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Volume 9 Numbers 1&2 Fall/Winter 1998 Charles Jeffress Looks Ahead…

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Volume 9 Numbers 1&2Fall/Winter 1998

Charles JeffressLooks Ahead…

U.S. Department of LaborAlexis M. Herman, Secretary

Occupational Safety and Health AdministrationCharles N. Jeffress, Assistant Secretary

Job Safety & Health Quarterly is the officialmagazine of the Occupational Safety and HealthAdministration, U.S. Department of Labor. It isavailable by subscription from the Superintendentof Documents, U.S. Government Printing Office,Washington, DC 20402, for $9.50 per year, or$11.90 if mailed to a foreign address. Singlecopies are $3.00 (U.S.) or $3.75 (foreign).See inserted order card.

The Secretary of Labor has determined that thepublication of this periodical is necessary in thetransaction of the public business required by lawof this Department. Use of funds for printing thisperiodical has been approved by the Director ofthe Office of Management and Budget.

Expressions of opinion in articles from sourcesoutside the U.S. Department of Labor do notnecessarily represent the views of the Department.Mention or depiction of companies or trade nameproducts in no way constitutes endorsement by theDepartment of Labor.

Material contained in this publication is publicdomain and may be reproduced fully or partiallywithout permission of the Federal Government.Source credit is requested but not required.Permission is required only to reproduce copy-righted photos and other copyrighted materialcontained herein.

Editorial communications should be addressedto the Editor, Job Safety & Health Quarterly,Occupational Safety and Health Administration,200 Constitution Avenue, N.W., Washington,DC 20210.

STAFFAnne Crown-Cyr, EditorKerri L. Lawrence, Associate EditorSusan Hall Fleming, WriterPat Foreman, WriterFrank Kane, WriterPhotography: Cover & pages 4 &18, Billy Rose;page 22, Douglas Prince, OSHA Area Office,Parsippany, NJ; pages 23 & 26, Michael Gall,Executive Director, Pacific Coast EducationCenter; page 24, Denise Woods, Niagara CountyCommunity College Education Center; page 30,© Rod Berry Photography, Columbus, OH;page 32, courtesy of Portland, Oregon, VisitorsAssociation; page 34, courtesy of AtlantaChamber of Commerce; page 35, courtesy ofPhiladelphia Convention and Visitors Bureau;pages 40-46, Steve Xanos, OTI, Des Plaines, IL;and page 51, Dan Dunkle, GE, Bangor, ME.

From the Editor...

I think I speak for everyone in welcomingCharles N. Jeffress as our new Assistant Secretaryfor Occupational Safety and Health. We werefortunate to have an in-depth interview withJeffress recently to discuss his plans and goals forOSHA. Our cover story highlights this interviewand Jeffress’ plans for the agency.

Note our second part of the feature on OSHAcooperative efforts. We also take a look at OSHA’strain-the-trainer program that is workingnationwide to improve workplace safety andhealth. There’s a brief story on OSHA’s meetingswith small business representatives to gain theirinput and concerns on the agency’s intention topropose a rule on safety and health programs.Another short story emphasizes how exemplarysafety and health program management canimprove workplace safety and reduce employercosts.

Our regular columns—What’s Happening?,Mark Your Calendar, and Toolbox—bring thelatest information on a variety of items such asmeetings, conferences, regulatory issues, andtraining and education. FatalFacts describe falland other hazards and preventive measures.A winter advisory details the hazards of coldweather.

Hope you enjoy the issue.

Anne Crown-CyrEditor

P.S. Don’t forget to give us your ideas by fillingout the reader response card in this issue.

Cover Design: Gene Hansen Creative Services, Inc.

Job Safety & Health Quarterly Fall/Winter 1998 1

FEATURES

DEPARTMENTS

Volume 9 Numbers 1&2Fall/Winter 1998

Assistant Secretary Charles JeffressDiscusses Plans for OSHAby Susan Hall Fleming 16

Changing the Way We Do BusinessThe final part of the series on OSHA cooperative effortsby Judith Weinberg 21

The Battle Against Tuberculosis—OSHA Fights Backby Kerri L. Lawrence 28

OSHA Asks Small Businesses for Inputon Safety and Health Program Proposalby Ted Twardowski 30

A Strategy for Improving Worker Safety and Healthby Anne Crown-Cyr 36

Outreach Training Promotes Safety and Health Awarenessby Don Guerra 39

Signing of Final Longshoring Regulationsby Paul Rossi 48

Maine 200: One Company’s Stepping Stone to Starby Susan Hall Fleming 50

Winter Advisory: Preventing Cold Stress 54

Assistant Secretary’s Message 2

OSHA Q&A 3

What’s Happening? 5

Mark Your Calendar 7

OSHA Semiannual Agenda—October 1997 14

The Toolbox 55

FatalFacts 57

ASSISTANT SECRETARY’S MESSAGE

2 Job Safety & Health Quarterly Fall/Winter 1998

his is my first column forJob Safety & Health Quar-terly as Assistant Secretary,

Charles N. Jeffress,Assistant Secretaryof Labor for OccupationalSafety and Health

and I am very proud to be here.OSHA is vital to America’s work-ing men and women, and I appre-ciate the confidence of PresidentClinton, Secretary Herman, and themany others too numerous to men-tion in business, labor, and govern-ment for their confidence in me. Ihope the thousands of OSHA pro-fessionals will lend me the benefitof their years of experience as Itackle this job.

When I took office, I pledged tocontinue the North Carolina tradi-

tion of cooperation andcommunication amongbusiness, labor, andOSHA. We share a com-mon mission of reducingworkplace injuries and ill-nesses, and we need towork on that mission in acooperative way. We are,after all, being measuredby the same yardstick—areduction in workplace in-juries and illnesses—andif you succeed, we suc-ceed. Let’s work togetheron this common mission.

My philosophy is thatOSHA is not simply theenforcer of rules and regu-

lations. We are professionals inworkplace safety; we must give la-bor and management our best ad-vice for reducing injuries, illnesses,and fatalities among their workers.That may mean giving advice oncorporate commitments, trainingline employees, or issuing citationsfor uncorrected hazards.

We shouldn’t be satisfied withjust observing whether or not rules

T

are followed. We must use our bestjudgment to help employers andemployees strengthen their pro-grams, increase their commitment,and find the help they need to bet-ter protect those at risk.

I salute OSHA compliance offic-ers, consultants, and trainers in thefield—you are the experts. It isyour actions—not speeches inWashington—that will change be-havior in the workplace, that willmake a difference in whether or notworking men and women go homesafely at the end of the day. I amhere to support you in your efforts,and I look forward to working withyou.

…OSHA is not simplythe enforcer of rules andregulations. We areprofessionals in workplacesafety; we must give laborand management our bestadvice for reducinginjuries, illnesses, andfatalities among theirworkers.

OSHA Q&A

Job Safety & Health Quarterly Fall/Winter 1998 3

Q: OSHA recently issueda final rule on abatementverification. What is it andwhat am I required to do?A: The abatement verification stan-dard requires employers cited forviolation(s) of the OccupationalSafety and Health Act of 1970(OSH Act) to certify that they haveabated the hazardous condition forwhich they were cited and to in-form the affected employees oftheir abatement actions.

To comply, cited employers must(1) fix the violation, (2) certify thatit has been fixed, (3) notify employ-ees and their representatives, (4) tagmovable equipment (if cited), and(5) send abatement documents toOSHA. Employers who don’t com-ply will get a citation for failure tofix, certify, notify, tag, or send.

The abatement procedures thata specific employer follows de-pends on the nature of the viola-tions identified and the actionsthe employer takes. If abatementoccurs during or immediatelyafter the inspection identifying theviolation(s), the employer does nothave to submit an abatement certi-fication letter to OSHA. If the vio-lation is other-than-serious or a se-rious violation that does not requireadditional documentation, the em-ployer must certify abatement us-ing a simple one-page form or theequivalent. Cases involving themost serious violations require ad-ditional documentation.

The final regulation simplifiesand streamlines the previous abate-ment certification procedures. Theregulation will reduce employers’paperwork, enhance employee par-ticipation in the abatement process,increase the number of cited haz-ards that are quickly abated, andstreamline and standardize theabatement procedures.

The new respirator standard protectsabout 5 million American workers innearly 1.3 million establishments. . . .

The agency has published the“Small Entity Compliance Guidefor OSHA’s Abatement VerificationRegulation—29 CFR 1903.19,”available on OSHA’s InternetHomepage (http://www.osha.gov/)under Compliance Assistance.The guide answers general and fre-quently asked questions as well ascontains a sample abatement certi-fication form.

Q: Has OSHA issued newstandards for respiratoruse ?A: Yes. On January 8, 1998, OSHApublished the revised final standardin the Federal Register. The newrespirator standard protects about5 million American workers innearly 1.3 million establishments inall industry sectors covered by theagency, except agriculture, andstrengthens protection against toxicsubstances.

The new standard updates a 25-year-old rule to reflect current tech-nology and methods of respiratorprotection and requires two-in/two-out procedures during interiorstructural firefighting. It clarifiesresponsibility for administering arespirator program, clarifies provi-sions and adds definitions, and pro-vides specific guidance on respira-tor selection and use, hazard deter-mination, medical evaluations, fittesting, and training. OSHA’s new

4 Job Safety & Health Quarterly Fall/Winter 1998

respirator standard and the two-in/two-out procedure dramatically in-crease firefighter protection, help-ing them save others lives and theirown.

Watch upcoming issues of JobSafety & Health Quarterly for moreinformation on this standard.

Q: Are federal worksitespermitted to participate inOSHA ’s VoluntaryProtection Programs(VPP)?A: In October, OSHA announcedthat it will begin accepting appli-cations from federal worksites withexemplary safety and health pro-grams for the VPP. Until this ac-tion, only private sector worksitescould apply for the VPP.

The VPP emphasizes the impor-tance of effective safety and healthmanagement systems in the preven-tion and control of workplace inju-ries and illnesses. At sites thatqualify for VPP participation, em-ployers and employees work to-gether and in partnership withOSHA to provide a level of safety

and health protection that goes wellbeyond the minimum OSHA stan-dards.

The key elements of the VPP forFederal Worksites Program—basi-cally identical with private sectorrequirements—include the follow-ing:• Applicants must be from a fed-

eral worksite.• Applicants must comply with

Title 29 Code of Federal Regu-lations (CFR), Part 1960—Basic Program Elements forFederal Employee OccupationalSafety and Health Programs,and all applicable standards.

• A worksite must notify its Des-ignated Agency Safety andHealth Officer (DASHO) oftheir intent to apply to the VPP.

• Applicants must track and sub-mit their accident rates as theirprivate counterparts do. Toqualify for Star—the premierVPP program—the rates must bebelow the current comparableprivate sector Bureau of LaborStatistics (BLS) rates. Applicantswith rates above the BLS aver-ages may qualify for Merit.

• Just as in the private sector pro-gram, federal worksites ap-proved to the VPP will not betargeted by OSHA for a pro-grammed inspection.For more information on the in-

clusion of federal worksites in VPPor any other questions regarding theVPPs, contact the Office of Volun-tary programs at (202) 219-7266.

Secretary Herman signs OSHA’s new respiratory protection rule.

WHAT’S HAPPENING?

Job Safety & Health Quarterly Fall/Winter 1998 5

Ortho Diagnostic Systems, Inc.,Raritan, NJ; Dow Chemical,Dalton, GA; Solutia, Inc., Decatur,AL; Union Camp Corp., Thorsby,AL; Mead Containerboard, Wash-ington Court House, OH; UnitedSpace Alliance, Logistic Support,Houston, TX; and Black & VeatchConstruction, Inc., Fort St. VrainRepowering Project, Platteville,CO.

Recent additions to OSHA’s VPPDemonstration Program are Aus-tin Industrial Maintenance, Inc.,Huntsman Petrochemical Corp.,Austin, TX; Mundy Contract Main-tenance, Inc., at Hoescht CelaneseTechnical Center, Corpus Christi,TX; Mundy Contract Mainte-nance, Inc., at Monsanto Chocolate

PublicationsSelected Construction Regula-

tions for the Home Building Indus-try assists residential construction

e m p l o y e r sand employ-ees in provid-ing safe andh e a l t h f u lworkplaces.This publica-tion identifiesthe Occupa-tional Safetyand Health

Administration (OSHA) standardsapplicable to the hazards most com-monly found at worksites in theresidential construction industryand those most likely to have a sig-nificant positive impact on thesafety and health practices of con-tractors within this industry.

OSHA’s Guide to Scaffold Usein the Construction Industry(OSHA 3150) addresses training

and varioustypes of scaf-folds, fallingobject protec-tion, ladders,weather con-ditions, aeriallifts, stilts,and other mat-ters covered

in OSHA’s revised scaffold stan-dards.

Both booklets are available un-der What’s New on OSHA’s Website at http://www.osha.gov. Aprinted copy OSHA 3150 also isavailable from the Superintendentof Documents, P.O. Box 371954,Pittsburgh, PA 15250-7954; (202)512-1800 phone or (202) 512-2250fax. Order No. 029-016-00188-3;cost $6.50.

Recent additions to OSHA’s VPPStar list are General Electric Co.,ED&C, Auburn, ME; GeneralElectric Aircraft Engines, Hooksett,NH; General Electric Corp., Re-search & Development, Niskayuna,NY; BE&K Construction Co.,Mead S-2 Project at MeadContainerboard, Stevenson, AL;Mead Containerboard, Covington,GA; WestPoint Stevens, Inc.,Chipley, FL; The Geon Co.,Laporte, TX; Occidental Chemical,Houston Chemical Complex,Deer Park, TX; Baxter HealthcareCorp., Renal Division, McGawPark, IL; International Paper,Russellville, AR; International Pa-per, Masonite Corp., Lisbon Falls,ME; Cosmair, Inc., Piscataway, NJ;

VPP Update

6 Job Safety & Health Quarterly Fall/Winter 1998

Bayou, Houston, TX; and Brown& Root Industrial Services,Weyerhaeuser Co., Valliant, OK.

Recent additions to OSHA’s VPPMerit list are Mobil Chemical Co.,Olefins/Aromatics Plant, Beau-mont, TX; Minolta Advance Tech-nology, Inc., Goshen, NY; MeadCorporation’s School & OfficeProducts, Atlanta, GA; GeneralElectric’s Decatur Plant, Decatur,GA; The Glidden Co., Plant #007,Oakwood, GA; WestPoint Stevens,Inc., Dunson Mill, LaGrange, GA;Champion International Corpora-tion, Camden, TX; Champion In-ternational Corp., Corrigan, TX;Houston Industrial Power Genera-tion Operations, Hewett, TX; AkzoNobel Chemical Co., Deer Park,TX; Vickers, Inc., Searcy, AR;Rohm & Haas, Inc., Deer Park, TX;

and Wheelabrator South Broward,Inc., Lauderdale, FL.

E.I. DuPont de Nemours andCo., Ingleside, TX, has now beenin the Star Program for 13 years.BASF, Holyoke, MA, and TennecoPackaging, Specialty ProductsGroup, Temple, TX, have now beenin the Star Program for 12 years.Huntsman Aromatics and OlefinsPlant, Port Arthur, TX, has been inthe Star Program for 9 years.Huntsman Petrochemical Corpora-tion, Austin, TX, and Dow NorthAmerica, Louisiana Division,Plaquemine, LA, have now been inthe Star Program for 7 years. Oc-cidental Chemical Corp., DallasSilicates Plant, Dallas, TX;Lyondell Technology Center,Alvin, TX; and Occidental Chemi-cal Corp., Hahnville, LA, have now

been in the Star Program for 3years.

Chevron Chemical Co., CedarBayou Plant, Baytown, TX; andRR Donnelley & Sons Co.,Senatobia, MS, advanced fromMerit to Star.

This brings the total participantsto 341 sites in the Federal VPP:277 in Star, 52 in Merit and 12 inDemonstration.

For more information onOSHA’s VPP, write the OSHA Di-rectorate of Federal-State Opera-tions, 200 Constitution Avenue,N.W., Room N-3700, Washington,DC 20210; or call (202) 219-7266.See also Programs and Serviceson OSHA’s Web site at http://www.osha.gov/.

MARK YOUR CALENDAR

Job Safety & Health Quarterly Fall/Winter 1998 7

OSHA TrainingInstituteSchedule100 Initial ComplianceCourse

Introduces compliance person-nel to the provisions of the Occu-pational Safety and Health Actof 1970 (OSH Act). Includes anorientation to OSHA regulations,the Field Inspection ReferenceManual, the Technical Manual,hazard recognition and control, andfundamental safety and health pro-gram elements.

Tuition: Federal and statepersonnel only

Dates: 3/3/98 - 3/13/98

102 Basic AccidentInvestigation

Introduces basic accident inves-tigation techniques related toOSHA compliance activities, in-cluding basic interviewing, photog-raphy, and mapping techniques aswell as legal issues regarding in-vestigations.

Tuition: Federal and statepersonnel only

Dates: 3/17/98 - 3/20/98

121a Introduction toIndustrial Hygiene for SafetyPersonnel

A shortened version of Course121 that focuses on the general con-cepts of industrial hygiene, includ-ing the recognition of commonhealth hazards such as air contami-nants and noise, hazard evaluationthrough screening and sampling,and control methods for health haz-ards including ventilation and per-sonal protective equipment.

Tuition: $540Dates: 4/20/98 - 4/24/98

141 Inspection Techniquesand Legal Aspects

Describes investigative tech-niques related to OSHA compli-ance activities and to the formalrequirements and processes of thelegal system, including interview-ing techniques, case file documen-tation, and workplace communica-tion skills.

Tuition: Federal and statepersonnel only

Dates: 3/24/98 - 4/3/98

143 Introduction to OSHAfor Non-Technical Personnel

Provides an overview of OSHA’shistory, terminology, structure, andoperations. Includes the OSH Act,the inspection process, and variousprograms within OSHA.

Tuition: Federal and statepersonnel only

Dates: 3/31/98 - 4/3/98

200 Construction StandardsGives an overview of OSHA’s

construction standards and of therequirements of the most frequentlyreferenced standards. Also coversrights and responsibilities under theOSH Act, contesting situations, andOSHA inspection procedures.

Tuition: Federal and statepersonnel only

Dates: 4/14/98 - 4/24/98

201 Hazardous MaterialsCovers OSHA general industry

standards and consensus and pro-prietary standards relating to haz-ardous materials such as flammableand combustible liquids, com-pressed gases, LP-gases, and cryo-genic liquids.

Tuition: $1,039Dates: 3/3/98 - 3/13/98

8 Job Safety & Health Quarterly Fall/Winter 1998

201a Hazardous MaterialsA shortened version of course

201 covering OSHA general indus-try standards and consensus andproprietary standards relating tohazardous materials such as flam-mable and combustible liquids,compressed gases, LP-gases, andcryogenic liquids.

Tuition: $540Dates: 3/16/98 - 3/20/98

204 Machinery and MachineGuarding Standards

Focuses on the various types ofcommon machinery and the relatedsafety standards. Also includeshands-on-training in the laborato-ries.

Tuition: $790Dates: 3/26/98 - 4/3/98

204a Machinery andMachine GuardingStandards

A shortened version of course204 that focuses on the varioustypes of common machinery andthe related safety standards. Alsoincludes hands-on-training in thelaboratories.

Tuition: $540Dates: 2/23/98 - 2/27/98

205 Cranes and RiggingSafety for Construction

Describes various types of mo-bile and tower cranes used in con-struction operations and providesinformation on crane operations,inspection, and maintenance.

Tuition: $415Dates: 3/31/98 - 4/3/98

207a Fire Protection and LifeSafety

A shortened version of Course207 that helps the student recognizepotential fire hazards and emer-gency procedures. Includes thechemistry of fire, types and effec-tiveness of extinguishing agents,means of egress, detection andalarm systems, fire brigades, fireprevention plans, and the LifeSafety Code (NFPA 101).

Tuition: $540Dates: 4/6/98 - 4/10/98

208 Cranes and MaterialsHandling for GeneralIndustry

Discusses overhead cranes,hoists, and powered industrialtrucks used in general industry aswell as overhead and crane inspec-tion and maintenance procedures.

Tuition: $415Dates: 4/21/98 - 4/24/98

221 Principles of IndustrialVentilation

Describes the principle of indus-trial ventilation as a means of con-trolling hazardous air contami-nants. Includes the classification ofventilation systems, fundamentalsof airflow, makeup air, fans, aircleaners, ventilation system sur-veys, and OSHA policies and stan-dards.

Tuition: $790Dates: 4/28/98 - 5/6/98

225 Principles ofErgonomics

Provides an overview of ergo-nomic principles for the reductionof stresses and strains to theemployee’s body. Includes workphysiology, vibration, anthropom-etry, cumulative trauma disorders,video display terminals, manuallifting, and temperature stress.

Tuition: $415Dates: 4/14/98 - 4/17/98

233 Indoor Air QualityHelps health and safety profes-

sionals determine indoor air qual-ity, including the nature and causesof indoor air problems in officebuilding environments as well asinvestigative approaches and solu-tions.

Tuition: $415Dates: 3/24/98 - 3/27/98

Job Safety & Health Quarterly Fall/Winter 1998 9

234 BiohazardsAssists health and safety profes-

sionals in evaluating biologicalhazards during occupational expo-sure. Emphasizes work practices,personal protective equipment, in-fectious waste handling, controltechniques, sampling instrumentsand measurements, and current ap-plicable OSHA standards.

Tuition: $415Dates: 3/10/98 - 3/13/98

236 Heating, Ventilation andAir Conditioning (HVAC)Systems

Provides information on types ofHVAC systems and components,related standards and codes, venti-lation measurements, maintenanceconsiderations, system evaluationand trouble-shooting, reading plansand specifications, and OSHAcompliance issues.

Tuition: $415Dates: 4/7/98 - 4/10/98

303 Concrete, Forms, andShoring

Teaches the principles of formsand shoring and the quality of con-crete, hot and cold weather plac-ing practices, and inspection pro-cedures, including reinforced con-crete, lift-slab construction, andreading concrete blueprints andshoring plans.

Tuition: $374Dates: 3/10/98 - 3/12/98

308 Principles of ScaffoldingPresents detailed information on

the safety aspects of scaffoldingfrom installation to dismantling.Includes builtup scaffolds, suspen-sion scaffolds, and interpretation ofrelated standards. Demonstratesinstallation and dismantling meth-ods.

Tuition: $415Dates: 3/24/98 - 3/27/98

309 Electrical StandardsProvides an indepth study of

OSHA’s electrical standards andhazards associated with electricalinstallations and equipment. In-cludes single- and three-phase sys-tems, cord- and plug-connected andfixed equipment, grounding,ground-fault circuit interrupters,hazardous locations, and safety-re-lated work practices.

Tuition: $1,039Dates: 4/21/98 - 5/1/98

311 Fall Arrest SystemsProvides an overview of state-of-

the-art technology for fall protec-tion, including the principles of fallprotection, the components of fall

arrest systems, the limitations offall arrest equipment, and OSHApolicies regarding fall protection.

Tuition: $415Dates: 3/3/98 - 3/6/98

312 Hazardous Waste SiteInspection and EmergencyResponse for theConstruction Industry

Increases knowledge of hazard-ous waste site operations, emer-gency response procedures, safetyand health hazards, and enforce-ment issues for the constructionindustry.

Tuition: $415Dates: 4/8/98 - 4/11/98

322 Applied WeldingPrinciples

Increases knowledge of the pro-cesses and hazards associated withwelding operations such as oxy-acetylene and open arc, proper useof each process, personal protectiveequipment, safety and health haz-ard recognition and control, andOSHA requirements.

Tuition: $415Dates: 3/17/98 - 3/20/98

326 Health Hazards in theConstruction Industry forSafety Personnel

Focuses on the recognition andevaluation of health hazards inthe construction industry. Topicsinclude abrasive blasting, asbes-tos, confined spaces, demolition,painting, roofing, silica, lead, andwelding.

Tuition: $415Dates: 4/7/98 - 4/10/98

10 Job Safety & Health Quarterly Fall/Winter 1998

330 Safety and Health in theChemical ProcessingIndustries

Provides the student with a sur-vey of 29 CFR 1910.119, ProcessSafety Management of Highly Haz-ardous Chemicals. Topics includean overview of processes, equip-ment, and materials commonlyfound in the chemical processingindustries; safety and health hazardrecognition; and effective hazardcontrol techniques. Includes anoverview of the Process SafetyManagement standard and OSHAcompliance policies.

Tuition: Federal and statepersonnel only

Dates: 4/14/98 - 4/24/98

333 OSHA Overview forOccupational Health Nurses

Provides an overview of OSHAand its regulations and guidelinesfor occupational health nurses. In-cludes an introduction to the in-spection process, tools, and termi-nology of industrial hygiene,recordkeeping and access to em-ployer exposure medical records,and the role of the occupationalhealth nurse in promoting occupa-tional safety and health.

Tuition: $374Dates: 2/24/98 - 2/26/98

600 Collateral Duty Coursefor Other Federal Agencies

Teaches how the provision of theOSH Act, Executive Order 12196,29 CFR Part 1960, and 29 CFR1910 may be implemented in theworkplace and effectively assistagency safety and health officers ininspection and abatement efforts.

Tuition: $478Dates: 2/23/98 - 2/27/98

To register for courses or to ob-tain a training catalog, write theOSHA Training Institute, 1555Times Drive, Des Plaines, IL60018; or call (847) 297-4913. Seealso OSHA Training and Regis-tration under Programs and Ser-vices on OSHA’s Web site at http://www.osha.gov/.

Job Safety & Health Quarterly Fall/Winter 1998 11

OSHA TrainingInstituteEducation Centers

The OSHA Training Institutealso has a program for other insti-tutions to conduct OSHA coursesfor the private sector and other fed-eral agencies. These include East-ern Michigan University/UnitedAuto Workers, Ypsilanti, MI, (800)932-8689; Georgia TechnologicalResearch Institute, Atlanta, GA,(800) 653-3629; Great LakesOSHA Training Consortium, St.Paul, MN, (800) 493-2060; KeeneState College, Manchester, NH,(800) 449-6742; Maple WoodsCommunity College, Kansas City,MO, (800) 841-7158; NationalResource Center for OSHA Train-ing, Washington, DC, (800) 367-6724; Niagara County CommunityCollege, Lockport, NY, (800) 280-6742; Red Rocks Community Col-lege/Trinidad State Junior College,Lakewood, CO, (800) 933-8394;The National Safety EducationCenter, DeKalb, IL, (800) 656-5317; Texas Engineering ExtensionService, Mesquite, TX, (800) 723-3811; University of California, SanDiego, CA, (800) 358-9206; andUniversity of Washington, Seattle,WA, (800) 326-7568.

For tuition rates and registrationinformation, contact the institutionoffering the courses and see alsoOSHA’s Web site at http://www.osha.gov/.

201a Hazardous MaterialsLocation: Eastern Michigan

University-UnitedAuto Workers

Dates: 3/9/98 - 3/13/98*

Location: Great Lakes OSHATraining Consortium

Dates: 3/24/98 - 3/27/98

Location: Maple WoodsCommunity College

Dates: 3/9/98 - 3/12/98Location: University of Califor-

nia, San DiegoDates: 3/30/98 - 4/2/98

204a Machinery andMachine GuardingStandardsLocation: Georgia Technological

Research InstituteDates: 2/23/98 - 2/27/98Location: Keene State CollegeDates: 2/9/98 - 2/13/98Location: Maple Woods

Community CollegeDates: 2/16/98 - 2/19/98Location: National Resource

Center for OSHATraining

Dates: 3/9/98 - 3/12/98Location: Niagara County

Community CollegeDates: 3/30/98 - 4/2/98Location: The National Safety

Education CenterDates: 2/23/98 - 2/27/98Location: University of Califor-

nia, San DiegoDates: 3/23/98 - 3/26/98Location: University of Wash-

ingtonDates: 3/23/98 - 3/27/98

225 Principles of ErgonomicsLocation: Niagara County

Community CollegeDates: 3/23/98 - 3/26/98Location: Red Rocks

Community CollegeDates: 2/18/98 - 2/20/98Location: Texas Engineering

Extension ServiceDates: 3/2/98 - 3/5/98 (D)Location: University of Wash-

ingtonDates: 3/9/98 - 3/11/98

12 Job Safety & Health Quarterly Fall/Winter 1998

226 Permit-RequiredConfined Space EntryLocation: Eastern Michigan

University-UnitedAuto Workers

Dates: 3/23/98 - 3/26/98*

Location: Keene State CollegeDates: 3/9/98 - 3/12/98Location: Niagara County

Community CollegeDates: 3/3/98 - 3/6/98Location: Red Rocks

Community CollegeDates: 3/4/98 - 3/6/98Location: Texas Engineering

Extension ServiceDates: 3/30/98 - 4/1/98 (H)Location: University of Califor-

nia, San DiegoDates: 3/9/98 - 3/11/98

309a Electrical StandardsLocation: Maple Woods

Community CollegeDates: 2/23/98 - 2/26/98Location: Niagara County

Community CollegeDates: 2/23/98 - 2/26/98Location: Red Rocks

Community CollegeDates: 3/24/98 - 3/27/98Location: Texas Engineering

Extension ServiceDates: 2/23/98 - 2/27/98 (D)Location: University of Califor-

nia, San DiegoDates: 3/30/98 - 4/2/98Location: University of Wash-

ingtonDates: 2/17/98 - 2/20/98**

500 Trainer Course inOccupational Safety andHealth Standards for theConstruction IndustryLocation: Eastern Michigan

University-UnitedAuto Workers

Dates: 2/15/98 - 2/19/98*

3/9/98 - 3/13/98

Location: Keene State CollegeDates: 3/16/98 - 3/20/98Location: National Resource

Center for OSHATraining

Dates: 2/23/98 - 2/26/98 (M)3/9/98 - 3/12/98

Location: Niagara CountyCommunity College

Dates: 3/2/98 - 3/5/98Location: Red Rocks

Community CollegeDates: 3/9/98 - 3/12/98Location: Texas Engineering

Extension ServiceDates: 2/16/ 98 - 2/20/98 (H)

3/30/98 - 4/3/98***

Location: The National SafetyEducation Center

Dates: 3/16/98 - 3/20/98Location: University of Califor-

nia, San DiegoDates: 3/2/98 - 3/5/98Location: University of Wash-

ingtonDates: 3/2/98 - 3/5/98***

501 Trainer Course inOccupational Safetyand Health Standardsfor General IndustryLocation: Eastern Michigan

University-UnitedAuto Workers

Dates: 3/16/98 - 3/20/98Location: Georgia Technological

Research InstituteDate: 3/2/98 - 3/6/98Location: Keene State CollegeDates: 2/16/98 - 2/20/98

3/23/98 - 3/27/98Location: Maple Woods

Community CollegeDates: 3/2/98 - 3/5/98Location: National Resource

Center for OSHATraining

Dates: 2/23/98 - 2/26/98Location: Niagara County

Community CollegeDates: 3/9/98 - 3/12/98

Location: Red RocksCommunity College

Dates: 2/16/98 - 2/19/983/16/98 - 3/19/98

Location: Texas EngineeringExtension Service

Dates: 2/9/98 - 2/12/98***

3/23/98 - 3/27/98 (H)Location: The National Safety

Education CenterDates: 3/9/98 - 3/13/98

3/23/98 - 3/27/98****

Location: University of Califor-nia, San Diego

Dates: 2/23/98 - 2/26/98Location: University of Wash-

ingtonDates: 3/23/98 - 3/27/98**

502 Update for ConstructionIndustry Outreach TrainersLocation: Eastern Michigan

University-UnitedAuto Workers

Dates: 2/16/98 - 2/18/983/17/98 - 3/19/98

Location: Great Lakes OSHATraining Consortium

Dates: 3/18/98 - 3/20/98*****

Location: Maple WoodsCommunity College

Dates: 2/16/98 - 2/18/98Location: National Resource

Center for OSHATraining

Dates: 3/30/98 - 4/1/98Location: Red Rocks

Community CollegeDates: 3/18/98 - 3/20/98Location: Texas Engineering

Extension ServiceDates: 2/16/98 - 2/18/98 (H)Location: The National Safety

Education CenterDates: 3/10/98 - 3/12/98

Job Safety & Health Quarterly Fall/Winter 1998 13

*Course scheduled at University of Findlay,Findlay, OH**Course scheduled in Portland, OR***Contact education center for courselocation.****Course scheduled in Appleton, WI*****Course scheduled at University ofCincinnati, Cincinnati, OH(D) Course scheduled in Dallas Area(H) Course scheduled in Houston(M) Course scheduled at Marshall Univer-sity, Huntington, WV(W) Course scheduled at West VirginiaUniversity, Morgantown, WV

503 Update for GeneralIndustry Outreach TrainersLocation: Eastern Michigan

University-UnitedAuto Workers

Dates: 3/9/98 - 3/11/98Location: Georgia Technological

Research InstituteDates: 3/24/98 - 3/26/98Location: Great Lakes OSHA

Training ConsortiumDates: 3/2/98 - 3/4/98

3/18/98 - 3/20/98*****

Location: Keene State CollegeDates: 3/30/98 - 4/1/98Location: Maple Woods

Community CollegeDates: 3/16/98 - 3/18/98Location: Niagara County

Community CollegeDates: 2/18/98 - 2/20/98Location: Red Rocks

Community CollegeDates: 3/4/98 - 3/6/98Location: Texas Engineering

Extension ServiceDates: 3/23/98 - 3/25/98 (H)Location: The National Safety

Education CenterDates: 2/23/98 - 2/25/98

510 Occupational Safetyand Health Standards forthe Construction IndustryLocation: Keene State CollegeDates: 2/23/98 - 2/27/98Location: Maple Woods

Community CenterDates: 3/9/98 - 3/12/98Location: Niagara County

Community CollegeDates: 3/16/98 - 3/19/98Location: Red Rocks

Community CollegeDates: 2/23/98 - 2/26/98Location: University of Califor-

nia, San DiegoDates: 2/23/98 - 2/26/98

521 OSHA Guide toIndustrial HygieneLocation: Eastern Michigan

University-UnitedAuto Workers

Dates: 2/23/98 - 2/27/98Location: National Resource

Center for OSHATraining

Dates: 3/16/98 - 3/19/98 (W)Location: University of Califor-

nia, San DiegoDates: 3/23/98 - 3/26/98

600 Collateral Duty Coursefor Other Federal AgenciesLocation: Eastern Michigan

University-UnitedAuto Workers

Dates: 3/2/98 - 3/6/98Location: Georgia Technological

Research InstituteDates: 3/16/98 - 3/29/98

Location: Keene State CollegeDates: 3/2/98 - 3/5/98Location: National Resource

Center for OSHATraining

Dates: 3/23/98 - 3/26/98Location: University of Califor-

nia, San DiegoDates: 3/9/98 - 3/12/98

OSHA SEMIANNUAL AGENDA—OCTOBER 1997

14 Job Safety & Health Quarterly Fall/Winter 1998

Nationally Recognized TestingLabs Programs: Fees1218-AB57

Flammable and CombustibleLiquids1218-AB61

Fall Protection in theConstruction Industry1218-AB62

Process Safety Managementof Highly Hazardous Chemicals1218-AB63

Revocation of CertificationRecords for Tests, Inspections,and Training1218-AB65

Plain English Revision of Exist-ing Standards (Phase II)1218-AB66

Electric Power Transmissionand Distribution; ElectricalProtective Equipment1218-AB67

Safety Standards for ScaffoldsUsed in the ConstructionIndustry - Part II1218-AB68

Published in April and October each year, the agenda includes all regulations expected to be underdevelopment or review by the agency during that period. The following list is from the agenda aspublished in the Federal Register 62 (209) 57746-57759, October 29, 1997.

PreruleTitle and Regulation IdentifierNumber (RIN)*

Standards Advisory Committeeon Metalworking Fluids1218-AB58

Control of Hazardous EnergySources (Lockout/Tagout)1218-AB59

Occupational Exposureto Ethylene Oxide1218-AB60

Fire Brigades1218-AB64

Grain Handling Facilities1218-AB73

Cotton Dust1218-AB74

Proposed RulesSteel Erection (Part 1926) (SafetyProtection for Ironworkers)1218-AA65

Prevention of Work-RelatedMusculoskeletal Disorders1218-AB36

Safety and Health Programs(for General Industry)1218-AB41

Occupational Exposureto Tuberculosis1218-AB46

Confined Spaces in Construction(Part 1926) (Construction: Pre-venting Suffocation/Explosionsin Confined Spaces)1218-AB47

General Working Conditionsin Shipyards (Part 1915,Subpart F) (Phase II) (Shipyards:General Working Conditions)1218-AB50

Fire Protection in ShipyardEmployment (Part 1915, SubpartP) (Phase II) (Shipyards:Fire Safety)1218-AB51

Permissible Exposure Limits(PELs) for Air Contaminants1218-AB54

Plain English Revisionof Existing Standards1218-AB55

Job Safety & Health Quarterly Fall/Winter 1998 15

*Office of Management and Budget (OMB)Regulation Identification Number. For copiesof OSHA final rules published in the FederalRegister, contact the Superintendent ofDocuments, Government Printing Office,Washington, DC 20402, for $8.00 a copyprepaid. Subscriptions are available at $651per year. GPO products also can be orderedonline at http://www.gpo.gov/.

Safety and Health Programsfor Construction1218-AB69

Control of Hazardous Energy(Lockout) in Construction (Part1926) (Preventing ConstructionInjuries/Fatalities; Lockout)1218-AB71

Final RuleRespiratory Protection (ProperUse of Modern Respirators)1218-AA05

Longshoring and Marine Termi-nals (Parts 1917 and 1918)—Reopening of the Record1218-AA56

Access and Egress in Shipyards(Part 1915, Subpart E) (Phase I)(Shipyards: Emergency Exitsand Aisles)1218-AA70

Recording and ReportingOccupational Injuries andIllnesses (Simplified Injury/Illness RecordkeepingRequirements)1218-AB24

Powered Industrial TruckOperator Training (IndustrialTruck Safety Training)1218-AB33

Permit Required Confined Spaces(General Industry; PreventingSuffocation/Explosions inConfined Spaces)1218-AB52

Standards Improvement Project1218-AB53

Long TermScaffolds in Shipyards (Part1915-Subpart N) (Phase I)(Shipyards: Safer Scaffolds)1218-AA68

Glycol Ethers: 2-Methoxyethanol,2-Ethoxyethanol, and TheirAcetates: ProtectingReproductive Health1218-AA84

Walking Working Surfacesand Personal Fall ProtectionSystems (Part 1910) (Slips, Trips,and Fall Prevention)1218-AB04

Accreditation of TrainingPrograms for Hazardous WasteOperations (Part 1910)1218-AB27

Indoor Air Quality in theWorkplace1218-AB37

Occupational Exposureto Hexavalent Chromium(Preventing Occupational Illness:Chromium)1218-AB45

Occupational Exposureto Crystalline Silica1218-AB70

CompletedActionsAbatement Verification (HazardCorrection)1218-AB40

16

Why did you agree tocome to W ashington

to serve as head of OSHA?During the past 5 years inNorth Carolina, we brought

the workplace injury and illnessrate down substantially. I wantedthe opportunity to try on a nationallevel some of the things we wereso successful with in North Caro-lina.

I believe we were successful be-cause we empowered our staff inNorth Carolina by decentralizingour operations and giving moreauthority to supervisors at the lo-cal level. At the same time, whilewe can assist employers and em-ployees, it’s really what they do inthe workplace that makes the dif-ference. What really made that dif-ference in North Carolina is thesense of cooperation we were ableto foster among business, labor, andgovernment—an agreement towork together to reduce injuriesand illnesses in the workplace.

What is your number

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Assistant SecretaryCharles JeffressDiscusses Plans

for OSHAby Susan Hall Fleming

Job Safety & Health Quarterly Fall/Winter 1998

one standard-settingpriority?

Clearly, ergonomics is thestandard that we must work

on. We’ve got to push forward toget a proposed rule ready. I will bespending a lot of time and atten-tion on ergonomics, working withthe team that David Cochran headsto make sure that the process goesforward. I’m also well aware ofhow long it takes to get a final ruleout. We’re prohibited by our appro-priations bill from issuing a pro-posed rule in this fiscal year. Nev-ertheless, we have a long way togo in developing the proposal, andI am going to work to keep thingsmoving forward so that we areready to issue that proposal nextyear.

A critical priority is safety andhealth programs. When we focused

In November, JSHQ staff was fortunateto have the opportunity to sit down withour newly appointed assistant secretaryand ask about his hopes and plans forOSHA. Here’s a look a what will be someof OSHA’s driving issues.

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Job Safety & Health Quarterly Fall/Winter 1998 17

on 248 companies in North Caro-lina that had high workers’ com-pensation case rates, we didn’t finda great many more hazards or moreserious hazards than at other com-panies. What we found was that thecompanies had no effective safetyand health programs. The real dif-ference between workplaces withlow accident rates and those withhigh rates appeared to be having aneffective safety and health pro-gram. That’s what drives my inter-est in getting a federal standard outon safety and health programs.

Another concern I have is thelength of time it takes to issue stan-dards. I don’t yet know how we canspeed it up. But I intend to spendtime trying to find ways to movestandards more quickly through theprocess. Every standard needs to bein plain language as well. Some arenow obtuse—a lot of those we in-herited from national consensusbodies. But I believe we can makeit much easier for employers andemployees to comply with our stan-dards if we can simplify them andmake them understandable, even ifthat means sacrificing some tech-nical or legal precision. If a stan-dard is understandable to 95 per-cent of the people, it will be a lotmore effective than something thatmay be a little more precise butonly understandable to 15 percent.

Do you see OSHAdoing more

inspections or fewer inthe next year?

I don’t know that there’s anyright number of inspections.

I do think to have a credible en-forcement program, we need to domore than walk around the work-place; we must provide technicalassistance and guidance to employ-ers. We have to do enough inspec-tions to serve as a credible deter-rent, and we have to do top-quality

inspections, particularly in thoseplaces where a lot of people arebeing hurt.

In the past, we have conductedinspections and observed hazards.We’ve shown employers the rulesand penalized those who didn’t fol-low them. Now, we’re asking ourcompliance officers to go beyondthe rules and determine whethermanagement has made a commit-ment to safety and health in thisworkplace. If not, our inspectorswill need to sit down with the em-ployer and say, “Look, you’re notshowing any leadership here. Youremployees must see you investedin this program. They have to seeyour commitment to it, your dol-lars and your time and your energyfocused on this.” Further, if the em-ployees aren’t involved in thesafety and health program, thecompliance officer will need to talkto employee representatives andperhaps management to be sure

The real difference between workplaces withlow accident rates and those with high ratesappeared to be having an effective safetyand health program.

they understand that the programwill only work if employees buy it,if they’re invested in it. Then thecompliance officer will need togive them some ideas on how to getemployees invested.

We must go beyond enforcingthe rules. And our complianceofficers will need to know howto identify an effective safetyand health program and how tocommunicate that to the peoplethey visit.

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18 Job Safety & Health Quarterly Fall/Winter 1998

Do you see a need forreform of the OSH Act?A number of provisions incurrent reform bills concern

me. One would have OSHA citingemployees for misconduct. That issomething we cannot do as anagency. Employers are responsiblefor their employees’ conduct. Wehave to hold employers account-able for disciplining their employ-ees.

Another proposal that troublesme is the idea of permitting em-ployers to use private consultantsand thereby immunize themselvesfrom any penalties from OSHA in-spections. My fear is that shouldsomething like that pass, the largeemployers will always buy consult-ants and never have an OSHA pen-alty, and smaller employers who

to involve them in our technical as-sistance programs, to incorporatethem in the consulting program runby states. We need to expand ourimpact, and private consultantshave a role to play. But I don’t thinkincorporating them into our en-forcement effort is the right way togo.

At the same time, I’m gratefulto Senator Enzi and others for com-ing up with some new ideas and arenewed focus on safety and health.His efforts have encouraged em-ployers, employees, and safety andhealth professionals to take anotherlook at ways we might work to-gether and multiply OSHA’s impactthrough private resources.

Is there a third-partyaudit program that

could be tied toenforcement that youcould accept?

Yes. Employers who seek outhelp in improving safety and

health by hiring a private consult-ant are demonstrating good faith,particularly if they can show thatthey have acted to implement theconsultant’s recommendations.Should we inspect that employerthere should also be fewer hazards,fewer violations, and thereforefewer citations and penalties. Butsimply hiring a consultant by itselfshould not immunize someonefrom the possibility of inspection.

As we base more of our inspec-tions upon high injury and illnessrates, if employers make good useof consultants, their rates should

We need to measure ourselves by the sameyardstick that employers and employeesmeasure their safety and health efforts:reducing injuries and illnesses.

can’t afford the consultant will be-come the only ones we penalize.Then OSHA will become anagency that only punishes smallemployers. And that’s not accept-able policy for the country.

I do believe it’s important to findways to use private industry andprivate consultants to expand ourservices. Clearly, government’s notgoing to grow much in the next fewyears, yet there’s a lot more workto be done in safety and health. Per-haps we can find a way to use con-sultants to teach safety and health,

Assistant Secretary Charles Jeffress explains plans for OSHA.

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Job Safety & Health Quarterly Fall/Winter 1998 19

come down and they will not windup on our primary inspection lists.Those who have hired consultantsand faithfully followed their recom-mendations should receive creditfor good faith [lowering any OSHApenalties] even if their rates remainsomewhat higher than average.

Do you want to makeany changes in

OSHA ’s strategic plan?I think it’s a good document,and as a state OSHA director,

I participated in the process of de-veloping it, so I share some own-ership. The strategic plan will beour blueprint. We will work by thisdocument to fulfill our commit-ment to reduce injuries and ill-nesses in the workplace. Of course,it’s the employers and employeesin the workplace that actually haveto do that. But if we’re not success-ful in motivating them to focus onsafety and health and improve theirprograms, then injuries and ill-nesses will not go down.

We need to measure ourselves bythe same yardstick that employersand employees measure their safetyand health efforts: reducing injuriesand illnesses. If we’re measuringourselves by this yardstick, maybewe can get beyond adversarial re-lationships to achieve our commongoals.

As we move forward and havemore experience, we may find dif-ferent ways to measure ourselves.We may find different things wewant to measure. And we may dis-cover some things are easier to dothan we thought and others areharder. We have the flexibility torevisit the plan periodically andmake changes as necessary. I thinkit’s a very good start.

The third goal in thestrategic plan

addresses creating aworld class organization,one of the concepts ofreinvention. What stepsdo you think OSHA needsto take to move fromwhere it is to become aworld-class organization?

As a new person in this job, Idon’t have a prescription right

now or formula for things that weneed to change. I will be listeningto folks to hear their thoughts aboutwhat we need to do to improve.

Charles N. Jeffress, confirmed bythe U.S. Senate to be the Assis-tant Secretary of Labor for Occu-pational Safety and Health, is anexperienced planner, successfulmanager, and innovative thinkerwho has spent the past 20 yearsworking on labor and workplaceissues. Prior to his nomination byPresident Clinton, Jeffress wasDeputy Commissioner and Direc-tor of OSHA at the North Caro-lina Department of Labor. In thatcapacity, he developed and com-municated occupational safetyand health policy for the state. Hedirected OSHA enforcement, con-sultation, and education and train-ing activities, and managed an or-ganization of 225 people with anannual budget of $13 million.

Jeffress served as AssistantCommissioner of the North Caro-lina Department of Labor from1977 to 1992, focusing on pro-gram management, governmentaffairs, and policy development.Direct responsibilities includedpreparing budgets, developingpersonnel policy, overseeing thedevelopment of new programs,

and acting as the chief legislativelobbyist for the agency with thestate legislature. Jeffress also di-rected agency research and ad-vised the Commissioner on issuesrelating to occupational safety andhealth, employment standards andjob training, and personnel.

In 1976, Jeffress was managerof the John Brooks for LaborCommissioner campaign, based inRaleigh, NC. In that capacity hedeveloped campaign strategy anddirected staff as well as supervisedthe publication of campaign ma-terials and fundraising operations.

Jeffress holds a Bachelor ofArts degree from the Universityof North Carolina at Chapel Hill,where he graduated with Phi BetaKappa honors in 1971. He is a1980 graduate of The GovernmentExecutives Institute at the UNC-Chapel Hill School of BusinessAdministration and a 1990 gradu-ate of the Program for Senior Ex-ecutives in Government at theJohn F. Kennedy School of Gov-ernment at Harvard University.

CHARLES N. JEFFRESS

I do want to break down barri-ers between top management andnational office staff and field officestaff. I think it’s important that weall have the same objectives and areworking to help each other achievethose objectives.

Another issue is continuing edu-cation and training. In North Caro-lina, we tried to make sure everyemployee—field inspectors, tech-nical folks, office support staff—had an opportunity for continuingeducation every year, preferably 40hours each year. It’s important tome that all of us stay current in our

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20 Job Safety & Health Quarterly Fall/Winter 1998

particular field. I want to make surethat we have the best-trainedworkforce possible to carry out ourmission to reduce injuries and ill-nesses.

As a former statedirector , would you

explain your view ofpartnership with thestates?

OSHA-approved state plans1

are very much our partners incarrying out safety and health poli-cies, and they should be our part-ners in developing safety and healthpolicies. Often, employers and themedia don’t distinguish between the29 states with federal OSHA juris-diction and the 21 states where astate authority has jurisdiction. If wewant the states to help us explainand promote our policies, we needto include them in our planning anddecisionmaking, much like we didduring the development of theOSHA strategic plan.

More inspections are done bystate programs than by federalOSHA inspectors. All the consulta-tions are done by state employeesusing federal dollars, to a large ex-tent. State programs generally havea much greater investment in edu-cation and training activities andother outreach to employers than wedo at the federal level. So it’s im-portant for us to recognize that thisprogram’s very much a partnershipbetween the state and federal gov-ernments, and we need to work to-gether to achieve our ends.

1 Section 18(b) of the Occupational Safetyand Health Act of 1970, P.L. 91-596, givesstates the authority to establish their ownsafety and health plans. These plans must be“at least as effective as” federal standards.OSHA evaluates, approves, and monitors thestandards and performance of the state plansand provides up to 50 percent of the cost ofoperating the state plans.

Would you supportexpanding the consul-

tation program? At theexpense of inspections?

In North Carolina, the firstthing we did was to get our

enforcement staff up to a level thatwe thought appropriate for thestate. That generated increased in-terest on the part of employers intraining and consultation. So afterestablishing that credible enforce-ment program, we then greatly ex-panded the training and consulta-tion efforts.

So, do I support an expansion ofconsultation? Yes, I do. When em-ployers come asking for help, weneed to be able to respond. Andmany states at this point are unableto respond to the demand that theyhave.

Would I support expansion ofeducation training? Yes, indeed, butnot at the cost of reducing enforce-ment. It’s important to have a cred-ible enforcement program. Andright now at the federal level, wehave relatively fewer inspectors, asmaller investment than the statesdo in enforcement. So I would notwant to see our enforcement pro-gram reduced to expand other ini-tiatives.

Right now we are making about34,000 federal inspections and an-other 56,000 state inspections. Addto that about 20,000 consultations,which gives us a five to one en-forcement versus consultation ra-tio. Is that an appropriate mix? It’sprobably reasonable. Is that enoughfor the country as a whole? Prob-ably not. We probably need to domore of both.

Fleming is a public affairs spe-cialist in OSHA’s Office of PublicAffairs, Washington, DC.

If we want the statesto help us explainand promote ourpolicies, we need toinclude them in ourplanning anddecisionmaking. . . .

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Changing the WayWe Do BusinessThe final part of the serieson OSHA cooperative effortsby Judith Weinberg

Job Safety & Health Quarterly Fall/Winter 1998 21

he commitment to promoteworker safety and healththrough cooperative part-T

nerships whenever possible has ledthe Occupational Safety and HealthAdministration (OSHA) to forgealliances in both likely and unlikelyplaces. The first part of this serieslooked at two well-establishedagency programs, OSHA Consul-tation and the Voluntary ProtectionPrograms (VPP), and how theirsuccess has demonstrated the valueof working cooperatively with em-ployers and workers to establish ef-fective workplace safety and healthprograms. This second and finalpart of the series shows other areaswhere voluntary partnerships arechanging the face of OSHA and thelandscape of worker safety andhealth.

Partnership W orksin Enforcement

At redesigned OSHA area of-fices, safety and health complianceofficers are undertaking strategic

1 See Edwin Bowers, “Parsippany Looks atNew Way of Protecting Workers,” Job Safety& Health Quarterly 7(2):23-24, Spring 1996;and Susan Fleming “ ‘New OSHA’ Works inAtlanta-East and Parsippany,” Job Safety &Health Quarterly 6(4):14-15, Summer 1995.

…voluntary partnerships are changing theface of OSHA and the landscape of workersafety and health.

initiatives that feature both a part-nership element and an enforce-ment component. They are takinga hard look at local problems andcoming up with new ways to com-bat serious workplace hazards suchas falls, body strains (ergonomics),trench cave-ins, and lead poison-ings.

For example, a five-pronged ini-tiative aspires to make New Jerseyhighways the safest worksites in thecountry for road construction work-ers.1 This effort grew from theParsippany Area Office’s need todeal with the tragic aftermath of anaccident in which a passenger truckcrossed over a barrier into a workzone and killed three highway con-struction workers. OSHA, the NewJersey Department of Transporta-tion (NJDOT), the New JerseyState Police, the Laborers Interna-tional Union, and Laborers Locals472 and 172 came together to

implement a strategy that includesthe following:• construction safety hazard

awareness training for a newstate police traffic-safety unit,

• a choice for contractors betweencooperative partnership or tradi-tional OSHA enforcement,

• data collection from state policereports to track hazard correctiontrends among highway contrac-tors and to educate the variouspartners,

• intervention by state troopersand enforcement by OSHAagainst offending contractors,and

• inclusion of permanent contractlanguage requiring contractors toestablish general and site-spe-cific safety practices in order tobid for state-funded highwaywork.

22 Job Safety & Health Quarterly Fall/Winter 1998

This effort is getting results.State troopers have reported thattheir safety and health interventionsare up 850 percent. From June 1995to July 1997, the 2,319 hazards thathave been identified and fixed in-clude unsafe lane closure, inad-equate crew protection, and unsafesite-vehicle operation. This has af-fected the worksites of more than135 different contractors. Workersare now at reduced risk, and so isthe driving public.

Based on its initial success, NewJersey not only added 20 officersto the 25 originally assigned to theproject, but also decided to expandthe collaborative effort to countyand local police. A combined totalof 545 state, county, and localpolice officers are to be trained andready to intervene if needed in haz-ardous situations at highway con-struction sites. A number of otherstates and localities have asked theNew Jersey State Police for help increating similar programs.

Prior to partnership with the NJ-DOT to improve the safety of high-way construction zones in New Jer-sey, the Parsippany area office ini-tiated a partnership with the New

Jersey Department of Transporta-tion and the New Jersey Depart-ment of Health (NJDOH) to reducethe excessively high lead exposuressuffered by workers contracted torepaint highway bridges.

All three partners collaborated toestablish permanent contract lan-guage addressing the safety andhealth precautions necessary tosafely remove existing lead-basedpaint prior to repainting. This ini-tiative began because of the fre-quent cases of lead poisoningamong workers removing lead-based paint caused by high airbornelead levels from the abrasive blast-ing removal. The comprehensiveand specific contract language,adopted in spring 1993, includedrequirements such as the following:

• Employers must take monthlyblood lead levels for all employ-ees exposed above 50 µg/m3.

• All contractors must implementa comprehensive Lead Healthand Safety Plan (LHSP).

• A full-time health and safety of-ficer must be onsite at all timesto enforce the LHSP.

• A health professional (e.g., Cer-tified Industrial Hygienist) mustindependently review theworksite and evaluate thecontractor’s compliance with theLHSP and the OSHA lead stan-dard (29 CFR 1926.62), create awritten summary of the findings,and send the report to NJDOT,NJDOH, and OSHA.

• The bridge painting contractormust use only New Jersey-basedapproved labs for blood leadanalysis. This requirement en-ables the tracking of theemployee’s blood lead levels bythe NJDOH who are sent, ac-cording to existing New Jerseylaw, all level in excess of 25 µg/dl (deciliters) of whole blood.

• All employees whose blood leadlevels exceed 40 µg/dl must bere-trained on the effective use ofrespiratory protection.To date, the results have been

impressive. Blood lead levelsamongst the bridge workers havegone down steadily—from anaverage of 42 µg/dl in 1991 to33 µg/dl in 1996. Similarly, the per-centage of blood lead levels be-tween 25 µg/dl and 39 µg/dl in-creased from 44 percent in 1991 to

…a five-pronged initiative aspires tomake New Jersey highways the safestworksites in the country for roadconstruction workers.

Proper taper setup for closing first lane and shoulder.

Job Safety & Health Quarterly Fall/Winter 1998 23

82 percent in 1996. In other words,82 percent of all blood leads re-ported were below OSHA’s actionlevel of 40 µg/dl level.2

Most rewarding of all was thedrop in the highest blood leads. In1991, 11 percent of all blood leadsreported were above the removalcriterium of 60 µg/dl. In 1995,only 1 percent were in excess of60 µg/dl, and in 1996, less than1 percent exceeded 60 µg/dl. Theseresults were achieved with a mini-mal increase in the cost of thebridge repainting and with the com-plete satisfaction of the contractorswho appreciate how the specificcontract requirements leveled thecompetitive playing field.

In another collaboration, OSHAstaff in the St. Louis Area Office—aware that many roofers were be-ing seriously injured in falls atresidential projects—organized apartnership with the local unions,roofing associations, and suppliersof roofing materials and fall pro-tection equipment. OSHA safetyspecialists helped local buildingcontractors develop practical fallprotection plans and conductedhazard-assessment training for thecontractors’ labor unions and safetyand health committees. The effortpaid off. The two contractor asso-ciations reported—and their unionsconfirmed—that within 6 months,roofing injuries declined 70 per-cent, from 61 in 1995 to 17 in l996.And only 9 of those 17 injuries re-sulted in lost work time.

Another example of integratingpartnership into OSHA enforce-ment is the first-of-its-kind volun-tary compliance agreement by

OTI’s Pacific Coast Education Center staff give students hands-on experiencein crane inspections during course on mobile crane and rigging safety.

Exide Corporation, the UnitedSteelworkers of America, theUnited Auto Workers, the Interna-tional Union of Electronic Work-ers, and OSHA. Exide and theunions representing workers at itsfacilities voluntarily approachedOSHA with a plan to reduce workerexposure to lead, cadmium, andinorganic arsenic—highly toxicchemicals used in Exide’s batterymanufacturing process—to thelowest feasible level. Exide agreedto hire a consultant, approved by

all parties, to conduct onsite evalu-ations at five company facilities infederal enforcement states and fivein states with OSHA-approvedplans. At its discretion, OSHA alsocan participate in these evaluations.The expert will identify all feasibleengineering and work practice con-trols and produce a report recom-mending controls for each facility.The report will go to Exide, localunions, local OSHA area offices,and OSHA’s Office of Health Com-pliance Assistance in Washington,

2 This is the level at which employers arerequired to take certain actions to keepworker exposures in check. See OSHA’s leadstandard for more specific information, Title29 of the Code of Federal Regulations, Part1926.62. See Standards at OSHA’s Web sitehttp://www.osha.gov/.

24 Job Safety & Health Quarterly Fall/Winter 1998

DC, for review and concurrence.Exide then will have 18 months toimplement the control recommen-dations at these 10 facilities.

These and other partnerships il-lustrate how labor, business, andthe government can work togethereffectively to improve workersafety and health. Implicit in thesecooperative ventures, and essentialif they are to succeed, is the genu-ine commitment of participants interms of time, money, and effort toprotect workers’ safety and health.

To date, 20,819 students have completedsafety and health course work at OSHATraining Institute Education Centers.

Education Center students at Niagara County CommunityCollege prepare to go through the personal decontaminationchamber before entering the work area to remove asbestos.

OSHA ’s Partnership withthe States

The benefits, complexities, andoccasional conflicts of shared re-sponsibility for ensuring safe andhealthful working conditions arenowhere better illustrated than inthe regulatory partnership of Fed-eral OSHA and the 25 states andterritories that have chosen to op-erate their own workplace safetyand health programs.3

In developing the OccupationalSafety and Health Act of 1970, theCongress recognized the need tocreate a strong federal presence thatwould set and enforce mandatorystandards. At the same time, theCongress acknowledged that manystates already were acting to pro-tect the safety and health of theirworkers and should be encouragedto continue to “assume the fullestresponsibility for the administra-tion and enforcement of their oc-cupational safety and health laws.”4

Consequently, although the Con-gress gave OSHA authority toadopt and enforce workplace safetyand health standards throughout thenation, it allowed states to continueto implement their own state OSHAprograms, subject to obtaining fed-eral approval and meeting specificminimum requirements. It becameOSHA’s responsibility to evaluate,approve, and regularly monitor thestandards and performance of thesestate plans, which must be “at leastas effective as” the federal pro-gram, and to provide annual fed-eral grants of up to 50 percent ofthe costs associated with operatingstate programs.

The 25 states that operateOSHA-approved state plans covermore than 40 percent of the nation’s

3 Section 18(b) of the OSH Act gives statesthe authority to establish their own safetyand health plans.4 Section 2(b)(11) of the Occupational Safetyand Health Act of 1970.

Job Safety & Health Quarterly Fall/Winter 1998 25

Grassroots Worker Protection -The Contribution of State Pro-grams to the Safety and Healthof America’s Workforce,8 is agood starting point for exploringthe role and contributions of stateprograms. Published annually bythe Occupational Safety andHealth State Plan Association,this report describes a widerange of state occupationalsafety and health activities—some of them offshoots of fed-eral programs and others pio-neering initiatives that havepaved the way for subsequentfederal adaptation. FederalOSHA recently incorporated“Grassroots” into the compli-ance officer training given by theOSHA Training Institute to en-courage a better understandingand appreciation of the vital staterole within the federal-state part-nership.

8 Copies of the report are available throughstate plan offices. OSHA publishes a list ofstate plan addresses on its Internet page. Goto http://www.osha.gov/oshdir/states.html.

workplaces. They also cover stateand local government employeeswho are not otherwise subject toOSHA protection. Although Fed-eral OSHA and the states withOSHA- approved plans sometimesmay have differing views on poli-cies and approaches, they bothshare a commitment to partnershipthat is leading to greater state in-volvement in OSHA’s planning andpolicy-setting processes and otheroperations.

OSHA’s Office of State Pro-grams in the Directorate of Federal-State Operations, among otherthings, coordinates and facilitatesthe agency’s partnership with the25 OSHA-approved state planstates. The office works closelywith the Occupational Safety andHealth State Plan Association(OSHSPA)5 to maintain effectivechannels of communication, tokeep the states abreast of federalinitiatives, and to ensure that stateinterests are considered within theframework of the national OSHAprogram.

OSHA Trainingand Education

OSHA’s many partnership initia-tives have shown that training andeducation are critical to an effec-tive safety and health program. TheOSHA Training Institute, located inDes Plaines, IL, offers basic and

advanced courses in safety andhealth for federal and state compli-ance officers, state consultants, per-sonnel from other federal agencies,and private sector employers, em-ployees, and their representatives.

To meet increased demand forInstitute courses from the privatesector and from other federal agen-cies, and to make it easier for a geo-graphically diverse student popu-lation, OSHA also has 12 TrainingInstitute Education Centersthroughout the country. The centersare nonprofit colleges, universities,and other organizations, selectedcompetitively, that offer a varietyof OSHA courses of particular in-terest to the private sector and otherfederal agencies.

The agency provides course cur-riculum outlines, suggested studenthandouts, orientation sessions forthe education center instructors,and assistance in explaining OSHApolicy, but does not provide anyfunding. Each education centersupplies its own instructors andcollects tuition6 to pay for salaries,course materials, and other operat-ing costs. This has been a success-ful partnership effort, and to date,20,819 students have completedsafety and health course work atOSHA Training Institute EducationCenters.

In addition, OSHA’s train-the-trainer program7 authorizes train-ers to teach occupational safety and

Partnerships illustrate how labor, business,and the government can work togethereffectively to improve worker safetyand health.

5 See Veronica Thomas and Carol Sanford,“All About OSHSPA: The OccupationalSafety and Health State Plan Association,”Job Safety & Health Quarterly 1(3):11-13Spring 1990.

6 In Fiscal Year 1997, the tuition for a 4-daycourse ranged from $495 to $695.7 See story on page 39 of this issue.

26 Job Safety & Health Quarterly Fall/Winter 1998

health standards and related topics.This outreach effort to promoteworkplace safety and health aware-ness conducted, on average, morethan 100 classes per week in 1996.OSHA also uses grants to help meetthe educational needs of employ-ers and employees.

Susan Harwood T rainingGrants

Through training grants, OSHAprovides funds to nonprofit orga-nizations interested in developingand conducting training and edu-cation programs in subject areas

Two grantees, the University ofCalifornia at Los Angeles and theService Employees InternationalUnion, are partners with GrancareCorporation in a project to reduceback injuries among nursing homeemployees.

The program started as a pilotproject at a Grancare nursing homein California with the formation ofa back injury prevention commit-tee. The committee, composed ofboth management and workers,conducted an assessment of job riskfactors at the nursing home andused the results to identify appro-priate lifting equipment for pur-chase. All employees then receivedgeneral training on lifting and backinjuries, began using a checklist toidentify specific problems on theirown jobs, and used followup train-ing to learn how to match liftingequipment and work practice con-trols to each individual’s specifictasks.

Establishing an effective safety and healthprogram is an investment strategy that paysbig dividends—and not just the financialkind, either.

where OSHA believes such train-ing is lacking.

In recent years, OSHA hasawarded grants to safety and healthorganizations, employer associa-tions, labor unions, and educationalinstitutions on topics such asbloodborne diseases in the healthcare industry, hazard communica-tion for small businesses, lead inconstruction, safe electrical workpractices, and safe logging workpractices.

One such program focuses onreducing ergonomic-related inju-ries through training and education.

Pacific Coast Education Center instructor Dave DuBose shows students how to do a soil analysis as part of a fieldexercise on types of soils and trenching devices.

Job Safety & Health Quarterly Fall/Winter 1998 27

Formerly known as the Tar-geted Training Grant Program,OSHA renamed the program inApril 1997 in honor of Dr. SusanHarwood, who served 17 yearswith OSHA before her death in1996.

Harwood held a Ph.D. in mi-crobiology and immunology, andas Director of the Office of RiskAssessment in the OSHA Direc-

torate of Health Standards Pro-grams, she helped develop OSHAstandards on bloodborne patho-gens, cotton dust, benzene, form-aldehyde, asbestos, and lead inconstruction.

The Susan Harwood TrainingGrant Program commemoratesher exceptional service to occu-pational safety and health.

Susan Harwood TrainingGrant Program

The back injury prevention com-mittee provides assistance and re-inforcement for the training on anongoing basis. If the program issuccessful in reducing back inju-ries, Grancare will replicate it in itsnursing homes in other locationsacross the country.

For 3 years, OSHA also has tar-geted some grants to assist smallbusinesses (those with fewer than250 employees) in setting up safetyand health programs. There are sixgrants at present, each with its ownapproach for training small busi-nesses. Grantees offer training and,in some of the programs, onsiteassistance as well.

One of the recipients, the Na-tional Safety Council, conducted afollow-up survey of participants inits 2-day training course. The sur-vey showed that 83 percent of thetrainees introduced or improvedemployee participation in theirworkplace safety and health pro-grams. Another grantee, the AliceHamilton Occupational HealthCenter, provides training to smallbusiness managers and offers to goto a trainee’s worksite to help iden-tify hazards and develop a writtensafety and health plan. Busi-nesses—such as a constructioncompany doing renovation work, abiomedical research laboratory, anauto repair shop, a printing shop,and a home health care agency—have taken advantage of thecenter’s program.

All of these efforts point to howpartnership can be an efficient wayof delivering services and improv-ing worker safety and health withfewer resources.

OSHA Can HelpEstablishing an effective safety

and health program is an invest-ment strategy that pays big divi-dends—and not just the financial

kind, either. These programs saveboth lives and dollars. In addition,companies often experience de-clines in absenteeism, both qualityand quantity improvements in pro-duction, and real but tough-to-mea-sure increases in employee morale.Safety and health programs are keyfor financially successful compa-nies and for those that want to be.

OSHA can help with extensiveexpertise, support, and cooperation.Small employers with hazardousoperations can take advantage ofthe free assistance availablethrough OSHA’s Consultation Pro-gram.

Employers and workers willingto take on the challenge of OSHA’sVoluntary Protection Programs canexpect to reap the many benefitsVPP participants experience, in-cluding often dramatically reducedinjury and illness rates and relatedfinancial costs. The VPPPA9

Mentoring Program can help makecooperative excellence a realityeven for employers with little ex-perience in safety and health pro-tection.

The courses offered at the OSHATraining Institute and EducationCenters, together with OSHA’smany publications, computer-as-sisted tools, and myriad resourcesavailable at its Internet site, offer avariety of paths to greater safetyand health awareness, expertise,and voluntary compliance.

As many in the safety and healthcommunity have already discov-ered, whether by participating inOSHA’s voluntary programs or itsvarious cooperative enforcementinitiatives, partnership can be apowerful tool for change—andOSHA can be a valuable partner.

For more information on theseand other OSHA programs, contactyour nearest OSHA regional or areaoffice, or visit the agency’s Web siteat http://www.osha.gov/.

Weinberg is a program analyst inOSHA’s Division of VoluntaryPrograms, Washington, DC.Contributions to this article byHelen Beall, OSHA Office ofTraining and Education.

9 Voluntary Protection Program ParticipantsAssociation

n a continuing effort to protectworkers from exposures to haz-ardous substances on the job,I

the Occupational Safety and HealthAdministration (OSHA) recentlyproposed a standard to protect em-ployees exposed to tuberculosis, or

led.

areas, is growing. Of even greaterworry now is the emergence of anew and deadly form of the diseasethat is resistant to current treatment.Infection with these multi-drug re-sistant strains can lead to severelung damage and is often fatal. Oneof my top priorities is to ensure asafe and healthful workplace. Wemust do all in our power to protectworkers against this deadly dis-ease.”

What is TB?Tuberculosis is caused by bac-

teria called Mycobacterium tuber-culosis. The bacteria usually attackthe lungs, but several other organsof the body—including the brain,

TB as it is commonly cal

The Battle AgainstTuberculosis—OSHA Fights Backby Kerri L. Lawrence

28 Job Safety & Health Quarterly Fall/Winter 1998

1 For more information, see Questions andAnswers About TB. U.S. Department ofHealth and Human Services. Public HealthService, Centers for Disease Control andPrevention, National Center for PreventionServices, Division of Tuberculosis Elimina-tion. 1994. See also http://www.cdc.gov/.

kidneys, and bones—can be af-fected. Left untreated, the infectionmultiplies and destroys affected tis-sues, leading to serious illness ordeath.

The disease is spread through theair from one person to anotherwhen someone with TB disease ofthe lungs or throat coughs orsneezes. People nearby maybreathe in bacteria and become in-fected. Left untreated, one personwith an active case of tuberculosiswill infect from 10 to 15 people peryear.

Anyone can get TB. Those atgreatest risk, however, include per-sons with HIV infection, poor andmedically neglected people, home-less individuals, nursing home resi-dents, elderly persons, and healthcare workers and others who comeinto contact with high-risk popula-tions or persons with infectious TB.

What is OSHA doing tocombat TB?

Through the years, OSHA hasbeen actively tracking the numberof TB cases throughout the U.S.In fact, the proposed standardcomes on the heels of nationwideenforcement procedures issued by

From 1985 to 1992,the number of activeTB cases increased20 percent, reversinga previous 30-yeardownward trend.

Once the leading cause of deathin the United States, TB slowlybegan to disappear after scientistsin the 1940s discovered the first ofseveral drugs to treat the disease.But by the mid-1980s, a resurgenceof TB cases demonstrated that thewar had yet to be won.

From 1985 to 1992, the numberof active TB cases increased 20percent, reversing a previous 30-year downward trend. Statisticsfrom the Centers for Disease Con-trol (CDC) show that the numberof TB cases reported in the U.S.began increasing after 1984—withmore than 25,000 cases reported in1993.1 By 1992, however, the num-ber of TB cases again began a de-cline.

“The battle against TB is farfrom over,” says Secretary of La-bor Alexis M. Herman. “The riskfor the workers who care for cli-ents and patients infected with TBcontinues to be high and, in some

28 Job Safety & Health Quarterly Fall/Winter 1998

Job Safety & Health Quarterly Fall/Winter 1998 29

the agency in February 1996 thatreflect revised guidelines by theCDC to prevent the transmission ofTB, including drug-resistant strainsof the disease.

OSHA’s proposal incorporatesbasic elements of the revised CDCrecommendations for health carefacilities, such as written exposurecontrol plans, procedures for earlyidentification of individuals withsuspected or confirmed cases, andemployee education and training.

A final OSHA rule would requireand enforce these types of provi-sions. This enforcement alternativeis important because compliancewith various portions of OSHA’sproposed TB standard is sporadic.For example, OSHA estimates that95 percent of hospitals have TBtesting programs, whereas only 15percent provide TB training andonly 50 percent use respirators.Outside of the health care sector,compliance with TB preventionand control measures falls sharply.OSHA estimates that, on the whole,hospitals have a 50-percent com-pliance rate with OSHA’s proposedprevention and control measures,with other sectors averaging only21-percent compliance.

The agency’s new proposedstandard would protect an esti-mated 5.3 million workers in worksettings with a high risk of TB in-fection. Specifically, the standardwould cover employees in morethan 100,000 facilities, includinghospitals, homeless shelters, hos-pice centers, long-term care facili-ties for the elderly, detention andcorrectional facilities, and certainlaboratories performing high-haz-ard procedures, handling TB speci-mens, or processing and maintain-ing resulting cultures. Also, the pro-posed standard would cover occu-pational exposure to workers in-volved in social work, social wel-fare services, teaching, law en-

forcement, or legal services, if pro-vided in any of the previously men-tioned settings. Finally, the stan-dard would apply to workers pro-viding emergency medical ser-vices, home health care, or home-based hospice care.

OSHA’s research supports thefinding that the proposed standardwould prevent 21,000-26,000 casesof work-related TB infections an-nually and would save from $89million to $116 million in medicalcosts for treatment of TB and lostproduction caused by worker ab-senteeism and associated disabili-ties with active cases of TB.

What does OSHA ’sproposed TB standardentail?

The proposal incorporates basicinfection control provisions de-signed to reduce occupational risksfor exposed workers. It requiresemployers to develop a written ex-posure control plan and identifyand isolate individuals with sus-pected or confirmed infectious TBor transfer them to facilities withisolation capabilities. The proposedstandard also requires engineeringcontrols in some facilities, such asestablishing negative-pressure inTB isolation rooms or areas.

Other provisions in the standardinclude tuberculin skin testing, haz-ard communication and training,and recordkeeping. Respiratoryprotection also would be requiredunder specific conditions.

The standard gives employersclearly defined steps to protect theirworkers and, at the same time, as-sures workers that steps will betaken to help protect them againstthis deadly disease.

Although the proposed rule rep-resents OSHA’s best ideas for pre-venting workplace transmission ofTB, the agency is seeking broadpublic participation through a se-

ries of hearings to ensure that thefinal rule is refined and tailored toaddress the many different types ofworkplaces it would cover. Hear-ings are set to begin in Washing-ton, DC, this spring and will be heldin the auditorium of the Departmentof Labor (Francis Perkins Build-ing), 200 Constitution Avenue,N.W., Washington, DC.

Subsequent public hearings willbe held in other U.S. locations. AFederal Register notice will be is-sued upon determination of the lo-cations and dates of those hearings.

How can I find out more?The full text of OSHA’s pro-

posed rule, which appeared in theOctober 17, 1997, edition of theFederal Register, can provide de-tailed information on this importantagency action. For a copy of theproposal, contact OSHA’s Publica-tions Office at (202) 219-4667 orsend a self-addressed mailing labelto OSHA Publications, P.O. Box37535, Washington, DC 20013-7535. See also, Federal RegisterNotices on the agency’s Homepageat http://www.osha.gov/.

Lawrence is associate editor ofJob Safety & Health Quarterlyand a staff writer-editor inOSHA’s Office of Public Affairs,Washington, DC.

The agency’s newproposed standardwould protect anestimated 5.3 millionworkers in worksettings with a highrisk of TB infection.

Job Safety & Health Quarterly Fall/Winter 1998 29

30 Job Safety & Health Quarterly Fall/Winter 1998 Downtown Columbus business district.30 Job Safety & Health Quarterly Fall/Winter 1998

Job Safety & Health Quarterly Fall/Winter 1998 31

epresentatives of smallbusinesses had an opportu-nity this summer to discuss

OSHA Asks SmallBusinesses for Inputon Safety and HealthProgram Proposalby Ted Twardowski

Rvarious safety and health issueswith OSHA and the Small BusinessAdministration (SBA). The twogovernment agencies sponsoredfour meetings with the small busi-ness community in Atlanta, GA;Philadelphia, PA; Columbus, OH;and Portland, OR. The small busi-ness meetings, held in cooperationwith the SBA Office of Advocacyand the Office of Management andBudget, focused specifically onsmall business issues.

OSHA and the SBA Office ofAdvocacy selected 20 small busi-ness attendees for each meeting,which provided diverse points ofview and representation from awide range of industry groups.“This type of collaboration was afirst and contributed greatly thesuccess of the meetings,” notes ArtDeCoursey, OSHA’s small busi-ness liaison. “We had a good mixof small businesses ranging fromthe self-employed individual to asmall manufacturing plant of 150to larger associations representingmany small business,” he adds.

These meetings gave OSHA aface-to-face dialogue with about 80

small business representatives whomade recommendations on theagency’s draft safety and healthprogram proposal. In addition, rep-resentatives from many differentkinds of small businesses discussedtheir own individual experiencesand concerns about safety andhealth programs, giving OSHAsome new perspectives in this area.

Safety and health programs isnot a new concept. In 1989, OSHApublished non-mandatory guide-lines for safety and health programsin the Federal Register.1 Theseguidelines reflect the best safetyand health management practicesobserved. Basically a “find and fix”approach, the standard would re-quire employers to set up a safetyand health program; the complex-ity of this program would dependon the needs of the workplace. Evi-dence shows that, in addition toincreasing employee safety andhealth, these types of programshave positive effects on decreasingemployee turnover and workercompensation costs while increas-ing employee morale and produc-tivity.

An estimated 50,000 chronic ill-ness-related fatalities, 6,000safety-related fatalities, and12,000 amputations occur eachyear in the workplace. A dispro-portionately high number ofwork-related fatalities occur inestablishments with fewer than10 employees. These workplacesrepresent only 17 percent of thetotal workforce employment and75 percent of all establishments.They account for approximately33 percent of all workplace fa-talities and for about 1 millionemployer-reported injuries eachyear.2

2 U.S. Department of Labor, OSHA Office ofRegulatory Analysis, Directorate of Policy,Washington, DC, July 1997.

1 Safety and Health Program ManagementGuidelines (Federal Register 54 (16):3904-3916, January 26, 1989.

Many, including OSHA, havelong recognized the value ofworksite safety and health pro-grams in preventing job-related in-juries, illnesses, and fatalities.These include states, members ofthe safety and health community,insurance companies, professionalorganizations, companies partici-pating in the agency’s VoluntaryProtection Programs, as well ascompanies participating in othersafety and health programs stem-ming from OSHA consultation ser-vices and compliance.

Because of the recognized effec-tiveness of these types of programs,one of OSHA’s top regulatory pri-orities is to publish a proposed stan-dard on safety and health programsthat addresses serious safety andhealth hazards in the workplace.This standard would require that allemployers have a system in placeto identify and control hazards in

32 Job Safety & Health Quarterly Fall/Winter 1998

their workplaces and would includefive major elements: managementleadership and employee participa-tion, hazard assessment, hazardprevention and control, informationand training, and program evalua-tion.

Also known as a “building blockstandard” because it is the founda-tion of a safe and healthful work-place, the standard would help em-ployers, especially small busi-nesses, comply more systemati-cally with other OSHA obligations.Consequently, the standard will re-quire review under the Small Busi-ness Regulatory Enforcement Fair-ness Act (SBREFA). Signed into

Portland city skyline with Mount Hood in background.

law in 1996, the purpose of this leg-islation, in part, is to facilitate theeffective participation of smallbusinesses in the regulatory processand includes a review of most regu-latory actions by a Small BusinessAdvocacy Review Panel to see thatthe concerns of small businessesare identified and, where appropri-ate, addressed.

Several weeks prior to eachmeeting, participants receivedOSHA’s draft regulatory text andan estimate of the time and costburden that the agency believedwould be incurred by promulgat-ing the standard. Participants re-viewed the materials and came pre-pared to discuss issues of concern.

These meetings gaveOSHA a face-to-facedialogue with about80 small businessrepresentatives whomade recommenda-tions on the agency’sdraft safety andhealth programproposal.

Job Safety & Health Quarterly Fall/Winter 1998 33

Enacted by the Congress onMarch 29, 1996 the Small Busi-ness Regulatory EnforcementFairness Act (SBREFA), containssix main components to helpsmall businesses:

(1) Simplified RegulatoryCompliance: Federal agenciesmust develop comprehensiveguidelines in plain English and awell-defined process to respond tosmall business inquiries abouthow they must comply with fed-eral agency regulations.

(2) Equal-Access-to-JusticeAmendments: Small businesseshave expanded authority to go tocourt for attorney’s fees and costs

when a federal agency has beenfound to be excessive in enforcingfederal regulations.

(3) Congressional Review: TheCongress can review each majorrule promulgated before it can takeaffect.

(4) Regulatory EnforcementReform of Penalties: Within1 year, each agency has to have apolicy for the reducing and, in somecircumstances, waiving civil pen-alties for violations of a regulation.

(5) Small Business AdvocacyReview Panels: Before proposedrules are published, the Environ-mental Protection Agency andOSHA must establish government

Overview of SBREF A

panels to receive input fromaffected small businesses and tomake public the panel’s report.

(6) Oversight of RegulatoryEnforcement: SBA must appointa Small Business and AgricultureRegulatory Enforcement Ombuds-man and 10 Small Business Regu-latory Fairness Boards to allowsmall businesses an opportunity tocomment on enforcement activi-ties of federal regulatory agencies.The National Ombudsman and theFairness Boards will receive com-ments about federal complianceand enforcement activities andreport these findings annually tothe Congress.

34 Job Safety & Health Quarterly Fall/Winter 1998

At each meeting, OSHA repre-sentatives explained in detail whyan effective safety and health pro-gram is necessary, why small busi-nesses should be included in thisstandard, and why this standardwould benefit all involved. OSHAstaff also provided a list of sug-gested topics for discussion onitems such as scope and coverage,core elements, employee participa-tion and management leadership,hazard identification and assess-ment, hazard prevention and con-trol, information and training, pro-gram evaluation, phased-in compli-ance dates, burden to comply, en-forcement, program experience,multiemployer worksites, docu-mentation, and outreach.

“We want ourstakeholders toknow that for smallbusinesses whowant our help inensuring a saferworkplace, we’reonly a phone callaway.”

Art DeCoursey, smallbusiness laison for OSHA

Atlanta skyline with Capitol in background.

priority discussion were different ateach meeting, these and other top-ics stakeholders wished to raisewere addressed. For example, par-ticipants raised questions on suchdiverse and broad-ranging issuesas—Would a performance-orientedstandard give too much flexibilityto both the employer and the com-pliance officer which could resultin excessive litigation? Would theregulation exclude low-hazard in-dustries and/or small businesses?Doesn’t the standard overlap withother OSHA standards? Will thestandard cover hazards not specifi-cally addressed by regulations (e.g.,ergonomics, violence in the work-place)? Will promulgation of thisstandard result in double citations,

Stakeholders were asked at eachmeeting to vote on the six topicsthey believed most important. Al-though the six topics selected for

Job Safety & Health Quarterly Fall/Winter 1998 35

Philadelphia City Hall.

one for the hazard, and one for nothaving an effective safety andhealth program? Will OSHA sup-ply checklists or model programs?

The comments received duringthese meetings are likely to beconsidered in helping clarify thelanguage or requirements of thedraft proposal to indicate that(1) there is no requirement for awritten safety and health program,(2) OSHA will not cite employerstwice for the same violation, and(3) employee participation can bein the form of a safety and healthcommittee but OSHA does notmandate such committees. Theseand other valuable insights and in-formation provided will help theagency in considering the concernsof small business, as appropriate,when further developing the re-quirements of a future proposedstandard.

Participants believed the fourregional meetings were highly suc-cessful. “This was definitely a greatopportunity for all of us. We wantour stakeholders to know that forsmall businesses who want our helpin ensuring a safer workplace,we’re only a phone call away,”DeCoursey concludes.

Twardowski is a safety and healthspecialist in the Office of FireProtection, Directorate of SafetyStandards, Washington, DC.

36 Job S

SHFis20O

Governmesults Act agency’s gperformansigned intlic Law 10eral agenplans, prefying agennually on apared to gimprove pFederal Gagencies aprogram forces fedepayers theachieving are getting

In comOSHA devthe OfficeBudget a goals to hmission workplaceOSHA’s vclass leadand healthprotectingAmerica’salso rediremission frotivities to zdo this, theterdepend

A Strategyfor Improving Worker

Safety and Healthby Anne Crown-Cyr

afety & Health Quarterly Fall/Winter 1998

A’s Strategic Plan forcal Years (FY) 1998-02, as required by thent Performance and Re-(GPRA), defines theoals and objectives andce benchmarks. GPRA,

o law in July 1993 (Pub-3-62), requires all fed-

cies to develop strategicpare annual plans identi-cy goals, and report an-ctual performance com-oals. The purpose is toublic confidence in theovernment by holdingccountable for achievingresults. The new lawral agencies to show tax- kinds of results they arewith the resources they.

pliance with the law,eloped and submitted to of Management andstrategic plan outliningelp achieve the agency’sof making America’ss the safest in the world.ision is to be a worlder in occupational safety, with a clear focus on

the safety and health of workers. But, the plancts the focus of OSHA’sm one of measuring ac-eroing in on results. To agency has set three in-ent and complementary

strategic goals to guide the devel-opment of OSHA programs andactivities.

The three basic goals center onimproving workplace safety andhealth, increasing employer andemployee awareness and commit-ment to health and safety, and earn-ing public confidence in OSHA.Each goal has specific, quantifiableobjectives to help assess OSHA’sperformance.

Nationwide efforts to reduce in-juries and illness will include fo-cusing on a specific hazard, a par-ticular industry, or a specific work-place that has a history of high in-jury and illness rates. In construc-tion, for example, the agency willdecrease fatalities by 15 percentover 5 years by focusing on the fourleading causes of fatalities—falls,struck-by, crushed-by, electrocu-tions, and electrical injuries.The agency also may evaluate and,if necessary, revise the 11(c)“whistleblower program,” andby FY 2000, resolve 75 percentof all whistleblower cases within90 days.

To help change workplace cul-ture to increase awareness andcommitment to safety and health,the agency will offer a partnershipapproach and provide complianceassistance services to employerswho agree to implement a compre-hensive safety and health program.

By FY 2002, OSHA will makesure that 50 percent of employersin general industry who are targetedfor or who request an OSHA inter-vention will have either imple-mented an effective safety andhealth program or will have signifi-cantly improved their existing pro-gram. The agency also will imple-ment a targeted outreach plan forall new initiatives such as stan-dards, guidelines, and emphasisprograms.

To help secure public confidencethrough the delivery of programsand services, OSHA will imple-ment an active and ongoing strat-egy to regularly consult withstakeholders to help the agencyset and assess priorities. Forexample, the agency will continue

OSHA’s vision is to be a world class leaderin occupational safety and health, with aclear focus on protecting the safety andhealth of America’s workers.

Job Safety & Health Quarterly Fall/Winter 1998 37

its use of consensus-based ap-proaches to rulemaking suchas negotiated rulemaking, andadvisory committees.

To measure its success, byFY 2002, OSHA wants to makesure that 95 percent of its stake-holders and partners rate as “posi-tive” their involvement in theagency’s stakeholder/partnershipprocess. Employers and employeeswho interact with OSHA will beable to rate OSHA staff profession-alism, competence, and knowl-edge. OSHA’s goal is that 80 per-cent of these be “satisfactory” byFY 2000.

Deputy Assistant Secretary,Greg Watchman points out, “Wedeveloped this plan with very broadinput from managers within theagency to a variety of stakeholdersand partners in the safety and healthcommunity. The strategic plan isreally changing the way that wethink about our mission and chang-ing the way we think about our re-sponsibilities. It is forcing us to in-tegrate all of the different programsand activities that we have at theagency.”

Everyone will be able to see thatwe’ve set goals to save lives andreduce injuries and will see a mani-festation of that effort,” says FrankStrasheim, Regional Administratorfor Region IX. “Employers willknow what to expect from OSHA.They’ll be able to see that our planis not only common sense, butthey’ll see ways they can supportit as well.”

The development and formula-tion of the strategic plan began thispast March with a strategic plan-ning task force involving manag-ers within OSHA, stakeholders,OMB, and the Congress. The ulti-mate success of this plan will, ac-cording to Paula White, Director ofFederal-State Operations, reflectthat broad-based input. “We’ve

Goal 1 - Improve workplacesafety and health for all workers,as evidenced by fewer hazards, re-duced exposures, and fewer inju-ries, illnesses, and fatalities. BySeptember 30, 2000, OSHA will:

• Reduce injury/illness rates20 percent in at least 50,000 ofthe most hazardous work-places.

• Ensure that worker complaintsrequiring an onsite inspectionare resolved within a median of20 working days after notify-ing the employer of the resultsof the complaint.

Goal 2 - Change workplace cul-ture to increase employer andworker awareness of, commit-ment to, and involvement in safetyand health.

OSHA ’s Strategic Goals

• Make often complicated regu-lations easier to understand,OSHA will increase the num-ber of standards written in plainEnglish—whether new or re-vised—from 1 per year in 1998to 5 per year in FY 2000.

• Make all standards, regulations,and reference materials avail-able on the OSHA Home Pageon the Internet (http://www.osha.gov).

Goal 3 - Secure public confidencethrough excellence in the devel-opment and delivery of OSHA’sprograms and services.

• Redesign all field enforcementoffices by September 30, 1999,to improve the agency’s abilityto reduce worker injury, illness,and death in the most hazard-ous workplaces.

been able to develop our strategyas a cross-agency team,” Whiteemphasizes. “We designed this planto address the realistic operationsof a real-world agency,” she con-tinues. “It’s an agency that will be-come much more focused and clear

about what it’s doing and what itintends to do. We can’t measureimpact now, but we have begun thevery significant process of identi-fying the steps that will take us tothe end result we want to achieve.”

It’s going to move us from anagency that’s been focused on ac-tivities in the past, to one focusedon impacts,” says Richard Terrill,Acting Regional Administrator forRegion X.

“We’ve focused a lot in the paston how many inspections wedid—how many citations we is-sued,” notes Larry Liberatore, Di-rector of Maritime Safety Stan-dards in the National Office. “Ifwe’re going to count something, weneed to count how many liveswe’re going to save; how many in-juries we’re going to prevent. Thisplan represents the unified strategyto do just that.”

The three basic goalscenter on improvingworkplace safety andhealth, increasingemployer andemployee awarenessand commitment tohealth and safety,and earning publicconfidence inOSHA.

38 Job Safety & Health Quarterly Fall/Winter 1998

GPRA SummaryThe Government Performance

and Results Act (GPRA) requiresthe Federal Government to im-prove its performance and in-crease its results. It was signedinto law in July 1993 (Public Law103-62) and will be implementedin all federal departments andagencies. The purpose of GPRAis to:• Improve public confidence in

the federal government by sys-tematically holding federalagencies accountable forachieving program results.

• Improve program effectivenessand public accountability bypromoting a new focus on re-sults, service quality, and cus-tomer satisfaction.

• Help managers improve servicedelivery and improve internalmanagement of the FederalGovernment.

• Improve congressional deci-sionmaking by providing moreobjective information.

GPRA RequirementsGPRA requires all federal agen-

cies to:• Develop strategic plans (prior

to FY 1998).• Prepare annual performance

plans that set out the agency’s

performance goals (beginningin FY 1999).

• Report annually on actual per-formance compared to goals(first report due in March2000).

Strategic PlanRequirements

By September 30, 1997, eachfederal agency must submit a stra-tegic plan for its program activi-ties to the Office of Managementand Budget. The plan must coverat least 5 fiscal years and be up-dated at least every 3 years. Thestrategic plans must include:• A comprehensive mission

statement.• General goals and objectives

for the agency’s major func-tions.

• A summary of the resources,systems, and processes that arecritical to goal achievement.

• A description of how the gen-eral goals and objectives will beachieved.

• A description of key externalfactors that could affectachievement of these generalgoals.

• A description of how programevaluations are used in estab-lishing goals, along with aschedule of future evaluations.

Building on ReinventionOSHA’s strategic plan really

builds on its reinvention efforts.1

For example, OSHA’s early rein-vention principles—taking a “com-mon sense” approach to enforce-ment and developing OSHA part-nerships with stakeholders—set thestage for implementing theagency’s new strategic plan. UnderGRIP (Getting Results and Improv-ing Performance), OSHA has rede-signed 27 field offices. By the endof FY 1999, the agency expects tocomplete redesign of the remain-ing 40 federal enforcement area of-fices as part of its drive for excel-lence in delivering programs andservices to the public.

Through reinvention, OSHAcontinues to seek to become a per-formance-oriented, data-driven or-ganization with a high premium onsafety- and health-related resultsrather than activities and processes.This effort dovetails with OSHA’sstrategic plan goal to secure publicconfidence in the agency by be-coming a world leader in occupa-tional safety and health.

“OSHA’s strategic plan builds onthe successes experienced throughits reinvention process,” said BobKulick, who heads the agency’s re-invention office. “Reinvention isresults-oriented, and the strategicplan focuses on results.” He notedthat several initiatives in the planare drawn directly from reinventionprograms, such as Maine 2002 and

customer service goals, which flowfrom OSHA’s improved complaintprocess.

Reinvention now becomes ameans to an end—achievement ofour goals—rather than an end it-self,” Kulick adds. “We will needto build upon all of the tools and

programs developed through rein-vention to meet the ambitious goalsin the strategic plan.”

Cyr is editor of Job Safety& Health Quarterly in OSHA’sOffice of Public Affairs, Washing-ton, DC.

1 See also, Susan Hall Fleming, “ReinventingOSHA: A Progress Report,” Job Safety &Health Quarterly 7(1):10-14, Fall/Winter1995; and Frank Kane, “Maine 200-TypePrograms Spread Throughout the U.S.,” JobSafety & Health Quarterly 7(3) 9-15,Summer 1996.2 Identifies the top 200 employers in thatstate with highest number of injuries fromworkers’ compensation claims and offersthem a chance to work with OSHA inreducing injuries and illnesses.

hoOW

tion projecnies, safettions, otherutility compcontractor oand small bmon? TheOSHA’s Ougram, a puthat promothealth awa

Throughalso knownprogram, Otor individugeneral insafety andauthorizesworkers the

1 See Judith WEfforts: A GoodEmployers,” Jo8(4):11-15, SuWarren, “OSHAtion Services foHealth Quarter

Outreach TrainingPromotes

Safety and HealthAwareness

by Don Guerra

Job Safety & Health Quarterly Fall/Winter 1998 39

at do educationalrganizations, unions,SHA state consulta-

ts,1 insurance compa-y and health organiza- government agencies,anies, consultant firms,rganizations, and largeusinesses have in com-y all participate intreach Training Pro-

blic-private partnershipes workplace safety andreness. this voluntary effort, as the train-the-trainerSHA trains private-sec-als in construction anddustry occupational health standards and them to teach other subject matter.

The Office of Training and Edu-cation and its OSHA Training In-stitute (OTI) in Des Plaines, IL,have administered this outreacheffort since the 1970s. The programhas been a highly effective way forOSHA to leverage its training re-sources and reach a large numberof workers. Because of its success,the program has grown rapidly inthe last 7 years. For example, the

einberg, “OSHA Cooperative Deal for Workers and

b Safety & Health Quarterlymmer 1997; and William V. Safety & Health Consulta-r Employers,” Job Safety &ly 2(2):26-29, Winter 1991.

2 The Occupational Safety and Health Act of1970, P.L. 91-596, December 29, 1970; asamended by P.L. 101-552, §3101, Novem-ber 5, 1990.

number of workers trained by au-thorized trainers went from 12,000in 1990 to more than 105,000 in1997—almost an 800 percent in-crease!

In addition, more than 2,100 au-thorized trainers conducted an av-erage of about 115 outreach classesper week last year. The scope of theoutreach training, as illustrated bythe types of participants, is largeand diverse. The program is key forsmall businesses, but also is usedby a significant number of largecompanies. As more employers,workers, and organizations learnabout the program, more decide touse it at their workplaces.

Used to doing more with less,OSHA employs this outreach effortand several other training strategiesto disseminate information onworker and employer rights andresponsibilities under the OSH Act.2

Used to doing morewith less, OSHAemploys this outreacheffort and severalother training strategiesto disseminateinformation on workerand employer rightsand responsibilitiesunder the OSH Act.

40 Job Safety & Health Quarterly Fall/Winter 1998

Outreach team takes a break from discussions on upcoming events. From left to right: Don Guerra, General IndustryOutreach Program Coordinator; Diana Ward, Secretary, Division of Training and Educational Programs; CindyBencheck, Construction Outreach Program Coordinator; and Teresa Angelilli; Secretary, OSHA Training Institute.

The goal, of course, is to improveworkplace safety and health. Thepremise of outreach training is totrain participants from interestedemployer and employee groups toteach selected safety and healthtopics and skills to others. The out-reach trainers, who are qualified toteach OSHA outreach courses, arean occupationally diverse group.Most of the construction trainersare representatives of union andcontractor organizations. GeneralIndustry trainers are usually frombusinesses, educational organiza-tions, and safety and health orga-nizations. Also, a large number ofsafety and health consultants offer

general industry training to smalland large businesses.

Construction and GeneralIndustry Programs

The students who participate inthe Outreach Training Program, bytaking classes taught by authorizedoutreach trainers, represent a broadspectrum of workers across thecountry. The program training inconstruction and general industrystandards3 is held in all 50 states,Puerto Rico, Guam, and severalother international locations.

Since 1994, the number of stu-dents trained in the constructionindustry program has almostdoubled (from 40,600 to 74,600),while the general industry programhas tripled (from 10,300 to 30,900).…the number of workers trained by

authorized trainers went from 12,000 in1990 to more than 105,000 in 1997—almost an 800 percent increase!

3 The construction training deals with Title29 of the Code of Federal Regulations (CFR)Part 1926 and general industry focuses on 29CFR Part 1910.

Job Safety & Health Quarterly Fall/Winter 1998 41

In recent years, the program hasgrown rapidly and significantly.Several factors account for thisgrowth, including the following:• Businesses may save on work-

ers’ compensation insurance bytraining their employees.

• Many employers, especially inconstruction, are requiring work-ers to complete the 10-hourtraining class before working on-site.

• Beginning in 1992, OSHA ap-proved 12 OSHA Training Insti-tute Education Centers to teachthe outreach trainer courses.OSHA is increasing the use ofthe education centers to conductprivate-sector training. Prior tothis, the OSHA Training Institutewas the sole source for outreachtraining. In the past year, the edu-cation centers taught more than200 outreach trainer courses,which represents more than 90percent of the total number oftrainer courses.

• This program has been increas-ingly accepted as a viable sourceof training on a standardizedgroup of OSHA topics.

Program BasicsTo become a trainer, one must

complete Course 500, TrainerCourse in Occupational Safety andHealth Standards for the Construc-tion Industry or Course 501,Trainer Course in OccupationalSafety and Health Standards forGeneral Industry. These coursesrun for 1 week and are availablethrough OTI and the OTI Educa-tion Centers, at least one of whichis located in each of OSHA’s 10regions. Upon completion of eitherthe 500 or 501 course, each partici-pant receives a certificate of coursecompletion and an OSHA outreachprogram trainer card. Outreachtrainers are authorized to conduct

Construction General IndustryIntroduction to OSHA Introduction to OSHAElectrical Walking and Working SurfacesFall Protection ElectricalScaffolding Means of Egress and Fire ProtectionExcavations Machine GuardingCranes, Derricks, and Hoists Hazard CommunicationStairways and Ladders Bloodborne PathogensPersonal Protective Equipment Lockout / TagoutTools - Hand and Power Permit Required Confined SpacesMaterials Handling Recordkeeping

Typical 10-Hour Programs

In the past year, the education centers taughtmore than 200 outreach trainer courses,which represents more than 90 percent of thetotal number of trainer courses.

42 Job Safety & Health Quarterly Fall/Winter 1998

10- and 30-hour construction orgeneral industry courses and areeligible to receive OSHA coursecompletion cards to issue to theirstudents. Last year, the 10-hourcourses accounted for 90 percent ofthe classes held and studentstrained.

Both the construction and gen-eral industry programs have a cur-riculum of required and electivetopics that trainers must follow toearn student course completioncards for the classes they conduct.Required topics account for 50 to75 percent of the class time. Theremaining time is used to meet theneeds of the audience, as long asall topics are based on OSHA stan-dards or policy.

Outreach ProgramStudents Trained120000

100000

80000

60000

40000

20000

0’90 ’91 ’92 ’93 ’94 ’95 ’96 ’97

Outreach trainers have someother guidelines to follow whenconducting classes:• Each course topic is taught for

no less than 1 hour.• Breaks and lunch periods are not

counted towards class time.• Classes must be completed

within a period of 6 months, anddocumentation must be submit-ted within 6 months of the lastclass date.

• Other qualified persons may as-sist in conducting the training, aslong as the outreach trainer re-mains in attendance for over-sight.

• Training must be delivered in-person and onsite. Videotape,computer, and other types oftraining are not permissible. To obtain student course

completion cards for the 10- or 30-hour classes conducted, the out-reach trainer must submit to theOSHA Office of Training and Edu-cation an attendance report withinformation on the course con-ducted, trainer data, and the names

Since 1994, the number of studentstrained in the construction program hasalmost doubled…while the generalindustry program has tripled. . . .

Job Safety & Health Quarterly Fall/Winter 1998 43

and addresses of the students whocompleted the course, the list ofcourse topics and time spent oneach topic, and a short studentevaluation summary. The construc-tion or general industry coordina-tor reviews the documentation, andif all is satisfactory, processes thedocumentation and sends studentcourse completion cards to thetrainer, who then enters the nameof the student, signs and dates thecard, and mails the card to the stu-dent. These cards signify the par-ticipants’ completion of a standard-ized OSHA outreach training classon the basics of OSHA standards.

The student cards do not expire,although many employers scheduleretraining for their employees.Trainers, on the other hand, muststay current on OSHA standardswith special update courses.

Update T rainingRequirement

To help outreach trainers do this,OSHA offers two 3-day courses—

Course 502, Update for Construc-tion Industry Outreach Trainersand Course 503, Update for Gen-eral Industry Outreach Trainers.As of October 1, 1997, trainersmust take a 3-day outreach updateclass every 4 years to maintain theirstatus as authorized Outreach Pro-gram Trainers. Trainers also havethe option of retaking Course 500or 501 to maintain their trainer sta-tus. All persons taking an updatecourse, however, must have previ-ously taken the applicable trainerCourse 500 or 501. As of October1, the OTI Education Centers alsoare conducting the update coursesto help meet the increased demand

Outreach Growth ComparisonStudents Trained80000

70000

60000

50000

40000

20000

30000

10000

0’90 ’91 ’92 ’93 ’94 ’95 ’96 ’97

General Industry

Construction

Through this voluntary effort…OSHA trainsprivate-sector individuals in construction andgeneral industry safety and health standardsand authorizes them to teach other workersthe subject matter.

44 Job Safety & Health Quarterly Fall/Winter 1998

for these courses and to make iteasier for outreach trainers to travelto a nearby location for training.

All trainers authorized since1990 remain in good standing. Thenew update plan requires peoplewho received their last training be-tween 1990 and 1992 to take anupdate course during 1998; thosewho received training between1993 and 1995 to complete suchtraining during 1999; and thosewho received training in 1996 tocomplete such training during2000. Everyone who attended an

Linda Vosburgh, Librarian, organizes Resource Center training materials.

Many companies…use the outreachtraining materials for such activities astoolbox meetings and in-house safetytraining sessions. . . .

outreach class in 1997 or later willbe required to take update training4 years from their last training date.Those who attended their last out-reach training class prior to 1990are no longer authorized trainers.Trainer authorization can be rein-stated by attending another out-reach training class.

Impact of the OutreachProgram

The impact and significance ofthe program and its effect in theworkplace are both broad and di-verse. For example, there has beentraining for firefighters, day labor-ers, contractors, construction work-ers, maintenance workers, vicepresidents, general managers in in-dustries such as plastics manufac-turing, paper milling, chemical pro-cessing, and construction, to namea few.

Many companies, particularlylarger ones, use the outreach train-ing materials for such activities as

Job Safety & Health Quarterly Fall/Winter 1998 45

toolbox meetings and in-housesafety training sessions, but do notrequest student completion cards.These types of training practicesare an outgrowth and an added ben-efit of the OSHA Outreach Pro-gram.

This program will continue togrow as more employers and busi-ness associations require OSHAOutreach Training for their work-ers. The OSHA Office of Trainingand Education will continue tomonitor the program and make ap-propriate changes to ensure that thebest service is provided to programparticipants. The OSHA HomePage (http://www.osha.gov/) on theInternet will be used to maintain acommunication link to the outreachcommunity.

For further information on theprogram and OSHA’s training op-portunities, contact the following:

OSHA Office of Trainingand Education, 1555 Times Drive,Des Plaines, IL 60018, (847)297-4810;

■ Cindy Bencheck, Construc-tion Outreach Program Coordi-nator, extension 126;■ Don Guerra, General IndustryOutreach Program Coordinator,extension 135; and■ Linda Vosburgh, Librarian(Resource Center), OSHA Of-fice of Training and Education,extension 136.National Technical Information

Service, U.S. Department of Com-merce, Springfield, VA 22161;(703) 605-6000, Web site http://www.ntis.gov/.

The OSHA Office of Trainingand Education has two primary di-visions that work on the outreachprogram. The OSHA Training In-stitute, directed by ZigmasSadauskas, conducts the outreachtraining, inputs training informa-tion, distributes the student cards,and makes program decisions.

The Division of Training andEducational Programs, headed byRonald Mouw, provides outreachplanning, policy, and trainer guid-ance; monitors the program; and

The OSHA Office of Trainingand Education

reviews the documentation sent inby outreach trainers. An automatedsystem, which is currently being re-vised, is used to process outreachclasses and maintain trainer files.

In addition, the Division ofTraining and Educational Develop-ment develops the outreach coursecurriculum and two supplementaloutreach trainer guides which areavailable through the NationalTechnical Information Service(NTIS).

The Division of Administrationand Training Information, throughits Resource Center, operates aloan program which allows out-reach trainers and other OSHAgroups to borrow materials forclasses they are conducting. Theoutreach trainers are the principalusers of the Resource Center. Asa result, the use of the ResourceCenter is increasing rapidly. Forexample, in Fiscal Year 1997, thecenter loaned about 2,600 audio-visual materials, which almostdoubled the amount of materialsloaned in the prior fiscal year.

46 Job Safety & Health Quarterly Fall/Winter 1998

■ OSHA Construction OutreachProgram Guide, Order number:AVA19275BB00. Cost is $115plus shipping■ OSHA Voluntary Compliance(General Industry) OutreachProgram Guide, Order number:AVA19915BB00. Cost is $110plus shipping

Don Guerra is a program analystat OSHA’s Office of Training andEducation, Division of Trainingand Educational Programs, DesPlaines, IL.

The author thanks the organiza-tions who contributed theiroutreach experiences for thisarticle.

OSHA Training Institute, US Department of Labor Des Plaines, IL 847-297-4913

Education Centers

Eastern Michigan University / United Auto Workers Ypsilanti, MI 800-932-8689

Georgia Tech Research Institute Atlanta, GA 800-653-3629

Great Lakes OSHA Training Consortium (University of Minnesota, St. Paul, MN 800-493-2060the Minnesota Safety Council, and the University of Cincinnati) Cincinnati, OH

Keene State College Manchester, NH 800-449-6742

Maple Woods OSHA Training Center Kansas City, MO 800-841-7158

National Resource Center for OSHA Training (Building and Washington, DC 800-367-6724Construction Trades Dept. AFL-CIO, West Virginia University Morgantown, WVand the Occupational Health Foundation)

The National Safety Education Center (Northern Illinois University, Chicago, IL area 800-656-5317the Construction Safety Council, and the National Safety Council

Niagara County Community College Lockport, NY 800-280-6742

Red Rocks Community College / Trinidad State Junior College Lakewood, CO 800-933-8394

Texas Engineering Extension Service / Texas Safety Council Mesquite, TX 800-723-3811

University of California - San Diego San Diego, CA 800-358-9206

University of Washington Seattle, WA 800-326-7568

Locations for Outreach Trainer Courses

John Grzywacz, OSHA Training Institute Instructor,reviews course materials.

Job Safety & Health Quarterly Fall/Winter 1998 47

Examples of the Impact and Use of the OSHA Outreach Program

• In Ohio, the outreach trainingis given for state firefighters inconjunction with their requiredannual training.

• At Honda, general industry out-reach training began in 1992,with one OSHA-authorizedoutreach trainer training em-ployees with day-to-day healthand safety responsibilitieswithin the production depart-ments. Since then, OSHA hasauthorized four more trainers,making it possible to providethe 10-hour program in all fourHonda facilities. The targetedaudience has also expanded tomiddle and upper management.To date, 300 associates havecompleted the 10-hour training.Also, in 1995, Honda held a 2-day safety symposium that pri-marily focused on the 10-hourprogram. Nearly 100 automo-tive parts supplier representa-tives completed the training.

• Action Labor, in Florida, is aday laborer employer that pro-vides the 10-hour constructionand general industry classes foreach employee as a way tolower injury and workers’ com-pensation rates. For some of theemployees, who were homelessor unemployed for a long pe-riod, this has been a life- chang-ing experience, providing themwith more permanent job op-portunities.

• In North Carolina, the PhoenixFund provides the outreach classfree to clients for whom theyprovide workers’ compensationinsurance.

• The Pennsylvania NationalGuard has sent 186 first-line su-pervisors through the OSHA 30-hour general industry trainingover the past 5 years. Among theimprovements cited as a result ofthe training, their most hazard-ous worksite has gone over 3years without a lost-workday ac-cident.

• The St. Paul Fire and MarineInsurance Company’s construc-tion division conducts safetytraining for their clients to assistthem in meeting their safetygoals and improving profit mar-gins.

• At Alcoa Davenport Works,Davenport, IA, three changes inthe way contractor safety is ad-ministered were made in March1995: (1) A “Contractor SafetyPractices Manual” was issued toall contractor firms, (2) contrac-tor employees were required toattend a 1-hour interactive safetyorientation video session, and(3) construction contractors wererequired to prove that their work-ers completed the 10-hourOSHA construction outreachcourse. As a result of thesechanges, the recordable injuriesdecreased by 57 percent from

1994 to 1996. Since March1995, more than 2,000 contrac-tor employees have completedthe training.

• In northeast Indiana, Coach-men Industries hosted seven10-hour general industry out-reach classes which were con-ducted by the State of Indianato train workers from the main-tenance staff to vice presidentsand general managers. An in-house trainer gave 12 sessionsof similar training—also affect-ing many different occupa-tions—at Crystal River III, anuclear generating facility.

• At Honeywell Industrial Auto-mation and Control, in OldOcean, TX, all new employeesmust complete a 10-hour out-reach training course beforethey begin working.

• At Shawnee State University inPortsmouth, OH, the 10-hourOSHA General Industry courseis presented as a component ofan Occupational Safety andHealth Management courseseveral times a year. Many ofthe students are employed inplastics manufacturing, papermilling, chemical processing,petroleum refining, and cokeindustries. The completion ofthe 10-hour program has beeninstrumental in several studentsreceiving job offers and em-ployment opportunities.

any of you may remem-ber the movie “Onthe Waterfront” in which

Signingof FinalLongshoringRegulationsby Paul Rossi

Marlon Brando plays a New Yorklongshoreman. That movie was re-leased in 1954, and until this pastJuly, OSHA’s safety and healthregulations for longshoring werealmost as old.

Developed and promulgatedin the late 1950s under theauthority of the Longshoreand Harborworkers Com-pensation Act, these regu-

M On July 18, 1997, Secretary ofLabor Alexis Herman and DeputyAssistant Secretary Greg Watch-man had a signing ceremony for thenew Longshore and Marine Termi-nals standard. With representativesfrom labor and management look-ing on, the Secretary signed the fi-nal Longshore and Marine Termi-nals regulation. She praised thenew rules saying that they will help

Secretary Herman had signed sinceher confirmation.

This effort was a large undertak-ing because it involved reviewingall 10 subparts of the longshoreregulations and related sections ofOSHA’s 1983 marine terminalsrequirements. Any revisions inmarine terminals had to be consis-tent with analogous longshoreregulations.

Longshoring is themarine cargo handlingactivity that takes place

Secretary Herman (seated) signs longshoring rule. From left to right(standing): Deputy Assistant Secretary Greg Watchman; John Faulk, SafetyDirector, S.S.A. Stevedoring; Lindsay McLauglin, International Longshoreand Warehouse Union; John Bowers, Jr., International Longsoremans’Association; and Tom Simmers, Vice President, ITB Corp.

Longshoring is the marine cargo

48 Job Safety & Health Quarterly Fall/Winter 1998

1 Public Law 91-596, December 29, 1970, asamended by P.L. 101-552, §3101, November5, 1990.

lations remained largelyunchanged, even after be-ing adopted in the early1970s by OSHA undersection 6(a) of the Occu-pational Safety and HealthAct of 1970.1 Work prac-tices and hiring practicestoo have dramaticallychanged since the fifties.

prevent fatalities and injuries in themarine cargo handling industry.This was the first regulation that

on a vessel, which caninvolve using thevessel’s cargo gear,climbing in and out ofthe hold of a vessel, andusing gangways. Ma-rine terminals is thecargo handling activitythat takes place on theland next to the vessel,

and it can involve warehouse op-erations, loading and unloadingcontainers, and equipment repair.

handling activity that takes place ona vessel, which can involve usingthe vessel’s cargo gear, climbing inand out of the hold of a vessel, andusing gangways.

Job Safety & Health Quarterly Fall/Winter 1998 49

For example, many technologi-cal changes have taken place in thecargo handling industry that havealso introduced different hazardsinto the workplace. The change thatprobably has had the greatestimpact on the maritime industryhas been the development ofthe intermodal container. Theintermodal container looks similarto the box-like trailer one might seeon the highway, but it is designedto international specifications withspecial fixtures on each corner thatallows it to be lifted from the topor bottom. This allows the samecontainer to be carried by train,truck, or ship. When carried byship, the containers are oftenstacked up to seven high on thedeck. Devices that secure the con-tainers for the ocean voyage mustbe put in between each containerthat is carried onto the deck of thevessel. This requires longshoreworkers to climb on the containersto place and remove those devices.This operation can expose them to

falls of 50 feet or more to a steeldeck below.

The new regulations require, af-ter July 26, 1999, that engineeringcontrols— known in the regulationas positive-container securing de-vices, or PCSDs—be used to elimi-nate the need for workers to go ontop of containers to do this type ofwork. Although PCSDs cannot beused for all types of work, theygreatly reduce exposures to fallhazards in these instances. In thearena of international trade wheremillions of containers are handledevery year, the United States leadsthe world in preventing falls fromthe tops of containers in this way.

To help inform employers aboutthe new longshoring requirements,OSHA has developed an extensiveoutreach program in conjunctionwith the publication of the finalrule. Beginning this past Septem-ber, two teams of OSHA personnelhave been going to maritime portsaround the country to discuss themajor elements of the standard. The

teams include Tom Pope, Area Di-rector, Norfolk, VA; Tom Savage,Compliance Officer, Raleigh, NC;Paul Rossi, Project Officer for theLongshore Final Regulation, Wash-ington, DC; Carl Halgren, Area Di-rector, Portland, OR; Barry Buuck,Compliance Officer, Baton Rouge,LA; and Jim Estep, National Of-fice, Office of the Solicitor,Longshore Regulation Project At-torney, Washington, DC.

The team members conduct a 6-hour overview of the highlights ofthe new regulations. The outreachis hosted by a local maritime en-tity, usually a port authority or portmaritime association. The audiencegenerally consists of OSHA per-sonnel from the regional and areaoffices, members of the unions thatdo cargo handling in the port, rep-resentatives of the local stevedor-ing companies, port authority per-sonnel, OSHA state plan represen-tatives, and representatives fromother government agencies such asthe U.S. Coast Guard.

These outreach sessions havebeen well received, and it is hopedthat this approach can be a modelfor future outreach programs. Todate, there have been sessions inSeattle, WA; Portland, OR; Oak-land and Long Beach, CA; Boston,MA; Newark, NJ; Philadelphia,PA; Baltimore, MD; Charleston,SC; Memphis, TN; Savannah, GA,Miami, FL; Norfolk, VA; Mobile,AL; Chicago, IL (Burns Harbor);Tampa, FL; San Juan, PR; and An-chorage, AL.

For further information on thesesessions, please call the Office ofMaritime Safety Standards at (202)219-7234.

Rossi is an occupational safetyand health specialist in OSHA’sOffice of Maritime Safety Stan-dards, Washington, DC.

OSHA longshoring team members smile for the camera after the signingceremony. From left to right: Larry Liberatore, Director, Maritime Stan-dards; Deputy Assistant Secretary Greg Watchman; Paul Rossi, Office ofMaritime Standards; Jim Estep, Office of the Solicitor; and Paul Bolon,Office of Regulatory Analysis.

50 Job Safe

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Maine 200:One Company’s Stepping

Stone to Starby Susan Hall Fleming

ty & Health Quarterly Fall/Winter 1998

trategy

ord, environmentald safety manager forlectric’s Power Gen-on in Bangor, ME,tly thrilled with hisin Maine 200.1 Be-

the Maine list of com-e highest aggregate

orker compensationardly an honor. That from taking advan-portunity to draw at-rkplace safety and

nefit.titive market, G.E.’scing steam turbineepends on 10-percent

ains each year to sur-f those gains have

provements in work-esulting from partici-ne 200 and movingellence demanded of

participants in OSHA’s Star Volun-tary Protection Program.2

G.E. is not merely surviving. It’sthriving. That’s because the nearly500 employees who work there rel-ish a challenge. OSHA gave themone. And they responded by step-ping from fair to good to stellar.

Getting ThereAlthough surprised to be in-

cluded in Maine 200—until he

looked more closely at plant injurynumbers—Crawford found it justthe vehicle he was looking for tojump-start a structured, organizedsafety and health program. “Thecriteria for Maine 200 melded withwhat I wanted to do....Maine 200became a tool for me to influencethe actions of others in the plant. Iwas able to say, ‘We have to do it—OSHA says so.’”

Crawford soon found that beinginvited to join an OSHA partner-ship was not all bad news. Goingthrough the Maine 200 processchanged both his own perspectiveon OSHA and his company’s rela-tionship with the agency. Today, hecharacterizes that relationship asexcellent.

200 employers in that state with highest number of injuries from workers’ims and offers them a chance to work with OSHA in reducing injuries ando Frank Kane, “OSHA’s Maine 200 Program Receives Prestigious Nationaly & Health Quarterly 7(1):15-16, Fall/Winter 1995. Star program, participants must have excellent workplace safety and healthlow-average injury rates for their industry. See also cover story in this issue;aro and Judith Weinberg, “Answers to Some Frequently Asked Questions on Health Quarterly 5(4):22-25, Summer 1994; Kerri L. Lawrence,

ion Programs Praised for Accomplishments,” Job Safety & Health19, Fall/Winter 1995.

“The criteria for Maine 200 melded withwhat I wanted to do....Maine 200 becamea tool for me to influence the actions ofothers in the plant. I was able to say, ‘Wehave to do it—OSHA says so.’”

Jim Crawford, GE Environmental Health and Safety Manager

Job Safety & Health Quarterly Fall/Winter 1998 51

GE Bangor Plant Core Safety Team raises VPP flag at their Star site. From left to right: Jerry King, Jean Malo,Bill Pearsall, Skip Pierce, Tom Sawyers, Al Crowley, Jim Crawford, Steve Graebert, and Sue Hart.

“Companies havefound that theydon’t want to stopimproving whenthey reach theminimum level ofacceptability. Theywant to keepmoving forward toreach excellence.”

Bill Freeman, OSHA AreaDirector, Bangor, ME

Typical safety issues at G.E.’sPower Generation Division includemachine guarding, electrical haz-ards, forklift truck operation, andcrane and sling handling. Healthhazards include metal fumes, oilmist, noise, dust, and organic sol-vents. G.E. Power Generation alsoneeded to deal with lifting hazardsand repetitive stress injuries.

Crawford found the plant notonly ready to meet the challengeposed by OSHA, but also eager todo better than OSHA expected. Ayear before the plant “graduated”from Maine 200, the facility com-mitted itself to attaining recognitionas a Star site under OSHA’s Vol-untary Protection Programs (VPP).

“We were making good progressin accomplishing our Maine 200goals, but we weren’t good enough.We needed a continuing process tokeep us from backsliding. The VPPcriteria were similar to Maine200—you just had to be a lot bet-

ter at achieving them,” Crawfordsays.

“By the time we graduated fromMaine 200, we had our applicationfor VPP ready. We got our gradua-tion letter from Maine and the nextday sent our VPP application letterto OSHA’s Region I Office in Bos-ton,” he adds.

The Power Generation Divisionbecame a Star site in April 1997, ayear after its graduation fromMaine 200. Its injury incidencerates are 45 percent below the in-dustry average for machine shopsand its lost-workday injury rate is74 percent below industry average.It is the 10th General Electric siteto join the program.

Although the Power GenerationDivision may be the first to take thisstep, others are following close be-hind. “We actually have a numberof Maine 200 graduates in the pipe-line seeking recognition underVPP,” notes Bill Freeman, Area

52 Job Safety & Health Quarterly Fall/Winter 1998

The difference between a pretty goodsafety and health program and a reallyoutstanding one is often thecommitment of employees. Gettingemployee buy-in and ongoinginvolvement is essential.

Director of OSHA’s Bangor, ME,office. “Companies have found thatthey don’t want to stop improvingwhen they reach the minimum levelof acceptability. They want to keepmoving forward to reach excel-lence.”

“Reaching for VPP recognitionis a logical next step for a companycommitted to employee safety andhealth,” says Cathy Oliver, direc-tor of the program. “They’ve donethe hard work of setting up a goodsafety and health program. Nowthey’re ready to capitalize on theirefforts.”

Employees Makethe Difference

The difference between a prettygood safety and health program anda really outstanding one is often thecommitment of employees. Gettingemployee buy-in and ongoing in-volvement is essential.

“From the beginning, I feltstrongly that employee involve-ment in safety was critical. I triedas environmental health and safetymanager to write procedures andimpose them on the plant. It justdoesn’t work. Employees have nopersonal stake in it. People mustwant safety for themselves andmust do it themselves. Every em-ployee in the plant needs to betrained in certain safe work prac-tices,” Crawford believes.

G.E. involves their employees atthree different levels. On an indi-vidual level, each employee serveson a rotating stint as weekly safetyauditor for his or her area of theplant about every 5 or 6 weeks.Every Monday the auditors of theweek meet with the area safetyteam to watch a video that offers abrief refresher on the auditor’s roleand the 64-item list they will usein their audits. All three shifts au-dit the worksite.

With four business areas, thePower Generation Division alsoruns four area safety teams—againon all three shifts. Composed ofvolunteers, each of these teams hasreceived in-depth training onOSHA standards and plant pro-cesses. Every member has his orher own copy of the OSHA gen-eral industry standards and knowshow to find information in thebook. The safety teams conducthigher level audits, investigate in-juries or near misses, and imple-ment corrective action. Area safetyteams have set up complaint pro-cedures with forms that employeescan submit, anonymously if theywish, to the team, to management,or to the health and safety director.

G.E. also has a core safety teamthat functions facilitywide. Thisteam includes several membersfrom each of the area teams. Meet-ing once a week, the core team de-velops overall plant procedures.Members share “best practices”

Maine 200 is a partnership pro-gram to help companies with thehighest number of worker injurycompensation claims reduceworkplace hazards and relatedinjuries. The program beganin 1992 in Maine with OSHAidentifying the top 200 companiesin the state with largest numberof worker injury compensationclaims. OSHA offered eachemployer the choice of work-ing with the agency to identifyand correct worksite hazardsand implement comprehensivesafety and health programs tocarry out the effort, or face tradi-tional enforcement inspection.Nearly all firms chose to enter intopartnership with OSHA.

The State of Maine became thefirst pilot because, in 1990, itsworker injury and illness inci-dence rate was 63-percent higherthan the national average, and in-juries from lost-work time were71 percent higher than the rest ofthe nation. In Maine, prior to thetargeting program, the traditionalOSHA inspection method hadidentified approximately 37,000hazards at 1,316 workplaces. Inthe first 18 months under theMaine 200 program, the numbersnearly tripled. Of 95,800 work-place hazards identified, 55,200were abated.

Job Safety & Health Quarterly Fall/Winter 1998 53

A successfulsafety program isnot accidental. Ittakes effort andplanning. Theprod of an OSHApartnershipprogram can helpemployers take thefirst step towardexcellence.

OSHA’s Voluntary ProtectionPrograms are cooperative effortsamong labor, management, andgovernment. Acceptance into theVPP requires worksites to havesafety and health programs ex-ceeding OSHA’s standards. Sitesparticipating in the VPP havelost-workday rates 40 to 80 per-cent below their industry aver-ages.

The three programs compris-ing VPP—Star, Merit, and Dem-onstration—recognize outstand-ing achievements by companiesthat successfully integrate acomprehensive safety and healthprogram into their total manage-ment system. Star, the highestprogram level, recognizesworksites with outstandingsafety and health protection foremployees. Merit is a steppingstone to Star for worksites com-mitted to providing the bestworker protection and willing tomeet established safety andhealth progtram managementgoals. Demonstration allowsworksites to pilot cutting-edgeworker protection strategies notaddressed in Star.

About 360 U.S. worksites cur-rently are VPP Federal and Stateparticipants.

For more information on VPP,see Programs and Services onOSHA’s Web site at http://www.osha.gov/ or write to theU.S. Department of Labor, Oc-cupational Safety and HealthAdministration, Office of Fed-eral-State Operations, 200 Con-stitution Avenue, N.W., RoomN-3700, Washington, DC 20210.

from their areas, which then maybe adopted plantwide. The plantsafety and health team, which hasreceived the highest level of train-ing, conducts even more detailedaudits.

Tackling ErgonomicsFor its Maine 200 effort on er-

gonomics, G.E. initially chose aslightly different tack. Again fo-cusing on employee involvement,the facility brought in a consultantto train a team of 19 employees toassess work stations. The consult-ant helped the team to identifystressors and possible solutions.

Once trained, ergo team mem-bers go to work stations, videotapeworkers, get their comments, andthen study the information to lookfor risk factors they’d been trainedto recognize. After pinpointing therisk factors, they develop correc-tive actions. Recently, the areasafety teams decided to merge er-gonomics into the safety programso 62 safety team members wentthrough 2 days of ergonomics train-ing conducted by the initial ergo-nomics team and then began con-ducting their own work station as-sessments.

Sometimes success has comesimply by approaching a task witha different mindset. For manyyears, operators at one of the oldermachines in the plant had to secureeach workpiece to the machinewith a heavy slide hammer. “Work-ers had to bang the slide hammeronto the machine and then bang itoff again,” Crawford says. Theminute workers at that station wereeligible for a transfer to anothermachine within the plant, they tookit. Until the ergonomics team re-viewed the situation, no one hadever paid attention to the turnover.The ergonomics team replaced theslide hammer with a hydraulic sys-tem reducing wear and tear on the

operator and noise as well. Nowtransfers are no longer sought or arenecessary.

In another case, ergonomicsteam members responded to a com-plaint of elbow pain from a workerwho was holding a small part in onehand and filing a metal burr off thepart with the other hand. The teamsaw to it that a soft abrasive wheelwas installed to replace the handfiling process for all the workersdoing this task. Workers now reportthey’re not so tired at the end ofthe day. Plus, the new system hasboosted productivity as well.

A successful safety program isnot accidental. It takes effort andplanning. The prod of an OSHApartnership program can help em-ployers take the first step towardexcellence. G.E. took the unwel-come opportunity to participate inthe Maine 200 partnership andturned it to its own advantage, im-proving productivity and workersatisfaction at the same time. To-day G.E. is a willing and welcomepartner with OSHA—by its ownchoice—as part of the VPP.

Fleming is a public affairs spe-cialist in OSHA’s Office of PublicAffairs, Washington, DC.

54

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wein llowweconcotwewomechowasucof heapro

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54

Winter Advisory:Preventing Cold Stress

Job Safety & Health Quarterly Fall/Winter 1998

hen your body tempera-ture drops even a fewdegrees below normal

ich is about 98.6°F) you canin to shiver uncontrollably, be-e weak, drowsy, disoriented,

onscious, even fatally ill. Thiss of body heat is known as “coldss” or hypothermia. People who

rk outdoors or who enjoy out-r activities should learn about to protect against loss of bodyt. The following guidelines can

p you keep your body warm andid the dangerous consequencesypothermia.

ss in Layersutdoors, indoors, in mild

ather or in cold, it pays to dressayers. Layering your clothes al-s you to adjust what you’rearing to suit the temperatureditions. In cold weather, wearton, polypropylene, or light-ight wool next to the skin, andol layers over your undergar-nts. For outdoor activities,ose outer garments made of

terproof, wind-resistant fabricsh as nylon. Because a great dealbody heat is lost through thed, always wear a hat for addedtection.

Keep DryWater chills your body far more

rapidly than air or wind. Even inthe heat of summer, falling into alake with a water temperature of40°F can be fatal in a matter of min-utes. Always take along a dry setof clothing whenever you are work-ing (or playing) outdoors. Wear wa-terproof boots in damp or snowyweather, and always pack rain geareven if the forecast calls for sunnyskies.

Take a CompanionThe effects of hypothermia can

be gradual and often go unnoticeduntil it’s too late. If you know you’llbe outdoors for an extended periodof time, take along a companion,or let someone know where you’llbe and at what time you expect toreturn.

Symptoms and StagesAs body temperature drops,

symptoms go through stages. In thefirst stage, dexterity may be dimin-ished, so that individuals may findit difficult to do things like light amatch, tie a knot, or button cloth-ing. Next, speech becomes slurred.Victims may stumble, seem con-fused, or deny that they are cold or

need medical attention. They mayseem weak or tired. At this point,shivering may stop. Breathing maybe shallow and the pulse hard tofind. As the body gets colder,muscles become stiff and the heart-beat becomes uneven. Uncon-sciousness sets in. Death can resultif breathing or the heart stops.

First-Aid FastEven if you only suspect hypo-

thermia, call an ambulance or doc-tor right away. It may be a life-or-death call. Then, use first aid, whichcan save the victim’s life. Take thevictim to a warm place. If that’simpossible, shelter from any wind,rain, or snow and keep the headcovered. Remove all wet clothingand bundle with dry blankets ordress in dry clothing. Do not rubor massage the victim or place thevictim in hot water. If the person isconscious give warm beverages,but no alcohol or caffeine. If thevictim is unconscious, use artificialrespiration or CPR if you aretrained in this life-saving techniqueuntil professional help arrives.

Information derived from U.S. Departmentof Labor Safety and Health BulletinNo. 97-2.

Job Safety & Health Quarterly Fall/Winter 1998

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THE TOOLBOX

Job Safety & Health Quarterly Fall/Winter 1998 55

RuleReinforcing steel. All protruding

reinforcing steel—onto and intowhich employees could fall— shallbe guarded to eliminate the hazardof impalement.

IntentConversations with construction

personnel frequently include ac-counts of situations where an em-ployee has fallen and impaled him-self on a piece of steel rebar. Theseaccounts are some of the most grue-some stories related to accidents inthe construction industry.

This rule requires guarding forthe ends of the rebar where the po-tential for impalement exists. Thetwo most common guarding tech-niques are (1) specially manufac-tured rebar caps that fit on top ofthe rebar; or (2) lumber is securedon top of the rebar. The theory is todissipate the force of the fall by dis-tributing it over a larger area thanthe diameter of the rebar—i.e, lessforce reduces the chance of impale-ment.

HazardsImpalement/puncture. Resulting

injuries can range from serious in-ternal injuries to death.

Guarding of Protruding Steel Rebars1926.701(b)Rank in Frequency Cited: #14*

■■ VIOLATION

■■ IN COMPLIANCERebar caps which are acceptable as meeting OSHA requirements.

■■ VIOLA TION

■■ IN COMPLIANCEThe arrows show 3 rebars without protective caps which create a hazard.

* Derived from OSHA’s publication, The 100Most Frequently Cited OSHA ConstructionStandards in 1991: A Guide for the Abatementof the Top 25 Associated Physical Hazards,Washington, DC, February 1993. This publi-cation is available from the U.S. GovernmentPrinting Office, Washington, DC 20402.Order Number 029-016-00145-0; Cost $5.50;(202) 512-1800 phone or (202) 512-2250 fax.

56 Job Safety & Health Quarterly Fall/Winter 1998

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(Among Other) SuggestedAbatements

Prior to installing rebar at thesite, ensure that enough rebar capsor materials to construct caps willbe available.

Selected Case HistoriesAn employee pulling a concrete

hose along a form fell two storiesand hit his head on steel bars, punc-turing his brain.

A laborer fell approximately8 feet through a roof opening to apatio foundation that had about 20

half-inch rebars protruding straightup. The laborer was impaled by oneof the bars and died.

Comments(1) This is another example of a

specification standard which iseasy to identify and substantiate;it’s either in place or it’s not. Eventhough exposed vertical rebarwould not be present at manyOSHA construction inspections,this situation is being cited very fre-quently as evident by its #14 rank-ing on the Most Cited Physical

Hazards List. This may be an indi-cator of the lack of industrywidecompliance.

(2) This standard was cited in 12fatality investigations.

Additional Documents toAid in Compliance

Title 29 Code of Federal Regu-lations, Part 1926, Subpart Q; Con-crete and Masonry Constructionfinal rule; American National Stan-dards Institute (ANSI) A10.9-1983Concrete and Masonry Work SafetyRequirements.

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FATALFACTS

Job Safety & Health Quarterly Fall/Winter 1998 57

Accident ReportFrom the U.S. Department of LaborOccupational Safety and Health Administration FatalFacts No. 62

Brief Descriptionof Accident

Two connectors were erectinglightweight steel “I” beams on thethird floor of a 12-story building,54 feet above the ground. One em-ployee removed a choker slingfrom a beam and then attempted toplace the sling onto a lower emptyhook on a series of stringers. Whilethe crawler tower crane was boom-ing away from the steel, the windmoved the load line and stringerinto the beam the employee wasstanding on. The beam movedwhile the employee was trying todisengage the hook and fell to hisdeath.

Accident SummaryAccident Type Fall

Weather Clear,Windy

Type of Operation StructuralSteelErector

Crew Size 23

Competent SafetyMonitor Onsite? Yes

Safety and HealthProgram in Effect? Yes

Was the WorksiteInspected Regularlyby the Employer? Yes

Training andEducation Provided? Yes

Employee Job Title IronWorker

Age/Sex 37/Male

Experience atthis Type Work 10 Years

Time on Project 4 Days

Inspection ResultsFollowing the inspection, OSHA

cited the company for three seriousviolations of OSHA standards. Hadthe company followed applicableOSHA construction requirements,this fatality might have been pre-vented.

Accident PreventionRecommendations

(1) On tiered buildings or struc-tures that cannot accommodatetemporary flooring and where scaf-folds are not used, install and main-tain safety nets if employees areworking more than two stories or25 feet above the ground [Title 29Code of Federal Regulations Part1926.750(b)(1)(ii)].

(2) Use tag lines to control craneloads hoisted during structural steelassembly [29 CFR 1926.751(d)].

(3) During the faint placing ofsolid web structural members, se-cure all members with at least twobolts or the equivalent at each con-nection. The bolts must be drawnup wrench tight before the load isreleased from the hoisting line [29CFR 1926.751(a)].

Sources of Help• For information on OSHA-

funded free consultation ser-vices, call the nearest OSHA areaoffice listed in telephone direc-tories under U.S. Labor Depart-ment or under the state govern-ment section in states adminis-tering their own OSHA pro-grams. See also OSHA’s Website at http://www.osha.gov/.

• OSHA Safety and Health Train-ing Guidelines for ConstructionAvailable from the National

Technical Information Service,5285 Port Royal Road, Spring-field, VA 22161; Phone (703)605-6000 or (800) 553-6847;Order No. PB-239-312/AS, $27,to help construction employeesestablish a training program.

• Courses in construction safetyare offered by the OSHA Train-ing Institute, 1555 Times Drive,Des Plaines, IL 60018; phone(847) 297-4913.

Note: The case described here is representa-tive of fatalities caused by improper workpractices. No special emphasis or priority isimplied nor is the case necessarily a recentoccurrence. The legal aspects of the incidenthave been resolved and the case is nowclosed. Your company or workplace iseligible to receive one free copy of thisleaflet, which you may duplicate and sharewith your coworkers. To be placed on thedistribution list, send a self-addressed label(using four or fewer lines) with your titleand address to FatalFacts, OSHA, RoomN-3647, 200 Constitution Avenue, N.W.,Washington, DC 20210. This informationwill be made available to sensory impairedindividuals upon request. Voice phone:(202) 219-8151. TDD message referralphone: (800) 326-2577.

58 Job Safety & Health Quarterly Fall/Winter 1998

FATALFACTS

Accident ReportFrom the U.S. Department of LaborOccupational Safety and Health AdministrationFatalFacts No. 64

Accident SummaryAccident Type Fall

Weather Good

Type of Operation Demolition

Crew Size 5

Competent SafetyMonitor Onsite? No

Safety and HealthProgram in Effect? Yes

Was the WorksiteInspected Regularlyby the Employer? No

Training andEducation Provided? Inadequate

Employee Job Title Laborer

Age/Sex 30/Male

Experience at thisThis Type Work 9 Days

Time on Project 3 Days

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Brief Descriptionof Accident

An employee was working on ascaffold near the top of a 250-footsmoke stack when a section of con-crete being removed fell onto thescaffold, knocking the employeeoff. The employee was not tied offwith a safety belt and lanyard andfell to the ground below.

Inspection ResultsAs a result of its investigation of

the accident, OSHA issued cita-tions alleging two willful and sev-eral serious violations. OSHA’sconstruction standards include re-quirements which, if they had beenfollowed here, might have pre-vented this fatality.

Accident PreventionRecommendations

(1) The employermust install standardguardrails (toprail,midrail, and toeboards)on all open sides and endsof the bracket scaffoldaround the top of the smokestack [Title 29 Code of FederalRegulations Part 1926.451(a)(4)].

(2) The employer must providetraining to inform employeesof potential hazards while work-ing on the scaffold [29 CFR1926.21(b)(2)].

(3) The employer must providea positive procedure to ensure thatconcrete sections fall inside, in-stead of outside, the smoke stack.[Section 5(a)(1) of the Occupa-tional Safety & Health Act of 1970(P.L. 91-596)].

Sources of Help• Title 29 Code of Federal Regu-

lations (CFR) Part 1926—OSHA construction standards.Revised 7/1/97. Order No. 869-032-00106-5 ($38.50). Availablefrom the Superintendent ofDocuments, Government Print-ing Office, Washington, DC20402-9325; phone (202) 512-1800. You may use a GPO de-posit account, Visa, MasterCard,or a check made payable to Su-perintendent of Documents.

• For information on OSHA-funded free consultation ser-vices, call the nearest OSHA areaoffice listed in telephone direc-tories under U.S. Labor Depart-

ment or under the state govern-ment section in states adminis-tering their own OSHA pro-grams. See also OSHA’s Website at http://www.osha.gov/.

• OSHA Safety and Health Train-ing Guidelines for Constructionto help construction employersestablish a training program.Available from the NationalTechnical Information Service,5285 Port Royal Road, Spring-field, VA 22161; phone (703)605-6000 or (800) 553-6847;Order No. PB-239-312/AS, $27.

Note: The case described here is representa-tive of fatalities caused by improper workpractices. No special emphasis or priority isimplied nor is the case necessarily a recentoccurrence. The legal aspects of the incidenthave been resolved and the case is nowclosed. Your company or workplace iseligible to receive one free copy of thisleaflet, which you may duplicate and sharewith your coworkers. To be placed on thedistribution list, send a self-addressed label(using four or fewer lines) with your titleand address to FatalFacts, OSHA, RoomN-3647, 200 Constitution Avenue, N.W.,Washington, DC 20210. This informationwill be made available to sensory impairedindividuals upon request. Voice phone:(202) 219-8151. TDD message referralphone: (800) 326-2577.

Job Safety & Health Quarterly Fall/Winter 1998 59

FATALFACTS

Accident ReportFrom the U.S. Department of LaborOccupational Safety and Health Administration FatalFacts No. 69

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Accident SummaryAccident Type Death due

to burns

Weather Unknown

Type of ExcavatingOperation for building

a road

Crew Size 2

Competent Person Noon Site?

Safety and Health NoProgram in Effect?

Was the Worksite NoInspected Regularlyby the Employer?

Training and NoEducation Provided?

Employee Job Title BulldozerOperator

Age/Sex 44/Male

Experience at 15 YearsThis Type Work

Time on Project 2 days

Brief Descriptionof Accident

A bulldozer operator was prepar-ing a road bed by using the machineto lift trees out of the way. A hy-draulic line to the right front hy-draulic cylinder ruptured, sprayinghydraulic fluid onto the enginemanifold and into the operator’scompartment. Upon contact withthe hot manifold, the hydraulicfluid ignited, engulfing the opera-tor in flames. The operator diedfrom the burns he received.

Inspection ResultsFollowing an inspection, OSHA

issued citations for two serious vio-lations of OSHA standards:

(1) Frequent and regular inspec-tions of equipment were not madeby competent persons designated

by the employer in accordance with29 Code of Federal Regulations(CFR) 1926.20(b)(2). It was deter-mined that the hydraulic hose hadbeen installed backward so that abend in the fitting connection madecontact with the body of the bull-dozer, resulting in wear and abra-sion of the hose at the connection.This was not discovered during in-spection of the machine.

(2) The employees doing inspec-tions were not instructed to exam-ine the hoses for signs of wear andabrasion as required by 29 CFR1926.21(b)(2).

Accident PreventionRecommendations

(1) Train maintenance and oper-ating personnel to recognize poten-tial problems with the operation ofthe machinery.

(2) Have competent persons per-form periodic inspections of all op-erating equipment.

(3) Ensure that the employer ini-tiates and maintains a safety andhealth program, in accordance with29 CFR 1926.20(b)(1).

Sources of Help• OSHA Construction Standards

[29 CFR Part 1926], which in-clude all OSHA job safety andhealth rules and regulations cov-ering construction, may be pur-chased from the GovernmentPrinting Office, phone (202) 512-1800, fax (202) 512-2250, OrderNo. S/N 869-032-00107-3; $40.

• OSHA-funded free consultationservices listed in telephone direc-tories under U.S. Labor Depart-ment or under the state govern-ment section where states admin-ister their own OSHA programs.

• OSHA Safety and Health Train-ing Guidelines for Construction,Volume III (Available from theNational Technical InformationService, 5285 Port Royal road,Springfield, VA 22161; phone(703) 605-6000 or (800) 553-6847; Order No. PB-239-312/AS, $27) to help constructionemployers establish a trainingprogram.

• Courses in construction safetyare offered by the OSHA Train-ing Institute, 1555 Times Drive,Des Plaines, IL 60018, (847)297-4913.

• OSHA regulations, documentsand technical information alsoare available on CD-ROM,which may be purchased fromthe Government Printing Office,phone (202) 512-1800 or fax(202) 512-2250, Order No. S/N729-13-00000-5; cost $38 annu-ally; $15 quarterly. The informa-tion also is on the InternetWorld Wide Web at http://www.osha.gov./

Note: The case described was selected asbeing representative of fatalities caused byimproper work practices. No specialemphasis or priority is implied nor is the casenecessarily a recent occurrence. The legalaspects of the incident have been resolved,and the case is now closed. Your company orworkplace is eligible to receive one free copyof this leaflet which you may duplicate andshare with your co-workers. To be placed onthe distribution list, send a self-addressedlabel (using four or fewer lines) with yourtitle and address to FatalFacts, OSHA,Room N-3647, 200 Constitution Avenue,N.W., Washington, DC 20210.

60 Job Safety & Health Quarterly Fall/Winter 1998

FATALFACTS

Accident ReportFrom the U.S. Department of LaborOccupational Safety and Health Administration FatalFacts No. 71

Accident SummaryAccident Type Crushing

Weather Fair/cold

Type of DemolitionOperation

Crew Size 3

Competent Person Unknownon Site?

Safety and Health InadequateProgram in Effect?

Was the Worksite NoInspected Regularlyby the Employer?

Training and InadequateEducation Provided?

Employee Job Title Laborer

Age/Sex 50/Male

Experience at 2 1/2This Type Work months

Time on Project 7 hours

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Brief Descriptionof Accident

Three employees were disman-tling an old refinery. As two of theworkers used torches to cut awayat the side of an old steel box, thethird worker picked up scrap on theother side of the box. Suddenly,that side of the box toppled overbecause the removal of materialcaused a reduction in stability.When the two cutters realized thattheir co-worker was missing, theylooked under the toppled sectionand found him trapped below. Hedied of massive chest injuries.

Inspection ResultsAs a result of its investigation,

OSHA issued citations for four se-rious, one repeat, and four other-than-serious violations of OSHAstandards. Had the workers beenadequately trained and the opera-

tion adequately planned, this fatal-ity might have been prevented.

Accident PreventionRecommendations

The employer must:(1) Train employees in rec-

ognition and avoidance of un-safe conditions and the regula-tions applicable to their workenvironment, in accordance with 29Code of Federal Regulations (CFR)1926.21(b)(2).

(2) Ensure that a competent per-son is designated to frequently andregularly inspect job sites, materi-als, and equipment, in accordancewith 29 CFR 1926.20(b)(2).

(3) Ensure that employees areprotected from struck-by hazards;using barriers, in accordance with29 CFR 1926.95(a) or, at a mini-mum, signs to prevent entry, in ac-cordance with 29 CFR 1926.200.

Sources of Help• OSHA Construction Standards

[29 CFR Part 1926], which in-clude all OSHA job safety andhealth rules and regulations cov-ering construction, may be pur-chased from the GovernmentPrinting Office, phone (202) 512-1800, fax (202) 512-2250, OrderNo. S/N 869-032-00107-3; $40.

• OSHA-funded free consultationservices listed in telephone direc-tories under U.S. Labor Depart-ment or under the state govern-ment section where states admin-ister their own OSHA programs.

• OSHA Safety and Health Train-ing Guidelines for Construction,Volume III (Available from theNational Technical InformationService, 5285 Port Royal road,Springfield, VA 22161; phone

(703) 605-6000 or (800) 553-6847; Order No. PB-239-312/AS, $27) to help constructionemployers establish a trainingprogram.

• Courses in construction safetyare offered by the OSHA Train-ing Institute, 1555 Times Drive,Des Plaines, IL 60018, (847)297-4913.

• OSHA regulations, documentsand technical information alsoare available on CD-ROM,which may be purchased fromthe Government Printing Office,phone (202) 512-1800 or fax(202) 512-2250, Order No. S/N729-13-00000-5; cost $38 annu-ally; $15 quarterly. The informa-tion also is on the InternetWorld Wide Web at http://www.osha.gov./

Note: The case described was selected asbeing representative of fatalities caused byimproper work practices. No specialemphasis or priority is implied nor is the casenecessarily a recent occcurrence. The legalaspects of the incident have been resolved,and the case is now closed. Your company orworkplace is eligible to receive one free copyof this leaflet which you may duplicate andshare with your co-workers. To be placed onthe distribution list, send a self-addressedlabel (using four or fewer lines) with yourtitle and address to FatalFacts, OSHA,Room N-3647, 200 Constitution Avenue,N.W., Washington, DC 20210.

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U.S. Department of LaborOccupational Safety and Health Administration