ORC HSE Viewpoints


Category archive of ORC HSE Viewpoints

Lead Poisoning & OSHA: Is it Time to Reconsider?

I recently read a piece on lead poisoning in the May 2019 edition of Scientific American magazine in the “50, 100 & 150 Years Ago” section. The short write-up was entitled 1969 – Lead Poisoning Epidemic and reads as follows:

“Though lead pigments were eliminated from interior paints in the U. S. some 20 years ago, multiple layers of lead-based paint still cover the walls and woodwork in many old houses and apartments. Therefore, lead poisoning, once an occupational hazard for painters, is now primarily a disease of small children and toddlers between one and five who live in slum housing and nibble steadily at the paint that flakes off dilapidated walls and can be gnawed off peeling windowsills. At a conference at Rockefeller University in March (1969) participants estimated that lead poisoning in children is much more prevalent than is generally assumed, but they pointed out that the ‘silent epidemic’ could be eliminated by aggressive medical, social, and legal action.”

OSHA’s Rulemaking Process: Why Does it Take So Long?

A question I receive frequently is “Why does the OSHA setting of a standard take so long?” The reasons are many. Multiple requirements – statutory, legislative, judicial, and administrative – combine to slow the standards development process.

ORC HSE Book Review: How Could This Happen? Managing Errors in Organizations

If you feel happy, is it time to be concerned? You have likely seen the video of singer Pharrell Williams’ infectious song featuring the refrain—- I’m Happy! When it comes to safety, we may need to sing a different tune. How Could this Happen: Managing Errors in Organizations is a compilation of 17 papers by authors with wide-ranging approaches to error management. Edmondson and Verdin quote John Carroll’s research that in many organizations “workers are worried, supervisors are concerned, managers are mixed, and executives are happy!” Carroll’s observation reminds me of the Iceberg of Ignorance frequently presented by Allergan’s David Eherts. Carroll and Eherts’ ideas strike me as two sides of the same coin.

OSHA Inspections and Document Requests

Over the last several years ORC HSE has received enquiries from member companies in regard to excessive document requests at the beginning of an OSHA inspection. In some cases the requests by the Agency for documents and copies of programs will run two or more pages in length. These requests are provided to the employer during the opening conference. The concerns raised by ORC HSE member companies is that the requests seem open-ended, are very long, and contain requests for information that do not appear to be at all related to the reason and scope of the OSHA inspection as explained by the compliance officer. According to these companies the time involved to produce the items asked for would be excessive, especially for a limited scope inspection.

OSHA’s Treatment of Voluntary Employer Health and Safety Self-Audits

In 1996, ORC HSE (formerly ORC) visited the Occupational Safety and Health Administration (OSHA) on behalf of several member companies to request that the agency limit OSHA compliance safety and health officers’ practice of asking to see employer self-audits during the normal course of their inspections.

OSH Network Special Event: Meet Dr. Sidney Dekker

We are very excited to announce that one of the world’s foremost experts on incident causation and human error, Sidney Dekker, will provide unique opportunity to learn and interact with him at our OSH Group meeting on February 6, 2019. Dr. Dekker’s ideas have created a revolution in thinking throughout the safety world…

A Blow to OSHA Enforcement

A recent decision by the U.S. Court of Appeals for the 11th Circuit has dealt a serious blow to OSHA’s long-standing authority in determining the appropriate scope of safety and health inspections.

ORC HSE Comments to OSHA on Tracking of Workplace Injuries and Illnesses

ORC HSE Partner Steve Newell and colleagues have submitted comments on OSHA’s Notice of Proposed Rule Making (NPRM) “Improve Tracking of Workplace Injuries and Illnesses” that appeared in the July 30 Federal Register.

Cardinal Rules, Employee/Management Collaboration, and Improving Safety Performance

Cardinal Rules have been around for a long time and can go by a variety of names, such as Golden Safety Rules, fundamental rules, critical rules, etc. Simply put, they are usually a set of rules about the behavior of frontline employees that the employer has identified as important to good safety performance and accident prevention in their operations. Some can be common across companies like “always de-energize equipment before working on it”, while others may be very specific to a particular company and its operations. Historically, they have often been implemented with some form of “zero tolerance” policy that says something like “if you violate these rules you will be disciplined, up to and including termination”.

PPE Hazard Assessments – Are you meeting all of the requirements?

An Amazon Fulfillment Center is contesting an Other-than-Serious (OTS) citation with a $1,000 penalty for not meeting all of the requirements in the personal protective equipment (PPE) hazard assessment regulation – specifically 29 CFR 1910.132(d)(2). Ask almost any EHS professional and they will say, of course we know PPE hazard assessments are required. What may be forgotten, however, is the level of documentation that is also required.