Environmental & Safety Blog

 A new hazard alert was issued by the U.S. Department of Labor's Occupational Safety and Health Administration (OSHA), in conjunction with the National Institute for Occupational Safety and Health, warning employers and employees of the neurological illnesses linked to 1-Bromopropane (1-BP), as well as the risks of cancer and reproductive disorders. 1-BP is a solvent that is used in degreasing, dry cleaning, spray adhesives, and aerosol solvents.

OSHA has recommended that employers take the necessary precautions to protect workers from the effects of 1-bromopropane (1-BP) exposure.


According to the alert, use of 1-BP has increased in workplaces over the past 20 years and, as with many other solvents, workers can be exposed by breathing in vapor or mists of spray. Workers might also be exposed if the chemical touches their skin because it can be absorbed. Additionally, the risk of health effects to workers increases the longer they work with or near 1-BP. Impacts on health have been seen in workers after exposures for as little as two days, although symptoms are more commonly associated with longer exposure.

Currently, federal OSHA does not have a specific exposure standard for 1-BP. However, employers are required by law to keep their workers safe from this recognized hazard. New rules regulating the use of this compound could have major implications for the way companies conduct a site inspection, as there could be more stringent compliance requirements. 
for more information.

Tool box talks can be a tough thing to put together and it can be even tougher to stand in front of a group and speak on a topic. Establishing a safety culture is very important to do right each day when the focus can easily be turned towards getting the job done. Below we will discuss 5 tips to engage an audience and make a difference in going home safe each day.

Tip #1: Short clear message
When employees are on the job they are more worried about hitting their deadline than listening to a generic topic that doesn’t relate to them. When giving tool box talks keep the message of the day clear and short so that it will be remembered by all. As the speaker talk directly to the audience at all times.
Tip #2: Hands on Learning
Do not just lecture to the group! Provide a visual whenever possible and examples from the work environment for better understanding. Processing the topic of the day and having to react to a scenario will prove the workers have the correct understanding.
Tip #3: Tell a story
Workers are much more interested in stories than facts and data. If a story provides a good message and is applicable to the situation employees are about to face, the message will be remembered better. Always stay positive.
Tip #4: Let workers provide insight
No one knows the landscape of hazards better than the workers who operate in the environment each day. Let the workers speak up, providing insight of real examples or areas of improvement for all. A great safety professional or facilitator will listen, learn and drive improvement.

Tip #5: Have a goal
Going into a tool box talk, 1 or 2 goals should be established for the team. Examples of measurable goals include identifying all hazards in the current environment, reminding workers of the consequences of not working safely or giving positive feedback of something done right.

Consistency is key! Toolbox talks are great to use 2-3 times per week spending 5-10 minutes a piece. Tool box talks are highly effective and one of the best ways to keep safety in the mind of all employees. If you are having trouble finding topics of your own, let us know at 270-753-6529. We have over 30 years of safety experience and 100+ tool box talk topics to choose from. 

Hazard communication 2012 & GHS transition
The mere mention of OSHA's changed Hazard Communication standard which includes GHS (Globally Harmonized System) may cause some of us to wince simply because the old system has been in place for so long, and change is rarely easy. Thankfully, OSHA is cushioning this transition with feasible deadlines for compliance. Mark your calendar so you accomplish compliance goals before these dates:
12-1-2013     Train employees on new labels & SDS
06-1-2016     Update labels, complete training and update written program
For chemicals manufactures, distributors, and importers
06-01-2015      Comply with provisions, except can ship under old system until December 1, 2015, which gives distributors / importers time to update

For ESH personnel who want to ensure their company transitions into compliance, here are some of the steps that can make this journey easier.
1.      Review your site-specific written program
a.       If you used definitions or took part of the text from the standard, you will probably need to change the language in the program.
b.      The label section will need to reflect the new labels that are required – internal and from the manufacturer
c.       MSDS language will now be SDS – they dropped the “M”
2.      Labels
a.       Look at your in-house printing system and determine if you can accommodate the new format. A lot of folks are already offering good systems to make in-house labels.
b.      Think about new posters to help inform your employees
3.      Safety data sheets
a.       Will your current system accept the new format?
b.      Are you required to develop SDS – then start now
c.       Recognize that the hazard class and categories will be new to employees, so think about how to best communicate this to them.
d.      If you use HMIS or NFPA, the numbers are opposite - so it is critical to communicate what these systems are saying to us;
            HMIS and NFPA uses “4” for severe, while GHS uses “1” as severe
4.      Training
a.       The best tool to help with understanding this system is through the use of consistent training information, video clips and signs/posters
b.      Check out our GHS transition presentation – it’s yours just for free to help get you through this transition. 
Remember – the same four parts that have always been the cornerstone of Hazard Communication have not been replaced. The plan is that GHS will update information about every two years and OSHA will determine what items may need to be amended. Look for some changes in other OSHA regulations; PSM, flammable and combustible, and chemical specific standards to align with the new formats. Other countries that have adopted GHS are currently in the process of phasing in the GHS components.

With recent weather related tragedies and the unfortunate explosion in Boston, it got me to thinking hard about how people prepare for emergencies, and if they are prepared for them at work. If a tornado were to plow into your town, where would you take shelter if you were at work? Are your employees prepared? Are you prepared not only for fires and explosions, but all types of emergencies such as weather-related events, chemical spills, medical emergencies, earthquakes, domestic violence, and even major computer system outages? An emergency can threaten anyone, anywhere, anytime!
A written plan must be kept in any workplace with 10 or more employees and should be available for employee review at any time. Well-developed emergency plans and proper employee training will result in fewer and less severe workplace injuries during emergencies. The purpose of an Emergency Action Plan is to facilitate and organize employee actions in the event of a workplace emergency.
Almost every place of business is required to have an emergency action plan. If you have an EAP plan, is it current? The plan is no good if employees are not trained on what to do in an emergency. The time to decide what to do when the emergency hits is NOT when the emergency hits, but well beforehand.
STEP offers services to help prepare your facility in the event of an emergency. Contact us to help prepare you for an emergency!
Raea Hounshell
EHS Safety Consultant



There have been a number of huge changes to the Hazard Communication Standard (HCS) recently. Are you ready?


This is the year you'll need to train employees on how to read and understand GHS formatted safety data sheets (SDSs) and labels. If you haven't done so already, now is the time to lay the groundwork for compliance.


The hazcom standard applies to almost every organization and employer covered by OSHA regulations. It applies to manufacturers, importers, and distributors of hazardous chemicals, and to employers with employees exposed or potentially exposed to hazardous chemicals in general industry workplaces, shipyards, marine terminals, long-shore operations, construction sites, and certain agricultural workplaces.


Here are 6 helpful tips that can help ensure compliance with HazCom and the protection of your employees:


  • Identify all hazardous chemicals in the workplace and make sure they are properly labeled.
  • Develop a written hazard communication plan, including a list of the hazardous chemicals you've identified, procedures for communicating hazards, the names of the individuals in the organization responsible for managing the program, and so on. Review your plan periodically and keep it up to date with changes in the workplace and changes in hazards.
  • Post safety signs wherever they are needed to warn employees of chemical hazards.
  • Ensure availability of SDSs and accuracy (SDS files should be updated as needed). Employees should have access at all times to the SDSs they need.
  • Train employees to recognize substances that are hazardous, understand the hazards, understand GHS-compliant labels and SDSs, take proper precautions to prevent exposures and other incidents, and report spills and other problems related to hazardous materials in the workplace. You only have until December 1 to train employees on GHS labels and SDSs.
  • Make sure that employees for whom English is a second language fully understand hazards and required precautions. Translate written materials and/or use translators to ensure comprehension if necessary.


We offer compliance consulting and assist petro chemical, manufacturing and general industry clients with 40 CFR 112 SPCC Plans.
Since December 1973 the EPA has used the requirement for SPCC plans as a critical part oil spill prevention. The main emphasis of the regulation is the ”prevention” part as opposed to the after-the-fact response requirements. Owners and operators of facilities engaged in drilling, producing, gathering, storing, processing, refining, transferring, or consuming oil or oil products must comply providing the facility:
·         Is non-transportation related
·         Has aboveground storage capacity in excess of 660 gallons or an aggregate storage greater than 1,320 gallons
·         Has a below ground storage total capacity greater than 42,000 gallons
·         Due to their location could reasonably expect spilled oil to reach US waters
A spill contingency plan is required as part of the SPCC Plan, but the objective is to not have the initial “spill”. A SPCC Plan is a well thought out plan, prepared with sound objective data and requiring full approval and “buy-in” from top management. These plans, while following general topics, are unique to each facility. EPA’s November 2011 SPCC field inspection and plan review checklist is incredibly helpful to environmental folks in the development or on-going compliance of implementing a SPCC plan. This SPCC checklist can also be used as a partial compliance checklist to make sure items are complete and up-to-date.
EPA periodically performs inspections to assure compliance with the SPCC Plan regulations. If a discharge occurs – in excess of 1,000 gallons in a single event or two discharges occur in “harmful quantities” within any twelve month period, the facility responsible person must submit copies of the plan to the Regional Administrator or to the State water pollution control agency. 
You must keep a complete copy of your SPCC Plan at your facility and ensure that it has been certified by a professional engineer per 112.3(d). EPA requires that a SPCC Plan be available to the EPA for on-site review and inspection during normal working hours.
Common SPCC violations include:
·    No Plan at all. [40 CFR 112.3 (a) or (b)]
·    Failure to prepare and implement SPCC plan, specifically failed to include all elements of a complete plan as required by SPCC regulations. [40 CFR 112.3 (c)]
·    Plan not PE certified. [40 CFR 112.3 (d)]
·    Plan not reviewed/updated every three years. [40 CFR 112.5 (b)]
·    Plan does not include all oil on facility, i.e., transformers, hydraulic systems, emergency generators, drum storage, etc. [40 CFR 112.7 (e)(2)]
·    Plan does not accurately identify, from each oil storage location, the detailed path spilled oil would take to reach a waterway, i.e., a typical facility is so wide, drainage may flow in different directions, to different receptors, especially in urban locations. Drains not traced out. [40 CFR 112.7 (e)(1)]
·    Designated staff does not conduct regular walk-through inspections. [40 CFR 112.7 (e)(8)]
·    Small, scattered Above-ground Storage Tanks (ASTs) are not adequately protected from tampering/vandalism. [40 CFR 112.7 (e)(9)]


The New Year generally brings changes for everyone, and I am no exception to that rule. That said, I feel a short introduction is in order. My name is Raea Hounshell, and I am a graduate from Murray State's OSH program and STEP's newest employee. Choosing a safety related career was one of the easiest decisions I have ever made, thanks to my roots. While growing up on my family's farm and working around heavy machinery and day-to-day activities, my #1 question was always, ‘Am I going to get hurt?’ Not only was my personal safety important to me, but I was just as concerned about the safety of my family - which is why after witnessing multiple injuries throughout my life, I found my way into MSU's safety program. And, now I am here at STEP helping others keep themselves and their employees safe and safety compliant. Do you have a safety issue or need help with one of your safety programs? Contact me at (270)753-6529 or email me at raea@stepky.com, and the STEP team will work with you to help you solve it!
On the bright horizon of this brand new year, what are your plans for improved safety? Have you set your goals or made your resolutions? Perhaps setting 2013 safety goals is on your “to-do” list? If not, it should be! Not only does a sound safety plan save lives, it also saves money! Did you know that "maintaining a good safety record for at least two or three years can reduce a company’s workers’ comp and general liability insurance (GLI) premiums by as much as 40%?" (according to Bill Thomas, safety and insurance specialist with National Safety Consulting in Chesterfield, MO). Now that we are talking tangible dollars, do I have your attention?
How do you go about creating your goal plan? For the most part setting goals is fairly straight-forward, though sometimes getting started with plan design and sticking to the implementation of it can be a bit challenging. You must consider both long and short-term goals, along with employee safety and equipment needs. Need assistance getting started? OSHA’s strategic management plan provides a basic outline for helping you set goals and stick to the plan. 
On January 23, we are offering an 8-Hour Industrial Incident Command System training seminar at our Murray location. This seminar is designed to educate not just Incident Commanders, but also command officers who interface with emergency services during an onsite emergency. This seminar includes classroom instruction and table-top drills geared toward helping employees pre-plan safety maneuvers for their organization based on "what if" situations.
Are your 2013 goals set to help you achieve reduced incident rates at your company? Don’t wait to take the first STEP up to compliance; call us today!

Many businesses generate or use hazardous substances that can be harmful to human health and the environment, and most workers are exposed to these substances at some point in the workday.
Most of us know that a safe STEP when handling hazardous goods is to properly store and handle waste. Workers should always use caution when handling and storing waste, making sure not to stack goods or situate them where they will originate any damage.
In regards to proper storage, the facility used for storage must be properly inspected at a minimum of weekly. If a spill were to occur, spill kits should be readily available for an emergency response.We also know that proper waste documentation is an important part of tracking and maintaining liability for shipments. Workers should be familiar with the documents required for their facility and waste types including EPA Identification numbers issued by the Environmental Protection Agency and Uniform Hazardous Waste Manifests. The transportation of hazardous wastes should be done according to regulation requirements.
 Due to the potential harm that hazardous materials can cause, you must require and document that workers are aware of the safety hazards and proper handling and disposal procedures in order to protect the environment, themselves, and comply with state and federal regulations.
I'm sure that we all know that not all parties are aware of these rules and regulations, or at least all their workers are not aware of them. Even a major corporation such as WalMart can overlook the key principles of hazardous waste. Look and learn from their mistake
Contact STEP for any of your hazmat training needs. We'll be glad to help!


By: Shannon Rule
How many safety incidents did your company record last year? How much money did those incidents cost the company's profit? Perhaps your company's loss control program needs to be re-evaluated. Are you familiar with loss control? Loss control is anything done to reduce loss from the risks of business, which includes:
  • the prevention or reduction of loss exposures
  • the minimizing of loss when loss producing events occur
  • the termination or avoidance of risk
Most people think that loss control deals directly with the bottom line. However, loss control goes far beyond protecting your company's assets by preventing theft and focusing on profit. Loss control is also concerned with people, equipment, materials, and environment.
Loss can happen when your employees are injured and unable to work. It can also happen when your equipment malfunctions and is in need of repair, causing production to stall, resulting in a profit loss. Loss happens when your materials are not up-to-quality resulting in an increase in waste. This can cut right into the bottom line. Last, but not least, environment can cause loss. The environment deals with not only nature, but the employer's premises and other locations where employees are engaged in work-related activities or are present as a condition of their employment. If an accident occurred that made the building unstable, the company would definitely suffer a loss.
How do you manage the risk in your facility?
  • Identify all loss exposures
  • Evaluate the risk in each exposure
    • This includes the severity, frequency, and probability of an incident.
  • Develop a plan
    • What do you do when a risk is found?
  • Implement the plan
    • Put your ideas into action.
  • Monitor the system
    • Does the plan work? Should any changes be made to the plan?
OSHA recommends their Four-Point Workplace Program  when developing your loss control strategy.
OSHA can and will request documentation, through subpoena if necessary, of loss control inspections in the event that your company has an incident. Keeping up-to-date on these inspections may reduce further loss to your company by reducing violation fines.
Loss control is more than preventing accidents. It is the managerial practice of protecting organizational assets (people, equipment, inventory, property, environment, and reputation) thereby enhancing the business mission (profit or service).




Most of our industrial folks involved with hazmat shipping will ship the same several hazardous materials all the time. And yet when an employee changes jobs or leaves the company, so does all that knowledge regarding shipping hazardous materials safely and within compliance. We have developed a Hazmat Shipping Program that allows us or you to customize the information you need for shipping your hazardous material. We can work through specific carrier requirements to help your folks understand what is required before the shipment needs to go out.
This program becomes the blueprint for shipping hazardous materials.



Holiday season is party season - company parties, church potlucks, Christmas pageants at elementary schools, and festive gatherings with friends and families. Each of these occasions requires its own dress code, and like it or not, wearing heals, and/or ties is often the requisite for the occasion. Working in industry is not so very different, because it also dictates its own form of dress code. But unlike party-wear which can be optional, mandatory dress in industry is enforced by OSHA whenever Personal Protective Equipment is involved.
When I was a young child, my father worked at one of the industrial plants in Calvert City, KY. That was long before the dawning of OSHA, and much longer still before OSHA had refined its directive enough to strongly enforce its standards. Back then, there were no company issued respirators, just face masks with disposable foam-rubber inserts that acted as filters. Safety glasses were constructed of heavy metal frames with glass lenses and flip out side panels to protect the eyes between the brow and temple (very attractive, let me tell you!). Usage of either of these forms of personal protective equipment was optional. While most employees did not choose to don any form of PPE, my father did. Always. 
Fast forward to December 2012, and the usage of personal protective equipment is no longer optional. Exposure to carcinogens, metal dust and other forms of eye irritants, hazardous chemicals, and other potentially hazardous conditions demand the usage of various forms of PPE. As a safety professional, it is your responsibility to ensure that your employees are equipped with appropriate PPE to fulfill their job function. As of January 2009, OSHA was granted the jurisdiction of being able to  multiply any fines related to personal protective equipment violations by the number of employees, rather than issuing one practice-wide citation. Non-compliance is not only not optional, it's not cheap!
So, how do you know if your employees are properly dressed? The OSHA standard for PPE gives a general overview of PPE requirements. Additionally, OSHA has also published  supplementary information for download that helps employers gauge the types of PPE needed in order to be compliant. If you are still unsure whether or not you are in compliance, give us a call, we can help.
I remember thinking as a child how funny I thought my Daddy looked in those cumbersome old glasses and mask. As it turned out, he only worked in that plant for six years and had to quit because of a back injury unrelated to his job. It can't be said whether it was because of his choice to wear the PPE, because of his shortened tenure in that position, or because he never smoked, but as it turned out, he was one of only two men in his work unit (totaling about twenty men) that did not eventually die from cancer and/or lung disorder. There is no question that wearing proper PPE saves life and limb. The question is: are your employees dressed for the occasion?



Over the last 25 years I have met a group of the some of the greatest folks – those employees designated for chemical emergency response and confined space rescue. I have been amazed by some of the “tough” places industry expects these men and women to go.
OSHA has printed several interpretive letters on the matter of safety for these responders and has promulgated several standards to follow when organizing and training a team. OSHA states that “no citation may be issued to an employer because of a rescue activity undertaken by an employee of that employer with respect to an individual in imminent danger unless:”
  1. The employee is designated or assigned by the employer to have responsibility to perform or assist in rescue operation, and
  2. The employer fails to provide protection of the safety and health of such employee, including failing to provide appropriate training and rescue equipment; or
  3. The employer failed to instruct employees not designated or assigned to perform or assist in rescue operations of the arrangement for rescue, not to attempt rescue, and of the hazards of attempting to rescue without adequate training or equipment.
On the face of things this seems easy, but for those of us who are part of emergency and rescue teams
We know this is a GREAT amount of time and energy kind of thing to do. An effective emergency team must have at least these 10 items:
  1. Someone in charge
  2. Written feedback loop for team comments and responses/actions to these comments
  3. Written procedures that change based on team and management input
  4. Adequate equipment
  5. Equipment inspections
  6. Equipment upgrades, as needed
  7. Training guidelines that build on each year’s training
  8. Understanding the levels of training you must have
  9. Adequate and consistent training
  10. Understanding of the ICS by all management
  11. Redundancy built in via team roles and communication systems
OSHA does not tell you what you must have for your responders – they simply say it must be adequate and enough to let your responders do the job you ask them to do!



By: Tammy Wade, STEP


In order to create and maintain a solid, effective ESH  program at any company, you must incorporate and execute a variety of training options for your employees. Certainly, nothing replaces the effectiveness of person to person, site-specific, hands-on ESH  training for delivering core  information and regulatory  updates. But there are times when it is necessary to supplement the information  delivered by this type of training or when you need to deliver the same training repetitively. This is where a training video or CBT can help you. So what are the differences between videos and CBTs? Let's take a look at each.
What is a CBT?
CBTs or Computer Based Training modules are generally site or topic specific, and are available to be administered whenever the training coordinator desires. CBTs are  computer-based modules that train users on a specific area of interest, like how to use a fire extinguisher, or the safety requirements of a contractor working at your facility. The possible topics are limitless. The beauty of a CBT is that as a single-user training, the user controls the pace of delivery, advancing section-by-section at their own rate. CBTs may contain assessments at the end of the module or at set points within the module. CBTs may contain any combination of video clips, audio clips, still photos, and/or text. Depending on how savvy your requirements, CBTs can reside either on a company computer, a CD or DVD, or can be maintained at aLMS (Learning Management System) site. CBTs can either be site-specific or general.
Training videos have been used for decades. They are excellent tools for delivering either general or site-specific ESH  information to a larger group of participants  than the  CBTs we just discussed. There are a limitless number of general safety training videos available for purchase. The best choice for video training, however, is one that is site specific and uses media (videos, audio, still photos) from the company's actual operation. Video training that incorporates actual media from your company to train future employees, visitors, or contractors bring a level of realness to the information being delivered, and better fulfill OSHA's requirement for site-specific training. Like CBTs, video training modules can incorporate any combination of audio, video, text and still photos. They are generally deployed either via DVD or awindows-formatted video file, or may be uploaded to the internet or stored on a company's intranet.



You are subject to SPCC rule if:

  • You are a non-transportation-related facility that distributes, drills, gathers, produces, processes, refines, stores, transfers, uses, or consumes oil and oil products; and
  • You have above ground storage capacity > 1,320 gallons or completely buried storage capacity > 42,000 gallons and there is a reasonable expectation of a discharge into or upon navigable waters of the US or adjoining shorelines. Read more


  • STEPs open seminars. More...
  • October is Breast Cancer awareness month - hat's off to the survivors and those we have left us
  • November 10, 2011 is EPA final deadline to amend or develop Spill Prevention Control and Countermeasures (SPCC) plans.
  • OSHA's new Safety and Health Training Resources page was developed to help users locate occupational safety and health training materials.
  • 4,547 workers died on the job in 2010

Mention “Fall Protection” and one can easily conjure up images of workers bravely risking life and limb 20 feet, 30 feet or higher above solid ground -- their safety guaranteed only by a few buckles, a lanyard and body harness. Of course, the above does not reflect the realities of fall protection. A properly implemented fall protection program limits the risk of falling from a walking/working surface four (4) feet or higher to a lower level by providing appropriate training in recognizing fall hazards and using fall protection systems and equipment.

Fall hazards may exist at any facility. In fact, falls are the leading hazard at work. Because all facilities are not the same and working conditions vary, OSHA has provisions within their standards allowing contractors to create a Fall Protection Plan for a specific site. This plan would then become part of our Fall Protection Program. It is important to note that a Fall Protection Plan can only be used when conventional systems provided within the standard (guardrail systems; personal fall arrest systems; safety net systems; positioning device systems; warning line systems; controlled access zones; and safety monitoring systems) are not feasible.  

Fall protection also concerns the falling of objects from any height. The mandatory wearing of hard hats, toeboards on scaffolds, and controlled access zones aid in the protection of workers where falling objects present a potential hazard.

It is interesting to note that fall protection standards do not apply directly to ladders and scaffolds. Scaffolds and ladders have their own safety requirements which, when followed, prevent falls.

You must be aware that on multi-employer work sites, fall hazards (primarily falling objects) may be created by other employers. Stay out of controlled access zones and wear a hard hat at all times.  Understand that when working at a height of four (4) feet or over, a fall protection system must be used.

Safety equipment such as harnesses, ropes, and lanyards used as personal fall protection devices must be used for no other purpose such as lifting materials.

It should be noted that effective January 1, 1998, body belts are not acceptable as part of a personal fall arrest system. However, they are acceptable as part of a positioning device system.

Falls from a height of four feet or more can result in very serious injury. Be aware of fall hazards and never work without fall protection if a fall hazard exists. The most effective fall protection programs start with an assessment. We have provided a fall protection checklist, to help you implement or more effective program or put a check on your current safe work practices.

by: Sara Fineman
We all strive for zero injuries and illnesses. That is a lifelong goal of most ESH professionals. And yet, how well are we doing? NIOSH recognizes that injuries continue to significantly impact workers. Since the enactment of the OSH Act, workplace injures/illnesses have declined. In 2006, BLS statistics tell us that 5,840 workers died compared to 2010, where BLS reports 4,547 fatalities (about the same as 2009).
Researchers have begun to better understand the impact and burden injuries/illnesses have on the job as well as off work. Charlie Morecraft, in his “The Best of Charlie” says it most clearly, “it is not only the two years  I spent in the hospital, from my workplace accident, it is the two years of hxxx I put my family through.” NIOSH research shows that worker compensation costs reflect only a portion of the actual cost related to injuries.   Some of the off-the-job issues include; long term relationship hardships; domestic changes due to inability of the injured to do certain tasks; financial changes causing family hardships, and shifts in the family dynamics, etc. In other words, the total person must be assessed including the environment the person lives in to really understand the impact an injury has on a worker.
In a current, outstanding article by J. Paul Leigh and colleagues (based on a considerable body of research that deals with these “total person” issues and the impact of injuries / illnesses), Leigh concludes that “The costs (of injuries/illnesses) are enormous and continue to grow. The health risks are high, given that most people between the ages of 22 and 65 spend 40 percent of their walking hours at work.” Dr. Leigh’s  research  reports that injury/illness costs are:
8,564,600 fatal and non-fatal work related injures = $192 billion
516,100 fatal and non-fatal work-related illnesses = $58 billion
Why do we need this type of information? The most obvious reason is to help promote workplace injury/illness prevention. There are many techniques the ESH professional uses that may not be completely understood by those not in the field. It is our job to help educate all management to understand that prevention far out-weighs the hefty price of an injury/illness. We can teach and reinforce accident prevention through behavior based techniques; job hazard analysis; safety committee involvement; OSHA’s S&H Management Guidelines; and equalization of safety to production.

(a personal look at machine guarding)

 by: Tammy Wade
Most manufacturing facilities utilize pieces of machinery that have moving parts, and anywhere there is machinery with moving parts being operated by humans, there is potential for injury. These potential injuries include things like crushed bones, eye and skin injury, burns, asphyxiation, and even death . Many, if not all, of these types of injuries are preventable, and OSHA has regulations in place designed to provide guidelines for companies in their endeavors to facilitate proper machine guarding.
Fresh out of college, and without a job offer in my chosen major, I worked night shift for a few months on an assembly line in a light fixture manufacturing plant. I was as unknowledgeable as one could be of the operations and potential dangers of a manufacturing environment. While OSHA may have been birthed a decade before, I doubt any inspector had ever shadowed the door of that facility. On my first night of work, the shift supervisor, Charlie (a weathered, grumpy old man), stationed me at the first position of an assembly line that was running chandeliers. My job was to place a chandelier arm in a press, correctly position it onto the joint of the body of the chandelier, and push the button that engaged the press and melded the two pieces together. There were five arms per chandelier, and we had a quota to run. I was eager to make quota.
Not once did Charlie explain the potential dangers of operating a press - nothing about the pounds of pressure, the statistics on dangers, or cautions that should be taken. And there was certainly no type of machine guarding in place; there was just me and the press. There was no safety talk, either - at least not until two hours later when Charlie chanced by just at the moment I allowed my right-hand pointer finger to lie too closely to the press's die so that when I pressed the button, the press plate pinched the outer edge of my finger. In an instant, a chunk of my skin was missing, my finger was bleeding, and I was stunned. The press had barely missed my nail. I had no idea until that moment just how unforgiving moving machinery could be.  I was lucky. A fraction of an inch further, and my right hand would have been irrevocably marred and the pain would have been much worse. Not everyone is so lucky.

And what did Charlie do? He just said something like "you need to watch that; you could lose a finger!", and then made his way back to his office. THAT was my safety talk.
That was 1986, and while OSHA has gotten more stringent (with surprise inspections and enforced standards) machine guarding injuries still occur regularly. According to the Bureau of Labor Statistics, "during the period 1992-99, there were on average more than 21 fatal and more than 11,000 nonfatal workplace amputations annually (resulting from improper machine guarding)". EHS magazine states that during FY 2010, "24 percent of OSHA's Top 10 citations for manufacturing dealt with machine guarding violations. Those violations resulted in more than $6 million in proposed penalties. Most of the violations were judged as serious violations, which can carry a penalty of up to $7,000 per instance."
These types of injuries are preventable. As a company, it is your legal duty to ensure that proper machine guarding procedures are followed, and that your employees are trained on the correct procedures for operating machinery with moving parts. Knowing and enforcing OSHA's machine guarding standard saves lives, limbs, and money, and it's the right thing to do!

Ladder safety is a serious issue. Although we think the usage of a ladder is a basic part of the work environment, failure to observe some basic safety rules can be dangerous or fatal


These simple steps will help to eliminate ladder accidents.


Choose the Right Ladder

             Type I - Industrial: heavy-duty with a load capacity of no more than 250 lbs.

             Type II - Commercial: medium-duty with a load capacity not more than 225 lbs.

             Type III - Household: light-duty with a load capacity of not more than 200 lbs.

Correctly Use the Ladder

             Secure the ladder-properly.

             Make sure ladder extends three feet past the platform being climbed to.

             ALWAYS face the ladder.

             Do not climb higher than the second rung on stepladders or the third rung on straight or extension ladders.

             Hands should be free of material while climbing ladders.

             Utilize the 4-1 ratio.

Visit our Free Resources section of the website, and download the Ladder Safety tool box talk.

As soon as you set foot on the ladder's first rung and pull your body off the ground, gravity works to bring you back to earth. Therefore, it's no surprise that ladder safety begins from the ground up.


Do your employees handle or manufacture hazardous materials or chemicals? Do you have a staff of employees who are properly trained on how to respond to a chemical release should an accident occur? OSHA says you must. According to OSHA, the Hazwoper standard applies to five distinct groups of employers and their employees. This includes any employees who are exposed or potentially exposed to hazardous substances including hazardous waste -- and who are engaged in one of the following operations as specified by 1910.120(a)(1)(i-v) and 1926.65(a)(1)(i-v): Those five groups as stated by OSHA are:
  • clean-up operations -- required by a governmental body, whether federal, state, local, or other involving hazardous substances -- that are conducted at uncontrolled hazardous waste sites;
  • corrective actions involving clean-up operations at sites covered by the Resource Conservation and Recovery Act of 1976 (RCRA) as amended (42 U.S.C. 6901 et seq.);
  • voluntary clean-up operations at sites recognized by federal, state, local, or other governmental body as uncontrolled hazardous waste sites;
  • operations involving hazardous wastes that are conducted at treatment, storage, and disposal facilities regulated by Title 40 Code of Federal Regulations Parts 264 and 265 pursuant to RCRA, or by agencies under agreement with U.S. Environmental Protection Agency to implement RCRA regulations; and
  • emergency response operations for releases of, or substantial threats of releases of, hazardous substances regardless of the location of the hazard.
Initial Hazwoper training should be a hands-on 24-Hour presentation on the various aspects of proper procedures for dealing with the handling and cleanup of hazardous chemicals. Followup refresher training should be performed each year. Often, we are asked "what if it's been longer than a year since our 24-hour training, do we have to repeat the 24-hour training or can we just take a refresher?"   
OSHA answers this question in this manner:   
If the date for refresher training has lapsed, the need to repeat initial training must be determined based on the employee's familiarity with safety and health procedures used on site. The employee should take the next available refresher training course. "There should be a record in the employee's file indicating why the training has been delayed and when the training will be completed."  
If you have on-site workers who are not directly involved in cleanup activities, OSHA has special regulations to cover those workers as well.


(29 CFR 1910.1200) is, once again, the most cited violation in General Industry in 2011. Respiratory Protection (29 CFR 1910.134) comes in second and Lockout/Tagout (29 CFR 1910.147) follows close behind. Here are some tips to avoid these citations in your facility:

·         Be sure all chemicals are clearly labeled. (29 CFR 1910.1200(b)(4)(i))
·         Fully prepare MSDSs and make them available to employees. (29 CFR 1910.1200(b)(3)(ii)) for more information
·         Keep all respiratory equipment properly cleaned and maintained. (29 CFR 1910.134 App B-2)
·         Be sure all employees are properly fitted to their respiratory equipment. (29 CFR 1910.134 App A
·         Ensure that the LO/TO procedures are properly developed. (29 CFR 1910.147(c)(1))
·         Periodically inspect energy control procedures. (29 CFR 1910.147(c)(6)(i))
Let us help you stay in compliance and avoid costly violations.





  • OSHA has submitted to the White House Office of Management and Budget (OMB) the draft proposed rule to align the current Hazard Communication Standard (HCS) with Globally Harmonized System for Classification and Labeling of Chemicals (GHS). If OMB does not request an extension of the typical 90-day review period, we can expect to see a final rule in February 2012. 
  • Acetylene Standard has been finalized and will be published in Spring 2012. This will update 29 CFR 1910.102, based on the most recent Compressed Gas Association and NFPA standards. 


The wide assortment of dangerous goods that can be manufactured and/or distributed is limitless and the methods for shipping them are also varied. The U.S. DOT requires that all persons who are involved with shipping and/or preparation of hazardous materials must have appropriate training, though determining exactly what training is required for your employees can be daunting.
The U.S. DOT regulations that govern the movement of hazardous materials are contained in 49 CFR Parts 100-180. Employees who ship hazardous materials must meet the U.S. DOT training standard. If the shipments will be made via air or sea vessel, they must also be trained on the IATA (International Air Transportation Association) and/or IMDG (International Maritime Dangerous Goods) Code. The nature of this training should be "to the extent such training addresses functions authorized by 49 CFR Part 171 Subpart C". How much training depends on what tasks are performed by your company. The International Air Transportation Association (IATA) outlines training requirements in subsection 1.5 of the IATA Dangerous Goods Regulations (DGR).
As for frequency, the U.S. DOT (under 49 CFR 172.704(c)(2) requires that training be repeated in its entirety every three years. Should an employee's job responsibilities change during that three year period, then the employee's training must be updated. The rules of enforcement that govern training are stringent. Employees who are not trained by the three year deadline may not legally perform any hazamt employee functions. Additionally, IATA requires a refresher training within 24 months of the initial training (IATA While this IATA deadline is not legally enforceable, some air carriers may refuse shipments from companies whose employee training is not up-to-date.
Penalties for non-compliance can be stiff. In fact, civil penalties for violation of DOT regulations can be as high as $55,000 per day per incident. Criminal penalties top the scale at $250,000 per day per incident and five years in jail (for individuals) and up to $500,000 per day per incident for organizations.
We are often asked by companies if their employees must have DOT (49 CFR) training if they have already had IATA (Or IMDG) training. The answer is yes. There are many DOT rules and requirements found in 49 CFR that shipments must meet. The DOT allows hazardous material shipment under IATA Dangerous Goods Regulations (for air shipments) provided the shipment complies with the additional DOT requirements (listed at 49 CFR 171.22, 171.23, and 171.24).
The bottom line is that if you are involved with packaging or shipping hazardous goods, you are required to be trained on 49 CFR. If those shipments are sent via air or sea, you are also required to be trained on IATA and/or IMDG. And, your training must be kept up-to-date. Potential penalties for non-compliance are too stiff to ignore!


As many of us know, the addition of GHS was a significant change. In fact, it was so significant that it impacted several other OSHA standards in both general industry and construction.
In the fiscal year of 2011 there were more than 80 serious violations that occurred related to Class I liquids (dispensing). In May of 2012 regulations related with Hazcom were modified due to reflect the new Globally Harmonized System. The changes were far from massive, but were necessary in OSHA's eyes in order to be consistent with the GHS criteria.
But 1910.106 (1926.152) was seriously revised with a revamping of the old "classification" of flammable and combustible liquids. This means MANY written programs, procedures, and training materials regarding flammable and combustible liquids may require some pertinent revisions.
For example, the old 1910.106 defined a "combustible liquid" and a "flammable liquid". Now we NO LONGER use the term "combustible liquid" nor will we use the term "Class" when defining the levels of flammability/combustibility. In fact OSHA revised 1910.106, 1910.107, 1910.123, 1910.125, 1926.152, and 1926.155 to remove the term and references to "combustible liquids" and to reference the Flammable Categories as 1-4 instead.
However, the new HAZCOM standard still requires the hazard statement "combustible liquid" on the label for Category 4 Flammable liquids (flashpoint greater than 60C (140F) but not greater than 93C (199.4F).
 For more information check out the OSHA General Industry Digest. To search interpretations of 1910.106 visit here.
Below is a table with a side-by-side comparison between the old and new definitions.



Day-to-day activities in every business present situations and scenarios that may be identified as safety hazards. While conscientious safety managers may make every effort (known to them) to ensure complete OSHA compliancy within the company, sometimes that does not happen, resulting in potential dangers (both known and unknown) that are not addressed or corrected. Many times, OSHA inspectors drop in for an unscheduled visit, cite points of safety concerns, and often fine the business for non-compliance. This leaves management and safety personnel wondering of OSHA, "Who told you?"
Sometimes, it's OSHA's inspection priorities that prompts a surprise inspection, sometimes it's because of a recorded incident, and sometimes, it's because an employee files a complaint or concern (valid or invalid) with OSHA resulting in a follow-up inspection. An employee who contacts OSHA to reveal a perceived safety hazard is referred to by OSHA as a whistleblower.
As an employer, you should be aware that OSHA's Whistleblower Protection Program was designed to protect employees from discrimination and/or retaliation resulting from informing OSHA of a company's safety pitfalls. This serves as protection for employees from such actions as firing or laying off, disciplinary actions, intimidation, and threats just to name a few. Employees have a right to contact OSHA at will with a safety concern, and OSHA has a right to either embrace or deny that concern. As an employer, you must respect those rights. There can be no retaliation against whistleblowers.
According to OSHA, "..if workers have been retaliated or discriminated against for exercising their rights, they must file a complaint with OSHA within 30 days of the alleged adverse action." So, what are the repercussions when a company discriminates against whistleblowers? If OSHA determines that the employee's complaint is valid, OSHA may respond with further citations and/or fines.
How can YOUR company safeguard against an unfavorable OSHA inspection? The best preventative measure is to ensure that your safety programs and procedures are comprehensive, compliant, and up-to-date, and that your employees are adhering to those programs and procedures. Scheduled safety audits should be performed consistently. If you do not have staff who can perform a sound safety audit, hire a professional to do the audit for you. When safety hazards are identified by the audit, correct the point(s) immediately! Don't wait until a whistleblower tells OSHA, or even worse, an accident claims a victim. And when your employees address you with a perceived safety concern, find out whether or not their concern is valid. If it is valid, fix the issue! Never ignore the concerns of your employees.  
Compliancy takes a lot of work, but the payoff in saved lives and eliminated fines is huge!


Is your OSHA Recordkeeping Summary posted?
Posting dates (February 1st- April 30th)
New Recordkeeping Rules and Tools!
It can sometimes be overwhelming and somewhat perplexing determining what should be recorded, and what should be reported to OSHA with the new changes to the 1904 Recordkeeping Standard. This is especially difficult, if you are someone in a new position tasked with the responsibility of keeping your company in compliance with these records.
There has been one major change for "reporting" in KY as of January 1, 2016, and that is the addition of a "loss of an eye" (see KY OSHA notice).  Note: if you're not in KY, and need your state's reporting requirements, call us!
All employers in KY must report incidents shown below within the time frame indicated:
         1.     All work-related fatalities (including heart attacks) within 8 hours.
         2.     All work-related inpatient hospitalizations (3 or more) within 8 hours.
         3.     All work-related inpatient hospitalizations (less than 3 employees); all amputations;
                 and all losses of an eye, within 72 hours.
You can report to OSHA by:
        1.    Calling your closest KY Area Office during normal business hours
               (8:00 a.m.-4:30 p.m. EST) (502) 564-3070 . 
        2.    Calling OSHA's free and confidential number hotline at 1-800-321-OSHA (6742).
        3.    The online form reporting form is not available for KY at this time.
KY OSHA's website provides an easy decision tree to determine which injuries/illnesses should be called in and reported to OSHA. Click on this "Decision Tree" for a  understandable diagram that provides the information you need in making a determination for reporting.
Also, see this Special Edition Newsletter from federal OSHA which shows how the reporting requirements have already changed the focus of 1904 Recordkeeping in the past year.
For specific KY industry sectors newly required to keep injury/illness records starting January 1, 2016, click here .
Remember to post your Annual Summary (300- A) February 1st- April 30th of each year! All job-related injuries and illnesses that were logged on the 300 Form must be displayed in a common area where all employees have access, even if you by did not acquire a recordable injury/illness in the past year.    
STEP is here to help you with your Recordkeeping requirements, and many other ESH services! Call us today (270-753-6529) to step up to compliance!


What Can YOUR IH Management Plan do for YOU?

Did you know there are benefits as to what an Industrial Hygiene Management Plan can do for you? 
Check out the top 5 benefits that can help your workplace remain safe and compliant:
1. Compiles all industrial hygiene sampling in one location
2. Prioritizes containment/health hazards by location
3. Easily pinpoints problem areas
4. Helps protect workers
5. Protects management/owners by reducing costs
Who will benefit:
  • Employees
  • Management
  • Safety Professionals/ Risk Management
  • Company Owner(s)
For questions about IH Management Plans, or to view a sample contact us!
STEP can complete an IH management plan for you. STEP has an IH consultant with over 21 years of experience. Contact us today for information!

 Industrial hygiene surveys and employee exposure monitoring are essential when determining if health hazards are a real or potential issue. OSHA requires you to know the types of contaminant hazards in your workplace, and determine if those constituents are exceeding OSHA's permissible exposure limits. You are also required to know the noise levels in your facility and ensure that your employees are properly protected.

Our consultants have worked with clients for over 30 years, conducting exposure assessments and establishing sampling strategies to determine if chemicals being used by employees are a health concern.
Our Monitoring Projects include:
  • Sampling strategy based on a SDS review and job task exposures.
  • Personal and area sampling of contaminants in your workplace.
  • Interpretation of the results.
  • Onsite observations taken during monitoring provides us with an understanding of the source of exposures.
  • A report with recommendations to help your company work toward compliance.
Through the use of our Industrial Hygiene Management Plan, we help you determine sampling priorities. We use all well recognized IH protocol/practices to review & calculate exposures to potentially hazardous chemical, physical, and biological agents. Noise monitoring results can also be included in this plan.
Our Management Plan includes:
  • Defining concentrations of contaminants and changes in potential employee exposures by area and job tasks.
  • Evaluating, prioritizing and controlling exposures that present health hazards.
  • Documenting exposures and control efforts, and helping to communicate the results with affected employees.

We offer 1 to 1.5 hours of free onsite time to review your IH program and needs.
If you are questioning a potential issue within your work place give our team a call at 270-753-6529.


A fire is a scary thing. Most people will either run from the building or stay and try and fight the fire. The
truth is, there are many people who do not know how to properly use a
A fire consists of three components:  oxygen, heat, and fuel. These three components combine to create a chemical reaction, but if one of these three are eliminated, the fire will die out. A fire extinguisher works by getting rid of one of the components, thus killing the fire.
There are five types of fire extinguishers:
  • Type A, used on fires involving combustible materials such as wood, paper, cloth, etc.
  • Type B, used on fires involving liquids, greases, and gases.
  • Type C, used on fires involving electrical equipment
  • Type D, used on fires involving metals
  • Type K, used on kitchen fires
Are employers required to train their employees on fire extinguishers? The answer is yes, unless the employer has established a safety plan that requires all employees to evacuate as soon as the fire alarm sounds. If this is not the plan, the employer must provide extinguishers and keep the employees trained on how to use the extinguisher. Remember the acronym PASS.
  • Pull the safety pin. (This will also break the tamper seal)
  • Aim low and point the extinguisher at the base of the fire.
  • Squeeze the trigger to release the extinguishing material.
  • Sweep the extinguisher from side to side until the fire is out.
If the extinguisher becomes empty and the fire is not out, evacuate immediately.
A fire is not something to play around with. Educate your employees on the proper use of extinguishers, as well as the nearest exit point. Taking the time to do so may save lives.


It's just dust. How could it be dangerous, let alone explosive?


Any combustible material can burn rapidly and explode in a finely divided form. Facilities that intentionally manufacture powders as well as those that incidentally generate them through handling and processing solid materials are potentially subject to combustible dust hazards.


Common types of combustible dusts include various metals, wood, plastic, rubber, coal, flour, sugar, and paper. By no means is this a comprehensive list, but is a starting point for determining what sorts of dusts may present danger. For a partial list of identified combustible dusts, please refer to OSHA's Combustible Dust Information Poster. 


It is critical for safety managers responsible for facilities where combustible dust hazards exist to take a close look to determine if all of the necessary components of a dust management and control program are in place.

Although this can be a challenging task, if you follow some proven steps, you can develop an effective program that will protect employees, company assets, and keep your organization out of the headlines!


There are many ways to keep dust under control. Some of these methods include:

  • Control ignition sources
  • Practice good housekeeping (Click here for a FREE toolbox talk on housekeeping) 
  • Collect and segregate dust at the point of generation
  • Conducting regularly scheduled inspections
  • Using proper dust collection systems and filters
  • Keeping dust from escaping from equipment or ventilation systems
  • Using surfaces that are easy to clean


There have been a number of high visibility explosions and as a result both federal and state OSHA agencies have focused more resources on industries where combustible dust is a health, safety, and explosion concern.



When it comes to safety in the work place, we tend to spot the most obvious hazards: chemicals, falls, and poor housekeeping to name a few, but what about machine guarding? Many times, people tend to remove machine guards in an attempt to make the job easier or quicker. However, this can be a dangerous, even fatal, mistake.
Beware of the most common types of hazardous machinery motions and actions:
·         Rotating motion
·         Transversing motion
·         In-running nip points
·         Reciprocating
·         Cutting action
·         Punching action
·         Shearing action
·         Bending action
 These motions and actions can easily grab a worker and pull him/her into the machine. Workers should take care to keep limbs, hair, clothing articles, tools, and any other objects away from machine parts that make these actions.
Your facility should develop a checklist of safety procedures and precautions to protect your workers from cuts, amputations, crushes, and possibly death. There are a few minimum guard requirements that your facility should have implemented. Machine guards should:
·         Prevent contact
·         Be secured to the machine
·         Protect from falling objects
·         Create no new hazards
·         Create no interference
·         Allow safe lubrication
Remember that machine guards are only effective if they are left in place and used correctly. 



A lot of people use ladders on a daily basis, many times in an unsafe way. Most of us don’t think twice about pulling a ladder out and stepping onto it, without doing any type of functional check. There are several things that should be checked before getting onto a ladder.
For starters, always check to make sure your ladder is in good condition. Are the rungs secure and free from debris? Are the feet sturdy and placed on a flat, sturdy surface? Are the side rails in good condition and not splitting or cracking? A ladder in poor condition greatly increases your chances of injury.
Keep in mind a few pointers for keeping yourself safe while on a ladder:
·         Always maintain three points of contact while on a ladder.
·         Never stand on the top rung of a ladder.
·         Always face the ladder when climbing up or down.
·         Leaning ladders should always extend at least three feet above the top platform.
·         Never allow more than one person at a time on a ladder.
·         Make sure the weight your ladder is supporting does not exceed its maximum load rating (user plus materials).
·         All metal ladders should have slip-resistant feet.
·         Be sure all locks on extension ladders are properly engaged.
·         Keep your body centered between the rails of the ladder at all times. Do not lean too far to the side while working.
If you think ladder safety is something you shouldn’t be concerned about, think again. One wrong step could mean serious injury or even death.
In a Bureau of Labor Statistics study of 1,400 ladder accidents that resulted in injuries the following findings were made:
66%     of those injured had not been trained in how to inspect ladders for defects before using them;
61%     had not been secured at the top
53%     of the non-self-supporting ladders had not been secured or braced at the bottom;
53%     of the ladders involved in the accidents broke during use
42%     of those injured were working on the ladder when the accident occurred;
39%     of the ladders involved in the accidents had not been extended three feet above the        landing level;
23%     percent of the accidents were in construction;
19%     percent of the ladders involved in the accidents had one or more defects and
4%       percent of the ladders involved in the accidents did not have uniformly spaced steps


Many people view Lockout/Tagout (LO/TO) as a waste of time, assuming that they will be safe from harm because they will only be working on the machine for a minute or two. That is  not always the case (Read Doug's Story). Oftentimes, serious injury or death can occur before the worker has time to react to an unexpected machine energization or user error. This is why every company should develop and utilize LO/TO procedures.
OSHA enforces LO/TO as a way of protecting employees from unexpected start-up of machinery or equipment during service or maintenance activities. All companies should have a LO/TO procedure developed and the procedure should be implemented by all employees. Every employee needs to be fully trained on the company's LO/TO procedure, and follow the procedure at all times, even when the task will take just a minute.  Performing periodic audits is a way to help ensure facility compliance.
In order to have an effective LO/TO procedure, you must be sure to:
  1. Identify the energy source(s)- some machines may have more than one source
  2. Isolate the energy source(s)- cut all power supplies to the machine
  3. Lock and Tag the energy source(s)- let others know that the energy has been disabled for maintenance
  4. Prove that the equipment isolation is effective- test the machine to ensure that all power is gone
The locking and tagging of the isolation point lets others know not to re-energize the device. It should also be stated in your procedure that only the person who locked and tagged the equipment is allowed to remove the tag. The tags also should have identifying marks to show who they belong to.     
Effective lockout / tagout procedures not only saves lives, it saves money for companies due to the minimization of  accidents and down-time. Because of the reduced number of accidents, some insurance premiums will actually offer lower premiums to companies who can show the positive statistics that their lockout program produces.  

This procedure may, at times, seem like a hindrance to productivity. After all, many times it takes longer to perform a LO/TO procedure than it does to actually do the work on the machine. However, knowing that your employee is safe and will be going home that night is enough incentive to faithfully LO/TO equipment every time it is needed.
Reduced injury. Saved dollars. How can your company not afford to have an effective lockout / tagout program in place?


In general, loss control is any combination of actions taken to reduce the frequency or severity of losses (e.g., installing locks, burglar alarms or sprinklers). Often times, people assume it deals directly with loss of profit through theft or damaged property. This is true, but it's more than that. Loss control also covers loss of personnel, property, products, and even the environment. Some factors to consider:
·         Fines from non-compliance 
·         Worker’s Comp
·         Increase in insurance rates due to incidents 
·         Loss of production due to downtime
Preventing these losses is the responsibility of all employees, including management. Most losses are caused by human error. Everyone should work together to ensure that Safe Work Practices (SWP) are designed and followed for each job in the facility. Employees should be thoroughly trained, provided the proper PPE, and encouraged to make suggestions on changes that may result in a safer work environment.


 By: Shannon Rule

The new Global Harmonized System (GHS) is a global method of classifying, defining, and labeling hazardous materials. It takes the current Material Safety Data Sheets (MSDS) and creates a common method of communicating the hazards on Safety Data Sheets (SDS) and hazard labels. In this new method, chemicals will be classified according to the types of hazards they present. The intent of this new system is to make trade among countries easier and quicker. There will be a common labeling method, so relabeling will not be necessary during the trade process.
In the GHS, you will see specific Hazard Classification Criteria. 
·         Physical Hazards
The GHS will standardize labels globally. Hazard Pictograms, Signal Words, and Hazard Statements will be the same all over the world. The labels must also include Product/Supplier Identifier and Chemical Identity, as well as Precautionary Information.  Only two signal words will be used (Danger and Warning) although some labels will not have a signal word. There will also be a standardized set of hazard pictograms. Employers may continue to use their current methods of labeling materials within the facility, if they choose. However, these labels must contain the required information and they must be consistent with the new classifications. All labels will be written in English, although other languages may be added if necessary. 
The SDSs will have a new, 16 part format that must be followed.  (Note: Sections 12-15 may not be mandatory, as they are out of OSHA’s jurisdiction.)
In a March 20, 2012 press release OSHA announced the final rule on GHS. Further information and discussion about GHS from Dr. David Michaels can be found on OSHA's website and/or by attending STEP's GHS Webinar in May.
June 1, 2012               Deadline for manufacturers & importers to modify labels and SDSs
December 1, 2013        Deadline for exposed employees to receive initial training

June 1, 2016               Deadline for employers to update Hazard Communication programs or any other workplace signs


Be prepared – OSHA compliance is. If and when you get an OSHA visit, there are several items that you should have ready. We believe a pre-plan for an OSHA visit. Have a system in place for when OSHA arrives. Here are some tips.

OSHA compliance will:

  • Present their credentials
  • Expect to see a safety video or information before going onsite
  • Lead an opening conference explaining why they are there
  • Conduct a walk through
  • Provide a closing conference

Know ahead of time, who you want to have in the opening and closing conferences. Plan ahead for which person or persons you can call on if OSHA discovers issues. This would be someone who understands the importance of “fixing” the item before OSHA gets offsite.





  • According to the Bureau of Labor Statistics Census of Fatal Occupational Injuries (CFOI), of the 4,547 fatal workplace injuries that occurred in the US in 2010, 506 were workplace homicides.
  • STEP Webinars in November:

             Nov 17 OSHA inspections Nov 17
             Nov 21 DOT hazmat shipping
             Nov 28 Confined space
             Click here for more….

STEP utilizes the National Safety Council’s and the Occupational Safety and Health Administration’s Safety and Health Management guidelines to assist companies with their overall safety and health programs. This system is structured to ensure high standards of safety performance for establishing a winning safety program. These programs have proven themselves time and time again.

OSHA’s guidelines recommend four basic elements:
  • Management commitment and employee involvement
  • Worksite analysis
  • Hazard prevention and controls
  • Safety and health training
This program goes hand in hand with the key characteristics of the NSC’s Safety Management System below which includes:
  1. Management leadership and commitment,
  2. Employee involvement,
  3. Measurement systems, and
  4. Continuous improvement process.



On November 17, 2016 the U.S. Department of Labor’s Occupational Safety and Health Administration issued a final rule for updating walking-working surfaces standards and establishing personal fall protection systems requirements. This update is for general industry walking-working surfaces standards and is specific to slip, trip and fall hazards. This rule also includes a new section under the general industry personal protective equipment standards that establishes employer requirements for using personal protection systems.


The final rule’s most significant update is allowing employers to choose the best fall protection system for their environment. Employers can choose from options including personal fall arrest, ladder safety systems, safety netting, travel restraint, and work position systems. These are great options to have instead of requiring guardrails which the current ruling mandates.

OSHA anticipates that the changes provided in the final rule will prevent 29 fatalities and 5,842 lost-workday injuries annually.


The final rule became effective on January 17, 2017. Some requirements in the new rule have compliance dates after the effective date including:


  • Ensuring exposed workers are trained on fall hazards and the use of fall protection equipment (6 months)
  • Inspecting and certifying permanent anchorages for rope descent systems (1 year)
  • Installing personal fall arrest or ladder safety systems on new fixed ladders over 24 feet and on replacement ladders/ladder sections, including fixed ladders on outdoor advertising structures (2 years)
  • Ensuring existing fixed ladders over 24 feet, including those on outdoor advertising structures, are equipped with a cage, well, personal fall arrest system, or ladder safety system (2 years)
  • Replacing cages and wells (used as fall protection) with ladder safety or personal fall arrest systems on all fixed ladders over 24 feet (20 years)


This ruling will affect approximately 112 million workers at 7 million worksites.


If you need training regarding this new ruling give us a call – 270-753-6529 – STEP up to Compliance!

The deadline for posting the OSHA 300-A Summary of Work-Related Injuries and Illnesses is fast approaching; if you haven’t already sent it to the boss for certification, now’s the time to do so. You must post your 2011 annual summary no later than February 1 and keep it posted through April 30 in a conspicuous place where notices are normally posted. You must also make sure the summary is not altered, defaced, or covered up during that time.
And you must complete and post a 300-A Summary even if you had no recordable injuries or illnesses for that year.
OSHA’s basic requirement for the 300-A Summary at 1904.32(a) tells you that at the end of each year, you must:
1.      Review your OSHA 300 Log to verify that the entries are complete and accurate (and correct any mistakes)
2.      Fill out a summary of the injuries and illnesses recorded on the log
3.      Certify the summary
4.      Post the annual summary
The Form 300-A is used to summarize the entries from the OSHA Form 300 Log of Work-Related Injuries and Illnesses at the end of the year. To fill out the summary, you simply total the columns on the 300 Log.
Other items you’ll need to include are:
-Average number of employees, and the total hours worked by all employees over the year.  (OSHA includes a worksheet to help you figure out the average number of employees and the total hours worked).
Finally, 1904.32(b)(3) explains how to certify the Annual Summary: 
-A Company Executive must examine the 300 Log and declare that he or she reasonably believes, based on knowledge of the process by which the information was recorded, that the annual summary is correct and complete.
A company executive can be:
- an owner of the company
- an officer of the corporation
- the highest ranking company official working at the establishment
- the immediate supervisor of the highest ranking company official working at the establishment.
 OSHA doesn’t go into detail about how to evaluate your recordkeeping system to ensure accuracy or completeness, but expects employers to be familiar with the injury and illness recordkeeping requirements found at 29 CFR 1904.



The National Emphasis Program (NEP) is an inspection program for facilities dealing with Highly Hazardous Chemicals (HHCs) to verify compliance with OSHA’s process safety management standard (29 CFR 1910.119). The program is set up to review employee attendance sheets, disciplinary records, incident reports, accident investigation records, and other company documents. Any third-party workers compensation provider or medical provider will also be asked to submit documentation. 
OSHA has found in past reviews that many companies have an extensive written safety program, but do not enforce and implement the program. The NEP will verify that the company is implementing their program in a manner that is consistent with their written program. 
There are four types of companies being targeted:
-EPA Risk Management Program (RMP) Program 3 facilities
-Explosive Manufacturers
-Previously cited under PSM
-Identified by local OSHA Area office
How is the NEP different from the current program-quality-verification (PQV) approach?
            - PQV questions are broad and open-ended, while the NEP uses focused and specific                          investigative question.
            - The NEP investigation is designed to gather facts related to the PQV standard.
            - The NEP provides guidance for reviewing documents, interviewing employees, and                             verifying implementation.
STEP has a group of consultants who are well-equipped to train and assist you with an onsite review of your PSM, as well as a review of your hazardous operations procedures. Contact us for more information. 



Welding is a common practice utilized within many different work environments, all the way from  ambitious underwater welding jobs to repairing ships or pipelines, to more standardized industrial welding within the manufacturing sector. 
However, welding involves the use of extremely hot and bright energy which can pose many safety risks, for instance look at this OSHA News Release. The use of PPE is essential to the safety and well-being of any welder. The types of PPE used usually depend upon the type of weld being conducted. Nevertheless, it is crucial that any PPE used is capable of withstanding the inherent hazards associated with welding. There are different levels of protection based on shading, electrode, and arc current. An easy way to think of this may be to think in terms of sunscreen; an SPF 15 is not going to provide as much protection from the sun as an SPF 50.
Here are some helpful tips to ensure safety while welding:
1. Set up in a well-ventilated area. The welding process produces fumes dangerous to your health. The fumes contain hazardous substances that can cause acute or chronic health effects including headaches, metal fume fever, and nausea. Ensure that you have adequate ventilation to protect yourself from such health concerns.  
2. Use appropriate welding supplies and gear. All areas of the body should be covered by wearing proper welding protection equipment. To protect the eyes and face, wear a helmet with a filter lens and cover plate. Use safety glasses with side shields under the helmet to avoid eye irritation. Welding supplies should also include earplugs or muffs. If loud noise is present, the earplugs will not only prevent hearing loss, they will also prevent sparks and spatters from entering and burning the ears. Welding gloves will safeguard  hands from burns and cuts. Protect feet and ankles by wearing leather, steel-toed, or high-topped boots. In heavy-spark areas wear fire-resistant boot protectors or leather spats strapped around pant legs and boot tops. Use dry, hole-free, fire-resistant, and insulated welding gloves to protect the hands from burns, cuts, electric shock, and scratches.
To complete the welding supply, wear protective clothing. Make sure all skin is protected when welding. Wear oil-free clothing made of heavy material such as wool because it is more flame retardant. Keep your clothes dry to reduce the possibility of an electric shock. Don't forget to check if your clothes are free from holes, tears, or frayed edges. Lastly, unroll your cuffs and button your pockets to prevent sparks from entering.
3. Check your welding equipment. Keep your welding equipment in good condition. Never use a tool that is in a faulty state. Know and practice the proper way to use your welding equipment and its safe limits. Don't forget to store your welding equipment in a safe place. Many accidents are caused by tools falling off shelves or ladders.
Need to train your employees? Here's some useful training tools:  Tool Box Talk on Welding    Hot Work Video 




In the 2010 BLS survey of Occupational Injuries and illnesses, the incidence rates for the combined recordable cases among private industry declined greatly. Manufacturing was the sole private industry sector to experience an increase. These numbers are used to direct OSHA’s National Emphasis Programs or inspections for target groups in a particular standard industrial code, like the residential construction industry.
To be prepared for an OSHA visit make sure your safety practices are in compliance with their requirements and be able to show them documentation to that effect. Your safety plan and manual should be a “blueprint” for how you assess workplace hazards and ensure a safe work site for your employees. OSHA requires company specific written plans – not the generic “off-the-shelf” stuff.
What are OSHA inspection triggers?
-         Employee complaints
o       Do you have an effective system for employee comments, concerns, or feedback?
-         Fatalities or catastrophic event
o       Do you have the area office number and are you ready to meet with OSHA today
-         Scheduled inspections 
o       If OSHA walked through the door today, could you handle the open conference, walk-through and closing conference?
-         National emphasis programs or target groups
o       Are you in one? Do you know?
Know ahead of time which company representative should be part of the opening and closing conferences; company personnel that are knowledgeable about the process, onsite hazards, employee work tasks, and the regulatory process. Understand that your rights include taking duplicate copies, samples, photos, instrument readings, etc. if the OSHA Compliance Officer is doing so. Make sure that your Hazard Communication program is current. The program should include: the written program, safety data sheets, labels and site specific training. GHS is around the corner, so go back and visit this requirement.
Plan ahead for which person or persons you can call if OSHA discovers issues during their paperwork review or walk-around. This would be someone who understands the importance of fixing the item before OSHA gets offsite. This demonstrates good faith and may lower the penalty that would be assessed. Remember, if the hazard has been identified fix it or you have the potential to UP the penalty to a willful. Finally, if the inspector is hostile, abusive, or intrusive beyond the initial scope of the inspection, make sure you include other company personnel into the inspection process, be professional and immediately consult with legal counsel about adjourning the meeting so that contact can be made with the Area Director.



Many people consider dust to be a part of life and don't think about the potential consequences of dust accumulation. However, dust can be deadly if the circumstances are right. Since 1980, over 100 workers have been killed and over 700 injured due to combustible dust fires and explosions in general industry.   OSHA has recently begun citing under Section 5(a)(1), as a "Willfull" type of violation for allowing employees to be exposed to fire and explosion hazards when processing Class II combustible dusts.
Combustible dust is a combustible particulate solid that presents a fire or deflagration hazard when suspended in air. Not all combustible dust is obvious. Some types of dust that can be combustible are:
  • Wood
  • Food
  • Metal
  • Plastic
  • Sugar
  • Inorganic
A buildup of dust in a facility can cause a deflagration, which is when dust particles build up pressure and suddenly explode, usually resulting in a fire. Before a deflagration can occur:
  • Dust has to be combustible AND
  • Dust has to be dispersed in the air AND
  • There has to be an ignition source
Reducing dust accumulation is an important part of protecting employees and facility resources.  Dust control measures include, but are not limited to:
  • Use dust collection systems
  • Inspect the facility regularly
  • Clean dust at regular intervals
  • Develop and implement a written program for basic housekeeping in the facility
Combustible dust has been added to the training requirements of OSHA's revised Hazard Communication. OSHA has not provided a definition for combustible dust to the final HCS given ongoing activities in the specific rule-making, as well as in the United Nations Sub-Committee of Experts on the GHS (UN/SCEGHS). However, guidance is being provided through existing documents, including the Combustible Dust National Emphasis Program Directive CPL 03-00-008, which includes an operative definition, as well as providing information about current responsibilities in this area. In addition, there are a number of voluntary industry consensus standards (particularly those of the NFPA) that address combustible dust.

In the final HCS, combustible dust hazards must be addressed on labels and SDSs. Label elements are provided for combustible dust in the final HCS and include the signal word "warning" and the hazard statement "May form combustible dust concentrations in the air".
Although OSHA did not provide a definition in the new standard, they have provided guidance in many of their documents, which allows the employer to determine what housekeeping, work practice and training is required.


The Gift of Safety


As 2014 kicks off, STEP wants to challenge you to take the necessary steps to become a safer person.

 So why not consider giving yourself the Gift of Safety in the New Year? Caring about your personal safety translates into every aspect of your life. Learning to live with strength, courage and common sense helps you be a better employee, a more productive coworker, a stronger example.

 Top 10 2013 OSHA Violations-Click Here   

 Enroll in one or more of the open enrollment seminars shown to left and you'll be taking the first steps toward giving yourself the Gift of Safety. 

 5 Tips to improve safety performance in 2014

 Refuse to accept a dangerous work environment.  Remember:  "An employee may refuse to do any act at his place of employment where there is reasonable grounds for believing that the act is likely to endanger his health or safety or the health or safety of any other employee." (Section 19 of the OHS Act)

 Take some time to check personal protective equipment (PPE) for wear and tear: Are safety boots worn? Can you still see clearly through the lenses of your safety glasses? Start the year off right by ensuring your PPE is effective and properly fitted.

 Get the most from your managers and supervisors. Managers and front-line supervisors have the most direct access to workers. Their actions, reactions, and attitudes can have a huge impact on employees' safety performance.

 Put it in writing. OSHA considers a written safety and health program the gold standard. If you don't have one, you should. You also need a safety and health mission statement that aligns with your corporate goals and culture.

 Be ready Emergencies don't just happen to the business down the road. You've got to be prepared for a wide range of unexpected events.


Put safety first!


We do our best to avoid workplace injuries, but we can't avoid the weather and the hazards it carries. Life would seem fairer to those who labor in the heat if we all had an office job. But, unfortunately there is work to be done and someone's got to do it.
OSHA's campaign slogan to prevent heat illness in outdoor workers this summer is "Water. Rest. Shade".
It is best to train workers on heat illness symptoms and remind them of safety measures they should take; including planning their day around the peak heat times to help avoid a heat-related injury. Express the importance of wearing the proper clothing and UV protection, resting in the shade and staying hydrated. Using planning checklists can help assure the proper areas are covered to help prepare the workplace and workers for hot weather.
 Check out this map of heat fatalities to see if your area is influenced.
What better reason for workers to beat the heat than to send them to a STEP training seminar. We have a few coming up, take a look!
Enrollment can be completed on STEP's website, via email or phone. We look forward to working with you, and as always STEP appreciates your business. .
Stay cool!



by: Raea Hounshell
With summer quickly approaching, temperatures rising, and the fun-in-the-sun holidays near, it seems fitting to discuss the effects of sun-kissed skin and how it can impact the workforce.
Though we know that UV rays widely contribute to skin cancer, and in its deadliest form- melanoma, society today doesn't seem to take much action in prevention. Society's culture has conditioned us to think that being tan is the norm, and sporting a bronzed glow is encouraged! The sad fact is that one American dies from melanoma almost every hour.
In July 2009, the International Agency for Research on Cancer (IARC), part of the World Health Organization, concluded that tanning devices that emit UV radiation are more dangerous than previously thought, and declared them "carcinogenic to humans," per CDC.
While we do spend much of our time at work inside, we are still often susceptible to the harmful rays of the sun. One article I came across used five S-words to help you remember the steps to protect your skin:
Slip - be sure to wear clothing that can protect your skin with high necklines, etc.
Slop - slather on a broad spectrum sunscreen
Slap  - when outside wear a broad-brimmed hat
Seek - do your best to seek shade if you are working outdoors
Slide - wear sunglasses with high UV protection
Follow these guidelines when going outside, at work or at home. Supply sunscreen to workers who are outside, or exposed to UV rays, and require the proper PPE for prevention.
According to the CDC, and based on well-documented associations between occupational exposures and cancer, it has been estimated that 4% to 10% of U.S. cancers (48,000 incident cases annually) are caused by occupational exposures. Key to all occupational exposures is that virtually all such exposures can be prevented.
Click here to learn more about skin cancer in Kentucky or to learn more about skin cancer in your state visit www2.epa.gov/sunwise/skin-cancer-facts-your-state.
Skin is not only effected by the sun, the type of environment you are in can cause skin problems directly or they can work with other factors to increase skin problems. These factors include:
  • Heat - causes sweating. Sweating may dissolve chemicals and bring them into closer contact with the skin. Heat increases the blood flow at the skin surface and may increase the absorption of substances into the body.
  • Cold - dries the skin and causes microscopic cracking. This cracking allows substances to cross the outer layer of the skin, thus entering the body.
  • Sun - burns and damages the skin. Sun can increase absorption of chemicals. Sun reacts with some chemicals to enhance their negative affects on the body.
How to Protect Your Skin:
When using gloves or clothing to protect yourself and your skin, be careful when removing contaminated clothing, so you do not contaminate yourself.
If a worker is exposed, or thinks he/she may have been exposed to a hazardous substance, the area should be rinsed for at least 15 minutes. He or she should get under a shower immediately and remove the clothing while showering. Certain substances can be absorbed quickly across the skin. Time is critical. Medical help should be obtained immediately. Eyewash and shower stations should be inspected, use an inspection list for record keeping.
Whether you are a cancer survivor or not, protecting yourself from the sun is important. Be ahead of OSHA and give your workers the extra protection!
Download EPA's FREE UV index app.


Is it important to train the trainer?
One of the most important parts of a training session is the trainer. The trainer must be knowledgeable, a good listener, flexible and highly motivated.
Some companies recognize that training offers a way of developing skills, enhancing productivity and quality of work, building worker satisfaction and critical to our personal growth because training provides knowledge that enhances our job.
However, many times companies do not see how critical it is to have a systematic approach to training the trainer. Trainers not only need to know the subject matter they also need to possess the skills to deliver the material – either in an on-the-job venue or in a classroom setting.  Understanding adult learning skills is essential. The adult learner comes to the training session with a wealth of real world experiences. These experiences can enhance the training session, if the trainer recognizes the value of the adult experience. Our train the trainer classes provide a look at those adult learning styles AND include subject matter content.
Because we have believe in our message, we are willing to provide you with a free download that will help you provide a great train-the-trainer presentation to your trainers. 
When using our presentation and including it in your content training, think about the following:
·         Provide clear expectations
·         Search for “real-life” pictures & video clips to get the message across in your overheads – forget the words – show the action
·         Some folks quote these numbers -
90% of what they learn when they teach someone else/use immediately.
75% of what they learn when they practice what they learned.
50% of what they learn when engaged in a group discussion.
30% of what they learn when they see a demonstration.
20% of what they learn from audio-visual.
10% of what they learn when they’ve learned from reading.
5% of what they learn when they’ve learned from lecture
·         What this means is mix it up – let the participants do some teaching and coach them on the good and not so good! To help get you on your way, we offer afree download which includes some great train-the-trainer tipsAdd your real-life photos to these overheads and you have a great training methods presentation to present to your trainers.



With electrocution being the 4th leading cause of fatalities in industry, it is important to ensure that employees are trained properly to work with electrical equipment. Though electrocution is a hazard, it is important to also remember the other hazards while dealing with electricity:
·         Arc Flash and Arc Blasts
·         Fire Ignition
·         Falls
Thanks to the NFPA, these hazards can be prevented by:
·         Determining the operating voltage
·         Determining the approach boundaries
·         Determining (and using) proper PPE
Everyone has a responsibility when it comes to safety. Employers are responsible for ensuring safety policies and procedures, training employees, and providing proper PPE when necessary. Employees are responsible for following procedures put into place by their employers. Each person is responsible for ensuring their own safety. 
With over 25 years of experience in safety training, let us help you STEP up to compliance.



The cold days of winter and moderate days of spring have passed, and summer is now setting the rules of temperature. This weekend's forecast for western Kentucky and Tennessee tops numbers in the 90 degree range. Are you and your workers prepared to handle the heat?
Every year, workers suffer heat-related injury and illnesses ranging from dehydration to heat exhaustion, heat stroke and sometimes even death. The sad truth is that with the correct preparation and prevention, these types of injuries are very preventable.
What is Heat Exhaustion?
Heat exhaustion can be a precursor of heatstroke; the symptoms include heavy sweating, rapid breathing and a fast, weak pulse. Heat exhaustion, if not addressed, can quickly lead to heat stroke.
What is Heat Stroke?
It is a form of hyperthermia in which body temperature is drastically elevated (measured at 105.1 degrees and above). Sufferers of heat stroke are in danger of death if the symptoms are not addressed and treated promptly.
Common Symptoms of Heat Stroke
  • high body temperature (measured at 105.1 and above)
  • the absence of sweating, with hot red or flushed dry skin
  • rapid pulse
  • difficulty breathing
  • strange behavior
  • hallucinations
  • confusion
  • agitation
  • disorientation
  • seizure, and/or
  • coma
  • Rapid mechanical cooling; body temperature must be lowered immediately.
  • Move patient to cool area (indoors or at least in the shade)
  • Remove clothing to promote heat loss
  • Bathe victim in cool water - NOT COLD (avoid this step for unconscious patient)
  • Do not wrap patient in wet towels or clothing since these can act as an insulator and increase body temperature
  • Cold compresses to torso, head, neck and groin
  • Fan or dehumidifying air conditioning unit
  • If patient is conscious, give plenty of water to rehydrate
  • Standard resuscitation measures if necessary
  • Seek medical attention immediately
Who is At Risk?
According to OSHA, "those most at risk are workers exposed to hot and humid conditions, especially those doing heavy work tasks or using bulky protective clothing and equipment. Some workers might be at greater risk than others if they have not built up a tolerance to hot conditions."
In order to prevent and/or minimize risk of overheating, it is recommended by OSHA to "remember three simple words: water, rest, shade. Drinking water often, taking breaks, and limiting time in the heat can help prevent heat illness." OSHA now offers a free mobile App for smartphones as a tool to help outdoor workers stay safe from heat related illnesses. According to OSHA, the App, called the OSHA Heat Safety Tool is available for iPhone and Android platforms, and will be available later for Blackberry.
You can't fully avoid the sweat of summer, but you can avoid the injury that its scorching heat may offer. By following OSHA's guidelines, you and your workers can remain safe and injury-free in the sweltering dog days of summer.

OSHA puts together a list of the top 10 safety and health violations they see each year. In 2016, nearly 32,000 inspections were completed and the top 10 list barely changed once again. The top 10 violations rarely change from year to year with inspectors continually seeing the same on-the-job hazards.


Top 10 most frequently cited safety and health violations of 2016:

  1. Fall protection
  2. Hazard communication
  3. Scaffolds
  4. Respiratory protection
  5. Lockout/tagout
  6. Powered industrial trucks
  7. Ladders
  8. Machine guarding
  9. Electrical wiring
  10. Electrical, general requirements


Each year more than 4,500 workers are killed on the job along with 3 million being injured. If employers used this list as a starting point for workplace safety the number of injuries, hospitalizations and deaths would drastically decline.


Employers should go above and beyond the minimal requirements to create a good safety culture. Establishing a good safety culture reduces costs, raises productivity and improves employee morale. Tackling these most common hazards is a good place to start when creating a safe working environment and increasing safety awareness among employees.


As long as the Mayan calendar is incorrect and the world continues to exist beyond December 21, 2012, cold weather is just around the corner for most of us. For those employees whose jobs allow them to sit warmly behind a desk or in a well-heated work area, cold weather presents little if any change to the day's business. But for those who are required to work outside part or all of the time, considerations and safety precautions for working in the elements must be factored into their daily safety plan. Does your job require you to work outside part or all of the time? Do you know the risks associated, and how to avoid them?
Risks resulting from prolonged exposure to freezing or cold temperatures include:
Immersion Foot / Trench Foot
Frostnip and Frostbite
Snow Blindness
Carbon Monoxide Poisoning
Certainly, the best way to avoid injury is by enforcing proper prevention measures. OSHA discusses many of these measures on their website including recognizing dangerous conditions, wearing proper clothing, taking breaks, learning the signs and symptoms of cold-induced illnesses, knowing what to do to help others, etc. The CDC is also an excellent resource for reading up on symptoms, prevention and first aid measures that should be taken in the event of over exposure.
According to NOAA National Weather Service, 29 deaths in 2011 were directly related to symptoms arising from exposure to freezing or cold temperatures. Are your employees who work outside prepared for the cold weather? If not, you should make quick haste at getting them trained and prepared. And don't wait for December 22; the temperature is already dropping!



Waste Minimization Is Sound Practice and Can Generate $$$
By Sara Fineman

In 1984, amendments to RCRA established the following national policy, making waste minimization the nation's preferred hazardous waste management practice: "...the generation of hazardous waste is to be reduced or eliminated as expeditiously as possible. Waste that is nevertheless generated should be treated, stored, or disposed of so as to minimize the present and future threat to human health and the environment." (RCRA Sec.1003 [b], 1984.)
RCRA requires large and small quantity hazardous waste generators to certify that they have a waste minimization program in place that reduces the quantity and toxicity of hazardous waste generated to the extent economically practicable. Many times the inspector will ask for the written waste minimization program you acknowledged having in place. Be ready, and include the facility-specific methods you have implemented. Have the waste minimization trends and quantity reduction organized to be able to prove your positionEPA suggests you include the following in your program:
1.      Source reduction
2.      Environmentally sound recycling methods
3.      Energy recovery
4.      Treatment, and finally, disposal
The Pollution Prevention Act, passed in 1990, expanded the nation's waste prevention policy beyond a RCRA-only framework and included minimizing or eliminating toxic releases to all environmental media and natural resources. When feasible, source reduction and recycling should be implemented. Waste that cannot be reduced or recycled must be treated or disposed of in a safe manner, so that future generations are not given the burden of finding a better alternative. 
The Pollution Prevention Act has encouraged many organizations to expand their focus from RCRA-only to a multimedia pollution prevention focus. EPA offers a variety of information sources on multimedia pollution prevention.
Benefits for this sound environmental management program may include:
·         Reduction of the quantity and toxicity of hazardous and solid waste generation
·         Raw material and product loss decrease
·         Raw material purchase costs decrease
·         Waste management recordkeeping and paperwork burden streamlined
·         Waste management costs reduced
·         Workplace accidents and worker exposure decrease
·         Compliance violations go away
·         Environmental liability reduced
Through the implementation of the Waste Minimization Program improvements should include:
·         Production efficiency
·         Profits
·         Good neighbor image
·         Product quality
·         Environmental performance



Did you participate in the safety stand-down yesterday? The stand-down supported OSHA's nationwide outreach campaign to raise awareness among employers and workers about the hazards of falls. STEP is pleased to say that we partook in this effort to raise awareness, and we hope you did as well.


No fall protection equipment - regardless of how effective - can save an employee who is not trained in its use. Workers must be able to identify potential fall hazards, determine which products to use in specific work environments, demonstrate proper anchoring procedures, etc. Employees must also learn inspection and maintenance procedures and the proper wearing of fall protection equipment.


A Personal Fall Arrest System is comprised of three (3) key components - anchorage connector; body wear; and connecting device. While a lot of focus has been given to anchorage connectors and body wear (full-body harnesses) when discussing fall protection, the connecting device (a shock-absorbing lanyard or self-retracting lifeline) actually bears the greatest fall forces during a fall.


Employers must know the types of fall protection products that are available, and decide which would be most suitable for the workplace. Because all work environments differ, it is impossible for the manufacturer to determine exactly which fall protection products will provide maximum protection for each job. By understanding how fall protection products operate and knowing the differences in product functions, the employer can select products that are best suited for its workers.



To learn more about fall protection, visit our website, or Miller's website & enroll in the upcoming Miller training STEP is hosting in October. How better to learn about fall protection equipment that from the people who are famous for making it? Don't miss this opportunity! 

Be sure to enroll through STEP for special pricing!

What are the chances that your workplace may be on OSHA's list for site specific target inspections?
OSHA's inspection list for 2014 is based on injury and illnesses data collected during the 2010 survey.

Inspections for states that run their own safety and health programs will be based on 2010 specific injury and illness rates and will target all establishments with the following DART and DAFWII rates:

  • Manufacturing facilities with a DART (Days away, Restricted, or Transferred) rate at or above 7.0 or a DAFWII (Days Away From Work Injury and Illness) case rate at or above 5.0; and
  • Most non-manufacturing facilities with DART rates at or above 15.0 or a DAFWII rate at or above 14.0.

Once the primary list has completed, OSHA will move on to the Secondary inspection list. This list is comprised of the following establishments:

  • Manufacturing establishments with DART rates of 5.0 or greater or a DAFWII case rate of 4.0 or greater;
  • Most non-manufacturing facilities with DART rates of 7.0 or greater or a DAFWII rate of 5.0 or greater;
  • Nursing and personal care facilities; and
  • A random sampling of facilities that did not provide rate information on their injury and illness surveys by May 2012. (OSHA says including these establishments is intended to discourage employers from trying to avoid inspection by not responding.)

How loud is your workplace? Did you know that occupational hearing loss is the most common work-related illness in the United States?


Facts and Statistics: 

 -According to NIOSH, 4 million workers go to work each day in damaging noise.

-Ten million people in the U.S. have a noise-related hearing loss.

-Twenty-two million workers are exposed to potentially damaging noise each year. 


Over the past few decades, much has been learned about the implementation of hearing loss prevention programs. The eight components of a successful hearing loss prevention program are:

  • Noise exposure monitoring
  • Engineering and administrative controls
  • Audiometric evaluation
  • Use of hearing protection devices
  • Recordkeeping
  • Program evaluation
  • Program audit
  • Employee training and motivation


 FREE Hearing Loss Tool Box Talk


Take this short quiz to test your hearing loss:


According to the National Institutes of Health, the following questions will help your employees determine if they need to have their hearing evaluated by a medical professional:


1. Do you have a problem hearing over the phone?

                         Yes      No

2. Do you have trouble following the conversation when two or more people are talking at the same time?

                         Yes      No

3. Do people complain that you turn the TV volume up too high?

                         Yes      No

4. Do you have to strain to understand conversation?

                         Yes      No

5. Do you have trouble hearing in a noisy background?

                         Yes      No

6. Do you find yourself asking people to repeat themselves?

                         Yes      No

7. Do many people you talk to seem to mumble (or not speak clearly)?                  Yes      No

8. Do you misunderstand what others are saying and respond inappropriately?     Yes     No

9. Do you have trouble understanding the speech of women and children?            Yes     No

10. Do people get annoyed because you misunderstand what they say?                Yes     No


Those who answer "yes" to three or more of these questions may want to see an otolaryngologist or an audiologist for a hearing evaluation.


The new system for tracking workplace injuries and illnesses, OSHA recordkeeping log is easier to understand and to use. Isn’t it? The question and answer format is a better system and allows you to skim the standard and focus on the questions that you have with the answers located below the question. The forms have been changed and are now:
Form 300 is now reformatted to fit legal size paper
From 301 includes more data about how the event occurred
Form 300A makes it easier to calculate incidence rates – posting the form from February 1 to April 30 of each year
Click HERE to download forms
The standard exempts smaller employees (10 or fewer employees) and those in service and retail industries. It further defines work relationship, medical treatment, first aid and restricted work.   There are some great website presentations, one from the Oklahoma Department of Labor that does a great job of explaining the different sections. Finally, injury and illness record keeping is an excellent resource for reviewing trends, targeting new safety programs and working toward zero tolerance for worksite accidents.


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