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.

How Does your Company's Safety Program Measure Up?

 
In the broadband industry, safety isn’t just a priority—it’s a core value that can’t be compromised. But not all safety programs are created equal. They evolve over time, progressing through stages of maturity. Understanding where your safety program stands on the maturity spectrum can help you find areas of improvement and ensure your workforce is protected at all times. 

In this blog post, we'll explore how to measure the maturity of your safety program and provide suggestions for improving safety at each level.

Too long; won't read? Take this quiz to find out which stage your company is in. Personalized recommendations included: https://take.quiz-maker.com/QL3V4JR3J

1. Reactive Stage

What this looks like:

• Safety is mostly put on the backburner, or if it's considered, is mostly driven by compliance with regulations, sometimes after the threat of a citation.
  
• Incidents and accidents are often the drivers for safety initiatives.
• There is minimal employee involvement in safety processes.

How to improve at this stage:

•  Establish Basic Reporting Systems: Implement a simple incident reporting system that allows employees to easily report hazards and near-misses. It doesn't matter whether this is paper or electronic -- simple is best.
  
• Training & Awareness: Conduct basic safety training sessions to ensure all employees understand the importance of safety and their role in it. If TT&S is your training provider, great! Make sure management is attending trainings and referring to training to help bolster the points being made.
  
• Develop a Safety Policy: Create a clear safety policy that outlines the company’s commitment to safety and the responsibilities of each employee, or feel free to adopt or borrow from TT&S's rural broadband safety manual.
  

2. Compliance-Based Stage

What this looks like:

• The focus is on adhering to legal and regulatory requirements.
• Safety processes are in place, but they are often seen as a checkbox exercise.
• Employee involvement is still limited, and safety culture is weak.

How to improve at this stage:

 

• Strengthen Leadership Commitment: Encourage leaders to actively participate in safety initiatives and demonstrate a commitment to safety beyond compliance. Consider making safety the first line item of management meetings as a start.
  
• Improve Communication: Start regular safety meetings and encourage open communication between management and employees about safety concerns. If you haven't already started a near miss reporting program, now's a great time. Starting a company safety committee is great too -- make sure both management and front line employees are represented.
  
• Expand Training Programs: Introduce more comprehensive training that goes beyond compliance, focusing on hazard identification, risk assessment, and proactive safety behaviors. Attending or watching recordings of TT&S's safety leadership topics trainings would be a great start here.
  

3. Proactive Stage

What this looks like:

 

• Safety is integrated into daily operations, and there is a focus on preventing incidents before they occur.
• Employees are increasingly involved in safety initiatives, and there is a growing safety culture.
• Safety performance is monitored and used to drive continuous improvement.

How to improve at this stage:

 

• Implement a Safety Management System (SMS): Develop and implement a formal SMS that includes risk management, incident investigation, and safety performance monitoring. Does your company have formal annual reviews for employees? Consider including an annual safety goal along with their other goals that are reviewed yearly.
  
• Encourage Employee Ownership: Empower employees to take ownership of safety through involvement in safety committees and suggestion programs.
  
• Focus on Leading Indicators: Shift focus from lagging indicators (like injury rates) to leading indicators (like safety observations and near-miss reports) to predict and prevent incidents.

4. Managed Stage

What this looks like:

 

• Safety is well-managed with documented procedures and processes.
• Safety performance is systematically reviewed and improved.
• The safety culture is strong, and employees actively participate in safety initiatives.

How to improve at this stage:

• Enhance Data Analytics: Use advanced data analytics to identify trends and make informed decisions to further reduce risks. Measuring those leading and lagging indicators will get you there.
  
• Benchmarking: Compare your safety performance with industry peers to identify best practices and areas for improvement.
• Continuous Improvement: Regularly update safety procedures based on feedback and the latest industry standards (TT&S can keep tabs on that for you). Engage in ongoing training and development to keep safety practices current.

5. Integrated Stage

What this looks like:

 

• Safety is deeply integrated into the company’s values and business strategy.
• Safety leadership is demonstrated at all levels, and employees are fully engaged in maintaining a safe work environment.
• Continuous improvement is embedded in the organization’s culture, with safety performance reaching excellence.

How to improve at this stage:

• Innovate and Lead: Focus on innovation in safety practices and technologies, becoming a leader in safety within the industry.
• Share Knowledge: Share your safety success stories and best practices with the broader industry to contribute to overall industry safety improvement.
• Sustain the Culture: Continuously nurture the safety culture by recognizing and rewarding safety excellence, keeping safety at the forefront of every decision.

Assessing the maturity of your safety program is an essential step in ensuring the well-being of your workforce and the overall success of your company. By understanding your current maturity level and taking actionable steps to improve, you can create a safer work environment, reduce incidents, and foster a culture where safety is truly valued. Start where you are, and commit to continuous improvement—because when it comes to safety, there’s always room to grow.

Construction Focus Four: Fall Hazards

 

We're going to end our blog series on OSHA's "Fatal Four" hazards with a discussion on fall hazards, the last hazard in our series.

 

In the rural broadband industry, it's not uncommon for employees to find themselves working at significant heights, whether on ladders, bucket trucks, or communication towers. This high-altitude work comes with inherent risks, with falls being one of the leading causes of injury and fatality.

For rural telecom workers, the risks can be even more pronounced due to the unique challenges they face—isolated locations, unpredictable weather, and limited access to immediate emergency response. This makes prioritizing fall protection not just a regulatory requirement but an essential aspect of worker safety and productivity.

Understanding the Hazards

      1. Ladders, bucket trucks, scissor lifts

Working on any of these presents a significant fall hazard, especially in remote areas where terrain can be uneven or weather conditions hazardous. Ice, wind, or even loose soil can make footing uncertain, making the need for stable and reliable fall protection systems critical.

 

      2. Rooftop Work

While many urban telecom workers may rely on roof safety systems that are already in place, rural workers often deal with rooftops that lack such precautions. When installing or repairing rooftop equipment, there may be no guardrails or designated fall protection systems, increasing the need for personal protective equipment (PPE) and careful planning.

 

            3. Communication Towers

Rural telecom workers sometimes climb communication towers to install or maintain antennas and equipment. These towers often extend hundreds of feet in the air, and falls from such heights can be devastating. Without proper fall protection systems in place—like harnesses, lanyards, and anchor points—the risk of serious injury or death increases exponentially.

 

Key Fall Protection Solutions

To mitigate these risks, rural telecom companies should implement a comprehensive fall protection strategy that includes:

      • Personal Fall Arrest Systems (PFAS): Every worker climbing a tower or working at heights should be equipped with a PFAS, which typically includes a harness, lanyard, and an anchorage point that meets OSHA standards.

      • Guardrails and Barriers: Where possible, use physical barriers such as guardrails to prevent workers from reaching the edge of a rooftop or elevated platform.

      • Ladder Safety Devices: Fixed ladders on communication towers and poles should be equipped with safety devices, such as climbing ladder sleeves or safety cages, to prevent falls. However, if using such devices, it is absolutely essential that employers confirm safety devices are in working order with documented inspection and maintenance practices.

      • Training and Competency: Workers must be trained not only in how to properly use fall protection equipment but also in hazard identification. Routine training and refresher courses are essential to ensure workers remain competent in fall protection techniques.

      • Emergency Response Planning: In remote areas, timely emergency response is not always available. It’s crucial to have a well-established rescue plan in place, including ensuring that workers have communication devices on hand and that nearby hospitals or emergency responders are aware of the site and can provide timely assistance if needed.

Adapting to Rural Challenges

Rural environments introduce additional variables that telecom workers must consider when implementing fall protection measures. For instance, wind speed at higher altitudes on towers can make climbing more hazardous. Uneven terrain can destabilize ladders or platforms, while extreme weather conditions—common in rural areas—can further complicate safe work practices.

Rural telecom companies need to ensure that their fall protection systems are adaptable to these conditions. Regular inspections of both equipment and job sites are critical in ensuring that everything is in working order and that workers are always operating under the safest possible conditions.

By ensuring that proper fall protection systems are in place, companies can significantly reduce the risk of falls and help ensure that every worker returns home safely at the end of the day.

Construction Focus Four: Electrical Hazards

 
Following along our review of the top four hazards in construction safety, one of the most significant dangers is electrical hazards. Whether you’re climbing poles, working on underground cables, or performing maintenance on equipment, understanding and mitigating electrical risks is crucial for your safety.

Understanding Electrical Hazards

Electrical hazards in the broadband industry can arise from a few sources, including:

      1.    Power Lines: Direct contact with live power lines is a major risk. Even without direct contact, electrical arcing can cause severe injuries.

      2.    Faulty Equipment: Old or poorly maintained equipment can malfunction, leading to electric shocks or fires.

      3.    Improper Grounding: Equipment that is not properly grounded can become a hazard, especially in wet or damp conditions.

      4.    Static Electricity: Accumulated static electricity can lead to sudden discharges, potentially causing harm.

Key Safety Measures

• Conduct Thorough Inspections: 
• Before starting any work, inspect all tools and equipment. Look for signs of wear, damage, or frayed wires.
•  Ensure all equipment is properly grounded.
  
• Stay Informed and Trained:
• Regularly participate in safety training sessions.
•  Stay updated on the latest safety protocols and industry standards.
• Follow Proper Procedures:
• Always assume that power lines are live. Maintain a safe distance and use insulated tools.
•  De-energize and lock out/tag out equipment before performing maintenance.
• Be Mindful of Weather Conditions:
•   Avoid working in wet or stormy weather whenever possible, as moisture increases the risk of electrical hazards.
•  Use additional caution when working in damp environments.

Emergency Preparedness

In case of an electrical incident, you have to act quickly.

      1.    Do Not Touch: If someone is in contact with an electrical source, do not touch them directly. Turn off the source of electricity if possible.

      2.    Call for Help: Immediately call emergency services.

      3.    Administer First Aid: If trained, provide first aid such as CPR until professional help arrives.

Working in the broadband industry can be rewarding but comes with its share of risks. By understanding electrical hazards and adhering to strict safety protocols, you can protect yourself and your colleagues. Remember, safety always comes first—never compromise on the precautions necessary to ensure you return home safely at the end of the day.

Construction Focus Four: Caught-in or -Between Hazards

Last blog post we spent some time outlining one of OSHA's Focus Four hazards, so this week we're turning to a new one: Caught-in or -between hazards.

This hazard includes instances where employees are trapped between heavy construction equipment and fixed objects such as walls, trapped in trench collapses, or caught in parts of moving machinery.

Key ways to protect yourself from caught-in or -between hazards include:

1. Trench safety practices, such as soil classification, shoring, sloping, and benching. Make sure a trenching competent person is available to make the determination for which of these is the most appropriate for the trench you're working in. Remember also that air monitoring is required for any trenches deeper than four feet.

2. Lock-out Tag-out procedures for each piece of equipment that employees may need to perform maintenance on or otherwise need to have their hands or other body parts exposed to moving machinery. The equipment should have a step-by-step process to ensure that the machine cannot be accidentally turned on while the employee is engaged in the tasks that must be done while the machinery is powered off.

3. Line of sight with equipment operators - Employees on foot in a construction zone should attempt to keep within the line of sight of equipment operators. Similarly, equipment operators should not proceed with operating if they know a pedestrian is there and not currently visible. Hand signals should be discussed and agreed upon before work begins as well.

Check out this 1.5 minute video that summarizes how to keep yourself safe from caught-in or -between hazards:

Construction Focus Four: Struck By Hazards

We're well into construction season and lots of projects are underway. It's a great time to review struck by hazards and what can be done to protect yourself.

Struck-By hazards are one of what are called OSHA's Fatal Four hazards -- the top four hazard categories in construction fatalities.

The others are falls, caught-in or between, and electrocutions.

Together, these account for 60% of fatalities in construction.

Struck-by hazards are a big category. Incidents can include being struck by a vehicle, a thrown tool, rocks or gravel, or any other objects, large or small.

Check out this two and a half minute video on how to anticipate and protect yourself against struck by hazards, which can be just about anywhere in a construction setting.

Make sure to remain aware, wear your required PPE, and stay out of a vehicle's path of operation as a pedestrian.

Fourth of July Safety

TT&S wishes everyone a safe and happy Fourth of July! We hope everyone has a great time with their family and friends. Remember these safety tips to keep yourself and your loved ones safe and unharmed over the holiday.

Numbers are In: Safety Training's Impact on Employees

EHS Today recently published an article on how safety training affects employees' attitudes about their workplace, including how safe they feel, whether they'll consider staying with the company, and their overall job satisfaction.

One of the points we like to educate readers on continually is how safety is not just an added expense or cost of doing business, but that it can contribute to your bottom line. It's just not always an intuitive connection. Articles like these help to bolster that point.

The survey referred to in the article reached out to 600 employees across several safety-sensitive industries. Here's some of the findings:

• "81% report that their training makes them feel more inclined to stay at the company
• 62% believe that good training improves job satisfaction
• 57% say that safety issues make more seasoned workers leave – which contributes to the skills gap
• 44% say that safety issues make it harder to hire – which contributes to the labor shortage and widening skills gap"

Workforce hiring, training, and retention are all real costs to the business. One component to keeping those costs down is a robust safety culture and safety training program.

 

Challenge Ahead: Spot the Hazards

June is the National Safety Council's safety month. They've released a lot of great resources for employers, but this one especially caught our eye. Can you spot the hazards in each of these pictures?

Here's an idea: Consider sending these pictures out to employees. Ask if they can spot all the hazards in the picture most relevant to their workspace (the office picture for office employees, etc). The employee that finds the most hazards wins the challenge -- and maybe even a prize? Up to you. The hazards that get found the least are the ones that your employees need the most training about. Feel free to connect with TT&S to deliver training on the subject.

Check out the pictures below and follow this link to find the answers to the challenge.