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Cal/OSHA Consultation Visits On The Rise

Posted by Terra Laverty
22 Jul 2022 06:59 PM

We have witnessed a rise in Cal/OSHA consultation visits and surprise enforcement inspections this year. Typically, these visits include an analysis of programs such as your Injury & Illness Prevention Program, Heat Illness Program, Training Program, and a walk-through inspection of your worksite.

To stay safe and be prepared, ensure your company safety programs are being implemented and are effective.  This means your programs are current and up to date, employees are experienced in the job being performed and employees have effective training in matters respective to their particular job assignments.

Your programs such as your IIPP and Heat Illness Program are required to be updated and reviewed annually at a minimum or whenever new substances, processes, procedures, or equipment are introduced to the workplace and represent a new hazard. These programs must be readily available for employees to access.

If Cal/OSHA Shows up:

SAFETY COACHING UPDATE SUBMITTED BY BEN W. LAVERTY, III, Ph.D., CSP, FACFE, REPA
 

1.Opening Conference: Issues to be reviewed.

  • a. Have IIPP available
  • b. Have training records available
  • c. Have disciplinary notice(s) available
  • d. Have 5 years of OSHA 300 Logs with current year included
  • e. Have 5 years of OSHA 300A Logs with current year included

2.  Escort Cal/OSHA person to incident scene using route least likely to offer the Cal/OSHA person a view of other operations.

3.  Be truthful and brief when answering questions.

4.  Do not share opinions on: injured individuals, (verbal or mutual), training programs, competency or supervisory personnel at time of inspection (get all available evidence first).

5.  Make copies of or note any statements made by Cal/OSHA inspector.

6.  If inspector takes a picture, a mirror image of that picture MUST BE taken by company personnel, developed, documented and put into the investigation file.

7.  Never argue with a Cal/OSHA representative.

8.  Do not ask if there will be a citation.

9.  Do not say that you think a citation should be written even if at the time you may think one is deserved. (Yet to be discovered evidence could change your mind…you will have difficulty in taking the statement back).

10.  Be on the alert for verbal entrapment. The inspector will often:

  • a. Ask, ask, ask – is the answer the same each time?
  • b. Implying “another” usually higher-ranking individual, said the facts were different.
  • c. Let Cal/OSHA expert draw and report on any preliminary conclusion, not you.
  • d. Don’t get hooked with “what do you think.” Answer with, “I’m holding off on making conclusions until I have all the information.”

11.Closing Conference: Listen and take notes.

 

ETS Covid-19 3rd Re-adoption

Posted by Terra Laverty
29 Apr 2022 08:29 PM

I hope everyone is doing well as the spring season begins.  I wanted to reach out to discuss Covid-19 regulations even though it is obvious that most of us humans have some Covid fatigue.

The Cal/OSHA Standards Board voted for a 3rd re-adoption of the Emergency Temporary Standard (ETS) T8 3205.  It is anticipated to be effective May 6, 2022.

The update includes several minor changes and clarifications, however, doing away with Covid regulations and relying on previous IIPP 3203 regulations or other significant changes were not made.  See link below to 28 page re-adoption document which shows changes.

Highlights – Executive Orders and CDPH orders take a precedence over the ETS. 

  • Surfaces are not specifically included as potentially infectious. 
  • Return to work testing can be documented by a time stamped photo instead of observation. 
  • Allowing light to pass through masks condition is eliminated from the new ETS requirement. 
  • “Fully vaccinated” definition has been eliminated. 
  • “Infectious period” terminology is used instead of “high risk exposure period.”
  • “Returned case” definition added. 
  • Employer not required to make testing available to returned cases. 
  • No requirement for unvaccinated to be masked indoors. 
  • Eliminated the requirement for 6 feet of distance from unmasked employees if employee is utilizing an exemption from mask wearing. 
  • Cleaning and disinfection requirements have been eliminated. 
  • Employers must provide masks and testing if symptomatic to employees upon request regardless of vaccination status. 
  • CDPH guidance shall be followed for close contacts. 
  • Return to work after close contact details in ETS have been eliminated including exclusion for vaccinated along with details concerning masking, six feet distance etc. 

(c) (10) Return to work criteria:

  • Negative test required if returning to work after 5 days from positive test, no symptoms but no test required if returning to work after 10 days. 
  • If you have symptoms and a positive test the symptoms must be resolving. 
  • Any positive tested employee must wear a mask when returning to work for 10 days. 
  • No testing is required for “returned cases” return to work under (c) (10) if no symptoms.
  • Close contacts need a negative test within 3-5 days or follow (c) (10). 
  • Distance employees as much as feasible language utilized.

Read link for 3205.2-4 changes.

https://www.dir.ca.gov/oshsb/documents/Apr212022-COVID-19-Prevention-Emergency-txtcourtesy-3rd-Readoption.pdf

https://www.dir.ca.gov/dosh/coronavirus/ETS.html

COVID-19 Prevention Emergency Temporary Standards

The COVID-19 Prevention Emergency Temporary Standards remain in effect. The workplace standards were updated in December 2021 to include minor revisions related to returning to work after close contact. The revisions became effective starting on January 14, 2022. In addition to these requirements, employers must follow public health orders on COVID-19. The latest order from the California Department of Public Health on February 28, 2022 provides new recommendations and requirements on the use of face coverings in certain circumstances and industry sectors. This order became effective on March 1, 2022. More information on the COVID-19 Prevention Emergency Temporary Standards is available in Cal/OSHA's Frequently Asked Questions.

Masks:

From Cal/OSHA FAQs –

Additionally, masks are strongly recommended for all persons, regardless of vaccine status, in indoor public settings and businesses (examples: retail, restaurants, theaters, family entertainment centers, meetings, state and local government offices serving the public); on public transit (examples: airplanes, ships, ferries, trains, subways, buses, taxis, and ride-shares); and in transportation hubs (examples: airport, bus terminal, marina, train station, seaport or other port, subway station, or any other area that provides transportation). Surgical masks or higher-level respirators (e.g., N95s, KN95s, KF94s) with good fit are highly recommended.

If you have any questions, please contact me.

Stay Safe!

Ben IV

Night Work in Agriculture

Posted by Terra Laverty
09 Mar 2022 01:49 PM

Agricultural workers have been known to work long hours traditionally from sunrise to sunset. There is no denying that working at night presents unique hazards that would not typically exist during the day. Night work or “hours of darkness” is defined as agricultural work activity that takes place between sunset and sunrise.

Effective July 2020, GISO §3449, requires agricultural employers to evaluate each outdoor worksite to ensure that adequate lighting is available during hours of darkness, and operations taking place between sunset and sunrise are illuminated to ensure safe work and visibility.

The illumination levels are dependent on the operation and task being performed, which is outlined below in Table 1 – Illumination Levels. Cal/OSHA uses the reference to foot-candles and lumens which are both units of measuring light.

For example, Workers must have a minimum illumination of 10 foot-candles when working within 25 feet of operating tractors, trucks, self-propelled or towed equipment.

It is also required that safety meetings conducted at the beginning of each shift include how to safely access restrooms, drinking water, designated break areas, nearby bodies of water and high traffic areas. Class 2 high visibility garments must also be provided and worn by workers.

Table 1

Foot-Candles

Lux

 Operations Areas or Tasks

0.09-0.19

1-2

Poultry harvesting or catching operations.

3

32.29

Meeting area and meal/rest area.

5

53.82

Outdoor agricultural operations except where otherwise specified in this table.

Pathways leading to and around restrooms and drinking water.

Inside restroom facilities.

Storage areas accessed by employees.

10

107.64

Intermittently exposed or exposed point of operation equipment, covered under

Group 8. Points of Operation and Other Hazardous Parts of Machinery.

Operationally visible moving parts of machinery covered under Group 6.

Power Transmission, Prime Movers, and Machine Parts of the General Industry Safety Orders.

Task lighting for agricultural operations that involve the use of tools that can

Potentially cause cuts, lacerations, or punctures.

20

215.30

Task lighting for maintenance work on equipment.

For more information and to schedule an inspection with CSTC® call us at 661-377-8300 or email biv@cstcsafety.com.

Tractor ROPS Labeling

Posted by Terra Laverty
15 Feb 2022 06:31 PM

Tractor accidents on farms cause the highest number of fatalities. Tractor turnovers accounting for 44 % of all tractor fatalities. Roll-Over Protective Structures (ROPS) provide a safer environment for the tractor operator in the event of a rollover. Per CCR T8 §3651, where a recognized hazard exists, operator protection from falling or rolling objects shall be provided by either ROPS or other independent means compatible with the use of ROPS.

ROPS must also bear a label, the labeling must include the following information:

Text

Description automatically generated
(1) Manufacturer's or fabricator's name and address;

(2) ROPS model number, if any;

(3) Tractor makes, models, or series numbers

that the structure is designed to fit;

(4) A statement of compliance with the appropriate

ASAE Standard or SAE Recommended Practice;

Labels shall be stamped plates or other permanently attached means of identification, and shall not be obscured, obliterated, or changed. CCR T8 §3651(d)(1-4)

In addition to proper labeling, remember operators must always wear their seatbelt when operating equipment where rollover protection is installed.

If you have questions or would like to schedule a Program Audit and Safety Inspection with California Safety Training Corporation®, Contact us at 661.377.8300!

Reminder: OSHA 300 Logs to be posted by tomorrow

Posted by Terra Laverty
31 Jan 2022 03:09 PM

 

Don’t forget to fill out, submit(as required) and post(Form 300A only) your OSHA 300 logs February 1 – April 30.  Forms can be found at https://www.osha.gov/recordkeeping/forms.

Recordables are an illness that is work-related and result in one of the following:

  • Death
  • Days away from work
  • Restricted work or transfer to another job
  • Medical treatment beyond first aid
  • Loss of consciousness
  • A significant injury or illness diagnosed by a physician or other licensed health care professional.

The forms must be filled out even if no recordable illnesses have occurred.

 

Outdoor Workplace Challenges

Posted by Terra Laverty
15 Jul 2021 03:16 PM

Outdoor Workplace Challenges

 

 

HIGH HEAT Central Valley California.

Posted by Terra Laverty
06 May 2021 08:37 PM

If you are living in the warm climate of the San Joaquin/Central Valley of California, then heat illness is an environmental reality.  This week the temperatures are over 95 degrees which is the “high heat” threshold for several California regulatory requirements including a morning tailgate meeting to encourage workers to drink enough water(see below CSTC’s email tailgate).  Companies must provide 1 quart per person per hour throughout the day.  If you are working 10 hours this could be accomplished by having a 2.5 gallon insulated jug with procedures for replenishment.  Employers must also provide a 10 minute cool down recovery period for every 2 hours worked in temperatures over 95 degrees. 

 

For us at CSTC we utilize an email to communicate to our instructors/inspectors for the tailgate reminder.  For complete requirements see Cal/OSHA Title 8 3395.

 

Have a great and safe day!

Let's Start 2021 Out Right

Posted by Terra Laverty
27 Jan 2021 08:10 PM

First blog of 2021 and I’m avoiding another Covid-19 compliance discussion.  So, I asked my good friend Tricia Bland, a Registered Dietitian Nutritionist, with several decades of professional experience:  What should I eat to help me resist the Covid-19 virus?
She sent me 2 short pages containing 7 herbs and 8 food sources which can help boost your resistance and reduce inflammation.  Some of my daily favorites on the list are cinnamon and almonds which made me feel great about some of my diet…:)  If you want to get more information, please reach out to Tricia at www.triciabland.com
 
For me, the formula for success has been diet (healthy breakfast) , daily exercise (walking or gardening count), sleep (at least 7 hours) and stress management (10 minutes of meditation).  Hope this helps!
 
Have a great and safe 2021!

Ben Laverty IV

 

The Best Herbs for Reducing Inflammation

Anti-Inflammatory Meal Planning

Cal/OSHA Ag COVID-19 Checklist, CSTC CSP COVID-19 Update, Worksite Specific COVID-19 Plan Checklist

Posted by Terra Laverty
07 Jul 2020 12:26 AM

Cal/OSHA has been visiting worksites and asking for and or utilizing the general checklist attached to enforce COVID-19 protocols.  Please see the link for the Cal/OSHA Ag checklist specific to COVID-19 and note that when the CSTC worksite specific document (see link) is utilized with the IIPP topic (see link) then the checklist items are addressed.

 

Cal/OSHA COVID-19 Checklist for Ag

 

IIPP-CSP COVID-19 Update 6.25.20

 

Worksite Specific COVID-19 Prevention Plan Checklist

 

We are here to support you.  Please reach out to any of our staff.

 

Stay Safe! Stay Healthy!

 

CSTC Team

 

COVID-19: The Rough... AND The Good

Posted by Terra Laverty
12 Jun 2020 12:03 AM

Two weeks ago I did a Zoom meeting presentation on COVID-19 for my business networking group here in Hawaii.  After sharing the PowerPoint with Ben (my brother and colleague), he thought it would be great to share with all of you.  If you would like to talk about any of the information in the slides or want further details of the presentation, please reach out to me.  I would love to share and chat. 

 

CSTC COVID-19 TLAV 5.2020

 

Stay Safe!  Stay Healthy!

We are all in this together!

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