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Archive for the ‘OSHA’ Category
$14M OSHA Budget Increase for 2011 with Emphasis on Enforcement
Last week, Hilda Solis, the Secretary of Labor, went through the rationale behind the Department of Labor’s (DOL) FY 2011 budget request, which includes a $14M increase for OSHA. In addition to supporting President Obama’s repeated calls for creating new jobs, the message is crystal clear that the increase’s emphasis will be on enforcement.
This makes sense, considering the Administration’s National Emphasis Program (NEP) announced last fall, and reinforces OSHA’s approach of using the hammer to get compliance, as in the record $87M fine levied against BP in 2009 for the 2005 Texas City oil refinery explosion.
Secretary Solis said, “Today’s budget affirms this administration’s strong commitment to vigorous enforcement. With the largest fine in OSHA’s history and more egregious cases, we are sending a strong message throughout industry that we will not tolerate the endangerment of workers. We will continue those efforts with a number of new and innovative enforcement initiatives in the coming year.”
The take away from this is that now, more than ever, it will pay to be proactive in managing safety programs, in more ways than one. In addition to protecting employees, OSHA’s making it clear that their plan includes heavy penalties for offenders.
Is your Injury and Illness Prevention Program (IIPP) up to date, effectively implemented, and is everyone trained? If you need help getting your safety or training programs up to speed, give us a call or send us an email. We’re here to help you succeed.
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Cal/OSHA Top 10 Manufacturing Safety Violations for 2009
In the last half of 2009, there was plenty of news, budget appropriations, and proposed regulatory changes from OSHA to tighten regulations and increase the focus on compliance in 2010. As always with Safety, the most cost effective approach is to be preventive and proactive rather than take your chances in an inspection or appealing citations.
In 2009, in California, issues related to the IIPP (Injury and Illness Prevention Program) continued to be the top cause of violations for manufacturing companies. For manufacturers in the period October 2008 to September 2009, there were 397 Cal/OSHA IIPP citations.
The 2009 top 10 Cal/OSHA manufacturing violations are:
- IIPP – 397 violations. This is the top level document a company must have in California that outlines its safety program. From a Cal/OSHA standpoint, not only must you have an IIPP in place, it must be effective, which includes employee involvement and training.
- Lockout/Blockout – 316 violations. Any time equipment is being cleaned, maintained, set-up, or adjusted, electrical (lockout) and mechanical (blockout) energy must be controlled to prevent unexpected start-up.
- Air Tanks – 461 violations. Air tanks, which are pressure vessels, require a permit issued by DOSH (Department of Occupational Safety & Health) to be in operation.
- Portable Fire Extinguishers – 166 violations. Issues regarding placement, use, maintenance, and testing of portable fire extinguishers provided for use by employees.
- Electrical Equipment Clearance – 149 violations. Sufficient clearance must be provided around all electrical equipment for safe operation and maintenance.
- Respiratory Protection – 141 violations. Respirators protect workers against insufficient oxygen environments, harmful dusts, fogs, smokes, mists, gases, vapors, and sprays. Employers need to have a written respiratory protection program and it needs to be part of the company’s IIPP.
- Control of Hazardous Materials – 128 violations. Employers are required to prevent or minimize the consequences of catastrophic releases of toxic, reactive, flammable, or explosive chemicals.
- Hazard Communication (HazCom) – 115 violations. Employers must provide information to their employees about the hazardous substances to which they may be exposed. This includes a written hazard communication program, labels and other forms of warning, material safety data sheets (MSDS), information, and training.
- Emergency Eyewash and Shower Equipment – 113 violations. Eyewash equipment must be provided at all work areas where, during routine operations or foreseeable emergencies, the eyes of an employee may come in contact with a substance that can cause corrosion, severe irritation, permanent tissue damage, or which is toxic by absorption. An emergency shower must be provided at all work areas where, during routine operations or foreseeable emergencies, areas of the body may come in contact with a substance which is corrosive, severely irritating to the skin, or which is toxic by skin absorption.
- Powered Industrial Truck Operator Training – 103 violations. All employees, prior to operating powered industrial trucks (e.g., forklifts, etc.), must be trained and evaluated by successfully completing a training program.
Do recognize any of the top 10 that you may have issues with? Is your IIPP up to date and is everyone trained? If you need help getting your safety or training programs up to speed, give us a call or send us an email. We’re here to help you succeed.
Preventive Medicine is the Best Kind
If you see this on your front lawn or on your property, chances are that a Cal/OSHA representative will soon be on the scene to investigate. For anyone not familiar with this incident, this is a picture of the crane that toppled in a Santa Rosa neighborhood on November 16th while removing an oak tree. Although thankfully no one was hurt in the incident, there was a significant amount of property damage to the residence.
Cal/OSHA did in fact show up to investigate, and though the results of that investigation have not yet been released, the objectives are to determine why it happened and how similar incidents can be avoided in the future. This is a case in which Cal/OSHA knocks with an “I’m from the government and I’m here to help.”
In your own case, it may not be as obvious, but there are hazards in your workplace and the objective should be preventive or proactive action instead of being reactive after an accident has occurred. Common sense may not necessarily be as common as we think, and you should be observant in your own workplace for some obvious and not so obvious signs.
- Is equipment being operated without all machine guards in place?
- Are electrical interlocks being defeated out of convenience or to improve productivity?
- Are employees taking shortcuts or not following established procedures?
- Are all employees aware of and trained on your Injury and Illness Prevention Program (IIPP)?
- Do employees know where MSDS sheets are for all substances that they work with?
- Do employees know how and where to get help?
Although you may think the some of the answers may be obvious, that’s an assumption that can be disastrous after the fact if an accident were to occur. It’s always better and less expensive for all involved to practice some preventive medicine and be proactive in order to prevent accidents. In the case of the Santa Rosa crane collapse, the house needs to be rebuilt and someone is going to have to pay for it. In your own workplace, if there’s an accident, there are costs incurred that in all likelihood could have been avoided, such as workers’ comp, lost time and productivity, accident investigation, increased insurance premiums, etc. It pays to manage your risk in a preventive way, as the ROI will always be worth it.
Do you need help in getting your own preventive maintenance program started or not sure where to start? Give us a call or send us an email. We’re here to help you succeed.
Cal/OSHA Recordkeeping Requirements
Do you have all the Safety records you need and are they up to date if OSHA or Cal/OSHA comes knocking on your door? If so, that’s great. If not, you need to get working on it because knocking on doors is exactly what OSHA plans on doing as part of their National Emphasis Program on Injury and Illness Recordkeeping, effective as of October 1st of this year (link here).
The intent of the program is to assess and evaluate the degree of under-reporting of workplace injuries and illnesses, which not only has been suggested by academic studies, but was also prominent in a report on the accuracy of employer worker injury and illness data, released by the GAO on Monday (link here).
Here are the key records you need:
1. One of the unique requirements for California employers under Cal/OSHA is the need to “establish, implement, and maintain an effective Injury and Illness Prevention Program (IIPP).” Issues relating to the IIPP are the most often cited violation by Cal/OSHA and the key operative word should be considered maintain. Just having an IIPP filed in a binder is insufficient. Cal/OSHA won’t look at it kindly if it’s not being used as an active tool or employees don’t even know that it exists.
2. OSHA Form 300, Log of Work-Related Injuries and Illnesses. Unless exempt (less than 10 employees, or in an exempt SIC code), employers are required to record all recordable or reportable injuries or illnesses on Form 300, along with a detailed incident report (Form 301 or equivalent).
3. Annually posting the previous year’s Annual Summary of Work-Related Injuries and illnesses (Form 300A) from February 1 through April 30.
4. Worker exposure records, including MSDS’s, environmental & biological monitoring results, and other relevant records.
5. Worker medical records created by doctors, nurses, and other healthcare personnel (dentists, therapists, etc.) that apply to the IIPP or to workplace injuries and illnesses.
Employers need to be able to make these records available on a timely basis to someone who has a right to request them, including employees, former employees, or OSHA & Cal/OSHA representatives.
Keeping records can be frustrating, confusing, and time-consuming, but it’s also important. Getting ahead of the curve and keeping records well-organized and well-maintained not only can help keep employers out of hot water with Cal/OSHA, but can also be used as a problem-solving tool.
Need help getting your IIPP or recordkeeping programs up to date? Not sure of where to start? If so, give us a call or send us an email. We’re here to help you succeed.