When to Change Respirator Cartridges?

Do you know when to change the cartridges on your respirators?  Many written programs rely on these words: “Cartridges should be disposed of immediately when the smell or taste of vapors are noticed or it becomes difficult to breath.”  This statement will not meet the requirements of the 1910.134 (d)(3)(iii)(B)(2), which requires a written change schedule for canisters and cartridges if there is no End of Life Service Indicator.  OSHA has provided three valid ways for you to estimate a cartridge’s service life:  Conduct Experimental Tests, Use the Manufacturer’s Recommendations, or Use a Math Model.  www.osha.gov/SLTC/etools/respiratory/change_schedule.html 

There are pros and cons for each method, but any one of them can be used in determining the service life of the canisters or cartridges.  If the three methods are overwhelming to you, OSHA also has a Rule of Thumb method that can be used.  http://www.osha.gov/SLTC/etools/respiratory/rule_of_thumb/rule_of_thumb.html  If you need additional help, Advanced Safety and Health is here is assist you.

$191K Fine Over OSHA 300

Federal OSHA Has Proposed Over $191,000 in Penalties for Construction Company's Failure to Report Injuries

The Occupational Safety and Health Administration (OSHA) has cited Stoughton, Mass.-based Stone and Webster Construction's maintenance division and proposed penalties totaling a whopping $191,700 for failing to properly record injuries and illnesses at Tennessee Valley Authority (TVA) nuclear plants in Tennessee and Alabama.

An OSHA investigation revealed that the company failed to record a total of 84 incidents involving company maintenance worker injuries at Browns Ferry Nuclear Plant, Athens, Ala.; Sequoyah Nuclear Plant, Soddy Daisy, Tenn.; and Watts Bar Nuclear Plant, Spring City, Tenn.

Officials from the TVA, which operates the three facilities, contacted OSHA when they noticed discrepancies on the OSHA 300 Log used to record work-related injuries and illnesses. OSHA regulations require employers, with few exemptions, to maintain accurate records of fatalities, injuries, and illnesses and to post a summary of these incidents each year at job sites.

The company received one willful citation, with a proposed penalty of $63,000, for failing to record injuries and illnesses in 2004, 2005 and 2006 at the Browns Ferry site and $1,800 in proposed penalties for failing to accurately record injuries that resulted in days away from work and restricted work activity at the facility.

OSHA also proposed a $63,000 penalty for similar willful recordkeeping violations for the years 2004, 2005 and 2006 at Sequoyah and 2004 and 2006 at Watts Bar. In addition, the Watts Bar plant received a proposed $900 penalty for failing to record an injury that resulted in restricted work activity.

Don’t forget that your 300A “Summary of Work – Related Injuries and Illnesses” for 2006 should be posted by now and is to remain posted until April 30^th. 

What is Design-In Ergonomics?

And Why It’s Worth Considering for Your Company

By: Laura Dietrich

Most companies never consider design-in ergonomics and many may not even know what it means.  This is unfortunate because design-in ergonomics may be the most cost efficient form of ergonomics and can impact your bottom line in a significant way.

Design-in ergonomics is applying the concepts of ergonomics at the start of the design phase for a part, tooling purchase, or workstation.  As an ergonomist, I am often called in to “fix” a problem after an injury has occurred.  The design of the part will have already been completed, the tooling has been purchased, and all of the line heights, part presentation, etc. are in place.  From an engineering standpoint, the choices to resolve the issue are limited.  If you have ever been in such a predicament, you may have thought to yourself, “If only the design of the part or tool or workstation was different, this would not even be a problem.”  Sometimes all that can be done is to put a band aid on the situation until the area or part is redesigned. 

At the start of the design process, the engineer attempts to balance many aspects of the design, such as cost, durability, efficiency, quality, part weight, and customer requirements.  Unfortunately, ergonomics is rarely on the list, and ergonomic problems are literally designed into the part, tool, or workstation.  When ergonomics is a part of the design process, however, most ergonomic concerns are usually identified and resolved.

If design-in ergonomics is such a good process for companies, why aren’t more companies doing it?  I think there are two reasons.  Some companies operate under the theory that if it’s not broken don’t fix it (or if an injury has not occurred, then don’t fix it).  The problem with this type of thought process is that if a significant risk factor exists, then eventually someone will become injured. 

Secondly, if significant risk factors exist, then the operation will most likely not be efficient.  As an example, let’s consider an operation that requires the operator to use a high amount of force to install a bracket.  It will take the operator more time ($) to install the bracket because of the high force.  The operator at the end of the day may not correctly install the brackets due to fatigue and some of the parts may need to be re-worked ($) as a result.  The brackets may not wear as well in the field due to the poor fit between components and have warranty issues ($).  Finally, when the ergonomic issue is addressed, a manufacturing tool will need to be utilized to install the bracket for the operator ($$).  And we haven’t even considered the cost of an OSHA recordable injury ($) and the effects on the workers compensation premiums ($).  As you can see, designing the bracket correctly from the start with acceptable insertions would have been much less costly for the company.

Design-in ergonomics should be included at the onset of the design of the part, tool, or workstation.  Data about existing ergonomic concerns should be gathered and communicated to the design engineers.  A checklist should be completed that specifically targets design issues.  If the design is being outsourced, the ergonomic requirements should be included in the quote so that that the price quoted will include the implementation of specified ergonomic principles.  Finally, ergonomics should be evaluated in the prototype phase of the design.  As soon as a prototype is available, it should be re-evaluated for ergonomic input.

The bottom line on design-in ergonomics is that you can fix or prevent most ergonomic concerns with very little cost to the company.  The accompanying benefits are less assembly time, better quality, fewer manufacturing assists, lower injury rates, and lower workers compensation costs.  If the design of the part/tool/workstation is incorrect, you will be fixing it at some point.  So, you should ask yourself, “Do I want to fix it for the lowest cost and have the optimum resolution? Or, do I want to wait and pay all of the above costs due to inefficiencies and then fix the problem?”

If you would like assistance from Laura Dietrich, please feel free to contact her at (502) 240-6910 or ldietrich@AdvancedSafetyHealth.com.

Fan Safety Recall

Tower Fans Recalled by the Holmes Group Due to Fire Hazard

The U.S. Consumer Product Safety Commission, in cooperation with The Holmes Group, announced a voluntary recall of the Holmes® Oscillating Tower Fans. Consumers should stop using these recalled products immediately unless otherwise instructed. There are about 300,000 of the units in use and were sold through Target, Bed Bath & Beyond, and additional department and specialty stores nationwide.  They were sold from July 2002 through June 2005 for about $30.

Electrical arcing in the fan’s wiring can cause a fire hazard.  The Holmes Group has received 16 reports of property damage, including one reported injury involving minor burns and smoke inhalation.

The recall involves the Holmes HT30 Oscillating Tower Fan. The model number can be found on the silver label on the back of the unit. “Holmes®” is printed on the front of the base.  The tower fans are white. Consumers should contact The Holmes Group for instructions on receiving a free replacement unit.  For additional information, call The Holmes Group at (800) 524-9204 anytime or visit the firm’s web site at www.holmesfanrecall.com

Why’d They Do That?

Here is this month's photo that left us asking "Why'd They Do That".  If you look closely you will find more than one safety violation going on when it comes to lack of fall protection.  Click the image for a larger view.

 Last month we had a Photo of some ladder usage taking place, and asked for you to see how many unsafe ladder practices you could find.  We put our collective heads together for this list.  Did you find anything else?

• Worker using a step ladder as a straight ladder
• Step ladder appears to be supported by a pipe, i.e. even if the worker was using a straight ladder the ladder is not properly supported (Is the pipe capable of supporting the force of the ladder and worker); or could the ladder slip off the pipe? 
• Worker is facing the wrong direction (and possibly descending) on the ladder
• Rope, extension cord, welding cable (we aren't positive as to what it is) appears to be in the path of travel
• Pipe interferes with path of travel, i.e. insufficient clearance
• If the extension ladder is being used (it appears to be in place to be used), it is not at the proper 4:1 angle and the extension section is fully lowered and not engaged with the main ladder section, i.e. the steps (between the two sections) are uneven.