OHSA’s Hazard Communication Standard

The following information can be found from FirstComp Insurance.  To see a full copy, click here.

Paint remover, degreaser, fertilizer and glass cleaner; these and other chemicals are a part of today’s high quality of life and a necessary part of many work environments. The hazard communication standard first went into effect in 1985 and covers almost all workplaces under OSHA jurisdiction. The basic idea behind the standard requires chemical manufacturers and employers to communicate information to workers about the hazards of workplace chemicals or products. Material Safety Data Sheets (MSDS), container / product labels,  employee training and a written program are the main components for communicating chemical information to employees. These elements are designed to prevent injuries and keep workers healthy and safe while performing their job.

Health and Safety

The best way to protect employee health and safety is to educate them on each of the chemicals they work with. Some chemicals can explode, start fires or violently react with others. Some can cause skin rashes, breathing problems, or more serious injuries including burns and death. But if hazardous chemicals are handled carefully and the proper precautions are followed, chemicals can be handled and used safely.

MSDS and Labels

Illness and injury can be prevented by reading the MSDS and container / product label for each chemical being used. These two major program components provide important health and safety information about the hazardous chemicals employees will be working with. Employers must make MSDS.s and labels available to workers, but the program can only be effective with the help and cooperation of all employees.

Be Compliant

Many employers think the Standard doesn’t apply to their workplace.  However, the vast majority of workplaces under OSHA jurisdiction have some exposure to chemicals that require documentation and proper labeling. Some examples of common chemicals are household or commercial cleaning fluids, fuels, solvents, lubricants, degreasers, and aerosols.

Take Part

Work smart by participating in the company’s hazard communication program. Safe work practices for properly handling chemicals, how to use required personal protective equipment, and any first aid procedures in case of an accident will be taught. Since health and safety is your responsibility, be sure to understand the job function, and ask your supervisor any questions regarding using and/or handling chemicals safely.

Claimant Fraud

Special Investigation Unit Manager Accidents may occur. However, when employees are involved in fraudulent claims it hurts entire communities, especially an employer, whose workers compensation insurance premiums increase due to the loss. At FirstComp we are dedicated to protecting policyholders by combating fraud. Below is a story of a win in the battle against workers compensation fraud:

Sam was a convenience store clerk who felt he should only work when he wanted to. Before starting his shift on a Friday evening he devised a plan to skip work and still be paid. Early in his shift he paced up and down a store aisle watching customers and his co-worker at the register. Once he realized his coworker was distracted he walked over to a wire rack – and shook it – to see if it would fall. Realizing no one was watching he pulled the wire rack down on himself and started screaming for help. Eventually, an ambulance was called to transport him to the hospital. What Sam did not realize was the store not only had a video camera over the cash register but also over the store aisles. His .staged. accident was caught on video tape.

Sam faces up to 5 years in prison for workers compensation fraud if convicted by a court of law. Some potential fraud red flags to be on the lookout for include:

  •  The employee has injuries that do not match with the story of the accident
  •  There are no witnesses to the accident
  •  The accident occurred early on a Monday morning or after a holiday weekend
  •  The accident leads to rumors or whispers around the workplace that the injury was faked

 

Hazardous Energy Control Procedures

The following information comes from FirstComp Insurance.  A full version can be found here.

Hazardous energy control — more commonly known as lockout/ tagout . procedures are an important, though frequently overlooked, component of many safety & health programs.  These procedures are designed to protect employees from being injured, or worse, by the accidental startup or movement of machinery or equipment that they are working on. The standard on which all lockout programs are based is OSHA Standard 29 CFR 1910.147 .The Control of Hazardous Energy. You must have a control of hazardous energy program if any employees perform maintenance work on machinery or equipment that either:

  •  Exposes them to injury if the equipment were to accidentally be started, or
  •  Exposes them to injury if an unexpected release of hazardous energy were to occur, such as a blast of steam, corrosive chemical or electrical arc flash.

Some examples of tasks commonly performed by employees that would usually require lockout are: 

  •  Replacing belts on machinery, and vehicle engines 
  •  Disassembling equipment to replace/repair motors or pumps; 
  •  Maintenance on electric/ hydraulic equipment;
  •  Boiler repairs
  •  Working on engines and drive trains of vehicles/mobile equipment;
  •  Working under elevated buckets, booms, or dump bodies of vehicles and mobile equipment
  •  Changing saw blades;
  •  Electrical work where employees are exposed to conductors under the assumption that they are .off., like replacing light ballasts;
  •  Repair work or clearing jams on conveyors

A good lockout program should be specific to your operations and equipment. Essential elements of a Lockout program include;

1. A written hazardous energy control policy

2. Equipment specific lockout procedures

3. Lockout equipment

4. Employee training

5. Guidelines and training for contractors and other outside employers

6. Periodic program evaluation

7. Recordkeeping guidelines

Although lockout accidents are not as common as other mishaps, but when they do occur, they may result in serious injury or death. Do not wait for an accident to determine whether

 

OHSA Record Keeping

The following information comes from FirstComp Insurance.  You can read the full copy here.

Every employer covered by the Department of Labor’s Occupational Safety and Health Administration (OSHA) with more than ten (10) employees (except employers in certain low-hazard industries – retail, finance, insurance, real estate, and service sectors) must maintain specific records of job related injuries and illnesses. Despite the exceptions, all employers must report by telephone or in person to the nearest OSHA office within eight (8) hours of any work-related fatality or inpatient hospitalization of three or more employees. OSHA approved State Plans may have stricter requirements regarding: reporting of fatalities, catastrophes or multiple injuries, industry and size exemptions, and record access provisions. For specific requirements please contact your local state OSHA office.

Recording Criteria:

Generally an injury or illness must be considered work-related if an event or exposure either caused or contributed to the resulting condition or significantly aggravated a pre-existing  ondition. An injury or  illness is considered to meet general recording criteria if it results in any of the following: death; days away from work, restricted work or transfer to another job (DART); medical treatment beyond first-aid; loss of consciousness; or involves a significant injury or illness diagnosed by a physician or other licensed health care professional. The following must also be recorded: work related needlestick injuries and cuts from sharp objects that are contaminated with another person’s blood or other potentially infectious material are recordable; an employee that is medically removed from work under the requirements of a specific OSHA health standard; an employee’s hearing test (audiogram) reveals that an employee has experienced a work related Standard Threshold Shift (STS) in hearing in one or both ears, and the employee’s total hearing level is 25 decibels (dB) or more above audiometric zero in the same ear as the STS; an employee is exposed to someone with a known case of active tuberculosis (TB), and subsequently develops a TB infection.

Recordkeeping Forms:

OSHA provides three basic forms OSHA Forms 300, 300A and 301 for recordkeeping purposes. Form 300 is called the “Log of Work-Related Injuries and Illnesses” and is used to record specific information applicable to each recordable case. Form 300A is the “Summary of Work-Related Injuries and Illnesses” and is used to summarize Form 300 information at the end of the year. OSHA Form 301 is the “Injury and Illness Incident Report” and includes additional data on how the injury or illness occurred. An equivalent form such as your company’s incident report form can replace OSHA Form 301, as long as the equivalent from includes all of the same data. Within seven (7) calendar days of receiving information about a case, the employer must decide if the case is recordable, and then complete the 300 “Log” and the 301 “Incident Report”.

Other Requirements/Considerations:

● Employers must set up a specific method for employees to report injuries and illnesses, and must instruct all employees on how to report. An employer may not discriminate against an employee for reporting a work-related injury or illness.

● Cases such as; use of nonprescription medications, tetanus shots, cleaning, flushing or soaking of wounds, use of bandages, wraps or eye patches, use of hot, cold or massage therapy, and drinking fluids to relieve heat stress are considered first-aid and are not recorded.

● Employers must record the injuries and illnesses of all employees on payroll including temporary workers since the company exercises day-to-day control over them.

● Employers are allowed to cap the number of days away and/or restricted work/job transfer when a case involves 180 calendar days.

● If a company has more than one establishment (a single physical location where business is conducted or where services or industrial operations are performed), then a separate Form 300 must be maintained for each establishment expected to be in operation for more than a year. Industries such as construction and transportation are examples where employees do not work at a single location. For these, the establishment is a main or branch office that either supervises such activities or serves as the base location.

● For privacy cases, employees may request that their names be withheld from the 300 form. Reasons may include; injuries to the reproductive system, sexual assault, mental illness, HIV, hepatitis, sharps with contamination, tuberculosis, or voluntary request by the employee.

● Employees, former employees, their personal representatives, and their authorized employee representatives have the right to access the 300 Log Form and the 300A Summary Form. If requested, the employer must provide the requester a copy of the forms by the end of the next business day.

● Since records are generally not filed with OSHA, they must be maintained at the worksite for five (5) years and made available to employees and OSHA inspectors upon request. In addition, they must be updated to reflect changes that occur in recorded cases, and new entries must be made for previously unrecorded cases.

● Form 300A must be finalized at the end of each calendar year. A company executive must certify and sign the form. Additionally, the form must be displayed (where notices are normally posted) for a 3-month period beginning on February 1st and ending on April 30th of the year following the year covered by the summary. This also applies if there are no recordable cases for the year.

Grading, Trenching & Excavation: OSHA’s Revised Hazard Communication Program

The following information comes from FirstComp Insurance.  To view the full copy, click here.

OSHA has enhanced its Hazard Communica-tion Standard (HCS) 29 CFR 1910.1200 to align with the United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals (GHS). GHS is primarily concerned with the classification of hazardous chemicals and the communication of hazards related to those chemicals to users of the products via warning labels and Safety Data Sheets (SDS). Currently over 65 countries have or are in the process of adopting GHS. OSHA is calling the revised standard “HazCom 2012” and it went into effect in the U.S. May 25, 2012 affecting over 5 million employers and 40 million work-ers. Two significant changes contained in the revised standard require the use of new label-ing elements and a standardized format for SDSs, formerly known as, Material Safety Data Sheets (MSDSs).

GHS Compliance Deadlines

The first deadline is December 1, 2013. By this date, employers must train employees on GHS (how to read and understand new labels and SDSs), manage the influx of new SDS’s which will include replacing their entire MSDS library, and be ready to produce GHS compliant workplace labels. To prepare, employers should begin educating themselves on the changes as they will want to train employees well before the December 1, 2013 deadline. Existing fines and penalties for non-compliance with the HCS will extend to the new GHS alignment. This means that HCS violations, which already rank #3 on OSHA’s Top Ten Violations List, could see even more action.

The next compliance deadline is June 1, 2015, the date by which chemical manufacturers and distributors must reclassify their chemicals according to GHS guidelines and produce GHS formatted safety data sheets and labels.

The final deadline is June 16, 2016, the date by which employers must be fully compliant with GHS. This means all training of employees on any new hazards that have been identified in the reclassifying of chemicals by the manufacturers and distributors. It also means workplace labeling and workplace hazard programs must be up-to-date.