Professional Documents
Culture Documents
09 OHS Journal Sep 2012
09 OHS Journal Sep 2012
INCENTIVES:
Why OSHA’s Concerned 1
16
6
CHEMICAL SAFETY/MSDS:
Advances in Global SDS
Management 26 6
VISION PROTECTION:
Going Beyond Z87.1 36
ELECTRICAL SAFETY:
7 Considerations
for Designing a
Safe Workplace 42
www.ohsonline.com
EDITORIAL STAFF
H
EDITOR Jerry Laws
ere’s an interesting challenge for workshop agreed PPE for the fire service is PRINT MANAGING EDITOR Ronnie Rittenberry
PPE manufacturers: the greatest need, according to the report. WEB MANAGING EDITOR Brent Dirks
The July issue of NFPA’s Electric (Grant’s report says the towing and salvage E-NEWS EDITOR Tyler Thurston
Vehicle Safety Training newsletter industry “is highly decentralized with over CONTENT DEVELOPMENT TEAM Cindy Horbrook
contains information sure to be of interest 30,000 operators, and reaching them with Elizabeth Freed
to many, if not all, emergency responders. training and education materials has inher- Ariel Brouillard
that the National Fire Protec- sources supplied by more than PRODUCTION MANAGER Teresa Antonio
Research Foundation pre- OSHA’s jurisdic- these emergencies is not crys- NORTHEAST & SOUTHEAST Jenna Conwell
DISTRICT SALES MANAGER 610-436-4372
pared the report. tal clear, at least not yet. Fire-
Participants in the work-
tion in these fighters employed by publicly
MID-ATLANTIC DISTRICT Rick Neigher
SALES MANAGER/ 818-597-9029
shop represented organiza- emergencies is funded fire departments are ONLINE SALES DIRECTOR
tions including NHTSA, not crystal clear, typically outside their jurisdic- SECURITY, SAFETY AND ENVIRONMENTAL PROTECTION GROUP
NFPA, UL, PPE manufactur- tion, but tow and salvage op- PRESIDENT & GROUP PUBLISHER Kevin O’Grady
ers, motor vehicle manufac-
at least not yet. erators employed by private- GROUP CIRCULATION DIRECTOR Margaret Perry
turers, EMS organizations, and the New sector companies are within in, the report GROUP MARKETING MANAGER Susan May
York State Police. The agenda addressed notes. “In summary, federal OSHA is just
PPE currently used by firefighters, current now becoming aware of the EV issue, and
electrical PPE, existing electric vehicle they will need more time to study the scope PRESIDENT & Neal Vitale
emergency response guidance and tactics, of the topic to clarify how OSHA will apply,” CHIEF EXECUTIVE OFFICER
and analysis of specific hazards responders it states. SENIOR VICE PRESIDENT & Richard Vitale
CHIEF FINANCIAL OFFICER
may face. To read it, visit www.nfpa.org/assets/files//
EXECUTIVE VICE PRESIDENT Michael J. Valenti
Tow operators who provide roadside Research%20Foundation/EVPPEWorkshop-
assistance may sometimes be first on the Part1.pdf. VICE PRESIDENT, Christopher M. Coates
FINANCE & ADMINISTRATION
scene of an emergency; law enforcement JERRY LAWS
VICE PRESIDENT, Erik A. Lindgren
and EMS often are. But participants in the jlaws@1105media.com INFORMATION TECHNOLOGY &
APPLICATION DEVELOPMENT
VICE PRESIDENT, David F. Myers
EVENT OPERATIONS
Occupational Health & Safety (ISSN 0362-4064) © Copyright 2012 by 1105 Media, Inc. All rights re- Direct your Media Kit requests to: CHAIRMAN OF THE BOARD Jeffrey S. Klein
is published monthly by 1105 Media, Inc., 9201 served. Printed in the U.S.A. Reproductions in whole Lynda Brown
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CIRCLE 22 ON CARD
© 3M, 2012. All rights reserved. 3M and The power to protect your world are trademarks and service marks of 3M Company. Used under license in Canada.
Safety Features
Breakaway zippers in coveralls and outerwear allow
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accident. There is no exposed metal on the interior
of any garment. All garment components—thread,
buttons, pocketing—are FR.
resistant garments for safety, storage. The roomier pant legs fit easily over work
boots. Wider belt loops on pants make it easier
to slide a utility belt through.
function, style and comfort.
Flame-resistant (FR) garments are unique in that
they need to be practical for daily wear, but also
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wear. This focus has resulted in an understanding
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some of the ways in which Workrite builds a more Comfort Features
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when reaching over head, and the wider waistband
on pants prevents rollover.
© 2012 Workrite Uniform Company
800/521-1888 | www.workrite.com
CIRCLE 20 ON CARD
www.ohsonline.com
Meeting the Challenge of
General Industry Fall Protection
For general industry, the trigger height for providing fall protec-
tion is 4 feet — something OSHA has consistently reinforced for
more than 30 years. Some employers still have trouble comply-
ing, however. J.J. Keller & Associates, Inc. workplace safety
Editor Jennifer Stroschein explains what is required and how to
implement a program to prevent falls.
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CIRCLE 28 ON CARD
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CIRCLE 27 ON CARD
sideration, we believe that Whitney Brew- ton’s industrial complex,” Coats said. “MCR
ster is the best person to lead this agency fits into our long-range industrial growth
into the future,” said Victor Vandergriff, plan perfectly. They are exactly the type of
the department’s board chairman. The business partner we want and will continue
agency has about 760 employees, a bien- to pursue. We sincerely appreciate their
nial budget of approximately $300 mil- investment and extend a very warm com-
lion, and more than $1 billion in annual munity welcome to MCR, their employees,
revenue collections. and the Crews family.”
Groundbreaking Marks
MCR’s Expansion Awards &
Officials of Memphis, Tenn.-based Shelby
Group International and several elected
Hilliard Crews, founder of Shelby Group Interna-
tional; Jason Crews; and Stacy (Crews) McGee Recognition
participated in the June 28 groundbreaking
officials, including the mayor of Piperton, ceremonies. ■ Morneau Shepell received an “Innova-
Tenn., Henry Coats, took part in ground- tion of the Year” award for its My EAP mo-
breaking ceremonies June 28 for an ex- center, according to the company. bile device app when the Employee Assist-
panded headquarters of MCR Safety and The distribution center will be on 50 ance European Forum held its annual
a state-of-the-art distribution center. Both acres of land in Piperton, initially 500,000 conference in Athens, Greece this year. The
buildings are scheduled to be completed in square feet in size but capable of being ex- free app is available globally and provides
summer 2013. panded to twice that size. It will house the users with clinically based health and well-
The headquarters will be located in Col- Innovations Technology Center Lab, sam- ness information, interactive tools, and the
lierville at Schilling Farms and will include ple room, and all production and packag- opportunity to connect with counselors on
45,000 square feet of Class A office space ing functions. a variety of work, health, and life issues.
with ample room for growth, training facil- “MCR’s distribution facility will imme- Visit www.shepellfgi.com/myeap for addi-
ities, product showrooms, and a conference diately become the cornerstone of Piper- tional information.
I did !
JULIE CARTER, GRADUATE 2010
The Mundy Companies
www.ColumbiaSouthern.edu/OSHMag | 877.845.7780
Recognizedd by:
b Visitit our website
Visit b it att www
www.ColumbiaSouthern.edu/Disclosure
CColumbiaSouthern
l bi S th edu/Disclosure
d /Di l for
f information
i f ti about
b t gainful
i f l employment
l t iinclu
including
l cost of attendance,
on-time graduation rates, occupational opportunities, median student debt and other important information about CSU programs.
Circle 8 on card.
14
CIRCLE 38 ON CARD
O
everyone’s dismay, there is no cookie-cutter program
SHA recently published an article disparag- or solution. Each incentive program should be built
ing company safety incentive programs. This to complement the company’s existing safety plan,
is not a new stance — it has always been the goals, and objectives. Ideally, safety-based incentive
administration’s position. However, the reg- programs should be designed to emphasize positive
ulatory agency’s new Memorandum issued on March reinforcement and leading indicators, such as safe be-
12, 2012, Employer Safety Incentive and Disincentive haviors, and not lagging indicators, such as recordable
Policies and Practices, directs field compliance officers incidents or lost-time injury reduction goals.
and “whistleblower” investigative staff to beef up their As you reflect back on your company’s program,
enforcement of 29 CFR 1904.35(b)(1), which address- consider the following questions:
es work-related reporting of injuries and illnesses, Is your safety incentive program one component
and Section 11(c), which contains the whistleblower of a well-thought-out and effectively administered
statues. This memorandum is targeted at employers risk management program? Does your incentive pro-
who have implemented safety incentive programs that gram include the measurement of leading indicators
discourage workers from reporting injuries and have and/or safety activities, such as safe behavior observa-
a policy that requires disciplinary action against em- tions, safety meeting attendance, etc.?
ployees who are injured on the job, violate injury re- Is your incentive program consistently well sup-
porting guidelines, or violate a safety rule. ported by top management because it increases safety
Excerpts from the memorandum state: “There are awareness and has a positive impact on the safety cul-
several types of workplace policies and practices that ture? Does your company involve employees when
could discourage reporting and could constitute un- developing the program? Does your company regu-
lawful discrimination and a violation of federal stat- larly provide feedback to employees on performance
ues…. OSHA has received reports of employers who and the progress being made toward company goals?
have a policy of taking disciplinary action against em- When asked, could employees from all levels of the
ployees who are injured on the job, regardless of the organization explain the purpose and goals of the pro-
circumstance surrounding the injury. Reporting an gram? Do your employees understand that the pro-
injury is always a protected activity.” gram has a genuine purpose and life span, as opposed
The key to remember is that OSHA is not truly to expecting or feeling entitled to the incentives? Is the
against safety incentive programs. It is against pro- program regularly evaluated for effectiveness?
grams that discourage workers from reporting ac- If you answered no to any of these questions, you
cidents or injuries. In the memo, Deputy Assistant may want to further evaluate your program to deter-
Secretary Richard E. Fairfax states, “While OSHA mine whether you may be able to improve upon it in
appreciates employers using safety as a key manage- any way. The bottom line is that safety incentive pro-
ment metric, we cannot condone a program that en- grams do work and are still an effective tool in the
courages discrimination against workers who report workplace — when they are executed in the right way,
injuries.” OSHA believes that if employees do not feel with the right goals and outcomes. Safety incentives
free to report injuries or illness, then it puts a com- are only one part of an overall safety-minded culture
pany’s entire workforce at risk. Most insurance carri- whose goal should be to mitigate unsafe acts and en-
ers tout the same position. The phenomenon of non- courage safe worker behaviors.
reporting of injuries due to policy or pressure actually Simply dangling gift cards, free lunches, and fa-
has a moniker in the insurance industry — it’s called vorite sports team hard hats are no longer accept-
the “bloody pocket syndrome” (so named after an ex- able forms of motivation to encourage accident-
ample of when an employee cuts a finger and puts his free days. By getting employees involved in the
hand in his pocket, instead of reporting the injury, in process of creating a safe work environment, one
fear of blowing his chance or his team’s chance at some supported by top management, companies will be
incentive or prize). more likely to develop a program that truly encour-
However, since the emphasis of the OSHA directive ages and promotes workplace safety while not vio-
is expanded to include protection for employees who lating OSHA statutes.
violate injury reporting timeliness rules, it remains to A list of the most common potentially discrimina-
be seen if this emphasis has unintended consequences, tory policies can be found at http://www.osha.gov.
such as increased claim cost from late reporting.
All of this talk about effective safety incentive Henry Wright, MBA, CFPS, CECD, and Michelle Bark-
programs begs the question, how would your incen- er, ARM, CDT, are employed by BB&T Insurance Ser-
tive program fare if evaluated by OSHA? Much to vices Inc. They are Authorized OSHA Outreach Trainers.
W
BY ROBERT BROWN processes, though in recent years it has become less
elding in the workplace can present popular in industrial applications. However, it is still
significant health hazards unless the widely used for welding pipes and tubes, as well as re-
potential (and actual) exposures to pair work. It is also frequently well suited, and favored,
welding fumes are properly identified, for fabricating some types of metal-based artwork.
evaluated, and controlled. The sheer numbers of the ■ Arc Welding is popular due to low costs. An
types of exposure, both acute and chronic, justify a electric current is created between the welding device
thorough review of the possibilities, the hazards of ex- and the materials to be welded, creating an “arc.”
posure, and potential controls. This article, while not ■ Electroslag Welding is a fast welding process
covering all of these possibilities, may at least prompt used to join large materials, such as thick steel plates.
environmental, health, and safety professionals to ■ Flux-Cored Welding is an alternative to “stick
consider these exposures, evaluate actual exposures, welding.” Flux-cored is used often in automatic, fast-
and implement appropriate protective measures. speed applications, used primarily in construction en-
vironments.
What are Welding Fumes? ■ Gas Metal Arc Welding is another automatic
Welding is the method typically used to join two or welding process. The application, used widely in auto-
more metal parts through the utilization of heat. The mobile repair and manufacturing, involves a welding
heat causes the metals (or some other material) to melt gun that automatically feeds the weld metal through
and, after cooling, to create a strong connection be- the gun for use. The gun also distributes a shield gas
tween the metal parts. Welding fumes are essentially a for protection from the natural elements.
mixture of (somewhat complex but often predictable) As the chart makes clear, there are a wide variety
metallic oxides, fluorides, and silicates. While this is of fumes, gases, and organic vapors to be considered
true, other contaminants and coatings can present an when determining exposures during welding op-
even more complex mixture from which people need erations. Although this article is focused on welding
to be protected. It should be noted that: fumes and related exposures, be certain to keep in
■ The welding process may involve the metals mind some of the other hazards related to welding,
themselves. including eye damage from arc flash, thermal burns,
■ The welding process may also involve the use radiation burns, fires, and electrical hazards.
of a third agent, or “filler” or “flux.”
■ Welding may occur on new clean stock metal, Control Options
new metal with residual compounds from manufac- Options to protect welders from exposure to weld-
ture, and/or used or existing metal with residual con- ing fumes include, in accordance with the hierarchy
tamination from operations, including coatings. of controls: ventilation, which may include general
and/or local ventilation (engineering controls); train-
Are All Fumes the Same? ing and restricted work times/locations (administra-
The answer to this is no, unfortunately. While gener- tive controls); and respiratory protection, either air-
alizations can be made for mild steel, stainless steel, purifying or supplied air (PPE). Only you can decide
and various nickel alloys, the truth is that the answer which is most appropriate for your workplace and the
is not so simple. The potential for exposure could in- exposure profiles expected.
clude such fumes as aluminum, beryllium, cadmium,
chromium (including hexavalent chrome), copper, Robert Brown, CIH, CSP, is president and owner of
fluorides, iron oxides, lead, manganese, nickel, va- Robert Brown & Associates, Concord, Calif. For infor-
nadium, and zinc oxides. In addition, the potential mation on welding fumes, EHS audits, IH Sampling
for exposure to both source gases and resulting gases Strategies, or other EHS issues, call 510-860-5491 or
from the welding process are possible. email bbrown1960@gmail.com.
Table I: Health Effects of Fumes, Gases, and Organic Vapors During Welding1
19
A
BY AMANDA WHITE Health and Mental Hygiene awarded $67 million to
fter a grueling, three-month debate over the a consortium of vendors led by Noridian, including
hearing on the controversial Patient Protec- Curam, Connecture, and CNSI, in February 2012 for
tion and Affordable Care Act (ACA), the the design, development, and implementation of a
U.S. Supreme Court decided to uphold the benefit exchange.
law, including the individual mandate. However, the ■ Washington: The Washington Health Care
court is making it much clearer that the penalty serves Authority awarded $63.1 million to Deloitte in April
more as a tax — a mechanism Congress has power to 2012 for its benefit exchange system.
exercise. Under this language, Americans are not nec- ■ New York: The New York State Department of
essarily being “forced” to purchase health insurance; Health awarded $37 million to Computer Sciences
they are merely encouraged. Corporation (CSC) for its benefit exchange system.
The court also upheld Medicaid expansion, which ■ Mississippi: The Mississippi Comprehensive
will soon allow individuals making up to four times Health Insurance Risk Pool Association awarded
the poverty line to get Medicaid coverage. Under the eHealthinsurance Services Inc. in June 2012 for Phase
current Medicaid program, individuals cannot sign 1 of an insurance exchange portal.
up for plans on the basis of being poor alone; they ■ Florida: The state awarded $68 million to Xe-
also must fall under categories such as being pregnant, rox in June 2012 for building a Small Business Health
a child, or over the age of 65. Options Program (SHOP) called Florida Health
But for state governments, the most critical im- Choices; however, Gov. Rick Scott opposes creating a
pact of the decision has to do with health insurance private insurance exchange.
exchanges (HIXs). States are expected to have these States are expected to submit letters of intent, or
online marketplaces up and running by January 2014. blueprints, that confirm their intent to run a state-
The U.S. Department of Health and Human Services based or partnership exchange. The blueprint has two
(HHS) has awarded hundreds of millions of dollars to components: the declaration letter and the exchange
states to help them set up their exchanges and will be application. The blueprints must be received by the
doing so through 2014. That doesn’t mean, however, Center for Consumer Information and Insurance
that states are ready. Oversight (CCIIO) by Nov. 16, 2012.
In March, many states decided to pause planning Hawaii was the first state to submit a letter of in-
for their insurance exchange in anticipation of the tent to have an insurance exchange up and running
ruling. States including Alaska, Iowa, and Wyoming by the Jan. 1, 2014, deadline. Hawaii’s Web portal is
expected the court to find the health care reform law expected to integrate with the state’s new Medicaid
unconstitutional but believed an insurance exchange eligibility system. The state recently awarded SH Con-
system was a viable solution for the uninsured. Other sulting LLC a $244,000 contract for system support
states — specifically Texas, Maine, and South Carolina consulting services for the new system.
— were not so eager. They have made extremely slow Because there is very little time left, states may
progress on setting up a benefit exchange. look to different procurement strategies in order to
Republican lawmakers in Maine approved a bill expedite the contracting process. For instance, Or-
this spring that delayed state action on the state’s in- egon utilized a special procurement for its insurance
surance exchange. As a result, that state faces a con- exchange, which, as mentioned above, was awarded
siderably high risk in being forced to implement the to Oracle. The state released the solicitation on May
federally run exchange, produced by CGI Group Inc. 23, 2011, and closed the special procurement on May
— the law’s penalty for states that fail to create their 30, 2011. The special procurement, released by the
own is to have one that is federally run. Oregon Health Authority, allowed the state to be flex-
There are many states that have taken great strides ible and swift in meeting the deadlines set by the Early
in setting up their HIX. These states already have con- Innovator Grant.
tracted with vendors to set up theirs: Other strategies may include states adding insur-
■ Oregon: The Oregon Department of Human ance exchange components onto existing contracts,
Services awarded Oracle an $8.7 million contract in such as for eligibility systems. Much of the informa-
June 2011 for its insurance exchange system. tion stored in these systems overlaps, which may
■ California: The California Health Benefit Ex- make existing system contractors the most knowl-
change awarded Accenture a $359 million contract in edgeable regarding what infrastructure will allow for
Scan to learn
about the Breathe
Easier Program.
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optimal interoperability.
Another technique states may choose to
use is procuring for multiple components of
the exchange under the same contract, such
as call center and program integration ser-
vices. The Colorado Department of Health
Care Policy and Financing utilized this
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CIRCLE 25 ON CARD
8/10/12 12:49 PM
CHEMICAL SAFETY/MSDS
G
chain analysis, and integration with internal tools
lobal environmental, health, and safety (Authoring, BOM, Purchasing…).
(EH&S) management can be an intricate
tightrope walk with many challenges lurk- Global SDS Management,
ing to disrupt its delicate balance. Potential Implementation Process
obstacles include evaluating differing global strate-
gies, managing changing regulations, varying local
resources and expertise, local infrastructure, and
cultural considerations. With these considerations
in mind, taking a corporate global safety data sheet
(SDS) management strategy and implementing it lo- 1. Research Current Systems. There is usually a
cally can seem daunting. However, with a thorough large variance of systems in place already — paper-
understanding of why global SDS management is so based, Access/Excel, third-party applications, and ap-
beneficial, knowledge of best practice methods for plications built by in-house IT teams. How those sys-
developing a system, and a few tips for circumvent- tems are used and the documents and data held within
ing common pitfalls, this worthwhile process can be these systems will need to be included in your transi-
dramatically streamlined. tion evaluation. Additionally, the people in charge of
those systems will be the cornerstone of local adoption
Reasons for Global SDS Management for your new system, so engage their expertise.
Let’s first describe what global SDS management 2. Regulatory Awareness. The next portion is be-
means. It is a set of corporate guidelines, coupled ing aware of the regulations involved and your respon-
with a comprehensive management system to handle sibilities within each country. While elements of SDS
a company’s SDSs for all global locations. SDSs are management are similar throughout the world, there
stored, viewed, and downloaded from a centralized are country-specific requirements which should be ac-
access point, in addition to document management counted for in any new program. Some examples:
and supplier relations procedures designed to ensure ■ Languages: Ensure employees have access to
there is an SDS for every product on site, and those SDSs in local languages, possibly multiple languages per
SDSs are kept current. The application and supporting location, which can be the case in Canada or Belgium.
resources should to be synchronized to ensure success. ■ Suppliers’ updating obligations: A supplier’s
Once a global system is in place, many corporate and obligation to downstream users differs in relation to
local advantages are achieved. These rewards justify when it needs to re-author or send an updated SDS. In
the collaborative effort of rolling out such a compre- the United States, an SDS needs to be updated within
hensive system. 90 days when there are significant changes to its infor-
■ Compliance Administration. Compliance is at mation. In Canada, an SDS needs to be updated every
the heart of any SDS management system. Organizing three years regardless if there are changes required.
this through one system allows for centralized admin- In Europe, it needs to be updated as soon as possible
istration to ensure local and corporate due diligence. and sent to customers that have purchased the prod-
■ Centralization. One system for all locations uct within the last 12 months. The United States and
and departments allows for inventory, data, and SDS Canada have no requirements for suppliers to provide
consolidation and corporate transparency. revised SDSs to previous customers in the absence of
■ Productivity. Removal of task replication be- subsequent sales.
tween locations and reduction of overall SDS manage- ■ EU REACH: European extended SDSs can
ment effort enables employees to a focus on other tasks. have multiple Exposure Scenarios attached, creating
■ Cost Reduction/Avoidance: documents of up to hundreds of pages long. Your sys-
• Increased overall efficiency removes opera- tem should handle documents of this size. In addition
tional costs to this, while the law states that Exposure Scenarios
• Increased compliance lowers exposure to are to be incorporated into the SDS, it isn’t often the
regulatory body fines, employee lawsuits, and the case in practice. Employees should learn how to load
compromising of a company’s PR and brand. Exposure Scenarios with associated SDSs.
■ Data repository. A large repository of SDSs ■ Safety Cards: Many countries (the United
and product data will be quickly amassed. The cen- Kingdom, Germany, etc.) require employees to access
RUGGED WORKERS
RUGGED ENVIRONMENTS
TRUSTED PROTECTION
www.uvex.us
CIRCLE 35 ON CARD
Uvex® brand safety eyewear is offered for sale by Honeywell Safety Products exclusively in the Americas. facebook.com/UvexByHoneywell
See the ing how it will affect their work tasks, and, importantly, outline the
overall benefits.
the best anti fog proach can be segregated by a number of factors, including geog-
raphies, business unit/location groups, regulatory landscape, and
current systems.
Download our whitepaper at During any rollout, keep previous systems in place until the new
www.defogitworks.com/HowAntifogWorks one is launched and employees are fully trained. This will ensure
employees do not lose access to SDSs during the implementation;
this avoids a sense of panic caused by change without a transition
period. This being said, an official “turn off ” date is recommended
once training for your new system is complete.
)HUVT*\[[PUN,KNL*\[9LZPZ[HUJLHUK4H_7S`HYLYLNPZ[LYLK[YHKLTHYRZVM)HUVT;YH__HUK[OL;YH__ [YLHKHYL[YHKLTHYRZVM)HUVT
+`ULLTHPZHYLNPZ[LYLK[YHKLTHYRVM9V`HS+:45=)HUVT
CIRCLE 24 ON CARD
Major Changes in the OSHA HazCom Standard ■ (j)(2) Chemical manufacturers, importers, dis-
Considerable testing of chemicals that are tributors, and employers shall be in compliance with
handled in the workplace may be required. all modified provisions of this section no later than
June 1, 2015.
BY STEVEN J. LUZIK AND RICHARD W. PRUGH
A
■ (j)(2)(i) After Dec. 1, 2015, the distributor shall
s stated in the OSHA Fact Sheet entitled not ship containers labeled by the chemical manufac-
“Hazard Communication Standard Fi- turer or importer unless the label has been modified
nal Rule,” new changes to OSHA’s Hazard to comply with paragraph (f)(1) of this section.
Communication Standard (HCS) are bring- ■ (j)(2) (ii) All employers shall, as necessary, up-
ing the United States into alignment with the Globally date any alternative workplace labeling used under
Harmonized System of Classification and Labeling of paragraph (f)(6) of this section, update the hazard
Chemicals, or GHS, and further improving safety and communication program required by paragraph (h)
health protections for America’s workers. (1), and provide any additional employee training in
HCS 2012 still requires chemical manufacturers accordance with paragraph (h)(3) for newly identified
and importers to evaluate the chemicals they produce physical or health hazards no later than June 1, 2016.
or import and to provide hazard information to em- ■ (j)(3) Chemical manufacturers, importers,
ployers and workers by putting labels on containers distributors, and employers may comply with either
and preparing safety data sheets. The old standard al- 1910.1200, revised as of Oct. 1, 2011, or the current
lowed chemical manufacturers and importers to con- version of this standard or both during the transi-
vey hazard information on labels and Material Safety tion period.
Data Sheets in whatever format they chose. The modi-
fied HCS provides a single set of harmonized criteria Hazard Classification
for classifying chemicals according to their health and As can be seen in the following outlines to the ap-
physical hazards and specifies hazard communication pendices to the HCS, a very large amount of infor-
elements for labeling and safety data sheets. mation is required by the Globally Harmonized Sys-
OSHA published a Notice of Proposed Rulemak- tem for hazards communication and is now required
ing to update the Hazard Communication Standard by OSHA.
in September 2009 and held public hearings in March Health Hazards Criteria (Mandatory Appendix
2010. Then, on March 20, 2012, a revised HazCom A of 29 CFR 1910.1200)
rule was filed at the Office of the Federal Register, and The following sections provide detailed descriptions
this rule took effect on May 25, 2012. Essentially, there of hazards and quantitative criteria for health hazards:
are three major changes to the previous version of the
HCS standard. These include: Section Title
■ Hazard classification: The new mandatory Ap- A.0 General Classification Considerations
pendices A, B, C, and D greatly expand the previous A.1 Acute Toxicity
Appendices A and B.
A.2 Skin Corrosion/Irritation
■ Labels: Chemical manufacturers and import-
ers will now be required to provide a label that in- A.3 Serious Eye Damage/Irritation
cludes a harmonized signal word, a pictogram, and a A.4 Respiratory or Skin Sensitization
hazard statement for each hazard class and category. A.5 Germ Cell Mutagenicity
■ Safety Data Sheets: MSDSs will now be re-
A.6 Carcinogenicity
ferred to as SDSs and will now have a specified
16-element format, including 11 elements that will A.7 Reproductive Toxicity
be enforced by OSHA. A.8 Specific Target Organ Acute Toxicity
■ Information and training: To facilitate under- A.9 Specific Target Organ Chronic Toxicity
standing of the new system, the new standard requires
A.10 Aspiration Hazards
that workers be trained on the new label elements and
safety data sheet format. Although paragraph A.0.2.1 states, “There is no
requirement for testing chemicals,” it is very likely that
Implementation Dates quantitative data may not be available to determine
The following dates for implementation of the HCS whether or not a particular chemical would meet the
are given in paragraph (j) of the standard: criteria for a “hazardous material.” Thus, it is also very
■ (j)(1) Employers shall train employees regard- likely that some type of testing would be required for
ing the new label elements and safety data sheets for- chemicals that are handled in the workplace to deter-
mat by Dec. 1, 2013. mine the extent of — or absence of — a hazard, par-
www.honeywellsafety.com/culture
CIRCLE 30 ON CARD
ticularly for the training of employees. tory Appendix C of 29 CFR 1910.1200) Section Title
Physical Hazards Criteria (Manda- The lower chart provides detailed de- B.1 Explosives
tory Appendix B of 29 CFR 1910.1200) scriptions of the requirement for the label- B.2 Flammable Gases
The top chart on this page provides de- ing of materials that present one or more
B.3 Flammable Aerosols
tailed descriptions of hazards and quantita- of the hazards described in Appendices A
tive criteria for physical hazards. and/or B in the OSHA standard. B.4 Oxidizing Gases
If there is any likelihood that a chemical For each of the hazards in Sections B.5 Gases Under Pressure
could be described as being within one or C.4.1 to C.4.30, a Hazard Category, a Signal B.6 Flammable Liquids
more these categories, considerable testing Word, and a Hazard Statement are suggest-
B.7 Flammable Solids
may be required. This could include flash ed, together with the required Pictogram.
point, heat of combustion, heat of decom- Also, Precautionary Statements are sug- B.8 Self-Reactive Chemicals
position, burning rate, thermal stability, gested for Prevention of injury, Response B.9 Pyrophoric Liquids
reactivity, and/or corrosivity. to exposure, Storage requirements, and B.10 Pyrophoric Solids
Allocation of Label Elements (Manda- Disposal methods.
B.11 Self-Heating Chemicals
B.12 Water-Reactive Materials
[EXTINGUISHER
B.13 Oxidizing Liquids
B.14 Oxidizing Solids
TRAINING B.15
B.16
Organic Peroxides
Corrosive to Metals
CLEAN. SAFE. EFFECTIVE. Section Title
C.1 Supplier’s Information
C.2 Labeling Requirements
C.2.1 Signal Word
C.2.2 Hazard Statement
C.2.3 Pictogram Requirement
C.2.4 Precautionary Statement
C.3 Supplementary Hazard
Information
C.4 Specifications for Warnings
C.4.1 to Specific Requirements for
C.4.13 Health Hazards
C.4.14 to Specific Requirements for
C.4.30 Physical Hazards
Safety Data Sheets (Mandatory Ap-
pendix D of 29 CFR 1910.1200)
In the past, the requirements for quan-
titative data in MSDSs have been limited to
vapor pressure, flash point, and threshold
limit value for inhalation toxicity. How-
ever, the revised HCS requires much more
quantitative data in SDSs (note that the
TRAIN MORE PEOPLE MORE EFFECTIVELY IN LESS TIME word “Material” is removed from the title
WITH A BULLEX SYSTEM. of these documents).
A statement that has appeared in previ-
The I.T.S. Xtreme™OLYHÀUHH[WLQJXLVKHU SURSVLQFOXGHDWUDVKFDQVWRYHWRS ous MSDS requirements has been retained
WUDLQLQJV\VWHPSURYLGHVVDIHHIIHFWLYH HOHFWULFPRWRUDQGSDLQWORFNHU in the updated HCS, namely: “If no rel-
KDQGVRQÀUHVDIHW\OHVVRQVDW SURYLGLQJDQLQWHUDFWLYHUHDOLVWLF evant information is found for any given
\RXUFRQYHQLHQFH,QWHUFKDQJHDEOH KDQGVRQWUDLQLQJH[SHULHQFH subheading within a section, the SDS shall
clearly indicate that no applicable informa-
DOWNLOAD OUR FREE GUIDE tion is available.” Such statements — and
“Preparing Employees for a Fire Emergency” “Stable at normal temperatures and pres-
>WWW.BULLEX.COM > http://go.bullex.com/OHS9 sures” — show an absence of information
that may be critically important in the con-
©2012 Bose Corporation. The Bluetooth® word mark and logos are registered trademarks owned by Bluetooth SIG, Inc. and any use of such marks by Bose Corporation is under license. C_011004
CIRCLE 29 ON CARD
trol of hazards and should be avoided. Dili- Guidance for Carcinogenicity Hazard Clas-
gent research into the wide expanse of the
Section Title sification (Non-Mandatory Appendix E)
open literature would be needed to ensure 1 Become Familiar with the Rule The mandatory criteria for classification of
that “no applicable information is avail- 2 Identify Responsible Staff a chemical for carcinogenicity under HCS
able” to avoid the situation where OSHA 3 Identify Hazardous Chemicals are found in Appendix A.6 to this section.
would find that pertinent hazards informa- This non-mandatory appendix provides
4 Preparing/Implementing Program
tion indeed was available. additional guidance on hazard classifica-
Guidelines for Employer Compliance 4A Labels/Other Forms of Warning tion for carcinogenicity. The sections of this
(Advisory Appendix E) 4B Material Safety Data Sheets appendix are:
Appendix E has not been modified in the 4C Employee Information and Training
new HCS. However, it is likely that “Mate- Section Title
4D Other Requirements
rial Safety Data Sheet” would be replaced A Background Guidance:
by “Safety Data Sheet” and “MSDS” would 5 Checklist for HCS Compliance Humans; Animals
be replaced by “SDS.” The sections of this 6 Further Assistance [202-219-8151] B International Agency for Research
appendix are: on Cancer Classifications
C National Toxicology Program
SPEC IT
Classifications
D Equivalence Among Classifications
Conclusion
OSHA has taken a major step in adopt-
ing GHS for the U.S. HazCom Standard.
Considerable effort will likely be required
to obtain the chemical hazards data and in-
Safety On Demand formation that will be needed for SDSs and
for additional employee training.
It will be important for members of
management and technical staffs at plants
Shower & Eyewash Stations and other facilities that handle hazard-
Put Workers’ Safety First. ous materials to become familiar with the
new HCS. Several pertinent documents are
readily available at http://www.osha.gov/
20-40 gallons of tepid water hazcom/index.html.
per minute continuously
Steven J. Luzik, P.E., CFEI is a Senior Pro-
Meets ANSI Z358.1 standards kW Range
36-144 kW cess Safety Specialist at Chilworth with more
than 30 years’ experience in the area of fire
Meets UL and CSA standards and explosion hazards, including gas/vapor
ETL/cETL approved explosions, dust explosions, and fire and ex-
Flow Range
1.5-40 GPM plosion protection strategies.
Available skid mounted Richard W. Prugh, M.S.Ch.E., CSP, P.E.,
is a Senior Process Safety Specialist at Chil-
Easy to install & durable worth; he provides process safety engineering
Voltages expertise focused on chemical manufactur-
Just add power and water 480V & 600V
3 Phase Delta ing and oil/gas operations. He has extensive
experience in instrument engineering, explo-
Learn more at keltech-inc.com. sion hazards testing, explosives manufac-
turing and testing, pilot-plant supervision,
organic chemicals research, safety and fire
protection audits, and process safety con-
sulting. Since 1985, he has provided process
safety services to chemical and petrochemi-
cal plants throughout the United States and
internationally. He has presented at the Loss
Prevention Symposia more than 25 times
and is the author of the Toxicity section of
800.999.4320 / keltech-inc.com the 2008 issue of “Perry’s Chemical Engi-
neers’ Handbook.”
CIRCLE 7 ON CARD
BOLLE SAFETY
has to trail by a large distance.
BY PEGGY PITTS KROESCH AND JIM KATZ
A
ccording to the OSHA website, “Thousands 1. How can I best select protective safety eyewear
of people are blinded each year from work- based on the hazards present in the plant?
related eye injuries that could have been 2. Head sizes vary; which products provide the
prevented with the proper selection and maximum protection, performance, comfort, and
use of eye and face protection. Eye injuries alone cost style to my employees?
more than $300 million per year in lost production 3. What lens technology is most appropriate to the
time, medical expenses, and worker compensation.” environment, such as high-pressure sodium lamps,
There’s no doubt that the International Safety Equip- metal halide/mercury vapor, fluorescent, or LED?
ment Association’s recently promulgated ANSI/ISEA The simple solution may be to select protective
Z87.1–2010 American National Standard for Oc- eyewear products that meet or exceed the new ANSI
cupational and Educational Eye and Face Protection Z87.1–2010 standard, but as a manufacturer of pre-
(ANSI Z87.1-2010) has made the workplace much mium safety eyewear, we present additional and im-
safer for many employees. Going into effect just over portant factors to consider. We provide innovative
two years ago, the new standard updated guidelines eyewear solutions designed to provide maximum eye
last revised in 2003. protection, enhance long-term eye health, and in-
Manufacturers of safety eyewear products bearing crease workplace productivity. Meeting the provisions
the new standard must provide proof of protection set forth by ANSI Z87.1-2010 is both an imperative
against specific hazards, including optical radiation, and a starting point for the major players in the safety
impact and coverage, droplet and splash, and dust/ eyeglass industry. These companies possess the tech-
fine dust, as well as provide products for different nical know-how and manufacturing expertise to pro-
head sizes. The standard makes it imperative for any duce products that meet or exceed the new standards,
manufacturer of personal protective equipment to as- but that is really only half the battle.
sess all possible workplace environmental risks and As obvious as the benefits of wearing effective eye
provide tangible technological solutions within the protection may seem, too often workers provided with
parameters of the new standard. perfectly functional safety glasses fail to wear them at
To comply with the new standard, an employer all appropriate times. Therefore, the prudent course of
needs to consider a considerably more complex set of action is to examine every possible reason workers do
issues, including these: not wear protective eyewear, and then thoroughly and
Over ten million workers daily benefit from the recognized SOS SideWear®.
Protection engineered to meet or exceed current and future ANSI standards.
Features so unique that nine patents have been issued or pending in the U.S.,
China, Korea and the European Community countries.
The SafetyWing™ mitigates cuts and fractures of the eye orbit facial structure.
Optional Comfort Cushions supply customized facial conformity, blocking foreign debris.
SOS SIDEWEAR® shields easily adjusted to fit small, medium and large frames.
B-26+, B-27+, B-52+ & B-53+ comply with
OSHA 29CFR1910.133 and ANSI Z87.1
- Revised August, 2003
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MADE IN
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CIRCLE 18 ON CARD • Patent No. 5,748,278, 6,393,609 B1 and others.
The prudent course of action is to examine every safety eyewear made by an established, well-known manufacturer
with the expertise and resources to incorporate the most up-to-
possible reason workers do not wear protective date designs, you can provide workers with glasses that won’t fog.
eyewear, and then thoroughly and comprehen- Aftermarket anti-fog coatings, which are typically sprayed on,
sively address each possible issue. also can be very helpful. When using these products, safety manag-
ers and workers alike always need to remember to reapply these
comprehensively address each possible issue. coatings from time to time, because they are not permanent.
Although common sense dictates and statistical data prove Several safety eyewear manufacturers apply anti-fog coatings
that safety glasses are effective at preventing debilitating and during manufacturing. These coatings typically last for the life of
costly eye injuries, a Bureau of Labor Statistics study found that the product. We use a proprietary technology on both sides of
60 percent of injured workers were not wearing eye protection at all lenses.
the time of an accident.
Comfort is King
Lost in a Fog “They don’t fit well.” “They’re too heavy.” “They pinch my nose/
A September 2011 article in this magazine titled “Coming Out of temples.” The chorus of comfort-related complaints about safety
the Fog” identified fogging as a significant reason that workers failed glasses is common, numerous, and persistent. Certainly, glasses
to wear protective eyewear. In fact, a 2009 study cited in the article that cause the wearer discomfort aren’t likely to remain in place for
named fogging as the number one vision-related reason for not more than a few minutes, let alone hours on end.
wearing safety glasses. Fortunately, there are several methods of suc- Here again, the best advice is to look for established brands
cessfully minimizing the buildup of moisture that causes fogging. with recognized design capabilities and manufacturing process-
A good place to start is with eyewear that is carefully designed es that utilize the latest and best materials. Reliable indicators
to improve air flow and promote ventilation. Although air flow include the following: flexible temples (the parts of the glasses
may seem an obvious solution, many products on the market still that extend over the ears, commonly referred to as “arms”), soft
rely on antiquated shapes with little or no venting. By purchasing material strategically located at some or all points of contact,
Circle 39 on card.
38 Occupational Health & Safety | SEPTEMBER 2012 www.ohsonline.com
CIRCLE 34 ON CARD.
For more information, call 1-800-336-3255 or visit www.honeywellsafety.com.
©2012 Honeywell International Inc. All rights reserved.
adjustable nose pads, and high-quality hinges. dards and looks great, as well. It takes the kind of attention to detail
that can be attained only by years and years of industry experience.
Seeing Everything Clearly
Clear, distortion-free vision is important to just about all workers, Putting It All Together
regardless of the complexity of the tasks they perform. The level of From Kia to Mercedes-Benz, all automobiles sold in the United
visual acuity provided by safety glasses is determined by several key States have to meet the same safety standards. And while there’s no
factors. Lens material is at the top of the list. Manufacturers have doubt the former makes a perfectly acceptable car, who wouldn’t
several good choices, but polycarbonate lenses dominate because opt for the latter, given the choice? Despite some very obvious flaws
of a near-perfect combination of shatter resistance, light weight, in the analogy, the same basic idea holds true for protective eye-
and optical clarity. wear. Fortunately for safety managers—and bean counters—the
In many industrial and outdoor workplaces, glare resulting gap in price between premium safety glasses and ordinary brands
from reflected light can become a serious issue. Several brands of- is nearly imperceptible when the value of workers actually wearing
fer the option of polarized lenses, which work by absorbing per- them is factored into the equation.
pendicular light rays, the main cause of glare. And while polarized The bottom line is this: The first and most important consid-
lenses may cost more, the benefits can far outweigh the costs. eration when purchasing protective eyewear is that the product
chosen meet the ANSI Z87.1-2010 standard. That, however, should
Style Counts not be where the decision ends. Premium safety glasses offer real-
Completely subjective? You bet. But how long do you think world advantages that far exceed any difference in price, and that
your employees will wear safety glasses that make them look makes them your best value.
like Mr.—or, worse, Ms.—Magoo? Inarguably, form must follow
function. That doesn’t mean, however, that form has to trail by Peggy Pitts Kroesch is Marketing/Trade Marketing Manager for
a large distance. Attractive shapes are not simply the product of a Bolle Safety/Bolle Tactical, Bushnell Outdoor Products. Contact her
designer with a keen sense of style. Advanced designs, manufac- at pkroesch@bushnell.com or 913-752-3496. Jim Katz is principal
turing techniques, and engineering skills are necessary to produce of Breakaway Communications, a firm that specializes in the eye-
protective eyewear that meets or exceeds all of the applicable stan- wear and sporting goods industries.
It’s hot out there, and if you have on FR workwear, it can feel like an inferno. That’s why we designed GlenGuard®
FR fabrics to be the lightest-weight, most comfortable FR fabrics in their class. GlenGuard FR exceeds both
governmental and industry safety standards, plus, it’s solution-dyed to maintain its color for the life of the uniform.
So don’t compromise. Specify workwear made of GlenGuard FR for unsurpassed comfort and personal protection.
1-800-630-3759 | glenguard.com
Circle 1 on card.
40 Occupational Health & Safety | SEPTEMBER 2012 www.ohsonline.com
A
ergy when working on the equipment. This reduced
s more and more employers perform arc overcurrent mode minimizes arc flash hazards during
flash assessments of their facilities to keep maintenance. When working around a motor, it’s a
workers safe and meet OSHA and NFPA good practice to use this feature so that overcurrent
70E requirements, they usually discover and ground fault conditions are stopped before they
that they have a lot of dangerous equipment or areas create safety hazards.
where workers must use heavy and bulky PPE. Many
employers are seeking ways to eliminate or minimize 3. Use Current Limiting Devices
these hazards to keep workers safe, minimize down- Fuses and circuit breakers that are “current limiting”
time, and increase productivity. will limit the amount of let-through current during
What’s more, as plant staffs grow leaner, younger a fault or arc flash event. That’s because a UL Listed
workers often don’t have the benefit of working side current-limiting device opens very quickly — within
by side with experienced maintenance workers and the first half-cycle of a fault (8.3 msec). Its fast action
electricians who deeply understand electrical safety. limits the amount of current that can flow through the
To help keep workers safe, managers can design safety circuit and reduces the destructive energy of a short or
into the facility’s electrical system. This article cov- arc flash. Most standard non-current-limiting circuit
ers seven considerations for designing safety into the breakers can take up to 6 AC cycles (0.1 second) to
workplace, ranging from fuses and grounding to re- open under short circuit conditions — a minimum of
lays and arc flash assessments. 12 times longer than a typical current-limiting fuse or
current-limiting circuit breaker.
1. Switch to Resistance Grounding
More plants and commercial facilities are switching 4. Use Indicating Fuses and Fuse Holders
from traditional solidly grounded electrical systems Typically, finding which fuse has opened requires
to resistance-grounded systems, in which a large re- poking around an energized electrical panel with a
sistor is placed between the wye transformer and tester. Avoid this unnecessary risk by using indicating
ground. Such resistors are designed to limit the cur- fuses or fuse holders. Indicating fuses have a dark spot
rent that can flow to ground to about 5A, too low to that appears when the fuse opens, and indicating fuse
allow an arc flash to develop in a phase-to-ground holders point out open fuses with a bright neon lamp
short. In the “Industrial Power System Grounding or with a signal to a PLC. These are available from a
Design Handbook,” Dunki-Jacobs, et al., estimate that number of suppliers. In addition, using touch-safe de-
95 percent of all electrical faults are phase-to-ground vices or fuse holders with covers also reduces expo-
faults. Therefore, resistance grounding has a dramatic sure to live parts.
effect on electrical safety.
There are some special considerations. In resis- 5. Conduct an Arc Flash Assessment
tance-grounded systems it is possible to lose ground The design of a safe electrical work environment starts
and not even know it, so monitor the health of the with an arc flash assessment. NFPA 70E standards
resistance-grounding equipment with a special relay require that arc flash hazards be identified at each
made for this purpose. Also, realize that equipment electrical panel or piece of equipment that may be
with on-board ground fault detection will probably worked on while energized, indicating the category of
never trip in a resistance-grounded environment. arc flash hazard. Because the arc flash hazard is based
Most variable frequency drives, for example, are set on the available fault current at a particular piece of
by the manufacturer to trip at ground fault currents equipment, hazards can be decreased by changes to
above 5A, so the user should consider adding ancil- the electrical system, such as adding a current-lim-
lary ground fault relays. iting fuse or circuit breaker. The design changes are
Because the arc flash hazard is based on the may open more slowly in equipment located downstream. This ac-
tually will increase the amount of potential incident energy, some-
available fault current at a particular piece times very significantly.
of equipment, hazards can be decreased by Some managers stop arc flash assessment at the first 480V drop
changes to the electrical system, such as add- off the bus because they wrongly assume there is no risk of arc flash
below that point. One example of this mistake is stopping the as-
ing a current-limiting fuse or circuit breaker. sessment at the main switchgear or a motor control center (MCC).
relatively easy; the tricky part is the assessment. This not only compromises worker safety, it is a violation of OSHA
A reliable arc flash assessment almost always involves engineer- regulations and the NFPA 70E standard that require all equipment
ing calculations by an expert. NFPA 70E provides a table for de- to be assessed down to 50V for shock and arc flash hazards.
termining Hazard Risk Categories, but the table’s footnotes state Coming changes to NFPA 70E include more explicit require-
it may be used only if the available fault current and the overcur- ments for arc flash warning labels, including what types of equip-
rent protective device clearing time are known to fall within cer- ment need them and what information they should include. The
tain limits. Many people overlook these footnotes and use the Table label is the point where the worker interacts with the hazard as-
Method as a shortcut without doing the required analysis. For ex- sessment on a daily basis. For example, flash protection boundaries
ample, for panelboards or switchboards operating at 240 or 480V, should be included on arc flash warning labels. Using information
the available fault current cannot exceed 25kA and the clearing from an arc flash assessment, the distance can be calculated; only
time of the overcurrent protective device cannot exceed 2 cycles or qualified workers wearing the proper PPE are allowed to go beyond
0.03 second. These values must be calculated and verified in order this boundary.
to use the table.
Another common mistake is assuming that if equipment is 6. Install Arc Flash Relays
determined to be a Hazard Risk Category 0, then equipment fed An arc flash relay provides an easy way to design safety into the
downstream is also a Hazard Risk Category 0. Because impedance electrical workplace. It can be retrofitted into any electrical panel
in wiring reduces available fault current, a fuse or circuit breaker where the available fault current is sufficient to allow an arc flash.
TO LEARN MORE:
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Circle 21 on card.
44 Occupational Health & Safety | SEPTEMBER 2012 www.ohsonline.com
Does your company train 125 or more employees in CPR and first aid in a year?
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HeartQuarters Training is a full-service training solution offered by the American Heart Association.
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To prevent nuisance tripping — from intense current. In environments with high amounts of ambient light, it is
possible to increase the trip threshold to prevent nuisance tripping;
sunlight or a nearby arc welder, for example however, ambient light is not an issue when cabinets are closed.
— most arc flash relays don’t depend on light Installation of an arc flash relay is straightforward, involving the
placement of light-detecting sensors throughout the cabinet. The
detection alone. user may choose to use a long fiber-optic sensor or multiple point
These relays detect the light of an emerging arc flash and send a trip sensors. Then the relay’s control output is wired to the existing cir-
signal to the existing circuit breaker in less than 1 ms. cuit breaker, which must be capable of signal trip. As an option, the
The amount of energy released during an arc flash is a func- installer may wire other relay signal outputs to factory systems in
tion of time and current. During a 50 kA bolted fault on a 480V order to communicate status and alarms.
system, there is little damage in the initial stages; however, in those
stages the arcing current is too low to instantaneously trip a cir- 7. Monitor in Real Time to Detect Problems
cuit breaker. Around 100 ms the cable catches fire, and at 150 ms Before They Occur
the copper conductors catch fire. At this point, a cloud of ionized If knowledge is power, then data from equipment is a potent part-
copper gas could form — a near-perfect conductor that allows an ner in reducing costs and increasing safety. Modern digital motor-
explosion of heat and light. An arc flash relay detects the light and protection relays have made it possible for leaner staffs to remotely
increased current of an emerging arc extremely quickly. By mak- monitor the health of pumps and motors and then to trend that in-
ing the breaker trip much sooner, the total clearing time is reduced formation to make smarter decisions about maintenance. By catch-
to around 35 to 60 ms, which dramatically reduces the amount of ing problems sooner, such as worn insulation, high temperatures,
energy released during an arc flash event. and ground faults, protection relays prevent malfunctions that can
To prevent nuisance tripping — from intense sunlight or a near- expose workers to electrical safety hazards.
by arc welder, for example — most arc flash relays don’t depend
on light detection alone. The relay compares input from the light Tony Locker, P.E., is product manager for Littelfuse Protection Re-
sensor with input from current transformers on each phase. The lays. Founded in 1927, Littelfuse offers circuit protection products
relay won’t trip unless there is both strong light and quickly rising and solutions.
1-877-368-3530 ContactUs@dnv.com
www.dnvba.us | www.dnvtraining.com
Circle 9 on card.
TSI Incorporated
Tel: 1 800 874 2811 Web: www.tsi.com/trust
CIRCLE 40 ON CARD
S
BY DREW D. TROYER As a risk manager, you may or may not have con-
lip, trip, and fall accidents result in more trol over the selection and condition of pedestrian
than 8 million emergency room visits and shoes. In a manufacturing plant, for instance, you can
more than 21,000 deaths each year. They are require the use of safety footwear. In a retail mall or
second only to moving vehicle accidents as a restaurant, it’s impossible to influence the footwear of
source of death and injuries in the USA. The National the general public. At most, you can target the reduc-
Floor Safety Institute (NFSI) estimates that the finan- tion of contaminant ingress onto walking surfaces and
cial impact exceeds $80 billion per year. take action to clean spills when they occur, but this
Often, these accidents become litigious. The gro- is not foolproof. Managing and monitoring the con-
cery industry alone spends more than $450 million dition of pedestrian walkways offers you the greatest
per year to defend slip, trip, and fall accidents. Most degree of control and must be a focal point in your
of these incidents are same-level accidents, where the efforts to ensure pedestrian safety.
pedestrian slips and falls on an even pathway. In 55
percent of these cases, the walkway is implicated as New Walkway Monitoring Standards = A New
the cause (Figure 1). Era for Walkway Safety
Three important new standards have been released
that are game changers in your fight against pedes-
trian slip, trip, and fall accidents.
■ ANSI/NFSI B101.0: This new standard speci-
fies the process by which walking surfaces shall be
audited for slip resistance using an NFSI-approved
walkway tribometer. A walkway tribometer is a device
that measures the coefficient of friction (COF) or slip
resistance of a hard-surface walkway, which is where
most slip and fall accidents occur.
■ ANSI/NFSI B101.3: This standard specifies
the process for measuring the dynamic coefficient
Figure 1. The walking surface is implicated in the majority of of friction (DCOF), which is the classic definition of
slip, trip, and fall accidents. friction. It measures the pounds of pulling or push-
Managing the condition of walkways must be a ing force required to slide a pound of mass across a
priority for any risk and safety manager – both to pro- surface. The higher the DCOF, the better — as DCOF
tect pedestrians from injury and to protect the organi- increases, slip resistance increases. This standard
zation against lawsuits for negligence. Up until recent- specifies action limit values, so you know when regu-
ly, monitoring the condition of pedestrian walkways lar maintenance or more serious attention is required.
has been a largely subjective science. New standards ■ ANSI/NFSI B101.1: This standard specifies the
issued by the American National Standards Institute process for measuring the static coefficient of friction
and NFSI are changing that landscape. Welcome to (SCOF). SCOF differs from DCOF in that it measures
the era of science and control in the management of the force required to initiate sliding. Typically, more
walkway and pedestrian safety in the USA. force is required to initiate sliding than is required to
Safe walking requires a sufficient degree of friction perpetuate it.
between the shoe and walking surfaces. Some shoe One can technically argue the merits of measur-
materials offer more slip resistance than others; some ing DCOF versus SCOF. The author personally prefers
flooring materials offer more slip resistance than oth- DCOF because it tends to be a more repeatable measure,
ers. Moreover, contaminants such as water, detergents, and a significant body of research has been dedicated
oil, dust, etc. serve as lubricants to reduce the coeffi- to determining the relationship between DCOF and
cient of friction on walkway surfaces. Also, the condi- walkway safety. Much of that study has been done in
tion of the floor can change over time due to wear or Germany, where the standards for pedestrian safety and
technological research are highly advanced. consequences, and the effectiveness of your warning signs are up and very visible.
To support these standards, NFSI has current controls. Utilize historical records Look for spills or other contaminants that
created an interlaboratory study (ILS) pro- on slip, trip, and fall accidents to evaluate increase the risk of a slip, trip, and fall ac-
cess to confirm that walkway tribometers your risk. Incorporate accident reporting, cident. Regularly monitor the COF of your
are valid, repeatable, and reproducible. Ac- analysis, and corrective action protocols to hard surface walkways using ANSI/NFSI
companying the ILS is a walkway tribom- continuously assess and improve your esti- B101-standardized test methods and ap-
eter approval process. Together, the NFSI mates of risk. proved tribometers.
ILS and tribometer approval process en- 2. Do. Once you have analyzed the risks 4. Act. If inspections and walkway
sure that your walkway tribometer — and associated with slip, trip, and fall accidents condition monitoring of the COF reveal
the company that produces it — are both for a geographical space, you may need to deficiencies, take proactive steps to correct
dependable. take some actions to adjust the risk in high- whatever condition fell out of control. For
priority walkway spaces to tolerable levels. hard surfaces, if the COF falls below accept-
Executing Walkway Safety Monitoring These actions could be as simple as putting able limits, action is required to clean, treat,
With the new auditing and walkway COF down mats or installing warning signs. maintain, or replace the surfaces. ANSI/
standards, your walkway safety manage- In other instances, it may be necessary NFSI B101.3, the standard for measuring
ment process fits neatly into the Plan-Do- to adjust the specification for acceptable the wet DCOF for a hard-surface walkway,
Check-Act cycle with which you most footwear, when that is within your control. provides specific value limits. Based upon
likely are familiar (Figure 2). Sometimes it’s necessary to modify the decades of research in Germany, these
DCOF value limits and the related guide-
lines tell you when walkway maintenance
action is required (Figure 3).
Actions could include cleaning, degreas-
ing, treatment, or, in extreme cases, replace-
ment of the affected walkway surface.
Monitoring Walkways
Couldn’t Be Easier
Historically, monitoring the COF of a walk-
way was cumbersome and imprecise. New,
microprocessor-based technology makes it
a breeze today. Modern walkway tribom-
eters are fast (a test can be completed in a
matter of seconds), easy to use, and por-
Figure 2. The Plan-Do-Check-Act process management tool is perfectly suited to walkway safety management.
table. Many have on-board printers and
Wet DCOF Value Slip Resistance Potential Action the ability to upload data to a computer for
trending and/or inclusion in a report.
>0.45 (inclines), >0.42 (level) High — lower probability of Monitor DCOF regularly and
slipping maintain cleanliness.
Conclusion
0.30 – 0.45 (inclines), Acceptable — increased Monitor DCOF regularly and Slip, trip, and fall accidents are commonly
0.30 – 0.42 (level) probability of slipping maintain cleanliness. Consider
used as fodder to entertain people in mov-
traction-enhancing products and
practices where applicable for ies, comedy acts, and cartoons. In real life,
intended use. falls aren’t funny. Rather, they’re very costly
to individuals, organizations, and society at
<0.30 Low — higher probability of Seek professional intervention.
slipping Consider replacing flooring and/ large.
or coating with high-traction
products. Drew D. Troyer, CRE, is founding principal
of Sigma Reliability Solutions LLC (www.
Figure 3. DCOF action limits published in the ANSI/NFSI B101.3 standard.
sigma-reliability.com) of Tulsa, Okla. He is a
1. Plan. Preventing slip, trip, and fall COF of the walkway itself with treatments recognized authority on tribology, risk man-
accidents is a risk management proposi- or, where serious deficiencies exist, replace agement, and reliability engineering, having
tion. A variation on common tools for risk the flooring itself. published more than 200 books, chapters,
analysis, such as Failure Modes & Effects 3. Check. To create a control system, articles, and technical papers on the topics of
Analysis (FMEA), should be employed to you need a feedback loop to check and reliability engineering and tribology. He is a
evaluate a geographical space, such as a verify the effectiveness of your efforts. member of NFSI and the ANSI/NFSI B101
convenience store, for accident potential Conduct routine inspections to look for standards committee and the creator of the
and to assign priority based upon the like- damage, buckling, curling, or other defi- NFSI interlaboratory study process and
lihood of an event, the magnitude of the ciencies in mats and rugs. Confirm that standard for walkway tribometers.
Fh[fWhWj_edH[ifedi[H[Yel[hoC_j_]Wj_ed
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Any organization looking to upgrade or fit new 1. Ensure the quality and performance of the unit are suitable
for your needs and the needs of your personnel and meet the cur-
emergency shower facilities needs to carry out a rent ANSI standards. Shortcuts can cost more in the long run and
comprehensive risk assessment. lead to legal action by harmed employees.
2. Check that the water supply pipework is capable of delivering
Normally, a 15-minute time period would be a suitable length 20 gpm.
to wash most contamination off clothing. However, when the tepid 3. On all units, check that the correct temperature is being
water turns to freezing, workers can be tempted to step out of the maintained, this being under 77 and above 60 degrees Fahrenheit.
shower, believing their clothing to be free of the hazardous sub- If the temperature is too hot, it can increase the harmful effects
stance. Unfortunately chemicals can react when they come into of chemicals on the skin. Too cold, and it can cause hypothermia,
contact with water (such as caustic soda, which turns to a slimy plus the correct drenching time may be insufficient because the
consistency and can be difficult to wash off ). This can result in user will not be able to stay under cold water for the recommended
contaminants remaining on clothing even after a 15-minute flush, 15 minutes, let alone the 30 minutes required for certain chemicals.
which is why it is imperative for an operative to strip off all clothing 4. Check on the disposal of the contaminated water. Residual
for full flushing to be effective. water should be disposed of carefully to ensure contaminated water
When installing an emergency shower facility, it is vital to assess is not allowed to enter the water main. Also any excess water col-
risk on an individual basis. This can include a risk assessment not lected on the floor during testing or after an emergency can be a
only against the control of hazardous substances, but also against hazard, creating a slippery or icy surface.
climatic conditions, the surrounding environment, and the work- 5. Measure employees’ sizes and check the area you want to
force, including lone workers and the mix of male/female employ- designate for a shower unit to ascertain whether it will provide a
ees, for example. suitably sized emergency facility. With the average physical size of
We advise that any organization looking to upgrade or install a people in North America increasing, there needs to be adequate
new emergency shower or eyewash unit at their facility to carry out room to accommodate the necessary movement when using the
a comprehensive risk assessment. Important areas that need to be shower. Struggling to quickly strip off contaminated clothing in a
considered include: restricted area is very difficult, uncomfortable, and can exacerbate
the problem, especially with part of the space occupied by an eye-
wash unit. The recommended ANSI standard of a 34 inch (86.4
cm) cubicle diameter is adequate but not ideal. Increasing the size
of a decontamination unit it will provide better protection.
6. Check the pipework feeding the shower. With a changing cli-
mate, exposed pipework that survives a normal winter season is no
longer adequate and will not meet the recommended standards.
This will mean either relocating the shower unit or insulating and
heat tracing the pipework.
7. Are curtains or doors needed for modesty? Not providing a
modest safety shower can cause employees to hesitate to appropri-
ately wash down. In emergency situations, time is critical.
Complying with ANSI requirements puts the safety of your
employees first while protecting employers from governmental
enforcement and legal actions. The cost to update or install the cor-
rect safety equipment pales in comparison to the cost of a citation
and, more importantly, an employee’s life. The bottom line is that it
only makes sense to put safety first by providing safety equipment
that will perform in the critical few moments when it is used.
Z
An incident is a failure in your a mantra we should
ero incident programs and goals are the desires of aver- systems, programs, and approaches to
similarly use in safety.
age safety cultures, not excellently performing ones. Or- safety. When the goal, programs, and
ganizations that have achieved sustainability of excellent process are based on zero incidents, this translates as zero failures,
results in culture and performance define, measure, and thus promoting the mentality: Don’t fail. Of course we do not want
motivate what they want, rather than what they don’t. people to fail, but is this the motivation we truly desire: “Work hard
Is health the absence of visible disease? If you never receive a to not fail”? When organizations establish Zero Incidents/Injuries,
check-up by a physician, yet you feel good and nothing appears to this frames: Safety Excellence = Zero Incidents.
be wrong, have you reached your goals of health and feel confident When excellence in safety is measured by zero failures, a self-
you will live a long life with this approach? limiting organizational viewpoint and very dangerous employee
To define health as the absence of visible, self-reporting indica- belief are created: “If safety means no incidents, then anything that
tors is recognizably dangerous. “Early detection, early response,” I do that doesn’t result in an incident or get me hurt must be safe.”
the motto of Dr. Larry Brilliant, who helped eradicate smallpox and When this occurs, risk will be overlooked, complacency will set in,
frame the thinking that shapes global infectious disease control, is a an important and healthy degree of vulnerability of risk will be lost,
mantra we should similarly use in safety. and organizations will be surprised by an incident that occurs out
of nowhere. This will often sound like, “I can’t believe that experi-
enced, well-trained employee did that” or “How did we miss that?”
When an organization is surprised by results or events, this is an
indicator that the measurement systems are not properly aligned to
capture and motivate both results and performance. If we set goals
based only on results and individuals cannot clearly decipher what
performance will contribute or deviate from the results, not only
are the measurement systems misaligned, but the behavior within
the culture will be, as well.
What do you want in safety? What are you trying to accomplish
and why? Is the motivation to achieve the goal based on organiza-
tional or individual value? What do success and excellence look
like — not just indicators and activities, but behaviorally, when you
Figure 1. Perpetual Cycle of Avoiding Failures get there?
Organizations that achieve excellence set targets such as 10,000
Within the medical community, to respond is positive, to react Percent Safe™, a methodology used with clients to measure, moti-
is negative. If the body responds to a drug, procedure, or interven- vate, and drive performance and organizational processes toward
tion, this is positive. When the body reacts to such approaches, this being 100 percent safe, 100 percent of the time. Safe should be de-
is negative. When we measure success by negative reported out- fined as not being at risk, and safety should be defined by what we
comes, we are driving safety culture excellence by reaction rather individually or collectively do to create a risk-free outcome.
than proactive identification and response. Definitions and terminology drive beliefs, which affect decisions
How we frame our goals is the difference in excellent perfor- and behaviors at work and away. Is your goal to have zero incidents
mance and excellent results; the two are not interchangeable. If or successful beliefs and behaviors? Both, I’m sure, but what do your
the goal is zero incidents/injuries and it is obtained, what is the measurements indicate? Next month, I will share a methodology
measure of continuous improvement? Moreover, if an organiza- and framework to help you move beyond failure avoidance to suc-
tion obtains excellent results and cannot precisely describe why, cess-seeking goals, metrics, and performance.
the successful results are lucky, not excellent. Whenever results are
rewarded, by default the performance that obtained the results is Shawn M. Galloway is the president of ProAct Safety. An interna-
reinforced. Were the excellent results obtained by excellent perfor- tional consultant, professional speaker, and seminar leader, he has
mance, or did the group just get a little luckier this year? helped hundreds of international organizations achieve and sustain
Figure 1 outlines the approach most organizations take to improve excellence in performance and culture. He is also the host of the ac-
safety. Leadership will review the current incident rates, determine claimed weekly podcast series Safety Culture Excellence®. He can be
a new incident rate goal (either a desired rate or reduction amount), reached at 800-395-1347 or info@ProActSafety.com.
AR12-100 © The Lincoln Electric Co. All Rights Reserved. www.lincolnelectric.com CIRCLE 67 ON CARD
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Classical Leadership
H
ere’s how to become a “Classical” leader. Plato contended pride themselves on being “rational.” Sure, for any proposed course of
the human soul is filled with Reason, Will, and Desire. action, there are always numerous logical reasons for supporting or
Of course, this mix can greatly vary between people. Fur- sinking it — or to avoid making any decision at all. Have you ever
ther, I’ve found that highly effective leaders understand been in a situation where you heard, “This might possibly be of use,
they have to appeal to all of these attributes to foster agreement but we don’t have the time, the energy, or the resources to take it on.
(persuade) and generate enough of the energy required to break Besides, this wasn’t planned into our current budget cycle,” until
through status quo-hugging inertia (propel, magnetize). someone high up in the company became excited about the proposed
Looking at these three interwoven components: “Reason” re- change? Then the organization “magically” finds the time, resources,
fers to understanding how the world works and what approaches and energy to quickly go full speed ahead with the new initiative?
would be best suited to fix shortfalls; “Will” means taking oneself Ultimately, while they may scrupulously weigh costs and ben-
in hand, not allowing fear or other concerns to sidetrack working efits, people rarely become motivated by their head/thought pro-
toward improvement; “Desire” refers to cravings, a push to do or cesses. They sign on with their gut. Then their Will drives them
receive something. When unchecked, Desire — both physical and to continue their efforts. This is even true in a court of law where
emotional — can incite overwhelming actions that evidence purportedly rules but emotional reactions
actually hurt a person’s well-being overall. actually dominate.
As in the Rochambeau game of Rock-Paper-Scis- Reason doesn’t motivate because anything is
sors, these three human components can each simul- open to interpretation by someone predisposed to-
taneously overcome and succumb to one other. For ward bending it to his Will. If logic and reason ruled,
example, some try to Will themselves to take actions likely no one would smoke, we all would be slim and
that their Reason pushes back against, “arguing” ei- athletic — and everyone would act toward others
ther these aren’t possible to accomplish or don’t pro- as they’d wish to be treated. We’d certainly not lose
vide good payback on effort expended. (“I’ll just hurt control and blurt out relationship-torpedoing state-
myself if I persist”; “I’m too old to try a new activity.”) ments that we later regret. And, in the arena of Safety,
And both Reason and Will seem to continually none would take “silly” but unrewindable risks.
struggle with Desire. (“I will not have another piece of Remember that Desire is receptive to and even looks for oppor-
pie… or a third one”; “I know I should exercise — but everyone every- tunities that come out of the blue. In contrast, Rea-
the game’s on”; “Don’t say it, don’t say it… I can’t be- son tends to slow things down, arguing for thorough
lieve I said it!”; “Why did I do that? I knew better….”) where longs for analysis and contingency planning prior to attempt-
My lifelong experience as an agent of change: something. ing anything new. Will, while important to actuating
■ When attempting to reach others, it’s essential results, is a toolset, a let’s-get-it-done focus, useful
to incorporate each of these elements. Appealing to only one or two only after the decision to do something has been set. But Desire ul-
of them makes it more likely the left-out element will resist or that timately stokes the fire that forges new tools; heats up, shrugging off
there’ll be a critical missing performance link (e.g., even with strong lethargy; and transfers energy into setting the wheels of change into
motivation to change — but not much more than that — lack of ef- motion. So if you wish to be a high-level “classical” leader, consider:
fective planning or execution will stunt actual results). ■ making sure to include Reason, Will, and Desire into every
■ Timing greatly affects relative weighting of Reason, Will, and persuasive argument you convey and every reinforcement plan.
Desire. Change expert Kurt Lewin wrote that every person lives in ■ enlisting Reason by making it easy for others to grasp the
his or her Dynamic Present, which is comprised of three elements: benefits and potential pitfalls of a proposed change and what they
1. The Immediate Past — what recently happened that’s af- personally can do to become more effective. Yes, even with execu-
fecting him/her now (e.g., had a fight with his spouse just before tives, include projected cost savings as a rationale for adopting new
coming to work and is still stewing, something pressing came up tools or applications — but go well beyond just financial returns.
the day before that’s currently on her mind, back pain that blos- ■ providing specific skills and tools that enable Will to easily
somed yesterday is distracting attention today, etc.). operate (e.g., move away from “Pay attention to what you’re doing
2. The Immediate Present — those influences directly acting next time” and toward “Here are some practical skills for directing
on him/her (e.g., boss seems to ignore me during our team meet- your attention to most important tasks and to your safety”).
ing, she’s hungry, etc.). ■ most important, motivating through Desire.
3. The Immediate Future — known deadlines or upcoming Remember that everyone everywhere longs for something —
activities that affect what he/she’s doing now (e.g., pressed now because improvements, less stress, greater returns, enhanced respect, better
must finish presentation for this afternoon’s managers’ meeting). relationships, and much more. Desire is the most elemental part of
In addition to time, each person’s three-part mix changes based each person.
on his/her level of attraction or repulsion to it. So if a manager sees
a new initiative can elevate her control and power (Desire), she may Robert Pater (rpater@MasteringSafety.com) is Managing Direc-
Will herself to do extra work to make this intervention really fly. tor, Strategic Safety Associates and MoveSMART®, www.Mastering
■ Desire is the ultimate driver of change, even among those who Safety.com.
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More info at www.enconsafety.com/twst
Encon ® is a registered trademark of Encon Safety Products, Inc. Houston, TX.
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