Fall Protection Equipment Checklist

Fall protection equipment should be inspected by “competent” workers, who can use this checklist to ensure that this equipment is in good condition and safe to use. Adapt the checklist for the fall protection equipment in your workplace, safety laws, and the requirements or recommendations from the equipment’s manufacturer.

Inspector:___________________________ Date:_______________________

Company:___________________________ User:_______________________

Serial#:_____________________________ Model#:____________________

Manufacturer:________________________ Date of Man.:_______________

Violence, including murder and assault, happens in just about any industry. The presence of strong policies, combined with management support and effective implementation of policies and procedures, are all important measures to help protect workers.

Each workplace is different and the steps needed to prevent violence against workers may vary. Be sure to account for differences in your working environment as you plan and implement policies and procedures to stop workplace violence.

The following checklist identifies some of the questions you need to ask to help you recognize the danger signs and prevent future acts of violence in your workplace.

If you answered “yes” to one or more of these questions, then you may have a workplace that is at high risk for violence. It means you need to take action. Below are some things you can check to help improve the situation.

Citations were issued for four alleged willful, repeat and serious violations of safety standards following an OSHA inspection at a water main installation site in September 2006. Employees were found working inside a nine-foot-deep trench that lacked protection against a collapse of its sidewalls. Willful citations were issued because the company had been cited for the same hazard just one month earlier. Proposed penalties total $64,700.

[Powershot Utility Construction Services LLC. Release number 07-91-BOS/BOS 2007-015, Jan. 17, 2007]

A roofing contractor has been cited for five alleged repeat violations after an OSHA inspector observed employees working without fall protection at heights of 38 to 44 feet. The contractor was cited for allowing employees to work without fall protection, failure to train employees in fall protection methods and fall hazards, failure to provide a safety monitor competent in identifying fall hazards, failure to position a safety monitor to communicate with employees about fall hazards and failure to ensure that an employee wore heat protection. The company had been cited for similar hazards at other worksites in September 2006 and April 2007. Penalties of $70,000 have been proposed.

[A.M. Stern Inc., Rochester, NY. Release number 08-1248-NEW/BOS 2008-249, Sept. 4, 2008].

OSHA conducted a safety and health inspection in August 2007 and issued three repeat citations alleging failure to provide adequate protection, training, monitoring and emergency plans regarding employee exposure to ethylene oxide, a dangerous, colorless gas used in the sterilization process. The company was also issued 12 serious citations alleging failure to address hazards associated with ethylene oxide exposures, failure to implement engineering controls to reduce ethylene oxide levels that exceeded OSHA’s permissible exposure limits, and failure to provide baseline medical examinations for employees prior to working with ethylene oxide. The company also received a serious citation alleging a lack of guardrails on platforms and scaffolding.

[Steris Isomedix Services, Waukegan, IL.Release number 08-54-CHI, Feb. 7, 2008]

OSHA has proposed $54,250 in fines after twice finding workers exposed to falls between 24 and 26 feet while engaged in brick maintenance work in East Boston, MA. OSHA says workers were observed working on a makeshift form comprised of a fiberglass extension ladder laid horizontally atop a pump jack scaffold. On a second occasion, workers were observed facing similar fall hazards while standing on a work platform consisting of half an aluminum ladder and two dressed pieces of lumber. Other alleged hazards include improperly installed lifelines, scaffolding that wasn’t braced, an unguarded roof edge and walkway and inadequately or improperly used ladders. Other problems alleged by OSHA include a lack of fall protection, a lack of scaffold hazards training, the absence of a competent person to inspect for, identify and correct hazardous conditions, a lack of head protection, an unguarded saw blade and electrical hazards.

[Star Service Corp., East Boston, MA, Jan. 25, 2010]

OSHA conducted an inspection in October 2010 and cited the company for failure to use lockout/tagout procedures for energy sources, guard open-sided floors and platforms, provide standard railings for fixed stairways, mark doorways or passages along an exit route, ensure fire extinguishers were readily available and provide machine guarding. Other alleged serious violations include failure to remove a front-end loader from service when repairs were needed, perform periodic inspections of crane hoists, keep aisles clear and free from debris, protect electrical conductors from abrasions, ensure unused openings in electrical panels were effectively closed and provide covers for junction boxes. The company was also issued three other-than-serious citations alleging failure to complete OSHA 300 logs, certify a personal protective equipment hazard assessment and document the inspection of lockout/tagout procedures. Penalties totaling $76,500 have been issued for these alleged violations. 

[Imperial Aluminum, Scottsboro, AL,March 10, 2011]

Odds of winning the lottery: 1 in 135,145,920 (multi-state, mega-millions jackpot)
Lifetime odds of drowning in natural water: 1 in 2,828 (Source: National Safety Council’s Odds of Dying)

1. The Canadian Red Cross says only one in five Canadians who die as a result of boating incidents is found to have been wearing an appropriate personal flotation device (lifejacket).
2. Nearly 500 US residents die each year as a result of unintentional, non-fire related carbon monoxide poisoning.
3. There were 16 deaths associated with confinement or entrapment in low-oxygen environments across the United States in 2004.
4. In 2004 there were 48 deaths associated with suffocation following cave-ins.
5. Across the US in 2004 there were 52 allergic-reaction deaths following stings from bees, wasps or hornets.
6. In Canada in 2004 there were 100 deaths as a result of choking on food.

Odds of winning the lottery: 1 in 135,145,920 (multi-state, mega-millions jackpot)
Odds of a woman experiencing domestic violence at some point between ages 18 and 64: 1 in 4 (Source: Domestic Violence Council reporting on a 1997 US survey)

1. Thirty-seven percent of women who have experienced domestic violence reported that it had an impact on their work performance, hampering job promotions, attendance, their ability to show up on time and ability to keep their jobs.
2. Forty percent of business leaders surveyed said they were personally aware of employees and other individuals affected by domestic violence.
3. Workplace productivity has suffered as a result of domestic violence, according to 47 percent of executives polled.
4. Seventy-four percent of domestic violence victims have suffered abuse, harassment or violence from their partners on at least one occasion while at work.
5. Seventy-eight percent of human resources professionals polled by Personnel Journal stated that domestic violence is a workplace issue.
6. Domestic violence was ranked as a significant security problem for 94 percent of corporate security officers surveyed.

Odds of winning the lottery 1 in 135,145,920 (multi-state, mega-millions jackpot)
Lifetime odds of dying from electrocution: 1 in 5,000 (Source: LiveScience.com)

1. The minimum electrical current detectible by a person is 1 mA (milliampere).
2. Electrocution is the 5^th leading cause of occupational injury deaths in the US.
3. Workers must ensure that ladders, scaffolds, pipes and other tools and materials are not brought any closer than 10 feet from overhead power lines. With higher-voltage lines, that safety margin should increase to 35 feet.
4. Every 30 minutes, a worker suffers an electrical injury severe enough to require time off work to recover.
5. Work experience or lack of it plays a significant part in electrocutions, with 41 percent of US victims having been on the job for a year or less.
6. An electrical current of 100 mA (milliamperes) can be fatal, depending upon how it passes through the body.

Odds of winning the lottery: 1 in 135,145,920 (multi-state, mega-millions jackpot)
Odds of experiencing a mid-afternoon energy slump: 84 in 100 (According to a survey conducted by Harris Interactive for Diet Pepsi Max)

1. Twenty-five percent of Canadian adults claim to have difficulty getting to sleep or staying asleep (Statistics Canada).
2. Thirty-one percent of Americans say their jobs are directly responsible for their exhaustion.
3. Forty-seven percent of Canadians admit to cutting back on sleep to create extra time in their days (Statistics Canada).
4. Fifty percent of respondents in the Harris Interactive poll said they have caught co-workers sleeping on the job.
5. Consuming beverages containing caffeine is the coping mechanism for dealing with a mid-afternoon slump for 52 percent of respondents.
6. Fifty-eight percent of the Americans polled said they get up and walk around the office to try to shake off mid-afternoon sleepiness.

Odds of winning the lottery: 1 in 135,145,920 (multi-state, mega-millions jackpot)
Lifetime odds of dying in a fall from a ladder or scaffolding: 1 in 9,616 (National Safety Council Odds of Dying)

1. The United States experienced more ladder-related fatalities, 355 in 2004, than any other nation. That makes it the number one country in the world for ladder deaths.
2. Most ladder deaths involve falls of 10 feet or less.
3. Canada recorded 39 deaths from falls on or from ladders in 2004, according to the World Health Organization (WHO).
4. Fifty percent of occupational fall fatalities in the US occur in the construction industry.
5. Falls account for 70 percent of fatalities involving scaffolds.
6. The US Consumer Product Safety Commission (CPSC) reports that there are approximately 164,000 ladder-related injuries across the country each year.

If your workers work outdoors or in unheated indoor spaces, you’ll need to equip them—physically and mentally—to handle the hazards of cold weather. As a safety coordinator, you know well that frostbite and hypothermia (which, for simplicity’s sake, we’ll refer to collectively as “cold stress”) represent a serious threat that is not to be trifled with. They can paralyze, amputate and kill. But your workers might not get the message until it’s too late.

Are you doing enough to protect your workers against the risks of cold-stress? If one of your workers should suffer a serious or fatal cold-stress injury, could you and your company be liable? This article will help you answer that question. We’ll look at what the law requires employers to do to safeguard their workers against the dangers of cold stress. We’ll also show you how to create an exposure plan to insulate your workers against injury and your company against legal risk. There’s a Model Plan below.

What the Law Says About Cold Stress

There is a legal duty to guard workers against cold stress, even though OSHA doesn’t have a specific standard on cold stress. The OSHA General Duty Clause (Section 5(a)(1) of the OSH Act) says that every employer must safeguard workers against “recognized hazards” that can cause great bodily harm or death. Cold stress can cause great bodily harm or death. And it’s a recognized hazard. As a result, all employers must take steps to protect their workers against cold stress.

Many states also require employers to take specific measures against cold stress.

As you might expect, the OHS laws of all Canadian provinces and territories, without exception, recognize cold stress as a workplace hazard and require employers to take measures to protect workers against it. But the nature of the obligation varies from province to province. There are two basic patterns of regulation.

10 jurisdictions (BC, Fed, NB, NL, NS, ON, PE, QC, SK and YK) directly address cold stress in their OHS regulations and require employers to take specific measures. The level of detail in each regulation varies from provinces to province. So while ON and federal regulations simply state a minimum temperature level an employer must maintain, provinces like QC, BC and SK lay out an array of measures employers are supposed to take.

In the latter provinces, the preferred approach is to implement engineering controls to maintain thermal comfort; if use of engineering controls to eliminate the hazard is not “practicable,” employers must use a combination of administrative controls and protective clothing and equipment to manage it. And, of course, employers are also required to warn and educate workers about the dangers of cold stress, including how to recognize and treat the various signs and symptoms of frostbite and hypothermia.

A typical example of a fully developed cold stress regulation is Part 7 of the BC OHS Regulation which requires employers to:

• Conduct a cold stress risk assessment and create an exposure control plan that provides for monitoring and worker education, among other things (Sec. 7.34);
• Implement engineering controls to reduce exposure to levels classified by ACGIH (American Conference of Government Industrial Hygienists) as of “little danger” (Sec. 7.35(1));
•  If engineering controls are not “practicable,” reduce exposure hazard through the use of administrative controls and PPE (Sec. 7.35(2));
• Provide a “nearby” heated shelter for workers exposed to a thermal environment with an equivalent chill temperature of less than -7o C (-19o F) (Sec. 7.36); and
• Ensure that workers exhibiting symptoms of cold stress are removed from further exposure and treated by a qualified first aid attendant or physician (Sec. 7.38).

Four provinces and territories (AB, MB, NT and NU) don’t specifically mention cold stress in their OHS regulations. But, as we hope you know, employers aren’t supposed to address only the hazards specifically mentioned in the OHS regulations. All OHS statutes include a General Duty clause requiring employers to furnish workers a safe place to work and take reasonable measures to eliminate foreseeable risks. The four provinces where there are no cold stress regulations interpret their General Duty clauses as applying to cold stress.

Two of these provinces, AB and MB, have issued guidelines setting out the measures employers should take to protect workers against cold stress. Although they don’t carry the same legal authority as a regulation, when the government agency of a province prescribes specific guidelines for dealing with a hazard, employers concerned about their liability should give serious consideration to adopting those measures, or at the very least have a compelling justification for not doing so.

Why You Should Create a Cold Stress Exposure Plan

Simply reminding your workers to stay warm and to be careful in the cold isn’t enough to protect them or ensure compliance with legal requirements regarding cold stress. You must also educate your workers about the dangers and apply appropriate engineering, administrative and work controls to manage those dangers.

BC and PEI require employers to implement a cold stress exposure plan. The other provinces don’t mention anything about a plan; even so, creating such a plan and putting it into effect is a good strategy for protecting workers and managing liability risk no matter what part of Canada you come from.

How to Create a Cold Stress Exposure Plan

There’s no such thing as a one-size-fits-all plan for cold stress exposure. Solutions, policies and procedures will vary according to industry, facility type, work process involved and the requirements of your province’s law. But the Insider’s Model Plan on page x can help you get organized and frame an appropriate plan. The Model Plan, which is based on the cold stress guidelines prepared by the Government of BC, lays out the fundamental elements a basic plan should include. Just make sure you adapt it to meet your own needs and circumstances.

Like ours, your plan should:

Explain the Plan’s Purpose. Help workers understand the dangers they are trying to prevent, such as frostbite and hypothermia, by explaining them in the plan.

Require Periodic Monitoring of Temperature, Wind Chill, and Other Factors. The legal obligation to protect workers against cold stress involves monitoring temperature and wind chill levels. But it doesn’t stop there. Your supervisors should also consider whether the worker is performing light, moderate, or heavy work. While moderate work provides a warming effect, heavy work produces perspiration which makes workers more vulnerable to cold stress injuries. Another important factor is whether working conditions are wet — which would require additional protection — or dry.

Require Supervisors to Protect Workers Subject to Cold Exposure. Several provinces — including BC, NL, SK and YK — require employers to provide specific measures for protecting workers, including special equipment such as shelters, warm clothing, hot drinks, and limited work schedules. And virtually every province expects employers to schedule work breaks in accordance with recommendations published by the American Conference of Governmental Industrial Hygienists (ACGIH). You can obtain these recommendations by going to www.acgih.org and searching for “cold stress TLV” (without quotes). For a similar version that you won’t have to pay for, take a look at Section G7.35-3 of British Columbia’s cold stress guidelines: www2.worksafebc.com/Publications/OHSRegulation/GuidelinePart7.asp.

Insist that Workers Work in Groups. Like heat stress injuries, cold stress problems can creep up on a worker before he realizes what’s going on. The best way to protect your workers is to have them work together, putting each worker in charge of another’s safety.

Provide for Worker Training. The plan should require somebody at your facility to train all workers and supervisors about the signs, symptoms and prevention of cold stress. Too many workers regard being cold as a mere discomfort, something a “real man” (or woman) wouldn’t complain about. Chances are, they don’t know much about hypothermia; and, while they’ve all heard the term “frostbite,” not many are likely to understand what the condition is and how it can hurt them.  Because warming a person improperly can cause additional damage, your workers should also be trained on the appropriate first aid measures for each form of cold stress.

COLD EXPOSURE CONTROL PLAN

PURPOSE: ABC Company (“Company”) is adopting this Cold Exposure Control Plan to ensure that workers are protected from exposure to cold stress injuries such as:

• Frostbite: destruction of body tissue (usually on the face, ears, fingers and toes) that can result in permanent damage and destruction, including amputation.
• Hypothermia: a life-threatening condition where the body’s core temperature falls below normal (37°C) due to a sudden or prolonged exposure to cold such as falling into cold water or working outdoors for an extended period.
• Chillblains: mild cold injury due to prolonged and repeated exposure to cold temperatures that results in swollen, red, and itchy or painful skin.
• Trench Foot: cold, swollen, or numb feet that have been subjected to cool water (often, at above-freezing temperatures) for prolonged periods, resulting in nerve and muscle damage.

These hazards can occur any time that workers are exposed to artificial or natural cold, including cold storage rooms, freezers, and refrigerated transportation units or unheated and outdoor work spaces during cold weather.

POLICY:

1. Supervisors must exercise due diligence for worker safety when assigning work in cold environments by monitoring and taking the following into account:
   • Air temperature;
   • Wind chill factor;
   • Level of work effort (light, moderate, or heavy); and
   • Work conditions (dry or wet).
2. Each supervisor shall ensure that workers are equipped with the following work controls when necessary to protect against cold stress hazards:
   • Appropriate clothing (including insulated footwear, layered garments, head coverings, and gloves or mittens) that protects against cold and water and provides traction to prevent slips and falls;
   • Appropriate protective equipment such as insulated sleeping bags and survival equipment that will allow a worker to endure natural elements until rescued;
   • Barricades or other structures to block air or reduce air velocity at the work location;
   • Machine controls and tools that workers may operate without removing protective clothing such as mittens or gloves;
   • Postponement of non-urgent tasks and rescheduling of work activities to allow for work during the warmest part of the day or when the wind is the most calm;
   • Heated shelters and warm liquids; and
   • Increased time to acclimatize to cold temperatures.
3. Workers at risk of exposure to the cold shall be permitted to take work/warm-up breaks in accordance with the guidelines recommended by the American Conference of Governmental Industrial Hygienists (ACGIH). In the event they are extremely uncomfortable, they shall be allowed to interrupt their work for an extended time period.
4. All workers subject to cold exposure shall work in groups of at least two workers each so that they may be observed by at least one other designated person in the workgroup. Workers who observe symptoms of cold stress must take the employee to a heated first aid room, contact his or her supervisor, and (if appropriate) call immediately for medical assistance.
5. All workers with the potential for exposure to conditions that could cause cold stress shall receive initial and annual refresher training on:
   • Recognizing signs and symptoms of cold stress illnesses and injuries;
   • Cold stress prevention, including proper clothing habits and safe work practices;
   • Factors that could increase the risk of cold stress injuries and illnesses, such as caffeine or alcohol consumption and direct contact with metal surfaces;
   • Increased risks associated with handling materials and equipment in extreme temperatures; and
   • Proper first aid response and emergency procedures for responding to cold injuries and illnesses.

• During a coffee break, ship workers notice that one of their colleagues is missing. He was last seen inside the hull of a barge making repairs. A worker enters the confined space to check on him. When he doesn’t come back, a third worker goes in to rescue them both. Then a fourth and a fifth. Before it’s all done, four workers are dead. The company is fined $130,000 for not protecting workers against confined space hazards [Westminster Marine Services].
• A worker is spray painting the interior walls of a water tank. Combustible vapors are building up inside the tank. Suddenly, the worker’s troubleshooting light goes out. When he tries to relight it, a spark causes the vapors to ignite. The worker suffers burns over 90 percent of his body. The director of the company he works for is fined $10,000 [ v. Raglan Industries Inc.].
• Two paper mill workers are sent to clean up a sulphuric acid spill inside a containment tank. The soda ash they’re using to clean the spill reacts with the acid and emits carbon dioxide vapors. One of the workers passes out and falls face first into the acid. He suffers severe facial burns and loses an eye. The mill is fined $12,000 for failing to adequately train and equip the worker to work safely in a confined space [ v. Pine Falls Paper Co. Ltd.].

If you’re ever unfortunate enough to have a serious or fatal accident at your workplace, it’s a pretty good bet that it will happen inside a confined space. That’s because confined spaces are one of if not the most dangerous part of any workplace. The three cases above drive home this point. They also show that companies run the risk of liability when injuries occur inside confined spaces.

Confined spaces regulation is a very complex topic. This article zeroes in on one aspect: The use of entry permits to limit who can get into a confined space. This article will explain what the law says about entry permits and how to comply with the requirements.

The Law of Confined Spaces

OSHA and Canadian OHS regulations require employers to use a combination of engineering measures (such as atmospheric testing), safe work practices (such as mandatory buddy systems) and administrative controls (such as training) to protect workers against confined space hazards.

U.S. OSHA standards impose an additional administrative requirement: Employers must use entry permits to limit workers’ access to certain kinds of confined spaces. The permit lists critical safety information such as the workers’ qualifications and the protective equipment required for the work. The worker isn’t allowed into the space unless and until a supervisor reviews the permit to verify that it’s complete and accurate.

In Canada, Alberta, BC, Nova Scotia and Ontario are among the provinces that follow the U.S. OSHA example and require employers to establish an entry permit system. In AB, BC and ON, the permit gets issued before the worker enters the confined space and is posted at the entry during the work. NS uses a variation of the permit system in which a “competent person” issues a general certificate stating that conditions in the confined space have been tested and found safe for the particular type of work for a particular period of time. Somebody then reviews the permit before the confined space work begins to ensure that it’s current.

How to Create an Entry Permit

Once you decide to implement a permit system, you must create the right kind of permit form to use. The important thing is making sure that your permit includes all of the information you need to review to determine if the proposed entry into the confined space is safe and all hazards have been addressed. The regulations list the information a permit must list. These typically include:

• Location of the confined space;
• Name of each worker who enters the space;
• Reason for entry (AB)/work activities covered (BC)/description of work to be performed (ON);
• Period for which permit is valid;
• Precautions necessary
• Name of the attendant watching over the confined space;
• When each worker entered and exited;
• List of equipment required for entry and rescue;
• Verification that equipment is in good working order; and
• Results of atmospheric testing, if any.

Conclusion: The Training Challenge

Safety training plays a critical role in protecting workers from confined space dangers. First and foremost, the supervisor must familiarize workers with the dangers of confined spaces. The Safety Talks and other materials you find in SSOL can make this job much easier.

The second part of the training challenge is to familiarize workers with the company’s confined space practices, policies and procedures, including the use of permits. The Model Permit below can be adapted to meet the circumstances of your own workplaces.

More than 32 million American adults wear contact lenses. Of course, many of them are employees who wear lenses in a variety of industrial environments.

Here’s what the employee, employer and first responder should know about contact lenses in the workplace.

The Employee View

Contact lens materials and designs have advanced a long way in the past 30 years. Today’s contact lenses are cleaner and more comfortable to wear on the eyes. These advances have lead to a healthier use of contacts for the wearer.

Disposable soft contact lenses can be replaced daily, weekly, monthly or quarterly. Prescription options enhance the eye’s muscle coordination and offer a wider field of vision. There are even bifocal contacts.

Contact lenses can be used cosmetically, for example, to change or enrich eye color. But it is important to remember that contact lenses are classified by the Food and Drug Administration as a medical device requiring a doctor’s prescription.

How the Workplace Affects Contact Lenses

Where contact lens use is permitted in the industrial workplace, employees must be sure to inform their eye doctor that they plan to wear their lenses at work. That’s because there are a number of critical variables that may affect the doctor’s final choice of a contact lens design. Besides the prescription itself, the variables associated with the employee’s industrial environment include:

• Dust and airborne debris levels;
• presence of vapors or gases; and
• Exposures to chemicals.

Based on the information supplied by the employee, the doctor’s final choice of a contact lens may:

• Include a larger diameter to protect the eye from debris; or
• Consist of a plastic material which is more resilient to dirt and debris collecting upon the contact lens surface.

Or, the doctor may determine that contact lenses are not appropriate for the industrial environment and advise against providing a prescription for such an application altogether.

What to Tell Your Eye Doctor

To help the doctor make an appropriate decision, employees should provide the doctor a summary of information relating to how they use their eyes during work activity. In the summary, employees should explain to their eye doctor:

• What the work environment is like;
• The on-the-job visual demands it involves; and
• The unique distances involved with the work activity (this information is especially vital for wearers of bifocals).

Teaching Your Employees to Care for their Lenses

There are four things a person needs to properly care for contact lenses.

1. Lubricants

Contact lenses dry-out during use. We blink less when we tire. This causes the lens to dry. Dust and debris in the workplace also contribute to the drying process.

It’s therefore necessary to use a contact lens lubricant to maintain the proper moistness level and maintain contact lens performance during the workday. It’s important to use the right kind of lubricant. Long gone are the days when saliva could be used for lubrication. Drops designed for “getting the red” out of your eyes will permanently destroy a contact lens if used while the contacts are on the eye.

2. Carrying Case

In my experience, most contact lens loss or damage can be traced to the fact that no case was available. When filled with fresh solution, a carrying case provides the safest way to store a contact lens. A glass of water is not a safe or sterile alternative.

3. Back-up Contact Lenses

Contact lenses are generally uncomfortable when debris builds up on the lens surface, a rip or tear develops along the lens edge or a crack occurs in the body of the lens. A back-up contact lens allows the employee to replace the uncomfortable lens with a fresh one. If the eye is still uncomfortable or irritated, the employee should remove the contact lens and consult the eye doctor.

4. Safety Glasses

What better way to continue your workday endeavors safely and comfortably than by using your safety glasses? They won’t help you if they’re at home on the dresser. The safety glasses prescription should also be up-to-date. If the prescription is over two-years-old, chances are you won’t see as well as you should to perform your best on the job.

The Employer View

Let’s now consider contact lenses from the employer’s perspective.

Know the Regulations

There’s only one OSHA standard that specifically addresses the wearing of contact lenses in an industrial workplace. This standard recommends against contact lens use when working with acrylonitrile, dibromo, chloropropane, ethylene oxide, ethylene chloride and ethylene dianiline chemicals.

Canada: In Canada, there are six jurisdictions with legislation on wearing contact lenses in the workplace: Federal, PEI, Ontario, BC, Yukon and NT. In the remaining provinces, contact lens use would be encompassed under the so called “general duty” clause of the OHS laws—which requires employers to safeguard employees against known risks.

Develop a Contact Lens Policy

To address situations specific to your workplace, you should create a contact lens policy.  Your first step should be to assess the requirements for protective eyewear by reviewing the work environments in accordance with OSHA 29 CRF 1910.132 (d). Next, you should conduct your own hazard assessment. (SafetyXChange members can download my company’s hazard assessment form from Tools.)

3 Danger Signs

When preparing your hazard assessment, these three questions will help you determine if contact lenses are inappropriate for any given area in an industrial environment.

1.  Does this area already have a documented history of eye injuries and thus pose a potential hazard to the contact lens wearer? Note that chemical splashes currently account for 20% and flying debris 70% of eye injuries.
2. Does wearing contact lenses place the eye at greater risk of eye injury?
3.  Do contact lenses conflict with any existing safety requirement or strategy?

What Your Policy Should Say

Once you have identified that contact lens usage is appropriate for your workplace, be sure your company’s contact lens policy:

• Sets out which, if any, areas of your workplace where the use of contact lenses by employees and visitors is prohibited and restricted;
• Requires employees who wear contact lenses to have the four kinds of support materials as detailed in last week’s article: lubricant, carrying case, back up contact and safety glasses;
• Requires employees to fill out a form to ensure that their doctor has the information necessary to provide (or deny) an appropriate contact lens prescription;
• Requires employees to clearly indicate on their personal identifications if they are wearing contact lenses.

The First Responder View

Here’s what first responders need to know about contact lenses in the workplace.

Training First Responders on Contact Lens Removal

If an employee wearing contact lenses suffers an eye injury, it’s imperative to check the eye and remove the lens. If the lens is not removed, the eye can suffer serious injury. Ideally, injured employees can perform these functions themselves. But if for some reason, they are unable to remove their own contact lenses, a first responder might have to do it for them.

First responders need to be trained how to do this. Improper removal of a contact can make a bad situation worse and cause more serious damage to the eye. Training should cover both rigid and soft lens contacts since removal techniques differ for each.

First responders and safety personnel who wear or have worn contacts themselves may be best suited to do this. But even these individuals require training in the detection of injury and proper handling of contact lenses. My experience with contact lens wearers is that over time they tend to develop poor handling and maintenance techniques that could adversely influence their emergency techniques.

Keep the Appropriate First Aid Supplies

Your first aid center or kit should contain these five items to assist first responders:

1. Sterile gloves: Tears in the eye can lead to infections ranging from simple conjunctivitis (pink eye) to HIV. First responders handling contact lenses must wear gloves to protect against these risks. Gloves should be sterilized to avoid infecting the victim.
2. Multipurpose solutions: You need solutions to help loosen a contact lens if bonding to the eye’s epithelium has occurred and also for temporary storage of contacts. You need solutions for soft and rigid lenses. Caution:Eye wash solutions contain a type of salt that make them inappropriate for contact lenses.
3. DMV removal devices: These specially designed removal instruments, referred to as “plungers,” are helpful in removing a rigid contact lens from the eye.
4. Glostrips: Available for both rigid and soft lenses, glostrips are used to detect a contact lens that has moved off center onto the eye‘s sclera (the white part of eye).
5. Temporary storage contact lens cases: Having temporary storage cases on hand will help prevent any loss or damage to the contact lenses once removed.

Keep Records

Your first responders should also have access to a data file that lists both office and plant employees who wear contact lenses and the type they wear (i.e., soft lens or rigid). This information may prove crucial to the rendering of appropriate first aid.

Conclusion

Employers who permit contact lens usage should have a clear contact lens policy in force; first aid responders should have proper training and resources; and employees who wear contact lenses in an industrial environment must follow their doctor recommendations for safe wearing and care. By implementing these protocols, contact lenses should not pose a risk to the employee, the first responders or the business.

The focal point of training workers in proper use of respiratory equipment is to demonstrate all of the different forms of respiratory protection and the kinds of hazards each one is suited to protect against. Here are the seven basic kinds of respiratory protection equipment in order of complexity, i.e., starting with the simplest and ending with the most complex. If you don’t have actual pieces of the equipment, you can substitute photographs:

1. Dust Masks

Dust masks protect against dust and airborne particles. Masks are inexpensive, simple to use, minimally invasive and typically disposable. Limitation: The tradeoff is that they offer only limited protection and aren’t appropriate for tasks that involve severe respiratory risks.

Air Purifying Types of Respirator 

The next three forms of respirator are what are known as Air Purifying Types of Respirator. What they have in common is the use of a filter or cartridge to protect against airborne hazards. There are three types of Air Purifying Respirator:

2. Particulate Respirator

Particulate respirators use a filter and/or cartridge that captures particles in the air and prevents workers from breathing them in. Limitation: Filters and cartridges must be periodically cleaned and replaced in accordance with the manufacturer’s instructions. Particulate respirators don’t protect against gas or vapors.

3. Gas & Vapor Respirators

Gas and vapor respirators are designed to protect against hazardous gases and vapors in the air through use of a special chemical filter. Some gas and vapor respirators are designed to screen out specific types of gases and vapors. Limitation: Gas and vapor respirators don’t protect against airborne particles.

4. Combination Respirators

The difference between particulate and gas and vapor respirators on the one hand and combination respirators on the other is that the latter protects against both airborne particles and gas vapors. That’s because combination respirators include particulate and chemical gas vapor filters that need to be maintained and replaced according to the manufacturer’s instructions.

Air Supplying Respirators

Now the respiratory equipment is becoming more complex. The next three kinds of respirator are what are known as Air Supplying Respirators. Such respirators aren’t simply a head piece but a system of equipment containing four basic pieces:

1. A hood;
2. A helmet;
3. A face piece; and
4. A compressor or cylinder.

You should demonstrate how each system works including the component parts of the system. There are three basic systems:

5. Air Supplied Respirators

Air supplied respirators are a lightweight system that delivers clean air through a hose. They’re normally used for extended work periods in environments that are low in oxygen content or contain non-immediately life threatening levels of gases or vapors. Limitation: Air supplied respirators aren’t appropriate for work in atmospheres that are or may be immediately dangerous to life and health.

6. Combination Air Supplying Respirators

Combination air supplied respirators have an auxiliary self-contained air supply that workers can use if the primary supply source or system fails. They’re normally used for extended work periods in environments that are or may beimmediately dangerous to life and health such as work in confined spaces.

7. Self-Contained Apparatus (SCBA)

SCBA systems contain a wearable clean air supply pack and a hose connection that doesn’t restrict movement. Closed circuit systems provide air for up to 4 hours. Open circuits provide air for a fraction of that time—typically up to 60 minutes. SCBA systems are normally used when there’s a short time needed to enter and escape from atmospheres that are or may be immediately dangerous to life and health.

Getting workers throughout your company to display a “safety attitude” is the key to a safe and healthy work environment. Of course, that’s easy to say. The hard part is to actually cultivate such a safety attitude among your workforce. Here’s what safety trainers can do to achieve this objective.

The Challenge of Gaining Buy In

The biggest challenge is establishing and maintaining a safety conscious work environment. That’s a tall order and a full-time job. Sure, you might think and eat safety every day; but that’s not enough to get other people in the company to do the same.

By definition, a safety culture has to be experienced company-wide. The commitment must exist at all levels, including workers, supervisors and managers. Of course, buy-in at the upper levels is of critical importance. After all, if the rest of the management team’s agenda conflicts with this goal — such as an agenda that stresses maximizing production and output without regard for employees’ safety and welfare — then there’s no way the culture will be created.

The Role of Upper Management

You must have full support and buy-in from the top of the organization where the marching orders are initiated. Your task is to harness upper management’s muscle behind your culture building efforts. That involves working with your safety director to secure management’s help to:

• Promote safety to the Big 3: Safety must be recognized and included with the same importance as the “big three” – Quality, Delivery and Productivity. Safety can’t be the odd man out. It can’t be taken into consideration only when problems arise, or else problems will arise.
• Make safety everyone’s job: Every job description in the organization should include safety-related responsibilities and every employee should be held accountable for fulfilling these responsibilities.
• Establish safety goals: Quarterly and annual goals are set for the “big 3.” The same should apply for safety metrics. Establish the goals, monitor them, display them and celebrate accomplishments along the way. Accordingly, the company’s success should be measured in part on the achievement of safety goals and the responsibility must be everyone’s in order to achieve the goals for that success.
• Make safety a corporate mission: That corporate mission statement that you see hanging in a company’s reception area and board room generally includes a nice statement about satisfying the customer by providing a quality product. That’s all well and good. But if there isn’t also a reference to the company’s commitment to maintain a safe and healthy work environment, then odds are you’re looking at a company that doesn’t have a true safety culture.

From Preaching to Practice

Once you have gained the corner office’s commitment to a safety culture, everything just takes care of itself and health and safety nirvana is achieved. Right? Wrong. Sorry, but this is just the beginning of the challenge. The really tough task lies ahead. That task is to get everyone in the company to follow the directive in that corporate mission statement. Now you must create a work environment where people actually do think and act safely on the job. And a big part of the burden to champion this effort and keep it going falls squarely on the shoulders of you and the company’s safety director. Let’s look at what you can do to build a company-wide safety attitude.

Start at the very beginning. As soon as a new employee walks in the door and before they can even set foot in the plant, give them a thorough safety orientation. This is the best and earliest opportunity to plant the seed of the “safety attitude.” A safety orientation establishes the importance of safety to the company by laying it out as a responsibility that goes along with being a good employee.

Share the Responsibilities

Good safety managers utilize their best resources, including:

1. Managers & Supervisors. Managers and supervisors work with the employees on the front line every day and therefore can have the most consistent impact by:

• Setting an example;
• Carrying out the established safety guidelines and policies throughout the company; and
• Providing feedback for prevention and solutions to safety-related issues and problems.

2. Workers. Once you have the buy-in and support from managers, the workers on the floor need to be involved. Create a plant-wide safety committee program with representatives from all areas and shifts in the facility, so that everyone has a voice in safety issues.
3. Safety Committee. How many safety committees just meet, talk and complain? How many more propose ideas, solutions, changes and actions, but have no authority or commitment to follow through and implement any of their proposals? The ineffectiveness of a committee will quickly undermine your progress. And it’s much more difficult to win back the support and confidence lost along the way. A good safety committee must be consistent and active and it must produce visible results. Once you have an effective, working safety committee with good representation and support at all levels of management and on the shop floor, then you have a good foundation to support your safety program and a medium for continuous two-way communication.

Lead by Example

Your safety attitude must be contagious. You must be seen not as the enemy trying to impede the process, but as someone dedicated to a safer work environment, fighting for everyone’s safety every day.

Your workers need to see and feel the company’s commitment to providing a safe and healthy work environment. Seeing improvements or changes made in the name of safety demonstrates management’s dedication and goes a long way to getting everyone involved.

Discipline is also an important part of the program. View the individuals in your workplace as a safety team with your role being to constantly recruit players. Those who blatantly undermine the team by continuously ignoring safety and putting others at risk don’t belong on the team or in the company. Safety rules must be consistently and firmly enforced to let everyone know that following established safety policies is just as important as quality, delivery and productivity.

Never Give Up

Having the support and resources of everyone makes a world of difference when you can’t be everywhere, 24/7. You need to allocate time and energy to other important EHS-related responsibilities, such as training, operating permits, licenses, inspections, as well as OSHA, EPA and local regulatory requirements. Hey, someone has to drive the bus and that’s you.

You need to keep everyone thinking and acting safely every day. That requires effort. Make yourself accessible, encourage suggestions and show your commitment by implementing changes and improvements that make for a safer work environment.

Conclusion

The safety attitude is the all-important “intangible” that every team or program must have to be successful. You can’t touch it, but you can feel it. You can also feel it when it’s missing. The absence of a safety attitude is what we fight against every day to avoid the most hated word in the supervisor’s vocabulary: “accident.”

NIOSH (National Institute for Occupational Safety & Health). NIOSH has information on just about every topic you need in an industrial setting and eye safety is included.

Here are some of the many online resources on eye safety.

1. NIOSH Eye Safety

NIOSH (National Institute for Occupational Safety & Health). NIOSH has information on just about every topic you need in an industrial setting and eye safety is included.

“Each day about 2,000 U.S. workers have a job-related eye injury that requires medical treatment. About one-third of the injuries are treated in hospital emergency departments and more than 100 of these injuries result in one or more days of lost work.”

So begins the information on NIOSH’s website. From this site you have links to various eye statistics, as well as some Health Hazard Evaluations of some recent reports related to eye safety.

2. NIOSH Contact Lens Use

When the subject of eye safety in an industrial setting comes up, contact lens use is an often-asked question. NIOSH has a link from its eye safety home page to Current Intelligence Bulletin 59 – Contact Lens Use in a Chemical Environment. You can download the report by going to this website.

3. ANSI via International Safety Equipment Association

Safety eye wear has to meet tough ANSI requirements and their document, ANSI Z87.1-2003, Occupational and Educational Eye and Face Protection Devices provides manufacturers with the specifications to do just that. ANSI standards are copyrighted and cannot be reproduced. You need to purchase your copy. The International Safety Equipment Association is one of the organizations that sell this publication. You can order it from them by printing their order form and faxing them an order. The order form can be downloaded here.

4. Lab Safety Supply

Lab Safety Supply’s EZ Facts provides helpful information. Fact Sheet 125, What to Look for When Choosing Protective Eyewear, is one such bulletin. You can read it online, here.

5. Foundation of the American Academy of Ophthalmology

The Foundation of the American Academy of Ophthalmology has information on its website about eye safety around the home, for home activities, for sports and for hobbies. For example, many of us use steel-toed shoes when we’re mowing the lawn. How many also use safety glasses? Get more information at their website.

6. Prevent Blindness America

Prevent Blindness America is the nation’s leading volunteer eye health and safety organization with the sole mission of preventing blindness and preserving sight. Their website is full of easy-to-navigate links that provide information on eye safety, eye problems, and children’s eye problems. There is an eye test that you can print and useto test your eyes at home.

7. Prevent Blindness America, Connecticut Chapter

Getting children into the habit of using eye safety will reap big rewards for them as they grown up. The Connecticut Chapter, along with Prevent Blindness America, developed an interactive website for children’s eye safety. You can find it here.

Conclusion

You can also find some helpful information on the websites of the various safety eye wear providers.

It’s quite natural to think of your home as the safest place you can be. After all, that is where you escape the cares of the world and the pressures of work. However, many serious accidents happen at home. Painful injuries, permanent disability and even death can be the result of home accidents. Falls and fires are particular dangers at home.

Fortunately, there is much you can do to improve the safety in your home.

Start by following this home safety checklist:

  Is lighting adequate in all traffic areas, including sidewalks, entrance areas, basements and stairways?
  Are traffic areas free of clutter?
  Are stairways clear, with no items stored on them, even temporarily?
  Are there sturdy railings on all stairways, even in the basement and outdoors?
  Are stairs, steps and floors in good condition and free of tripping hazards such as torn carpet and loose tiles?
  Is there a non-slip surface on the floor of the shower and bathtub?
  Is your home protected by these safety devices: Smoke detectors, fire extinguishers, carbon monoxide detectors, Ground Fault Circuit Interrupters on electrical outlets in the bathroom and basement?
  Is all wiring in good condition? Is wiring adequate for the electrical appliances used in the house, including computer equipment?
  Are extension cords used only temporarily? Are they kept out of traffic areas?
  Are chimneys for wood burning stoves and fireplaces cleaned yearly?
  Are any flammable liquids such as gasoline and paint thinner stored in approved covered containers, in well ventilated areas? Are they kept far away from sources of ignition, such as cigarettes and pilot lights?
  Are drawers and cabinet doors closed immediately after use to prevent tripping accidents and head injuries?
  Are the handles of pots and pans always turned toward the center of the stove, not the edge of the stove where they can be reached by children or accidentally contacted by someone passing by?
  Are knives stored safely in a knife holder or other device so someone will not accidentally touch the blade?
  Are glass doors marked at eye level to prevent someone from accidentally walking into them?
  Is the house safe for children, even if they only visit occasionally? Are all medicines and cleaning materials stored well out of reach of children? Are stairways barricaded so youngsters cannot fall down them? Are electrical outlets covered by child-proof plugs?
  Are emergency numbers posted at each telephone? Is the house address and telephone number posted there as well?
  Do you hold regular family fire drills? Does each member of the family know how to escape from his or her bedroom and where to meet outside?

If you find hazards while you are inspecting your home, correct them now. If they require expert help, such as rewiring by an electrician, arrange to have the work done. Then make a regular safety review part of your family’s routine!

Summer Safety Checklist

HEAT STRESS PREVENTION
Drink plenty of water throughout the day. Water rehydrates your body better than other fluids such as pop or juice. Water at room temperature is absorbed into your system faster.
Plan ahead. Try to plan the most physically demanding tasks for the coolest time of the day.
Wear light, natural fiber clothing that will allow heat to escape.
If you are working outdoors, wear a hat.
Acclimatize yourself by gradually exposing yourself to the heat.
Get out of the heat during breaks.

DRIVE SAFELY
Before leaving on summer vacation, ensure your vehicle is in top running condition.
Be prepared for “the other guy” who may not be driving safely.
Keep your headlights on at all times, regardless of weather conditions.
Wear a seatbelt at all times and request that your passengers do the same.
As the driver, keep your concentration on the road; do not allow yourself to become distracted by the scenery, passengers, etc.
Avoid eating or drinking while driving; both hands are required on the wheel at all times.
Do not allow yourself to become too frustrated or upset by traffic jams or careless drivers.

WATER SAFETY
Swim only where there are lifeguards and never in isolated areas.
Do not swim beyond designated points.
Insist that children take frequent rest breaks.
To avoid cramps, wait a sufficient amount of time after eating before going into the water.
Always check out the conditions before diving into a body of water.

BOATING SAFETY
Ensure your trailer is in good condition.
Do not overload your trailer. Ensure the tongue capacity is not exceeded.
If you store articles on your boat, make sure that they are properly secured.
Drinking and driving don’t mix, and neither do drinking and boating.
Tell someone where you will be and what time you plan to return.
Provide a Coast Guard-approved flotation device for each passenger.

Working with machinery and equipment is always hazardous. But workers are especially at risk when they try to troubleshoot machinery that isn’t working properly. And troubleshooting is a common task in many workplaces. So given its inherent hazards, it’s important that you have a troubleshooting policy to ensure that workers can safely address machinery issues.

Machinery and Equipment Troubleshooting Policy Checklist

Weed Eater Pre-Start Checklist

Belts

  Secured?

  Not cracked or separated?

Blade

  Secure and balanced?

  Sharpened?

  Free of excessive wear?

  String/blade attached properly?

  String/blade shield in place and secured?

Fluid Leaks

  No sign of fluid leaks?

Accumulated Grass or Grease

  Mower, deck and chute free of debris?

Guards

  All guards in place?

  No sign of damaged guards?

Attachments

  Mounted and secured properly?

OSHA cited a company after an inspection found employees installing a water line in an unprotected trench more than five feet deep. OSHA says the cave-in hazard was made worse by the piling of excavated material at the trench edge. It could have undermined the trench’s walls and fallen onto workers. There was also no ladder or other safe means of exiting the trench and no head protection was used by employees in the trench. The same company was cited in March 2007 for similar hazards at another worksite. Four repeat citations carrying $22,200 in proposed fines were issued, along with three serious citations alleging that water was allowed to accumulate at the bottom of a trench, failure to have a competent person inspect a trench for hazards, and use of a damaged sling. Proposed penalties for the serious violations total $12,000.

[Bortolotti Construction Inc., Marston Mills, MA. Release Number 07-1805-BOS/BOS 2007-358, Nov. 26, 2007]

After receiving a complaint alleging electrical and machine guarding hazards, OSHA initiated an investigation on Sept. 27, 2006. As a result, two willful violations and 10 serious violations were cited. Willful violations were issued for alleged failure to properly guard machinery. Serious violations being alleged include failure to establish procedures to ensure the control of hazardous energy from machines, failure to train employees in the safe operation of powered industrial trucks, and electrical hazards. Total penalties of $111,500 have been proposed.

[Phoenix Trim Works Inc., Williamsport, PA. Release Number 07-445-PHI (OSHA 07-035), March 27, 2007]

OSHA inspected a Gadsden, AL jobsite as part of a regional emphasis program focused on reducing falls in the construction industry. Fast-J Steel Erectors was cited for serious violations alleging failure to conduct frequent and regular inspections of the jobsite and failure to ensure that employees wore protective headgear. Repeat violations for which the company was cited include a lack of fall protection on the structure, a lack of fall protection while using aerial lifts and allowing employees to climb onto and over railings while engaged in steel erection activities. Magna Steel Erectors was cited for four alleged serious violations, including the use of unsafe electrical equipment, a lack of fall protection on aerial lifts, improper installation of a fall protection system and failure to secure the building’s framework before placing construction loads on the steel. Fast-J is facing $105,750 in proposed fines, while Magna is facing $18,000 in proposed fines.

[Fast-J Steel Erectors and Magna Steel Erectors, Houston, TX. Release Number 07-725-ATL (119), June 6, 2007]