Kevin Ian Schmidt

SPCC – A brief Introduction

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A SPCC (Spill Prevention, Control and Countermeasure) plan is a document that should be drawn up by the owner of any oil storage facility to describe what steps are to be taken for the handling of oil, what to do if spills occur, what drainage or discharge controls are in place, who is in charge, and what resources and equipment can be brought into use to prevent any oil spills from reaching the coastline or any busy shipping lanes. The SPCC plans must be drawn up according to recognized engineering standards.

Oil spills are a danger to the health of the public, pollute drinking water, spoil natural resources and cause disruptions in the economy. The United States uses enormous quantities of oil for heating, fuel for vehicles and for the operation of hundreds of thousands of machines. Often, oil is spilled from storage facilities, while being transported, or during the course of exploration or production processes and it ends up soaking into the land or being carried away by rivers and streams.

The prevention of oil spills should be high on the agenda of any oil storage facility and if they do occur, they should be cleaned up as quickly as possible. It often costs less to prevent a spill than to clean one up after the event. The purpose of the SPCC rule is to assist oil storage facilities prevent spilled oil from reaching navigable waterways or the closest shoreline.

The SPCC rule applies to any facility that can store more than 1,320 gallons of oil above ground or greater than 42,000 gallons below ground and there is a reason to suspect that there may be an oil leak. All types of oil are covered, including fuel oil; petroleum; refuse oil; sludge; waste oil and vegetable oil to name but a few. The type of facilities that are covered by the regulation are any that store, refine, process, consume or use oil and are not in the business of transporting the oil.

Check Out: Spill Response Plan – Training

All covered facilities have to comply with the SPCC rules by preventing oil from spilling and by setting up and following their own SPCC plan. Some of the steps an owner or operator can take to prevent oil from spilling include; use suitable containers for the stored oil, use an alarm system to indicate overfill, provide backup containment measures for bulk storage vessels that is able to contain a major spill from the vessel plus any rainfall, if using a dike, this should be constructed from concrete or earth. Using a tank with double walls may also be acceptable.

Secondary containment should be provided to catch the spills that occur when transferring oil between containers and when offloading tankers. Drip pans, absorbing materials or curbing mechanisms should be used as well as regular inspections of all containers and pipes. Underground pipes need to be leak tested after installation or repair and written records should be included in the plan for these tests.

It is the owner/operators responsibility to draw up and implement an SPCC plan. Once all of the elements have been described in detail, the plan has to be certified by a Professional Engineer. The owner or operator can certify the plan if he is able to or chooses to only if certain conditions are met.

These conditions are subject to certain eligibility criteria such as; the total capacity of aboveground storage should be 10,000 gallons or less, for three years prior to certification, there has been no single oil discharge into the water or onto the shoreline that exceeds 1,000 gallons, two discharges of oil into the water or shoreline have not exceeded 42 gallons over the previous twelve months. If the facility cannot meet the above requirements then a licensed Professional Engineer must certify the SPCC plans.

Download and view the SPCC Generic Template below:

SPCC GenericTEMPLATE

 

How to Persuade Your Staff to Wear Personal Protective Equipment

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Let’s face it, people don’t do what they’re supposed to do a lot of the time and there are a variety of reasons. This article shows a practical way of persuading your staff to wear Personal Protective Equipment (PPE). To understand the behavior or lack of behavior by other people it is best to first understand yourself. You might say to yourself but why do I need to do this because the rules are clear, in certain areas and in carrying out certain tasks PPE is mandatory, no argument. Understanding your own behavior is a step to understanding other peoples’ behavior. Nowadays, it is a very important aspect of management and leadership. The need to understand human behavior has increased many fold over the last 10 years. It is an area that all people in leadership roles should learn about.

If you have a situation where staff members are not wearing PPE at the appropriate time and in the appropriate place, the first stage is to ask them why they are not wearing it. Normally, the range of responses will include, “It’s too uncomfortable.” “I have been doing it this way for 20 years and never hurt myself.” “I can’t see the point of it.” “I forgot.” And so on. Without a doubt, human nature being what it is, the easy way or the comfortable way will always be the first choice before the slightly harder way or the less comfortable way.

One of the ways to increase the use of PPE is to talk to your team about the consequences of not wearing it. For example, ask them if it is fair and reasonable to wear ear protection in noisy areas. You may get the response, “I am already deaf so it won’t make any difference.” Point out at this stage that the newer people will mimic behavior so they will copy a bad example. Ask them if they had their time again would they like their hearing returned.

On the other hand, the majority of people will readily agree that it’s fair and reasonable to wear ear protection in noisy areas. You then have to ask the question, “What will be the consequences of not wearing ear protection?” This way, it’s possible to set in place a consequence for that unsafe behavior. Gradually you can go through each item of PPE during your safety talks and achieve two objectives, firstly, get agreement that wearing PPE is fair and reasonable and, secondly, get agreement of the consequences that should occur if people don’t wear it.

Need components of a PPE program? Check out what I offer for small businesses here

That may be necessary to follow this method several times before an impact is made. Gradually, you will find that the levels of compliance will rise until the majority of people will raise the situation with the minority who were not wearing their protective equipment.

 

The 6 Key Principles of Persuasion

    1. Reciprocity – “Gimme Five” the concept is we want and expect the return of favors, even simple handshakes. That’s why you get all those free samples at grocery stores. We hold a reasonable expectation of gifts and good deeds in return for our attention; a scratch my back sort of thing!
    1. Commitment and Consistency – You are more likely to keep a promise when it is consistent with the way you see yourself, even when the other side fails to meet expectations. Honesty still tends to prevail.
    1. Social Proof – You Tweet because your friends Tweet. We are likely to follow the path of “crowd think”, believing so many Frenchmen can’t be wrong!
    1. Authority – The people we look up to, give us permission to act out differently than normal; even when it’s wrong. That’s why good boys may do bad things.
    1. Liking – We are more likely to follow the advice or purchase the brand endorsed by a famous movie star or pop idol. Diet plans wouldn’t be as popular just showing common folks losing weight!
  1. Scarcity – If you didn’t have to stand-in line to get the latest tech gadget, you wouldn’t be as likely to buy one.

These six principles of persuasion are universal. Here’s an example Cialdini uses to show how human behavior is both subtle yet mechanical.

An Example of Persuasive Superpowers

The experiment by Harvard social psychologist Ellen Langer, states that it is commonly believed when asked a simple favor, we are more likely to oblige if the request is accompanied by a plausible reason. It goes something like this:

STAGE 1. Langer first provides a base test by asking a ‘small favor’ of a group of people in line at… Let’s say a coffee shop, “Excuse me, I need to get my caffeine fix. May I go ahead in the line, because I’m in a hurry?” The effectiveness of this request-plus-reason was nearly total: Ninety-four percent of those asked allowed her to skip to the front of the line.

STAGE 2. Compare this success rate to the results when she made the request-only, “Excuse me, I have to get my caffeine fix. May I go ahead in the line?” Under those conditions, only 60 percent complied. It would infer that the difference in results was due to the additional information offered, “because I’m in a hurry” as in the stage one.

STAGE 3. But a third request tried by Langer demonstrated this was not the case. It seems it was not the series of words that made the difference, but solely the first word, “because“. Langer’s third attempt used the word “because”, but added no new information or reason for the request. She merely restated the obvious, “Excuse me, I need to get my caffeine fix, may I go ahead of you, because I need my caffeine fix.” The result was once again nearly all (93 percent) allowed her to cut in line even though there was no justifiable reason given.

When you make a request of someone else, regardless of the reason, humans are programmed to respond positively to the stimulus word “because”. Knowing this, there would be no reason not to use this.

Ask yourself, if you stated in front of all your work mates that you thought that wearing PPE because it was fair and reasonable, what would be the chances of you complying with that statement? I would suggest that it would be very high. It is called a psychological contract and is very effective.

Back and Lifting Safety Training

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Back injuries are a major cause of missed time – only second to the common cold! The majority of back injuries occur during lifting tasks and these injuries can be very costly for companies in lost productivity and insurance claims. In the short term, a back injury can cause serious discomfort and pain for the employee but in the long term, it can have a devastating effect on the employee’s lifestyle and ability to work.

Here are 4 of the major causes of back injuries in the workplace:

Insufficient Training: It’s easy to assume that everyone has an intuitive sense of how to lift and carry objects and knows how much they can safely lift by themselves. However, back injuries are extremely common and many people don’t understand the consequences of improper lifting and how they can lift safely. Any workplace that requires employees to lift heavy objects should cover the proper techniques as a part of basic safety training.

Improper Lifting: Starting everyone off with proper safety training is essential, but knowledge and commitment to safe work practices can fade over time. Employees may become complacent in their lifting and develop bad habits that erode their technique and can result in injury. Reinforcement of lifting safety principles is important and supervisors or colleagues should correct employees using improper techniques. Safety reminders should be frequent but also varied so that they do not lose their impact. Consider reminding employees through a mix of email reminders, safety meetings, and workplace safety notices to keep lifting safety top of mind.

Not Appreciating the Risk: If employees are regularly lifting things in the course of their job, they can become desensitized to the risk. This makes them more likely to make mistakes like lifting with poor posture, twisting while lifting, or lifting objects that are too heavy. If an employee has not experienced a back injury before and felt the pain for themselves, they may not realize the debilitating outcomes they are risking with poor lifting technique. Your safety training should explain how back injuries often become a chronic problem that can not only limit their ability to work, but also their ability to do basic tasks like getting out of a chair or playing with their kids. As an employer, you should make sure that workers understand their lifting limit and why they should respect it. It’s also important to schedule work to allow for breaks and create a balanced workday where employees don’t continuously work through physically demanding tasks.

Rushing: Tight deadlines and long work days can cause employees to feel rushed and lifting technique can be compromised as a result. Many injuries occur when employees are under pressure and in a hurry because back strain is the last thing on their minds. Sometimes tight deadlines and workplace stress are unavoidable, but by understanding how that impacts safety and back health, you can try to schedule work appropriately and better support the safety of your workers.

Remember that any type of safety training is only as good as its reinforcement. Regular reminders of proper lifting techniques are critical to prevent employees slipping into bad habits, and everyone should be encouraged to watch and correct unsafe work practices.

Some essential Do’s and Don’ts of lift safely include:

Do:
• Try an eliminate manual lifting when possible.
• Stay in good physical shape.
• Make sure you have a good grip on any item you lift.
• Test the weight and balance of the item to be lifted.
• Ask for assistance if an item is too heavy or awkward to lift safely.
• Keep the item being lifted close to your body.
• Stand in a stable position and lift mostly by straightening your legs.

Don’t:
• Twist or bend in a sideways direction when lifting.
• Lift or lower an object from an awkward position.
• Lift or lower an object if your arms are extended.
• Try and continue to lift an object if you realize it’s too heavy.
• Lift anything above your shoulders or below your knees.

Download and view the Back and Lifting Safety Training below

Back-Safety

 

Safe Workplace for Everyone

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Creating a safe workplace is not just about the employees who work there regularly. It extends to all individuals who enter the premises, including contractors, visitors, and the public. Ensuring their safety is as crucial as safeguarding those familiar with the environment. Recognizing the potential hazards within a workplace is vital, especially for individuals who are unfamiliar with the setting. Identifying these risks and taking steps to improve the safety of the workplace is paramount.

To help establish the safest environment for everyone entering your workplace, consider these ten essential steps:

  1. Take a Comprehensive Walkaround: Begin by thoroughly exploring your workplace. Familiarize yourself with every nook and cranny, inside and out.
  2. Heighten Your Awareness: Pause, close your eyes, and then turn left and right, still keeping your eyes closed. This exercise sharpens your other senses and perception of the space.
  3. Visualize Emergency Situations: Imagine yourself in an emergency scenario. Picture low visibility and a sense of panic. How would you navigate the area?
  4. Identify Walkways and Exits: Open your eyes and carefully observe your workspace. Locate walkways and exits that could be crucial during an emergency evacuation.
  5. Critical Self-Assessment: Evaluate the environment as if you were an outsider entering in an emergency. Are there hazards that are apparent to you but might not be to someone unfamiliar with the workplace?
  6. Conduct a Job Site Hazard Analysis: If you find it challenging to identify potential dangers, consider conducting a job site hazard analysis. This assessment can reveal risks that might otherwise go unnoticed.
    Check Out: How to Conduct a Job Hazard Analysis
  7. Address Identified Hazards: If you recognize hazards that could pose a threat to someone unfamiliar with the premises, take immediate action. Fix, change, or remove these hazards to enhance safety.
  8. Take Immediate Action: Implement these changes promptly. Waiting can increase the risk of accidents. Addressing hazards promptly is key to maintaining a safe workplace.
  9. Regular Vigilance: Repeat this evaluation every time you walk around the workplace. Hazards can change, so regular checks are essential to ensuring a consistently safe environment.
  10. Promote a Safety Culture: Encourage all employees, visitors, and contractors to be vigilant and report any hazards they notice. A collective effort ensures that potential dangers are identified and rectified promptly.
Check Out: The Road Map to Build a Positive Safety Culture

By adhering to these steps, workplace safety for everyone who enters can be significantly improved. It’s a simple yet effective way to ensure a secure environment for all, fostering a culture of safety and well-being in your workplace. Remember, a safe workplace is everyone’s responsibility.

Employer Requirements to Recording Injuries and Illnesses

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The OSH Act of 1970 requires the Secretary of Labor to produce regulations that require employers in certain industries to keep records of occupational deaths, injuries, and illnesses. The records are used for several purposes.

Injury and illness statistics are used by OSHA. OSHA collects data through the OSHA Data Initiative (ODI) to help direct its programs and measure its own performance. Inspectors also use the data during inspections to help direct their efforts to the hazards that are hurting workers.

The records are also used by employers and employees to implement safety and health programs at individual workplaces. Analysis of the data is a widely recognized method for discovering workplace safety and health problems and for tracking progress in solving those problems.

The records provide the base data for the BLS Annual Survey of Occupational Injuries and Illnesses, the Nation’s primary source of occupational injury and illness data.

 

What is the effect of workers’ compensation reports on the OSHA records?

The purpose section of the rule includes a note to make it clear that recording an injury or illness neither affects a person’s entitlement to workers’ compensation nor proves a violation of an OSHA rule. The rules for compensability under workers’ compensation differ from state to state and do not have any effect on whether or not a case needs to be recorded on the OSHA 300 Log. Many cases will be OSHA recordable and compensable under workers’ compensation. However, some cases will be compensable but not OSHA recordable, and some cases will be OSHA recordable but not compensable under workers’ compensation.

 

The Purpose of Recordkeeping

The recordkeeping and reporting rule requires employers to record and report work-related fatalities, injuries and illnesses. It’s important to know that recording or reporting a work-related injury, illness, or fatality:

  • does not assign fault to anybody
  • does not prove the violation of an OSHA rule
  • does not establish the employee’s eligibility for workers’ compensation or other benefits

Scope of the Rule

All employers covered by the Occupational Safety and Health Act (OSH Act) are covered by these Part 1904 regulations. However, most employers do not have to keep OSHA injury and illness records unless OSHA or the Bureau of Labor Statistics (BLS) informs them in writing that they must keep records. For example, employers with 10 or fewer employees and business establishments in certain industry classifications are partially exempt from keeping OSHA injury and illness records.

Check Out: Who and Where Does OSHA Regulate

Criteria for Recording Injuries and Illnesses

Each employer is required to keep records of fatalities, injuries, and illnesses that:

  • are work-related
  • are new cases
  • meet one or more of the general recording criteria of Section 1904.7 or the application to specific cases of Section 1904.8 through Section 1904.11

Recording Rule Exemptions

Employers in certain industries are not required to keep OSHA injury and illness records (visit this OSHA webpage for a list of partially exempted industries), unless they are asked in writing to do so by OSHA, the Bureau of Labor Statistics (BLS), or a state agency operating under the authority of OSHA or the BLS. All employers, including those partially exempted by reason of company size or industry classification, must report to OSHA any workplace incident that results in a fatality, in-patient hospitalization, amputation, or loss of an eye.

If your company had ten (10) or fewer employees at all times during the last calendar year, you do not need to keep OSHA injury and illness records unless your State Plan or Federal OSHA Director or the BLS informs you in writing that you must keep records under Section 1904.41 or Section 1904.42. However, as required by Section 1904.39, all employers covered by the OSH Act must report to OSHA any workplace incident that results in one or more fatalities or the hospitalization of three or more employees.

  • If your company had more than ten (10) employees at any time during the last calendar year, you must keep OSHA injury and illness records unless your establishment is classified as a partially exempt industry under Section 1904.2.
  • The partial exemption for size is based on the number of employees in the entire company.
  • To determine if you are exempt because of size, you need to determine your company’s peak employment during the last calendar year. If you had no more than 10 employees at any time in the last calendar year, your company qualifies for the partial exemption for size.

 

When is an injury or illness work-related

You must consider an injury or illness to be work-related if an event or exposure in the work environment either caused or contributed to:

  • the resulting condition, or
  • significantly aggravated a pre-existing injury or illness.

You should presume work-relatedness for injuries and illnesses resulting from events or exposures occurring in the work environment, unless an exception in 29 CFR 1904.5(b)(2) specifically applies. We’ll discuss these exceptions in the next section.

When is a workers’ compensation case work-related?

A case is presumed work-related if, and only if, an event or exposure in the work environment:

  • is a discernible cause of the injury or illness; or
  • a significant aggravation to a pre-existing condition.

The work event or exposure need only be one of the discernible causes; it need not be the sole or predominant cause.

“Work Environment”

The work environment is the establishment and other locations where one or more employees work or are present as a condition of their employment.

The work environment includes not only physical locations, but also the equipment or materials used by the employee during the course of their work.

Do you have employees in nontraditional work environments. check out this post to learn more

“Significantly Aggravated”

A pre-existing injury or illness is significantly aggravated when an event or exposure in the work environment results in any of the circumstances below.

  1. Death, provided that the pre-existing injury or illness would likely not have resulted in death but for the occupational event or exposure.
  2. Loss of consciousness, provided that the pre-existing injury or illness would likely not have resulted in loss of consciousness but for the occupational event or exposure.
  3. One or more days away from work, of restricted work, or days of job transfer that otherwise would not have occurred but for the occupational event or exposure.
  4. Medical treatment in a case where no medical treatment was needed for the injury or illness before the workplace event or exposure, or a change in medical treatment was necessitated by the workplace event or exposure.

To ensure that non-work-related cases are not entered on the Log, the rule requires employers to consider as non-work-related any injury or illness that “involves signs or symptoms that surface at work but result solely from a non-work-related event or exposure that occurs outside the work environment.” (See Table here.)

Pre-existing conditions also include any injury or illness that the employee experienced while working for another employer.

Non Work-Related Injuries

An injury or illness occurring in the work environment that falls under one of the following exceptions is not work-related and therefore is not recordable. Do not record injuries and illnesses if the circumstances below occurred.

 

View & download the OSHA Recordability First Aid Answer Sheet below

OSHA-Recordability-Medical-Treatment-First-Aid-1

 

Basics of a Written Safety Plan

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A Written Workplace Safety Program is a management approach for identifying, analyzing, and controlling workplace safety and health issues. This includes developing systematic policies, and practices in creating and maintaining a safe and healthy working environment. The implementation of a written safety plan is a proven and effective method for reducing the number of accidents and injuries among your employees.

Controlling injuries can save your company money in employer’s compensation costs, decrease employee time away from work, and help improve employee productivity and morale.

  1. Where and How to Start

First, you will need to develop a safety policy statement. Your safety policy statement must contain short and concise statements each employee can recite. It must explain the goals and objectives of your safety and health program, reinforce the principle that safety is everyone’s responsibility and be signed by the most senior officer in the organization.

 

  1. Commitments of the Management

Commitment’s of the management in writing the written workplace safety program include, management involvement, communicating responsibility, and resources to responsible parties and holding those parties responsible. In addition, management needs to make sure that employers are encouraged to report hazards, injuries, illness and symptoms and that there aren’t any programs or policies discouraging this report.

Check Out: Workplace Safety Meetings – 7 Ways To Increase Their Effectiveness

 

  1. Division of Responsibilities

Your workplace safety program must explain how the responsibilities for safety and health have been assigned to managers, supervisors, employees, and any other entities (such as safety committees) in your organization. Clear assignments of responsibility will allow each employee, supervisor, and manager to know what activities and behaviors are expected. What employees, supervisors and managers are held accountable for is what normally gets accomplished in your operation. Be as specific as you can and then hold them to it. Use this as part of your performance appraisal process to evaluate employee effectiveness. Assess your current business activities, positions, and responsibilities. Make a list of all employees, showing date of hire, job description, and what experience and training each might have.

Check Out: Establishing a Safety Committee

 

  1. Hazard Identification

Your written safety program must explain how you intend to identify, analyze, and control existing, new or potential hazards at your organization. This should include: regular inspections of your facilities, and analysis of hazard operations, carrying out workplace accident investigations, injury trend analysis, and taking action to eliminate future injuries. Be more specific and delegate who will be completing each activity, when they are to complete the activity, and how this will be evaluated for effectiveness.

Check Out: How to Conduct a Job Hazard Analysis

  1. Hazard Analysis

Analyzing your hazards is an important step in reducing the potential for accidents, as it will help you use your resources more effectively when you begin to correct them. Once your hazards and potential hazards have been identified, you will need to list the methods you intend to use to analyze them. Each of these components should be evaluated independently. Once this has been done, you can combine the two components to determine the gravity of each hazard.

Check Out: PPE Hazard Assessment and Certification

  1. Hazard Control

Now that the hazards have been identified and categorized, it is time to avoid them. If possible, eliminate the hazard(s) completely. If not, you must control the hazard(s) by using one or more of the following: Engineering Controls: Barricades, and ventilation systems. Administrative Controls: changing work schedules, or assignments. Generally, to manage hazards the workers will have to be trained in hazard recognition and how to reduce their exposure. Some examples of Administrative and Procedural Controls include Hazard communication programs and Lock-out/tag-out procedures. Personal Protective Equipment (PPE) such as eye protectors, hand protectors, and respirators. Personal Protective Equipment should always be used as a final option. Solutions should be sought in engineering or administrative controls first.

Check Out: What Is the Hierarchy of Control?

  1. Accomplishing Hazard Identification

Hazard identification shall be accomplished using the following means: Safety/health inspections, employee safety hotline, reports of safety monitors, and review of records. Department supervisors will conduct inspections in their departments quarterly on the first Friday during the months of February, May, August, and November. Hazards reported through the employee safety hotline will be sent to the corresponding department supervisors. The hotline information will not have employees’ names. The goal is to learn what the hazards are and correcting them. No one will take any unfavorable action against anyone for identifying a hazard. The reports of the safety monitors will be sent to the safety committee and the plant manager. The safety manager will evaluate the hazard bulletins and provide them to the department supervisors to be addressed at the next department meeting.

Check Out: How to Develop an Internal Safety Audit Schedule

8: Role of the Safety Managers

The safety manager will coordinate the hazard analysis effort. The safety manager will review accident investigation reports to identify the need to improve training, evaluate if corrective action has been addressed, and determine that action has been taken to reduce injuries. Any problems identified may indicate a need to address the system, processes, and controls. The safety manager will communicate results of the area and personal sampling to the employees and supervisors. The supervisors must correct problems resulting in levels discovered that are beyond acceptable limits. Any sort of necessary action out of the supervisor’s control will be directed to the plant manager and safety committee. Department supervisors will conduct a job hazard analysis at least annually for each job classification in their departments and ensure they are updated. This includes a hazard assessment for personal protective equipment (PPE). The safety manager and safety committee will evaluate accident trends from the policyholder statements and OSHA Injury and Illness log while ensuring the appropriate confidentiality. They will notify and work with the department managers to evaluate solutions and implement procedures or controls to reduce future injuries.

 

  1. Accomplishing Control

After a hazard has been analyzed, it must be given priority based on its overall gravity. Hazards will then be controlled as any hazard that can be eliminated. All other hazards will be controlled by using engineering or administrative controls or a combination of these as appropriate. The supervisors must correct hazards within their control and ensure the remaining hazards are passed to the plant manager and safety committee for action. The safety committee and plant manager will evaluate and implement controls for the hazards. Administrative and work practice controls for hazards will be either designated as a separate program or part of our procedures.

  1. Safety Procedures

The safety manager will monitor the progress of all abatement procedures and ensure that all affected employees are apprised of the status. The safety manager will coordinate safety communication to vendors and subcontractors working within the plant. The safety manager will provide the company president with the status of implemented controls, needed controls based on hazards, injuries and regulations.

 

Once the workplace safety program is been prepared after thorough analysis, training programs need to be established. Items to train your employees on include your safety program, their rights; compulsory training based on the OSHA regulations. Your written safety program must include an explanation of your training policy and procedures. This should include who will conduct the training, how often training will be completed, a list of the training required for your activities, how the training lesson plan will be maintained, and how the training records will be maintained. Providing training to your staff and employees is a crucial part of having an effective safety and health program.

In fact it may be the most crucial element. After all, a well-trained employee can be a much safer and more productive employee.

Bloodborne Pathogen Forms

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An important component of a bloodborne pathogen program are specific forms.

Forms for a BBP program

  • Receipt of Bloodborne Pathogen Plan: this form is used to document training of the employees, and to document that employees that face potential exposure have been provided with the bloodborne pathogen program. It is required to provide all employees that face potential exposure with a copy of the plan.
  • Hepatitis B Vaccine Record: As part of a bloodborne pathogen program, employees are required to be offered a hepatitis B vaccine. If employees opt to accept the vaccination, the employer should document the process. These records must be handled confidentially.
  • Declination of Hepatitis B vaccine form: As part of a bloodborne pathogen program, employees are required to be offered a hepatitus B vaccine. Some employees may decline this vaccine, and as such, this declination should be documented as proof that employees were offered the vaccine.
  • Exposure Documentation: In the event that an employee becomes exposed to a bodily fluid, it should be documented thoroughly, as quick response is important for the safety of the employee.

All of these forms should be maintained as part of the records associated with a quality bloodborne pathogen program.

Do not store these records in an employee’s personnel file with HR, as these forms are medical documentation, and mixing them with personnel records can create an issue of employee confidentiality. These records should be maintained in a separate area, with controlled access, to maintain employee record confidentiality.

Forms and programs are not the end point of protecting employees. It starts with ensuring that employees use universal precautions and proper PPE to minimize exposure potential. Always keep that at the forefront of all things associated with a bloodborne pathogen program.

 

Download the Receipt of BBP Exposure Control Form below:

 

Download the Bloodborne Pathogen Vaccine Record-keeping Form below:

 

Download the Bloodborne Pathogen Vaccine Declination Record below:

 

Download the Bloodborne Pathogen Exposure Control Form below:

 

 

Workplace Safety Rules

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Workplace Safety Rules are the starting point for a business to provide employees with a safe working environment. Without basic rules for safety, employees may not know of hazards in their workplace which could result in injuries.

These Workplace Safety Rules are a foundation upon which to build a comprehensive safety program, to keep employees safe and reduce company risk exposure.

 

 

 

Among the rules for employers under OSHA, is the responsibility to:

Inform employees of OSHA safety and health standards that apply to their workplace.

While verbal communication may inform employees, a written set of workplace safety rules will be able to be followed easier for employees and managers, and allow for universal training.

 

Under the Occupational Safety and Health Act of 1970 the United States Federal Government established clear rules for workplace safety, one of which is:

Review copies of appropriate standards, rules, regulations, and requirements that the employer should have available at the workplace.

These workplace safety rules should be made available to employees, to not just comply with OSHA regulations, but also to encourage and foster a safe working environment.

Check Out: OSHA Citations Explained

A key function of workplace safety rules is to list off activities and areas that require extra caution, or additional equipment(PPE).

While these workplace safety rules are not 100% inclusive, they can serve as a base to build upon for most workplaces. In the member’s area of EHS Center, there are extensive collections on workplace safety rules, allowing you to select which would be the best fit for your workplace.

Check Out: How to Change the Workplace Safety Culture

Download & view the workplace safety rules

Safety-Health-Rules

 

OSHA Recordability Flowchart

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Not all work environments are the classic 4 walls work environment, many employees work on the road traveling, work from home, or in other special situations, how do these unique work situations effect recordability of injuries?

Work Environments While Traveling

Work in the interest of the employer. Injuries and illnesses that occur while an employee is on travel status are work-related if, at the time of the injury or illness, the employee was engaged in work activities “in the interest of the employer.” Examples of such activities include:

  • Travel to and from customer contacts, conducting job tasks, training, work-related meetings, and entertaining or being entertained to transact, discuss, or promote business. Work-related entertainment includes only entertainment activities being engaged in at the direction of the employer.
  • Similarly, if an employee is injured in an automobile accident while running errands for the company or traveling to make a speech on behalf of the company, the employee is present at the scene as a condition of employment, and any resulting injury would be work-related.

Home Away From Home. When a traveling employee checks into a hotel, motel, or into another temporary residence, for one or more days, he or she establishes a “home away from home.” After he or she checks in, evaluate the employee’s activities for their work-relatedness in the same manner as you evaluate the activities of a non-traveling employee. For example:

  • When the employee checks into the temporary residence, he or she is considered to have left the work environment. When the employee begins work each day, he or she re-enters the work environment.
  • If the employee has established a “home away from home” and is reporting to a fixed worksite each day, you also do not consider injuries or illnesses work-related if they occur while the employee is commuting between the temporary residence and the job location.

Taking a Detour. Injuries or illnesses are not considered work-related if they occur while the employee takes a detour for personal reasons from a reasonably direct route of travel. For example, the employee took a side trip for personal reasons.

OSHA has decided not to limit the recording of occupational injuries and illnesses to those cases that are preventable, fall within the employer’s control, or are covered by the employer’s safety and health program.

The issue is not whether the conditions could have, or should have, been prevented or whether they were controllable, but simply whether they are occupational, i.e., are related to work. This is true regardless of whether the employee is injured while on travel or while present at the employer’s workplace.

  • An employee who is injured in an automobile accident or killed in an airline crash while traveling for the company has clearly experienced a work-related injury that is rightfully included in the OSHA injury and illness records and the Nation’s occupational injury and illness statistics.
Check Out: Conduct Your Own Mock OSHA Inspection

 

OSHA believes that employees who are engaged in management, sales, customer service and similar jobs must often entertain clients, and that doing so is a business activity that requires the employee to work at the direction of the employer while conducting such tasks. If the employee is injured or becomes ill while engaged in such work, the injury or illness is work-related and should be recorded if it meets one or more of the other criteria (death, medical treatment, etc.).

  • Gastroenteritis, for example, is one type of injury or illness that may occur in this situation, but employees are also injured in accidents while transporting clients to business-related events at the direction of the employer or by other events or exposures arising in the work environment.

On the other hand, not all injuries and illnesses sustained in the course of business-related entertainment are reportable. To be recordable, the entertainment activity must be one that the employee engages in at the direction of the employer. Business-related entertainment activities that are undertaken voluntarily by an employee in the exercise of his or her discretion are not covered by the rule.

  • For example, if an employee attending a professional conference at the direction of the employer goes out for an evening of entertainment with friends, some of whom happen to be clients or customers, any injury or illness resulting from the entertainment activities would not be recordable. In this case, the employee was socializing after work, not entertaining at the direction of the employer.
  • Similarly, the fact that an employee joins a private club or organization, perhaps to “network” or make business contacts, does not make any injury that occurs there work-related.

Note that the recordkeeping regulation does not apply to travel outside the United States because the OSH Act applies only to the confines of the United States (29 U.S.C. Section 652(4)) and not to foreign operations. Therefore, the OSHA recordkeeping regulation does not apply to non-U.S. operations, and injuries or illnesses that may occur to a worker traveling outside the United States need not be recorded on the OSHA 300 Log.

Working at Home. Injuries and illnesses occurring while the employee is working for pay or compensation at home should be treated like injuries and illnesses sustained by employees while traveling on business. The relevant question is whether or not the injury or illness is work-related, not whether there is some element of employer control. The mere recording of these injuries and illnesses as work-related cases does not place the employer in the role of ensuring the safety of the home environment.

OSHA has issued a compliance directive (CPL 2-0.125) that clarifies that OSHA will not conduct inspections of home offices and does not hold employers liable for employees’ home offices. The compliance directive also notes that employers required by the recordkeeping rule to keep records will continue to be responsible for keeping such records, regardless of whether the injuries occur in the factory, in a home office, or elsewhere, as long as they are work-related, and meet the recordability criteria.

Work-Relatedness While Telecommuting

When an employee is working on company business in his or her home and reports an injury or illness to his or her employer, and the employee’s work activities caused or contributed to the injury or illness, or significantly aggravated a preexisting injury, the case is considered work-related and must be further evaluated to determine whether it meets the recording criteria. If the injury or illness is related to non-work activities or to the general home environment, the case is not considered work-related. For example:

  • Work-related. If an employee drops a box of work documents and injures his or her foot, the case is considered work-related.
  • Work-related. If an employee’s fingernail is punctured by a needle from a sewing machine used to perform garment work at home, becomes infected and requires medical treatment, the injury is considered work-related.
  • Non-work-related. If an employee is injured because he or she trips on the family dog while rushing to answer a work phone call, the case is not considered work-related.
  • Non-work-related. If an employee working at home is electrocuted because of faulty home wiring, the injury is not considered work-related.

 

Reporting Unclear Injuries and Incidents

If an employee reports a condition but cannot say whether the symptoms first arose during work or during activities off work, the employer must evaluate the employee’s work duties and environment to decide if one or more events or exposures in the work environment caused or contributed to the condition or significantly aggravated a preexisting condition. Below are examples of work-related and non-work-related incidents:

  • Work-related. If the employee is diagnosed with Lyme disease, the employer would determine the case to be work-related if the employee was a groundskeeper with regular exposure to outdoor conditions likely to result in contact with deer ticks.
  • Work-related. If an employee trips while walking across a level factory floor, the resulting injury is considered work-related under the geographic presumption because the precipitating event — the tripping accident — occurred in the workplace. The case is work-related even if the employer cannot determine why the employee tripped, or whether any particular workplace hazard caused the accident to occur.
  • Non-work-related. If an employee has a staph infection, the employer would consider the case not work-related if the infection is an isolated incident – no other employees with whom the newly infected employee had contact at work had been out with a staph infection.
  • Non-work-related. If an employee reports a swollen joint, but cannot say whether it resulted from an event that occurred at work or at home, the employer might determine that the case is not work-related because the employee’s work duties were unlikely to have caused, contributed to, or significantly aggravated such an injury.

View the OSHA Recordability Flowchart below

OSHA Reporting flowchart

Workplace Ergonomics Training

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When we think about our daily routines, many people sit more than they stand throughout their day. We wake up in the morning and we sit to read the newspaper and drink our coffee. We leave for work and we sit in our cars or public transit each way. Once we get to work, most of us sit at a desk for hours at a time, sit to eat our lunches, and then return to work to sit for several more hours. We arrive home to sit and eat our dinner. Following dinner, we either get back on the computer or just watch TV until time to go to sleep. On any given day we could sit for 13-14 hours out of the 24 hours we are given.

According a British Medical Journal study, if you sit for less than 3 hours per day, you could extend your lifespan by up to 2 years. Our health is clearly affected by the number of hours we sit and that could drive up our healthcare costs. The obvious problems are obesity, weakness of muscles, and nerve impingement. The not so obvious are less blood flow, joint stiffness, back pain, neck pain, lower oxygen intake, and problems with your digestive system. Sitting compresses the spine. Even if your office is ergonomically correct, you can still suffer from chronic illnesses.

Check Out: British Medical Journal study; Stand Up for Health.

In the seated position, your torso is compressed causing pressure on your digestive system making it difficult to digest your food properly and intestines to work properly. This can lead to indigestion and bladder pain. Your chest will typically round in as we work on computers to write on the desk. This will reduce your ability to fully expand your lungs. Over time, your body will maintain this position even when standing and your stamina will suffer. Your head will lean forward putting pressure in the mid back increasing your risk of headaches and even ringing in your ears. Finally sitting can shorten the front of your thighs, quads, and increase your risk of low back pain or even knee pain.

Check Out: Here’s What Sitting too Long does to your Body

How can you reverse the risks? Obviously, stand up more any time you can. When on the phone, stand up and talk. If you are in a meeting, if possible stand up. When going to lunch, walk instead of riding, if possible. When you do have to sit, be conscious of how you sit. Keep your back straight and don’t slouch in the chair. Make sure your feet can touch the floor and pull your chair closer to your desk, so your body will be straighter.

Finally, learn how to stretch your body to reverse the posture you have held all day. While sitting at your desk, start by stretching your neck up. Place both hands under your chin and look up. Give yourself a nice little stretch for 2 seconds and release. Repeat the stretch 10 times and do them 3 times per day. Use a door way and stretch your chest to take the pressure off your mid back. Remember to hold the stretch for 2 seconds and repeat 10 times. In the evening you can stretch out your upper quads, the front of your thighs, to take pressure off your low back. This stretch can be done by lying on the floor or your bed. Lay on your side and pull your lower knee up toward your chest. Grab the ankle of the upper leg and pull your heel back to your hip. You should be able to touch your hip. If not, practice this until you can. Hold for 2 seconds and repeat 10 times. Lastly, with the heel of your upper leg against your hip, kick your knee back and you will feel the stretch in the upper thigh. Hold 2 seconds and repeat 10 times.

Check Out: 7 Simple Exercises That Undo the Damage of Sitting

Doing these few things can help relieve your common aches and pains from sitting and allow you to do the activities you enjoy most. I would suggest you do the neck and chest stretches daily. Do the thigh stretches every other day. It may take a little time now, but it can save you a lot of pain later.

Check Out: Safe Lifting & Carrying Training

5 Tips to Getting Companies “invested” into True Ergonomics

  1. Focus on productivity, health, safety and prevention instead of lagging indicators such as injury rates. Reaction to injury leads to poor choices that get rationalized as sensible, but show little benefit. Providing hearing protection only for workers whose hearing is already damaged would seem like foolishness to most of us. Yet it is actually the policy of most companies to consider alternative computer keyboards only for injured workers. This is like closing the barn doors after the horses have run away. Encourage your employer to be proactive about prevention. (You could suggest that your managers read this article.)
  2. Insurance companies who write coverage for Worker’s Compensation need to become proactive in establishing incentives for companies who will invest, not just in any product that says it is ergonomic, but in products that can be demonstrated in scientifically sound studies to show promise, and in paying for independent ergonomists (those who don’t sell the ergonomic products they recommend) to help make sound decisions. It takes a small leap of faith, but any insurer who does this will be at a competitive advantage in the years to come by having a lower claims rate and offering lower premiums.
  3. Standards need to be established. Many ‘ergonomic’ products are designed by marketing or manufacturing people with no clear understanding of the ergonomic problems that need to be solved. New initiatives like the ErgonomicStar™ program, and other evaluation procedures or rating systems need to be developed as buyers’ guides so money isn’t wasted on products that don’t accomplish the buyer’s purpose.
  4. Don’t waste energy on government regulation. Even if the OSHA standards put in place at the end of the Clinton administration had remained, there would not have been sufficient funding to ensure across-the-board compliance. Why start over on a losing proposition? There are very real and tangible benefits over the long run to implementing sound ergonomic choices. If government offices at all levels would invest in the best ergonomic consultants and equipment currently available, it would stimulate the economy and protect a large body of workers all at the same time. The best role of government is to set an example rather than create regulation.
  5. Look for the obvious targets of opportunity within your own company. Computer workstations are certainly not the only only area of concern regarding ergonomics. They do present an easy opportunity in many companies to make a lot of difference, however. Every manufacturing environment can present different challenges. Every computer workstation shares a large number of similarities with most others. Identify those types of opportunities within your business and suggest a task force be formed in the interest of greater productivity, as well as better health and safety.

View & download the Ergonomics Training below:

ergonomics