Workplace Safety Awareness Council Blog

The Workplace Safety Awareness Council is a 501(c)(3) not for profit organization dedicated to keeping America's workforce safe. We invite you to join our blog and comment. We also invite you to our next series of Free OSHA update training and OSHA Bootcamps.

Monday, August 17, 2009

OSHA Begins to Refocus on Enforcement Activities

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OSHA Begins to Refocus on Enforcement Activities

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We mentioned this a few months ago but its worth repeating and providing an update or two. . .

President Obama put together a report on the upcoming budget and it had some very interesting things to say about the OSHA budget. In particular here is what the report says:

"For the past eight years, the Department's labor law enforcement agencies have struggled with growing workloads and shrinking staff. The President's Budget seeks to reverse this trend. The Budget will increase funding for the Occupational Safety and Health Administration, enabling it to vigorously enforce workplace safety laws and ensure the safety and health of American workers"

On February 17, 2009 the American Recovery and Reinvestment Act of 2009 was signed into law by President Obama. The Act is an extraordinary response to a crisis unlike any since the Great Depression, and includes measures to modernize our nation's infrastructure, enhance energy independence, expand educational opportunities, preserve and improve affordable health care, provide tax relief, and protect those in greatest need.

Well what does this have to do with OSHA?
OSHA role is to ensure that worker protection laws are enforced as recovery infrastructure investments are carried out.

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What This Means For Employers and Their Recordkeeping Responsibilities
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How will OSHA carry out these responsibilities - after all this will cost more money right?

Well thanks to new budgets OSHA is looking at a $27 million increase over previous years budgets and requires OSHA to improve its tracking of workplace injuries and illnesses.

This last sentence is interesting - "requires OSHA to improve its tracking of workplace injuries and illnesses".

The funding increase also contains a $52 million increase for the Bureau of Labor Statistics (BLS), which is aimed at improving the reporting of workplace injury statistics.

Look for OSHA to shortly announce a National Emphasis Program (NEP) on OSHA Injury & Illness Recordkeeping. This NEP is the result of heat OSHA's been taking from a number of corners including a GAO report initiated by Senator Kennedy.

We'll be talking more about this on our blog in September so stay tuned. . .

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Bad Performers Beware: Severe Violators Inspection Program (SVIP)
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Acting Assistant Secretary of Labor for OSHA Jordan Barab announced a new program named the Severe Violators Inspection Program (SVIP) at a recent House Subcommittee in April.

"Some changes under consideration for the program include mandatory -- not recommended -- follow-up inspections, more inspections of other establishments of an identified company, and additional enhanced settlement provisions," Barab continued "The new program will include a more intensive examination of an employer's history for systemic problems that would trigger additional mandatory inspections".

He also told the House subcommittee that he's suspended the practice of setting goals for new VPP sites and Alliances to direct OSHA's resources instead to enforcement.

This new program is a welcome additional to OSHA's arsenal directed to the bad performers -

The question is:

Are you on the list (or will you land on it in the future) and what will you do to stay off the list?

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Monday, August 3, 2009

Heat Stress & Employers Responsibilities

Earlier this year I was conducting training in Dubai and what I remember as I got off the plane and waited for my taxi was the intense heat - at midnight! I'm from Florida and quite used to hot weather but this was different, Dubai after all is a little slice of concrete paradise carved into the desert and the temps reach 120 degrees without a blink.

Because of these unbearable temperatures, Dubai passed laws that outside work may not be performed between 11:00am and 2:00pm. This was to serve as a protection from the heat. Not a bad idea, but what about your business. Shutting down work may be a bit extreme, so what other precautions can you take - and how does OSHA view your responsibility to protect workers from heat?

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First - what are symptoms of of a heat exposure problem?
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Symptoms of Heat Exhaustion

* Headaches, dizziness, lightheadedness or fainting.
* Weakness and moist skin.
* Mood changes such as irritability or confusion.
* Upset stomach or vomiting.

Symptoms of Heat Stroke

* Dry, hot skin with no sweating.
* Mental confusion or losing consciousness.
* Seizures or convulsions.

Preventing Heat Stress

* Know signs/symptoms of heat-related illnesses; monitor yourself and coworkers.
* Block out direct sun or other heat sources.
* Use cooling fans/air-conditioning; rest regularly.
* Drink lots of water; about 1 cup every 15 minutes.
* Wear lightweight, light colored, loose-fitting clothes.
* Avoid alcohol, caffeinated drinks, or heavy meals.

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Next - what could you do to protect workers?
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Using the recommended process of Engineering Controls, then Work Practices (Administrative Controls) and then PPE, here are a few ideas:

1. A variety of engineering controls including general ventilation and spot cooling by local exhaust ventilation at points of high heat production may be helpful. Shielding is required as protection from radiant heat sources. Evaporative cooling and mechanical refrigeration are other ways to reduce heat. Cooling fans can also reduce heat in hot conditions. Eliminating steam leaks will also help. Equipment modifications, the use of power tools to reduce manual labor and personal cooling devices or protective clothing are other ways to reduce the hazards of heat exposure for workers.

2. Work practices such as providing plenty of drinking water -- as much as a quart per worker per hour -- at the workplace can help reduce the risk of heat disorders. Training first aid workers to recognize and treat heat stress disorders and making the names of trained staff known to all workers is essential. Employers should also consider an individual worker's physical condition when determining his or her fitness for working in hot environments. Older workers, obese workers and personnel on some types of medication are at greater risk.

3. Alternating work and rest periods with longer rest periods in a cool area can help workers avoid heat stress. If possible, heavy work should be scheduled during the cooler parts of the day and appropriate protective clothing provided. Supervisors should be trained to detect early signs of heat stress and should permit workers to interrupt their work if they are extremely uncomfortable.

4. Acclimatization to the heat through short exposures followed by longer periods of work in the hot environment can reduce heat stress. New employees and workers returning from an absence of two weeks or more should have 5-day period of acclimatization. This period should begin with 50 percent of the normal workload and time exposure the first day and gradually building up to 100 percent on the fifth day.

5. Employee education is vital so that workers are aware of the need to replace fluids and salt lost through sweat and can recognize dehydration, exhaustion, fainting, heat cramps, salt deficiency, heat exhaustion, and heat stroke as heat disorders. Workers should also be informed of the importance of daily weighing before and after work to avoid dehydration.

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OK, but does OSHA require you to protect workers from heat and sun exposure?
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An April 16, 1998 Interpretation Letter from OSHA says that worker exposure to the sun's radiation is discussed indirectly under 29 Code of Federal Regulations 1910.132(a) pertaining to personal protective equipment. Employers are to use effective forms of protection such as wide-brim hats and long sleeve clothing. In situations where the only effective means of protection is sun screen, then it too may be used.

If OSHA can prove over exposure to the sun and an employer did not move to protect the worker, a general duty clause citation may be issued.

For further information, OSHA has provided some great information in the OSHA Technical Manual: http://osha.gov/dts/osta/otm/otm_iii/otm_iii_4.html

Another great idea is to print out the Heat Stress Quick cards and provide them to all employees as a reminder of precautions they can take
OSHA Quick Card http://osha.gov/Publications/osha3154.pdf

Give these ideas some serious thought and see if your company can implement these ideas.

Its a brutal summer out there, but remember - winter is right around the corner and then we'll discuss freezing temperatures!

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