Keeping the Chill Out: Working Safe in Cold Weather | EHS Today

Keeping the Chill Out: Working Safe in Cold Weather EHS Today

There has been a lot of cold storms coming through the US this week and although I usually work on project management and reports, I was one shivering in the cold on Monday morning to start off a chemical remediation project. But for those who work in much colder conditions and for longer periods of time, this article is a reminder. Layer your clothes with gloves and hat. If your feet and hands are warm, this is a great start. You also need to keep up with the fluids.

When working in cold temperatures, the best defense is common sense. Knowing what to wear, what to eat and drink and what to do if an employee is suffering from a cold-related illness can save lives.

ES&H Audit Tips

The end of the year is here and many organizations are scheduling their "walk around" audits. Whether your focus is environmental or safety, or a combination of the two, this inspection is a part of your environmental, safety, and health (ES&H) program. The "walk around" audit is a visual approach to determine if the organization's policies and procedures are being properly implemented, verify the company is in compliance with ES&H laws, and identify what improvements or areas of concern need attention.

Before you begin your audit, here are a few tips to consider so that you can get the most of your "walk around" audit:

• Know the goals and objectives of your audit. Review your ES&H program to determine the policy and procedure for performing the audit and evaluate what standard for auditing you are using. Knowing what regulations apply to your organization with access to those regulations is a minimum, but your organization may have recommended goals that are more stringent than the regulatory guidelines. Standards such as ISO, ASTM, and NIOSH are recommendations that your organization may have incorporated into their program. Your organization might also have Best Practices to help build and reinforce your ES&H culture.
• Communicate with your safety team. Having your auditing team on board with your vision for this audit is extremely important. Clearly define the goals and objectives for the team and make sure everyone on your team knows what they will be responsible for, what procedures they are to follow, and how much time they have to complete the audit and reporting of results.
• Keep your scope, budget, and deadline reasonable. You want to have a team large enough, capable, and available to complete the audit in a timely manner, besides making the audit a reasonable task for the size of the organization. If you are considering that the audit be done internally, be aware that members of your team may not be able to provide the audit full attention during the entire project without fulfilling other project requirements.
• Follow a checklist. Since there are various standards for performing an audit, select a checklist that meets your program requirements. If your organization does not have a checklist, you may want to create one of your own. A good checklist should be designed to reflect the standard for the operation, area, and/or equipment that is being checked. Having your checklist arranged by division, department, or area may help avoid going back and forth to check equipment in an area you already went through.
• Recognize there are risks. By managing and controlling the "walk around" audit based on the organization's policies and procedures, you can give your thoughtful attention toward the audit and maintain its scope. But be aware that risks exist when you identify or fail to identify ES&H concerns, increasing the potential for financial and legal liabilities. Be careful what recommendations you make for correcting concerns, how you word findings, and who you discuss your findings and recommendations with, as some of these may be confidential or involve trade secrets. Inaccuracies can be avoided by having meetings with your team before beginning the walk through and after completing the audit, then by cross checking your information. When looking at recommendations, be realistic about what your organization will be willing to budget in an acceptable time frame.
• Get employees involved. They know that this is coming and there should be a certain part of preparedness within each plant, department, etc. since the walk around is a regular occurrence. You want cooperation and to make this as useful for everyone as possible. Arrange to meet with a representative from each plant or area to go through the walk with them. This way you can provide comments directly. Talk to employees where you can. They are the ones who know the operations, tools, and equipment. And they can usually offer suggestions on how to correct an ES&H concern. In many situations, problems can be fixed on the spot or as soon as possible when the employee in that work station is present.
• Review your audit policies and procedures. When your audit is complete, make recommendations where appropriate on what you could have done differently with your "walk around". Evaluate your scope, budget, and deadline to verify it was appropriate in meeting the program requirements. There could be something outdated with the policies or missing in the procedures you are using to perform the "walk around". For example, you may have the same people year after year looking at the same things. Having a fresh set of eyes perform the audit annually can help bring in a different perspective.

A good "walk around" audit can be used to lay out your goals and objectives for the new year. Keep in mind that your controls may be suitable for complying with today's regulations, but may not meet future changes in the regulations. In some cases, external audits can be more advantageous than internal audits because they can provide a fresh pair of eyes, be objective, relieve some of the liability, among other things.

Battle Unexpected Absenteeism...And Win! — legalworkplace.com

Battle Unexpected Absenteeism...And Win! — legalworkplace.com

Reducing absenteeism and tardiness starts long before the employee calls out unexpectedly, it starts during the hiring when the expectations are communicated, in the written policies and procedures, and in the actions of all employees. Things recommended: reward good attendance, make the workplace a place employees want to come to work, be concerned about an employee when he or she is absent, be flexible when possible, and allow unused time to be carried over.

Performing Phase I and Phase II Environmental Site Assessments

Is it not incredible how quickly this year is moving along? Towards the end of the year we see many commercial properties changing ownership and an increase in Phase I and Phase II Environmental Site Assessments. The Phase I investigation includes a visual property inspection and review of historical property records, regulatory records, interviews with persons knowlegable about the property and surrounding area, as well as other reviews to help determine if there are any recognized environmental concerns, called RECs. When an REC becomes know, the Phase II investigation may be necessary to evaluate subsurface conditions in the soil and groundwater.

At times, the Phase I and Phase II Environmental Site Assessments may be performed simultaneously. This combination is beneficial when time is of the essence. For example, if you know the loan requirement for refinancing a dry cleaning facility requires a Phase I, it is highly likely that a Phase II will also be necessary if the dry cleaning activities were performed onsite. The chemicals used in dry cleaning activities create a REC because of their hazardous nature. Instead of waiting for the Phase I report to be complete, a Phase II subsurface investigation can be added into the scope of work to determine if a release of chemicals has occurred, thus allowing the question of whether further action will be necessary to decide on the loan.

By combining the work of both surficial and subsurface investigations, there could also be a cost savings on the project. Let us take the scenario above with the dry cleaner. By adding the Phase II scope of work, the project management time for setting up and scheduling the project can often be done at the same time. Mobilization to the site can be decreased into one mobilization depending on the location of the site. In other words, sometimes a two day consecutive site visit is less expensive with a per diem compared to the cost of driving back and forth. And the reporting can be combined into one document.

One of the disadvantages of combining a Phase I and Phase II Environmental Site Assessment together include not knowing all the RECs. If you mobilize a drilling rig to install temporary borings, you probably have a plan to collect soil and groundwater samples for dry cleaning chemicals. Immediately prior to the field implementation, you determine during the regulatory review that the property once had a retail paint shop onsite. In this case, it is relatively easy to add in the additional analysis, if needed, since both dry cleaning solvents and paint are volatile organic compounds. But there are circumstances, such as the addition of 8 RCRA metals or other chemical analysis, or increased drilling that may be needed if more RECs become known. Depending on the age of the paint shop, Lead may be an additional analysis. Other scenarios may be the location of offsite RECs that may warrant drilling for subsurface sampling in a different location on the property.

In today's economy, financial institutions are making loans but the circumstances for approving a loan have become harder. If there are RECs, there are the potential for releases from past onsite operations. Until it is clear that the property has not been impacted by chemicals from past operations, most loans will not be approved. And as long as there is the existence of contaminants beneath the subsurface, many loan officers today will not approve a loan until the regulatory agencies provide a No Further Action Required. Even then, a clean bill of health on the property via remediation may be required by the loan. It is important to understand the process by talking to your financial officer or environmental consultant before, during, and after the assessment is performed.

Audit Fatigue - Perhaps you need a fresh approach

http://www.ishn.com/Articles/Feature_Article/BNP_GUID_9-5-2006_A_10000000000000919171

Auditing can become mundane, especially when done by the same person or group of people every year, year after year. Your procedure and timing may be too predictable and you expect the same results. Perhaps it is time for a change in pace. Try doing your audit more spontaneous and with a different person or group. If you hire an outside source for your audits, check with them to see how they are changing their process or approach. At a minimum, there should be new safety rules and regulations that apply from the last audit.

The auditor can interview different people and change the questions. Sending out a survey in advance can provide the people being interviewed with time to think about the questions and write out comments. But it can also be important to plan surveys by reviewing the records available and incorporating some key points and statistics into the surveys. It shouldn't surprise you to find out people don't always know the happenings outside their own work area. A simple question about if they knew something that happened in the company from a different division or department will help you to know very quickly if there is some communication barriers.

If you think you are not considering the human factors, such as stress, trust, teamwork and leadership, why not phase your questions towards these factors? Or maybe try performing the interview portions of the audit as a group meeting. Brainstorming about safety in the workplace can be beneficial when a group discusses the issues. Getting people involved more with the process helps to create buy-in and accountability.

All too often the audit is looked at as a snapshot in time, while the goal for safety is longterm. Sharing the audit information and follow-up are ways to keep safety in the minds of everyone. In order to build the perception that the workplace is safe, there needs to not only be support in leadership but thinking about safety needs to be a continual behavior that involves all levels of the company.

Noise in Workplace related to Heart Problems

http://www.ishn.com/Articles/Industry_News/BNP_GUID_9-5-2006_A_10000000000000920175

This article about persistent, loud noise in the workplace being related to increased heart disease just makes common sense. How many times have we all experienced overhearing people arguing, kids screaming, or tools such as hammering that have distracted us and caused headaches? We become more anxious and irritable - stressed. We want to escape and go for a walk or find a quiet place to relax. Destressing from work may be trying to relax on the drive home. If we are driving along a noisy highway, we close the windows and turn on music to adjust the noise around us, making a more appealing listening environment.

Constant, loud noise can put a strain on your mental state that should be minimized at the source. There are numerous engineering controls to help decrease noise on machines or sound barriers to minimize noise in specific areas. However, engineering controls are only part of the correction. In some circumstances, the addition of PPE is needed. It is important to recognize that PPE can add something to that worker's quality of life. Convincing a worker who has been doing his job without PPE everyday for years may be necessary and for his best interest. If he has become content with the way he does his job because that is the way he has always done it, we may need to persuade him that there are always ways to improve what we are doing. Comfort and appearance should no longer be an issue as PPE has improved over the years and is more comfortable to wear and more aesthetic. And getting the employee involved with PPE selection may be advantageous in purchasing something they will use.

GAEPD USTMP New Report Templates

http://www.georgiaepd.com/Documents/epdforms_lpb.html#ust


The GAEPD Underground Storage Tank Management Program has provided new reporting templates for the Monitoring Only (MO) and Remediation Reports. These are available online. The new templates are very similar to the prior Progress Report templates from 2001, with the addition for remediation. The GAEPD has indicated that the MO template can be used if there is only one mobile vacuum event performed onsite, but if more than one event is performed then the remediation template would be necessary. Chemical remediation also requires using the remediation template, although this template appears to be best setup for discussing operation and maintenance (O&M) and remediation results on a full scale system. Only time will tell how user friendly these new forms will be. The main thing for now is getting everyone onboard with consistency of reporting.

NSC: OSHA, MSHA, NIOSH Leaders Discuss the State of Occupational Safety | EHS Today

NSC: OSHA, MSHA, NIOSH Leaders Discuss the State of Occupational Safety EHS Today

In an October 5 National Safety Council Conference, Keynote Speakers included OSHA Administrator David Michaels, NIOSH Director John Howard, and MSHA Administrator Joe Main. I2P2, Vaccination, and Black Lung are on the regulators minds these days. In his keynote speech, David Michaels indicated that OSHA cannot be everywhere at once so the agency "must think of creative ways to have a bigger impact. The key to workplace safety and health is working on prevention". Indead, one key to prevention is communication. For example, the Illness and Injury Prevention Program, called I2P2, proposes finding and fixing safety problems before they cause occurrences. To do this there must be a plan of action that is endorsed by those in charge and implemented by everyone from human resources, management, and employees. Getting key imput from those directly affected and getting support from those above is critical in making realistic safety goals, purchasing appropriate engineering controls and PPE, properly using these controls and equipment, etc. Finding and fixing by means of proper and thorough communication are challenges every company faces.

On a different note, John Howard spoke on vaccination and the timing of flu season on Oct 1. As companies continue to struggle with meeting production goals for the end of 2010, sick time runs out on some employees, stress of missing days when sick to only have to pick up the pace when one returns back to work cause other employees to come to work sick, while in other circumstance employees sometime miss work to care for their sick children. Besides vaccination, when was the last time your keyboard, mouse, and phone were cleaned? And, keeping a small hand sanitizer around is another way to minimize germs.

Joe Main's emphasis was also on prevention, that of keeping miners safe through re-education programs, improvements on dust respirators and engineering controls, and better evaluations of the mining situations during shift changes. Again, communication challenges must be overcome to plan, find and fix problems to minimize other incidents in the future.

Dr. Michaels Emphasizes Priorities at NSC Summit in San Diego

Industrial Safety and Hygiene News sent out an article summarizing the summit session where Dr. Michaels spoke about OSHA's priority for the I2P2 Standard, or the Injury and Illness Prevention Program rule. In his discussion, Dr. Michaels indicates that changes required will address industries finding and fixing hazards before they can cause accidents. He emphasized that changes will require a close collaboration between mangers, team leaders, and employees. Many companies have already taken steps to train employees in accident prevention, where managers and employees watch out for others and report potential problems so they can be fixed before a major incident occurs. But there is the increased problem of sick or injured workers coming to work too soon because they don't have enough time off or are afraid of losing their jobs. Depending on the circumstances, they could be placing themselves and others at a higher risk. What changes has your company done to prevent injuries and illnesses?

For the proposed ruling, go to: osha.gov/FedReg_osha_pdf/FED20100504.pdf

Elements of the rule consist of:

1. Management duties such as establishing a policy, goal setting, planning and allocating resources, and assigning and communicating roles and responsibilities,
2. Employee participation such as involving employees in the establishment and implementation of the policies, providing access to employees for health and safety information, involving the employee in the incident investigation,
3. Hazard identification and assessment such as identifying hazards, gathering information, workplace inspections and incident investigations, hazard associations with workplace changes, determining priorities and identification tools,
4. Hazard prevention and control such as determining and priorizing what hazards must be controlled, and evaluating the effectiveness of controls,
5. Education and training, including content, effectivenss, relationship for training,
6. Program evaluation and improvement, with monitoring, evaluating performance, and determining deficiencies.

The rules require a continual plan to review and improve, after all, the workplace is continually changing. Communication will be essential in this plan. People are different in how they train, how they work with others, yet everyone can bring something of value into the program. Getting people to communicate requires team collaboration skills that have often been challenging. What challenges does your company face in meeting this proposed plan?

Career Day Important Opportunities for Students

What a wonderful group of rising 9th graders I met today during Career Day at the Conyers Middle School! Yes, I had the opportunity to go class to class talking about what I do as an environmental consultant. I prepared by linking what I do to some of what these kids might be seeing in the future and got a great response. Of course, most questions seemed to be more about the BP disaster since that is what is in the news. But, whatever the questions, it is great to see the interest and potential of some future environmental consultants.

SCDHEC UST Contractor's Forum

SCDHEC announced a re-scheduled forum on June 4, 2010 to discuss the requirements of a Programmatic Quality Assurance Program Plan (QAPP). The QAPP will be replacing all UST Program guidance documents. The QAPP is available on the UST webpage at www.scdhec.gov/environmental and all work on or after July 1, 2010 is subject to the requirement of the QAPP, revised October 2009.

Injury Rates Higher with Young Workers

During 4QR's upcoming seminar on May 13, 2010, there will be a discussion about the safety obligations of companies that hire youth workers. Youth workers are minors from the ages of 14 to 17. During the school year, minors can work minimized hours around school hours. These hours are extended during the summer schedule when school is out. There are specific regulations on the type of work youths can do in an industrial company. And all counties in Georgia this summer are organizing Teen Work Programs that use Stimulus Money to help youths find work.

Some companies may also have young workers under the age of 25, which are estimated to make up about 14 % of the labor force. A recent article from EHS Today discusses some of the statistics and indicates that injuries are greatest among 18 and 19 year old workers. The article goes on to indicate "fatalities of younger workers occur most frequently in services, construction, retail trade, and agricultural." In all age categories, fatalities are mostly reported in transportation accidents.

Youths have inexperience in dealing with equipment and vehicles. The mentality of invincibility may be strong. And unfortunately, youths do not often understand the importance of personal protective equipment, sometimes placing comfort first. Then there is the added stress factor of trying to be a great employee - the temptation of taking short cuts to make timely deliveries.

Training for the supervisors and team leaders who manage youths can help minimize injuries and raise awareness to the regulations. If your company has or is planning to hire youths in the near future, how would you rank your knowledge on understanding the safety obligations regarding youths in the workplace? Are you comfortable that the positions companies are placing youths in are suitable for their safety and the safety of others?

Top Worst Ozone Cities announced for 2010

With summer approaching, many cities across the U.S. will have smog alerts. Click to see the cities with the worst pollution at www.forbes.com/2010/04/28/polluted-cities-smog-lifestyle-health-american-lung-association-ozone_slide.html Smog alerts are usually consistent with the hottest days of the year, when air pollution is at its height. But the good news is that some cities, such as Atlanta and Pittsburg, have been reducing their smog. Atlanta has one of the lowest air pollution levels reported since 1994. EPA controls on industry emissions have played a role in reducing air pollution. And while traffic has increased in cities such as Atlanta, new vehicle emission standards over the past few decades, along with carpooling campaigns to reduce the number of vehicles on the road, have helped to reduce air pollution.

4QR employees work from home, with some exceptions such as when doing field work. And we try to combine field work into minimal trips. Fewer trips result in less emission of vehicle fumes that will get into the air. And combining trips help to reduce fuel and save time. We also try not to have employees work outside at job sites during the hottest days. Although this cannot always be done, staying indoors when air quality is at its worst can help you breath easier. Another way to reduce ozone is to avoid fueling during the hottest parts of the day.

What are some of the things you and your company are doing to minimize air pollution?

Hidden Brownfields

At what point will the truth about the commercial real estate market blossom? By this, I refer to the "hidden Brownfields" that lenders and property owners of closed industrial facilities are sitting on. With so many vacancies in shopping centers, corner gas stations, and manufacturing buildings, certainly there is only so much time that can go by before it becomes public knowledge the extensive number of contaminated properties that are out there. There has been some talk on changing environmental brownfields regulations for handling these many sites. And just who will be responsible for those properties that have been foreclosed? What are your thoughts about the brownfield talks? What are your thoughts of how banks are handling the environmental (or lack of it) on commercial properties?

Hazwoper Training

Although Hazwoper refresher is a requirement for training by OSHA, many companies seem to delay sending their employers at the yearly interval. Are you getting refreshers every 12 months or are the intervals exceeding 12 months? If exceeding, how long does your company wait to give refreshers and why do you think there is the delay?

GAEPD: Chemical Remediation for UST Cleanup

Recently we have seen more acceptance from the Georgia Environmental Protection Division when it comes to chemical remediation to remove free product at leaking underground storage tank facilities. There has been mixed feelings about what conditions are right for using chemical remediation and differences begin with the contractors performing the remediation. For example, some contractors indicate chemical remediation can only be effective when free product is less than 0.5 foot thick at a site, while some others indicate that as long as a mobile multi-phase extraction/high vacuum extraction event is performed prior to the injection, injection of chemicals can be very effective with thicknesses as high as 1 foot. What are your thoughts on this?

SCDHEC Transition in Financial System

SCDHEC issued a statement on February 22, 2010 that it will be converting its existing financial system to a new statewide system. The transition will begin on April 16, 2010 and is expected to last up to six weeks. According to the statement, any invoices for environmental work submitted after April 7 will be delayed for processing until the conversion to the new system is complete. How will this affect you?

Safety with Management

I recently went on a group tour of a industrial manufacturing plant. Although the plant boasted that they were "Top in Safety", I was surprised that the plant manager that provided the tour did not wear his hearing protection the entire time. There was heavy machinery that produced noise much above the standard decibels which would require hearing protection. As the tour progressed, I believe his lack of concern affected business people in our group, as many of them did not continually wear their earplugs. Being a plant manager, he sets an example for his employees and those visiting the plant. Have you come across this and if so, why do you think people overlook the need for protection?

UST Soil Cleanup

I recently had a client selling a gas station where the contaminated soil was not removed during a underground storage tank (UST) closure. The potential buyer wanted my client to incur the expense of removing soil. But this is not a requirement for remediation under the Georgia UST regulations and the site has already received a "No Further Action Required". Many developers can go in and redevelop or utilize existing buildings on such property without removing petroleum-contaminated soil. Do you think a seller should have to remediate soil for a buyer?

We are up and running and want your comments

What are some of the current issues in your business that relate to environmental and safety industry in the US?