Hearing protection and the Hierarchy of Controls

First published by Safety+Health an NSC publication.
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Responding is Matt Block, director of health and safety services, Magid Glove & Safety Mfg. Co. LLC, Romeoville, IL.

Obviously, the standard is familiar to all safety managers: OSHA’s Hierarchy of Controls. It tells us that personal protective equipment is the least effective mitigation solution and the last thing we should employ to safeguard workers’ hearing.

Accordingly, we start with elimination. Is it possible to eliminate the hazard entirely? Is the equipment obsolete? Is there a better way to accomplish the task that doesn’t involve the current level of noise?

Next, we move to substitution. Is there a newer version of the equipment that produces a lower level of noise? This may be a more expensive alternative if you’re replacing entire pieces of equipment, but in some cases, it can be the most effective. Sometimes, it’s a simple matter of equipment maintenance. Review your logs to see if replacing one or more parts might fix the issue.

Once you know what equipment you have to work with, you can move on to engineering controls. This can take several different forms. If it’s possible to identify a particular part of a machine that’s causing a great deal of vibration or noise, you can look into adding measures to dampen that portion. Sound absorption techniques such as sound baffles or insulators to absorb some of the noise in the area can be effective. It may even be possible to add shock absorbers or sound dampening materials to portions of the equipment to dampen the noise before it reaches the room.

You can also work to contain the noise. You might move loud equipment to a separate room, or even con-struct a room around the equipment itself if it’s very large or in the middle of your facility.

This can be a double-edged sword, however, because the rest of your facility is protected from the noise, but workers who have to use the equipment may be in closer proximity and in an enclosed space, thereby increasing their noise exposure.

If you’ve done all you can with the hazard itself, it’s time to turn to administrative and work practice controls. The most common administrative control is to change workers’ schedules so they have less time exposed to the noise level. You should factor noise levels into your worker rotations just as you do ergonomic issues.

Work practice controls include setting up your facility so people aren’t working in noisy areas. This might mean putting your loudest equipment in an isolated place. If that’s not possible, you will look at the next step in your process to see how you might be able to move that.

For example, if you have a loud machine doing cutting, followed by an assembly step, rethink where that assembly can be done. Can you move the cut materials and assemble them in a quieter area?

Once you’ve controlled as much noise as possible, it’s time to consider PPE. Quality products are important, but equally important is training and reminders. Be sure everyone knows how to wear their hearing protection properly and that they understand the consequences of cutting corners.

Above all, remember that every application and environment is unique. Tackling your noise problems in this order, while sometimes thinking outside the box, is the path to preserving your workers’ hearing and good health.


McCraren Compliance offers many opportunities in safety training to help circumvent accidents. Please take a moment to visit our calendar of classes to see what we can do to help your safety measures from training to consulting.

Time for a safety walkaround

First published by Safety+Health an NSC publication.

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Safety walkarounds demonstrate an employer’s commitment to safety and allow managers to see for themselves how effective their safety and health management program is, OSHA says in a fact sheet from its Safe + Sound campaign.

Walkarounds can be broken down into three parts: pre-inspection, onsite inspection and post-inspection.

Pre-inspection

  • Plan to focus your inspections on areas where hazards have been identified. Check to see if previously identified hazards have been abated or if further action is needed.
  • If your workplace has a safety committee, schedule a pre-inspection meeting and invite workplace safety representatives as well as other managers and supervisors to get their perspective on the worksite’s safety issues.
  • Determine what safety equipment you’ll need to conduct the inspection.
  • Lead by example: Wear appropriate personal protective equipment.

Onsite inspection

Look for easily observable hazards first, such as:

  • Tripping hazards
  • Blocked exits
  • Frayed/exposed electrical wires
  • Missing machine guards
  • Poor housekeeping
  • Poorly maintained equipment

During the inspection, talk to employees at their workstations. They’re the ones likely to know the most about the hazards. Encourage conversation by asking open-ended questions such as, “What’s the most hazardous task in your job? What makes it hazardous?” and “If you’ve been injured, what was the injury and how did it happen?”

Another important part of an inspection is observing workers as they perform their job. Do they lift heavy objects? Do they stand/sit in awkward postures? Are they performing repetitive motions? If so, take notes and photos. “Try to find solutions for hazards while you are conducting the inspection by applying your own creativity and inspiring the creativity of workers,” OSHA recommends.

Post-inspection

Soon after the inspection, prepare an abatement plan containing a list of the hazards found, corrective actions needed and a timeline for implementation. “Some complex hazards may require further evaluation, study, or engineering work to design and implement appropriate controls,” OSHA cautions.

Share the abatement plan with managers, supervisors and workers, and track progress by sharing or posting periodic updates to the plan.


McCraren Compliance offers many opportunities in safety training to help circumvent accidents. Please take a moment to visit our calendar of classes to see what we can do to help your safety measures from training to consulting.

Protecting construction workers during COVID-19

First published by Safety+Health an NSC publication.
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Photo: CPWR – The Center for Construction Research and Training

Silver Spring, MD — Mitigating the spread of COVID-19 on construction sites should be a team effort, OSHA Directorate of Construction Director Scott Ketcham said during a Feb. 25 webinar.

Hosted by OSHA, NIOSH, and CPWR – The Center for Construction Research and Training, the event focused on helping construction employers and workers identify exposure risks and determine appropriate control measures.

Ketcham detailed how updated COVID-19 guidance issued by OSHA on Jan. 29 affects construction employers and workers. He also noted that safety professionals still need to contend with other hazards during the pandemic.

“Controlling this disease process with coronavirus and mitigating other hazards really takes all of us working together,” he said. “We all know that in the construction industry we have multiple trades working on a construction site for different companies. Coordination of efforts to make sure that we’re looking out for one another and protecting one another is important.”

Ketcham added that OSHA will use the multi-employer work policy to assess how contractors are following the guidance on construction sites.

Amanda Edens, deputy assistant secretary of labor for occupational safety and health at OSHA, acknowledged that new and updated guidance can lead to confusion among federal agencies and employers.

“It’s challenging for OSHA and CDC to give guidance because science changes,” she said. “And it’s challenging for employers too because they’re trying to keep up with what we’re learning as we go.”

Edens said worker safety issues such as trenching and cranes have remained a priority throughout the pandemic, and topped by those related to COVID-19.

“The bread-and-butter work of the agency continues,” she said. “We still have a lot of construction work to get done, even if COVID wasn’t around. But it is, so we have to do that work and do it in a COVID environment.”

Timothy Irving, deputy director of OSHA’s Directorate of Construction, encouraged employers to consider the mental health needs of workers as he discussed nontraditional hazards.

“OSHA might not be the first federal agency you think of when you hear about nontraditional workplace conditions – PTSD, drug use, suicide and other mental health issues,” he said. “But our mission is to prevent work-related injuries, illnesses and deaths.”

OSHA’s suicide prevention webpage provides multiple resources to assist workers who might be in crisis. When providing resources to workers, Irving said employers should consider a wide variety of helpful information.

“When you share health and safety resources, be aware that mental health is a part of health and safety,” he said.


McCraren Compliance offers many opportunities in safety training to help circumvent accidents. Please take a moment to visit our calendar of classes to see what we can do to help your safety measures from training to consulting.

National grain safety week set for March 29-April 2

First published by Safety+Health an NSC publication.
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Photo: Stand Up 4 Grain Safety Week

Washington — OSHA and its Alliance Program partners in the agriculture industry are hosting the fifth annual Stand Up 4 Grain Safety Week – slated for March 29-April 2.

The industrywide initiative aims to raise awareness of hazards related to grain handling and storage by providing employers and workers with educational opportunities, resources and training on best safety practices. Employers are encouraged to designate a coordinator for their individual events, decide what type of event to conduct, determine the best time and length, choose who should be involved, and promote the event internally and externally.

The types of events can include a toolbox talk or companywide safety activities such as discussions on job-specific hazards, developing rescue plans or conducting safety equipment inspections. Group demonstrations of safety procedures and regional half- or full-day seminars with safety or equipment demonstrations also can be planned.

The event’s organizers recommend encouraging all employees to participate. Local producers and Four-H Club or National FFA Organization chapters also can be invited to take part.

The event starts at 10 a.m. Central each day, with a virtual kickoff event scheduled for March 29. Registrants will have free access to virtual training sessions during the rest of the week, each day featuring a different focus and resources:

  • March 30: Near-miss reporting
  • March 31: Impact of quality on safety
  • April 1: Bin safety
  • April 2: Emergency action plans

The organizations in the OSHA Alliance Program that are sponsoring the event are the National Grain and Feed Association, the Grain Handling Safety Coalition, and the Grain Elevator and Processing Society.


McCraren Compliance offers many opportunities in safety training to help circumvent accidents. Please take a moment to visit our calendar of classes to see what we can do to help your safety measures from training to consulting.

OSHA launches program to protect high-risk workers from coronavirus, focuses on employers that retaliate against workers with safety concerns

First published by OSHA

WASHINGTON, DC – In response to President Biden’s executive order on protecting worker health and safety, the U.S. Department of Labor’s Occupational Safety and Health Administration has launched a national emphasis program focusing enforcement efforts on companies that put the largest number of workers at serious risk of contracting the coronavirus. The program also prioritizes employers that retaliate against workers for complaints about unsafe or unhealthy conditions, or for exercising other rights protected by federal law.

“This deadly pandemic has taken a staggering toll on U.S. workers and their families. We have a moral obligation to do what we can to protect workers, especially for the many who have no other protection,” said Principal Deputy Assistant Secretary of Labor for Occupational Safety and Health Jim Frederick. “This program seeks to substantially reduce or eliminate coronavirus exposure for workers in companies where risks are high, and to protect workers who raise concerns that their employer is failing to protect them from the risks of exposure.”

NEP inspections will enhance the agency’s previous coronavirus enforcement efforts, and will include some follow-up inspections of worksites inspected in 2020. The program’s focused strategy ensures abatement and includes monitoring the effectiveness of OSHA’s enforcement and guidance efforts. The program will remain in effect for up to one year from its issuance date, though OSHA has the flexibility to amend or cancel the program as the pandemic subsides.

“With more people being vaccinated and the number of infections trending down, we know there is light at the end of the tunnel. But until we are past this pandemic workers deserve a Labor Department that is looking out for their health,” added Frederick.

OSHA state plans have adopted varying requirements to protect employees from coronavirus, and OSHA knows many of them have implemented enforcement programs similar to this NEP. While it does not require it, OSHA strongly encourages the rest to adopt this NEP. State plans must notify federal OSHA of their intention to adopt the NEP within 60 days after its issuance.

In a related action, OSHA has also updated its Interim Enforcement Response Plan to prioritize the use of on-site workplace inspections where practical, or a combination of on-site and remote methods. OSHA will only use remote-only inspections if the agency determines that on-site inspections cannot be performed safely. On March 18, 2021, OSHA will rescind the May 26, 2020, memorandum on this topic and this new guidance will go into and remain in effect until further notice.

OSHA will ensure that its Compliance Safety and Health Officers have every protection necessary for onsite inspections. When conducting on-site inspections, OSHA will evaluate all risk and utilize appropriate protective measures, including appropriate respiratory protection and other necessary personal protective equipment.


McCraren Compliance offers many opportunities in safety training to help circumvent accidents. Please take a moment to visit our calendar of classes to see what we can do to help your safety measures from training to consulting.

Safe + Sound Week slated for Aug. 9-15

First published by Safety+Health an NSC publication.

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Photo: OSHA

Washington — OSHA, NIOSH and a coalition of safety organizations – including the National Safety Council – are joining forces for the fifth annual Safe + Sound Week, scheduled for Aug. 9-15.

The national initiative is intended to help promote awareness and understanding of workplace safety and health programs. More than 3,400 employers participated in last year’s event, according to OSHA.

“Successful safety and health programs can proactively identify and manage workplace hazards before they cause injury or illness, improving sustainability and the bottom line,” the agency says. “Participating in Safe + Sound Week can help get your program started, energize an existing one or provide a chance to recognize your safety successes.”

Registration is set to open in July.


McCraren Compliance assists employers in protecting their workers, starting with a comprehensive Work-site Analysis, Hazard Prevention, Controls, and Safety & Health Training.

Please contact us today at 888-758-4757 to learn how we can provide mine safety training and consulting for your business.

10th year running: Fall Protection leads OSHA’s annual ‘Top 10’ list of most frequently cited violations

First published by Safety+Health an NSC publication.

Itasca, IL — “Fall Protection – General Requirements” is OSHA’s most frequently cited standard for the 10th successive fiscal year, the agency announced Feb. 26 during an exclusive Safety+Health webinar.

Patrick Kapust, deputy director of OSHA’s Directorate of Enforcement Programs, presented preliminary data for OSHA’s Top 10 most cited violations for fiscal year 2020, which ended Sept. 30. S+H Associate Editor Kevin Druley moderated the session.

Although multiple standards swapped positions, the standards that make up the Top 10 remained unchanged from FY 2019. Of note, a newcomer emerged among the top five: Ladders, which ranked sixth in FY 2019, rose one spot. Additionally, Respiratory Protection climbed to third from fifth, while Lockout/Tagout fell two spots, dropping to sixth from fourth.

The full list:

  1. Fall Protection – General Requirements (29 CFR 1926.501): 5,424 violations
  2. Hazard Communication (1910.1200): 3,199
  3. Respiratory Protection (1910.134): 2,649
  4. Scaffolding (1926.451): 2,538
  5. Ladders (1926.1053): 2,129
  6. Lockout/Tagout (1910.147): 2,065
  7. Powered Industrial Trucks (1910.178): 1,932
  8. Fall Protection – Training Requirements (1926.503): 1,621
  9. Personal Protective and Life Saving Equipment – Eye and Face Protection (1926.102): 1,369
  10. Machine Guarding (1910.212): 1,313

“Use the Top 10 as a guide for your workplace,” Kapust recommended. “It’s a good place to start if you don’t know where to start. Look at what OSHA is finding. Look at the things that are applicable to your particular industry as well.”


McCraren Compliance assists employers in protecting their workers, starting with a comprehensive Work-site Analysis, Hazard Prevention, Controls, and Safety & Health Training.

Please contact us today at 888-758-4757 to learn how we can provide mine safety training and consulting for your business.

On Safety: What an ETS and National Emphasis Program on COVID-19 are likely to look like

First published by Safety+Health an NSC publication.

A lot of rumors are floating around regarding a potential OSHA emergency temporary standard and a National Emphasis Program enforcement action related to COVID-19. Rumors I’ve heard include that there are two versions of an ETS, that a draft is available for internal review and that OSHA is developing an NEP to accompany the ETS.

I think it’s a bit too soon for OSHA to have a draft ETS done, but perhaps one is very close. Based on past practice with a newly issued standard, OSHA will use an NEP to focus on compliance with any potential ETS. Under an Executive Order signed by President Joe Biden on Jan. 21, an ETS, if deemed necessary by the agency, must be issued by March 15. That ETS likely would follow the OSHA COVID-19 guidelines that were updated and rereleased Jan. 29.

The requirements in the NEP would mirror the requirements of the ETS. The following are likely to be addressed by OSHA in the ETS and NEP, and should be implemented at worksites:

  • A written infectious disease or exposure control program that covers:
    • Physical distancing criteria
    • Sanitation (including vacuuming of workplaces)
    • Personal hygiene
    • Testing and screening – following local guidance
    • Engineering controls, including barriers and ventilation – negative pressure and increased ventilation in areas such as conference rooms
    • Employee and manager training
    • Use of face coverings and respirators (N95 in health care) and use of personal protective equipment (gowns, gloves, faceshields and goggles, as appropriate)
    • Identification of where exposures may occur (site risk assessment)
    • Procedures for communicating to employees
    • Isolation/separation of employees showing any signs or symptoms of exposure
    • Use of Environmental Protection Agency-approved cleaning materials and proper PPE for those doing any cleaning
    • Whistleblower/retaliation protection
    • Recordkeeping
  • A designated program coordinator
  • Process/procedures for handling customers or visitors

Concerning vaccination, OSHA likely will not require employees to be vaccinated and will allow employees to opt out from being vaccinated. This is based on the fact that OSHA has allowed employees to decline hepatitis B vaccines under the standard on bloodborne pathogens (1910.1030). However, some process or procedure for making vaccines available to employees at no cost will likely be included.

As for employer coverage under the scope of an ETS and NEP, OSHA may defer to the Centers for Disease Control and Prevention, as well as use any and all data OSHA is able to acquire (including recent enforcement data). Initially, an NEP will likely focus on hospitals, assisted-living facilities, nursing homes, health clinics, meat processing (beef, pork and poultry), and warehousing/distribution operations where there are a lot of people. An NEP could provide an enforcement opening if there are outbreaks in other industries.

If employers are thinking this will only apply to health care, they would be mistaken. My advice would be for employers to coordinate with their state and local health departments and look at the risk of COVID-19 in their respective areas. If the risk is “medium to high,” they should have an infectious disease or exposure control program in place. The scope could vary for their program based on the level of risk in their community or history of exposure in their workplace. The unknown is what to do where the risk is low? Low-risk establishments should still have an infectious disease or exposure control program, but it could be scaled back – again, companies facing a low risk should coordinate with their state and local health departments – and all efforts should be documented.

This article represents the views of the authors and should not be construed as a National Safety Council endorsement.

Richard Fairfax (CIH, retired 2017) joined OSHA in January 1978 and retired from the agency in 2013. At OSHA, he was a practicing field industrial hygienist, as well as the deputy director and director of enforcement programs. In 2008, Richard served as acting director of construction and, in 2010, was designated deputy assistant secretary – overseeing all field, enforcement and training operations. From 1993 through 2010, Richard wrote an industrial hygiene column entitled, “OSHA Compliance Issues” for the Journal of Occupational and Environmental Hygiene. He still serves on the Editorial Review Board. Richard now works part time for NSC-ORC HSE.


McCraren Compliance offers many opportunities in safety training to help circumvent accidents. Please take a moment to visit our calendar of classes to see what we can do to help your safety measures from training to consulting.

The eighth annual National Stand-Down to Prevent Falls in Construction will be held May 3-7.

First published by OSHA

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Photo: OSHA

The 2021 National Safety Stand-Down to Prevent Falls in Construction is scheduled for May 3–7, OSHA has announced. The annual safety stand-down is intended to raise awareness of fall hazards and to encourage conversations about industry best practices to prevent fall fatalities and injuries. According to OSHA, fatalities caused by falls from elevation continue to be a leading cause of death for construction workers: in 2018, 320 of the 1,008 fatalities recorded in construction were attributed to falls.

Workplaces that participated in past years’ safety stand-downs include commercial construction companies, residential construction contractors, subcontractors and independent contractors, highway construction companies, general industry employers, the U.S. military, other government participants, unions, trade associations, institutes, employee interest organizations, and safety equipment manufacturers. OSHA encourages any employer who wants to prevent hazards in the workplace to participate. Employers whose workers are not exposed to fall hazards can use the safety stand-down as an opportunity to focus on other job hazards, protective methods, and safety policies and goals. Following the stand-down, employers will be able to download a certificate of participation and provide feedback about their experience.

The website for the safety stand-down provides resources to help workplaces participate in the event, including free training materials, videos, and additional educational resources. Highlights​ from previous years are also available.​​​​​

 


McCraren Compliance assists employers in protecting their workers, starting with a comprehensive Work-site Analysis, Hazard Prevention, Controls, and Safety & Health Training.

Please contact us today at 888-758-4757 to learn how we can provide mine safety training and consulting for your business.

The ‘first step’: OSHA updates COVID-19 guidelines as Biden administration focuses on worker safety

First published by Safety+Health an NSC publication.

Photo Credit: Courtesy of Turner Construction

Washington — OSHA has issued updated COVID-19 guidance for workplaces – the “first step” by the Biden administration and new OSHA leadership to address the pandemic.

“The guidance issued today is the first step in the process, but it’s certainly not the last step in that process,” Jim Frederick, OSHA’s acting administrator and the agency’s principal deputy assistant secretary, said Jan. 29 during a Department of Labor virtual news conference.

The updated guidance, titled Protecting Workers: Guidance on Mitigating and Preventing the Spread of COVID-19 in the Workplace stems from an Executive Order signed by President Joe Biden on Jan. 21. In addition to issuing the updated guidance, the order directs OSHA to consider an emergency temporary standard related to COVID-19. If an ETS is considered necessary, the agency is instructed to issue one by March 15.

A little more than one week into his new job, Frederick said he wasn’t ready to commit to a clearer time frame or outline what a potential ETS would include.

“We do not have an outline of what an ETS might look like, should we consider to go there,” Frederick said. “That is something we’re deliberating about and we’ll be working on.”

In the updated guidance, OSHA replaces suggestive language with stronger language, such as employers “should implement” prevention programs to reduce the transmission of the coronavirus. Unlike a regulation, however, the guidelines provide no legal obligations for employers.

Steps employers should take to reduce transmission of COVID-19 among workers include adopting policies that encourage potentially infected workers to remain home without punishment for their absences. Workers also should have protection from retaliation for raising COVID-19-related concerns, and employers should communicate policies and procedures in every language spoken by their workforce.

Additionally, the guidance calls for hazard assessments and the identification of control measures that will limit the spread of the coronavirus.

The guidance includes information about physical distancing and face coverings, among other recommended measures, as well as the roles of employers and employees in COVID-19 responses. This includes considerations for workers who are at higher risk of severe illness, including older employees, “through supportive policies and practices.”

Other sections address the installation of barriers when physical distancing of 6 feet or more isn’t feasible, ventilation, personal protective equipment, good hygiene practices, and routine cleaning and disinfection.

“More than 400,000 Americans have died from COVID-19 and millions of people are out of work as a result of this crisis,” M. Patricia Smith, senior counselor to the labor secretary, said in a press release. “Employers and workers can help our nation fight and overcome this deadly pandemic by committing themselves to making their workplaces as safe as possible. The recommendations in OSHA’s updated guidance will help us defeat the virus, strengthen our economy, and bring an end to the staggering human and economic toll that the coronavirus has taken on our nation.”

Another step in the process is “streamlining” the COVID-19-related citation process, OSHA Senior Advisor Ann Rosenthal said during the news conference.

She said the previous administration had “so many levels of review for COVID-related citations that, generally, they were issued on the final day of the six-month statute of limitations.” The goals of the streamlined process, she added, are timely abatement of hazards and informing workers.


McCraren Compliance assists employers in protecting their workers, starting with a comprehensive Work-site Analysis, Hazard Prevention, Controls, and Safety & Health Training.

Please contact us today at 888-758-4757 to learn how we can provide mine safety training and consulting for your business.