OSHA Injury Reporting & Recordkeeping Changes

OSHA recently adopted final rules on discrimination and injury/illness reporting that will impact most employers! Here’s a breakdown of the significant changes:

OSHA Injury Reporting & Recordkeeping Changes

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Reporting Changes (Effective 1/1/16)

Employers are required to report fatalities and serious injuries as follows:

  • Fatalities: These are required to be reported within 8 hours.
  • Serious Injuries: Hospitalization of one employee (changed from three), any amputation, or loss of an eye must be reported within 24 hours.
  • The reports can be submitted directly by phone or online through this OSHA link; https://www.osha.gov/report.html. Note that State Plan states may have their own reporting functions. You can find out through the same link.

Electronic Recordkeeping

Employers have always been required to maintain the OSHA 300 logs. This hasn’t changed, but OSHA is implementing an electronic reporting function (Changes effective 1/1/2017), which will require the following:

  • Employers with 250+ employees require electronic submittal of all Form 300, 300A and 301 information.
  • Employers with 20-249 employees in certain industries require electronic submittal of only Form 300A information.
  • Employers with <20 employees are not required to submit electronically, but must still maintain the OSHA logs in-house (except certain exempt industries).
  • Note that OSHA will post this data on a publicly available website, which may be accessed by competitors, contractors, employees, and employee representatives. If possible, care should be taken to avoid posting information such as employee names, addresses, and other confidential information.

Additional requirements effective 8/10/2016


The new rule includes an anti-retaliation section. OSHA compliance officers can issue citations to employers who discipline workers for reporting injuries or illnesses when it believes that no legitimate workplace safety rule has been violated.

Post-Accident Drug-Testing

The final rule includes elements to ensure no “adverse actions” are taken by employers that might dissuade an employee from reporting a workplace injury. They have concluded that a blanket policy for post-accident drug testing may constitute an adverse action, instructing employers to “limit post-incident testing to situations in which employee drug use is likely to have contributed to the incident, and for which the drug test can accurately identify impairment caused by drug use.” For this reason, employers might want to review their policies on post-accident drug testing.

Incentive Programs

OSHA also believes that incentive programs that deny a reward based on injury or illness reports may constitute possible “adverse actions.” Employers with incentive programs should also review these programs to ensure that they provide benefits based on compliance with Safety rules or other positive actions by employees.

Contact Chuck Paulausky, CHMM at CP Safety if you need additional information, guidance or training on this topic!

Safety Teams – An Important Key to Culture Change

According to the February 6, 1955 Des Moines Tribune, “The State Senate of Illinois yesterday disbanded its Committee on Efficiency and Economy, for reasons of efficiency and economy.”

There are lots of articles out there about Safety Committees. Meriam Webster defines a committee as “a body of persons delegated to consider, investigate, take action on, or report on some matter.” For me over the years, the word “committee” has developed certain connotations as being a group of people that meets too often for too long to discuss too much without getting a lot done. I have taken a different approach to these groups for a couple years and tend to call them “teams”, defined by Meriam Webster as “a group of people who work together.” You will get better results with a “team” than with a “committee.”

I’ve been working in the Environmental, Health and Safety field for more than 25 years and have developed Safety Teams for a number of companies. My last corporate position was with an international company, with responsibility for employee safety at multiple facilities across the globe. I couldn’t be everywhere at once, so it was necessary to have people at each facility to be my “eyes on.” These Safety Teams performed a number of functions, and without them, I couldn’t have effectively done my job.

Since then, I’ve encouraged my clients to develop a Safety Team as a way of getting the employees involved in the Safety program. Other benefits include:

  • Demonstrating management concern for the employee’s well-being
  • Increasing employee Safety awareness
  • Making changes to reduce injuries and cut the related costs, including Worker’s Compensation.
  • Improving employee morale
  • Reducing the risk of OSHA citations and penalties

The purpose of a Safety Team is to bring workers and managers together to promote and maintain a safe, healthful workplace. A Team ensures that safety is treated as an integral function of the company. Participants can vary based on the type of facility. Some companies have Team members from the EH&S Department and production workers. Others include members from engineering, quality, and management. Whatever the make-up, teamwork is the key. Each member must have assigned tasks and responsibilities, and the opportunity to contribute.
Safety Team functions can vary depending on the specific needs of the company and the safety program. Some possible functions may include:

  • Making recommendations for change
  • Detecting hazards through facility inspections
  • Analyzing and solving problems
  • Reviewing new chemicals and maintaining Safety Data Sheets
  • Conducting accident investigations and analyzing injury trends
  • Reporting findings and making recommendations to management
  • Performing safety equipment inspections, i.e. fire extinguishers, eyewash/safety showers, spill kits, etc.
  • Taking lead roles in emergency response and evacuations

Critical elements in developing a Safety Team include:

1. Establishing a Foundation

  • Get management commitment to both the time necessary and to implementing necessary and feasible recommendations
  • Establish a common objective
  • Establish an effective method of communication between the Team, Management and the employees
  • Set clear expectations and reasonable objectives
  • Develop an effective corrective action system that ensures that corrections are followed through in a timely manner

2. Recruiting Team Members

  • The first question to consider is how many members does your team need. You don’t want the Team to be too large, but it should have some representation from your primary departments. As a rule of thumb, if your company has less than 200 employees, plan on no more than 10 members; with more than 1000 employees, you should look at multiple Teams for adequate coverage.
  • Look first for volunteers. These employees want to be there and are more likely to attend and contribute.
  • When possible, include members from all levels of the organization:
    • Managers can help communicate needs to upper management, make needed decisions, and be more effective in getting funding, where needed.
    • Supervisors play a key role in communication with the workers and in implementing changes.
    • Employees on the Team will send a message to all the workers that the Team values their involvement and input on Safety issues.
    • Facilities and Human Resource presence on the Team can be crucial to being effective and getting things done.

3. Team Formation

  • Team leadership. Select someone to lead the Team with knowledge, dedication to Safety and the ability to interact with the others towards effective results.
  • Establish clear and practical goals for the Team.
  • Cleary define the functions that the Team and its individual members will perform, and provide training, as needed to perform those functions.

4. Safety Team Meetings

  • Establish a set meeting frequency, but be flexible. I recommend monthly meetings to start. Once the Team is functioning, you may find that you can adjust this to every other month, or quarterly, as long as this gives your Team adequate time to be effective. Quarterly meetings should be a minimum.
  • Set the meeting schedule for the same time and date each month, e.g., the first Wednesday of each month at 1:00 PM. Allow adequate time for the meetings, but try not to exceed one hour. Set the meeting using a company network calendar, like Outlook, so that these meetings will show up on everyone’s calendar.
  • Prepare a format for meeting agendas and minutes. Keep good records and documentation of the meetings, including recommendations, assigned tasks, and corrective actions.
  • Use the meetings to assign responsibilities and target dates for new Safety issues, review status on past issues, discuss projects, Team inspections, etc.

5. Communication

  • Post names of the Safety Team members throughout the facility, and let the employees know that these are contacts for them, if they have safety concerns. Also establish a method that the employees can use to make suggestions or voice concerns, e.g., suggestion boxes. And bring these concerns up at the Team meetings. These concerns need to be taken seriously, and deserve a response, even if the answer is no.
  • Use the agenda and minutes to communicate with the Safety Team members. The minutes can also be posted for all employees to see that the Team is working to their benefit. Copy managers and supervisors when you send out the minutes, so they know what’s happening and how it might affect them, their departments and employees.
  • Periodically acknowledge the Team members for their contributions.
    Like any other company function, Safety Teams can pose some challenges. These are some pitfalls to avoid:
  • Make sure that it’s clear to all the employees and management that the Safety Team doesn’t bear total responsibility for Safety at your company. Safety takes effort by everyone, from upper management to the custodian and everyone in between.
  • Try not to limit Team membership to only specific levels or groups within the organization.
  • Don’t expect overnight results. Culture change takes time.
  • Avoid “assigning” members to the Team. Volunteers make more valuable members.
  • Avoid complacency. Rotate members periodically to get a fresh perspective.
  • Realize that not all safety concerns brought to management will be addressed.
  • Don’t waste time and effort. Assess risk to set priorities.
  • Maintain confidentiality when discussing employee injuries.
  • Don’t assign Team members to perform Safety inspections without some training and guidance. Like anything else, they can’t do the job as effectively if they don’t know how.
  • Stay on track. Document everything, including meetings, decisions, recommendations, and follow-up for corrective actions.
  • Be willing to go outside the company for the right resources.

Note that while there are currently no Federal requirements for Safety Committees, most states do have requirements in one form or another. Be sure to check with your state to see what is or isn’t required. Also note that the CalOSHA IIPP requirements include Safety Committees, and that OSHA is considering adopting similar requirements on a Federal level.

Other strategies that you should consider for your safety program:

  • Monthly Supervisor training topics
  • Plant meetings
  • Group employee meetings
  • Safety alerts and newsletters
  • Safety incentive programs
  • Near miss reporting and evaluation

Safety Teams are critical to developing and maintaining a safe workplace. An effective Safety Team can reduce workplace injuries, and the costs that directly affect a company’s bottom line. Employees will recognize that the company is serious about safety and will gradually become more safety-aware, which will contribute to a positive change in your company’s safety culture.

Special thanks to Laura Malone, who I worked with on this topic several years ago.

Chuck Paulausky, CHMM, is President of CPSE LLC, a consulting firm specializing in OSHA and EPA compliance and loss control for small to medium-sized businesses. Chuck is active with several professional and business organizations and is an AHMP Champion of Excellence Award winner. For over 25 years, Chuck has been providing safety, environmental, and worker’s compensation support to companies in Arizona, Texas, California, Minnesota, Washington, Utah, Europe, and Asia. Chuck can be reached at: 480-694-1975, cpaulausky@www.cpsafety.net, www.cpsafety.net
This article was published in the 2014 Dec/Jan issue of the Journal of Environmental Management-Arizona

Ergonomics, It’s Personal!

ErgonomicsChester Carlson worked as a patent analyzer in the late 1920s, spending long, tedious hours making multiple copies of drawings and documents by hand. He was nearsighted and his cramped posture, combined with his arthritis, made the work unbearable. His solution came three years later, when he invented the copy machine!

Ergonomics is essentially the science of fitting the work to the worker. The term comes from the Greek words “Ergo” (Work) and “Nomos” (Laws) and basically means “the laws of work.”

Ergonomics, as a science, draws on many disciplines, including biomechanics (the effects of internal/external forces on the human body), anthropometry (body measurements), and physiology (body functions), among others.

Some of the more familiar ergonomic concerns include musculoskeletal disorders (MSDs), repetitive motion injuries (RMIs), and carpal tunnel syndrome (CTS); the costs of these can be significant. U.S. employers shell out billions of dollars every year in medical costs, disability payments, and lost productivity because of workplace MSDs. Back injuries are one of the leading workers’ compensation claims. Repetitive motion injuries account for hundreds of thousands of lost workdays every year.

Your wallet can cause sciatica! It’s reported that a lawyer suffered aches and pains in his left leg, not far from where he kept a wallet that in the previous three years had been growing thick with charge cards. The patient’s condition was described as “credit-carditis” but is more commonly called “back-pocket sciatica.” The quick and simple remedy is referred to by doctors as a “wallectomy,’ or wallet removal.


The ability to understand what ergonomics is, and how to identify some of the most common risk factors and practical solutions to use, will aid in reducing the number of ergonomic injuries.

Common MSD Symptoms
These are common symptoms of musculoskeletal disorders:

  • Painful joints
  • Pain, tingling, or numbness in hands or feet
  • Shooting or stabbing pains in arms or legs
  • Swelling or inflammation
  • Pain in wrists, shoulders, forearms, knees
  • Fingers or toes turning white
  • Back and neck pain
  • Stiffness or burning sensations
  • Decreased range of motion and grip strength
  • Inability to perform normal tasks

Risk Factors
Common risk factors include these:
1. Frequent manual material handling
2. Repetitive motions throughout the work shift
3. Awkward or stationary work positions
4. Unnecessary or improper lifting of heavy and awkward items. (Why six-packs? In the 1930s, the major breweries decided that six beers were “the maximum a woman could safely carry” while grocery shopping. Sorry, ladies.)
5. Using excessive force or localized pressure to perform tasks
6. Exposure to excessive vibration, extreme temperatures, and poor lighting
7. Exposures for long durations with insufficient rest periods

Solutions to these risks include:

  • Keep the work in the comfort zone–the area above the knees and below the shoulders.
  • Keep heavy or frequently-handled materials above the knees. Reaching down to lift heavy parts from the floor poses significant risk for back injuries.
  • Keep work materials and processes in line with the spine. Avoid twisting whenever possible.
  • Keep materials close. Reaching for materials, or lifting them at a distance from the body, increases exponentially the possibility of an injury.
  • Keep the wrists in a neutral position. Bending, twisting, and skewing the wrists decreases strength and blood flow.
  • Avoid holding awkward postures for extended periods. Poor postures or high forces for long periods of time are just as bad as repetition.
  • Provide ergonomically designed tools and supports that eliminate awkward hand position, weight, and vibration.
  • Eliminate contact stress. Pressure on soft body tissue will decrease blood flow and reducing oxygen and nutrients to the muscles.
  • Design the workstation for a seated or standing position, as needed. Simply adding a chair to standing workstation isn’t necessarily enough. The seated position needs to be correct, ergonomically, for the work being done. The same approach works for designing a standing workstation.
  • Decrease exposure to vibration. High levels of vibration can increase onset of certain musculoskeletal disorders.
  • Provide ergonomic assessments for general and individual workstations.
  • Provide regular training for supervisors and managers for identifying ergonomic exposures and for the employees to implement changes and improvements, and also for safe lifting.
  • Don’t forget computer workstations, which are a common source of exposure for CTS and other ergonomic conditions.

I’ve got three final comments. First, ergonomics is not a one-size-fits-all approach. If you are going to provide fixes, ensure there is enough flexibility to make adjustments for differently sized workers. Second, much of ergonomics is very personal. An employee’s personal factors over which an employer has no control, such as age, and some control, such as health, lifestyle, hobbies, etc., also will have an impact. Third, as an employer, you can put fixes in place and provide training in how to “do it right,” but it can be difficult to get a worker to change lifelong habits, even if it’s in the worker’s best interests.

Do the best you can, and you should be able to reduce injuries and workers’ compensation claims, as well as promote productivity and a healthy workplace.


This article originally appeared in the September 2014 issue of Occupational Health & Safety.

Housekeeping Tip

The 40 year-old man was shocked by the disaster before him.  He didn’t know how anyone could survive these conditions.  He could only hope that somewhere in the overwhelming destruction he would find his 16-year- old son.  Walking was virtually impossible with so many things strewn across his path.  “Danny! Danny!” he whispered, as he tripped and almost fell several times.  He thought he heard something move.  In desperation, he cried out, “Danny!”  From a nearby pile of unidentified material, he heard his son, “I’m here, Dad.”  “Well, it’s time to get up and get ready for school,” the man sighed. “And for heaven’s sake, clean up this room!”

Poor housekeeping is a common cause of the slips, trips, and falls that result in a large number of employee injuries and fatalities each year. Train your employees to clean up their work areas each day, to put away electrical cords, tools and materials when not in use, and to immediately clean up chemical, oil or water spills.  This can go a long way to keeping them from falling down on the job and dragging your company down with them.

Foot Protection Tip

Police dogs in Duesseldorf Germany have been fitted with special booties to protect their feet from broken glass bottles from drunken party revelers. The blue shoes match the police uniforms and the dogs require training to walk in the shoes. Similar shoes are used by dogs in Alaska for walking on ice.

OSHA has requirements for foot protection which reference ANSI standard Z41-1991 for Personal Protective Footwear. It’s important to evaluate your workplace for conditions that can injure the foot through exposure to impact, punctures, and electrical hazards. It’s also wise to watch for conditions which can cause slips and falls that you can also protect against. Examples may include icy conditions, oily or greasy floors, and of course, broken glass!

Electrical Safety — Don’t be Shocked!

By Chuck Paulausky, CP Safety & Environmental, LLC and Jack Rubinger, Graphic Products

One challenge that’s got a lot of electricians, safety trainers, and frontline workers confused is the definition of low voltage. Another question regards the difference between Alternating Current (AC) and Direct Current (DC) in terms of the risk of shock and/or electrocution. These two areas are linked, since the potential of shock from low-voltage, both AC and DC, is dependent on the amperage involved.

In one case, a client had low voltage direct current exposures to exposed terminal strips on devices on racks under test. The equipment normally operated at 48VDC, but many had variable capacity to operate between 48-73VDC. The devices were changed out frequently as testing was completed. Some of the equipment came with terminal covers, but were frequently left off. Note that the engineers did not work on live circuits. Any exposure to these terminals was incidental, when walking between the rows of racks or when installing a new unit for testing. Monthly facility inspections lead to the discovery of many exposed terminals. Two questions arose:

  • Were these exposed terminals regulated if operated at no more than 48VDC?
  • Was there a potential risk since the exposures were Direct Current, and not Alternating Current?

Voltage Definitions

“Low-voltage” is not specifically defined in OSHA regulations for electrical safety, although there are references to requirements related to “50 volts or more,” such as 1910.303(g)(2)(i) for guarding of live parts, which states that “live parts of electric equipment operating at 50 volts or more shall be guarded against accidental contact“…).”

Another regulation covering the use of work practices and specifically deenergizing parts (§1910.333(a)(1)) states “Live parts that operate at less than 50 volts to ground need not be deenergized if there will be no increased exposure to electrical burns or to explosion due to electric arcs.“

The training requirements specified in 1910.322 include a table (Table S-4) of typical at-risk occupations, with the footnote, 1Workers in these groups (all except Electricians and Welders) do not need to be trained if their work or the work of those they supervise does not bring them or the employees they supervise close enough to exposed parts of electric circuits operating at 50 volts or more to ground for a hazard to exist.

There are also frequent references in the OSHA regulations and elsewhere that refer to high-voltage as being anything greater than 600 volts. The National Electrical Code (NEC) does cover “installations operating at less than 50 volts, including both DC and AC.“

Overall, these references seem to imply that the regulatory ranges are as follows: >600 volts = High Voltage; 50 ““ 600 volts is Low Voltage; and <50 volts (sometimes referred to as “extra-low voltage”) is generally not regulated except by NEC.

Direct Current vs. Alternating Current

Is there a different risk when working with direct current as opposed to alternating current at the same voltage? Research indicates that direct current (DC) is more likely to “freeze” a victim in a shock scenario, but the victim is more likely to recover afterwards. This is one reason that Automatic Defibrillating Devices (AEDs) operate using DC power to halt fibrillation and then give the heart a chance to recover.

Alternating Current (AC) is more likely to cause a heart fibrillation, which is a more dangerous condition for the victim after the shocking current has been halted. The fluctuating AC current is less likely to cause the “freeze” effect. Exposure to both types of current poses risks, albeit different, and both should be avoided. In both cases, the level of risk depends on the amperage of the circuits. Higher amps equal higher risk.


These issues present ongoing problems for many electricians. A combination of training and work practices will safeguard potentially exposed employees, especially those engineers directly involved in the installation and testing process.

I’m a big believer in site-specific training, which should include:

  • General electrical safety topics
  • OSHA applicability and applications for both AC and DC current
  • Types of exposure and methods to reduce the exposures
  • The effects of amperage on electrical shock involving low voltage
  • Proper grounding techniques
  • Daisy-chaining (plugging one extension cord or power strip into another), which can overload wiring
  • Site specific issues and solutions for exposed terminals
  • OSHA requirements for “qualified persons.”

The best approach is to understand both actual risks, and potential risks based on your specific situation. OSHA regulations and NEC guidance provide dependable methods for determining work practices. These include:

  • Regular site inspections of areas and processes prone to electrical risk.
  • Site- and process-specific procedures or SOP’s that require employees to safeguard the equipment being worked on
  • Proper wiring and grounding methods, including wire sizing, use of GFCI’s, etc.
  • Installation of guards to ensure inadvertent exposures
  • Use of approved cabinets and enclosures
  • Proper use of flexible cords and power strips
  • Installation of required signage for guarded locations. OSHA has stated that entrances to rooms and other guarded locations containing exposed live parts must be marked with conspicuous warning signs forbidding unqualified persons to enter.
  • Application of equipment labels

Through diligence, persistence, and follow-up inspections, my client’s exposed terminal problem has decreased dramatically.

Application of these work practices and development of an electrical safety and LO/TO program, will help employees avoid injuries, shock and electrocution.


Chuck Paulausky, CP Safety & Environmental, is a Certified Hazardous Materials Manager. He has worked as an Environmental, Health & Safety professional for over 24 years providing EH&S management and compliance services for manufacturing facilities in Arizona, Texas, Utah, California, Europe, and Asia. For more information, visit www.cpsafety.net.

Jack Rubinger, Graphic Products, contributes to industrial safety blogs and publications worldwide. Graphic Product is the global leader in workplace labeling and signage. For more information about electrical safety and industrial labeling systems, visit www.GraphicProducts.com or email jarubinger@graphicproducts.com.

Laser Safety: The Eyes Have It

Pierre Gougelman had the first glass eye factory in the United States in 1851. At first, the public thought artificial eyes actually gave their wearers new sight.

If only glass eyes worked that way! Unfortunately, some Lasers can result in permanent retinal damage and blindness. Lasers have many common applications these days; everything from barcode scanners and Laser pointers to military Laser targeting and weapons, and a wide range of medical and industrial applications. It’s this last group that I’m most familiar with, having worked for several companies as the Laser Safety Officer.

Laser Light – Laser light differs from ordinary light in three ways:

  • Monochromatic- Laser light consists of one color or wavelength. In contrast, ordinary white light is a combination of many colors or wavelengths.
  • Directional- Lasers emit light that is highly directional, emitting as a relatively narrow beam in a specific direction. Ordinary light, such as from a light bulb, is emitted in many directions away from the source, out of phase.
  • Coherent- The wavelengths of the laser light are in phase in space and time. Ordinary light can be a mixture of many wavelengths.

It is these differences that make the Laser beams useful, and potentially hazardous.

Laser Radiation – Lasers produce Non-Ionizing radiation, which is less hazardous than Ionizing radiation which can interfere with normal cell processes. Lasers operate within a specific range in the electromagnetic spectrum, including Ultraviolet, Visible, Infrared wavelengths. Within this range is the Retinal Hazard Region, which includes Visible and Near Infrared wavelengths. Eye exposure within this Region can result in permanent retinal damage.

Image 1

Laser Classes – Lasers are categorized by class, with Class 3B and Class 4 being of major concern, falling under regulatory requirements for Laser safety programs. Basic classes include:

  • Class 1- These are generally safe as long as they are not disassembled. The MPE is not likely to be exceeded. Common uses: CD ROM players, drives.
  • Class 2/2a- There is a potential hazard if you stare into the beam, but the human blink reflex usually prevents damaging exposures. Example: Supermarket barcode scanners.
  • Class 3a- These may pose an eye hazard if collected or focused into the eye. The MPE can be exceeded, but risk of injury is low. Example- Laser pointers.
  • Class 3b- These pose a serious eye hazard if direct or reflected beam is viewed, but diffuse exposure should not be hazardous. Examples: Research applications, some industrial uses.
  • Class 4- There is an eye hazard if direct, reflected or diffusely-reflected beam is viewed, resulting in devastating or permanent eye damage. These also have potential for significant skin damage. They may also pose a fire risk and fume hazard, depending on the use. Examples: Research, manufacturing.

Laser Bioeffects – Lasers can result in significant skin damage, which must be protected, but eye damage is the primary hazard. Beam damage can be in three forms:

  • Thermal- This is the result of heat generated and absorbed at the site of exposure, causing burns to skin and eyes.
  • Acoustic- This produces a mechanical shockwave similar to the wave effects of dropping a pebble into a pond. Acoustic effects can cause local vaporization and tissue damage.
  • Photochemical- Certain wavelengths can generate chemical reactions in tissue, which in some cases can result in cataracts, corneal or retinal burns, and a greater risk of skin cancer.

The effect to the eye depends on various factors including pupil size, pigmentation, laser pulse duration and repetition, wavelength, and various other factors. Different wavelengths will penetrate the eyes to different levels, causing damage at that level, to the cornea, lens or retina:

Image 2Image 3

Image 4Image 4

Laser Terms – Basic Laser safety terms are used to identify, understand and calculate the protection requirements for a specific laser operated at specific settings. Any changes to a Laser setting will likely change these calculations which are critical to employee safety:

  • MPE (Maximum Permissible Exposure) is the highest Laser energy to which the eye or skin can be exposed without risk, for a given Laser. The MPE is similar to the OSHA Permissible Exposure Limits for chemical exposures.
  • NHZ (Nominal Hazard Zone) is the area within which the exposure to direct, reflected or scattered radiation exceeds the MPE. No controls are required outside of the NHZ
  • NOHD (Nominal Ocular Hazard Distance) is the distance along the Laser beam axis beyond which the MPE is not exceeded.
  • OD (Optical Density) is a logarithmic measurement of attenuation for protective filters, such as Laser eye protection. The OD defines the specific level of protection for a specific Laser when operated at specific settings.

Engineering Controls – There are a variety of controls available, depending on the type of exposure. Examples include, but are not limited to:

  • Interlocks, installed on process enclosures and guards to prevent the Laser from firing or to close a shutter stopping the beam.
  • Beam housings, used to contain an exposed Laser beam between the point of origin and the work.
  • Shutters, which are used as doors that close to stop the beam. These can be interlocked with guards, doors and other computerized functions.
  • Remote firing controls that position the operator away from the exposure.
  • Attenuators, which are used to decrease the power as a beam passes through reflective or absorptive filters or scattering media. The desired level of attenuation is at least the calculated Optical Density for the specific Laser in use.
  • Class 1-rated enclosures, which must be certified for Class 1, or the requirements for the Laser Class must be met.
  • Fume exhaust, to be used when the process generates potentially toxic fumes.
  • Laser Barrier curtains, which can be used to surround a Laser operation to protect anyone outside the curtain from exposure.

Administrative Controls – There are a variety of administrative controls which provide additional protection through signage, labels, Standard Operating Procedures and training. Ensure that responsibility for Laser operations is assigned.

Many states have specific requirements for Laser Safety Officers, and Laser incident reporting. These requirements usually only apply to Class 3b and Class 4 Lasers. Be sure to check with the agency responsible for Laser Safety in your state. Many states refer to or incorporate ANSI Standard Z136.1 for Laser Safety into the state requirements, which may include Laser registration, inspections, medical surveillance, ocular history, and a variety of other requirements.

Personal Protective Equipment – PPE is used as a last resort, when engineering and administrative controls don’t adequately reduce the hazard. Laser PPE may include:

  • Gloves or special clothing, to reduce skin exposure
  • Laser eyewear, to attenuate the laser radiation for eye protection. Laser safety glasses must meet very specific requirements:
    • They must be approved and labeled per ANSI Z136.1
    • They must have the appropriate OD for the Laser type, wavelength, mode of operation (continuous versus pulse wave), and power settings.
    • They should be comfortable for the wearer.

Non-Beam Hazards – There are a number of hazards not directly related to the laser beam exposures:

  • Explosion hazards may exist from accumulation of high-pressure gases in flash lamps, when fired. Also, some lasers use capacitor banks which can explode when not handled properly. Always follow manufacturer’s recommendations when servicing Lasers.
  • Gas exposures from cryogenic and other gases used in generation of certain laser types. Always follow safety procedure for gases and cryogenics
  • Toxic fumes or Laser-Generated Air Contaminants (LGAC) from materials being processed by the Laser beam. Fume exhaust systems will reduce this exposure.
  • Electrical exposures through contact with power sources. Electrical safety and LOTO procedures should be followed
  • Class 4 Lasers are capable of causing fires. Use flame-retardant materials when possible, and always keep a fire extinguisher nearby.

Some of the most common causes of Laser accidents include:

  • Bypassing interlocks. This is always a bad idea.
  • Inserting reflective objects into the beam path.
  • Accidental firing of the Laser.
  • Altering the beam path, or adding additional optical components.
  • Changing the Laser settings without recalculating the MPE, and Optical Density requirements.

Laser Safety Plans – Written plans may be required, but, required or not, I always develop a Laser Safety Plan for my clients that defines the equipment, MPE/NHZ/NOHD, Optical Density/PPE requirements, training, and all other factors for safe operations of the Lasers.

Chuck Paulausky, CHMM, is President of CPSE LLC, a consulting firm specializing in OSHA and EPA compliance and loss control for small to medium-sized businesses.  Chuck is not a Certified LSO, but has maintained Laser safety compliance for companies with Laser operations for over 17 years, including Laser safety plans, registrations, training, and reporting.

Chuck is active with several professional and business organizations and is an AHMP Champion of Excellence Award winner. For over 23 years, Chuck has been providing safety, environmental, and worker’s compensation support to companies in Arizona, Texas, California, Utah, Europe, and Asia. Chuck can be reached at: 480-694-1975, cpaulausky@www.cpsafety.net, www.cpsafety.net

Accident Investigation

A city slicker stopped to ask a farmer for directions. Noticing the dog sitting at the farmer’s feet, he asked “Does your dog bite?” The Farmer replied “Nope.” So, the stranger was very surprised when he bent down to pet the dog and it bit him! “I thought your dog doesn’t bite!” yelled the man. The farmer calmly replied, “My dog doesn’t.”

Asking the right questions is one important key to successfully investigating an employee accident. Standard questions start with the words WHO, WHAT, WHERE, WHEN, WHY, and HOW. If you ask the right questions of everyone involved, including the injured employee, his supervisor, and all witnesses, you should be able to determine what really happened. But more important, you should also identify the causes for the accident, and corrective actions. Remember that the goal of an accident investigation is to prevent future injuries.

Death by Forklift is Really the PITs

From the September issue of OHS Magazine
By Chuck Paulausky, CHMM

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The owner of a machinery and equipment training school was killed while filming a forklift safety video. He was thrown from the forklift and crushed. The investigation revealed that the fatality was due to driver error, high speed over rough terrain, and an unused seat belt.

Unfortunately, this type of forklift fatality is all too common. OSHA statistics indicate that there are ~85 forklift fatalities and 34,900 serious injuries each year. 42% of the forklift fatalities result in the operator being crushed by a tipping vehicle. The safest place for the driver to be is strapped into the seat with a seat belt. According to OSHA, their enforcement policy on the use of seat belts on powered industrial trucks is that “employers are obligated to require operators of powered industrial trucks which are equipped with operator restraint devices or seat belts to use the devices.” Compliance officers will enforce the use of such devices under Section 5(a)(1) of the OSH Act, the General Duty Clause.

OSHA has established detailed regulations for operation of “powered industrial trucks”, which includes all types of material-handling vehicles, from forktrucks to powered pallet jacks to order-pickers. The Powered Industrial Truck (PIT) regulations can be found at 29CFR1910.178. Incorporated into the regulation by reference, ANSI B56.1-1969 covers the design and construction requirements for PITs.

The OSHA regulation provides specific designations for PITs, based on the type of power source and safeguards. In addition, “designated locations” are identified, such as hazardous atmospheres. The regulation also covers a variety of other topics, including operation maintenance and regular, documented inspection of the vehicles, but one critical part of the regulation is for operator training.

PITs can be especially unforgiving under the wrong conditions. Operators need to understand that PITs are very different from regular vehicles in the way they maneuver and are balanced. Employees who have never driven a PIT will not have the innate knowledge and skill to drive one without training. For this reason, much of the required training is focused on operation, load capacity, stability, and operating limitations.

Some of the key factors that should be covered to help operators understand technical aspects of forklift operation include:

  • Center of Gravity- The size and the center of gravity of a load can directly affect the safe lifting capacity of the PIT. Positioning the center of gravity as close as possible to the center of the PIT will help keep the vehicle from toppling sideways, especially when turning.
  • Load Center- The load center relates to the distance of the center of gravity from the vertical face of the forks. Keeping the load as close as possible to the vertical face will help keep the load from overcoming the counterweight at the rear of the vehicle causing it to tip forward. Simple calculations can be used to determine whether a load can be handled by a particular forklift: Capacity x rated Load Center = Maximum Allowable Inch-Pounds; Dividing this by a load’s actual load center will tell you the maximum allowable weight for the load.
    • For example, let’s say a forklift has a 4000-pound capacity with a 24″ load center. The Maximum Allowable Inch-Pounds is 96000 in-lbs. Suppose a load has a 30″ Load Center. Dividing 96000 by 30″ results in 3200 pounds, the maximum the load can weigh to be safely lifted by this forklift.
  • Stability Triangle- This is a triangle formed by the front axle and the rear center point inline with rear axle. The combined center of gravity (load center plus vehicle center of gravity) must stay within the stability triangle to maintain stability. Speed of travel, centrifugal force from turning, load height, mast tilt, ground slope, and various other factors will also affect the location of the combined center of gravity.

Center of GravityOperators must receive training for each type of PIT that they will be operating, including the use of any attachments, i.e. manlifts, drum attachments, etc. The training must also include the conditions under which the vehicle will be operated, such as surface conditions, ramps and slopes, hazardous locations, visibility, and pedestrian traffic. Since these factors are different from workplace to workplace, OSHA requires the training to be site-specific.

Training must be conducted by “persons with the necessary knowledge, training, and experience to train powered industrial truck operators and evaluate their competence.” The training must include both formal instruction and practical driver training. The trainees must also be evaluated initially and every 3 years to establish that they are qualified to safely operate the equipment. Refresher training is required: (1) whenever an operator is observed operating unsafely, (2) when an operator receives an unsatisfactory evaluation, (3) when an operator is assigned to a different type of PIT, and (4) when changes in workplace conditions could affect safe operation. As with any OSHA-required training, the training and evaluations must be documented.

The use of Powered Industrial Trucks is critical to many industries. By implementing a forklift safety program and effective PIT training, you can ensure that this asset doesn’t become a liability.

Stay Safe! Chuck Paulausky

This updated article was originally published in the June 2008 issue of the Journal of Environmental Management-Arizona

Chuck Paulausky, CHMM, is President of CP Safety & Environmental LLC, a consulting firm providing EPA & OSHA compliance support, and worker’s compensation loss control/risk assessment services. Since 1989, Chuck has been providing safety and environmental support to manufacturers and other industries in Arizona, Texas, California, Utah, Europe, and Asia. Chuck is active in several professional and business organizations, and is an ACHMM Champion of Excellence Award winner. Chuck has been an annual planning committee member and presenter for the Gatekeeper Regulatory Roundup, Arizona’s premier professional development event since its inception in 2005. Chuck can be reached at: 480-694-1975, cpaulausky@www.cpsafety.net, www.cpsafety.net

Top Ten Mistakes Made When Completing OSHA 300 Log

According to Chuck Paulausky, President of CP Safety & Environmental, employers from nonexempt industries with more than 10 employees are required to maintain the OSHA 300 Log for work-related, OSHA-recordable injuries. Beginning February 1 until April 30, employers are required to post their annual OSHA Summary Form 300A for the previous calendar year. This annual Summary needs to be displayed in a location accessible to all employees.

The Log can be downloaded at https://www.osha.gov/recordkeeping/RKforms.html. Because completing the Log can be challenging and confusing, here is a list of the most common mistakes made by employers:

OSHA 300 Log Top Ten Mistakes

  1. Failure to maintain the Log. There are some exclusions to this recordkeeping requirement, but it is required for most companies with more than 10 employees.
  2. Not using unique case numbers (Item A). This unique number will help keep the cases straight, and should transfer to the OSHA Form 301 which is filled out for each case.

  3. Failure to provide a detailed description (Items E and F). OSHA requires the injury type, location and source. However posting “Cut finger” just doesn’t cut it. A better entry would be, “Employee sliced tip of left index finger while using a utility knife to open a box in the stockroom.”

  4. Too many columns checked for classifying the case (Items G-J). OSHA wants only the most severe information about the case. Selections are listed left-to-right in order of severity: “Death (G)” is worse than “Days Away From Work (H).”  Days Away is worse than “Job Transfer (I)” and so on. Anything else is “Other recordable cases (J).”  CHECK ONLY ONE.

  5. Incorrect lost days count (Item K). The day of the injury is not counted as a lost-time day. Even if the employee is injured at the very beginning of the workday, goes to the clinic, spends the rest of the day at home and returns to work the next day, there is no lost time. One helpful point – what the physician says regarding “time off” determines lost time days, not the actual days lost.

  6. Over-counting for restricted and lost workdays (Items K and L). OSHA puts a 180-day cap for each case in each of these columns. Stop at 180 days, even if the worker has lost more time.

  7. Incorrect addition. Double-check page totals for each column, and add the correct numbers to the 300A Summary. The Log and Summary must match at the time of the annual posting. (Note: Any changes in lost or restricted days after the Summary is posted must be maintained on the Log, but not reported again on the Summary. If questioned, any difference between the two postings posted can be explained).

  8. Incorrect certifying person. The 300A Summary must be signed by the highest-ranking person at the site, not necessarily the person filling out the form.

  9. Confusing OSHA recordable injuries with Workers Compensation claims. Workers Comp and OSHA recordkeeping are two different systems, with different definitions! If your WC insurance denies a claim, it doesn’t mean the injury can be removed from the Log. And if an injury is accepted by WC as work-related, it doesn’t necessarily mean it must go on the OSHA Log. Usually the two are the same, but not always! Know the difference.

  10. Recording every injury or illness. Don’t record everything! During an inspection, OSHA will look at your Log to help decide how safely your company is performing. Reporting lots of incorrectly reported injuries looks bad. In addition, the injuries you record can be used by the Bureau of Labor Statistics to determine industry- and site-specific targeting programs for OSHA compliance inspections thus increasing your changes for a future audit. So while it is a bad idea to record injuries that aren’t recordable, under-reporting is citable offense! Know what to and what not to record. As a reminder, recordable injuries are: 1) work-related, 2) new and as yet unreported, and 3) those meeting specific recordability criteria. (All physician-ordered lost time and restricted duty is recordable.)

One final note: Post only the annual 300A Summary between February 1 and April 30. The rest of your Log contains sensitive employee information that should be considered private and confidential.

If you need more information on OSHA-recordability and other recordkeeping requirements, or want training on the OSHA 300 Log, contact Chuck Paulausky at (480) 694-1975, cpaulausky@www.cpsafety.net.