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Fourth Quarter 2017

OSHA’s New Silica Rule: Don’t Be Left in the Dust

By: Mark Williams, Safety Consultant

Beginning September 23, 2017 the long awaited OSHA silica standard (29 CFR 1926.1153) update will go into effect. The new standard has been redesigned with the purpose of providing workers exposed to respirable crystalline silica with the maximum protection possible. The standard is set up to allow employers to use predetermined compliance solutions (outlined in Table 1) or to design their own for their particular workplaces and job functions. With the new standard, employers must make some key changes to their silica policies in order to maintain OSHA compliance and provide their workers a safer environment in regard to silica exposure.

 

The update reduces the permissible exposure limit of crystalline silica from 250 micrograms per cubic meter of air over an 8-hour TWA to 50 micrograms over the same. OSHA has put together a chart “Table 1” on recommended control practices for a list of commonly performed tasks known to expose workers to silica. For employers following the control methods in OSHA Table 1, no further air quality testing is required unless it is noted the Table 1 control method is not effective and noticeable amounts of silica dust are still present. For employers that elect to utilize alternative control methods, industry-wide objective data must be available demonstrating exposure levels are below the levels mentioned in the standard. If such data is unavailable, exposure assessments must be conducted to prove exposure levels are below the action level. Exposure assessments must be conducted and reviewed to determine if the control method is effectively reducing workers’ exposure to below the action level of 25 µg/m3  Where results do not reveal exposure levels are below the action level, employers must conduct ongoing assessments to monitor workers’ exposure levels and compare results while instituting other effective control methods.

Regardless of the exposure control method of choice, all construction employers affected by this standard must complete the following core steps:

·Establish and implement a written exposure control plan that identifies tasks which expose                          employees to respirable crystalline silica and the methods the employee plans to use to protect                  workers.

·Designate a competent person who will implement the exposure control plan.

·Train employees on effective practices to limit exposure to respirable crystalline silica.

·Adjust housekeeping practices to minimize worker exposure to silica dust by eliminating dry sweeping        and compressed and using a HEPA-filtered vacuum system or wet method. 

·Provide medical exams to employees that are exposed to silica dust to such an extent that they   must      wear a respirator 30 or more days a year.

·File and maintain records of workers’ silica exposure and any related medical treatment. 

For more information on what this new rule means for your industry or company or assistance with compliance, contact Safety Resources, Inc.  

References:

OSHA.gov. OSHA Fact Sheet “OSHA’s Crystalline Silica Rule: Construction.”

Slowey, Kim. “What contractors need to know about OSHA’s new silica rule.” constructiondive.com. 22 Aug. 2017.  

 

How Behavior-Based Safety Can Reduce Serious Injuries & Fatalities (SIF)

By: Neil Spaeth, Safety Consultant 

Sometimes when we are faced with continuous and repeating minor injuries and illnesses, we often are able to identify the root cause and prevent them from occurring again through the implementation of programs, or the changing of a policy or procedure. Why have the statistics for serious injuries and fatalities been consistent for years? Research has shown that the difference between fatal and less severe injuries is due to safety practitioners treating every incident in the same manner. As a result, there has been an increased focus to the potential severity of incidents, first aid cases, and near misses. This article will dig into the benefits of implementing a behavior-based safety program in order to help understand the meaning behind the word “potential.”

 

Utilizing Behavior-Based Safety

Behavior-based safety has been proven to reduce overall unsafe practices, but can this be applied to incidents that have the potential to be serious or fatal? The simple answer is that yes it can, if it has the necessary elements included in it. While a behavior-based safety program will not be able to identify every potential serious injury or fatality, it can be implemented in a way to ensure that each level of a company is involved and leading indicators are actively identified prior to beginning high hazard work.

-          Observation Sheets/Cards should include SIF (serious injuries and fatalities) potential

Often times, observation cards do not include how to treat a potential SIF situation. Observation cards must include environmental conditions, as well as who or what should be identified in order to create a management change to the process.

-          Training

During training, observers should be taught the proper way to identify a potential SIF task. This will ensure observers know the right questions to ask in order to determine if a gap in the process is evident.

-          Choose the right observers

Behavior-based safety can become stale very quickly. To prevent this, choose multiple work groups ranging from upper management to line-level employees. A beneficial practice is to rotate observers weekly, monthly, and quarterly, in order to involve everyone and have a number of eyes on the same task in order to identify gaps. This will also speed up the process of implementing cultural change throughout a work group.

-          Use your data

Your data will be your best friend. Use this to identify areas that should be improved or further researched.

Evidence shows that while not all potential SIF events will be detected using behavior-based safety, we can use the data to detect the potential in order to analyze high hazard tasks with a different method. Using this will help your company initiate a well-rounded safety program as it relates to identifying pre-cursors, environmental factors, and leading indicators.

 

 

References:

Mangan, Mike. “Safety in Practice: Applying Behavior-Based Safety to Serious and Fatal Injury Prevention.” Dekra Insight.

 

 

Safety Tools and Rules: The Basics You Need to Know

By: Jeff Stoll

There are various levels of understanding OSHA regulations, but one thing most of us understand is that no one has 500+ pages of regulations memorized. There are three relatively straightforward rules of thumb that help generalize these regulations and can go a long way to staying safe at work.  

1.) Use the tool the way the manufacturer of that tool recommends.

An example: use extension ladders at the proper angle (4:1), extend them over the landing by 3’, utilize the cleats properly depending on the surface, and do not remove any stickers that give load ratings or other manufacturer-supplied information.  This also works for mobile equipment used on the construction site such as all-terrain forklifts, scissor lifts and/or boom lifts.  Manufacturers undergo immense scrutiny for safety rules and recommendations regarding their products prior to hitting the consumer market.  This is done by such organizations as ANSI (American National Standards Institute), or the U.S. Consumer Product Safety Commission.  Additionally, manufacturers have internal quality control departments that help assure these products are “tried and true” prior to hitting the markets.  Manufacturers are careful to avoid litigation and recalls as that is extremely negative to the overall impact of a company’s bottom line.  Training workers on the manufacturer’s suggested product usage will help prevent incident or injury from occurring.

2.) Use the right tool for the job.

This “rule” seems simple, but it’s actually quite common. Just because a particular tool or process will work, doesn’t mean it is safe. Examples:  1.) Using a scissor lift while working on uneven ground on a new construction site.  Scissor lifts are meant to be used on very firm, even, and flat surfaces, and designed to go vertically upward perpendicular to the surface in which it operates. 2.) Using a boom lift as a crane.  Boom lifts are designed by the manufacturer to lift workers and their tools and materials to an elevated location, not to lift I-Beams, large doors, drywall, or other items into place. 

Common reasons various employees state they either can not or will not utilize proper tools may include:  “the equipment rental company didn’t have what we really needed, so we are using something similar”.  How about companies that purchase undersized equipment that will be dangerously maxed out, or even overloaded during common operation on job sites, perhaps because the budget does not allow the correct sizes. Possibly the most reoccurring reason is “it was the only one we had available on the job site”.  A specific example of this may be the worker who needs a 10’ ladder, but only has access to the 8’ ladder. This employee searches and decides no one will see him access that top step, and ends up falling as a result.  Falls from ladders account for 43% of fatalities from falls in the last decade, according to OSHA.  Personal fall arrest items such as anchor points, harnesses, and lanyards also apply in this category.  If workers only have access to a harness with just a dorsal ring, as opposed to one with side rings also, their ability to apply an efficient, safe fall restraint system may be inadequate.  If workers have only 8’ self-retracting lifelines (SRL’s) when they need the 20 feet available, they may try to utilize another unsafe option.  Fall protection is an OSHA “Focus Four” item, meaning, that many fatalities, injuries, and incidents occur because of lack of proper management as it relates to these safety regulations.  Management must always ensure proper options are available in work trucks, tool boxes, and job sites overall, so workers are not defaulting to the wrong tool, enhancing the chance for an incident to occur.  If a regulated tool is not available, workers should receive total support from management to put off the task until the right tool can be obtained.

3.) Use the tool only with the proper training.

A good example of using tools either prior to, or without proper training is when a single axle dump truck breaks down on the way to a job site. The driver exits the truck, raises the bed to access the hydraulic lines, positions his body under the suspended load (the raised bed of material), and the bed falls- crushing the driver.

In addition to an overall lack of training, modifications of tools by unqualified workers can potentially negate the stringent safety standards set forth by the tool or equipment manufacturer.  Working on tools or equipment must be done by thoroughly trained, qualified individuals who know the proper utilization methods. Employers, and their associated safety professionals should continually reiterate that modifying tools or operating equipment without the proper training, is both unsafe, and strictly prohibited.

When it comes to safety, education is imperative and knowledge is power. Minimizing risks at work starts at the top, and support for these efforts sends messages to employees that not only will the company support safe work practices, but that they care.

 

 

 

 

 

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