Many proactive employers are already meeting or exceeding these requirements, but this is a good opportunity to:
-Provide formal comments to Cal/OSHA about these new regulations.
-Get an idea about what new regulations may be coming that could affect your industry.
-Use the proposed regulation as a way to check your own existing safety programs for your housekeeping staff.
Keep in mind that these proposed regulations are requiring an injury and illness prevention program specific to housekeeping staff, but every employer should already be evaluating and mitigating workplace hazards for every employee position.
For San Diego employers, we offer first aid/cpr classes, hazard communication training, bloodborne pathogens, active shooter courses and more, conducted onsite at your hotel or resort property.
First, evaluate the types of tasks employees perform, and identify any job duties that might result in a chemical exposure to the eyes or body. This exposure could be either during routine tasks or forseeable emergencies. Make a list of these chemicals.
Second, evaluate the chemicals themselves by reading the safety data sheet, or consulting the manufacturer. Identify if these chemicals can cause any of the following: corrosion, severe irritation, permanent tissue damage, toxicity by absorbtion. If so, you will need an eyewash station and/or shower.
Third, select the correct equipment. If the potential exposure is to the eyes, an eyewash station should be provided. If the potential exposure is to the body, a safety shower should be provided. If both an eyewash and shower are needed, they should be located so they can be used at the same time by the same person. This equipment must comply with certain requirements (look for ANSI Z358.1 compliant products); just having a sink, hose or regular shower nearby doesn't count. The equipment should be installed in an area that is unobstructed, no more than ten seconds from the hazard, provide at least 15 minutes of flow, and be tested/inspected regularly.
If a full face mask is required for respiratory protection, quantitative fit testing of that mask is also required. Quantitative fit testing uses computerized equipment to measure how well the respirator seals to the wearer's face. Qualitative fit test methods like irritant smoke, bitrex, saccharine or isoamyl acetate ("banana oil") are not permitted for these full face respirator usage situations.
The fit testing requirements are found in the Federal 29 CFR 1910.134 ( link ) or Cal OSHA T8 §5144 ( link ) regulations. However, the language used in the regulations can be difficult to understand. They are more clearly explained in the Federal OSHA Small Entity Compliance Guide for Respiratory Protection ( link ):
"If a full facepiece APR [air-purifying respirator] is to be used in atmospheres with levels of contamination greater than ten (10) times the PEL, a quantitative fit test must be used."
OSHA defines a Permissible Exposure Limit (PEL) for nearly all chemicals. This is the maximum airborne concentration of a substance an employee can be safely exposed to. If the concentration of a contaminant in the air is more than the PEL, the employee must use a respirator. If the concentration is more than 10 times the Permissible Exposure Limit (PEL), a full face respirator must be worn, since half face masks are not rated to provide protection in concentrations more than 10 times the PEL.
In summary: if the contaminant concentration requires the level of respiratory protection provided by a full face mask, then quantitative fit testing is required. This is because:
- OSHA requires full face respirators where contaminant concentration is more than 10 times the PEL.
- OSHA also requires quantitative fit testing where contaminant concentration is more than 10 times the PEL.
If you have employees that are required to wear full face masks for respiratory protection, make sure you are conducting quantitative fit testing. If you are outsourcing your fit testing, as many employers do, verify with the vendor that they are doing quantitative fit testing, and ask to see a copy of the current calibration certificate for their equipment. There are only two manufactures of quantitative fit testing equipment (TSI Incorporated and OHD USA) and both require annual calibration.
There are other benefits to quantitative fit testing even when not required by OSHA. Quantitative fit testing provides a more accurate and precise measure of respirator fit, and certain quantitative fit test methods (Controlled Negative Pressure) are also faster than any existing qualitative method, so your employees get back to work sooner.
Note: This article explains regulatory requirements as they apply to full and half face air-purifying respirators; there are different requirements for other respirator types, as well as for situation where contaminant concentration is more than 50 times the permissible exposure limit or Immediately Dangerous to Life and Health.
Here are some simple and correct tips on what to do when an earthquake hits.
INSIDE A BUILDING
Stay where you are until the shaking stops. Do not run outside. Do not get in a doorway as this does not provide protection from falling or flying objects, and you may not be able to remain standing.
Drop down onto your hands and knees so the earthquake doesn’t knock you down. Cover your head and neck with your arms to protect yourself from falling debris. Stay where you are until the earthquake stops. If you are in danger from falling objects, and you can move safely, crawl for additional cover under a sturdy desk or table and hold on. If no cover is available, stay low to the ground and find an inside corner of a wall away from windows and objects that can fall on you.
If you are outside when you feel the shaking, move away from buildings, streetlights, and utility wires. Drop and cover if possible. Stay there until the shaking stops. This might not be possible in a city, so you may need to duck inside a building to avoid falling debris.
IN A CAR
If you are in a moving vehicle when you feel the shaking, stop as quickly and safely as possible and stay in the vehicle. Avoid stopping near or under buildings, trees, overpasses, and utility wires. Proceed cautiously once the earthquake has stopped. Avoid roads, bridges, or ramps that the earthquake may have damaged.
It is important to understand that proper training for your powered industrial truck operators may involve two related, but distinct types of courses.
Operator safety training courses are designed for people who know the basics of driving a forklift or other powered industrial truck, but need to be educated on how to perform material handling tasks safely, follow OSHA safety guidelines, and be evaluated as they demonstrate these safe handling behaviors “behind the wheel.” This is an important part of your facility accident prevention program, and is required by OSHA for all forklift operators.
These types of operator safety trainings are not designed for brand new operators (those who have never driven a forklift before). It would be like hiring someone who has never driven a car before, and sending them in a company vehicle to a defensive driving class or performance driving school when they don't even know how to control the car.
So what can you do when you have a hire that you want to drive forklifts in your facility, who needs to attend a safety training course, but has no driving experience? This is where new operator training comes in.
In new operator training, attendees will typically work one-on-one with an instructor in a controlled environment to gain knowledge and practical experience in the basics of forklift operation. This will prepare them to attend a forklift safety course and succeed in the behind-the-wheel evaluation.
As an alternative, employers who have an experienced forklift operator with the training, knowledge and experience to safely train new operators in the basics of forklift operation may elect to conduct this new operator training themselves, and then have these employees ready for the forklift safety training course conducted by a vendor.
Either way, employers should ensure each attendee is in a course appropriate for their skill level. Having brand new operators in a safety training class is both unproductive and unsafe.
Many classes were brief, usually presented by human resources or safety generalists without a background in security or active shooter response. They utilize “stock” materials provided by the Department of Homeland Security or other government agencies. Make no mistake, these simple trainings are an excellent start ; they get employees who might have never thought about what to do in a workplace shooting to start thinking about what they can do to survive. However, from a training perspective, it does not go far enough in teaching employees specific techniques, and the facilitators usually only have an awareness-level knowledge of the topic themselves.
In contrast, many employers turned to hiring third party instructors, generally ones touting military or law enforcement credentials. While this can be an excellent background for facilitating these courses, having experience as a soldier or police officer doesn’t in itself equate to being a good instructor. Showing up as one of many armed responders after a shooting has started is a very different position from being an unarmed worker caught by surprise when an incident begins. Many attendees seemed to leave these classes feeling more frightened and less empowered than when they started.
Over the last few months, active shooter training programs have improved significantly to better address the needs of the typical workplace, and employers have learned to become more discerning when evaluating the qualifications of vendors or instructors.
Training providers are developing better programs, and fielding instructors that have the right combination of experience and teaching ability. Attendees are learning not just that they should run, hide or fight, but getting confident about knowing how to do these things. However, one critical topic is still missing from many workplace active shooter trainings: first aid.
According to FBI statistics ( source ), most active shooter incidents are very quick: almost all under five minutes, most under two minutes. While protracted gun battles and standoffs might capture more media attention, statistically mass shootings in workplaces start rapidly and end a few minutes later when the shooter either flees or commits suicide. In other words, the event will probably be over long before 911 arrives. Even once professional responders arrive, their priority will be security: making sure the shooter is either gone, dead or arrested. Medical help for shooting victims will not be provided until after the area is secure.
An employee injured during a shooting faces a very long wait until medical help will be provided. Run, hide, fight is a great strategy that we teach in all our workplace active shooter classes at SAFEWEST. However, the reality is that a training course on not getting shot should also include training on what to do if someone does get shot. This is a step beyond mass shooting prevention and defense, and also different from standard workplace first aid trainings. However, first aid for gunshot wounds is a topic that can be simplified and taught to employees, and should be a key component of any comprehensive workplace active shooter training.
To stay compliant, a company with an automated external defibrillator (AED) for use by their employees should:
- Obtain a physician's authorization (essentially a facility "prescription") for the AED unit.
- Notify the local EMS agency of the type of AED installed, and its location.
- Maintain the AED according to manufacturer guidelines and have current, unexpired pads and batteries.
- Inspect the AED at least once a month, or more frequently as required by the manufacturer. An inspection is a quick check for potential issues related to operability of the device, including a blinking light or other obvious defect that suggests a problem, and checking the condition and expiration date of batteries and pads.*
- Test the AED at least twice a year, or more frequently as required by the manufacturer. A test is more involved than an inspection, and generally requires the running of a program or protocol on the AED. Most AEDs should do this automatically without user intervention. Check your AED documentation.
- After an AED is used, it should be tested. Pads should be replaced and the battery may need to be replaced.
When the building owner provides an AED, they must also meet the following requirements in regards to informing building tenants or occupants of the AED and its use:
- Next to the AED, post instructions, in no less than 14-point type, on how to use the AED.
- Provide annual demonstration of the AED to the person(s) in the building who may need to use the AED in an emergency.
- Provide annual information to tenants about who they can contact if they want to voluntarily take AED or CPR training.
*Note: While California 1714.21 only requires inspections every 90 days, most AED manufactures require monthly checks, and the American Heart Association recommends weekly or monthly checks.
Here are three simple improvements based on best practices from leading safety programs:
- Improve engagement. Don't have lockout/tagout be just a yearly safety topic. Designate a lockout/tagout lead person in each area or department that can act as a mentor, monitor compliance and provide quick refreshers.
- Keep lockout/tagout equipment as close and convenient as possible. Employees are less likely to use equipment (especially during emergencies or for quick tasks) if they have to go to a far away office or locker.
- Simplify the lockout/tagout process. Try to design your equipment and lockout systems with easy lock attachment points that don't require extra devices or adapters from kits.
Keep these simple tips in mind when designing or reviewing your lockout/tagout program. Small improvements add up to a big difference when it comes to facility safety and efficiency.
While prevention is the most important thing, if a person begins suffering from heat-related illness, you must act fast! Here's the most current research from the Safewest first aid curriculum.
Heat exhaustion can happen when a person is working hard or exercising in the heat and their body is having a difficult time coping with the elevated temperature.
You will usually see the following symptoms:
- Heavy sweating
- Feeling tired or dizzy
- Muscle cramps, especially in the torso and legs
First Aid measures for heat exhaustion are relatively simple, and involve moderate cooling measures. As with any first aid situation, make sure the scene is safe before rushing in to help anyone.
- Have the person lie down in a cool, shady place.
- Remove any heavy outer clothing, protective equipment and shoes.
- Wipe the victim’s exposed skin with cool, wet cloths.
- Fan or move victim to air conditioned room.
- Offer sips of an electrolyte drink or water.
If a person suffering from heat exhaustion doesn't get help, they can suffer from a more serious condition called heat stroke. With heat stroke, the body can no longer maintain a normal temperature, and begins overheating. This is potentially deadly, and you will have to act fast.
A person suffering from heat stroke will have many of the same symptoms as a person with heat exhaustion, but the important difference is the effect on their mental status. If they're getting so hot that their brain is affected, you will see symptoms like:
- Seizures or hallucinations
- Confusion or disorientation
- Irritability and personality changes
- Uncoordinated, Difficulty walking well
- Not responding/unconscious
First Aid for heat stroke involves rapidly and aggressively cooling the person. As always, make sure the scene is safe before helping with any emergency. First, if you suspect heat stroke, call or have someone call 911 or your emergency response number immediately, then begin the following steps.
- Move the victim to a cooler environment, such as indoors, shade or an air-conditioned vehicle.
- Remove clothing down to underclothes.
- Reduce body temperature with a cold bath or sponging.
- If you have ice bags or instant ice packs available, these can be placed at the sides of the neck, at the groin, under the armpits and behind the knees to help cool the body.
- Use fans and air conditioners.
- Give a beverage only if the victim is alert and can sit up and swallow.
Workplaces, regardless of industry, need to consider the chances that either an employee or an outsider may arm themselves and start shooting. As with any workplace safety concern, prevention is critical. Evaluate your facility security measures, recognize potential workplace violence indicators and ensure proper access control procedures are adhered to.
If prevention fails, your employees should have some basic knowledge of what to do. Active shooter training doesn't necessarily have to be extensive; a brief awareness-level training for all your employees can help significantly increase the odds of survival during a workplace incident.
For most situations, the best response to an active shooter training can be summarized with the following steps:
- Run: get out of the building or area as quickly as possible.
- Hide: conceal or barricade yourself in a safe area.
- Fight: use empty hands or improvised weapons to fight back.
The steps are deliberately ordered in this way, from the safest and most desirable to the riskiest. In other words, don't stay and try to fight if you have a clear way out to safety, or don't hide in a storage room when an easy escape exists. However, if a fast exit isn't a possibility, you may have to resort to hiding or fighting.
By starting with these simple steps, and planning in advance, employees will be better prepared for an active shooter event in the workplace. Consider testing and reinforcing any training concepts by staging an active shooting escape drill in the same way employees might practice fire drills or other emergency evacuation procedures.
The video below provides a good introduction on what to do in an active shooter event: