“How Six Sigma Can Improve Your Safety Performance”

Six Sigma is the evolution of statistical quality improvement processes that have been used extensively to improve manufacturing and other process-related industries. How good is Six Sigma? It is a statistical measure of variability or standard deviation. The Six Sigma process calculates to 3.4 defects per million opportunities. Needless to say, that is near perfect execution of a process. Although not often used in the safety arena to full potential, Six Sigma tools can help produce significant and sustainable improvements in safety performance, injury reduction and associated pain.

Total Quality Management
To gain an understanding of Six Sigma, it is helpful to have some historical knowledge of the original statistical improvement tools or the Total Quality Management (TQM) concept. Original quality pioneers such as Walter A. Shewhart, W. Edwards Deming and Kaoru Ishikawa worked with Japanese manufacturing companies in the 1950s to significantly improve the quality of products. The original concept, TQM, has been defined as a management philosophy that produces continuous improvement of products and processes.

One of the most powerful tools that came out of TQM is the Plan/Do/Check/Act (PDCA) continuous improvement wheel. In this concept, plan to do something, do it, check for the effectiveness and, if it’s not performing as planned, act upon that by making changes. Then, on an ongoing basis, “turn the wheel” or plan, do, check and act again. This produces continuous improvement. The concept of PDCA is still just as powerful today as it was when first proposed.

A safety application of PDCA at both a strategic and an operational level is shown in the following diagram.

Six Sigma – Quality on Steroids
Although TQM provided significant quality improvement for users, there were still opportunities to improve the concept. That is why Six Sigma came to be. The Six Sigma management concept was originally developed by Motorola USA in 1986. In 1995, Six Sigma became more visible when Jack Welch made it a focus of business strategy at General Electric. Today, the Six Sigma concept has become the standard process for quality improvement in many industries. The objective of Six Sigma is to improve the quality of processes by identifying and removing the causes of defects. In safety, these process defects can be unsafe behaviors, incorrect procedures or equipment failures, all of which can result in injury.

A Formal Improvement Process
The original TQM used a number of statistical tools, but there was no formal process for integrating all of these tools and developing a complete process improvement solution. Six Sigma uses DMAIC, a clearly defined five-step improvement process that consists of the following:

Define
• Identify the process and define the scope of the project.
• Clearly identify the inputs and outputs of the process.
Measure
• Evaluate the measurement systems and resulting data.
Analyze
• Determine cause-and-effect relationships.
• Identify the root cause of the defects.
Improve
• Develop and implement improvements.
• Test effectiveness of improvements.
Control
• Implement a system to sustain the improvements.

Define Stage – What Are We Working On?
In the Define Stage, clearly identify the scope of the project or what it is that needs work. Also determine what the target performance should be. It will be necessary to understand what process is failing and resulting in what kinds of injuries.

One of the Six Sigma tools that is typically used in the Define Stage of the DMAIC method is the SIPOC. This tool is typically used in the manufacturing process where it is important to identify the suppliers, inputs, processes, outputs and customers. The diagram below shows the use of this tool in a very simplified version of the line construction work process.

By applying this tool to safety, one can see how some of the suppliers and inputs – which are normally not considered to have an impact on safety – can indeed have impact. For example, the SIPOC tool helps demonstrate that the people who design the project, design the standards or determine the specifications of the materials should consider safety implications when doing design work.

Measure Stage – Is the Data Correct and What is it Telling You?
In this stage, the data being used is extensively assessed and interpreted. First, ensure that the data is valid and accurately measuring the desired subject. This can often be an issue when analyzing behavior observations. Behaviors such as use of safety glasses are easy to document and address. More controversial items, such as adequate cover-up, are not always documented and addressed. As a result, when combining all of the observation data, since some of it is not valid, the overall observation results may not reflect actual performance.

Often in this phase, charts and graphs will provide directional information stating that performance has improved or degraded, but this may be misleading. Many charts and graphs reflect averages, and important information can be lost in averages. There are a number of tools used in this stage to identify whether it is truly statistically improving or if it just looks better on a chart. Tools that are used in the Measure Stage include histograms, Paretos and process capability.

Analyze Stage – Identifying the Root Cause
In the Analyze Stage, use the data collected and validated in the Measure Stage to determine the root causes of the process defects or injuries. A few of the tools that are used in the Analyze Stage include Cause & Effect Fishbone Diagram, Five Whys and Correlation Testing. The fishbone diagram is familiar to most people because of its extensive use in identifying the root cause of accidents. The importance of this stage cannot be understated because if the root cause is not validated, the corrective measures – tied to that root cause – will not provide the desired results.

Improve Stage – The Corrective Measures
After completing the Analyze Stage, potential corrective measures often become evident. During the Improve Stage, it is most important to test the potential corrective measures to see if they will address the root cause. In the safety arena, that does not mean to wait and see if another injury occurs. The root cause needs to be prevented, not the injury. In the case of eye injuries, the identified root cause may be the employees not wearing safety glasses or employees wearing improperly fitting safety glasses. In this case, the Improve Stage would include a process for fitting glasses and providing them to employees. In this stage, pilot trials or other forms of testing effectiveness can be used.

Control Stage – Make it Sustainable
The primary objective of the Control Stage is to monitor results and ensure that the expected improvements are being achieved and sustained. One of the biggest challenges, especially when implementing safety improvements, is ensuring that those improvements will be sustained. Far too often, events or injuries occur and upon analysis, corrective measures were recommended and implemented several years ago for a previous event, but are not working or are not in place for various reasons.

One reason for this could be that a good process was not in place to sustain corrective measures. Actual examples include:
• A safety improvement memo was sent out, but there was no follow-up to ensure that people implemented it.
• A new, safer tool was specified and purchased, but the older, unsafe tool is still found throughout the system. In the case of safety glasses, the employees are no longer using the ones they were fitted with.

Another reason may be that the original corrective measure did not correct the original root cause. This should have been identified when testing the effectiveness of the corrective measure in the Improve Stage.

Of all of the stages in the DMAIC process, I feel the Control Stage is the most important and most overlooked.

Conclusion
This represents only a small example of the tools and methods that are typically used in the DMAIC process. There is no question that use of Six Sigma and the DMAIC process requires trained facilitators to assist in providing desired results. The results, though, can be substantial if the process is properly followed. If an organization has access to someone with these skills, they can be very helpful in identifying the root causes of injuries and developing sustainable corrective measures. Appropriately utilized, Six Sigma can be an important component in creating an injury-free workplace.

About the Author: Ted Granger, CSSBB, CUSP, is an independent safety consultant affiliated with the Institute for Safety in Powerline Construction. He provides training, lectures and safety consulting services. Prior to his current role, Granger served in various managerial positions during his 37-year career at Florida Power & Light Company. These included T&D operations, human resources, logistics and safety, where he utilized his Six Sigma Black Belt certification. He can be contacted at tedjgranger.

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OSHA’s Top Citation: Fall Protection: New Gear, New Regulations and New Standards – What Every EHS Pro Should Know!

OSHA’s Top Citation:  Fall Protection: New Gear, New Regulations and New Standards – What Every EHS Pro Should Know!

Excellent read on LeadingEHS.

LeadingEHS

By Guest Blogger: Allyson Clark

Photo Credit: Western Area Power

Plan, Provide and Trainis OSHA’s slogan for fall protection – sounds easy enough, Right? Well except that for the last 10 years, fall protection has been the number one issued citation by OSHA for construction and general industry. In fact, falls rank as the number one cause of work related injury and deaths.   So what regulation, product performance standards and gear should EHS Professional be in the know of? – Well Keep Reading!

New Regulation for General Industry:

On Jan 17th, 2017, OSHA’s 29 CFR 1910.21-.30 Walking-Working Surfaces (WWS) Rule specific to slip, trip, and fall hazards  became enforceable. Slips trips and falls are proportionally high for general industry accidents and for the construction industry.  This final rule adds training, inspections, as well as updates for general industry standards and adds requirements for personal fall protection standards…

View original post 1,393 more words

“Employer In Fatal Boston Trench Collapse Did Not Provide Safety Training & Basic Safeguards For Employees, OSHA Finds”

Atlantic Drain Service Co. Inc. cited for 18 violations

BOSTON – Robert Higgins and Kelvin Mattocks died on Oct. 21, 2016, in Boston, when the approximately 12-foot deep trench in which they were working collapsed, breaking an adjacent fire hydrant supply line and filling the trench with water in a matter of seconds.

An investigation by the U.S. Department of Labor’s Occupational Safety and Health Administration found that their employer, Atlantic Drain Service Co. Inc., failed to provide basic safeguards against collapse and did not train its employees – including Higgins and Mattocks – to recognize and avoid cave-in and other hazards.

“The deaths of these two men could have and should have been prevented. Their employer, which previously had been cited by OSHA for the same hazardous conditions, knew what safeguards were needed to protect its employees but chose to ignore that responsibility,” said Galen Blanton, OSHA’s New England regional administrator.

OSHA’s inspection determined that Atlantic Drain and owner Kevin Otto, who oversaw the work on the day of the fatalities, did not:

–       Install a support system to protect employees in an approximately 12-foot deep trench from a cave-in and prevent the adjacent fire hydrant from collapsing.

–       Remove employees from the hazardous conditions in the trench.

–       Train the workers in how to identify and address hazards associated with trenching and excavation work.

–       Provide a ladder at all times so employees could exit the trench.

–       Support structures next to the trench that posed overhead hazards.

–       Provide employees with hardhats and eye protection.

As a result, OSHA has cited Atlantic Drain for a total of 18 willful, repeat, serious and other-than-serious violations of workplace safety standards and is proposing $1,475,813 in penalties for those violations. OSHA cited Atlantic Drain trenching worksites for similar hazards in 2007 and 2012. The full citations can be viewed here.

In February, a Suffolk County grand jury indicted Atlantic Drain and company owner, Kevin Otto, on two counts each of manslaughter and other charges in connection with the deaths. OSHA and the department’s Regional Office of the Solicitor worked with the department’s Office of the Inspector General, the Boston Police Department’s Homicide Unit and the Suffolk County District Attorney’s Office during the course of this investigation.

Atlantic Drain has 15 working days from receipt of the citations and proposed penalties to meet with OSHA’s area director, and to contest the citations before the independent Occupational Safety and Health Review Commission, if it chooses to do so.

The walls of an unprotected trench can collapse suddenly and with great force, trapping and engulfing workers before they have a chance to react or escape. Protection against cave-in hazards may be provided through shoring of the trench walls, sloping the soil, or by using a protective trench box. Employers must ensure that workers enter trenches only after adequate protections are in place to address cave-in hazards. More information about protecting employees in trenches and excavations can be found here and here.

“We want to emphasize to all employers that trenching hazards can have catastrophic consequences if they are not addressed effectively before employees enter a trench,” said Blanton.

To ask questions, obtain compliance assistance, file a complaint, or report amputations, eye loss, workplace hospitalizations, fatalities or situations posing imminent danger to workers, call OSHA’s toll-free hotline at 800-321-OSHA (6742) or the nearest OSHA Area Office.

Under the Occupational Safety and Health Act of 1970, employers are responsible for providing safe and healthful working conditions for their employees. OSHA’s role is to ensure these conditions for America’s working men and women by setting and enforcing standards, and providing training, education and assistance. For more information, visit http://www.osha.gov.

# # #

Media Contacts:

Ted Fitzgerald, 617-565-2075, fitzgerald.edmund@dol.gov
James C. Lally, 617-565-2074, lally.james.c@dol.gov

Release Number:  17-413-BOS

Here Is WHY Trenching Safety Training IS Required!

“OSHA National Safety Stand-Down To Prevent Falls In Construction – May 8-12, 2017” #StandDown4Safety

Fatalities caused by falls from elevation continue to be a leading cause of death for construction employees, accounting for 350 of the 937 construction fatalities recorded in 2015 (BLS data). Those deaths were preventable. The National Fall Prevention Stand-Down raises fall hazard awareness across the country in an effort to stop fall fatalities and injuries.


What is a Safety Stand-Down?

A Safety Stand-Down is a voluntary event for employers to talk directly to employees about safety. Any workplace can hold a stand-down by taking a break to focus on “Fall Hazards” and reinforcing the importance of “Fall Prevention”. It’s an opportunity for employers to have a conversation with employees about hazards, protective methods, and the company’s safety policies and goals. It can also be an opportunity for employees to talk to management about fall hazards they see.

Who Can Participate?

Anyone who wants to prevent falls in the workplace can participate in the Stand-Down. In past years, participants included commercial construction companies of all sizes, residential construction contractors, sub- and independent contractors, highway construction companies, general industry employers, the U.S. Military, other government participants, unions, employer’s trade associations, institutes, employee interest organizations, and safety equipment manufacturers.

Partners

OSHA is partnering with key groups to assist with this effort, including the National Institute for Occupational Safety and Health (NIOSH), the National Occupational Research Agenda (NORA), OSHA approved State Plans, State consultation programs, the Center for Construction Research and Training (CPWR), the American Society of Safety Engineers (ASSE), the National Safety Council, the National Construction Safety Executives (NCSE), the U.S. Air Force, and the OSHA Training Institute (OTI) Education Centers.

How to Conduct a Safety Stand-Down and FAQ’s

Companies can conduct a Safety Stand-Down by taking a break to have a toolbox talk or another safety activity such as conducting safety equipment inspections, developing rescue plans, or discussing job specific hazards. Managers are encouraged to plan a stand-down that works best for their workplace anytime during the May 8-12, 2017. SeeSuggestions to Prepare for a Successful “Stand-Down” and Highlights from the Past Stand-Downs. OSHA also hosts an Events page with events that are free and open to the public to help employers and employees find events in your area.

Certificate of Participation

Employers will be able to provide feedback about their Stand-Down and download a Certificate of Participation following the Stand-Down.

Share Your Story With Us

If you want to share information with OSHA on your Safety Stand-Down, Fall Prevention Programs or suggestions on how we can improve future initiatives like this, please send your email to oshastanddown@dol.gov. Also share your Stand-Down story on social media, with the hashtag: #StandDown4Safety.

If you plan to host a free event that is open to the public, see OSHA’s Events page to submit the event details and to contact your Regional Stand-Down Coordinator.

Additional Resources:

OSHA’s Falls Prevention Campaign Page (en español)

Fall Prevention Training Guide – A Lesson Plan for Employers (PDF) (EPUB | MOBI). Spanish (PDF) (EPUB | MOBI).

Fall Prevention Publications Webpage contains fall prevention materials in English and Spanish.

Ladder Safety Guidance

Scaffolding

  • Ladder Jack Scaffolds Fact Sheet (PDF)
  • Narrow Frame Scaffolds Fact Sheet (HTML PDF)
  • Tube and Coupler Scaffolds – Erection and Use Fact Sheet (PDF)
  • Tube and Coupler Scaffolds – Planning and Design Fact Sheet (PDF)
  • Scaffolding Booklet (HTML PDF)
  • OSHA Scaffold eTool
Stand-Down Partner Materials

Outreach Training Materials

Fall Safety Videos

Additional Educational Materials

“Donnie’s Accident” – “I Was Too Good To Need My Safety Gear”

Donnie's Accident

On August 12, 2004, I was connecting large electrical generator in preparation for Hurricane Charlie. The meter I was using failed and blew carbon into the gear and created an electrical arc which resulted in an arc blast. The electrical equipment shown in the video is the actual equipment after the explosion when my co-workers were there trying to restore power and make temporary repairs. I ended up with full thickness, 3rd degree burns to both hands and arms along with 2nd and 3rd degree burns to my neck and face. I was in a coma for two months due to numerous complications from infections and medications.

During this time my family endured 4 hurricanes and the possibility of losing me. I am a husband, a father, a son and a brother, not just an electrician. It took almost two years of healing, surgeries and rehabilitation to only be able to return to work to an office job. I can’t use my hands and arms as well as I once could… BUT I’M ALIVE! There are those who have had similar accidents and fared much, much worse. I use my experiences to caution others.

All of this could have been avoided if I had been wearing my personal protection equipment (PPE), which I was fully trained to do and was in my work van. I would have probably only gone to the hospital for a checkup! I am asking you to protect yourself by following your safety procedures. Accidents at work not only affect you; think about the effects on your family, your friends, your finances, your company, your co-workers… your entire world.

Most of these injuries can be prevented by following the safety rules your company probably have in place. Most of these rules were put in place because of accidents like mine. Be safe, wear your PPE; not for fear of fines, penalties or getting fired. Be safe for yourself and for all the people close to you. I got a second chance… You might not!!! !!!

You can read a more in depth account of my accident on the “Full Story” page.

OSHA Arc Flash Safety Information
Understanding “Arc Flash” – Occupational Safety and Health …

https://www.osha.gov/…/arc_flash_han…

Occupational Safety and Health Administration

Employees must follow the requirements of the Arc Flash Hazard label by wearing the proper personal protective equipment (PPE), use of insulated tools and other safety related precautions. This includes not working on or near the circuit unless you are a “qualified” worker.

“OSHA Delays Enforcing Crystalline Silica Standard in Construction” #ConstructionSafety

OSHA is delaying enforcement of the crystalline silica standard that applies to the construction industry to conduct additional outreach and provide educational materials and guidance for employers. Originally scheduled to begin June 23, 2017, enforcement will now begin Sept. 23, 2017.

OSHA expects employers in the construction industry to continue to take steps either to come into compliance with the new permissible exposure limit or to implement specific dust controls for certain operations as provided in Table 1 of the standard. Construction employers should also continue to prepare to implement the standard’s other requirements, including exposure assessment, medical surveillance, and employee training.

“What is Your Company’s EMR? – Experience Modification Rate?” #WorkersCompensation

What Is an EMR Rate?

Experience Modification Rate (EMR) has a strong impact on your business. It is a number used by insurance companies to gauge both past cost of injuries and future chances of risk. The lower the EMR of your business, the lower your worker compensation insurance premiums will be. An EMR of 1.0 is considered the industry average.

If your business has an EMR greater than 1.0 the reasons are simple. There has been a worker compensation claim that your insurance provider has paid. To mitigate the insurance company’s risk, they raise your worker compensation premiums. The bad news is this increased EMR sticks with you for 3 years.

Want to know how Experience Modification Rates are calculated?

The base premium is calculated by dividing a company’s payroll in a given job classification by 100, and then by a ‘class rate’ determined by the National Council on Compensation Insurance (NCCI) that reflects the inherent risk in that job classification. For example, structural ironworkers have an inherently higher risk of injury than receptionists, so their class rate is significantly higher.

A comparison is made of past claims history to those of similar companies in your industry. If you’ve had a higher-than-normal rate of injuries in the past, it is reasonable to assume that your rate will continue to be higher in the future. Insurers examine your history for the three full years ending one year before your current policy expires. For example, if you’re getting a quote for coverage that expires on January 5, 2008, the retro plan will look at 2004, 2005 and 2006.

NCCI has developed a complicated formula that considers the ratio between expected losses in your industry and what your company actually incurred, as well as both the frequency of losses and the severity of those losses. A company with one big loss is going to be ‘penalized’ less severely than a company with many smaller losses because having many small losses is seen as a sign that you’ll face larger ones in the future.

The result of that formula is your EMR, which is then multiplied against the manual premium rate to determine your actual premium (before any special discounts or credits from your insurer). Essentially, if your EMR is higher than 1.00, your premium will be higher than average; if it’s 0.99 or lower, your premium will be less.

How does a high EMR affect costs?

An EMR of 1.2 would mean that insurance premiums could be as high as 20% more than a company with an EMR of 1.0. That 20% difference must be passed on to clients in the form of increased bids for work. A company with a lower EMR has a competitive advantage because they pay less for insurance

How do I lower EMR?

The good news is that EMR can be lowered. If you need help in putting an effective safety program in place that eliminates hazards and prevents injuries contact us at Benton Safety Consultants.  Remember, No injuries equal no claims.

In the real world, injuries will happen, but the response can help keep EMR from increasing as much as it could without proper management. Having a plan to manage injuries and workers compensation claims is a must to get control of the EMR.

Reducing EMR gives you an edge over your competition when bidding out work and save money. Construction general contractors and owners are realizing the benefits of low EMR numbers and often prequalify companies before they even look at bids. It would be unfortunate to lose business and money because of high EMR.

“Top 5 OSHA Issues to Track in 2017″ Webinar” @OSHA_Guy

Presented by Eric J. Conn, Kate McMahon, Amanda Strainis-Walker, Micah Smith, Lindsay DiSalvo and Dan Deacon

The ball has dropped, the confetti has been swept out of Times Square, and 2016 is in the books.  It’s time to look back at the year and take stock of what we learned from and about OSHA over the past year.  More importantly, the question on everyone’s mind (well, maybe just ours), is what can we expect from OSHA in the first year of the Trump Administration?  In this webinar event, attorneys from the national OSHA Practice Group at Conn Maciel Carey will review OSHA enforcement, rulemaking, and other developments from 2016, and will discuss the Top 5 OSHA Issues employers should monitor and prepare for in the New Year.

Participants will learn the following:

  • 2016 OSHA enforcement data and trends and rulemaking achievements

  • Important OSHA developments from 2016

  • Major OSHA rulemaking and other developments to expect during the Trump Administration’s inaugural year

  • Other significant OSHA policy issues to watch out for in the New Year

Click here for a complete list of Conn Maciel Carey OSHA Webinars for 2017

safety, safety training

“PeopleWork: 3 Ways to Get Commitment to Safety” @KevinBurnsBGi

Published on Apr 3, 2017

http://www.kevburns.com/peoplework

One of the most pursued issues by safety people is getting employees to commit to the safety program. On this episode, 3 ways to get a better commitment to safety.

Employee commitment to safety is important. And as well-meaning as the efforts of your senior management may be to safety, without the employee commitment to safety, any safety initiative is going to fall flat. You need a commitment to safety from especially the front line employees.

Here’s why. The majority of safety incidents happen at the front line. The largest numbers of workers are at the front line. The most amount of activity is at the front line. And so it’s at the front line where the focus on safety needs to take place. It is at the front line where safety leadership is needed most.

There are three areas where you can work to build employee commitment to safety.

Kevin Burns is a management consultant, safety speaker and author of “PeopleWork: The Human Touch in Workplace Safety.” He is an expert in how to engage people in safety and believes that the best place to work is always the safest place to work. Kevin helps organizations integrate caring for and valuing employees through their safety programs.

“Reminder: Are You In Compliance With OSHA’s New Construction Confined Space Standard?”

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Most employers in the construction industry already know that OSHA issued a new confined space standard for construction that became effective on August 3, 2015. Companies with employees who enter confined spaces at construction sites must be sure to understand the new regulation and adjust their processes in order to remain in compliance. Although the new standard has been in effect for six months, this blog provides a reminder on some of the key provisions of which employers should be aware.

As background, OSHA used to just have a confined space standard for general industry employers (29 CFR 1910.146). However, in recognition that construction sites often host multiple employers and are continually changing, with the number and nature of confined spaces changing as work progresses, OSHA promulgated a new standard, available at 29 CFR Subpart AA 1926.1200, tailored to the unique characteristics of construction sites.

While the general industry standard and the construction standard have many similarities, some key differences are:

The construction standard requires coordination when there are multiple employers at the worksite. Specifically, the construction standard imposes duties on three types of employers because of the recognition that different workers may perform different activities in the same space, which can result in hidden dangers:

Entry employers. This is defined as an employer who decides that an employee it directs will enter a permit space. Entry employers have a duty to inform controlling contractors (defined below) of any hazards encountered in a permit space. Entry employers also have to develop safe entry procedures.

Host employers. This is defined as the employer who owns or manages the property where the construction work is taking place. If the host employer has information about permit space hazards, it must share that information with the controlling contractor (defined below) and then the controlling contractor is responsible for sharing that information with the entry employers.

Controlling contractor. This is defined as the employer with overall responsibility for construction at the worksite. The controlling contractor is responsible for coordinating entry operations when there is more than one entry employer. Controlling contractors must provide any information they have about any permit space hazards to all entry employers.

The controlling contractor is also responsible for coordinating work in and around confined spaces so that no contractor working at the site will create a hazard inside the confined space. After the entry employer performs entry operations, the controlling contractor must debrief the entry employer to gather information that the controlling contractor then must share with the host employer and other contractors who enter the space later.

Continuous atmospheric monitoring is required under the construction standard “whenever possible.” In contrast, the general industry standard merely encourages continuous atmospheric monitoring where possible and only requires periodic monitoring as necessary.

The construction standard requires that a “competent person” evaluate the work site and identify confined spaces including permit-required confined spaces.

Notably, the general industry standard does not require that a “competent person” complete this task. A “competent person” is defined under the new standard as someone who is capable of identifying existing and predictable hazards associated with working conditions, including, of course, whether a workspace is permit-required.

Employers who perform construction-related activities need to make sure they understand the requirements of the new confined space construction standard. For more information, download : Confined Space in Construction: OSHA 29 CFR Subpart AA 1926.1200 here: https://www.osha.gov/confinedspaces/1926_subpart_aa.pdf or consult with your Seyfarth attorney.

Source: Seyfarth, Shaw : Evironmental Safety Update / Law Blog

http://www.environmentalsafetyupdate.com/osha-compliance/are-you-in-compliance-with-oshas-new-confined-space-standard-for-the-construction-industry/

 

 

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