New Study: OSHA Inspections Lower Workers Compensation Costs

[tweetmeme] A new study says it confirms that OSHA’s inspections not only prevent workers from getting hurt on the job, they also save billions of dollars for employers through reduced workers’ compensation costs. The study by business school economists at the University of California and Harvard University, analyzed how workplace safety inspections affected injury rates and other outcomes. In a comparison of 409 randomly inspected establishments in California with 409 matched-control establishments that were eligible, but not chosen, for inspection the study found no evidence that the inspection process and subsequent corrective actions came at the expense of employment, sales, credit ratings, or the firm’s survival.

Key Findings from the Study

  • 9.4% drop in injury claims at workplaces in the four years following an inspection
  • 26% average savings on workers’ compensation costs compared to similar, non-inspected companies
  • $355,000 average savings for an employer (small or large) as a result of an OSHA inspection
  • $6 billion estimated savings to employers nationwide

As researchers David Levine, Michael Toffel, and Matthew Johnson explain, “The benefits of a randomized safety inspection appear to be substantial.  These results do not support the hypothesis that OSHA regulations and inspections on average have little value in improving health and safety.” Furthermore, the researchers found “no evidence that these improvements came at the expense of employment, sales, credit ratings, or firm survival.”

Dr. David Michaels responded strongly to the study,  “I have been promoting that message since I became head of the Occupational Safety and Health Administration almost three years ago. It is supported by empirical evidence—and now—it’s been confirmed by a peer-reviewed study published in Science, one of the world’s top scientific journals. Not only that, the new study, conducted by professors at the University of California and Harvard Business School, shows that OSHA inspections save billions of dollars for employers through reduced workers compensation costs.”  OSHA’s full response to the study.

Read the entire study here.  “Randomized Government Safety Inspections Reduce Worker Injuries with No Detectable Job Loss,”

OSHA Has Specific Training Requirements For Workers

[tweetmeme]Working with many different types of clients is a lot of fun, but it also keeps you on your toes.  Especially regarding training requirements. One of the most frequently asked questions I get involves OSHA regulations on how often you must have safety meetings.

Currently OSHA has no regulation on how often you must have safety meetings. However, there are regulations that require training on a scheduled basis such as Bloodborne Pathogens (29 CFR 1910.1030) training, which is required annually.

Other general industry standards that require annual training include:

  • Asbestos—29 CFR 1910.1001
  • Exposure and Medical Records—29 CFR 1910.1020
  • Fire Brigades—29 CFR 1910.156 (quarterly training required for interior structural firefighters
  • Fire Extinguishers—29 CFR 1910.157
  • Fixed Fire Extinguisher Systems—29 CFR 1910.160
  • Grain Handling—29 CFR 1910.272
  • HAZWOPER—29 CFR 1910.120
  • Machine Guarding—29 CFR 1910.217 and 218
  • Noise—29 CFR 1910.95
  • Respiratory Protection—29 CFR 1910.134
  • Toxic Substances—29 CFR 1910.1003, 1017,1018, 1025-1029, 1043, 1045-1048, 1050

Then there are two standards that require training every 3 years: Process Safety Management (29 CFR 1910.119) and Powered Industrial Trucks (29 CFR 1910.178).  For more information on OSHA required training visit the OSHA website, or contact me directly at

GHS is finally here…almost!

[tweetmeme]OSHA’s recently published the final rule to adopt the Global Harmonization System (GHS), which according to them will not change the framework and scope of the current Hazard Communication Standard (HCS) but will help ensure improved consistency in the classification and labeling of all workplace chemicals. GHS provides a single set of harmonized criteria for classifying chemicals according to their health and physical hazards and specifies hazard communication elements for labeling and safety data sheets. Under GHS, labels would include signal words, pictograms, and hazard and precautionary statements and safety data sheets would have standardized format. This system was agreed on at an international level by governments, industry, and labor, and adopted by the UN in 2002 with a goal of 2008 for implementation.

According to OSHA this change will affect over 40 million workers in about 5 million workplaces. The change to GHS was a long time in coming and necessary as the global chemical business is more than a $1.7 trillion per year enterprise. In the U.S., chemicals are more than a $450 billion business and exports are greater than $80 billion per year. Existing laws and regulations are currently different enough to require multiple labels for the same product both within the U.S. and in international trade and requiring multiple safety data sheets for the same product in international trade. Several U.S. regulatory agencies and various countries also have different requirements for hazard definitions as well as for information to be included on labels or material safety data sheets. GHS effectively establishes agreed hazard classification and communication provisions with explanatory information on how to apply the system worldwide.

It is important to remember that GHS itself is not a regulation or a standard. The GHS Document (referred to as “The Purple Book”) is simply a mechanism to meet the basic requirements of any hazard communication system, which is to decide if the chemical product produced and/or supplied is hazardous and to prepare a label and/or Safety Data Sheet as appropriate. OSHA’s HCS will incorporate the needed elements of GHS to make international trade and commerce easier.

Of course with change comes the need for training. Employers will need to have trained their employees regarding the new label elements and safety data sheets format by December 1, 2013 with full implementation of GHS taking place December 1, 2015.

OSHA has published a side-by-side comparison of the current HCS with the new GHS elements incorporated which can be found here.  If you need more information or training contact me,  I’d be happy to help you find the needed resources.

4-Year GHS Compliance Transition Period

May 25, 2012 to November 30, 2013
All employers that use, handle, store chemicals
Train employees how to read and interpret chemical labels and (material) safety data sheets in compliance with either:

  • The pre-GHS HazCom standard for labels and MSDSs; or
  • The revised HazCom standard with GHS for new-style labels and SDSs; or
  • Both old and new requirements at the same time
December 1, 2013
All employers that use, handle, store chemicals
Train employees about the new GHS-compliant chemical labels and SDSs.
June 1, 2015
Chemical manufacturers, importers, distributors
Comply with all the requirements of the GHS rule, including classify chemical hazards and prepare new labels and SDSs. Distributors have until December 1, 2015 to comply with the shipping requirements for GHS-compliant labels.
December 1, 2015
Chemical manufacturers, importers, distributors
All shipments of chemical containers must include the new GHS-compliant label (signal word, pictogram, hazard statement, and precautionary statement).
June 1, 2016
All employers that use, handle, store chemicals
Update alternative workplace labeling and hazard communication program as necessary, and provide additional employee training for newly identified physical or health hazards.

Get By With A Little Help From A Friend: Safety Professionals & Trainers

[tweetmeme]Recently I had the great pleaure of getting to know more and more experienced safety professionals and trainers using LinkedIn Groups.    Some of the more interesting subjects within our industry are being discussed right now by a wide range of professionals whose insight and knowledge has helped me immensely in my career.   I have listed below a couple of the more interesting blog posts that I have discovered using LinkedIn.   

The Most Overlooked Paragraph in the OSHA Standards

Several months ago I was reading posts made by members in one of the many social networking groups I belong to that are dedicated to occupational health and safety matters. The original discussion question inquired about the regulations that should be applied to workers who were not wearing fall protection harnesses while spreading metal decking…(read more).

Don’t Overlook OSHA’s “Unscheduled” Refresher Training Requirements

When I conduct mock-OSHA inspections for companies, we spend a lot of time focusing on their employee safety training efforts. What we typically find is that most employers provide a new employee safety orientation to get the newbies up to speed on the mandatory OSHA topics…(read more).

Beware – Where Behavior Based Safety Programs and OSHA Standards Collide

Occasionally a company that has implemented an OSHA compliance program asks me for recommendations to help them “go to the next level” and “exceed OSHA compliance”. Often times I recommend they look into implementing a behavior based safety (BBS) program to compliment what they have in place. Many of you in the safety profession already know what a behavior based safety program is…(read more)

OSHA Changes Hazard Communication Standard to Match GHS

[tweetmeme](from OSHA website)

New changes to the Occupational Safety and Health Administration’s (OSHA) Hazard Communication Standard are bringing the United States into alignment with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS).

Major changes to the Hazard Communication Standard:

  • Hazard classification: Chemical manufacturers and importers are required to determine the hazards of the chemicals they produce or import. Hazard classification under the new, updated standard provides specific criteria to address health and physical hazards as well as classification of chemical mixtures.
  • Labels: Chemical manufacturers and importers must provide a label that includes a signal word, pictogram, hazard statement, and precautionary statement for each hazard class and category.
  • Safety Data Sheets: The new format requires 16 specific sections, ensuring consistency in presentation of important protection information.
  • Information and training: To facilitate understanding of the new system, the new standard requires that workers be trained by December 1, 2013 on the new label elements and safety data sheet format, in addition to the current training requirements.

Changes from the Proposed to the Final Rule: OSHA reviewed the record and revised the Final Rule in response to the comments submitted. Major changes include:

  • Maintaining the disclosure of exposure limits (Threshold Limit Values [TLVs]) established by the American Conference of Governmental Industrial
  • Hygienists (ACGIH) and carcinogen status from nationally and internationally recognized lists of carcinogens on the safety data sheets;
  • Clarification that the borders of pictograms must be red on the label;
  • Flexibility regarding the required precautionary and hazard statements to allow label preparers to consolidate and/or eliminate inappropriate or redundant statements; and
  • Longer deadlines for full implementation of the standard (see the chart below):

What you need to do and when:

  • Chemical users: Continue to update safety data sheets when new ones become available, provide training on the new label elements and update hazard communication programs if new hazards are identified.
  • Chemical Producers: Review hazard information for all chemicals produced or imported, classify chemicals according to the new classification criteria, and update labels and safety data sheets.
Effective Completion Date Requirement(s) Who
December 1, 2013 Train employees on the new label elements and SDS format. Employers
June 1, 2015*December 1, 2015 Comply with all modified provisions of this final rule, except:Distributors may ship products labeled by manufacturers under the old system until December 1, 2015. Chemical manufacturers, importers, distributors and employers
June 1, 2016 Update alternative workplace labeling and hazard communication program as necessary, and provide additional employee training for newly identified physical or health hazards. Employers
Transition Period Comply with either 29 CFR 1910.1200 (this final standard), or the current standard, or both. All chemical manufacturers, importers, distributors and employers

* This date coincides with the European Union implementation date for classification of mixtures.

During the transition period to the effective completion dates noted in the standard, chemical manufacturers, importers, distributors and employers may comply with either 29 CFR 1910.1200 (the final standard), the current standard or both.

The final rule revising the standard is available at*.

Easy Steps for a Successful Accident Investigation

[tweetmeme]Some companies use the term “Circle of Prevention” when following the Plan, Do, Check, Act model for their safety and heath programs. As safety is really a continuing process of improvement, the OSHA standards should only be the beginning. They may help identify many of the general hazards of general business and construction, but you and your employees should be working together to identify on-the-job hazards unique to your industry and your work areas, using formal and informal safety audits and hazard analysis.

Whether through reading OSHA standards, consulting other guidelines or making your own observations, the circumstances of the hazards in your organization must be analyzed, the problem diagnosed, a plan of action developed, and then effective corrective action taken to minimize the risks.

But for whatever reason, somehow, even with your excellent safety and health program in place, an accident happens. Now what? After all the initial work is done including securing the scene and caring for the employee, you need to conduct a thorough accident investigation in order to help prevent similar accidents from happening in the future.

How your investigation is conducted will determine in large part how useful it will be.

When to start an Accident Investigation

You must act quickly as memories get fuzzy and initial perceptions may change, other employees start talking and with that the ‘water cooler’ effect takes over. Perceptions and eye witness accounts start being influenced by the storytelling. However, even though you want to get started right away do not get locked into a deadline for completing the investigation. If you are too rushed you may reach the wrong conclusions about the root causes.

Who should conduct the Investigation?

Most minor incidents and accidents can be investigated by the supervisor who is often the person most familiar with the operation. The supervisor is also in position to implement remedial measures as necessary. More serious and complicated incidents and accidents require more expertise. A team approach that includes the supervisor, safety professional or risk manager, management representative, perhaps a safety committee member and even a human resources representative will allow for a wide range of issues to be addressed. In addition, your insurance company will certainly be involved with any serious accident.

The purpose of the Investigation is Prevention not Blame.

It is crucial to the success an accident investigation to make sure you are getting full cooperation from witnesses or those involved in the accident. Remember, the people you are interviewing may be afraid that you will blame them and react defensively or even embellish the facts if they feel threatened. It is important to make sure they understand that you are simply trying to find the factors that led to the accident so future accidents can be avoided.

Review the facts.

  • Description of the accident
  • Witness Discrepancies
  • Condition of any equipment involved
  • Environmental factors
  • Personnel issues with injured employee(s) (training, competence, attitude, past performance, alcohol/drug use, etc.)
  • Routine or non-routine task

Consider all the possibilities

  • The immediate cause?
  • Contributing factors?
  • Underlying root causes?
  • Unpredictable factors?
  • Alternative theories?

Accident Investigation Reporting

Your report should summarize the facts of the accident and events leading up to it. Include any injuries suffered from the accident, the total of all property damages and any other costs of the accident, and if “human error” was involved, this should be included in the report; however, disciplinary recommendations should not be included as part of the investigation. It is however crucial to include information about the immediate and underlying causes and definitely report any dissenting opinions if the investigation was a team effort.

Management can’t do accident prevention in a vacuum, employees need to be involved. Without their understanding and cooperation, nothing management does will really work in the long run to stop the accidents and injuries.

Updated OSHA Videos Intended To Provide Respirator Training Resources


The Occupational Safety and Health Administration (OSHA) has recently posted a series of 17 videos to help workers learn about the proper use of respirators on the job.

These short videos are intended to provide information to workers in general industry and construction.  Topics include OSHA’s Respiratory Standard, respirator use, training, fit-testing and detecting counterfeit respirators. The videos are available with closed captioning for streaming or download from OSHA’s Web site.

OSHA’s Safety and Health topics page on Respiratory Protection also includes additional training materials, information about occupational respiratory hazards in different industries, and details of OSHA’s Respiratory Protection Standard (29 CFR 1910.134 and 29 CFR 1926.103).

EPRCA Tier II Reports born from Tragedy

[tweetmeme]In the early morning of December 3, 1984, a Union Carbide plant near Bhopal, India released approximately forty tons of Methyl Isocyanate (MIC) into the air. The gas quickly spread over the ground and, in the end, killed upwards to 5,000 people and injured 50,000 more. The other place that Union Carbide manufactured MIC was at its Institute plant in West Virginia. Following the Bhopal release Union Carbide elected to shut down production of the deadly chemical at its West Virginia location until it could make $500 million worth of safety improvements.

New Safety Programs

Approximately four months after completion of the safety improvement program, 500 gallons of highly toxic aldchiloxin (and MIC) leaked from the plant. Although no one was killed, 134 people living around the plant were treated at local hospitals.

Both the Bhopal and West Virginia incidents highlighted the serious nature of modern-day chemical production — no matter what safety precautions are taken, no matter how well trained a plant’s employees may be, and no matter how prepared a plant may be to handle an emergency situation, accidents can still occur and people may die.

Congress Acts

With thousands of chemical accidents occurring in the United States within a five year period in the mid-1980s, Congress passed the Emergency Planning and Community Right-to-Know Act (EPCRA) in 1986, ushering in a new wave of regulations and reporting requirements designed to alert the surrounding communities of the dangers posed at chemical facilities in the U.S.

To implement EPCRA, Congress required each state to appoint a State Emergency Response Commission (SERC). The SERCs are required to divide their states into Emergency Planning Districts and to name a Local Emergency Planning Committee (LEPC) for each district.

The facilities covered by EPCRA requirements are now required to submit an Emergency and Hazardous Chemical Inventory Form to their LEPC, as well as their SERC, and their local fire department annually by March 1st.

The reports known as “Tier II Reports,” require basic facility identification information, employee contact information for both emergencies and non-emergencies, and information about chemicals stored or used at the facility.
Under the EPCRA, SERCs and LEPCs are charged with four primary responsibilities:

  1. Write emergency plans to protect the public from chemical accidents;
  2. Establish procedures to warn and, if necessary, evacuate the public in case of an emergency;
  3. Provide citizens and local governments with information about hazardous chemicals and accidental releases of chemicals in their communities; and
  4. Assist in the preparation of public reports on annual release of toxic chemicals into the air, water, and soil.

Tier II Reporting Information

What facilities are covered?

  • Any facility required under Occupational Safety and Health Administration (OSHA) regulations to maintain material safety data sheets (MSDSs) for hazardous chemicals stored or used in the work place. Facilities with chemicals in quantities that equal or exceed the following thresholds must report:
  • For Extremely Hazardous Substances (EHSs) , either 500 pounds or the Threshold Planning Quantity (TPQ), whichever is lower
  • For gasoline (all grades combined) at a retail gas station, the threshold level is 75,000 gallons (or approximately 283,900 liters), if the tank(s) was stored entirely underground and was in compliance at all times during the preceding calendar year with all applicable Underground Storage Tank (UST) requirements at 40 CFR part 280 or requirements of the State UST program approved by the Agency under 40 CFR part 281.
  • For diesel fuel (all grades combined) at a retail gas station, the threshold level is 100,000 gallons (or approximately 378,500 liters), if the tank(s) was stored entirely underground and the tank(s) was in compliance at all times during the preceding calendar year with all applicable Underground Storage Tank (UST) requirements at 40 CFR part 280 or requirements of the State UST program approved by the Agency under 40 CFR part 281.
  • For all other hazardous chemicals, 10,000 pounds.

Tier2 Submit Software

  • EPA has recently developed ‘Tier2 Submit,’ an online software program designed to help facilities prepare an electronic chemical inventory report. Although many states accept Tier2 Submit, some states such as Missouri do not.


  • The owner or operator or the officially designated representative of the owner or operator must certify that all information included in the Tier Two submission is true, accurate, and complete.


  • Any owner or operator who violates any Tier II reporting requirements shall be liable to the United States for civil penalty of up to $27,500 per day for each such violation.
  • Although each day a violation continues shall constitute a separate violation it has been EPA’s policy not to enforce the daily penalty on those companies making a good faith effort to come into compliance with the reporting requirements.

For more information on EPA Tier II reporting requirements visit their website.  Specific state requirements links can also be found there.

OSHA 2013 Budget Request Unchanged From 2012

[tweetmeme]The U.S. Department of Labor today outlined its part of the president’s fiscal year 2013 budget request to Congress, which according to DOL focuses on efficiently achieving the department’s goals while exercising fiscal restraint.    See Summary below:

For information on the president’s FY 2013 budget request for the Department of Labor, visit


OSHA Slashes Number of Online Trainers and Encourages Enrollment at OTI Ed. Centers

[tweetmeme]The Occupational Safety and Health Administration (OSHA) announced earlier this month, its selection of only 10 OSHA authorized training providers out of the hundreds of applicants to deliver online courses as part of its Outreach Training Program.  Although more than 135,000 workers were trained online in 2011, which represents a five-fold increase from the number of online students trained in 2007, OSHA dramatically curtailed the overall number of online training providers available for prospective students to chose from.

Of the newly anointed 10 authorized providers, only two are non-profits or Universities, with the bulk of the providers being private for-profit companies.   Several high profile online providers who previously offered OSHA online Outreach courses were not selected by OSHA including, The University of South Florida,, Coastal Training Technologies, Summit Training Source, and Redvector.

Not all of the new providers that OSHA authorized even have currently available programs, according to OSHA.  Those organizations must still work on building an acceptable program in order to receive a full blessing from OSHA. So the overall number of online course providers may get smaller in the coming months.  In an email received from Mr. Don Guerra, OSHA Program Manager, OSHA continued to recommend that prospective students “compare program offerings and pricing from multiple providers” in order to determine which one best meets their training needs.  However given this latest round of cuts to available online providers, it is highly probable the cost for this online training will rise dramatically for prospective students and employers given the lack of competition in the marketplace.

OSHA also continues to encourage  students to consider taking classroom training instead of online courses.   Which of course, are being offered  and marketed by the OSHA Education Centers around the country in direct competition to private and public classroom training providers.   Although no direct link has been suggested between the slashing of online providers and the encouragement to go to the OSHA Ed. Centers; a clearer message could not have been received!

See the January 12, 2012 news release on new online Outreach Training Program selections.

New and Currently available programs 

Programs that will no longer be available after March 31, 2012