OSHA Still seeking nominations for members for National Advisory Committee on Occupational Safety and Health

July 25, 2012

Contact: Office of Communications

Phone: 202-693-1999

WASHINGTON – The Occupational Safety and Health Administration (OSHA) today announced that nominations are being accepted for four members to serve on the 12-member National Advisory Committee on Occupational Safety and Health (NACOSH).

NACOSH was established under the Occupational Safety and Health Act of 1970 to advise the Secretaries of Labor and Health and Human Services on matters relating to the administration of the Act.

Nominations will be accepted for one representative from each of the following categories: public; management; occupational safety; and occupational health. Members will serve a two-year term.

Nominations may be submitted electronically at www.regulations.gov, the Federal eRulemaking Portal. Submissions may also be sent by mail or facsimile. If submitting nominations by mail, hand delivery or messenger service, send three copies to the OSHA Docket Office, Room N-2625, U.S. Department of Labor, 200 Constitution Ave. NW, Washington, D.C. 20210; telephone 202-693-2350. See the Federal Register notice for details. Nominations must be submitted by September 10, 2012.

Under the Occupational Safety and Health Act of 1970, employers are responsible for providing safe and healthful workplaces for their employees. OSHA’s role is to ensure these conditions for America’s working men and women by setting and enforcing standards, and providing training, education and assistance. For more information, visit http://www.osha.gov



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Do You Hire Subcontractors?


In construction there are many contractors who then subcontract the work to other parties, who further subcontract the work… and so forth. Although your customers expect the job to be completed safely, the focus is typically lost within the tiers of contractors. In other words your safety program doesn’t help the people who are actually doing the work for your company.Subcontractors

Why do you conduct periodic quality inspections, post-job inspections, product standards training for your installers, etc.? The answer is to manage your quality. You manage your quality because you know that if your subcontractor’s quality is not adequate your company’s reputation is on the line.

What you might not understand is that if you hire a subcontractor and they create unsafe conditions, your company’s reputation, plus a whole lot of liability is also on the line.

So here are a few of misconceptions that are important for you to know:

  • I am not responsible because they are not my employee.

If you hire them as a sub-contractor you are always responsible no matter how many tiers! “In no case shall the prime contractor be relieved of overall responsibility for compliance with the requirements of this part for all work to be performed under the contract…the prime contractor assumes all obligations prescribed as employer obligations under the standards contained in this part, whether or not he subcontracts any part of the work. Ref. OSHA regulation 1926.16

FYI: OSHA and other regulators can and will fine you, the injury could be placed on your workers compensation plan if the subcontractor is uninsured, you can be sued if your subcontractor has an incident, or if you contractor creates a situation that results in an incident involving another company, or a member of the public.

  • I am protected because my sub-contractor agreement says they must follow OSHA regulations.

With respect to subcontracted work, the prime contractor and any subcontractor or subcontractors shall be deemed to have joint responsibility. Ref. 1926.16(c)

Where joint responsibility exists, both the prime contractor and his subcontractor or subcontractors, regardless of tier, shall be considered subject to the enforcement provisions of the Act. Ref. 1926.16(d)

  • I cannot communicate with my sub-contractors because they don’t speak English.

Some contractors have attempted to justify this by stating employee turnover, inexperienced workers, and language barriers make it nearly impossible to manage safety. These contractors however have failed to realize that if it is possible to train inexperienced non-English speaking workers to build walls, shingle roofs, or any other task for that matter, then it is possible to have them do those tasks safely.

The fact that these companies can produce a high quality job in an efficient manner proves that if held accountable, an inexperienced and non-English speaking workforce will perform a quality job safely and efficiently.

So what do you have to do to better manage your sub-contractors?

Here are some ideas to further manage you contractors:

Evaluation (Pre-hire Qualification). You could complete a pre-qualification safety evaluation of the company. This could include having them submit a copy of their written programs, inspection results, training records, etc.

Pre-qualification based on a numerical experience system. You can have them provide you with their incidence rates (based on their OSHA recordable cases) so that you could compare them against their industry average found on the Bureau of Labor Statistics webpage. This can tell you if they are having more incidents then should be expected for their type of work.

You can look at their workers compensation “Experience Modifier Rate”. This modifier can tell you how many workers compensation claims they have in relation to others in their line of work.  A modifier of 1.0 means that they are average in their industry. A modifier less than 1.0 means that they are better then average in their industry. A modifier greater than 1.0 means that they are worse than average.

Evaluation of Contractor Safety (After Hired)

Conduct pre-job briefing prior to site entry and at other times, as necessary, to ensure that employees are aware of site hazards.

You can have them provide you with ongoing documentation to prove their program is operation including: Recordable cases (Lost time, Restricted cases, etc), OSHA citations, Inspection results, incident reports, safety meeting summaries, responses to Corrective Action Reports, etc…

This will help you answer these crucial questions:

  • Is senior management committed to safety?
  • Is safety an integral part of project management?
  • Are safety and training improvement programs in place.

Conduct periodic safety inspections to show your commitment, and to hold your contractors accountable.


Contractors have the responsibility to ensure that all employees and sub-contractors are properly trained. To do this you can:

Provide a safety orientation for new contractors so they can pass the information to their employees. This should include a review of:

  • Physical and chemicals hazards on site such as fire, explosion, falls, health (i.e. Silica), etc.
  • General safety rules and regulations.
  • Emergency reporting and response procedures.
  • Other day-to-day issues.
  • Involve your contractors in your weekly, monthly quarterly or periodic training sessions.

Continual Improvement

Guidelines must be created for contractors.

This could include company policies and standards, contractor safety rules and procedures. Then each contractor must be trained on it and they must pass the information down to their employees. (Hint: You may want documentation from them proving that they have actually provided the training to their employees).

You must learn from any mistakes or near misses. As such sub-contractors must report incidents and near misses so you can investigate them.

Most importantly like anything else safety must be measured and monitored. If you don’t do this you have lost accountability!

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Safety Tip Presentation – Gas Detection

Do you know what OSHA’s gas detection PEL’s are? Or the proper use of measuring instruments? In this month’s safety tip, you will get a great overview of gas detection must-know tips to use when entering areas of possible threat.

Get familiar with the oxygen levels, PEL’s, types of atmospheric testing devices, proper usage, and common mistakes to avoid in our 25-slide presentation below…

Safety Tip

To learn more about Gas Detection and Confined Space safety training, visit us at https://www.safetylinks.net/index.php/training/safety-courses-for-all-industries/confined-space-with-hands-on or contact us at 407-353-8165 / info@safetylinks.net.

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Noise Levels & Risks Involved

Noise Testing

Noise Testing

In the following New York Times article, writer Cara Buckley takes a look at hazardous noise levels in NYC public places, the risks of exposure for their employees and the overall lack of enforcement. In it, it also states how even though most venues such as restaurants and bars in the city are obviously operating their businesses with employees exposed to noise levels that would easily require them to wear noise protection, complaints from workers are pretty much nonexistent. She does make it a point that part of the problem is a lack of awareness, not surprisingly. New York City is notorious for its loud noise level almost anywhere you go.

However, as an employer or employee, one should be well aware of the dangers that come with being exposed to long hours of noise in a long-term effect. Not only can it be annoying, but stress, communication interference, or even hearing loss can occur if safety measures never are taken. No matter the location, industry, or size of a business, all employers have an obligation to protect their workers from any of these possible debilitating hazards.

To view the article, visit http://www.nytimes.com/2012/07/20/nyregion/us-standards-on-workplace-noise-trail-those-of-other-countries.html.

To inquire about noise testing and safety, visit us at https://www.safetylinks.net/index.php/industrial-hygiene/noise or call us at 407-760-6170.

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OSHA Excavation Safety Video

Did you know that working in trenches kills an average of 40 construction workers in the United States every year? Employers MUST follow OSHA’s rules to protect workers in trenches and excavations.

One cubic yard of soil can weigh as much as a car! Unless the trench is cut entirely into stable rock, protection against cave-ins must be used for all trenches more than 5ft deep. Always make sure a competent person is there to supervise and to remove any potential hazards throughout and at the beginning of every shift.

OSHA classifies each soil in a trench as:

  1. Stable rock – most stable
  2. Type A
  3. Type B
  4. Type C – least stable

Depending on the type of soil found at the site of the trench, different protective systems should be used for each trench project such as sloping, benching, shoring, and shielding.

Learn how to apply each protective system depending on its soil type for you and your employees in more detail as shown on the following video:


To sign up for our upcoming open class on August 9, visit https://www.safetylinks.net/index.php/training/construction-safety-courses/excavation-competent-person.

For information on onsite Excavations/Trenching classes, call us at 407-353-8165 or email us at info@safetylinks.net.

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NIOSH Works With Latin America on PPE


Worker protection and educational support in Latin America, including workshops and meetings, have recently been provided by NIOSH’s National Personal Protective Technology Laboratory (NPPTL) to the Institute of Public Health (ISP) from Chile. The main focus during these international arrangements has been on respirator protection and other occupational PPE to protect workers from the dangers of exposure to industrial chemical dusts, chemicals, and more.


Maryann D’Alessandro, Ph.D., director of the NIOSH Pittsburg-based laboratory explains, “these partnerships help promote international stability for U.S. business, continue the tradition of U.S. technological leadership globally and provide information that we can sue in turn to further worker health and safety in the U.S.”

Participants included representatives from the Ministry of Health and Labor, the International Labor Organization, multinational manufacturers of PPE, various academic bodies and industrial sectors such as construction and mining. Audits were also performed on respirator manufacturers in Colombia, Chile, and Brazil for maintenance of their NIOSH respirator certification status.

To view the original article from EHS Today, visit HERE.

To inquire about respirator training or fit testing, visit us at https://www.safetylinks.net/index.php/respirators or call us at 407-863-8165.

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The Federal Railroad Administration works with OSHA on whistleblower protection

Due to the number of whistleblower complaints in the railroad industry with a high percentage of retaliation allegations, the U.S. Department of Transportation’s Federal Railroad Administration (FRA) and OSHA have signed a memorandum agreement that will facilitate the coordination and cooperation of workers’ whistleblower rights.

From 2007 to 2012, more than 900 whistleblower complaints were reported by OSHA and almost 63 percent involved some sort of allegation of retaliation. Although the FRA has a broad authority over rail safety, it does not have direct authority to address whistleblower incidents. It is the Federal Railroad Safety Act’s (FRSA) whistleblower provision act that protects railroad employees from retaliation when they report safety violations, or work-related personal injuries or illness.

The memorandum established procedures to follow complaints any allegations. The FRA will refer railroad employees who complain of retaliation to OSHA. OSHA will then provide the FRA with the copies it receives under the FRSA’s whistleblower provision. In turn, both agencies will work together to assist FRA enforcement staff in recognizing complaints and assist OSHA enforcement staff in recognizing potential violations of railroad safety regulations found in investigations.

“This memorandum is a watershed moment for both railroads and labor alike,” said FRA Administrator Joseph Szabo. He continued, “Securing a process that protects employees who report safety violations is critical to maintaining safety standards in the workplace.”

For more information on FRSA and other industry whistleblower cases, visit http://www.whistleblowers.gov/wb_news_room.html.


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CET/CIT Integrated into BCSP Family of Certifications & Technologist Certifications Improved

Updates straight from the BCSP newsletter…
The Certified Environmental, Safety and Health Trainer (CET) & Certified Instructional Technologist (CIT) certifications are swiftly becoming part of the BCSP family of certifications.CET/CIT Integrated into BCSP Family of Certifications Now Recognizable as BCSP Certifications


The training certifications’ new logo is increasingly featured on BCSP materials, and the new CET/CIT process and applications, results of months of diligent preparation, can be found on BCSP’s CET/CIT webpage.

The process of fully integrating the CET/CIT is well underway. By the end of 2012, the certifications’ will be wholly operated by BCSP.

Inquiries related to the certification may be made through the CET/CIT Inquiry form.

Technologist Certifications Improved. CLCS Folded into Updated OHST


The Occupational Health and Safety Technologist® (OHST®) exam began following the most recent set of knowledge required of SH&E technologists this July 2, 2012.

The update, as announced last year, is the result of a validation study to determine the task, knowledge, and skills associated with the OHST practice.The OHST’s latest blueprint and reference materials are available on the OHST webpage.

As part of the OHST update, the Certified Loss Control Specialist® (CLCS®) certification is discontinued. CLCS certificants, and those in process of achieving CLCS certification, can contact Barbara Patterson, BCSP Manager of Customer Service, with questions.

Don’t forget to view our OHST Prep Course page for more information on our upcoming course that will be held on November 6-8. You can also sign up by calling us at 407-505-2803 or email at info@safetylinks.net.

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The Work of Miners Photographed

Earl Dotter Photography

Earl Dotter Photography

This morning, I stumbled upon a great online photo display on a specific photographer’s work, Earl Dotter, who spent most of his life documenting the work lives of Americans for more than 30 years now.

The image shown here represents what most of his work’s focus has been, which is rigorous hazardous work. He started his career in the late 1960’s, when many miner regulations were not in place, as they are today. He gained more interest in coal miners and their work lives during an assignment to the Cumberland Plateau Region of Tennessee.

In 1972, he was later offered to work for the United Mine Workers in America Journal, where he focused on capturing many coal miners’ struggles, from dangerous daily tasks to their struggle with “black lung” cases and workers’ rights.

One of his most impacting and praised works, THE QUIET SICKNESS: A Photographic Chronicle of Hazardous Work in America, is a collection of vivid portraits and images of coal miners that does an excellent job at capturing an honest look at the hard work and dangers involved. He later on branched out and began to document other occupational subjects, as well.

One thing is for sure. Viewing Dotter’s images can definitely leave an impacting reminder to all safety leaders of their purpose: to protect all workers from health and safety hazards. If you’d like to see more of his work, take 5 minutes to view Dotter’s work through his website at http://earldotter.com/portfolio/stock/.

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Evidence Suggests OSHA Inspections Benefit Organizations

Do you ever wonder how big of an impact OSHA inspections actually have on worker productivity loss or company profit? According to recent studies done in California, inspections can actually save a substantial amount of money to companies and organizations. More than many might believe.

The study, done by Michael Toffel, professor at Harvard Business School and David Levine, professor at Hass School of Business, and Matthew Johnson, doctoral student at Boston University, analyzed inspections conducted in highly hazardous industries in California and found that once done, they reduced injury claims by up to 9.2 percent. They also concluded it saved 26 percent on workers’ compensation costs in the four following years after the inspections were done. An estimated $355,000 was saved in injury claims and compensation for paid lost work.

Overall, there was no evidence showing these inspections led to a drop in sales or profit. These findings make a great example of how important implementing safety procedures, plans and culture in an organization can be highly beneficial in many aspects.

“The OSHA inspection itself affords employers an opportunity to recognize where their safety policies and programs aren’t fully effective and, in turn, encourages them to take action, whether that means dealing with a specific hazard noted in the workplace and eliminating or lowering it or changing the way you communicate and train employees,” Johnson says. “There are many ways employers can identify and understand the areas where they can improve safety, and OSHA is one of them.”

To read the original article, visit http://www.hreonline.com/HRE/story.jsp?storyId=533348983.

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