Archive for: November, 2020

OSHA Says Face Coverings Not Considered PPE Under Its Standard

By: November 30th, 2020 Email This Post Print This Post

By Guy Burdick , EHS Daily Advisor

The Occupational Safety and Health Administration (OSHA) does not consider cloth face coverings personal protective equipment (PPE), the agency said on November 18 in an update to its frequently asked questions (FAQs) about coronavirus disease 2019 (COVID-19).

OSHA revised its advice for employers following an updated scientific brief from the Centers for Disease Control and Prevention (CDC) about community use of cloth face masks to control the spread of SARS-CoV-2, the virus that causes COVID-19. The CDC now recommends the use of masks, especially nonvalved multilayer cloth masks, to prevent transmission of SARS-CoV-2.

Cloth masks can both block the mask wearer’s exhaled respiratory droplets and particles and offer the wearer some personal protection through droplet and particle filtration, according to the CDC.  However, the filtration effectiveness of different masks has varied widely across the studies so far performed due to differences in study design and the particle sizes analyzed, the CDC said.

One study found that during a COVID-19 outbreak aboard the aircraft carrier U.S.S. Theodore Roosevelt, servicemembers who practiced precautions, including avoiding common areas, practicing physical distancing, and wearing face masks, had a lower infection rate than servicemembers who did not report taking precautions. The use of face coverings on board was associated with a 70% reduced risk, according to the CDC.

A study of a high-exposure event, when two symptomatically ill hair stylists interacted for an average of 15 minutes with 139 clients during an 8-day period, found that none of the 67 clients who subsequently agreed to an interview and testing developed an infection. The stylists and clients all complied with a local ordinance and company policy to wear face masks while in the salon.

Despite encouraging reports from the CDC, OSHA does not believe there is enough information currently available to determine whether any particular cloth face covering provides enough protection from SARS-CoV-2 to be considered PPE under the agency’s standard. The CDC indicated that more research is needed to determine the blocking and filtration effectiveness of various materials.

The design, construction, and fabric selection of a mask all can have a substantial impact on the overall effectiveness of a face covering as personal protection. OSHA acknowledged current efforts to develop a consensus standard on the design and performance of face coverings at ASTM International (formerly the American Society for Testing and Materials).

OSHA continues to encourage workers to wear face coverings, if appropriate in work environments, when in close contact with others to reduce the risk of spreading the SARS-CoV-2 virus. Three states so far—VirginiaMichigan, and Oregon—have established emergency temporary standards (ETSs) for workplace COVID-19 exposures, and each has different requirements for face coverings. Oregon’s rule requires cloth face coverings in indoor spaces, regardless of physical distancing. Michigan requires employers to provide face masks at no cost to employees.

proposed ETS in California also would require employers to provide no-cost face coverings, as well as no-cost COVID-19 testing. There is no federal ETS for workplace COVID-19 exposures. OSHA has cited employers for violations of the General Duty Clause of the Occupational Safety and Health Act, along with violations of recordkeeping, reporting, and respiratory protection standards. The agency so far has proposed penalties totaling $2,851,533.

KPA COVID-19 Operations Checklist

By: November 30th, 2020 Email This Post Print This Post

Companies are facing many risks associated with COVID-19. Since it’s not going away in the short-term, you need to put strategies in place to protect employees and customers.

Establishing a plan and training employees can demonstrate that you put forth a “good faith effort” to regulatory agencies like OSHA.

This checklist reviews the steps to create a thoughtful COVID-19 operating strategy including:

  • Appointing a COVID-19 coordinator and response team
  • Develop an infectious disease plan
  • How to operate if absenteeism rises; and more

Download the COVID-19 Operations Checklist now for free here

Amid COVID-19, OSHA issues respirator guidance for long-term care facilities

By: November 12th, 2020 Email This Post Print This Post

By Guy Burdick, EHS Daily Advisor

The Occupational Safety and Health Administration (OSHA) issued respiratory protection guidance for assisted living, nursing home, and other long-term care facilities. The guidance focuses on the use of respirators while emphasizing a primary reliance upon engineering and administrative controls for controlling exposures, consistent with good industrial hygiene practice and the agency’s traditional adherence to the “hierarchy of controls.”

The industrial hygiene “hierarchy of controls” is a series of workplace safety and health interventions that begins with elimination of hazards, followed by substitution, then engineering controls, administrative controls (including work practices), and personal protective equipment (PPE).

OSHA has instructed its compliance safety and health officers in its area offices to exercise discretion in the enforcement of the respiratory protection standard during the coronavirus disease 2019 (COVID-19) pandemic. COVID-19 is a respiratory disease caused by the SARS-CoV-2 virus.

The agency insists that workers wear respirators when necessary, such as when in close contact with a resident of a long-term care facility with suspected or confirmed coronavirus infection. Employees then must wear an N95 filtering facepiece respirator (FFR) or equivalent or a higher-level respirator approved by the National Institute for Occupational Safety and Health (NIOSH).

The guidance describes other source control measures, including the use of cloth face coverings, face masks, and U.S. Food and Drug Administration (FDA)-cleared or -authorized surgical masks. Healthcare workers should wear such source control products or devices at all times while inside a long-term care facility, according to the agency, including in break rooms or other spaces where they might encounter other people.

OSHA told employers that they should reassess their engineering and administrative controls, such as ventilation and practices for physical distancing, hand hygiene, and cleaning and disinfecting surfaces, to identify changes that could avoid over-reliance on respirators and other PPE. OSHA reminded employers that the agency has temporarily allowed for some enforcement flexibility regarding respirators, including requirements for annual fit testing that consumes disposable respirator supplies.

However, the agency also reminded employers that when respirators must be used, employers must implement a written, worksite-specific respiratory protection program that includes medical evaluation, fit testing, training, and other elements of the agency’s respiratory protection standard (29 CFR 1910.134).

OSHA offered employers the following advice for administering a respiratory protection program during the ongoing pandemic:

  • Consider alternatives to N95 FFRs, including other FFRs (for example, P100s and N99s); reusable elastomeric respirators; and powered air-purifying respirators (PAPRs), given shortages of N95 FFRs during the pandemic.
  • Choose eye and face protection to be worn with the type of respirator used, but exercise care to ensure the eye or face protection does not interfere with the seal of the respirator.
  • Consult NIOSH’s list of approved N95 FFRs and warnings about counterfeit respirators or misrepresentation of NIOSH approval.
  • Assign a suitably trained program administrator to oversee all elements of the program, such as an infection prevention and control practitioner or a nurse administrator, or consider hiring a local industrial hygiene consulting service if no suitably trained administrator is available on staff.
  • Conduct a risk assessment to identify which workers are at risk of exposure to any airborne hazards such as SARS-CoV-2, tuberculosis (TB), Legionella, or certain hazardous chemicals, and classify exposure risk to SARS-CoV-2, according to OSHA’s four risk exposure levels.
  • Implement procedures for performing medical evaluations of workers required to use respirators to determine their ability to safely wear a respirator before needing to wear one in the workplace; identify a physician or other licensed healthcare professional who can conduct medical evaluations and maintain confidentiality.
  • Ensure that any worker using a tight-fitting respirator is fit tested following OSHA-approved fit-test protocols before initial use and whenever a different respirator size, style, model, or make is used.
  • Establish procedures and schedules for the maintenance and storage of any respirators used beyond a single use, including procedures for cleaning, disinfecting, storing, repairing, and discarding respirators.
  • Train workers who wear respirators on how to properly put them on (donning) and take them off (doffing), as well as how to conduct proper user seal checks and recognize respiratory hazards in their workplace and the capabilities and limitations of respirators.

Checking in on Your Organizational Safety Culture

By: November 11th, 2020 Email This Post Print This Post

By Guy Burdick, EHS Daily Advisor

A few weeks ago during the EHS Daily Advisor’s Safety Culture Week, we provided a wide array of content to help you build a safety culture that is effective all year round. But to maintain a healthy culture, it’s important to constantly check in on it. So, how is your safety culture? You might begin by asking yourself, “What does ‘safe’ look like?” Is it a low recordable incident rate? Is it a lower number of workers’ compensation claims?

Safety conversation

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Measuring outcomes is important, but you may need to dig deeper to understand how those outcomes affect your business and the underlying hazards, risks, and risky behaviors that lead to accidents and incidents.

The most obvious sign of a troubled safety culture is workers who fail to comply with safety rules, policies, and procedures. Worse than mere disregard for rules is risky worker behavior. You need your employees to fall in line, especially now.

Worker compliance is even more critical during the ongoing coronavirus disease 2019 (COVID-19) pandemic, starting with the risk of a sick employee showing up for duty. There are engineering and administrative controls you can put in place to help prevent infections, like installing plexiglass shields where distancing of 6 feet or more is impractical, staggering shifts and installing additional time clocks to prevent close contact at shift changes, and removing chairs and tables in break rooms. However, preventing infections relies heavily on individual behaviors, from social distancing and the proper use of cloth face coverings to hand-washing, cough and sneeze etiquette, and staying home when sick.

Where duties can be performed remotely, an effective telework policy can help ensure workers do not show up sick at your workplace, but you may want to add start-of-shift screening that includes temperature checks and symptom assessments.

Resuming operations following state-imposed shutdowns and continuing operations during the uncontrolled spread of COVID-19 may require new approaches specific to a pandemic response. You should begin by assessing how the pandemic has affected your organizational culture.

You may need to communicate new operational objectives to your employees and update how you deliver safety training to your employees in addition to incorporating infection prevention into your training programs. You also may need to add resources to reinforce safety training for employees who have been away from the workplace. Some states have new regulations with COVID-19 training requirements.

You also need to communicate your new policies and practices with your employees to counter any reentry anxiety.

Healthcare PPE

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Patient and Worker Safety in Health Care

The impact of safety culture can extend beyond employees themselves, as researchers at Imperial College London recently found. A positive safety culture in a healthcare facility can result in improved patient safety and better patient health outcomes. Training and support for redeploying healthcare workers during the onset of the COVID-19 pandemic resulted in better safety attitudes and a reduced number of reported safety incidents.

The Occupational Safety and Health Administration (OSHA) years ago acknowledged the benefits of linking patient and worker safety after the release of an Institute of Medicine (IOM) report, “To Err is Human: Building a Safer Health System.” IOM concluded that a safer environment for patients would also be a safer environment for workers and vice versa. Several studies have shown a correlation between a strong safety culture and the safe handling of sharps and bloodborne pathogens.

According to the IOM report, a strong safety culture in a healthcare facility is created through:

  • The actions management takes to improve both patient and worker safety,
  • Employee participation in safety planning,
  • The availability of appropriate protective equipment,
  • The influence of group norms regarding acceptable safety practices, and
  • The organization’s socialization process for new personnel.

An effective safety and health management program can help employers find and fix workplace hazards before workers are hurt, according to OSHA. Many healthcare facilities may already have a safety and health management program in place to conform to Joint Commission standards. Joint Commission certification usually is a prerequisite for insurance, Medicaid, and Medicare reimbursement.

OSHA has identified management leadership, worker participation, hazard identification and assessment, hazard prevention and control, education and training, and system evaluation and improvement as key elements to an effective safety and health management program.

The National Institute for Occupational Safety and Health (NIOSH) even has a National Occupational Research Agenda (NORA) for the healthcare and social assistance sector. As part of the healthcare and social assistance research agenda, NIOSH developed a “Stop Sticks” Campaign focused on the knowledge, behaviors, and attitudes of healthcare workers surrounding the use of devices with sharps injury protection (SIP).

Safety Rules Compliance

Even in the best of times, employees “bending” or breaking workplace safety rules and procedures can have serious consequences—even the loss of a limb.

For example, evidence emerged in a lockout/tagout case at a Wal-Mart distribution center that company and contract employees regularly circumvented company procedures for entering an Electrified Monorail System (EMS) consisting of trolleys to move pallets of merchandise within the warehouse. Employees for Wal-Mart and its contractor, Swisslog Logistics, crossed over fixed conveyors to enter the EMS. Employees also had placed pieces of cardboard over the light curtains between loops of the EMS—an employee tripping a light curtain normally would stop the trolleys in that section—resulting in the light curtains being in a muted state. Employees could walk from one loop to another without tripping a light curtain, even where trolleys operated in full-speed mode. An employee servicing trolleys was struck by one, and a piece of machinery penetrated his leg.

Rank-and-file employees aren’t the only challenges to your safety culture, and the threat can be hard to spot if it is one of your managers and supervisors. A research study last year found that abusive behavior among managers and supervisors degraded safety behavior and led to poor safety outcomes among workers.

Bullying bosses can make workers become more self-centered, causing them to forget to comply with safety rules or ignore opportunities to promote others’ safer work behaviors. It even can create circumstances in which other people are likely to become injured.

You should intervene with abusive managers and supervisors, researchers suggest, by utilizing training programs to improve managers’ and supervisors’ skills in interacting with the employees they supervise so they have the skills to provide discipline and feedback in ways that are not offensive or threatening. Researchers also recommend that you promote a civil and engaged working environment, strengthening social bonds among employees to create a buffer that limits the negative consequences of their boss’s bad behaviors. You may even want to institute a transparent performance evaluation process so employees have no question about their social status in the workplace.

You also need to ensure that “safety first” is more than a motto and that all your managers and supervisors are steeped in safety culture.

You can get real-world results from a strong safety culture when supported by emerging safety technologies. Researchers found that trucking companies that have strong safety cultures and take advantage of advanced safety technology have seen better safety outcomes than motor carriers that don’t.

Best practices in a strong trucking safety culture require a consistency that includes:

  • Having zero-tolerance policies for hours-of-service violations;
  • Implementing improvements in hiring policies and training protocols and modifying driver scheduling to reduce fatigue;
  • Informing drivers about the carrier’s safety culture during orientation and including all employees—not just drivers—in safety training and education; and
  • Sharing carrierwide safety indicators with managers and drivers.

Training can be critical. Researchers have found strong evidence that training affects worker safety and health behavior, especially behavior surrounding ergonomic hazards.

Training needs to be geared toward the intended audience, taking employees’ cultural and educational backgrounds into consideration, including literacy levels. In some instances, training may need to be delivered in a language other than English.

The American Society of Safety Professionals (ASSP) has suggested looking at safety training at a higher level and integrating it into an overall safety and health management system. Safety and health management programs also include safety observations, safety audits, job hazard analyses, and incident investigations.

These elements can help reinforce a strong safety culture in your facility or at your jobsites.

Safety training

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‘Hidden’ Safety Culture

You also need to be aware that there may be a “hidden” safety culture, like the one among the employees at the Walmart distribution center. This hidden safety culture may be starkly different from your stated policies and procedures. It cannot be found in the safety manual sitting on the safety manager’s desk.

First, you will need to embrace a certain amount of discomfort. Issues with your safety culture may not be obvious, and you will need to persist until you get to the underlying issues.

Next, look below the surface for hidden “mixed” messages, picking up on the internal forces that can lead to unsafe actions. Develop consistent messaging that reinforces how workers should perform their duties safely.

Develop your pattern-recognition skills. Look for common threads in incident investigation reports. Look, too, for employees’ jury-rigged solutions for challenges to safety and comfort, like padding adhered to sharp workstation edges. There may be issues with your current equipment, and replacing some of it may offer you low-cost solutions.

Continue asking the right questions, but realize you may not be able to “see the forest for the trees” and may need to bring in outside help.

While fostering a strong safety culture among a diverse, multigenerational workforce has its challenges, older workers still in the workforce can offer a model of safe workplace behaviors that younger workers can emulate. Older workers tend to become injured less often, although their injuries may be more severe when they do become injured. They may have knowledge about hazards in the workplace picked up over years of experience.

Your safety culture also may need to adjust to cultural differences in an increasingly diverse workforce. You need to become aware of your own biases, as some workers may not have grown up receiving the same cultural messages as you and other employees. Do not let your assumptions hinder your safety efforts.

While you and some of your employees may perfectly understand American sports metaphors like “team” and “teamwork,” workers raised in other cultures may be more accustomed family metaphors when referring to work colleagues.

Check your assumptions so your safety policies and procedures do not become “lost in translation.” Encourage a free exchange of ideas. Different is not necessarily better or worse.

You need a safety culture that works for you today during a pandemic and every day after the outbreak.

11 Rules for Safe Handling of Hazardous Materials

By: November 11th, 2020 Email This Post Print This Post

By Chris Kilbourne
, EHS Daily Advisor

These 11 rules are presented in no particular order. They are all top priorities for chemical handlers. However, feel free to rearrange them in whatever order you think is best for your workplace, your workers, and your material hazards.

You’ll undoubtedly have other safety rules to add to the list. Better yet, present the list in a safety meeting and get employees involved in helping you add to the list. This will create a sense of ownership over your safe chemical handling rules. To employees, they’ll be “our” rules rather than “their” rules. That way, people will be more likely to follow them.

Rule #1. Follow all established procedures and perform job duties as you’ve been trained.

Rule #2. Be cautious and plan ahead. Think about what could go wrong and pay close attention to what you’re doing while you work.

Rule #3. Always use required PPE—and inspect it carefully before each use to make sure it’s safe to use. Replace worn out or damage PPE; it won’t provide adequate protection.

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Rule #4. Make sure all containers are properly labeled and that the material is contained in an appropriate container. Don’t use any material not contained or labeled properly. Report any damaged containers or illegible labels to your supervisor right away.

Rule #5. Read labels and the material safety data sheet (MSDS) before using any material to make sure you understand hazards and precautions.

Rule #6. Use all materials solely for their intended purpose. Don’t, for example, use solvents to clean your hands, or gasoline to wipe down equipment.

Rule #7. Never eat or drink while handling any materials, and if your hands are contaminated, don’t use cosmetics or handle contact lenses.

Rule #8. Read the labels and refer to MSDSs to identify properties and hazards of chemical products and materials.

Rule #9. Store all materials properly, separate incompatibles, and store in ventilated, dry, cool areas.

Rule #10. Keep you and your work area clean. After handling any material, wash thoroughly with soap and water. Clean work surfaces at least once a shift so that contamination risks are minimized.

Rule #11. Learn about emergency procedures and equipment. Understanding emergency procedures means knowing evacuation procedures, emergency reporting procedures, and procedures for dealing with fires and spills. It also means knowing what to do in a medical emergency if a co-worker is injured or overcome by chemicals.

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