Safety & Health


Simple Safety Action Item Tracking Log Template

What Get’s Measured, Get’s Managed

If your workplace is not tracking safety action items, you are missing a real opportunity to show progress, build culture, create a safer work environment, and manage your safety systems. As Peter Drucker is quoted as saying,

What get’s measured, get’s managed.

You don’t need to go out and pay hundreds of dollars per year, per user, or any variation thereof. Excel (or even Google Sheets) can be an effective method of tracking open safety action items and ensuring that those items move towards the ultimate goal of completion.

OHShub.com Free Template – Safety Action Item Tracking Log

OHShub has generated a quick excel safety action item tracking log that you can use within your facility. Modify it as you need to fit your work environment (add departments, person who identified, etc.).

The tracking log template includes conditional formatting, which highlights action items that are coming due (within 30 days) in ORANGE, and overdue items in RED. Completed items are GREEN. Additionally, the spreadsheet can be filtered by status, date, person responsible, priority, or any combination thereof.


How Does OSHA Define Bodily Entry – Confined Space

One of the common questions that OHShub is presented with is, “What does OSHA mean by ‘bodily enter’ when it comes to a confined space?” 

Is this even a confined space?

There are a few different questions here:  The first is defining what it means to “bodily enter” a space when we are looking to determine if that space even meets the OSHA definition of a confined space.  The second is, once we have defined a space as a confined space (or more specifically, a permit required confined space), what constitutes “entering a space.”

Complete body must be able to enter the “confined space”

In the preamble to the Permit Required Confined Space standard, OSHA is clear that for a space to meet the requirement of “large enough and so configured that an employee can bodily enter and perform assigned works”, you must be able to completely bodily enter it.  That is, put your whole body in the space.

While OSHA is concerned that spaces that are too small for complete bodily entry may pose hazards for employees, the Agency did not intend to cover such spaces under the permit space standard. OSHA believes that the NPRM preamble discussion of permit space incidents and of proposed provisions clearly indicates that the proposed rule was intended-to cover only spaces that were large enough for the entire body of an employee to enter.

Source: https://www.osha.gov/FedReg_osha_pdf/FED19930114.pdf

Therefore, as we are attempting to define whether a space is a confined space or not, if I can not put my whole body into the space, I do not meet one of the three requirements for defining as a confined space, therefore it is not a confined space and can not ultimately be a permit required confined space.

Be cognizant of other hazards in a space that is not a confined space

Now this does not mean that this space is “safe”, but far from it.  There may still be hazards associated with the space that we must mitigate to ensure our employees are safe when performing work within it, however, we don’t have to meet the requirements of the permit required confined space standard.

Take a look at OSHA’s Letter of Interpretation providing further guidance (emphasis added):

Scenario: The access to aircraft fuel cells (tanks) are approximately 12 inches wide but many feet in length. Workers remain outside the tank but have their upper extremities and, on occasion, their head extending into the tank to perform the required tasks. The aircraft fuel tank will be drained of its contents, purged of vapor, and monitored for gases and vapors.

Question: Would these tanks be considered confined spaces as defined by OSHA’s Permit-required confined spaces standard, 29 CFR 1910.146.

Reply: If it is possible for the employee to fit his or her entire body within the tanks, then they would be confined spaces under §1910.146. On the other hand, if an employee cannot enter the tanks with his or her entire body due to the size of the tanks’ diameters, then the tanks would not be considered confined spaces. An employee may still be injured or killed as a result of some atmospheric hazard within such a tank; however, the permit-required confined spaces standard is not intended to address all locations that pose atmospheric hazards. Please be advised that the procedures to protect workers from atmospheric hazards within these tanks would be required by other OSHA standards, such as Subpart Z of Part 1910 General Industry Standards.

Source: https://www.osha.gov/laws-regs/standardinterpretations/2008-03-05

Break the plane

The second part of understanding “bodily enter” or “bodily entry” is looking at it from the standpoint of a space that has been defined as a confined space, and more specifically, a permit required confined space.  If the space is question is a permit required confined space, simply breaking the plane of that space is considered entry, and must be done within the requirements as stated in the standard, to include permitting.

Summary: TLDR

Summary: TLDR: If I can’t put my full body in, it can’t be classified as a confined space, therefore bodily entry doesn’t apply. But, break the plane on a confined space, or permit required confined space, and I have bodily entered.


Combustible Dust Accumulations Allowed in the Workplace

If you work in an facility that creates dust, there are several questions you may be asking yourself regarding combustible dust, including:

  • How much dust am I allowed to have on surfaces? Is it 1/4 of an inch, 1/8 of an inch, 1/32 of an inch?
  • Am I at risk for a combustible dust explosion?
  • How do I test to see if my dust is classified as combustible dust?
  • How large of an area can have dust accumulations?
  • How do I determine if I can be cited by OSHA under the walking working surfaces standard (1910.22) or the material handling standard (1910.176).

Combustible Dust, Defined

First off, what is a combustible dust? CCOHS provides the following:

Essentially, a combustible dust is any fine material that has the ability to catch fire and explode when mixed with air. Combustible dusts can be from: most solid organic materials (such as sugar, flour, grain, wood, etc.) many metals, and some nonmetallic inorganic materials.


Some of these materials are not “normally” combustible, but they can burn or explode if the particles are the right size and in the right concentration.


Therefore any activity that creates dust should be investigated to see if there is a risk of that dust being combustible. Dust can collect on surfaces such as rafters, roofs, suspended ceilings, ducts, crevices, dust collectors, and other equipment. When the dust is disturbed and under certain circumstances, there is the potential for a serious explosion to occur. The build-up of even a very small amount of dust can cause serious damage.

Canadian Centre for Occupational Health and Safety

Acceptable Accumulation Levels for Combustible Dust

The Combustible Dust National Emphasis Program references 1/32 inch dust accumulation levels, however this is based on some assumptions, including: uniform distribution of the dust and a bulk density of 75 lb/ft3. However, not all dust meets this density (some are lighter, some are heavier). NFPA 654 allows the dust accumulations to exceed the layer depth criteria of 1/32 inch according to the following equation for materials with bulk densities less than 75 lb/ft3.

Additionally, NFPA 654 states that a dust explosion hazard and dust flash fire hazard are deemed to exist in any building or room where any of the following conditions exists:

  • The total area of nonseparated dust accumulations exceeding the layer depth (LD) criterion is greater than five percent of the footprint area.
  • The area of any single nonseparated dust accumulation exceeding the layer depth (LD) criterion is greater than 1000 ft2.
  • The total volume of nonseparated dust accumulations is greater than the layer depth (LD) criterion multiplied by five percent of the footprint area.
  • The total volume of any single nonseparated dust accumulation is greater than the layer depth (LD) criterion multiplied by 1000 ft2.

Calculate Allowable Combustible Dust Levels

In order to calculate the level of dust accumulations that may be allowed at workplaces for combustible dust you must know the bulk density. Bulk densities depend on may factors, including the type of material (e.g. wood, paper, plastic, other organics, metal, etc.), the dust particle size, and the dust particle shape. However, OSHA compliance officers must take into consideration the bulk density of the dust prior to determining if there is a violation and subsequent citation.

Very low bulk density materials (e.g. paper dust and corn dust – 25 lb/ft3 and 16 lb/ft3, respectively), may not create a deflagration (heating until it burns away rapidly) hazard even at an accumulation level of 1/4 inch, covering over five percent of the floor area or 1000 ft2, whichever is less. Therefore, facilities should determine their dust bulk densities in order to determine the level of accumulation that does not present a combustible dust hazard.

One of the easiest manners to determine bulk densities is to use an online resource, such as:

The referenced bulk densities can then be plugged into the equation below to determine the allowed LD

Example – Allowed Dust Accumulation

For example, for paper dust with a bulk density of 25 lb/ft3, the layer depth criterion is approximately 1/10th of an inch.

Therefore, in this example, a dust explosion hazard and dust flash fire hazard are deemed to exist if:

  • The total area of non separated dust accumulation exceeding 1/10th of an inch over greater than 5 percent of the footprint area, or
  • The area of any single nonseparated dust accumulation exceeding 1/10th of an inch is greater than 1000 ft2, or
  • The total volume of non separated dust accumulations is greater than 1/10th of in inch multiplied by five percent of the footprint area, or
  • The total volume of any single nonseparated dust accumulation is greater than 1/10th of an inch multiplied by 1000 ft2.

How Does OSHA Evaluate Dust Accumulations?

It should be noted that OSHA compliance officers will only likely send samples out for bulk density determination if the material is light (e.g. paper dust, fabric fibers) and the levels of accumulation exceed 1/4 of an inch over 5% of the floor area of a room or building, of 1000 ft2, whichever is less.

However, if dust accumulations are documented to exceed one inch in depth (extending over 5 percent of the floor area or a room or building, or 1000 ft, whichever is less), samples of dust don’t need to be submitted for bulk density determination. The OSHA compliance officer can use the referenced sources as guidance to determine the approximate values for LD and can issue citations without the bulk density determination.

Source: OSHA – Evaluating Hazardous Levels of Accumulation Depth for Combustible Dusts


Guide for Developing Job Safety Analyses & Safe Work Procedures

While Administrative Controls may not be the most effective hazard control method, they are still extremely valuable to sustainable an lasting change in most organizations.

What is a Job Safety Analysis or Safe Work Procedure?

Job Safety Analyses (JSA) and Safety Work Procedures (SWP) (also known as job hazard analysis/analyses, pre job plan, safe work plan, etc.) are step by step instructions for doing work the right way. JSAs and SWPs identify the materials and equipment needed, how and when to use them, and usually include:

  • regulatory requirements;
  • personal protective equipment requirements;
  • training requirements;
  • responsibilities of each person involved in the job;
  • a specific sequence of steps to follow to complete the work safely; permits required;
  • emergency procedures.

Why Use a JSA or SWP?

JSAs and SWPs are generally prepared for jobs that:

  • are critical (high risk jobs where accidents have or could result in severe injuries);
  • are hazardous and where accidents occur frequently;
  • new or have been changed;
  • have had new equipment added;
  • require many detailed tasks;
  • involve two or more workers who must perform specific tasks simultaneously;
  • are done infrequently.

10 Steps to Create a Job Safety Analysis (JSA) or Safe Work Procedure (SWP)

  1. An easy way to develop a job safety analysis or safe work procedure procedure is to break the task into small steps. For each step, determine the hazards and ways to correct them. Some hazards to think about include: being struck by moving equipment; coming in contact with hazardous substances; hitting obstructions or other workers; becoming caught in machinery; falling; being struck by objects falling from above; suffering from exposure to toxic gases, insufficient oxygen or extreme temperatures.
  2. You can then use the breakdown of hazards and corrective measures to prepare a written JSA or SWP. Consider using the following process to develop your safe work procedures. List all jobs on your work sites that meet the criteria above. Concentrate on those that have potential for: serious injuries; frequent injures; severe property damage; significant interruptions to production; public liability; government intervention.
  3. Put the list of jobs in order by the degree of hazard they present and the frequency they are performed.
  4. Analyze each job by observing and interviewing workers. Record the following information: job name and location; each step of the job and its hazards; roles of each worker involved; special equipment required; applicable regulatory requirements.
  5. Determine the measures needed to control job hazards, such as: engineering controls to eliminate hazards; worker training; personal protective and safety equipment; hazard markings; safety meetings.
  6. If engineering controls or worker training can be used to permanently eliminate or reduce the impact of hazards, implement them.
  7. Prepare your safe work procedure by listing (in order of occurrence) each: step of the job; control measure required (excluding one time measures such as engineering controls and development of training); regulatory requirement; special equipment required; specific training requirement for workers (e.g., BOP Level l or journeyman electrician).
  8. Test the procedure in the field to ensure it: is accurate; meets regulatory requirements; is understandable to workers.
  9. Finalize the written procedure and place it at appropriate work sites.
  10. Train workers in the procedures.

7 Ineffective Safety Practices (and what to do instead)

Your Safety Management System (SMS) hitting a roadblock? Real safety culture change not occurring in your facility? Maybe you (and senior managment) are looking it all wrong. Here are few Do’s and Don’ts for improving the effectiveness of your safety program.

DO

  1. Focus on Leading Indicators – Know where you are going, not focus solely on where you have been.
  2. Reinforce Correct Behavior – Strengthen what’s working and discourage inappropriate behaviors within your Behavior Based Safety system.
  3. Focus on needs-based training – can’t do, train for fluency; won’t do – Change the consequences and ultimately the outcome – go beyond compliance.
  4. Speak with your Actions, not your Words – Demonstrate commitment and uphold integrity.
  5. Analyze and take Action – Avoid the blame game for past accountability lapses. Develop accountability processes that expect future results and hold true to them.
  6. Encourage Near Miss / Near Hit / Close Call Reporting – Some of your most valuable data can come from the data associated with near misses. Encourage reporting. Don’t place blame but use as a learning opportunity. As your program matures, so will the near miss reporting processes.
  7. Be a Safety Coach – Build on what is right in your safety program and don’t focus on what is wrong. Be an encourager and not a defeatist.

DON’T

  1. Focus on Lagging Indicators – While lagging indicators can let you know where you have been, they should not be your focus and road map on where your safety program and management system is going. Be proactive rather than reactive.
  2. Implement Injury based Incentive Systems – Injury based incentive systems can drive injury and near miss reporting underground, which can cause a false sense of hope. Additionally, OSHA has specifically addressed and discouraged these type of incentive programs.
  3. Rely Solely on Awareness Training – While awareness level training is important, it shouldn’t be the breadth of your training program. Use your data from DO #3 and focus on where your gaps and needs are. Spend your training capital there.
  4. Rely on Motivational Signs & Messages – “Safety Starts with You”, “Think Through It Before You Do It”, etc. At best, you get some (slight) short term benefit, if any. Signage is quickly ignored, overlooked, and blends in with the environment. Don’t depend on motivational signage as your safety culture booster.
  5. Force Compliance via Blame and Discipline – Nothing on this list more quickly puts safety shortcuts into the underground than the prevalence of blame and discipline within an organization. Don’t fall into the trap. Accountability, yes. A focus on Blame and Discipline, no.
  6. Discourage Near Miss Reporting – All incidents are not created equal. And this goes with near misses as well. Review your accountability methods to ensure you are not using DON’T #5 to discourage near miss reporting. Near misses must be treated as learning opportunities. Use them to your benefit.
  7. Be the Safety Cop – You don’t want people to comply just because you come walking through the facility. You want your employees to seek you out for assistance to safety questions or concerns. Without building relationship (coach) and by leading by force (cop), you will surely send your safety culture reeling.

Graphic Source: Aubrey Daniels International


Examples of Permissible Occupational Drug Testing

When can I perform drug testing in the workplace?

  • Random drug testing
  • Drug testing unrelated to reporting of work-related injury or illness
  • Drug testing under state workers’ compensation law
  • Drug testing under other federal law, such as US DOT regulation
  • Drug testing to evaluate root cause of workplace incident that harmed, or could have harmed, employees
  • Note: If the employer chooses to use drug testing to investigate an incident, the employer should test all employees whose conduct could have contributed to the incident, not just the employee(s) who reported injuries.

Source: OSHA


Quick Safety Observation Card – Free Template


OHShub.com Quick Safety Observation Card (front)

Performing safety observations are one of the easiest and most effective methods of checking the pulse of the safety culture in your organization. Through safety observations, you are able to observe and understand actual safety-related conditions and behaviors in your facility, and more importantly, do something about it. The results of your safety observations should lead to:

  • a ‘Thank You’ (observing a safe behavior),
  • a ‘Conversation’ (observing an unsafe behavior), or
  • an ‘Action’ (observing an unsafe condition).
OHShub.com Quick Safety Observation Card (back)

The OSHhub.com Quick Safety Observation template (.pdf format) provides a quick method to document a safety observation for entry into your facility’s safety tracking system. Note: The cards are pocket sized (approximately 3″x5″) and should be printed front and back. 4 cards are on each 8.5″ x 11″ sheet of paper. Download the Word format HERE.

Basis for Conducting Safety Observations

Carnegie Mellon recently did a study where they reviewed 112 Million Safety Observations from 15,000 worksites.  From the review of the data, they were able to develop predictive models that were between 90-97% effective in predicting injuries.  And it boiled down to 4 factors of influence.  The 4 Safety Truths.

4 Safety Truths

  1. More inspections predict a safer worksite.
    • More eyes increases safety.
  2. More inspectors, specifically outside of the safety function, predict a safer worksite.
    • Getting everyone involved, increases safety.
  3. Too many 100% safe inspections predicts an unsafe worksite. 
    • You are flying blind.
    • Encourage finding of “unsafes” to increase safety.
  4. Too many unsafe inspections predicts an unsafe worksite. 
    • Self-explanatory.

What Kind of Observer are You?

  1. Balanced – documents safe/unsafe behaviors & unsafe conditions, equally
  2. Pencil Whipper – documents only safe behaviors or conditions
  3. Non-Confronter – does not document behaviors, only conditions
  4. Fault Finder – does not document safe behaviors, only unsafe
  5. Non-Participant – does not document , i.e. “I’m too busy”

Incorporating KPIs into your Safety Management System

Assume for a moment that your facility has the basis for a Safety Management System (SMS).  Are you measuring its effectiveness?  Are you looking at the trends to see what’s behind and what’s ahead?  Peter Drucker is quoted as saying, “what gets measured gets managed.”  Measuring the performance of your SMS is conducted through the use of Key Performance Indicators (KPIs).  KPIs will help you to demonstrate to all levels in your organization where your SMS stands.  Simplified, it’s based on the Deming Wheel, or Plan – Do – Check – Act (PDCA) model. 

PLAN

  • Gather Support
    • Support from top management is an absolute.  Safety should not be considered the sole responsibility of the site Safety Lead/Team.
    • Do you have the support of leadership?  Have they committed to UAS (Understand – Accept – Support) the process?  Do you have members from other areas of the organization developing and supporting the framework around the KPIs? 
  • Identify Metrics
    • Identify the existing metrics that your organization uses. 
    • Is your organization solely meeting compliance (i.e. are you only tracking lagging indicators based on injury rate)?  Have you incorporated leading indicators into your metrics?  Have you established criteria around what is acceptable performance?  .
  • Communicate the Plan
    • Communication is a key factor in Safety.  Communicate early and often.
    • Do you have an effective plan to communicate established KPIs to all levels of your organization?

DO

  • Start Small
    • If you are just beginning to establish KPIs or are looking to expand what you are measuring, start small, but just start.  Use the KISS (Keep it Simply Simple) method. 
    • You are tracking lagging indicators (e.g. total case incident rate), can you add one to two leading indicators to your KPIs?
  • Involve Others (outside of the Safety Team)
    • Involve other areas and multiple levels within the organization (front line employees and supervisors, Engineering, etc.). 
    • Do others in the organization have actionable and measureable “skin in the game”?  Is their input valued?
  • Establish Expectations
    • In your very busy work environment, starting small is vitally important if you are adding new expectations for employees, however establishing (and tracking adherence to) expectations is a must. 
    • What are the expectations around the established KPIs?

CHECK

  • Measure Success
    • The information gathered from the KPIs must translate into success.  Use your lagging indicators as a basis for cross-checking your tracked leading indicators.
    • Are the KPIs that you are tracking resulting in a decrease in severity or incident rate?  Are risks being reduced?
  • Ensure Outputs Add Value
    • KPIs that you are tracking, must provide meaningful information.  P-D-C-A this individual component. 
    • Can I act on the information that the KPIs are providing?  What is the path forward?
  • Solicit Feedback
    • Don’t live in a “safety bubble”.  Get feedback from people in the organization and prepare to act on it.  Soft feedback is often just as important as hard data. 

ACT

  • Refine or Redefine
    • Take the information learned in the “Check” phase to refine your KPIs.  Don’t be afraid to change it up. 
    • Metric X isn’t providing insightful or actionable information, what are you missing?
  • Take Action
    • If it’s not working, do something different, but just do something.  If it is working, identify ways to make it better.
    • How can you continuously improve your organizations safety results?  What KPIs have you identified that you are not tracking?  How can you incorporate those KPIs into your SMS?
  • Achieve Sustainability
    • If you don’t put the systems in place to make capturing and reviewing your KPIs maintainable, you are expending unnecessary effort. 
    • Are these KPIs providing real value to your organization?

An effective SMS is vital in today’s lean work environments.  Establishing value-added KPIs help your organization evaluate the effectiveness of the SMS and can serve as a basis for continuously improving safety within your organization.

Source: Paper360 May/June 2019 – George Bower


Complying with the OSHA Silica Standards

Looking for resources on interpreting the crystalline silica standard?

When guarding against exposure to silica, the protection of our employees must remain the primary focus. However, protection of the “bottom line” should also play a part as OSHA has ramped up it’s enforcement of the standard (read: VA contractor faces $300K in fines over silica violations).

How do you effectively comply with the standard? ASSP recently released a resource entitled “Silica Resource Guide for Contractors” that provides a FAQ for the questions contractors are asking, including:

  • when air sampling is required
  • how to use “objective data”
  • medical surveillance requirements
  • respiratory protection requirements, etc.

Additionally, OSHA has released a 64- question FAQ for general industry on it’s Respirable Crystalline Silica standard (29 CFR 1910.1053) and a FAQ for the construction industry (29 CFR 1926.1153).


BCSP Offers Free Quizzes for Recertification

The BCSP (Board of Certified Safety Professionals) is offering free quizzes for recertification.  The quizzes provide a great opportunity for CE credits and is available the web or through mobile apps (Google or Apple).  Every online quiz is worth 0.1 CM points and there are currently 58 quizzes available as of this writing.  The quizzes are broken into two general categories based on publication (Professional Safety or Safety & Health), are open book, and may be taken repeatedly until passed (80% correct to pass).

Source: BCSP


Work Related Fatalities on the Rise – NSC Webinar

The number of fatalities in the US work environment have increased over the past 9 years, and the rate per 100,000 workers has remained flat.  With all of the focus on workplace safety, why is this the case?  

Join the National Safety Council’s Statistics Manager, Ken Kolosh, as he explains the data and trends.  You can sign up for the webinar HERE.

Source: NSC Injury Facts 2017


Safety Walk-Arounds: OSHA Factsheet

Safety Inspections, Safety Walk-Around, Safety Walk-About, GEMBA Walk, Safety Walk… the process goes by many different names.  However, the basis and benefit for conducting these routine safety walks are the same.

OSHA recently released a guidance document, , on conducting effective safety walks that improves hazard recognition and communication about identified hazards with employees.

Why conduct a safety walk?  Two reasons:

  1. Demonstrate management’s commitment to improving safety and health in your facility by identifying and mitigating hazards, and
  2. Allow management the opportunity to see for themselves how the safety and health program is working and it’s effectiveness in identifying and eliminating hazards.

The document provides a brief overview on pre-inspection, inspection, and post-inspection practices that can be applied in virtually every working environment.