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Reduce Safety Risks and Remain Compliant with an I2P2

By Mandy Sunderland, Sr. Industrial Hygienist, Total Safety

For years, OSHA has been developing a rule to require employers to establish and maintain an Injury and Illness Prevention Program (I2P2). While the actual rule is still in the works,  OSHA released a white paper in January 2012 concerning I2P2 and a potential new rule that would require employers to proactively find and fix hazards in their workplace.

What is an I2P2?

Typically created by experienced safety and health professionals, an I2P2 defines minimum acceptable work practices at a given work site and lays out a structure of responsibility and authority to systematically address workplace safety and health hazards on an ongoing basis to reduce the extent and severity of work-related injuries and illnesses. Basically, an I2P2 takes a proactive approach to controlling incidents as it focuses on finding hazards in the workplace before an accident occurs and developing a plan for preventing and controlling them.

The key elements common to successful I2P2s are:

  • Management leadership
  • Worker participation
  • Hazard identification and assessment
  • Hazard prevention and control
  • Education and training
  • Program evaluation and improvement

In addition, it’s critical to periodically evaluate your I2P2 to determine whether improvements need to be made.

For readers who participate in OSHA’s Voluntary Protection Program (VPP), you are already familiar with these core elements of your organization’s safety and health program. Readers whose organizations have incorporated either one of the two voluntary consensus standards, ANSI/AIHA Z10-2005 or OHSAS 18001-2007 on Occupational Health and Safety Management Systems should be well-prepared for I2P2.

OSHA’s 1998 Draft of a Proposed Rule on Safety and Health Management Programs allowed the “grandfathering” of employers who have implemented a program that included the core elements mentioned above, or demonstrated the effectiveness of any provision that differs. Although there is no guarantee that any future proposed rule would include a grandfather clause, the benefits to be gained in finding and fixing safety and health hazards in an organized and documented manner are worth the time and effort.

Why do we need an I2P2?

Every day, more than 12 workers die on the job, which equates to over 4,500 a year. In addition, more than 4.1 million workers suffer a serious job-related injury or illness each year. The actual cost of a fatality or lost workday injury is substantial, not to mention to the anguish these incidents impose on the workforce. For every dollar spent on direct costs, up to ten times more is spent on indirect and hidden costs. These indirect costs include:

  • Lost productivity by the injured employee and their co-workers
  • Time spent on investigations completing paperwork
  • Clean up and re-start of operations interrupted by the accident
  • Time to hire or train replacement workers
  • Time and cost for repair or replacement of damaged equipment or materials

However, we are not powerless when it comes to preventing serious injuries. We can and should have a handy tool in our EHS arsenal to help prevent these incidents from occurring in the first place – a solid, effective I2P2. As stated by OSHA in their January 2012 white paper:

‘Thirty-four states and many nations around the world already require or encourage employers to implement [I2P2s]. …These countries include Canada, Australia, all 27 European Union member states, Norway, Hong Kong, Japan and Korea. This initiative also follows the lead of 15 U.S. states that have already implemented regulations requiring such programs.”

Whether you need to develop a comprehensive program tailored to your facility for the first time or simply need to update your existing I2P2, you will help reduce the risk of work-related incidents and remain in compliance with current and future legal requirements.

ICU, a Total Safety Company, Has Relocated

ICU, Total Safety's Environment, Health and Safety Services Company, has relocated in Houston, Texas.ICU, A Total Safety Company will now offer environmental, health and safety services from a new location:

4100 N. Sam Houston Parkway W., Suite 290 Houston, TX 77086

Business: 281.363.9939
Fax: 281.363.4744

ICU’s professional experience and expertise provides customers with the resources necessary to complete  EHS projects successfully, within budget and on time, while reducing risk and liability. Continue to look to our experts for Occupational Health Services, Safety Services, Technical Training Services, Environmental Services and more, just from a new, centralized location.

Total Safety Acquires Industrial Hygiene Consulting Firm, Pacific Environmental

Total Safety Acquires Pacific Environmental Consulting“We are honored to have Pacific’s talented team join the Total Safety family,” said David E. Fanta, Chief Executive Officer of Total Safety. “Canada remains a very strategic market for Total Safety and we have many clients asking us to expand our service offering to include industrial hygiene and occupational safety. Working with Peter and the other professionals at Pacific, we will now be able to provide an even more comprehensive suite of safety solutions in this key market.”

Pacific Environmental, headquartered in Vancouver and founded in 1990, provides engineering and consulting services focused on worker health and safety. Those services incorporate Canadian Centre for Occupational Health and Safety (“CCOHS”)/Provincial Workers Compensation Board (“WCP”) regulatory requirements in the delivery of workplace environmental and industrial hygiene consulting services to a wide range of customers in Western Canada.

Its core industrial hygiene competencies include worker exposure monitoring, air quality assessments, laboratory analysis and chemical safety audits. Pacific also handles environmental consulting and assessments, hazardous material audits, worker training programs, health and safety audits, confined space audits, fall protection programs and workplace regulation reviews in consultation with regulatory authorities.

Peter Hansen, Pacific’s President and Co-Founder, stated, “This is a very exciting time for our employees and clients. The synergy between our two companies will accelerate market growth and career opportunities, a true winning combination. The Pacific team looks forward to partnering with such a dynamic team, offering our customers additional services, and complementing Total Safety’s current Canadian portfolio while continuing to add value for our clients.”

For more information on Total Safety and how we can equip your company with the best in industrial hygiene services and equipment, give us a call at 888.44.TOTAL.

Total Safety – The Best Minds in the Business!

 

Industrial Hygiene Planning for Successful Turnarounds

By Mandy Sunderland, Senior Industrial Hygienist , Total Safety

 Turnarounds can be expensive in terms of lost production while the process unit is offline, and in direct costs for labor, tools, heavy equipment and materials used to execute the project.

A well planned and executed turnaround helps ensure the project is conducted safely and efficiently, so the unit can be returned to operation as quickly as possible.  Tremendous effort typically goes into planning and coordinating the various aspects to ensure all necessary repairs and maintenance are conducted during the turnaround, so the unit doesn’t have to be shut down again until the next planned turnaround.  However, far too often industrial hygiene issues are not adequately addressed in the early phases of turnaround planning.  Playing catch-up in this area can have a negative impact on worker safety, project budget and schedule.

To help ensure turnaround success, the following industrial hygiene items should be considered during planning:

  • DETERMINE potential exposures to chemical agents well in advance and identify requirements for trained personnel and equipment.  Based on potential exposures, the project may require IH devices such as real time direct reading instruments to measure agents such as total hydrocarbons or H2S. Personal and area air samples for laboratory analysis may also be required to measure specific agents in welding fumes or catalyst. 
  • DEVELOP clear guidelines for PPE (personal protective equipment) use throughout the project, including respiratory protection, hearing protection, gloves, coveralls and safety shoes. Access control plans should be developed to ensure workers aren’t exposed to hazards unnecessarily. Special attention should be given to any jobs involving confined space entry. Defining and communicating PPE requirements in advance helps ensure that contractors will provide proper equipment and trained personnel.
  • DEFINE the types and numbers of worker and activities to be monitored. An IH sampling strategy should be developed which sets requirements for full shift TWA (time weighted average) sampling or activity specific STEL (short term exposure limit) sampling. Some operators monitor their own company employees, but require contractors to monitor their own workers. Coordinating these plans will help prioritize resources to better protect workers.
  • UNDERSTAND the full scope and length of the turnaround. Determine if IH monitoring will be required during the preparation phase, actual shutdown, line breaks, vessel entries or start up and commissioning. Ensure adequate and appropriate IH materials, supply and support are available throughout the project.
  • DECIDE which analytical laboratories will be used for IH samples.  Agree on the types of reports needed (e.g. full report with specific recommendations or rough data only). Consider who will need to see results in order to keep the project running smoothly and maximize worker protection. 
  • ANTICIPATE the unexpected. Don’t get caught off guard by unexpected exposures to NORM (naturally occurring radioactive material), asbestos or PCBs. If you don’t have a clear picture of potential exposures, bring in an IH expert to conduct a survey of the project area and a review of the turnover plan.

In summary, a comprehensive industrial hygiene strategy will help ensure your next turnaround project is completed safely, within budget and on schedule. Therefore during your next turnaround planning cycle be sure to thoroughly examine industrial hygiene issues in your decision making process.  It can save you bucks!

To learn more about Total Safety or our complete line of industrial hygiene services, contact us at 888.44.TOTAL (888.448.6825).

Total Safety – The Best Minds in the Business!

The HazCom World is Changing

By John Baker, CIH, Industrial Hygiene Support Services Manager, Total Safety

Back in 1983, the OSHA Hazard Communication Standard, 29CFR1910.1200, was born. This important worker right-to-know standard was well founded on a three legged stool: (1) labels on containers, (2) accurate and complete Material Safety Data Sheets (MSDS) and (3) training of employees.

In that year, most personal computers still used the MS-DOS operating system and didn’t have a mouse; the last episode of M*A*S*H was aired, and President Ronald Reagan called the Soviet Union the “Evil Empire,” while we were still in the throes of the Cold War. We were on the threshold of major changes in our international relationships as a suicide bomber destroyed the US Embassy in Beirut, Lebanon killing 63 people.

Since then, the world has continued to change as a result of “globalization.” We are exporting products to and importing products from countries, which may use hazard classifications that differ from ours. These differing classifications could impede trade and the accurate communication of safe practices to employees, customers and the general public. For example, a liquid with a flash point of 120º F would have been considered “Flammable” in Germany, but OSHA would consider it “Combustible.”

Under the leadership of the U.S. Department of State, OSHA, along with EPA, CPSC, FDA and DOT, are considering whether our approach to informing and protecting workers and the public should conform to the Globally Harmonized System for Classification and Labeling of Chemicals (the GHS) established by the United Nations in 2003 with the current 3rd edition released in 2009. Regarding employee safety and health, OSHA published a proposed rule in 2009 to implement the GHS, with public hearings to be held this year. For transportation purposes, DOT has already revised the Hazardous Material Regulations to harmonize classification of toxic materials and flammable liquids with UN Model Regulations. Regardless of whether the rest of the U.S. government formally adopts the GHS, we, in industry, must become knowledgeable about the system because most of our important trading partners, including Canada, Mexico, the UK and the other members of the European Union, China, Japan, Korea and Australia, have committed to aligning their hazard communication requirements with the GHS.

So what will change under GHS?

For one thing, Material Safety Data Sheets (MSDS) will be known as “Safety Data Sheets (SDS),” and they must adhere to a 16 section format similar to ANSI Z400.1 developed through the leadership of the American Chemistry Council. But under GHS, Section 2 will be “Hazard identification” and Section 3 will give “Composition/information on ingredients” instead of the other way around.

Also Section 2 must list the GHS hazard class and category, such as Flammable Liquid, category 1, and specific label elements including “signal words,” e.g., “Danger” or “Warning;” standardized hazard statements and code, such as “H224, Extremely Flammable Liquid and Vapor,” standardized precautionary statements and codes, such as “P210, Keep away from heat/sparks/open flames/hot surfaces – No smoking” and new graphic symbols called “pictograms.” For example, the three pictograms below indicate that the material may pose various types of toxicity. The proper pictogram to use will depend on the GHS hazard class and category.

For the latest in occupational health and safety, go Total Safety.

At this time, it is expected that after the public hearings this year, and a post-hearing comment period, OSHA will draft and adopt a final rule in 2011, with a transition period for adoption through 2014. There is a wealth of information at the OSHA web site, which should be checked regularly to keep posted on changes.

Building an Industrial Hygiene Program from the Ground Up

By Chuck Dingman, CIH, CSP Industrial Hygiene Services Manager, Total Safety

For the best in industrial hygiene, go Total Safety.So your manager has instructed you to develop a new Industrial Hygiene Program or correct deficiencies in the current program for your organization.  Just what does that mean, and where do you begin?

Simply stated, the field of industrial hygiene encompasses agents and conditions that can impact employee health and well-being in the work environment.  The list of potential factors or stressors that can impact health and well-being include exposure to chemicals, high noise levels, ionizing and non-ionizing radiation, biological organisms, temperature extremes and ergonomic hazards. All these hazards must be assessed and controls implemented where unacceptable exposure conditions exist.  Potential controls include hearing conservation, respiratory protection, radiation safety, heat stress, medical surveillance programs, and work practice and engineering controls.  These programs and controls must be managed effectively to protect employee health and well-being.  But which programs and controls do you really need?     

The Workplace Exposure Assessment Process

There are two options available to you for identifying needed programs and controls. The first is to spend your time, money and effort putting out fires, i.e. reacting to workplace complaints, concerns and demands. The other option is to conduct a comprehensive, systematic assessment of needs and implement a proactive program to address and manage those needs. In either case, the assignment can be daunting, but can be made manageable with the right approach. The Workplace Exposure Assessment (WEA) process provides one such approach.

Traditionally, the WEA process was developed to evaluate potential chemical exposures. With modifications, the same WEA process can, however, be applied to evaluate nearly all potential industrial hygiene health risks. 

The process of performing a WEA involves a series of distinct steps. The first step in a chemical WEA is to identify job classifications with potential exposure to specific chemicals. Secondly, a list of tasks that involve potential exposure to those chemicals is made. Step three is to evaluate the toxicity of the chemicals using health codes developed for the Hazardous Materials Information System (HMIS), carcinogenicity ratings, and regulatory or recommended exposure limits.

Finally, a review is made of the respiratory exposure conditions based on the potential for the chemical to become airborne, ventilation or other control systems, and the frequency and duration to which workers may be exposed to the chemical. Workers in job classifications with similar exposure potential to specific chemicals are referred to as Similar or Homogenous Exposure Groups in the WEA process. Decision making logic within the WEA process is applied to produce a listing of SEGs prioritized from highest (A) to lowest (C) exposure potential. In the case of potential chemical exposures, industrial hygiene monitoring is performed initially for “A” priority SEGs and secondarily for “B” Priorities.  “C” priorities are those determined through the WEA process to be in control. 

Ultimately, the WEA process is used to drive the need for respiratory protection, hearing conservation, ventilation, medical surveillance, personal protective equipment, radiation protection or other industrial hygiene programs. Where programs are needed, a written program is developed that establishes procedurally the process by which the program will be implemented and managed. The end result of the process may be the determination that a program is not needed or can be eliminated. In this case, the organization has data and documentation justifying the lack of a particular program or termination of an ongoing program.           

The WEA process does not guarantee success.  Ultimate success will require ongoing management support and a focus on staying the course. In the real world, issues will arise that will require a shift in priorities from time to time. The goal is to ensure that these shifts are only temporary and that focus is returned to the systematic path you have charted once the issue is resolved.

For more infomation on how to develop an industrial hygiene program for your company, call us at 888.44.TOTAL.

Total Safety – The Best Minds in the Business!

The OSHA Challenge Program, First Steps to the VPP Star

By Chuck Gibson, VPP Manager, Total Safety

For increased occupational health and safety, go Total Safety.Preparing for and attaining certification in the OSHA Voluntary Protection Programs (VPP) can sometimes seem to be a confusing and overwhelming task, particularly for companies that do not have mature safety and health management systems already in place. To help, OSHA has developed a program for companies that are interested in improving their safety and health management systems and potentially participating in VPP, but may need assistance in understanding and meeting VPP requirements. The Challenge Program provides a comprehensive self-paced, three-stage roadmap that leads to improved safety and health management systems and preparation for VPP application.

Challenge is open to General Industry and Construction employers (determined by SIC/NAICS code) in both public and private sectors under OSHA federal jurisdiction. The Program is facilitated by OSHA-designated Administrators who may be corporations, nonprofit organizations or federal agencies. The Administrators act as the primary contact between OSHA and the Challenge Participant, and guide the Participant through the program stages. At the completion of each stage, the Administrator will review the participant’s progress and authorize advancement to the next stage.  OSHA will formally recognize progression from stage to stage and issue a certificate of graduation upon completion of Stage III. Provided it meets basic criteria, such as mishap rates and citation history, an organization should be ready to submit a VPP application following graduation, and may be considered for expedited review for certification.

To become a Challenge Participate, a candidate organization must first affiliate with an Administrator. A list of Administrators is available on the OSHA website or by calling your local OSHA office. The candidate organization completes an application and statement of commitment that is reviewed by OSHA, and upon acceptance, is designated an OSHA Challenge Participant. The Participant then proceeds through three progressive stages of safety and health program improvement with specific action and outcome requirements related to the VPP elements; management leadership and employee involvement, worksite analysis, hazard prevention and control, and safety and health training. As the Participant organization works through the stages, it will change from being reactive to proactive in identifying and controlling hazards. Additionally, it will progress in knowledge of and compliance with OSHA standards, develop an improved workplace safety culture, have improved documentation, increase safety and health activities, and show improvements in injury and illness rates. Documentation of achievements is required and progress is tracked on an electronic spreadsheet that provides color-coded status on each action and outcome item and a percentage completion level for the current stage.

The beauty of Challenge is the step by step guidance and direction it provides for improving a safety and health management system. The required actions and outcomes for each sub-element in each stage eliminate the guesswork of “what do I do next” for Participants. The status tracking sheet provides a visual and easy to understand tool to chart program progress. Even for organizations that consider their safety and health management systems more mature, Challenge tools and guidelines provide utility in confirming that necessary program elements are in place and functioning effectively. Go online and look at the list of Challenge Participants. It should come as no surprise that the list includes OSHA regional and area offices that are striving to become VPP certified themselves. So follow the lead of the experts. If you think your organization is not quite ready for VPP don’t be troubled – take the OSHA Challenge and travel the road to improved safety and health.

For more ideas on ways to increase occupational health and safety in your workplace, call us at 888.44.TOTAL.

Total Safety – The Best Minds in the Business!