Jan at last year’s VOSH Conference discussing the finer points of purchasing the correct electrical safety equipment. (Photo: from Virginia Department of Labor & Industry video of session and off of their website)

This year I suggested speaking on how safety and health professionals can use Digital Photography in Support of Safety.  Here is the brochure description:

This is not your typical accident investigation photography class.  Instead, we will discuss the ever- growing opportunities to use – and misuse – digital photography in our safety and health efforts.  Topics will include effective use of the camera as a tool in documentation of the workplace; camera selection (point & shoots are just fine); privacy and property rights, including legal and ethical issues; use of digital images for safety training and communication of safety messages; use of image- enhancing software.  If you are reading this before the conference, you are invited to bring prints of your best examples of “digital safety.”  We will set up an exhibit!  All levels of photo experience are welcome – this is really about safety!

Those of you who have been following this blog will see my sneaky attempt to merge my professional work with my love of photography.  If you are in the Northern Virginia – DC – Maryland region, please join us June 1 – 4, 2010.  Day-tripper admissions are available.  Follow the link above and bring your safety photos with you.

Only one of several types of tie-off instructions put on modern scissor lifts. (Photo: Jan Thomas)

Last Friday I received a call from a client’s superintendent asking me to go over the reasoning and authority for tying off on scissor lift and other personnel hoists. This is the same question I’ve been answering for years and I’ve been answering it in the same way for years… specifically, “Despite what OSHA says, if the manufacturer has provided anchors points, please use them as they have been put there for your safety!”  

In Virginia, in the fall of 2006, my answer became a little stronger as I could now point to the “authority” of VOSH when someone wanted to argue with me that OSHA doesn’t require tie off on scissor lifts. 

Earlier this year I wrote our clients a memo on this topic – it applies to industrial worksites, construction and all sectors of employment in between.  Here is a link to that memo. 

By the way, the superintendent was being questioned by one of his disbelieving subs.  So I reminded him that the true answer to “Why do we have to tie-off?” is “Because it’s our rule!”

(An excellent example of a crew working safely within vehicle backing zones. Photo: Jan Thomas)

See the ready mix truck on the left?  Thirty years ago, I did a fatality investigation of a worker on foot who was run over by such a vehicle.  Virginia averages two fatalities per year involving what has become known as “reverse operations.”   Sure, there are multiple causes to all such fatalities but it’s still accurate to say that we’ve been running over workers for decades because we have made pedestrians mainly responsible for their own safety. 

The OSHA standards (except for an exception in logging) have used what I call the “one solution” approach to keeping workers safe in a vehicle’s backing zone.   Up until now, it’s pretty much been about back-up alarms or maybe a flagger.  Three years ago, VOSH threw down the flag and started the public process to develop Virginia-specific Reverse Signal Operation Safety Requirements.  The new rule uses a multiple-strategy approach and requires action from drivers, ground guides as well as all workers on foot.  Emphasis is placed upon employee training!

VOSH starts enforcement on September 18, 2009, but don’t panic if you didn’t know about this.  The Virginia Department of Labor and Industry has developed and published excellent outreach and training materials and promises to use a phased-enforcement strategy.  When to use a designated observer or ground guide can be a complex and confusing issue but VOSH has already gone a long way to helping us understand when to flag and when to train.  Start here http://www.doli.virginia.gov/vosh_enforcement/reverse_signal.html .

By the way, a big Hi-Vis Fluorescent Yellow star goes to the contractor whose crew is shown above (I believe this is Jack L. Massie Contractors out of Williamsburg, Virginia).  Even their yellow hard hats give the drivers one last chance to spot the workers on foot.

A screenshot from http://www.doli.virginia.gov/ media_room/annual_reports/2008/ annualreport_08.pdf

I don’t like checklists, especially when used to guide a safety professional’s hazard audit or inspection.  If you just look for what is on the paper, you will miss what is right in front of you. One of the best inspection tools is the “What If?” analysis – but I’ll save that for a later blog.

Nonetheless, check-lists do have their place. At Circle Safety, we sometimes use them during our OSHA 10 and OSHA 30 hour training sessions as handouts to be taken away and reviewed later. We also sometimes use them when Safety Mentoring, but only as “training wheels.”  And, they are helpful as a reminder for a step-by-step series of tasks, such as those I’ve created for our construction clients at “Setting up Site Safety.”

Oh, speaking of checklists.  The Virginia Department of Labor and Industry has just published their 2008 Annual Report.  In it you will find VOSH’s General Industry and Construction lists for their “25 Most Frequently Cited Standards” – follow the link just below the screenshot.  We recommend that you use these as a check-list!

Kristian, our FA/CPR Training Coordinator caught while cleaning and repacking the CPR manikins. Photo: Kathy Redfern

While we are on the topic of Emergency Action Plans – and I have your attention with this weird photo, I want to highlight the recent changes to First Aid/CPR training requirements adopted on April 16, 2009 by the Virginia Safety and Health Codes Board for use by the Virginia Department of Labor and Industry’s VOSH program.  (See http://www.townhall.state.va.us/L/ViewMeeting.cfm?Meetingid=12584 )

Right now, if you read the federal OSHA standards – general industry or construction – you will find that they have different requirements and have been interpreted differently.   VOSH has been using these same requirements but has decided it’s time to standardize and modernize.   As a long time emergency responder, all I can say is YES!  And, it makes sense. Common practice in many US worksites is to have first aid and CPR trained workers immediately available to respond.

VOSH’s new regulations will require First Aid/CPR services when employees are exposed to serious occupational hazards in construction and general industry.  The test appears to be “if you could get seriously hurt at this workplace, you need immediate first aid response…. No waiting around for 911 to send help.”  The new standards also provide employers with some flexibility to make arrangements for services; for example, you can make arrangements with your on-site security contractor to provide first aid.

The new rules also clarify questions we always have about mobile crews and individuals out working alone.  And, since current OSHA regulations do not require CPR training for designated first aid providers, in Virginia that requirement is now clearly stated!

By the way, if you need CPR and First Aid training, call Kristian at 804.355.7255 and she will get you enrolled in one of our monthly open enrollment classes or schedule a special class for your workforce.

Jan Thomas presenting on Electrical Safety at the 2009 VOSH Conference. Photo by Jim Morris, VaDOLI

educational sessions – Jan presented on Electrical Safety and Anna spoke on OSHA Recordkeeping Issues – but we are also attendees at the break-out sessions.  Each year our consultants who attend the conference select sessions that build our individual and corporate knowledge base.  We ask questions, take notes,
collect handouts and business cards, and share what we learn with each other.

Here are only a few of our notes:

New Dust Mask Demonstration – Reed Schaffer with 3M Corporation demonstrated newer dust mask and respirator technologies that are on the market protecting workers.  He stressed the importance of evaluation selection criteria – knowing the contaminants and their concentrations is key in choosing an appropriate respirator; i.e., exposure limits, odor thresholds, IDLH limits, and particulate molecular weight.  Correct donning of even the simplest respirator protection still remains a key point for employee training and management follow-up.

 Leading & Lagging Indicators – Dave Mazary from Western Yorktown Refinery clearly showed that setting “OSHA compliance” as the goal leads to a minimal effort, comparable to a  C- grade.  Relating this grade to performance in school, we would hope that most managers would strive for a higher grade.  This can be accomplished by incorporating industry best-practice as a supplement to OSHA rules and by helping  workers reach peak safety performance through clearly defined tasks & objectives;  training the workers to properly perform these tasks; measuring the performance with validity; and rewarding for desired performance – immediately, personally and sincerely.

Crane Maintenance – Bill Davis with Zurich provided excellent photographs and a fast-paced discussion of the leading causes of crane accidents with highlights on crane maintenance and correct set-up and operation as preventions.  Q&A time highlighted areas of improvement in the new OSHA crane standard (to come out in Fall 2009?).  The proposed standard is supposed to include a 20-foot “limited approach” prohibition for overhead power lines – a 10-foot improvement on what we have now.

As we wrap up this year’s conference, we look forward to what VOSH has planned for the coming year, and as always, we anticipate interesting topics and new learning opportunities.

Buyer’s Guide above the extension cords in the electrical aisle at hardware store.

Part of what we do at Circle Safety is “mentor” people who have been designated as Safety Coordinator by their employer.

Recently I’ve started taking my clients to Lowes or Home Depot for a session on comparative safety shopping.  As we walk the aisles, I show them how to determine whether products meet two basic, important tests – OSHA compliance and best-practice. 

Consider that extension cord you want to buy.  If you have never researched the origins of OSHA standards on flexible cords and cables or dissected the meaning of “hard use” as applied to ratings then you may not make the best selection.  This is usually the case for most employees who are asked to order equipment or to go to the hardware store and pick up a new cord. 

As any good comparative shopper knows, you have to research and read labels.  And labels can be very deceptive.  I find this to be case with extension cord packaging/labeling.  That’s why I’m very grateful that the Home Depot and Lowes both have large instructional signs over their extension cord shelves.  So, yes, it’s getting easier to select the right extension cord but this isn’t the case for other electrical items typically seen in the workplace.

What about GFCIs, temporary lights or replacement plugs/ends for extension cords?  There is much confusion (some due to the OSHA standards), and a lot of outright deception in packaging. 

I’ve now introduced a hands-on workshop in our OSHA 10/30 hour training classes which gives attendees a chance to examine the boxes and attached labeling on commonly-used electrical products.  Those attending my Electrical Safety: Common and Not So Common Issues sessions at the 14^th Annual Virginia Occupational Safety & Health Conference 2009 will get a chance to participate in comparison shopping for safety.

Jan Thomas, PhD, CSP
President & Consultant

Front cover of current VOSH ARM

VOSH Administrative Rules Require Compliance with Manufacturers’ Guidelines -

This is BIG.

This is Virginia-specific information but really should be of interest to all safety and health professionals. 

In the fall of 2005, the Virginia Safety and Health Codes Board considered the Virginia Department of Labor & Industry’s request to update 16VAC 25-60 better known as the VOSH Administrative Regulations Manual.  Anna Jolly, JD, CHMM, my business partner here at Circle Safety, is a long-time member of the Codes Board.  She received a briefing package of the proposed language and attended the March 2006 meeting where the changes were adopted after public hearing.  No big deal…

Soon after, Anna and I attended the 2006 VOSH Conference and had one of those impromptu but important hallway discussions; we were talking with Ray Davenport, Commissioner of the Virginia Department of Labor, and Glenn Cox, VOSH Director.  Mention was made of the inability of OSHA to keep up with technical changes and research-based knowledge in the workplace.  This is especially hard for us professionals who must continue to respond to the question, “Where in the OSHA standards does it say I have to do that?” Our VOSH colleagues spoke of how new ARM language might begin to take care of this problem.

Here is §130 of the ARM, which is specific to Construction.  The same language is given for General Industry, Agriculture and Maritime standards.  All language became effective September 21, 2006.

 ”The employers shall comply with the manufacturer’s specifications and limitations applicable to the operation, training, use, installation, inspection, testing, repair and maintenance of machinery, vehicles, tools, materials and equipment; unless specifically superseded by a more stringent corresponding requirement in Part 1926…”  (See full text at http://www.doli.virginia.gov/publications/pdfs/ARM_2006_booklet.pdf).

In future Circle Safety blogs we’ll discuss specific examples of this knowledge-based approach to safety.  This is BIG.  Dare I predict that OSHA will come around to this approach?

Jan Thomas, PhD, CSP
President & Consultant

Some of the Circle Safety team at the 2008 VOSH Safety Conference lunch

Everyone is blogging. I like to write and several of us here at Circle Safety do technical writing for our clients on a daily basis. It seems natural that we should promote professional practice through support of a safety blog. Yet, I recently told a colleague that I would never blog! Never say never! 

Welcome to Circle Safety & Health Consultants’ blog for full-time, part-time and collateral-duty safety and health professionals. We plan on drawing from our growing circle of consultants to provide a full range of observations, comments and discussions on topics of interest to occupational and environmental safety and health professionals. 

Some of the Circle Safety team.

We have years of practical field experience – hard hats, safety glasses and well-worn safety boots in the vehicles, and plenty of safety resources. We’ve seen a lot and we’ve helped many organizations – small local start-ups to international firms – improve their EHS systems. We are always looking for ways to help move others from “compliance to excellence.” We have opinions and resources and we’d like to share them with our professional colleagues. So, let’s get started.

Jan Thomas, PhD, CSP
President & Consultant