General Safety

Pour Me Another Cup of Coffee

Jones Posted by Anthony G. Jones, R.N., COHN

Pour Me another Cup of Coffee… for I am a truck driving man” comes from the song “Truck Drivin’ Man” recorded by Buck Owens in 1965. This blast from the past came to mind when thumbing through a recent AAOHN journal. I came across an article referencing a Virginia Tech Transportation Institute (VTTI) study on caffeine and truck driving.1  The study looked at the relationship between caffeine use, sleep, and “Safety Critical Events” (SCE). An SCE is described as a collision, tire strike, near-collision, unexpected lane deviation, or collision related conflict. 

The VTTI study, conducted over a four-month period, used long and short haul drivers from four companies. The subjects drove instrumented trucks, which included cab mounted video and driver maintained logs recording their sleep patterns and caffeine use.  Any SCE events were evaluated by researchers watching the video feeds in conjunction with the subject’s log books.

The study revealed that caffeine did not interrupt the sleep of drivers who were habitual users of caffeine. Drivers in the study actually slept longer during their “on duty” sleep periods than during their “off duty” sleep periods. This was despite increased caffeine use during “on duty” periods. Although it was noted in the study “participants experienced less sleep than the time historically considered adequate for safe driving performance.”

That was interesting, but what really got my attention was this finding: “Overall, a 6% reduction in the rate of SCE per eight (8) ounces of caffeinated beverage consumed.”

The positive and negative effects of caffeine are well known. It is one of the most used stimulants and commonly found in coffee, tea, energy drinks, and soft drinks.  According to WebMD, caffeine works by stimulating the central nervous system, heart, muscles, and the centers that control blood pressure. Caffeine can raise blood pressure, but it might not have this effect on people that use it all the time.  It can also act as a “water pill”, or a mild diuretic. But again, it may not have this effect on people who use caffeine regularly. Caffeine improves mental alertness and is used in combination with painkillers such as aspirin and Tylenol to treat simple and migraine headaches. 

Up to 400 milligrams (mg) of caffeine a day appears to be safe for most adults, according to the Mayo Clinic.  That’s roughly four cups of brewed coffee, 10 cans of cola, or two “energy shot” drinks.  Heavy use of more than 500 to 600 mg a day may cause such symptoms as insomnia, nervousness, restlessness, irritability, stomach upset, fast heartbeat, and muscle tremors. 

The VTTI study suggests SCE’s may be reduced for those who have the caffeine habit. The VTTI study suggested “caffeine use among habitual users offers some protection against SCE without negative effect on sleep.”  However, two groups did not improve. Drivers aged 30 to 39 had an increase in collisions, and drivers aged 21 to 29 experienced an increase in unexpected lane deviations. The report indicated it wasn’t clear if those age groups were more distracted by secondary activities, or risky behavior such as speeding or tail-gating.

An Australian study also found caffeine use had a positive benefit in SCE reduction. The study used more subjects, a control group, and ran longer than the VTTI study.  “Our findings suggest that the consumption of caffeinated stimulant substances is associated with a significantly reduced risk of involvement in a crash for long distance drivers in Australia,” the study concluded. “The use and influence of caffeinated stimulants should be considered as an effective adjunct strategy to maintain alertness while driving.”

It appears the use of caffeine can have a benefit in reducing overall truck accidents and near miss incidences. That’s the good news. The bad news is truck drivers are not getting adequate sleep.  Significantly, as shown in the Australian study, the SCE benefits only came with high consumption of caffeine. There was no real improvement for those with low or moderate caffeine use.

Significantly, according to Lisa Sharwood, M.S., one of the Australian study authors, “While caffeine may seem effective in enhancing their alertness...it should be considered carefully in the context of a safe and healthy fatigue management strategy… Energy drinks and coffee certainly don't replace the need for sleep.” 

For more information regarding sleep and safe driving, check out the resources available at DrowsyDriving.org., and the Virginia Tech Transportation Institute.

 

1 American Association of Occupational Health Nurse Association (AAOHN) “Workplace Health and Safety” August 2015 Vol. 63 #8.  “The Effect of Caffeine Use on Driving Safety Among Truck Drivers Who are Habitual Caffeine Users.” Authored by Karen Heaton PhD, FNP-BC and Russell Griffin PhD.

 

 

 

 


Safety Shoes – Selecting the Right Shoe for Your Workplace

LevesquePosted by Adam Levesque, MBA, CSP

What better day to discuss this topic than “Shoe the World Day?”  There are multiple factors to consider when selecting the most appropriate foot protection.  The goal is to make sure that your feet are comfortable, supported, and protected.  In a recent post, we demonstrated that a pair of safety shoes is an effective piece of personal protective equipment.  However, the hazards are not only falling objects or fork trucks rolling over toes, but discomfort due to improper fit and selection.  Choosing the appropriate safety shoe could prevent foot related problems like bunions, corns, calluses, hammertoes, and even prevent discomfort to the legs, hips, and back. 

Consider these tips when selecting your next pair.

  1. Safety should be the initial consideration when selecting the correct pair of protective footwear. There are many options in the market but you should choose a pair that will protect your feet from the hazards present.  A combination of safety toe caps, metatarsal guards (protection for the top of the foot), steel plate soles (puncture resistant), sole material (slip resistance, electrical insulation, flexibility, and hardness), and overall construction materials used should be considered. 
  1. Fit is very important! Did you know that the human foot actually grows during the day and shrinks while you sleep? While that’s not entirely true, everyone’s feet are slightly larger after a hard day’s work.  This means the end of the day is the best time to try on a new pair of shoes or boots.  Making sure your new shoes fit well is key to preventing future discomfort.  About one-third of adult men are wearing shoes that don’t fit properly, so take the time to ensure you are selecting the proper size.   
  1. Comfort is a must! The majority of quality safety shoes and boots will not stretch or need a break in period.  Make sure that when you’re test driving potential footwear, your feet are immediately comfortable.  Areas of comfort include appropriate space in the toe box, no pinching or cramping at the ball of the foot or toe area, and adequate support in the arch and heel. Make sure the padding and materials used are adequate for your work climate.  Utilizing a shoe with moisture control technology for both warm and cold climates is a great option, but can affect how your shoe fits.  When feet are comfortable, your knees, hips, and lower back are better aligned and supported.

Be aware that no footwear can provide protection against all injuries.  Hazards must be controlled by elimination, engineering controls, and administrative controls primarily.  Relying on PPE alone is not acceptable.  However, by selecting the correct shoe for your work environment and personal needs, you will have the best personal protection for preventing foot related injuries should other controls fail. 

Additional information on safety footwear is available from several online sites including The American Orthopedic Foot and Ankle Society, WorkingPerson.me, National Safety Council,  OSHA, and Grainger.   


Load Limits for Structurally Supported Surfaces

LarochellePosted by Greg LaRochelle, WCP

The last line of the lyrical refrain in the 1968 hit song “The Weight” by Canadian-American rock group The Band reads, “You put the load right on me.”  In the context of a work environment with a mezzanine storage platform, this verse conjures up a mental picture of disaster for anyone who might happen to be underneath the platform if it were to suddenly collapse.  OSHA addresses this load limit concern in their recently updated Walking-Working Surfaces standard, 29 CFR 1910.22, general requirements, as follows:

    1910.22(b) Loads. The employer must ensure that each walking-working surface can support the maximum intended load for that surface.

It’s important to note the previous general industry rule, 1910.22(d), required that “a plate of approved design indicating the floor load capacity must be posted.”  In a letter of interpretation, OSHA states, “There is no longer a requirement for a floor loading sign; however, the employer must ensure that employees involved in warehousing or storage activities know the intended load limits. This applies to ‘structurally supported surfaces.’”  

The general requirements of the standard also cover inspection, maintenance, and repair with the employer to ensure:

  • Walking-working surfaces are inspected, regularly and as necessary, and maintained in a safe condition;
  • Hazardous conditions on walking-working surfaces are corrected or repaired before an employee uses the walking-working surface again. If the correction or repair cannot be made immediately, the hazard must be guarded to prevent employees from using the walking-working surface until the hazard is corrected or repaired; and
  • When any correction or repair involves the structural integrity of the walking-working surface, a qualified person performs or supervises the correction or repair.

While there are several online resources for calculating floor load capacity, it is advisable to have a professional engineer calculate the maximum intended load.  In a manner of speaking, maintaining the structural integrity of a storage platform along with ensuring its maximum load capacity is not exceeded is intended to ensure “the last waltz” doesn’t happen to an employee working on or under the supported structure.

MEMIC policyholders have access to a General Industry Self Inspection Checklist in the Safety Director Resource Library.  

 

 


Redefining the Workplace

BrownPosted by Allan Brown, PT

It would seem that everyone would like to work at Google. Google’s efforts to create the happiest place to work include more than complimentary gourmet meals, massages, “nap pods” and other lavish perks.  Their efforts center around a different way of looking at the workplace with a focus on my specialty, ergonomics.  Ergonomics is human engineering, designing things or spaces so people can utilize them more comfortably, efficiently and safely.

Fortunately, workplaces around the country are following Google’s lead. Organizations in every industry are realizing that their people are their most important assets and their workplace must be optimized for them. Here are some of the top workplace trends I see as organizations endeavor to increase productivity, improve employee health, and retain employees for the long term.

Collaboration is encouraged.  Workers must be given more diverse spaces and the autonomy to move around those spaces. Many workplaces are creating collaboration spaces of different sizes so people aren’t trapped at their desks or battling over the large conference room.  The effective open office is about space reflecting and enhancing organizational culture. Opening doors, increasing communication and collaboration, and breaking down departmental silos is the new paradigm.

Mobility is king. The workplace is dynamic, don’t be left sitting still or you will be left behind. Technology has allowed people to untether from the desk. The BlackBerry thumb has been replaced by Smartphones, tablets, and laptops.  Many organizations are replacing desktops with laptops and docking stations so employees can work seamlessly in the field, move about the office and utilize the collaboration spaces created.

The emphasis on mobility is coming just in the nick of time.  The percentage of obese and overweight workers has reached epidemic proportions. The health impacts of a sedentary workplace have led some experts to say, “Sitting is the new smoking.” Dynamic sit/stand workstations have been adopted in offices across the country so workers can transition from sitting to standing throughout the day and not be trapped in one unhealthy posture.  Should you sit or stand at your desk?  The answer to the question is both. It’s the ability to change positions that creates the opportunity for wellness.

Aesthetics is functionality. An open office must take into consideration the whole person and the whole work experience. The work environment should optimally address all the senses and create a coherent whole that complements your organizational culture. Think sight, sound, and smell. What is your office decor? Are the colors for different spaces appropriately relaxing or stimulating? Do you have a scent/fragrance policy? Is there proper ventilation, especially around the break room? What is the noise level? Do you need sound proofing, white noise machines, or to designate certain disruptive tasks to specific spaces?

It’s not about money, it’s about attitude. Yes, Apple is spending $5 billion building a new campus but ergonomic solutions don’t need to be expensive. Start with your employees that sit the most and create an environment that allows them more freedom of movement throughout the day. It’s the little things that show employees you see them and value them as individuals.  The key to human engineering is adapting your workplace to fit your people, not the other way around.

Individual workstation setup is more important than ever.  Even small changes can bring ergonomic benefits.  To learn more about office ergonomics please join me for a 30 minute webinar at 10:00am EST on March 9, 2017 entitled “Office Ergo:  Little Changes Make a Big Difference.” 

Click here to nominate MEMIC Safety Net as your favorite workers' comp safety blog!


Personal Safety – Listen To Your Inner Voice

Randy-Morehouse-bio Posted by Randy Morehouse

During a recent safety training session the subject of famous last words came up.  The favorite last words turned out to be, “Hey! Watch this!”  We can all imagine any number of ways that this ends with someone getting hurt.  In fact, television shows, social media sites, and the internet in general are full of bad endings.  Usually we smile and wonder, “What were they thinking?!”  Unfortunately, the reality of a workplace injury isn’t funny and it ends up costing everyone.  According to the Bureau of Labor Statistics, in 2015 there were over 2.9 million private industry recordable injuries. 

We all have an inner voice that says, “This could go badly!” right before we do something unsafe.  It is the same voice that says, “Told you so!” when things do go wrong.  For some this voice is loud and demanding.  For others it is timid, barely heard and seldom listened to.  We all have it; whether we choose to listen to it or not is our choice.  However, safety culture also plays a significant role in determining how often this voice is heard.

Think of this inner voice as your built-in self-preservation device.  It is there to keep you safe and requires attention.  There are many reasons why this voice is brushed off.  But employers have an obligation to provide workplaces where employees are encouraged, or better yet required, to act responsibly and safely in all aspects of their jobs.  Listening to the inner voice becomes much easier when the organizational culture supports safety at all levels and asks for employee input.   

For example: what if you had to walk across an icy parking lot to enter your workplace?  Your inner voice has let you know that you might fall.  What do you do? 

  1. Walk across it as you do every day and just hope for the best?
  2. Call for assistance?
  3. Park closer to the entrance to limit the exposure to the ice?
  4. Put on those ice cleats that you were issued?
  5. Spread some sand on the walkways as you enter?

If option A is chosen, the opportunity to act safely and reduce or eliminate the risk has been missed.  In this single situation we may have made it across the parking lot, but understand that the likelihood of injury is directly related to how often we choose to listen before acting.    

Crossing an icy parking lot is one of many unsafe acts that occur with regularity.  Here are some other choices people make that affect their safety:

  • Lifting a heavy object                                   
  • Wearing footwear that is not slip-resistant
  • Leaving a trip hazard or a spill on the floor          
  • Driving too fast for the road conditions
  • Using a cell phone while driving

If we choose to regularly ignore our inner voice, eventually we will be hurt.  The more we listen to, and act on, what our inner voice is saying, the less likely we are to be injured.  It takes practice and deliberate action to improve our safety in everyday situations, but the good news is that the more we listen to our inner voice, the louder it gets and the easier it is to follow it.  A supportive safety culture also makes it easier to do the right thing. 

Thankfully our inner voice is with us everywhere.  Whether it is at work, at home, or while driving, it is there and needs to be listened to.  If you are a supervisor make sure you are listening to your inner voice, but also make sure that you are allowing your employees to do the same.  If production ends up having the loudest “voice” then safety voices can be drowned out. 

If you are looking for ways to improve workplace safety, give every employee a voice in the matter.  Dan Petersen is featured in an EHS Today piece entitled “Dan Petersen: Why Safety is a People Problem.”  Check it out; it might help you better understand the importance of personal responsibility and how organizational cultures can either improve or hinder employee safety.  

Listen to your voice, and encourage your coworkers do the same! 


Back Belts – Do They Prevent Back Injuries?

SylvesterPosted by Rob Sylvester, CEHT

Back injuries are common in many industries, and can be extremely debilitating.  According to the Bureau of Labor Statistics, there were 155,740 private industry back injury cases in 2015.  That’s over 400 cases per day!  How do we prevent so much pain and lost productivity?  Should we give back belts to everyone that lifts or “moves stuff” as part of their job?  Should we give them to someone that has already had a back injury? In this post we’ll take a closer look at the first question.  The latter is something that should be discussed with the treating therapist and/or medical provider and will not be covered here.

What do the experts say?

In 1996, the National Institute of Occupational Safety and Health (NIOSH) responded to an increase in advice on back belt selection. In their response, the Institute decided to address a more fundamental question. Rather than ask "Which belt will best protect workers?" NIOSH researchers began with the question, "Do back belts protect workers?"

NIOSH “does not recommend the use of back belts to prevent injuries among workers who have never been injured. If you or your workers are wearing back belts as protective equipment against back injury, you should be aware of the lack of scientific evidence supporting their use.

Harvard Medical School supported these findings in 2012“Several studies have cast some doubt on whether back belts (also called back supports or abdominal belts) help protect workers' backs or reduce sick time and workers' compensation claims. One report, published in the Journal of the American Medical Association, found that these belts didn't curtail back injuries. In this two-year study, which included several thousand employees who handled merchandise, the use of back belts didn't reduce either the incidence of low back pain or the number of back injury claims. Another study looked at two groups of people with work-related low back disorders.  Those in one group were asked to wear back belts and receive education on back health.  Those in the other group received the educational component only. There was no significant difference in the recovery of the two groups.”

Rather than relying on a back belt to prevent back injuries, incorporate safer work practices. Since the majority of back injuries result from lifting, twisting or material handling, solid ergonomic programs are a key to success.  Here are some thoughts and tips.

Together, we can continue to make America’s workforce safer!

 

 


OSHA’s Updated Electronic Recordkeeping Rule: Are you Prepared?

  LevesquePosted by Adam Levesque, MBA, CSP

OSHA has updated their recordkeeping requirements for employers across many different industries in an effort to ensure the completeness and overall accuracy of injury and illness information.  The update requires employers to inform employees of their right to report work related injuries and illness free from retaliation, clarifies the requirement for employers to establish a documented procedure for reporting and managing work related injuries which do not deter or discourage reporting, and includes an updated statute prohibiting employers from retaliating against employees who report work related injuries and illnesses.

Of particular note, the new rule, which took effect January 1, requires specific employers in pre-identified industries to electronically submit their injury and illness data.  The required information for electronic submittal includes the same data that employers are already collecting and reporting annually on the OSHA injury and illness forms.  OSHA will analyze and publically publish the information submitted by employers with the intent to motivate employers to improve health and safety performance.  The database of public injury and illness information will allow businesses to benchmark their performance against others in like industries.  The accessible data will also allow potential employees, customers and the public to see where health and safety of workers stands within businesses.

The updated electronic reporting requirement is being phased in over the next two years.  OSHA has separated the affected establishments into two categories: employers with 250 or more employees, and employers with 20-249 employees in high risk industries which are classified by an industry NAICS code.

Recordkeeping

OSHA states that the total number of employees is based on a single physical location where operations are conducted or services are provided.  The total employee count must consider an establishment’s peak employment during the reporting year which includes seasonal, temporary and part-time workers.  As an example, if your business is not in a high risk industry and has 400 employees in four different locations with 100 employees in each location, then electronic reporting is not required.  Subsequently, if your business is in a high risk industry and has 50 employees in two locations with 40 employees at one location and 10 employees at the other, then electronic reporting would be required only for the operation with 40 employees. 

During 2017, the first year of implementation, employers who fall into either of the above categories must submit 2016 data recorded on the 300A form electronically by July 1, 2017. During the second year of implementation the same employers must submit 2017 injury and illness data contained on all three OSHA forms (300A, 300 and 301) by July 1, 2018.  Beginning in 2019, those employers will be required to annually report all OSHA forms electronically by March 2.

Once you have made the determination on your establishment’s reporting requirement applicability, you need to know where you can submit your information.  OSHA has stated that there will be three options available for submitting data: manual data entry via web form, upload of a single CSV (excel type) file which will allow for the submission of multiple site information, and transmission of electronic data through a custom software application available from OSHA.  The site is scheduled to launch in full in February, however OSHA has already released the CSV template and information on the software application.

It is worth noting the potential impact of the recent memorandum issued by the Trump Administration related to federal agencies sending new regulations to the Office of the Federal Register.  This may “temporarily postpone” the implementation of this, and other, OSHA regulations. 

According to Mark Ames of the American Industrial Hygiene Association, “…the White House issued a regulatory freeze impacting all pending regulations – including final rules that have yet to be fully implemented… This seems straightforward, but there’s actually a lot of vague language in the memo that can be interpreted in multiple ways, making the specific impacts on worker health and safety hard to predict. While agencies are rushing to provide guidance on which rules are subject to the freeze, this period of regulatory disruption is likely to continue for some time, even after President Trump’s nominees have been installed, since the president has ambitious plans for cutting federal regulations, creating additional vast uncertainties.”

Nevertheless, bringing your company into compliance with this and all proposed regulations is likely the right path to take at this time. 

For more information see the resources below.

OSHAs Recordkeeping Webpage and Frequently Asked Questions

OSHA Fact Sheet – Final Rule to Improve Tracking of Workplace Injuries and Illnesses

OSHA Fact Sheet – Who is Required to Keep Records and Who is Exempt

Click here to read the rule


OSHA Issues Final Rule for Beryllium – Part III.

PierettiPosted by Luis Pieretti, PhD, CIH, CSP

In prior posts, we covered the new exposure limits for beryllium and the requirements for exposure assessment, work areas, written exposure control plan, engineering controls, respiratory protection and personal protective clothing and equipment.  In our final post of this three-part series, we will cover the information related to medical surveillance, training, recordkeeping and effective dates.  While the Trump administration is delaying this and other OSHA rules 60 days for review, bringing your organization into compliance with all proposed regulations is likely the right path to take at this time. 

Medical Surveillance

A medical surveillance program is required for Employees exposed to beryllium levels above beryllium’s new action level for more than 30 days, those who show signs or symptoms of chronic beryllium disease (CBD) or other beryllium related health effects, employees exposed to beryllium during an emergency, or those workers with a recent written medical opinion that recommends periodic medical surveillance.  The medical surveillance is required within 30 days of determining the need for a medical examination, or at least every two years.  The medical examination should include:

  • A medical and work history with emphasis on beryllium.
  • A physical examination with emphasis on the respiratory system and skin rashes.
  • Pulmonary function tests.
  • A standardized Beryllium Lymphocyte Proliferation Test (BeLTP) or equivalent test.
  • A low dose computed tomography (LDCT) scan when recommended by the physician or other licensed health care professional (PLHCP) and other tests deemed appropriate by the PLHCP.

Multiple requirements surround the medical surveillance program.  The details of the program, medical exams, medical removal eligibility, and associated employer responsibilities and employee rights can be found within the standard.  Refer to OSHA’s final rule for beryllium for more details should your organization determine that medical surveillance is required.  MEMIC policyholders are welcome to contact their MEMIC Safety Management Consultant.

Training

The employer must provide initial and annual training to affected employees about beryllium health hazards, including CBD signs and symptoms, the written exposure control plan, use and limitations of personal protective equipment, applicable emergency procedures, measures employees can take to protect themselves, purpose and description of the medical surveillance program, the standard content, and record access rights. 

Recordkeeping

The employer should maintain information about all exposure assessments:

  • Date of each assessment.
  • Task monitored.
  • Sampling and analytical methods used.
  • The number, duration and results of samples obtained.
  • Personal protective equipment used by monitored employees.
  • Name, social security number, and job classification of each employee represented by the monitoring, including which employees were actually monitored.

If objective data was used, the employer must document the data relied upon, the material containing beryllium, the source of the objective data, a description of the process, tasks, or activity in which the objective data were based, and other relevant data. Data related to the medical surveillance and training should also be kept.

Effective Dates (as originally published, now subject to the Trump administration regulatory freeze)

The final rule was to take effect on March 10, 2017.  Employers have one year to comply with most of the requirements, two years to provide any required change rooms and showers, and three years from the effective date to implement engineering controls.             

(The information provided here is a summary.  It should not be interpreted to be the complete text of the OSHA standard.) 

 


OSHA Issues Final Rule for Beryllium – Part II.

PierettiPosted by Luis Pieretti, PhD, CIH, CSP

This is the second post in a three-part series reviewing OSHA’s final rule for beryllium. In the first part of this series, we covered the exposure assessment, work areas, and written exposure control requirements.  This post covers the respiratory protection and personal protective clothing requirements as well as hygiene practices.

Respiratory Protection

The employer must provide respiratory protection during operations, maintenance activities, and non-routine tasks where engineering controls are not feasible and airborne exposures of beryllium are expected to exceed OSHA’s short term exposure limit (STEL) and/or permissible exposure limit (PEL).  Employers are required to provide a powered air purifying respirator (PAPR) instead of a negative pressure respirator where respiratory protection is required by the standard and an employee requests the PAPR, provided the PAPR provides adequate protection.

Personal Protective Clothing and Equipment

The final rule requires use of protective clothing and equipment where employee exposure exceeds, or can reasonably be expected to exceed the PEL or STEL, or where there is a reasonable expectation of dermal contact with beryllium.  The employer must also:

  • Ensure that each employee removes the protective clothing at the end of the work shift or when it becomes visibly contaminated with beryllium (following the procedures specified in the written exposure control plan as outlined in part one of this series).
  • Contaminated clothing or equipment removed from the facility should be transported in labeled sealed bags or other impermeable containers.
  • The employer also must ensure that all reusable clothing and equipment required by the standard is cleaned, laundered, repaired, and replaced as needed.
  • When using other companies to clean or repair the protective clothing or equipment, the employer must inform them in writing about the potential harmful effects of airborne exposure to and dermal contact with beryllium, and the contents should be handled in accordance with the standard.

Hygiene Practices

For each employee working in a beryllium work area, employers must provide:

  • Accessible washing facilities and ensure that employees who have dermal contact with beryllium wash any exposed skin at the end of the activity, process or work shift before eating, drinking, smoking, chewing tobacco, applying cosmetics, or using the toilet.
  • Change rooms should be provided if employees are required to remove their personal clothing.
  • The employer must provide showers where airborne exposure exceeds OSHA’s regulatory limits or where beryllium can reasonably be expected to contaminate employee’s hair or body parts other than hands, face, and neck.
  • Where showers are provided, the employer must ensure that each employee showers at the end of the work shift or work activity.
  • If employees are allowed to consume food or beverage at the worksite where beryllium is present, the employer must ensure that surfaces in eating/drinking areas are free of beryllium and employees should not enter the eating/drinking areas with protective clothing unless the beryllium has been removed from the clothing.

Housekeeping

The employer must maintain all surfaces in beryllium work areas as free of beryllium as practicable as stated in the company’s written exposure control plan. HEPA filtered vacuuming or other methods that minimize the likelihood and level of airborne exposure should be used.  Dry sweeping or brushing should not be allowed.  Compressed air should also not be allowed unless it is used in conjunction with a ventilation system designed to capture the particles made airborne by the compressed air.  If dry sweeping, brushing, or compressed air is used, the employee should be protected with a respirator and protective clothing.

Next week, in part three of this series we will cover medical surveillance, training, and effective dates of this final rule.

Click here to view OSHA Issues Final Rule for Beryllium – Part I.


OSHA Issues Final Rule for Beryllium – Part I.

  Pieretti Posted by Luis Pieretti, PhD, CIH, CSP

In January 2017, OSHA issued its final rule for beryllium.  Standards were issued for the general industry (1910.1024), shipyard industry (1915.1024) and the construction industry (1926.1124).  More information on where beryllium is present in the workplace and the previous standard can be found here.  As expected, the new rule reduces the permissible exposure limit (PEL) for beryllium to 0.2 µg/m3 averaged over 8 hours (time weighted average or TWA) and also establishes a short term exposure limit (STEL) of 2 µg/m3.  This is the first of a three part series that addresses the general industry requirements.

Be

Exposure Assessment

The general industry standard requires employers to conduct exposure assessments.  These include (as specified in the standard) initial monitoring to assess short term exposures for each work shift/each job classification and each area where operations are likely to produce airborne exposures above the STEL. Additional monitoring may be required if exposures are above the new STEL and/or PEL.  Monitored employees should be notified of the results.  Where the exposure assessment indicates airborne exposures above the STEL or PEL, the employer must describe in the written notification the correction action taken to reduce airborne exposure to or below the limit exceeded where feasible corrective action exists but had not been implemented when the monitoring was conducted.

Work Areas

The employer must establish and maintain beryllium work areas (areas where employees are or can reasonably be expected to be exposed to airborne beryllium levels above the regulatory limits).  Areas must be identified and access should be limited. All employees entering the regulatory areas must be provided with respiratory protection and personal protective clothing.

Written Exposure Control Plan

Additionally, the employer shall develop a written exposure control plan.  This plan should list the operations and job titles expected to have dermal contact with beryllium, or airborne exposure at or above the STEL or PEL. It should also contain procedures to minimize cross-contamination including transfer of beryllium between surfaces, equipment, clothing, and materials within the beryllium work areas.   A list of engineering controls, work practices, and respiratory protection should also be included.  Lastly, identifying required personal protective clothing and procedures for removing, laundering, storing, cleaning, repairing and disposing beryllium-contaminated personal protective clothing and equipment, including the respirators is required. 

This plan should be reviewed at least annually or when necessary as stated in the standard.  Reviews are required if:

  • Any changes in production that can reasonably be expected to result in new or additional airborne exposure to beryllium.
  • The employer is notified that an employee is eligible for medical removal, referred for evaluation or shows signs or symptoms associated with airborne exposure to or dermal contact with beryllium.
  • The employer has any reason to believe that new or additional airborne exposure is, or could occur.

Engineering Controls

The employer must ensure that at least one of the following controls is in place for each operation in a beryllium work area that releases airborne beryllium:

  • Material/process substitution.
  • Isolation (full or partial ventilated enclosures).
  • Local exhaust ventilation at the point of operation, material handling and/or transfer.
  • Process controls such as wet methods and automation.

If controls cannot lower the airborne concentrations below the PEL, the employer must implement and maintain engineering and work practices controls to reduce the airborne concentration to the lowest feasible level and supplement these controls with respiratory protection.  The standard also states that rotating employees to different jobs to achieve compliance with the PEL is prohibited.

In our next post, we will cover the requirements for respiratory protection, personal protective clothing and equipment, hygiene practices and housekeeping.