Clarifying Representation: The Department of Labor's Newest Regulatory Update
Discover the latest regulatory update by the Department of Labor, aiming to redefine representation during OSHA workplace inspections. This pivotal adjustment could significantly enhance inspection effectiveness and safety outcomes, marking a new ...
On August 29, 2023, the Department of Labor proposed a change to its Representatives of Employers and Employees regulation. According to the U.S. Department of Labor, this rule serves to clarify who can be authorized to serve as a representative during OSHA workplace inspections; stating that the representative may be an employee or someone from a third-party. It also clarifies that third-party representatives are not limited to industrial hygienists or safety engineers, a common misunderstanding of the existing regulation. If the compliance officer deems the individual has skills, knowledge, or experience that would be helpful, they may be granted permission to represent the employee during the inspection. The main goal of this proposed change is to have a more effective inspection conducted to prevent possible injuries (Godinez, 2023).
Should this pass, this would mean that Cornerstone could be a third-party representative for clients who have a scheduled OSHA inspection. Frequently, however, physical OSHA inspections occur without a heads-up from the OSHA officer. In this case, it would be very difficult for a third-party to be involved. That said, in the case that an inspection is scheduled ahead of time, bringing in outside representation would be much easier to coordinate.
Another limiting factor to Cornerstone’s involvement would be whether the client knows what areas of the workplace will be inspected. If the OSHA officer does not provide a scope of what will be inspected, then consulting oversight might be a moot point. That said, Cornerstone can help clients review inspection results and propose recommendations accordingly, regardless of our ability to be involved in the inspection itself.
Ultimately, this change would be a benefit to all parties involved with physical OSHA inspection. It will help make sure the right people are involved and, therefore, will lead to better outcomes.
Godinez, Victoria. “Department of Labor Announces Proposed Changes to Clarify Regulations on Authorized Employee Representation during Workplace Inspections.” Occupational Safety and Health Administration, August 29, 2023. https://www.osha.gov/news/newsreleases/national/08292023.
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Understanding Metalworking Fluids: Types, Risks, and Control Measures
Learn about the four categories of metalworking fluids, including their risks and control measures.
What are Metalworking Fluids?
Metalworking fluids (MWFs) refer to fluids used during grinding and machining and include four classes of MWFs: straight oil, soluble oil, semisynthetic, and synthetic MWFs. MWFs serve to prolong the life of the tool, carry away metal debris that results from cutting and grinding, protect the part being produced, and carry heat away from the ground or cut surface.
Occupational exposures to MWFs are a concern and need to be controlled. Repeated inhalation of MWF mists can cause respiratory illnesses and asthma, leading to non-reversible lung damage. Additionally, contact with skin can cause various skin diseases, most notably allergic dermatitis.
Types of MWFs
MWFs are grouped into four categories. The first category is “straight” oil (neat oil) MWFs. These oils are solvent-refined petroleum oils, animal, marine, vegetable oils, or synthetic oils that are not diluted with water. The straight oils may or may not contain additives that may include corrosion inhibitors, emulsifiers, buffers, and extreme pressure additives.
The next class are the soluble oils (emulsifiable oils), which are between 30 to 85 percent severely refined lubricant base oil with emulsifiers and may also contain additives. Soluble oils also contain a small percentage of water.
The semisynthetic class contains less of a percentage of the severely refined lubricant base oil (5-30%) and contains a higher percentage of emulsifiers and up to 50 percent water.
The final category is synthetic MWFs, which contain no petroleum oils and are diluted with 10-40 parts of water.
Occupational Exposure
Occupational exposures to MWFs occur either by inhaling mists and aerosols or from direct skin contact. Besides the MWF aerosols and the added additives or biocides, exposure risk can include metals and alloys from the parts ground or machined. Additionally, background contaminants in the work area and bacterial or fungal contamination in the water component of MWFs pose a risk.
The National Institute of Occupational Safety and Health (NIOSH) has established a Recommended Exposure Limit (REL) of 0.5 milligrams per cubic meter (mg/m3) for an eight-hour time-weighted average exposure. The REL applies to all categories of MWF. In addition to NIOSH, the Occupational Safety and Health Administration has established a Permissible Exposure Limit (PEL) of 5 mg/m3, which only applies to mineral oil-based MWFs. The NIOSH REL is based on regular and recent reviews of health hazard data and is the occupational exposure limit referred to for best practices.
During machining operations, the risk of Inhalation exposures is greater depending upon how close the worker is to the machine, whether there is an enclosure or splash guard, and whether the machine is operating at a high speed and making deep cuts. Other factors contributing to exposures during machining or grinding are whether there is exhaust ventilation installed to capture mists and aerosols near the point of generation and whether the exhaust system has been poorly designed or maintained. Additionally, improper machine maintenance can result in excessive fluid application or contamination of the oil with machine tramp oils.
In addition to inhalation, skin contact is a major concern with respect to exposure. Exposures occur when there are not enclosures or guards to protect from splashes during machine operation, and from handling parts, tools, or equipment without personal protective equipment (gloves and aprons), or prolonged contact with clothing contaminated with oil.
Health Effects
The NIOSH REL was established to address non-malignant respiratory disease. MWF concentrations above the REL in nine out of ten studies have been shown to cause respiratory conditions, including hypersensitivity pneumonitis (HP) which produces flu-like symptoms, acute airway irritation, chronic bronchitis, impaired lung function, and asthma. Cases of HP have been linked to water-based or diluted oils, and microbial contamination is believed to be the most likely cause. Three recent studies have shown that the risk of developing asthma is elevated and up to three times greater for workers exposed to synthetic MWFs than for workers who are not exposed.
A variety of skin diseases can result from direct skin contact with MWFs. The following factors contribute to the development of disease:
The MWF category and additives used
The duration of the skin contact
An existing skin abrasion or cut
Individual susceptibility
Inadequate or infrequent skin cleansing following contact
The use of irritating soaps or detergents
High or low humidity, hot or cold temperatures
Wearing MWF-soaked clothing or handling soaked rags.
The general cleanliness of the surrounding work area
Lack of controls i.e., machine enclosures, exhaust ventilation, personal protective equipment (gloves, sleeves, aprons)
The most reported skin diseases are irritant contact dermatitis or allergic contact dermatitis. The latter type of dermatitis is caused by an immune response to a substance that the body has become sensitized to. Dermatitis causes skin lesions and discomfort from burning and itching. Dermatitis is common with contact with soluble, semisynthetic, and synthetic MWFs.
Other skin diseases, including folliculitis (hair follicle infection), oil acne, and keratosis (rough, scaly skin patches), are linked to contact with straight oil MWFs.
Controlling Exposures to MWFs
The machine tool industry has undergone major changes in recent decades, leading to significant exposure reductions. The changes made have included the increased use of synthetic MWFs, which have increased tool and cut speeds which reduce machining time. Technological advances have also been made, leading to the development of machines with partial enclosures and the installation of local exhaust ventilation. During the 1970s and 80s, industries began installing air cleaners (mist collectors) and improving the recirculation of air and filtration.
Recommendations for Controlling Exposures
NIOSH recommends developing and implementing a comprehensive health and safety program to control exposures to MWFs. For programs to succeed, management must have a strong commitment and include worker involvement. The four main components recommended are safety and health training, worksite analysis, hazard prevention and control, and medical monitoring of exposed workers.
Worker training programs should teach workers to identify potential exposure hazards in their work areas and the adverse health effects of MWF exposure.
Worksite analysis refers to monitoring work practices and assessing personal exposures (air sampling) to assess the effectiveness of controls.
Hazard reduction can be achieved by the proper selection of MWF, i.e., using the most non-irritating, non-sensitizing fluids, regular fluid maintenance, isolation of the operation, and installation of exhaust ventilation.
With respect to PPE, workers should be trained in the proper use and care of protective equipment. If personal exposure assessment indicates that respiratory protection is needed, a respiratory protection program must be established in accordance with the OSHA Respiratory Protection standard (29 CFR 1910.134).
For more in-depth information about MWFs and controlling exposures, consult NIOSH publication 98-116, Occupational Exposure to Metalworking Fluids
Mary Dunlap is a Certified Industrial Hygienist and has been with Cornerstone Environmental, Health and Safety since 2016. When she is not working, you can find Mary enjoying the outdoors.
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OSHA's New National Emphasis Program: Safeguarding Workers in High-Risk Industries from Warehouse Injuries and Heat Hazards
OSHA recently launched an NEP focused on preventing injuries in warehouses, processing facilities, distribution centers, and high-risk retail establishments. Learn more.
National Emphasis Programs, also known as NEPs, are “temporary programs that focus OSHA's resources on particular hazards and high-hazard industries,”(OSHA 2023). On July 11th, 2023, OSHA launched a NEP focused on preventing injuries in warehouses, processing facilities, distribution centers, and high-risk retail establishments. This NEP decision was made based on ten years of injury history in these workplaces. According to the OSHA national news release, warehouses and distribution centers currently employ 1.9 million people, and the injury and illness rate is higher than the overall private industry.
The NEP will last three years and will consist of inspections focused on hazards related to powered industrial vehicle operations, material handling and storage, walking and working surfaces, means of egress, and fire protection. These safety focuses would be considered high-risk, which means if an injury occurs then there is a higher chance it will result in a serious injury or fatality.
The NEP also focuses on other safety topics that are not considered high-risk but attributed to the high injury rate: heat and ergonomic hazards. Additionally, OSHA may expand an inspection’s scope when evidence shows that violations may exist in other areas of the establishment. Overall, these are great areas of focus within these industries. Throughout my five years of being in the warehouse and distribution center sector, sprains and strains have been the most frequently occurring injury type and contributed to around half of all injuries I encountered. OSHA inspections related to ergonomics should look at packaging and loading workstations. The workforce in warehouse and distribution centers tend to be diverse, and one employee’s size and height could be completely different from another. Workstations, however, will be fixed. Heat-related illnesses vary throughout the United States, but states like Arizona tend to have 40-50 work-related fatalities due to heat stress.
For more information, visit: https://www.osha.gov/news/newsreleases/national/07132023#:~:text=%22This%20emphasis%20program%20allows%20OSHA,ensure%20worker%20health%20and%20safety.%22
Tyler Sandy is a Health and Safety Specialist and consults with clients in the area of worker safety. Tyler's experience includes industrial hygiene services, safety training, RCRA as well as OSHA and EPA compliance. His experience includes working with the packaging industry, railroad, welding, warehouse, food and medical waste, chemical manufacturing, and casting.
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A.C.T- Assess Control, Train
Read Part I of our IV part series: A simple pathway to Health and Safety Management
Part I of IV: A simple pathway to Health and Safety Management
No matter which framework an organization uses to develop its Health and Safety System, three critical steps remain the basis for keeping workers healthy and safe. Cornerstone has simplified those into the acronym A.C.T. for Assess, Control, Train.
ASSESS
OSHA’s “Safety and Health Programs Step-by-Step Guide” (https://www.osha.gov/safety-management/step-by-step-guide) has ten steps, including one for Hazard Identification and Control. While the OSHA tried-and-true Job Hazard Analysis (JHA) approach is similar to ours, we focus on evaluating risk as a guide to everything we do. OSHA’s method also has a risk analysis element; however, it results in an alphanumeric risk level which we have found to be less intuitive than the method we use. Cornerstone expands risk ranking by using an approach that assigns a rating for the Severity and Probability (1 through 4, with the lower rating corresponding to lower severity and probability) to each hazard identified. The product of multiplying these two ratings results in a numerical ranking of hazard controls needed. We work on the highest risks first. The risk levels correspond to a priority for controls.
Cornerstone uses the OSHA Hierarchy of Controls in this next step. This requires an organization first to eliminate, substitute, or isolate (engineer) hazards. Administrative controls, including procedures, plans, and training, are then considered, and, as a last resort, PPE is used to shield workers from the hazard.
The controls often include the development of administrative policies, procedures, and programs. Cornerstone works hard to develop these along with stakeholders at every level of the company. The information gathered in the previous steps guides how this is done. Controls can range from something as simple as wearing protective gloves all the way to Injury and Illness Prevention Plans and the establishment and facilitation of Health and Safety Committees.
TRAIN
Worker Health and Safety training and coaching are integral to making the controls come to life. If workers do not understand the controls, they will not use them. This is particularly important for Administrative and PPE controls where workers have a direct impact on the success of the control. Examples include how to wear PPE such as hearing protectors effectively and properly, Energy Control (aka Lockout/Tagout or LOTO) Procedures, and Ergonomic coaching. Classes can be set up for a subset of affected employees all the way up to organization-wide Health and Safety Orientation and Awareness training. Cornerstone works with its clients to make classes and scheduling effective and efficient. Our team of trainers has decades of experience in industry, education, logistics, and regulatory agencies.
TRAIN
Worker Health and Safety training and coaching are integral to making the controls come to life. If workers do not understand the controls, they will not use them. This is particularly important for Administrative and PPE controls where workers have a direct impact on the success of the control. Examples include how to wear PPE such as hearing protectors effectively and properly, Energy Control (aka Lockout/Tagout or LOTO) Procedures, and Ergonomic coaching. Classes can be set up for a subset of affected employees all the way up to organization-wide Health and Safety Orientation and Awareness training. Cornerstone works with its clients to make classes and scheduling effective and efficient. Our team of trainers has decades of experience in industry, education, logistics, and regulatory agencies.
Conclusion
Cornerstone’s A.C.T approach to health and safety management leverages industry best practices, broad experience, and a mind toward efficient action that maximizes our client’s resources and minimizes risks to workers.
Come back next month for a deeper dive into our risk-based hazard assessment service. We will demonstrate how it is conducted with a series of examples and case studies and discuss further some of the philosophies behind why we do what we do.
John Scifres is Cornerstone’s Director of Health and Safety Services. He is a Certified Hazardous Materials Manager and is a Provisional Lead Auditor for ISO 14001 and OHSAS 18001. He oversees Cornerstone’s team of EHS Project Managers. In addition, he consults with clients nationwide to ensure compliance with EHS regulations and evaluate opportunities to go above and beyond compliance.
#OSHA #Safety #InjuryandIllness #OSHA-300-A
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Occupational Exposure to Crystalline Silica: Possible Revisions
There are 2.3 million people in the U.S. alone that are exposed to silica at their workplace. Silica can be found in materials like sand, stone, concrete, and mortar which are in products such as glass, pottery, ceramics, brick, and artificial stone. High exposure to silica can result in diseases like Silicosis, lung cancer, chronic obstructive pulmonary disease, and kidney disease. The action level OSHA established is 25 µg/m3 and the permissible exposure limit is 50 µg/m3.
On March 25, 2016, OSHA made a final decision regarding occupational exposure to respirable crystalline silica. The standard established much needed action levels and permissible exposure limits which are calculated based on an eight-hour time-weighted average. The standard, however, did not establish a medical removal provision and only established medical surveillance provisions. Medical removal provisions are important for OSHA recordkeeping because if an employee meets or exceeds the limits during their medical surveillance, the employee must be removed from work. When an employee is removed from work for a medical condition or after surveillance, it is considered a recordable injury/illness due to an employee accumulating days away from work or restricted work. As of January 2023, there is not an established medical removal provision for crystalline silica, but there is a strong possibility this may change this year.
In the Spring of 2022, the U.S. Court of Appeals for the District of Columbia Circuit concluded that OSHA failed to explain why a medical removal provision was not included in the 2016 decision. As a result, a meeting to discuss further consideration was created and deliberation is currently scheduled for May 2023. If the change is made, it would have a major impact on industries across the country.
The importance of adding a medical removal provision, from an OSHA recordkeeping and employee health standpoint, is apparent but this doesn’t include a company’s financial and employee and employer relations point of view. Hypothetically, let’s assume that a company’s grinding operation exposes a dozen associates to a level where they are required to be medically removed from work. The grinding operation would need to be halted completely until certain controls have been made to reduce exposure for associates to continue working. Depending on the severity of the exposure, this could take months or even years to install equipment or create a respiratory protection program that reduces or eliminates exposure. This same company would also have to communicate this information to their employees, who may choose to leave due to unhealthy working conditions.
This potential change is one of many examples of why air sampling monitoring is vital to maintain a safe work environment. Silica monitoring should be completed at least on an annual basis or whenever there are process changes that may affect employees’ level of exposure to silica. In most cases, air sampling monitoring for silica can be completed in a single day with results coming back within the same month. Lastly, whether a medical removal provision is added or not in May 2023, there is a strong likelihood one will be established in the future, so getting a head start on monitoring and, if necessary, creating exposure controls will help long term.
Tyler Sandy is a Health and Safety Specialist and consults with clients in the area of worker safety. Tyler's experience includes industrial hygiene services, safety training, RCRA as well as OSHA and EPA compliance. His experience includes working with the packaging industry, railroad, welding, warehouse, food and medical waste, chemical manufacturing, and casting.
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Safety Signs 101: Understanding the Basics
Improper hazard communication including failure to properly follow safety sign regulations is one of the top 10 workplace violations cited by OSHA and contributes to thousands of workplace accidents each year. OSHA standard 1926.200 indicates that appropriate signage must be visible when performing work in at-risk areas. OSHA regulation 1910.145 tackles the specifications for accident prevention signs and tags. It discusses the different categories, colors, wording, and tags of signs.
Regularly checking the accuracy and visibility of safety signage at your facility is one of the easiest and most effective ways to prevent workplace injury. In fact, studies indicate that well-placed safety signs can minimize workplace accidents by up to 80%. This article will review standard 1910.145 to help you stay in compliance.
Categories and Colors
Danger Signs
Danger signs indicate immediate danger and that special precautions are necessary. The colors of the sign are red, black, and white. The image below is outside a construction site where there is a danger of falling objects. Therefore, as a safety precaution, hard hats must be worn in that area.
Caution Signs
Caution signs warn against potential hazards as well as against unsafe practices. The sign should be yellow with black lettering. The example below is of the wet floor sign we often see placed on freshly mopped floors of businesses.
Safety Instruction Signs
Safety instruction signs are used where there is a need for general instructions and suggestions relative to safety measures. The background should be white with a green panel and white letters. Any letters used on the white background should be black. You’ll often see the green signs around eyewash stations, safety showers, and exits.
Slow Moving Vehicles
If you have ever traveled in the Midwest during planting or harvest season, there is a good chance you have gotten stuck driving behind farming equipment. You might have noticed a triangle emblem on the back. Vehicles with a speed of 25 mph or less on public roads are considered slow-moving and are therefore required to display the triangle emblem. To make the sign visible both during the day and at night, the emblem is fluorescent yellow-orange with a dark red reflective border.
Wording
The wording of all signs follows the same general rules. If there is text, it must be clear, simple to read, and easily understood. The language must also be accurate and make a positive suggestion. The word "biological hazard" or "biohazard" must only be used to refer to infectious pathogens that are a danger or potential risk to human health.
Accident Prevention Tags
A tag is a label typically made of cardstock, paper, pasteboard, plastic, or other material that is used to classify a hazardous condition. Tags consist of a signal word and a major message. A signal word is intended to catch the pedestrian’s attention and should be able to be read from at least five feet away. Signal words include "Danger," "Caution," "Biological Hazard," "BIOHAZARD," or the biological hazard symbol (see below). You might also see “Warning” which can be used if the hazard level is between “Caution” and “Danger.” A major message identifies the hazardous condition or instruction for the employee and can be in the form of written text, pictographs, or both. Examples are “High Voltage” or “Do Not Use.” A pictograph uses pictures to represent a hazardous condition. With the help of tags, hazardous situations can be recognized and a warning to workers can be issued.
Conclusion
While this is not intended to be an exhaustive list of all the regulations relating to safety signs, it is a good basic introduction to the OSHA standards for signs. For more information, the ANSI standards Z53.1-1967 and Z535.1-2006 provide additional details on the regulations as referenced in the OSHA standard. If you would like to learn more about sign regulations, additional OSHA regulations regarding signs are referenced below.
1910.146 (c) – requiring signs for confined spaces
1910.335 (b) – electrical hazard signs
1910.37 (b) – signs for exits
1915.16 – employee comprehension of signs and labels
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Keep Pedestrians Safe from Forklift Accidents with OSHA Safety Training
It all begins with an idea. Maybe you want to launch a business. Maybe you want to turn a hobby into something more. Or maybe you have a creative project to share with the world. Whatever it is, the way you tell your story online can make all the difference.
Don’t worry about sounding professional. Sound like you. There are over 1.5 billion websites out there, but your story is what’s going to separate this one from the rest. If you read the words back and don’t hear your own voice in your head, that’s a good sign you still have more work to do.
Be clear, be confident and don’t overthink it. The beauty of your story is that it’s going to continue to evolve and your site can evolve with it. Your goal should be to make it feel right for right now. Later will take care of itself. It always does.
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OSHA Injury and Illness Recordkeeping and Reporting Requirements
Preventing workplace injuries and illnesses is always the focus of any company’s health and safety program; however, despite best efforts to eliminate workplace hazards and reduce risk, workplace injuries and illnesses still happen.
In my current position in the private sector and as a former OSHA Compliance Officer, I have provided safety and health consultation to employers in a wide range of industries. In both roles, I have noticed that many employers are not aware of their worker safety compliance obligations. Typical requirements that may be overlooked include injury and illness recordkeeping and reporting, documenting those records with sufficient detail, or submitting required records in a timely manner.
OSHA’s Recording and Reporting Occupational Injuries and Illnesses regulation, 29 CFR 1904, provides the compliance obligations for employers for recordable workplace injuries and illnesses. Many employers with more than ten employees are required to keep a record of serious work-related injuries and illnesses. (Certain low-risk industries are exempted). Minor injuries requiring first aid only do not need to be recorded. Visit the following links for more information on these topics:
During my career, I have found that some employers do not record occupational injuries and illnesses altogether. The basic requirement for recording listed in 29 CFR 1904.7(a) states: The employer must record any work-related injury or illness meeting the general recording criteria. That is, if it results in any of the following: death, days away from work, restricted work or transfer to another job, medical treatment beyond first aid, or loss of consciousness. Also, if it involves a significant injury or illness diagnosed by a physician or other licensed health care professional, even if it does not result in death, days away from work, restricted work or job transfer, medical treatment beyond first aid, or loss of consciousness.
OSHA Injury and Illness Recordkeeping Forms
Employers must use the required forms (or forms soliciting equivalent information). OSHA provides the following forms for injury and illness recordkeeping purposes:
Forms 300, 300A, 301 and Instructions PDF Fillable Format
Forms 300, 300A, 301 Excel format (Forms ONLY) Requires Microsoft Excel or equivalent
Recording Details and Following Instructions Required by the Form
In my experience, when an employer has kept injury and illness records, the records lack the detail required and the instructions were not followed. There are numerous examples of this: not classifying the case correctly; entering the wrong information on number of days away from work or days of restricted work; incorrect tallying of injury and illness case totals; or lack of employer representative signature are a few examples commonly mentioned.
Maintaining and Posting Records
The records must be maintained at the worksite for at least five years. Each February through April, employers must post a summary of the injuries and illnesses recorded the previous year. Also, if requested, copies of the records must be provided to current and former employees, or their representatives.
Severe Injury Reporting
Employers must report any worker fatality within 8 hours and any amputation, loss of an eye, or hospitalization of a worker within 24 hours.
Electronic Submission of Records
On many occasions, I’ve noted that an employer has failed to submit injury and illness records to OSHA in a timely manner or not at all. OSHA’s Injury Tracking Application (ITA) provides a secure website that offers three options for injury and illness data submissions. You can manually enter your data, upload a CSV file to add multiple establishments at the same time, or transmit data electronically via an API (application programming interface).
Who is covered by this reporting requirement?
Only a small fraction of establishments are required to electronically submit their Form 300A data to OSHA. Establishments that meet any of the following criteria DO NOT have to electronically report their information to OSHA. Remember, these criteria apply at the establishment level, not to the firm as a whole.
The establishment's peak employment during the previous calendar year was 19 or fewer, regardless of the establishment's industry.
The establishment's industry is on Appendix A to Subpart B of OSHA’s recordkeeping regulation, regardless of the size of the establishment.
The establishment had a peak employment between 20 and 249 employees during the previous calendar year AND the establishment's industry is NOT on Appendix A to Subpart E of OSHA’s recordkeeping regulation.
What must covered establishments submit?
Covered establishments must electronically submit information from their OSHA Form 300A.
When must covered establishments submit their completed Form 300A?
Establishments must submit the required information by March 2 of the year after the calendar year covered by the forms (for example, by March 2, 2022 for the forms covering calendar year 2021).
If the submission due date of March 2 has passed, establishments that meet the reporting requirements and failed to do so must still report their Form 300A data through the ITA and can do so until December 31.
Does OSHA provide training for the general public on recordkeeping requirements?
Yes. Through its national network of OSHA Training Institute (OTI) Education Centers, OSHA offers the OSHA #7845 Recordkeeping Rule Seminar course. This half-day course covers the OSHA requirements for maintaining and posting records of occupational injuries and illnesses, and reporting specific cases to OSHA. Included in the course are hands-on activities associated with completing the OSHA Form 300 Log of Work-Related Injuries and Illnesses, OSHA Form 300A Summary of Work-Related Injuries and Illnesses, and the OSHA Form 301 Injury and Illness Incident Report. To search for specific course locations and dates, please visit the OTI Education Centers searchable schedule.
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Proactive Steps That Can Prevent Workplace Incidents
Most people are familiar with the basic regulatory requirements facilities must meet under their respective reporting regimes. Many of these requirements involve documenting incidents AFTER they occur and then performing risk or root cause analysis to drive potential change in the workplace. There is no doubt these are important steps in creating a safer workplace culture, but what if you could have a safer workplace before waiting for something bad to happen?
This is where the concept of a behavior-based safety program comes into play. Programs like these are setup so that you can identify unsafe conditions and behaviors and perform risk analysis operations on them; thereby eliminating potential accidents before they ever occur.
What would this look like in practice?
Observations
Having a daily observation program in place to monitor workers during the day for five minutes can have a huge impact. A simple observational program can be easily formed and effortlessly repeatable. Those small observational data points can then be combined to provide trends to safety managers to see if there are changes necessary to the safety program.
Checklists
In this instance, employees are provided with a checklist of things to do to operate efficiently and safely in their environment. This can be anything from lockout/tagout procedures, work procedures and/or training manuals for specific equipment operation. Having clear-cut directions simplifies tasks and makes them much safer.
Goal Setting
Establishing identifiable safety goals to work towards can also make your workplace safer. Everyone is familiar with the typical “days without incident goal”, but there are many other achievable victories to be had. Reducing the number of days with PPE infractions is an example. Combining goals with small incentives will eventually save money by helping to reduce incident costs, lower insurance costs, and prevent the loss of productivity.
This may seem like a lot of work to prevent something that may not even happen, but I promise it is worth the time and effort to set up a system to automate these tasks. To help, Cornerstone has built systems that manage these elements and can provide templates and startups to get a new, more proactive safety management system off the ground quickly and easily.
Not only does Cornerstone have the applications to easily manage all this data, but we have the expertise and knowledge behind all our systems to provide insights, offer advice and guide our users in the right direction. All of this combined has saved our customers time, money, and lives. That’s the ultimate end goal of any safety system: to provide a productive work environment for employees and see them all go home at the end of each shift safely. We are proud to provide our clients with the tools and knowledge to help make that happen.
Joshua Sampia is the Director of Product Development. He is responsible for the applications development team at Cornerstone, ranging from web-based and mobile applications to device management for safety and environmental compliance and applicability.
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Risk Assessment: The Starting Point of Health and Safety Management Systems
Starting at the Beginning
Over the past couple of years, the focus on a systematic approach to worker health and safety has never been greater. Whether due to unprecedented illness records due to the pandemic or a greater focus on how their workers’ health impacts a company’s sustainability, it is something that is gaining momentum. A key first step in creating the basis for an occupational health and safety management system is to assess the risks that a company faces. This assessment is the starting point to controlling risks and keeping workers healthy and safe.
Tackle the Most Important Things First
One of the key advantages of a risk-based approach is that the most important and risky things are worked on first. Every organization has a limit to their available resources. Allocation of these resources is critical. Traditional job hazard analysis does not provide as distinct of a list of priorities as using a risk-based approach. Hazards are simply identified for control with little or no explicit ranking of needed action. Incorporating risk analysis into job hazard analysis is the key to prioritizing controls to best utilize resources.
Take Advantage of Worker Participation
Cornerstone begins the task of evaluating worker health and safety hazards and their risks with a risk-based workplace hazard assessment. This is a cooperative practice with the workers who face the hazards. Along with HSE managers and supervisors in the work areas, each job and its tasks are assessed to determine the hazards present. The team then determines the risk of negative outcomes from each task by judging the severity and probability of the negative outcome. They assign a numerical score to each risk and the product of those gives us a risk level for each hazard.
Control the Risks
We determine an acceptable risk level with the team and anything that exceeds that level requires action. Our staff will then determine required or recommended controls for each hazard. We use the US OSHA (Occupational Safety and Health Administration) Hierarchy of Controls to guide this part of the assessment. In the end, Cornerstone Health and Safety evaluators produce a prioritized list of needed controls. Those hazards with a higher risk level demand more urgent action. This action is designed to reduce the risk level. Either through eliminating the hazard, minimizing the severity, or decreasing the probability, the list of hazards and their risk level shifts as controls are implemented. This automatically shuffles the priorities so that, again, the highest risks are controlled first.
Whether done to conform to an ISO Standard, for ESG (Environmental, Social and Governance) efforts, or simply to improve as a corporate citizen, the development of a formal occupational health and safety management system is more and more commonplace. Nearly all formal standards rely on a risk-based analysis of hazards as a starting point for the system. These analyses help organizations identify all the hazards, determine the level of risk they present, and prioritize them for action. Talk to Cornerstone more about how we can help you in your efforts to continually improve your occupational health and safety management system.
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OSHA Form 300A Compliance
Form 300A is the summary of work-related injuries and illnesses occurring at your facility during the previous year. Employers are required to post this information at their location from February 1 through April 30 of the following year.
Just like Tier II compliance, summaries are required for each individual plant or facility under your management. Separate logs and summaries should be maintained at each site.
One of the more recent developments, however, is that summary information must be submitted to OSHA through their online portal if your facility meets certain size and industry requirements. For more information regarding requirements for industry, you can use OSHA’s FAQ website here: https://www.osha.gov/injuryreporting .
The rule requiring establishments with over 250 employees to submit the entire 300 Log and not just the summary was amended and is no longer required; however, facilities must continue to maintain those records and are required to provide them to an inspector upon request.
So, how can Cornerstone help?
Our Incident Management program will not only help you accurately collect and maintain incident information, but it can also provide customization and control well beyond OSHA’s generic spreadsheets and manual collection. It will also keep backup archives so this information can never be lost.
All facilities are required to submit information through the OSHA Injury Tracking Application (ITA) website. Cornerstone can help by automatically generating files in “.csv” format to upload to the OSHA ITA program to save you time entering the summary data for every single facility. Even for a single facility, it is much more efficient to upload the csv file rather than manually entering the data.
In addition to proving a summary to comply with reporting requirements, the program will automatically generate the “.pdf” files necessary for display at the facility. Again, this is not a reporting requirement, but is required for compliance.
This is just a fraction of the benefits an incident management system can provide. Most importantly, it can help drive a healthier and safer workforce while also easily keeping you in compliance with electronic recordkeeping requirements.
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Controlling Occupational Exposures
The role of an industrial hygienist is to recognize potential exposure hazards, evaluate exposures, provide input for the development of controls, and finally evaluate control methods for effectiveness in reducing exposures.
When controls are warranted, the process begins with a risk assessment to characterize the problem. The hygienist can provide assistance in identifying and characterizing the hazard, the emissions and sources, worker involvement with the sources and how air movement occurs.
Control measures can be grouped into three categories: administrative, engineered, and personal protective equipment. When considering controls, there are five fundamental assumptions to bear in mind:
All hazards can be controlled (to some degree).
There are different approaches for control.
Sometimes, more than one control method is needed.
Some control methods are more cost-effective than others.
Controls may not always be completely effective in limiting the exposure hazard.
Administrative controls place part of the burden of control on the worker and are often not completely effective when used as a single approach. Examples of administrative controls include rotating workers, providing best practice training for performing job tasks, improving personal hygiene, and implementing housekeeping programs.
When considering options, it is necessary to evaluate the sources of exposure, the way in which it can affect the worker, and the route of entry. Typical routes may include unprotected exposure to noise, skin contact or inhalation of vapors and aerosols. The controls considered should be matched with the employee, the process or task, and be cost-effective. In some cases, there are regulatory requirements for controls such as the OSHA (Occupational Safety and Health Administration) requirement for exhaust ventilation for abrasive blasting (1910.94).
Worker rotation is frequently used to reduce the amount of time a worker is exposed to a hazard. A common example is rotating workers performing jobs in high-noise areas. Another example is to move workers every few hours who perform highly repetitive job tasks to reduce musculoskeletal strain.
Training in good work practices can significantly reduce exposures. For example, coaching proper body postures such as how to stand and position the head while welding or reinforcing the need to face forward to work and pivot feet instead of twisting the body.
Good housekeeping and personal hygiene are also important components of administratively controlling exposures. Settled dust becomes a secondary source of exposure with increased air movement, traffic activity and vibration produced by equipment. Frequent cleaning helps to prevent dust accumulating on surfaces.
Training and reinforcing the need for personal hygiene, such as frequently washing hands and avoiding hand to mouth contact while working can reduce the risk of exposure by ingestion. Several standards contained in OSHA 1910 Subpart Z for toxic and hazardous substances mandate personal hygiene practices. Administrative controls are usually used in conjunction with engineered controls.
Although they are more expensive to implement, engineered controls are the most effective since they offer greater cost savings over time. Examples of engineered controls include source modification, substitution, process change, isolation, and ventilation. The development and installation of engineering controls is usually the responsibility of a facilities engineering department and maintenance staff.
Source modification refers to changing an emission source to make it less hazardous. An example of source modification is wetting dust particles released in a foundry shakeout operation to reduce dispersion. Another example may be to reduce temperatures to lower the level of chemical off-gassing and vaporization.
Modifying a process to reduce the hazard is another type of engineered control. An example of this would be to dip rather than to spray paint parts. Automation would also be an example of changing the process. A good example is robotic welding to replace manual welding.
Substitution refers to changing to a different material, type of equipment, or process to reduce the hazard. Examples include substituting a solvent having a low occupational exposure limit (OEL) and higher vapor pressure to a different solvent having no established OEL, or a lower OEL and less volatility.
Isolation refers to separating employees from hazardous processes, equipment, or environments. Isolation can be achieved by placing barriers around equipment or materials, such as the use of ventilated flammable cabinets or placing enclosures around high-noise sources. Isolation separates employees from hazards. Examples are control rooms, isolation booths and supplied air islands.
Ventilation is frequently used as a method to control emissions near the source or to dilute emissions to levels that are acceptable. Local exhaust ventilation (LEV) attempts to eliminate emissions to the work room air. LEV controls are designed to capture, control, or eliminate emissions using control structures such as hoods, exhausted enclosures, ductwork, air cleaners, fans, and exhaust stacks.
General exhaust ventilation relies on fresh air dilution, either by open doors, windows or make-up air provided by air intakes and ventilation systems. For constant emission sources, effective dilution relies on good air mixing and constant air flow.
In addition to engineered solutions, regular and preventative maintenance is an important part of preventing uncontrolled and unexpected exposures. Insufficient maintenance could result in a catastrophic failure such as a rupture failure, increasing leaks from flanges, seals, access doors, and breakdowns of equipment.
Personal protective equipment (PPE) should always be used as the last option for control when other methods of control are not feasible or effective enough to reduce exposure to safe levels. Relying solely on earplugs or respirators places the burden of control on the worker and the protection is only as good as how properly the PPE is fit, worn, and maintained.
There are many different options to help keep workers safety, contact us to evaluate exposure concerns in your facility.
Mary Dunlap is a Certified Industrial Hygienist and has been with Cornerstone Environmental, Health and Safety since 2016. When she is not working, you can find Mary enjoying the outdoors.
Source: Case Studies: Sixty Practical Approaches of OH&S Control Principals. D. Jeff Burton, MS, PE (former CIH (Certified Industrial Hygienist), CSP)
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OSHA Proposes a New Scheme for Injury and Illness Reporting
On March 28, 2022, OSHA announced a proposed rule to amend the federal occupational injury, illness recordkeeping regulation. If approved, the proposed rule will change the requirement to submit illness and injury summaries (OSHA 300-A) for many companies with 20-249 employees and almost all employers with 250 employees, and would potentially require fewer establishments to report more detailed information.
The proposed change will require establishments with 100 or more employees, in certain high-hazard industries, to electronically submit not only the 300-A summary but more detailed information from their log of injuries/illnesses (OSHA 300) and the Injury and Illness Incident Reports (OSHA 301).
The “high-hazard industries” (found in Appendix B to the proposed rule) includes a wide swath of the economy including agriculture, manufacturing, wholesale, retail, transportation, warehousing, real estate, healthcare, art, entertainment as well as hotels and food service.
Another critical change will require establishments to include their company name when making electronic submissions to OSHA. This is very important when you consider that the submissions are posted online. That has been the case for years and the data is very revealing, but only in a limited way. The additional reporting requirements would make details about your worker injuries and illnesses a matter of public record. In addition, accurately recording and reporting the information will become even more critical. (The data reported currently is available at https://www.osha.gov/Establishment-Specific-Injury-and-Illness-Data)
At a time when your company’s data is more accessible than ever by a global audience, it is crucial to understand how and when it is shared. Cornerstone will monitor this proposed rule and keep you informed. In the meantime, we recommend that all impacted employers read and understand the proposed rule and comment as needed. Comments must be submitted by May 31, 2022.
Read the full release and get more information here: https://www.osha.gov/news/newsreleases/national/03282022-0
John Scifres is Cornerstone’s Director of Health and Safety Services. He is a Certified Hazardous Materials Manager and is a Provisional Lead Auditor for ISO 14001 and OHSAS 18001. He oversees Cornerstone’s team of EHS Project Managers. In addition, he consults with clients nation-wide to ensure compliance with EHS regulations and evaluate opportunities to go above and beyond compliance.
#OSHA #Safety #InjuryandIllness #OSHA-300-A
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Do You Need a Confined Space Permit?
Many facility managers get understandably confused when they try to decide if they have to comply with the Occupational Safety and Health Administration (OSHA) standard on Confined Spaces (29 CFR 1910.146). OSHA requires all workplaces to evaluate the entire facility and determine if there are any permit-required confined spaces. This process has two steps.
Step 1: Does It Meet the Definition?
You first must evaluate any potential space to see if it meets the definition of a confined space. The OSHA definition of a confined space has three parts:
It is large enough and so configured that an employee can bodily enter and perform assigned work. This means the employee must fit his entire body into the space.
It has limited means of entry or exit. This could mean a single entry/exit or multiple entries/exits that are very small or hard to get through.
It is not designed for continuous employee occupancy. For example, it is not designed to have an employee inside while the system is in operation.
If any spaces meet all three of these parts, then it is a confined space. If it only meets one or two, it may still be a hazardous area, but it is not a confined space, and 29 CFR 1910.146 does not apply. As an example, a basement may meet the first and second parts but, as it is designed for employee occupancy, it would not be a confined space.
When it does meet all three of these parts, then the facility must determine if its employees will enter the space. If they will not enter the space, the facility still has requirements to secure the space to make entry difficult, install signage marking the hazard near the point of entry, and train employees where the spaces are and why they should not enter.
If employees will enter the space, then you must conduct Step 2.
Step 2: What Is the Hazard Type?
You must evaluate each space to see what hazards may exist. OSHA has identified four potential hazards in a Permit-Required Confined Space
Atmospheric: It contains or has a potential to contain a hazardous atmosphere. Such spaces may lack oxygen, contain toxic gases, have flammable vapors, or hold combustible dust.
EH&S Managers should keep in mind that some spaces may only temporarily have hazardous atmospheres. Tanks and pits that do not normally present a risk could develop a hazard episodically or accidentally. An example could be a pit that fills with a heavy vapor from a nearby propane fueling area or vehicle fumes.
In order to determine if your space meets any of these conditions, the facility must use an air monitor; normally a three-gas meter that detects oxygen levels and, toxic and flammable gasses. In addition, you must train any employees who would enter the space to use the meter
Engulfment: Contains a material that has the potential for engulfing a person. This would include either liquids (water or chemicals) or solid materials (like dusts, grains or resins). If an worker sinks into particles up to his diaphragm, he has the potential to be asphyxiated before he can be rescued. Even if a space is temporarily empty, facility managers should remove the potential for the space to fill by locking out any pipe or valve systems that could fail and fill up a space while an employee inside.
Entrapment: The defined confined space has an internal configuration that can trap or asphyxiate an employee by inwardly converging walls, sloping floors, tapering spaces. Dust collection systems are examples of the inwardly converging walls, while ventilation systems may slope downward and taper at the ends.
Others: Any other recognized serious safety hazard. This covers a multitude of potential hazards such as electrical, thermal, corrosives, and mechanical hazards such as rotating parts, augers, or blades.
If the confined space has one or more of the above hazards, then it falls under the OSHA requirements of a Permit-Required Confined Space for entry. The employer must prepare a written program that details how the company will protect the employees who enter the space including preparing a permit, training employees, monitoring the space to ensure acceptable conditions are maintained, and emergency rescue equipment.
Exemptions
There are two potential exemptions to the regulation. Employers can install equipment to eliminate mechanical or electrical hazards from the exterior before entering the space or add a forced-air ventilation system to disperse atmospheric hazards. In each of these exemptions, OSHA requires clearly defined procedures and periodic testing to ensure worker safety.
Safety First
Dozens of workers are injured each year in confined spaces. It is the employer’s responsibility to ensure that any entry into a confined space must be according to the rules and be safe. It’s up to you to get your employee home safely at the end of every shift.
Cornerstone offers the most comprehensive hazard evaluation service in the industry, call us today to discuss your confined space program. www.corner-enviro.com
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Winter Weather Driving Safety Tips
The onset of winter weather brings to mind the obvious hazard of cold stress; however, workers also can be exposed to weather-related hazards while driving.
Winter Driving
Employers should encourage workers to implement safe driving behaviors. The first step should always be to assess the risk of driving in winter weather conditions. Crashes can be avoided if workers recognize the hazards of driving on snow-and ice-covered roads and train to drive safely in slick conditions. Employers should establish driver safety policies; monitor drivers’ safety performance; and enforce driving rules.
To ensure safety, employers must implement an effective maintenance program for all vehicles and equipment operated. A vehicle inspection to determine proper functioning should include:
Brakes: Brakes should provide even and balanced braking. Also check that brake fluid is at the proper level.
Gas Tank: keep the tank at least 1/2 full.
Cooling System: Ensure vehicle cooling systems have the proper level and mixture of antifreeze and water.
Electrical System: Check the ignition, battery, and alternator belt.
Engine: Inspect all engine systems.
Exhaust System: Check exhaust for leaks.
Tires: Check tread depth, signs of damage or uneven wear, proper tire inflation.
Oil: Check oil level.
Visibility Systems: Inspect all exterior lights, defrosters, and wipers. Install winter windshield wipers.
Work Zone Traffic Safety
Workers can be struck by vehicles or mobile equipment in work zones. This leads to many injuries and fatalities annually. During snow and ice events, vehicles can skid causing drivers to lose control. It is important to properly set up work zones with traffic controls identified by signs, cones, barrels, and barriers, to protect workers. Workers also need to wear proper PPE such as high visibility vests, jackets, and pants when entering work zones.
Stranded in a Vehicle
If you are stranded in a vehicle, stay in the vehicle. Call for emergency assistance if needed, but be aware that due to severe weather, response time may be slow. You should also call someone, such as a family member or your employer, and notify them of your situation. Do not leave the vehicle to search for assistance unless help is visible within 100 yards. Signal distress by hanging a brightly colored cloth on the vehicle’s radio antenna and raising the hood.
To help keep warm, turn on the vehicle's engine for about 10 minutes each hour and run the heat. Also, turn on the vehicle's interior lights when the vehicle is running as an additional distress signal. However, you should beware of carbon monoxide poisoning. Keep the exhaust pipe clear of snow and open a downwind window slightly for ventilation.
Watch for signs of frostbite and hypothermia and maintain good blood circulation by doing minor exercises, such as clapping your hands and moving your arms and legs occasionally. Try not to stay in one position for too long. Staying awake is vital so that you will be less vulnerable to cold-related health problems. Use blankets, newspapers, maps, and even the removable car mats for added insulation. However, you should avoid overexertion since cold weather puts an added strain on the heart. Unaccustomed exercise such as shoveling snow or pushing a vehicle can bring on a heart attack or make other medical conditions worse.
Cornerstone's safety experts are ready to help you develop a world-class safety program and train your workers in the latest safety information. Contact us at info@corner-enviro.com for more information or view our website at www.corner-enviro.com
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Health and Safety Sustainability: Does Your Operation Go "Above Compliance"?
Earlier this year, I wrote an article entitled “Where the S in ESG intersects with HS in EHS.” While I stand behind the tenor of that piece, there is one thing I said that gives me some pause. I wrote “Today, compliance with Environmental, Health, and Safety (EHS) regulations is a given. Employers must go beyond compliance.” That statement is true when viewed through the ESG and sustainability lens. But my history with clients, including recent work, has shown that sometimes even the most sophisticated of our clients still falls down when it comes to compliance with OSHA regulations. At times, companies within the regulated community have difficulty remaining in compliance with applicable regulations. So, how can they go beyond compliance to sustainability?
I’ll be the first to admit that compliance with governmental regulations doesn’t always equate to a healthy and safe workforce. Unfortunately, it doesn’t always work that way; however, when regulators discover violations and take enforcement action, investors, competitors, and employees will take notice. You simply cannot have strong ESG performance without a good compliance record.
Take the Hazard Communication Standard (HazCom) for example. Failing to properly label chemicals or not keeping an updated chemical list and corresponding Safety Data Sheets (SDSs) is always one of the Top 10 Most Frequently Cited Standards. In 2020, it was #2 on the list. HazCom has been around since the beginning of my career. You can do some research and see that is a very long time — over 30 years! What that means is that in three decades, many facilities still struggle with basic aspects of labeling and documentation. A recent project at a very large corporate client demonstrated this, when we discovered almost 99% of their chemical list was outdated or missing SDSs.
Another frequently cited Standard is Energy Control (a.k.a. Lockout/Tagout). It was #6 in 2020. We do dozens of projects each year with very large clients, and it is unanimous that if OSHA took even a cursory look at their procedures and training, violations could follow. Conducting lockout, training employees, writing procedures for each piece of equipment, and inspecting the procedures each year is required.
One reason more enforcement doesn’t occur is that OSHA is a very small agency. Inspections fell drastically in 2020 due to the pandemic. In 2019, over 33,000 inspections were conducted. This dropped to under 22,000 in 2020. In early 2021, the Department of Labor Office of Inspector General called OSHA out on this reduction, and everyone agreed that more and deeper inspections were needed. In short, expect more inspections and investigations.
Additionally, in October, Douglas Parker was confirmed as OSHA’s new leader. It bears mentioning that he is a past chief of California’s Division of Occupational Safety and Health (Cal/OSHA). Anyone with experience in California knows the approach taken there to worker health and safety. It is a much more enforcement-focused regulatory scheme. It is likely that some of that scheme will follow Mr. Parker to the Federal OSHA he now leads.
So, the question is, are you ready to go beyond compliance? If you do not have a good feeling about your compliance program, the answer may be “no.” And, if that is the case, what are you risking beyond the health and safety of your workers? If sustainability and ESG performance are what you aspire to, you may be risking investment, growth, and the long-term outlook of your business.
Further Information
As ESG reporting becomes more vital and more publicly transparent, Cornerstone’s industrial health and safety experts can help ensure that your programs and data are ready for the spotlight. Contact us at info@corner-enviro.com or visit our website for more information regarding our ESG services.
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Industrial Hygiene Services Prevent Health Hazards for the Plastics Industry
The U.S. plastics industry employed just under one million workers in 2020 and continues to grow and expand. Leading the way in production and employment are Texas, Ohio, and California. In addition to environmental and safety issues, health hazards associated with the production of plastic products are a concern and should be recognized.
Man manufacturing upvc frame
Types and Characteristics of Commonly Used Plastics
The major types of plastic are classified as thermosets, elastomers, and thermoplastics. Thermosets are heated and require a curing agent which results in a permanent form that cannot be reground and reused. Elastomers can return to the original shape and size after deformation but are not formed by the same process as rubber. Thermoplastic polymers (resins) are widely used because they can be re-ground and re-molded; thereby eliminating waste and reducing production costs.
The most common thermoplastic polymers in use include:
Polyethylene
Polypropylene
Polyvinyl chloride (PVC)
Polystyrene
Acrylonitrile-butadiene- styrene (ABS)
Styrene acrylonitrile
Styrene-butadiene copolymers
Prior to molding, thermoplastic resins are mostly inert and present a low health risk except for any unreacted residual monomers, or molecules that bond together to form the polymer structure. A striking example of the effects of overexposure to resin dusts occurred in the 1970s when several workers who handled PVC resins were diagnosed with angiosarcoma, a rare liver disease. A significant reduction in exposure that lowered the risk for the development of disease was achieved when controls were applied to reduce the amount of unreacted monomer present in PVC resins. The levels went from as high as 1 percent to 0.001 percent.
Other sources of exposure can occur when the additives are combined with the resins to produce specific properties for the end product. Ideally, this occurs in a closed-looped system that exhausts the dust and minimizes exposure. In smaller operations, this is often not the case.
Additives are added to modify the properties of resins, aid in the molding process, and provide color. Common additives include flame retardants, antioxidants, blowing agents, optical brighteners, antistatic agents, UV light absorbers, fillers, solvents, curing agents, and reinforcements. Nearly 2,500 different chemicals are used in the production of additives. Additive compounds that commonly pose risks include:
Phthalates in plasticizers
Antimony, boron, bromine compounds in flame retardants
Hydrochlorofluorocarbons (HCFCs) and azodicarbonamide in blowing agents
Toxic heavy metal compounds (lead, cadmium, and chromium) in colorants
Thermal degradation products from organic colorants that are used as alternatives to metal compound colorants
Hazards During the Molding Process
The next phase where hazards exist is during the molding process, when the mold is released, and during purging and maintenance. Purging is performed whenever there is a resin or color change, or maintenance is needed on equipment. During purging, higher than usual molding temperatures are needed to clear the equipment of residue, and smoke is produced that may contain thermal degradation products from the resin and additives.
To protect workers, it is necessary to provide adequate exhaust ventilation in and around molding lines. If ventilation controls are inadequate in controlling dust levels during mixing, mists and vapors during mold release, or smoke generated during purging, occupational exposures should be assessed.
Sampling Strategy
The starting point for designing a good strategy for sampling is to review Safety Data Sheet (SDS) information for the resin and additives used in the process to determine regulated components and thermal degradation products. Some examples of constituents that are commonly assessed during personal sampling include the following:
Butane- contained in n, and acrolein in polypropylene resins
Hydrogen chloride in PVC resins
Styrene contained in polystyrene
Phenols and butadiene contained in ABS resins
Nuisance dust
When results from sampling are available, it can be determined if exposures have exceeded occupational exposure limits (OELs) established by the Occupational Safety and Health Administration (OSHA), the American Conference of Governmental Industrial Hygienists (ACGIH), and the National Institute of Occupational Health and Safety (NIOSH). If exposures exceed OELs, the proper respiratory protection can be provided to the workers in accordance with the OSHA Respiratory Protection standard but should be used only as a stopgap before control measures can be implemented and tested for effectiveness.
Noise Exposure
Another health hazard to consider in the plastics industry is noise exposure. It is common for noise exposures to exceed the OSHA Action Level (AL), which is 85 “A”-weighted decibels (85 dB(A) for hearing conservation.
In a typical operation, there is a high density of noise sources such as motors, fans, hydraulic pumps, and other equipment. Depending upon the size of the operation, exposures can even exceed the Permissible Exposure Limit (PEL) of 90 dB(A), and when that occurs, engineering and/or administrative controls are needed to reduce exposures.
Personal noise exposures are easily assessed utilizing calibrated noise dosimeters that record and average sound levels throughout the work period. The data logged is then used to determine the 8-hour time-weighted average exposure which can then be compared with the AL and PEL.
Further Information
Cornerstone serves clients that produce plastic products or packaging used by the food and beverage industry, health and beauty products, and a variety of consumer goods. Our Health and Safety department can perform a Personal Exposure Assessment to observe operations, job tasks, and work practices for air, noise, and ergonomic safety. Our experts provide reports of risks, prioritize areas for changes, and recommend control measures. Contact Cornerstone at info@corner-enviro.com or on our website for more information.
Mary Dunlap CIH, is a Senior Industrial Health and Safety Specialist and Certified Industrial Hygienist. She works with Cornerstone’s clients to develop exposure assessment strategies tailored for their work environments. She regularly performs ergonomic assessments using a variety of OHA and NIOSH tools to rate severity of risk for work related to musculoskeletal disorders.
References:
Recognition of Health Hazards in Industries – Second Edition, William A. Burgess
The Hazards of Plastic Injection Molding and Recommended Engineering Safety Controls – Sentry Air Systems
Recent Posts
OSHA Frequency Requirements for Safety Training
Don’t let Worker Health and Safety Training slip through the cracks! The safety of your workplace depends on providing your employees relevant, up-to-date training — plus it is a key requirement to comply with OSHA regulations.
Is your workforce receiving the training they need when they need it?
Digging through OSHA’s website to find this information can be time-consuming, and often training requirements may still be unclear after reading the regulations.
Cornerstone’s worker safety team members have decades of experience from industry, agencies, and the military. We will work with your organization to deliver an effective worker safety program that helps ensure OSHA compliance and prevent workplace emergencies.
Recent Posts
Air Quality Modeling: What Is It?
Frequently, a manufacturing plant or industrial operation may have processes that emit air pollutants into the atmosphere. In most cases, the operation will be required to calculate the potential, and sometimes actual, emissions and present the findings to their State’s environmental agency. Then, the type of emission sources and the potential and/or actual emissions rate will be used to determine if an air permit is required. The State will also review the sources and emissions and apply specific regulations to the plant to allow those emissions to be released into the environment. This information will typically be summarized and included in an air permit. Additionally, depending upon the amount or nature of the emissions, the permit may include requirements for controls or limits on emissions.
In some cases, a regulatory agency may ask an operation to present information beyond the amount of calculated air emissions released into the atmosphere. The plant may have to determine what the impact of their emissions is on the surrounding community. When an operation has the potential to release chemicals that, in high concentrations, could cause unhealthy conditions, State regulatory agencies may require an estimate of downwind effects of air pollution emissions. This is accomplished by using air quality modeling.
How do you calculate downwind air pollutant concentration?
Calculating the volume of pollutants being emitted from a stack is relatively straightforward, however, using air quality modeling to determine the concentration of pollutants downwind of the facility is a more complex process. Air quality modeling uses computer programs to calculate the release of a pollutant into the atmosphere and determine how it disperses as it travels downwind. The program will then calculate the eventual concentration of that pollutant at a certain location.
The U.S. EPA has developed many different air quality models to calculate downwind air pollutant concentrations, and these models vary in size and complexity. Simple air quality models, known as Screening Models, can quickly determine concentrations and require limited information about the emissions and the emission points. Screening Models are relatively quick to prepare, do not require a lot of site-specific information, and will provide general estimates of downwind concentrations.
Other more sophisticated models, known as Refined Models, require more detailed information to generate results. These models use site-specific information, such as local weather data, terrain elevation around the site, and other specifics about the emission sources. Due to the complexity and amount of information required, Refined Models require significantly more set-up time and effort to obtain proper results.
You may ask, “If the Screening Model is so easy to use, why would anyone want to use the Refined Model?” The simple answer is that Screening Models are not as accurate as Refined Models. Usually, Screening Models tend to estimate concentrations on the high end to prevent underestimating the downwind impacts. Screening Models are also very general and are not designed to estimate emissions from complex scenarios. Refined Models are able to model complex situations and are site-specific.
Which model should you use — Screening or Refined?
In most cases, Screening Models are used as a “first step” and, since they tend to overestimate emissions, provide a conservative estimate of concentrations from a source. If the calculated concentrations from a Screening Model show no adverse health effects, then one can assume the emission source will not adversely affect the surrounding environment. If, however, a Screening Model shows concentrations higher than allowable values, all is not lost. A Refined Model can be used to provide more accurate and often lower concentrations, possibly showing that the emission source would not have detrimental effects on the downwind area.
Further Information
Cornerstone can help you determine whether air quality modeling is necessary for your facility. Our team of experts has provided clients with both Screening and Refined Modeling analyses to assist them with State agency modeling requirements and other studies. For more information about our air quality services, please visit our website or contact us to discuss your specific needs.
John Nuckels, Sr. Environmental Engineer
John helps clients with the preparation of air permits and supports them in responding to inquiries by State permitting agency personnel. His expertise in air quality monitoring, stack tests, recordkeeping, and reporting assists clients in achieving and maintaining air quality compliance. Industry experience includes aerospace, aluminum, motor vehicle / automotive parts, government, plastics, military, and other manufacturing clients in both public and private sectors.
Recent Posts
Incident Investigation and Injury/Illness Reporting Requires a Systematic Approach
No one wants to have workplace accidents, but when they happen it’s important to have an Incident Investigation and Injury/Illness Reporting Program in place. The program must include the procedures necessary to properly investigate the incident and determine the cause as well as how to prevent a recurrence. The following is a summary of the steps necessary to properly respond, investigate and record an incident to meet OSHA compliance.
Reporting the Incident
First and foremost, employees must immediately report all incidents and near misses to their supervisor who will then notify the person responsible for incident investigation and injury/illness reporting. Depending upon the type and severity of the incident, notification to OSHA may also be required.
Investigate the Scene
All incidents, regardless of severity or impact, need to be thoroughly investigated. The process must look beyond what happened to discover why it happened. This will allow for the identification and correction of shortcomings in the safety and health management programs. The principal incident investigators must go to the site of the incident to conduct the investigation. It is critical that the scene is preserved to prevent material evidence from being removed or altered. Using cones, tape, and/or other guards may be required. Facts must be carefully documented.
Collect Information
The principal incident investigators must collect information through interviews, review of documents, and other means. Using a checklist may help ensure that all information pertinent to the incident is collected. In addition, other sources of useful information may be sought out such as equipment manuals and training records.
Determining Root Cause of the Incident
The principal incident investigators must determine and document the underlying reasons the incident occurred and the corrective actions required to prevent future incidents. At a minimum, a determination must be made whether there are deficiencies in any area, and in doing so persistently ask the question “Why?” at least 5 times to probe the area in depth.
Corrective Actions
The investigation is not complete until corrective actions are implemented that address the root causes of the incident. Implementation entails program-level improvements and must be supported by senior management. It is important for the person(s) responsible for incident investigation and injury/illness reporting to review the root cause factors and corrective actions and forward the information to appropriate management personnel for follow-up and implementation. It is recommended for management personnel to(s be responsible for ensuring corrective actions are implemented.
Training
The person(s) responsible for incident investigation and injury/illness reporting must also provide training to management employees who are assigned duties under the program. The training must cover a review of the Incident Investigation and Injury/Illness Reporting Program, including all the information needed and steps involved in the process.
Records Required by OSHA
The person(s) responsible for incident investigation and injury/illness reporting must ensure all injury/illness records required by OSHA are completed and maintained. The company must record information about every work-related injury or illness that involves loss of consciousness, restricted work activity or job transfer, days away from work, or medical treatment beyond first aid. Significant work-related injuries and illnesses diagnosed by a physician or licensed health care professional must also be recorded. In addition, the company must record work-related injuries and illnesses that meet any of the specific recording criteria listed in 29 CFR 1904.8 through 1904.12.
OSHA recordkeeping and reporting requirements are extensive and necessitate a robust system for reporting and retaining records related to incident investigations. To ensure all the necessary information is investigated and reported properly, ask an expert for help when implementing an Incident Investigation and Injury/Illness Reporting Program.
Further Information
Cornerstone offers a structured software application for Incident Management which can be an invaluable tool to support incident prevention programs and facilitate the process of investigating and recording incidents. We also offer safety management programs and training to help prevent injuries and illnesses in the workplace. Learn more about Incident Management Systems.
David Blane is a Senior Health and Safety Specialist. He is a Certified Safety Professional by the Board of Safety Professionals. He currently provides health and safety compliance auditing, program development, training, and industrial hygiene monitoring to Cornerstone’s industrial and construction sector clients. Blane formerly served as an OSHA compliance inspector.