“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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“Forklift Safety: 5 Factors That Reduce Lifting Capacity”

5 Factors That Reduce Lifting Capacity
5 Factors That Reduce Lifting Capacity

The maximum weight data placard on forklifts should never be regarded as the maximum amount able to be lifted. There are several factors that affect the lifting capacity, which is often reduced for various reasons. It is important to remember the lifting capacity is based upon the load center.

Did you know you lose weight-lifting capacity for every one inch beyond the actual load center? It is your responsibility to calculate the load center for any type of attachment used with the truck, including the original one. In addition, each time you switch attachments, it is essential to recalculate the load center and maximum load lift capacity of the forklift.

To learn more about the factors that affect the load center and load capacities, please feel free to continue reading the following infographic presented by Lift Truck Capacity Calculator. We can also provide assistance with determining the load center for a variety of attachments, as well as those that are worn by contacting us directly.

“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

“Are You In Compliance?”-“June 1, 2016 – HAZCOM And GHS, The Final Deadline”

HazCom and GHS: The Final Deadline

HazCom and GHS: The Final Deadline by Safety.BLR.com

June 1, 2016, is the final deadline in the 4-year phase-in period for OSHA’s 2012 revisions to the hazard communication standard that aligned with the Globally Harmonized System for the Classification and Labelling of Chemicals, or GHS. Check out the infographic for an overview of what the final deadline requires and tips to make sure your facility is prepared.

“June 1, 2016 – HAZCOM And GHS, The Final Deadline”

HazCom and GHS: The Final Deadline

HazCom and GHS: The Final Deadline by Safety.BLR.com

June 1, 2016, is the final deadline in the 4-year phase-in period for OSHA’s 2012 revisions to the hazard communication standard that aligned with the Globally Harmonized System for the Classification and Labelling of Chemicals, or GHS. Check out the infographic for an overview of what the final deadline requires and tips to make sure your facility is prepared.

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

image

 

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/

 

 

OSHA 300 Log – “Reminder: Post Your 2015 OSHA Recordkeeping Annual Summary By February 1, 2016”

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OSHA Form 300A: A step-by-step guide

OSHA Form 300A: A Step-by-Step Guide by Safety.BLR.com

Download OSHA 300 Log Kit Here: https://www.osha.gov/recordkeeping/OSHArecordkeepingforms.pdf

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OSHA 300 Log – “Reminder: Post Your 2014 OSHA Recordkeeping Annual Summary By February 1, 2015”

image002

OSHA Form 300A: A step-by-step guide

OSHA Form 300A: A Step-by-Step Guide by Safety.BLR.com

Download OSHA 300 Log Kit Here: https://www.osha.gov/recordkeeping/OSHArecordkeepingforms.pdf

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OSHA Publishes Direct Final Rule On Standards Update To Rules On Signage

Understanding OSHA’s Safety Sign Standards Update

For decades, OSHA’s regulations for workplace safety signs were based on outdated formats that were not aligned with the latest safety communication standards and their state-of-the-art warnings technology. These sign and tag regulations had not been updated since their inception in 1971, which referenced the 1967 and 1968 versions of the USASI Z53 and Z35 standards. But, in September 2013, new OSHA regulations went into effect. OSHA updated its regulations to incorporate the latest ANSI Z535 (2011) standards, effective September 11, 2013. This regulation change is an opportunity for organizations to rethink and elevate visual safety communication in the workplace.

Clarion’s Role in Championing the Latest Advances in Visual Safety

Clarion’s CEO, Geoffrey Peckham, who also serves as chair of the ANSI Z535 Committee for Safety Signs and Colors and chair and delegation head for ANSI to the ISO standards pertaining to safety signs, has spearheaded this update to OSHA’s consensus standards. His goal has been to better align OSHA with the latest advances in safety sign technology. Read our Issue Brief to learn more.

What This Means For Workplace Safety Signs and Tags

With OSHA’s regulatory update, organizations can now utilize the advances in warnings technology established in the ANSI Z535 standards for facility safety signs and tags – and be in compliance with OSHA. Prior to the rule change, facility owners using ANSI Z535 signs or tags would run the risk of being cited for violating OSHA standards because the OSHA standards only referenced the old 1967-68 standards (called a “de minimus situation”). This rule update allows employers to use either the old or new standards. For existing signage, OSHA will grandfather signs that comply with its current requirements. For new signage, OSHA will allow use of safety signs and tags that are compliant with either the old or new USASI/ANSI standards.

Why the New Standards Are Better

Most safety signs and tags in use today are based on antiquated, 70-year-old designs that lack the warnings technology incorporated into modern safety sign standards. They also fail to meet the demands of an increasingly global workforce with multiple language needs. The 2011 ANSI Z535 standards have many safety communication benefits as compared with older versions. These standards incorporate the past 70+ years of advances that have taken place in safety sign technology. As such, their use in workplaces is a significant step forward in improving safety and better protecting workers of all backgrounds.

Benefits of Using the Latest ANSI Z535 Signs and Tags
  • The new signs and tags typically provide a more substantial level of information so people can make safer decisions (such as the nature of the hazard, the consequence of interaction with the hazard, and how to avoid the hazard).
  • The concepts contained in the ANSI Z535 standards are supported by human factors research on effective warnings and by modern risk assessment methodologies.
  • The newer formats better accommodate multiple language panels and graphical symbol panels so safety is better communicated to non-English readers.
  • The ANSI Z535 standards contain design principles that exemplify current legal criteria for “adequate warnings” as defined by the past thirty years of U.S. case law.
  • See Updated Information here:
  • http://www.clarionsafety.com/OSHA-Signage-Update

__________________________________

Clarion Safety Systems, a longstanding leader in advancing best practices in visual safety communication, announced today that its efforts to promote the use of industry best practices related to safety signs, colors and tags to the Occupational Safety and Health Administration (OSHA) has resulted in the agency issuing a Direct Final Rule (DFR) on a proposed update to its regulations on signage. If no significant adverse public comments on the DFR are received by July 15, 2013, the agency’s next step will be to confirm the effective date of the rule.

Clarion’s CEO, Geoffrey Peckham, who also serves as chair of the ANSI Z535 Committee for Safety Signs and Colors and chair and delegation head for ANSI to the ISO standards pertaining to safety signs, has championed this update to OSHA’s standards to better align with the latest advances in safety sign technology. Over the last four years, together with the National Electrical Manufacturers Association, Peckham has lobbied OSHA to recognize that the American National Standards Institute’s ANSI Z535 series of standards for safety colors, signs and tags provide an equal or greater level of safety as compared to the 1967-68 USASI Z53 and Z35 standards that are presently referenced in OSHA’s regulations.

“At Clarion, workers’ lives and livelihoods matter. In our view, OSHA’s proposed update marks a significant step towards advancing workplace safety with effective signage,” says Deb Patterson, President of Clarion Safety Systems. “Our comprehensive knowledge of the latest standards coupled with our practical experience applying them across industries brings our clients best practice products. We know that there’s a better way to warn than what’s present in most workplaces around the country. It’s why we have been such strong advocates of OSHA’s adoption of the ANSI Z535 standards; safety signage, when done well, reduces risk and protects people.”

According to OSHA, the goal of the safety sign rulemaking update is to improve workplace safety and health by allowing employers to use the latest consensus safety sign standards (ANSI Z535) in order to take advantage of the safety communication benefits that the newer standards represent. When compared to the older 1967-1968 standards, the ANSI Z535 standards are considered the state-of-the-art because they have the following characteristics:

  • Provide critical information viewers need in order to make safe decisions, such as the nature of the hazard, the consequence of interaction with the hazard, and how to avoid the hazard
  • Are supported by human factors research on effective warnings and by modern risk assessment methodologies for accurately communicating hazard severity
  • Have the ability to use multiple language panels and graphical symbol panels to communicate safety to non-English speaking workers
  • Meet current legal criteria for “adequate warnings” as defined by the past thirty years of U.S. case law

Most employers currently use signs that comply with the older 1967-1968 standards. Because OSHA aimed to avoid creating an economic burden to employers, the older 1967-1968 standards will continue to be referenced in OSHA’s regulations. However, the corresponding ANSI Z535-2011 reference will be placed next to the older reference. For instance, whenever the OSHA standards reference the 1968 USASI Z35.1 Standard for Accident Prevention Signs, the 2011 ANSI Z535.2 Standard for Environmental and Facility Safety Signs will also be referenced. In effect, this will allow employers to use safety signs that comply with either the old or the new standards.

Prior to this rule change, employers using the newer ANSI Z535 standards for their signage would run the risk of being cited for violating OSHA standards. The outcome of this violation would not result in a fine due to the fact that the ANSI Z535 standards are the current version of the document that was used as the basis for OSHA’s safety sign regulations. Called a “de minimus situation,” this provision provides little incentive for employers to adopt the latest industry best practices with regards to safety signs, colors and tags. The new rule that incorporates ANSI Z535 safety sign, color and tag references into OSHA standards eliminates this problem, allowing employers to use the ANSI Z535 standards without the possibility of a citation.

“OSHA’s commitment to uphold the advances that have taken place in safety sign technology is a step forward in improving safety, reducing compliance uncertainty, and better protecting workers of all backgrounds,” says Peckham. “This is an opportunity for organizations to elevate visual safety communication in their workplaces. Safety and risk-conscious companies understand that, when it comes to zero harm and accident prevention, your workers, your company and your industry will be best served by utilizing the advances in warnings technology established in the ANSI Z535 standards. Industry leaders who already have a strong culture can now utilize signage that reflects their values in their facilities – and be in compliance with OSHA.”

To help safety advocates to learn more about the ANSI standards, as part of its comprehensive library of short, educational videos designed to promote a better understanding of current best practices in product safety labeling and facility sign systems, Clarion has produced a video titled, “ANSI Standards in Safety Signs and Labels.” The video is available through the Clarion website’s video library as well as through the company’s YouTube channel.

Clarion specializes in bringing companies up-to-date with the latest warnings technology and produces a product line of best practice, standards-compliant facility safety sign systems. Additional information is available by contacting the company or visiting http://www.clarionsafety.com.

ABOUT CLARION SAFETY SYSTEMS
Clarion Safety Systems, LLC, is the leading designer and manufacturer of visual safety solutions that help customers in more than 180 industries worldwide to make their products and premises safer. Clarion offers a full range of standard and custom products including machinery safety labels, environmental and facility safety signs, pipe and valve identification markings, lockout/tagout products, and safety-grade photoluminescent egress path-marking escape systems. Founded in 1990, the company continues to play a leading role in the development and writing of international and national standards for safety signs, labels, and markings. Clarion is headquartered at 190 Old Milford Road in Milford, PA, 18337, and online at http://www.clarionsafety.com.

Clarion CEO Geoffrey Peckham’s ongoing leadership efforts in bolstering adoption by the Occupational Safety and Health Administration (OSHA) of the Updated American National Standards Institute’s (ANSI) Standards leads to direct final rule on Consensus Standard Update on Signage, Marking Important Advancement in Workplace Safety.

OSHA 300 Log – “Reminder: Post Your 2013 OSHA Recordkeeping Annual Summary By February 1, 2014”

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OSHA Form 300A: A step-by-step guide

OSHA Form 300A: A Step-by-Step Guide by Safety.BLR.com

Download OSHA 300 Log Kit Here: https://www.osha.gov/recordkeeping/OSHArecordkeepingforms.pdf

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