Study: Safety Professionals Need to Examine Their Management of OHS Incident Reports

Researchers recommend looking beyond individual incident to system, design solutions

If a worker is injured slipping from a ladder while accessing an electrical panel, does this incident warrant more training on the employee’s part on how to properly use a ladder or does it call into question larger organizational issues that should be addressed?

In an article in the February issue of Professional Safety titled, “Problem Solving, Are Higher-Order Controls Ignored?” authors Michael Behm and Demetria Powell reviewed 249 valid investigation reports from seven organizations. They found a majority of occupational health and safety (OHS) professionals and their companies focus solely on the incident without looking at factors like why a ladder is needed to reach a panel in the report.

“By not including it, an opportunity for organizational learning about possible future design and redesign changes has not been documented and, thus, is lost,” the authors write.

At issue is ANSI Z10, a U.S. consensus standard for Occupational Health and Safety Management Systems, which has six solution categories: 1) elimination; 2) substitution for less hazardous materials, processes, operations or equipment processes; 3) engineering controls; 4) warnings; 5) administrative controls; and 6) protective clothing.

The first three options are considered higher-order control solutions because they require more effort to improve a situation within a corporate culture. The authors discovered OHS professionals and their companies used administrative controls, known as lower-order controls, in 87% of the reviewed investigation reports, suggesting that they may be fixated on identifying single causes close to the work operations.

“All organizations should analyze what types of failures and subsequent solutions they are identifying,” the authors write. “When investigators look beyond the immediate failures and into the system, they will initiate true organizational learning and be impactful for risk reduction on both the micro and macro scales.”

Controls for Noise Exposure

NIOSH urges employers to create hearing-loss prevention programs

Loud noise at work can damage hearing. Approximately 22 million U.S. workers are exposed to hazardous noise at work. To minimize occupational noise-induced hearing loss, the National Institute for Occupational Safety and Health (NIOSH) recommends that workers should not be exposed to noise at a level that amounts to more than 85 decibels (dBA) for 8 hours. To create a more healthful workplace, NIOSH recommends an approach based on the hierarchy of control.

The Hierarchy of Control

Occupational safety and health professionals use the hierarchy of control to determine how to implement feasible and effective controls.

Traditionally, a hierarchy of controls has been used as a means of determining how to implement feasible and effective controls. One representation of this hierarchy can be summarized as follows:

  • Elimination
  • Substitution
  • Engineering controls
  • Administrative controls
  • Personal protective equipment

This approach groups actions by their likely effectiveness in reducing or removing the noise hazard.

In most cases, the preferred approach is to eliminate the source of hazardous noise. When elimination is not possible, substitution of the loud equipment for quieter equipment may be the next best alternative to protect workers from hazardous noise. If the hazardous noise cannot be controlled through elimination of the source or substitution of quieter equipment, engineering controls may be installed to reduce noise to safer levels or remove noise at the source.

Engineering controls require physical changes to the workplace such as redesigning equipment to eliminate noise sources and constructing barriers that prevent noise from reaching a worker. If it is not possible to remove the hazard through elimination, substitution, or engineering controls, the next step is to reduce noise exposure through the use of administrative controls. For example, an employer may change an employee’s work schedule to avoid too much noise.

Personal protective equipment (PPE), such as ear plugs or other hearing protection devices, is the last option in the hierarchy of control. PPE is generally less effective than elimination, substitution, and engineering controls because they rely on human actions to reduce noise. Used in combination with other levels of control, such as administrative controls, PPE may provide worker protection when engineering controls do not adequately remove the noise hazard.

Solutions for Reducing Noise in the Workplace

Occupational safety and health professionals and employers can take the following actions to reduce noise in the workplace. Consider these solutions when creating your hearing loss prevention program:

  • Buy quiet—select and purchase low-noise tools and machinery
  • Maintain tools and equipment routinely (such as lubricate gears)
  • Reduce vibration where possible
  • Isolate the noise source in an insulated room or enclosure
  • Place a barrier between the noise source and the employee
  • Isolate the employee from the source in a room or booth (such as sound wall or windows)

Learn more about these strategies and review case studies.

SBA Recommends That OSHA Assess Concerns with Silica Rule

Proposed rule sets new crystalline silica exposure limits

The U.S. Small Business Administration’s Office of Advocacy (Advocacy) recently submitted public comments on OSHA’s Proposed Occupational Exposure to Respirable Crystalline Silica Rule. [78 Fed. Reg. 56274 (September 12, 2013)]. The rule would change the regulatory requirements that employers must meet when their employees are exposed to respirable crystalline silica above a certain level.

Silica is basically sand (most commonly quartz) that comes in a variety of forms and conditions and is used in a wide range of applications across a host of industries. Exposure to respirable crystalline silica (which consists of very small particles that are able to penetrate into the lungs) has been linked to silicosis, lung cancer, and other diseases.

OSHA’s proposed rule would establish a new permissible exposure limit (PEL) of 50 μg/m3 with an action level of 25 μg/m3 (both calculated as an eight-hour time-weighted average). Exceeding the action level would require periodic exposure assessments, while exceeding the PEL would trigger a host of administrative and regulatory controls.

OSHA convened a Small Business Advocacy Review panel in 2003 to consider the impact of a proposed rule on small entities. Small entity representatives, who provided advice and recommendations to the panel, generally opposed lowering the PEL and recommended that OSHA enforce the existing limits and focus on compliance assistance. Advocacy has also engaged in extensive outreach about the proposed rule with small business representatives. Advocacy’s comments are reflective of the issues raised during the small business panel process and in additional meetings and discussions with small business representatives:

  • Advocacy commended OSHA for making several changes to the proposed rule that would reduce the impact on small entities but noted that small business representatives have raised significant concerns about OSHA’s risk assessment as well as the technological and economic feasibility of complying with the proposed rule.
  • Advocacy recommended that OSHA carefully consider the comments it receives from small businesses and their representatives and continue to evaluate whether older exposure data is reliable and whether the form and condition of silica can significantly affect risk.
  • Advocacy recommended that OSHA work with the construction industry to refine Table 1 into a means of achieving compliance with the PEL (i.e., a safe harbor).
  • Advocacy recommended that OSHA consider providing additional opportunities for small businesses and their representatives to effectively participate in this rulemaking process.

Read Advocacy’s letter to OSHA.

A Top OSHA Official to Speak at CBIA Conference

James Mulligan to deliver keynote

CBIA is pleased to announce that Assistant Regional Administrator for OSHA Region I James Mulligan will be the keynote speaker at CBIA’s 2014 Safety and Health Conference, May 22 in Cromwell.

Mulligan will discuss initiatives that OSHA will be emphasizing during the final two years of the Obama administration. Other topics include GHS implementation and OSHA rules companies find most problematic.

Register for the conference today!

Winter Weather Is Here!

Plan, equip, and train with these tips from OSHA

In previous issues of this newsletter we have commented on OSHA’s efforts to protect workers from extreme heat. Perhaps not as well publicized are the agency’s actions to protect workers from extreme cold. Here, the agency addresses issues such as cold stress and its prevention, other winter related hazards, and the problems caused by wind chill temperature.



OSHA Extends Comment Period on Proposed Rules

Crystalline silica, injury tracking rules affected

OSHA is extending the public comment period for the Notice of Proposed Rulemaking on Occupational Exposure to Crystalline Silica for an additional 15 days to Feb. 11, 2014.

In response to concerns raised about possible public confusion due to an error on, the federal government’s online portal for submitting rulemaking comments, the deadline has been extended from Jan. 27 to Feb. 11 to allow stakeholders additional time to comment on the proposed rule.

To submit comments using, stakeholders may click on the “COMMENT NOW!” box next to the title “Occupational Exposure to Crystalline Silica; Extension of Comment Period” and follow the instructions online for making electronic submissions.

Public hearings on the proposed rule are scheduled to begin on March 18, 2014. Information on the proposed rule is available here.

Injury Tracking Rule

OSHA also announced that it will extend the comment period to March 8, 2014, on the proposed rule to improve workplace safety and health through improved tracking of workplace injuries and illnesses. The proposed rule would amend recordkeeping regulations to add requirements for the electronic submission of injury and illness information that employers are already required to keep under OSHA’s regulations for recording and reporting occupational injuries and illnesses.

The comment period has been extended 30 days in response to a request from the National Association of Home Builders. Comments may be submitted electronically, by mail, or facsimile.



New Study Sheds Light on Long-Haul Truck Driver Health

Truckers more at risk for chronic disease than population overall

A new study from the National Institute for Occupational Safety and Health (NIOSH) finds that U.S. long-haul truck drivers were twice as likely to be obese compared to the adult working population, as well as more likely to smoke and suffer from other risk factors for chronic disease. The study, published in the American Journal of Industrial Medicine, is the first to provide a comprehensive look at the health status, risk factors, and work practices of long-haul truck drivers in the U.S.

NIOSH conducted the survey in 2010 interviewing 1,670 long-haul truck drivers at truck stops across the continental U.S. about their health and work practices. According to the survey, 69% of these drivers were obese and 54% smoked.

Additionally, 88% of long-haul truck drivers reported having at least one risk factor (hypertension, smoking, and obesity) for chronic disease, compared to only 54% of the general U.S. adult working population.

“Truck drivers serve a vital role in our nation’s economy, ensuring the safe and timely delivery of goods across the U.S.,” said NIOSH Director John Howard, M.D. “This initial survey helps us work collaboratively with the trucking industry on understanding how to improve the lives of truckers both on the road and at home.”

Long-haul truck drivers are professional drivers of heavy and tractor-trailer trucks whose delivery routes require them to have to take sleep breaks away from home. There is limited information on illness and injury in this population, which prompted the survey by NIOSH. The data collected will help to establish a picture of the health conditions, risk factors, and work practices for U.S. long-haul truck drivers, giving the trucking industry and researchers valuable information to guide health and safety efforts. ■

Have You Posted Your Form 300A?

Posting deadline is Feb. 1

OSHA  requires employers with 10 or more employees to record (Form 300) certain work-related injuries, including death, loss of consciousness, days away from work, restricted work activity or job transfers, or medical treatment beyond first aid. Employers need to also record the following conditions when work related:

  • Needle stick injury or cut from a sharp object that is contaminated with another person’s  blood or infectious material
  • Any case requiring an employee’s removal under the requirement of an OSHA health standard
  • Tuberculosis infection
  • An employee’s hearing test reveals that the employee has experienced  hearing loss has defined by OSHA’s standards

Employers who are required to keep Form 300, the Injury and Illness log, must post Form 300A, the Summary of Work-Related Injuries and Illnesses, in a workplace every year from Feb. 1 to April 30. Current and former employees, or their representatives, have the right to access injury and illness records. Employers must give the requester a copy of the relevant record(s) by the end of the next business day.


For a company to be exempt from completing Form 300, it must have fewer than 10 employees throughout the previous calendar year. Part-time, temporary, and seasonal workers are to be included in the count. Also, the total number of employees in the whole company, not just a particular division, is the basis of the total.

In addition to the small employer exemption, certain industries are also exempt from completing Form 300 and posting Form 300A.

A complete list of the exempt industries can be found here, and the necessary forms here.


OSHA Renews Two Safety Alliances

Includes strategic partnership with electric transmission, distribution industry

OSHA has renewed its alliance with the Scaffold and Access Industry Association to provide information and training to protect the safety and health of workers who use scaffolds and lift equipment. Through the alliance, OSHA and SAIA will work to reduce and prevent fall and caught-in-between hazards and issues related to frame, mast climbing, suspended scaffolds, and aerial lift equipment. In addition, alliance members will emphasize the rights of workers and the responsibilities of employers under the Occupational Safety and Health Act and use injury and illness data in selected industries to help identify areas of emphasis for alliance awareness and outreach activities.

“Worker injuries and deaths from scaffolding hazards can be prevented when employers provide training on safe setup and use of equipment,” said Assistant Secretary of Occupational Safety and Health Dr. David Michaels. “By renewing our alliance with SAIA, we will expand our outreach to employers and workers and provide important training to protect workers in the scaffold and access industry.”

The agreement will remain in effect for five years.For more information, click here.

Through its Alliance Program, OSHA works with unions, consulates, trade and professional organizations, faith- and community-based organizations, businesses, and educational institutions to prevent workplace fatalities, injuries, and illnesses. The purpose of each alliance is to develop compliance assistance tools and resources and to educate workers and employers about their rights and responsibilities. Alliance Program participants do not receive exemptions from OSHA inspections or any other enforcement benefits.

Strategic Partnership Renewal

The second partnership renewal was one with employers, workers, and professional associations in the electrical transmission and distribution industry to reduce injuries, illnesses, and deaths among linesman and other electrical workers. The partnership includes ten of the nation’s largest electrical transmission and distribution contractors, an electrical industry labor union, and two trade associations, representing about 80% of the industry.

Since its establishment in 2004, there has been a noticeable reduction in the injury, illness, and fatality rates among the partners’ employees, which include close to 26,000 workers. Fatalities among these workers have dropped from 11 in 2004 to 1 in 2013.

“By working on common goals through the partnership, partner injury, illness and fatality rates have been reduced,” said Assistant Secretary of Labor for Occupational Safety and Health Dr. David Michaels. “Through this national partnership, the partner companies and associations looked at factors causing fatal incidents and other serious injuries and implemented changes to reduce and prevent the number of fatalities not only within their own companies but in the industry as a whole. We look forward to seeing even greater outcomes of this partnership in the future.”

The partnership has developed and implemented best practices that directly correspond to key hazards and operations associated with injuries, illnesses, and fatalities in the industry. These practices include fall protection, the use of specific insulating protective equipment, and the implementation of safety checks. The partnership also has trained more than 33,000 workers and supervisors through industry-specific courses developed by the partners. OSHA and industry partners are in the process of expanding these courses to provide industry-wide training.

More information

OSHA’s Strategic Partnership Program helps encourage, assist and recognize the efforts of partners to eliminate serious workplace hazards and achieve a high level of worker safety and health. Most strategic partnerships seek to have a broad impact by building cooperative relationships with groups of employers and workers. These partnerships are voluntary relations among OSHA, employers, worker representatives, and others including trade unions, trade and professional associations, universities, and other government agencies.

New Hampshire Gunpowder Plant Owner Sentenced in Death of Two Workers

Cited for 50 safety violations in 2010

The owner of a New Hampshire gunpowder plant, Craig Sanborn, was sentenced on Nov. 27 by a superior court judge to five to 10 years on two counts of manslaughter, to be served consecutively, for a total of 10 to 20 years, and assessed fines of $10,000, following the 2010 death of two of his workers.

Jesse Kennett and Don Kendall had been on the job only a month when they died May 14, 2010, in an explosion at Black Mag LLC’s facility in Colebrook, New Hampshire, where they were manufacturing a gunpowder substitute.

“The disregard for safety cost two workers their lives, and this jury agreed that Craig Sanborn’s actions were criminal,” said Assistant Secretary of Labor for Occupational Safety and Health Dr. David Michaels. “Sanborn recklessly ignored basic safety measures that would have protected their lives. His criminal conviction and sentence won’t bring these men back to life, but it will keep him from putting workers’ lives in peril. And it should drive home to employers this message: Worker safety can never be sacrificed for the benefit of production, and workers’ lives are not—and must never be—considered part of the cost of doing business.”

In October 2010, OSHA cited Sanborn for more than 50 willful, egregious, and serious violations of safety standards in connection with the explosion—including failure to provide employees with training and personal protective equipment, and failure to implement essential controls to protect workers at the facility.

See Dr. Michaels’ statement and OSHA’s 2010 news release for more information.