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“Confined Spaces – “What To Do Before You Enter” #ConfinedSpace #StayAlive

80% of fatalities happened in locations that had been previously entered by the same person who later died.

Each year, an average of 92 fatalities occurs from confined spaces locations due to asphyxiation, acute or chronic poisoning, or impairment.

But, what is a “confined space?”

A confined space is a space that:

  1. Is large enough and so arranged that an employee can bodily enter it;
  2. Has limited or restricted means for entry and exit;
  3. Is not designed for continuous employee occupancy.

Examples of confined spaces include:

  • Sewers
  • Storm drains
  • Water mains
  • Pits
  • And many more

Permit-required confined spaces include:

  • Contains or has the potential to contain a hazardous atmosphere
  • Contains a material with the potential to engulf someone who enters the space
  • Has an internal configuration that might cause an entrant to be trapped or asphyxiated
  • Contains any other recognized serious safety or health hazards

Here are some steps you can take to help ensure the safety of your workers.

1. Is This a Confined Space?

2. Is the Atmosphere Safe?

Testing must be done in several levels of the space because specific hazardous gases react differently to the rest of the atmosphere. Why? Hydrogen Sulfide is slightly heavier than air, while other dangerous gases such as methane may be lighter than air and rise to the top. Only by testing all levels of the tank you are about to enter can you be reasonably sure the atmosphere is acceptable for breathing.

3. How Do I Exit Safely?

Before you start thinking about entering, first make sure you can get back out. Meaning you have a rescue plan and are working with someone else who can provide for rescue.

If you don’t have a rescue plan, don’t enter.

4. How Do I Enter Safely?

Does the job or project require special equipment to get in and out of the space, such as a body harness?

5. Will The Atmosphere Stay Safe?

Once you’ve established that the atmosphere is safe to enter, you next have to know that it will stay that way. Which leads us to our next point.

6. Does the Space Need Ventilating?

If the air is found to be unsafe within the confined space because of existing fumes or gas, or if the work being done will contribute to a degradation of the breathable atmosphere, the space needs to be ventilated and you need to be using an air monitoring device.

7. Equipment Check

It’s important to check your equipment before beginning any sort of confined space entry work. Has your gas detector been bump-tested or recently calibrated? Have all lanyards and lifelines been checked for wear? Have harnesses been properly stored?

8. Lighting

Confined spaces are often cramped, dark and awkwardly shaped. A well-lit worksite helps workers avoid injury.

9. Communication

Radios are a great way to stay connected with workers, but also keep in mind that, nothing can replace having a standby worker positioned at the exit when workers are in a confined space. This tried and true system allows the outside person not only to communicate with workers within the space but also to call for help if it is needed.

10. Are you and your crew up to the task?

Can each team member be relied upon in a life-threatening situation?

This list is not meant to be comprehensive, check the OSHA Standards for that.

Stop to consider the dangers before you enter, and be mindful that confined spaces can become dangerous after you have entered.

Source: Vivid Learning Systems – Safety Toolbox

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“OSHA 300 Logs: Four Common Mistakes Employers Make”

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This is your annual reminder about the important annual February 1st deadline to prepare, certify and post your OSHA 300A Annual Summary of workplace injuries and illnesses, for all U.S. employers, except those with ten or fewer employees or those whose NAICS code is for the set of low hazard industries exempted from OSHA’s injury and illness recordkeeping requirements, such as dental offices, advertising services, and car dealers (see the exempted industries at Appendix A to Subpart B of Part 1904).

Specifically, by February 1st every year, employers must:

  • Review their OSHA 300 Log(s);
  • Verify the entries on the 300 Log are complete and accurate;
  • Correct any deficiencies identified on the 300 Log;
  • Use the injury data from the 300 Log to calculate an annual summary of injuries and illnesses and complete the 300A Annual Summary Form; and
  • Certify the accuracy of the 300 Log and the 300A Summary Form.

The Form 300A is a summation of the workplace injuries and illnesses recorded on the OSHA 300 Log during the previous calendar year, as well as the total hours worked that year by all employees covered by the particular OSHA 300 Log.

Four Common 300A Mistakes that Employers Make

We see employers make the following four common mistakes related to this annual injury and illness Recordkeeping duty:

  1. Not having a management representative with high enough status within the company “certify” the 300A;
  2. Not posting a 300A for years in which there were no recordable injuries;
  3. Not maintaining a copy of the certified version of the 300A form and
  4. Not updating prior years’ 300 Logs based on newly discovered information about previously unrecorded injuries or changes to injuries that were previously recorded.

Certifying the 300 Log and 300A Annual Summary

The 300 Log and the 300A Annual Summary Form are required to be “certified” by a “company executive.” Specifically what the company executives are certifying is that they:

  1. Personally examined the 300A Annual Summary Form;
  2. Personally examined the OSHA 300 Log from which the 300A Annual Summary was developed; and
  3. Reasonably believe, based on their knowledge of their companies’ recordkeeping processes that the 300A Annual Summary Form is correct and complete.

A common mistake employers make is to have a management representative sign the 300A Form who is not at a senior enough level in the company to constitute a “company executive.”  As set forth in 1904.32(b)(4), company executives include only the following individuals:

  • An owner of the company (only if the company is a sole proprietorship or partnership);
  • An officer of the corporation;
  • The highest ranking company official working at the establishment; or
  • The immediate supervisor of the highest ranking company official working at the establishment.

Posting the 300A Annual Summary

After certifying the 300A, OSHA’s Recordkeeping regulations require employers to post the certified copy of the 300A Summary Form in the location at the workplace where employee notices are usually posted.  The 300A must remain posted there for three months, through April 30th.

Another common mistake employers make is to not prepare or post a 300A Form in those years during which there were no recordable injuries or illnesses at the establishment.  Even when there have been no recordable injuries, OSHA regulations still require employers to complete the 300A form, entering zeroes into each column total, and to post the 300A just the same.

Maintaining the 300A for Five Years

After the certified 300A Annual Summaries have been posted between February 1st and April 30th, employers may take down the 300A Form, but must maintain for five years following the end of the prior calendar year, at the facility covered by the form or at a central location, a copy of:

  • The underlying OSHA 300 Log;
  • The certified 300A Annual Summary Form; and
  • Any corresponding 301 Incident Report forms.

In this technology era, many employers have transitioned to using electronic systems to prepare and store injury and illness recordkeeping forms. As a result, another common mistake employers make is to keep only the electronic version of the 300A, and not the version that was printed, “certified” typically by a handwritten signature and posted at the facility. Accordingly, those employers have no effective way to demonstrate to OSHA during an inspection or enforcement action that the 300A had been certified.

Finally, another common mistake employers make is to put away old 300 Logs and never look back, even if new information comes to light about injuries recorded on those logs.  However, OSHA’s Recordkeeping regulations require employers during the five-year retention period to update OSHA 300 Logs with newly discovered recordable injuries or illnesses, or to correct previously recorded injuries and illnesses to reflect changes that have occurred in the classification or other details.  This requirement applies only to the 300 Logs; i.e., technically there is no duty to update 300A Forms or OSHA 301 Incident Reports.

Source: JD Supra – Eric Conn

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“What Should You Do When OSHA Shows Up At Your Door” #OSHA #Inspection

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1/27/2017 by Krista Sterken  | Foley & Lardner LLP

You arrive at work bright and early, only to find that someone beat you there — OSHA is waiting to perform an inspection. Now what? Many employers think they have little say in what happens next. Actually, employers have many choices to make, starting as soon as OSHA arrives.

The first thing step is simply bringing the compliance officer to a conference room or other appropriate location. You should select a location that is private and located close to the entrance, so you do not have to walk the compliance officer through any more of your facility than necessary. If the compliance officer happens to see something that may be a violation, this could provide the basis for a citation and/or expansion of the inspection.

Next, it is time to collect some information — you need to understand why OSHA is there. There are three main types of inspections: complaint inspections (conducted in response to a safety complaint), report inspections (conducted in response to a report of an employee death, injury, or illness), and program inspections (conducted under one of OSHA’s emphasis programs, which focus on particular industries or hazards). In some cases, a previous citation might provide the basis for a follow-up inspection.

You also need to know what OSHA intends to do. The inspection should be tailored to the reason for the visit. For example, a complaint inspection should be limited to areas related to the complaint. Program inspections are dictated by the focus of the program — you can obtain more information from OSHA’s website. All inspections should follow OSHA’s Field Operations Manual.

Finally, you must decide whether to agree to OSHA’s inspection plan. If OSHA identified a legitimate basis for the inspection and an appropriate inspection plan, then you might decide to allow the inspection to begin. However, if you have concerns, you have the right to refuse entry and require OSHA to return with a warrant (unless there is an imminent danger, in which case OSHA must be permitted immediate entry). If you require a warrant, OSHA will have to persuade a judge that its intended inspection is appropriate.

Employers are often nervous about requiring a warrant. However, you have the right to do so. OSHA understands this, and is not permitted to retaliate against you in any way. Requiring a warrant can be an effective way to impose fair parameters for the inspection.

Once the inspection has started, you are only at the very beginning of the process. Because there will be countless other important decisions, involve counsel early (preferably, as soon as OSHA arrives). Every company should also give some advance thought to its “OSHA plan,” identifying specifically how a request for inspection will be handled long before a compliance officer shows up on the company’s doorstep.

“The True Cost Of Work Related Injuries – Accidents Cost More Than People Realize!”

The True Cost Of Work Related Injuries – An infographic by the team at SafetyVideos.com

“OSHA’s Wall Of Shame – With Limited Staff, Agency Targets “Severe Violators”

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Source: FairWarning.org – By Paul Feldman and Stuart Silverstein

Soon after beginning their cleanup of a fume-filled tanker car at an Omaha, Nebraska rail maintenance yard, Adrian LaPour and Dallas Foulk were dead.

An explosion that April 2015 afternoon trapped LaPour in a flash fire inside the car and hurled Foulk out the top to his death.

Six months later their employer, Nebraska Railcar Cleaning Services, was hammered by the U.S. Occupational Safety and Health Administration with seven citations for “egregious, willful” workplace violations, along with 26 other charges. The agency proposed fines of nearly $1 million. To top it off, OSHA announced that it was tossing the company into its Severe Violator Enforcement Program, or SVEP.

Six years into the severe violator program – arguably the broadest workplace safety initiative launched during the Obama administration – more than 500 businesses are on its list of bad actors. They include corporate giants such as DuPont and International Paper, each with tens of thousands of employees, as well as more than 300 construction firms, many with fewer than a dozen workers.

Just last week an auto parts maker in Alabama, Ajiin USA, was labeled a severe violator and hit with proposed fines of $2.5 million related to the June death of a 20-year old worker. Regina Allen Elsea, who was two weeks away from getting married, was crushed when a robotic machine she was doing maintenance on abruptly restarted. Ajiin, which supplies automakers Kia and Hyundai, said in a statement it will continue to cooperate with OSHA and that “safety has always been our guiding principle.”

Along with subjecting employers to a form of public shaming, the severe violator program helps OSHA work out settlements intended to force companies to clean up their job safety practices. The program, which replaced a George W. Bush administration initiative that an inspector general’s audit derided as ineffectual, also can result in extra inspections, sometimes at multiple sites, and force companies to hire new safety personnel. The effort, though, faces an uncertain future under the Trump administration.

The severe violator list represents an attempt to deal with an overwhelming regulatory challenge. With OSHA and its state counterparts relying on fewer than 1,850 inspectors to monitor about 8 million workplaces, it would take federal officials 145 years to inspect each job site once, union researchers estimate. The aim of the list is to let OSHA’s limited staff zero in on some of the worst offenders.

David Michaels, the assistant secretary of labor in charge of OSHA, said in an interview with FairWarning that “even if we doubled our inspectors, we would still be able to only get to a small portion of employers. And so we need tools like SVEP, which extend our capabilities and encourage more employers to do the right thing even without inspections.”

But the targeted nature of the program creates a Catch-22. The death of a worker is clearly the worst thing that can happen at a job site. Yet with about 4,800 workplace fatalities a year nationally, putting every company with a death on the severe violator list would overwhelm OSHA and defeat the goal of tougher enforcement for a subset of the worst offenders. For that reason, the death of a worker will put a company on the list only if the circumstances are particularly flagrant or reflect a pattern of reckless conduct. In 2015 only one out of every roughly 200 employers with an on-the-job fatality landed on the list.

At the same time, it’s not certain that the program has effectively deterred recalcitrant employers, as OSHA lacks any comprehensive assessment of its performance. For evidence of the impact, OSHA officials point to settlements they have reached with companies on the list. “There hasn’t been a really good objective evaluation,” said MIT Professor Thomas A. Kochan, co-director of MIT’s Institute for Work and Employment Research.

One critic, John Newquist, (a LinkedIn connection of mine) and former OSHA official in Chicago, said his sense is that among employers, “There’s no fear of OSHA at all.”

Michaels, who will leave the agency by the January 20, 2017, presidential inauguration, expressed hope that the Trump administration won’t dismantle the severe violator effort or other enforcement initiatives. He said tough enforcement protects responsible employers because it “levels the playing field” between them and competitors who skimp on safety. Still, the anti-regulation views of Trump cabinet picks including Andrew Puzder, the president-elect’s choice for labor secretary, are raising expectations of cutbacks in workplace enforcement.

Nebraska Railcar –- currently the target, several sources say, of a Justice Department criminal investigation of last year’s explosion –- highlights how long it can take a wayward company to be put into the severe violator program. Jacob Mack, who worked for the company in 2013, says he told OSHA about brutal conditions long before the deadly blast. “Not a day goes by I don’t remember the hell there,” Mack said.

The company wasn’t listed until after the explosion even though it, as well as other businesses controlled by Nebraska Railcar’s majority owner, Steven Braithwaite, had repeatedly been cited by OSHA dating back to 2005. That includes a 2013 citation involving a fire risk from oil storage tanks. Nebraska Railcar stayed off the list, though, partly because its prior violations didn’t involve hazards the agency deemed high-priority, such as falls, amputations, cave-ins and exposure to toxic chemicals.

(Nebraska Railcar is contesting its current OSHA citations, as are other companies cited in this story that haven’t reached a settlement with the agency. Nebraska Railcar and most of the other companies have not responded to requests for comment.)

Case Farms, a leading poultry processor with plants in Ohio and North Carolina, finally landed on the list in 2015 after being cited for more than 350 violations over a 25-year period, according to OSHA. The case, which processes nearly 3 million chickens a week for fast food chains and supermarkets, last year was fined $861,500 for 55 violations, including amputation and fall hazards, at its Winesburg, Ohio, plant.

Sometimes disaster has struck even after companies were put in the program. One such case, in October, spurred a public outcry in Boston. Two laborers working for Atlantic Drain Service died after being trapped in a trench that was inundated by water, dirt, and debris after a pipe burst. Atlantic Drain had been on the severe violator list since 2012.

The October deaths “were entirely preventable,” The Boston Globe wrote in an editorial, “had city and state officials taken minimal steps to investigate the construction company before issuing permits.”

Whatever the shortcomings of the severe violator program, labor advocates say, the wide range of companies it snares -– and the number and gravity of their violations -– underscore its importance and the need to protect workers from callous bosses. OSHA’s other options are limited. The agency lacks the authority to shut down dangerous workplaces and its fines generally remain modest despite an increase that took effect in August.

“OSHA is one-eighth the size of the EPA, it has the lowest penalties of almost any government agency – but even though it is small, it is critical that enforcement is maintained,” said Deborah Berkowitz, the OSHA chief of staff from 2009 to 2013. The severe violator list, she conceded, is “not an end-all tool,” but an important tool.

An example OSHA officials point to is Ashley Furniture, the nation’s largest retailer of home furnishings. It was listed last year after being cited for 38 violations, 12 of them willful, and assessed $1.76 million in fines. Inspections showed more than 1,000 work-related injuries in less than four years at its plant in Arcadia, Wisconsin.

Over 100 of the injuries took place on similar woodworking machines, including a July 2014 incident in which a worker lost three fingers. In June, the privately held firm settled the case, agreeing to pay penalties of $1.75 million and to adopt safety measures in Arcadia and at three other plants in Wisconsin and Mississippi.

Some corporate defense lawyers say being labeled a “severe violator” is such a black eye that it strongly motivates companies to avoid trouble with OSHA. However, they criticize the program for lacking due process, because companies are labeled severe violators even as they appeal citations.

“You are dumped into SVEP essentially the day that the citations are issued and a citation is nothing more than an allegation,” said Eric J. Conn, a Washington, D.C.-based attorney who specializes in OSHA defense cases. “Having the federal agency that is responsible for safety and health branding that employer as a bad actor … absolutely has significant consequences to the employer’s business.”

In the meantime, corporate lawyers say, competitors or critics can take advantage of the situation. If residents near a listed site “don’t like your company, to begin with, this is more ammunition they can use to go to a zoning board to block permits for expansion,” said Adele Abrams, a Washington, D.C.-based attorney.

On-the-job deaths can keep companies in the program for years. DuPont was listed after four workers at its La Porte, Texas, chemical plant died of asphyxiation in 2014. The disaster occurred after a supply line released more than 20,000 pounds of deadly methyl mercaptan gas. The company, which manufactures pesticides at the Texas plant, was assessed $273,000 for eight OSHA violations. DuPont said it couldn’t comment because it is appealing its case.

AMF Bowling Centers, Inc. has been on the list since 2011, when a worker at its lanes in Addison, Texas, was fatally pulled into an automatic pin-setting machine while trying to clear a jam. OSHA had previously cited AMF in 2007 and 2008 for failing to provide proper machine guarding on pinsetters. The case was settled, with AMF agreeing to pay more than $90,000 in penalties.

Oil services giant Nabors Completion and Production Services Co. was listed following the death of welder Dustin Payne, a 28-year-old former Marine who served in Iraq and Afghanistan. He was killed in a 2014 explosion when vapors ignited inside a tank he was welding in North Dakota.

Houston-based Nabors, which boasts of operating the world’s largest land-based drilling rig fleet, was assessed $97,200 in fines and charged with a willful violation for not having thoroughly cleaned the tank of oil residue before sending Payne in.

“Dustin Payne and his fiancée should be discussing marriage and their future together. Instead, she is left stricken and trying to move forward without him,” Eric Brooks, OSHA’s area director in Bismarck, N.D., said in a news release.

International Paper Co. was added to the list last year after a 57-year-old mechanic was killed in a fire while replacing filter bags in machinery at its Ticonderoga, N.Y., plant. The bags contained combustible dust that ignited.

In assessing $211,000 in fines, OSHA said the company had failed to supply fire-resistant clothing or adequate training. The firm had previously been cited for failing to conduct annual inspections of ignitable equipment at company sites in Chicago and Newark, Ohio.

Although big companies draw the most widespread attention, the employers most commonly labeled severe violators are small construction firms with high emphasis hazards related to falls or excavation cave-ins. Yet small construction firms often elude the follow-up inspections that are supposed to be a key feature of the program.

A FairWarning analysis of the current list of 523 severe violators found that 167 had not been re-inspected, and almost all were construction firms. In many cases, the firms had shut down their worksites or went out of business before inspectors could return.

Eric Frumin, safety and health director of the union coalition Change to Win, said given the way the industry operates, OSHA can be “powerless to find and vigorously confront the worst actors.”

A trench collapse last year in New York that put a construction firm on the list also led to criminal charges. The cave-in collapse in lower Manhattan buried Carlos Moncayo, 22, under tons of dirt. His employer, Sky Materials Corp. of Maspeth, was fined $140,000 and listed for willfully failing to provide cave-in protection

Last month, Sky’s site foreman was convicted of criminally negligent homicide in the death of Moncayo, one of at least 18 New York City construction workers who died on the job in 2015. The project’s general contractor, Harco Construction LLC, was convicted of manslaughter and criminally negligent homicide in June.

Deadly incidents also have brought rail tank car cleaning companies into the program. At Nebraska Railcar, the disaster came soon after the workers returned from a lunch break and started digging out thick residue from an oil tanker. The lone survivor among the three employees working on the tanker, Joe Coschka, 36, said he was just outside the car, lowering buckets of the blacktop like material into a 55-gallon drum.

Coschka said the odor from inside the tanker was powerful, and that an air monitor was beeping. Even so, he said he assumed a supervisor who should have known better than him whether the air was a hazard, should have informed workers to evacuate the tank car immediately.

Soon Coschka heard a loud hiss, and then sparks started shooting out of the tanker. The next thing he remembers is dangling from the side of the car, still attached to his safety harness, with a fire raging inside. “And I knew Adrian was in there, and Dallas was looking pretty bad on the ground. I just knew I had to get out of there,” said Coschka. He managed to scramble to safety despite suffering back and shoulder injuries.

Coschka remains haunted by the disaster. Although he sometimes blames himself for not questioning the foreman who sent the workers into the tanker car, most of his anger is aimed at Braithwaite, the main owner of the business. He said he wishes the tougher OSHA actions had come sooner. Referring to the years of citations against Braithwaite’s companies, Coshka added: “It’s just sad because this guy dropped the ball so many times and he just keeps getting away with it.” Coschka had started at Nebraska Railcar only a month earlier.

Source: FairWarning.org – By Paul Feldman and Stuart Silverstein

“OSHA Enforcement Case Database By State” #OSHA #Violations #Data

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Enforcement Cases with Initial Penalties Above $40,000

(Includes citations issued starting January 1, 2015. Cases are updated weekly. There is a posting delay to ensure the parties have been notified.)

Click on link to view States Map and Violations by State : https://www.osha.gov/topcases/bystate.html

NOTE: OSHA is currently migrating its legacy system. Cases prior to 2011 (Federal OSHA) and 2013 (OSHA State Plans) may be affected by this migration. Cases indicated without the .015 extension reflect the data as of 08/05/2016. The next updates for those cases will be reflected October, 2016. Should you need case status updates for those cases before October 2016, please contact your originating OSHA Office.

“Miller Fall Protection Safety Webinar” & “Fall Clearance Calculator App”

Miller Fall Protection Webinar

When working at height, it is important to know your fall clearance and swing fall, whether using a shock-absorbing lanyard or self-retracting lifeline. Calculating your fall clearance and swing fall is critical to your safety. The Miller Fall Clearance Calculator App gives workers who work at heights, the ability to quickly calculate the required fall clearance for Shock Absorbing Lanyards and Self-Retracting Lifelines, including swing fall.

Download the New Miller Fall Clearance Calculator App by Honeywell : Download link – https://itunes.apple.com/us/app/miller-fall-clearance-calculator/id971198656?mt=8

Miller Fall App

“How Would Nick Saban Handle An OSHA Inspection?”

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Lessons for Employers from the Crimson Tide’s Championship Football Coach

September has arrived. That can only mean one thing: it’s time for college football!

Labor Day weekend offered several high-profile games for our viewing pleasure. Number-one ranked Alabama won one of those contests, with the Crimson Tide overwhelming Southern California by the score of 52-6. Alabama looked well-prepared and disciplined in its lopsided victory over a ranked opponent, showing once again why its coach Nick Saban is likely the best in college football.

Coach Saban’s unprecedented success – having won five career national championships, including four out of the last seven – is the result of his unparalleled work ethic and a commitment to excellence even the CEO of a Fortune 500 company would envy. Indeed, his processes transfer well to the corporate world and some companies attempt to mimic what Saban has developed at Alabama. His attention to detail could create a successful environment at any business.

Employers can learn from Saban’s methodical determination to succeed. His model provides employers an example on how to, among many other things, institute programs to handle adversity and challenges that arise in the workplace.

Following Saban’s routine of working hard, staying focused, teaching discipline, and developing character could help any employer prepare for unexpected events like a workplace accident or visit by a government compliance agency, such as the Occupational Safety and Health Administration (OSHA).

Given what we know about the habits that led to his success as a football coach, here’s how Saban – if employed as a safety supervisor – might handle the difficult tasks of developing a culture of workplace safety and responding to an OSHA inspection:

Pre-Game Preparation- Before OSHA Arrives

1. Be Prepared. No coach prepares like Nick Saban. Saban rarely loses a game for which he had additional time to prepare. In fact, he has never lost a national championship game, which generally does not take place until several weeks after the end of the regular season. Safety Supervisor Saban would have his company extremely prepared for any government agency visit, including an OSHA inspection. He would take the proactive approach of creating robust safety programs, rigorous training techniques, and a culture of accountability.He would not wait until after OSHA arrived to take these steps.

2. Challenge the (Safety) Program. Coach Saban loves for his team to play top-notch opponents, especially early in the season. Stiff competition challenges his team and only makes it better. He currently employs 21 consultants – in addition to his coaching staff – to analyze the quality of his program at Alabama. Safety Supervisor Saban would have consultants from top safety companies and safety professionals from competitor companies review his safety program and give feedback on how to make it better. He would listen to and learn from these consultants in an effort to develop new techniques and continuously improve safety in his workplace.

First Half – The Opening Conference with OSHA

3. Take Charge and Speak for the (Safety) Team. Coach Saban prohibits his assistant coaches from speaking to the media on behalf of the program. If you have a question about the Alabama football team, you ask Coach Saban. If OSHA arrived for an inspection, Safety Supervisor Saban would instruct his employees not to speak to any OSHA representative until he arrived. OSHA could only meet with the head of the safety program prior to beginning its inspection. This would ensure proper, and knowledgeable communication is delivered on behalf of the company.

4. Know the (OSHA) Rules. Coach Saban understands the rules of college football. In fact, he often questions why other coaches aren’t following them, or why certain rules should be changed. He is a student of the game. Safety Supervisor Saban would know not only the OSHA safety regulations but the procedures OSHA must follow when conducting an inspection. He would understand, for instance, that regardless of the reason OSHA appears at your door, if you consent to the inspection without limiting the review to the stated reason OSHA is there (e.g., hazard alleged in a complaint), most arguments relating to the scope of the inspection are lost. Saban would know what OSHA can and cannot do, and require the agency to follow its procedures.

Second Half – OSHA’s Walk-Through and Interviews

5. (Make OSHA) Focus on the Task at Hand. Coach Saban refuses to allow certain team personnel to speak on the headsets worn by coaches during the game. He believes any additional conversation is unnecessary and a waste of time. He also requires his players to focus on each individual play and attempt to execute it without error. Saban generally prohibits players and coaches from discussing the score at any point during the game. He believes that if you take care of each play, the score will take care of itself. While walking through his facility with OSHA during an inspection, Saban would require OSHA to focus solely on the reason why it is there. If OSHA is there for a complaint on a press machine, OSHA would inspect the press machine- nothing else. There would be no discussion of any other matters.

6. Tell the Truth and Don’t Make Excuses. Coach Saban doesn’t like excuses. Win or lose; he generally gives the other team credit for their excellent play; he doesn’t blame the referees.He also requires his players, to be honest. Saban believes honesty is a crucial character trait. Safety Supervisor Saban would require his employees, to tell the truth, if interviewed by OSHA. If there is a safety issue, he would instruct them to not hide it or make excuses. Honesty is the only policy.

Post-Game – After the Penalties

7. Learn from Mistakes. Saban doesn’t always win. When he loses, however, he allows that experience to be an opportunity to learn. Rarely does Saban lose to the same team twice in one season, or more than one year in a row. If Safety Supervisor Saban received a citation, he may contest it if plausible defenses existed. More importantly, however, he would learn from the experience and rigorously reassess and evaluate his safety program with respect to the alleged hazard in order to improve.

8. Above All, Be Professional. Coach Saban is a professional. He generally refrains from yelling or swearing on the sidelines, and treats others with respect in both victory and defeat. Safety Supervisor Saban would understand that employers and OSHA are on the same page from a mission standpoint. They want to keep employees safe. Being abrasive or unprofessional is not the demeanor that will help accomplish this goal. Saban would realize the importance of remaining cordial throughout the inspection process.

Coach Saban’s success is the product of habits that could produce results on and off the football field. Employers can learn from accomplished leaders like him.

When determining how to improve your safety program, consider what has led to success for others, even if that success occurred outside your industry. Think outside the box. This innovation and critical evaluation will lead to results.

By Travis Vance of Fisher Phillips

Contractors: “Who Is Responsible For Their Safety?”

If you hire contractors, perform contract work, or work at a multi-employer work site, it can be difficult to determine what your safety responsibilities are. Use this infographic to gain a better understanding of how multi-employer rules apply in common situations and what you should look for when hiring a contractor.

Contractors: Who's Responsible for Safety?

Contractors: Who’s Responsible for Safety? by Safety.BLR.com

“No Injury, No Accident”……..Right??

Discover how near misses can add up to major accidents. “No Injury, No Accident?” dramatically shows employees how to recognize and prevent serious injuries or fatal accidents before they occur. Based on the pioneering work of W. H. Heinrich and his renowned “Heinrich Triangle,” the program demonstrates how the odds of a serious or fatal accident occurring emerges from a series of typical injury-fee accidents. “No Injury, No Accidents?” also shows employees the importance of reporting the accident, investigating how it happened, and eliminating the cause. It’s an essential message for every safety program.

Note: The first 23 seconds of this 18 Minute video are a little garbled.

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