 |
|
|
|
|
Greetings,
We are excited to share with you our new monthly safety newsletter format that also matches the look and feel of our new website that will be rolling out in the next few days. I will be sharing more with you in the October newsletter as to the improved website and helpful resources we will be adding. Please bear with us as we iron out a few kinks and work on the finishing touches.
Sincerely,
Dwayne Towles (502) 240-6910 dtowles@AdvancedSafetyHealth.com
|
| Congratulations to Thybar Corp. |
On Monday August 11, Thybar's operation located in Jeffersontown, Kentucky was awarded the Kentucky Governor's Safety and Health award by Mark Brown, Kentucky Deputy Secretary of Labor. This company is a sheet metal manufacturer of roof curbs and HVAC accessories who opened its Kentucky division in 1997 in a 27,000 square foot facility. The operation has grown to 60,000 square feet and over 60 full time employees. To be eligible for this award, a company with less than 125 employees must work a minimum of 250,000 hours without experiencing a lost time accident or illness. At the time of application, the employees have achieved 395,469 hours and counting. Thybar Corporation's last lost time accident was recorded on May 19, 2005. Thybar Corporation has partnered with Advanced Safety & Health the last several years to help them take their safety program to the next level. This partnership has really paid off for the company and most importantly for the employees. Thybar Corporation has taken a safety first approach with every aspect of manufacturing in their facilities and, with the hard work of all employees, they were able to achieve this goal. |
| Back to Top |
| PPE Training Standards Changes Being Proposed |
OSHA Looking to Cite on a Per-Employee Basis
OSHA is proposing to amend its regulations to add language to explicitly state that noncompliance with the personal protective equipment (PPE) and training requirements in its safety and health standards will expose the employer to liability on a per-employee basis. The amendments consist of new paragraphs added to the introductory sections of the listed parts and changes to the language of some existing respirator and training requirements.
This action is in response to recent decisions of the Occupational Safety and Health Review Commission indicating that differences in wording among the various PPE and training provisions in OSHA safety and health standards affect the Agency's ability to treat an employer's failure to provide PPE or training to each covered employee as a separate violation. The amendments add no new compliance obligations. Employers are not required to provide any new type of PPE or training, to provide PPE or training to any employee not already covered by the existing requirements, or to provide PPE or training in a different manner than that already required. The amendments simply clarify the remedy for violations of these requirements.
The proposal ( http://edocket.access.gpo.gov/2008/E8-18991.htm) discusses several key cases in the history of per-employee citation, such as the Ho decision. This case involved 11 untrained workers directed to remove asbestos without respiratory protection from a Houston building undergoing demolition. OSHRC vacated all but one of the respiratory and one of the training violations, believing that "the plain language of the standard addresses employees in the aggregate, not individually." This was affirmed, although on different grounds, by the 5th U.S. Circuit Court of Appeals. Also discussed is Secretary of Labor v. Manganas Painting Co., (Rev. Comm'n 2007), where OSHRC found the initial respiratory protection paragraph of the 1993 construction lead standard (1926.62(f)(1)) authorizes per-employee citations.
The proposal states: "The failure to provide an appropriate respirator to each such employee may expose the employer to per-employee citations." OSHA said that its Advisory Committee on Construction Safety and Health supports the changes proposed for the construction standards. |
| Back to Top |
|
|
| K.I.S.S. = Keep It Simple For Stock |
| Simple Steps for Preventing Shoulder Injuries
When it comes to setting up a workstation, it is frequently the little things that count the most when trying to prevent employee injury. Employers often think that ergonomic improvements will carry high dollar costs and therefore shy away from even starting an ergonomic process. The exact opposite is true in many cases. Here are a few areas for you to evaluate in your workstations to ensure that the "little things" have been considered. Are the material bins located within arms reach (15" or less) and at work surface height? If the bins require the employee to raise or extend their arms/elbows to reach the stock, they will be using their shoulder muscles and joints each time they get a part. This usually translates into feedback from employees that shoulders ache by Friday afternoon. Even though the part may only weigh one pound, it is the repetitive lifting and extending of the arm at the shoulder joint that cause pain and eventual injury. This is probably the most common mistake seen when performing evaluations and the easiest to fix. If your tools are mounted on an overhead rail, does the tool location require the employee to reach above chest level? The tool is usually placed in that location to keep it out of the work area when not being used. A better location would be slightly to the side of the employee, at or below chest level. Every time the employees reach for the tool, they are repetitively engaging the shoulder. Finally, evaluate any racks that store boxes of material that the employees use to pull stock. Many times the stock is arranged by the material handling department based on delivery schedules. It is important to have the highest frequency boxes be located on the center rack, at waist level; the second highest frequency parts between knee and waist level; and finally the lowest frequency or empty box return located on the top level. This will minimize the number of times employees are either bending or reaching above shoulder level.
|
| Back to Top |
| Orlowski Co. Cited Again |
OSHA Cites Orlowski Co. Inc. for Numerous Willful Workplace Health and Safety Violations and $175,600 in Penalties
OSHA has cited Orlowski Co. Inc., a building masonry company based in Chicago, for multiple alleged willful and serious violations of federal workplace safety and health standards. As a result of an inspection initiated in February, OSHA has issued citations for five willful violations with proposed penalties totaling $175,000. The willful violations address Orlowski Co. Inc.'s failure to provide fall protection on scaffolds and hoist equipment and its failure to provide fall protection for employees working at or near floor holes at the construction site. OSHA also issued a citation for a serious violation with a proposed $600 fine for failing to initiate and maintain a safety and health program. Orlowski Construction, reportedly a predecessor company to Orlowski Co. Inc., has a judgment pending in the United States District Court for $409,195 for unpaid OSHA penalties from 17 previous inspections. Also pending before the Occupational Safety and Health Review Commission is a citation involving Orlowski Co. Inc. for alleged violations of OSHA's fall protection standard with penalties totaling $56,600 involving an investigation that occurred in November 2007. Orlowski Co. Inc. has approximately 23 employees who perform masonry work on building exteriors and apparently a very lengthy history with OSHA. |
| Back to Top |
| Our OSHA Outreach Training Schedule |
General Industry 10 Hour
On September 17-18 and December 10-11, we are offering the OSHA 10 hour General Industry training at our Louisville, Kentucky location. Please check our website for more details and to register. The cost is $225 per attendee. This two day program is designed for personnel from all types of industries to present general information on how the provisions of the OSHAct may be implemented in the workplace.
This class is focused on emphasizing hazard identification, avoidance, and control. The course also includes an introduction to OSHA's general industry standards and an overview of the requirements of the more frequently referenced standards. Participants who successfully complete this course will receive an official course completion card from Federal OSHA. This is a great class for members of your safety committee and/or first line supervisors.
Construction 10 Hour On November 12-13, we will offer the OSHA 10 Hour for the Construction Industry also at our Louisville, Kentucky location. Please check our website for more details and to register. The cost is $225 per attendee. This two day program covers many of the hazards associated with maintaining a safe construction site and overall prevention of worker injury. This class is focused on emphasizing hazard identification, avoidance, and control. Using OSHA standards as a guide, special emphasis is placed on becoming knowledgeable about the most hazardous areas of this industry. Participants who successfully complete this course will receive a course completion card from Federal OSHA.
You may also contact Jamie Jarboe by email or call 502-240-6910 or toll free 1-866-339-8040 if you have any questions. |
| Back to Top |
| OSHA Doesn't Give Grace Periods |
What Does Annual Mean?
When OSHA says "annual", they don't mean 366 days. (Unless there is a leap year, I guess.) When you see annual requirements for things like training or respirator fit testing OSHA means within 365 days. See excerpts from two letters of interpretation below: Scenario: Various OSHA standards address frequency of employee training. Some standards are very explicit on frequency, stating "no later than 12 months from the date of the previous training," while others simply state that training must be performed "at least annually." Question: Could you please clarify OSHA's interpretation of training requirements and what is expected when training must be conducted "at least annually"? Reply: You are correct in stating that the language may vary in certain OSHA standards. However, wherever OSHA standards require that employee training be conducted "at least annually," OSHA interprets that to mean that employees must be provided re-training at least once every 12 months (i.e., within a time period not exceeding 365 days). This annual training need not be performed on the exact anniversary date of the preceding training, but should be provided on a date reasonably close to the anniversary date taking into consideration the company's and the employees' convenience in scheduling. If the annual training cannot be completed by the anniversary date, the employer should maintain a record indicating why the training has been delayed and when the training will be provided. Please keep in mind that the term "at least annually" is generally regarded as indicating that circumstances which warrant more frequent training may occur. It is extremely important that employees are trained to protect themselves from all known workplace hazards, including new hazards which may result from changes in workplace practices, procedures, or tasks. For example, OSHA's bloodborne pathogens standard at 29 CFR 1910.1030(g)(2)(v), provides for "additional training when changes such as modification of tasks or procedures or institution of new tasks or procedures affect the employee's occupation exposure." More frequent training may also be required when employee performance suggests that the prior training was incomplete or not fully understood. Second Excerpt: In your second question, you have asked for a clear definition of what OSHA means by "annual", with regard to the training and fit test requirements in the Respiratory Protection Standard. Annual means that training and fit testing must be conducted every year, before or on the anniversary date of the employee's previous training and fit test. For example, if the employee is trained or fit tested on February 1, 1999, then the employee must be trained or fit tested before or on February 1, 2000.
|
| Back to Top |
| Why'd They Do That? |
|
Now the irony here is that this was what the employee did after the site safety manager had just talked with him 10 minutes earlier for standing on the top of a stepladder. Yep, the one in the right of this picture. So it got us to wondering "Why'd He Do That?"
Click image for a larger view |
| Back to Top |
Advanced Safety & Health 2309 Watterson Trail Suite 100 Louisville KY, 40299 Phone: 1-502-240-6910 |
If you wish to not receive any future e-mail offers from Advanced Safety & Health please click here. |
| |
| Click here to forward this message to a friend. |
| |
Powered by Media Marketers E-Mail Marketing Service |