Stay in OSHA’s Good Graces BY JESSICA VAUGHAN
It feels like everything's changed, but there are several important requirements from OSHA, the Occupational Safety and Health Administration, still in place. Don’t fall afoul of inspectors; that’s a headache you don't need right now.
Guard against the 10 most frequently cited violations on worksites. Prevent falls. This is one of the most common causes of serious injuries on job sites. Keep up with all preventative measures: scaffolding protections, ladders, harnesses, and PPE requirements. Fall protection needs to be in place anytime someone works over four feet off the ground. Part of protecting against falls is training. Make sure you have at least yearly training in fall protection and job hazards. The law specifically states it must be in a language they understand, so if your team is multi-lingual, take that into account. One guy whispering to another guy in the back of the room doesn't count.
Train yearly on hazard communication. All chemicals and their hazards need to be identified to all workers. You must have all chemicals labeled correctly and display the material safety data sheets to each one. Once a year, you must train your workers on hazards they face, how to read chemical labels, and where to find these MSDS sheets.
Evaluate your respirators. Lack of respiratory protection is another common violation. If your workers require protection, inspect it regularly, train on proper use, and make sure you have backups. Since there's such a huge demand for respiratory protection for virus-related safety, knowing you have the supplies for your construction needs is critical.
Ensure PIT or other machinery safety. If you work with Powered Industrial Trucks or other heavy machinery, ensure everyone who uses it is trained or certified to do so. Make sure you have measures in place to “lockout, tag out” a machine, which means to deprive it of power if it is broken, usually by locking the power cord up, so someone can't accidentally injure themselves if they don’t know it’s not working.
You must hold additional safety meetings and training. Most of these citations require specific annual training. Most companies need to touch on safety more often than that to answer the question “Did this employee receive adequate training on the job?” A monthly safety meeting is a good way to discuss opportunities and threats, needed PPE, and other safety measures. Many companies add a safety topic to their monthly TQM meetings or weekly production meetings.
Emergency Action Plan and Fire Prevention Plans are required. All companies are required to have an emergency action plan in place for major hazards workers may encounter during their workday. If you work with anything that can cause a fire, like welding tools, and you have more than ten employees, you need to have a fire prevention plan on the books. It must include a list
of all major fire hazards, proper handling and storage for flammable materials, as well as potential ignition sources. Personal Protective Equipment is an article unto itself, but many major OSHA requirements have to do with what PPE you need to supply, what PPE your employees supply themselves, and what's required for various jobs. Please consult OSHA for the latest information.
Record keeping and reporting are critical. Another general OSHA requirement is to keep and post records of injuries. Any company over ten employees is required to record serious work-related injuries and illnesses. If it only requires first-aid, it doesn't need to be reported. These records must be maintained for five years. Each February through April, you must post a summary of injuries and illnesses recorded the previous year and also provide copies to current and former employees, if requested. You also need to submit these records to OSHA. That’s form 300A and fortunately can be done online as of this year. Any severe injuries must be reported immediately to OSHA. Any fatality must be reported within eight hours and any amputation, loss of an eye, or hospitalization must be reported within 24 hours. Please note, amputation includes the tip of a finger if the bone is nicked.
COVID-19 Please consult OSHA for the latest in this fast-changing pandemic. As of May 26, 2020, a diagnosed case of COVID-19 that's work-related is a recordable illness. To determine workrelated, the guideline is to do a “reasonable” investigation. Privacy concerns prevent “extensive medical inquiries.” OSHA recommends three steps: 1. Ask the employee how they believe they contracted the illness. 2. Ask about their work and out-of-work activities that may have led to the illness (while respecting their privacy and right to decline to give details.) 3. Review the work environment for potential exposure. The illness is likely work-related if a cluster of cases shows up on a team or if they had prolonged exposure to a customer or coworker with the illness. If you can't determine the origin after this good faith investigation, you can treat this as nonrecordable. If you determine it was likely recordable, add it to the usual forms as a respiratory illness. These are the highlights of what it takes to keep workers safe and keep in OSHA’s good graces as of August 2020. As always, please consult OSHA for the most accurate, up-to-date information.
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