Management Support for Safety: Disrupting the Paradigm Scotty Dunlap Eastern Kentucky University

Eastern Kentucky University Encompass

EKU Faculty and Staff choS larship

Spring 2019 Management support for safety: Disrupting the paradigm Scotty Dunlap Eastern Kentucky University

Follow this and additional works at: https://encompass.eku.edu/fs_research

Recommended Citation Dunlap, S. (2019). Management support for safety: Disrupting the paradigm. Safety Decisions. (Spring/Summer, 22-24)

This Article is brought to you for free and open access by Encompass. It has been accepted for inclusion in EKU Faculty and Staff choS larship by an authorized administrator of Encompass. For more information, please contact [email protected]. BEYOND COMPLIANCE: TAKING CARE OF THE SAFETY PROFESSIONAL p34

Spring/Summer 2019 SafetyDecisionsMagazine.com

Management OSHA Support for Safety: Explains Disrupting the Hybrid Paradigm p22 SDSs p43

Unaffected by Government Shutdown, OSHA Increases Penalties p48 We Can’t Fix Mental Health Lockout/ Tagout: Are with Duct Tape: There Changes on the Horizon? A New Frontier p30 in Safety p12

Spring/Summer 2019 Contents VOLUME V n NUMBER 2 DEPARTMENTS 40 Employers See the Effect of Rises in Marijuana and Opioid Use The use and misuse of both illicit and Keeping Up prescription drugs are affecting a growing 6 Beryllium Enforcement … Avetta and number of employers. BROWZ Merge … NTSB’s ‘Most Wanted’ By Guy Burdick … Whistleblower ADR Policy … Carbon

Monoxide … Telgian’s CFATS Software … Nurses and PPE … NIOSH Resources … 43 OSHA Explains Hybrid SDSs Wal-Mart Citation Vacated … Still confused about some of the finer Defense Contractor Safety Violations … points of the HazCom and GHS standards? You’re not alone, and OSHA recently provided some guidance. Strategy By William C. Schillaci 22 Management Support for Safety: Disrupting the Paradigm EHS Professional Profile “In order for safety to be effective in any organization, you must gain management’s 46 John Herr support.” That has been the mantra of the CEO—Avetta safety profession for decades. By Scotty Dunlap, EdD, CSP

28 All the HazCom Updates You Can 10 Expect This Year Revisions are coming. Here’s what you can expect to see—but don’t jump the gun on aligning your hazard communication Cover Story programs just yet. 12 We Can’t Fix By Guy Burdick 30 Lockout/Tagout: Are There Mental Health Changes on the Horizon? OSHA may be planning to explore alternative 48 with Duct Tape: methods of ensuring workers are protected from sources of hazardous energy (chemical, electrical, hydraulic, mechanical, A New Frontier pneumatic, thermal, and others). Day to Day By Guy Burdick 48 Unaffected by Government in Safety Shutdown, OSHA Increases Penalties Historically, mental health and suicide Beyond Compliance The government shutdown several months have not been considered safety ago affected many federal agencies and priorities—until now. Here is why industry 34 Taking Care of the Safety contractors but not the Occupational Safety should care deeply about these issues, Professional and Health Administration (OSHA). along with evidence-based tactics to By Ray Prest By the Safety Decisions Staff save lives and alleviate suffering. By Sally Spencer-Thomas, Psy.D. Practical Tips 50 A Trove of Fatality Data Released from the Labor Department 36 The Two-Way Relationship The federal government has long tracked PLUS Between Workers’ Comp and Safety both fatal and nonfatal workplace injuries. Do you fully understand how your workers’ The Labor Department’s Bureau of Labor 4 Editor’s Letter compensation programs and policies Statistics (BLS) has been compiling and 53 Just for Fun interact with your organization’s releasing a national Census of Fatal 54 Advertising Index safety program? Occupational Injuries (CFOI) since 1992. 54 Reader Resources By Guy Burdick By Guy Burdick

Safety Decisions is published four times a year by BLR, 100 Winners Circle, Suite 300, Brentwood TN 37027. Periodicals postage paid at Brentwood, TN, and at additional mailing offices. Postmaster: Send address changes to Safety Decisions Magazine, PO Box 5094, Brentwood, TN 37024.

SafetyDecisionsMagazine.com Safety Decisions | Spring/Summer 2019 3 Editor’s Letter

VOLUME V n NUMBER 2

PUBLISHER SIMPLIFY COMPLIANCE MENTAL HEALTH: SAFETY MUST www.simplifycompliance.com

DEFEAT SILENCE AND STIGMA EDITORIAL Senior Managing Editor, EHS AMANDA CZEPIEL, JD training or personal protective equipment. [email protected] Dr. Spencer-Thomas has provided our readers with a wealth of information and Contributing Editors resources in her cover story—please do not GUY BURDICK hesitate to use them at your organization! WILLIAM C. SCHILLACI [email protected] But while the safety professional is taking care of everybody else, who takes Senior Editor care of the safety professional? Often, good JUSTIN SCACE self-care is the key. SafeStart’s Ray Prest [email protected]

tackles the flip side of the workplace Copy Editors mental health equation in his Beyond JOAN CARLSON Compliance column, providing tips on [email protected] how safety pros can avoid burnout and stay LINDA COSTA both physically and mentally healthy. [email protected] As always, stop by the Keeping Up section AMANDA FAVA for 10 timely safety news items, and we have [email protected] e have some exciting a wide selection of other articles in this issue news at Safety Decisions as well: ART —our Fall/Winter 2018 • Management Support for Safety: Art Director issue is a Jesse H. Neal Disrupting the Paradigm DOUG PONTE Award finalist for Best • The Two-Way Relationship Between [email protected] Single Issue of a Tab- Workers’ Comp and Safety Cover Illustrator KELLY CHURCH loid/Newspaper/Maga- • Unaffected by Government Shutdown, [email protected] zine! We won’t know whether we have won OSHA Increases Penalties Wuntil after this issue has gone to print, but • Lockout/Tagout: Are There Changes on MARKETING AND we’ll keep you posted in the EHS Daily the Horizon? OPERATIONS Advisor. We are honored to be a finalist and • An EHS professional profile of John Marketing Director are very proud of the work we do bringing Herr, CEO of Avetta AMANDA HURLBURT our readers important workplace safety • A new cartoon plus OSHA challenge [email protected] news, trends, and best practices. trivia on the Just for Fun page Marketing Manager KYLE EMSHWILLER And speaking of important trends in • And much, much more! [email protected] safety, our cover story this quarter is not to be missed. Mental illness affects every- At Safety Decisions, we love hear- one, either personally or through connec- ing from our readers! Drop us a line at SALES Director, EHS Media Sales tions with friends, family, or coworkers. [email protected] RYAN VINCENT Construction workers, although they are to let us know how we’re doing and what [email protected] in a very safety-conscious industry, are at you’d like to see next. Media Client Success Manager a particularly high risk of suicide. In an MICHELLE DEFRANCESCO in-depth article, Sally Spencer-Thomas, Thanks for reading, [email protected] Psy.D., illuminates the facts of the issue along with evidence-based strategies for suicide prevention and other assistance for employees who may be struggling with their mental health. Addressing this safety issue is a great challenge today, and Justin Scace proper knowledge and intervention can Senior Editor Copyright 2019 BLR®— be just as life-saving as fall protection [email protected] Business & Legal Resources

4 Safety Decisions | Spring/Summer 2019 SafetyDecisionsMagazine.com

Keeping Up

OSHA BERYLLIUM ENFORCEMENT RAMPS UP On March 11, OSHA began enforcing additional provi- • Using Method 1023 to assess beryllium exposure levels if sions of its general industry beryllium standard, specifically beryllium is found when sampling welding fumes using the requirements for change rooms and showers. OSHA Method 125G (which cannot adequately assess OSHA will begin enforcing general industry require- exposure levels); ments for engineering controls to limit worker beryllium • Collecting one or more personal breathing zone samples dust exposures a year later, on March 10, 2020. At on the first day of the inspection; construction and shipyard workplaces, the agency is only • Placing a sampling cassette outside of the helmet/hood enforcing the permissible exposure limit (PEL), which is to monitor for abrasive blasting exposures when an 0.2 micrograms per cubic meter (µg/m3) of air averaged employee is wearing an abrasive blast respirator with a over 8 hours. hood/helmet; and Inspection procedures for enforcing the PEL include: • When collecting an air sample on a welder wearing a • Using the agency’s new sampling and analytical method protective helmet, positioning a sampling cassette inside for beryllium, OSHA Method 1023; the helmet.

qualifying the suppliers that sup- Avetta and BROWZ Merge port their global clients. Avetta’s and BROWZ’s 450 combined clients in- to Become a Leading clude blue chip companies in industry verticals such as energy, chemicals, Provider of Supply-Chain manufacturing, utilities, construction materials, facilities management, Risk Management communications, transportation, logistics and retail, mining, aerospace Avetta and BROWZ, two lead- innovator, and thought leader, expand- and defense, and food and beverage. ing providers of SaaS-based supply- ing the company’s global network to These industry leaders require better chain risk management software, 85,000 customers in over 100 countries visibility into supply-chain risks, such announced they have combined to in the fast-growing $14 billion global as workplace health and safety, sus- form a new, market-leading organi- marketplace for supply-chain risk tainability, modern slavery, data pri- zation focused on delivering the best management solutions. vacy, antibribery and corruption, and in supply chain risk management ser- Avetta and BROWZ combine more regulatory and insurance compliance. vices to companies worldwide. The than 3 decades of experience in mak- Read our profile of Avetta CEO transaction further solidifies Avetta’s ing industries safer, more sustain- John Herr in this issue of Safety position as a world-class organization, able, and compliant by vetting and Decisions! NIGHTMAN1965/GETTY.COM

6 Safety Decisions | Spring/Summer 2019 SafetyDecisionsMagazine.com OSHA Revises Its NTSB Releases Whistleblower ADR Policy Transportation OSHA has updated its policies and In the new ADR directive, changes procedures for Alternative Dispute include: Safety ‘Most Resolution (ADR) to resolve whis- • Revising the confidentiality section, tleblower retaliation complaints. The explaining circumstance in which the OSHA directive, CPL 02-03-008, OSHA official facilitating the ADR Wanted’ List amends an earlier ADR directive, re- may share information with other placing CPL 02-03-006, issued August agency officials; The National Transportation 18, 2015, and makes changes to termi- • Making minor changes in the termi- Safety Board (NTSB) released its nology and confidentiality procedures nology used to describe 2019–2020 “Most Wanted List of for the ADR process. the process and the OSHA Transportation Safety Improve- OSHA offers the ADR process as an personnel involved in the ments,” the regulatory and vol- alternative to a whistleblower complaint program; and untary changes the board feels investigation. Under the ADR program, • Revising the ADR request form to will reduce transportation-related the parties involved in a whistleblower incorporate new procedures and injuries and fatalities. dispute can choose to participate in an terminology. The NTSB is seeking 267 early resolution process leading to a set- changes, 46 in the next 2 years, to tlement agreement with the assistance of The agency now refers to the staff address the following issues: a neutral OSHA whistleblower expert. member who facilitates ADR as “the • Eliminating distractions, The process is voluntary; both parties Neutral.” It previously referred to the • Ending alcohol and drug must agree to ADR, and both must sub- neutral, OSHA expert who facilitated impairment, mit a written “Request for Alternative ADR as the Regional ADR Coordina- • Ensuring the safe shipment of Disputes Resolution (ADR)” form. tor (RADRC). hazardous materials, • Fully implementing positive train control, • Implementing a comprehensive strategy to reduce speeding- Don’t Forget Carbon Monoxide related crashes, • Improving the safety of Part 135 as a Cold Work Hazard aircraft flight operations, • Increasing implementation of If cold weather lingers in your area this spring, don’t forget about a hazard collision avoidance systems in all that is often overlooked. OSHA recently reminded employers about the carbon new highway vehicles, monoxide (CO) hazards of using portable generators, fuel-burning space heat- • Reducing fatigue-related ers, and other equipment. accidents, “Every year, carbon monoxide poisoning claims the lives of employees nation- • Requiring medical fitness screen- wide, usually when fuel-burning equipment and tools are used in buildings or semi- ing for and treating obstructive enclosed spaces without adequate ventilation,” OSHA said in a public statement. sleep apnea, and “The danger increases during the winter months when this type of equip- • Strengthening occupant ment is used in indoor areas that have been sealed tightly to block out cold protection. temperatures and wind,” according to the agency. Fuel-burning portable generators and space heaters are common sources of The Labor Department’s Bureau CO, as is anything that uses combustion to operate, such as: of Labor Statistics recently report- • Compressors, • Welding equipment, ed that transportation incidents • Furnaces, • Pumps, and accounted for 40% of occupational • Power tools, • Gas-powered forklifts and their motorized vehicles. fatalities in 2017, a—total of 2,077. Heavy and tractor-trailer truck OSHA said employers should install effective ventilation systems, avoid using drivers had the largest number of fuel-burning equipment and vehicles in enclosed or partially enclosed spaces, fatal occupational injuries with and use CO detectors in areas where CO hazards may exist. 840.

SafetyDecisionsMagazine.com Safety Decisions | Spring/Summer 2019 7 KEEPING UP TELGIAN LAUNCHES CFATS COMPLIANCE SOFTWARE

Telgian Management Technologies (TMT), a leading supplier of software solutions that enhance chemical industry adherence to compliance regulation requirements, recently released a new module for its Telgian Compliance Manager. The module addresses the U.S. Department of Homeland Security’s Chemical Facility Anti-Terrorism Standards (CFATS), a regulatory program focused specifically on security at high-risk chemical facilities. This CFATS module is the first commercially available relational database software application designed specifically to track CFATS compliance solutions and security measures in a concise and effective platform. The module is flexible, scalable, and secure and provides consistent and efficient data management in real time, allowing users to manage all of their security protocols in one place. In addition, the Telgian Compliance Manager’s CFATS module allows organizations to submit and track forms and reports related to various requirements. The software also provides ongoing tracking of compliance activities, including plan or document reviews and revisions. As site security plan or alternative security program data are entered, the software offers continuous, one-step documenting and tracking of required annual audit information. “For the chemical industry, this module release comes at a crucial juncture,” explains TMT Program Manager Ashley Reiter. “Just weeks ago, Congress unanimously passed legislation to reauthorize the CFATS program.”

While these drugs are vital for cancer patients—the Study Discovers drugs kill rapidly dividing cancer cells—the drugs also can threaten a nurse’s healthy cells, as well as the cells of a Some Nurses Aren’t developing baby. The effects of these hazardous drugs include: • Carcinogenicity (actually causing cancer in Using PPE with otherwise healthy cells); • Cytoxicity (literally toxic to cells); Hazardous Drugs • Fertility impairment or reproductive toxicity; Female nurses who give cancer patients their med- • Genotoxicity (causing mutations); ications don’t always wear gloves or gowns to protect • Organ toxicity; and themselves from hazardous drugs, according to a new • Teratogenicity (causing mutations in embryos National Institute for Occupational Safety and Health or fetuses). (NIOSH) study. When nurses administer chemotherapy in pill or liquid The NIOSH study found that nurses—including those form (in an intravenous drip, for example) to patients di- who were pregnant—reported not wearing protective agnosed with cancer, the nurses are exposed to hazardous gloves and gowns, the minimum protective equipment drugs known as antineoplastic drugs. recommended when administering these drugs. METAMORWORKS/GETTY.COM

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GAO Finds History ELIMINATE NIOSH Resources Click of Safety Violations with Employers Among Defense The National Institute RISKS for Occu- • NIOSH Lifting Equation; and Contractors pational Safety and Health (NIOSH) • NIOSH Manual of Analytical announced the most accessed re- Methods. Department of Defense (DOD) WITH THE MAT THAT sources on its blog, social media ac- contracting officials need to more counts, and website during 2018. Website users also frequently read closely focus on contractor safety Employers, workers, and the pub- NIOSH pages on emergency needle- performance when awarding defense lic can find evidence-based safety and stick information, NIOSH-approved contracts, the Government Account- health resources on the institute’s site N95 particulate filtering face piece res- ability Office said in a new report. and social media accounts. pirators, and the institute’s World Trade The GAO also wants OSHA to Users can download copies of Center Health Program, which provides consistently include a searchable STICKS NIOSH’s print publications on its medical monitoring and treatment for company identification number in website, https://www.cdc.gov/niosh/ responders at sites of the September 11, its inspection and enforcement data. index.htm. These include publications 2001, attacks at the World Trade Center, The GAO found a history of indispensable for complying with fed- Pentagon, and Shanksville, Pennsylvania. workplace safety and health vi- eral and state regulations. The ones The terms most often searched on olations among companies that most often downloaded last year were: the NIOSH website were: were awarded defense contracts, • NIOSH List of Antineoplastic and • NIOSH, according to its report, “Defense Other Hazardous Drugs in • NIOSH pocket guide, Contracting: Enhanced Informa- Healthcare Settings, 2016; • NIOSH hazardous drug list, tion Needed on Contractor Work- • NIOSH Pocket Guide to • WTC health program, and place Safety.” However, GAO au- Chemical Hazards; • Heat stress. ditors found it difficult to match defense contractors with company names in OSHA’s database. YOUR PROBLEM OUR PROVEN SOLUTION The GAO also recommended that the DOD take the following steps: • Advise contracting officials He strides into the plant ready to take on the day. Will your wrinkled rental rugs trip him up before he starts? that the OSHA website is a ® OSHA’S CITATION AND resource for information Stop holding your breath — eliminate the risk with Grippy Mat. about contractors’ workplace Adhesive-backed Grippy Mat is the PROVEN safe floor solution that reduces slip, trip and fall claims FINE OF WAL-MART safety and health records. • Explore the feasibility of re- by at least 80% while cutting floor mat expenses in half. Here’s what it did for this happy user: quiring a safety performance “Decreasing falls is always an annual performance monitor and goal of our safety staff. We have VACATED rating for contracts in indus- An Administrative Law Judge (ALJ) vacated OSHA’s citation of tries that have relatively high been at zero fall incidents since installing Grippy Mat.” – Rebecca, Grippy Mat customer Wal-Mart and one of its contractors for alleged violations of the lockout/tagout rates of occupational injuries, It’s not magic. It’s super-safe Grippy Mat — the world’s FIRST adhesive-backed mat. standard. The alleged violation was cited following an incident in which a work- such as manufacturing, er at a Brundidge, Alabama, distribution center was struck by an automated construction, and ship Only from New Pig and our fine distribution partners. trolley October 18, 2016, and sustained a serious leg injury. building and repairing. OSHA had sought penalties of $126,749 each from Wal-Mart Stores East, L.P., and Swisslog Logistics, Inc. The ALJ with the Occupational Safety and The DOD concurred with both Health Review Commission (OSHRC) dismissed the fines. recommendations. ® OSHA accused both Wal-Mart and Swisslog of willful violations of the GRIPPY FLOOR MAT lockout-tagout standard for failing to have documented procedures in place Keeping Up is compiled by staff and for the control of hazardous energy. The ALJ instead ruled that Wal-Mart had contributors of the EHS Daily Advisor TM rigorous procedures in place; but that Wal-Mart and Swisslog employees failed and Safety Decisions magazine. NO SLIP. NO TRIP. ALL GRIP. to follow those procedures. Reprint: SD_0319-1 Take the first step to safer floors! Get a FREE Grippy Mat Switch Kit at

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KELLY CHURCH COVER STORY

Historically, mental Safety professionals are well-versed in the “fatal four”— falls, struck by object, electrocution, and caught in be- health and suicide have tween—and know that if they are able to prevent these forms of death, they will save almost 600 lives each year.1 not been considered What most safety professionals are unaware of is that suicide in construction takes many more lives. A recent study safety priorities— published by the Centers for Disease Control and Preven- tion (CDC)2 found that, in their sample, 20% of all men until now. Here is why who died by suicide in the United States were in the construction/extraction industry. 47,173 people died by sui- industry should care cide in 2017, and 27,404 of them were men ages 20-64.3 If 20% of these men were in construction/extraction, that deeply about these means we can estimate that over 5,000 men working in this industry died by suicide—about nine times more than all issues, along with of the fatal four deaths combined. When a workplace fatality happens, the cause is very evidence-based frequently determined to be “accidental” and a deeper investigation into intent to die is not undertaken. With this tactics to save lives mindset, the remedy is often simple: more safety training. When we look at these fatal occupational injuries, howev- and alleviate suffering. er, the first two most common (transportation incidents and falls) are also common ways people think about taking their lives.4, 5 Thus, it is possible that some, if not many, of these workplace fatalities are actually suicide deaths— By Sally Spencer-Thomas, Psy.D. which means that additional safety training may not be effective in preventing them. The reason suicide has not widely concerned safety professionals before is that most suicide deaths do not occur at the workplace and thus were not considered work-related fatalities. Today, we know different, and there are many

SafetyDecisionsMagazine.com Safety Decisions | Spring/Summer 2019 13 COVER STORY

things workplaces can do to prioritize suicide prevention and mental health promotion within their health and safety programs. Why Is Construction at Risk? [text]Not all workplaces are created equal when it comes the so-called “deaths of despair”—suicide, overdose, and the fatal outcomes of addiction.6 In the U.S., the construction industry ranks first for all industries by highest number of suicides, and second for all industries by rate of suicide. White men of middle age have some of the highest rates and total numbers of suicide in the U.S.,7 so part of the answer is due to the demographic working in construction; however, many aspects of the work also increase risk. While self-reliance is often valued as a sign of strength and mental stability, it is paradoxically one of the stron- gest predictors of poor mental health and suicide risk when looking at several attitudes.8, 9, 10 Therefore, industries that value self-reliance are often at heightened risk. Atti- tudes and beliefs such as “I can solve my own problems” and “Others do not need to worry about me” are often a major barrier to seeking support from family, peers, or professionals. Thus, it is not surprising that occupations like construction that tend to be male-dominated and value stoicism and other traditional masculine norms have the highest rates (in construction’s case, a rate of 53.3 per 100,000 workers) of suicide.2 Why Are These Workplace Safety Concerns? There are many reasons why mismanaged mental health conditions and unchecked suicidal thoughts can lead to safety concerns. • Distraction. Having suicidal thoughts and symptoms of illnesses like depression, anxiety, and addiction are intense, and trying to hide them from other people can make them all-consuming. For example, racing or intrusive thoughts as experienced by people living with bipolar condition, trauma, or thought disorders such as schizophrenia can be very distracting. This distraction can interfere with decisiveness and attention to safety. • Impulsivity, impaired perception, and bad judg- ment. Agitation, tunnel vision, distorted thinking, microsleep,11 where the brain involuntarily goes “of- and paranoia are common symptoms among several fline” into a sudden sleep state for a matter of seconds. mental health conditions. When left untreated these This state can have disastrous consequences for many symptoms can interfere with workplace security, safety, safety-conscious professions, including those involving and morale. the operation of machinery and heavy equipment. • Fatigue and microsleep. Sleep disorders are common • Other medical complications. When mental health in many forms of mental illness and suicidal intensity. challenges reach crisis levels, other physical health Insomnia is present in many forms of mood disorders, challenges involving pain, gastro-intestinal problems, anxiety disorders, and substance use disorders. People and heart function can result. living with depression often experience lethargy and • Risk-taking and disregard for safety precautions. what is known as anhedonia—the inability to feel When people are overwhelmed by the emotional pain pleasure. Sometimes extreme fatigue can result in in their life and have come to a place where the only

14 Safety Decisions | Spring/Summer 2019 SafetyDecisionsMagazine.com way they can get out of this pain is to die, they often trigger suicidal thoughts. When an employee also has the consciously or subconsciously start to take more risks “capability for suicide”—an innate or learned fearlessness or even practice suicidal behavior as they test out their of death—the risks for death by suicide increase.14 capacity for self-harm. Job Strain and the Stress Injury Continuum What Contributes to Suicide Risk? Many workplaces realize that the concept of “occupational Mental Health Conditions health” has shifted to “total worker health.” According to “Mental health conditions” is a broad phrase that encom- the National Institute for Occupational Safety and Health passes a wide spectrum of issues, from what mental health (NIOSH), “Total Worker Health” is a holistic approach to providers call “adjustment disorder” (reaction to a stressful promote worker well-being through policy, programs, and life event) to depression to bipolar condition to schizo- practices.15 Researchers are clear: Risk factors in the work- phrenia. The phrase can also include the wide range of place can contribute to health concerns—including suicide substance use disorders like binge drinking and opioid ad- risk—previously considered unrelated to work.15, 16, 17 Thus, diction. Most of these conditions are dynamic and exist on improvements in the psychosocial conditions of work may a continuum, which means people can move up and down improve well-being and prevent suicide. the severity scale of their symptoms. We tend to call something a mental health “condition” or “illness” or “disorder” when the symptoms get in the way of love, work, and play. For instance, if your anxiety is so intense you cannot sleep well for the better part of two weeks, you might meet the criteria for an anxiety disorder. If you find yourself craving alcohol and continually overconsume despite consequences like hangovers or risky behaviors, you might meet the criteria for an alcohol use disorder. Mental health conditions may be brought on by things that happen to us. Some people may succumb to mental health conditions like depression when experiencing over- Adapted from NIOSH’s Hierarchy of Controls whelming life challenges like divorce, layoffs, pain, or other health challenges. Still others may feel the effects of trauma from car accidents, sexual assault, or natural disasters. When we look at NIOSH’s Hierarchy of Controls, work- Some people may inherit a predisposition to certain places striving to prevent suicide can first eliminate threats mental health conditions based on their genetics or how to psychological safety (e.g., bullying and/or toxic manage- their brains were wired when they were born. Some people ment practices) and substitute these unsafe practices with live with chronic and severe symptoms; others experience those that promote mental health and protective factors symptoms only once or intermittently. (e.g., cultivating a sense of belonging). Redesigning work The good news is that treatment can be very effective culture for optimal well-being might include making access for most people. According to the CDC, 80% of people to quality mental health care easier or changing the process with depression will improve with treatment.12 When de- of performance reviews to make them more collaborative pression or other mental health conditions are not well and mindful of how psychological distress impacts work managed, however, workplaces often see a drastic impact abilities.18 At the bottom of the hierarchy, we find personal on productivity and absenteeism. For instance, in a three- empowerment interventions of education and training for month period, people living with depression experience an psychological safety and encouraging individual practices average of 11.5 days of reduced productivity and 4.8 missed of self-care and treatment. The environmental interven- work days. Of all the costs related to workplace depression, tions at the top of the pyramid are more likely to be effec- the American Psychiatric Association Foundation found tive because they impact everyone is a systemic way. that “presenteeism” was the biggest drain—in other words, Many workplace well-being hazards and “job strain” put people were showing up to work but they were unable to workers at risk for suicide and significant emotional dis- function.13 tress. These hazards include but are not limited to: When left untreated, mental health conditions can • Low job control, a lack of decision-making power, and progress, like cancer, to become life-threatening. The emo- limited ability to try new things; tional pain and hopelessness can leave many to feel there • Lack of supervisor or collegial support and poor is no other way to escape the unimaginable suffering. For working relationships; others, the experience of feeling like a burden or feelin • Excessive job demands and constant pressure or like important social connections have been lost can overtime;

SafetyDecisionsMagazine.com Safety Decisions | Spring/Summer 2019 15 COVER STORY

• Effort-reward imbalance, related to perceived insuffi- This continuum helps us to normalize these states and cient financial compensation, respect, and/or status; allows managers and employees to appreciate how peo- • Job insecurity, such as the perceived threat of job loss ple can move along this continuum when experiencing and anxiety about that threat; different life events, environmental threats, and internal • Bullying, harassment, and hazing at work; challenges. Once we better understand the challenges, we • Prejudice and discrimination at work; are in a better position to take action. • Work-related trauma; • Work-related sleep disruption; Aspiring to a Zero Suicide Mindset at Work: • Toxic work design elements (i.e., exposure to environ- Building a Resilient Workforce mental aspects that cause pain or illness); and The idea of “aspiring to zero” is not foreign to safety- • Workplace culture of poor self-care and maladaptive conscious workplaces. Workplaces and industries that have coping (e.g., alcohol and drug use). successfully reduced work-related mortality and morbidity went beyond just compliance with workplace safety Of these, job security has been associated with higher regulations. They fully embraced a 24/7 mindset and a odds of suicidal ideation and issues with job control ap- paradigm-shifting commitment to safety that permeated pear to be more connected to a risk of suicide attempt and all areas of their cultures and became closely tied to the death.16 Prospective evidence also exists that workplace core values of their organizations.19 The concept of making bullying, especially physical intimidation, can lead to construction a zero suicide industry is aspirational.20 It is suicidal intensity.17 not “zero tolerance,” a quick fix, a marketing strategy, or a One study16 found that proximal risks to the construc- short-term goal that we have “failed” if we don’t reach it. tion workers’ suicide deaths included a transition in work The intent is to create a stress- and blame-free culture that experiences, a workplace injury resulting in pain or dis- examines every suicide death with this perspective—how ability, and financial issues. The study also found that the can our company improve to save lives? decedent often disclosed to coworkers about suicide plans In order to prevent suicide and alleviate the suffering prior to death, indicating that peer support could be a brought on by mental health conditions, companies must life-saving intervention. develop a comprehensive and sustained approach to pre- By understanding the interplay between environmental vention and risk mitigation. A comprehensive and sus- hazards and mental health, we can start to conceptualize work- tained suicide prevention strategy does not consist of a ers’ distress and despair. The U.S. Marine Corps has done this “one-and-done” training session or a standalone awareness as a color-coded continuum, from the green zone of vibrant day. Rather, activities, communications, training compo- well-being to yellow and orange zones of reaction and injury nents, and other elements are woven into the places where to the red zone of potentially life-threatening illness. other health and safety activity is already happening. This

The Stream Parable

You are walking along a river one you have saved two lives in one day, you because it’s hard to learn how to tread day and you hear a plea for help from mop the sweat from your brow. When water when you are drowning. someone who is drowning. You are you turn around, however, you see more startled but energized as you dive into drowning people com-ing down the Everyone looks at each other, complete- the water and save him. Using all your river. One after another. ly overwhelmed, wondering when this strength you pull him to shore and start will stop. Finally, you stand up and start administering CPR. Your adrenaline is You shout out to all the other people running upstream. Another rescuer racing as he starts to regain conscious- around you to help. Now there are glares at you and shouts, “Where are ness. Just as you are about get back on several people in the river with you— you going? There are so many drown- your feet, another frantic call comes pulling drowning people out left and ing people; we need everyone here to from the river. You can’t believe it! You right. One of the rescuers swims out to help!” To which you reply, “I’m going dive back in the river and pull out a the drowning group and tries to start upstream to find out who or what is woman who also needs life-saving care. teaching them how to tread water. This pushing all of these people into the Now a bit frazzled but still thrilled that strategy helps some, but not all of them river—and why.”

16 Safety Decisions | Spring/Summer 2019 SafetyDecisionsMagazine.com integration will not only help preserve the longevity of the efforts, but it will also help people connect the dots between these varying health and safety priorities.

Framework for a Comprehensive Approach: The Stream Parable What the research tells us is that our best outcomes in reducing suicide rates come from comprehensive and sustained efforts where training is just one component of an overall strategy.21 Viewing a common parable (see the sidebar) from a public health perspective illuminates what a comprehensive approach might entail. Upstream, midstream, and downstream approaches are needed to prevent suicide. Upstream strategies build protective factors that can mitigate risk, such as cultivating a healthy culture of respect, compassion, and dignity and eliminating stig- matized language and discriminating actions against people living with mental health conditions. Additionally, companies can focus on building resilience by enhancing life skills and mental hardiness and by bolstering mental health and suicide prevention literacy. With an upstream focus we can build a smarter workplace design with more flexibility and greater individual and team input into decision-making. We can also focus on psychosocial harm and hazard reduction.

SafetyDecisionsMagazine.com Safety Decisions | Spring/Summer 2019 17 COVER STORY External Links and Resources General Resources for Workplace Mental Health • Screening for Mental Health, Inc.: www.mentalhealthscreening.org and Suicide Prevention • Interactive Screening Program by the American Foundation • Construction Working Minds: http://www.constructionworking- for Suicide Prevention: https://afsp.org/our-work/interactive- minds.org/ screening-program/ • Construction Industry Alliance for Suicide Prevention: http:// www.preventconstructionsuicide.com/ Downstream Resources • Suicide Prevention Resource Center resource: Preventing suicide • National Suicide Prevention Lifeline: http://www. among men in the middle years: Recommendations for suicide suicidepreventionlifeline.org/ prevention programs: http://www.sprc.org/sites/default/files/ • Crisis Text Line: www.CrisisTextLine.org resource-program/SPRC_MiMYReportFinal_0.pdf • Partnership for Workplace Mental Health: http://www.workplace- Communication mentalhealth.org/ • Framework for Successful Messaging in Suicide Prevention: http://suicidepreventionmessaging.org/ Upstream Resources • KyndHub, an online community (with workplace partners) that Training fosters daily practices of volunteerism, intentional acts of kind- • Mental Health First Aid for Workplaces: https://www. ness, and gratitude: www.KyndHub.com mentalhealthfirstaid.org/at-work/ • Right Direction (addresses depression in the workplace): http:// • Working Minds: https://www.coloradodepressioncenter. www.rightdirectionforme.com/ org/workingminds/ • safeTALK: https://www.livingworks.net/programs/safetalk/ Midstream Resources •Question, Persuade, Refer (QPR): https://qprinstitute.com/ • Man Therapy: www.ManTherapy.org • Advanced Crisis Intervention Training (ASIST): https:// www.livingworks.net/programs/asist/

A major key in developing a proactive mental wellness of the well-known suicide prevention gatekeeper training mindset is leadership engagement. Successful programs program Question, Persuade, Refer (QPR), Dr. Paul Quin- will have top-level leaders that see issues of mental health nett states, “the person most likely to save your life from promotion and suicide prevention as cutting edge issues suicide is someone you already know.” Some companies and imperative to workplace ethics. Cultivating the mind- have developed an informal “buddy check” program that set of civility in community and a culture of trust comes goes beyond looking out for physical safety but also has from the top. True leadership isn’t afraid to be bold; true coworkers noticing patterns of emotional distress. leaders are vocal, visible, and visionary with no fears of Other groups have set up more formal peer support stepping forward to do the right thing. Communication programs as a way to promote a caring culture and in- from leadership on building a caring culture where peo- crease the chances of early intervention. Many military and ple look out for each other’s well-being and pull together first responder communities have discovered this type of when times are tough needs to be tied to the mission and program is often the key in building a link in the chain of vision of the organization—and properly communicated survival, especially among their stoic, “tough guy” cultures to the workers. Leaders demonstrate this commitment by where men in particular are reluctant to seek professional investing resources of time and money into mental health mental health services. resources, training, and education and by modeling appro- We know that many of those most at risk for suicide priate self-care and compassion. are sometimes the least likely to reach out to professional Midstream approaches help identify those workers clinical services,22 but they often will reach out to a trusted facing emerging risk and then link them to appropriate peer or colleague. A properly selected, trained, and super- support before the issues develop into a suicidal crisis. vised peer has the potential to decrease loneliness through Midstream strategies include screening for mental health empathic listening and shared lived experience, and he or conditions and suicidal thoughts, promoting and normal- she may provide hope as a model of recovery. izing help-seeking behavior, and training populations on Downstream tactics are necessary when determining how to have difficult suicide-specific and mental health how best to respond when a suicide crisis has happened, support conversations. including acute thoughts of suicide, suicide attempts, or At the heart of midstream psychological safety work- suicide deaths. Downstream approaches support recovery place programs is effective peer support. No longer is it only by helping employees reintegrate and receive help during the mental health professionals’ responsibility to prevent and after stressful life events and challenges with mental suicide—everyone can play a role. In fact, as the founder illness. This support includes allowing for sick leave and

18 Safety Decisions | Spring/Summer 2019 SafetyDecisionsMagazine.com other accommodations just like would be provided after health and suicide stems from fear, and this fear is the re- other major illnesses, injuries, or accidents. sult of ignorance—we fear what we don’t understand. Pro- Having access to the right mental health services through viding education and awareness can help reduce this fear a quality Employee Assistance Program (EAP) program is and replace it with a reassuring reality. essential. Mental health conditions top the list of the most Education on mental health and suicide prevention costly illnesses in the United States, far outpacing the cost literacy primarily focuses on three things: burden of cancer, obesity, heart disease, and stroke; one- 1) Knowledge about mental health conditions and third of this cost burden is connected to productivity loss, substance use disorders (especially alcohol and opioid disability, and decreased work performance.23 use), as well as how these are connected to other health Unfortunately, only 50–60% of adults with these men- issues like pain and sleep dysregulation; tal health conditions are getting the services they need. 2) Familiarity with mental health resources, support tools, Because many people who have suicidal thoughts do not and treatment options; and connect their despair to a mental health issue, and the 3) Stories of hope and recovery. majority who die by suicide do not have a known mental health condition,22 the assumption can be made that many Of these three, the last is the most powerful in creating people living with suicidal thoughts are also not getting change. Facts and frameworks are helpful, but getting to any treatment. know people who have “lived expertise” with depression, When people do get treatment for depression, they im- anxiety, addiction and suicidal thoughts does more to prove in work and in life. One report23 mentioned that undo stigma than all other methods. 80% of people who were treated for depression improved One innovative approach that helps with all three goals quickly, especially when the problems were identified ear- is “Man Therapy,” a program designed to reach the “double ly in the progression. Additionally, 86% of employees who jeopardy” man—the man who lives with a number of risk were treated reported a decrease in absenteeism/presentee- factors for suicide and also is the least likely to reach out ism and an increase in work performance.23 for help himself. Man Therapy uses compelling, humor- Downstream approaches also address what to do after a ous media to drive men to the Man Therapy website portal mental health or suicide crisis has impacted the workplace. (www.ManTherapy.org), where they can take the 20-point These events cannot be swept under the carpet—they must head inspection. The results help answer the question be addressed head-on with compassion and dignity for all “How bad is it?” when it comes to their depression, anxi- involved. ety, substance use issues, or anger. Based on the results, the website then helps link the man to specific resources based Suggested Activities on his presenting concerns. Some are self-help tips, others Toolbox talks. Many construction companies are now in- are external resources, and some are inspirational videos of tegrating mental health and suicide prevention topics by real men in recovery. developing toolbox talk briefings that educate the workforce on what to look for and what to do (see some examples from Construction Working Minds at http://www. constructionworkingminds.org/toolbox-talks.html). Stand Down for Suicide Prevention. This very well- established OSHA program usually focuses on preventing falls and is highlighted in May of each year, involving mil- lions of employees.24 Others have now taken up this concept in suicide prevention. For example, the U.S. Army has conducted a Stand Down for Suicide Prevention where a mandatory servicewide shut down occurred so that service members could be trained in suicide prevention.25 Union Pacific (UP), an organization with 10,000 employees, also conducts a stand down event every year on World Suicide Prevention Day.26 Nearly 200 volunteers throughout the UP system make personal contact with employees as they report to work or leave work, handing out wallet-sized Develop a tiered training program. One best practice cards about suicide and giving employees a key chain with for a comprehensive mental health promotion and suicide the inspirational message, “Stay Connected.” prevention program is to build out a stratification of roles Tackle prejudice by educating and inspiring your and skills. At the bottom level everyone gets some basic workforce. Too often our reluctance to talk about mental mental health awareness and skills training. The more

SafetyDecisionsMagazine.com Safety Decisions | Spring/Summer 2019 19 COVER STORY

reluctant to seek help on their own. Frequent and regular “Workplace mental health screenings for testicular cancer or blood pressure can help identify problems before they develop into life-or-death promotion and suicide situations—similarly, the prognoses for mental health conditions are most favorable when they are detected early and treated appropriately. prevention is not only Like other medical checkups, screenings for mental health conditions are most effec-tive when they are repeat- a good safety priority, ed over time and considered a standard part of one’s overall healthcare routine. Screenings are a universal tool—any- it’s the right thing to do. one can use them to help de-tect signs and symptoms of larger issues. They should not be used to diagnose, but they Workers who know can provide a snapshot to help identify low- and high-risk populations and pro-vide a call to action. Screening that is given throughout a workplace sends a strong cultural that their well-being is message—we value what we measure. Kick the tires of your Employee Assistance Program. connected to the mission EAPs are a valuable asset to the workplace. They help employers by offering psychological assessment and of the company are more short-term counseling, managing critical incidents, and conducting fitness for duty evalua-tions, to name just a few likely to be engaged services. EAP providers can be critical consultants when an employer is concerned about a staff member’s safety and can help develop reintegra-tion plans for employees and productive.” who need to go on medical leave due to a mental health problem. The problem with most EAPs is that they are a hidden benefit when offered by em-ployers. Most people don’t people know, the more eyes we have on the playing field know how to access their EAP or what services are offered. and the more likely someone will notice and take action Not all EAPs are equal—some provide state-of-the-art when needed. Indeed, research supports the conclusion care in a wide range of ser-vices, while others just provide that greater awareness of symptoms of suicidality is associated superficial, short-term, or inadequate referral services. with greater help-seeking.27 Therefore, the first step in promoting mental health ser- At the middle tier are managers, peer supporters, vices like EAPs or other com-munity mental health centers wellness coordinators, safety man-agers, and the like with is to kick the tires a bit. Company leaders should personally advanced mental health and suicide prevention aware- investigate or even partake in the services to understand ness/skills and psychological first aid skills. MATES in the experience and ei-ther advocate for better services Construction (http://matesinconstruction.org.au/about/ or simply be an informed liaison to the existing services. how-mic-works/), an evidence-based work-place program, Once a quality EAP has been identified, the benefit needs call this tier “The Connectors.” This tier is like the EMT to be promoted regularly through multiple communica- level of the comprehensive suicide prevention community. tion channels along with on-site opportunities to meet They are the ones people turn to in or-der to see if prob- providers and ask questions. lems can be resolved with basic active listening, empathy, Promote crisis resources. The National Suicide Pre- empowerment, and caring follow-up, or if a more rigorous vention Lifeline (NSPL) repre-sents the prevailing network intervention is needed. of hotlines today. Calls to this national toll-free number, At the top level are highly trained and supported EAP 1-800-273-TALK (8255), are funneled through this net- mental health professionals and trusted community men- work to local call centers across the U.S. based on the area tal health partners—these professionals assist with the code of the caller. During calls, the crisis call counselors most complicated and acute cases. The top level also helps listen empathically and empower callers to make decisions supervise the middle tier, regu-larly providing state-of-the- that resolve their own cri-ses. They offer information and art continuing education to sharpen their skills on suicide resources, and they help callers craft plans for how they will risk assessment, management, and recovery. prevent, cope with, or get help for their emotional crises. Anonymous and confidential screening. Anonymous The Crisis Text Line (www.CrisisTextLine.org) also of- and confidential screening can help engage those most fers immediate support during any type of crisis. Just like

20 Safety Decisions | Spring/Summer 2019 SafetyDecisionsMagazine.com well-being. By Lee MP, Hudson H, Richards R, Chang CC, Chosewood the NSPL, the Crisis Text Line is free and offers 24/7 sup- LC, Schill AL, on behalf of the NIOSH Office for Total Worker Health. Cincinnati, OH: U.S. Department of Health and Human Services, port for those in crisis. People in crisis (and/or the people Centers for Disease Control and Prevention, National Institute for who are supporting them) just text HELLO to 741741 from Occupational Safety and Health. DHHS (NIOSH) Publication No. 2017-112. anywhere in the U.S. to be connected via text to a trained >16Milner, A., Witt, K., LaMontagne, A. & Niedhammer, I. (2017). Psychosocial job crisis counselor. stressors and suicidality: A meta-analysis and systemic review. Occupational and Environmental Medicine. Retrieved on January 3, 2018 from https://oem. bmj.com/content/75/4/245. The New Safety Frontier >17Leach, L., Poyser, C. & Butterworth, P. (2017). Workplace bullying and the To help you on your journey to keep your workforce safe association with suicidal ideation/thoughts and behavior: A systemic review. Occupational and Environmental Medicine, 74: 72-79. from both physical and mental health hazards, we’ve pro- >18McClatchey, M. & Spencer-Thomas, S. (2017). New approach to mental health. vided an extensive array of external links on page 18. Please Insurance Thought Leadership. Retrieved on January 8, 2019 from http:// don’t hesitate to use them! insurancethoughtleadership.com/new-approach-to-mental-health/. Workplace mental health promotion and suicide pre- >19Lehmann, R. & Spencer-Thomas, S. (2017). When Workplace Safety Is Core… Insurance Thought Leadership. Retrieved on January 2, 2019 from http://insur- vention is not only a good safety priority, it’s the right thing ancethoughtleadership.com/when-workplace-safety-is-a-core-value-mental- to do. Workers who know that their well-being is connect- health-promotion-and-suicide-prevention-matter/. ed to the mission of the company are more likely to be >20Leieritz, J. (2016). Construction Industry Alliance Announces New Resources Aimed at Preventing Suicides. Associated Builders and Contractors News Re- engaged and productive. It’s time safety professionals em- leases. Retrieved on February 14, 2019 from https://www.abc.org/News-Me- braced this new frontier of safety—because no one should dia/News-Releases/entryid/7940/construction-industry-alliance-announces-new-resources-aimed-at-preventing-suicides. die in isolation and despair. >21Knox, K. L., Litts, D. A., Talcott, W. G., Feig, J. C., & Caine, E. D. (2003). Risk of suicide and related adverse outcomes after exposure to a suicide prevention Endnotes: programme in the US Air Force: Cohort study. BMJ: British Medical Journal, >1U.S. Department of Labor (n.d.) Commonly Used Statistics. Retrieved on Febru- 327(7428), 1376-1378. http://dx.doi.org/10.1136/bmj.327.7428.1376. ary 14, 2019 from https://www.osha.gov/oshstats/commonstats.html. >22CDC (2018). Suicide rising across the US: More than a mental health concern. >2Peterson, C., Stone, D.M., Marsh, S.M., Schumacher, P., Tiesman, H., LiKamWa Retrieved on January 2, 2019 from https://www.cdc.gov/vitalsigns/suicide/info- McIntosh, W., Lokey, C., Trudeau, A., Bartholow, B. & Luo, F. (2018). Suicide rates graphic.html#graphic2. by major occupational group—17 States, 2012 and 2015. MMWR Morbidity and >23Goetzel, R. Roemer, E., et al. (2017). Mental health in the workplace: A call to Mortality Weekly Report; 67:1253–1260. DOI: hop://dx.doi.org/10.15585/mmwr. action—Proceedings from the mental health in the workplace “Public Health mm6745a1. Summit”, Journal of Occupational and Environmental Medicine. Retrieved >3CDC (2017). Injury Prevention & Control Data and Statistics (WISQARS): Fatal on February 11, 2019 from https://www.ncbi.nlm.nih.gov/pmc/articles/ Injury Data. Retrieved on February 14, 2019 from https://www.cdc.gov/injury/ PMC5891372/. wisqars/fatal.html. >24OSHA (2019). Join the National Safety Stand-Down To Prevent Falls in Con- >4Crosby, A., Cheltenham, M. & Sacks, J. (1999). Incidence of suicidal ideation and struction: May 6-10, 2019. Retrieved on February 14, 2019 from https://www. behavior in the United States, 1994. Suicide and Life Threatening Behavior, 29(2): osha.gov/StopFallsStandDown/. 131-140 >25Leipold, J. (2012). Suicide prevention stand down set for Sept. 27. The U.S. Army. >5DeAnrade, D. & DeLeo, D. (2007). Suicidal behavior by motor vehicle collision. Retrieved on January 2, 2019 from https://www.army.mil/article/87401/suicide_ Traffic Injury Prevention, 8(3): 244-247. prevention_stand_down_set_for_sept_27. >6Case, A. & Deaton, A. (2017). Mortality and morbidity in the 21st century. Re- >26Jones, M. (2016). Union Pacific leads on suicide prevention.Insurance Thought trieved on November 20, 2017 from https://www.brookings.edu/wp-content/ Leadership. Retrieved on January 2, 2019 from http://insurancethoughtleader- uploads/2017/03/6_casedeaton.pdf. ship.com/union-pacific-leads-way-for-suicide-prevention/. 27 >7Suicide Prevention Resource Center. (2016). Preventing suicide among men in > Milner, A. & Law, P. (2017). Summary Report: Mental Health in the Construction the middle years: Recommendations for suicide prevention programs. Waltham, Industry. Retrieved on February 11, 2019 from http://micaus.bpndw46jvgfyc- MA: Education Development Center, Inc. mdxu.maxcdn-edge.com/wp-content/uploads/2015/11/MIC-QLD-construction-industry-roundtable-report.pdf. >8Han, J., Batterham, P. J., Calear, A. L., & Randall, R. (2017). Factors Influencing Pro- fessional Help-Seeking for Suicidality: A Systematic Review. Crisis. http://dx.doi. org/10.1027/0227- 5910/a000485. >9Affleck, W., Carmichael, V. & Whitley, R. (2018). Men’s mental health: Social determinants and implications for services. Canadian Journal of Psychiatry, 63(9):581-589. >10Milner, A. & King, T. (2018). Men’s work, women’s work and suicide: a retro- spective mortality study in Australia. Australian and New Zealand Journal of Public Health, 10.1111/1753-6405.12859. Sally Spencer-Thomas, Psy.D., is a clinical psychologist, inspirational >11Kock, M. (2016). Sleeping while awake. Scientific American. Retrieved on De- cember 27, 2017 from https://www.scientificamerican.com/article/sleeping- international speaker, and an impact entrepreneur. She was an while-awake/. invited speaker on men’s mental health at the White House in 2016, >12Centers for Disease Control and Prevention (n.d.). Depression. Retrieved on discussed mental health promotion and suicide prevention in a recent February 14, 2019 from https://www.cdc.gov/workplacehealthpromotion/ health-strategies/depression/index.html. Tedx Talk, and has also held leadership positions in the International >13American Psychiatric Association Foundation (n.d.). Quantifying the cost of de- Association for Suicide Prevention, the American Association for pression. Retrieved on December 27, 2017 from http://workplacementalhealth. Suicidology, and the National Suicide Prevention Lifeline. Find her on org/Mental-Health-Topics/Depression/Quantifying-the-Cost-of-Depression. Facebook (@DrSallySpeaks), Twitter (@sspencerthomas), and LinkedIn >14Joiner, T. (2006). Why People Die by Suicide. Cambridge: Harvard University Press. (https://www.linkedin.com/in/sally-spencer-thomas-8539424/), or visit >15NIOSH (2016). Fundamentals of total worker health approach- www.SallySpencerThomas.com. es: essential elements for advancing worker safety, health, and Reprint: SD_0319-2

SafetyDecisionsMagazine.com Safety Decisions | Spring/Summer 2019 21 Strategy

Current Strategies The safety profession has employed numerous strategies to gain management support for safety efforts. Though intuitive to those in the safety profession, efforts to protect human life in organizations’ operational processes can actually be met with resistance. This resistance is not necessarily intentional but can be the result of a lack of integrating occupational safety into the career trajectory of industry leaders. To overcome resistance, the safety profession has re- sorted to various methods to gain management support for workplace safety efforts. Some of these methods include the following.

Learning Their Language A brief Internet search of the term “leadership” reveals thou- sands of books and models on the topic. The challenge for the safety professional is determining how to integrate occupational safety best management practices into any given management style or philosophy in a facility or organization. To accomplish integration, safety professionals must learn how to speak the language of existing management. For example, worker engagement has long been a component of a successful occupational safety and health management system and is represented in the newly published Management global standard, ISO 45001. In the event that servant leadership is the leadership style of a given industry leader, a Support for safety professional can effectively reach him or her with the concept of worker engagement, as servant leadership focuses on those who do the work as having the true answers Safety: Disrupting to the organization’s challenges. the Paradigm Marketing the Benefit of Safety Professionals “In order for safety to be effective in any Safety professionals are often forced to market themselves organization, you must gain management’s as valuable to the organization. Safety might simply be perceived by industry leaders as a regulatory requirement rather support.” That has been the mantra of the than an important part of organizational operations. Safety safety profession for decades. professionals might find themselves having to market their value to an organization through services that help meet or- By Scotty Dunlap, EdD, CSP ganizational goals.

t is a challenge that has been accepted by safety pro- Marketing the Value of Safety fessionals in both recent and long-past generations. Safety’s true value to an organization might be difficult to We have accepted it as part of the unchangeable sta- demonstrate on the surface due to safety investments pos- tus quo, and it is a challenge that has been met with sibly being perceived as a cost of doing business. Safety mixed success in individual careers and across the professionals must establish the business case for safety. safety profession as a whole. We have filled safety ac- This has traditionally been achieved through processes ademic programs of study and professional develop- such as presenting the sheer volume of direct-cost loss ment seminar rosters with tricks of the trade on how to through medical bills and property damage loss. Iaccomplish this daunting task. The business case for safety is further bolstered through But imagine a world where this challenge, which is piv- indirect-cost loss. Indirect loss includes such items as poor otal to the success of injury reduction efforts, is a fraction production quality as a result of placing a less-experienced

of what the safety profession currently experiences. worker in place of a highly experienced worker who might TUIPHOTOENGINEER/GETTY.COM

22 Safety Decisions | Spring/Summer 2019 SafetyDecisionsMagazine.com be away from work due to an injury. departmental meetings, shift who hold positions that range from Lower product quality could result in meetings, and plant meetings. plant manager to vice president of loss of customers, which, in turn, re- Safety’s being a component of operations. Fundamentally, these in- sults in decreased organizational sales. these meetings can communicate dustry leaders graduated from high Indirect costs have been shown to be a that it is an important part of school, something occurred, and then factor of as much as three times the di- organizational operations. they obtained their position of lead- rect cost, though the exact multiplying • Including safety metrics in ership over a safety professional. The factor will vary based on the unique operational discussions. From a challenge is to investigate the “some- industry and associated hazards. strategic perspective, safety thing occurred” phase of the leaders’ professionals can include both professional development. Engaging Management leading and lagging measures of The Master of Business Adminis- Safety professionals might often find organizational safety performance tration (MBA) curriculum is a gold themselves having to educate industry in meetings where other similar standard for educating industry lead- leaders on the importance of occupa- discussions are had—to include ers and could be part of the “some- tional safety in organizational opera- profit and loss discussions and thing occurred” that resulted in an tions, which might not be the case of quarterly business reviews. Safety individual’s being in a position above their peers in such disciplines as op- metrics can be presented in a way a safety professional. This makes the erations, human resources, and main- that indicates how safety can be MBA curriculum a key issue that tenance. Industry leaders can be en- used to support the accomplishment could impact how industry leaders gaged in safety activities that include: of organizational goals. and safety professionals reach a high • Incident investigations. Depart- level of partnership in accomplishing ment and shift operations managers Though the list presented here organizational goals. can be included in injury and might not be comprehensive, it touch- A study of the MBA curriculum in- property damage investigations. es on a spectrum of tools safety pro- cluded an analysis of the leading MBA This experience can help managers fessionals have utilized to integrate program in the United States, as well understand what has occurred, safety into organizational operations as participant interviews at a regional why the incident occurred, the and leadership strategies. These tools comprehensive university’s college of factors that influenced the inci- have all been utilized to gain manage- business, where participants were lim- dent, and what can be done to pre- ment support for safety—a task that ited to those who were near the com- vent recurrence. Incident investi- has been ingrained in our profession pletion of their program of study and gations are an outstanding avenue for decades. had experience in industrial leader- that provides industry leaders However, imagine an environment ship. These findings should be of great with a detailed understanding of where such effort is not needed as concern for the safety professional: specific safety issues. much as it is now; an environment • The MBA curriculum offered little, • Facility inspections and audits. where industry leaders can converse if any, clear educational experi- Industry leaders can be asked to with safety professionals on critical ence for industry leaders to help accompany safety professionals issues with the same ease with which them understand the value of on facility inspections or audits. they converse with peers in disciplines occupational safety in protecting Whereas engagement in incident that include human resources, opera- workers and the impact of occu- investigations is a reactive activity, tions, finance/accounting, and main- pational safety on organizational engaging industry leaders in facility tenance; a world where “gaining man- performance. This was evidenced inspections or audits is a proactive agement support” is not as necessary through examining coursework in activity. Safety professionals can use as it is in the current environment; or the MBA program, which exam- facility inspections and audits as a world where management support ined both core courses and elective opportunities to educate industry for safety comes naturally. courses, as well as through leaders on hazard identification interviewing the MBA students. and elimination, as well as general The ‘Something The closest connection to oc- safety management system issues. Occurred’ Gap in cupational safety in the MBA • Safety as a meeting agenda item. Leadership Development curriculum was revealed through Safety professionals can provide To create such a world, a basic ex- participants’ references to safety key topics, and even narrative, amination must occur to determine possibly being included in a course that can be included in primary where the challenges of the safety addressing human resources. organizational meetings. These profession exist. Many safety pro- • Research was also conducted by meetings can include preshift fessionals report to industry leaders exploring potential occupational

SafetyDecisionsMagazine.com Safety Decisions | Spring/Summer 2019 23 STRATEGY

safety content in professional trajectories of industry leaders can be and that dialogue can be expanded development courses for industry accomplished through a number of to include worker safety and leaders offered through the Amer- avenues: quality of life within quality ican Management Association. It • Higher education curriculum. management systems. was found that exposure to safety Applicable courses in business, content was limited. engineering, or other degree Though occupational safety has • Interviews with industry leaders programs can be used to integrate been a mainstream issue since the who were near completion of an occupational safety where appropri- Williams-Stiger Occupational Safety MBA program revealed that per- ate. The protection of workers can and Health Act of 1970, a great deal sonal experience was the primary be presented as an ethical, legal, and of opportunity for improvement exists driver for engagement in occu- operational responsibility of indus- through strategically integrating oc- pational safety. For example, one try leaders. Details can be provided cupational safety into the career tra- participant had a family member to give industry leaders an under- jectories of industry leaders. Current- who had been injured at work, standing of personal responsibility ly, industry leaders might have limited which highlighted the need to for worker safety and what they can exposure to occupational safety as a focus on safety in the workplace. do to impact safety as a component component of organizational opera- Though this focus could be con- of organizational culture. tions, which exacerbates the problem sidered positive, it is without con- • Professional development. Trade of the unnecessary workplace injuries text and could actually result in organizations and mainstream and fatalities that occur each year. nonproductive effort in addressing leadership development training workplace safety issues. agendas can be used to introduce Exposing industry leaders to the industry leaders to concepts of oc- value of occupational safety in their To date, the fundamental problem cupational safety and how related career development through target- is that education on workplace safety efforts can be used to accomplish ed educational opportunities should among industry leaders lacks cohe- organizational goals. Tactical position safety professionals on a sion and design. Industry leaders do initiatives can be introduced that similar level to peers’ disciplines, not necessarily need to become sub- focus on industry-specific efforts such as human resources, operations, ject matter experts in occupational that can be made to address and maintenance, where issues can safety, but they do need to understand workplace safety. be effectively discussed and worker the benefits occupational safety brings • Leadership books. Applied protection strategies identified and to an organization, such as meeting leadership texts can be written and implemented. operational goals and protecting our utilized to help industry leaders most valuable asset: our workers. In- understand the importance of tegrating safety into the educational occupational safety in organiza- curriculum would make it equal to tional performance. In the realm other operational disciplines, such of adult education, organizations as human resources, operations, and provide mainstream leadership maintenance. books to leadership teams to read and discuss ideas that can enhance Scotty Dunlap, EdD, CSP, is a professor in Disrupting the Paradigm organizational performance. the Eastern Kentucky University School of The status quo must be disrupted. In Leadership books focused on Safety, Security, and Emergency Manage- the previous example, industry lead- occupational safety can be used to ment. He entered academia after a 15-year ers graduate from high school, some- open the dialogue among leaders career in industry working in occupational thing happens, and then they arrive to identify opportunities for safety safety leadership for organizations that in a position to which occupational improvement that can impact not include the state of Maryland, AutoZone, safety professionals report. In the only worker safety but also organi- Cargill, Archer Daniels Midland, and Nike. “something happens” phase, safety zational performance. Scotty served as a member of the U.S. management education must occur so • Targeted journal articles. Similar Technical Advisory Group (TAG) for the they are equipped with the fundamen- to leadership books, articles can establishment of the recently published tal information that will allow them to be written for publications read by global ISO 45001 standard on occupational understand why occupational safety industry leaders that will intro- safety and health management systems. must be integrated into organizational duce them to concepts of work- You can reach him via e-mail at scotty. operations. Strategically integrating place safety. Deming introduced [email protected]. occupational safety into the career principles of quality management, Reprint: SD_0319-3

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900015537 0319 ©2019 National Safety Council displace oxygen. When confined spaces are designed to store chemicals or are part of a working chemical process, the remaining material after the confined spaces are emptied will pose atmospheric hazards.

3. What’s the best way to check for gases before entering a confined space? Current laws require confined spaces to be free of all hazardous conditions before someone enters. This includes toxic and flammable gases and requires the oxygen to be at a safe volume. There are multiple methods to adhere to when evaluating confined space environments. Ambient air must be evaluated prior to entering the space (pre-entry checks), during entry (continuous), and when an entrant exits the confined space and re-enters. Gases stratify based on their weight, and depending on the gas compound, there can be a stratification effect of gases sinking or rising in a confined space. Workers should use a gas detector with a pump to evaluate the quality of the air in the space, so the entrant can understand the atmospheric conditions before entering. Preventing Would-Be When using an instrument with a pump, the user must wait for the gas to reach the sensor to have an accurate reading. Sample time will vary Rescuer Tragedies per instrument and accessories being used, so proper training on the equip- According to the Canadian Centre for Occupational Health and Safety, an estimated 60% ment is essential to gathering correct of confined space entry fatalities have been among the would-be rescuers. A would-be rescuer is a atmospheric gas readings. person who is trying to help someone who has become unresponsive in a confined space. We sat down with gas detection training specialist Mike Platek to understand atmospheric hazards in confined 4. If you check the spaces and how to prepare for potentially dangerous entries or rescues. atmosphere before entering the space, why 1. Can you describe an example of a would-be rescuer scenario? do you need a gas monitor Two workers prepare to enter a confined space. They open the manhole, set up barricades to prevent during the entry? accidental entry, and gather the necessary tools to perform the assigned tasks of the entry. The first The condition of the confined space employee enters the space. While descending the ladder, he is overcome with a lack of oxygen due to atmosphere can change due to the activ- an unknown gas leak. His partner outside of the space hears his gasp for air and sees him fall off the ities performed during the entry. Welding ladder. In a panic, he calls to a passer-by to call 911 for the fire department. He then descends the is a perfect example. Depending on the ladder himself to rescue his friend. Unfortunately, he too is overcome with the lack of oxygen and falls type of welding being performed, haz- to the bottom of the manhole. The fire department arrives, sees the two men at the bottom of the ladder, ardous gases can emit from the arc or and attempt to rescue them. They too become victims of the same oxygen deficiencies. These tragic oxygen-depleting gases can collect inside deaths could have been prevented had the workers checked the atmosphere before entry. the space. During conventional stick welding, carbon monoxide and nitrogen 2. What are some reasons why a confined space would have hazardous dioxide gases are released. When con- atmospheric conditions? ducting metal inert gas (MIG) welding, There are both natural and man-made causes of hazardous atmospheric conditions in confined carbon dioxide and argon are typically spaces. For example, rotting vegetation and the decomposition of organic materials will give off toxic used. Both gases are heavier than air and and flammable gases. Not only are these gases dangerous, but in larger concentrations, they can will force the oxygen out of the space.

26 Safety Decisions | Spring/Summer 2019 Sponsored Material | SafetyDecisionsMagazine.com 5. What are some of the common mistakes you see people make when gas detectors, the attendant will know performing a confined space entry? immediately if an entrant is exposed to I can sum it up in one word, complacency. Too many times I have heard, “I’ve been doing this for twenty a hazardous atmospheric condition. In years and nothing has happened.” Well, it only takes that one time. In a previous question, you asked addition to gas alarms, the instruments about would-be rescuers. The story I told was true, and the men who entered that space had performed now have man-down and panic alerts that same job at that same location for years. And that one time, it ended in tragedy. that are transmitted to other instruments in a wireless network. So not only does 6. How can training help you better prepare for confined space safety? the attendant get notified, but fellow Training workers on confined space entry will open their eyes to the dangers of confined spaces and explain workers in your area can respond and how incidents can occur. Educating them on how different gases act, where they come from, and how render aid if it’s safe and necessary. they affect the body is critical to safe operations in a space. Workers also need to be comfortable using the equipment that is made to save their lives. Conducting hands-on training with gas detectors will greatly 9. If you had to give one increase workers’ skills in operation and application. Through training, workers will understand that using gas piece of training guidance detectors is not difficult. Demonstrating how the instruments react to changing atmospheric conditions will to someone working with help them become more comfortable with the gas detectors, which will ultimately keep them safe. gas detectors in confined spaces for the first time, 7. What if a company is on a tight budget? What are some alternative what would it be? training resources? Wear your gas detector! There are gases you cannot see or smell, and they can kill Life-saving training is worth the investment, but if you are truly limited by budget, there are helpful resources you. Carbon monoxide is odorless and available. Online classes usually cost less than live training, and in some cases may be free of charge. Online colorless and is known as the silent killer. training is also less of a time commitment than face-to-face training. It may only be a few hours long versus In its natural form, methane is also odor- traveling for a multi-day class. Online training is less and colorless, and a concentration a great option for those who are already familiar between 5-15% by volume will explode with the course content and just need a refresher if an ignition source is present. As a First or recertification. Some people also prefer online Responder and Hazmat Technician, I will training because they can take the course in a “Online training classes not approach a hazardous area without quiet place without the distractions encountered my gas detector. n in a classroom. Like a face-to-face course, online also have flexible courses can be customized to focus on the areas that an organization needs the most help with. scheduling and are Mike Platek serves as Senior Gas Detection Spe- Online training classes also have flexible sched- cialist at Industrial Scientific Corporation. He started uling and are ideal for companies that have sites ideal for companies with Industrial Scientific in 1985 and has worked in across multiple regions. many departments including engineering, sales, In an online gas detection course, a live that have sites across and training. As a Training Specialist, he hosts Gas instructor delivers the course material and uses multiple regions.” Detection Made Easy classes both in-house and a camera to show attendees what he is doing regionally throughout North America, as well as at with the gas detectors. The camera allows the customer locations. instructor to show attendees how to properly Mike is also certified nationally for Firefighter calibrate, operate, or repair an instrument in I, and in the State of Pennsylvania, as an EMT. real-time. Instructors can also introduce soft- He holds certification in Hazardous Materials and ware to the students and walk them through how to use it within their organizations. Although online Confined Space Supervision and participates in courses are not as interactive as in person, they do offer the option to submit questions and feedback classes for training and safety. He is a volunteer through the dialogue box. Attendees who have a computer or phone with an internet connection can firefighter and serves on his county’s hazardous participate from home or work and still receive a certificate of completion for passing the class exam. materials team. Another beneficial option that many companies offer is online video training. Online videos are available for viewing 24 hours a day, seven days a week, and are broken up into short clips no more than two https://www.ccohs.ca/ minutes long. If a worker is trying to find a specific topic, it is easy to locate it without having to watch oshanswers/hsprograms/ a long training video or participate in a one- or two-day class. Although pre-recorded videos don’t offer confinedspace_intro.html the same interaction that face-to-face or live online courses do, they give students the flexibility to watch whenever and as often as needed. For companies that have small training budgets, taking advantage of online video training is a great way to supplement worker education.

8.How can wireless gas detection technology improve safety in confined space entries? The question many confined space entrants have asked is, “How do I know the attendant knows I’m OK?” With new, wireless SPONSORED BY:

Sponsored Material | SafetyDecisionsMagazine.com Safety Decisions | Spring/Summer 2019 27 STRATEGY All the HazCom Updates You Can Expect This Year Revisions are coming. Here’s what you can expect to see—but don’t jump the gun on aligning your hazard communication programs just yet. By Guy Burdick

formed the basis for OSHA’s March 2012 revisions to the Hazard Commu- nication Standard (HCS). Although the agency incorporated elements of the GHS in a March 2012 rulemaking, those revisions brought the HCS in line with the third edition of the GHS. However, the GHS is a “living document” that is revised about every 2 years, and the UN just completed the seventh edition. With each revision, the UN has updated what can be included in precautionary statements for various hazards and how such statements should be worded. OSHA said in the autumn 2018 agenda of regulatory and deregulatory actions that it planned to issue a notice of proposed rulemaking in March 2019 to update the HCS to incorporate elements of the latest edition. Changes Since Third Edition The fourth edition of the GHS included new hazard categories for chemically unstable gases and nonflammable aerosols, as well as further adjustments to the precau- he Occupational Safety additional compliance requirements tionary statements and some clarifi- and Health Administra- once the revisions take effect. cations of criteria for precautionary tion (OSHA) is expected The GHS is meant to facilitate in- statements to avoid differences in to revise its hazard com- ternational trade with a uniform set of their interpretation. munication (HazCom) chemical labels and standard practices The fifth edition included: standard this year to bring for creating safety data sheets (SDSs) • A new test method for oxidizing it in line with the cur- for chemicals in commerce. The GHS solids; rent Globally Harmonized System was agreed upon by the United Na- • Miscellaneous provisions intended T(GHS) of Classification and Labelling tions (UN) with the goal of adoption to further clarify the criteria for of Chemicals and formalize various of the system in as many countries some hazard classes (skin enforcement policies that have been as possible by 2008. OSHA and oth- corrosion/irritation, severe eye issued since the last major update er federal agencies have long partici- damage/irritation, and aerosols); to HazCom in 2012. Employers that pated in GHS negotiations. Negotia- • Revised and simplified classifica- manufacture, import, distribute, or tors have agreed to many changes to tion and labeling summary tables; use hazardous chemicals may face the GHS since the third edition that and TUNART/GETTY.COM

28 Safety Decisions | Spring/Summer 2019 SafetyDecisionsMagazine.com • A new codification system for hazard pictograms. “EMPLOYERS THAT MANUFACTURE,

The sixth edition included: IMPORT, DISTRIBUTE, OR USE HAZARDOUS • A new hazard class for CHEMICALS MAY FACE ADDITIONAL desensitized explosives; • A new hazard category for COMPLIANCE REQUIREMENTS ONCE pyrophoric gases; • Miscellaneous provisions intend- THE REVISIONS TAKE EFFECT.” ed to clarify the criteria for some hazard classes (explosives, specific target organ toxicity following minimum, affected employers would backfire. Not only has OSHA not yet single exposure, aspiration hazard, need to train their employees on any indicated which elements of the Sev- and hazardous to the aquatic changes to labels and SDSs and pro- enth Edition it intends to adopt, but environment); vide information regarding any new according to OSHA’s 2015 Inspection • Additional information to be hazard classifications that apply to Procedures for the Hazard Communi- included in the safety data sheets; chemicals in use at the workplace. cation Standard, where a later version and of the GHS conflicts with the current • New examples addressing labeling Formalizing Guidance HazCom standard, employers may of small packages. According to the entry in the Fall 2018 be cited with violations if their use regulatory agenda, the other goal of of a more recent version of the GHS The seventh edition includes: OSHA’s HazCom revisions is to “cod- contradicts or casts doubt on • Revised criteria for categorization ify a number of enforcement policies OSHA-required information. For the of flammable gases within that have been issued since the 2012 time being, HazCom 2012 remains Category 1; standard.” the standard by which OSHA will • Miscellaneous amendments in- Exactly what that might entail is assess employer compliance. tended to clarify the definitions not yet public. However, since the Therefore, the best course of ac- of some health hazard classes; implementation of the 2012 standard, tion for employers aiming to prepare • Additional guidance to extend the OSHA has issued a number of direc- for HazCom revisions is simply to coverage of section 14 of the Safety tives, letters of interpretation, and focus on compliance with the current Data Sheets to all bulk cargoes memos intended to clarify points of standard, which remains the most fre- transported under instruments of confusion for stakeholders. Many of quently cited standard in general in- the International Maritime these would likely form the basis for dustry and the second most frequent- Organisation (IMO), regardless any revisions to the standard. ly cited standard across all industries. of their physical state; Issues addressed in LOIs and other Common violations under the • Revised and further rationalized guidance since the implementation of current HazCom standard include: precautionary statements in the 2012 standard include: • Failure to develop and implement Annex 3; and • Labeling of small packages a written hazard communication • New example in Annex 7 address- • The use of concentration ranges program that meets the require- ing labeling of small packages with on SDSs ments of the standard fold-out labels. • The use of non-GHS hazard • Failure to provide adequate symbols on labels and SDSs employee training GHS does not require participat- • Information on Hazards Not • Failure to maintain copies of SDSs ing agencies to adopt the system “as Otherwise Classified (HNOC) for each hazardous chemical and is,” and OSHA has not yet indicated on labels and SDSs ensure they are readily available which elements of the updated GHS it • Classification of flammable and to employees intends to adopt. However, any chang- nonflammable aerosols • Failure to train employees on es to hazard classifications, SDS re- • Combustible dust hazards labels and SDSs quirements, and labeling practices are • Failure to properly label chemicals likely to impact companies that man- Takeaways for Employers in the workplace ufacture, import, or distribute hazard- Some employers may be tempted to ous chemicals, as well as all employers preemptively align their HazCom Guy Burdick is a contributing editor of whose employees could be exposed to programs with the Seventh Edition of Safety Decisions. hazardous chemicals on the job. At a the GHS; however, this approach can Reprint: SD_0319-4

SafetyDecisionsMagazine.com Safety Decisions | Spring/Summer 2019 29 STRATEGY

SHA announced plans Lockout/Tagout: Are in the Department of Labor’s (DOL) most recent agenda of regulato- There Changes on the ry and deregulatory actions to issue a prerule Horizon? request for information The Occupational Safety and Health Administration (OSHA) O(RFI) on alternatives to its existing lockout/tagout standard. may be planning to explore alternative methods of ensuring There are computer-based controls workers are protected from sources of hazardous energy now available that may be effective in protecting workers but that don’t (chemical, electrical, hydraulic, mechanical, pneumatic, meet the requirements of the existing thermal, and others). OSHA lockout/tagout standard. The agency plans to publish an RFI on the By Guy Burdick strengths and limitations of this new technology and any potential hazards. Equipment manufacturers have increasingly incorporated computer- based controls into their designs. There also are industry consensus and international standards that recognize and accept the adoption of such technology for safeguarding workers. Yet, the OSHA standard has not kept pace with technological advancements. ‘Old School’ Lockout/ Tagout The traditional control measures to prevent the unexpected start-up of machinery being serviced have been physical locks and tags (lockout/ tagout) that can only be removed by “authorized employees” who have re- ceived special training. The lockout/tagout standard (29 CFR 1910.147) was the fifth most frequently cited OSHA standard in fiscal year (FY) 2018. It usually is among the top ten most cited standards and typically in the top five. OSHA’s lockout/tagout standard was issued in 1989 and is based primarily on an existing industry standard. The American National Standards Institute (ANSI)/Amer- ican Society of Safety Engineers (ASSE) Z244.1 Lockout Standard was published in 1982. The ANSI/ASSE standard has been updated every 5 years since to reflect technological

advances in controlling machinery HAILSHADOW/GETTY.COM

30 Safety Decisions | Spring/Summer 2019 SafetyDecisionsMagazine.com and hazardous energy, while OSHA’s The agency, so far, has not revised suffered 20 years earlier during the lockout/tagout standard has mostly the lockout/tagout standard to reflect Clinton administration. remained static since 1989. updates to ANSI Z244.1 or incorporated the revised consensus stan- Late Obama Existing Standard Becom- dard by reference. OSHA previously Administration Move ing an Issue has claimed that parts of the revised On October 4, 2016, OSHA proposed While the technology for protecting industry standard do not provide removing a single word—unexpected— workers from machinery shutdown protections to workers as effective as from the lockout/tagout standard. for service or hazardous energy has those in the federal standard. The existing standard starts off by advanced, OSHA’s standard has not If OSHA were to revisit this posi- defining its scope: kept up with these changes. In its latest tion through revisions to the lockout/ “This standard covers the servic- regulatory agenda notice, the agency tagout standard, it could give employers ing and maintenance of machines acknowledged that it has recently seen a greater variety of options for and equipment in which the unex- an increase in requests for variances protecting their workers. pected energization or start up of the from the lockout/tagout standard for these alternative controls. While OSHA has not updated the lockout/tagout standard to include ap- proval for computer-based safety de- “THE EXISTING STANDARD CREATES vices, regulators in other nations have. The existing standard creates prob- PROBLEMS FOR MANUFACTURERS THAT lems for manufacturers that want to incorporate sensors in equipment WANT TO INCORPORATE SENSORS and machinery for sale in the United IN EQUIPMENT AND MACHINERY FOR States, as well as, elsewhere. The standard also limits the choices available SALE IN THE UNITED STATES, to U.S. employers that wish to take advantage of the latest technology. AS WELL AS, ELSEWHERE.” No, No, No The regulated community has looked to OSHA both for guidance and ‘Unexpected’ Change machines or equipment, or release of flexibility. For instance, on November On the other hand, some lawyers and stored energy, could harm employees” 11, 2011, a safety consultant wrote the consultants interpret OSHA’s plans for (29 CFR 1910.147(a)(1)(i)). agency asking whether light-emitting the lockout/tagout standard different- The agency proposed removing diode (LED) sensors confirming equip- ly. Blog posts on their websites include the word “unexpected” from subpara- ment de-energization would satisfy the headlines like: graph (a)(1)(i) and elsewhere in the lockout/tagout standard. In its response, • “Deleting a single word in OSHA standard as part of its Standards Im- the agency told the safety consultant that standard could upend lockout/ provement Project (SIP). LED sensors could not be used to satisfy tagout;” The agency wanted to remove “un- a number of requirements such as: • “What the new lockout/tagout expected” from the standard because • Verifying that the isolation and revision could mean for you;” it felt the language had been misinter- de-energization of a machine or and preted in a number of legal decisions. piece of equipment have been • “Why Did OSHA Propose to accomplished; Remove the Principle of ‘Un- GMC Delco • The requirement for a “qualified expected Energization’ from its In the most famous case, involving person” to test equipment and Lockout/Tagout Standard?” General Motors Corporation (GMC) verify de-energization; and and its Delco Chassis Division, the • An alternative method of verifying What is this supposedly monu- Occupational Safety and Health Review de-energization. mental lockout/tagout rulemaking? Commission (OSHRC) ruled against It was a push by the previous admin- OSHA’s citing of GMC Delco for viola- To each of the consultant’s requests istration to deal with what it thought tions of the lockout/tagout standard. for flexibility, the agency answered “no” was a misinterpretation of the original In this incident, workers were ser- in its standard interpretation letter. standard. It sought to reverse a defeat vicing machines that required following

SafetyDecisionsMagazine.com Safety Decisions | Spring/Summer 2019 31 STRATEGY

an 8-to-12-step start-up procedure. and Health Act did not support such Code of Federal Regulations, eluding Start-up of the machinery was signaled a change. the watchful eye of the White House by audible and visual warnings. The SIP Phase IV rulemaking was Office of Information and Regulatory The review commission ruled that, listed on the Labor Department’s latest Affairs. because the machinery was equipped list of planned regulatory and deregula- However, OSHA has not taken with warning signals before starting tory actions in the final rule phase. How- the step back from enforcement that up, that start-up could not be consid- ever, it is unknown whether the lockout/ many expected under the current ered “unexpected.” tagout revisions are still included. administration. Without a perma- The Clinton administration appealed Although the SIP Phase IV agen- nent Trump-appointed OSHA head the OSHRC’s decision, and Labor da notice still contains references to in place, the administration has not shifted agency priorities in the same way it has elsewhere. “WHAT IS LESS CONTROVERSIAL, THOUGH A Modern-Day Lockout/ Tagout Standard STILL LIKELY TO BE SEVERAL YEARS AWAY, What is less controversial, though still likely to be several years away, is IS A LOCKOUT/TAGOUT STANDARD THAT a lockout/tagout standard that recog- RECOGNIZES THE TECHNOLOGICAL nizes the technological advances of the past 30 years. ADVANCES OF THE PAST 30 YEARS.” There has been rapid advancement in sensor technology. For example, Amazon is reportedly testing sensor Secretary Robert Reich lost his case in changes to General Industry stan- vests to prevent robots from striking the U.S. 6th Circuit Court of Appeals. dards (29 CFR 1910), which could in- or colliding with human workers. The appeals judges sided with the clude the lockout/tagout standard, the Lockout/tagout and other standards OSHRC, dismissing Reich’s challenge. notice states that most of the revisions need to accommodate such advances impact construction regulations. in safety technology. Obama DOL Move The rulemaking is described as In the meantime, employers should In the waning days of the Obama addressing: ensure their current lockout/tagout administration, the DOL tucked the • Removing unnecessary provisions; procedures and programs are fully proposed change to the lockout/ reducing burdens of paperwork; compliant with the existing standard. tagout standard into a SIP rulemak- • Removing requirements that em- Employers should: ing. It would be part of the fourth SIP ployers include an employee’s so- • Develop and implement a written rulemaking. cial security number on exposure program for controlling hazardous The SIP rulemakings usually are monitoring, medical surveillance, energy, including lockout/tagout reserved for easing the regulatory bur- and other records; and procedures, employee training, dens on employers. These rulemak- • Reducing the number of necessary and inspections; ings most often incorporate industry employee X-rays and elimination • Provide training on methods of consensus standards by reference of posting requirements for resi- energy isolation and control to or adjust existing standards to more dential construction employers. production workers, as well as to closely conform to industry consen- maintenance workers; sus or international standards. Status of the ‘Unexpected’ • Ensure that workers receive train- The proposed lockout/tagout change Rulemaking ing in their primary language; was unlike any other SIP proposal and Is the rulemaking to remove “unex- • Clearly label isolation devices, was met almost immediately with ob- pected” from the wording of the lock- such as breaker panels and control jections from employers and employers’ out/tagout standard still planned for valves; and representatives. 2019? It’s possible, though not certain. • Provide workers with a sufficient The U.S. Chamber of Commerce It would be surprising if a Trump number of lockouts, tagouts, and filed a comment, objecting that re- administration Department of La- any other necessary hardware. moving the word “unexpected” would bor chose to burden employers with change employers’ duties under the onerous new lockout/tagout require- Guy Burdick is a contributing editor of standard. It also said the legislative ments. It also is unlikely regulators Safety Decisions. history of the Occupational Safety could sneak such a change into the Reprint: SD_0319-5

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In the safety profession, there are a few major causes of burnout. Un- Taking Care of the fortunately, most of them are baked into the job description. Management Safety Professional conflicts, a high degree of repetition, a lack of downtime, general stress—any By Ray Prest of these sound familiar? If you’re an EHS manager, I bet you’re well versed f you work in safety, then you around the corner. With a never-ending in at least a couple of them. know what it means to work. to-do list and a lack of recognition for Does this mean burnout is un- Sixty-hour weeks. Countless the sizable load that they carry, there’s a avoidable for safety folks? If you’re responsibilities. First, you’re high risk of exhaustion setting in. looking for a silver bullet to slay rolling up your sleeves on the Safety folks act as caretakers of the chronic exhaustion, then you’re prob- worksite, and then, you’re wad- workforce. But when burnout looms ably out of luck. But while burnout ing through spreadsheets in your and they need to be taken care of, who can’t be banished from safety careers, office. When a serious incident -oc will look after them? it can be mitigated—and the solution Icurs, it’s your phone that rings in the By and large, the answer is no one. starts with self-care. middle of the night. The nature of safety jobs means there’s Most environment, health, and safe- no one tapping you on the shoulder Self-Care for Safety ty (EHS) managers push themselves to suggest that you get some rest. And Professionals week after week because they know how because safety managers are so focused Self-care is a concept that most safety important their job is. They’ve experi- on their work, they find it easy to push professionals should be familiar with. enced what it’s like to save someone’s through the first hints of burnout. After all, EHS folks regularly preach life. Nobody needs to tell safety folks Unfortunately, a little bit of burn- personal awareness in order to stay how important their job is—they’re al- out leads to a lot more burnout. Your safe. And many are also responsible ready motivated by a desire to do what- productivity diminishes, you no lon- for health and wellness initiatives at ever they can to keep people safe. ger have insightful moments, and their site. So it’s hardly a stretch to But there’s a downside to being your spark is extinguished. At that suggest they apply these same princi-

so driven. Burnout is always lurking point, you’re helping no one. ples to themselves. WILDPIXEL/GETTY.COM

34 Safety Decisions | Spring/Summer 2019 SafetyDecisionsMagazine.com Before every commercial airline lives? The opportunity to stand in takes off, a flight attendant reminds “LEADERS CAN BETTER front of a room of people and teach passengers that in case of emergency, KEEP UP WITH THE them important safety skills? The abil- they should put on their own oxygen ity to provide hands-on coaching to mask before helping passengers who RIGORS OF THEIR JOBS help people perform their jobs more need assistance. The message is sim- safely and effectively? Identify your ple: You can’t help others until you IF THEY KEEP early sparks for EHS, and then dote help yourself first. on them in an effort to rekindle your People in the safety industry are THEMSELVES IN motivation. notoriously bad at taking care of RELATIVELY DECENT themselves. As a profession, we’ve got- What Are You Going ten quite good at keeping stress, burn- SHAPE.” to Do? out, and job fatigue in the shadows. The Occupational Safety and Health That’s why I want to shine a light on Administration (OSHA) is never go- the problem—and highlight the steps ing to create a self-care standard. So, you can take to stave off burnout and you need to create one for yourself. keep yourself mentally and physically training—but you’re more likely to Take some time to determine what healthy, day after day and year after engage trainees if you can muster the you can do to help yourself recover year. To that end, here are a few things energy for class after class. when you’ve had a few tough weeks— safety professionals should consider if or months—on the job. they’re feeling exhausted by their jobs. Job Renewal And then comes the tough part: Stress and long hours are inherent developing the habit of actually Time Off parts of the job. But wheel-spinning taking care of yourself. It doesn’t mat- Short breaks are one of the easiest and a high degree of repetition aren’t. ter what you do as long as it works ways to prevent workers from becom- If you find yourself stuck in a rut, it’s for you and, most importantly, you ing fatigued on the job (and increas- time to do something about it. actually do it. ing their risk of injury as a result). The first option is to initiate a Start small by deliberately inte- The same is true for you. If you find change in your job. This could mean grating self-care into your everyday yourself feeling chronically tired, give looking for a new gig—but it doesn’t routine. Plan a 15-minute break in yourself permission to take some time have to. You can also look for ways to the middle of your day, go for a short to recover. restructure your job description, or walk after work to clear your head, Not only is it important to take you can dedicate yourself to devel- or schedule time in your calendar to some time off from work, but it’s oping new skills to become a better think about exciting things you’d like also important to do other things. manager. to accomplish in the future. A change is as good as a rest, as the You work hard, and you deserve Whatever you choose to do, re- old saying goes, and you can recharge learning opportunities. Seizing these member that by taking care of yourself, your batteries by spending time on a opportunities will help you feel pro- you’re improving your ability to look nonsafety pursuit. active rather than reactive and make out for others—and that’s a form of you feel more like you’re taking back care we can all agree is worthwhile. Physical Care control of the safety agenda. You are what you eat—and you are Finally, you can also look for new how you exercise, too. I’m not going to ways to solve the everyday safety lecture you on eating better or getting headaches. Look into new concepts a gym membership but only because and programs that offer new avenues magazines like Forbes, Fortune, and of injury prevention—and that might Inc. have already been doing so for renew your enthusiasm for your job. years. They’ve all touted the job- Ray Prest is Marketing Manager at performance benefits of executives Motivation SafeStart, a family-owned company that taking care of themselves. And the One of the surest signs of burnout is has provided safety training solutions to same principles apply to safety folks. a loss of motivation. When this hap- industry, education, and the military for Leaders can better keep up with the pens, it’s time to reconnect with what over 40 years. You can learn more and read rigors of their jobs if they keep them- motivates you. Ray’s recent articles, blog posts, and safety selves in relatively decent shape. You Ask yourself what you first loved guides at safestart.com/ray. don’t need a six-pack to deliver safety about your job. Is it the ability to save Reprint: SD_0319-6

SafetyDecisionsMagazine.com Safety Decisions | Spring/Summer 2019 35 Practical Tips

nsuring compliance with federal or state occupational safety and health laws and regulations is only part of a workplace safety and health professional’s job. Often, safety managers also handle aspects of an Eemployer’s workers’ compensation program. The two aspects of the job have different demands. OSHA, a federal agency within the Department of Labor, develops workplace safety and health standards that apply nationwide. Despite the fact that approximately half of U.S. states operate under state plans for occupational safety and health, there is a high degree of overall uniformity in workplace safety compliance obligations from one state to the next. Meanwhile, workers’ compensation is administered at the state level. It shields employers from liabilities for workers’ injuries, illnesses, and deaths while covering the costs of workers’ medical treatments and lost wages or providing death benefits to the surviv- ing spouse and children of a worker killed on the job. Most states’ original workers’ compensation laws predate the federal Occupational Safety and Health (OSH) Act of 1970, and the provisions of these laws vary greatly from state to state. All states except Texas require employers to purchase workers’ compensation insurance coverage. Insurance coverage may be sold and provided by private insurers, or it may be offered through a state- run program. Some employers have The Two-Way Relationship the option of self-insuring or joining a group self-insurance pool. Some Between Workers’ Comp states have publicly funded insurance pools to cover claims at workplaces and Safety where an employer has neglected to buy insurance coverage. Do you fully understand how your workers’ compensation Employer Responsibilities programs and policies interact with your organization’s The OSH Act and state workers’ com- safety program? pensation laws create competing and complimentary responsibilities for em-

By Guy Burdick ployers. Some of these responsibilities HYBRID IMAGES/GETTY.COM

36 Safety Decisions | Spring/Summer 2019 SafetyDecisionsMagazine.com fall directly on safety managers, while others may be primarily managed by Human Resources or another division “SAFETY MANAGERS CAN HELP THEIR within an organization. Depending on the company, safety managers may be EMPLOYERS CONTAIN THE COSTS OF WORKERS’ tasked with: • Ensuring compliance with federal COMPENSATION CLAIMS AND PREMIUMS BY or state safety standards, as well SPOTTING AND CORRECTING WORKPLACE as the OSH Act’s General Duty Clause; HAZARDS BEFORE THEY CAUSE AN INJURY AND • Administering workers’ compensation claims; BY FOSTERING A STRONG CULTURE OF SAFETY • Monitoring workers on leave because of workplace injuries and THROUGHOUT THE ORGANIZATION.” illnesses; • Handling an injured worker’s return to work or arranging for duties or if the worker must be as- • Old injuries or injuries from and monitoring light-duty signed light or alternate duties. previous jobs. programs for workers not yet Light- and alternate-duty programs recovered enough to resume frequently require a safety manager’s Safety managers must tread care- their regular duties; and involvement, working in coordination fully. They have a duty to report sus- • Containing the employer’s costs with Human Resources and other per- picious claims to their employer and for workers’ compensation claims sonnel to meet an injured employee’s its insurance carrier. However, it is or premiums. work restrictions. the insurance provider’s responsi- Alternate or light duty may involve bility—not that of the safety manag- When a workplace injury or illness less strenuous parts of workers’ regu- er—to investigate suspicious claims. occurs, the first task is to ensure that lar jobs, or it may involve temporarily Confronting a worker about a suspi- the employee receives proper medi- filling a different job at the same com- cious workers’ compensation claim cal attention. If the injury or illness is pany. The best designed light-duty can foster an adversarial relationship compensable under workers’ compen- programs manage to offer meaning- and undermine employee morale, in sation rules, the employee may need ful work opportunities—rather than addition to creating potential liability assistance in filing a claim and navi- mere busywork—while still staying problems for the employer. gating the insurance system. within the limits of what a returning Remaining in contact with workers employee can do safely without jeop- Fraudulent or Uncertified out on leave because of an injury is ardizing his or her recovery. Providers essential. This communication serves Regardless of the return-to-work While fraudulent claims can and do the practical purposes of confirming assignment—regular, alternate, or happen, fraud and impropriety can that injured workers are receiving light duties—the safety manager happen on the provider end, too. proper treatment and monitoring should closely monitor the work to Not everyone who offers workers’ the progress of recovery, in addition ensure the worker doesn’t become compensation insurance coverage is to maintaining a dialogue with the reinjured. aboveboard. In December, Califor- injured employee and demonstrat- nia’s Insurance commissioner penal- ing the employer’s concern for his or Fraud Concerns ized American Labor Alliance and her recovery. Some employers and insurers worry CompOne USA $4,345,000 for selling Throughout the process, employ- about having to pay out fraudulent workers’ compensation and liability ers should be mindful of the end goal: workers’ compensation claims. Fraud policies to employers of farmworkers returning workers to their regular du- is rare, but it does happen. Fraudulent without being properly licensed by the ties. A worker’s absence can mean a claims may involve: state’s Department of Insurance. loss of critical knowledge, as well as a • Faked injuries or malingering to Any policies sold in California by loss of productivity. avoid work; American Labor Alliance and Com- Once an injured worker has recov- • Non-work-related injuries; pOne USA are invalid. On February ered, a physician or another medi- • Not returning to work once an 13, the state’s Labor commissioner cal professional will certify whether injury has healed while continuing reminded California employers that a worker is fit to return to normal to collect “lost” wages; or the commissioner’s office can cite the

SafetyDecisionsMagazine.com Safety Decisions | Spring/Summer 2019 37 PRACTICAL TIPS

fixing slip, trip, and fall hazards before they become slip, trip, and fall injuries. They can hold safety meetings or give toolbox or tailgate talks—educating “BEING AWARE OF AND ENGAGED IN WORKERS’ employees about hazards inherent to their jobs and instructing them in haz- COMPENSATION IS A NECESSARY AND CRITICAL ard controls or proper use of personal protective equipment (PPE). PART OF A SAFETY PROFESSIONAL’S JOB.” They can conduct regular safety audits to identify and correct problems on the job and make sure workers are following the workplace safety policies and procedures. Even the best employer $1,500 per employee not Controlling Premium Costs intended policies and procedures are covered by valid workers’ compensa- Workers’ compensation insurance worthless if employees aren’t follow- tion insurance. premiums can vary by state. Each ing them. state has its own formula for calculat- Workers’ compensation carriers Fraud’s Flip Side: ing premiums. An individual employ- can often assist in these efforts. Many Underreporting er’s premiums are also affected by the offer consultation services and oth- There is a flip side to employees’ fil- risks inherent in its industry and the er safety resources to help employers ing of false, fraudulent, or ineligible company’s claim history. take proactive steps to prevent injuries workers’ compensation claims: un- The key metric for employers is the and control costs. derreporting injuries. Workers may experience modification rate (EMR), be afraid of retaliation from their su- which is a numerical expression of an Simply Complicated pervisors or employers and may not employer’s claims history and safety Being aware of and engaged in work- report legitimate workplace injuries. record in comparison to other com- ers’ compensation is a necessary and If a worker suffers a legitimate panies in the same industry. An EMR critical part of a safety professional’s workplace injury—one that would of 1.0 indicates an average level of risk job—on top of the responsibilities of qualify for workers’ compensation— for the industry, while an EMR below complying with federal or state occu- but doesn’t report it, this can create 1.0 indicates a lower risk (i.e., better pational safety and health regulations. legal problems for the employer, in than average safety performance for In many ways, the workers’ compen- addition to undermining safety at the the industry), and an EMR above sation part of the job is simple: company and increasing the chances 1.0 indicates a higher risk (i.e., worse • Prevent accidents, injuries, and of an injury or illness worsening. safety performance or more claims exposures that lead to occupational Such an injury probably is record- than the industry average). Generally illnesses; able under OSHA’s injury and illness speaking, a higher EMR translates to • Ensure injured workers receive recordkeeping regulations. If an in- higher premium costs. prompt medical care; jury goes unreported, the employ- The best defense against high pre- • Monitor their progress while out er could be cited and penalized for miums and claims is the same as the on leave; and recordkeeping violations. best defense against being cited by • Coordinate their return to work. OSHA requires employers to OSHA: preventing accidents, illness- record a work-related injury if it es, and injuries. What complicates this part of the involves: job is money—the money involved in: • Death; How Can Safety • Ineligible or fraudulent claims; • Days away from work; Professionals Help? • Poorly administered treatment; • Restricted work or transfer to Safety managers can help their em- • Reinjury after workers return to another job; ployers contain the costs of workers’ work; and • Loss of consciousness; compensation claims and premiums • Higher insurance premiums as • Diagnosis of a significant injury or by spotting and correcting workplace a result of an excessive level of illness by a physician or licensed hazards before they cause an injury injuries and claims. healthcare provider; or and by fostering a strong culture of • Certain other specific outcomes, safety throughout the organization. Guy Burdick is a contributing editor of such as needlesticks, work-related Safety managers can make sure em- Safety Decisions. tuberculosis, and hearing loss. ployees stay on top of housekeeping— Reprint: SD_0319-7

38 Safety Decisions | Spring/Summer 2019 SafetyDecisionsMagazine.com TRAIN YOUR TEAM

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2. Worker impairment from marijua- Employers See the Effect na and opioid use; 3. Overdoses and deaths in the workplace; and of Rises in Marijuana 4. Health hazards faced by emergency responders and law en- and Opioid Use forcement officers encountering The use and misuse of both illicit and prescription drugs are synthetic opioids like fentanyl. affecting a growing number of employers. Marijuana Use Growing Marijuana was the most commonly By Guy Burdick detected substance in worker drug tests, according to Quest Diagnostics, a company that tests workers’ urine samples for employers and performs patient blood, urine, and other diag- nostic tests for healthcare providers. Quest reported that positive results for marijuana increased by more than 33% between 2015 and 2017. Some users fail to exercise caution surrounding their marijuana use. Over half of medical marijuana users reported driving while “a little high,” according to University of Michigan researchers. They found that 56% of the users surveyed reported driving within 2 hours after using marijuana; 51% reported driving while “a little high,” and 21% reported driving while “very high.” With more states enacting laws approving medical or recreational marijuana use, an industry has quickly expanded to meet consumer demand. The American Industrial Hygiene Association (AIHA) voiced hether marijua- marijuana in addition to existing several concerns about the cannabis na or opiates are laws recognizing medical uses of industry in its recent public policy obtained legally marijuana; agenda, including: or illegally, both • Physicians have prescribed • Worker impairment due to are present in the opioid painkillers for work- marijuana use; workplace. An related and non-work-related • Health and safety hazards posed increasing num- injuries; and by the growing, processing, and ber of workers are even dying on the • As some individuals became retail sale of marijuana and the Wjob from drug and alcohol overdoses. dependent on or misused these need to reach out to the industry The most acute hazards are faced by prescription painkillers, they to implement hazard controls; and firefighters, police officers, and- oth switched to illicit opioids. • The need for research into iden- er emergency responders, as well as tifying and characterizing worker cleanup workers. These have led to four key impairment, as well as a voluntary These issues have been fueled by problems: prohibition of marijuana use by a number of developments: 1. Health and safety hazards in the workers in safety-sensitive posi- • Several states have enacted laws growing, processing, and retail tions until impairment caused by

allowing recreational use of sale of marijuana; marijuana use is better understood. WILDPIXEL/GETTY.COM

40 Safety Decisions | Spring/Summer 2019 SafetyDecisionsMagazine.com Steep Learning Curve for emergency egress without needing for drugs do not test for synthetic an Emerging Industry a badge to exit the facility; and opioids. Participants in the emerging canna- • Develop and implement a written The standard five-panel drug test bis industry may be unprepared for respiratory protection program that checks for amphetamines, cocaine, and ill-equipped to handle the health meets the requirements of OSHA’s heroin, marijuana, and phencycli- and safety hazards involved with the respiratory protection standard. dine (PCP). It does not screen for growing, processing, and retail sale of dilaudid, fentanyl, hydrocodone, or marijuana. Overdoses on the Job oxycodone. The California Division of Oc- Overdoses and even overdose deaths Opioids include: cupational Safety and Health (Cal/ are becoming increasingly common • Natural opioids, such as morphine OSHA) recently cited a marijuana occurrences in the workplace. and codeine, derived from the processing company for a workplace The Labor Department’s Bureau opium poppy; explosion in which an employee suf- of Labor Statistics (BLS) reported • Semisynthetic opioids, including fered burns. When the employee was that the number of fatal overdoses illicit heroin and the prescription using propane to extract cannabis oil has increased by at least 25% for 5 drugs hydrocodone and oxyco- from leaves, the propane ignited, straight years. The number of over- done; and causing an explosion. doses has been rising since 2012: • Synthetic opioids, such as The National Institute for Occu- • From 65 in 2012 to 82 in 2013, methadone, tramadol, and pational Safety and Health (NIOSH) • To 114 in 2014, fentanyl. has published two Health Hazard • To 165 in 2015, and Evaluation reports following investi- • To 217 in 2016 and 272 in 2017. The NSC went on to develop a set gations at cannabis industry facilities. of recommendations for employers At an outdoor organic farm where The 272 drug and alcohol over- specific to responding to prescrip- marijuana is harvested and pro- doses accounted for 5.3% of all fatal tion opioids in the workplace. The cessed, NIOSH reported finding that: injuries in 2017. group first recommended that em- • Tetrahydrocannabinol (THC) Quest Diagnostics noted a spike ployers reevaluate their drug-free was present in every surface wipe in positive results for opiates. Quest workplace policy and drug testing sample; and has performed over 10 million program. The NSC said an effective • Some hand-trimming activities re- worker drug screens over a 3-year drug-free workplace policy consists quired a lot of hand motions, and period, from 2015 through 2017, and of five components: employees were concerned about found the highest rate of positive 1. A clear, written policy; repetitive-motion injuries. results for opioids in the following 2. Employee education; industry sectors: 3. Supervisor training; Investigators recommended the • Health and social assistance, .47%; 4. An employee assistance program employer rotate workers to reduce • Public administration, .47%; (EAP); and the duration of repetitive hand mo- • Construction, .34%; 5. Drug testing. tions and wipe work surfaces to • Manufacturing, .33%; and remove the THC. At a medical mar- • Accommodation and food The policy should clearly state ijuana processing facility, NIOSH services, .31%. that prescription drugs should be researchers had a longer list of sug- taken in the standard dosage ac- gestions for the employer. They sug- NSC Surveyed Employers cording to a physician’s instruc- gested that the employer: A National Safety Council (NSC) sur- tions. The NSC also suggests that • Install local exhaust ventilation to vey found most employers are unpre- employees share their job descrip- reduce exposures during grinding pared to cope with opioids and especial- tion with the prescribing physician operations; ly prescription opioids in the workplace. to determine whether a prescribed • Move the decarboxylation process The NSC found that: medication would interfere with (to extract cannabinoids) to a • More than 70% of employers are the employees’ assigned duties. The seldom-occupied area in the affected by prescription drugs in employees also should ask whether facility to prevent unnecessary the workplace; a nonopioid medication could be exposures to potentially • 76% do not offer training to iden- prescribed for pain. hazardous substances; tify the signs of misuse; Supervisors should be trained • Limit access to the areas where • 81% lack a comprehensive drug- to recognize typical behavioral higher-exposure tasks are occurring; free workplace policy; and and performance-related signs of • Redesign security doors to allow • 41% of those that test employees impairment.

SafetyDecisionsMagazine.com Safety Decisions | Spring/Summer 2019 41 PRACTICAL TIPS

An employer-sponsored EAP can brand names Narcan® and Evzio®, can face the risk of exposure to fentanyl be a cost-effective way to address reverse an opioid overdose. in liquid, powder, or tablet form. prescription painkiller dependence The symptoms of an overdose Fentanyl, a synthetic opioid, is or addiction. However, the NSC include: 50 to 100 times more potent than noted that while many companies • Slow breathing or no breathing, morphine; and one of its analogues, offer EAPs, few employees use • Drowsiness or unresponsiveness, carfentanil, is 10,000 times more them. Employees can often fear a and potent. stigma or negative ramifications re- • Constricted or pinpoint pupils. As part of the federal govern- sulting from using their employer’s ment’s response to an epidemic of opi- EAP. The NSC suggested that em- Police officers, emergency medi- oid use, NIOSH developed a health ployers educate their employees in cal services providers, and other re- and safety topic page on its website the value of their EAP. sponders routinely carry Naloxone about prevention of fentanyl expo- The NSC also suggested that for that purpose. However, Nalox- sures among emergency responders Prescription Benefit Managers one only counters the effect of opi- and law enforcement officers. Law (PBMs) have technology that can oid overdoses and not overdoses of enforcement personnel at risk in- help stop prescription painkiller other drugs or alcohol. clude special operations officers and misuse. The council suggests em- NIOSH developed a fact sheet crime scene and evidence technicians, ployers ask the following when for employers considering imple- as well as workers who clean up evaluating PBMs: menting a Naloxone program. seized opioid manufacturing sites. • Does the PBM provide infor- Employers contemplating a Emergency response, fire, and po- mation about total opioid drug Naloxone program must weigh a lice employees face the risk of sever- spending and trends? number of issues, including: al routes of exposure, including: • Does your PBM have a flag for • Does your state allow the admin- • Ingestion, repeated attempts for “too early istration of Naloxone by nonli- • Inhalation, refills” that would potentially show censed individuals? • Mucous membrane contact, and noncompliance with the prescrib- • Does your state’s Good Samaritan • Needlesticks. er’s recommendation? law provide a shield from liability • Are dose levels flagged, including for providing Naloxone? Skin contact is less likely to pro- morphine equivalents exceeding • Has your workplace experienced duce an overdose. However, NIOSH 120 milligrams per day? an overdose or are there signs of recommended several hazard controls • If the “duration of therapy” limit opioid misuse on-site (drugs or depending on the hazards present at is flagged, what is the process drug paraphernalia)? various response scenes. Recommend- when an opioid prescription has • How quickly can emergency ed personal protective equipment been changed during the course of responders arrive at and gain (PPE) range from nitrile gloves; safety treatment? access to your workplace? goggles; and disposable N100, R100, • Is there a system flag when opioids • Can Naloxone be added to and P100 face piece respirators to: are combined with other drugs, first-aid kits or automatic • Sleeve covers, gowns, and overalls; especially in combination with external defibrillators (AEDs) • Air-purifying respirators (APRs); sedative benzodiazepines (like already on-site? • Powered air-purifying respirators Valium and Xanax)? • Is there a high risk of opioid over- (PAPRs); and • Does the system show if an doses in your geographic area? • Self-contained breathing employee is seeing multiple apparatus (SCBA). physicians who prescribe the NIOSH Fentanyl Resources same or similar prescription The greatest hazards are faced by po- The institute also recommend- opioid painkillers? lice and emergency responders to ed postexposure decontamination: scenes where synthetic opioids like washing hands with soap and wa- Employer Naloxone fentanyl and its analogues are present. ter. NIOSH cautioned against using Programs A quantity as small as a poppy seed alcohol-based hand sanitizers or Because overdoses, even fatal ones, can be fatal to humans. Even police bleach solutions, which can actually are occurring on the job, NIOSH working dogs exposed to fentanyl or enhance absorption of fentanyl. has recommended that employers other synthetic opioids have suffered consider having Naloxone on hand fatal overdoses. Guy Burdick is a contributing editor of in the workplace to reverse opioid Emergency medical services pro- Safety Decisions. overdoses. Naloxone, sold under the viders, firefighters, and police officers Reprint: SD_0319-8

42 Safety Decisions | Spring/Summer 2019 SafetyDecisionsMagazine.com OSHA Explains Hybrid SDSs Still confused about some of the finer points of the HazCom and GHS standards? You’re not alone, and OSHA recently provided some guidance. By William C. Schillaci

n 2012, the Occupational Safe- OFor example, in a recent letter SDSs for a chemical manufacturer or ty and Health Administration of interpretation (LOI) to a company importer may be a liable party with (OSHA) completed a compre- that provides worldwide services re- regard to meeting the HCS require- hensive revision of its Haz- lated to the HCS and similar interna- ments. While the letter covers these ard Communication Standard tional programs, OSHA’s directorate and other aspects of SDS require- (HCS), with the general ob- of enforcement programs answered ments, OSHA’s main point seems to jective of achieving alignment questions about the applicability of be that additional information can be with the United Nations’ (U.N.) 2009 the HCS and the SDS requirements included in hybrid SDSs as long as it IGlobally Harmonized System of Clas- to imported products. The compa- does not “contradict or cast doubt” on sification and Labelling of Chemi- ny’s main question concerned the the information required in SDSs. cals (GHS). The revision provided degree to which SDSs can include in- much-needed improvements in how formation and be formatted to meet Background information about hazardous chem- both OSHA’s HCS requirements and OSHA issued the original HCS in icals in the workplace is communi- the requirements of Health Cana- 1983. Chemical manufacturers and cated to employees, but there remain da’s Hazardous Products Regulations importers were required to evaluate questions about implementation of (HPR) and its Workplace Hazardous the chemicals they produce or import the HCS and particularly about one Materials Information System (WH- and provide hazard information to of its critical components: safety data MIS). The LOI also addresses wheth- downstream employers and employ-

ANDRESR/GETTY.COM sheets (SDSs). er a company contracted to develop ees by putting labels on containers and

SafetyDecisionsMagazine.com Safety Decisions | Spring/Summer 2019 43 PRACTICAL TIPS

with information in SDSs required by “PERHAPS THE MAJOR PROBLEM WITH THE OSHA’s HCS. 1983 MSDS REQUIREMENT WAS THAT IT WAS Cooperation on this issue has already been addressed by the two PERFORMANCE-BASED. WHILE CERTAIN nations. For example, in June 2013, OSHA and Health Canada signed INFORMATION ABOUT THE CHEMICALS AND a memorandum of understanding (MOU) to formalize implementation THEIR HAZARDS WAS MANDATORY, THERE of the GHS in ways that reduced dif- WAS NO REQUIREMENT THAT THE INFORMATION ferences between the two jurisdictions and to build a common approach to BE PROVIDED IN A SPECIFIC FORMAT.” future changes of the GHS (see the OSHA memo at https://www.osha. gov/laws-regs/standardinterpreta- tions/2016-09-21). Also, in May 2015, preparing material safety data sheets manufacturers had already been using OSHA announced that it would con- (MSDSs). Information that was man- for years on a voluntary basis) com- tinue its partnership with Health datory in MSDSs included the prop- prises 16 sections presented in a spe- Canada to align the U.S. and Cana- erties of each chemical; the physical, cific order. Items of primary interest dian regulatory approaches regarding health, and environmental health haz- to exposed employees and emergency labels and SDSs and classification re- ards; protective measures; and safety responders are presented at the begin- quirements for workplace chemicals. precautions for handling, storing, and ning of the document, while more tech- “Where an SDS element is required transporting the chemical. nical information is presented in later by Health Canada’s WHMIS, and not by Perhaps the major problem with the sections. Also in line with the GHS, OSHA’s Hazard Communication stan- 1983 MSDS requirement was that it the revised HCS requires that chemical dard, it is permitted/allowed by OSHA, was performance-based. While certain manufacturers and importers provide unless the information would contra- information about the chemicals and their chemicals with labels that include dict or cast doubt on the required in- their hazards was mandatory, there harmonized signal words, pictograms, formation,” the memo states. “Similarly, was no requirement that the informa- and hazard statements for each hazard an SDS element that is required under tion be provided in a specific format. class and category. Precautionary state- HCS 2012 is permitted in Canada. An Accordingly, chemical manufacturers ments must also be provided. example applies to carcinogenicity. The and importers conveyed the required “The modifications to the HCS HCS 2012 requires that if a chemical is information in MSDSs and on labels will significantly reduce burdens and identified as a carcinogen by OSHA, the in whatever format they chose. Man- costs, and also improve the quality International Agency for Research on ufacturers were also required to eval- and consistency of information pro- Cancer (IARC), or the National Toxicol- uate the potential hazards of chem- vided to employers and employees re- ogy Program (NTP), then this informa- icals—a vague word that resulted in garding chemical hazards by provid- tion must be disclosed in SDS section more information disparities among ing harmonized criteria for classifying 11, Toxicological information. Health MSDSs. The result was that employers and labeling hazardous chemicals and Canada permits this information on the were forced to continually relearn how for preparing safety data sheets for SDS even though under WHMIS the to read and understand MSDSs that these chemicals,” OSHA stated in the IARC and NTP listed carcinogens are were dissimilar in how they presented preamble to the revision. not required to be disclosed on the SDS. data and described hazards. However, if an SDS from Health Cana- In its 2012 final rule, OSHA revised United States and Canada da is sent to the U.S., the SDS must dis- the HCS to conform to the U.N.’s GHS Signed MOU close information on any OSHA, IARC (Rev. 3, 2009). The revisions included All this brings us back to OSHA’s LOI, and NTP listed carcinogens.” adoption of the GHS’s standardized which you can find online at www. format for MSDSs. To differentiate msdsonline.com/wp-content/up- Avoiding Confusion from the original HCS, OSHA intro- loads/2018/10/OSHA_Letter_of_In- Points made in the LOI include the duced a new term for the new format: terpretation_091818.pdf. As noted, following. safety data sheet. The information the thrust of the letter was to deter- • Section 1 of the SDS must include required in SDSs was largely the same mine how information in SDSs re- the name, address, and telephone as what was required in MSDSs. But quired by Canada’s WHMIS can be in- number of the manufacturer, im- the new format (which chemical corporated into or is interchangeable porter, or other responsible party.

44 Safety Decisions | Spring/Summer 2019 SafetyDecisionsMagazine.com (The HCS defines responsible party importer to include its address on permissible to use the hazard and as “someone who can provide its SDS for chemicals to be used precautionary statement from the additional information on the on-site. OSHA’s HCS does require more recent revision of the GHS hazardous chemical and appro- that all SDSs include a U.S. address because it would contradict or cast priate emergency procedures, if in Section 1 of the SDS. OSHA doubt on HCS required informa- necessary.” A responsible party may says it does not currently plan to tion. also be a partnership, association, change this requirement. • The HCS requires inclusion of corporation, business trust, legal • A contracted company that pro- health hazards not otherwise clas- representative, or any organized vides additional information for sified (HNOCs) in the SDS. Also, group of persons. These parties a hazardous chemical may be an HNOCs may be included on the automatically become the responsi- SDS author or contracted prepar- label as supplemental information. ble party.) er. In this arrangement, a man- Additionally, OSHA permits the • Section 1 must also include an ufacturer or importer may agree use of the exclamation mark picto- emergency phone number. “The to list the contracted company on gram to indicate the hazards of an address must be in the United its chemical label and SDS as the HNOC on the label and SDS if the States, and the phone number party to be contacted to provide label also indicates that the picto- must be a domestic number,” additional or emergency informa- gram is being used for an HNOC. states OSHA. “If a manufacturer, tion. However, the manufacturer However, the exclamation mark importer, distributor, or employer or importer remains the responsi- pictogram may appear only once chooses to add a foreign address to ble party and, as such, maintains on a label; if it already appears as a an SDS, it may be listed in Section the ultimate responsibility for required pictogram for a classified 1 if the responsible party believes compliance with OSHA’s HCS. The hazard, it may not appear a second they may be able to provide addi- contracted party may not claim time as supplemental information tional supplemental information responsibility for the SDS and its for the HNOC. and it is done in a fashion that contents. • Canada’s HPR requires the use does not cause confusion. To avoid • Hybrid labels and SDSs that con- of precautionary statements for confusion, the supplemental infor- tain all the required HCS elements hazard classes not covered by mation may instead be provided in may include foreign country infor- the GHS. These hazard classes Section 16 of the SDS.” mation as long as no information are combustible dusts, simple • The party or importer that receives contradicts any requirement in asphyxiants, pyrophoric gases, the chemical shipment from a OSHA’s HCS. physical hazards not otherwise foreign supplier is liable for all • A responsible party may follow the classified (PHNOC), and bio- HCS 2012 requirements for that most recent version of the GHS hazardous infectious materials. chemical, including classification as long as the hazard informa- The question was whether OSHA and developing an SDS as soon as tion does not contradict or cast would allow the hybrid SDS to it is in the importer’s possession. If doubt on the HCS 2012 required add precautionary statements the chemical arrives at the facility information. If the hazard and for hazard classes not covered by without an SDS, the importer precautionary statements in the GHS. OSHA responded that must create an HCS-compliant Canada’s HPRs differ from 2012 while it does not require precau- SDS. If the shipment arrives at HCS statements because they were tionary statements for HNOCs, the facility with an HCS 2012- adopted from a more recent revi- it permits them as supplemen- compliant SDS, the importer may sion of the GHS, the responsible tal information as long as the use that SDS to meet the HCS party may use them as long as the statements do not contradict or requirement. hazard information does not cast cast doubt on the requirement • lf the chemical will not be leaving doubt on the HCS 2012 required information. HCS 2012 requires the facility, the U.S. importer may information. Minor differences are hazard statements for combus- follow the workplace labeling re- acceptable. (See OSHA Standard tible dust, pyrophoric gas, and quirements at 29 Code of Federal Interpretation at https://www. simple asphyxiants but does not Regulations (CFR) 1910.1200(f) osha.gov/laws-regs/standardinter- require precautionary statements (6), which provide several options pretations/2017-11-29.) However, for those hazards. not available when chemicals leave classification or hazard categories the workplace. may be different in a more recent William C. Schillaci is a contributing editor • Health Canada’s 2015 WHMIS version of the GHS than in HCS of Safety Decisions. regulation does not require an 2012. In these cases, it is not Reprint: SD_0319-9

SafetyDecisionsMagazine.com Safety Decisions | Spring/Summer 2019 45 Professional Profile

Shortly after the merger was announced, Herr shared with Safety Decisions some reflections on the current state of risk management and what he’s most excited about when he considers the future of safety.

Tell us a little bit about your experiences working in the risk management and safety space. What inspired you to get involved in the industry? Every year some two million men and women lose their lives through accidents and diseases linked to their work. Hear- ing this and the corresponding stories of the real people affected inspired me to propel risk management into the fore- front of the market. The more people realize what is at stake, the more proactive they become in ensuring every worker John Herr makes it home safely each night, and I am no different. CEO While I’ve only led Avetta for five years, I’ve been involved Avetta in risk management for almost two decades. I’ve learned that no matter what industry you’re in, there will always be lia- t’s been a busy time for John Herr, CEO of supply bilities and hazards. As a result, risk management is a topic chain risk management software provider Avetta. that needs to be brought into every boardroom discussion. In mid-February, the company announced that it Working across various industries has given me unique had combined with supply chain solutions provider insight into the wide variety of risks factors that handicap a BROWZ, expanding Avetta’s global network to 85,000 company. From supply chain inconsistencies to data security customers in more than 100 countries. The ultimate breaches and everything in between, no company is immune. goal? To elevate safety and sustainability in workplaces The first step to building a strong and sustainable business Iaround the world. is making safety a priority. Once you can ensure that your

46 Safety Decisions | Spring/Summer 2019 SafetyDecisionsMagazine.com employees will arrive home to their families safe each night, the door to compliance and safety liabilities that will great- then you can start tackling the tougher issues of business. ly impact the success of companies. Fortunately, while this is a large stumbling block for many professionals, the solu- What are the biggest supply chain safety tion already exists—a proactive risk management system. and risk management issues giving Looking to the future, companies will be able to bypass organizations problems today? safety and compliance issues by preemptively auditing and The biggest impediment to safety and strong risk manage- monitoring their supply chain. ment is tradition. We work with industry leaders who use outdated paper and filing cabinet systems simply because What advice do you have for safety that’s the way it’s always been. What they don’t realize is professionals looking to optimize their that their own systems are frequently causing inconsisten- use of technology within their programs? cies and weaknesses in their supply chain. As compliance My main message is one of encouragement. Implement- requirements become more complex, such processes will ing and optimizing new technology into existing programs only become more inefficient and error-prone. will always be an adjustment, but it’s worth the effort. Our Oftentimes it takes an incident occurring to help business- technological daydreams from 20 years ago are simple es realize there’s a better way to manage their teams. Our goal children’s playthings today. This progress was only made is to help companies recognize their unique risks before some- because people were willing to look past what has always thing tragic happens. While supply chain risk management been done and instead see what could be possible. Strategi- comes with costs, the cost of noncompliance is even more dev- cally and continuously doing so, regarding technology ad- astating, not just for the company but for the lives and families aptation, will not only strengthen your business but sustain of affected workers as well. A third-party platform can help re- it through the natural rises and falls as well. duce these risks, while at the same time lowering administra- One of best ways to optimize technology is to choose tive costs. What once took an entire team a full week or more platforms that are adaptable to your specific needs. Many com- to manage, can now be automated on our platform in less than panies set themselves at a disadvantage by choosing a “one- a day. More important than the massive savings companies size-fits-all” solution. On paper these appear nice, but the truth have found is the confidence they have gained in their supply is you end up paying more for services that don’t benefit you. chain, the confidence that their employees and their brand And when it comes time to adapt, your technology is often the are protected. issue that’s lacking. Here at Avetta, our clients are able to con- figure our platform to their specific needs. Your business and What innovations in safety are you most supply chain are unique, so your solution should be too. excited about, and what concerns do you As always, you should look to the people who are going have for the future of safety? to be using the technology on regular basis. As an execu- The future of risk management is progressing rapidly, with new tive it’s easy to mandate what systems will be used further developments hitting the market every month. It’s an amazing down the line. However, if the individuals tasked with us- and exciting time to be part of the industry! Currently, I’m in- ing the program aren’t supportive or compliant with these terested in the power of analytics to predict unfavorable events requests, the technology will never be leveraged to its full and prevent them from occurring. Our system enables compa- extent. That’s one of the reasons why we spend so much nies to track trends in their supply chain. Through intuitive re- time here at Avetta ensuring that the contractors and supporting tools, data visualization, and in-application modeling, pliers using our platform find value in it as well. Through they receive pragmatic data points that are then used to make our unique Marketplace and Insurance offerings these con- informed and efficient business decisions. tractors get discounts on products they already use simply As these analytics and automation advancements contin- for being our customer—no extra charge. When it comes ue, business will gain unparalleled insights into every aspect of to creating and optimizing a world-class, technological their supply chain, from far-reaching overviews of compliance platform, we look at the customer experience from the en- all the way down to the compliance level of individual workers. tire operational standpoint. This has helped us successfully Not only that, but at the same time this increase in data will give help businesses reduce their Total Recordable Incident Rate them the power to implement real changes that make a differ- (TRIR) without disrupting their existing supply chains. ence. While the ability to protect and manage your supply chain from anywhere in the world is already reality, better automation Check out our Keeping Up section in this issue of Safety and analytics will make it a household item for companies. Decisions for more details on how Avetta and BROWZ joined One of my main concerns is that with expanding global forces to become a world leader in supply chain risk management. supply chains comes a lack of knowledge on how to nav- To learn more, visit www.avetta.com.

THITIVONG/GETTY.COM igate across borders and languages effectively. This opens Reprint: SD_0319-10

SafetyDecisionsMagazine.com Safety Decisions | Spring/Summer 2019 47 Day to Day Unaffected by Government Shutdown, OSHA Increases Penalties The government shutdown several months ago affected many federal agencies and contractors but not the Occupational Safety and Health Administration (OSHA). By the Safety Decisions Staff

oth OSHA and the Mine through September 2019. Employers were suspended. The remaining staff Safety and Health Ad- therefore expected the same level of were on call in case a serious incident ministration (MSHA) inspections, enforcement, and com- occurred during the shutdown. The were fully operational pliance assistance that was in place Department of Justice’s (DOJ) enforce- during the shutdown. Due pre-shutdown. ment efforts were also affected, as its to a minibus appropria- However, the Chemical Safety and lawyers were furloughed. DOJ law- tions bill signed by Pres- Hazard Investigation Board (CSB) yers requested that their civil cases be ident Donald Trump in September had approximately 95% of its staff fur- stayed and deadlines postponed for the

B2018, the agencies are fully funded loughed, and all of its investigations length of the shutdown. JERRY2313/GETTY.COM

48 Safety Decisions | Spring/Summer 2019 SafetyDecisionsMagazine.com The following chart compares the 2019 penalties with the 2018 levels:

Violation 2018 Penalty Levels 2019 Penalty Levels

Any willful violation of OSHA rules or standards Minimum of $9,239 up to $129,336 Minimum of $9,472 up to $132,598

Any repeat violation of OSHA rules or standards Up to $129,336 Up to $132,598

Any serious violation of OSHA rules or standards Up to $12,934 Up to $13,260

Any OSHA violation deemed not serious Up to $12,934 Up to $13,260

Failure to correct a violation Up to $12,934 for each day the condition continues Up to $13,260 for each day the condition continues

Violation of posting requirements UUp to $12,934 Up to $13,260

from $72,718 to $74,552 per day “EFFECTIVE FEBRUARY 6, 2019, THE per violation; • Safe Drinking Water Act (SDWA) MAXIMUM CIVIL PENALTIES THAT THE EPA violations: from $55,907 to MAY IMPOSE FOR VIOLATIONS OF VARIOUS $57,317 per day per violation; • Toxic Substances Control Act ENVIRONMENTAL STATUTES HAVE (TSCA) violations: from $38,892 to $39,873 per day per violation; INCREASED BY JUST OVER 1%.” • Emergency Planning and Com- munity Right-to-Know Act (EP- CRA) violations: from $55,907 to Higher OSHA Penalties Higher EPA Penalties for $57,317 per day per violation; and Now in Effect Noncompliance Are Also • Federal Insecticide, Fungicide, During the final days of the shut- Now in Effect and Rodenticide Act (FIFRA) vi- down, OSHA’s final rule to increase If your duties extend beyond safety into olations: from $19,446 to $19,936 its civil penalties by approximately the environmental compliance arena, per day per violation. 2.5% for 2019, with a new maximum you should also know that, although single-violation penalty for willful delayed by the government shutdown, The new penalty levels apply to all and repeat violations of $132,598, the U.S. Environmental Protection violations occurring after November was published in the Federal Register Agency (EPA) has also finalized reg- 2, 2015, for which penalties are as- and took effect immediately on Jan- ulations adjusting its civil penalties to sessed after February 6, 2019. uary 23, 2019. The penalty increases account for inflation. Effective Febru- While the increased maximum pen- adjust for inflation as required by the ary 6, 2019, the maximum civil penal- alties may not impact the actual penal- Federal Civil Penalties Inflation Ad- ties that the EPA may impose for viola- ties the EPA seeks when dealing with justment Act of 2015, which initial- tions of various environmental statutes a specific environmental violation, the ly raised civil penalties by 78% after have increased by just over 1%. Agency believes it is important that the over 2 decades without a penalty in- For example, maximum penalties maximum penalties reflect inflation to crease and mandated annual adjust- have increased as follows: maintain the intended deterrent effect ments each year. • Clean Air Act (CAA) violations: and promote compliance. The new levels were not expected from $97,229 to $99,681 per day to take effect until the partial govern- per violation; Keep an eye on the EHS Daily Advisor for ment shutdown ended but instead • Clean Water Act (CWA) viola- further developments. For more information were published during the shutdown. tions: from $53,484 to $54,833 per on federal regulatory enforcement in the The new penalty levels will apply to all day per violation; environment, health, and safety (EHS) space, violations occurring on or after Janu- • Resource Conservation and visit www.osha.gov and www.epa.gov. ary 23, 2019. Recovery Act (RCRA) violations: Reprint: SD_0319-11

SafetyDecisionsMagazine.com Safety Decisions | Spring/Summer 2019 49 DAY TO DAY

n December 18, 2018, the BLS released its most current figures for 2017. The overall results were encouraging. After 3 straight years of increases, there were 43 fewer workplace deaths in O2017 than in 2016. The bureau reported a total of 5,147 fatal work injuries in 2017— down from 5,190 in 2016. The total brought down the rate of fatal injuries from 3.6 per 100,000 full-time equiv- alent workers in 2016 to 3.5 in 2017. The bureau also reported decreases in deaths due to certain causes and in certain types of incidents: • Violence and other injuries by persons or animals decreased 7% in 2017— homicides dropped by 8% and suicides decreased by 5%. • Incidents involving contact with objects and equipment were down 9% (695 in 2017, which is down from 761 in 2016), with caught in running equipment or machinery deaths down 26% (76 in 2017, which is down from 103 in 2016). • Crane-related workplace fatalities fell to their lowest level ever recorded in the CFOI at 33 deaths in 2017. All-Time Lows for Private Manufacturing Some industries saw decreases in fatal injuries. In the private manufacturing and wholesale trade industries, A Trove of Fatality the number of workplace deaths was its lowest since the BLS began break- Data Released from ing out figures for these industries in 2003. There were 303 fatalities in manufacturing in 2017 and 174 in the Labor Department the wholesale trade—down from 318 The federal government has long tracked both fatal and and 179, respectively, in 2016. While there was a decrease in the number nonfatal workplace injuries. The Labor Department’s of wholesale trade deaths, the rate of Bureau of Labor Statistics (BLS) has been compiling fatal injuries held steady at 0.2 (still well below the overall rate of 3.5 for and releasing a national Census of Fatal Occupational all industries). Injuries (CFOI) since 1992. However, the fatal injury rate for manufacturing dropped from 2.0 in

By Guy Burdick 2016 to 1.9 in 2017. STURTI/GETTY.COM

50 Safety Decisions | Spring/Summer 2019 SafetyDecisionsMagazine.com Increases Also Reported occupational injuries at 840. This rep- and Transportation Security Admin- However, despite the overall reduc- resented the highest number of deaths istration are responsible for air safety. tion in fatal injuries, some types of since the BLS began tracking injuries The U.S. Coast Guard oversees safety incidents reached all-time highs, and for the occupation in 2003. on the waterways. certain occupations remained ex- In fact, two occupational groups, tremely dangerous. For example, fatal the transportation and material mov- Employees vs. Self-Employed falls reached their highest level in the ing group and the construction and The rate of fatal injuries also was much 26-year history of the survey, account- extraction group, accounted for 47% higher for self-employed workers ing for 887 (17% of) worker deaths. of all worker deaths in 2017. than for wage and salary employees. Other increases included: Overall, transportation incidents While 4,069 wage and salary employ- • Alcohol and drug overdoses on accounted for 40% of occupational ees died on the job in 2017, their fatal the job; fatalities—a total of 2,077. Those also injury rate was 2.9. The rate for self- • Deaths of heavy and tractor-trailer include: employed workers remains at 13.1. truck drivers; and • 126 in aircraft incidents, In 2017, 1,078 self-employed workers • Deaths of fishing and logging • 48 in rail vehicle incidents, died on the job. workers. • 313 in pedestrian incidents (56 struck by a vehicle in a Deaths of Older Workers In fact, fishers and related fishing work zone), There also was a significant correla- workers and logging workers had the • 68 in water vehicle incidents, and tion between worker age and both the highest published rates of fatal injury • 337 in roadway incidents involv- number and the rate of fatal workplace in 2017. ing a collision with an object other injuries. For example, while only sev- than a vehicle. en 16- to 17-year-old workers died in Fishing Remains Most 2017 at a rate of 0.8 per 100,000, work- Dangerous Job Jackknifed or overturned vehicles ers aged 55 to 64 years old account- Fishing remained one of the deadli- resulted in 197 roadway and 111 non- ed for the highest number of fatal est occupations. While only 41 fish- roadway deaths. injuries—1,155—at a rate of 4.6. ers and related fishing workers died in 2017, the fatal work injury rate for the occupation was 99.8. Other occupations with significantly high fatal “FISHING REMAINED ONE OF THE DEADLIEST injury rates include the following: • Logging workers, 84.3; OCCUPATIONS. WHILE ONLY 41 FISHERS • Aircraft pilots and flight engineers, 48.6; AND RELATED FISHING WORKERS DIED • Roofers, 45.2; IN 2017, THE FATAL WORK INJURY RATE • Refuse and recyclable material collectors, 35.0; and FOR THE OCCUPATION WAS 99.8. ” • Structural iron and steel workers, 33.4. There were 1,084 fatal occupation- The highest fatal injury rate in Fatalities were down slightly for al injuries among motor vehicle oper- 2017 was seen among workers aged ground maintenance workers and su- ators. So, a large share—40%—of all 65 years and over. They account- pervisors. There were 244 fatalities in fatal workplace injuries results from ed for 775 deaths at a rate of 10.3. 2017—a small decrease from 247 who causes outside the purview of the fed- Workers aged 65 or over accounted died in 2016. However, that still was eral Occupational Safety and Health for 15% of fatally injured workers the second-highest total since 2003. A Administration (OSHA) or state an all-time high in the 26-year total of 36 deaths were due to falls from worker safety and health agencies. history of the CFOI. trees, and another 35 were due to being Several Department of Transpor- The toll was especially high among struck by a falling tree or branch. tation and Department of Homeland older farmers, ranchers, and agricul- Security agencies and a patchwork of tural managers. Approximately 63% Transportation Takes a state motor vehicle and local police of farmers killed in 2017 were aged Heavy Toll departments are responsible for safety 65 and over, and 48 of those were Heavy and tractor-trailer truck driv- in the air and on roads and waterways. 80 years old or over. There were 258 ers had the largest number of fatal The Federal Aviation Administration fatalities overall among farmers,

SafetyDecisionsMagazine.com Safety Decisions | Spring/Summer 2019 51 DAY TO DAY

ranchers, and agricultural managers; • 663 fatalities in roadway collisions Massachusetts, Michigan, Montana, 103 of those involved a farm tractor. involving another vehicle—12.9%. Nebraska, Nevada, New Hampshire, There also was a gender dispari- New Jersey, Oklahoma, Oregon, ty in both the numbers and the rates Slips, Trips, and Falls Rhode Island, South Carolina, South of workplace deaths. Men accounted The 887 fatal slips, trips, and falls ac- Dakota, Texas, Utah, Virginia, and for nearly 93% of all fatal injuries. In counted for 17.2% of deaths. In fact, Wyoming. 2017, 4,761 men died on the job at a fatal falls were at their highest level in The three states with the highest rates rate of 5.8 per 100,000. However, 386 the survey’s history. of fatal occupational industries were: women died at a rate of 0.6. Along with falls, many of the lead- • Alaska with 10.2 per 100,000; Fatalities incurred by non- ing causes of fatal occupational inju- • North Dakota with 10.1; and Hispanic black workers and non- ries closely correspond to the viola- • Wyoming with 7.7. Hispanic Asian workers each decreased tions most frequently cited by OSHA. 10% from 2016 to 2017. However, In fiscal year (FY) 2018, the most fre- Invaluable Research Source workplace deaths among Hispanic or quently cited federal standards were: Like the Survey of Occupational Inju- Latino workers rose from 879 in 2016 • Fall protection, construction; ries and Illnesses (SOII), which tallies to 903 in 2017. • Hazard communication; and characterizes nonfatal injuries, • Scaffolding, general requirements, CFOI data are invaluable resources Overdoses on the Job construction; for industry and academic research- Not all workplace deaths were due to • Respiratory protection; ers. The BLS offers access to tables, job-related causes. Drug and alcohol • Control of hazardous energy charts, and database searches of data abuse contributed to a growing num- (lockout/tagout); collected over decades. ber of occupational fatalities. Fatal • Ladders, construction; The BLS’s collected data are avail- overdoses on the job increased 25% • Powered industrial trucks; able online at https://www.bls.gov/iif/ from 217 in 2016 to 272 in 2017. The • Fall protection training home.htm. While the bureau identi- number has increased over several requirements, construction; fied 5,147 fatal injuries in 2017, it re- years and now accounts for a signifi- • Machinery and machine guarding; ported 2,811,500 nonfatal injuries and cant portion of workplace deaths. and illnesses in 2017. These resulted in 8 Unintentional overdoses due to • Eye and face protection, median days away from work. BLS nonmedical use of drugs and alcohol construction. data tables sort these incidents by case have increased by at least 25% for 5 circumstances and worker character- straight years. The number of over- Mixed Results istics, as well as by industry. doses has been rising since 2012: Among States The CFOI is compiled by the BLS’s • From 65 in 2012 to 82 in 2013, A total of 27 states had fewer fatal Occupational Safety and Health Sta- • To 114 in 2014, and workplace injuries in 2017 than in tistics program from various state, • To 165 in 2015. 2016, while 21 states and the District federal, and independent data sourc- of Columbia had more. es. For its 2017 data collection, BLS The 272 drug and alcohol overdos- The number of fatalities remained researchers review over 23,400 unique es accounted for 5.3% of all fatal inju- unchanged in California and Maine. source documents. However, BLS fig- ries in 2017. However, the rate of fatal injuries in ures may not always correspond to Maine increased from 2.4 in 2016 to data reported by others. Some of the Other Causes 2.7 in 2017. data used in the CFOI may be outside Many workplace deaths were the re- Fatalities increased in Arizona, the scope of other agencies or regula- sult of a handful of causes and types of Arkansas, Connecticut, the District tory coverage. incidents. While suicides were down of Columbia, Georgia, Idaho, Indi- The national data compilation from 291 in 2016 to 275 in 2017, sui- ana, Louisiana, Minnesota, Missis- also excludes certain territories and cides represented 5.3% of fatal work- sippi, Missouri, New Mexico, New U.S. possessions. It does not include place injuries in 2017. Other causes York, North Carolina, North Dako- figures for Guam, Puerto Rico, and accounted for even larger percentages ta, Ohio, Pennsylvania, Tennessee, the U.S. Virgin Islands. The CFOI of deaths: Vermont, Washington, West Virginia, does include data for the District of • 317 deaths due to exposures to and Wisconsin. Columbia. harmful substances—6% of all The number of deaths went down deaths; in Alabama, Alaska, Colorado, Del- Guy Burdick is a contributing editor of • 458 homicides—8.9%; aware, Florida, Hawaii, Illinois, Safety Decisions. and Iowa, Kansas, Kentucky, Maryland, Reprint: SD_0319-12

52 Safety Decisions | Spring/Summer 2019 SafetyDecisionsMagazine.com Just For Fun

OSHA Challenge Trivia!

1. Other than the Occupational Safety and Health Act of 1970, 3. Which version of the United Nations Globally Harmonized for how many federal statutes is OSHA responsible for investi- System for the Classification and Labelling of Chemicals (GHS) gating and resolving whistleblower retaliation complaints? is OSHA’s current hazard communication standard based on? A) None A) Revision 1 B) 12 B) Revision 3 C) 21 C) Revision 5 D) 24 D) Revision 7

2. According to the Bureau of Labor Statistics, which of the 4. What is the compliance date for the Employer Identification following groups is responsible for the highest percentage of Number (EIN) to be included with injury and illness data sub- workplace homicides? mitted under OSHA’s electronic recordkeeping rule? A) Robbers A) March 2, 2019 B) Coworkers B) March 2, 2020 C) Customers, clients, and patients C) December 31, 2020 D) Relatives or domestic partners D) July 1, 2020

Hungry for more OSHA Challenge Trivia? Visit oshachallenge.blr.com to sign up for weekly questions, view leaderboards, and compete for prizes!

What would YOU like to see in the next issue of Safety Decisions? We want to be sure that we’re addressing our readers’ top safety needs. Do you have a request for a future article topic or have questions or comments on this issue or previous issues of Safety Decisions? We’d love to hear from you!

Send your comments, questions, or requests to our team at [email protected].

Answer Key to Trivia: 1. C; 2. A; 3. B; 4. B

SafetyDecisionsMagazine.com Safety Decisions | Spring/Summer 2019 53 Ad Index

Company Page Phone # URL

SafeStart CII 800/267-7482 www.SafeStart.com

Tingely Rubber 05 800/631-5498 www.TingleyRubber.com

OLFA 09 800/962-6532 OLFA.com

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54 Safety Decisions | Spring/Summer 2019 SafetyDecisionsMagazine.com September 18–20 | Denver Colorado

Safety Culture 2019 will empower employers to create an engaging and effective safety culture in the workplace that will strengthen safety compliance and engagement, reduce risk for accidents and injury, and avoid costly OSHA fines and litigation.

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• Supercharge your safety committees for maximum safety engagement and retention • Manage with difficult employees and train them to make safety a priority • Measure safety performance with analytics and hazard tracking • Evaluate and fine-tune incentives & disciplinary systems to ensure maximum effectiveness • Identify and eliminate cultural hazards that threaten workers • Improve your safety training to ensure its engaging and accessible for all employees

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