comply with OSHA’s fall protection standard or implement a written fall protection plan. If the employer’s practices do not meet the requirements set in the old directive, OSHA will issue appropriate citations.

If an employer fails to implement the fall protection measures outlined in a hazard alert letter, and during a subsequent inspection of one of the employer’s workplaces OSHA finds violations involving the same hazards, the Area Office shall issue appropriate citations.

The new directive, Compliance Guidance for Residential Construction (STD 03-11-002), a detailed description of the phase-in policy, a presentation and other guidance materials about requirements for protecting workers from falls are available at http://www.osha.gov/doc/residential_fall_protection.html.

The equipment and training to comply with the directive are suprisingly affordable.  For just a few hundred dollars, reusable equipment can be purchased to fully meet the regulations to protect each worker.  With an extra 90 days, there is not reason to not be in compliance.

SafetyRich can provide Fall Protection training and recommend equipment to help you protect your workers.

See our Web site: SafetyRich

DOL-OSHA removes requirements, streamlines and simplifies standards.

WASHINGTON – The U.S. Department of Labor’s Occupational Safety and Health Administration announced the release of a final rule that streamlines and simplifies standards while reducing employer burdens.  The published rule will help keep OSHA standards up-to-date and better enable employers to comply with their regulatory obligations.

“The final rule is the third in OSHA’s Standards Improvement Projects initiative that periodically reviews OSHA regulations with the goal of improving and eliminating those that are confusing, outdated, duplicative or inconsistent,” said Assistant Secretary of Labor for OSHA Dr. David Michaels. “OSHA estimates that the final rule, without reducing employee protection, will result in annual cost savings to employers exceeding $43 million and significant reductions in paperwork burden hours.”

These updates will be in line with the goals of the president’s Executive Order 13563, “Improving Regulation and Regulatory Review,” issued Jan. 18 to simplify standards and reduce unnecessary regulatory burdens.

The executive order is available at http://www.regulations.gov/exchange/sites/default/files/doc_files/President's%20Executive%20Order%2013563_0.pdf.

The rule will update OSHA’s standards and identify requirements for revision based on an agency review, comments from the public and recommendations from an Office of Management and Budget report. It builds on the

The new rule will result in several changes to OSHA’s existing respiratory protection standard, including aligning air cylinder testing requirements for self-contained breathing apparatuses with U.S. Department of Transportation regulations, clarifying that aftermarket cylinders meet National Institute for Occupational Safety and Health quality assurance requirements and clarifying that the provisions of Appendix D, which contains information for employees using respirators when not required under the standard, are mandatory if the employee chooses to use a respirator.

Other changes to result from the new rule will include updating the definition of the term “potable water” to be consistent with the current Environmental Protection Agency standards instead of the former and outdated Public Health Service Corps definition, removing the outdated requirement that hand dryers use warm air because new technology allows employers to use hand-drying products that do not involve hot or warm air and removing two medical record requirements from the commercial-diving standard because that standard no longer

Updates also will include deleting a number of requirements for employers to transmit exposure and medical records to NIOSH, thus saving NIOSH significant costs to store and maintain the records.  According to NIOSH, these records did not serve a useful research purpose.  The slings standards also will be updated and streamlined by requiring that employers use only slings marked with manufacturers’ loading information.

There will not be any new requirements set by this rule, so employers will be able to comply with it immediately. 

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. For more information, visit http://www.osha.gov.

See our Web site: SafetyRich

Training - Part 1 of 2

Training is required by law.  OSHA requires training, but is rarely specific about what training is required.  In the Introduction to OSHA training session, the first action required of workers is “Read the [OSHA] poster.”  The OSHA poster contains a good deal of information for the worker about awareness and reporting of hazards – the basis of training.

Training is required at two times: 1) On initial assignment; and 2) When the assignment, hazards or standards change.  These two consist of basic safety training, plus training in special skills or hazards for workers who might be exposed to those hazards.  All employees need to be trained in basic safety, but not all workers need training in welding, fighting chemical fires or driving forklifts.

OSHA provides, but does not mandate the content of most training.  The 10-hour or 30-hour courses presented by Outreach Trainers are not mandatory – the content is partially mandated, for issuing cards proving completion of the courses, but the courses themselves are not mandatory.  The 10- and 30-hours courses do present a “shorthand” to describe the content of the courses, thus the understanding that the worker has a base level of knowledge.

In the area of specialized training, OSHA does not mandate content.  The mandate from OSHA is that the employer must be satisfied that the operator has the skills and the hazard and safety rules awareness to be a forklift operator.  More on this subject in Part 2.

A fairly recent development is the requirement for presenting all training in the worker’s Language of Understanding.  The Language of Understanding refers to the primary language spoken and understood by the workers, modified to his/her education level.  Courses must be presented in a language and at a level understood by the workers in the course.  It is a citable violation to do otherwise.

This brings us to discussing Training Records.  Clients and OSHA frequently request training records.  Clients want proof of training to meet internal and insurance requirements.  OSHA looks for proof the employer has met the training obligation.  Failure to properly train can be cited.

Training is the law and has a proven direct and indirect financial benefit in reducing injuries and illnesses. 

See our Web site: SafetyRich

OSHA Visits.

Hardly a day goes by that I do not get an email advertising a seminar on what to do if OSHA makes a visit.  Our suggestion is to offer them coffee.  Realistically, according to OSHA, if an employer has fewer than 50 workers and a DART rate of less than 6, a visit from OSHA is not likely.  On the other hand, if a construction company is conducting unsafe work outside, an OSHA visit is nearly a certainty.

If OSHA drops by, contact your Safety Manager immediately.  If the Safety Manager is at hand, the OSHA representatives are usually willing to wait a short time for him/her to show up.  Do not, under any circumstances, delay the OSHA representative.  You are allowed to have your top safety person and an “employee representative” along on the inspection, but you are not allowed to delay the proceedings.

Every OSHA inspector conducts their visits differently, but most of the time, they will need the same information.  This covers the process of many inspections.  The important thing to remember is that OSHA’s mission is to protect the worker.  If the workers are safe and the employer is complying with the law, there is absolutely nothing of concern.

Be sure the form 300 reporting injuries/illnesses and all training records are current and available.  The 300 report should be current to at least the prior day.  Training records should be fully current unless a class is being conducted.  The law requires training a) on initial assignment and b) if the assignment, work conditions or regulations change; or if new hazards are introduced.  There is no wiggle room here, but the law is quite simple to understand and to meet.

If the facility is a factory or if work is being conducted, the inspector will probably want to walk around the place.  During the inspection, the OSHA representative has the right to speak privately with employees.  As we said above: If the workers are safe and the employer is complying with the law, there is absolutely nothing of concern.

Have a safe work environment, keep training and records up to date, obey the law – OSHA’s visit will be simple, painless and free of citations.  If the inspector does give suggestions on items which need corrected, do them immediately.

Since 1971, OSHA’s mission has been to protect the worker.  To fulfill this mission, OSHA has created standards which must be met – it’s the law.  Protect workers and obey the law.

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Heat Stress

A weather report on Sunday said the we are now officially at the start of a typical Houston Summer: highs temps in mid-upper 90s, low in mid 70s to mid 80s yes, that is a perfect description of a typical southeast Texas Summer.  And many other places around the world, for that matter.

Heat-related illness (Heat stress) happens when the body is not able to cool itself and the body overheats.  Heat stress can cause injury, disability or death, but it is preventable.  OSHA has a strong focus for 2011 and an excellent page dedicated the subject: http://www.osha.gov/SLTC/heatillness/edresources.html.

Be aware of two kinds of Heat Stress: Heat Exhaustion, a serious condition and Heat Stroke, a medical emergency requiring immediate care.  The above OSHA page has a good number of publications in both English and Spanish.  See the OSHA•NIOSH Information sheet at: http://www.osha.gov/Publications/osha-niosh-heat-illness-infosheet.pdf for basic details about prevention, symptoms and treatment of the various heat-related conditions.

Before workers have symptoms is the time to take action with prevention.  Work in the shade wherever possible, make sure the workers have water and drink small amounts frequently.  Sport drinks that replace electrolytes are good, but plain water is best overall.  Sugared and carbonated drinks are better than nothing, but a poor choice for dealing with heat illness prevention.  Take frequent cool-down breaks.  Be most aware (and take more preventive action) when employees are doing heavy work in direct sunlight.

OSHA has clear standards for protecting workers from Heat Stress hazards.  Train your workers in the hazards and in preventing their own exposure.  The resources page above includes information in employee’s “language of understanding” – spoken and educational level.

See our Web page: SafetyRich