Latest Safety Forum (5/5/16): Heat Illness Prevention


Presenter: Michael Miller, Cal/OSHA Consulting

On Thursday May 5 at 8:30am, Safety Center hosted its monthly Safety Forum on the topic of “Heat Illness Prevention” to address the legal obligations of employers to maintain proper work environments during hot weather conditions. During this month’s forum, Michael Miller of Cal/OSHA Consulting discussed this topic and provided insight into Cal/OSHA inspection procedures. Twenty five safety professionals participated in a lively discussion regarding the obligations of employers to prevent heat illness among their employees.

The presentation summary is as follows:

Training Goals:

  • Review the regulatory language and heat illness preventive measures
  • Increase awareness and commitment to safety and health at the worksite

Heat Illness Prevention Elements Include:

  • Access to water
  • Access to shade
  • Weather monitoring and acclimatization
  • High heat procedures
  • Employee and supervisory training
  • Written procedures including emergency response

Access to Water

  • Potable drinking water must be made available at no cost to the employee
  • Maintain, at all times, sufficient quantities of pure and cool potable drinking water, i.e. enough to provide at least one quart per employee per hour for the entire shift
  • Water must be fit to drink. Water containers CANNOT be refilled from non-potable water sources, e.g. irrigation wells, sprinkler or firefighting systems
  • Care must be taken to prevent contamination of the drinking water supplied to the workers
  • Implement and maintain effective replenishment procedures when beginning the shift with smaller quantities
  • Locate the water containers as close as practicable given the working conditions and layout of the worksite
  • Keep it readily accessible, move it with the workers!
  • Encourage the frequent drinking of water

Remind workers not to wait until they are thirsty!

Shade Up: when the temperature exceeds 80 degrees F

  • Have and maintain one or more areas of shade at all times, when employees are present
  • Locate the shade as close as practical to the area where employees are working
  • Provide enough shade to accommodate the number of employees on recovery or rest periods
  • Provide enough shade to accommodate the number of employees on meal period who remain on site
  • Remember: Access to shade must be permitted at all times
  • Encourage employees to take a cool-down rest in the shade
    • Monitor employees on cool down rests
    • Ask them if they’re experiencing symptoms of heat illness
    • Don’t order back to work until symptoms abated allow at least a five minute rest
    • Take appropriate first aid steps or emergency response as necessary
  • Shaded area must not cause exposure to another health or safety hazard. Areas underneath mobile equipment, e.g. tractor, or areas that require crouching in order to sit fully in the shade are not acceptable

If temperature is below 80 degrees F

  • When the temperature does not exceed 80 degrees F, provide timely access to shade upon request

When Infeasible or Unsafe:

  • In situations where the employer can demonstrate that it is not safe or feasible to provide shade, an employer can utilize established procedures for providing shade upon request or, for non-agricultural employers, alternative cooling measures that provide equivalent protection

Monitor the Weather

  • Instruct supervisors to track the weather of the jobsite (by monitoring predicted temperature highs and periodically using a thermometer)
  • Determine, and instruct supervisors, on how weather information will be used to modify work schedule, increase number of water and rest breaks or cease work early if necessary

High Heat Procedures:

  • Industries covered by this subsection:
    • Agriculture
    • Construction
    • Landscaping
    • Oil & Gas Extraction
    • Transportation or delivery of agricultural, construction materials or other heavy materials

When the temperature equals or exceeds 95 degrees F

  • You must implement additional preventive measures:
    • Ensure effective communication (by voice, observation or electronic means)
    • Observe employees for alertness and signs and symptoms of heat illness:
      • Supervisory or designee observation of 20 or fewer employees
      • Mandatory buddy system
      • Regular communication
      • Other effective means
    • Designate one or more employees to call for emergency services
    • Give more frequent reminders to drink plenty of water
    • Hold pre-shift meetings on prevention
    • For agricultural employers
      • Temps 95 or above, ensure employees take a minimum ten minute net prevent cool-down rest every two hours
      • Additional ten minute cool-down rest at end of 8th and 10th hour of work

Emergency Response Procedures

  • Ensure effective communication
  • Respond to signs and symptoms of possible heat illness
    • Supervisor to take immediate, appropriate action
    • If indicators of serious heat illness, implement emergency response procedures
    • Employees exhibiting or reporting signs or symptoms of heat illness shall be monitored and not left alone. Onsite first aid or appropriate emergency medical services shall be offered
    • Contact emergency medical services and ensure that clear and precise directions to the site can be provided

Address Lack of Acclimatization

  • As an employer, you are responsible for the working conditions of your employees, so you must act effectively when conditions result in sudden exposure to heat that your workers are not used to
  • All employees shall be closely observed by a supervisor or designee during heat waves
  • Employees newly assigned to high heat areas shall be closely observed by a supervisor or designee for the first 14 days of employment
  • Thus, determine how your company will:
    • lessen the intensity and/or shift length of newly-hired employee’s work during a two or more week break-in period
    • modify the work schedule or reschedule non-essential duties, during the hot summer months
    • be extra-vigilant with your employees to recognize immediately symptoms of possible heat illness

Employee & Supervisor Training

    • Ensure all employees and supervisors:
      • Are trained before beginning work that should reasonably be anticipated to result in a heat illness
    • The environmental and personal risk factors for heat illness, as well as the added burden of heat load on the body
    • Your company’s heat illness prevention procedures
      • Including, but not limited to, the employer’s responsibility to provide water, shade, cool-down rests, and access to first aid as well as the employees’ right to exercise their rights under this standard without retaliation
    • Importance of frequent consumption of small quantities of water
    • Different types of heat illness, common signs and symptoms; and appropriate first aid or emergency response
    • Knowledge that heat illness may progress rapidly
    • The concept, importance, and methods of acclimatization
    • Training must include the importance of acclimatization, how it is developed, and how your procedures address it.
    • Importance of immediately reporting signs or symptoms of heat illness to a supervisor
    • Procedures for responding to possible heat illness

Procedures to follow when contacting emergency medical services, providing first aid, and if necessary transporting employees

  • Procedures that ensure clear and precise directions to the work site, including designating a person to be available to ensure that emergency procedures are invoked when appropriate


Supervisor Training


  • The heat standard requirements
  • The procedures they must follow to implement the requirements
  • Procedures to follow when a worker exhibits or reports symptoms consistent with possible heat illness, includnig emergency response procedures and first aid
  • How to monitor weather reports and how to respond to hot weather advisories


Written Procedures


  • As long as they are effective, your Heat Illness Procedures can be integrated into your IIPP
  • Maintain the procedures onsite or close to the site, so that it can be made available to employees and representatives of Cal/OSHA upon request
  • Plan in English and the language understood by the majority of the employees
  • Detail how your company will:
    • Provide access to water & shade
    • Monitor the weather
    • Institute high heat procedures
    • Address acclimatization methods and procedures
    • Train all employees and supervisors
    • Respond to heat illnesses without delay, provide first aid and emergency services
    • Provide clear and precise directions to the worksite


Serious Hazard
You risk a serious citation if the outdoor temperature in the work area exceeds 80 degrees F and any of these required elements are not present at the site:

  • Drinking water
  • Shade
  • Trained employees or supervisor
  • Emergency response procedures

Imminent Hazard: Don’t Risk an OPU!
You may also risk an Order Prohibiting Use (OPU) and a Serious Citation if the heat and lack of facilities create an imminent hazard.
An OPU may be issued if:

  • The temperature is > 95 degrees F and water, shade, training or emergency procedures are not in place
  • The temperature is > 80 degrees F, and there is a heat wave, heavy workload or other critical factor putting employees in danger


  • Will shut down the operation
  • Work will not be allowed to resume until the employer demonstrates that the imminent hazard has been corrected

Additional Heat Illness information links:

Multilingual educational materials can be downloaded free from the website

Before We Begin

A Safety Management Approach

Bob Lapidus, CSP, CSMS

Oftentimes, accidents happen because we do not plan what we are going to do. We do not think about what hazards pose a threat to us on the particular job that needs to be done.

There are different names of analytical systems that help employers and their employees prepare to do a task safely. Three such systems are Job Safety Analysis (JSA), Job Hazard Analysis (JHA), and Pre-Job Briefings. The latter system is sometimes the implementation of the first two.

We have a job that needs to be completed. If the task has been evaluated previously, we might have a document that carefully lists the steps we need to take, what hazards are involved, and what actions we can initiate to reduce or even eliminate those hazards. If we do not have such a document, something like it truly needs to be created prior to beginning the task.

We need to think through:

1. The various tasks we are going to do
2. The people involved
3. The equipment we are using
4. The environment in which we are working
5. The hazards built into the task, the people and the equipment
6. What personal protective equipment will help us most to eliminate or at least reduce getting hurt
7. Who will work together and how will employees assist each other
8. What changes do we have to make to how we normally do our work to ensure a safe working experience in this case
9. What steps do we take in the event of an accident

There may be times during the job that work needs to be stopped to adjust what is going on due to changes out of our control or things we find that are different from our original assessments. Better to stop than to let someone get hurt.

Accidents happen in a split second. The optimum scenario is prevention, not letting an accident happen. What we do to prevent the accident is all part of the planning process.

For More Information:
To become part of discussions on topics like the one above, go to to obtain information about Safety Center’s Safety Management Specialist Certificate.

After completing this nine-day program, graduates may take the exam to achieve the Certified Safety Management Specialist (CSMS) designation. Recipients of the CSMS receive a beautiful plaque and become part of an elite group of safety specialists who have achieved this recognition. Once this certification is attained, successful candidates keep it for the rest of their lives without any additional requirements or fees.

Understanding the Final GHS Deadline

From Safety+Health magazine:

QUESTION: The next and final GHS deadline is June 1, 2016. What does that mean for me as an employer?

Responding is Brad Montgomery, marketing and communications director, Accuform, Brooksville, FL.

ANSWER: After many years, the final effective completion date for the Globally Harmonized System of Classification and Labeling of Chemicals (GHS) nears. As we know, OSHA adopted new hazardous chemical labeling requirements as a part of its revision of the Hazard Communication Standard (HCS), 29 CFR 1910.1200, bringing it into alignment with the United Nations’ GHS. These changes will help ensure improved quality and consistency in the classification and labeling of chemicals, and will also enhance worker comprehension. As a result, workers will have better information available on the safe handling and use of hazardous chemicals, thereby allowing them to avoid injuries and illnesses related to exposures to hazardous chemicals.

Let’s look at how OSHA’s June 1, 2016, requirements actually reads. In short, OSHA says, “Update alternative workplace labeling and hazard communication program as necessary, and provide additional employee training for newly identified physical or health hazards.” This final timeline requirement applies to employers, but what does it mean? Essentially it means that employers must have workplace labeling and hazard communication programs up to date as necessary (this includes having all Material Safety Data Sheet-formatted documents replaced with the newer Safety Data Sheet-formatted documents). It also states that additional training must be conducted for newly identified physical or health hazards.

On June 1, 2016, the three-year transition period ends. This transition period allowed compliance with HCS 2012, HCS 1994 or both.

The GHS label format provides detailed yet easy-to-understand guidance for application of the hazard communication elements on a label. It specifies for each hazard, and for each class within the hazard, what signal word, pictogram and hazard statement should be used. The GHS hazard pictograms, signal words and hazard statements should be located together on the label. I would encourage you to view Annex 7 of the UNECE Rev. 3 (2009) Purple Book (available at, which explains how the GHS pictograms are expected to be proportional to the size of the label text so that generally, the GHS pictograms would be smaller than the transport pictograms.

Employers must ensure the SDSs are readily accessible to employees for all hazardous chemicals in their workplace. This may be done in many ways. For example, employers may keep the SDSs in a binder or on computers – as long as the employees have ready access to the information without leaving their work area when needed, and a backup is available for immediate access to the SDS in the case of a power outage or other emergency situations. Furthermore, it’s a good time to remember that employers should designate a person(s) responsible for obtaining and maintaining the SDSs. If the employer does not have an SDS, the employer or designated person(s) should contact the manufacturer to obtain one.

For more information, visit OSHA’s comprehensive hazard communication website at

Year One of OSHA’s Severe Injury Reporting Program

Article from the U.S. Department of Labor on March 17, 2016

Over 10K severe worker injuries were reported in the first of year of the OSHA requirement. Most employers cooperated with OSHA to fix hazards, but some tried to hide them.

In the first year of a new reporting requirement, employers notified the U.S. Department of Labor’s Occupational Safety and Health Administration of more than 10,000 severe work-related injuries, creating the opportunity for the agency to work with employers to eliminate hazards and protect other workers.

Since Jan. 1, 2015, employers have been required to report any severe work-related injury – defined as a hospitalization, amputation or loss of an eye – within 24 hours. The requirement that an employer report a workplace fatality within eight hours remains in force.

In the first full year of the program, employers reported 10,388 severe injuries, including 7,636 hospitalizations and 2,644 amputations. In a majority of those cases, OSHA responded by working with the employer to identify and eliminate hazards, rather than conducting a worksite inspection.

“In case after case, the prompt reporting of worker injuries has created opportunities for us to work with employers we wouldn’t have had contact with otherwise,” said Assistant Secretary of Labor for Occupational Safety and Health David Michaels, who authored the report. “The result is safer workplaces for thousands of workers.”

OSHA found some employers exceeded the agency’s requirements to protect workers from future incidents. Unfortunately, a few responded with callous disregard. One manufacturer tried to hide an entire room full of machinery from OSHA inspectors.

The evaluation of 2015 results, which breaks out the top 25 reporting industries, notes that by instituting the requirement, the agency can better target resources where needed, and engage employers in high-hazard industries to identify and eliminate hazards. The evaluation finds the reporting requirement is meeting both goals.

“OSHA will continue to evaluate the program and make changes to improve its effectiveness,” Dr. Michaels wrote in the report. “We are also seeking new ways to make sure that small employers know about their reporting obligations and the resources available to them.”

The full report is available here.

Media contacts:
Brian Hawthorne
Mandy McClure

A Heart for Safety

A Safety Management Approach

Bob Lapidus, CSP, CSMS

Over the years, I’ve told my students in Safety Center safety management classes that managers either have a heart for safety or they do not. I have also admitted that if a manager does not have a heart for safety, I (as a safety advisor) have never been able to change his or her closed heart.

The only thing I have ever seen change a manager’s heart from turning away from safety to turning toward safety is a fatality or severe injury to an employee who the manager cares about. Did you get that?

That is an awful thing to say, but that is my real life experience.

Why do some managers and first-line supervisors not have a heart for safety?

I believe it is because they have never worked in an environment where safety was important, where ensuring that all tasks are performed efficiently, productively, and safely is integral to performing all work.

In many organizations, employees are expected to do their tasks without benefit of initial and ongoing training, without continual observation of their behavior, without any follow up to ensure their performance is right and good.

That is an awful thing to say too, but it’s the truth.

What does a work environment look like that is filled with a heart for safety?

It begins with top management’s commitment and follow through to ensure everything is done right, the first time. To achieve that level of perfection, all employees throughout the organization are carefully hired to fit the job they are going to fulfill. They receive initial and continuing training on how to do their work correctly, efficiently, productively, and safely. Their work is observed and reviewed. When they do what is wanted, they are recognized. When they fail to work as is desired, they are corrected.

The right equipment is purchased and maintained. Good housekeeping is sustained. Order is the daily state of how things are done.

Management writes policies and procedures to reflect what is wanted and such documents are regularly enhanced to improve the quality of the work performed.

High employee morale is sought. Management seeks to make the work environment a positive atmosphere. No negative concern is left to fester. All issues are dealt with and improved upon.

To create such a great work environment, all employees are involved. Their thoughts and suggestions are an important part of building a successful organization, an enterprise that is well managed and has a heart for doing what is proper and worthy.

For More Information
To become part of discussion on topics like the one above, go to to obtain information about Safety Center’s Safety Management Specialist Certificate.

After completing this nine-day program, graduates may take the exam to achieve the Certified Safety Management Specialist (CSMS) designation.  Recipients of the CSMS receive a beautiful plaque and become part of an elite group of safety specialists who have achieved this recognition.  Once this certification is attained, successful candidates keep it for the rest of their lives without any additional requirements or fees.

A Significant Symptom of a Safety Problem: Lack of an Injury & Illness Prevention Program

17 Feb 2016 Comments

A Safety Management Approach

Bob Lapidus, CSP, CSMS

My colleagues and I do 100 to 200 safety surveys annually for a variety of organizations. Currently, we are targeting those entities with an Experience Modification of 1.19 and above, and over the last five years have sustained three or more serious injuries (incurred losses of over $10,000 per injury), and a frequency of more than ten occupational injuries or illnesses during that same time period.

We are finding that these high-loss establishments either do not have an Injury & Illness Prevention Program (IIPP) or the program in place has not been fully implemented.

These high-loss organizations do not have a foundational safety program in place comprising the following functions of the required IIPP:

  • Establishing responsibilities
  • Including activities that provide compliance or accountability systems
  • Communicating safety-related information
  • Inspecting workplace facilities and operations
  • Investigating accidents and injuries
  • Correcting identified safety problems
  • Training employees on how to do their tasks in a safe manner
  • Recording all safety activities as well as occupational injuries and illnesses

Surprising, some managers in these organizations do not know what an IIPP is or from whence it came. Adopted and implemented by Cal/OSHA in 1991 (25 years ago), California was the first state to require its employers to have a foundational safety program in place. The eight functions required establish a comprehensive basic safety program. See Title 8, Section 3203 for the IIPP requirements.

Of the eight required IIPP functions, the one that stands out from the rest in our safety visits is the lack of occupational injury and illness investigations. Most of these entities file the appropriate workers’ compensation forms, but beyond that, no thought goes into what caused the specific event to occur. Consequently, no action is being taken to prevent the same kind of incident to occur again. They are not learning anything from their negative events.

Interesting about the IIPP is the fact that not having one is normally considered by Cal/OSHA to be a general violation, a relatively low-cost penalty citation. On the other hand, if Cal/OSHA comes into an organization due to a severe injury or illness, and the Cal/OSHA inspector finds that the entity does not have an IIPP in place, the lack of the program can generate a serious violation, starting at about $18,000 and going up from there. Cal/OSHA considers the lack of an IIPP where a serious injury has been sustained, as a critical fault on the part of the employer.

For More Information
To become part of discussion on topics like the one above, go to to obtain information about Safety Center’s Safety Management Specialist Certificate.

After completing this nine-day program, graduates may take the exam to achieve the Certified Safety Management Specialist (CSMS) designation.  Recipients of the CSMS receive a beautiful plaque and become part of an elite group of safety specialists who have achieved this recognition.  Once this certification is attained, successful candidates keep it for the rest of their lives without any additional requirements or fees.

Four Ways to Adapt to an Aging Workforce

17 Feb 2016 Comments

two workers in uniforms in warehouse

Article from Harvard Business Review

by Michael North & Hal Hershfield

Calls to maximize the utility of older workers – by honoring experience, providing training opportunities, and offering flexible work and retirement options – began to sound at least a decade ago. HBR [Harvard Business Review] contributors have suggested we “retire retirement” and “adapt for an aging workforce.”

But proposing reform is one thing. Instituting it is another. Have companies followed through? Our analysis suggests that some are starting to. We’ve found four best practices for accommodating older workers that should serve as a model for other organizations:

1. Flexible, half-retirement. Although retirement reform remains stagnant at the policy level, companies are being more proactive about modifying employee exit schemes. For example, Scripps Healthcare has installed a phased-retirement program: Retirees work part time, while drawing a portion of their retirement funds, so they still effectively earn a full salary and benefits. Meanwhile the company avoids having to hire expensive temporary workers and retains talented employees in areas where skills are scarce. WellStar Health System offers a similar option for employees who have been with the company at least ten years.

2. Prioritizing older-worker skills in hiring and promotions. Companies like Vodafone are putting more emphasis on employees’ loyalty, track records, competence, and common sense, all commonly found in older workers. Vita Needles does the same, noting that loyal older employees not only enhance the company’s reputation, but also yield higher quality work and attention to detail. B&Q (winner of the 2006 “Age Positive Retailer of the Year” Award) says that it hires for soft skills, such as conscientiousness, enthusiasm and customer rapport, which senior workers also seem to show in abundance, while Home Depot famously looks to older store clerks for the experience-based know-how that customers demand. And these aren’t just perceptions: A report from the Sloan Center on Aging & Work at Boston College has found that, compared to younger workers, older workers do have higher levels of respect, maturity and networking ability.

3. Creating new positions or adapting old ones. Migros Geneva retrains employees for jobs that better suit their aging skill-sets – for example teaching a 58-year old cashier to be a customer service representative. Marriott’s Flex Options for Hourly Workers program offers a similar service, helping 325,000 older “associates” around the world transition out of physically taxing roles by teaching them new skills on the job, while United Technologies invests $60 million dollars annually in its Employee Scholar Program. And Michelin rehires retirees to help oversee projects, foster community relations, and facilitate inter-generational mentoring. This strategy works at the executive level, too. HPEV, the intellectual property and product development company, recently formed a Strategic Advisory Board headed by a recent retiree, Dick Schul, recognizing the value of his 43 years’ experience in the industry. Other companies, such as ExecBrainTrust, specialize in matching recently retired executives with temporary consulting roles.

4. Changing workplace ergonomics. Although not all older workers are feeble, companies can and should adapt for those who need some extra support. BMW has made inexpensive tweaks to workplace ergonomics for older employees (think wooden assembly-line floors, custom shoes and easier-to-read computer screens). Another example comes from Xerox, which recently introduced a training program to teach better ergonomic health strategies and raise awareness about the normal aging process. Unilever UK has also instituted a wellness program designed to prolong the working life of its older employees.

Companies that make these changes have seen tangible improvements in retention and productivity, organizational culture, and the bottom line. Since B&Q began actively recruiting older workers, its staff turnover has decreased by a factor of six, while short-term absenteeism is down 39%. Leaders say its growing ranks of older employees have been integral in creating a friendlier, more conscientious work environment. And profits are up 18%. Following its ergonomic changes, BMW has seen productivity jump 7% and its assembly line defect rate drop to zero. United Technologies has boosted its older worker retention rate by 20%, and Unilever UK estimates that it gains six euros in productivity for every one euro spent on wellness. Companies with high over-50 employment rates – at both the staff and executive level – are also proving to be leaders in their respective industries. Michelin and WellStar Health System are two examples.

Given demographic trends in the developing world, corporate workforces are set to age significantly in the next few decades. Is your organization ready to adapt?

Original article can be found here.

Eye Protection for Shop Safety

15 Jan 2016 Comments

A Safety Management Approach

Bob Lapidus, DSP, CSMS

What makes for a safe workshop? Whether it be a metal shop, carpentry shop, vehicle maintenance facility, paint shop, or any of a myriad of other kinds of shops where skilled employees repair, maintain, and even build things, there are certain safety matters that pertain to all of them. All of them come under the field of safety management. Safety requires a planned approach to preventing occupational injuries.

We need to manage our work environments. For example, shops are locations where employees do technical and skilled crafts. There are inherent hazards for each type of work. Identifying those hazards, developing remedies to eliminate them, and establishing procedures to go forward and maintain a safe work environment both in terms of conditions and practices is what we are supposed to do.

There are eye hazards in many shops from either the debris coming off machinery (such as abrasive wheels, drill presses, lathes, and chemical processes) or the fragments generated by manual work from such activities as hammering, sawing, and working with other power and hand tools. The debris hazard is emanating at the point of work, but the debris can fly in any direction, not just at the worker, but at other people walking past the work being done.

As a safety consultant, I find many shops allow their employees to put on eye protection when the employees feel like doing so. I rarely see signs requiring the wearing of eye protection for the employees at the point where they are doing the work. When such signs are posted, I often see employees working without eye protection and no one is saying anything to change that behavior. Under the heading of safety management, that is called lack of accountability.

The ideal shop eye-safety program includes the requirement to wear eye protection as soon as or even prior to entering the shop. In this way, no debris from whatever work is being done, will get into someone’s eye. Signs are posted on entry doors and in the interior of the shop requiring all people in the shop to wear the needed eye protection. It is fail safe. No one in the vicinity of the work being done is exposed to an eye injury. Their eye protection prevents it.

For More Information
To become part of discussion on topics like the one above, go to to obtain information about Safety Center’s Safety Management Specialist Certificate.

After completing this nine-day program, graduates may take the exam to achieve the Certified Safety Management Specialist (CSMS) designation.  Recipients of the CSMS receive a beautiful plaque and become part of an elite group of safety specialists who have achieved this recognition.  Once this certification is attained, successful candidates keep it for the rest of their lives without any additional requirements or fees.

Final GHS/HCS Deadline is 2016: Are You Ready?

15 Jan 2016 Comments

Article from
By Fred Hosier

The final deadline in OSHA’s four-stage conversion to the Globally Harmonized System of Classification and Labeling of Chemicals (GHS) occurs in 2016. Companies will now have to be in full compliance with the revised hazard communication standard (HCS).

The final deadline is scheduled for June 1, 2016. According to the OSHA document, Small Entity Compliance Guide for Employers That Use Hazardous Chemicals:

  • “If an employer identifies new hazards after December 1, 2015, due to the reclassification of the hazardous chemicals, it has six months, until June 1, 2016, to ensure that those hazards are included in the hazard communication program, workplace labeling reflects those new hazards, and employees are trained on the new hazards.”

What about secondary containers? OSHA says:

  • “When a secondary container is used for longer than one shift, a label needs to be applied to the secondary container. This label must contain two key pieces of information: the identity of the hazardous chemical(s) in the container (e.g., chemical name) and the hazards present. There are many ways to communicate this hazard information. Employers should select a system that will work for each location.”

OSHA required employers, manufacturers, importers and distributors of hazardous chemicals to meet three previous deadlines:

  • December 1, 2013: Employers must train employees about the format and presentation of the new GHS labels and safety data sheets (SDSs) they will be seeing in the workplace.
  • June 1, 2015: All new labels and SDSs from manufacturers, importers and distributors had to be finished by this date.
  • December 1, 2015: Manufacturers, importers and distributors could no longer use 1994 HCS-compliant labels as of this date.

OSHA adopted GHS in 2012 so that labels and SDSs would be consistent with those used in most parts of the world.

HCS is the second most violated standard cited by federal OSHA. From October 2014 to September 2015, HCS was cited 5,482 times in 3,055 federal OSHA inspections for a total of $3,308,262 in proposed penalties. Only the fall protection standard for construction is cited more often by OSHA.

Reminder: The OSHA Form 300A is required to be posted on Monday, February 1st, and remain posted for 90 days.

Keeping Safety in Front of Employees

15 Dec 2015 Comments

A Safety Management Approach

Bob Lapidus, DSP, CSMS

Safety does not come naturally for some people. They have to be taught how to do their jobs safely. If left to their own way of doing things, they often will do what is expedient rather than what is safe, especially if they have not been taught how to do the work. Many employers believe their organization’s tasks are so basic that no training is required whatsoever. That is not true.

Whether it be working in an office, on an assembly line, or in the field, every environment has its own innate hazards. Management’s job is to identify those hazards, analyze why the hazard exists, and then develop steps to eliminate or reduce the hazard.

All employees who work in any given area must be trained on safety to include how to maintain a safe environment, how to do each task safely, what personal protective equipment (if any) to wear, how to protect others, and what to do in an emergency. Such training is foundational for the employee to have prior to starting work.

Once work starts, keeping safety in front of employees is important because we forget, and we get so immersed in the task at hand that we can get distracted. How can we help employees maintain an ongoing awareness of working safely on an ongoing basis?

  1. Give employees a reminder at the start of each day or shift.  It could be a safety slogan sent via email or something posted on doors, or safety information mentioned in a staff meeting.  For employers with crews or teams, a short safety talk at the start of each day or shift could be a beneficial reminder.  Get input from all employees on ideas so every work day has a different safety topic.
  2. Before a non-routine task or high hazard task is started, remind all involved employees of the hazards included in the job and what needs to be done to ensure everyone’s safety.
  3. Provide bright-colored personal protective equipment that does the job of protecting employees from dangers while being a colorful reminder that all work is done safely.
  4. Put safety reminders in and on organizational vehicles or equipment.  Change them on a regular basis.
  5. Have safety slogans put on organizational shirts as a reminder for all employees.  Have a variety of such slogans imprinted so employees are seeing an assortment of slogans.
  6. Create, implement, and maintain a solid Injury & Illness Prevention Program (IIPP) that is up front and personal for all employees.
  7. Recognize and praise work being done safely while coaching and correcting unsafe work.
  8. Ask employees for their input on making a safer work environment.

Why take the above actions?  We get distracted.  We lose our train of thought.  We think we can get away with not doing something in a safe manner.  We need something to keep us focused and aware of what we are doing so we do not get hurt.

The well-done job is a job that is done safely.

For More Information
To become part of discussion on topics like the one above, go to to obtain information about Safety Center’s Safety Management Specialist Certificate.

After completing this nine-day program, graduates may take the exam to achieve the Certified Safety Management Specialist (CSMS) designation.  Recipients of the CSMS receive a beautiful plaque and become part of an elite group of safety specialists who have achieved this recognition.  Once this certification is attained, successful candidates keep it for the rest of their lives without any additional requirements or fees.