Our Safety Blogs

HAZMAT TRANSPORTATION TRAINING REQUIREMENTS An Overview of 49 CFR Parts 172-173 IT'S THE LAW Training is the best means of preventing or reducing, hazardous materials (hazmat) incidents in transportation that are caused by human error. The Federal hazardous materials transportation law (49 U.S.C. 5101, et seq.) is the statute pertaining to the transportation of hazmat in the United States, and requires the training of ALL hazmat employees. The purpose of this training is to increase a hazmat employee’s safety awareness and to be an essential element in reducing hazmat incidents. The Hazardous Materials Regulations (HMR) includes training requirements in several sections of Title 49 Code of Federal Regulations (CFR) as follows: GENERAL §173.1 FUNCTION-SPECIFIC §172.704 MODAL Air §175.20 Vessel §176.13 Highway §177.800, 177.816 Receiving the required training enhances employee safety and security, and increases employee productivity and skills. Effective training also reduces incidents and accidents thereby reducing operating costs and losses from property damage, thus increasing profits. HMR TRAINING REQUIREMENTS Each hazmat employer must train and test their hazmat employees, certify their training, and develop and retain records of current training. Hazmat training must include, or be: General awareness/familiarization; Function-specific (for example; packaging, markings, labeling, placarding, etc.) Safety; Security awareness; In-depth security training, if a security plan is required; and Driver training (for each hazmat employee who will operate a motor vehicle). Accordingly, we offer a range of online safety training courses to fulfill the training requirements as stated in the U.S. DOT's Hazardous Materials Regulations (HMR) to support employers in their objective of protecting employees' health while satisfactorily completing their job tasks. FREQUENCY OF TRAINING Initial training of new hazmat employees, or an employee who changes job functions, must be completed within 90 days of employment or change in job function. A new employee may perform hazmat job functions before completing training provided the employee does so under the direct supervision of a properly trained and knowledgeable hazmat employee. Recurrent training is required at least once every three years. The three-year period begins on the actual date of training. Relevant training received from a previous employer or source may be used to satisfy the requirements, provided a current record of training is obtained from the previous employer or other sources. TRAINING RECORDS Training records must be kept by the hazmat employer for each hazmat employee, and must include the following: the hazmat employee’s name; the completion date of the most recent training; training materials used (copy, description, or location); the name and address of the hazmat trainer; and certification that the hazmat employee has been trained and Training records must be retained for each hazmat employee for three years from the date of the last training, and for 90 days after the employee leaves. DEFINITIONS Training - a systematic program (consistent approach, testing, and documentation) that ensures a hazmat employee has knowledge of hazmat and the HMR, and can perform assigned hazmat functions properly. See §172.700 through §172.704. Hazmat employer - a person who uses one or more employees regarding: transporting hazmat in commerce; causing hazmat to be transported or shipped in commerce; or designing, manufacturing, fabricating, inspecting, representing, marking, certifying, selling, offering reconditioning, testing, repairing, or modifying packaging as qualified for use in the transportation of hazmat. The term “hazmat employer” also includes any department, agency, or instrumentality of the United States, a State, a political subdivision of a State, or Native American Indian tribe engaged in offering or transporting hazmat in commerce. This term includes a person who is self-employed, including an owner-operator of a motor vehicle that transports hazmat in commerce. Hazmat employee - a person employed by a hazmat employer, or person who is self-employed, and who directly affects hazmat transportation safety including: an owner-operator of a motor vehicle that transports hazmat; a person who: loads, unloads, or handles hazmat; designs, manufactures, fabricates, inspects, tests, reconditions, repairs, modifies, marks, or otherwise represents packaging as qualified for use in the transportation of hazmat; prepares hazmat for transportation; is responsible for safety of transporting hazmat; or operates a vehicle used to transport hazmat. Enroll Now FREQUENTLY ASKED QUESTIONS Question: Why is the DOT Hazmat Transportation Advanced General Awareness training course important? Answer: According to the United States Department of Transportation (DOT) all hazmat shipments must comply with the U.S. DOT Hazardous Materials Regulations as set forth in Title 49 – Transportation. Hence, all hazmat employers and employees who prepare hazardous materials for shipment or engage in the actual commercial transportation of these materials must receive the relevant training. Question: Who should enroll in the DOT Hazmat Transportation Advanced General Awareness online training course? Answer: Employees who work for the following categories of employers must receive the requisite U.S. DOT hazmat training: Common, contract, and private carriers who transport hazardous materials in commerce; Shippers who offer hazardous materials in commerce for transport within states, between states, or internationally; Persons who design, manufacture, inspect, maintain, recondition, repair, or test a package, container, or packaging component that is used for transportation of hazardous materials in commerce; Persons who indicate by marking, labeling, or other means that a hazardous material being transported in commerce is present in a package; Persons responsible for the safety of hazardous materials during transportation; and Compliance officers who certify that all applicable requirements of the HMR are being met. Question: Is there a need for DOT Hazmat Transportation Advanced General Awareness training when transporting small quantities of hazardous materials? Answer: The DOT’s Hazardous Materials Regulations (HMR) do not specify any exceptions to training requirements for shippers/carriers transporting limited or small quantities of hazardous materials. Hence, all personnel involved in transporting HazMat must be adequately trained, irrespective of the amount of hazardous materials being shipped. Question: Do I receive a Wallet ID Card once I successfully complete this DOT Hazmat Transportation Advanced General Awareness training course? Answer: To receive a plastic wallet ID card, upload a passport-style and size photograph to your HAZWOPER OSHA Training account. Alternately, email the photograph to info@hazwoper-osha.com You will receive the plastic wallet card via U.S. mail within 2-3 weeks of course completion. Question: What happens when an employee is not properly trained and what type of fines would be involved? Answer: Violations of any hazmat regulations including training may be subject to a civil penalty of up to $77,114 for each violation. If the violation results in death, serious illness, or severe injury to any person or substantial destruction of property, the maximum civil penalty is $179,933. The minimum civil penalty amount for a training violation is $463. Criminal violations may result in fines, imprisonment, or both. (See 49 CFR §107.329 and §107.333.) Question:  An office secretary types the required hazmat description on a shipping paper at the direction of another, item by item. Is the secretary considered to be a hazmat employee requiring training? Answer: Yes. Any person who performs a function subject to the HMR must be trained, except for special circumstances addressed by §172.704(e). Question: Do hazmat training regulations apply to employees working with materials that are consumer commodities? Answer: Yes. Consumer commodities are listed as ORM-D in the hazardous materials table §172.101. Question: Our hazmat employees have training to ship materials by ground. Are they authorized to ship packages by air or water, also? Answer:   No. Hazmat employees that usually prepare shipments for transportation via highway may not have sufficient training to ship hazmat via other modes of transportation. Trained hazmat employees should be generally aware of the requirements for shipping hazmat via all modes of transportation, but may need additional function-specific training (i.e., modal-specific training) in order to comply with the HMR. Question: Do the hazmat training regulations apply to foreign flag vessels  carrying hazmat? Answer:  Yes. The regulations apply to each non-bulk domestic and foreign vessel while operating in navigable waters of the United States. Question: Do the hazmat training regulations apply to hazmat employers and/or employees who operate a bulk vessel transporting hazmat? Answer: No. Except for transportation in bulk packagings, the bulk carriage of hazmat by water is governed by 46 CFR Chapter I, Sub chapters D, I, N, and O. See 49 CFR §176.5(d).

3 Rewarding Safety Training Methods All employers are well-aware that their employees must receive the appropriate safety training in line with their job roles and responsibilities. While organizations such as the Occupational Safety and Health Association (OSHA) mandate a range of safety training across industries and occupations, these training requirements can differ from industry to industry and based on the risk levels to employees’ safety and health. Employees in construction, mining, hazardous waste, emergency response, hospitals, or factory operations are at greater risk as their exposure to hazards is higher than office-based occupations. Therefore, employers in such industries have a higher stake in ensuring employees are safeguarded than their counterparts in industries prone to lesser physical and health hazards such as banking, financial services, or even the stock exchange! Another set of individuals for whom safety training is of the utmost import is those involved in hazardous materials, chemicals, or hazardous waste transportation. These—full-time, part-time, or contract—employees of private carriers and shippers transporting hazardous cargo in commerce should receive training on reading hazard labels, placards, and hazard markings while being aware of the security requirements when transporting hazmat. The U.S. Department of Transportation (DOT) has put in place the Hazardous Materials Regulations (HMR) to guide on prevailing hazards of transporting hazardous substances and materials, together with guidance on training requirements. Ensure Your Employees Receive Relevant On-Time Safety Training as per OSHA, EPA, RCRA, NFPA, and DOT Hazmat Regulations This brings us to an important question, “how should employees be trained?” The answer can vary depending on the type of work being carried out, the type of industry the organization falls within, and the hazard exposure levels of employees. Furthermore, don’t forget that a lot depends on what governing bodies like the OSHA, EPA, and DOT state in their regulations related to safety training. Examples of Training Requirements as per Regulations To put into context the numerous types of training required, the below table outlines the training requirements as per OSHA, DOT, or EPA regulations. Course Name Online, Virtual ITL, or Group On-Site Training* Field Experience*  OSHA 40 Hour HAZWOPER Online Training – 29 CFR 1910.120 (e) A minimum of 40 hours of off-the-site instruction. A minimum of 3 days of actual field experience.  OSHA 24-Hour HAZWOPER Online Training – 29 CFR 1910.120 (e) A minimum of 24 hours of off-the-site instruction. A minimum of 1 day of actual field experience.  24-Hour HAZWOPER – RCRA TSD Operations Training The initial training shall be for 24 hours, and refresher training shall be for 8 hours annually.  OSHA 8 Hour HAZWOPER Supervisor Online Training 40 hours of initial training OR 24 of initial training + 8 hours of specialized training for the supervisor job role. 3 days of supervised field experience OR  1 day of supervised field experience  Electrical Safety Training (NFPA 70E) Classroom training OR On-the-job type training  OSHA Bloodborne Pathogens Training Training to ensure employees have adequate knowledge to carry out their work as per recommended practices outlined in the Standard. Relevant practical workplace-specific information  DOT Hazmat Advance Awareness 10-Hour Training General awareness/familiarization training and function-specific training *The information regarding the training requirements is a synopsis to give readers a better understanding of the diverse needs of different regulatory standards. This information has been interpreted by the author, for a simpler discourse. The complete training requirements are set forth in the respective standards and can be retrieved from (1) https://www.osha.gov/laws-regs/regulations/standardnumber/1910, (2) https://www.osha.gov/laws-regs/regulations/standardnumber/1926, or (3)  https://www.ecfr.gov/current/title-49/subtitle-B. As seen from the above table, to fulfill the regulatory safety training requirements, employers must use a combination of training methods. These safety training methods must educate the employees on the requirements of key topics as identified in the standard and provide practical hands-on or field experience in the areas of their job responsibilities. To support employers in fulfilling their safety and health obligations to employees and make safety training painless, we have developed and made available at competitive prices a range of safety training courses covering the instruction-based learning aspects as per the safety training requirements of the different regulatory bodies. For a full list of our courses, look at our 2022 Course Catalog!  Examples of key topics for which employees must be trained A general introduction to the relevant OSHA or DOT regulatory standard, The health hazards on site or associated with exposure to a hazardous substance, Use of personal protective equipment, Medical surveillance requirements, and Safe use of engineering controls. We offer these courses in several formats for the convenience of our customers and to suit the diverse training needs of organizations depending on the number of people being trained and the number of safety training courses required. Training Method 1 Training Method 2 & 3 Training Method 4 All our courses are available on our website on our very own dynamic learning management system (LMS) which allows the EHS or safety training manager or the supervisor to register for an account and enroll as many individuals as required for a variety of safety training courses. When employers prefer having an OSHA-approved instructor leading the training program, we provide instructor-led virtual training programs and conduct on-site group training programs.   We also have an option for organizations with their in-house learning management systems (LMSs). Read on to find out more. Online Safety Training As a specialized online safety training service provider our courses meet the highest standards in regulatory training requirements. Our course development team is led by experienced OSHA Certified Outreach Trainers who ensure that all critical aspects of training are fulfilled. Our courses are regularly reviewed; and updated as soon as new requirements or regulations are issued by OSHA, EPA, DOT, and other regulatory agencies. We also understand the importance of using modern and technology-driven learning tools, as well as including a variety of engaging and interactive content to keep the learner involved and make online learning an interesting, easy, and enjoyable experience as possible. Go to our Home Page, hover over the ‘Online Courses’ tab and enroll for the safety training course of your choice! Instructor-Led Virtual Safety Training Our instructor-led training (ILT) is conducted visually using a two-way audio-video communication platform of your choice. Our instructors are highly experienced and bring to the class a variety of real-life examples that truly puts into context the need for safety training and annual refresher training to protect employees working in hazardous works sites. For more information on ILT, click here! Group On-Site Safety Training The third form of training we offer is the traditional classroom training method with a twist. This simply means that we do not expect your employees to travel to a location of our choice but let you choose your preferred site! Whether employers want us to conduct in-person training in their organization’s training auditorium or at another location, we are ready and willing, provided adequate time is given to make the arrangements and we all adhere to the relevant CVOID-19 pandemic safety regulations. For more information on ILT, click here!Simply call or email us for more details! BONUS! SCORM Packages for Corporate LMS Here's our fourth training option. We understand that many larger organizations have their in-house learning management systems (LMSs) and have become experts at providing e-learning, especially through the last two pandemic-infected, social distancing-required years. To facilitate organizational training and development goals and support the learning culture, we can provide you with SCORM packages of whichever HAZWOPER, OSHA construction or general industry, RCRA, DOT Hazmat, or NFPA 70E training course you require. For more information on SCORM Packages, click here!

Recycling Hazardous Waste Encouraged by the RCRA Recycling Hazardous Waste Recycling is an important method for the conservation of natural resources. By adopting the practice of recycling, companies can benefit in many ways—earn a good reputation, attract environmentally conscientious investors and customers, protect scarce resources for future generations, contribute to climate change prevention initiatives, minimize liabilities and risks, lower costs, create new revenue streams, circumvent tedious and detailed regulations of hazardous waste management, among others. When companies pursue recycling goals, they indirectly create broader benefits that benefit the community and the environment in the long term. What is Recycling? According to the EPA, “Recycling is the process of collecting and processing materials that would otherwise be thrown away as trash and turning them into new products.” Who should Recycle Hazardous Waste? Everyone should recycle hazardous waste whenever, wherever, and as much as possible. Most people and organizations are very familiar with the idea of recycling glass, paper, plastic (a hazardous waste in its way), and other materials we use as part of our everyday lives, but most don’t pay adequate attention to recycling hazardous waste. Organizations do seek to store, dispose, and treat hazardous waste and hazardous materials are per OSHA, EPA, and the Resource Conservation and Recovery Act (RCRA) regulations, but there is further room for improving this disposal process by considering the effectiveness of recycling parts of the hazardous waste, materials, and chemicals used and produced when executing business processes and activities. Thus, all organizations must research and implement recycling as part of their hazardous materials and hazardous waste disposal processes. Recycling activities by those hazardous waste generators identified by the RCRA as large quantity generators (LQG), small quantity generators (SQG), and very small quantity generators (VSQG) must become a priority as their efforts would not only benefit their organization but also result in protecting the planet and the health and safety of workers and the public in the longer term. 6 Reasons to Recycle Hazardous Waste Here are six reasons organizations (irrespective of the amount of hazardous waste generated) should embark on hazardous waste recycling. 1.     Broaden your recycling goals Organizations that are identified as hazardous waste generators are already segregating, collecting, and disposing of hazardous waste as per the OSHA, EPA, and RCRA regulations. These organizations also likely have in place recycling goals for other types of waste collected. So, why not broaden recycling efforts and incorporate hazardous waste recycling as part of being a good corporate citizen? Furthermore, those organizations that report using internationally recognized standards such as GRI and integrated reporting principles require to disclose their efforts regarding hazardous waste management. So, if you produce sludge, scrap metal, other hazardous waste materials that can be recycled or reused then you will not only reduce the amount of hazardous waste being disposed and treated but create new avenues for minimizing the use of scarce resources and extending organizational recycling goals. 2.     Contribute to organizational cost control measures Recycling or reusing hazardous materials and hazardous wastes as part of manufacturing operations would result in an indirect benefit of contributing towards organizational cost control initiatives. Just think about it – when sludge is treated and reused within manufacturing operations, then the safe disposal (including storage and transportation) cost of this sludge is negated, and the cost of purchasing other materials that the sludge has replaced would also be nil. 3.     Generate new revenue streams If hazardous waste, chemicals, or other hazardous materials are recycled to produce a by-product then these could be sold to the marketplace and the organization could create a new revenue stream adding to business profitability. Alternately, where there is an excess of recyclable hazardous waste, then the organization could sell this waste to specialized entities for treatment and reuse, converting an expense-centric activity to a revenue-generating one! 4.     Follow EPA and RCRA recommendations on hazardous waste reduction Laws and regulations recommend organizations reduce the amount of hazardous waste created. So, when hazardous wastes like sludges, scrap metal, spent solvent wastes, wood preserving wastes, electroplating and other metal finishing wastes, and partly used or unused chemical wastes are reused or recycled, organizations can benefit from regulatory exclusions where such products/by-products are not considered as hazardous waste. This also reduced organizational risk and exposure to rigorous management of hazardous waste as imposed by RCRA requirements. Remember, when signing off a hazardous waste manifest as required by the EPA and Department of Transportation (DOT)’s Hazardous Materials Regulations (HMR) for the off-site transportation of hazardous waste, the organization is attesting to the fact that every effort has been made to reduce the quantity of hazardous waste generated. 5.     Benefit from RCRA regulatory exceptions To encourage recycling of hazardous waste where possible, the EPA and the RCRA offer regulatory omissions and guidance through alternative standards for the recycling of hazardous wastes, hazardous materials, and solid wastes to hazardous waste generators as part of their regulatory compliances. Some items that fall within the RCRA relief measures include batteries, scrap metal, Cathode Ray Tubes (CRTs), used oil, aerosol cans, certain pesticides, mercury-containing equipment (thermometers), lamps, and precious metals. For in-depth details on the EPA and RCRA regulatory exclusions and alternative standards read here. 6.     Enhance organizational reputation When all the above elements are combined and considered holistically, the organization will be able to enhance its reputation as an ethical business entity striving towards profitability while making every effort to conserve natural resources, protect the environment, and embark on a sustainable journey for meeting the needs of triple bottom line business activities.   Thus, as important as it is to follow the RCRA and EPA’s rules and regulations on the generation, transportation, treatment, storage, and disposal of hazardous waste, it is equally important to implement recycling aimed at reducing the quantity of hazardous waste generated by an organization. To better understand these RCRA regulations for hazardous waste generators, enroll in our RCRA Hazardous Waste Generator online training course. Also, remember that the RCRA recommends annual retraining which can be obtained through our RCRA 4-hour Refresher training course. By following this training, you will be able to apply the RCRA regulations for hazardous waste management by a hazardous waste generator. This training will also support your endeavors to comply with the EPA guidelines for hazardous waste management, as the RCRA has been created to give the EPA the authority to control hazardous waste from cradle to grave!     Reference/Source EPA. (n.d.). Categories of hazardous waste generators. Website. https://www.epa.gov/hwgenerators/categories-hazardous-waste-generators EPA. (n.d.). Recycling basics. Website. https://www.epa.gov/recycle/recycling-basics EPA. (n.d.). Regulatory exclusions and alternative standards for the recycling of materials, solid wastes, and hazardous wastes. Website. https://www.epa.gov/hw/regulatory-exclusions-and-alternative-standards-recycling-materials-solid-wastes-and-hazardous EPA. (n.d.). Resource Conservation and Recovery Act (RCRA). Website. https://www.epa.gov/fedfacts/resource-conservation-and-recovery-act-rcra

Do You Really Know Your 4-Gas Meter? First, I'd like to express that I am writing about 4-gas meters in general and not any specific company meter. Over the years, I’ve consistently found individuals who know very little about their 4-gas meter, other than turning it on and waiting to hear the dummy sensors. I’ve always said, “Don’t wait for the sensors, Dummy.” I’ve seen people blow into the meter tubing as a sort of ‘bump test’; I’ve seen people turn on the meter and calibrate it in the actual hazardous atmosphere in question; I’ve seen people walk through testing areas so fast they don’t allow the meter time to analyze the right areas; I’ve seen people improperly monitor vertical confined spaces by not monitoring all levels and doing it too fast; and people who don’t take into account corrective factors. I’ve also seen people who don’t understand parts per million (PPM) and percentages; I’ve seen meters improperly cared for by leaving them on rigs all day in cold weather and being knocked around; and lastly, but certainly not the least, people who have no idea of their meter’s limitations, of which there are many.  Not here, but in my next blog, I will also introduce you to ‘T’ ratings, groups and zones, class and division, and temperature ratings. Case in point: I was teaching a class on 4-gas meters a few years back to a group of safety managers. Before the class, I asked if someone had a meter that I could borrow for a 10-minute demonstration the next day. One person obliged, and I read the operation manual the night before in preparation. During the presentation I mentioned, for example, “this manual clearly states in bold print on the first page: This meter does not monitor acetylene or hydrogen gas.” I was pretty shocked that this safety manager, whom I borrowed the meter from, did not know this! He told me that’s what he specifically needed the meter for! Consequently, he bought a new meter and did his homework. The moral of this story - know your potential atmospheres, do your research, and above all; read your manual. Fast Fact: When you meter a space, ensure you take your time at all levels (low, middle, and high) because of the various vapor densities of the gases that could be present in the space being monitored (see Figure2). Caring for Your Meter Let’s start with caring for your meter. Sadly, too often an overlooked and significant detail regarding meters. Some of us like to keep our meters in the outside compartment of a rig all day, in cold weather and unsecured, nor in its case. The meters generally operate at their maximal potential anywhere from 64 0F – 86 0F. Temperatures venturing farther away from this range will make the sensors less reliable. Normal operating temperatures are generally between 14 0F –104 0F. In cold weather environments, this could be an issue. Some meters are drop-tested from 10 feet to 25 feet, that’s fine, but please protect your meter and keep it in its case, secure the case and keep it in relatively ambient temperature inside the cab of your apparatus. If your rig is stored outdoors and exposed to the elements (cold or hot), please bring the meter inside overnight. Operating Your Meter Most of us know that a 4-gas meter analyzes four gases: Oxygen (O2), Carbon Monoxide (CO), Hydrogen Sulfide (H2S), and Combustible Gases (LEL) with a hydrocarbon base. Most of us may know that CO and H2S are expressed as parts per million (ppm) on the meter display (the toxic gases), and oxygen and LEL’s are displayed as a percent (%). However, most of us don’t know how to convert ppms to percentages and vice versa. We’ll talk about that in-depth later. The Occupational Safety and Health Administration (OSHA) advises to bump test your meter before each day’s use. The bump test is only a function test to see if the sensors activate and the machine is operating. It does not test for the accuracy of such sensors. That is done through a full calibration test (generally every six months or according to the manufacturer’s recommendation); or if you find an issue with the bump test or come across other operational errors. When you turn your meter on for usage, it will run through a fresh air set-up (FAS); this is not a full calibration. Please perform the FAS in a non-hazardous atmosphere before entering a hazardous atmosphere, otherwise, the bad air will be locked in as a baseline and you won’t be able to detect any appreciable amount of hazardous air. When you're metering an area, it takes 10-15 seconds reflex or response time for the meter to get 90 percent of a final reading. In other words, don’t rush through rooms or concerned areas because you might get a hot reading from the previous room or area up to 50 feet back, or at the previous vertical levels in a hole. We’re all pretty familiar with low-level and high-level alarms, such as TWA and STEL alarms. However, are you familiar with corrective factors? Today, most meters use a methane base to measure the combustible gas spectrum. Therefore, gases with a hydrocarbon base, other than methane, require multiple factors applied to your Lower Explosive Limit (LEL) reading. Depending on the meter, this can range from approximately 0-5.0.For example, gasoline has a factor of 1.63. If you get a reading on your meter at the bottom of a trench or basement of 1.0 percent, you must multiply 1.0 x 1.63 = 1.63 percent. Now, there is also a margin of error of +/-.25 percent; 1.63 + .25 = 1.88 percent as a true reading. Presumably doubling the reading from your meter to get your actual gasoline reading. I always told my firefighters to double the reading in their heads if they did not know the immediate corrective factor. Why is this important? Well, the flammable range of gasoline is 1.4-7.6 percent; without the applied corrective factor above, our reading would indicate that you are below the flammable range; when in fact, you are well into the flammable range (see Figure 3).A better example is xylene. Xylene has a factor of 4.83. Imagine the discrepancy and danger with a flammable range between 0.9 to 7.0 percent! A reading of 0.5 percent would actually be over 3 percent, showing a very explosive atmosphere. So, it is imperative to keep your corrective factors in mind. Meters have differing corrective factors. They also have some sensor cross-sensitivities with other gases. Read Your Manual. By the way, when you actually reach the LEL, the meters generally display ‘XXX’, ‘100’, or ‘OVER’, etc. Fast Fact: Did you realize that when you add a probing tubing or a wand to your meter you should allow for a one-second per foot lag for the gas to get to the meter and an additional 10-15 seconds, minimally, to get an evaluation? Well, now you know! Visual example to show where on the scale percentage of LEL is measured. Additionally, some meters will only guarantee flammable liquid readings with flashpoints up to 100.4 0F. Anything above that point result will get lower LEL readings, as the sensor will start to drift. Furthermore, oxygen sensor drift happens due to atmospheric elements of air pressure, temperature, and humidity. Humidity above 90 percent alone can change the oxygen reading by .5 percent. Once the oxygen sensor drifts, the entire meter becomes less reliable, more often than not sensing low readings. Corrosive gases also tend to damage the sensors. Consequently, work diligently in these atmospheres. It would be a good idea to have the meter inspected, bump-tested, and calibrated, if necessary, after such exposure. Other Limitations to Watch Out for When Utilizing Meters Don’t use them in oxygen-deficient or enriched atmospheres (<10% or > 25%), Don’t use them in inert environments, Don’t use them in mist or dust atmospheres, and Remember, flashpoints > 100.4 0F may result in low readings. When do Sensors Become Desensitized During the Analyzing Stage? When atmospheres are contaminated with: Organic silicones, Silicates, Lead-containing compounds, or Hydrogen Sulfide >200 ppm or >50 ppm for 1 minute. Oxygen Displacement Remember earlier I mentioned converting parts per million (ppm) to percentages? Let’s discuss it now. The normal O2 reading on a 4-gas meter is 20.9 percent. We know the oxygen sensor goes into low-level alarm at the 19.5 percent reading. Suppose you're in a confined space and that oxygen reading drops to 19.6% and you are unaware of it because you only listen for the dummy sensors to alert you. Hopefully, you will still be alive if this happens. WHY? Because 13,000 ppm of oxygen has been displaced and you don’t know by what? We know it couldn’t be CO, LEL, or hydrogen sulfide; or the alarms would have alerted you. Something else is with you! As an analogy, CO will kill you at 10,000 ppm or 1% percent in the air in 1-2 minutes. We have 13,000 ppm!!! Scary part (arguably)! Multiply that by 5x’s because you're extrapolating the 20.9 percent oxygen portion of air. 13,000 X 5 = 65,000 ppm. I say arguably because I’ve talked to industrial hygienists with opposing thoughts on the 5x’s. Regardless, a frightening scenario. This is why I always tell my people to eyeball the meter every 5 minutes. In Closing… Finally, I hope I’ve enlightened you to most of the significant limitations of your meters, although not inclusive. Proper care and usage are of utmost importance. Equally significant is recognizing the potential atmospheres you may encounter. Doing your homework on the right meter to purchase for your business goes without saying. You can find this information in my next blog. Remember: Read your manual and know your meter! “Don’t wait for the sensors, Dummy.” If you are interested in gas meters, then I assume you may be interested in our catalog of online courses dealing with gas meters. Some of our courses, such as Confined Space Training; Competent Person for Excavation, Trenching, and Shoring; and the HAZWOPER series of courses give comprehensive information on testing atmospheres for hazardous gases. Stay safe everybody!    Stay tuned for my next Blog: Choosing the Right Gas-Meter for You!   Michael J. Conroy, Retired Battalion Chief/Paramedic, Chicago Fire Dept. with 36 years of experience, is also a Certified Safety Professional (CSP) and Construction Health & Safety Technician (CHST). Mike is also an OSHA-Authorized Trainer and a certified Fire Dept. Safety Officer. Mike has vast experience and holds advanced certifications in confined space, fall protection, rigging, excavation rescue, and all the hazardous material disciplines, among many other certifications in the safety field. Mike will continue to write and speak on safety topics and share his years of safety experience through this media.

What is Safety? Are you ever curious when someone tells you to be safe? Like when your mother used to say, “be safe Michael.” We all probably hear it every day, all through our lives, even as adults. You get in your car you hear “drive safe” or “be safe;” when you leave the house your spouse may yell “Be safe honey.” When you’d ride your bike as a kid or walk across the street, the same thing, “be careful or be safe.” Then, when you get to work you hear “work safe” by your supervisor, and the management always tells you “being safe is our number one priority.” When I was in the fire service we would be subjected to oral interviews and the interviewers would always want to hear the word, safety, they just wanted to hear it. We hear it all the time. The word ‘safety’ always felt like an empty term to me years ago, now it has much more meaning. What does safety really mean and how do you define it? After years of being in the construction field and the fire service, I think I've finally figured it out! Unbeknownst to the many people who have told you to be safe throughout your life; they are actually telling you to recognize hazards, evaluate your risks, and control such hazards! Some of you may recognize this as a JHA (Job Hazard Analysis). It’s also called JSA (Job Safety Analysis), THA (Task Hazard Analysis) and sometimes you’ll see acronyms such as RACE, ARECC, and typically what we refer to at HAZWOPER OSHA Training as the Three-Stage Safety Model. Each of these famed acronyms revolves around basically the same formula:  Recognize + Evaluate + Control = SAFETY The three-stage safety model is not a ‘Risk Assessment.’  However, it is similar in some ways. The most notable difference is that JHA’s are micro in nature, whereas the risk assessment is macro. Thus, the key difference is scope. Furthermore, JHA’s are limited to an individual or group task while risk assessments typically assess safety hazards across the entire workplace or business. The risk assessment provides a broader view of all types of risks across the entire business. However, generally speaking, a JHA performed in the construction industry typically involves a general task or series of tasks to accomplish an objective for a particular time period (usually a half-day or full-day). Meanwhile, JHA’s undertaken in the general industry usually concentrate on individual movements in one particular task and break each movement down to determine the potential risk involved within sub-tasks. Let’s talk about what actually constitutes a hazard. What is a Hazard?  Before discussing the aforementioned formula, let’s first understand what a hazard is. According to OSHA, “a hazard is associated with a condition or activity that, if left uncontrolled, can result in an injury, illness, or death.”   Hazard Recognition  The most difficult aspect of the Three-Stage Safety Model is to possess the ability to recognize a hazard in the first place. Whether it’s recognizing a car coming around the corner while crossing a street, or looking both ways before crossing, or working in a confined space while being unaware of the potential dangers inside. If you don’t have a trained eye, knowledge, or experience to recognize a hazard, subsequently, nothing else matters. I’ve found over the years; a majority of people don’t possess the ability to recognize a hazard in the first place. Some have worked around the same hazard(s) for many years and were just very fortunate to have encountered no accident(s). Recognizing a hazard is derived from years of experience, education, and a trained eye. Once you gain that knowledge, hazards seem to stick out like fireworks going off in front of your eyes, they become easy to recognize.  Hazard Evaluation  Once someone can recognize a hazard, they usually evaluate risk at their own level of comfort. Sometimes they misjudge that risk and don’t take the necessary controls to mitigate that risk and suffer the consequences of injury, illness, or death, and if fortunate, a near miss (or hit). When a hazard is found, OSHA states that you must ask yourself “what can go wrong, what are the consequences, how could it happen, what are contributing factors, and how likely is it that the hazard will occur?” Once the risks at hand are determined, then it's time to gauge your control options, and this is where NIOSH’s Hierarchy of Controls plays a vital role in workplace safety and health.  Source: NIOSH. (n.d.). Hierarchy of Controls. Website. https://www.cdc.gov/niosh/hierarchy-of-controls/about/index.html Hazard Controls  The last stage in the model is ‘Control’. This is where the Hierarchy of Controls, as we’ve expressed in our HAZWOPER OSHA courses, comes into play with the image of the upside-down pyramid. The ’Hierarchy of Controls’ starts with the most effective controls at the top of the pyramid, with the least effective controls coming in at the bottom. The top of the pyramid (elimination, substitution, and engineering controls) basically removes the human being from the source of danger or hazard. Work practices or administrative controls, together with personal protective equipment (PPE) at the bottom of the pyramid, insert the human being at the source of danger but advise precautions while doing so. These control measures have proven to be very effective over the years.  Is There More? However, I personally feel the pyramid is not complete. Ultimately, you are responsible for your own safety. Therefore, I believe that below the PPE level, at the bottom of the pyramid should be an added layer termed “individual safety.” This is where all the cumulative and instinctual safety messages come into play. Moreover, consider this point; it is not only individual safety, but when you work unsafe, you put your co-workers and everybody around you in an unsafe environment. Remember, your mother was telling you to be safe, she unknowingly was telling you to recognize hazards, evaluate risks, and control such hazards. This is the knowledge we should follow throughout our lives. Remember, Mom is always right!  At HAZWOPER OSHA, our online courses consistently carry this safety theme and the Three-Stage Safety Model throughout. Stay safe everybody! Now you know what it means. Stay tuned for my next Blog: Do You Really Know Your 4-Gas Meter?     Michael J. Conroy, Retired Battalion Chief, Chicago Fire Dept. with 32 years of experience, is also a Certified Safety Professional (CSP) and Construction Health & Safety Technician (CHST). Mike is also an OSHA-Authorized Trainer and a certified Fire Dept. Safety Officer. Mike has vast experience and holds advanced certifications in confined space, fall protection, rigging, excavation rescue, and all the hazardous material disciplines, among many other certifications in the safety field. Mike will continue to write and speak on safety topics and share his years of safety experience through this media.  

Silica Exposure Awareness for Occupational Safety What is Silica? Silica, also known as silicon dioxide (SiO₂), is a naturally occurring mineral in the earth’s crust; often found as stone and sand. Silica occurs in two forms – crystalline silica and amorphous (non-crystalline) silica. Crystalline silica is hard, with a high melting point, and is chemically inactive. Quartz is the most common form of crystalline silica found and used in the creation of various products. Cristobalite and Tridymite are the other two known forms of crystalline silica. Silica is found in a variety of products, and there are various uses for silica, globally. Crystalline silica is used to make pottery, ceramic, and glass products. Also, when sand, stone, or rocks are used to produce other materials; for example, concrete, mortar, bricks, etc., these transformed products also contain silica. Crystalline silica is also found in granite and paints. Amorphous silica on the other hand is often found in the form of silica gel, and is used in food additives, food wrappings, toothpaste, and cosmetics; as this form of silica has been found to have no adverse health effects at levels found naturally in the environment or commercial products. What is Respirable Crystalline Silica? Respirable Crystalline Silica is the tiny airborne particles formed when crystalline silica or any silica-containing materials including rocks, stones, concrete, brick, block, and mortar is manipulated by cutting, drilling, sawing, grinding, crushing, or breaking. This dust is deemed to be 100 times smaller than sand grains found on a beach; and is often referred to as ‘silica dust’. Silica dust can easily be inhaled and get into the human respiratory tract causing harm to the health of those exposed to respirable crystalline silica while working with silica-containing materials. Silica and the Construction Industry Workers in the construction industry are the most exposed to respirable crystalline silica as they participate in work activities that require them to cut, saw, grind, and drill silica-containing materials. Such work activities include mixing concrete and mortar, cutting bricks and blocks, abrasive blasting with sand, crushing and grinding stones or rocks, sanding or drilling into concrete walls, cutting granite, etc. Also subjected to the hazards of silica exposure are the employees of brick, concrete block, and stone or granite countertop manufacturers. Furthermore, people working in excavation and trenching operations are also exposed to respirable crystalline silica due to work activities such as sifting sand; and crushing, grinding, and moving rocks that may disturb silica particles. OSHA’s Respirable Crystalline Silica Standard for the Construction Industry As such, all construction industry workers must obtain adequate knowledge about working with silica and the dangers of silica exposure. Accordingly, the Occupational Safety and Health Administration (OSHA) has developed and implemented the respirable crystalline silica standard for the construction industry (29 CFR 1926.1153) to support employers in their endeavors to protect employees from silica hazards and limit worker exposures to respirable crystalline silica by adopting the appropriate methods and safeguards. OSHA’s construction industry respirable crystalline silica standard provides flexibility to employers on the different protection methods – specified exposure control methods based on the Silica Table 1 provided in the standard or alternative exposure control methods based on distinct workplace measurements of worker exposure to silica dust and the best ways to limit the permissible exposure limit (PEL) in the workplace by using the  Hierarchy of Controls. OSHA’s respirable crystalline silica standard for the construction industry specifically requires employers to: Create and implement a written silica exposure control plan. This plan should identify the silica exposure tasks and detail the methods used to protect workers from silica exposure. The plan must also explain the procedures to restrict access to work areas where high exposures may occur. Ensure a competent person is responsible for implementing the written exposure control plan. Identify and use reasonable appropriate alternative housekeeping practices to avoid housekeeping practices that could increase workers’ exposure to silica. Ensure workers who are required by the standard to wear a respirator for 30 days or more annually, undergo medical exams every three years. These medical surveillances examinations should include chest X-rays and lung function tests. Provide workers with the appropriate training on work operations that result in silica exposure and ways to limit exposure. Maintain records of exposure measurements, the relevant objective data, and medical examination records of workers as required. Silica Used in Other Industries Silica exposure and awareness are not limited to construction industry workers. Employees in other industries working with silica-containing materials are also in danger of exposure to crystalline silica and silica dust. Popular examples include hydraulic fracturing (fracking) operations and foundry work that requires workers to use sand. Moreover, makers of pottery, ceramic, and glass products are also exposed to silica dust. Therefore, employees exposed to silica in other industries must also be provided with adequate information on silica exposure and gain the appropriate silica awareness training. These industries, too, are governed by OSHA. OSHA has developed and issued respirable crystalline silica standards for the general industry and maritime (29 CFR 1910.1053) that employers can use to put in place the necessary precautions to reduce silica exposure levels of employees. Silica Exposure Risks and Controls Exposure to respirable crystalline silica can result in several health hazards. These illnesses include silicosis, lung cancer, Chronic Obstructive Pulmonary Disease (COPD), kidney disease, activation of latent tuberculosis infections, and autoimmune diseases. Thus, employers must provide the necessary precautions in the workplace to reduce employees’ exposure to silica by implementing a range of appropriate measures as recommended by the OSHA standards. The measures may include a combination of engineering and work practice controls, housekeeping procedures, respiratory protection, medical surveillance, hazard communication, silica air monitoring measures, and silica methods of sample analysis. Silica Awareness Training An effective way to create awareness of silica exposure and related silica health hazards in the workplace is to provide relevant training to employees. Our silica awareness online training course will enable employers to fulfill the training requirements as outlined in the Federal OSHA Regulations 29 CFR 1910.1053 and 29 CFR 1926.1153. Our training program aims to acquaint workers with the hazards associated with exposure to respirable crystalline silica and the hazard control measures that must be implemented to minimize exposure within safe limits to comply with the relevant OSHA respirable crystalline silica standards. So, enroll today, and learn more about the regulatory requirements of working with crystalline silica-containing materials and the exposure control methods that must be implemented in the worksite to ensure compliance and safeguard the health of workers.   Reference: SafeSilica. (n.d.). Crystalline Silica: The Science. Website. https://safesilica.eu/crystalline-silica-the-science/ OSHA. (n.d.). Silica, Crystalline. Website.  https://www.osha.gov/silica-crystalline OSHA. (n.d.). Construction. Complying with the construction standard. Website https://www.osha.gov/silica-crystalline/construction  

California’s Oil Spill: A Marine and Ecological Calamity The recent news of the California oil spill contaminating acres of beach, polluting oceans, and harming marine life and wetlands brings to light the importance of being ready for the unexpected! The oil spill attributed to a pipeline leak off the coast of Orange County is expected to pollute the marine ecology and also taint the stretch of beach from Huntington Beach to San Diego County! While the spill was expected to be much larger when the oil pipeline leak was first discovered, more detailed evaluations in the last week have resulted in officials revising their original estimation of a 126,000-gallon spillage to between 24,696 gallons and 131,000 gallons at a maximum (Fry, Gerber, and Winton, 2021). Despite this lower estimation of the oil leak into the Pacific Ocean, the ecological damage to marine life, wetlands, birds, and other species, as well as the Southern California beach shores will be severe. The destruction is already being reported in leading news media. In addition, the closing of the beaches will also impact people and their recreational activities. Oil spills are known occurrences globally. In February of this year, a massive oil spill was reported in the Mediterranean off the coast of Israel (Cohen, 2021). However, this month’s (October 2021) California oil spill has occurred after 52 years, following the 1969 Santa Barbara spill that resulted in bringing about much tighter environmental laws and regulations related to oil spill disasters. This was also a turning point in federal environmental legislation with the establishment of regulatory bodies such as the Environmental Protection Agency (EPA) in 1970 and the creation of the Clean Air Act and the Clean Water Act in 1970 and 1972, respectively (Larson, 2021).

Fire Prevention and Protection A fire can occur anywhere at any time. While we take every precaution to safeguard against fires, be it at home, in schools, in offices, at restaurants, in hotels, in warehouses, or manufacturing facilities; the possibility of a fire occurring remains a concern for everyone. This is mainly because fires often take place quite unexpectedly; starting with just a spark or due to the mixing of two or more chemicals that results in an adverse reaction. Of grave concern is that once a fire starts, the spread can be quite rapid, and a few seconds or minutes could make the difference between life and death! Thus, it is not surprising that all people make every effort to safeguard against fires occurring and put in place measures to alert the people in the vicinity in case of a fire. Let’s see what can be done to prevent fires, increase fire safety in homes and workplaces, and what processes we can put in place to safeguard families, friends, coworkers, and employees in case of a fire. Tips for Preventing Fires in Homes Install smoke alarms and/or smoke detectors in the kitchen, bedrooms, basement, and other rooms. Install a sprinkler system that could auto-activate when a fire is detected. Ensure that you test the smoke alarms and home sprinkler systems at least once a month, to check for defects or the need for new batteries. Sit with your family (children included) and discuss what should be done in case of a fire. Plan how they should leave the home and where they should gather, and how to contact the fire department. Put up a poster in common areas where emergency contacts are identified with their phone numbers. This will help scared children and stressed elders to call for help without hassle in case of a fire. Be careful when using equipment and tools that spark and could cause a wildfire. Examples include welders, lawnmowers, weed-eaters, chain saws, grinders, and trimmers. When using candles, matchsticks, lighters, and other similar fire-starting items make sure to keep the surrounding areas clear and free of materials that could easily catch fire. When using flammable chemical products or other fuels in homes, follow instructions and apply best practices that safeguard against causing fires. Ensure electrical wiring is checked regularly to prevent fires from occurring due to faulty wiring. If an electrical short occurs when using any electrical equipment, immediately stop using it, and get it checked and repaired or replaced. How to Prevent Fires in Workplaces Preventing fires in workplaces can be much trickier than safeguarding against fires occurring in homes. Many workplaces (for example, factories, goods manufacturers, laboratories, educational institutions, etc.) use various chemicals and flammable materials which can increase the occurrence of fires. Some works tasks such as those carried out in the construction industry, by maintenance services, and facilities management also use electrical tools and equipment that can cause sparks that could result in wildfires! Even offices, shopping malls, and apartment buildings use a combination of everyday cleaning solutions and electrical tools, some of which are fire hazards. In workplaces, it is the responsibility of employers to ensure the safety of employees. The Occupational Safety and Health Administration (OSHA) requires employers to implement fire protection and prevention programs in the workplace. Such programs guide and direct employees on the possible causes of fires and what must be done to prevent fires from occurring. These plans also help with workplace fire safety efforts. To ensure the fire protection and prevention plans are adhered to and executed properly, employers must provide the relevant training to employees. Such training would enable employees to understand workplace fire hazards, protocols to follow in an emergency, how to properly use firefighting equipment, and the evacuation procedures that must be put into operation. As a part of these fire preventions safety plans and programs, employers must also ensure: Clearly marked emergency exits that are kept clear at all times, so that workers can evacuate the facility without delay in case of a fire. In areas where electrical power may not be reliable, Tritium Exit Signs provide a dependable, non-electrical solution by illuminating in the dark without the need for wiring or batteries. Put up relevant emergency exit signs and a diagram indicating the evacuation route to be followed in case of an emergency such as fire. Install and maintain all relevant fire detection equipment and fire suppression systems such as fire alarm systems, sprinkler systems, fire extinguishers, water outlets, fire hoses, etc. Ensure the proper storage and handling of flammable and combustible materials and substances to minimize the risks of fires from occurring. Use containers as stated in OSHA regulations. The recommendation is to use only approved, closed containers for the storage of flammable or combustible liquids. For example, safety cans or containers that are approved by the U.S. Department of Transportation (DOT). Appointing a fire safety officer as per regulatory requirements. Planning and executing fire drills to prepare employees on what should be done if a fire breaks out in the building. In addition, employees can also contribute to workplace fire prevention and fire safety by: Adhering to the relevant fire prevention and protection procedures and policies in place at their workplace. Being vigilant when using equipment or flammable materials that can cause fires. Reporting electrical or other hazards that can cause fires. Ensuring electrical outlets and circuits are not overloaded. Bringing to the employer’s notice malfunctioning electrical equipment, open electrical wires, or any other hazards that may cause fires. Making sure no damaged electrical outlets or electrical cords are being used to carry out work tasks. Being alert and careful when working in areas such as laboratories, kitchens, and rooms with high voltage equipment that are fire-prone. Following instructions and the information provided in the safety data sheets (SDS) on the proper storage and handling of flammable materials. Keeping combustible substances (e.g., chemicals) or materials (e.g., paper, hazardous waste, etc.) at a safe distance from electrical equipment. Annually getting the relevant training on fire safety and prevention measures.   References: OSHA Fact Sheet (2020, August). Fire Safety. Website. https://www.osha.gov/sites/default/files/publications/OSHA3527.pdf NFPA. (n.d.). Fire Prevention Week. Website. https://www.nfpa.org/Events/Events/Fire-Prevention-Week

Safety Measures When Working at HeightsPeople involved in the construction industry are very familiar with the phrase “working at heights”. Many tasks require workers to work at an elevation invariably increasing their exposure to falls and other height-related hazards. According to the U.S. Bureau of Labor Statistics (BLS), in the last few years, falls from working at heights are recognized as a leading cause of death for construction workers. OSHA also strives to inform employers and employers of the dangers lurking when construction work and other maintenance is done at higher elevations which can be harmful to human health and safety.Many occupations require people to work at heights, and employers must ensure the safety of their workers when they carry out such work tasks as part of their occupational health and safety plans.Working at Heights ExplainedWorking at heights usually means that a job task is being carried out at a vertical or horizontal working or walking surface. A common example of a vertical surface on which work is done at heights is a ladder, while scaffolding is an example of a horizontal working surface. Due to work being carried out at a higher level than the ground, workers are at greater risk of falls which may result in a severe injury or even fatality. A person working on a roof, on electrical poles, on overhead bridges/walkways, or even on rigs would be considered to be working at heights.This is the reason OSHA has identified regulations for fall protection for people who undertake work tasks at heights. According to OSHA’s regulatory standards, workers must wear appropriate fall protection equipment when they work at heights, while whenever possible work areas should put in place engineering and administrative controls to safeguard workers from falls or falling objects. For instance, OSHA’s scaffolding standard recommends workers using a suspended scaffold, an aerial lift, or a bucket truck raised at a height of more than 10 feet above the surface to utilize personal fall arrest systems such as wearing a full-body harness. Furthermore, OSHA also guides and directs on a range of measures to be used for fall protection and other hazards related to working at heights utilizing the Hierarchy of Controls as developed and presented by NIOSH.OSHA’s Fall Protection RegulationsTo protect workers from falls, OSHA has developed fall protection regulations for:the construction industry in 29 CFR 1926 Subpart M,the general industry (29 CFR 1910),shipyard employment (29 CFR 1915),marine terminals (29 CFR 1917), andthe longshoring industry (29 CFR 1918).Furthermore, OHSA’s construction industry standard (29 CFR 1926) also considers fall protection when regulating other areas such as Steel Erection (29 CFR 1926 Subpart R). OSHA’s scaffolding regulations (29 CFR 1926 Subpart L) also contribute to the safety of people working at heights as its regulations are geared to safeguard workers who erect, dismantle, and use scaffolding to complete their work tasks.Safety Suggestions when Working at HeightsWhenever possible, employers should minimize the requirement for working at heights or reduce the need for workers to work at heights. However, when it comes to construction work it is quite inevitable that workers will have to work at heights as it is the nature of work! In this case, all necessary precautions, including engineering, administrative, and work practice controls as well as the use of necessary personal protective equipment (PPE) such as fall arrest systems and safety harnesses should be used to lessen the risks of working at heights.Installing guardrails and railingsWhen working on scaffolding or other open surfaces or platforms, ensure that guardrails and midrails are installed and used as recommended by OSHA. This will safeguard employees by reducing fall hazards. Furthermore, ensuring supported scaffolds are built and used as per standard regulations will further reduce the risks of scaffolds tilting or collapsing thereby minimizing risks to employees.Ensure ropes and other equipment are in good working orderWhen using suspended scaffolding to undertake work at heights, employers should ensure that the ropes and non-rigid, overhead supports are all in good working order. As required, these must be checked by a competent person before workers use a scaffold to carry out their work.Wearing the appropriate PPEWhen working at heights, employers must ensure workers are given the appropriate personal fall arrest systems. Equipment such as the full-body harness, an integral part of the personal fall arrest system, must fit correctly to ensure effectiveness. As such, workers must be fit-tested before they wear such equipment when carrying out job tasks.Ensure worker protection from falling objectsWhen people work at several elevations, there is the risk of tools and other objects falling from a higher level to a lower level or even to the ground. Thus, employers must put in place warning signs and other mechanisms such as safety nets to reduce accidents caused by a falling object.Regularly inspecting PPE and the worksiteA good practice to adopt, and one recommended by OSHA, is to regularly inspect protective equipment used by workers. In addition, equipment such as ladders should be checked for damage, while scaffolding must also be checked to ensure they are safe for use before the start of a work shift. If engineering controls such as safety nets and safety canopies are used, these must also be checked for tearing and other damage.Training for employeesLast, but never least, is training! Employers should provide training to their employees when they work at heights. Annual training helps people understand the need for safety at the workplace and provides pertinent information for individuals to practice safety while at work.One such training is the OSHA Competent Person for Fall Protection Training, and another is OSHA Scaffolding Safety Training course. We offer these courses in various formats - online training, in-person on-site group training, and virtual instructor-led training (ILT) - at very reasonable prices. Our courses are mobile-friendly with the flexibility to jump from one device to another in the midst of your online training.We believe that safety matters and are happy to partner with you to support your safety aspirations.

Core Elements of an Effective Safety ProgramOver the span of almost 40 years, involved in varying degrees of safety-related activities and working or consulting for numerous companies, I’ve developed what I believe are the basic core elements of an effective safety program: leadership, strategy, engagement, management buy-in, and culture. I’ve found many companies fail at safety, either because they don’t have proper leadership, or an effective strategy or formula to make it succeed, lack of employee and management engagement, and consequently, never able to develop a safety culture. Let’s delve a little deeper into these elements.Leadership  A trait that is not necessarily taught but learned through observation. Some people seem to be natural-born leaders. My observation over the years of effective and ineffective safety leaders is as such. An effective leader, in terms of personal traits, is firm and expects a level of production from employees. An effective leader is not afraid to get their hands dirty in the trenches. An effective leader engages employees and lets them know he/she is looking out for their well-being, not just in words, but by actions. An effective leader empowers employees and allows their input to be heard and put in place as necessary. An effective leader channels employee concerns to other company leaders and managers. An effective safety leader can also tow or navigate the line of production and safety in a compromising fashion. Lastly, an effective leader earns the respect from not only employees, but also from fellow leaders and peers, not by title, but through actions.  Conversely, an ineffective leader lacks most of these personal traits, and therefore, will not effectively lead. I’ve found during times of organized chaos; effective leaders will prevail. My years in the fire service taught me that in times of organized chaos (what we call larger-scale emergency scenes) true leaders will show themselves, while ineffective leaders suddenly become silent, take a step back and move into the shadows, and are not to be heard from. They lose the respect of the firefighters. Believe it or not, people yearn to be led. Given a great leader, you feel like you’d run through a brick wall for them or follow them through the gates of hell with a fire extinguisher. I’ve been privileged to work for some of those leaders.Strategy  A safety strategy is critical for sustained business success. Let’s face it; a company needs to produce it core business product or execute its overall strategy in order to remain a viable business. I’ve found many companies have a safety position filled for the purpose of having a safety position filled! As such, these individuals have no influence on company decision-making, nor any influence on actual safety in the trenches or line production. When production and safety butt heads, production seems to always win. This is where an effective safety leader comes into play, where he/she must put their political hat on and make difficult but correct decisions. A Safety Professional needs to be involved in the highest levels of decision-making positions within the company. A Safety Professional needs to have input in just about every decision of the company, and therefore, should be right near the top of any company’s chain-of-command or organizational structure. They cannot be ignored or sidelined. In some organizations, the Safety Professional is placed just below the CEO and above division heads on their organizational chart. This action shows the leadership’s commitment to safety and health within the organization.  Another important consideration when formulating the safety strategy is: Does the company utilize active safety or passive safety? Active safety is real-time and includes safety audits and training with follow-up and support from upper management to include the CEO and top supervisors. Without their support, the company’s occupational safety plan and program are in peril. Everybody needs to buy in to have an effective safety program. Passive safety is like the ineffective leader; stand back and rely on past or historical trending records for the company’s safety program, rather than playing a hands-on role and staying ahead of the curve, and not behind it.  What happens when a business lacks any safety strategy? Consequently, safety fails; and ultimately people are injured, sometimes seriously or even fatally. Unfortunately, some companies, having experienced safety-related mishaps, may still not learn their lesson. This is typically seen in larger companies that often absorb such costs as production loss, higher insurance costs, workmen’s compensation claims, legal fees, and remedial training costs among others. On the contrary, smaller companies may not be able to absorb such costs and lose their businesses altogether.  Fortunately, some companies do learn from their mistakes and start prioritizing safety and pushing the position higher up the organizational chart. I can’t tell you the number of times I’ve made recommendations over the years to management, only to be ignored, leading to a serious or fatal injury occurring directly related to not heeding my advice. On the other hand, I’ve also worked with many companies where safety was at the forefront of almost every business decision, which resulted in a pleasant environment for any safety manager. Knowing the upper management heeded my advice just made the working environment feel less anxious and gave me the authority to do the right thing and not worry about workplace safety taking a backseat. I didn’t feel like I was stuck between a rock and a hard place. I’m sure every Safety Professional understands what I’m saying!  REMEMBER: Nobody Wins When Someone Gets Hurt!Engagement Generally, words of motivation do not engage people to be safe. Simply telling someone to be safe does not engage or motivate an employee. Safety incentives only encourage cheating amongst employees to be safe, it does not engage them. I previously mentioned active safety. Engaging employees directly by training and performing safety audits is a good example. Engaging with employees is the time where management and line personnel get to know each other and expectations are disclosed. This is the time to be firm and layout consequences for unsafe workplace practices. This is also the time to build a rapport with company members. This is where workers share and gain valued input and develop some ownership into organizational safety processes and practices. This relationship-building exercise makes employees feel respected and part of the team. They feel empowered and don’t feel like they are just only workers. They have skin in the game and the Safety Professional acts as their liaison with the upper management. When a company considers the well-being of their personnel and listens to their members, employees know it too! And trust me, they will respond in kind. As for training employees, what better way is there to lay out your company’s Safety & Health Program as it pertains to OSHA safety regulations! The Safety Director puts forth the company safety blueprint to all its employees and engages with them as an open forum. Again, this is where accountability, ownership, and skin in the game comes in. However, finding the time to train employees and taking them out of the production line becomes a real problem. Over the years, I’ve found this to be problematic. Consequently, companies have been transitioning to outsourcing some of their safety training to online safety training providers. Online training provides the necessary tools for a company to train its workers to operate safely at the worker’s own pace without interrupting business production. Online safety training delivers programs that encompass safety standards such as OSHA, HAZWOPER, EPA, DOT, etc., directly to the employee via mobile phones and laptops making training convenient for workers, while also providing wallet ID cards and immediately downloadable course completion certificates for accountability. Management should consider a convenient and reliable online safety training partner to supplement their Safety & Health Program.Management Buy-In Without full cooperation from management, the safety program will not thrive! I was once involved as a safety consultant for a company where the management expected me to dictate safety for their company without their involvement. Past experiences made them (the management) afraid of the employees' union and lawsuits. Everyone had ceded to employees, or union stewards making the majority of safety-related decisions. Thus, the management wanted me to step in and basically manage all safety responsibilities because they were afraid to manage it themselves. How do you think that worked out? Was enough emphasis given to safety and health measures? Now consider a scenario that I actually faced - working for a company that won’t allow you to say anything to third-party vendors, that they hired, when you see concerning scenarios related to safety and health. My experiences reiterate that it is paramount for the top brass or upper management to be completely immersed in providing a safe and healthful work environment for their employees [OSHA General Duty Clause 5(a)(1)].  Culture Creating a safety culture takes time, patience, and a culmination of the core elements. An experienced safety consultant can generally tell right away when approaching a construction site or lobby of a general industry structure, whether they have an established safety culture or not. When I was performing safety audits for companies, I could practically smell it! Where does culture start? Right from the top to then permeate downwards through the rest of the organization. If upper management doesn’t buy-in to the importance of a safety culture, forget it, it’s like banging your head against the wall!  The first apparent aspect of a safety culture not being in place is always the lack of, or improper signage, usually noticed from the exterior. I’ve come across instances where companies seemed like they were advertising their lack of safety practices! I recall seeing ladders not 36” above the roof edge and not tied-off, people on the roof with no fall protection gear, warning lines not in use, scaffolds missing mid-rails, people not tied-off in aerial lifts, scissor lifts with no chain in place, and the list just goes on... These scenarios were like an advertisement to OSHA to come fine us! Mind you, I was still on the street and hadn’t even set foot on the property.  The aforementioned screams: There is NO Safety Culture Here!  They might as well have had a banner hanging on the side of the structure stating the same. By the way, I used to tell my company supervisors to load-up on safety signs and caution tape; it goes a long way in protecting your company and workers, and is inexpensive.   Remember, a safe work culture doesn’t happen overnight. It’s like a fine wine, it takes time to age and ferment, and if you do it right, you really have something special. Culture is really the culmination of the core elements of leadership, strategy, engagement, and management buy-in. Again, it can take years and patience to develop a proper safety culture once all the ingredients are added properly. The finished product is well worth the wait.Stay safe everybody!  Stay tuned for my next blog: What is Safety?  Michael J. Conroy, Retired Battalion Chief, Chicago Fire Dept. with 32 years of experience, is also a Certified Safety Professional (CSP) and Construction Health & Safety Technician (CHST). Mike is also an OSHA-Authorized Trainer and a certified Fire Dept. Safety Officer. Mike has vast experience and holds advanced certifications in confined space, fall protection, rigging, excavation rescue, and all the hazardous material disciplines, among many other certifications in the safety field. Mike will continue to write and speak on safety topics and share his years of safety experience through this media.