Monday, December 22, 2008

Fall protection and skylights

Apparently, the ASTM has a work group looking into the development of a skylight fall protection test standard.

A manufacturer's group has published a salvo across the bow, saying there are issues. My interpretation of their issues are:

  • The data out there has been inaccurately presented
  • Needs more study-- we don't have enough facts
  • This is really complicated
  • We need to be reasonable about this
Hmm.... Anyway, if you get past all those stall, deflect, and distract strategies, they do have some pertinent suggestions: conduct a hazard assessment; mitigate the hazards through engineering control, operation protocols or PPE; minimize the risk by minimizing the number of personnel authorized to access the roof; train personnel on the hazards and controls; and employ appropriate signage. I can't argue with that.

Link:
http://www.aamanet.org/upload/Skylight_Council_Position_Paper_rev_Dec_08.pdf

Nanomaterial risk review

The federal government's plan for researching the health and environmental risks of nanomaterials has "serious weaknesses," says this report from the National Research Council.

Links:
http://books.nap.edu/openbook.php?record_id=12559&page=R1

Tuesday, December 16, 2008

Audit results: Santa's Workshop

SUBJECT: Safety Inspection of Santa’s Workshop.

1. Background. Santa’s workshop (SW) incorporates a range of workers, laborers and elfs from various backgrounds and skill levels. Some are registered as skill laborers and some as basic laborer, carpenters and master carpenters. A wide variance in health hazards exist in the workshop are present that place workers at risk. This report characterizes these hazards.

The walkaround was accompanied by Elf representatives from each of the respective work centers at SW so that each group was allowed to participate. The inspection was divided into sections so that each area received equal attention.


2. Findings. The inspector performed a comprehensive review of this workplace from December 1 through 12th during the height of activity. The following activities were observed:

a. Woodshop activities
b. Loading/unloading activities (Packing and transportation)
c. Radiation Protection.


a. Woodshop activities. The woodshop activities consist of skilled and unskilled carpenters and laborers involved in the development, fabrication, and finishing of toy products for general consumption of the public. Each of the areas lacks essential local exhaust ventilation (LEV) for protection of elfs and workers. There is a question whether the exposure to wood dust is in excess of the airborne standard outlined in the ACGIH TLV booklet, 2008. Housekeeping was poor around saws, workstations and break areas. Elfs complained about the height of workstations and the need for step-stools. Using the standard fall protection standard for elves, the working height limit would be 2 feet (29 CFR 1910). The use of paints, solvents and adhesives will be evaluated on a subsequent visit.

b. Loading/Unloading Activities. The tables in ACGIH, Table 1, do not apply for elves because these standards are based on standard man, not elf. Recommended limit was 16 kg was reduced to 4 kg based on size and strength. This standard is consistently exceeded at SW. A full comprehensive ergonomics evaluation is recommended.

c. Radiation Protection. The primary radiation at SW was identified as an organic source: Rudolph’s nose. The spectrum of the electromagnetic radiation has been identified as non-ionizing. The light is in the range of 595 nm and extends into the near infrared. It presents retinal spectral hazards to any individual within 2 meters and is limited to 0.1 W/cm2. This source produced actinic light capable of causing temporary blindness. Elfs complained of needing to purchase sun-glasses when in close proximately to the Nose during loading/unloading activities. Company provided eye wear is needed for all loading/unloading personnel.



3. Results. Numerous violations of OSHA, ACGIH standards were identified at SW. It appears that managers were aware at least in part of some of the deficiencies. However, they were amenable to immediate correction of deficiencies following the Holiday rush. A penalty will not be considered because SW recognition of hazards and the employer’s “good faith” in correcting these deficiencies.

EPA Proposes Final Authorization of State Hazardous Waste Management Program Revision



EPA has proposed to authorize Wisconsin's Hazardous Waste Management Revisions which took effect in August 2006. The proposed rule can be found at:

Of interest to me was a (rather lengthy) table that correlates Federal provisions with former NR provision, as well as the recodified NR provision.

Also:

G. Where Are the Revised State Rules
Different From the Federal Rules?
These practices are prohibited in Wisconsin: Underground Injection (40 CFR Part 144), and Land Treatment (40 CFR 270.20). Wisconsin also does not provide for Permit by Rule (40 CFR
270.60). Wisconsin does not allow automatic authorization under the permit modification regulations found in 40 CFR 270.42 (b)(6). The 10 year Remedial Action Plan, or RAP (40 CFR
270.79 et seq.) is replaced by a 5 year Remediation Variance (NR670.079). These Wisconsin regulations are more stringent: 662.220(5)(c,d), 662.220(6)(c,d,f), and 670.030 (annual
report required instead of a biennial report). Wisconsin maintains different financial regulations that allow for additional equivalent financial mechanisms (664.0143), do not allow the net worth test for closure under Part 665, and maintain some more stringent insurance requirements under 664.0143(5)(h), 664.0147(1)(a)(3), and 665.0147(1)(a)(3). The following Wisconsin regulations have no Federal counterpart: 666.081, 666.900 through 666.910, and 673.11.
There are no Wisconsin provisions for 40 CFR 268.5, 268.44 (other than 268.44(h)), and 270.3 as these are Federal non-delegable provisions.

Tuesday, December 9, 2008

Distracted driving


A day after reading "Weighing distracted driving risks," an article in Safety+Health magazine, I stumbled across reference to recent research showing that drivers make more mistakes when talking on a cell phone than when talking to passengers.

The research addresses the common question about whether driver distraction comes from cell-phone use specifically or conversation generally. Even when drivers used a hands-free cell phone, driving performance was significantly compromised. The findings appear in the Journal of Experimental Psychology: Applied (American Psychological Association).


“Passenger and Cell Phone Conversations in Simulated Driving,” Frank A. Drews, PhD, Monisha Pasupathi, PhD, and David L. Strayer, PhD; Journal of Experimental Psychology: Applied, Vol. 14, No. 4.

Got PPE?

Difficulty in getting employees to wear PPE is not limited to colleges and universities, at least not according to this report in FacilityBlog/TFM (from Today's Facility Manager magazine).

A recent survey conducted by Kimberly-Clark Professional found that 89% of safety professionals polled have observed workers failing to wear personal protective equipment (PPE) when they should have been.

Wednesday, December 3, 2008

Final Definition of Solid Waste Rule


On October 7, 2008, the Environmental Protection Agency issued a new final rule that streamlines regulation of hazardous secondary materials to encourage beneficial recycling and help conserve resources. By removing unnecessary regulatory controls, EPA expects to make it easier and more cost-effective to safely recycle hazardous secondary material.

The final rule and associated documents can be found here:

The rule excludes materials from the federal hazardous waste system that are:
•generated and legitimately reclaimed under the control of the generator;
•generated and transferred to another company for legitimate reclamation under specific conditions; or
•determined by EPA or an authorized state to be non-wastes on a case-by-case basis via a petition process.
The rule also contains a provision to determine which recycling activities are legitimate under the new exclusions and non-waste determinations. These exclusions are not available for materials that are considered inherently waste-like, used in a manner constituting disposal, or burned for energy recovery.

We cannot use the provisions until WIDNR adopts them.

EPA accepting comments on nanoscale silver

EPA has published in the Federal Register a notice requesting public comment on a petition filed by the International Center for Technology Assessment (ICTA) et al. The petitioners note the rapid increase in the number of products containing manufactured or engineered nanoscale materials.

They further point out that scientists have identified that nanoscale materials can have fundamentally different properties from the non-nanoscale or bulk forms of the same compounds, and that these unique properties may pose new environmental and human health risks.

Additionally, the petitioners review EPA’s procedural history with respect to nanotechnology and conclude that the Agency has not provided adequate regulatory oversight for this emerging technology.

The petition requests that the EPA:

  • classify nanoscale silver as a pesticide,
  • require formal pesticide registration,
  • analyze the potential human health and environmental risks of nanoscale silver, and
  • develop appropriate regulatory oversights for nanoscale silver products.
The Agency has determined that the petition raises issues that potentially affect private and public sector stakeholders. Through this notice, EPA is asking for public comment, which may be submitted through January 20, 2009.

Monday, December 1, 2008

DNR Publication about Sharps Disposal


DNR has posted a new publication describing Wisconsin sharps collection program:


Contact information


Office of Safety and Loss Prevention
University of Wisconsin System Administration
(608) 262-4792
 
Clicky Web Analytics