Archive for the ‘Safety’ Category

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Be Careful When Using Contractors – They Can Hurt You?

Thursday, November 24th, 2011

Many companies depend on contractors to provide dependable, quality work. Most of the time that faith is well founded, but often it is based on mistaken assumptions. When contractors work at your facility, your company falls under the OSHA Multi-Employer Worksite Policy (CPL-02-00-124). In my experience, this policy is either unknown or misunderstood by many.

In general, this policy requires the host employer (the company that owns or operates the facility or worksite) and the contractor to share responsibility for the safety of the contractor’s employees while working at the facility or worksite. If an incident occurs and a contractor employee is injured, OSHA will determine which employer (host employer or contractor) is the Controlling Employer and ultimately the responsible party. Because the host employer has overall responsibility for the facility or worksite, the host employer is usually determined to be the Controlling Employer. However, there are situations where the host employer may not be the Controlling Employer, such as on a construction site where there is a general contractor. In these cases, there is often a clause in the contract between the host employer and the general contractor giving the general contractor the authorities and responsibilities of the host employer. (more…)

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Linking EHS, Ethics and Economic Prosperity

Monday, October 24th, 2011

Striving to “do the right thing” can help environmental and health & safety (EHS) professionals create sustainable EHS programs that also have a positive impact on a company’s economic strength. EHS professionals must go beyond regulatory compliance and consider ethics in order to build successful programs that also boost the bottom line. While laws and regulations inform individuals and companies what they cannot do, ethics instruct individuals and companies as to what they should do. In other words, ethics is about doing the right thing, not about simply avoiding the wrong thing.

I support an “EHS management systems approach” in the workplace, which recognizes that unsafe acts, unsafe conditions and accidents are symptoms of problems in the organizational management system. In this philosophy, senior management is ultimately responsible for building an ethical system that effectively analyzes and controls workplace conditions and hazards. This means that EHS is no longer a “sunk cost,” but an integral function of doing business, just like quality.

Perhaps the greatest economic reason to support an ethics-based approach to EHS management within a capitalistic system is that prosperity generates an environment where continuing improvement and reduced risk are affordable.

EHS professionals must promote a more ethical approach to managing their own profession. This strategy requires moral courage, conviction and professional unity, including a bottom-up approach at their facilities and through professional organizations, and understanding the need to look out for workers, the environment, and the public despite culture, pressure and misdirection from management and peers.

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Go Green and Create a More Productive Work Environment

Monday, October 24th, 2011

Here are a few tips to green the workplace and keep employees working at their best:

• Preserve and make use of green spaces, including courtyards, ponds, walking paths and decks that allow occupants to enjoy and interact with the outdoors. Design workspaces that provide unobstructed views of windows to help bring the outdoor environment inside.

• Avoid “sick building syndrome” by improving air quality in the workplace. Ensure an adequate supply of fresh air and monitor CO2 levels to keep it within a healthy range and to avoid fatigue, headaches and difficulty concentrating.

• Evaluate and control employee exposure to airborne contaminants. Consider banning smoking on your campus including outdoor areas, and install permanent “knock-off” grates at all entrances to control unwanted particles from entering the workplace on employees’ shoes.

• “Green” your cleaning, maintenance and pest management operations by using more environmentally friendly cleaning products and organic, synthetic filters for equipment. For pest control, use non-toxic or minimally toxic methods only in targeted locations and for targeted species.

• Promote recycling. Distribute recycling containers around your buildings or campus to encourage separation of waste and recyclable items. Think beyond cans, glass, and paper. Consider composting food waste, including coffee grounds, from your cafeteria to improve the environment and reduce the cost of the waste stream.

• Control your own environment to work in greater comfort. Ask for the flexibility to adjust temperature, lighting and airflow to maintain personal comfort levels.

• Create a team of employees to monitor, patrol and educate workers on environmentally friendly behaviors. Celebrate events such as Earth Day and World Water Day to raise awareness and promote involvement.

• Add amenities such as huddle areas and quiet rooms to provide an inviting alternative to meeting rooms. Acoustical spray on ceilings and sound masking through white noise can minimize distractions in open office environments.

• Consider adding a fitness center to promote exercise and general health and well-being.

Remember – if employees are happy, healthy and comfortable, they are more likely to be productive at work.

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Maintaining a Safety Committee

Monday, October 24th, 2011

Encouraging worker involvement in company safety committees sometimes can be a challenge. Even so, to create a workplace that fosters employee engagement, morale and safety, workers must have a voice.

Depending on the specific workplace, some managers may face an uphill battle in achieving active employee participation in safety committees. Pressure to increase production, a temporary or short-term work force and overall lack of motivation can contribute to the difficulties of creating a productive safety committee at work. (more…)

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Are You Ready for TSCA Reform?

Monday, August 29th, 2011

The question most often asked when addressing this topic is, “Are you ready for Toxic Substance Control Act (TSCA) reform?” as if it is looming on the horizon but has yet to happen. The truth, however, is that most producers, manufacturers, and importers of chemical substances are dealing with chemical management changes on a daily basis.

Last year, there seemed to be growing momentum on this topic when both the TSCA of 2010 (H.R. 5820) and the Safe Chemicals Act of 2010 (S. 3209) were introduced. Both bills were immediately referred to congressional committees, where they remained for quite some time. Although one committee hearing was held on H.R. 5820, no further legislative activity was ordered, and because these bills were introduced in a previous session, no further action can occur. So are they dead? Not likely. Members often reintroduce bills that did not come up for debate under a new number in the next session. Although last year’s expedited reform came to a halt, it is safe to say TSCA reform by Congress is not behind us. However, when it will return remains a question. (more…)

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Posted in EHS Violations, Environmental, EPA, OSHA, Ralph Carito, Safety, Total Environmental & Safety | No Comments »

Maybe it’s Time to Hire the Right EHS Consultant

Monday, July 25th, 2011

In a climate of close scrutiny and hefty fines across all aspects of environmental and health and safety (EHS) regulatory compliance, securing the right EHS consultant to assist your company can make the difference between achieving and maintaining compliance at a reasonable cost, or spending too much money and remaining at risk. Let’s face it, almost every aspect of a company’s operation touches upon one or more of the many changing EHS regulation, it’s no wonder that there are so many consultants hovering over industry…or should I say those who call themselves EHS consultants.

Engaging a consultant, who is knowledgeable and who can swiftly and efficiently navigate through the many rules, regulations, laws and mandated compliance at the federal, state and local levels, will help your company stay on track and keep you moving in the right direction with little or no interruption to your operations or business. The flip side could be unfavorable, including excessive costs, fines, negative public relations, and worse yet an injury, death, or negative impact to the environment. (more…)

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What Chemicals do I need an MSDS for?

Thursday, June 23rd, 2011

Are you like most others; do you put every Materials Safety Data Sheets (MSDSs) you receive into your MSDS binder? Does your MSDS station look like the Congressional Library? Do you ever wonder what MSDSs really need to be maintained. How about wite-out or copy toner, or cleaning chemicals, or those small containers of hand cleaner that plant employees use.

If you work in a facility that uses or stores chemicals, you should be somewhat familiar with
OSHA’s Hazard Communication Standard, 29 CFR1910.1200. It is of my opinion that the purpose, design and requirements of this standard are exceptional and certainly needed. The main objective of this standard is to ensure that all chemicals produced or imported are evaluated to identify hazards, and for the hazards to be communicated to the facilities and individuals who use the chemicals. (more…)

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When it Comes to Electrical Safety, OSHA Standards can be Technical and Confusing

Wednesday, June 1st, 2011

What requirements do safety managers need to know?

Wouldn’t it be nice to know exactly what OSHA is training its inspectors to look for during an inspection that includes electrical safety, including surprising new areas of emphasis based on national OSHA directives? This article covers some of the typical electrical safety questions that OSHA inspectors will ask during a field investigation.

For electrical safety in the workplace, OSHA relies on expert consensus bodies such as the National Fire Protection Association (NFPA) and its standards published in NFPA 70E. To ensure that employers are following NFPA and OSHA guidelines, OSHA trains its inspectors and compliance officers to ask specific questions in the event of an electrical safety incident. Some typical questions are as follows: (more…)

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Managing EHS Regulatory Compliance: Be Prepared for Change

Saturday, March 26th, 2011

The risks and costs of environmental and health & safety (EHS) regulatory non-compliance are rising as the regulatory environment becomes more challenging. Compliance needs are pervasive and persistent across all geographical jurisdictions and industries. Today’s EHS professional (and those who wear a 2nd or 3rd hat as the person responsible for EHS compliance) face a vast and complex regulatory matrix that includes regulatory authorities focused on workplace safety, the environment, transportation and homeland security, to name just a few. EHS management now often encompasses requirements that extend beyond the immediate boundaries of the company, including upstream and downstream supply chain management.

The last 2 years have given shape to a complex regulatory landscape, with the United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals (GHS); the European Union’s (EU) Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) regulatory framework; and the possible reform of the United States’ Toxic Substance Control Act (TSCA). It is highly likely that 2011/2012 will bring many new compliance challenges.

By reviewing the below representative samples of the regulatory challenges that emerged in 2010, you can better prepare for 2011/2012′s emerging challenges and, therefore, begin to prioritize strategies and tactics that align with these challenges. (more…)

Posted in Environmental, EPA, NJDEP, NYDEC, OSHA, PADEP, Ralph Carito, Safety, Sastainability, Total Environmental & Safety | No Comments »

How to Properly Clean Up a Broken Fluorescent Lamp, According to the EPA

Monday, February 21st, 2011

The U.S. Environmental Protection Agency (EPA) updated its existing guidance document on how to properly clean up a broken fluorescent lamp. The updated document also includes recommended precautions in schools to prevent exposure to polychlorinated biphenyls (PCBs) that are found in older fluorescent light fixtures. (more…)

Posted in Environmental, EPA, Ralph Carito, Safety, Total Environmental & Safety | No Comments »

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