Monday, February 14, 2011

The OSHA Consultation Program

Using a free consultation service funded by the Occupational Safety and Health Administration (OSHA), employers can find out about potential hazards at their worksites, improve their occupational safety and health management systems, and even qualify for a one-year exemption from routine OSHA inspection.
The service is delivered by state governments using well-trained professional staff. Consultations take place on-site, though limited services away from the worksite are available. However, consultations cannot take place during an enforcement inspection, and may not take place until citations, if any, have been issued and become final orders.

Primarily targeted for smaller, high-hazard businesses, OSHA’s safety and health consultation program is completely separate from the OSHA inspection effort. In addition, no citations are issued or penalties proposed.

Confidentiality will be strictly maintained during the consultation process. The consultant will only report hazard information to OSHA if the employer fails to correct an imminent danger or serious hazards.

The employer’s only obligation will be to commit to correcting serious job safety and health hazards – a commitment which is expected to be made prior to the actual visit and carried out in a timely manner.

Getting Started
Since consultation is a voluntary activity, employers must request it. A telephone call or letter sets the consulting machinery in motion. The consultant will discuss specific needs with the employer and set up a visit based on the priority assigned to the request, the employer’s work schedule, and the time needed for the consultant to prepare for the visit. OSHA encourages a complete review of a firm's safety and health situation; however, an employer may limit the visit to specific problems. Certain obligations must be met, including agreeing to correct all serious hazards found during the visit in an agreed-upon time frame.

The On-Site Consultants Will:
• Meet with the employer and, at times, employees or employee representatives;
• Walk-through the worksite with the employer and employees;
• Review company injury and illness rates;
• Help identify hazards in the workplace;
• Identify kinds of help available for further assistance;
• Give detailed findings in a closing conference;
• Provide a written report summarizing findings;
• Assist the development or maintenance of an effective safety and health program;
• Provide training and education for the employer and employees;
• Recommend the site for a one-year exemption from OSHA programmed inspections, when SHARP criteria are met.

In rare instances, the consultant may find an “imminent danger” situation during the walk-through. If so, the employer must take immediate action to protect all employees. Other situations – those which would be judged a serious violation under OSHA criteria – require the employer and the consultant to develop a plan and schedule to eliminate or control the hazard.

The On-Site Consultants Will Not:
• Issue citations or propose penalties for violations of OSHA standards;
• Report possible violations to OSHA enforcement staff;
• Guarantee that your workplace will “pass” an OSHA inspection.

Hazard Correction and Follow-Through
The consultant will send to the company a detailed written report about 20 days after the closing conference that explains the findings and confirms agreed upon correction periods. A list of hazards is included in the report and must be posted electronically or in an easily observable area by employees for three days or until the listed hazards are corrected. Consultants may also contact the business from time to time to check progress, and employers may always contact them for assistance. Employers using the consultation service are deferred from OSHA’s scheduled inspections while the consultation remains “in progress.” This period encompasses the time between the onset of the consultation and the final correction dates, including any extensions.

Ultimately, OSHA does require hazard correction so that each consultation visit achieves its objective – effective employee protection. If there is a failure to eliminate or control identified serious hazards (or an imminent danger) according to the plan and within the limits agreed upon, the situation is referred from consultation to an OSHA enforcement office for appropriate action.

Knowledge of workplace hazards and ways to eliminate them can only improve the company’s
operations – and the management of the firm. Employers receive professional advice and assistance on eliminating or preventing workplace hazards via the on-site hazard survey or the on-site training from the consultant. The consultant can help establish or strengthen an employee safety and health program, making safety and health activities routine considerations rather than crisis oriented responses. Improving workplace safety and health also brings fewer accidents, lower injury and illness rates, decreased workers’ compensation costs, and limits product losses. Consultations will also help the entire company comply with OSHA standards.

Employers may participate in OSHA’s Safety and Health Achievement Recognition Program (SHARP) or a similar state program. This program is designed to provide incentives and support to employers to develop, implement and continuously improve effective safety and health programs at their worksite(s). SHARP provides for recognition of employers who have demonstrated exemplary achievements in workplace safety and health by receiving a comprehensive safety and health consultation visit, correcting all workplace safety and health hazards, adopting and implementing effective safety and health management systems, and agreeing to request further consultative visits if major changes in working conditions or processes occur which may introduce new hazards. Employers who meet these specific SHARP requirements may be exempted from OSHA programmed inspections for a period not less than one year.

Thursday, February 10, 2011

Personal Protective Equipment (PPE)

Personal protective equipment, or PPE, is designed to protect workers from serious workplace injuries or illnesses resulting from contact with chemical, radiological, physical, electrical, mechanical, or other workplace hazards. Besides face shields, safety glasses, hard hats, and safety shoes, protective equipment includes a variety of devices and garments such as goggles,coveralls, gloves, vests, earplugs, and respirators.

Employer Responsibilities

OSHA’s primary personal protective equipment standards are in Title 29 of the Code of Federal Regulations (CFR), Part 1910 Subpart I, and equivalent regulations in states with OSHA approved state plans, but you can find protective equipment requirements elsewhere in the General Industry Standards. For example, 29 CFR 1910.156, OSHA’s Fire Brigades Standard, has requirements for firefighting gear. In addition, 29 CFR 1926.95-106 covers the construction industry. OSHA’s general personal protective equipment requirements mandate that employers conduct a hazard assessment of their workplaces to determine what hazards are present that require the use of protective equipment, provide workers with appropriate protective equipment, and require them to use and maintain it in sanitary and reliable condition.

Using personal protective equipment is often essential, but it is generally the last line of defense after engineering controls, work practices, and administrative controls. Engineering controls involve physically changing a machine or work environment. Administrative controls involve changing how or when workers do their jobs, such as scheduling work and rotating workers to reduce exposures. Work practices involve training workers how to perform tasks in ways that reduce their exposure to workplace hazards.

As an employer, you must assess your workplace to determine if hazards are present that require the use of personal protective equipment. If such hazards are present, you must select protective equipment and require workers to use it, communicate your protective equipment selection decisions to your workers, and select personal protective equipment that properly fits your workers.

You must also conduct PPE training to train workers who are required to wear personal protective equipment on how to do the following:
• Use protective equipment properly,
• Be aware of when personal protective equipment is necessary,
• Know what kind of protective equipment is necessary,
• Understand the limitations of personal protective equipment in protecting workers from injury,
• Put on, adjust, wear, and take off personal protective equipment, and
• Maintain protective equipment properly.

Protection from Head Injuries
Hard hats can protect your workers from head impact, penetration injuries, and electrical injuries such as those caused by falling or flying objects, fixed objects, or contact with electrical conductors. Also, OSHA regulations require employers to ensure that workers cover and protect long hair to prevent it from getting caught in machine parts such as belts and chains.

Protection from Foot and Leg Injuries
In addition to foot guards and safety shoes, leggings (e.g., leather, aluminized rayon, or other appropriate material) can help prevent injuries by protecting workers from hazards such as falling or rolling objects, sharp objects, wet and slippery surfaces, molten metals, hot surfaces, and electrical hazards.

Protection from Eye and Face Injuries
Besides safety glasses and goggles, personal protective equipment such as special helmets or shields, spectacles with side shields, and faceshields can protect workers from the hazards of flying fragments, large chips, hot sparks,optical radiation, splashes from molten metals, as well as objects, particles, sand, dirt, mists, dusts, and glare.

Protection from Hearing Loss
Wearing earplugs or earmuffs can help prevent damage to hearing. Exposure to high noise levels can cause irreversible hearing loss or impairment as well as physical and psychological stress. Earplugs made from foam, waxed cotton, or fiberglass wool are self-forming and usually fit well. A professional should fit your workers individually for molded or preformed earplugs. Clean earplugs regularly, and replace those you cannot clean.

Protection from Hand Injuries
Workers exposed to harmful substances through skin absorption, severe cuts or lacerations, severe abrasions, chemical burns, thermal burns, and harmful temperature extremes will benefit from hand protection.

Protection from Body Injury
In some cases workers must shield most or all of their bodies against hazards in the workplace, such as exposure to heat and radiation as well as hot metals, scalding liquids, body fluids, hazardous materials or waste, and other hazards. In addition to fire-retardant wool and fire-retardant cotton, materials used in whole-body personal protective equipment include rubber, leather, synthetics, and plastic.

When to Wear Respiratory Protection
When engineering controls are not feasible, workers must use appropriate respirators to protect against adverse health effects caused by breathing air contaminated with harmful dusts, fogs, fumes, mists, gases, smokes, sprays, or vapors. Respirators generally cover the nose and mouth or the entire face or head and help prevent illness and injury. A proper fit is essential, however, for respirators to be effective. Required respirators must be NIOSH-approved and medical evaluation and respirator training must be provided before use.

Wednesday, February 9, 2011

What to do with a Job Injury or Illness

OSHA Requirements When a Worker Experiences a Job-Related Injury or Illness

Over the past three decades, occupational injuries and illnesses in the U.S. have
declined by 42 percent, even though employment has more than doubled. Nevertheless, every year, nearly five million workers experience an occupational injury or illness on the job. More than half of these injuries and illnesses are severe enough to cause the worker to spend time away from work. OSHA, along with safety and health professionals around the nation, is working with employers and employees to move toward zero injuries and illnesses in U.S. workplaces. And the agency will not be satisfied until every worker in America goes home safe and sound each day.

Reporting Catastrophes
When a worker is killed on the job and/or three or more workers are hospitalized, the employer covered by OSHA must report to the agency within eight hours. Fatal heart attacks also must be reported. Employers can call the nearest OSHA area office or the agency’s toll-free number 800-321-OSHA (6742) to provide this information.

Providing First Aid
Employers who can not reach a hospital, infirmary or clinic within a reasonable amount of time must be prepared to provide first aid to workers who experience injuries or illnesses on the job. OSHA requires that adequate first aid supplies must be readily available and that someone must be adequately trained to render first aid.

The agency also encourages employers to consider acquiring automated external defibrillators (AEDs)—medical devices designed to revive victims of sudden cardiac arrest. These devices analyze a victim’s heart rhythm and deliver an electric shock to restore heart rhythm to normal. Battery-operated AEDs are compact, lightweight, portable, safe and easy to use. Having them onsite can save precious time and improve survival odds because they can be used before emergency medical service personnel arrive.

Recording Injuries and Illnesses
Most employers in high hazard industries are required to keep records of injuries and illnesses experienced by their employees. An annual summary of these injuries and illnesses must be posted in the workplace from February 1 to April 30. Details on recordkeeping requirements and forms are available from OSHA’s website at The website also offers training to help employers complete the forms.

Those with 10 or fewer employees are exempt from injury and illness recordkeeping requirements except when selected by OSHA or the Bureau of Labor Statistics to participate in a mandatory data collection.

Investigating Accidents
One of the hallmarks of an effective safety and health management system is a commitment to investigate every incident that results in a worker injury or illness—and near-misses as well. By immediately following up, employers can identify root causes and take corrective steps to prevent future problems.

Getting Help with Safety and Health Management Systems
When it comes to injuries and illnesses, the best defense is a good offense— a pro-active safety and health management system that focuses on finding and fixing hazards before they can lead to problems. OSHA offers various services— such as consultation and compliance assistance programs— to help employers establish safety and health management systems.

OSHA’s Consultation Program, for example, is a free service to help smaller employers identify and fix hazards in their workplaces. OSHA also has compliance assistance specialists available in each area office to help employers and employees comply with OSHA requirements. OSHA cooperative and partnership programs often offer assistance with establishing safety and health management systems. Other sources of help include trade associations, insurance companies and private consultants.

Monday, February 7, 2011

Respiratory Protection & Safety

Question 1: Should respirator medical evaluation questionnaires be maintained or destroyed by the physician or licensed healthcare provider (PLHCP) after the completion of the medical evaluation?

Reply 1: The respiratory protection standard requires an employer to retain and make available records of medical evaluations (including medical determinations and the questionnaires) in accordance with OSHA Regulations29 CFR 1910.1020, Access to Employee Medical and Exposure Records. All information from the questionnaire and/or the medical exam is confidential and arrangements must be made by the employer to ensure it is kept confidential. Usually, the employer will have the records maintained by the PLHCP.

Question 2: Should the employer ensure that respirator medical evaluation questionnaires are not kept with employee records?

Reply 2: Yes. Medical records are to be kept confidential and separate from other employee records (e.g., timesheets, training).

Question 3: Is the employer only required to maintain the written recommendation regarding an employee's medical determination from the PLHCP in accordance with 29 CFR 1910.134(e)(6)?

Reply 3: All medical records (including the medical determination) must be kept and made available by the employer as required by 29 CFR 1910.134(m)(1) and 1910.1020.

Question 4: Is it acceptable for the program administrator to "pre-complete" questions 10-19 of the respirator medical questionnaire with standard information?

Reply 4: Pre-filling any part of the medical questionnaire by the employer is not appropriate. The employee should be trained by the employer, so that the employee can answer the questions. Furthermore, the requirement under 29 CFR 1910.134(e)(5) requires for the employer to provide the PLHCP with supplemental information for each employee. This requires providing the PLHCP with the answers to similar questions, as well as a copy of the employer's respiratory protection program and a copy of the standard. However, it is not mandatory to complete questions 10 through 19 of the respirator medical questionnaire unless requested by the PLCHP.

Question 5: Are there any additional recordkeeping requirements for fit test results that would prevent the department from destroying historical fit test records, as long a current test record is maintained?

Reply 5: There are no additional requirements. 29 CFR 1910.134(m)(2)(ii) only requires fit testing records to be retained by the employer until the next fit test is administered.

For more information about the use of respirators in the workplace, please visit this link:
Workplace Safety Training for Respirator Use