Newsletters

The Safety Net is a newsletter published by NETC. The following articles were from the Summer 2003 edition.

From the President....

Seeing school is back in session, let’s have a pop quiz. Except here, the answer has real life implications, often though, not always yours. Complete the following riddle: When times get tough...

1. the tough get going—(right out the door)
2. we trim line items and budgets
3. we re-engineer

Notice a common theme here, one that’s all too prevalent in today’s society? In order to maintain and achieve our bottom line goals—profit, we sacrifice and risk the very fiber of those achieving this great goal: Worker Safety. Now I’m not here pretending to be an employee advocate, however, without them, you would be nowhere. So why do we treat them indifferently, and I don’t mean maliciously maltreat, but by not adhering to or abiding by basic safety principles, we are in fact, maltreating our employees.
     For the second time in about a years time, OSHA has announced its ‘hit list’ if you will. It means it is focusing on those companies whose Lost Work Day Injury and Illness rates (LWDII) exceed the national average. This is compiled from the very data off your OSHA 200 logs that you submit every year. This is, in essence, a public statement on the state of your safety management programs.
     In spite of all the publicity OSHA has received recently, it continues to amaze me how employers continue to use ignorance as an excuse for not complying with the law. It must have been the Safety Directors problem. Remember though, it is the CEO of the company that is signing the OSHA 200 logs certifying and attesting to the fact you are not compliant or safe. It is also the CEO who has ordered remaining employees to do more with less; has let the Safety Director go and has ordered supervisors to be responsible for all the safety issues, training, record keeping, manual preparations, etc. that was done by the former safety professional—the one who otherwise could never have been able to run your presses or machines like you do.
      We no longer can afford to train our employees adequately in safe practices, they just need to osmotically come to work with these habits. There are companies who actually feel if they post a poster on the shop door stating ‘Everyone in this factory must work safely’, and expest that they are absolved of liability because they have warned and instructed their employees to be safe. Please, take a look at your safety programs, your training records and programs, but most of all, invest in your employees, and you shall reap the rewards of this investment. Don’t think for a moment you are exempt from OSHA, or fall into the ‘it will never happen to me’ mode of thinking. In the end, you may have just found a way to actually ‘re-engineer’ yourself right out of business.

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Blood borne Pathogen Standard Revision
By: David Lundquist
Director of Training

OSHA has published the revisions to the Blood borne Pathogen Standard (29CFR1910.1030) that was originally released in 1991. This revision places new requirements for compliance that include keeping a sharps injury log and additions to the Exposure Control Plan. Further emphasis is placed on the use of engineering controls to reduce the estimated 600,000 percutaneous contaminated sharp injuries experienced by healthcare workers every year. Engineering controls are the preferred method to protect workers from hazards, including sharp injuries. The revision specifies that “safer medical devices, such as sharps with engineered sharps injury protection and needleless systems,” must be used where feasible. This is not a new requirement. The original standard required that “engineering and work practice controls shall be used to eliminate or reduce employee exposure.’’
     There has been much progress in the development of these protective devices for sharps and needle less systems. You need to evaluate available devices (using employee input, see below) and implement such devices now. Evaluation of devices is a required annual event along with your entire Blood borne Pathogen Exposure Plan. Include the evaluation process and the chosen engineering controls in your exposure control plan. Although not addressed in the standard, best practice would include any introduction of new equipment evaluated at different intervals to assure that the equipment is appropriate and being used correctly. Document this process as well. Training and documentation of such, with the introduction of new equipment is required.
     Employee input must be solicited for the identification, evaluation and selection of engineering controls. Note that input is required for all three phase of this and may be used to serve all situations. Of course input from managers is also important, but the standard specifies non-management employees. The process for input must be documented in your exposure control plan. This may be by reference to another committee or copies of documents process. These non-managerial employees must represent the range of exposure situations that are present in your work environment.
     There are very different exposures and equipment used on a pediatric unit verses a rehab unit and not one piece of equipment to request input or records of responses. A list of employees involved along with process description meets this obligation.
     The Exposure Control Plan has always included an annual review and update. You must now include changes in technology to reduce occupational exposure and consider the availabilty of safer devices. Documentation of this process includes the devices evaluated, the methods used to evaluate these candidates and justification for their eventual selection. Again, best management practice would include justification for not selecting products as well. With today’s changing structure of healthcare, many facilities find themselves with more complex patients. These patients may change the type or degree of exposure to healthcare providers. Remember to review your exposure assessment at least annually as required and with the introduction of patients that present with technology or medical conditions not previous experienced in your facility.
     Record keeping rule changes are the requirements of a sharps injury log. This log must contain the following information:

• type and brand of the device involved
• location of the incident
• description of the incident

Further information is not required, but may be included. You can determine the format of the log. And remember, privacy for the employees must be maintained. Unlike your OSHA 200 log, this log would include sharp injuries documentation even if no medical treatment is required.
     These revisions are effective as of April 18, 2001 with OSHA enforcement of these changes starting after a 90 day outreach effort that ends July 17, 2001. This is an excellent time to fully review the OSHA Standard and NIOSH recommendations (do not overlook airborne pathogen transmission) and of course the impetus for the OSHA revisions, the Needle Stick Safety and Prevention Act.

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Record Keeping Update
By: Andrea Greene, MBA, IH Senior Safety Specialist

The OSHA record-keeping rule will go into effect January 1, 2002. What does this mean for you as the keeper of the workplace injuries and illnesses records? What are the changes? Why did they do this?
     This new rule has been revised to make you life as the “keeper of the records” easier. The rules are simpler and easier to understand. One of the goals behind the revised system is to create better information about occupational injuries and illnesses so that workplace hazards can be easily identified. In turn, meaningful corrective actions can be put into place. Another goal is to protect employees’ privacy. The current record keeping requirements have been in effect since 1971. Just like anything else that is 30 years old, some preventive maintenance is required, wouldn’t you agree? Just like before, employers with 10 or less employees are exempt from most of the requirements. Also, the low-hazard classified industries such as retail, service, finance, insurance and real estate sectors are also exempt. Remember that all employers covered by Occupational Safety & Health Act must continue to report any workplace fatality or hospitalization of three or more employees.
     Some of the changes include provisions for recording needle stick and sharps injuries to coincide with the revised blood borne pathogens standard. (Please refer to “Blood borne Pathogen Standard Revision” article on page two of this newsletter.) A separate column has been added for recording musculoskeltal injuries or MSDs. Both of these provisions are expected to increase the number of incidents reported.
     There is also clarification regarding the recording of restricted work. There is now a clearer definition as to what constitutes light duty or restricted work. Ever wonder whether an injury is work-related or not. There are better guidelines for identifying work-related injuries and those that just happen at work but not related to work.
     The revised regulation is written in a question and answer format much easier to understand. Checklists and flowcharts are also used to simplify the requirements.
The OSHA requirements of the record keeping rule are the basis for collecting the information on Occupational Injury & Illnesses. The Bureau of Labor Statistics (BLS) gathers this data for OSHA which sets and enforces regulation for workplace injuries and illnesses utilizing this information.
     In summary, there are three new forms (all on smaller legal sized paper): OSHA 300, the log of work-related injuries and illnesses; OSHA 301, the incident report, including more data on HOW the injury or illness occurred; OSHA 300A, summary of work related injuries and illnesses. All of the following work-related injuries and illness must be recorded: Death, Days away from work, Restricted work or transfer to another job, Medical treatment beyond first aid, Loss of consciousness, Diagnosis of a significant injury/illness by a physician or other licensed health care professional. Recording preexisting injury or illness requires a significant degree of aggravation.
     Work-related exemptions include: Eating and drinking of food and beverage, Common colds, Blood donations & Exercise programs. Recording “Light duty” and restricted work cases must be activities preformed by the employee at least weekly. Recording required of all needle sticks and sharps injuries contaminated by another persons blood and body fluids. Elimination of “Lost workdays” replaced with days away from work, restricted work or job transfer. Work days changed to calendar days.
     Communication and training required for employee awareness injury and illness reporting procedure. Employee representatives now have access to the OSHA 301 form.
     Post annual summary for three months instead of one. Company executive must certify log. Some motor vehicle and motor carrier accidents including fatalities and catastrophes may be excluded from reporting. A special note: The current regulations are in effect until January 1, 2002. After that date the 1986 Record keeping Guidelines for Occupational Injuries and Illnesses will no longer be in effect, in addition to all previous letters of interpretation. If you have any question, please give one of our Safety Specialists a call or check out the NETC website at www.netcinc.com for the links to the OSHA.

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Middlesex County Chamber of Commerce hosts OSHA General Industry Safety Course

Middlesex County Chamber of Commerce hosts OSHA General Industry Safety Course New England Training & Consulting is providing it’s Fourth Annual 10-hour OSHA Compliance Safety Course focusing on the General Industry Standards. This 2-day course will be held at the Middlesex County Chamber of Commerce in Middletown, CT on November 15 & 16th from 8:00 AM to 5:00 PM
     This course will provide participants with an intensive review and understanding of the OSHA standards.
     Please contact either the Chamber at (860) 347-6924 or NETC at (860) 342-4382 as soon as possible to assure seating, as seating is limited.
     On behalf of the staff of New England Training & Consulting , I would like to extend our warmest thoughts and prayers to those who may have lost friends, co-workers or family in the New York Disaster. We would also like to offer any assistance possible and necessary to those companies who may have lost or are planning to lose any Safety Professionals to the Military call-ups. NETC provides in-house retainer services to many clients, and can easily and quickly supplement your safety programs with very little transition time. As a show of respect, we are offering a 20% discount to any new client calling for assistance as a result of being impacted by the disaster. We are not looking to capitalize on this tragedy, but are trying to help those in need and simply cover costs.
     Please call Bob Ziegler, President, directly to schedule a meeting or to discuss any details.
     Remember, United We Stand, Divided We Fall.
     With all of the recent events both locally and nationally, we want to remind everyone that this is the time to thoroughly review, revise or develop as necessary all parts of your Emergency Response Plans, Operations Plans, what ever you’re calling them. Be sure to include sections on Security issues, including work place violence; bomb threats; hazardous material spills; bio terrorism or WMD (Weapons of Mass Destruction) issues. I don’t think I have to explain why these are important, but while you’re looking at the upgrades, think about some basic concerns. Issues like, are you predictable in your responses? Are your employees predictable in their responses? Will they always evacuate a building and stand in one location? Understanding that with violence and terrorism, you may be more vulnerable outside congregated in one group then separated inside your building. So, do you evacuate or not? Secondary events are what we are most vulnerable to.
How often do you conduct a fire drill? Will employees even know what to do? If you don’t practice, you may never know. Security issues are fast becoming an integral part of ERP’s. Don’t discount this from yours, or discount our abilities to assist. NETC has the knowledge and capabilities in these areas.
     A second area of particular interest is Confined Spaces. At the recent National Safety Council Seminar, representatives from OSHA announced that they will be beginning to take a closer look at how companies are complying with the standard and how they are performing the required functions. Of particular interest will be Appendix F referencing ‘Rescue’ and ‘Self Rescue’. Many if not all companies are deficient in this area. Many companies are also still working under the premise that rescues will be done by the local fire departments. This couldn’t be farther from the truth, or capability. OSHA has also indicated that they do not accept this thought process as feasible or acceptable.
     For the last several months NETC has been working out the logistics of providing a non-emergency ‘confined space rescue service’. This would be a scheduled service for companies knowing they have to enter a space for a particular need, and need a ‘rescue’ component. The values of this are many: virtually no capital expenditures for equipment for the company, no annual (maximum time, quarterly is recommended) training, no equipment maintenance or repair, decrease of displaced employees during training and evolutions, a very potential decrease in Insurance premiums—avoiding risk avoids loss. Aside from the fact that, are you prepared to recover one of your own employees, especially with some of your own, and what if it was because of your issues? You have now lost more than just one employee.
     In order for us to move on, we need to know what are the thoughts and needs of the business community. Would you be interested in such a service? What would be the potential frequency of such use be? Would you take advantage of the peripheral services such as: general entry training, (how often do you train or recertify?) program development, hole identifications and listings, etc.? We are very interested in hearing from you. These responses will help direct our response and capabilities for you in the future, as we are always looking for ways to improve our services and core mission: “To provide a Proactive Approach to Safety in the Workplace”.
     Please take a moment to complete and return this section, or email us a response, or call us directly. We would greatly appreciate it.

……………………………………………………………
Company Name:___________________
Contact Name:___________________
Title:______________________
Address:______________________________
Phone:_______________ Fax:_____________
Email:_____________________
No. of ‘Permit Required Spaces’ on-site:______
‘Non-permit required’:______
No. of entries performed in a month:____________
In a Year:_____________
Do you have an on-site rescue team currently?:_________
Would you be interested in such a contracted service?:______
Do you currently have ‘rescue’ equipment?:_________
type:_________________

Send to:
NETC
P.O. Box 911
Portland, CT 06480-0911

or Fax to: (860) 342.5480

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