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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What to Expect During FOUNDATION Training
Cornerstone offers different training modules depending on what type of electronic service a user has access to including FOUNDATION Training, File Cabinet, Calendar Compliance, and Vision Training.
Recently, I was asked to assist with training for the FOUNDATION (SDS Management) System. Although I often work with the FOUNDATION system internally at Cornerstone, learning to lead one of these training events introduced me to many new features of the system which can benefit all users.
In our FOUNDATION training, we cover:
How to use the provided submittal form to help with adding and removing Safety Data Sheets (SDS).
How to locate an SDS through simple and advanced search options by using any category or site-specific cross-reference set-up
How the advanced search can be customized to fit your needs.
Do you need to quickly find which chemicals have an EHS in the constituents?
Do you need to have the ability to identify which materials have the highest VOC to ensure continual Air Permit compliance?
How to print secondary container labels based on the GHS information on the SDS which is entered by Cornerstone’s Chemical Management Department.
Maintaining current Tier II reporting year inventory for each SDS or product.
How to access past reported Tier II reports.
Please join us for one of our monthly FOUNDATION training sessions to learn about the many things that your system has to offer.
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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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Making the P2 Connection with the FOUNDATION Product Approval Module
Passage of the Pollution Prevention Act by Congress in 1990 was intended to focus industry as well as the U.S. public on efforts to reduce the amount of pollution being generated across the country.
The law gave the United States Environmental Protection Agency (U.S. EPA) the responsibility and the authority to develop and implement a source reduction strategy. As a result, EPA worked to integrate Pollution Prevention (P2) practices into general industry and reduce pollution “at the source” and not at the tailpipe, outfall, or landfill. The Act also required that EPA collect and disseminate information related to P2 to the public.
After passage of EPA’s mandate, each state then implemented its own P2 program which the federal law required to be as or more stringent than the program implemented by EPA. In the early 1990s, Indiana, for instance, adopted a very narrow definition whereby true Pollution Prevention could only be achieved through process change, in-process closed-loop recycling, or input substitution.
Using Indiana’s model as an example, the state’s goal was to reduce pollution through improved efficiency, recycling/reusing waste before it could be sent to a landfill, and by making changes to the raw materials used in the manufacturing process (input substitution). By focusing on the raw materials used in, or incidental to, production, a facility could identify less toxic materials to facilitate more environmentally safe production processes.
How can Cornerstone help your facility improve its P2 performance?
In the early 1990s, Cornerstone developed a chemical inventory system to analyze and track the chemical composition of materials used in production and manufacturing. Over time, Cornerstone’s chemical inventory system was further developed by adding SDS management to create the current FOUNDATION SDS Management and Chemical Inventory System. In addition, FOUNDATION determines the applicability of substances to the Emergency Planning and Community Right-to-Know Act (EPCRA), Clean Air Act, and OSHA regulations to help ensure continuous compliance.
While working with IDEM (the Indiana Department of Environmental Management) during the development of its P2 program, Cornerstone introduced me to the methodology of using a chemical inventory system to assist with Input Substitution. It seemed like the perfect tool to support P2 efforts through the identification of materials that could be substituted thereby protecting the environment (i.e., P2) and creating safer workplaces.
What can FOUNDATION’s Product Approval Module do?
The Product Approval Module in FOUNDATION enables users to fully evaluate and approve (or reject) materials to be used in their operation. The regulatory lists reviewed range from EPCRA, HAPs, Proposition 65 Chemicals, Carcinogens, Reach, ROHS, and can also incorporate customer-specific restrictions and chemicals of concern. Candidate lists are generated for each applicable regulation to which a chemical is subject. The Product Approval Module is also useful in compiling information for ESG (Environmental, Social and Governance) reporting related to customer requirements.
If a team of individuals is responsible for approving materials to be used in production, Cornerstone’s IT team works with the client to create a fully customized Product Approval system which enables mutual review, evaluation, and approval. A streamlined online approval process such as this eliminates delays in review and ensures a holistic approach product review.
Further Information
For more information or a webinar on our Product Approval system, please contact Cornerstone or your Sales Representative.
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SDS and Document Hosting
A few years ago, Cornerstone was approached by a client that needed to improve how they were delivering branded safety data sheets (SDSs) to users of their products after they determined their staff was spending an excessive amount of time responding to these requests. Having used our IT solutions in the past, they reached out for support to design an automated, efficient system to manage this process and thus our SDS (and document) hosting platform was born.
How does a hosting platform work?
A document hosting application allows customers to visit your web site, search for the document they need and download it immediately.
Let’s look at an example. You sell cleaning products. You have a customer who is looking for an SDS for your brand of stainless steel polish. The customer would visit your website and click on a link which would forward them to a page to begin an SDS search.
After typing in ‘stainless steel polish’, they would be presented with the SDSs that best match from the hundreds of products you sell. The customer then clicks on a link to the exact product they need which would be displayed a PDF of the SDS that can be downloaded or printed.
With Cornerstone’s hosting platform, not only can you deliver SDSs more efficiently, the system also allows for easy distribution of other documents for the products you sell such as technical data sheets, instructions, manuals, or diagrams.
Sounds like it could be expensive and time consuming to set up, right? That’s where Cornerstone’s SDS and Document Hosting solution comes in. Our team will get you up and running quickly, cost effectively and with minimal IT resources required on your part.
Depending on your specific needs, our hosting solution can be deployed as a standalone website or can be seamlessly integrated into your existing website.
Some of the additional features of our Professional plan level include:
User definable fields
Password protection at the site level and at the document level if needed
Multi-language site support
Multi-language document support
Automated document distribution
For more information about Cornerstone’s SDS and Document Hosting platform, contact Cornerstone at info@corner-enviro.com, on our website at https://www.cornerstone-ehs.com/contact-us/ or call (317) 733-2637.
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Go Beyond Recordkeeping with an Automated Employee Training Tracking System
Maintaining accurate training records is important for many reasons including compliance with federal, state, and local laws, conformance with quality standards, as well as improving worker safety and overall productivity. However, many companies continue to rely upon spreadsheets and cumbersome manual processes to track employee training. It is important to ensure a solid process is in place for tracking and maintaining training records. Without such a system, vital training may be missed, leaving employees either unsafe or unqualified for their positions. In addition, your organization may be cited for non-compliance if a regulatory agency performs an audit, and the required data cannot be retrieved.
Develop a Process for Tracking and Maintaining Records
We have been asked by clients numerous times how they should manage training information to help ensure their team is more productive, capable, and safe. The most effective way to track training is to use an automated system to manage the information and tasks involved in the process. A system such as this may be incorporated into a Quality and/or Worker Health and Safety Program to ensure all training requirements are met and the necessary data is captured to maintain certifications and/or OSHA compliance.
Typical Training Data to Track and Record
What should you keep track of, and what is the most effective process? Although organizations may have unique recordkeeping needs, training tracking systems commonly include the following information:
Training required for each role
Frequency of each training type
Completion and refresher dates of training
License and certification validity
Training course materials
Course assessments
Employee evaluations
What tasks can be automated?
Assignments of training based on an employee’s role
Rescheduling of refresher training, as needed, based on the frequency of requirements
Notifications to employees who require training
Easily accessible records of evidence in the event of an audit
Training class rosters
In addition to automating all of the required tasks for training tracking, metrics such as training effectiveness and course assessments can be accessed. Other performance indicators, like how often licenses or qualifications lapse, or the percentage of employees trained, can be used to evaluate the effectiveness of your training program.
Additional Benefits of an Effective Training Tracking System
In today’s business climate, one of the most important benefits of a training program is attracting, training, and retaining employees. You can leverage training tracking to see where employees are deficient and train them in the areas needed. Furthermore, if employees are not continually learning, it may prompt them to look elsewhere for opportunities that foster personal growth.
In short, using automated training tracking tools will help managers become more efficient with their training efforts, which promotes safety, increases job satisfaction, and creates a more educated, skillful, and productive workforce.
Further Information
Cornerstone offers Training Tracking software that helps users capture and retrieve the necessary information to remain current and compliant with applicable regulatory requirements. Our software automates the training process with features such as email reminders, mass scheduling, and monitoring the completion of courses. Contact us to discuss integrating this Training Tracking system into your operations.
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Are You Prepared for the Tier II Emergency and Hazardous Chemical Inventory Reporting Deadline?
Tier II Emergency and Hazardous Chemical Inventory Reports are due annually on March 1. Since these reports cover materials for the entire previous year, it’s important to continually track the chemicals/products entering and leaving your facility. Maintaining on-site inventory throughout the year will allow for a smooth Tier II reporting season. Don’t let the deadline sneak up on you!
The following is a quick overview of the EPCRA regulation and Tier II reporting:
What is EPCRA?
The Emergency Planning and Community Right-to-Know Act of 1986 was created to help communities plan for chemical emergencies. This regulation requires industry to report on the storage, use, and release of hazardous substances to federal, state, and local governments. EPCRA serves as the governing body for Tier II reporting.
What makes a chemical reportable under Tier II?
Reporting is applicable for any OSHA-hazardous chemical stored on site that exceeds the federal threshold quantity of 10,000 pounds, and any EHS stored in excess of 500 pounds or its threshold planning quantity (TPQ), whichever is less. Exceeding the threshold at any time during the reporting year triggers the reporting requirement. It is also important to note that individual states may have more stringent reporting requirements.
What is an EHS?
The Extremely Hazardous Substance (EHS) list identifies chemicals that could cause serious irreversible health effects as a result of a release. A full list of EHS chemicals can be found on epa.gov.
What storage information is needed to file the Tier II?
Reporting requirements include details of specific location(s) within a subject site where reportable chemicals are stored. In addition, the type of container utilized and exact maximum amount (typically measured in pounds) of hazardous chemicals present at the facility at any one time during the previous calendar year must be reported.
How do I know what reporting requirements exist for my state?
Although each state’s reporting system may vary, any subject facility must file a Tier II report annually with the State, County (LEPC), and local Fire Department. Additional information regarding filing criteria by state, along with associated fees, can be found at https://www.epa.gov/epcra/state-tier-ii-reporting-requirements-and-procedures.
Further Information
With a well-organized system in place, compliance with the Tier II reporting requirements is much easier to achieve. Cornerstone is an industry leader in chemical inventory management, electronic SDS imaging, and software management systems. Our proprietary software (FOUNDATION) combines both EPA and OSHA chemical tracking and reporting functions and provides a foundation for all compliance recordkeeping and reporting. Additionally, we have a team of experts who can assist with Tier II reporting and help keep your hazardous chemical data up to date throughout the year, so you will always be ready for the March 1 deadline.
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Update SDS Regularly for Better Work Safety
Safety Data Sheets inform employees about the hazards of the chemicals in their workplace, how to obtain information on chemicals, and what to do if a spill or accident occurs with those chemicals in order to provide a safe, secure workplace. The information contained on each SDS also enables organizations to better understand the chemicals they use and how those substances impact the environment. Constant communication of SDS updates to staff is a vital way to promote a positive safety culture in any company. It creates a safer, more informed environment for employees. Changes to SDS can impact the handling or transport of material, as well as disposal methods, and the potential health hazards to employees.
What OSHA regulations require SDS?
The OSHA Hazard Communication Standard (OSHA, 29 CFR 1910.1200(g) and Appendix D) requires manufacturers and importers of a new hazardous chemical to obtain or develop safety data sheets. From there, the manufacturers, suppliers, and distributors are responsible for passing that information along as the product moves through the supply chain. Those entities also are required to update existing SDS as new information becomes available regarding identification, handling, and spill response of hazardous chemicals. This applies to every hazardous chemical they produce or import. The HCS requires that SDSs be updated by the chemical manufacturer or importer within three months of learning of "new or significant information" regarding the chemical's hazard potential. The downstream or end users are responsible for the use and maintenance of SDSs, including accessibility to the most recent version of SDSs for all employees. Users can request updated SDS information from the original supplier or manufacturer. All along the supply chain, employers must provide training to employees regarding how to access an SDS and communicate changes to employees in a timely manner.
What other mandates require SDS?
The U.S. EPA also has regulations that address SDSs. These documents were a requirement under the Clean Water Act of 1970 and the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) of 1980. Subsequently, these were reaffirmed under the Superfund Amendments and Reauthorization Act (SARA) section 313 of the Emergency Planning and Community Right-to-Know Act (EPCRA), which is also known as Title III. Many state and local environmental and safety agencies have a number of regulations that may redundantly require SDSs. Most corporate safety and environmental protection programs also rely on SDSs to educate and inform workers about dangers in the workplace.
What are the dangers of an outdated SDS?
If a manufacturer chooses not to maintain up-to-date SDS documents on file, they are denying their staff valuable information about specific chemicals substances and how to safely handle them. This puts employees at risk and could lead to workplace incidents and injuries or environmental damage. In addition, OSHA or EPA inspectors have the authority to issue violations and assess fines for non-compliance with SDS-related regulations.
Further Information
With Cornerstone’s Foundation SDS Management and Chemical Inventory System, our Chemical Management team do the work for our clients to ensure that their SDS are regularly updated. For a free demo, contact us.
Yabelin Batista has been with Cornerstone since 2019. She is a member of the Chemical Management department at Cornerstone, Environmental, Health and Safety. One of her main responsibilities consists of sourcing and updating current Safety Data Sheets (SDS) for a wide array of products in our Foundation SDS Management and Chemical Inventory System. Her efforts help ensure our customers have the latest documents available.
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Using Leading Indicators to Prevent Workplace Injuries
By Joshua Sampia All companies have an obligation to create a safe work environment that allows their employees to do their jobs with minimal risk of injury. Most business understand their obligation to report accidents and illnesses to government agencies at the federal, state, and local level. What if you could use modern technology and trends to not only create a safer work environment but also prevent injuries from ever happening? This would save you time and money from completing reports, medical billing, and insurance claims, as well as reduce lost work time hours.
What are leading indicators?
Leading indicators are data points that can help predict future events and trends. This is where having a proactive safety culture comes into play. Leading indicators can be used to assess workplace culture in order to develop safety plans to minimize risk and increase productivity. OSHA defines leading indicators as “proactive and preventive measures that can shed light about the effectiveness of safety and health activities and reveal potential problems in a safety and health program.” The cost of worker’s compensation claims can range from thousands to hundreds of thousands of dollars depending on the nature of the incident. Having a program in place that can help prevent even one of those claims will automatically pay for itself. There also are many other intangible benefits like reduced costs for worker’s compensation insurance or a reduction in the number of fines. As the saying goes, an ounce of prevention is worth a pound of cure.
Set Goals for Leading Indicators
Most companies have goals set for lagging indicators, such as a threshold for lost work time or number of injuries; however, your organization should also set goals for leading indicators, such as:
Attendance Rates
Safety Observations
Risk Assessments
Preventative Measures and Maintenance
The key to any good program is setting, identifying, and reaching quantifiable goals. For example, we work with a company that had historically relied on lagging indicators such as types of injuries, location, and work task to track injuries. Our team worked with them to implement a more observational approach focused on minimizing future occurrences. They formulated daily observation checklists of employees to determine if they were performing their tasks in an efficient and safe manner. That daily observation data was then aggregated and analyzed develop better safety and training programs. The change has helped reduce the number of injuries and accidents. Incidentally, productivity has also increased. Implementing this kind of process does not have to be a time-consuming process. The daily observations are short checklists of yes or no type questions that take approximately two minutes each day to complete. The checklist can be completed on mobile devices which most staff are currently using in their work tasks. The company also can share observations across multiple departments and shift supervisors to create a network of data for the entire business.
Technology and Software for Worker Safety
There are other examples of using modern data technology to help. Tracking employee training is a great way to ensure a good safety environment. Making sure employees are well-trained and that training is up to date is crucial to safety success. Another important aspect is that you must have a robust program in place to capture and analyze the data. A good system will:
let you easily capture all this information through multiple devices and portals
let you report the data back into multiple formats and reports
have a great dashboard to see a visual representation of the data
improve accountability
It is also critical to have traceability so it is clear who entered what data and when. This is extremely important when it comes to having a chain of evidence.
How can Cornerstone Help?
Cornerstone’s Incident Management and Training Tracking systems can capture all of this information as well a provide data reporting, visual representation, and more. Our applications have highly customizable systems that can adapt to literally any industry including automotive, manufacturing, medical, industrial as well as retail and warehousing. Each system is configured to each company’s specifications and requirements. This can also be accomplished at a cost-effective price point, especially when compared to the cost of having one accident on record. Contact us for details on how Cornerstone can help your facility establish an effective safety program using leading indicators and our industry-leading software systems.
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.