Future Environment Designs Training Center's Pandemic Policy, Updated Policy 06/19/21!

Future Environment Designs Training Center (FEDTC) recognizes that the safety and health of our clients and their family are our shared concerns.  We also recognize that our clients need to renew licenses that are necessary to perform work in the field and that in-person classes are required by law.  FEDTC always reserves the right to refuse to train anyone we feel may be too ill to attend a course.  We will and can hold a private class at a mutually beneficial time after they have gotten better for these individuals.  Until this pandemic has ended we will follow the following procedures to reduce the potential interactions that could increase the risk of spreading disease (on June 19, 2021, we have modified our procedures based on the revised Centers for Disease Control (CDC) Policies and that we were immunized on April 18, 2021 (Pfizer 2 shots).  This policy will remain in effect until the pandemic is over (revisions are underlined):

Social Distancing Policy:
During training classes, the instructor and the students will be requested to:

• All students & instructors before they leave home should take their temperature (it should be less than 100 degrees Fahrenheit) and document absence of shortness of breath, new or change in cough, sore throat, loss of smell or taste, and muscle aches.  They should also check the CDC website for other symptoms at https://www.cdc.gov/coronavirus/2019-ncov/symptoms-testing/symptoms.html.  If possible, take the CDC self-check found at the site.  If you are ill or your temperature is above 100 degrees Fahrenheit they should call to reschedule the course.
• All students upon arrival will be asked what their temperature was before they left home, and do they have any of the symptoms of shortness of breath, new or change in cough, sore throat, and muscle aches.  We will also use a contactless thermometer to measure forehead temperature.  If students answer yes to any questions or the thermometer measurement is above 100 degrees Fahrenheit the student will not be allowed to attend training and must reschedule.
• All students will also, be asked if they are vaccinated and to show proof of vaccination (we recommend students use the NYS Excelsior Pass App).
• All students will be encouraged to bring and wear a face-covering during the training (FEDTC will provide face coverings, when available).  Students who prove they are vaccinated do not need to wear masks or social distance as per the CDC.
• FEDTC will be using our larger training rooms and advising students to sit at least 6 feet from each other and avoid person-to-person contact such as shaking hands.
• Instructors will perform all training at least 6 feet from students, will wear face coverings during training, and we are immunized.
• Cover coughs and sneezes using tissues or into the elbow of your sleeve.  To prevent droplets containing germs from entering the air or contaminating your hands.
• Wash your hands frequently with soap and water for at least 20 seconds (sing "Happy Birthday" twice).
• Use waterless hand sanitizer where soap and water (which are preferred) are not available.
• Instructors will avoid any unnecessary travel and cancel or postpone any courses they are feeling unwell or shall use a face covering while training.
• Instructors will be provided with a kit to help with the recommended procedures.

Pandemic Kit:

The pandemic kit each instructor will be provided with will include:

• Tape measure
• Surgical masks, when available
• N95 Disposable Respirators, when available
• Hand Sanitizers, when available
• Tissues
• Cleaning Disinfectant Wipes for cleaning tables
• Forehead Thermometer

Training Courses:

At the beginning of the course we will go over the basic steps for personal protection & prevention.  This will include a slide set and video regarding basic information on protection and prevention before the course begins.

FEDTC feels these steps will help reduce the risk of spreading disease and still enable students to refresh training in accordance with current regulations.  Should you have any questions feel free to give us a call.  Be safe! 

When Do Asbestos Certificates (Hard Cards) Expire Under COVID-19? New Update: No more extensions!

… … …

This question is the overwhelming number one question we at Future Environment Designs (FEDTC) are being asked at this time.  So, to answer this question we must remember that there are two agencies that regulate asbestos licensing and training.  The license (companies are licensed; individuals get certificates) or more appropriately the asbestos certificate (hard card) is issued by the New York State Department of Labor (NYSDOL).  This certificate expires annually on the last day of your birth month.  Currently, NYSDOL is enforcing expiration dates on certificates.  You may continue to work with your existing cards as long as it is not expired.  In addition, NYSDOL is no longer extending the number of days you can work with a DOH 2832 form when you took an initial course.  NYSDOL is allowing you to work with the DOH 2832 form for 45 days.

Hard card with picture (certificate) & Company license

The second agency that plays a part in this is the New York State Department of Health (NYSDOH).  The NYSDOH enforces 10 NYCRR Part 73 Asbestos Safety Program Requirements which regulates the asbestos training providers and also says that the training certificate (the DOH 2832 Form, the piece of paper you get once the class is completed) expires after one year on the date you took the training.  In addition, it has a grace period after that date that lasts a year.  Once the grace period is over you must take an initial course to get another certificate (DOH 2832) for that title.  Realize there has not been any waiver on this issue and so you will need to keep an eye on your training certificate expiration date and make sure you don't go over the grace period.  NYSDOH is now allowing virtual instructor-led courses, see FEDTC's Wednesday, May 27, 2020, blog post on the requirements for that training.  Because of this, there is no need to let your hard card or your training certificate expire.

DOH 2832 Form

Those of you who work in New York City, New York City Department of Environmental Protection (NYCDEP) regulate Asbestos Rules and Regulations, Title 15, Chapter 1 of the Rules of the City of New York.  This regulation also has certificates (NYCDEP hard cards) for individuals who are handlers, handler supervisors, investigators, and restricted handlers.  These hard cards expire every two years based on your birthday (but you must still meet the NYSDOL & NYSDOH requirements of training every year).  NYCDEP is allowing workers whose hard card expired on March 15, 2020, or later to continue to work using their existing card until August 31, 2021.  See NYCDEP's Extension of Asbestos Certification Deadline website for more information.

Hopefully, that answers everyone's questions and we hope to see you in a virtual or in-person class soon.

Top Ten OSHA Violations for 2020 and a hint to the Top Ten for 2021.

The Occupational Safety and Health Administration (OSHA) annually publishes the top ten most frequently cited OSHA standards violated in the previous fiscal year.  Unfortunately, the list has not been published yet on the OSHA website.  OSHA unveiled a preliminary list of its top 10 violations during a webinar with the National Safety Council's (NSC) Safety+Health magazine.  In the webinar, OSHA discussed the stats for the fiscal year (FY) 2020 (which runs from October 1, 2019, to September 30, 2020).  Here is the list of most frequently cited OSHA standards:

1. Fall Protection, construction (1926.501)
2. Hazard Communication Standard, general industry (1910.1200)
3. Respiratory Protection (1910.134)
4. Scaffolding, general requirements, construction (1926.451)
5. Ladders, construction (1926.1053)
6. Control of Hazardous Energy (lockout/tagout), general industry (1910.147)
7. Powered Industrial Trucks, general industry (1910.178)
8. Fall Protection - training requirements, construction (1926.503)
9. Eye and Face Protection (1926.102)
10. Machinery & Machine Guarding, general requirements, general industry (1910.212)

Proper Fall Protection and Scaffolding

It is interesting to see that Respiratory Protection moved into third place and Ladders moved into the top 5.  Considering OSHA published a list of the frequently cited standards related to COVID-19 inspections in November 2020, and that list also includes respiratory protection violations.  We may continue to see Respiratory Protection in the top three of most frequently cited violations again next year.  The COVID-19 list includes:

1. Provide a medical evaluation before a worker is fit-tested or uses a respirator.
2. Perform an appropriate fit test for workers using tight-fitting respirators.
3. Assess the workplace to determine if COVID-19 hazards are present, or likely to be present, which will require the use of a respirator and/or other personal protective equipment (PPE). 
4. Establish, implement, and update a written respiratory protection program with required worksite-specific procedures. 
5. Provide an appropriate respirator and/or other PPE to each employee when necessary to protect the health of the employees (ensuring the respirator and/or PPE used is the correct type and size).
6. Train workers to safely use respirators and/or other PPE in the workplace, and retrain workers about changes in the workplace that might make previous training obsolete.
7. Store respirators and other PPE properly in a way to protect them from damage, contamination, and, where applicable, deformation of the facepiece and exhalation valve.
8. For any fatality that occurs within 30 days of a work-related incident, report the fatality to OSHA within eight hours of finding out about it. 
9. Keep required records of work-related fatalities, injuries, and illness.

Quantifit Respirator Fit Testing System (QNFT)

In FY 2020, OSHA conducted 21,674 inspections, including 12,948 (about 60%) unprogrammed inspections, which include employee complaints, injuries/fatalities, and referrals, all of which were impacted by the COVID-19 pandemic.  In FY 2019 OSHA conducted 33,393 inspections which mean OSHA conducted 35% fewer inspections in 2020.  This reduction in inspections has been noted and criticized by the Department of Labor's Office of the Inspector General (OIG)  in its audit of OSHA.  That audit concluded OSHA received 15% more complaints in 2020 compared with the same period in 2019 but performed 50% fewer inspections.  Leading the audit to the conclusion that reduced OSHA inspections leave US workers' safety at increased risk.

     

Scaffolding Violations are number 4 for all industries & number 3 for the remediation industry

The top 10 violations in the Remediation Services Industry (which includes asbestos abatement, lead abatement, crime scene cleanups, oil spill cleanup, mold remediation, and hazardous materials remediation companies) were:

1. Duty to have fall protection (1926.0501)
2. Respiratory Protection (1910.0134)
3. Scaffolding, general requirements (1926.0451)
4. Reporting Fatality, Injury and Illness Information to the Government (1904.0039)
5. Hazard Communication (1910.1200)
6. Ladders (1926.1053)
7. Duty to have fall protection and falling object protection (1910.0028)
8. Fall protection systems criteria and practices (1926.0502)
9. Asbestos (1926.1101)
10. Respirable crystalline silica (1926.1153)

It certainly seems like fall protection has now become part of the focus in the remediation industry with 5 of the top ten involving falls.  Interesting how the respirator violations remain number two in the remediation industry.  When this should be the industry's specialty.

Mold Remediation Industry 

As you can see OSHA is still performing inspections and still issuing citations.  Though under President Biden's Administration, OSHA inspections are likely to increase, along with citations.  Which shouldn't be hard considering the few inspections conducted in FY 2020.  Though fall protection is still number one on OSHA's focus, respiratory protection is starting to creep up the ranks.