ehs/hr best practices teleconference 4th quarter hunter douglas inc. december 18, 2014

EHS/HR Best Practices Teleconference 4th

QuarterHunter Douglas Inc.December 18, 2014

EHS/HR Best Practices QuarterlyTeleconference

Agenda

• Recordkeeping Changes Reminder – Second Rule Information

• Lithium Battery Shipment Changes• NFPA 70E 2015 Edition Information• OSHA Employee Interviews – Rights for

Employees and Employers• State News - Utah• GHS Labels May Delay Your Air

Shipments• Sleepy & Unsafe - - Sleep Deficiency

Discussion• Upcoming events – Next Meeting


New Reporting Requirements – January 1, 2015• All work related fatalities must be reported to

OSHA within 8 hours.• All in-patient hospitalizations, amputations,

and losses of an eye within 24 hours of finding out about the incident.– Amputation is defined as “the traumatic loss of a

limb or other external body part. They include a part, such as a limb or appendage that has been severed, cut off, amputated (either completely or partially); finger-tip with or without bone loss; medical amputations resulting from irreparable damage; amputations of body parts that have been reattached. They do not include avulsions, enucleations (eyeball removal), deglovings, scalpings, severed ears, or broken or chipped teeth.”


Recordkeeping Rule – Part Two - - the second rule is going through the rulemaking process and is broader in scope. Key points to the rule:• Employers with more than 250 employees would be

required to electronically submit quarterly information from their injury & illness records.

• Employers with 20 – 249 employees where there are days away from work, job restriction or job transfer rates averaging 2.0 or greater would also be required to electronically submit information from their OSHA 300a.

• This information will be made available on its website as part of a searchable database, including:– All data fields from the 300a form– All data fields from the 300 log except the employee’s name


Recordkeeping Rule – Part Two (Continued)– Certain data fields from the OSHA 301 form, including the time

of the event, what the employee was doing prior to the incident, what occurred, what the injury or illness was, and what object directly harmed the employee.

• Concerns being raised - - The National Safety Council and others are concerned about how OSHA will ensure the privacy of the injured worker.

• OSHA said it would be responsible for “scrubbing” personal data off the logs it releases to the public. Keep in mind the agency would receive thousands of logs every quarter . . . are they prepared?

• Specific data fields – name, address and DOB can be blocked out, however it will be more difficult to scrub the details in the narrative.

Scheduled final action on rule is March

EHS/HR Best Practices QuarterlyTeleconferenceLithium Battery Shipment Changes • As of January 1, 2015 Lithium metal batteries

packed by themselves (not contained in or packed with equipment) are forbidden for transport as cargo on passenger aircraft. They will need to be shipped on Cargo aircraft only and bear new labels that note they are Forbidden For Transport Aboard Passenger Aircraft.

• Lithium ion and Lithium metal cell batteries require dangerous goods training, limit on quantity per package, specific packaging, specific labels and marking, and shippers declaration of dangerous goods.

• A Lithium Battery Guidance Document has been uploaded to the Corporate Safety Intranet under Tools


NFPA 70E 2015 Edition Changes• Eliminated the prohibited approach boundary,

however there are still shock hazard and arc flash boundaries that must be understood.

• The restricted approach boundary is closest to the energized equipment and may only be crossed by qualified workers with the proper PPE.

• Unqualified workers can cross a limited approach boundary only if they are in the proper PPE and accompanied by a qualified worker.

• The arc flash approach boundary is the boundary that requires any person who crosses it to be in the appropriate arc flash PPE.


NFPA 70E 2015 Edition Changes (continued)• Another change to be aware of involves work

permits. Any time the restricted approach boundary is crossed, a work permit will now be required. (A work permit may not be required when troubleshooting, testing or voltage measuring is taking place).

OSHA Employee Interviews – Rights for Employees and Employers• Employees can have private, one-on-one

interviews without fear of retaliation, can refuse to be interviewed, may elect to have a person of their choice attend the interview and can end the interview at any time.

EHS/HR Best Practices QuarterlyTeleconferenceOSHA Employee Interviews – Rights for Employees and Employers (continued)• Employees can also refuse to sign statements, and

be tape recorded or photographed. They are not required to provide contact information nor are they required to have the interview occur at the workplace.

• Employees have the right to legal counsel if they choose. They must also be informed that by agreeing to be interviewed they may expose themselves to potential criminal liability in the future since it is impossible to anticipate charges that may result from the inspection.

• It is worth noting that compliance officers are not required to give employees Miranda warnings, which may cause employees to incriminate themselves during the interview. Language barriers may cause issues in communicating clear answers.


OSHA Employee Interviews – Rights for Employees and Employers (continued)• Employers reserve the right to inform employees

of their rights during inspection. They must allow an employee to be interviewed by OSHA if the employee consents.

• Employers also have the right to participate in non-private employee interviews, and they also can attend interviews of employer management representatives.

• Employers can also end the interviews if they are disruptive in the sense that they are unreasonably interfering with ongoing work, or if they become confrontational.

• OSHA will not inform employees of their rights but there is no law that says employees can’t be made aware of them prior to an inspection.


State News - - Utah Launches Initiative on Amputation PreventionUnder a Local Emphasis Program (LEP) that began in November, Utah OSHA plans to closely examine establishments that use equipment or machinery such as conveyors, drills or saws – known to cause amputations. Compliance officers are instructed to pay close attention to worker exposure to points of operation during a machine’s regular use, cleaning, setup and clearing of jams. As a Best Practice, all facilities should take the same direction compliance officers are going to take and inspect your conveyors, drills or saws at the point of operation to ensure elimination of all potential areas for injury.

EHS/HR Best Practices QuarterlyTeleconferenceGHS Labels May Delay Your Air Shipments• Publication of the new GHS Standard was March

26, 2012, implementation by all of us is mandatory by June 1, 2015.

• The new labeling requirements may overlap with DOT’s Hazardous Materials rules which may cause a delay in any chemical shipments you are expecting.

• OSHA may regulate a chemical substance that DOT does not, packages will require the necessary GHS label and warnings only, it does not include any type of DOT information.

• Air shipments will fall under the IATA Dangerous Goods Regulations. Packages will need to be scrutinized when they have a GHS label to ensure the chemical is not regulated as dangerous goods under IATA.


GHS Labels May Delay Your Air Shipments (Continued)• To prevent delays when shipping OSHA-only

hazards by air, IATA suggests that shippers write the words “not restricted” on the waybill to indicate that the materials are not IATA dangerous goods.

Sleepy & Unsafe - - Sleep Deficiency Discussion Are your employees sleep deprived? Did you know a survey conducted in 2012 found that 11% of transportation workers admitted showing up to work feeling sleepy?Additionally, 20% of pilots and train operators and 15% of truck drivers said lack of sleep had directly caused at least one serious incident or near miss in their careers.


Sleepy & Unsafe - - Sleep Deficiency Discussion (Continued)• A study published in the Journal of Occupational

and Environmental Medicine concluded that sleep deficiency was associated with higher rates of musculoskeletal pain and functional limitations.

• Inadequate sleep affects many essential aspects of working safely. Sleep deprivation can significantly reduce workers’ reaction time, motor control, decision-making ability and situational awareness.

• Research shows that people in the US get 20% less sleep than a century ago. “if you are going to work more hours, you are going to spend less time on sleep – because you are not going to spend less time on family and friends . . . “


Sleepy & Unsafe - - Sleep Deficiency Discussion (Continued)• Over time , workers become very limited in their

ability to detect how sleepy they actually are. Recognize the signs of sleep deprivation:Physical signs: Frequent yawning, dropped head or eyelids, rubbing ones eyes, and microsleeps. Mental & performance signs: Difficulty in ability to concentrate on tasks, inattention, compromised memory & recall, forgetting to communicate important information, & incorrectly performing tasks.Emotional & behavioral signs: Becoming uncharacteristically quiet, withdrawn or moody, low energy, & lacking motivation to perform work well.


Upcoming Events – 2015

Imagewave (MSDS/SDS) SystemJanuary – Training to upload you own

MSDS/SDS’s into the system – date(s) to be determined

Safety Conference – Broomfield, ColoradoTentative dates: August 11 & 12, 2015

(Start planning your Best Practices presentation)

Liberty Mutual – Safety Net Demo February 25, 2015 2:00 PM Eastern


Next EHS/HR Best Practice Quarterly Teleconference

March 19, 2015 – 3:00 PM

Have a Safe and Merry Christmas and New Year!!

ehs/hr best practices teleconference 4th quarter hunter douglas inc. december 18, 2014

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