Back to Basics, Enforcement and Inspection, Personnel Safety

Best of ’21: Back to Basics

As the year winds down, we’re taking a look this week at some highlights from 2021. Today, we’re highlighting excerpts from some of our favorites from our Back to Basics feature, which made its debut in late July.

August 9: Common Hazards, Frequent Citations

Don’t let all the new, exotic workplace hazards distract you from the basics. The COVID-19 pandemic, historic wildfires in the West, and unprecedented levels of excessive heat may be capturing the headlines and dominating the newscasts right now, but more common hazards in your facility or at your worksites need your attention. Safety and health concerns can seem exotic lately, and these new and emerging hazards have prompted active government responses:

  • Last year, California, Michigan, Oregon, and Virginia established emergency rules for COVID-19, and there’s a new federal emergency COVID-19 rule for health care and healthcare support services; Oregon and Virginia made their rules permanent this year.
  • The California Division of Occupational Safety and Health (Cal/OSHA) has reminded employers repeatedly this summer to comply with the agency’s heat illness prevention and wildfire smoke standards.
  • This summer, Oregon created an emergency temporary standard (ETS) for heat stress while it develops a permanent rule.

However, common workplace hazards—chemicals in the workplace, energy sources or machinery not properly locked out, and unguarded machinery—can present serious worker risks and result in citations and substantial penalties. In fact, the top 10 most frequently cited Occupational Safety and Health Administration (OSHA) standards include the general industry hazard communication, lockout/tagout, and machine guarding standards. Others include the forklift (powered industrial trucks) and respiratory protection standards and five construction industry standards, including eye and face protection and four rules related to working at heights.

August 30: Do You Have a Crisis Communications Plan?

When disaster strikes your business, you need to respond, but you also need to communicate. This includes letting customers know if your business operations are disrupted and how it will affect them, keeping employees and their families apprised of the situation, staying in touch with regulators and local government officials if necessary, and informing any neighbors about what’s going on.

Developing a crisis communications plan will help you respond promptly, accurately, and confidently during and after an emergency. The Federal Emergency Management Agency (FEMA) provides good information about how to put together a crisis communications plan through Ready.gov.

When developing a plan for crisis communications, you need to determine who you will need to reach during an emergency. Each potential audience will need to have information during and after an incident that is tailored for its own needs. In addition, you’ll need to determine what they need for information and who in your business is best able to communicate with that audience.

Here is a list of potential audiences, according to Ready:

  • Customers
  • Survivors affected by the incident and their families
  • Employees and their families
  • News media
  • Community, especially neighbors living near the business
  • Company management, directors, and investors
  • Elected government officials, regulators, and other authorities
  • Suppliers

October 25: ESG Reporting 101

Have you heard of ESG reporting? What is ESG and how does it impact your business? Let’s take a look.

ESG stands for environmental, social, and governance impact. There has been a push for many years for companies to become more transparent on their environmental impact, social impact, and corporate governance.

Consumers, investors, employees, and other stakeholders want to know more about the steps companies are taking in this realm and are even choosing which companies to invest in as a result of this type of information in some cases.

For companies trying to be more transparent about their ESG impacts, the following lists are some of the things included in each of the ESG categories:

Environmental
  • Climate change impacts
  • Greenhouse gas or carbon emissions/carbon footprint
  • Sustainability
  • Air quality impacts
  • Water quality impacts
  • Pollution
  • Energy efficiency
  • Efficiency in resource usage
  • Impacts on deforestation
  • Waste produced (including emissions, electronic waste, material waste, etc.)

Social

  • Equality
  • Diversity
  • Inclusivity
  • Labor standards
  • Human rights (particularly in manufacturing, but also across the entire supply and distribution system)
  • Data protection for both consumers and employees
  • Community involvement and community relations
  • Safety measures
  • Customer satisfaction

Corporate Governance

  • Acceptance of money from lobbyists
  • Political affiliations or contributions
  • Ethics
  • Stability
  • Debt
  • Taxes
  • Bribery
  • Corruption
  • Transparency
  • Compensation fairness
  • Whistleblower programs
  • Competitive behaviors

November 8: Managing Permit-Required Confined Spaces

Are there spaces in your facility or at your worksites where you need to limit access? Are there spaces that contain a hazardous or potentially hazardous atmosphere, material that could engulf those who enter, or physical hazards like exposed live wires or unguarded equipment or machinery? Are there spaces where walls converge inward or floors that slope downward, tapering into smaller areas where someone could become trapped and asphyxiated?

Confined spaces are ones that are not designed to be continuously occupied and can be difficult to exit during an emergency. Confined spaces include underground vaults, tanks, storage bins, manholes, pits, silos, underground utility vaults, pipelines, and commercial grease traps. Workers who enter confined spaces can face life-threatening hazards that include asphyxiation, drowning or engulfment, electrocution, explosions, fall hazards, and flammable or toxic substances. The atmospheric hazards of confined spaces can be debilitating and even fatal.

For example, on February 2, 2007, at the Orleans Hotel and Casino in Las Vegas, Nevada, plumbers and engineers attempting to address a problem with a grease interceptor/trap in the hotel’s sewer system were overcome by hydrogen sulfide (H2S) inhalation. Two workers were pronounced dead on the scene, and another suffered permanent neurological damage.

Workers in confined spaces can be exposed to air contaminants, one of the American Industrial Hygiene Association’s (AIHA) “Focus Four” construction industry health hazards, along with excessive noise, high temperatures, and manual materials handling.

The Occupational Safety and Health Administration (OSHA) has general industry (29 CFR §1910.146), maritime (Part 1915, Subpart B), and construction industry standards (Part 1926, Subpart AA) regarding confined spaces. The standards contain requirements for entry permit programs, warning signs, training, atmospheric testing and ventilation, attendants, entry supervisors, and rescue and emergency services.

Besides manholes, pipelines, and storage bins, confined spaces include commercial grease traps and railcar and trailer tanks. As food waste decays in commercial grease traps, H2S is released.

November 22: Understanding OSHA’s Emphasis Programs

How likely are you to see a compliance safety and health officer (CSHO) show up at your workplace for an Occupational Safety and Health Administration (OSHA) inspection?

The agency has a few methods for allocating its enforcement resources. For example, the agency’s initial response to an employee complaint may be a letter or telephone call rather than an on-site inspection. The agency also evaluates the performance of its area offices using the OSHA Weighting System (OWS).

The OWS assigns a number of enforcement units (EU) for different types of inspections. The agency assigns the highest number of EUs for inspections involving criminal or significant cases: seven EUs. It awards five EUs for inspections for process safety management (PSM) of highly hazardous chemicals and for inspections following a fatality or catastrophe.

The weighting system awards three EUs for inspections for the agency’s “focus four” hazards: caught-in or between, electrical, fall, and struck-by hazards. OSHA assigns two EUs for inspections for certain hazards, including ergonomics (musculoskeletal disorders), permit-required confined spaces hazards, occupational noise, site-specific targeting (based on employer-submitted injury and illness data), and workplace violence. All other inspections receive one EU.

OSHA also uses national, regional, and local emphasis programs (NEPs, REPs, and LEPs) to focus its enforcement resources on particular hazards or high-hazard industries. The agency’s newest NEP is an emphasis program for COVID-19 launched March 12 and revised July 7, with minor changes made August 30.

Area offices begin their NEP enforcement efforts with site selection, generating a master list of establishments for possible inspection. Agency directives for hazard-specific NEPs typically include a list of targeted industries.

Primary targets of the COVID-19 NEP include ambulance and home healthcare services; correctional facilities; healthcare and long-term care facilities; hospitals and physicians’ offices; and department stores, groceries, supermarkets, restaurants, meatpacking and poultry processing facilities, and warehouses and storage facilities.