There is no such thing as common sense.
What is obvious to one person may not be obvious to another, according to Bethany Graves (Watson), a consultant specializing in occupational safety based out of Jefferson City.
Graves specializes in helping companies conform to Occupational Safety and Health Administration guidelines.
She recently presented a program to the Jefferson City Area Chamber of Commerce, in which she explained the agency’s requirements, including employer and employee responsibilities, record keeping, training and written programs.
She explained some of OSHA’s standards and guidelines.
The organization has a lot of guidelines.
It must, Graves said, if it is to keep workers safe from harm.
Despite OSHA’s work, more than 4,500 U.S. workers die in work-related incidents in private industry every year.
For calendar year 2017, there were 4,674 worker fatalities. Of those, 971 (one in five) were in construction. The leading cause of private-sector worker deaths in construction (excluding highway collisions) were falls, then “struck by object,” electrocution and “caught in or between.”
According to the agency website, osha.gov, the top 10 most frequently cited standards violations in 2017 were lack of fall protection, failure to provide hazard communication, failure to meet scaffolding requirements, lack of adequate respiratory protection, lack of lockouts or other controls to prevent electrocution, improper use of ladders, violations of “powered industrial trucks” (or forklifts) regulations, lack of fall prevention training, failure to provide machine guards (to keep employees from moving parts), and eye or face protection.
On its website, the agency provides its guidelines for all industries in a 270-page document. Additional training information may be found elsewhere, according to the document.
The agency divides its safety guidelines into four categories, Graves said, general industry (which is generally made up of businesses that are static and do not fall into the other categories), agriculture, construction and maritime.
“Each industry has specific requirements,” said Graves, whose company, 365 Safety Services, does safety consulting for companies. “Some standards (within those industries) have even more requirements.”
For example, within fall protection standards, there is what is called the “competent person,” who is responsible for the fall protection program and equipment and making sure everyone is using it properly.
The website also provides safety and training materials.
Graves helps businesses prepare for what happens if the agency does an inspection, tells them about how it works and explains businesses record-keeping requirements.
Basically, OSHA says employers must train their employees on everything — even how to put on safety glasses.
“If they’ve never done it before, you do,” she said. “The big thing is teaching employees the limitations of those glasses. When you’re grinding, you need to have a face-shield on, too. So, it’s the limitations of the types of protective equipment.”
If someone has never hammered a nail into a board, and that’s their new job, they need to be trained how to do that, she said. In noisy work environments, where ear protection is necessary, an employer has to train the employees how to install ear plugs.
“You need to train them in where ear plugs are required in the facility or on a construction job site, or on when the employee is using specific tools or equipment,” she said.
She suggested if employers aren’t certain if hearing protection is required that they go online and download a noise app for their phones. There is a variety of such apps on the App Store for prices ranging from $1-$20.
If the app produces a reading over 90 decibels, the employer may need to do a noise level survey, which basically determines an average of the noise over eight hours.
Respiratory protection is determined in a similar survey.
Proactive companies that have components of respiratory hazards have very particular requirements for respiratory tests. They require new employees to fill out an extensive medical questionnaire, receive a pulmonary function test and be examined by a physician.
“All industries might need it, including construction,” Graves said. “The smart companies have baseline hearing tests done upon hiring of a new employee. If they already have hearing loss — let’s say they like to four-wheel, shoot guns and listen to loud rock and roll — they may have already experienced some hearing loss. That’s on the record and not attributable to the company.”
Graves said she always recommends that companies, except for those with an office atmosphere, do hearing tests.
OSHA has two sides — inspections/compliance and consultations. The consultation side will come into a facility for free and do a comprehensive assessment, if requested. The organization will then write up a report and tell the company what it needs to improve on.
OSHA isn’t the scary organization many people make it out to be, Graves said.
“They’ve evolved a lot even since I’ve been involved in safety,” she said. “They used to focus on the compliance side. Now, they focus a lot on the company side of things. They want to provide consultations. They want you to train your employees. They provide online training. And they’ll come out and train as well.”
Companies should never know when OSHA is going to show up for an inspection. It is illegal for the agency to notify a company of an impending inspection.
There are numerous reasons the agency may show up at a work site or company — if there were a fatality, if the agency received an employee complaint, if the business were the site of a serious injury where someone was overnight hospitalized, if there was an amputation or even because it’s part of the agency’s local emphasis.
If OSHA sees a rise in certain kinds of work-related injuries, it may focus on a particular industry.
“One year, they focused on funeral homes. Why would they focus on funeral homes?” Graves asked. “Formaldehyde. People were being exposed to formaldehyde.”
Upon arrival at a site for an inspection, OSHA officials would begin by showing their credentials. They would then conduct an “opening conference” to tell the employer why they are there, such as one of the aforementioned causes.
The third part of the visit is the inspection itself.
“I’ve known companies that — on the inspection — (investigators) just said, ‘We want to see your OSHA logbook,’” Graves said. “They may just want to see your paperwork.”
Or they may simply want to see one portion of a plant.
On the other hand, inspectors can also observe from across the street for two days and then walk in, completely unannounced.
“Maybe they just saw a job site that looked terrible — a guy working on a third-story roof with no fall protection,” Graves said. “That’s terrible. That’s what’s called ‘imminent danger.’ In that case, they probably wouldn’t sit across the street for two days. They would actually go up right then.
“They don’t want anyone to die on the job.”
The fourth step of an inspection is called the closing conference. It doesn’t happen at the time of the inspection. The inspector takes the data back to an area director, who determines which citation, if any, will be issued to a company and the fine associated with it.
Graves said that when she’s consulting with companies, she talks about safety not only within the workplace, but also at home. A person can just as easily receive a serious injury at home as they can at work, and that would prevent them from receiving a paycheck.
Young people coming into a construction company who have never used a hammer or saw before may just want a paycheck, Graves said. They don’t realize that what they do today is going to affect them for the rest of their lives, especially if they maim or seriously hurt themselves.
“I’m very passionate about safety. I always feel like no one should go to work and not come home,” she said. “What’s common sense to you is not common sense to me.
“One thing I hear from employers is, ‘It’s just common sense. He should know not to do that.’ I don’t believe anything is common sense.”