Let there be no doubt: if you want a 0.0 recordable incident rate, you can get one. You either manage work to the extent incidents do not cause injuries or illnesses; or you manage your OSHA 300 log the way you would like it to look.

I certainly was not one to “fudge” the OSHA 300 log in my days at a manufacturing plant, but it seems that these games had been going on for many years with some companies. 

Check out this interesting article from ISHN on the dark world of safety recordkeeping.   

But, what can you do to prepare? What can be done to prevent or control these Big Four hazards?  Read on to learn more!

This information affects hundreds of thousands of workers who complete Outreach Training Program classes each year, and more than 50,000 authorized OSHA Outreach Trainers.

“For too long workers have avoided making claims of unsafe work conditions out of fear of losing their jobs,” said Assistant Secretary of Labor for OSHA David Michaels. “We are confident that this new training will embolden workers to speak up when they find work practices that endanger their lives and the lives of their co-workers.”

The module focuses on the importance of workers’ rights, employer responsibilities and how to file a complaint. It also includes helpful worker safety and health resources. It covers whistleblower rights, filing a complaint, a worker’s right to refuse to work because of dangerous conditions, and provides samples of a weekly fatality and catastrophe report, material data safety sheet and the OSHA Log of Work-Related Injuries and Illnesses. 

For more information and training materials clink here.

That means it is more important than ever for employers to ensure they are in compliance with OSHA requirements. Even the requirements that don’t have a direct relationship to injury and illness prevention, for example injury and illness recordkeeping, are being cited at an increased rate with tougher penalties (e.g., $110,000 in proposed penalties to a company for continually failing to document and report employee injuries and illnesses).

Take a look at this article to learn more how OSHA is flexing their muscles in this new administration.

It is essential that an employer conduct a Hazard/Risk Analysis to determine the flash protection boundaries within their workplace. With that data in hand, employers can then determine which Hazard/Risk Category they fall into and choose flame-resistant clothing and PPE with the necessary arc rating to protect their employees.

The new Severe Violator Enforcement Program (SVEP) is intended to focus OSHA enforcement resources on employers who endanger workers by demonstrating indifference to their responsibilities under the law. This new tool includes increased OSHA inspections in these worksites, including mandatory OSHA follow-up inspections, and inspections of other worksites of the same employer where similar hazards and deficiencies may be present. SVEP will become effective within the next 45 days. Click here, for more information.

Last year, OSHA assembled a work group to evaluate its penalty policies and found currently assessed penalties are too low to have an adequate deterrent effect. Based on the group’s findings and recommendations, several administrative changes to the penalty calculation system, outlined in the agency’s Field Operations Manual, are being made. These administrative enhancements will become effective in the next several months. The penalty changes will increase the overall dollar amount of all penalties while maintaining OSHA’s policy of reducing penalties for small employers and those acting in good faith.

The current maximum penalty for a serious violation, one capable of causing death or serious physical harm, is only $7,000 and the maximum penalty for a willful violation is $70,000. The average penalty for a serious violation will increase from about $1,000 to an average $3,000 to $4,000. Monetary penalties for violations of the OSH Act have been increased only once in 40 years despite inflation. The Protecting America’s Workers Act would raise these penalties, for the first time since 1990, to $12,000 and $250,000, respectively. Future penalty increases would also be tied to inflation. In the meantime, OSHA will focus on outreach in preparation of implementing this new penalty policy. Click here, for more information on the penalty policy.

 Here are some of the common safety equipment being used to safely handle lead based paint:

• HEPA Vacuums
• Half-Mask Respirators with P100 filters
• Disposable Coveralls – impervious to fine lead dust
• Disposable Gloves
• Cleanroom (Tacky) Mats – dust particles from feet stick to this mat as you walk across it
• Other equipment listed in this brochuer entitled “Lead Safety During Renovation” from the EPA

 Beginning April 2010, these individuals will need to use HEPA Vacuums, per the EPA Requirement (RRP) listed under Title 40,Part 745. Please click on the here for further details. As needed, please contact a Conney Safety advisor for additional assistance.

“This directive conforms with Secretary Solis’ clear and urgent goal of reducing injuries and illnesses among Latino and other vulnerable workers,” said Dr. Michaels. “These workers represent an integral and essential part of the key industries that keep our country running every day.”

OSHA requires that employers provide training to their workers on certain job hazards and safe methods for performing work. Investigators will now check and verify that training was provided in a language and vocabulary that the workers understand.

SVEP will apply where: workplace fatalities have occurred, numerous enforcement measures have been taken against the employer and extremely severe occupational hazards exist.

Targeted employers can expect followup inspections and higher monetary fines than seen in the past. The SVEP will be operational in June.

Drilling Operations

Flame Resistant Clothing (FRC) is usually not needed during initial rig up and normal drilling operations prior to reaching active hydrocarbon zones, unless other activities warrant their use; e.g., fracing a previously drilled well while rigging a well in close proximity.

A potential for flash fire exists once active gas or hydrocarbon zones are reached. Appropriate FRC shall be worn by exposed employees working on the well site prior to drilling into identified gas or hydrocarbon zones. CSHOs should verify that employees are wearing FRC in advance of reaching such zones.

Appropriate FRC should also be worn when there is a history of fluid or gas kicks from underground producing zones.  Once FRC is identified for use as provided above, employees should wear appropriate FRC until the final casing is cemented and the well is effectively closed.

Well Servicing Operations

CSHOs shall determine whether FRC is provided and worn during well servicing or workover operations, such as:

• Pulling wet string tubing
• Snubbing tubing
• Swabbing operations
• Fracturing or perforating the well
• Using bridge plugs or packers
• Open hole work
• Flow testing, blowing down or venting the well
• Plugging an abandoned well
• Flowback operations
• Cementing
• Stimulation
• Wireline operations
• Any operation working with wellhead or wellbore under pressure

Production-Related Operations

In OSHA’s experience, the potential for flash fire also exists in production-related operations that fall outside of drilling and well servicing. CSHOs shall determine whether FRC is provided and worn during production-related operations, such as:

• Equipment openings (e.g., line breaking or valve changes)
• Gauging
• Transfer of hydrocarbons
• Maintenance operations on production equipment
• Hot work operations
• Tank heating
• Using open flame
• Start-up operations

The following sample language is provided for citations proposed under 29 CFR 1910.132(a):”The employer failed to provide and ensure the use of flame- retardant treated clothing (FRC) necessary to protect employees from burns due to potential flash fires.”

Citation Guidance for Other PPE Provisions

Other provisions of the PPE standard may also apply to drilling, well servicing, and production-related operations.

• CSHOs shall cite 29 CFR 1910.132(b) where there is a failure to assure that employee-owned FRC is properly maintained and sanitary.
• CSHOs shall cite 29 CFR 1910.132(c) where the employer fails to provide FRC that is of safe design and construction for work being performed. Employers may consult consensus standards such as NFPA 2112 and 2113 to comply.
• CSHOs shall cite 29 CFR 1910.132(d) where the employer fails to conduct a hazard assessment to identify the potential for burn hazards where employees have occupational exposure(s) to flash fires. Please review 29 CFR 1910.132(g) for appropriate application. At the time of this memo, a comprehensive personal protective equipment enforcement directive is being developed that will provide further citation guidance on this issue.
• CSHOs shall cite 29 CFR 1910.132(e) when defective or damaged FRC is used.
• CSHOs shall cite 29 CFR 1910.132(h) when an employer fails to provide, at no cost to employees, FRC that is used to comply with the standard.

This article is Part 3 in a Series of 3. Click here for Part 1 or Part 2. For more information on this topic, visit the OSHA website.