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OSHA / Recordkeeping

  • OSHA News, Are We Paying Attention?

    I visit the OSHA website for recent news and fines fairly frequently, to see whose getting nicked for violations and what the violations are. I’m not sure why they publicize them, but it sure can be interesting, and eye opening. January did not disappoint, there were 37 news releases regarding enforcement and citations for violations. Just reading through these gives one reason to just shake your head and wonder: What are they thinking? Or not? Wile E. Coyote never had a OSHA safetymonth like this.

    Blast turns Fatal Death of Welder who fell from misused forklift Lack of fall Protection in worker Fatality Repeated safety Hazards 2 workers injured 1 fatally 2 workers succumb to dangerous fumes Construction fatality results in citations For the third time, OSHA finds roofing contractor allows fatal fall hazards

    The list reads like a bad novel or horror story, and the February list is already growing. If you’re reading this article then you are probably a concerned Safety Advocate. In the past we’ve discussed just about everything you’ll find in the violations OSHA is reporting on their website. Fall protection, fork lift safety, confined space, you name it we have even discussed repeat violations.

    Perhaps the site is a good venue for displaying the overall cost of the violations committed and the senseless loss of life, along with the violators. I may have mis-spoke my question of why. It needs to start somewhere. I understand that safety is everybody’s responsibility but reading this is frustrating. I do applaud all of you out there who are concerned about proper training, and make an effort to make sure that training, and retraining is delivered. Somehow however not everybody got the memo.

    Here’s our challenge as a safety community, we need to seek out other venues to share our information. Don’t overlook your local newspaper, sponsor a safety column. Social media is the current darling of information disbursement, learn how to use it. Preaching to the choir gets old and doesn’t get our message to the right people. Average Americans don’t read safety magazines. Have your company sponsor a safety rodeo for young people. And make sure the media is there. If you’re a Union this is a great way to give back to the community, and to show people that unions are still relevant. We all need to be relevant, and sooner than later.

  • My Mother: A Tribute to Competent Person Training

    I grew up in a family of twelve children, five girls and seven brothers. Little did I realize at the time that apparently OSHA had visited my house and declared “Mom” a competent person.

    The term "Competent Person" is used in many OSHA standards and documents. An OSHA "competent person" is defined as "one who is capable of identifying existing and predictable hazards in the surroundings or working conditions, which are unsanitary, hazardous, or dangerous to employees, and who has authorization to take prompt corrective measures to eliminate them" [29 CFR 1926.32(f)]. By way of training and/or experience, a competent person is knowledgeable of applicable standards, is capable of identifying workplace hazards relating to the specific operation, and has the authority to correct them. Some standards add additional specific requirements which must be met by the competent person. This definition is taken from OSHA.

    It seemed that Mom was always on the spot to guide us in the direction of sanity. She taught us some of the finer points of working safely in the kitchen, and of course the rewards of taste testing to make sure it was safe for the others. Cleaning was also on her radar, including sanitation. Right to know issues were whose turn it was to do dishes, or sweep the floors. Everybody was involved in cherry picking and pitting for pies and jam. The older boys had garage duty, or loading coal into the furnace hopper. Of course Dad was the force in the repair department, including repairing and glazing windows before putting on the storms in time for winter. Dad also inspected and repaired our 4 buckle boots. Yes PPE was a part of the routine. We didn’t necessarily have safety meetings but were reminded that if we were going out to play ball, to cross the road safely, make sure the dog didn’t follow us, and to look out for your little brothers. I’m not too sure what Mom told the girls except that she would flash the light on and off if they were in the driveway too long with a boyfriend. Mom passed away this past fall, but left us with a lifetime of memories. Competent Person training was passed down. Now I get to be the competent person in my own home, with my wife’s blessing of course.

    Competent person training is a big deal. Why train a competent person? Employers are required by law to comply with a number of OSHA regulations. These regulations are defined and driven by hazards which exist in your workplace. Compliance with these laws indicate that a “Competent Person” must be assigned the responsibility of identifying existing and predictable hazards, and has been given the authority to take corrective action. If you are a Human resource manager, Maintenance Manager, safety program Administrator, Hospital administrator, on a safety committee, process engineer, department manager, Risk manager, or anyone having safety management duties. You should have this type of training. It covers: Introduction to OSHA, components of an effective safety Program, OSHA Record keeping fundamentals, , Intro to Industrial hygiene/toxicology, Job hazard analysis & Procedures, accident investigation, PPE, Hazcom & GHS, LOTO, confined space. Along with that training the trainer could also be a part of this type of training. Seek out, find and enroll in the training you need. Competent Person Training, Your Mother would be proud.

  • "Overall Company Safety Plan" The Final Analysis

    This year has slipped by pretty quickly. I’m sure that in the final analysis we’ve all had some wins and some losses. I pray that you’ve had more in the wins column. This is the time of the year of course that you’ll want to make sure that your OSHA record keeping plan is up to date and compliant for the mandated OSHA standard 29CFR 1904. Additionally your OSHA Form 300a for 2013 is due for posting from February 1st to the end of April for all to see, like bearing the soul of the company. So if you are the person charged with this task it’s also a good time of the year to review your overall company safety plan.

    Your “Overall Company safety Plan” is a very important document. Not just for OSHA requirements, but it provides a road map for your company’s safety environment. If you haven’t already done so, then you should really familiarize yourself with “Process Safety”, or “Job Safety Analysis”. This is also a good time of the year to update your “Employee safety Handbook”. There are so many topics to consider when reviewing your “Overall Company Safety Plan” Have you considered “Emergency & Disaster Preparedness”, Crisis Management”, Defensive Driving”, “Personal Protective Equipment” including the use of safety footwear? Something not necessarily related to safety but should be recognized as a very important part of team building is “Preventing Discrimination In The Workplace” There are just so many topics to consider, if you don’t have a safety committee, perhaps you should take a look at creating one. This will enable you to get additional help in identifying hazards, and also sharing in the responsibility of creating a safe working environment, and identifying other potential topics.

    “Last One Out” No, don’t turn the lights out, but turn the lights on. Familiarize yourself with the many on line courses, safety videos, editable power point presentations, and written plans, available. They are all designed to give you, your employees and families a safer environment both at work, in the office and at home. In closing we would like to wish all of you a very Blessed Christmas and safe New Year. This will be made easier if you have an “Overall Company Safety Plan”.

  • Who's Keeping Score

    OSHA is the score keeper, and requires that most employers keep a “Log”. If you are a small business with ten (10) or fewer employees then you would be exempt from most of the requirements of the rule. Other exceptions would include a number of specific industries in, retail, service, finance, insurance, and real estate, which are classified as low hazard. You will want to check with your local OSHA office to confirm your exemption, which is determined by your company SIC code. For more information visit http://osha.gov/recordkeeping/ppt1/RK1exempttable.html If you don’t fall into one of these exceptions, and most of you don’t, then you are required to keep a “300 Log”.

    OSHA provides /requires, three record keeping forms: Form 300: Log of work related injuries and illnesses Form 301: Illness and injury incident report (this report includes more data about how the illness or injury occurred. Form 300A: Summary of Work related Injuries and illnesses. This is the most recent form making it easier to post and calculate incident rates.

    If you are inspected by OSHA, and are required to keep a 300 Log, you will need to be able to produce a copy during the inspection, or within 4 hours of their request for your log. You may keep your log electronically. And while you’re at it make sure you have OSHA Poster #2203 posted where your employees can readily review it. The required poster covers employee rights and protections under OSHA guidelines.

    Keeping your log can be a challenge, and you’ll need to understand the terms and definitions set forth by OSHA including the gray areas like “pre existing conditions”. Other questions? What is a recordable injury?, what doesn’t have to be recorded?, If I do have a recordable injury, will I also be required to have a written safety plan for “Light Duty Return to Work” and what about ADA , mental illness, and confidentiality?

    So let’s answer at least the elephant in the room; What is a Recordable Injury?

    *Results in death *Results in Days away from work *Restricts their ability to work or requires “transfer to a new job” *Medical treatment beyond 1st Aid *Loss of consciousness *Significant injury or illness diagnosed by a healthcare professional and determined to be work related *Mental Illness (if stated by a healthcare professional that it is work related) *ALL injuries from needles or sharps that are contaminated by another’s blood or infectious material *Work related cases of Tuberculosis *Cases where a worker is removed from work under the provisions of an OSHA standard (ie. Lead or asbestos exposure) *Some injuries incurred while an employee was traveling for work or working from home.

    We’ll cover more records information in our next article. If in the meantime you need additional information on recordable injuries and the subsequent OSHA standards, please visit: http://osha.gov/recordkeeping/entryfaq.html , or you can call us here in the office 866-598-2128 at www.Safetyinstruction.com .

    One Last thing, too late for this year. You must post the Summary only form 300A (not the Log) by February 1 of the year following the year covered by the form and keep it posted until April 30 of that year. The posting should be accessible to employees, preferably in the same area as the 2203 poster.

  • What Were they Thinking? Repeat Safety Violations

    An OSHA inspection and audit can be a daunting, anxiety laden experience. Should it be? Not really, Employers should be working with managers and employees to Identify and eliminate hazards within the confines of their business at the outset.

    I believe that every employer has a basic knowledge of the hazards in their respective industries. Whether its construction, manufacturing, food service, laboratory, municipal, utilities, farming, they are all aware of the potential hazards. It can be, Confined space entry, Combustible dust, electrical, fall protection, asbestos or lead safety awareness, machine guarding, lab safety, Personal protective equipment, as simple as hearing protection, the list is almost endless. To ignore them is just plain negligent. To ignore them after an OSHA inspection can be very expensive and perhaps even criminal.

    So what were they thinking? A REPEAT VIOLATION? Most recently a company in Concord NH was handed citations for “Willfull, Repeat, and Serious violations, of workplace standards”. Really? The proposed penalties for that is $143.000, The proposed fine in total for the other violations? $221,100.00. The sad part? This is not an isolated incident. If you visit OSHA’s website you will find their news releases outlining the infractions and related penalties.

    So how can all of this be avoided? There are several solutions:

    *Set up your own Safety committee, your employees are your most valuable asset. *Review your written safety policies and plans *Train your supervisors in Job Hazard analysis” *Do a site safety audit to identify potential hazards, and develop an action plan *Hire a safety consultant on a retainer if you can’t afford a full time trainer. This consultant can help you with your written plans, audit your facility, train the trainers, and employees, and outline an action plan. for far less than the cost of an OSHA citation

    Follow these simple steps and you are on your way to reducing your overall exposure to OSHA citations, creating and fostering good employer/ employee relations, and raising overall safety awareness.

    If you are interested in any of the safety services mentioned above visit www.safetyinstruction.com

  • Montana Company to Pay About $75,000 for Safety Hazards

    Some employers shrug off the importance of workplace safety, thinking that it would be too costly to implement safety and health programs. This is where their mistake lies. In truth, they may be paying penalties that amount to more than the cost of safety efforts. Just this month, a certain Montana manufacturing company has been fined $75,600 as a penalty for committing a dozen of serious violations. Read the news at ClaimsJournal.com.

  • Fireworks Company Blasted for 31 Safety Violations

    There are just some jobs which put their workers at risk. Sometimes, this is part of the job and is inevitable. Most of the time, though, a lot of workplace incidents and mishaps can be avoided if only the right safety guidelines and inspections push through regularly. This has been the case for Global Pyrotechnic Solutions, a company cited by the OSHA for having committed 31 different safety violations. Records show that the company already has had previous employees sent to hospitals due to burn injuries and other disabilities. Learn more about the violations, the fines, and the future awaiting this company here.

  • A “Fine” Line

    One cannot be prepared enough at all times - but not preparing at all is a different story. Parkland Memorial Hospital, in Dallas, has recently been fined a whopping $1 million for its shortcomings with occupational safety requirements - which have the tendency of putting not only patients, but health care and other workers as well, at risk. From understaffed nursing services to inadequate infection control measures, the hospital has been fined with the highest amount in the state’s history. Read more about this story by the Courthouse News Services here.

  • Safety Violations by a University?

    In July, the University of Texas paid a penalty of nearly $30,000 because of serious safety violations. Two lives ended when they fell more than 150 feet to the ground. Mede Nix of DallasNews.com wrote a news story regarding this tragic event: “OSHA Proposes Hefty Fine for Safety Violations in university of Texas at Dallas Crane Collapse.”

  • Outrageous Fines or Outrageous Negligence?

    The Times Reporter calls it outrageous, but the fines required from rule breakers are just right to teach them a good lesson. It seems that the staff (who wrote the opinion piece) lacks the information as to why OSHA has been existing in the first place. If it’s all about consumers catching the cost of company penalties, then they haven’t realized yet the impact of neglecting workplace safety to both employees and consumers themselves. What’s your view on this? Take a look at the article: “30 Seconds: Dover Chemical Fines Are Outrageous.”

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