Fatal injuries in confined spaces average 92 fatalities per year, according to the US Department of Labor. That’s almost two per week. Many workplaces contain spaces that are considered confined. The configuration of these places hinders the activities of employees who must enter, work in, and exit them. A confined space has limited or restricted means for entry or exit.
Confined spaces include, but are not limited to underground vaults, tanks, storage bins, manholes, pits, silos, process vessels, and pipelines. Workers in many industries are required to access them in order to obtain equipment, make repairs, and perform routine maintenance.
The most common risks of working in confined spaces include:
Limited entrances or exits
Poor air quality
Exposure to gases and dangerous toxins (which are more likely to build up to dangerous levels in confined spaces)
Risk of fires or explosions
Drowning risk in trenches, pipelines, or water tanks
Construction workers often perform tasks in confined spaces. However, the risk is not limited to construction workers. Agricultural workers, electricians, and maintenance workers are also at high risk of being injured in confined spaces. Spaces such as pits, manholes, and crawl spaces are not designed for continuous occupancy. It can be very tricky to exit these. An emergency makes escaping even more difficult. Confined spaces can present life-threatening hazards. Hazards such as toxic substances, electrocutions, explosions, and asphyxiation. Exposure to these hazards can largely be prevented if addressed prior to entering the space to perform work.
By definition, a confined space is not designed for continuous employee occupancy. According to OSHA, it is the employer’s responsibility to evaluate the workplace to determine if any spaces are confined spaces. Indeed, worker training is essential to the recognition of what constitutes a confined space and the hazards that may be encountered in them. For instance, if it is a confined space, the next step is to determine if it is a permit-required confined space.
Permit-Required Confined Space Characteristics:
Contains or has the potential to contain a hazardous atmosphere
Contains a material that has the potential to engulf an entrant
Has walls that converge inward
Has floors that slope downward and taper into a smaller area
Could trap or asphyxiate an entrant
Contains any other recognized safety or health hazard, such as unguarded machinery, exposed live wires, or heat stress
In general, the Permit-Required Confined Spaces Standard requires the employer, to evaluate the workplace to determine if any spaces are permit-required confined spaces. If workers are authorized to enter permit spaces, a comprehensive permit spaces program must regulate employee entry into permit spaces. OSHA provides detailed specifications of the elements of an acceptable permit spaces program.
Further, permit spaces must be identified by signs. Entry must be strictly controlled and limited to authorized persons. An important element of the requirements is that entry be regulated by a written entry permit system. In addition, proper atmospheric evaluation and testing of the space before and during any entry by workers. Further, an entry must be monitored by an attendant outside the space. Additionally, a rescue plan is required in the event of an emergency. In order for a rescue to be successful, the confined space safety plan must be quickly accessible to all employees.
Worker training is vital to keeping workers safe. In fact, OSHA outlines training requirements and specific duties for authorized entrants, attendants, and supervisors. According to OSH Online, Eighty-five percent of fatalities in confined spaces were among people who hadn’t been trained. Therefore, it is clear, proper training can save lives. In the same way, the reality is with proper training and equipment, the loss of workers in confined spaces can be prevented.
Training for entrants, attendants, and supervisors
Acute or chronic effects of working in confined spaces
Permit-required confined spaces
Emergency rescue from confined spaces
Personal Protective Equipment in Confined Spaces
This training is appropriate for any workers who will work in or around confined entry spaces. As a result of completing this training, workers will be certified in the OSHA Standard 1926 Subpart AA and should be able to use sound judgment and work within confined spaces safely. Thus, this training is also suitable for supervisors, and managers. Similarly, it is effective to train the trainer or as a refresher course for seasoned employees.
Preventing many laboratory safety risks is possible. In general, laboratories tend to have more health and safety risks than other workplaces. According to OSHA, there are more than 500,000 workers employed in labs in the U.S. The laboratory environment can be a hazardous place to work. Consequently, it is vital to train lab workers to recognize hazards in their workplace. Furthermore, workers must protect themselves from those hazards by following safety practices in order to address the hazards that are present. Often workers are unaware of the potential hazards in their work environment. Unfortunately, this makes them more vulnerable to injury. Many hazards found in laboratories seem easy to spot; however, many are frequently overlooked.
Common Types of Laboratory Hazards Include:
Toxins, Flammables, & Corrosives
Fire, Malfunctioning Equipment, & Shock
Microbes, Plants, & Animals
Projectiles, Heating Devices, & Slipping
Many labs are more hazardous and risk-filled than the average workplace which makes understanding the hazards that are present in this work the first step to creating a safe environment for workers. Indeed, it is vital that all lab employees understand each and every hazard of the laboratory. Knowledge and clear safety practices can help protect workers from harm caused by hazards in the laboratory.
There are several specific OSHA standards that apply to laboratories. The Occupational Exposure to Hazardous Chemicals in Laboratories standard (29 CFR 1910.1450) was created specifically for non-production laboratories. Other additional OSHA standards provide rules that protect workers from various aspects of laboratory activities and hazards in laboratories.
Employers’ Responsibilities for Keeping Lab Workers Safe:
Thanks to the OSHA Laboratory Standard, effective safety and training programs have been implemented to train laboratory personnel in safe practices. A crucial component of chemical education is to nurture attitudes so that safety is included in all laboratory activities. Particularly, preventing laboratory safety risks is needed to be most effective, safety and health must be incorporated into all laboratory processes. Strong safety culture is the result of positive workplace attitudes, involvement, and buy-in, of all members of the workforce.
Additionally, employers are required to develop and carry out a written Chemical Hygiene Plan (CHP). A CHP is a written program stating the policies, procedures, and responsibilities. These policies serve to protect employees from the health hazards associated with the hazardous chemicals used in that particular workplace. Overall, the CHP contains work practices, procedures, and policies that should provide a safe and healthy environment.
Laboratories present many challenges. It is easy to overlook worker health and safety. However, we can prevent both job-related illness and injury with proper guidance and training. With the many types of hazards found in Laboratories, safety training is especially important. In order to meet the need for safety training, National Safety Compliance offers several lab-specific training courses.
Eye injuries in the workplace occur daily. According to the National Institute for Occupational Safety and Health (NIOSH), about 2,000 U.S. workers per day sustain job-related eye injuries that require medical treatment. However, safety experts and eye doctors believe proper eye protection can prevent 90% of these eye injuries.
The Occupational Safety and Health Administration (OSHA) requires workers to use eye and face protection whenever there is a reasonable probability of injury. Personal protective eyewear, including goggles, safety glasses, face shields, and sometimes even full-face respirators must be used when an eye hazard exists.
Chemicals or foreign objects in the eye and scratches on the cornea are common eye injuries that occur at work. Other common eye injuries come from fluids splashed in the eye, burns from steam, and ultraviolet or infrared radiation exposure. In addition, health care workers and other workers may be at risk of acquiring infectious diseases from eye exposure. This can occur through direct contact with splashes of blood, respiratory droplets generated during coughing, or from touching the eyes with contaminated fingers or other objects.
Other occupations with a high risk for eye injuries include:
It is vital for employees to know the requirements for their work environment. The type of eye protection needed depends on the workplace hazards. Safety glasses with side shields are appropriate for a workplace with particles, flying objects, or dust. However, goggles are required when working with chemicals. In a workplace with hazardous radiation (welding, lasers, or fiber optics) special-purpose safety glasses, goggles, face shields, or helmets designed for that specific task provide better protection for workers’ eyes. It is important to note that side shields placed on conventional glasses do not offer enough protection to meet the OSHA requirement for many work environments. In addition, employers need to take steps to make the work environment as safe as possible.
The type of necessary eye protection depends upon:
The type of hazard
The circumstances of exposure
Other protective equipment used
Individual vision needs
Two main reasons for eye injuries at work include not wearing proper eye protection and wearing the wrong kind of protection for the job. A Bureau of Labor Statistics survey of workers who suffered eye injuries revealed that nearly three out of five were not wearing eye protection at the time of the accident. Most of these workers reported that they believed protection was not required for the situation.
Steps for preventing eye injuries in the workplace:
Assess: Inspect all work areas and equipment for hazards to the eyes. Identify operations and areas that present eye hazards
Protect: Select protective eyewear designed for a specific duty or hazard. Protective eyewear must meet the current standards.
Fit: Workers need protective eyewear that fits well and is comfortable. Provide repairs for eyewear and require each worker to be in charge of his or her own gear.
Plan for an Emergency: Set up first-aid procedures for eye injuries. Have eyewash stations that are easy to get to, especially where chemicals are used. Train workers in basic first-aid and identify those with more advanced training.
Educate: Conduct ongoing educational programs to highlight the need for protective eyewear. Add eye safety to your regular employee training programs and to new employee orientation.
Support: Management support is key to having a successful eye safety program. Management can show their support for the program by wearing protective eyewear whenever and wherever needed.
Review: Regularly review and update your accident prevention policies. Your goal should be NO eye injuries or accidents.
We offer an Eye Safety Training Course that will familiarize your staff with good eye safety practices. The topics included in our eye safety training class are potential eye hazards, hazard assessment, and implementing an eye safety protection program. Further, this training will cover appropriate OSHA-approved personal protective equipment and how to use it and assess eye danger in various situations appropriately.
Worried about noise exposure on the job? Work is one of the most common places people will be exposed to harmful levels of noise. Consequently putting them at risk of noise-induced hearing loss. Noise-induced hearing loss is permanent and often progressive. Indeed it often takes years to develop. That’s why it’s so essential to protect employees hearing throughout their working years.
OSHA requires employers to determine if employees are exposed to excessive noise levels. It is estimated that 30 million workers in the U.S. are exposed to hazardous noise. When employees are subjected to excessive noise levels, administrative or engineering controls must be used. The incidence of noise-induced hearing loss can be reduced or eliminated through the successful application of engineering controls and hearing conservation programs. Where controls are not sufficient, employers must implement an effective hearing conservation program.
Exposure to Noiseis measured in units of sound pressure levels called decibels, using an A-weighted sound level (dBA). There are several ways to control and reduce workers’ excessive noise exposure in the workplace. Engineering controls involve modifying or replacing equipment, or making related physical changes at the noise source or along the transmission path to reduce the noise level at the worker’s ear. Administrative controls are changes in the workplace or schedule that reduce or eliminate the worker’s exposure to noise.
Examples of inexpensive, effective Engineering Controls:
Choose low-noise tools and machinery
Maintain and lubricate machinery and equipment (e.g., oil bearings)
Place a barrier between the noise source and the employee (e.g., sound walls or curtains)
Enclose or isolate the noise source
Examples of Administrative Controls:
Operate noisy machines during shifts when fewer people are exposed
Limit the amount of time a person spends at a noise source
Provide quiet areas where workers can gain relief from hazardous noise sources
Control noise exposure through distance is often effective (Specifically, for every doubling of the distance between the source of noise and the worker, the noise is decreased by 6 dBA.)
According to the U.S. Department of Labor, Bureau of Labor Statistics, there were 14,500 work-related hearing loss illness cases in private industry, in 2019. Roughly 75 percent of those injuries occurred in the manufacturing industry. Including 2,000 cases in transportation equipment manufacturing and another 1,800 in food manufacturing, and 11,400 in fabricated metal product manufacturing.
Some other jobs carry a high risk for hearing loss, such as:
Airline ground maintenance
Jobs involving loud music or machinery
Military jobs that involve combat, aircraft noise, or other loud noise posts
In order to provide the proper hearing protection, employees must have a good knowledge and understanding of noise exposure as well as protective measures. Furthermore, companies must have a solid hearing conservation program in place. Our Hearing Conservation Training Course includes all the necessary materials for running a successful training class. It is ideal for new hire orientation. Additionally, seasoned employees would benefit from refresher training. This training is also important for environmental health & safety managers, manufacturing managers and supervisors, construction managers, and anyone who works in or manages employees in a noisy environment. Furthermore, this training is suitable for use to train the trainer.
Safety Data Sheets are critical to keeping employees informed of the identities and hazards of the chemicals present in their workplace. Specifically, OSHA’s Hazard Communication Standard (HCS) requires the development and dissemination of important hazardous chemical information. In addition, this vital information must be available and understandable to workers. All employers with hazardous chemicals in their workplaces must have labels and safety data sheets for their exposed workers. Furthermore, they must train them to handle the chemicals appropriately.
An important component of this workplace standard is the nine pictograms. Each pictogram consists of a symbol on a white background framed within a red border and represents a distinct hazard(s). The pictogram on the label is determined by the chemical hazard classification. The pictograms help alert workers of the types of hazards they are dealing with. The pictograms will also enhance worker comprehension. As a result, workers will have better information available on the safe handling and use of hazardous chemicals.
In addition to the pictograms, the Safety Data Sheets are valuable in communicating information regarding hazardous chemicals in the workplace. These sheets have a specified 16-section format. Sections 1 through 8 contain general information about the chemical, identification, hazards, composition, safe handling practices, and emergency control measures . Therefore this information should be helpful to those that need to get the information quickly. Sections 9 through 11 and 16 contain other technical and scientific information, such as physical and chemical properties, stability and reactivity information, toxicological information, exposure control information, and other information including the date of preparation or last revision. The SDS also contains Sections 12 through 15 which include the information required in order to be consistent with the UN Globally Harmonized System (GHS) of Classification and Labeling of Chemicals.
Specific Sections of Safety Data Sheets:
Section 1: Identification
Section 2: Hazard(s) Identification
Section 3: Composition/Information on Ingredients
Section 4: First-Aid Measures
Section 5: Fire-Fighting Measures
Section 6: Accidental Release Measures
Section 7: Handling and Storage
Section 8: Exposure Controls/Personal Protection
Section 9: Physical and Chemical Properties
Section10: Stability and Reactivity
Section 11: Toxicological Information
Section 12: Ecological Information (non-mandatory)
Section 15: Regulatory Information (non-mandatory)
Section 16: Other Information (This section indicates when the SDS was prepared or when the last known revision was made.)
Employers must ensure that the SDS are readily accessible to employees for all hazardous chemicals in their workplace. This is done in a variety of ways. For example, employers may keep the SDS in a binder or on computers as long as the employees have immediate access to the information without leaving their work area when needed. Furthermore, employers may want to designate a person responsible for obtaining and maintaining the SDS.
Employers are required to train their employees to recognize the nine GHS Pictograms. Our Safety Data Sheet binders make compliance easy because the SDS binder is printed with the GHS Pictograms. It is designed to allow easy reference for any employee accessing SDS records. The pictograms are printed on the inside of the binder along with the SDS Requirements.
Labor law poster changes seem to appear overnight. As such, keeping up with labor laws can be intimidating. We are closely monitoring the changes so you don’t have to.
Often, those changes are considered minor such as address changes, website address changes, department personnel changes, and changes in design. However other changes are considered major such as increases in minimum wages, newly enacted laws, and major changes to the text of existing laws.
While January is the most common month for updates, many states update various laws throughout the year. As a general rule changes to federal labor laws do not happen quite as frequently as those at the state level. Changes often occur midyear. As is typical, mid-year labor law poster changes this year vary from state to state.
Types of changes happening this year
Minimum wage increases are one of the more common updates both at the beginning of the year and also mid-year. This year is no exception as the District of Columbia, Hawaii, Nevada, Oregon, and New Jersey each have updated minimum wage and/or overtime laws.
While the changes in Connecticut and Utah relate to health and unemployment insurance information. New Jersey’s Family Leave Act has been updated. In New Mexico, the Paid Sick Leave requirements have changed. Likewise, Louisiana’s Earned Income Credit rates have been updated. Illinois has reformatted employee rights under ISERRA. In addition to the updates already mentioned for Oregon changes for that state also include equal pay, breaks, meals, sexual harassment, domestic violence, sick time, and family leave.
Periodically states not only have mid-year updates but will also have new postings required. This year Virginia enacted a new required poster highlighting seizure first aid. Meanwhile, the new additional poster in New York is titled Prohibited Retaliatory Action by Employers.
Keeping up with changes in labor law requirements can often seem like one more thing to try to manage. In light of that, we are carefully monitoring changes and strive to keep you informed of major changes that affect your business.
In 2014, the Industrial Truck Association founded National Forklift Safety Day to highlight the safe use of forklifts. An additional motivation was to serve as an annual reminder of the value of training and equipment checks in every industry that relies on forklifts. Forklifts are an essential piece of equipment in many workplaces. For example, warehousing and manufacturing depend on forklifts. These vehicles make work more efficient. However, they can also pose serious hazards to those operating or working near them. With this in mind, we can prevent forklift hazards. Properly trained workers that follow safe practices are the best prevention.
Steps that protect workers on forklifts
Always wear seatbelts when operating a forklift.
Never exceed the rated load, and ensure loads are balanced.
Make sure you have enough clearance when raising and loading materials.
Watch for pedestrians and observe speed limits.
Keep a safe distance from the platform and ramp edges.
OSHA’s Powered Industrial Trucks – Forklifts page provides additional ideas for keeping workers safe. Every year, forklift accidents result in an average of 85 deaths and 34,900 serious injuries. Therefore, training is vital in reducing the number of injuries and deaths. All employers have an important role in the safety of their employees.
Some additional safety measures for operating forklifts
Dress For Safety
Know Your Forklift
Conduct Daily Forklift Safety Checks
Never Operate a Damaged Forklift
Only Work in Well-Lit Locations
Never Touch The Mast During Forklift Operations
Refuel with Caution
Never Stand Beneath a Forklift Load
OSHA provides specific safety rules for operating forklifts. Therefore, employers are expected to conduct training for all employees working forklifts. Then operators must pass a test and recertify at least once every three years. Finally, ongoing supervision is essential to ensure forklift safety rules are enforced so that employees are kept safe.
In the ongoing quest for maximum safety in the workplace, OSHA’s annual release of their top 10 violations can offer employers a sense of which tasks and maneuvers may hold unexpected risk.
While you’re hopefully aiming to assess and avoid risk across the board at your company, targeted lists like this can be a great way to remind you of areas of concern you might have missed otherwise. After all, these violations are common for a reason, and the likelihood is that employers and workers alike are giving these regulations too little thought.
In this blog, we’ll go through the top 10 OSHA violations for 2021 in detail, offering further information about each violation as well as actionable tips for protecting your employees from these hazards.
1. Fall Protection – General Requirements (1926.501)
With 5,295 violations noted, this is the most violated requirement on OSHA’s list. This requirement is an umbrella for many more specific fall prevention requirements, including the inclusion of guard rails and toe-boards, hole covers, and safety nets or harnesses, depending on the circumstances.
While some falls may be relatively harmless, a fall always has the potential to do serious harm or even cause death, especially in situations where workers are performing high above the ground. To ensure your employees’ safety, make sure any holes are either covered or guarded by a rail, any open-sided, elevated floor or platform is protected by a guard rail and toe-board, and (even if there’s no elevation involved) any situation where a worker could fall onto or into dangerous machinery is likewise safeguarded.
2. Respiratory Protection (1910.134)
Although respiratory dangers are commonplace on a variety of worksites, 2,527 violations were noted by OSHA in the past year. In order to prevent diseases and other harm that can result from workers breathing contaminated air, OSHA requires that employers provide the right respirator for each specific hazard to every employee onsite.
This may include everything from an air-purifying respirator to a positive pressure respirator or even a supplied-air respirator. To ensure you’re supplying your team with the appropriate respirators for the task at hand, make sure to familiarize yourself with the OSHA standard with proper respiratory safety training.
3. Ladders (1926.1053)
If you’re new to following OSHA requirements, you might be surprised at just how complicated the rules about ladders can get. But unlike home use, jobsite ladder use is serious business — so serious that 2,026 people got it wrong this year.
There are ladder safety details to watch out for, but the most pertinent are these: portable ladders should support four times the intended load, while fixed ladders must support a minimum of 250 pounds on each side; rungs and cleats must be 10-14 inches apart; two or more ladders must not be tied together or stacked to add length; and ladder rungs should be level, parallel, and evenly-spaced.
4. Scaffolding (1926.451)
Like ladder use, scaffolding use calls for a wide range of requirements, from the broadly applicable to the minute. With 1,948 violations in 2021, it’s clear that many employers aren’t aware of just how detailed scaffold safety requirements can get.
Again, the most pertinent requirements have to do with how much weight the different elements of the scaffolding can hold (4-6 times the maximum expected load) and the prevention of falls through guard rails and appropriate planking amount. OSHA also notes that scaffolding must be designed by someone qualified and be constructed in accordance with the design.
5. Hazard Communication (1910.1200)
OSHA reported 1,947 violations of the hazard communications requirement this year, which is shocking when you consider that communicating a hazard is the first step to protecting employees from it.
In this case, OSHA is specifically regulating the communication of chemical hazards, and both the type of chemical and circumstances of its use or transportation have a bearing on the specific rules about communication. For example, when workers are only handling chemicals in properly sealed containers, employers only need to ensure that the labels on the containers when they arrive aren’t tampered with or removed, rather than labeling them themselves.
6. Lockout/Tagout (1910.147)
This requirement, which was violated 1,698 times in 2021, refers to the control of what OSHA calls ‘hazardous energy,’ in which the starting-up of certain machines or release of stored energy within the machines can harm workers. Specifically, this requirement covers the maintenance and servicing of such equipment.
OSHA’s requirements on this get pretty complex, especially as they pertain to what they don’t cover (such as agriculture and construction equipment), but two of the main rules are, broadly: there needs to be a lockout/tagout safety protocol for servicing these machines and employees need to be trained on that protocol.
7. Fall Protection – Training Requirements (1926.503)
This specific subsection of the general fall protection requirement was violated 1,666 times in the past year, which makes the general fall protection violations make a little more sense. If employees aren’t trained on preventing falls, it stands to reason that they’ll overlook the necessary requirements for keeping themselves and their coworkers safe from falls.
Essentially, this requirement holds that workers need to be trained on the fall prevention requirements of their jobsite, that they need to pass a certification proving that they’ve learned the necessary elements of the OSHA requirements, and that they must retrain if their employer ever has reason to believe they’ve either forgotten or never properly learned the skills in the original training.
8. Personal Protective and Lifesaving Equipment – Eye and Face Protection (1926.102)
Like the respiratory protection requirement, the face and eye safety standard requires employers to provide and ensure workers wear the appropriate protection for any task that would expose them to eye or face hazards, including sparks, molten metals, flying particles, chemical gases, or potentially harmful light radiation.
This one seems like an easy pass, but OSHA noted 1,452 violations in 2021. Make sure you’re prepared for every element of your next project by obtaining the correct protective gear for your employees.
9. Powered Industrial Trucks (1910.178)
If you use electric or internal combustion engine-powered trucks on your worksites — that includes forklifts, tractors, and platform lift trucks — make sure you follow OSHA’s forklift safety requirements, so you don’t wind up like the 1,420 employers who were in violation over the past year.
These requirements cover the design, maintenance, and operation of these vehicles, as well as fire prevention. Some of the requirements cover where and how these trucks should be used, what circumstances to avoid, and how they need to be marked to identify any post-factory attachments, among other concerns.
10. Machine Guarding (1910.212)
OSHA reported 1,113 violations of this requirement in 2021, indicating that far too many employers aren’t taking their workers’ safety seriously when it comes to machinery onsite.
1910.212 addresses the various kinds of machine guards that might be used on a worksite, including barrier guards, electronic safety devices, and two-hand trippers, and requires that the appropriate guard be used on any machine that may present a hazard in the form of flying particles, rotating parts, or nip points.
Individual OSHA violations may sometimes seem like an irritation rather than an indication that your worksite is unsafe—after all, many of these regulations are extremely specific—but OSHA creates these standards for a reason. They’re trying to help you keep your employees safe, which is of course better for your business in the long run.
Each year when the 10 violations are announced, it’s a great opportunity for your business to audit your practices, evaluate your emergency plans, and ensure your workers are properly trained for the hazards they face on the job.
Ready to host refresher training? National Safety Compliance makes OSHA safety training easy. Our simple-to-use video training kits include compliant training videos, lecture presentations, and printable assets to ensure your managers, supervisors, or human resources directors have everything they need to host a successful training session.
Keeping up with labor laws can be a daunting task. Changes seem to occur almost daily. And while this isn’t actually the case, it can sure feel that way. Changes to federal labor laws do not happen quite as frequent as those at the state level as a general rule. But in times of uncertainty, as we experienced with Covid in 2020, even federal labor laws can be enacted quickly as we saw with the passing of the CARES Act. The laws created by the CARES Act were of a temporary nature with many of the requirements ending in December of 2020. Most changes to labor laws are not temporary though. We find states often update various laws throughout the year. Some of those changes are considered minor such as address changes, website address changes, or department personnel changes. Other changes are considered major such as increases in minimum wages, newly enacted laws, and major changes to the text of an existing law.
Midyear often brings about many of those changes. The most common change is a state’s Minimum Wage. Although the Federal Minimum Wage has not increased since July 2009, many states, cities, and counties have a higher minimum wage. (Employers are required to pay workers the higher amount.)
The following states have mid-year minimum wage increases:
To keep up with the most current changes to the federal labor laws as well as your state labor laws you can sign up for a free email update service. Simply click here to enroll: https://www.nsccompliance.net/llp-updates/
On March 14, 2020 OSHA issued a temporary fit guidance for respiratory protection for Health Care Providers (HCP) in light of the current Covid-19 pandemic crisis. The guidance was in response to a memorandum by the President and was done to ensure HCP have proper and adequate access to N95 or greater respiratory protection.
On March 11, 2020 President Trump authorized the Memorandum
on Making General Use Respirators Available. In the memorandum President Trump
stated “It is the policy of the United States to take proactive measures
to prepare for and respond to public health threats, including the public
health emergency involving Coronavirus Disease 2019 (COVID-19), which was
declared by the Secretary of Health and Human Services on February 4,
2020.” He further stated “We must ensure that our healthcare providers have
full access to the products they need. …Unfortunately, at present, public
health experts anticipate shortages in the supply of personal respiratory
devices (respirators) available for use by healthcare workers in mitigating
further transmission of COVID-19.
To help prevent the spread of COVID-19, the Secretary
of Health and Human Services shall take all appropriate and necessary
steps with respect to general use respirators to facilitate their emergency use
by healthcare personnel in healthcare facilities and elsewhere… Additionally,
the Secretary of Labor shall consider all appropriate and necessary steps to
increase the availability of respirators.”
OSHA has provided temporary guidance for 29 CFR § 1910.134,
regarding required annual fit-testing which took effect March 14th and
remains in effect until further notice.
The Centers for Disease Control and Prevention (CDC)
currently recommends that Health Care Providers (HCP), who are providing direct
care of patients with known or suspected COVID-19, practice infection control
procedures. These include engineering controls (e.g., airborne infection
isolation rooms), administrative controls (e.g., cohorting patients, designated
HCP), work practices (e.g., handwashing, disinfecting surfaces), and
appropriate use of personal protective equipment (PPE), such as gloves, face
shields or other eye protection, and gowns. Appropriate respiratory
protection is required for all healthcare personnel providing direct care of
these patients. (For additional guidance, see COVID-19 Hospital
Preparedness Assessment Tool, https://www.cdc.gov/coronavirus/2019-ncov/hcp/hcp-hospital-checklist.html.)
OSHA recommends HCP employers follow existing CDC
guidelines, including taking measures to conserve supplies of these respirators
while safeguarding HCP. One such measure is that healthcare employers may
provide HCP with another respirator of equal or higher protection, such as N99
or N100 filtering facepieces, reusable elastomeric respirators with appropriate
filters or cartridges, or powered air purifying respirators. They may also change
the method of fit testing from a destructive method (i.e., quantitative) to a
non-destructive method (i.e., qualitative).
Workers should visually inspect the N95 respirator to
determine if the structural and functional integrity of the respirator has been
compromised. Over time, components such as the straps, nose bridge, and nose
foam material may degrade, which can affect the quality of the fit and seal. If
the structural and functional integrity of any part of the respirator is
compromised, or if a successful user seal check cannot be performed, discard
the respirator and try another respirator.
OSHA field offices should use their own discretion regarding
enforcement of the annual fit testing requirement as long as employers:
Make a good-faith effort to comply with 29 CFR § 1910.134;
Use only NIOSH-certified respirators;
Implement CDC and OSHA strategies for optimizing the supply of N95 filtering facepiece respirators and prioritizing their use;
Perform initial fit tests for each HCP with the same model, style, and size respirator that the worker will be required to wear for protection against COVID-19;
Inform workers that the employer is temporarily suspending the annual fit testing of N95 filtering facepiece respirators to preserve and prioritize the supply of respirators for use in situations where they are required to be worn;
Explain to workers the importance of performing a fit check each time they put it on to make sure they are getting an adequate seal from their respirator;
Conduct a fit test if they observe visual changes in the employee’s physical condition that could affect respirator fit and explain to workers that, if their face shape has changed since their last fit test, they may no longer be getting a good facial seal with the respirator and, thus, are not being adequately protected; and,
Remind workers they must inform their supervisor or their respirator program administrator if the integrity and/or fit of their N95 filtering facepiece respirator is compromised.