A Merry Holidays and a Happy New Year to all of you! Future Environment Designs Closed Until January 4, 2017!

We wish all of you a Merry Holidays, we hope the coming year brings you health, and happiness!  As usual, we are closed from December 23 - January 4, 2017.  We look forward to seeing all of you during the New Year!  We are very excited by this coming New Year since we are expanding the blended learning we started after our Edinburgh trip to LITE2016.

Rockefeller Centre Christmas Tree 2016

We started the process by putting our course manuals online and providing you access to the manuals and the student portal for 365 days.  We continue the process by now including an online course evaluation process through Coursecheck, that will eliminate the paper forms.  The next phase we are planning is an online examination process which should make it easier to take the exams and further reduce paper documents.  To help those who don't have portable devices we will be supplying these devices in our classes.  We are awaiting the supply of fifteen (15) Surface 3 tablets with keyboards so we can facilitate the blended learning we are morphing our classes into.  We hope our students are just as excited as we are, as we move into this new more informative and interactive training method.  We look forward to greeting you in the New Year with these new training methods!

English: Blended learning methodology graphic (Photo credit: Wikipedia)

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OSHA Fines Increase By 78%, Will That Lead To An Increase in Safety Consulting & Training?

Starting on August 1, 2016, employers who have Occupational Safety and Health Administration (OSHA) violations issued on or after this date for violations occurring on or after November 2, 2015 are subject to the new OSHA maximum civil penalties (fines) that are 78% higher.  This civil penalty increase was mandated by Congress, on November 2, 2015, through legislation that required all federal agencies to adjust their civil penalties to account for inflation.  For OSHA, the last time these penalties were adjusted was back in 1990.  Moving forward, as the legislation requires, the penalties will be adjusted each year based on the Consumer Price index.  OSHA will continue to do penalty reductions based on the size of the employer and other factors.

The following table shows based on the type of violation what the old fine was compared to the civil penalty increase:

Type of Violation	Current Maximum Penalty	New Maximum Penalty
Serious Other-Than-Serious Posting Requirements	$7,000 per violation	$12,471 per violation
Failure to Abate	$7,000 per day beyond the abatement date	$12,471 per day beyond the abatement date
Willful or Repeated	$70,000 per violation	$124,709 per violation

It is important to realize violations such as not performing respirator fit testing on your staff, or having a respiratory protection or hazard communication programs will now be $12,471 per violation.  Add to this OSHA's new reporting requirement that goes into effect on January 1, 2017.  This new reporting requirement requires electronic submission of injury and illness information that already is being collected.  The difference is this information will be made available to the public.  The idea is that with information being available to the public, employers will focus more on safety.  The new reporting regulation also anticipates an improvement in the accuracy of the data, because it prohibits employers from discouraging workers from reporting injuries and illnesses.  This part of the rule went into effect on August 10, 2016 (hey that's my birthday), however, OSHA has delayed enforcement till November 1, 2016.  It seems to us these two changes will create the perfect storm for employers to have an additional need for safety & health training and consulting.

Angelo Garcia, III Speaking at PACNY 2016

OSHA's website discussing the increase in civil penalties can be found here.  While the OSHA website discussing the new reporting requirements can be found here.

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Happy New Year! 2016 Brings New Regulations Merging With Annual Deadlines!

Happy New Year everyone!  2015 went out with a bang, especially with many people preparing for the new laws taking effect in 2016.  The biggest impact law is New York State's Article 32 (known as the Mold Law) requiring all companies advertising themselves as doing mold remediation or mold assessment will need to be licensed.  Also any worker performing mold abatement needs to be licensed, also.  Needless to say our schedule has been overwhelmed holding these classes preparing companies for this new licensing requirement.  This law also requires an independent mold remediation plan written by a mold assessor.  Requires a mold assessment and mold remediation contractors to be independent of each other on the same property.

Recent Mold Remediation Course

Don't forget that the annual posting of the OSHA log form 300A for injuries and illnesses must be posted by February 1, 2016.  See our previous posts regarding this issue.

Don't Forget to Post Your Company's OSHA 300A Form

The new OSHA confined spaces in construction standard went into effect August 3, 2015.  However, OSHA has two temporary enforcement policies that delay the enforcement of the standard for employers making "good faith efforts" to comply with the standard.  The first one expired on October 2, 2015 which was for all employers.  While the second one applies to employers working on residential construction that will expire on March 8, 2016.

The OSHA hazard communication standard 1910.1200 on December 1, 2015 required distributors to comply with the new labeling requirements.  The standard becomes fully implemented on June 1, 2016.  Meaning your hazard communication program, your chemical inventory, safety data sheets, and labeling should be in compliance with the Globally Harmonized System (GHS).

Changes are happening to the OSHA outreach program.  This is the program that authorizes the OSHA 10-hour & 30-hour construction safety training programs.  Starting March 1, 2016, OSHA will be issuing new cards that will be made of plastic (credit card style) and have a QR code for authentication.  The new cards will allow for electronic verification of the card to make sure it is valid.

A long string of new things on the horizon.  If we can assist you in any way in complying with any of this let us know.  Be Safe!

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• OSHA Log Form 300A Posting Due February 1, 2011.(futureenv.blogspot.com)

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• Confined Spaces In Construction Goes Into Effect August 3, 2015(futureenv.blogspot.com)

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• "Confined Spaces in Construction" - "What Employers Need To Know"(ehssafetynewsamerica.com)

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Confined Spaces In Construction Goes Into Effect August 3, 2015

On August 3, 2015 the new Occupational Safety and Health Administration (OSHA) standard Subpart AA confined spaces in construction goes into effect (1926.1200-1213).  This standard is very similar to the confined space standard in general industry (1910.146).  OSHA recently announced that enforcement of the new standard is being postponed until October 2 to allow additional time for the construction industry to train workers and purchase equipment.  OSHA will not issue citations to employers making a good faith effort to comply with the standard.  Factors OSHA will consider if an employer is making a good faith effort to comply are:

1. If the employer has not trained its employees as required under the new standard, whether the employer has scheduled such training,
2. If the employer does not have the equipment required for compliance with the new standard, including personal protective equipment, whether the employer has ordered or otherwise arranged to obtain such equipment required for compliance and is taking alternative measures to protect employees from confined space hazards, and
3. Whether the employer has engaged in any additional efforts to educate workers about confined space hazards and protect workers from those hazards.

The standard does not apply to construction work regulated by:

1. Subpart P Excavations.
2. Subpart S Underground construction, caisson, cofferdams, & compressed air
3. Subpart Y Diving

The standard requires the employer to comply with this standard and any other provisions that are required in other standards that apply to confined space hazards (i.e., welding).

Like most standards it begins with definitions (1926.1202).  Most of them are again similar to the general industry standard.  For example the definition of a confined space means a space that:

1. Is large enough & so configured that an employee can bodily enter it;
2. Has limited or restricted means for entry and exit; and
3. Is not designed for continuous employee occupancy.

Confined Space Testing & Monitoring in Brooklyn

However, some of the more interesting changes entail the difference between construction and general industry.  For example the definition for a "Controlling Contractor" is the employer that has overall responsibility for construction at the worksite.  There is a note attached to this definition which indicates if the controlling contractor owns or manages the property, then it is both a controlling employer and a host employer. 

Entry employer means any employer who decides that an employee it directs will enter a permit space. The note on this definition warns that the employer cannot avoid the duties of this standard by refusing to decide.  OSHA will consider the failure to so decide to be an implicit decision to allow employees to enter those spaces if they are working in the proximity of the space.

The standard defines host employer as the employer that owns or manages the property where the construction work is taking place.  This definition also has a note that states if the owner of the property on which construction activity occurs has contracted with an entity for the general management of that property, and has transferred to that entity the information specified in 1203(h)(1), OSHA will treat the contracted management entity as the host employer for as long as that entity manages the property.  Otherwise, OSHA will treat the owner of the property as the host employer.  In no case will there be more than one host employer.

The general requirement of the standard requires each employer (host employer, controlling contractor, & entry employer) must ensure that a competent person identifies all confined spaces…and identifies each space that is a permit space, through consideration and evaluation of the elements of that space, including testing as necessary.  

Two interesting sections of the standard are 1926.1203(h) which dictates Permit Space Entry Communication & Coordination and 1926.1211 which dictates Rescue & Emergency Services.  Permit Space Entry Communication & Coordination (Section 1926.1203(h)) spells out what is expected in the communication and coordination between the host employer, controlling contractor and the entry employer. While the Rescue & Emergency Services (1926.1211) spells out the requirements for an emergency/rescue service entity (1926.1211(a)) or if the entry employer will designate employees to provide permit space rescue and/or emergency services (1926.1211(b)).

According to OSHA this new standard will improve safety and protect nearly 800 construction workers a year from serious injuries and reduce life-threatening hazards.  Training requirements for entrants, attendants, and supervisors are relatively the same as the general industry standard.  Give us a call and we can provide this training, at your location or ours.

Its that time again! Have You Remembered To Post The OSHA 300A Form?

On February 1, covered employers were required to post the Occupational Safety and Health Administration's (OSHA) 300A form.  The 300A form summarizes the information that is kept on the OSHA 300 log form.  Covered employers are required to prepare and maintain records of serious occupational injuries and illnesses that occur at a workplace on the OSHA 300 log form.  At the end of the year, covered employers are required to tally the totals on each column and enter the totals on the OSHA 300A form.  The information should be used by employers to evaluate safety in the workplace and determine ways to eliminate or reduce hazards in the workplace.  OSHA's 300A form is required to be posted until April 30, 2015 and must be retained for 5 years.  During the retention period you are required to update the log to add new information regarding the occupational injuries and illnesses recorded on it.  OSHA has brief tutorial to help you complete the forms.

OSHA 300A Form

A final rule was announced on September 11, 2014, which went into effect January 1, 2015, changing the list of employers partially exempt from the above recordkeeping requirements.  The revised list uses the new method of classification of industries, the North American Industry Classification System (NAICS).  The partially exempt industry list includes: architectural, engineering, & related services; legal services; & drinking places (really!!!), as examples.  For the full list of exempt industries visit OSHA's website on recordkeeping.  In addition, to new exempt industries there are industries that have to start keeping records.  These industries include:  automotive dealers, building material & supplies dealers, & activities related to real estate, for example.  Find the industries that have start keeping records here.  

However, this does not exempt these industries or covered industries from reporting to OSHA, within 8 hours, any work-related fatality and reporting work-related in-patient hospitalizations, amputations, or losses of an eye within 24 hours.  This new reporting requirement was also part of the changes that went into effect on January 1, 2015.  Employers can report these events by telephone to the nearest OSHA Area office during normal business hours, or the 24-hour OSHA hotline 1-800-321-OSHA (6742), or electronically through a new tool which is being developed, look for it here.   Should you need any assistance with these requirements contact Future Environment Designs.

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• Have You Remembered To Post The OSHA 300A Form?(futureenv.blogspot.com)

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• OSHA Fines Increase By 78%, Will That Lead To An Increase in Safety Consulting & Training?(futureenv.blogspot.com)

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Wearable Technology In the Workplace

We just read the National Institute of Occupational Safety and Health's (NIOSH's) Science Blog regarding "The Future of Wearable Technology in the Workplace".  Wearable technology includes things like Fitbit, Jawbone, and things like Google glass or Microsoft's just announced HoloLens.  The potential to use wearable technology in the workplace to provide occupational safety and health information at the moment would be really useful.  Though the potential for distracted workers and some workers having health issues using the technology should give pause in rolling it out too quickly.  Considering all the new technology we've been keeping up with, we are very interested in seeing where wearable technology brings the occupational safety and health field.  Maybe some accidents could be prevented with the wearable technology.

Image of the ZYPAD wrist wearable computer from Arcom Control Systems (Photo credit: Wikipedia)

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HAPPY NEW YEAR!

Future Environment Designs (FED) want to take this time to wish you all a Happy New Year!  We hope 2015 is as good as you wish it to be and it is a safe and healthy one.  At Future Environment Designs, its another year of staying the course.  Our prices for asbestos refresher courses have not changed since 2007 and that will continue in 2015.  Over the years we started several initiatives which will also continue in 2015.  Our Safety Suzy Newsletter, which provides you with information regarding changes in Indoor Air Quality (asbestos, mold, lead, etc.) requirements, construction safety requirements, respirator use and fit testing, OSHA regulations, and NYS indoor air quality and construction safety regulations will continue.  We provide a loyalty discount to our clients who do their training with us every year and provide a referral discount to those who refer work to us (these discounts can be added together, see your monthly Safety Suzy Newsletter for details).  

In 2015 we will continue the following improvements:

• Future Environment Design's mobile site, will allow you to view upcoming courses and download safety resources in phone-friendly formats.  Your suggestions and feedback can help shape the experience.  Visit our website with your mobile device through this link:    http://www.futureenvironmentdesigns.com/index.html.  
• Future Environment Designs used to provide students in our classes with a course CD called the FED Training CD.  This CD had all the regulations and other helpful information.  With modern technology and advent of the cloud technology, we now provide a link to our dropbox folder that contains all this information.  You can find that link at: http://futureenvironmentdesigns.com/resources.html.
• Future Environment Designs is working on an app that we hope will be ready in time for the Professional Abatement Contractors of New York's (PACNY's) 19th Annual Environmental Conference at Turning Stone Casino.  
• Gloveguard (see below) is a product designed to help workers keep their work gloves close to them and increase their use.  Future Environment Designs is providing these to our students to help them keep their gloves with them and increase their use.

We look forward to seeing all of you in 2015, Happy New Year!

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Merry Christmas, One and All!

We wish you all a Merry and Joyous Christmas!

Thank you to all of you who attended training with us or who we consulted with in 2014.

We look forward to serving you in 2015!

From all us at Future Environment Designs, Inc

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Personal Protective Equipment (PPE), One Size Does Not Fit All.

In our previous blogpost, we discussed Ebola and the use of personal protective equipment.  Since then the Centers for Disease Control (CDC) has come out with revised guidance on purchasing PPE and protocols for wearing PPE while handling patients with the Ebola virus disease.  Find this information here.  

A disposable nitrile rubber glove. Nitrile gloves are available in different colours, the most common being blue and purpleCitation needed. (Photo credit: Wikipedia)

Fast Company Co.Design's article "Why Protective Gear Isn't Stopping Ebola" has an interesting discussion on the problems with PPE.  This discussion includes the usual complaints that its uncomfortable, it doesn't fit, restricts movement, visibility, etc.  It is interesting that before wearing a tight fitting respirator a worker must be either qualitatively or quantitatively fit tested with the respirator they will be wearing.  However, when it comes to PPE (like gloves or protective suits) there is no fit testing.  If you bought these items as clothing, you would try them on and purchase the best fitting one.
  

Asbestos Hands-on Demonstration

There is an unspoken assumption that the employer will purchase different sizes allowing workers to select the size that fits them the most comfortably.  This assumption is typically wrong and what actually happens is most employers buy larger sizes in the sense that one size fits all or they buy the size that fits the most people.  This results in complaints that wearing the PPE is more hazardous than not wearing it, which of course is the case if you are wearing ill-fitting or incorrect fitting PPE.

Wearing the proper PPE is not only about the right size, it is also about wearing the right type.  How many of you know that protective equipment are tested for how cut resistant they are?  The cut protection performance test (CPPT) is an American Society of Testing Materials (ASTM) F 1790 standard cut test for protective equipment.  A glove's performance rating is classified by the American National Standards Institute (ANSI)/International Safety Equipment Association (ISEA) 105-2005 from a 0-5 level, with 5 being the best cut performance, based on the outcome of the CPPT test.  Gloves are also tested for how long it takes for chemicals to breakthrough, degrade, or permeate the material the glove is made of.  ASTM F739 standard details the process for testing protective equipment for liquid and gas permeation (the video clip below shows how this is done).  Ansell Healthcare produces the "Chemical Resistance Guide" that includes permeation and degradation data for various glove material and a rating system.

When selecting PPE for your workers, unfortunately its not as simple as looking in a catalog and buying the cheapest PPE and/or buying one size that will fit most or all.  As the Occupational Safety and Health Administration (OSHA) standard (1910.133) requires for PPE, you must assess the hazard you want the PPE to protect the worker from and then find the best fitting PPE so the worker will wear it comfortably without creating a greater hazard.

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Ebola Virus - A Proper Perspective.

There has been a lot written about the Ebola viruses and the disease that it causes.  It is important to be well informed so that you can better know what is accurate information and what is misinformation.  In the old days, the main sources of information was television news, newspapers, or libraries.   Today, there is no excuse for succumbing to fear when accurate information is only a few clicks away.  There are several websites that will provide you with accurate information regarding ebola hemorrhagic fever which is caused by several strains of viruses in the Ebolavirus genus.  As a Council-certified Indoor Environmental Consultant one of our first resource website would be the Occupational Safety and Health Administration's (OSHA) Ebola website.  Here you will find information regarding the virus its background information, hazard recognition, medical information, Standards, control & prevention, and additional resources.  The standards section details the regulations OSHA expects employers, whose employees are at risk of being exposed to ebola, to comply with.  Obviously, the bloodborne pathogen (1910.1030); the respirator (1910.134); and the personal protective equipment (PPE) standards must be complied with in addition to the "general duty clause".  When cleaning and disinfecting, the hazard communication (1910.1200) and Sanitation (1910.141) standards would also have to be complied with.

English: Ebola virus virion. Created by CDC microbiologist Cynthia Goldsmith, this colorized transmission electron micrograph (TEM) revealed some of the ultrastructural morphology displayed by an Ebola virus virion. (Photo credit: Wikipedia)

Unfortunately, it is obvious mistakes were made, in Texas & by others, in the selection and wearing the safety equipment necessary to protect the health care workers from being exposed to the Ebola Virus.  The Centers for Disease Control (CDC) is the agency that develops these protocols and provides information and assistance in helping healthcare workers, click here for their Ebola website. Their website has a PPE training program to train you on donning (putting on PPE) and doffing (taking off PPE) the proper safety equipment.  These procedures are designed to ensure you do not contaminate yourself or others,  When properly followed the procedures should reduce the risk of the worker and others being exposed to the Ebola virus.  In addition, the CDC has posted "Advice for Colleges, Universities, and Students about Ebola in West Africa" which provides guidance on study abroad and foreign exchange.

None - This image is in the public domain and thus free of any copyright restrictions. As a matter of courtesy we request that the content provider be credited and notified in any public or private usage of this image. (Photo credit: Wikipedia)

New York State's Department of Health has an Ebola website, too.  This website provides information for the public, health care providers, hospitals, & EMS providers.  Information for the public includes "School Guidance on the Ebola Outbreak", which advises the health personnel for schools to stay informed about the current situation and have access to up-to-date, reliable information as events unfold.

As you can see there are plenty of websites and sources of information regarding Ebola and that's just the US websites.  Another excellent website is the World Health Organization's (WHO) Ebola website.  Their website also includes information on PPE, travel advice, fact sheets, and discussion of trials and production of ebola vaccine.  So don't allow fear to ruin your day, get the information you need to help you move forward,  As Franklin Delano Roosevelt said "The only thing we have to fear is fear it'self - nameless, unreasoning, unjustified, terror, which paralyzes needed efforts to convert retreat into advance."  So lets move forward!

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OSHA 300A Posting Required by February 1. Changes Coming for Recordkeeping.

This is your annual reminder that the Occupational Safety and Health Administration (OSHA) 300A injury and illness summary form is required to be posted from February 1 to April 30, 2014.  The 300A form is a summary of the information from the OSHA 300 injury and illness recordkeeping form.  You are not required to (nor should you) post the OSHA 300 form.  For more information on completing these forms visit OSHA's website at: https://www.osha.gov/recordkeeping/index.html. 

In addition, OSHA heard public comments from January 9-10, 2014 at the US Department of Labor in Washington DC.  OSHA held this meeting to give stakeholders the opportunity to remark on OSHA's proposed rule to amend recordkeeping regulations.  The amendment would require the electronic submission of injury and illness information to OSHA.  According to OSHA, the proposal would require electronic reporting by approximately 440,000 small companies (20+ employees) annually and larger companies (250+ employees), approximately 38,000 will need to submit injury and illness data on a quarterly basis.  This amendment does not add any new requirements; it just modifies an employer's obligation to submit these to OSHA.

These changes, according to OSHA, are necessary so that the government and researchers will have better access to data to encourage earlier abatement of hazards and improved programs to reduce workplace hazards and prevent injuries, illnesses, and fatalities.  OSHA also says that currently they only see 20 percent of the injury and illness data provided by employers.  Under the new system, they will see 50 percent of the data.

Needless to say, there are those who feel this is a good thing and there are those, many business representatives, who think well.......that public access to this data will encourage employers to underreport as a result of the potential negative impact on their businesses' reputations.  They are also concerned with liability.  Business representatives fear that posting injury and illness data online will open the business up to the pursuit of trial lawyers and unions.  Another concern of business representatives revolves around the costs associated with compliance, which can hurt business and job creation — especially the hiring of temporary workers.  Sounds like the usual business concerns, to us.

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