- How to protect your shop from fire and your employees from chemical overexposure.
Download the Article: Spray Booths and Sprinkler Heads – September 2020
Download the Article: Spray Booths and Sprinkler Heads – September 2020
Back in September, we posted some training tips.
Here are some more suggestions from Janet Keyes, CIH:
Safety training programs should be updated whenever changes are needed. Here are a few triggers:
Your safety training program should include the needs assessment and determine if training is the correct solution, as mentioned in the prior blog.
Updating the safety training program is different than updating a safety training session or presentation.
The training materials should be updated routinely, so you are not giving the same presentation to the same people, in the same way, year after year. There are many ways to present the same material in a new and engaging manner.
The more employees know the material, the more they should be participating in the training.
Minnesota prohibits smoking in all indoor workplaces, but what about vaping, or electronic cigarettes? Well, a 2014 state law prohibits e-cig use on government property and at child care and health care facilities. Hennepin and Ramsey Counties have extended the ban to all indoor workplaces. Some municipalities have also banned e-cigs in workplaces. But what if your county and city haven’t and you have employees that want to use e-cigs? Should you allow it?
Unlike traditional cigarettes, e-cigs don’t cause tar build-up in users’ lungs, but they haven’t been around long enough to determine their health effects with any degree of certainty. And aside from health risks, there is another issue with e-cigs, which comes from their design: they are meant to help people quit smoking. As a result, they contain hazardous wastes! The batteries that vaporize the liquid are not allowed in checked airline luggage because of their hazards, and throwing the batteries in the trash, at work or at home, is illegal. So does your facility have a collection program? If you allow vaping, you should. If the batteries are recycled, they’re a universal waste and not a hazardous waste – a big difference to regulators and your bottom line!
But there is still another hazard: the cartridges. These little capsules are designed to deliver nicotine-containing smoke without all the tar. And there’s the primary hazard: nicotine. With some vaping liquids containing up to 42 milligrams of nicotine per milliliter, two drops is enough to send an infant to the Emergency Room. Studies have shown that three drops (just 6 mg) will kill a baby. That is why nicotine is specifically listed as an acutely toxic waste. That’s why unless a container is cleaned to EPA regulations, it’s not considered empty and must be treated the same as a container with the chemical still in it.
So… what should we do?
Don’t smoke or vape. But if employees must, then set up smoking stations away from public entrances, occupied spaces, walkways, and building air intakes. Provide a smokers’ station where employees can dispose of cigarette butts (which are unregulated refuse). For vapers: we recommend a policy that states employees must use the same smoking stations and, further, take home whatever smoking materials they bring in.
Your alternative is to collect the vape cartridges and dispose of them as hazardous waste… and because it is acutely toxic it won’t take many before your facility will be a Large Quantity Generator.
For more information, see the MPCA fact sheet on e-cigarettes and nicotine waste at https://www.pca.state.mn.us/sites/default/files/w-hw4-65.pdf
Download the article: A Quick Guide to Respirators, Beards and Voluntary Use
Download the article: Working on Vehicles and COVID-19
Download the article: AWAIR…You’re Above Average and That Ain’t Good
Download the article: A Bad Mix
Download the article: I Got Poked
Download the article: Not This Again
Download the article: What Safe Jobs We Have?
Download the article: Can You Hear?
Download the article: How Much Do Injuries Cost You?
Download the article: Power: A Discourse on Cords
Download the article: Up in the Air
Download the article: Do You Know Where the Hazards Are in Your Shop?
Download the article: Inspections, Inspections, Inspections
Download the article: Perennial Problems
Download the article: Walk This Way.
Mice carry disease. What should you do if a client brings in an infested vehicle?
Download the article: Rats. I Have Mice.
Download the article: Sounds Good
Download the article: What If the Worst Happens? – March 2017
Download the article: A, B, C, D, Extinguish Fires – January 2017
by Jake Thorson, CHMM, CHESS Inc.
Do you spray aerosols at your facility? Brake cleaner? Paint? Lubricants? If you do, how do you dispose of them?
If you are at a facility in Minnesota and puncture your aerosol cans to dispose of them as scrap metal, you will no longer be allowed to puncture the aerosol cans after January 1, 2018 (the MPCA just extended the deadline a year. It had been 2017). The new policy reflects a decision by the Minnesota Pollution Control Agency to reverse a previously allowed practice. Puncturing aerosol cans has never been a technically legal method of disposal for aerosol cans, but it was permissible – again, that is changing.
Instead, companies will be permitted to treat aerosol cans as a universal waste. The cans will have to be collected for disposal in a vented drum with either their caps in place or the can’s pin removed (to prevent leaks and pressure buildup in the drums). The aerosol cans can then be shipped off as a universal waste (if your waste company allows), using a shipping paper or DOT bill of lading. The aerosol cans will not have to be recorded on your annual waste reports, and you won’t have to include a hazardous waste manifest.
Sounds easier, right? Well, not quite… The MPCA has not yet made aerosol cans a universal waste by rule. Instead, they are rolling out the policy until the rule is officially promulgated in the spring of 2017 (hopefully).
What does that mean?
If you are a large quantity generator, the rule may not be in place in time for the first of your twice annual waste reports to the federal Environmental Protection Agency. Until the aerosols are classified as universal wastes by rule, any aerosol cans must be shipped and manifested as hazardous waste. The EPA will identify any aerosols shipped as a universal waste as done in error.
The same will apply for all generators big and small if the rule is not passed by the end of 2017.
If you have a facility in the one of the MPCA-delegated jurisdiction seven metro counties (Hennepin, Ramsey, Scott, Carver, Dakota, Washington, and Anoka) the county must adopt the new MPCA rule for you to handle the spent aerosols as a universal waste.
So what can you do?
Stop puncturing aerosols as of January 1st. We recommend storing and labeling all spent aerosols as “Hazardous Waste: Spent Aerosols.” The aerosol cans should be shipped as a hazardous waste until the rule is finalized (and adopted, if in the seven-county metro area).
Even when the rule is finalized, if you ship the spent aerosols outside Minnesota for disposal, the waste will need to be identified and manifested as “hazardous waste,” as that is the federal requirement – and that is not changing.
Post note: The MPCA has a new fact sheet on aerosol cans.
Download the article: Why Can’t I Just Repair It Myself? – November 2016
Download the article: Give Us a Hand – September 2016
Download the article: Oil, Water and Shoes Don’t Mix – July 2016
OSHA published its newest standard today – a requirement for employers to electronically submit injury data to OSHA. OSHA plans to publish that data on its website.
The important details
Establishments with 250 or more employees will be required to submit their OSHA 300A summary to OSHA, electronically, as of July 1, 2017.
As of July 1, 2018, those establishments will also have to submit information from their OSHA 300 logs and certain information from injury reports (Form 301).
Personal data, such as the employee name and address and who treated the employee, shouldn’t be submitted. OSHA intends to remove that information if it is included.
The rule is by establishment, not company. So a company with a thousand employees spread through ten different facilities of 100 employees each wouldn’t fall into this category.
Industries that are not usually required to keep OSHA injury and illness logs now (such as insurance firms, engineering firms, and nearly all schools) will not have to submit.
Certain establishments with 20 or more employees will be required to submit their OSHA 300A summary to OSHA, electronically, as of July 1, 2017.
These establishments are those in industries with higher injury rates (for those who want details, DART [days away/restricted] above the three year private sector average for companies required to keep OSHA logs).
The industries include but are not limited to construction, manufacturing, utilities, wholesale trade, nursing homes and hospitals, grocery stores, amusement parks, and more. Automotive repair facilities are not included. Nor are government entities.
OSHA may ask certain companies to submit. If so, even a small facility will need to comply.
The data will need to be submitted by March 2 each year, for the previous year. Businesses will still be required to post their OSHA 300A summary in their facility.
Employers need to tell employees how to report work related injuries or illnesses. Along with that, they must tell employees that they have the right to report and won’t be discriminated against for reporting.
This may end up being the most controversial part of the new rule.
Disciplining an employee who violates a legitimate work rule is allowed. But disciplining someone for violating a rule that says “maintain situational awareness” may be considered retaliatory, because that’s too vague a work rule. Likewise, requiring post-accident drug testing for all injuries, including those where drugs clearly could not be a factor, might be discriminatory. How that actually plays out will be determined case by case.
States with state OSHA plans have six months to adopt this rule.
Local governments aren’t included under the federal rule, because federal OSHA doesn’t have jurisdiction over them. But they may be included under the state adoption of this rule. A city with 250 Public Works employees in one shop would be required to report. But a city with 250 employees spread out over two or more establishments would not need to submit.
Who will have access to the data?
It will be posted on OSHA’s website, available to anyone – just as records of OSHA inspections are available.
Why is OSHA requiring this?
OSHA published a new standard for crystalline silica today. It’s about time. The standard changes the exposure limit from a complicated formula based on measuring the percentage of quartz in a sample to 0.05 mg/m3, the level NIOSH recommended forty years ago.
We’ve known, for thousands of years, that fine silica dust can damage the lungs. It’s considered a known cause of lung cancer. It’s been linked to kidney disease, and even to an increased risk of tuberculosis. Given the ubiquity of silica, we know we won’t eliminate exposure. But we can control exposure.
Silica shows up in concretes and mortars. It’s naturally present in rocks and sand. It’s a crucial component of glass. Fracking uses silica. The list of industries affected by the standard range from construction to foundries to jewelry production. OSHA estimates over 100,000 workers in general industry and maritime and over two million construction workers are affected by the new standards.
For general industry, the standard is similar to those for other hazardous chemicals, such as lead or hexavalent chromium: first, determine if workers can be overexposed. If they are, use engineering controls and work methods to reduce their exposure. Use housekeeping measures to limit dust. Have a written exposure control plan. Provide medical surveillance. Train workers on the hazards and on ways to reduce their exposure. Use respirators if other control measures aren’t enough.
The construction standard doesn’t require monitoring. Instead, employers can use a control measure that OSHA believes is effective, one specified in the standard. Those typically incorporate water or dust collection systems to capture or suppress dust. But employees still need to be trained, medical monitoring is still required, and employers still need to develop a written exposure control plan. In addition, the construction standard requires employers to designate a competent person to go to the job sites, to make sure the exposure control plan is implemented.
For general industry, medical surveillance is required if employees are exposed above the action level of 0.025 mg/m3. For construction, it’s required if employees need to wear respirators for 30 or more days per year. Why the difference? General industry exposures are expected to be consistent. For construction, they’ll vary depending on the task and control measures used.
One of the concerns we’ve had about general industry standards for silica exposure is that those standards are written for a predictable environment. Public Works employees usually don’t do construction work. But they have some exposures that resemble construction – for instance, repairing a concrete sidewalk. The new standard provides for that, allowing employers to comply with the construction standard if the task is one of those listed in the construction standard and if it isn’t “performed regularly in the same environment and conditions.” So as long as our sidewalk repair is done wet, we can be confident that we’re in compliance with the standard.
Construction employers have a year to begin to comply with the standard. General industry has two years, and even longer for some aspects, such as implementing engineering controls. It’s about time.
Minnesota will need to adopt the new standard. I’d expect MnOSHA to act quickly on this one.
We use them all the time, and then, when they’re empty or stop working, we often throw them in the trash without a second thought. But is that the right thing to do?
Most spray cans (aerosol cans, to give them their proper name) contain organic solvents and a propellant, the substance that keeps them under pressure and allows them to spray out as a mist. Some use carbon dioxide as a propellant. But the most common propellant: propane and isobutane. Those are extremely flammable (ever try to make a flame thrower with hair spray? Don’t do it – it’s playing with fire. The reason it works isn’t because of the hair spray as much as it is the propellant).
If you throw that can away before it’s completely empty, you create a fire hazard for those who handle it downstream. And you may be polluting the groundwater, if the container ends up in a landfill. The solvents in aerosol cans are often regulated as hazardous waste.
What are your options?
If possible, use up the container completely. And then check that it’s really empty before you toss it and grab the next can. Shake it – can you hear any liquid? Try to spray some out. Will anything come out? Try it upside down, sideways, and then right-side up again. If you get nothing when you depress the nozzle and you hear nothing when you shake the can, it’s safe to throw away. We’d prefer it if you recycle the metal. But it can go in ordinary trash if your waste hauler okays that.
What if you can’t use it up completely? The Minnesota Pollution Control Agency (MPCA) used to allow the containers to be punctured and drained, as long as you used a charcoal filter to capture the vapors. But those filters don’t capture the propellants. As of January 2017, puncturing aerosol cans is not allowed, unless you have a way to collect both the liquid in the can and the propellant used to pressurize it.
The MPCA will allow businesses to handle aerosol cans as universal wastes. Those are hazardous wastes that are so common that special, less restrictive rules have been developed to handle them. Fluorescent lamps are an example of universal waste.
If you handle aerosols as universal waste, you need to:
You don’t need to use a hazardous waste manifest for these.
Bottom line: use it up and recycle, if you can.
Download the article: A Garage Burned Down – February 2016
Do you have employees who operate forklifts or work around forklifts? In Fiscal Year 2018, in Minnesota alone, MNOSHA investigated five serious injuries involving a body part (hand, leg, arm, foot) being hit by or run over by a forklift.
Federal OSHA has issued an OSHA Alert: a one page reminder about safety for those working around or operating a forklift. https://www.osha.gov/Publications/OSHA3973.pdf
That title might be cliche, but when it comes to safety, it is true. We have recently had the unfortunate opportunity to investigate several serious injuries. Some injuries could be prevented if the employee took one second or ten seconds to think about what he was about to do, to shut down the equipment and make sure it came to a complete stop. Not taking those precious few seconds resulted in hours (or days) away from work for a trip to the hospital and recovery.
Worse, it will impact the employee for the rest of his life. Think about it. Which finger are you willing to lose to a piece of equipment? What body part are you willing to live without? How would your family be impacted if you had a spinal cord injury?
Most recently, we saw how a motor vehicle accident changed lives. Distracted driving, use (or lack of use) of seatbelts, weather conditions, other drivers–those can all end up impacting you.
While it would be great to wrap everyone in bubble wrap to keep you safe, that is obviously not realistic. But, you can watch out for yourself and your co-workers. We want you to stay safe out there.
Download the article: Walk Around Your Building – January 2016
Download the article: Wheel Cleaners Can Be Nasty – November 2015
Download the article: Air Quality Permits – July 2015
Summer brings out the best in Minnesota–mosquitoes, wasps, poison ivy and wild parsnip. I did not know about wild parsnip until a few years ago, when Janet told me about it. Fortunately, I have not had a personal encounter with it.
What is the big deal with wild parsnip? It is an invasive species that grows along the side of roadways. It is a yellow flowering plant, growing from 6″ to 4′ high. You won’t feel much if you rub up against it. Until you see sunlight. When skin that has been in contact with wild parsnip is exposed to sunlight, the skin will burn and blister. This is a big deal for anyone working along roadways, for bicyclists who stop alongside a road, or anyone else who may stop or walk along areas that have wild parsnip.
The Minnesota DNR has a page dedicated to this plant: http://www.dnr.state.mn.us/invasives/terrestrialplants/herbaceous/wildparsnip.html
I’ve been behind in my blog posts, mostly because we’ve been so busy. The great news is that CHESS has added two new staff members: Dawn Billstrom and YaVone Wirtz. Dawn has worked for utilities departments and brings a great worker perspective. She completed a certificate program in safety through Hennepin Technical College. We are looking forward to her assistance with clients, especially with job hazard analyses.
YaVone worked for the Department of Public Safety and completed a paralegal program. Our clients will probably hear from YaVone when she calls to set up training.
So, with all these changes, look for more regular blog posts.
Download the article: Clear Coats, Hardeners, Isocyanates and Skin – May 2015
I just read a recent OSHA news release about two employees who were killed and another who was severely burned at a US Steel plant in Alabama. The article said “Management knew that attempting to operate the valve while the furnace was still running placed workers at risk, yet they allowed them to do it because they didn’t want the production line down for hours,” said Ramona Morris, OSHA’s area director in Birmingham. “This employer chose productivity over the safety of its workers, and two people died as a result of this decision.”
So, did the company save time by bypassing safety? I’m guessing the plant had to be shut down while investigations occurred and damage was repaired. That didn’t save any time.
I recall a supervisor who initially complained about his employees being so busy that they didn’t have time for safety training or to get the devices (carts, lifts, etc.) to help employees do their jobs. And then one of his employees hurt his back and was out of work for several weeks. So, they ran very short staffed during that time. Did they save time or money by bypassing safety? No. And the supervisor recognized the impact it had on his employees. Having a full staff take a little extra time to do things safely was a lot more productive than having fewer staff because someone is out with an injury.
And, the US Steel plant? The $107,000 in OSHA penalties is just the beginning of the costs.
I have been sadly amazed at the number of motor vehicle crashes I’ve read about in the newspaper recently. While I don’t know the cause of all of them, at least one crash with multiple fatalities was linked to distracted driving (posting to Facebook while driving). Whether it is medication, fatigue, or electronic devices (GPS, smartphones, email, Facebook, texting), distracted driving is a leading cause of vehicle crashes.
The National Institute on Occupational Safety & Health (NIOSH) recently published a guide for employers to develop programs and policies to keep employees safe while driving. The document can be found here.
CHESS can also help develop fleet safety programs and policies.
The most recent newsletter from CHESS is now available online. Topics include OSHA recordkeeping and new reporting requirements, regulatory updates, environmental deadlines, MPCA general permit updates, environmental and safety grants, hazardous waste hauler updates and employment poster updates. All of that available here.
Download the article: Records, Records and More Records – February 2015
Federal OSHA has implemented new injury reporting requirements as of January 1, 2015: you must report any fatality to OSHA within 8 hours (that has not changed). In-patient hospitalization of one employee (used to be three employees), amputation or loss of an eye must be reported within 24 hours of finding out about the incident.
Remember, these requirements are above and beyond reporting to Workers’ Compensation.
Minnesota is a state run program, so their time frame for implementing this is different. It looks like Minnesota will likely require this new injury reporting as of October 1, 2015. They have not yet published their proposal to adopt these regulations. We anticipate more inspections based on injury reporting.
NIOSH recently posted in their science blog that prolonged standing is not healthy–it can lead to musculoskeletal disorders and other health problems. There have been prior studies saying that sitting for long periods is bad for you. It sounds like you shouldn’t sit and you shouldn’t stand. So, what are you to do?
Well, unless you work as a mattress tester, lying down is not likely an option. The key to these studies is “prolonged.” It does cause health problems if we stay in one position for too long. Being able to walk, and switch between sitting and standing, is best. If you work in a job that requires standing for long periods, wearing comfortable shoes, using anti-fatigue mats, putting one foot up to relieve the pressure on your back, wearing shoe inserts or even compression socks may help.
If you are sitting for long periods, having an adjustable chair may help.
To help promote health, being able to move around, changing positions, short stretch breaks, any brief change in activity, will help.
Stay healthy and stay safe!
It’s warmed up in Minnesota, but you know snow and ice will be back. To keep from falling, walk like a penguin: take small steps, keep your knees relaxed, and turn your feet out a little. Limit how much you carry–use a back pack if you can.
Download the article: Respirator Medicals – AGAIN – and Aluminum – December 2014
We are back to writing our blog after a summer hiatus (well, and finishing up a couple of big projects).
We often have companies ask about Job Hazard Analyses (JHA). First, what it is: whether you call it a JHA or Job Safety Analysis (JSA) it is a process of breaking down a job by the most simple tasks and identifying the hazards with each task. That is the first part. Then, looking at each task, identify the potential hazards. Lastly, identify ways to control those hazards.
We’ve found JHAs, in the traditional sense, work fine in manufacturing settings where tasks are repeated over and over. For example, putting a part into the machine, close the machine, run the machine, wait for gate to open and remove part, …
The basic framework of task, hazard, and precaution can be used for any job, but you may not want to break it down as far. For example, driving. Driving becomes the task. What are the hazards: distraction, slips getting in or out of a vehicle, backing, ergonomics/strain if driving long distances, being hit, hitting something, and so on. Then, for each of those items identify the precautions: no talking on your cell phone, no checking emails or texting, no eating or smoking while driving, wear your seatbelt, exit the vehicle with both feet on the ground, check conditions around you, use a spotter if you cannot see behind you, etc. You may even want a separate column just to list personal protective equipment needed for the job.
JHAs can be very time consuming, so prioritize the jobs or tasks that need that kind of evaluation. You may prioritize based on injuries, near mis-haps, employee concerns or new tasks where you want to identify hazards and any personal protective equipment up front.
If you want to learn more, OSHA has a whole booklet on JHAs: https://www.osha.gov/Publications/osha3071.pdf
Download the article: Respirator Requirements – October 2014