Risk Management Bulletin

There are nearly 5 million permit-required confined spaces in workplaces nationwide, plus another million “non-permit” spaces. Confined space accidents, which often result in injuries or fatalities, happen more often than you might think. According to the National Institute of Occupational Safety and Health, these mishaps usually occur because workers encounter one or more of these potential hazards:

• Lack of natural ventilation
• Oxygen-deficient atmosphere
• Flammable/explosive atmosphere
• Unexpected release of hazardous energy
• Limited entry and exit
• Dangerous concentrations of air contaminants
• Physical barriers or limitations to movement
• Instability of stored products.

To prevent, or minimize accidents in confined spaces, we’d recommend a three-pronged safety program: Training, testing, and rescue preparedness.

1. Train
Training should emphasize recognizing what constitutes confined spaces, the potential hazards they pose, and the precautions that workers and managers must take to prevent accidents and injuries. Stressing that death is a likely outcome in confined space accidents usually makes trainees sit up and take notice.

2. Test
Testing, evaluation, and continuous monitoring are essential. More than half of confined space fatalities result from hazardous atmospheric conditions such as toxic vapors or lack of oxygen. NIOSH recommends that a qualified person test all confined spaces for oxygen level, flammability, and known or suspected toxic substances to determine whether the atmosphere is safe for entry.

3. Rescue
Make sure that trained, equipped, and experienced rescue personnel are available in case of emergency. A significant percentage of confined space fatalities and injuries involve would-be rescuers who rush in without proper training or equipment. NIOSH advises creating rescue procedures specific to the type of confined space and its hazards before rescuers enter the space.

Skin cancer accounts for more than half of the cancer cases in the nation each year. Exposure to the sun causes most of the more than 1 million cases of non-melanoma skin cancers (such as the basal or squamous cell type), which usually develop on sun-exposed areas of the body: Face, ears, neck, lips, and the back of the hands.

If your employees work outdoors during the summer, they should beware of these symptoms:

• Any change on the skin, especially in the size or color of a mole or other darkly pigmented growth or spot, or a new growth
• Scaliness, oozing, bleeding, or change in the appearance of a bump or nodule;
• The spread of pigmentation, such as dark coloring that spreads past the edge of a mole or mark
• Change in sensation, itchiness, tenderness, or pain.

Training outdoor workers to limit their exposure to the sun can help them not only to prevent skin cancer but also protect them against sunburn, premature skin aging, and eye damage.

Make sure that your employees:

• Avoid outdoor activities between 10:00 a.m. and 4:00 p.m.
• Stay in the shade if they’re outside midday
• Understand that because ultraviolet (UV) rays will penetrate clouds, it’ possible to get a bad sunburn even on a cloudy day
• Know their risk factors for skin cancer such as a fair complexion, family history, multiple or atypical moles, and severe sunburns as a child.

If your workers must be outside during peak sunshine hours, have them use sunscreen and lip balm with a sun protection factor (SPF) of 15 or higher, applied in generous amounts (about a palmful) several minutes before going outside, and reapplied every two hours – or after toweling dry or perspiring. They should also wear broad brimmed hats to protect their head, ears, and neck. Clothing should be dark colored, and made of tightly woven fabric treated with an Ultraviolet Protection Factor (UPF) rating of 50 or higher. Workers can also wash sun protection into their clothes with an approved laundry additive that increases the protection and lasts through 20 washings.

Make sure that employees protect their eyes and the surrounding skin as well. They should wear sunglasses that provide 99% to 100% UV absorption and block both forms of UV radiation—UVA and UVB (pricier sunglasses or those with a darker tint don’t necessarily offer more UV protection). It’s wise to select wraparound glasses that offer side protection.

Every business needs an effective drug and alcohol testing program to meet compliance requirements, reduce its legal liability for accidents due to substance abuse, keep costs under control, and maintain effective employee relations. Evidential breath testing (EBT) plays an essential role in these programs. You can use your own certified employees, contract out for these services, or join a consortium of employers.

An in-house specimen-collection and testing program will cost time and money for buying and maintaining EBT devices, training employees, and keeping records. Because alcohol testing renders immediate results and in-house operations tend to risk disclosure, you risk violating your employees’ right to privacy. On the other hand, using third-party testers also has its drawbacks; you need to consider the reliability, quality, experiences, and resources of the organization.

Only a trained breath alcohol technician who passes a proficiency exam by the Department of Transportation can calibrate and maintain the EBT machine.

In addition, the machine must:

• Meet National Highway Transportation Safety Agency standards
• Print the results in triplicate, sequentially numbered, with the manufacturer’s name, device name, and serial number, and time and date of the test
• Test “air blanks” before each screening;
• Perform external calibration checks. It also needs recalibration after each positive confirmation test and at least once a month.

The EBT program must use labs approved by the Mental Health Services Administration, and testers must carry adequate insurance.

Random drug testing is mandatory for 50% of employees each year. Random alcohol testing must be performed on 25% of employees each year (depending on the rate of violations).

You need to remove drivers with a 0.02% breath alcohol concentration from their safety-sensitive position immediately. Drivers with a 0.04 % concentration can’t return to duty without evaluation by a substance abuse professional and treatment for alcohol misuse.

Hand-related musculoskeletal disorders (MSDs) are painful, sometimes crippling, injuries that generally affect nerves, tendons, tendon sheaths, and muscles in the hands, fingers, and wrists. A worker with a severe hand-related MSD might require surgery, be out of work for weeks, and have to remain on restricted duty for a while after returning to work. All of that can add up to a lot of pain and suffering for the worker and lost productivity and increased costs for your organization.

Hand-related injuries develop from frequent repetitive motions on a machine or keyboard, packing, cutting, etc.; forceful exertion; or from the use of vibrating or impact tools. Carpal tunnel syndrome, for example, is a common MSD that occurs when the nerve that runs through the wrist’s carpal tunnel is pinched. Initial symptoms are numbness, tingling, and weakness. Carpal tunnel syndrome can reduce strength and mobility in wrist and hands and may cause permanent damage.

The best way to handle hand-related MSDs is to prevent them. It’s essential for employees to choose the right tool for the job to reduce strain and awkward positions. To prevent injury when using tools, employees should:

• Grip tools so the thumb and index finger overlap slightly
• Avoid bending wrists while holding tools
• Use clamps, jigs, etc., to help avoid awkward positions and bent wrists
• Carry materials using a palm-down grip
• Reduce vibration-related injuries by operating tools at the lowest efficient speed possible
• Hold tools as loosely as possible without losing grip
• Use mechanical aids, not hands, to grasp and hold materials while working on them
• Keep hands warm. Cold hands make workers grip tools and materials too tightly. When their hands are cold, workers are also more likely to develop problems from vibration.

Whatever their job, make sure that your workers:

• Avoid repetitive movements whenever possible
• Alternate tasks to reduce time spent performing tasks that put a lot of stress on hands
• Take frequent mini-breaks to relax tense muscles and give hands a rest.

Finally, encourage employees to report MSDs affecting the hands, fingers, and wrists immediately. Symptoms include pain or aching; numbness, tingling, and stiffness; a burning sensation; swelling; and weakness.

If you’re like many safety professionals, you spend your days (and probably nights, too) working on and thinking about ways to make your workplace safer. Unfortunately, this can all come to naught without one thing your workers need to develop: A sense of safety awareness — building safety into the way your workers think about things.

Without it, workers won’t wear their PPE, or won’t wear it properly. They won’t make full use of the safety features built into their equipment; and they won’t observe basic rules, such as those of good housekeeping, that can prevent accidents. Without safety awareness, workers might think about production, their compensation, or tonight’s softball game but not safety.

To get them to do so, follow these guidelines.

1. Develop a Safety Manual. This book, given to new workers on day one, should pool safety information from department managers, equipment and tool manufacturers, and workplace safety experts. It should include startup and lockdown procedures, types of activity to avoid at work, and proper attire for operating equipment.
2. Name a Safety Champion. Choose one employee in each work area to research and report on safety at regular safety or department meetings. It’s amazing how often workers take to this responsibility. In one organization, the safety coordinator subscribes to safety magazines and continually contacts safety organizations to bring his co-workers the best and latest information. The gratitude of his colleagues is his only payment
3. Hold a Safety Event. Let employees plan and carry out safety demonstrations or create exhibits for these events, which can be either freestanding or part of larger company gatherings. This is an ideal time to hold contests or distribute safety awards. You can also invite guest speakers from vendors or safety or trade associations.
4. Build Safety into Employee Communications. Every employee contact from daily e-mails to paycheck stuffers to newsletters should stress workplace safety. The more you focus on safety, the more it will become a core value for your organization. Don’t forget posters and how to display them properly. This means locating safety messages so they won’t drown in a sea of EEOC and Wage and Hour announcements. Make sure that these messages get priority placement in work areas and aren’t covered by other postings as time passes.

Noise isn’t a new hazard in the workplace, but it sometimes doesn’t get the attention it deserves. Repeated, unprotected exposure of your employees to loud noise can lead to permanent hearing loss. When information (such as noise monitoring) indicates that any employee’s exposure might equal or exceed an eight-hour average of 85 decibels (dB), OSHA requires you to implement a “hearing conservation program.”

An effective program should concentrate on five key areas:

1. A noise-monitoring program. Monitor noise in work areas to identify employees subjected to noise at or above 85. Make sure to have the instruments used for this checked and calibrated carefully before each survey. Keep records of noise monitoring for two years.
2. Engineering and administrative controls. If monitoring identifies work areas with exposure levels of 100 dB, determine the engineering or environmental changes needed to reduce noise levels. Consult with your safety committee to set up appropriate administrative controls, such as rotating employees in and out of high-noise areas.
3. Personal protective equipment (PPE). Provide employees exposed to noise levels of 85dB or more with appropriate hearing protectors, free of charge. Use a PPE hazard assessment to select the type of PPE that provides the best protection.
4. Audiometric testing. All employees exposed to noise levels of 85 dB or greater must have a baseline audiogram within six months of the first exposure, and every year thereafter. If an audiogram shows hearing loss has occurred compared with the baseline, inform the employee, reevaluate hearing protection, retrain the employee if necessary, and refer them for clinical audiological evaluation. Record any threshold shift (hearing loss) of 10 dB or more that results in an overall hearing level of 25 dB on the OSHA Form 300 under “Hearing Loss.”
5. Employee training. Supervisors must conduct annual training sessions for affected employees on the elements of your hearing conservation program. These sessions should include the effects of noise on hearing; the purpose of hearing protectors and how to use and maintain them, and the reasons for audiometric testing and an explanation of test procedures. Be sure to document this training.

Motor vehicle accidents are the most common cause of accidental death and of workplace deaths representing about one in four fatal work injuries. Whether your employees drive on the job or commute to work by car, they need defensive driving training. An effective plan should include these basic rules:

• Buckle up for safety.
• Follow traffic rules, signs, and signals.
• Don’t speed.
• Maintain a two to four second gap behind the vehicle in front of you, but don’t fixate on it. Scan ahead as far as possible to watch and plan for emerging traffic situations.
• Keep your eyes on the road, your hands on the wheel, and your attention on traffic.
• Check your rearview and side mirrors frequently.
• Adjust your speed and driving to changing weather and traffic conditions.
• Expect the unexpected and be especially alert in heavy traffic for sudden stops, vehicles passing or moving in and out of lanes, road debris, and work zones.
• Keep cool, yield right of way, and avoid disputes with other drivers.
• Pull over to make or receive phone calls.
• Don’t drink or take drugs and drive.

Be sure to stress vehicle maintenance. A safe, roadworthy vehicle is an indispensable part of driving safely. If the vehicle is unsafe, the driver and others on the road are at risk. Teach your employees to keep their vehicles maintained properly and follow the manufacturer’s recommendations for oil changes, tune-ups, and so on. Also, remind them to inspect their vehicles frequently between service checkups.

Our risk management professionals would be happy to help you implement a comprehensive safe driving program for your employees. Just call or send us an e-mail.

OSHA strongly recommends that all businesses have an emergency action plan in place that covers procedures for evacuations and sheltering.

You and your employees need to know exactly what to do in any emergency, from fires and natural disasters to chemical spills.

Your plan should include these elements:

1. A clear chain of command and designation of a person authorized to order an evacuation or shutdown.
2. Specific evacuation procedures, including routes and exits (note that high-rise buildings require special procedures).
3. Procedures for helping visitors and employees evacuate, particularly those with disabilities or who don’t speak English.
4. Designation of evacuation wardens and monitors.
5. Designation of employees who will remain after the alarm to shut down critical operations or perform other duties before evacuating.
6. A means of accounting for employees after evacuation.
7. Appropriate respirators, especially for employees with emergency response duties.
8. Clear, detailed, and prominently placed escape route maps or diagrams.
9. Co-ordination of your plan with other businesses, if any, in the same building or industrial complex.
10. A schedule of evacuation drills at regular intervals (or on short notice).
11. Compliance with both federal (OSHA, 29 CFR 1910.38) and state emergency action standards. Note that some states have stricter requirements than does OSHA.

Tailor evacuation plans to the nature of each emergency. Your plan should identify different emergency scenarios and describe employee responses to them. For example, if a tornado or chemical spill on a nearby highway threatens your workers, you might want them to assemble in one area inside the workplace On the other hand, if you’re facing a fire or chemical spill in the workplace, make immediate evacuation your top priority.

To help you determine what will be required, ask “what if� questions and brainstorm worst-case scenarios. What would happen if a storage area caught fire, your property was flooded, or a dangerous chemical was released? You and your employees need to know the answer to these questions and the appropriate response to take in each case.

For professional advice on developing and implementing your emergency action plan, please feel free to get in touch with us, that’s our job!

The bad news: Exposure to indoor mold can trigger serious allergic reactions and even infections among workers and visitors to your building, leading to lost productivity not to mention the costs and hassles of litigation.

The good news: Taking precautions against this risk can help prevent health problems, limiting your exposure.

The potential for indoor exposure to mold has increased in recent years because of the way we live. To conserve energy, buildings are being built more tightly — and the tighter the structure, the greater the exposure to indoor mold. Using synthetic building materials literally seals buildings and reduces air movement, creating a higher moisture content that nurtures mold growth.

Poorly designed or maintained heating, ventilation, and air-conditioning systems contribute to indoor mold exposure; Air filters and air filtration devices provide a comfortable habitat for mold, especially in high humidity conditions. HVAC systems can re-circulate air that contains mold spores and toxins if there are no effective filter systems to trap them. Failure to maintain and clean systems leads to unchecked mold growth and circulation indoors. Humidity worsens the problem; mold thrives in humid conditions.

Human factors contribute to mold exposure, including the fact that we spend so much time indoors, and many of us have compromised immune systems from diseases and medications. What’s more, new and harmful mold organisms are circulating constantly.

Although there’s no practical way to eliminate all indoor molds and mold spores, to stop indoor mold growth and reduce the presence of mold in the workplace, we’d recommend taking these steps:

1. Clean small-scale molds ASAP, using a 10% solution of chlorine bleach; always wear the proper Personal Protection Equipment (which includes gloves, eye protection, and a mask to protect against airborne spores) and dry surfaces completely after cleaning.
2. Fix leaks quickly; moisture from leaks provides an ideal environment for mold growth.
3. Seal surfaces with a substance such as paint to which fungicide has been added.

Large-scale mold problems require the use of professional cleaning services that employ such treatments as oxidizers, fungicides, bactericides, and shielding compounds, which seal the antimicrobial agents within the treated surface.

Our risk management specialists would be happy to help you deal with mold problems in your workplace. Just give us a call.

The ideal workplace inspection isn’t one that follows a safety incident, or a surprise visit from OSHA it’s the inspection that you arrange yourself!

Self-inspection audits offer the most effective way to improve safety management, prevent accidents, and ensure compliance with safety regulations.

Work area inspections will:

• Evaluate compliance with safety and health policies and procedures
• Identify hazards for correction
• Determine the need for safety training
• Ensure that your work areas get a high grade in the event of an OSHA inspection
• Demonstrate your concern for employee safety and health

The Occupational Safety and Health Act requires periodic evaluation of workplaces. The timing of self-inspection audits depends on the type of work areas involved. Very hazardous areas might require formal, weekly inspections, while office areas might need only a monthly inspection.

Supplement scheduled inspections with informal daily walkarounds, targeting areas that have had more than their share of safety problems. Follow up to make sure that previously identified problems have been fixed effectively. Use checklists (preferably written) for every inspection.

Although management needs to take the lead in work area inspections and is ultimately responsible for making sure action is taken to correct problems, make sure to involve employees. Work area safety inspections provide a great training tool and an effective way of motivating employees to work more safely. Here are a few ideas for getting workers involved in self-inspection audits:

• Ask workers to help develop inspection checklists for their work areas.
• Appoint individuals or, even better, a team to conduct inspections. To get everyone involved, have team members serve on a rotating basis.
• Meet with employee inspectors after inspections to discuss safety problems and corrective actions.
• Share the results of work area inspections with all employees in weekly safety meetings.

Safety is all about awareness and knowledge. Knowledge gives you the power to prevent accidents. One of the best ways to keep informed about ever-changing work area conditions is to perform routine safety inspections. Don’t wait for an accident to find out about a hazard that could have been corrected!