Archive for November, 2009

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.

Last week, OSHA released a preliminary report of the top 10 most frequent workplace safety violations. In revealing the list, OSHA said that the number of violations were up almost 30% over the same period in 2008. The final list will be published in December.

The workplace violations are:

1. Scaffolding – 9,093 violations. Scaffold accidents most often result from the planking or support giving way, or from the employee slipping or being struck by a falling object.

2. Fall Protection – 6,771 violations. Any time a worker is at a height of four feet or more, the worker is at risk and needs to be protected. Fall protection must be provided at four feet in general industry, five feet in maritime, and six feet in construction.

3. Hazard Communication – 6,378 violations. Chemical manufacturers and importers are required to evaluate the hazards of the chemicals they produce or import and prepare labels and safety data sheets to convey the hazard information to their downstream customers.

4. Respiratory Protection – 3,803 violations. Respirators protect workers against insufficient oxygen environments, harmful dusts, fogs, smokes, mists, gases, vapors, and sprays. These hazards may cause cancer, lung impairment, other diseases, or death.

5. Lockout-Tag out – 3,321 violations. “Lockout-Tag out” refers to specific practices and procedures to safeguard employees from the unexpected start up of machinery and equipment, or the release of hazardous energy during service or maintenance activities.

6. Electrical (Wiring) – 3,079 violations. Working with electricity can be dangerous. Engineers, electricians, and other professionals work with electricity directly, including working on overhead lines, cable harnesses, and circuit assemblies. Others, such as office workers and sales people, work with electricity indirectly and may also be exposed to electrical hazards.

7. Ladders – 3,072 violations. Occupational fatalities caused by falls remain a serious public health problem. The U.S. Department of Labor (DOL) lists falls as one of the leading causes of traumatic occupational death, accounting for 8% of all occupational fatalities from trauma.

8. Powered Industrial Trucks – 2,993 violations. Each year, tens of thousands of injuries related to powered industrial trucks (PIT), or forklifts, occur in U.S. workplaces. Many employees are injured when lift trucks are inadvertently driven off loading docks, lifts fall between docks and an unsecured trailer, they are struck by a lift truck, or when they fall while on elevated pallets and tines.

9. Electrical (general) – 2,556 violations. See #6.

10. Machine Guarding – 2,364 violations. Any machine part, function, or process that may cause injury must be safeguarded. When the operation of a machine or accidental contact injures the operator or others in the vicinity, the hazards must be eliminated or controlled.

Closer to home, the most frequently cited violation by Cal/OSHA over the same time period is the Injury and Illness Prevention Program (IIPP), which is a unique requirement of Cal/OSHA vs. Federal OSHA.

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.