Here are 12 good ideas for you and your safety program.

The new sheriff in town continues to make enforcement OSHA’s top priority.
Here are 12 good ideas  from American Safety and Health Management Consultants,Inc. to help you and your team avoid the new sheriff’s thirst for fines and penalties.

  1. Make safety a key priority. Really.
  2. Be ready for an inspection. Do not be caught off guard. Even if you aren’t there- have a plan.
  3. Review all written programs and update where necessary.
  4. Ensure that all employees receive the OSHA required training, document the training and follow up to assure they “got it.”
  5. Inspect your facility, or have a safety professional do it for you.
  6. Correct any and all violations as soon as practical.
  7. Follow up on employee safety related concerns.
  8. Establish supervisor responsibilities and hold them accountable.
  9. Know what to do in case of an OSHA inspection. Have assigned personnel to handle this.
  10. Audit your safety programs at least annually and develop a safety action calendar for each new year.
  11. Enforce you company safety policies fairly and consistently.
  12. Recognize and reward employees for good safety performance.

Photo of eggs.
(Actually, they aren’t really eggs.  And fining employers isn’t really about safety.)
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But give OSHA the Booby Prize for “most ambiguous” News Release on their website announcing the rule.

Here's your prize...

In its Trade News Release, May 21, 2010:  “Occupational exposures to hexavalent chromium can occur among workers handling pigments, spray paints and coatings containing chromates, operating chrome plating baths, and welding or cutting metals containing chromium, such as stainless steel.”
Link.
Cutting metals  containing chromium, such as stainless steel!
Our industry cuts stainless steel in our machines at ambient temperatures every day.  Not to worry, no hex chrome involved. Our  machine cutting processes are not “oxidative.”  They don’t make the chromium in stainless steel “hexavalent.”
Here’s what  another place on the OSHA website says about forming hexavalent chromium from stainless steel :
“Hexavalent chromium can also be formed when performing “hot work” such as welding on stainless steel or melting chromium metal. In these situations the chromium is not originally hexavalent, but the high temperatures involved in the process result in oxidation that converts the chromium to a hexavalent state.”   Link.
What the OSHA Trade Release should have said was “HOT WORK TORCH CUTTING” that can generate a metal fume.
In the mean time, even if OSHA can’t speak with precision, we just want to let you know that if you happen to do HOT WORK welding or torch cutting on stainless steels, decorative or hard chrome electroplating or any other process involving – say-  chromic acid, that June 15th, 2010 is the effective date for the direct final rule requiring employers to notify their workers of all hexavalent chromium exposures. 
Everybody else- just relax. 

 

Made in USA. Stainless Steel. Cooks Food.

 It’s still safe to use stainless steel to eat your food. To make your cookstove and kitchen appliances. Your pots and pans. And to machine precision parts on your cam type automatic or cnc precision machining lathe or mill.  Photo: Sur la Table
Its still okay to use this too,  just don’t take it on a plane.
Chrome-vanadium steel . Fine knife by Case. Not hexavalent.

 Case Knife
Blue- footed Booby
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If you have a high incidence and injury rate in your shop.
15,000 workplaces were sent the letter.

Employers receiving the letter are those whose establishments are covered by Federal OSHA and reported either the highest

  1. “Days Away from work,”
  2. ” Restricted work “or
  3. ” job transfer injury and illness”

          -(DART) rate to OSHA in a survey of 2008 injury and illness data.
Heres how the employers were selected:
For every 100 full-time workers, these  15,000 employers had 4.5 or more injuries or illnesses which resulted in days away from work, restricted work or job transfer.
The national average is 2.0.
The letter encourages employers to consider

  1. Hiring an outside safety and health consultant,
  2. Talking with their insurance carrier, or
  3. Contacting the workers’ compensation agency in their state for advice.

An excellent way for employers with 250 or fewer workers to address safety and health is to ask for assistance from OSHA’s on-site consultation program.
The consultation program is administered by state agencies and operated separately from OSHA’s inspection program. The service is free, and there are no fines even if problems are found.
The letter tells the employer where the OSHA consultation program in that state may be contacted.
Link to OSHA FOIA Letter Page .
Photo credit
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(OSHA) is initiating a national emphasis program (NEP) on recordkeeping to assess the accuracy of injury and illness data recorded by employers.

OSHA recordkeeping inspectors coming soon.
OSHA recordkeeping inspectors coming soon.

This new NEP will involve inspecting occupational injury and illness records prepared by businesses and appropriately enforcing regulatory requirements when employers are found to be under-recording injuries and illnesses.
The NEP will focus on selected industries with high injury and illness rates. The inspections include a records review, employee interviews, and a limited safety and health inspection of the workplace.
Now is probably a good time to do a self audit to assure your records are in order.
If you are the lucky recipient of one of these visits, how did it go?
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Business influenza information abounds. But what is authoritative?
The media is flooded with all kinds of stories about the Swine Flu /2009 H1N1 Novel Influenza. Our email boxes are being filled with all kinds of rumors, myths, and offers regarding this possible ‘pandemic.’
We’ve looked at a lot of sites, and a lot of resources. The workplace  planning tab at  www.flu.gov looked like a great all in one place resource for manufacturers like us. But following a link there led me to http://www.cdc.gov/h1n1flu/business/guidance/ and  I think that this is the one H1N1 influenza resource that you need.

Here's a 'Tool You Can Use!'
Here's a 'Tool You Can Use!'

Besides technical disease information and precautions, here are some of the ideas  from this site that employers should be considering if the H1N1 outbreak occurs this year.

  1. Prepare for increased numbers of employee absences due to illness in employees and their family members, and plan ways for essential business functions to continue.
  2. Advise employees before traveling to take certain steps
  3. Prepare for the possibility of school dismissal or temporary closure of child care programs
  4. Consider increasing social distancing in the workplace and canceling non-essential business travel
  5. Make sure your sick leave policies are flexible and consistent with public health guidance, and that your employees are aware of these policies.
  6. Make contingency plans for increased absenteeism caused by illness in workers or illness in workers’ family members that would require them to stay home. Planning for absenteeism could include cross-training current employees or hiring temporary workers.

More ‘Tools You Can Use’ include:
Born before 1957? Interesting article HERE.
For training materials including powerpoints and spanish language materials try here
OSHA has an easy to read explanation of what a pandemic is and other resources for employers and employees.
OSHA guidance on preparing our workplaces
The ability to anticipate and intelligently manage risk is what separates the great managers from the wannabes. These links help you with your preparations.
Have you reviewed your  sick leave, cross training, and other policies in preparation for the upcoming influenza season?
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