OSHA 300 Due February 1, 2010

That's Right,

It's again time to summarize your workplace injury and illness data on the OSHA Form 300-A, Summary of Work-Related Injuries and Illnesses and prepare to post February 1 thru April 30.

For a copy of OSHA's Form 300-A Summary of Work-Related Injury and Illnesses go to: http://www.osha.gov/recordkeeping/new-osha300form1-1-04.pdf

For the WAC 296-27 Recordkeeping and Reporting Standard and the OSHA 300-A Recordkeeping Summary requirements go to:
http://www.lni.wa.gov/wisha/rules/recordkeeping/default.htm#WAC296-27-02105

There are four (4) requirements for posting the summary:

1. You must review the OSHA 300 Log for completeness and accuracy. NOTE: (this is a great time to make necessary corrections on the 2009 Log or any other Log of the past five (5) years as required by the Regulation.)
   
2. Fill out the 300-A Summary Form
3. You must certify 300-A Summary
4. You must post conspicuously the 300-A Summary 2/1/2010 thru 4/30/2010
   

I recommend adding an incident rate to the summary if your Company has multiple facilities or job sites. It is great for general knowledge and for a topic at a safety meeting. Employees should know where they are on the corporate playing field regarding injury and illness statistics.

Also keep in mind that you are required to:

• Provide an employee or former employee who worked at the facility (site) or their personal representative a copy of the OSHA 300 Log or 301 Incident Report by the end of the next business day. (Exceptions exist for "privacy concern cases")
  
• Record cases involving hearing loss resulting in Recordable Threshold Shifts as specified in the Standard's Non-Mandatory Appendix A--Age adjustment calculations for comparing audiograms for recording hearing loss

Yes, you're right, I threw that last bullet in just to see if you were paying attention. However I do recommend using Appendix A as allowed by the Standard.

Lastly, remember that these OSHA Logs must be retained for a minimum of five (5) years.

Here is to a great New Year 2010,

Mark Close
Industrial Hygiene Consultant
P. 206-782-1254
Cell: 206-919-5314

All Confined Spaces Are Not Equal

Confined Space and Classifications

I'm often perplexed by comments regarding confined space when people say something along the lines of, "oh we just handle all of our confined space entries as permit-required confined space entries."

Why would anyone as a matter of routine, classify their confined space entries as the most dangerous type of confined space entry? Are these actually confined spaces where they are merely controlling the serious hazards not eliminating the serious hazards?

We should take all confined spaces seriously. However, it is my experience that less than one percent of all confined spaces are actually permit-required confined spaces.

Don't allow complacency to exist when your employees know that not all confined spaces are equally hazardous.

For the rest of this article go to http://www.closegroup.org/faq-industry.htm

New Dept. of Ecology Stormwater Permit Requirements

News Update!
Effective as of January 1, 2010 Washington State Department of Ecology has new Stormwater Permit requirements. Go to the following link and left click on the NEW! PERMIT on the right side
http://www.ecy.wa.gov/programs/wq/stormwater/industrial/index.html

I have been busy helping my clients, assuring that they are in compliance with the new DOE Stormwater Regulations.

The first order of business is to review the SIC classifications in Table I on page 6 and Table 3 on page 26 to determine whether the stormwater permit requirements apply to you.

If you fall under these requirements remember that until you make application for a permit your monitoring data is not reportable. This brings up the second order of business.

If you fall under the stormwater permit requirements, you may wish to conduct initial monitoring immediately and qualify and quantify any potential issues. Typically, the larger part of solving any stormwater issue is knowing what and how much is in your discharge.

It is important to remember that these requirements will be new for many businesses.

Don't ignore the inevitable. Allow the Close Group to assist you.

Best regards for the New Year

Mark Close
Industrial Hygiene Consultant
P. 206-782-1254
Cell: 206-919-5314
mark@closegroup.org

Hot and Cold Illness: use say "hot", I say "remember to acclimate"

As a dad of three boys I have come to expect the unexpected. I have even learned how to put in stitches when necessary. Parenting and Seattle weather have a lot in common. Conditions are always changing and preparedness is key. This month I wish to remind people of the significance of hot weather and employee well being. Last weekend our weather was hot and at times fairly humid. As I am writing this newsletter @ 9:00 PM, it is still warm and humid. It is important to remember that acclimation is key to worker well being during extreme weather conditions (hot or cold). As my 5 year son became flushed, cranky and sluggish during a brief walk/play yesterday in 85 degree weather, I am reminded just how fast a person can be affected by the heat. We in the Puget Sound see such wide range of temperature fluctuation, it is hard to acclimate and special attention should be made to Hot and Cold Illness. Tips for staying "cool" during our Puget Sound weather:
Planning (sufficient water, covered shelter, adjusting rest breaks, lunches and work hours)
Watch all employees more closely this summer it promises to be a hot one. Pay particular attention to new hires and returning workers with special attention to those workers who are not acclimated.
Encourage workers to eat smaller amounts of food more often, keep them hydrated and encourage abstaining from alcohol and tobacco products.
Train workers to recognize the signs and symptoms of heat stress, heat exhaustion and deadly heat stroke.
Remember that no one immediately suffers heat related illnesses. Heat related illness is highly preventable and the symptoms are readily apparent.
Not everyone tolerates the heat. We are all different. If someone has had a previous heat related illness they are more susceptible to the heat.
Don't forget that Labor & Industries has a "Outdoor Heat Exposure" Regulation go to http://www.lni.wa.gov/WISHA/Rules/generaloccupationalhealth/HTML/62j-1.htm#wac296-62-095

To download a heat index table visit our course website: http://www.closegroup.org/moodle under Health and Safety (FREE)

Respirators in the Workplace

It’s not just about Respirators

As an industrial hygienist I find the particular challenges of conducting exposure assessments fascinating. Many people tell be they would rather watch paint dry... more about paint later. Many clients tell me, we need to know what exposures should be assessed and which respirators make the most sense for our employees.
Lately, I have been involved in providing expert testimony in cases involving respiratory protection and worker exposure evaluations. The most recent case became so confused that the Judge queried me for nearly fifteen minutes regarding the rules surrounding respirators and employers’ responsibilities regarding conducting employee exposure determinations for airborne contaminates.
Afterwards, I thought to myself, if it is this confusing during a case before the Board of industrial Insurance Appeals how can we expect the average employer to understand… let alone comply with the law.
The use of any respirator should be based upon an accurate exposure assessment answering the question, how much airborne contaminate(s) will the employee be exposed? Only by an accurate exposure assessment can appropriate selection of respiratory protection be assured.

Let me give two (2) examples.

EXAMPLE 1: SILICA
Most of the time a negative pressure air-purifying respirator with HEPA cartridges is simply issued to a worker exposed to silica. However, in the Northwest, there are actually three (3) measurements that need to be taken when assessing airborne silica levels. Those measurements include:
Total respirable dust (unique monitoring required) PEL 5.0 mg/M3
Respirable silica (unique monitoring/analysis required) PEL 0.1mg/M3
Cristobalite (unique monitoring/analysis required) PEL 0.05 mg/M3
All three of these assessments can be accomplished simultaneously if the industrial hygienist and laboratory make appropriate preparations.
Ultimately, all three contaminates must be combined into a mixed contaminate assessment. In other words they are added together. The ten times (10x) protection factor (PF) for a half-face respirator may not be adequate.

EXAMPLE 2: PAINTS
The majority of time a half face negative pressure air-purifying respirator with organic cartridges with pre-filter/HEPA is given the worker exposed to paint mists/vapors. However, once again it is important to consider that the paint is typically a formulation of many hazardous chemicals. Exposure evaluations for paints should be unique permissible exposure limit (PEL) assessments referred to as fifteen (15) minute short term exposure limits or STELS. You might also have a unique chemical that requires a ceiling limit assessment.
Sampling for this type of exposure often results in multiple chemical assessment and analysis. The rule of law requires that all chemicals with a similar target organ must be combined. Similar to the Silica example where the target organ was the lung: if several solvents in a paint formulation have a similar target organ then they must be combined.
This is often referred to as a “mixed solvent” exposure assessment.

Exposure assessments do not need to be conducted for each and every exposure. Deciding what types of exposures and how many assessments need to be conducted is all part of a proactive safety program.