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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

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

 

Heat Illness Prevention and COVID-19

Posted by Terra Laverty
08 May 2020 07:40 PM

95° + temperatures have hit in the Central Valley.  We are updating Heat Illness Prevention Programs to incorporate Covid-19 precautions. In this blog we are focusing on two specific areas: water and shade.

 

First, I’d like to address water as everyone needs to be consuming adequate fluids, especially when the weather is hot. It’s important to follow personal hygiene and sanitization practices for commonly touched surfaces.  Igloo jugs to fill single use cups will need to be monitored and sanitized appropriately.  Even the single use water bottles will need to be handled with proper personal hygiene caution. As always, make sure you are providing sufficient quantities of cooled fresh water at 1 quart per person per hour in the workplace.

 

Preventative recovery rest breaks is the next area to be addressed.  Shaded rest areas must be provided.  For every two hours worked employees must be provided with a preventative rest period of at least 10 minutes. Employers must take additional measures to be sure that employees can take a break in a shaded area while obeying social distancing of 6 feet.

Employees should be trained to keep 6 feet of social distance during breaks and transportation to prevent infection.

 

In California, Cal/OSHA will continue to enforce regulations associated with COVID-19 and hazards associated with the workplace including heat illness and other applicable hazards. Please review your Heat Illness Prevention programs with a review of your specific COVID-19 procedures. 

 

Please contact us if we can help you in adjusting your plans accordingly.

 

Essential Industries with an employee who tests positive for COVID-19

Posted by Terra Laverty
05 May 2020 02:55 AM

Essential Industries with an employee who tests positive for COVID-19

  1. Isolate sick worker from other employees.
  2. Inform other employees while protecting privacy under HIPAA laws.
  3. Perform a contact tracing of the employee at your workplace for the previous 14 days including contractors and suppliers who may have been in close contact* with the infected worker.
  4. Sanitize surfaces which the worker may have touched including tools and transportation.
  5. Monitor employees who were potentially exposed. Ask daily about symptoms and potential exposures. Train employees to inform you if any symptoms appear while working and isolate any employee who has symptoms. Consider monitoring temperatures of employees.
  6. If contact tracing indicates the employee was exposed while working then recording (worker comp) and reporting to Cal/OSHA if the illness leads to a fatality, in-patient hospitalization or disfigurement.
  7. Review your companies code of safe practice for COVID-19 and review your infectious disease management plan and update as needed.

** Data is limited to define of close contact. Factors to consider when defining close contact include proximity (within 6 feet), the duration of exposure (e.g., longer exposure time likely increases exposure risk), whether the individual has symptoms (e.g., coughing likely increases exposure risk) and whether the individual was wearing a facemask (which can efficiently block respiratory secretions from contaminating others and the environment).


Sources: Cal/OSHA, CDC, OSHA, CA DHS and HHS

UPDATED COVID-19 Code of Safe Practice (E/S) for your IIPP replacing update from 4.6.2020

Posted by Terra Laverty
23 Apr 2020 02:12 AM

The CDC and Cal/OSHA regulations have been changing as the pandemic is progressing.  The Code of Safe Practice attached for COVID-19 reflects the most recent changes we are aware of.  In particular the return to work and quarantine guidelines have changed recently.  Please review and update your IIPP with this Code of Safe Practice.  If you have questions or need assistance in updating your programs please contact us.

IIPP CSP COVID-19 English 4.22.2020

IIPP CSP COVID-19 Spanish 4.22.2020

Meet the Trainer - Ben Laverty IV

Posted by CSTC Staff
28 Feb 2019 09:00 AM

We have a lot of great trainers here at CSTC. We wanted to do some interviews so you could get to know them better.
Our second interview we thought was fitting to meet the Ben Laverty IV, son of the founder of CSTC Ben Laverty III.

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