Overlooked Rules About the OSHA Workplace Notification Poster

 THE OSHA TRAINING BLOG HAS MOVED TO OUR NEW WEBSITE. VISIT US AT https://oshatraining.com/osha-training-blogs/

Answers to Top Five Questions about Hard Hats

 THE OSHA TRAINING BLOG HAS MOVED TO OUR NEW WEBSITE. VISIT US AT https://oshatraining.com/osha-training-blogs/

The OSHA Standard You May Not Realize Applies to You!

 THE OSHA TRAINING BLOG HAS MOVED TO OUR NEW WEBSITE. VISIT US AT https://oshatraining.com/osha-training-blogs/

 

“Best Practices”? Or Safety Run Amuck.

 THE OSHA TRAINING BLOG HAS MOVED TO OUR NEW WEBSITE. VISIT US AT https://oshatraining.com/osha-training-blogs/

 

Occasionally I am asked by attorneys to serve as an expert witness on lawsuits involving workplace injuries and fatalities. One of the most fascinating cases I worked on involved an office worker suing her employer for gross negligence because a maintenance man operating a scissor-lift ran over her foot as she exited her cubicle. Now why, you may wonder, would a scissor-lift be traveling down an aisle way in the office? The short answer is, the company was following the “best practice” for changing a light bulb. Perhaps I should back up several years to explain how this accident came to be. But be warned, while reading this story you may not know whether you should laugh or cry.

Quite a few years before this accident occurred, another maintenance man working for the same company had set up a 20-foot metal extension ladder against the exterior of the building to change a burned-out bulb that provided light to the parking area. Apparently the light fixture was mounted about 23 feet above the ground, and the soil was soggy from a leaky sprinkler pipe. You can probably see where this is headed, so to make a long story short; the maintenance man was standing on the next-to-the-top rung of the extension ladder, stretching to reach up over his head to change the bulb, when he received a small electrical shock that caused him to recoil. And that in turn caused him to fall off the ladder to the ground below, where he was seriously injured.

As a result of this accident, the owner of the business insisted that the safety manager implement “best practices” for ladder use to insure something like this never happened again. “Best practices” was the new buzzword in corporate America at that time, so everything the company did, the owner insisted be done in line with “best practices”. Personally, I get tired of hearing people, including safety professionals, pronounce every single policy they implement as a “best practice”; in fact, I’d guess you have to say it is one of my pet peeves. But none the less, it is something that is firmly entrenched in business vernacular, even though there is no organization or mechanism in place to validate most of these claims.

Back to my story; as you can probably guess, the safety manager quickly developed and implemented a comprehensive ladder safety program that included written policies on the proper selection and set-up of ladders, followed by training for affected workers. But the safety manager did not stop there; he decided to go above and beyond to mandate that employees always wear a fall protection harness attached to a lanyard or safety line before they set their foot on a ladder. One hundred percent fall protection all the time. No exceptions. Period!

Apparently the safety manager did not give deep consideration to the potential ramifications of this new policy. So it’s no surprise that the poop hit the fan a few months later when the company owner stopped by the safety manager’s office and chewed him out because he saw a (different) maintenance man who had climbed onto a step-ladder in the office lobby area, and he was not following their established “best practice”. So the safety manager responded by running downstairs to the scene of the crime and sure-enough, there was the worker standing on the third rung of an eight-foot stepladder changing a fluorescent light bulb, and he was not using fall protection gear. The safety manager chastised the worker for not tying off, and you can probably guess what the worker’s response was; “exactly where the heck do you suggest I tie off?”

The safety manager grabbed a broom from a nearby janitorial closet and used the handle to push over some ceiling tiles. Then he shined a flashlight into the hole so he could see up into the area above the ceiling grid. He was trying to find a suitable tie-off point for the safety line, but all he could see was a bunch of conduit, sprinkler pipes, and a flimsy-looking bar joist. Then the maintenance man told him to quit wasting his time, because even if he could find a suitable tie-off point, they had no way to climb up there to connect the safety line because they were not allowed to use a ladder unless they were already tied off!

So the safety manager told the maintenance worker to put off changing light bulbs in the office area until he could come up with something else that would work. And after racking his brain for a couple of days, the safety manager implemented a new “best practice”; from now on, workers must utilize a scissor-lift when changing light bulbs inside the office building.

Over the next few years they discovered a few bugs in their “best practice” that required the procedure to be further revised, such as on the day they realized they needed to change a light bulb on the second floor of the office building. Their elevator was too small for the scissor-lift to fit inside (and the lift was probably too heavy). So they ended up purchasing another scissor-lift to use on the second floor, disassembled and transported it upstairs in pieces, and then reassembled it, where it would remain exclusively for use when a light bulb needed to be changed.

Of course, the Fire Marshall had to express his displeasure when, during his annual inspection a few months later, he found the scissor lift parked in an aisle-way in the back corner of the office area, blocking access to an emergency exit. Due to a lack of an adequate parking spot for the scissor-lift, the company decided their only choice was to have someone move out of one of the offices situated along the outer wall, and then use that office to store the lift. But it couldn’t be just any office; clearance restrictions created by the rows of cubicle wall panels adjacent to the offices required them to park the scissor-lift in one of the corner offices; the Vice President of Human Resources was not pleased! So she booted the safety manager (who happened to report to her) out of his office and into a cubicle, and she relocated to his old, smaller office. Not the ideal situation, but a sacrifice that had to be made for the sake of “best practices”.

Over time, other challenges resulted in the evolution of their “best practice" for changing a light bulb, such as the time when the scissor-lift was being driven down an aisle-way and one of the carpeted floor panel that was situated over a hollow chase for computer wires collapsed. That resulted in the need for the revision of office floor plan maps, originally created for displaying their emergency evacuation routes, so they could also pinpoint where similar false floor panels were located. Then they fabricated special “floor plates” out of sheets of precisely-trimmed 1-inch thick plywood that they would place over portions of the floor with a void beneath when they drove the scissor-lift over them so they could prevent another collapse .

But a couple of years after that, they had to go back and bevel the edges of the sheets of plywood and paint them safety yellow, because a worker stubbed her toe on the edge of one of them as she was walking over it to get to the copy machine and split a toenail. Then about two years ago, the company had to revise their “best practice” once again, this time to require the placement of orange traffic cones to block off all pedestrian traffic in the area when the plywood sheets were laid down because an employee claims to have jarred his back when he stepped off of a piece and had to have surgery.

So now we approach the day of the accident that resulted in the lawsuit I told you about. In spite of the company implementing the “best practice” for changing a light bulb (a procedure that had been developed, formalized, and refined multiple times into a seven page document and an investment of thousands of dollars for equipment, materials, and labor), it became apparent that their procedure did not address one other potential hazard. As the maintenance man was backing the scissor-lift down an aisle-way and around a corner, he accidentally struck one of the cubicle walls, causing it to collapse.

Luckily nobody was inside that particular cubicle at the time, but it did create quite a racket. And a brand new laptop computer and printer were trashed when they were struck by the falling wall. As soon as he realized what he had done, the maintenance man shoved the scissor-lift into the opposite gear and lurched forward; at about the same time the plaintiff in this lawsuit came running out of an adjacent cubicle to see what had happened. And that was when her foot got run over by one of the wheels on the scissor-lift.

Now the moral of the story is NOT to discourage someone from trying to make a job safer by improving upon the procedure in place. That’s what safety people are supposed to do when they find a hazard that is not being adequately addressed. Frankly, I’m impressed the safety manager implemented a comprehensive ladder safety program that consisted of proper ladder selection, set-up and use after the initial accident occurred many years ago. But in hindsight, he probably wishes that he would have stopped right there, at least when it came to applying their "best practice" of requiring 100-percent tie-off when using a ladder to change burned-out light bulbs in the office. Now I’m just hoping the company does not implement a new "best practice" that requires office workers to wear steel-toe shoes! And still lost in all of this was the irony that every time the maintenance man had to mount the scissor-lift, he actually had to climb up a short built-in ladder affixed to one end of the lift.  

No, the point of my sharing this story with you is just to remind fellow safety professionals that we should not implement a new or revised safety procedure without thoroughly considering all the potential ramifications. And while I’m at it, let me ask you to do me a favor; the next time you develop or update one of your safety policies, please try and avoid pronouncing it a “best practice”, unless you have some kind of validation to back it up. Perhaps you could instead say something like “this is the safety policy or practice that works best for us”.

If you’d like to share a story about your experiences with a safety improvement that ran amuck, or make some other comment about this blog post, please do so in the “comments” section below. And last but not least, please pass a link to this blog post along to others in your network who you think may benefit (or at least be amused) by this information.

OSHA Training: The "Invisible" Employees

 THE OSHA TRAINING BLOG HAS MOVED TO OUR NEW WEBSITE. VISIT US AT https://oshatraining.com/osha-training-blogs/

 

 

Hello – can you see me? I must be invisible when it comes to OSHA training. Or maybe I am just exempt from all safety training regulations? Surely not!

I mean, if there was a fire or explosion in our building, I am curious to know what the company expects me to do. Is there some kind of alarm or signal to warn us to evacuate, or a place where I am expected to assemble? How would they know I got out safely? I wonder, but yet I have never been trained about this sort of thing.

And if a nearby co-worker suffered a heart attack or other serious medical emergency, I am not sure exactly how I should react. Does our company have a procedure in place? Maybe I just call an ambulance? Does anyone here know first aid or CPR? I have no idea, as our company’s safety manager never trained me about this sort of thing either. And while I’m at it, what am I supposed to do if a tornado is reported to be headed in our direction? Do I go get in my car and drive away? Or crawl under a table somewhere? I don’t know what the company expects of me, as I have never been instructed on what to do in this situation, either. I guess maybe I’m on my own.

I have also wondered on occasion what to do if there was ever a small fire break out in my work area. I mean, it is possible. In fact, there is a portable fire extinguisher hanging on the wall just 20 feet away from my work station. I guess I could grab it and try to extinguish the fire, but I’m not sure if I would be doing it right, or maybe I am not supposed to try to use it. You’d think our safety manager would provide me with some information on how to use those things, but I guess it’s not important.

Also, when I have to walk through a certain work area in our facility, I often wonder what that strong odor is that I smell. It makes my eyes water and my nose run. Is it coming from one of those drums back there? Is it something that I should be concerned about? I see other employees over there wearing facemasks sometimes, and I wonder if I need one, or maybe I should not be walking back there. But I don’t have a clue, as I have never been included in a safety meeting at work. And you would think the company would have some kind of papers available that tell me what I’d like to know about all those chemicals.

There is a hardhat hanging on a hook next to my workstation. It was given to me by a guy who works in a certain work area that I occasionally have to walk through to get to the manager’s office; he once scolded me for not wearing one, and told me I had to wear it whenever I go back there, just like everybody else. But it does not fit me very good, and I think the headband might be broken, but I’m not sure. So I just put it on my head every time I walk through there so I don’t cause a stir. I wonder if I should also be wearing a pair of those safety glasses like they all do, too, instead of my regular prescription glasses.

And one last thing I’d like to bring up. There is one of the maintenance guys working on a piece of equipment right over there, near my workstation. I really need to use that equipment to get some work done because my boss says she needs in a hurry. Oh look; the maintenance guy is gone right now, probably on a break or something. Certainly it would be okay just to walk over there and flip on the switch and use that piece of equipment until he gets back. I guess that could not hurt anything. Besides, if it wasn’t okay, surely someone would have given me some training telling me I shouldn’t do that.

I am the most overlooked employee at your facility; in fact, when it comes to OSHA safety training, I must be invisible. I heard our company has a safety manager on staff that spends a lot of his time training the other employees. But I guess workers like me are not to be concerned about all that safety stuff, since we are never called together for safety training. Or like I said, maybe we are invisible.

Who am I? Just walk into the office and look around, you’ll see me there. I am your office receptionist, or maybe I am the accounting clerk, or even the assistant sales manager manning the phones all day. Maybe I’m the young intern working in the drafting department. Or I could be the project manager’s assistant who works in the office trailer at your construction site. We are employees too, but when it comes to safety training, people like me who work in the office might as well be invisible.

There are OSHA regulations that require information and training for affected workers in these situations, even if they work in the office. And for you readers who are not sure which OSHA standards could be applicable, check these links:

·         Emergency Action Plan Training - 1910.38(f)(1) – (3)

·         Portable Fire Extinguisher Training - 1910.157(g)(1)– (4)

·         Hazard Communication Training - 1910.1200(h)

·         Personal Protective Equipment Training - 1910.132(f)(1)

·         Lockout Tagout Training for “Other” Employees - 1910.147(c)(7)(i)(C)

Hopefully this blog post will give you reason to pause and think about any “invisible” employees that may be working for your company or organization who might have been overlooked when it comes to OSHA training. So open your eyes and take a good hard look around.

If you’d like to make a comment about this blog post, please do so in the “comments” section below. Also, list any other hazards that office workers are required to receive OSHA training on, if any come to mind. And last but not least, please pass a link to this blog post along to others in your network who you think may benefit from this information.

OSHA Training Myths Busted! - Powered Industrial Truck Operator Training and Evaluations

 THE OSHA TRAINING BLOG HAS MOVED TO OUR NEW WEBSITE. VISIT US AT https://oshatraining.com/osha-training-blogs/

 

Where Federal OSHA (or other agency) Jurisdiction Supersedes State OSHA

 THE OSHA TRAINING BLOG HAS MOVED TO OUR NEW WEBSITE. VISIT US AT https://oshatraining.com/osha-training-blogs/

Finding OSHA Letters of Interpretation is a Snap (or a few clicks, actually)

 THE OSHA TRAINING BLOG HAS MOVED TO OUR NEW WEBSITE. VISIT US AT https://oshatraining.com/osha-training-blogs/

Is it an OSHA Violation? That Depends . . . .

 THE OSHA TRAINING BLOG HAS MOVED TO OUR NEW WEBSITE. VISIT US AT https://oshatraining.com/osha-training-blogs/

 

The Most Overlooked Paragraph in the OSHA Standards

 THE OSHA TRAINING BLOG HAS MOVED TO OUR NEW WEBSITE. VISIT US AT https://oshatraining.com/osha-training-blogs/

Comprehensive Lists of OSHA Training Requirements Now Available - Perfect Tool for Planning and Audits

 THE OSHA TRAINING BLOG HAS MOVED TO OUR NEW WEBSITE. VISIT US AT https://oshatraining.com/osha-training-blogs/

 

Have you ever visited the OSHA website and looked at their sizable selection of OSHA publications available to view and download? Some of them are excellent publications, some are so-so. But over the years, the one that I got the most use out of (by far) was titled “Training Requirements in OSHA Standards and Training Guidelines”, issued in 1998. As the name implies, the publication lists excerpts from the OSHA regulations where employee training is required. Unfortunately, the document is 14 years old now, and I suspected it was out of date. 
 

I started looking harder at the document last fall, and realized just how outdated it had become. There have been a few new OSHA standards issued since 1998 that require employee training. Quite a few OSHA standards that required training have been revised since then, too, and even a couple of them deleted. Being a little bit OCD (really), I decided to keep digging and create my own, updated list of OSHA standards that reference training; I nearly bit off more than I could chew.

I poured through the current OSHA regulations for general industry and construction (I’m still trying to decide if I should try and tackle maritime) to find all the references to employee “training” that I could. I also looked for OSHA standards that require the employer to “inform employees”, “make sure employees are knowledgeable about”, use a “certified” worker, designate “competent persons” or “qualified persons”, and similar verbiage that implies some level of employee training. After a few months of research, I had compiled over 250 pages of information, quite a bit more than appeared in the original OSHA document.  I decided this information was too valuable to keep to myself, so I published the results on our brand new website, oshatraining.com - (yes, I finally got the darn website finished).

You may be quite surprised (as I was) how many obscure references to OSHA training are buried in the OSHA regulations. As a result, my future OSHA training audits will be more comprehensive. There are also some surprising irregularities in OSHA training requirements. For example, the section of the OSHA regulations with the most references to employee training (by far) are the standards for cranes and derricks used in construction;  the section with the fewest references to training (only one) are the standards for cranes in general industry.  It also struck me as scary how many sections of the OSHA regulations have absolutely no reference what-so-ever about employee training!

Keep in mind this was a non-exhaustive review of the OSHA standards, meaning there could be something I overlooked that did not get listed. So please use this information as it was intended, as a guideline to help you home in on areas that require training, while keeping in mind that due diligence requires you to always reference the official OSHA CFR to make certain you have everything covered. And if any of you Safety Pros out there see a particular OSHA training regulation I overlooked and are kind enough to let me know, I will update the website where required.

Here are the links to the OSHA training requirements for General Industry, and the OSHA training requirements for Construction. It is my hope that my fellow safety professionals and all the employers who are regulated by OSHA find this information as useful for planning and audits as I have.

If you have a comment you want to make about our blog, including suggestions for future posts, please do so in the space provided below. And feel free to pass a link to this blog post along to others in your network who you think may benefit from this information.