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OSHA Hurricane season has yet to begin, however the recent tornadoes in Florida, Alabama, and other parts of the country remind us that we all need to be prepared. OSHA has developed an electronic matrix designed to prepare for and help employers in the moments and days following a catastrophic event such as a hurricane. You can view and download the matrix at: http://www.osha.gov/SLTC/etools/hurricane/index.html Also available on the OSHA website, at the top of the homepage is a downloadable pdf concerning what employers can do to provide protection in event of a pandemic flu. It contains information that is valuable for in any case of influenza, whether pandemic or seasonal. With links to federal as well as state and local planning activities, guidance on pandemic flu is also found at www.pandemicflu.gov WHAT IS THIS (from the EPA)? From the EPA – What is this picture? It is related to environmental protection. Try to guess before you click on the link to see what it is. http://www.epa.gov/epahome/enviroeye/answer.html NATIONAL SAFETY COUNCIL How do you instill safety in your employees? Read a short article taken from their current Safety and Health magazine, containing quotes from the top CEO’s whose attitudes towards safety promote safe workplaces. http://www.nsc.org/CEOs_2007.htm WHAT ARE YOUR RISKS. . . Of coronary or arterial disease? Do you know? The American Heart Association has a free assessment tool available in both English and Spanish on their website. Don’t let the word “women” in the title dissuade you, this check up is designed for both men and women. http://www.goredforwomen.org/ HAZWOPER MADE SIMPLE The Summary This is the final installment in the series written by our founder and Senior Trainer/Consultant, Paul Gantt, CSP, REA. It was written because some in the safety world know of the HAZWOPER regulation, but don’t fully understand what the regulation requires or how to apply it to their operation. Correctly certifying your employees to do the work you want them to do saves time and reduces the potential for injuries. You may remember from the previous installments that HAZWOPER stands for Hazardous Waste Operations and Emergency response. The regulation actually includes 3 distinct types of operations and outlines 9 levels of certification within those 3 types of operations. The regulation is found in 29 CFR 1910.120. To help you correctly chose which type of HAZWOPER training is required for your operations, simply ask yourself the following questions: Is my place of business one that is outlined in the scope of the HAZWOPER regulation? This includes sites recognized by a governmental entity as one that is an uncontrolled hazardous waste site. If your site is one listed on the National Priority List, Superfund list, or RCRA list, then the 24 or 40-hour HAZWOPER cleanup worker training outlined in section (e) of the regulation applies to you. Is my place of business an EPA licensed Treatment, Storage, and Disposal Facility that receives and processes manifested hazardous waste? If your site is a listed site, you must train your workers to the HAZWOPER training requirements outlined in section (p) of the regulation. Do I expect my employees to respond to emergencies that involve the release or potential release of a hazardous material as part of their job duties? If employees are expected to respond to emergencies that involve hazardous materials, the employees must be trained to do the specific functions required in accordance with section (q) of the HAZWOPER regulation. A discussion of the HAZWOPER training requirements would not be complete without mentioning the refresher requirements. Whether you are trained under the (e), (p) or (q) regulation, you may need some annual retraining. For those trained in as Waste (e) or TSDF (p) Workers you have an annual 8 hour refresher requirement. For Emergency response Workers (First Responder Operations or Technician levels) the regulation states they “shall receive annual refresher training of sufficient content and duration to maintain their competences at least yearly” 1910.120 (q)(8). Knowing what you need to accomplish with the training you receive is key to taking the right course at the right time. Have questions or are not quite sure of what you need? Contact us at newsletters@scm-safety.com. We’re here to help! IT’S NEVER TOO COLD FOR HEAT RELATED ILLNESSES Don’t Let The Outside Temperature Fool You It was a cold morning in late January. An employee who was working at a refinery, prepared to open a pipeline that had contained Sulfuric Acid. The Lock Out procedures were in place and the worker suited up in Level C with a chemical protective jumpsuit, gloves, and boots. While performing the work, as time went by, the sun came out. Although it was still rather cool outside, inside the suit the worker was sweating profusely. The heat built up to the point where the employee started to get dizzy and faint. Recognizing that he was in trouble, he stumbled out of the hazard area and fell to the ground. The good news was that there were some trained SCM staff at the site who worked with the site personnel to provide emergency medical care to the victim. Diagnosis? Heat stress. The outside temperature was around 50 degrees. A key learning point from this incident is that it does not have to be the middle of summer for someone to suffer from heat stress or heat related illnesses. Heat illness occurs when your body keeps in more heat than it loses, which is illustrated in the case mentioned above. The worker was encased in a chemical protective suit. The work he was performing was vigorous enough to increase his body temperature, while the suit prevented the coolness of the air from cooling him down. When the body begins to over heat, it sweats. As the sweat evaporates, the body cools down. It is a simple process. In the case above, the protective suit that kept chemicals out, also kept out the air currents that would have cooled down the worker, not allowing the sweat to do its’ job. As the internal temperature of the body rises, it needs more fluid to produce more sweat. This is why the new California regulation on heat illness prevention stipulates that “employees shall have access to potable drinking water” (8 CCR § 3395(c)). Drinking water is highly recommended as a measure for keeping the body hydrated. Sports drinks like Gatorade are also acceptable. Caffeinated, carbonated drinks, or alcohol can have an opposite effect, dehydrating the body. Experts advise to drink 32 ounces of water an hour whether or not you feel thirsty, to keep your body replenished. A good indication that you are drinking enough is that you feel the urge and need to urinate. There are some other physical factors that can increase your susceptibility to heat related illnesses. If you have diabetes, are taking medications that give a warning about heat illness, are new to working in the heat, have had a heat illness in the past or are on a low salt diet, talk with your supervisor and/or your doctor about working out in the sun. You may be more at risk than your co-workers. Get to know the symptoms of heat illness. If you or one of your coworkers are sweating excessively, have poor concentration on the task, loss of coordination, muscle pains or cramps, dizziness, fatigue, irritability, vomiting, blurry vision, and/or are confused take quick action to get out of the sun. Let a supervisor know, as you may have heat stress or exhaustion. Lay down in a cool place, loosen your clothing, and drink plenty of water. While most types of heat illness are easily resolved and are not usually life threatening, some can cause problems for those with these symptoms while working in hazardous environments. Fainting or vision issues can lead to serious injury if someone suffers them while working at heights or when potentially exposed to a hazardous material. However, one form of heat illness is potentially fatal on its own. That is termed Heat Stroke which is a condition where the normal ability of the body to cool itself is disrupted. In such cases they generally have dry, red skin, without sweat or moisture, may be dizzy or confused, and may be unconscious or having seizures. In such cases they need professional medical assistance immediately. Call 9-1-1 and stay with the person, no matter what they say, do not let them go home or be alone. Get them out of the heat, remove any outer protective clothing and cool them down with water. Remember that it is the evaporation of the liquid from the skin that cools so you can provide the sweat that is not there. The key to working with heat stress it to not be fooled by the lower outdoor temperatures, it is the temperature inside that matters. You can have a heat related illness at any time. Learn the symptoms and know your risks. For your benefit, we have included several links to websites with information on heat related illnesses. Those of you in California should pay special attention to that site as you may be affected by the recently enacted regulation on heat illness. Federal OSHA http://www.osha.gov/SLTC/heatstress/index.html Cal DOSH http://www.dir.ca.gov/dosh/heatillnessinfo.html American Red Cross http://www.redcross.org/services/hss/tips/heat.html FIRE DEPARTMENT INSPECTIONS What do you need to do to be ready? Fire department inspections occur on a regular basis. Depending on your type of business, or “occupancy” as the fire service might say, you may see an inspector as frequently as every year, or maybe just every other year. If you are remodeling, building, changing the chemicals or hazardous materials and wastes that you store, requiring a permit, a fire inspector may be involved in that process. Unless you are what OSHA considers a high hazard occupation or experience a number of occupational injuries and illnesses, it is much more likely that you will see a fire inspector more often than you would an OSHA inspector. Since the visit from the fire inspector is more likely, what should you do to prepare for it? The good news is that preparing for a fire department inspection is much like preparing for an OSHA or other regulatory inspection. If your work place is maintained in a manner largely compliant with OSHA regulations, you should be ready for almost any inspecting agency. However, there are some things that will capture the attention of most fire departments. Here’s a quick list. Emergency Action Plan (EAP): The OSHA requirement to have a plan for evacuations for any type of emergency includes fires. Keeping your EAP current will ensure it is ready for any inspector, whether it’s the fire department or OSHA. Your EAP should include how to report an emergency, how people are notified to evacuate, evacuation procedures, an assembly area where people report following an evacuation, how you plan to let people know they can return to the facility, and documented training on these procedures. Share that information with the fire inspector to see if your evacuation areas are not in locations that would interfere with their response. Exiting: If it is anything that relates to how someone can safety get out of your workplace in the event of a fire, it is something that will get inspected. This includes aisles, exit doors, signs, and the emergency lighting to see your way out. The fire inspector will ensure these things are in working order, all required inspections are up to date, and training conducted and documented. They may even ask your workers as they walk through the site questions on the evacuation plan. Where can you find information to make sure your exiting is ready for an inspection? Fire Protection Equipment: Fire extinguishers, automatic sprinklers, heat sensors, smoke detectors, kitchen hood/duct systems – these are examples of equipment that can protect your workers and your property should a fire occur. And like anything else, they require care and maintenance. Extinguishers need to be inspected monthly, whether you do it or hire a service to come in. They also need to be serviced annually by a certified fire extinguisher company and they need a hydro test the frequency of which depending on the type of cylinder. Other protection systems should be inspected and tested on a regular basis by a certified technician. Records of the inspections should be maintained for the inspector. Note: When performing a safety audit, we often find fire extinguishers sitting on the floor, or if mounted on the wall, being used as coat and umbrella holders. Extinguishers should be mounted with the top between 3 to 5 feet high, easily accessible and in plain view. Fire Prevention Requirements: This is a broad category, and is dependant on your specific operation. However, fire prevention requirements can be anything from general housekeeping issues such as picking up and properly disposing of oily rags and debris, to properly storing flammable materials in specially designed and separated storage cabinets or containers. If your business requires, you may need to have a Hazardous Materials Business or Management Plan (HMBP or HMMP). This is a written document that covers both fire and emergency plans for the safety of your workers and site, as well as the storage and use of the hazardous materials on your site. Whether you need one of these plans is determined by the amount of hazardous materials you have on site. If you are in doubt about needing one of these plans, it is best to contact your local fire department to ascertain if you meet the criteria. But much like your Hazard Communication Program, a list of hazardous materials used on the site is required for an HMBP. Fire Department Access Requirements: Is your building properly marked with the correct address, and can it be seen from the street? Are fire lanes required in front of your site, and are they properly maintained? If you need a fire response, you will want them to arrive at your site as quickly as possible, with as little difficulty in finding and accessing your site. A fire inspector will help you by making sure these requirements are met. While not a complete list, this gives you a brief overview of what you can expect should a fire inspector knock at your door. If you are in doubt of what you need to do for your operations, you can contact your local department for further information, or give us a call. We have former fire inspectors and regulators on staff. We can help you with the process. If you do not have a Fire Prevention Plan or Emergency Action Plan, OSHA has an etool that can walk you through the process. A link is provided below. http://www.osha.gov/SLTC/etools/evacuation/eap.html BECAUSE YOU ASKED What Training and Certification Do I Need to Clean Up Meth Labs? Beginning with this issue, we are adding a new feature to our Safety newsletter. “BECAUSE YOU ASKED” as the name implies, will present responses to questions we receive at Safety Compliance Management that might be of interest to many of you. If you have any questions you would like to read about, please let us know. You can send a note to newsletter@scm-safety.com. Methamphetamine (meth) producing laboratories present one of the most challenging of environmental issues. Not only do you have the criminal aspect of illegal drugs, combined with often booby-trapped hazardous surroundings but these sites are a toxic mess of hazardous wastes. The Environmental Protection Agency (EPA) estimates that there are over five pounds of waste produced for every pound of meth produced. This waste is typically dumped into the soil or poured down drains. There are actually two forms of meth, both with medicinal uses. You might be surprised to know that one, l-meth, is used in over the counter nasal decongestants. When used legally d-meth is available by prescription for ADHD and in some obesity treatments. Unfortunately, d-meth is a central nervous stimulant that is easy to manufacture illegally using chemicals you can purchase almost anywhere. Although pseudophedrine is more difficult to find, it is in some cold medications. When combined with other accessible products such as anhydrous ammonia, starter fluid, drain cleaner and paint thinner, d-meth is the result. Meth labs can be found just about anywhere. It is “cooked” in homes, trailers, campgrounds, hotel rooms and even vehicles. Usually, those doing the “cooking” are not concerned about the safety aspects of the operations, despite those concerns being considerable. Sometimes the labs are discovered as they explode, since these are unstable and often volatile compounds. And, when not in the cooking process, the chemicals are frequently stored haphazardly, sometimes in unmarked containers. The materials found at meth or clandestine drug labs pose other hazards as well. As the chemicals cook, they evaporate quickly, forming an inhalation hazard. From the components, as you might imagine, exposure to these materials includes shortness of breath, the potential for interior and exterior chemical burns, and damage to the central nervous system. When an illegal drug lab is discovered, after the law enforcement and legal proceedings, the site will need to be cleaned up. It generally takes remediation to put the site and anywhere the waste was dumped back into habitable condition. Typically at this point the site is under the jurisdiction of the local health authority. Depending on the structure of your local authorities, it could be a city, county or state health agency or officer. This agency may provide the testing, monitoring and sampling of the site to determine if any of the areas are hazardous and to what extent. When they have completed their work, they will most often contact private removal contractors to do the actual clean up or remediation work. The agency with the list of removal contractors may vary from location to location. Again, this may be city, county or state agency. For example, the California Department of Toxic Substance Control maintains a list of approved contractors for that state. If you are interested in being on a list of approved contractors, a good place to start would be with your local health agency or office to find out how they hire removal contractors. Because of these and other hazards, those wanting to contract to work in these environments must have appropriate training. These sites are hazardous waste sites. Workers at waste sites most often need Hazardous Waste Worker (HAZWOPER) training. What level of HAZWOPER training is required to qualify you as a contractor for cleaning up drug labs will be specified by the enforcement agency. Some agencies, such as California’s Tulare County Environmental Health Services require their contractors to be trained as 40 hour General Site Workers (29 CFR 1910.120(e)). We recommend that, at a minimum, you have the 24 hour Occasional Site Worker training. As the regulation states, an Occasional Site Worker is someone who works at a hazardous waste clean up site on an occasional basis like an engineer, project manager, or a surveyor; and someone who regularly works with, or cleans up hazardous materials or wastes with exposures within "permissible" levels (PEL) and that do not require the use of respiratory protection. Other training, while not required, but recommended is Bloodborne Pathogens and infectious disease prevention. In today’s world, we are very aware of the need to protect ourselves from infectious diseases such as hepatitis and the human immunodeficiency virus (HIV). People who working in illegal drug manufacturing are not always as well informed, or take as many precautions against diseases. If you are going to be involved in working in such an environment, you might consider learning more about how to protect yourself. At SCM we offer the 24-hour Occasional Site Worker HAZWOPER training and the Bloodborne Pathogen through our online hazmatschool program. You can see more about these and the other programs that we provide through our website at www.hazmatschool.com. To learn more about the clean up of meth drug labs, a link is provided below to the State of California’s DTSC Methamphetamine Drug Lab Cleanup Program. Even if you are not located in California, at the bottom of the page are links to federal and other state programs. Remember, if you have a question that you would like to see answered in our newsletter, just send us a note at newsletter@scm-safety.com. http://www.dtsc.ca.gov/SiteCleanup/ERP/Clan_Labs.cfm THE SCM TEAM You and Us in the Safety World The first quarter of 2007 has been one of the most challenging ones for the SCM Team, and one of our busiest ever! Our team members have provided safety services and consultation up and down the West Coast, from Yakima, Washington, to Long Beach, California. Just a highlight on some of the programs that we have been involved with:
Finally, we are growing rapidly and if you would like to be a part of a growing team in a challenging and fun environment, and you have experience in providing HAZWOPER and other safety training programs, please send your resume to resumes@scm-safety.com. We would love to talk with you about how to join our team.
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