MSDSonline Environmental, Health & Safety Blog

OSHA’s “Recordkeeping Rule” continues to make headlines in the EH&S world.  The most recent news involves  a report released by the Government Accountability Office (GAO), which concludes that underreporting and inaccurate employer injury and illness data may be attributed to a number of factors, including worker intimidation, and that the Labor Department’s OSHA audit process for verifying employer injury and illness records, is flawed.

Brief Background About the Report
The Department of Labor (DOL) is required under the OSH Act of 1970 to collect and compile occupational injury and illness records, and the Government Accountability Office (GAO) was asked to determine two things: 1) whether or not the DOL verifies that employers are accurately recording employee workplace injuries and illnesses, and, if so, how adequately and 2) what factors may affect the accuracy of employer injury and illness records. The results of the report were released this month.

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We are happy to share the news that MSDSonline was recently named to Brill Street + Company’s list of Top 50 Generation-Y Employers in the Chicago area. “It’s an honor to be recognized alongside of so many blue-chip Chicago companies,” said Glenn Trout, president and CEO of MSDSonline. “As a developer of Software as a Service (SaaS) solutions, we’ve found that this generation not only brings creativity and a strong work ethic, but they are very tech savvy, which is important in every facet of our business.”

“Generation Y makes up more than 50 percent of our workforce,” adds Trout. “We pride ourselves on the culture that we’ve built here. “It’s truly a family atmosphere, and because of that we’ve been able to attract and retain some great young talent.”

More specific information about MSDSonline’s ranking is available here.

To access the complete news release, visit the MSDSonline Web site.

-The MSDSonline Compliance Team

If you haven’t noticed, OSHA has been following through on its commitment to do more to update, create and modify guidance provisions, at least in the way of providing new guidance documentation.  The agency has released two new guidance publications in recent months, both happen to address dust-particle dangers. The latest document, Controlling Silica Exposures in Construction, provides recommendations for preventing worker overexposure to crystalline silica. It includes effective work practices and engineering controls for construction-related tasks, such as utilizing wet-cutting and vacuum-dust collection systems.

Unlike the combustibility hazards associated with the dust particles referenced in the other guidance document, Hazard Communication Guidance for Combustible Dusts, the hazards associated with silica airborne particles involve the respiratory function of exposed workers.

According to the National Institute for Occupational Safety and Health (NIOSH),  exposure to respirable crystalline silica is a risk for a whopping 1.7 million U.S. workers. This is a considerable number and is territory that OSHA has been carefully assessing.

OSHA and Silica
In addition to putting a guidance document together, OSHA also initiated a National Emphasis Program (NEP) for crystalline silica in early 2008, Directive CPL 03-00-007, which builds on a 1996 Special Emphasis Program (SEP) for Silicosis. According to OSHA, the purpose of the NEP is “to identify and reduce or eliminate the health hazards associated with occupational exposure to crystalline silica.”

Regarding compliance, if your company uses materials containing 0.1 percent or more crystalline silica, then you are covered by OSHA’s Hazard Communication Standard (HCS, HazCom, 29 CFR 1910) and must provide: material safety data sheets, proper warning labels and employee training.

You must also adhere to the permissible exposure limit (PEL), 29 CFR 1926.55, 1910.1000, that OSHA has set for this hazardous compound. The PEL represents the maximum amount of crystalline silica that employees can be exposed to during an eight-hour work shift.  The limit varies by the composition of the airborne dust present at a particular construction site, and the dust composition is affected by the type of material in use, the silica concentration found in that material, and the environmental factors impacting the worksite ( i.e., open or enclosed space, wind or no wind, etc).

If you’d like more details about OSHA’s PEL calculation for crystalline silica, visit the agency’s Silica eTool, or for a snapshot of regulatory standards related to the hazardous dust, click here.

NOTE: According to the new guidance document, OSHA is still in the process of reviewing silica PELs for both the construction and general industries. However, in this publication, the agency references a PEL benchmark of 0.1mg/m3 (milligrams per cubic meter of air) per eight-hour time-weighted average (TWA).

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Back in August of this year, Dave Schmidt, an economist in OSHA’s Office of Statistical Analysis, released details about OSHA’s $1 million, one year National Emphasis Program (NEP) for injury and illness recordkeeping at a National Advisory Committee on Occupational Safety and Health (NACOSH) meeting, and on Oct. 1, OSHA officially announced  that it was initiating this NEP.

The purpose of the NEP will be to protect workers by investigating certain employers for possibly under-recording workplace injuries and illnesses. The NEP will focus on industries with high injury and illness rates.

“Accurate and honest recordkeeping is vitally important to workers’ health and safety,” said acting Assistant Secretary of Labor for OSHA Jordan Barab. “This information is not only used by OSHA to determine which workplaces to inspect, but it is an important tool employers and workers can use to identify health and safety problems in their workplaces.”

The inspections will consist of three components: a records review, employee interviews and a limited safety and health inspection of the workplace.

1. Records review

• Of ALL available records for each employee sampled (medical records, Workers’ Comp, absentee records, audiograms, etc.)
• Of the OSHA 300 Log, 300A Summary and 301 Incident Report (or the equivalent) to verify accuracy

2. Interviews

• With the recordkeeper, management, employees and health care providers
• To find out about current incident recordkeeping processes
• To determine whether incentive and disincentive programs might be set up in such a way that deters reporting

3. Limited safety and health inspection of the workplace

• To determine if recorded incidences correlate with actual work environments
• Will simultaneously address any observable safety violations

OSHA stated that this NEP will help the agency work with the Government Accountability Office (GAO) and the Bureau of Labor Statistics, which have both cited concerns about the accuracy of recorded workplace injury and illness estimates.

Incident Management Assistance
Don’t be taken by surprise, prepare now for a possible inspection. With the help of MSDSonline’s Incident Management application, you’ll have one convenient location to record, store and access employee incident information.

It’s easy to get started; the 4-Step Case Guide takes you through a step-by-step process for entering new cases into the system. Once the cases are entered, you can use the analytics tools to identify workplace hazards and ― through the application ― begin scheduling corrective actions to eliminate them.

Call 1.888.362.2007 for more information or send  an inquiry via email.

The Department of Labor (DOL) and the Occupational Safety and Health Administration (OSHA) recently revised the personal protective equipment (PPE) standards concerning requirements for eye- and face protective devices, and head and foot protection for general industry, shipyard employment, longshoring and marine terminals. The final rule, which becomes effective Oct. 9, 2009, “Is another step in OSHA’s efforts to update or remove references to outdated national consensus and industry standards,” said Assistant Secretary of Labor for OSHA Jordan Barab.

According to the Federal Register notice, one of the changes includes “deleting editions of the national consensus standards that PPE must meet if purchased before a specified date.” The revisions to the standard require employers to follow guidelines from the most recent editions of applicable national consensus standards, standards set by groups like the American National Standards Institute (ANSI). The changes give the regulation sustainability, keeping it current as consensus standards evolve through time, and they also simplify compliance and enforcement.

“Workers exposed to occupational hazards requiring head, foot, or eye and face protection will now be provided protection based on a standard that reflects state-of-the-art technology and materials,” said Barab.

So, what does this mean for you if you’re the employer? Well, in an interview with EHS Today, from the article titled “OSHA Updates PPE Standards to Reference Consensus Standards,” the International Safety Equipment Association (ISEA) President Daniel K. Shipp summed it up nicely, he said, “It’s no great change. Companies will continue to use the same eye and face protection and head protection equipment they had been using that meets the current standard.” Shipp also concurred that the proposed changes will help to keep the regulation relevant in the future. He said, “We think the way that OSHA is proposing to update the standard will make it easier for the standard to stay up to date now with the state-of-the-art [advances] as new consensus standards are published.”

Visit OSHA’s Web site to read the complete new release or click here to read the final rule in the Federal Register.

If you’re considering purchasing new PPE, you can find a variety of products from trusted suppliers at MSDSonline’s Safety Mall.

– The MSDSonline Compliance Team