Near Miss Programs: A Crystal Ball into Safety

Does your company have a near miss reporting program?

Maybe it's already embedded into your incident reporting procedures. But when is the last time someone has reported a near miss?

While it takes some work to make employees comfortable reporting near misses, those reports are extremely valuable. They are like a "second chance" for your company to rewind and make some changes before someone gets hurt or property becomes damaged.

Let's take a step back here and discuss what a near miss is.

Near misses are basically just what they sound like. It's an event where no one was hurt, property was not damaged, but it almost happened. Here are some examples that hopefully don't hit too close to home.

In the old way of doing things, these incidents would not have resulted in a report since there was no injury, illness, or property damage. But in that case you would have lost a golden opportunity to learn from the event and prevent it from repeating in the future.

Employees should be encouraged to report near misses. However, if they are at all concerned they may be punished for reporting, they will not be incentivized to report. It's important to stress that no one will be punished for reporting a near miss. Best practices dictate that employees should be incentivized and recognized for reporting any near misses as well.

Once you have that near miss report in hand, your work is not done. It's a great idea to treat these reports the way you would an incident report. Open an investigation, determine root cause with an analysis, and open up any action items needed to mitigate the potential for a related incident in the future.

It's not every day that we get to have specific safety knowledge about our company or industry handed to us on a silver platter. Take advantage of the opportunity and keep everyone just that little bit safer!
 

PPE Fit for Employees - Now a Requirement

A new PPE requirement for construction will be going into effect mid-January 2025. While providing PPE to employees has already been the responsibility of the employer, the new requirement mandates that employers must also ensure construction PPE fits properly.

The final rule (available here: https://www.federalregister.gov/documents/2024/12/12/2024-29220/personal-protective-equipment-in-construction) summarizes some of the hazards that can come from PPE not fitting properly:

"In some cases, ill-fitting PPE may not protect an employee at all, and in other cases it may present additional hazards to that employee and to employees who work around them. For example:

• Sleeves of protective clothing that are too long or gloves that do not fit properly may make it difficult to use tools or operate equipment, putting the wearer and other workers at risk of exposure to hazards, or may get caught in machinery, resulting in injuries to the wearer such as fractures or amputations. 
• The legs of protective garments that are too long could cause tripping hazards for the worker with the improperly fitting PPE and could also impact others working near that worker. 
• Protective clothing that is too small may increase a worker's exposure to hazards by, for example, providing insufficient coverage from dangerous machinery or hazardous substances. 
• The issue of improperly fitting PPE is particularly important for smaller construction workers, including some women, who may not be able to use currently existing standard-size PPE. 
• Fit problems can also affect larger workers, and standard-size PPE does not always accommodate varying body shapes."

It's been a long road to recognizing the issues with one-size-fits-all PPE. With the change, it would be a good idea for companies to inventory their current PPE over the off season and stock up on different sizes as needed prior to the beginning of construction season in spring 2025.

Happy Holidays from TT&S!

 
Happy Holidays from our team to yours! It's a great season to celebrate the efforts that everyone has taken to keep workers safe. We look forward to the new year in assisting member companies with their safety and training programs.

 

3rd Annual TT&S Tech Wars & Cornhole Tournaments

The TT&S Annual Conference & Vendor Showcase is coming soon... February 18-20, 2025!

Registrations are open for exhibitors/sponsors and attendees.

Winter Resources Roundup

 

Whether we're ready or not, winter's here again. While we're bracing ourselves for some colder weather over the holiday season, it's good to review a few safety facts about this time of year.

Remember to always check https://travel.dot.nd.gov/ for road conditions prior to beginning travel, as well as weather forecasts that might alert you to upcoming winter weather. For traveling out of state, https://www.safetravelusa.com/ will allow you to view every state's road conditions.

You might want to consider reviewing some of our previous posts about winter as well:

• To review winter driving techniques and winter car kits: https://ttsafety.blogspot.com/2023/10/winters-here-how-do-we-do-this-again.html
• Brush up on how winter affects your health: https://ttsafety.blogspot.com/2024/02/winter-and-your-health.html
• Space heater safety: https://ttsafety.blogspot.com/2023/10/keeping-warm-and-safe-space-heater.html
• Generator safety: https://ttsafety.blogspot.com/2023/11/less-discussed-winter-hazard-generator.html
  

Stay safe out there!

2024 Top 10 OSHA Violations

OSHA has released its list of most cited standards over the last fiscal year. Some of these may be familiar to you as topics that TT&S has touched on for member employees.

The Top 10 most frequently cited workplace safety standards for FY 2024 are:

1. Fall Protection – General Requirements (1926.501): 6,307 violations

2. Hazard Communication (1910.1200): 2,888

3. Ladders (1926.1053): 2,573

4. Respiratory Protection (1910.134): 2,470

5. Lockout/Tagout (1910.147): 2,443

6. Powered Industrial Trucks (1910.178): 2,248

7. Fall Protection – Training Requirements (1926.503): 2,050

8. Scaffolding (1926.451): 1,873

9. Personal Protective and Lifesaving Equipment – Eye and Face Protection (1926.102): 1,814

10. Machine Guarding (1910.212): 1,541

If you're wondering where to start focusing on as far as improvements in your safety program, making sure you're up to speed in the areas on this list is a great start. If you would like assistance with this, please reach out to TT&S for support.

Fuel Storage Safety

Whether it’s for powering trucks, generators, or landscaping equipment, keeping a supply of gasoline or diesel on hand ensures smooth operations for many businesses. However, improperly stored fuel can mean serious safety risks, including fires, explosions, and environmental hazards. This guide will help you safely store small quantities of fuel to protect your employees, property, and the environment.

1. Choose the Right Containers

Using the correct container is the first step toward safe fuel storage. Many store fuel in the red plastic gas containers that you see everywhere, but not everyone knows those are not okay for businesses to use. 

 

At the very least, make sure the gas cans you're using are FM approved and/or UL listed. And if there's any chance of the container being transported in a company vehicle or being used in the field with construction, then DOT-approved cans are a must. 

 

Remember:

      •     Use certified safety cans that are FM approved and / or UL listed. The vast majority of these containers will be metal.

      •     Clearly label containers with the type of fuel inside (e.g., “Gasoline” or “Diesel”).

      •     Never store fuel in non-approved containers like plastic bottles or buckets.

2. Store Fuel in Well-Ventilated Areas

Gasoline and diesel give off vapors that are highly flammable and can accumulate if stored in confined spaces. Always store fuel in a well-ventilated area away from enclosed spaces, where vapors could ignite.

Best practices:

      •     Keep fuel containers outside, in a dedicated, well-ventilated shed, or in a flammable cabinet.

      •     Avoid storing fuel in basements, garages attached to living spaces, or other confined areas.

      •     Ensure there’s proper ventilation and airflow wherever fuel is stored.

3. Keep Fuel Away from Ignition Sources

Fuel vapors can ignite when exposed to sparks, flames, or heat sources. It’s crucial to store fuel away from anything that could cause ignition, including electrical equipment, heaters, or smoking areas.

Safety tips:

      •     Maintain at least 50 feet of distance between fuel storage and any ignition sources.

      •     Post signs indicating “No Smoking” near fuel storage areas.

      •     Store fuel away from direct sunlight to prevent pressure buildup in containers.

4. Limit Quantities Stored On-Site

It's best practice to only store the amount of fuel you need for short-term use to reduce potential risks. Storing large quantities of fuel increases the chance of accidents and makes them more severe.

Guidelines:

      •     Avoid stockpiling large quantities of fuel. Store enough for a few days or weeks based on operational needs.

      •     Regularly inspect and rotate fuel supplies to avoid keeping old, potentially unstable fuel on-site.

5. Follow Proper Fuel Handling Procedures

Handling fuel safely is just as important as storing it correctly. Ensure that all employees are trained in proper handling techniques to minimize the risk of spills, fires, and injuries.

Fuel handling dos and don’ts:

      •     Always handle fuel in a well-ventilated area and avoid skin contact.

      •     Wear protective gloves and avoid inhaling fuel vapors.

      •     Clean up spills immediately and dispose of contaminated materials properly.

6. Fire Safety Precautions

Even with all precautions in place, accidents can happen. Having fire safety equipment readily available and knowing how to respond to fuel-related emergencies is essential.

Recommendations:

      •     Install fire extinguishers rated for Class B (flammable liquids) fires near fuel storage areas.

      •     Train employees on how to use fire extinguishers and what to do in case of a fuel fire.

      •     Create an emergency response plan for fuel spills, fires, or leaks.

Fuel storage safety is a critical aspect of maintaining a safe work environment. By using the right containers, storing fuel in appropriate locations, and following best practices for handling and fire safety, you can significantly reduce the risks associated with fuel storage. Regular training and inspections will ensure your employees are always prepared to handle fuel safely.

Flammable Cabinet Basics

 

Flammable cabinets are everywhere, and that's a good thing. But everyone might be a little fuzzy on what should get stored inside them. We're here to give you the basics.

1.  Only flammable liquids should be stored inside flammable cabinets.

Sometimes, the cabinets can become a catch-all for all hazardous materials on a site, including any acids, corrosives, or other hazardous substances. However, these should not be stored together with the flammable liquids. A separate cabinet with the appropriate construction and color should be provided for these materials.

2. There are limits to the amounts of each material allowed in a cabinet. 

OSHA sets the limits as follows: "Not more than 60 gallons of Category 1, 2, or 3 flammable liquids, nor more than 120 gallons of Category 4 flammable liquids may be stored in a storage cabinet."

3. Not all flammable cabinets are created equal.

OSHA says the cabinet "shall be designed and constructed to limit the internal temperature to not more than 325 °F. when subjected to a 10-minute fire test." Look for a cabinet that is certified by an independent third party such as Underwriters Laboratory (UL) or Factory Mutual Global (FM), as well as one meets for OSHA and NFPA 30 requirements.

 4. You should avoid storing items on top of flammable cabinets.

They might be a convenient place to set items down, but doing so can pose a risk, especially storing easily combustible items such as paper or cardboard.

There you have it! You never knew you needed a blog post about a cabinet before, but things were not quite as simple as they might seem when it comes to flammable cabinets. Be sure to contact TT&S with any further questions on proper flammable cabinet use.

 

 

Little-Known Facts for HazCom Managers

 

OSHA's hazard communications (HazCom) standard is intimidating, and it changes a lot. Due to efforts to align with international regulations, OSHA makes incremental changes to the standard that can make it hard to keep up with. There are also different aspects of the standard that apply to chemical manufacturers, importers, and employers, so it can be hard to know what might apply to you.

You may also think that if you're job title isn't "hazcom manager," then you're off the hook, but if you:

• Manage or update your company's SDS's, 
• Are in charge of purchasing, 
• Or work with chemicals in your workplace,

then you might just learn something important today. Here's a few aspects of HazCom that are maybe not talked about as much and you should be aware of.

1. SDS's should be kept for 30 years after the chemical or material is no longer in use. (See this OSHA letter of interpretation.)

This one can be a shocker to many, but because SDS's can be used as exposure records as well as an inventory of current materials in use, it's not the best idea to get rid of SDS's as soon as you stop using a product. As it turns out, they are a very effective way to record the hazards an employee was exposed to. 

There is technically an alternative to storing SDS's for that long, but it might be taking the hard way out: "Employers may discard [material] safety data sheets if some record identifying the substances used, where it was used and when it was used is retained for at least 30 years." In the long run, it's probably simpler to just keep the old SDS around.

2. There's a consumer use exception for SDS's, but it's not as useful as you may think.  

Do you need an SDS sheet for every single product in the workplace? Technically no. "OSHA does not require that [M]SDS be provided to purchasers of household consumer products when the products are used in the workplace in the same manner that a consumer would use them, i.e.; where the duration and frequency of use (and therefore exposure) is not greater than what the typical consumer would experience." Great! Get rid of that Windex SDS, stat! 

Except, of course, it's not usually that simple. Is the employee who generally uses Windex using it for the same duration and frequency as a general consumer? Or are they in a facilities maintenance position where they may be using it for many hours a week, much more than a general consumer? If so, an SDS must be kept on file.

The same goes for any product on site. If motor oil is on site, frequency and duration of the product must be considered. Is any one employee exposed more than a general consumer would be? If there's any room for doubt, it's SDS time.

However, that does leave employers off the hook for products that employees may bring into the workplace, such as lotion or hand sanitizer to keep by a desk, or products that genuinely are used in the same manner as a general consumer.

3. All it takes is one unlabelled container. HazCom is almost always one of the top cited OSHA standards, and it's a really easy one to violate. What does it take? One spray bottle without a label can land you a citation. Remember to label your containers, and while you're at it, you want to make sure it's a compliant label too. See example of all required label elements for hazardous chemicals below.

Are there exceptions? Sure, if you transfer a chemical to a portable container for immediate use, you don't need a label. But it might not be a great idea to make a habit of it.

Remember, all of these products may not be as mild or effect-free as you may think. The HazCom standard exists for a reason.... to keep you safe from what might be sneaky effects in the products that you use every day.

Hard Hat Best Practices

 

While everyone knows what a hard hat is, and it seems pretty self-explanatory, there's a lot more beneath the surface you should know about selecting the right hard hat, how to keep them maintained properly, and when they should be replaced. Read on to learn more.

• If the manufacturer has a set expiration date, that's the date you must take the hard hat out of service.
• If there's no recommended expiration set by the manufacturer, a common timeframe is five years, although this is not a set-in-stone OSHA requirement.
  
• The recommended hard hat replacement schedule is two years if the hard hat is regularly subjected to harsh environments like sun exposure or extreme temperatures. Storing them in a temperature-controlled environment can help on this one.
• An easy test for hard hat condition is to use both hands to squeeze the hard hat’s shell inward. If you hear cracking or the hard hat ‘gives,’ then replace it.
  
• Sometimes the suspension system inside the hard hat has a different replacement schedule than the shell. Many manufacturers recommend replacing this on a yearly basis.
• This one is not always popular, but it’s best practice not to put stickers or paint on hard hats. The main gist is that it could affect the electrical protection or hide any damage or defects on the hard hat. (https://www.osha.gov/laws-regs/standardinterpretations/2009-10-27)
• Always make sure you’re using the correct hard hat for the job – there are different classes for electrical hazards and direction of hazards (above vs. above and from the side). See charts below.

 

 

(This image is from DuraLabel:  https://resources.duralabel.com/articles/osha-ansi-hard-hat-requirements)

(This image is from PowerPak.net: https://www.powerpak.net/blog/everything-you-need-to-know-about-hard-hats/)

Still not sure which hard hat is the correct type for you? Go ahead and follow this link to take a quiz: https://take.quiz-maker.com/QW2Y90M9K

If you're familiar with the TT&S safety manual, we recommend a Class E hard hat in general.