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Cal/OSHA Electronic Reporting of Injury and Illness Data

  • By carlo
  • 07 Dec, 2017

California's Delayed Implementation of Mandatory Electronic 300 Log Submission

With a rule that took effect January 2017, Federal OSHA began requiring  electronically submit Log 300 records of injuries and illnesses ( source ). This electronic reporting requirement applies to companies who meet any of the following criteria:
  • Having establishments (locations) with 250 or more employees 
  • Having establishments with 20-249 employees in certain high-risk industries ( source )
For states like California that have their own occupational safety and health plans, they will have to adopt requirements that are substantially similar to the requirements in this final rule. California was required to do so as of June 2017, but has yet to properly implement electronic reporting. According to a California Department of Labor information page , the state is in the process of developing their own electronic reporting requirements. However, as of December 2017, they have failed to do so. If your company meets any of the two establishment requirements listed above, check Cal/OSHA's information page periodically to see if there are updates. 


By carlo 02 Jan, 2018
The  Construction Health and Safety Technician (CHST) certification offered by the Board of Certified Safety Professionals is the best-recognized construction safety credential for safety professionals. The best place to start is with the BCSP's own guide, which is a PDF document called "Complete Guide to the CHST" ( link ). Before you even start thinking about applying and studying, make sure you meet the minimum requirements; you must have a high school diploma or GED, and at least three years of experience in the construction industry, where at least 35% of your primary duties were related to safety, health and environmental programs.

If you meet the requirements and have reviewed the complete guide to the CHST, it's time to start studying. Many CHST applicants have a lot of construction experience, and may be "doing safety" but not have a formal background or education in that area. Studying is going to require:
  • General principles of safety management
  • Details on the specifics of OSHA standards and industry best practices for construction
  • Math calculations that apply to common construction safety scenarios
If you read the Complete Guide to the CHST document, the amount of material on the exam seems daunting, and some of the areas you may need to study seem to fall far outside your experience, and may involve specialized types of construction that you are not involved with. The key to remember with the CHST is you only need to get a passing score on the exam. Rather than trying to learn everything , focus on gaining general knowledge and awareness of construction safety program management, and filling in details on the more common construction topics. Don't kill yourself trying to memorize safety procedures for more obscure areas like underground tunneling (unless you work for a company that does those types of projects) since you may only get one or two questions about that on the test. If you do well on the other material, you can afford to guess on a few questions. 

Construction safety will utilize many of the same "big picture" concepts as any other industry. The best way to get this background is to buy/borrow a comprehensive occupational safety reference manual. Here are a few suggestions. 

  • Yates' Safety Professional's Reference and Study Guide ( Amazon )
  • Goetsch's Occupational Safety and Health for Technologists, Engineers, and Managers ( Amazon )
  • Brauer's Safety and Health for Engineers ( Amazon )
Making the transition to understanding bigger picture safety concepts and practices can be daunting. As you review your selected reference book or other resource, try to break your review up into sections, and try to see how the concepts in each chapter might apply to construction safety programs. Not every section of these reference guides is relevant to construction.  Make sure you master key concepts about safety management, accident analysis/investigation, training, injury/illness tracking, and employee motivation. Go in depth on technical sections like lifting, excavations, fall protection, lifting/material handling, rigging, environmental (heat/cold) illnesses, respiratory protection and electrical safety, as the CHST exam will test your knowledge of these topics as they apply to construction. 

The books mentioned about all include reviews of important health and safety mathematical concepts. The ones that are most relevant to construction that you should focus on are:
  • Basic Trigonometry (understanding angles and applying these concepts to ramps, excavations, ladders, sling loads and other construction scenarios)
  • Calculating Rates (OSHA Recordable Incident Rate, Lost Time Case Rate, Lost Work Day Rate (LWD), DART Rate (Days Away/Restricted or Job Transfer Rate), Severity Rate
  • Heat Illness Risk Calculations (heat index and wet bulb globe temperature)
There are a variety of sources of practice questions for the CHST exam. Doing practice questions can help learn the breadth of exam topics, and also sharpen your test taking skills.The BCSP makes their own CHST self-assessment available. The plus side is that is closely replicates the types of questions you may see on the exam. The downside is that it's fairly expensive for what you get, and doesn't let you practice electronic test taking (which is how you will be tested on the CHST exam). On a budget, a good recommendation is making flashcards based on your study of safety reference guides, and any relevant construction safety materials you already have. You can also purchase online practice question software from Span Exam Prep or DataChem.

Using these study and practice strategies should help you in getting a passing score on the CHST exam. 

By carlo 07 Dec, 2017
With a rule that took effect January 2017, Federal OSHA began requiring  electronically submit Log 300 records of injuries and illnesses ( source ). This electronic reporting requirement applies to companies who meet any of the following criteria:
  • Having establishments (locations) with 250 or more employees 
  • Having establishments with 20-249 employees in certain high-risk industries ( source )
For states like California that have their own occupational safety and health plans, they will have to adopt requirements that are substantially similar to the requirements in this final rule. California was required to do so as of June 2017, but has yet to properly implement electronic reporting. According to a California Department of Labor information page , the state is in the process of developing their own electronic reporting requirements. However, as of December 2017, they have failed to do so. If your company meets any of the two establishment requirements listed above, check Cal/OSHA's information page periodically to see if there are updates. 

By carlo 14 Oct, 2017
As of October 2017, these are the penalties than can be imposed by Cal/OSHA for workplace safety violations. The most current information on penalties and fine amounts can be found in  §336: Assessment of Civil Penalties.  There is a very broad range for most of these proposed fines, based on the likelihood that they would lead to injury and illness, the potential severity of the injury or illness, the extent (number of workers exposed), and an employer's overall safety program and past history. 

Note that while most workplace safety violations are enforced with civil penalties (fines) against a company, an individual manager or owner can be charged with a crime for a willful violation of a safety standard that leads to the death of an employee; if convicted, they can be fined and imprisoned.

Regulatory Violations
Regulatory violations are those that relate to permit requirements, posting of required notices, improper record-keeping, and reporting of injuries and illnesses.
Penalty amounts range from about $500 to $12,500 for most general regulatory violations, with certain types having a higher minimum fine.

General Violations
Violations of OSHA standards that directly expose employees to harm, but not serious levels of harm. 
The maximum penalty amount is about $12,500. 

Serious Violations
Violations of OSHA standards that directly expose employees to serious harm.
Penalty amounts range from $18,000 to $25,000. 

Repeat Violations
Violation of an OSHA standard within five years of having been previously cited for a violation of the same or similar regulation. 
Penalty amounts will be multiplied by two for the first repeat violation, multiplied by four for the second repeat violation, and multiplied by ten for the third repeat violation, up to a total amount of about $125,000.

Willful Violations
Circumstances where evidence shows the employer knew they were violating OSHA regulations and were aware of a hazard, but made no reasonable efforts to correct the safety problem.
Initial penalty amounts will be multiplied by five, up to a total amount of about $125,000.

Failure to Abate Violations
If an employer fails to address a hazard after the deadline given by Cal/OSHA, additional penalties may be added of up to $15,000 for  each day the hazard goes uncorrected. 

By carlo 29 Sep, 2017
How is Hepatitis A Spread
The hepatitis A virus is primarily transmitted through oral contact with something that has been contaminated with the feces of an infected person. This can happen through direct contact with the person, or indirect contact with an object (including food or water) that has been contaminated.

What are the Symptoms of an Infection

Symptoms can include fever, fatigue, nausea, loss of appetite, yellow color in the eyes, stomach pain, vomiting, diarrhea, dark urine, and pale feces. Keep in mind that not every infected person will show these symptoms, and most of these symptoms could also match a number of other illnesses, some minor, some deadly.

What Workers are Most at Risk
The majority of persons infected in San Diego's current outbreak have been homeless and/or illicit drug users. However, this does not mean others are not at risk, or that someone with Hepatitis A is an illicit drug user. 

From a workplace practice perspective, the biggest exposure risks for Hepatitis A are to the following employee classes:
  • Those who travel or commute to and from counties with moderate or high risk of hepatitis A. Per the Center for Disease Control, this currently includes all parts of the world except  the United States, Canada, western Europe and Scandinavia, Japan, New Zealand, and Australia.
  • Workers who do cleaning and housekeeping as a main job duty, such as housekeeping or janitorial staff.
  • Workers who do cleaning as an occasional job duty, such as construction workers cleaning a new jobsite, or maintenance staff cleaning equipment before service.
  • First responders who may have contact with an ill or injured person. This includes employees trained in first aid, who may volunteer to help if there is a workplace emergency.
 What Businesses are Most at Risk Financially
Keep in mind, risks to individual workers is different than the financial risk a business may face due to a hepatitis outbreak. For example, demographics aside, the job of being a food service worker isn't as high risk for the employee as some other occupations, but Hepatitis A spread by a food worker can affect non-employee members of the public, and significantly impact a businesses operations. Hospitality and food service establishments should be particularly vigilant in order to protect not only their employees, but their customers, and business reputation. 

What are the Best Practices to Reduce Hepatitis A Risk?
There are many specific work practices and safety measures to reduce Hepatitis A risk, but the most important for all industries and workers are:
  • Proper hand hygiene. Clean hands frequently using lots of soap and warm water, or hand sanitizer (if hands are not visibly dirty).
  • Obtain the Hepatitis A vaccine (or verify previous vaccination). A very simple, two-shot series available at no cost to most people. 
What Other Resources Are Available

By carlo 29 Sep, 2017
OSHA requires that any employee wearing a respirator  complete a medical evaluation to determine the their ability to use a respirator. This medical evaluation should be provided (paid for) by the employer, and needs to be completed before the employee wears a respirator for fit testing, or for work. 

Unlike respirator fit testing and training, which must be done annually, OSHA standards do not set a time-based renewal period for the medical evaluations. According to Cal/OSHA §5144(e) and  Federal OSHA 1910.134(e) , medical evaluations must be redone if:

  • An employee reports medical signs or symptoms that are related to ability to use a respirator
  • A healthcare provider, supervisor, or the respirator program administrator informs the employer that an employee needs to be reevaluated
  • Information from the respiratory protection program, including observations made during fit testing and program evaluation, indicates a need for employee reevaluation
  • A change occurs in workplace conditions (e.g., physical work effort, protective clothing, temperature) that may result in a substantial increase in the physiological burden placed on an employee.

However, we recommended that employers develop a time-based renewal interval for medical evaluation questionaries. The criteria stated above for redoing the initial evaluation wont account for changing work conditions that aren't noted, and problems employees don't report or supervisors don't notice. In addition, even without any "red flags," the health condition of workers will decline over time due to the natural aging process. 

One year is the best and simplest renewal interval, as it would fit with the renewal of fit tests and respirator safety training. However, based on the nature of work, type of respiratory protection, and workforce demographics, other longer intervals may be reasonable. Most employees will not voluntarily disclose a health problem to their employer. However, if done correctly, regular interval medical evaluation questionaries provide them an opportunity to report such health problems confidentially, and to speak with a healthcare provider with any questions or concerns. In addition, regular medical evaluation questionaries are used by employers as "cheap insurance" so that if an employee should develop (or allege to have developed) a medical problem due to respirator use, but they did not report that problem on a medical questionnaire, it reduces the legal burden on the employer.

Keep in mind that this article is only in regards to the medical evaluation questionaries for OSHA's general respiratory protection standards. We always encourage employers to exceed that standard by sending employees for physical evaluations and/or pulmonary function tests before respirator use, as this will provide a more robust assessment of their health than a questionnaire.  Also remember that some high-hazard contaminants have their own standards which may require more extensive or frequent medical evaluations beyond what is required for general respirator use. 
By carlo 01 Sep, 2017
Any workplace safety program should begin with a thorough assessment of potential hazards and risk from these hazards. After identifying hazards, controlling them is generally guided by a process known as the hierarchy of controls. This hierarchy is traditionally visualized as an inverted pyramid. The idea behind this hierarchy is that the control methods at the top are generally more effective than those at the bottom, so employers should implement solutions using methods as high up on the hierarchy as possible. 

Elimination-Getting rid of the hazard completely
Substitution-Change to a safety alternative for completing the task
Engineering Controls-Isolate the worker from the hazard
Administrative Controls-Change how a task is done or scheduled to make it safer
PPE-Have a worker use Personal Protective Equipment for protection from the hazard

Consider for example a work task that involves exposure to an airborne contaminant, like using a strong solvent to clean a part.
Elimination would get rid of the task completely, by getting rid of the need to clean the part somehow, or outsourcing  that task to another company.
Substitution-The task would still be done, but using a solvent that's safer and less harmful to workers
Engineering Controls-Clean the part in a ventilated cabinet, or use fans or vacuums to remove contaminants from the air
Administrative Controls-Change the way the work is done, like brushing on the solvent instead of spraying it on, so less airborne contaminants are created) or provide the employee with training on how to minimize exposure
PPE-Have them employee wear a respirator

The controls higher on the list tend to be the most effective, and the least prone to failure. They often do cost more to implement, but in the long run, once in place, can save money. In reality, most situations will require a combination of approaches. The most important point is to focus on eliminating or reducing the hazard as much as possible before relying on worker PPE (personal protective equipment). 
By carlo 22 Jul, 2017
A recent American Heart Association survey finds that half of Americans are afraid to perform CPR in an emergency.  The top reason given is fear of legal problems. While the United States is a notoriously litigious country, this does not extend to first aid situations. First aid responders rarely encounter legal problems, even if the victim does not survive (most will not). In fact, all 50 states have passed "Good Samaritan" laws to protect laypersons who perform CPR or give other emergency care from civil liability, as long as they act responsibly and reasonably. Even for professional responders who provide emergency medical care every day, and don't benefit from Good Samaritan protection while working, lawsuits are very uncommon. 

Unfortunately, urban legends about lawsuits and exaggerated claims about liability risks prevent many persons from helping during an emergency. Other common reasons for not performing CPR included being afraid of hurting the person (which usually links to fears about legal liability), being overwhelmed by the complexity of CPR, and not having up-to-date training. Any good training course should teach attendees to manage liability risks, and for laypersons, should emphasize simple, effective compression-only CPR, which has similar survival rates when compared to CPR done in the traditional way with a combination of compressions and rescue breaths.

Effective CPR compressions boost cardiac arrest survival rates to about fifteen percent. While that may not sound like much, consider that the survival rate without CPR is about five percent. Use of an AED (Automated External Defibrillator) can boost survival rates to over 50 percent. An AED can restart the heart of someone who is in cardiac arrest. Some workplaces have invested in these lifesaving devices, but don't have employees adequately trained in their use. Another American Heart Association survey revealed that in workplaces with AEDs, more than half of the employees don't even know where the AED is, nevermind how to use it. While every employee need not be trained in how to use these devices, they should all be familiar with them, and be able to retrieve one in an emergency to assist a trained employee.

When a person's heart stops beating, every minute counts. Relying on 911 to rescue the victim is a losing proposition...95% of victims will die if the only "help" given is a phone call. However, if a bystander can begin chest compressions, and an onsite AED is deployed, survival rates are over 50%. Few companies are making the investment in proper training and equipment to enable these sorts of survival rates. Paradoxically, some are investing in defibrillators (which generally cost over $1,500), but then not following up with effective employee training and education. 

While certain accidents, like an electrical injury, can precipitate cardiac arrest, the problem is not one that necessarily limits itself to high hazard industries. In fact, with the elevated risk of cardiovascular problems caused by sedentary office work, combined with an aging workforce, high density office environments are perfect candidates for a workplace CPR and AED program. When weighed against the cost of either permanently or temporarily replacing an employee, the cost of training employees and providing an AED can be a bargain. Several years ago, we provided a defibrillator and first aid/cpr training for a small financial services firm, at a cost of over $3,00 dollars. We congratulated the management team on making the investment for the benefit of their employees. Their operations manager confessed that what ultimately led to the program being implemented was a simple cost-benefit analysis; the unexpected loss of any of their key personnel would easily cost the company tens of thousands of dollars...having a program in place to increase the odds of survival after an injury or an accident just made good financial sense. 
By carlo 15 Jul, 2017
While the format of courses may seem similar (classroom training followed by hands-on practice), the details are what will distinguish top-tier training providers.

First, remember that there is no regulation, licensing or certification of fire extinguisher training providers by Cal/OSHA or any other government agency. You should do your due diligence in selecting qualified providers, and evaluate overall value, not just cost.

Second, a key benefit of workplace fire extinguisher training is business continuity and profitability. If employees can use an extinguisher correctly to put out a small fire before it becomes a big fire, it saves product, equipment and buildings. However, they should also understand when it would not be safe to try and fight a fire, and know the limitations of portable extinguishers. A good training class will meet both these objectives.

Here are two important questions to ask potential vendors.

Who is doing the training and what is their background?
Knowing how to service extinguishers is a different skillset than training others to use them to safely put out fires. Make sure the class will be taught by an instructor experienced in workplace training, not just an extinguisher service technician who will occasionally teach a class with a video or powerpoint.

How is the hands-on portion done?
OSHA requires that fire extinguisher training include a hands-on component. Avoid vendors who do an extinguisher “demonstration” that attendees just get to observe, or where only a portion of attendees get to participate. Everyone should get to practice deploying an extinguisher.
The specific method used for the hands-on portion is also important. While a pan of diesel or gasoline and some dry chemical extinguishers provide a realistic training experience, it creates the hazard of a large pan of burning liquid in the workplace, and the residue from the powder chemical extinguishers will spread to surrounding areas of the parking lot, and can also create stormwater runoff/contamination and respiratory irritation in employees. A better alternative is modern propane-fueled training systems with a safe, clean-burning flame that can be controlled remotely, and water-charged extinguishers. Digital training systems are another alternative that use a simulated flame and extinguishers projecting a laser beam at sensors to evaluate attendee performance. 

It's worth taking the time to learn the details of the training methods used by each vendor, and speak with the instructor who will be presenting the training to evaluate their qualifications. For companies in San Diego, contact us to learn more about our fire extinguisher training classes . Course instructors all have 5 or more years of adult training experience, and a background in incipient-stage firefighting, and our trainings use propane-powered, electronically controlled burners and water-charged extinguishers. 

By carlo 12 Jul, 2017
Cal/OSHA General industry regulations for flammable liquid storage is found in   Article 141 . This article summarizes the basic storage requirements for when individual portable containers are kept inside a building.

Categories of Flammable Liquids
There are different rules for different types of flammable liquids. They are divided into categories, based on flash point and boiling point. Flash point is lowest temperature at which vapors of the material will ignite, when given an ignition source. A lower flash point is more dangerous than a higher one. Boiling point is the temperature at which a liquid turns to a vapor. A lower boiling point is more dangerous than a higher one. You can look at the Safety Data Sheet (SDS) for a chemical to find out what the flash point and boiling point is.

  • Category 1: Flashpoints below 73.4 °F (23 °C) and having a boiling point at or below 95 °F (35 °C).
  • Category 2: Flashpoints below 73.4 °F (23 °C) and having a boiling point above 95 °F (35 °C).
  • Category 3: Flashpoint at or above 73.4 °F (23 °C) and at or below 140 °F (60 °C). 
  • Category 4: Flashpoints above 140 °F (60 °C) and at or below 199.4 °F (93 °C). 
  • Category Other ("Combustible"): Flashpoint above 199.4 °F (93 °C)
Liquid Storage Requirements
These limits apply for most employers such as shops, offices, laboratories, or retail. Different requirements exist for warehouses ( §5540 ) and hotels and other large occupancy locations ( §5537 ). 

When you have more than a certain total amount of flammable liquids, you must store them in safety cabinet meeting NFPA requirements. Storage in a cabinet is required if you have: 
  • Over 60 gallons of any category liquid
  • Over 10 gallons of a category 1, 2, or 3 liquid, if stored in regular containers. 
  • Over 25 gallons of a category 1, 2, or 3 liquid, if stored in safety cans.
Safety cans  are specially designed containers with a spring-closing lid, spout cover and a flame arrester that are built specifically for fire safety.

Whether they are in a cabinet or not, no container for Category 1, 2 or 3 flammable liquids shall exceed a capacity of one gallon, except that safety cans can be two gallons.

Whether they are in a cabinet or not, flammable liquids should never be stored where they would limit or compromise the use of any emergency exit routes.

Not more than 120 gallons of Category 1, 2, 3 and 4 flammable liquids may be stored in a storage cabinet. Of this total, not more than 60 gallons may be of Category 1, 2 and 3 flammable liquid.

Not more than three cabinets may be located in a single fire area, except that in industrial operations, additional cabinets may be located in the same fire area if the additional cabinet, or group of not more than three cabinets, is separated from any other cabinets or group of cabinets by at least 100 feet.

While the regulations for flammable liquid storage may seem confusing, consider that every employer is already required to have Safety Data Sheets (SDS) for almost all chemicals in the workplace. Based on that information, you can categorize what you have and see what the storage requirements are. Basically, the more flammable the chemical, the less of it you can have. One thing some employers do to simplify things is to apply the stricter category 1, 2, and 3 requirements to all categories of flammable liquids, so there's less of a need to differentiate between the different categories, and the amounts of each you have.
By carlo 01 Jul, 2017
Would you know what to do if your coworker collapsed in front of you while working outdoors?  What if a friend or family member started suffering from heat exhaustion while out hiking or playing sports?

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
  • Nausea
  • Headache
  • 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 the person doesn’t feel better in a few minutes, or gets worse, call your emergency response number and continue cooling them.

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.
While there's no substitute for taking a First Aid class, reviewing these symptoms and emergency treatment measures for heat-related illnesses can help you be more prepared while working or recreating outdoors.  
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