Occupational safety and health simplified for the industrial workplace

Introduction vii 1 Occupational Safety and Health Practice 1 2 Safety and Health Terminology and Hispanic Outreach 25 3 Regulatory Requirements 49 4 Occupational Safety and Health Man

Occupational Safety and Health Simplified for the Industrial Workplace

Occupational Safety and Health Simplified for the Industrial Workplace

Frank R Spellman

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Introduction vii

1 Occupational Safety and Health Practice 1

2 Safety and Health Terminology and Hispanic Outreach 25

3 Regulatory Requirements 49

4 Occupational Safety and Health Management 61

5 Industrial Hygiene Concepts—Including Ventilation and Noise Controls 85

6 Worker Right-To-Know 111

7 Emergency Response and Process Safety 129

8 Industrial Facility Design 157

9 Ergonomics and Manual Lifting 193

10 Toxic Substances and Hazardous Wastes 209

12 Fire, Welding, and Hot-Work Safety 257

13 PPE, First Aid, and Thermal Hazards 277

14 Confined Space Entry 301

16 Electrical Safety 339

18 Pressure Vessel Safety 357

19 Rigging and Material Handling Safety 367

In the past (and even to a degree in the present), very little discussion took place or was emphasized on industrial worker safety and health—and even less emphasis was placed on developing a consciousness for worker safety and health as an integral part

of industrial operations This trend has been changing, however—as it should One

of the most significant changes has taken place in colleges and universities Safety and environmental health and other safety-related courses and curriculums have been added to the pertinent fields of study, where occupational safety and health has been approached as a science with well-defined goals and objectives, not as an exercise in lip service and sloganeering With the new demands for maintaining a violence-free workplace and in compliance with Homeland Security requirements, the demand, in many cases, for highly trained occupational safety and health professionals has also increased

Still, a problem exists Many of these relatively recent training courses and lums have focused on the purely theoretical and scientific aspects of safety, health, and related topics You want proof? Hire a recent graduate from one of these programs

curricu-Hiring a highly educated safety and health graduate who is well grounded in logic and logic systems such as Boolean algebra, systems analysis, and design for safety is not unusual—however, this same student may be lacking in what is really required: a fun-damental grounding in the concepts of real-world safety and health practice In other words, a real gap exists between what our undergraduate and graduate students are typically taught, and in what is really required in the work world—the real world

What is really required is a combination of education and common sense delivered in

a simplified approach to problem solving Occupational Safety and Health Simplified for the Industrial Workplace is designed to help fill this gap This text is based on

more than 50 years of occupational and safety health practice where mistakes were made and proper actions were taken, and learning resulted from both

Clearly written in everyday English with an understandable, accessible, and direct and conversational style, this text provides easy access to a wealth of practical and substantial information It emphasizes developing a consciousness for instituting safe work practices and maintenance of good health as an integral part of industrial work practice, and also addresses industry’s responsibility to curtail workplace violence and

to incorporate clear communication with non-English-speaking employees The ciples in this book (if conscientiously applied) can prevent the devastating effects of

prin-improper or unsafe practices in the creation and delivery of work outputs and work

activities

Before we proceed with discussing the nuts and bolts of the occupational safety and

health profession it is important to issue a word of caution to the reader and to anyone

who has ambitions to become an occupational safety and health practitioner: although

this book can be used as a how-to-do-it guide—a kind of cookbook of recipes on how

to mix and blend various regulations, standards, common safety and health work

prac-tices, and simply doing the right thing to protect industrial workers from on-the-job

hazards and toxic exposures—the success of mixing and blending these ingredients

to cook positive results requires the occupational safety and health professional to

possess a strong will combined with a great deal of fortitude and persistence

Why?

You might think that workers (and others) will automatically do all that needs to be

done to protect their own personal safety and health And to a point this is usually the

case However, complying with safety and health rules and regulations is not always

easy; it can be very uncomfortable For example, when it comes to wearing clumsy

safety shoes, or using uncomfortable safety glasses, or donning a heavy hard hat, or

putting on some other type of unwanted and uncomfortable personal protective gear,

some workers will simply not use this protective equipment Or, in another example

of workers’ failure to abide by established safety and health rules or regulations: a

worker may fall back on that natural human tendency—the tendency to always look

for the easy way of accomplishing certain work tasks That is, many of us have the

tendency to bypass safety rules and/or devices to finish a task quickly and with as little

effort as needed Unfortunately, bypassing safety and health rules for convenience has

led to many injurious and fatal consequences too lengthy to list in any text

Throughout this book, the focus is placed on the need for professionalism, scientific

analysis of risks and safety measures, concern for human and environmental needs,

and real-world examples of effective occupational safety and health management

Materials included within the text include pertinent terminology and information, case

studies, and sections on management aspects; Hispanic outreach; indoor air quality;

thermal stress; security and vulnerability assessment; preventing workplace violence;

and much more

Frank R SpellmanNorfolk, Virginia

Chapter 1

Occupational Safety and Health Practice

Fatality Incident (9/22/87): The service technician was “changing out” a pole, that is,

securing a cable television line from an old pole to a new pole nearby He was working from the bucket of an uninsulated aerial lift He had attached a “come along” to the cable to hold it in place while he transferred it from the old pole to the new pole The electrical conductor on the old pole was about three and a half inches from the new pole The new pole contacted the 20 KV (phase to ground) power line The employee was apparently in contact with the new pole and the cable TV line He received an electrical shock and fell out of the bucket approximately 23 feet to the ground He suffered no broken bones The cause of death was electrocution He was not wearing

a safety belt and was not tied off

OSHA Standards Cited During Fatal Incident Investigation:

• 1910.67(b)(4)(iii)—the owner of the electric power line or his authorized

represen-tative was not notified and provided with all pertinent information before operation

of aerial lifts in close proximity to electrical power lines

• 1910.268(n)(11)(iv)—insulated gloves were not worn

• 1910.67(c)(2)(v)—a body belt was not worn with a lanyard attached to a boom or

bucket when working from an aerial lift

• 1910.268(b)(6)—inspection of support structure of aerial lift before use.

• 1910.67(c)(2)(ix)—controls were not marked.

• 1910.268.(c)—employer did not assure that employee was not engaged in

tele-communication work until employee was properly trained in precautions and safe practices (OSHA, 2014)

Safety often is viewed largely as a simple matter of applying specific routines In many cases the routines are repeated regularly despite obvious signs of their inadequacies

Greatly needed is an understanding that the sources of harm, which the safety specialty should be able to control, have basic origins although their consequences will differ in character and severity This view furnishes the realization that hazards are not simply the agents most closely identified with injuries Merely regulating them is not the sure way

to limit their effect

Grimaldi and Simonds, 1994

THE OCCUPATIONAL SAFETY AND HEALTH PROFESSIONAL

When new acquaintances are asked standard questions (where they live, where they

are from), sooner or later in the conversation the question arises, “What do you do

for a living?”

If the answer is “I’m a professional,” we might be impressed, but the question isn’t

completely answered Professional? What type of professional? Many different

pro-fessional disciplines or specialties are possible, from locomotive operators to “flight

engineers” to custodial personnel (“sanitation professionals”)

So what kind of professional is our professional? Unless he or she answers with a

specific professional specialty, the natural tendency will be for the questioner to ask,

“What kind of professional are you?” or “What type of profession are you involved

with?”

The respondent may offer an answer we might expect—“I am a mechanical

profes-sional or maybe a civil, aeronautical, chemical, electrical, industrial, administrative,

accounting, finance, or environmental professional.” Or the respondent might answer,

“I am an occupational safety and health professional.” Unless you are familiar with the

occupational safety and health profession, you might be taken aback by this statement

Occupational safety and health professional? What is that? What does it involve?

Simply put, the occupational safety and health professional is a Jack or Jill of

many engineering, scientific, and other professions Does this mean that the

occu-pational safety and health professional is an expert in all engineering, scientific,

and the other disciplines? Good question The short answer is no The long answer

depends on your definition of “expert.” If you define expert as does Webster’s

Dictionary (Expert—A person with a high degree of skill in or knowledge of a

certain subject), the answer is yes, because safety and health professionals should

possess a high degree of skill in or knowledge of occupational safety and health

But this really doesn’t answer our question, does it? To better answer the original

question, “Is the occupational safety and health professional an expert in all

engi-neering, scientific, and other disciplines?,” two words in this question need to be

changed to render a more accurate answer The words “expert” and “all” should

be changed—“Expert” status denotes that the safety and health professional knows

everything about safety—something no one could do To accomplish this amazing

feat, the occupational safety and health professional would have to be an “expert”

in law, engineering, technical equipment, manufacturing processes, behavioral

sci-ences, management, health scisci-ences, finance and insurance, human behavior—as

they relate to safety and health issues—to name just a few fields While true that the

occupational safety and health professional is typically an “expert” in a particular

area of workplace safety and health, it is also true that he or she can’t be expected

to be an “expert” in everything (who can be?) With regard to the word “all,” no one

person knows all or can know all; that’s a given

Let’s take a look at what the occupational safety and health professional really is

The occupational safety and health professional is knowledgeable in many aspects

of engineering, scientific, and other related disciplines—simply stated: again, a Jack

or Jill of many engineering, scientific, and other disciplines While an occupational

safety and health professional isn’t an expert in all diverse fields, he or she should be

Occupational Safety and Health Practice 3expert in how safety and health issues affect these many fields, and in how to elimi-nate, reduce, or control workplace hazards for these fields.

The occupational safety and health professional is devoted to the application of engineering and scientific principles and methods to the elimination and control of hazards They must know a lot about many different engineering and scientific fields

The occupational safety and health professional specializes in the recognition and trol of hazards through the use of knowledge and skill related to engineering, scientific and other disciplines

con-Major Accidents and Disasters

Major advances (Herculean advances in some respects) in technology have been made

in recent decades These include advances in nuclear power, electronics, chemical processing, transportation, management information systems, and manufacturing pro-cesses, digital this and that, to name just a few of hundreds of growth industries and processes Modern society’s attempts to ensure “the good life” for us all, have, at the same time generated many perils that are also responsible for many of the woes that beset us Why? With technological advances come technological problems, many of which have direct or indirect impact, not only on the safety and health of employees, but also on the public and the environment

When a process or operation has been correctly engineered (properly designed and constructed), it will show clear and extensive evidence that the design included atten-tion to safety Such a process or operation, under the watchful and experienced eye of

a competent safety engineer, can continue to operate in a way that reduces the chance

of occupational injuries, illnesses, public exposure, and damage to the environment

An occupational safety and health professional, one well versed in the basics of civil, industrial, mechanical, electrical, chemical and environmental principles, takes information pertinent to workplace safety and health from each of these disciplines

Exactly what will such exposure afford the safety and health professional, our ronment and us? Let’s take a look at some examples

envi-• Civil engineering exposure Safety and health professionals who have had

expo-sure to this field understand the need for safe and sanitary handling, storage, ment, and disposal of wastes They have knowledge of the controls needed for air and water pollution They understand the need for structural integrity of bridges, buildings, and other constructed facilities They understand the planning required to build highways that are safe to use

treat-• Industrial engineering exposure Industrial engineering tries to fit tasks to people,

rather than people to tasks By doing this, they make work methods and ments physically more comfortable and safer Occupational safety and health pro-fessionals need to understand the concepts involved with human factor engineering and ergonomics

environ-• Mechanical engineering exposure The student of occupational safety and health

soon discovers that the mechanical engineering field really got the ball rolling toward incorporating safety requirements for machines such as boilers, pumps, air compressors and elevators, and many other types of mechanized equipment and

facilities The safety engineer must understand the operation and limitations of

mechanized machines and ancillary processes

• Electrical engineering exposure Electrical engineering is concerned with the

design of electrical safety devices such as interlocks and ground-fault interrupters

and other items Electrocution and fire caused by faulty electrical circuitry in the

workplace are more common than you might think The occupational safety and

health professional must be cognizant of these potential hazards and know what

needs to be done to prevent and correct such deficiencies

• Chemical engineering exposure Chemical engineering applies system safety

tech-niques to process design through the design of less hazardous processes, using less

hazardous chemicals, chemicals that produce less waste, or that produce waste that

can be easily reclaimed

• Environmental engineering exposure Like safety engineering, environmental

engineering is a broad-based, interrelated discipline that incorporates the use of

envi-ronmental science, engineering principles and societal values The occupational

safe-ty and health professional must have a good background in environmental science

and environmental engineering practices, primarily because protecting the

environ-ment from pollution is often one of the safety and health practitioner’s chief duties

Preventing major workplace accidents, disasters and illnesses is a primary

responsi-bility of the occupational safety and health professional Major conflagrations,

explo-sions, catastrophic failures of equipment such as boilers or airplanes, and prevention

of chemical releases and spills are just a few of the important responsibilities included

in workplace safety and health practice

Major accidents and disasters are terrible, obviously, to those directly affected

Serious injury, illnesses, or death resulting from such incidents take their toll; they

have impact in ways we cannot imagine until we actually experience them ourselves

The point is with proper, complete, and careful planning, accidents and human-made

disasters can be prevented

The results, consequences, impact, and horror involved when “things go wrong”

(when workplace safety and health management take a back seat to other “more

important” concerns) can kill or maim are all within reach of the site—and what is

within reach of the site is dependent upon the nature of the disaster and the physical

conditions of the site, as well as weather: elements beyond our control

The potential for risks involved with many industrial chemical processing

opera-tions is extreme Bhopal, India, is not alone in the historical records detailing the

horrors of major accidents and disasters (the Chernobyl and Three Mile Island Unit 2

nuclear power incidents are other famous examples) This book’s intent is not to point

the finger of blame at anyone for these incidents, but rather to point out that they do

and did occur More importantly for our concerns, these horrific events trumpet the

need for proper occupational safety and health practices in the workplace What is

hardest to bear in these and all other tragic incidents is that we recognize that they

could have been prevented—and we fear that the same greed, carelessness, and/or

disregard for human life may someday affect us as well

In one respect, the United States has been fortunate Two of the world’s most

terri-ble industrial accidents—accidents that changed how nations handled the very concept

Occupational Safety and Health Practice 5

of industrial safety—had United States counterparts The difference? The accidents

in the United States were on a far less serious scale Only months after OSHA’s Bhopal study on the U.S chemical industry’s chances of producing a similar incident, OSHA reported the possibility of such an event occurring in the United States as very unlikely Yet a similar spill did occur, in Institute, West Virginia, and more than 100 people became ill, but no deaths The result? The chemical manufacturing industry swiftly cleaned up its act Three Mile Island terrified the American public into a more-than-healthy respect for the potential harm a nuclear reactor represents Even with

post-no deaths or injuries from Three Mile Island, in the incident aftermath, post-no aspect of nuclear power operations is treated casually here Moreover, the United States again reassessed its regulatory standards after Chernobyl, using, as they should have, the hard-bought lessons in industrial safety Chernobyl had to teach

Regulatory Influence

Over the years, several changes related to safety and health in the workplace in the United States have come about because of regulations enacted by the U.S Congress (most of which, at their conception at least, were based on the British example)

The impetus for Congressional action in this area was prompted by increased pressure

on legislators (by the public) to force businesses to adopt safety measures, and to vide hazard-free work places The strong influence of governmental authority in regu-lating the safety and health of workers in the workplace cannot be overlooked One of the most important pieces of legislation that directly affected the push for a safer and healthier workplace was the advent of workers’ compensations laws The main inten-tion of the proponents of workers’ compensation legislation was to advance occupa-tional safety programs, which in turn sparked the need for highly trained occupational safety and health professionals to design, implement, and manage them

pro-Occupational Safety and Health Act (OSH Act) of 19701Congress created the Occupational Safety and Health Act (OSH Act) to assure safe and healthful conditions for working men and women by setting and enforcing stan-dards and providing training, outreach, education, and compliance assistance Under the OSH Act, employers are responsible for providing a safe and healthful workplace for their workers

Coupled with the efforts of employers, workers, safety and health professional, unions and advocates, OSHA and its state partners have dramatically improved work-place safety

The OSH Act clearly mandates that employers MUST provide their workers with

a workplace that does not have serious hazards and must follow all OSHA safety and health standards Employers must find and correct safety and health problems OSHA further requires that employers must first try to eliminate or reduce hazards by mak-ing feasible changes in working conditions rather than relying on personal protective equipment (PPE) such as masks, gloves, or earplugs (PPE is always considered the last resort in protecting workers) Switching to safer chemicals, enclosing processes

to trap harmful fumes, or using ventilation systems to clean the air are examples of effective ways to eliminate or reduce risks

Employers MUST also:

• prominently display the official OSHA Job and Safety and Health—“It’s the Law”

poster that describes rights and responsibility under the OSH Act (see Figure 1.1)

• inform workers about chemical hazards through training, labels, alarms,

color-coded systems, chemical information sheets and other methods

• provide safety training to workers in a language and vocabulary they can understand

• keep accurate records of work-related injuries and illnesses

• perform tests in the workplace, such as air sampling, required by some OSHA

standards

• provide required personal protective equipment at no cost to workers.*

• provide hearing exams or other medical tests required by OSHA standards

• post OSHA citations and injury and illness data where workers can see them

• as of January 1, 2015, notify OSHA within 8 hours of a workplace fatality or within

24 hours of any work-related inpatient hospitalization, amputation, or loss of an eye:

(800)321-OSHA (6742)

• not retaliate against workers for using their rights under the law, including their

right to report a work-related injury or illness

*Employers must pay for most types of required personal protective equipment

Employers are not required to pay for the following items:

• non-specialty safety toe protective footwear

• prescription safety eyewear (except when special use lenses must be used inside a

respirator face piece—employers must pay for the lenses–inserts)

• lineman boots

• logging boots that are required under SEC 1910.266 (d)(1)(v)

• everyday clothing such as long pants and long-sleeved shirts

• everyday work boots and work shoes

• dust masks/respirators that are under voluntary use provisions in SEC 1910 134

• back belts

• everyday rainwear

Workers have the right to:

• work in conditions that do not pose a risk of serious harm

• file a confidential complaint with OSHA to have their workplace inspected

• receive information and training about hazards, methods to prevent harm, and the

OSHA standards that apply to their workplace The training must be done in a

lan-guage and vocabulary workers can understand

• receive copies of records of work-related injuries and illnesses that occur in their

workplace

• receive copies of the results from tests and monitoring done to find and measure

hazards in their workplace

• receive copies of their workplace medical records

Occupational Safety and Health Practice 7

Figure 1.1 OSHA Job Safety Health It’s the Law! Poster From www.osha.gov.

• participate in an OSHA inspection and speak in private with the inspector

• file a complaint with OSHA if they have been retaliated against by their employer

as the result of requesting an inspection or using any of their other rights under the

OSH Act

• file a complaint if punished or retaliated against for acting as a “whistleblower”

under the 21 additional federal laws for which OSAH has jurisdiction

OSHA Standards

OSHA’s General Industry standards protect workers from a wide range of serious

hazards Examples of OSHA standards include requirements for employers to:

• provide fall protection

• prevent trenching cave-ins

• prevent exposure to some infectious diseases

• ensure the safety of workers who enter confined spaces

• prevent exposure to harmful chemicals

• put guards on dangerous machines

• provide respirators or other safety equipment

• provide training for certain dangerous jobs in a language and vocabulary workers

can understand

General Duty Clause of the OSH Act

29 U.S.C § 654 Section 5 (a) of Public Law 91–596 of December 29, 1970,

Occupa-tional Safety and Health Act (OSH Act) requires that each employer:

1 shall furnish to each of his employees employment and a place of employment

which are free from recognized hazards that are causing or are likely to cause death

or serious physical harm to his employees;

2 shall comply with occupational safety and health standards promulgated under this

Act

Did You Know?

It sometimes shocks employees to find out that they have obligations in the

work-place also; that is, under 29 U.S.C § 654, 5(b): each employee must comply with

occupational safety and health standards and all rules, regulations, and orders

issued pursuant to the Act which are applicable to his own actions and conduct

Final Note on Standards, Regulations, Laws, and Rules

No matter the number of standards, regulations, laws and rules that are made to

ensure workers’ safety and health and no matter how experienced and/or motivated

the organization’s designated safety and health official is, they are powerless without

Occupational Safety and Health Practice 9strong support from the highest levels of management Simply put, without a strong commitment from upper management, the safety and health effort is doomed On the other hand, when organizational management states that it is the company’s objective

to place “Safety First”—even before productivity and quality—then the proper sphere is present for the safety and health official to accomplish the intended objec-tive That is, the safety and health official will be able to provide a safe and healthy workplace for all employees to work in

atmo-When assigned the duty as the organization’s safety and health official, the first thing to be done is to meet with upper management and determine what the safety objective is The newly appointed safety and health official should not start on the plant’s safety program until he or she is quite certain what is expected of them The pertinent matters that need to be addressed during this initial meeting include devel-

opment of a written safety policy, a safety budget, exactly what authority the safety

official has and to whom does he or she report In addition, the organization’s safety rules and safety committee structure must be formulated as soon as possible

THE ORGANIZATION’S SAFETY POLICY—THE TICKET TO RIDE

The organization’s safety and health official should propose that an organizational safety policy be written and approved by the CEO, General Manager, or other top industry manager A well-written organizational safety policy should be the corner-stone of organization’s safety and health program Moreover, a properly written and disseminated safety policy statement is the safety and health professionals “Ticket to Ride”—to ride to success Why? Simply, if the occupational safety and health profes-sional does not have the support and backing of the organization’s top manager, he or she is wasting their time in trying to put together a program that will ensure the safety and health of all employees After more than 50 years in the safety and health profes-

sion, I can assure you that this is the case; it absolutely is the case!

There are several examples of safety and health policies used by Fortune 500 panies and others to model your organization’s safety and health policy after The key

com-to producing a powerful, tell-it-like-it-is safety policy is com-to keep it short, com-to the point, and germane to the overall goal Many organizational safety and health policies are well written but are too lengthy, too philosophical The major point to remember is that the organization’s safety and health policy should be written not only so that it might be understood by every employee but also so that all employees will actually read it An example of a short, to the point, and hard-hitting safety policy is provided

in Figure 1.2

Workplace Safety and Health Provisions: The Legal Ramifications

Whenever laws or regulations or rules are enacted, soon the legal profession is called

in New regulation means eventual testing of the law, regulation, or rule through the court system—for safety regulation, this meant to provide legal services for workers’

complaints against employers for hazarding their safety and health, and other related on-the-job concerns This, of course, is what has happened, and it had a profound effect

in the workplace In the old days (before OSHA) the employer hired and expected his

employee to work long, hard hours without getting injured (see Case Study 1.1) If the

employee was injured, the employer simply showed him the door and that was that

Thankfully, times have changed Thus the goal of most employers quickly became

to prevent such legal actions—because they are costly both in money and time The

primary way in which employers avoid expensive litigation is by ensuring compliance

with applicable workplace safety and health laws and regulations They most often

accomplish this by assigning the responsibility for ensuring workers’ safety and health

on the job to a designated occupational safety and health official; often this designated

safety official is a fully qualified occupational safety and health professional

Case Study 1.1: A Stitch in Time

The working conditions of the seamstress in nineteenth-century England received a

great deal of concern and attention in the media of the day, but actual reform came

very slowly Victorian women had little choice of career—nanny or governess

posi-tions, shop posiposi-tions, servant occupaposi-tions, certain kinds of factory work, and

dress-making were often the only legitimate jobs a woman might be qualified (or allowed)

to do Of these, dressmaking was frequently the only choice possible, because while

educational effort was seldom spent on girls until mandatory educational requirements

went into effect around the turn of the century, virtually every girl learned how to

sew and do fancy needlework Without a father, brother, or husband to protect or

sup-port her, a woman with limited education and means might be forced into a difficult

choice—servant work, dressmaking, or prostitution

NO JOB IS SO CRITICAL AND NO SERVICE

IS SO URGENT—THAT WE CANNOT TAKE THE TIME TO PERFORM OUR

WORK SAFELY

While it is true that the major emphasis is on efficient operations, it is also true

that this must be accomplished with a minimum of accidents and losses I

can-not overemphasize the importance that the organization places on the safety and

health and well-being of each and every employee The organization’s

commit-ment to occupational safety and health is absolute The organization’s safety and

health goal is to integrate hazard control into all operations, including compliance

with applicable standards I encourage active leadership, direct participation, and

enthusiastic support of the entire organization in supporting our safety and health

programs and policies

CEO/COO/General Manager

Figure 1.2 Sample Organizational Safety Policy

Occupational Safety and Health Practice 11Because these women all could sew, the potential labor force was huge In London,

in 1851, there were between 15,000 and 20,000 seamstresses working Since tion for jobs was steep, and because people wanted to buy their goods as cheaply as possible, wages were often inadequate—too small to live on Working conditions were generally dreadful (only the first-rate houses cared to treat their employees well—they hired top quality workers and expected to keep them), and by the nature of the profes-sion, many women gained little more than life-long ill health from their labor

competi-Comfortable hand sewing requires only a few necessities: good lighting and tilation, comfortable straight furniture, and frequent chances for movement But nineteenth-century custom houses frequently ignored these considerations The cus-tom houses fed, housed, and worked their apprenticed help as they pleased, in condi-tions that ranged from reasonable in first-class establishments, to places with living quarters where the women slept five to a bed At the height of the social season, when the houses were at their busiest, women would commonly work 18–20-hour days for weeks on end, to finish overbooked orders To finish special projects, they might work around the clock and into the next day With bad light, stuffy quarters, no chance for exercise, and little food, the health of these women was affected

ven-High fashion also created seamstress problems When the sewing machine came into general use in the mid-1860’s, a logical expectation might be that more could be accomplished faster—but as soon as the sewing machine came into use, it was used

to create clothing with more fine detail—if not handwork, then decoration: pleats, ruffles, lace, braid, and trimmings—as a display of caste and wealth Production time actually went up

Their work caused many of the health problems prevalent within the group Lack of fresh air (the gaslights used for illumination consumed as much of the available air as five adults—for each light), no exercise, the bent-over posture, as well as breathing lint and fiber particles caused many women to develop respiratory problems, sometimes compounded by organic poisoning from inhaled toxins Tuberculosis was quite com-mon, and internal distresses caused by bad posture, tight corseting, and bad food gradu-ally worsened the workers’ health Blindness, headaches, nervous exhaustion, anemia,

faintness, and chronic fatigue were other side effects In The Ghost in the Looking Glass, author Christina Walkley quotes nineteenth-century medical experts, who agree

that “no life style was better calculated to destroy health and induce early death” (p 32)

The upbringing that most Victorian women shared also created part of their lems Brought up to depend on men, these women were terribly unsophisticated when dealing for money and for their rights They had no organized lobby behind them

prob-They really didn’t know how to complain—or have anyone effective to complain to

Factories employed larger numbers of people, and had a formal internal structure, with a recognizable chain of command Custom houses were generally run by a single owner with only a few employees on site Many seamstresses relied on piecework employment, and often the only way to find piecework would involve a middleman, who could easily skim his portion of already meager wages Since often this was a woman’s only possible source of income, and the job market was full, she had little recourse She could work at the wages offered—or starve Often a slave would have been physically better off, because a slave was valuable property The seamstress was

an expendable worker

Over and over again, the journal Punch brought the seamstress’s plight to

Eng-land’s attention In 1843, Punch published Thomas Hood’s “Song of the Shirt” (a

poem which inspired much pity), but little toward reform could be accomplished

Between the private homes that housed the custom houses, the amount of

untrace-able piecework farmed out to individuals, and the fear of job loss for those who were

working, concrete proof significant enough to pass legislation was difficult to obtain

Conditions did not become easier until long after the turn of the century, when World

War I changed clothing styles radically enough to allow factory-made clothing to

become the norm By 1918, the Trade Boards Acts established hour and wage

regu-lations But even today, immigrant workers in the United States suffer many of the

same sweatshop conditions as those Victorian seamstresses, with as little recourse

Sweatshop factories exist in most third world countries, often using children to

pro-duce fashionable clothing inexpensively for companies in industrialized nations Nike,

a popular clothing line associated with Kathy Lee Gifford at WalMart, and others have

been tied to sweatshops and third world children’s labor, and stories about the plight

of deaf Mexican immigrants in U.S sweatshops have all made national news

***

After laying the above foundational information for this book, now it is time to get

down to the bricks and mortar that make up a viable occupational safety and health

program I begin with a discussion of accident prevention signs and tags and labels,

and, more specifically, with signal words

EMPLOYEE TRAINING

Throughout this book, I stress again and again the importance of employee safety

and health training This emphasis is for good reason For it is without a doubt that

providing routine safety and health training for workers is probably one of the most

important job duties the occupational safety and health official has in the industrial

(or any other) workplace Indeed, most managers know the importance of safety and

health training, but it is not well known that specific training requirements are detailed

in OSHA, DOT, and EPA regulations Under OSHA regulations, for example, it is

stated or implied that the responsibility of the employer is to provide training and

knowledge to the worker Moreover, employees are to be apprised of all hazards to

which they are exposed, relevant symptoms and appropriate emergency treatment, and

proper conditions and precautions of safe use or exposure

Throughout this book I feature several different OSHA safety and health standards

or programs Employers must comply with these standards and must also require

workers to comply More than 100 OSHA, DOT, and EPA safety and health

regula-tions contain training requirements

It is interesting to note that although OSHA requires training, it does not always

specify exactly what is required of the employer or entity which provides the training

However, information and instruction on safety and health issues in the workplace are

foundational to building a viable organizational safety and health program Workers

Occupational Safety and Health Practice 13cannot be expected to perform their assigned tasks safely unless they are aware of the hazards or the potential hazards involved with each job assignment

For years safety and health professionals have spoken about the “three E’s” of

occupation safety and health management: Engineering, Enforcement, and

Educa-tion While it is true that the best solution to control any hazard is to engineer out the problem, and while it also true that enforcement is critical to maintaining execution

of proper safe work practices, it is also true that the safety education aspect is equally important

Education in the form of providing information and training is one of the most vital elements in safety simply because a worker cannot be expected to comply with safe work practices unless they have been informed of and trained on the proper procedures

Experts in the occupational safety and health field have differing points of view on this topic One element points out that safety is not a behavioral issue, instead, it is technical—meaning that safety can be accomplished by engineering out the hazard

It should be remembered, however, that if there is a possibility for something to go wrong, workers will find the way to make it happen Even workplaces that have state-of-the-art engineering safety devices and strong enforcement programs do not always have effective hazard control programs unless the workers and supervisors understand the hazards and the potential for hazards that arise from not observing routine safe work practices A worker’s work routine and attitude cannot be engineered—workers are not robots

Worker safety and health training should begin right after the employee is hired

New Employee Safety and Health Orientation Training programs can be effective

if correctly structured and presented early in the worker’s tenure Simply, New Employee Safety and Health Training gets the new worker off to the right start This training should be tailored to satisfy several OSHA requirements For example, OSHA requires that workers be trained on the Hazard Communication Standard prior to their beginning work with or around hazardous materials

Before sending new employees to safety and health orientation training it must

be determined who needs what training Two approaches are typically used in ing this determination First, the industrial occupational safety and health official in conjunction with the personnel manager, work center supervisors, and safety council should determines specific safety and health training for each job classification This can be accomplished by conducting a “needs assessment” (sometimes called “needs analysis”) The idea behind the needs assessment is to ensure that job classifications requiring confined space training, for example, receive this critical training At the same time, the needs assessment also functions to ensure that the plant clerk who needs hazard communication training but who does not enter confined spaces, for example, does not receive confined space training Second, an industrial organization can simply choose to send all new employees to all the training presented during New Employee Safety and Health training Based on experience, this second approach might be the best method The thinking seems to be that when it comes to an employ-ee’s safety and health in the workplace, employees can’t be over trained

mak-Depending upon the organization’s turnover rate, the frequency of conducting New Employee Safety and Health Orientation Training can vary from presenting a session

In addition to providing New Employee Safety and Health Orientation Training

presented to all new employees, another technique for verifying new employee safety

and health knowledge is a system known as Personnel Qualification Standard

(PQS) for plant safety and health and industrial operations PQS is a term that comes

from the United States Navy The Navy has been using PQS to qualify its

person-nel for several years Like the Navy’s PQS program, industrial operation’s PQS has

proven to be an excellent training instrument Not only does it provide a guide of what

is to be learned, it also provides documentation to show that the training was actually

completed Additionally, this industrial PQS system is suitable for any and all

indus-trial applications and for just about any other workplace application

When attempting to implement a PQS program at your organization, keep in mind

that there are several requirements that must be completed prior to the new employee

being fully PQS qualified for his or her assigned position These qualifications should

also include a tour of all worksite facilities including knowing the names of all

build-ings, process unit machinery, and chemical storage locations In addition to naming

various components within the industrial plant site, the worker must show where all

first-aid kits, fire extinguishers, fire hoses and standpipes, emergency equipment

stor-age lockers, Hazard Communication Right-To-Know Stations, and emergency

evacu-ation routes are located After completing PQS training, the employer must ensure that

the employee signs some company document acknowledging the training they have

received It is important to include in this acknowledgment form that the employee

fully understood this training (see Figure 1.3) This simple but crucial document can

save employers and managers a lot of drama, pain, fines, possible imprisonment, and,

at the very least, embarrassment in a court of law and from OSHA

The benefits of using safety and health training PQS or some other training system

or technique for new workers cannot be overemphasized Consider the new employee

hired to operate a piece of heavy road building equipment, for example The hiring

authority should ensure that the equipment operator hired is qualified to operate the

equipment in a responsible and safe manner PQS is a viable way of ensuring the

viability of the potential new employee’s operating ability and skill sets Again, by

utilizing PQS or some other similar safety and health indoctrination process, the

supervisors are ensured of training their personnel and creating an accurate record of

the initial operations and safety and health training Experience has shown that this

PQS system is dynamic, constantly changing, and constantly improving

Safety begins with awareness Awareness is gained through training and

expe-rience Whichever type of safety training that is decided upon, it is important to

each week, every other week, once a month, or as required, depending upon the

his-torical hiring pattern

It is critical to keep and maintain and update records of any and all employee safety

and health training When OSHA arrives to audit a facility, one of the first items

they want to see is proof of employee safety and health training In OSHA and a

court of law’s view, if you do not have a record of training, then you did not

con-duct the training You MUST keep and maintain accurate training records

Occupational Safety and Health Practice 15

remember to assess the program’s effectiveness Workers who attend safety training should be asked their opinions of the training I have found that worker input is impor-tant Through the use of questionnaires, for example, it can be determined whether the approach being used is relevant and appropriate Supervisors are another good source

of information They are in a good position to determine if the safety training is ing off Improvements should also be noticeable in the workplace Reduced numbers

pay-of injuries on-the-job along with improved product quality and worker productivity are excellent indicators of the effectiveness of the plant’s safety training program

Finally, as stated previously, proper safety training can be accomplished but if it is not documented—the training was never done

CONTRACTOR TRAINING

Outside contractors hired by any industrial operation are in the business to make money; that is, to make a profit (aren’t we all?) The problem is that in order to make

Did You Know?

Along with certifying an employee’s training and operational proficiency by ing the newly trained employee sign some type of acknowledgment of training and understanding form, it may be advisable to video new employees’ actual training and their demonstration of proficiency I have found that video evidence of actual training and or demonstration of operator proficiency has saved on legal ramifica-tions that might develop in the future

hav-Figure 1.3 Acknowledgment of Training and Understanding Statement

a profit a contractor might have to cut corners, many corners Unfortunately, when

this happens, usually it is the safety and health provisions and programs designed to

protect the workers that is cut No one ever said that providing a viable safety and

health program to and for employees is cheap Cheap it is not Critical it is The

prob-lem is that the safety and health of employees is often viewed as nice to have and nice

to acknowledge but in terms of the bottom line, the safety and health of employees

does not contribute to it This is, unfortunately and based on personal experience, the

convoluted and sadly incorrect thinking or attitude of many employers, and especially

many contractors I have spent a lifetime on the lecture circuit and in many of the

pages on safety and health that I have had published trying to explain to employers

that safety is not cheap, but at the same time asking how much is a human life or

disability worth? In this day of “let me sue you before you sue me,” this question is

germane

Part of the problem with such a sour attitude toward safety and with compliance

with OSHA regulations stems from the diverse nature of the construction industry

itself Some construction entities are nothing more than fly-by-night, skeleton crew

operations, whose only goal is to procure a contract to construct projects in the least

amount of time, at the lowest possible cost, and with the largest possible profit margin

Obviously, such entities are often more concerned with the bottom line (making a

return on their work) than with complying with anybody (other than mandated

build-ing codes, that is) Cuttbuild-ing corners to cut costs is the mantra by which such entities

operate Safety? For such operations, safety is a burden—and one the operation

man-agement may not find is the “right” thing to do Only when OSHA (or other regulatory

agencies) cites such entities does such a company’s attention focus on compliance

with regulations Otherwise, “get the job done as quickly and cheaply as possible” is

the only important mandate to many of them

There are other contractor industry problems associated with compliance with

OSHA For example, many construction outfits hire subcontractors to complete parts

of the work Many of these subcontractors look at safety compliance as an additional,

unnecessary, costly burden Many of them do not have safety programs and do not

comply with safety regulations

Hiring practices cause another common problem in contractor noncompliance with

safety regulations This is the age of hiring “temporary” employees because of the

Affordable Care Act (Obamacare) and other cost-saving reasons Of course, this

prac-tice presents some obvious advantages In the first place, temporary employees are

normally cheaper to hire—the employer doesn’t have to make any long-term financial

commitments to such employees Moreover, they usually do not have to be paid costly

benefits Secondly, temporary workers are “temporary”—short-term employees who

might be hired to work one shift, one day, one week, one hour, and so on The

contrac-tor employer might feel that to provide such temporary workers with the training that

OSHA requires is a waste of time and money—especially since, by the time OSHA

might show up for inspection, the temporary employee will be long gone Out of sight

and definitely out of the former employer’s mind

As sad as it might be, some companies involved as contractors take a dim view,

not only of OSHA, but also with any compliance effort that costs them time and

money—worker safety and well-being are not a consideration This is not the case

Occupational Safety and Health Practice 17with every company involved in construction, of course We have also witnessed and worked with construction companies who take worker safety and compliance with OSHA very seriously—to the point that any infraction of safety rules by any worker

is cause for immediate dismissal Obviously, in this type of company (whether it be general industry or construction), occupational safety and health professionals will be able to do their best work

The Host-Contractor Safety Interface

Whether a contractor is working in a facility or as a subcontractor to a prime tractor on a job site, the host facility must ensure that the contractor and his or her employees follow the safety rules and procedures established for the facility or job site and all applicable regulatory requirements

con-The process begins when a prospective bid winner has been identified Before awarding the contract, though, check out the prospective contractor’s safety record

Make contact with the contractor’s references—with those he or she has done work for in the past Ask these former customers questions that will provide information (and insight) into the contractor’s safety and health record

Along with checking the prospective contractor’s safety record on previous jobs, review the contractor’s safety and health program This includes reviewing OSHA-200/300 logs for at least the past five years From these logs you can easily determine the contractor’s on-the-job injury incidence rate—and also determine the frequency and severity of these injuries If you ask to see the contractor’s OSHA-200/300 logs and the contractor replies, “What’s that?” or states, “We don’t keep one,” your research

is ended You have found out what you need to find out about that contractor—that is, that the prospective contractor has no safety program and is definitely not in compli-ance with OSHA If this is the case, obviously, you should eliminate this contractor from further consideration for the awarding of any contract

If you get beyond the OSHA Log (I find that often the OSHA Log is a stopping point; contractors who keep proper logs tend to maintain safety programs properly as well), you should review the contractor’s written safety program (a safety program must be in writing) If the program checks out—is up to regulatory standards and your expectations—ask to see the contractor’s safety training program, including attendance records for the training Remember, from OSHA’s point of view, all train-ing conducted without proper records of the training was not conducted—never, ever

This certainly is the view the regulators will take, and it is the view you should take

If a prospective contractor gets by your initial screening process, the next step involves the contract itself Always remember that contractors work according to con-tract specifications For example, if a contract stipulates that the walls of a particular building are to be painted a particular shade of purple (even if you tell the contractor what you really wanted were walls painted green), then purple-painted walls will be the likely result Contract specifications for just about any project must be carefully written and in considerable detail Remember that you are likely to get what your contract specifies, so make sure that contract language is clear, concise, and exact

This same practice applies to contract specifications related to safety compliance

The best advice we can give in this regard is to seek the assistance and advice of legal

counsel In the contracts that we have and do let for outside contractor work, our

stan-dard contract form includes a statement written by lawyers that states (paraphrased):

The host facility strongly supports and complies with OSHA and other applicable

regula-tory bodies in ensuring the safety, health, and well-being of its employees Contractors

working on host property or projects are expected to fully comply with host safety

regula-tions and all applicable regularegula-tions Failure to comply with host and applicable regulatory

safety and health requirements is grounds for immediate stoppage of all contractor work

and termination of this contract

Has this contract stipulation been effective? Has it actually been applied? Has it been

tested in a court of law?

A resounding “yes” to all these questions

In the past fifty years, I have had occasion to stop work and terminate contracts with

eleven different outside contractors for gross violations of host facility and OSHA

safety regulations The most recent case involved a contractor hired to recondition

three 5,000-gallon chemical storage tanks

Case Study 1.22

The contractor signed a contract with the above safety stipulations; that is, abide by

OSHA and site safety and health rules or the contract is terminated The contractor

was also informed of the chemical contents of the tanks: sodium hydroxide (caustic)

at a concentration of 50 percent Sodium hydroxide in such a concentration is highly

corrosive and dangerous to the safety and health of workers The large chemical tanks

were designated as Entry-by-Permit-Only Confined Spaces After the tanks were

emp-tied of their chemical contents, any entry by contract workers (or anyone else) could

only be effected by following the guidelines stipulated by OSHA’s Confined Space

Entry Standard, which are strictly enforced by the host facility

After being on the job for about a week and after the caustic tanks had been emptied of

their contents, the contractor ignored the confined space guidelines and directed workers

to enter the tanks to clean their interiors and to remove all residual chemical Not only

did the contractor violate his contract obligations by ignoring the stipulations about

abid-ing by the facility’s safety regulations, he risked the health of his employees by havabid-ing

them work improperly inside a confined space with very corrosive chemical residue The

workers were not equipped with respiratory protection or any other personal protective

equipment that would have afforded them some level of protection from the chemical

When we discovered that the contractor had violated its contract obligations and

was placing workers in harm’s way, we stopped the work and ordered the contractor

to leave our worksite After some haggling and a police escort from our property, we

later received notice from the contractor’s attorney that this matter would be litigated

in a court of law It was We won

***

After a contract has been awarded, the next move the host occupational safety and

health professional should take is to conduct a special “briefing” session (or sessions)

Occupational Safety and Health Practice 19for the contractor personnel where the safety rules are reviewed in detail The pro-cedure we recommend is somewhat different from what most safety texts (and even some regulations) advise or recommend Reading recommendations stating that spe-cial “training” sessions for the contractor personnel should be conducted is common

However, we recommend against this practice Providing a “briefing” session and providing “training” are two entirely different matters The problem lies in the mean-ing of the two words A briefing is simply a session designed to pass on information

A training session, on the other hand, connotes quite a different meaning, and possibly quite a different responsibility—and liability

Again, based on years of experience and expert witness testimony in various courts of law, the point being made here is quite simple, but not often considered:

When you train somebody (anybody), you conceivably buy into their later actions

For example, if you provide safety training to workers on how to properly and safely operate a bulldozer, then later, an employee you trained operates a bulldozer and runs it into someone’s personal property and destroys it, who is responsible? The driver of the bulldozer—or the person (or company) who trained the driver—or both? In some cases, both parties might be held responsible and liable Avoid this situation With contractor personnel, you must absolutely avoid it “Brief” contrac-tor personnel, do not “train” them—do not buy into their subsequent actions Again, this particular point is controversial Many OSHA regulations now stipulate that when a host hires an outside contractor to do work for the host, the host is respon-sible to “train” these employees on special processes, hazards, hazardous materials, and safe work practices that are normal conditions or requirements at the host’s site

Again, I recommend against this practice, and have ourselves explained to OSHA auditors that it is not our policy to train outside parties on host premises on host conditions Instead, we brief all outside personnel on the hazards and so forth We have had OSHA auditors argue this point with us, and have simply referred them to our legal counsel—where the problems were resolved without incident—and with little pain

Also remember that the contractor briefing process is not simply talking to the tractor and giving the contractor copies of safety rules This is not the proper briefing procedure to use Instead, the briefing should be an organized, formally presented

con-“briefing”—which includes requiring all attendees to sign an attendance and edgment of briefing form (see Figure 1.4) Remember, as with any training session, if you have no record that a contractor briefing was actually conducted, then according

acknowl-to OSHA, it wasn’t

In addition to conducting the contractor safety briefing and ensuring that all those who attended such sessions have signed a form such as the one shown in Figure 1.4, make provisions to ensure that two other important contractor requirements are met

First, the host should ensure that the contractor has some type of procedure to tee that any new hires during the contract work period are also fully trained and made aware of the host’s safety requirements This is important, especially today, when contractors often hire temporary workers, many of whom will work only long enough

guaran-to gain a paycheck, then leave employment We have hired contracguaran-tors guaran-to complete various projects and have witnessed, from start to end of the contract work, a complete turnover of personnel

The second provision that the host and contractor must come to agreement on is

periodic safety inspections of contract work—to be conducted by the host This is a

touchy area Again, we know of few contractors who readily accept the host looking

over their shoulders while contract work is underway To alleviate any friction this

procedure will cause (and it can and will cause friction), we recommend that the host

and contractor iron out a consensual procedure whereby both the host and the

con-tractor participate jointly in any inspection effort Any findings that point to unsafe

conditions and practices should be handled directly between the host safety engineer

and the contractor’s safety representative Why? Consider what kind of friction can

be generated when an enthusiastic host safety and health person goes out on a

con-tractor project in “witch-hunt mode” and finds various discrepancies, then takes these

findings right to the top contractor management—bypassing the contractor front-line

supervisor Obviously, I do not recommend this practice The key is to work with

contractors, not to antagonize them

One final point Situations may arise when host employees notice contractor

opera-tions in progress that put contract workers, host employees, or both in eminent danger

You must develop a policy, an understanding, with the contractor that in such cases,

the host safety official (or any other host official) has the right and the obligation to

stop the operation or operations involved immediately, until such time as the unsafe

condition has been corrected

Sample Outside Contractor Safety Briefing Date:

In accordance with the recordkeeping and “briefing” requirements under

vari-ous OSHA regulations and in particular 29 CFR 1910.119 (Process Safety

Man-agement Standard—PSM), I have received a safety briefing (in no way should

this briefing be construed by anyone as taking the place of required

contractor-conducted employee safety training) from host safety division personnel

cover-ing Hazard Communication, Lockout/Tagout, Confined Space Entry, Hot Work

Permitting Procedures, Personal Protective Equipment, and safety rules and

standard operating procedures used by the host facility I further understand

that the host expects outside contractors, including subcontractors, suppliers,

agents and employees of such, to perform construction activities under

OSHA-required guidelines and host procedures It is understood that all information

regarding the hazards, safety procedures, lockout/tagout procedures, hot work

permit procedures and systems operations shall be disseminated to all persons,

subcontractors and agents employed either directly or indirectly by us I agree

to submit documentation as requested by the host to verify that my employees,

subcontractors and any other parties working directly or indirectly for me are

conveyed the safety and health information required

Signature: Printed Name Company

Figure 1.4 Sample Outside Contractor Safety Briefing Roster

Occupational Safety and Health Practice 21

THE BOTTOM LINE ON OCCUPATIONAL SAFETY AND HEALTH IN INDUSTRY

For the new occupational safety and health practitioner who contemplates filling a safety and health professional’s position in any type of industry, we say check out the company first before committing to employment You should ask several questions, including:

• Where does safety stand in the organization?

• Do I have top management support in implementing a company safety program that will cost money and time?

• Will I have the authority I need to stop work that could severely injure or kill workers?

• Will you support my effort to bring this company into full compliance with OSHA and other regulators?

• If I discover unsafe work practices that are promoted and supported by work center supervisors, will I have your support to correct such situations?

With careful thought about your own concerns for worker’s safety and health mine other questions you could (should) ask your prospective employer To sum up this discussion, I simply point out that filling the position of company’s occupational safety and health professional is never an easy undertaking However, one thing is absolutely certain: if you take a position in a company with little or no support for safety and health compliance with applicable safety and health regulations, you put your head into the proverbial lion’s mouth—and the lion’s untamed and has a voracious appetite

deter-SIGNAL WORDS

Signal words, DANGER, WARNING, and CAUTION, along with signs, labels and

other markings are commonly used (and/or mandated) to warn personnel of a certain amount of risk associated with a work practice that cannot be controlled through engi-neering or administrative controls, personal protective equipment, or training Cover-age of these terms and their meaning and importance is provided in this introductory first chapter because when concerned with workers safety and health, a warning of some type or method is required to alert workers to the dangers or risk present We list them here first even though these signs, labels and other markings are often considered the last defensive measure employers can take to protect employees It is very impor-tant that occupational safety and health professionals know when and how to use these markings and which ones are required by the regulations

The Globally Harmonized System (GHS) (to be discussed in detail later) fies certain elements that should appear together on chemical labels Like the current pesticide labeling system, hazard statements, symbols (pictograms), and signal words required on pesticide labels depend on the toxicity or hazards of the product, while precaution statements, product identifiers and supplier information are required on all labels The GHS includes two signal words:

speci-• “Warning” for less severe hazard categories

• “Danger” for more severe hazard categories

Lower categories of classified and unclassified products would not require pictograms

or sign words under GHS The current EPA system includes a third signal word

“Cau-tion” which is used in addition to “Warning” and “Danger.”

Many OSHA regulations call for the use of English markings However,

increas-ingly, workplaces employ more and more employees who speak only foreign

lan-guages Employers and government agencies are beginning to realize that there is a

language barrier that accounts for great rates of injury and illness for those who do

not understand English Thus, when a worker (whether functionally illiterate or

non-English-speaking/reading) does not understand printed hazard warning labels because

of language issues, employers have a duty to take some action(s) to alleviate this

prob-lem I address this issue further in Chapter 2 and throughout this book where pertinent

NOTES

1 Information from All about OSHA (2014) Occupational Safety and Health

Administra-tion U.S Department of Labor, Washington, DC Accessed 1.5/2015 @ www.osha.gov

2 From F R Spellman and N E Whiting (2005) Safety Engineering: Principles and

Prac-tices, 2nd ed Lanham, MD: Government Institutes

REFERENCES AND RECOMMENDED READING

Allison, W W “Other Voices: Are We Doing Enough?” Professional Safety (February 1991):

31–32

Banks, W W and Cerven, F “Predictor Displays: The Application of Human Engineering

Process Control Systems.” Hazard Prevention (January/February 1985): 26–32.

Benner, L., Jr “Safety Training Achilles’ Heel.” Hazard Prevention 1 (1990): 6112.

CoVan, J Safety Engineering New York: John Wiley and Sons, Inc., 1995.

Fawcett, H K and Wood, W S., eds Safety and Accident Prevention in Chemical Operations

New York: John Wiley and Sons, Inc., 1982

Friend, M A and Kohn, J P Fundamentals of Occupational Safety and Health 6th ed

Lan-ham, MD: Bernan Press, 2014

Grimaldi, J V and Simonds, R H Safety Management 5th ed Homewood, IL: Irwin, 1994.

Hoover, R L., Hancock, R L., Hylton, K L., Dickerson, O B., and Harris, G E Health,

Safety, and Environmental Control New York: Van Nostrand Reinhold, 1989

Keller’s Official OSHA Construction Safety Handbook 5th ed Neenah, WI: J J Keller and

Associates, Inc., 2005

Mansdorf, S Z Complete Manual of Industrial Safety Englewood Cliffs, NJ: Prentice-Hall,

Inc., 1993

McCormick, E J., ed Human Factors Engineering 3rd ed New York: McGraw-Hill, 1970.

OHSA (2014) OSHA Fatality/Catastrophe Investigations Accessed 01/05/2015 @ http://

www.osha.gov/FatCat/fatcat.html

Peyton, R X and Rubin, T C Construction Safety Practices and Principles New York: Van

Nostrand Reinhold, 1991

Occupational Safety and Health Practice 23

Spellman, F R Safe Work Practices for Wastewater Treatment Plants Lancaster, PA:

Technomic Publishing Company, 1996

——— A Guide to Compliance for Process Safety Management/Risk Management Planning

Lancaster, PA: Technomic Publishing Company, 1997

——— Surviving an OSHA Audit Lancaster, PA: Technomic Publishing Company, 1998.

Spellman, F R and Bieber, R M Chemical Infrastructure Protection and Homeland Security

Lanham, MD: Government Institutes, 2009

U.S Department of State (2002) “September 11, 2001: Basic Facts.” Washington, DC: U.S

Department of State Archive (online) http://2001–2009.state.gov/coalition/cr/fs/12701.htm

Chapter 2

Safety and Health Terminology

and Hispanic Outreach

Fatality Incident (08/22/89): A severe localized thunderstorm had occurred and lines

were down A lineman, using rubber gloved hands, was removing grounds while in

an elevated bucket The grounds were put into primaries from the secondary neutral, and upon removing ends from the primaries, the employees put one of the two ends in the bucket While he was repositioning to remove the other ends from the neutral, his upper part of body (ear) came in contact with a primary line (5KV) His right thigh was touching the free end of the grounds which were still attached to the secondary neutral The lineman slumped in the bucket following a flash The aerial bucket was lowered and CPR was given He was dead on arrival at the hospital

OSHA Standards Cited Related to the Incident:

• 1926.26(b)(2)—the employees engaged in repairing electrical power lines were not

adequately instructed and trained in the recognition of the condition, system and/or consequences of not opening all circuits

• 1926.950(C)(2)(i)—the employees engaged repairing electrical power lines, did

not maintain the minimum safe working distance at all times while preparing repair work from the ground and/or removing wires from the elevated buckets

• 1926.950(d)(1)(ii)(a)—it was not assured by maintaining proper communications,

visual inspection, or by test that the No 3 cutout/use through which supplied the electrical power to the work area had been de-energized

• 1926.954(d)—de-energized line(s) and equipment which would be grounded were

not tested for voltage

• 1926.955(a)(6)—the aerial lift bucket was not grounded or bonded to a nearby

ground where/while and/or employee was performing repair from the ground

• 1926.950(c)(1)—the employee engaged in repairing electrical power lines brought

ends of ground wires into bucket of aerial lift truck before completely disconnecting the other ends from the ground line

“He who speaks and writes in two languages, has a wide knowledge of his own [language].”

Johann Wolfgang Goethe

SAFETY AND HEALTH TERMINOLOGY

Every branch of science, every profession, and every engineering process has its own

language for communication Occupational safety and health is no different To work

even at the edge of occupational safety and health, you must acquire a fundamental

vocabulary of the components that make up the process of administering safety and

health programs Administering occupational safety and health? Absolutely

Remem-ber the safety and health professional is—and must be—a practitioner of safety and

health—a specialized field

In this chapter, I define the terms or “tools” (concepts and ideas) used by

occu-pational safety and health professionals in applying their skills to make industrial

occupations safer We present these concepts early in the book rather than later (as is

traditionally done in an end-of-book glossary), so you can become familiar with the

terms early, before the text approaches the issues the terms describe The practicing

safety and health professional should know these concepts—without them it is

dif-ficult (if not impossible) to practice safety and health in the workplace Several other

chapters contain vocabulary specific to those more specialized fields

Occupational safety and health has extensive and unique terminology, most with

well-defined meanings, but a few terms—especially safety, accident, injuries, and

engineering (as used in the safety context)—often are not only poorly defined, but

are defined from different and conflicting points of view For our purpose, we present

the definitions of key terms, highlighting and explaining those poorly defined terms

(showing different views from different sides) where necessary

I do not define every safety and health term—only those terms and concepts

neces-sary to understand the technical jargon presented in this text

Defining Accident

Before I define some safety and health terms, I want to focus first on the term

acci-dent, the word/event everyone hopes to avoid This term is often misunderstood and

is often mistakenly used interchangeably with injury The meanings of the two terms

are different, of course Let’s look at the confusion caused by the different definitions

supplied to the term accident The dictionary defines an accident as “a happening or

event that is not expected, foreseen, or intended.” Defined another way: “an accident

is an event or condition occurring by chance or arising from an unknown or remote

cause.” The legal definition is: “an unexpected happening causing loss or injury which

is not due to any fault or misconduct on the part of the person injured, yet entitles

some kind of legal relief.”

Are you confused? Stand by This definition will help clear your heads

With rare exception, an accident is defined, explicitly or implicitly, by the unexpected

occurrence of physical or chemical change to an animate or inanimate structure It is

important to note that the term covers only damage of certain types Thus, if a person is

injured by inadvertently ingesting poison, an accident is said to have taken place; but if

the same individual is injured by inadvertently ingesting poliovirus, the result is but rarely

considered accidental This illustrates a curious inconsistency in the approach to accidents

Safety and Health Terminology and Hispanic Outreach 27

as opposed to other sources of morbidity, one, which continues to delay progress in the field In addition, although accidents are defined by the unexpected occurrence of damage,

it is the unexpectedness, rather than the production and prevention of that damage per se, that has been emphasized by much of accident research The approach is not justified by present knowledge and is in sharp contrast to the approach to the causation and prevention

of other forms of damage, such as those produced by infectious organisms, where little, if any, attention is paid to the unexpectedness of the insults involved, and only their physical and biological nature is emphasized—with notable success

or from some inadequacy in an existing system of hazard controls Based on applications

in casualty insurance, an event that is definite in point of time and place but unexpected

as to either its occurrence or its results

In this book I use the ASSE’s definition of accident

Terminology abatement period: The amount of time given an employer to correct a hazardous

condition that has been cited

absorption: The taking up of one substance by another, such as a liquid by a solid or

a gas by a liquid

accident analysis (see accident investigation): A comprehensive, detailed review

of the data and information compiled from an accident investigation An accident analysis should be used to determine causal factors only, and not to point the fin-ger of blame at any one Once the causal factors have been determined, corrective measures should be prescribed to prevent recurrence

accident prevention: The act of averting a circumstance that could cause loss or

injury to a person

accommodation: The ability of the eye to quickly and easily readjust to other focal

points after viewing a Visual Display Terminal so as to be able to focus on other objects, particularly objects at a distance

acoustics: In general, the experimental and theoretical science of sound and its

trans-mission; in particular, that branch of the science that has to do with the phenomena

of sound in a particular space such as a room or theater Safety engineering is cerned with the technical control of sound, and involves architecture and construc-tion, studying control of vibration, soundproofing, and the elimination of noise—to engineer out the noise hazard

con-action level: Term used by OSHA and NIOSH (National Institute for Occupational

Safety and Health—a federal agency that conducts research on safety and health

concerns) and defined in the Code of Federal Regulations (CFR), Title 40,

Pro-tection of Environment Under OSHA, “action level” is the level of toxicant that

requires medical surveillance, usually 50% of the PEL (Personal Exposure Level)

Note that OSHA also uses the action level in other ways besides setting the level

of “toxicant.” For example, in its hearing conservation standard, 29 CFR 1910.95,

OSHA defines the action level as an eight-hour time-weighted average (TWA) of

85 decibels measured on the A-scale, slow response, or equivalently, a dose of

50% (see Chapter 11 for more information on hearing conservation) Under CFR

40 § 763.121, action level means an airborne concentration of asbestos of 0.1

fiber per cubic centimeter (f/cc) of air calculated as an eight-hour time-weighted

average

acute: Health effects that show up a short length of time after exposure An acute

exposure runs a comparatively short course and its effects are easier to reverse than

those of a chronic exposure

acute toxicity: The discernible adverse effects induced by an organism with a short

period of time (days) of exposure to an agent

adsorption: The taking up of a gas or liquid at the surface of another substance,

usu-ally a solid (e.g., activated charcoal adsorbs gases)

aerosols: Liquid or solid particles that are so small and can remain suspended in air

long enough to be transported over a distance

air contamination: The result of introducing foreign substances into the air so as to

make the air contaminated

air pollution: Contamination of the atmosphere (indoor or outdoor) caused by the

discharge (accidental or deliberate) of a wide range of toxic airborne substances

air sampling: Safety engineers are interested in knowing what contaminants

work-ers are exposed to, and the contaminant concentrations Determining the quantities

and types of atmospheric contaminants is accomplished by measuring and

evaluat-ing a representative sample of air The types of air contaminants that occur in the

workplace depend upon the raw materials used and the processes employed Air

contaminants can be divided into two broad groups, depending upon physical

char-acteristics: (1) gases and vapors and (2) particulates

allergens: Because of the presence of allergens on spores, all molds studied to date

have the potential to cause allergic reaction in susceptible people Allergic reactions

are believed to be the most common exposure reaction to molds (Rose, 1999)

ambient: Descriptive of any condition of the environment surrounding a given point

For example, ambient air means that portion of the atmosphere, external to

build-ings, to which the general public has access Ambient sound is the sound generated

by the environment

asphyxiation: Suffocation from lack of oxygen A substance (e.g., carbon monoxide)

that combines with hemoglobin to reduce the blood’s capacity to transport oxygen

produces chemical asphyxiation Simple asphyxiation is the result of exposure to a

substance (such as methane) that displaces oxygen

atmosphere: In physics, a unit of pressure whereby 1 atmosphere (atm) equals 14.7

pounds per square inch (psi)

Safety and Health Terminology and Hispanic Outreach 29

attenuation: The reduction of the intensity at a designated first location as compared

with intensity at a second location, which is farther from the source (reducing the level of noise by increasing distance from the source is a good example)

audible range: The frequency range over which normal hearing

occurs—approxi-mately 20 Hz through 20,000 Hz Above the range of 20,000 Hz, the term ultrasonic

is used Below 20 Hz, the term subsonic is used

audiogram: A record of hearing loss or hearing level measured at several different

frequencies—usually 500 to 6000 Hz The audiogram may be presented graphically

or numerically Hearing level is shown as a function of frequency

audiometric testing: Objective measuring of a person’s hearing sensitivity By

recording the response to a measured signal, a person’s level of hearing sensitivity can be expressed in decibels, as related to an audiometric zero, or no-sound base

authorized person (see competent or qualified person): A person designated or

assigned by an employer or supervisor to perform a specific type of duty or duties,

to use specified equipment, and/or to be present in a given location at specified times (e.g., an authorized or qualified person is used in confined space entry)

autoignition temperature: The lowest temperature at which a vapor-producing

substance or a flammable gas will ignite even without the presence of a spark or flame

baghouse: Term commonly used for the housing containing bag filters for recovery

of fumes from arsenic, lead, sulfa, etc Many different trade meanings, however

baseline data: Data collected prior to a project for later use in describing conditions

before the project began Also commonly used to describe the first audiogram given (within six months) to a worker after he or she has been exposed to the action level (85 dBA)—to establish his or her baseline for comparison to subsequent audio-grams for comparison

bel: A unit equal to ten decibels (see decibel).

benchmarking: A process for rigorously measuring company performance versus

“best-in-class” companies, and using analysis to meet and exceed the best in class

behavior-based management models: A management theory based on the work of

B F Skinner, it explains behavior in terms of stimulus, response, and consequences

biohazard (biological hazard): Organisms or products of organisms that present a

risk to humans

biological aerosols: Naturally occurring biologically generated and active particles,

small enough to become suspended in air These include mold spores, pollen, viruses, bacteria, insect parts, animal dander, etc

boiler code: ANSI/ASME Pressure Vessel Code whereby a set of standards

prescrib-ing requirements for the design, construction, testprescrib-ing, and installation of boilers and unfired pressure vessels

Boyle’s Law: The product of a given pressure and volume is constant with a constant

temperature

carcinogen: A cancer-producing agent.

carpal tunnel syndrome: An injury to the median nerve inside the wrist, frequently

caused by ergonomically incorrect repetitive motion

catalyst: A substance that alters the speed of, or makes possible, a chemical or

bio-chemical reaction, but remains unchanged at the end of the reaction

catastrophe: A loss of extraordinary large dimensions in terms of injury, death,

dam-age, and destruction

casual factor (accident cause): A person, thing, or condition that contributes

signifi-cantly to an accident or to a project outcome

Charles’s Law: The volume of a given mass of gas at constant pressure is directly

proportional to its absolute temperature (temperature in kelvin)

chemical change: Change that occurs when two or more substances (reactants)

inter-act with each other, resulting in the production of different substances (products)

with different chemical compositions A simple example of chemical change is the

burning of carbon in oxygen to produce carbon dioxide

chemical hazards: Includes hazardous chemicals conveyed in various forms: mists,

vapors, gases, dusts, and fumes

chemical spill: An accidental dumping, leakage, or splashing of a harmful or

poten-tially harmful substance

chronic: Persistent, prolonged, repeated Chronic exposure occurs when repeated

exposure to or contact with a toxic substance occurs over a period of time, the

effects of which become evident only after multiple exposures

coefficient of friction: A numerical correlation of the resistance of one surface against

another surface

combustible gas indicator: An instrument that samples air and indicates whether an

explosive mixture is present, and the percentage of the lower explosive limit (LEL)

of the air-gas mixture that has been reached

combustible liquid: Liquids having a flash point at or above 37.8° C (100° F).

combustion: Burning, defined in chemical terms as the rapid combination of a

sub-stance with oxygen, accompanied by the evolution of heat and usually light

competent person: As defined by OSHA, one who is capable of recognizing and

evaluating employee exposure to hazardous substances or to unsafe conditions, and

who is capable of specifying protective and precautionary measures to be taken to

ensure the safety of employees as required by particular OSHA regulations under

the conditions to which such regulations apply

confined space: A vessel, compartment, or any area having limited access and (usually)

no alternate escape route, having severely limited natural ventilation or an atmosphere

containing less that 19.5 percent oxygen, and having the capability of accumulating a

toxic, flammable, or explosive atmosphere, or of being flooded (engulfing a victim)

containment: In fire terminology, restricting the spread of fire For chemicals,

restricting chemicals to an area that is diked or walled off to protect personnel and

the environment

contingency plan (commonly called the emergency response plan): Under CFR 40

§ 260.10, a document that sets forth an organized, planned, and coordinated course

of action to be followed in the event of an emergency that could threaten human

health or the environment

convection: The transfer of heat from one location to another by way of a moving

medium, including air and water

corrosive material: Any material that dissolves metals or other materials, or that

burns the skin

Safety and Health Terminology and Hispanic Outreach 31

cumulative injury: Any physical or psychological disability that results from the

combined effects of related injuries or illnesses in the workplace

cumulative trauma disorder: A disorder caused by the highly repetitive motion

required of one or more parts of a worker’s body, which in some cases, can result

in moderate to total disability

Dalton’s Law of Partial Pressures: In a mixture of theoretically ideal gases, the

pres-sure exerted by the mixture is the sum of the prespres-sures exerted by each component gas of the mixture

decibel (dB): A unit of measure used originally to compare sound intensities and

subsequently electrical or electronic power outputs; now also used to compare ages In hearing conservation, a logarithmic unit used to express the magnitude of

volt-a chvolt-ange in level of sound intensity

decontamination: The process of reducing or eliminating the presence of harmful

substances such as infectious agents, to reduce the likelihood of disease sion from those substances

transmis-density: A measure of the compactness of a substance; it is equal to its mass per unit

volume and is measure in kg per cubic meter/LB per cubic foot (D = mass/Volume)

dermatitis: Inflammation or irritation of the skin from any cause Industrial dermatitis

is an occupational skin disease

design load: The weight that can be safely supported by a floor, equipment or

struc-ture, as defined by its design characteristics

dike: An embankment or ridge of either natural or man-made materials used to

pre-vent the movement of liquids, sludges, solids, or other materials

dilute: Adding material to a chemical by the user or manufacturer to reduce the

con-centration of active ingredient in the mixture

dose: An exposure level Exposure is expressed as weight or volume of test substance

per volume of air (mg/l), or as parts per million (ppm)

dosimeter: Measuring tool that provides a time-weighted average over a period of

time such as one complete work shift

dusts: Various types of solid particles produced when a given type of organic or

inorganic material is scraped, sawed, ground, drilled, heated, crushed, or otherwise deformed

electrical grounding: Precautionary measures designed into an electrical

installa-tion to eliminate dangerous voltages in and around the installainstalla-tion, and to operate protective devices in case of current leakage from energized conductors to their enclosures

emergency plan: See contingency plan.

emergency response: The response made by firefighters, police, health-care

person-nel, and/or other emergency service workers upon notification of a fire, chemical spill, explosion, or other incident in which human life and/or property may be in jeopardy

energized (“live”): The conductors of an electrical circuit Having voltage applied to

such conductors and to surfaces that a person might touch; having voltage between such surfaces and other surfaces that might complete a circuit and allow current to flow