It’s time to post your OSHA Form 300A annual summary of work-related injuries and illnesses, which must be posted from February 1 through April 30.
“These summaries help increase awareness and understanding of health and safety issues in the workplace,” said Cal/OSHA Chief Juliann Sum. “By addressing potential safety hazards now, employers can help make next year’s list shorter.”
The overview includes the summary template, Form 300A, a required workplace posting which must be placed in a visible and easily accessible area at each worksite. Current and former employees, as well as employee representatives, must be allowed to review injury and illness records for those employees’ worksites.
Employers are required to complete and post Form 300A even if no workplace injuries occurred.
New Exclusions for Solvent Recycling and Hazardous Secondary Materials
EPA’s new final rule on the definition of solid waste creates new opportunities for waste recycling outside the scope of the full hazardous waste regulations. This rule, which went into effect on July 13, 2015, streamlines the regulatory burden for wastes that are legitimately recycled.
The first of the two exclusions is an exclusion from the definition of solid waste for high-value solvents transferred from one manufacturer to another for the purpose of extending the useful life of the original solvent by keeping the materials in commerce to reproduce a commercial grade of the original solvent product.
The second, and more wide reaching of the two exclusions, is a revision of the existing hazardous secondary material recycling exclusion. This exclusion allows you to recycle, or send off-site for recycling, virtually any hazardous secondary material. Provided you meet the terms of the exclusion, the material will no longer be hazardous waste.
Learn how to take advantage of these exclusions at Environmental Resource Center’s live webcast where you will learn:
- Which of your materials qualify under the new exclusions
- What qualifies as a hazardous secondary material
- Which solvents can be remanufactured, and which cannot
- What is a tolling agreement
- What is legitimate recycling
- Generator storage requirements
- What documentation you must maintain
- Requirements for off-site shipments
- Training and emergency planning requirements
- If it is acceptable for the recycler to be outside the US
Tampa RCRA and DOT Training
Chicago RCRA, DOT, and IATA/IMO Training
Dallas RCRA and DOT Training
How to Implement OSHA’s Globally Harmonized Hazard Communication Standard (GHS)
OSHA has issued a final rule revising its Hazard Communication Standard, aligning it with the United Nations’ globally harmonized system (GHS) for the classification and labeling of hazardous chemicals. This means that virtually every product label, safety data sheet (formerly called “material safety data sheet” or MSDS), and written hazard communication plan must be revised to meet the new standard. Worker training must be updated so that workers can recognize and understand the symbols and pictograms on the new labels as well as the new hazard statements and precautions on safety data sheets.
Best Touch Tub & Tile Employee Dies of Acute Exposure to Methylene Chloride
“This man died tragically and needlessly,” said Howard Eberts, OSHA’s area director in Cleveland. “OSHA recommends alternative, less hazardous chemicals or methods be used to eliminate exposure to methylene chloride. When employers use products containing methylene chloride, they must train workers to protect themselves.
Investigators determined Best Touch Tub & Tile employee, on the job for about three years, was working alone to refinish a bathtub in a Cuyahoga Metropolitan Housing Authority complex. To deglaze the tub, he poured a paint remover containing 85 to 90% methylene chloride into the bathtub, brushed it on the sides and began scraping the tub. With the room’s door closed to prevent fumes from filling the living area, the worker’s only ventilation was the bathroom window kept open with a can of shaving cream. Two hours later, the apartment’s resident found the man unresponsive. The investigation found the worker’s exposure to methylene chloride far exceeded permissible exposure limits.
OSHA cited Best Touch Tub & Tile for failing to:
- Monitor a worker’s exposure to methylene chloride
- Provide medical surveillance
- Train workers in using, storing and taking protective measures to minimize exposure to hazardous chemicals used on the job
- Provide adequate respiratory protection
- Develop a respiratory protection program
OSHA has proposed penalties of $25,200.
Auto Parts Manufacturer Fined for Serious and Repeat Safety Violations
Daeil manufactures struts and other automobile parts for Hyundai Motor Co. and Kia Motor Co.
Other violations include failing to provide workplace injury logs to OSHA within four hours.
“Management at this facility has adopted a productivity-over-safety mentality and repeatedly claims that it is ‘too expensive’ to address the safety hazards found in this workplace,” said Joseph Roesler, OSHA’s area director in Mobile. “The safety culture of this company must change immediately; protecting workers must always come before profit margins.
L&P Springs Manufacturing LLC Fined for Willful and Serious Violations
OSHA initiated an inspection of L&P Springs Manufacturing, LLC, on October 15, 2015, after an employee was hospitalized for serious injuries that occurred after being pulled into a machine that compresses, rolls, and wraps finished innerspring pads. The serious citation was issued for failing to train workers effectively on the use and limitations of work gloves when working with manufacturing equipment and moving material.
“Injuries from improperly guarded machines are preventable and yet L&P failed to provide these guards to protect its workers,” said David Nelson, OSHA’s Area Director in Englewood, Colorado. “The best way to stop these injuries is to equip machinery with the proper guards according to OSHA standards.”
L&P manufactures components and products for the bedding industry.
A S General Construction Inc. Fined $188,000 for 16 Violations
A S General Construction, a contractor with a history of safety violations has again exposed its employees to potentially fatal fall hazards at one of its worksites, this time in Woburn, MA.
Inspectors from OSHA found employees of A S General Construction, Inc. risked falls of more than 26 feet from an unguarded roof and an improperly constructed and erected ladder-jack scaffold at the 51 Pleasant St. job site.
“The danger to these employees was real and present and known to this employer. Not only did A S General Construction not provide required fall protection, it did not train the employees to work safely on scaffolds and had the workers climbing damaged and improperly set up ladders. The result was that these workers were steps or seconds away from deadly or disabling falls,” said Anthony Covello, OSHA’s area director for Essex and Middlesex counties.
Additional hazards found at the Woburn site included lack of safe access to the roof and scaffold, not inspecting the scaffold and its components for defects, failing to remove nails and debris from the work area, and lack of head protection and safety glasses.
A S General Construction has a history of OSHA violations. Several of the violations at the Woburn worksite are similar to those cited by OSHA between 2011 and 2015 at worksites in Dedham and Windham, New Hampshire.
Proposed penalties for these violations total $188,760.
Employers who needlessly and repeatedly fail to do so are gambling with their workers’ lives and well-being,” said Kim Stille, OSHA’s New England regional administrator.
The program focuses on recalcitrant employers that endanger workers by committing willful, repeat, or failure-to-abate violations. Under the program, OSHA may inspect any of the employer’s facilities if it has reasonable grounds to believe there are similar violations.
Telefast Industries is a subsidiary of Elgin Fastener Group of Brecksville, Ohio, which operates eight manufacturing locations around the country. The company provides engineered fastening solutions serving wholesalers, distributors, and equipment manufacturers.
Seitz Tech LLC Fined $55,400 for Latest Violations
Investigators found that employees were again exposed to fire and electrical hazards, including work areas that were not free from excess materials, including, but not limited to piles of scrap, cardboard boxes, and building debris; outlet boxes installed without a cover or face plate; and the use of flexible cords and orange construction-type extension cords as a replacement for permanent wiring. The company was cited for similar violations in June 2011 and March 2015.
“Seitz Tech LLC is taking unnecessary chances with the safety of its employees by refusing to correct these hazards,” said Nicholas DeJesse, director of OSHA’s Philadelphia Area Office. “Its level of disregard for worker protection will not be tolerated.”
Service Plus Inc. Cited for Willful and Serious Safety Violations
Inspectors also found the company:
- Did not require employees to use appropriate hand protection when exposed to thermal burns
- Did not install electrical equipment properly, in accordance with instruction
- Improperly used flexible electrical cords
“Each year thousands of workers are injured on the job by machine and electrical hazards like we found at Services Plus,” said Robert Bonack, OSHA’s area director in Appleton. “Services Plus must immediately reevaluate its safety and health practices to protect their workers on the job.”
Services Plus is a custom packaging company that also inspects and repackages product that may have become damaged or mislabeled.
Hurtado Construction Co., Fined for Serious and Repeat Trenching Violations
- The repeat violations include failing to provide a safe means of egress, failing to provide protection from excavated materials, failing to inspect an excavation prior to the start of work, and failing to provide adequate cave-in protection such as sloping, benching, or using a protective shield system.
“A trench cave-in can take a life in a matter of seconds. Repeatedly exposing workers to trenching hazards without adequate protections is unconscionable,” said Joann Figueroa, OSHA’s area director in the Houston North office. “OSHA’s standards must be followed to prevent workers from being harmed.”
Rich Products Corp. Fined $155,000 for Chemical, Noise, Other Hazards
Some of the 11 serious violations cited include failing to:
- Provide written notice of annual audiograms
- Refit workers for hearing protection and training
- Test ammonia detectors, and implement an emergency response plan for potential release of anhydrous ammonia
- Provide an annual fit test for respirator use
- Provide a medical evaluation to determine employee’s ability to use a respirator
The repeat violations, all relating to the PSM, include failing to:
- Include a relief design system for the process safety information to maintain adequate pressure
- Provide accurate calculations for the ventilation system design
- Provide adequate procedures for draining oil pot vessels
Proposed penalties total $155,000.
“Process safety management is necessary for preventing or minimizing the consequences of an unexpected release of toxic, reactive, flammable, or explosive chemicals in the workplace. This includes liquids and gases in processes involving highly hazardous chemicals such as ammonia,” said Travis Clark, OSHA’s area director in Corpus Christi. “It’s vital that Rich Products ensure safeguards are in place to protect worker safety and health at this facility.”
Telefast Industries Inc. Exposed Workers to Amputation Hazards, Fined $121,000
OSHA cited Telefast for four repeated, two serious, and two other-than-serious safety violations on January 21. The agency has proposed penalties of $121,000.
“I cannot imagine reaching into a machine to clear a product jam or make a quick fix without knowing the machine was inoperable,” said Howard Eberts, OSHA’s area director in Cleveland. “Yet, these workers—like thousands do across the nation each day—reached into operating machines. Many suffer severe and disabling injuries. Employers must protect their workers on the job.”
Two Employers Fined for Serious Meat-Grinder Accident
Cal/OSHA has cited Vitco Meats and temporary employment agency Volt Workforce Solutions a combined $74,500 following a nearly fatal accident at a San Luis Obispo meat processing plant that left a worker with a crushed right hand, a broken arm, and nerve damage. Neither company had trained the employee to safely operate or clean the industrial meat grinder he was operating.
“When companies hire temporary employees they do not sign away their responsibilities to protect workers from industrial accidents,” said Cal/OSHA Chief Juliann Sum. “Both temporary employment agencies and host employers are required to ensure workers are trained and understand safety procedures.”
On July 16, 2015, the worker was attempting to remove ground beef stuck inside the hopper of a meat mixer, which moves beef into the grinder. When he reached into the hopper, the power was still live. Paddles that move the beef rotated twice, causing severe injuries to the employee. Had the paddles rotated a third time, the accident could have been fatal.
Cal/OSHA’s investigation found that Vitco Meats did not require employees to disengage the power on industrial equipment prior to cleaning. Additionally, the company lacked specific procedures for powering down the meat grinder, which also lacked a required cover with interlock. Cal/OSHA issued a total of nine citations to Vitco Meats with proposed penalties of $63,900.
Cal/OSHA also issued a serious citation to Volt Workforce Solutions for failing to ensure that Vitco Meats had an injury and illness prevention program or safety training for meat grinders. A serious violation is cited when there is a realistic possibility that death or serious harm could result from the actual hazardous condition. The company was also issued one regulatory and two general citations for proposed penalties of $10,600.
Workers can be electrocuted or suffer permanent disfigurement due to inadvertent activation of a machine while it is being maintained, repaired or adjusted. Failure to develop and follow lockout/tagout procedures before working on machinery is one of the major causes of serious injury and death in California. Lockout/tagout procedures refer to the use of devices to ensure equipment cannot be operated until the devices are removed.
Lake Compounce Theme Park Employees Exposed to Chemical, Fire, Other Hazards
On January 15, 2016, the Hartford Area Office of OSHA cited the Lake Compounce Family Theme Park for 18 serious violations of workplace safety standards.
The company exposed employees spraying coatings on park equipment and working with caustic chemicals in the park’s paint room to chemical, burn, and respirator hazards. These hazards included failing to:
- Train employees about hazardous chemicals
- Complete a hazard assessment for protective equipment needed by workers
- Provide required eye- and hand-washing facilities for employees working with chemicals
- Fit-test and determine employees’ ability to wear respirators and provide them with respirator training
- Ground electrical equipment properly
- Keep spark-producing tools out of a flammable spray booth
- Dispose of flammable waste properly
- Prevent flammable spraying when a ventilation system is inactive
Proposed penalties total $70,200.
“These conditions exposed Lake Compounce Family Theme Park employees to serious burn, fire, chemical burn, electric shock and eye, face and hand injuries. The employer must act promptly to effectively eliminate these hazards before they injure its employees,” said Warren Simpson, OSHA’s area director in Hartford.
Phoenix Products Co. Fined $61,600 for Multiple Safety Violations
Inspectors found that Phoenix Products, a manufacturer of swimming pool chemicals and acetone preparations used in nail polish were exposed employees to chemical, fire, and exit access hazards. The company’s manufacturing processes use large amounts of the flammable chemicals acetone and isopropyl alcohol 99%. OSHA standards require a workplace to have a program for safely managing processes involving large amounts of these chemicals.
Deficiencies included:
- Not conducting a hazard analysis
- Having no written operating procedures for each step of the process
- Not compiling information about process equipment
- Not inspecting and testing process equipment
- Not documenting employee training
- Lacking an emergency action program
Additional chemical and fire hazards involved a locked emergency exit gate, an exit route through a hazardous area, rusted exit stairs, lack of overflow protection for storage tanks, deficient vent piping, and not documenting that storage tanks had been strength tested. Proposed penalties total $61,600.
“Work involving large amounts of highly hazardous chemicals requires that the employer analyze, document and provide safeguards to prevent the possibility of an explosion or uncontrolled release of these chemicals. The deficient safeguards at this plant increase employees’ risk of sustaining serious, even life-threatening burns,” said Warren Simpson, OSHA’s area director in Hartford. “Phoenix Products needs to effectively and expeditiously correct these deficiencies to minimize and prevent a catastrophic incident.”
Allenwood Federal Prison Workers Exposed to Infection from Sharps
On July 23, 2015, OSHA inspected in response to a complaint alleging hazards involving exposure to needles and other sharps. Investigators determined the prison exposed its employees to sharps-related injuries while they performed pat downs and housing unit searches because the employer did not require the use of puncture resistant gloves in these activities. This resulted in the willful violation.
“Without puncture resistant gloves, Allenwood prison employees are at risk of puncture wounds and exposure to potentially contaminated sharps, as well as the dangers of infection caused by blood-borne pathogens,” said Mark Stelmack, director of OSHA’s Wilkes-Barre Area Office. “It is the employer’s legal responsibility to ensure a safe and healthful workplace for prison employees.”
PGE Wind Farm Wins Safety Recognition
Oregon OSHA has announced that Portland General Electric Co.’s, Biglow Canyon wind farm has received an award for completing its first year of involvement in the Safety and Health Achievement Recognition Program (SHARP).
SHARP provides an incentive for Oregon employers to work with their employees to find and correct hazards, develop and implement effective safety and health programs, and continuously improve. The program aims to encourage employers to become self-sufficient in managing workplace safety and health issues. Currently, about 32 employer locations in Oregon participate in SHARP. That’s in addition to about 142 employers that have graduated from the program. An employer becomes a graduate when it completes five years of SHARP.
PGE employs nine people at the wind farm near Wasco in Sherman County. Encompassing 217 turbines spread across 25,000 acres of wheat fields, the wind farm produces an average of 150 megawatts—enough to power an estimated 125,000 homes. The wind farm’s peak generating capacity is 450 megawatts.
“The SHARP program is important to us because it is driven and owned by the employees,” said Ken Brock, safety coordinator for PGE’s generating plants in eastern Oregon and Washington. “It continues to push people to look for something better or think outside the box instead of settling for the ‘we are good enough’ mindset. You look around in different industries and see so many top-down driven programs, but they just aren’t as effective. When a program is owned by the employees it changes the culture, and that’s what drives us to a safe and healthy workplace.”
Oregon employers that have been in business for more than one year are eligible to apply for SHARP regardless of size or type of business, although the program is primarily designed to help small and mid-size businesses.
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