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Personal Protective Equipment: Not the First Choice in Controlling Hazards

Posted: Nov 22, 2014

Renee Witherspoon, MS, CSP, CIH, CHMM, TWUA Safety Committee Chair and ASSE South Plains Chapter President

I had the opportunity to participate in the Special Topics Class at the 66th Annual West Texas Regional School in Lubbock in November 2014. Chairman Neil Weems, Cesar Castanon and their entire committee did a tremendous job in organizing this event.  The Special Topics class was divided into short 1-hour presentations with multiple speakers and varied topics from confined space and direct potable reuse to UV disinfection and water well rehab.

My presentation was on personal protective equipment or PPE.  Since most are familiar with the use of PPE, participants in the class were not as familiar with the actual content of the OSHA standard and the use of PPE may not be the first choice when controlling a hazard. Read More

Sleep Deprivation Can Affect Safety

Posted: Aug 22, 2014

By Renee Witherspoon, MS, CSP, CIH, CHMM, South Plains Chapter President

Many of us know that we need to get an adequate amount of sleep every night but how many of us actually do? Work, school, or family responsibilities can cause stress throughout our day so that we end up missing sleep. And many would say that sleep is just “down time” when the body rests, but in reality, it is so much more than that and can have a huge impact on safety and our day-to-day lives.

Consequences of Sleep Deprivation

Shift workers or people having to work a “graveyard shift” are often tired and sleepy because of their work schedule. If workers are overly tired then concentration on their work can be difficult. There is also the possibility of decreased reaction times, increased moodiness, and impaired judgment. All which can lead to the possibilities of accidents.

Sleep deprivation and fatigue has been shown to have serious consequences and be the root cause of some of the largest disasters in recent history including the nuclear accident at Three Mile Island in 1979, the Exxon Valdez oil spill in 1989, the nuclear meltdown at Chernobyl in 1986 and recently in 2013, a commuter train derailed killing four people because the train engineer had fallen asleep at the controls when the train was going 82 mph into a 30 mph curve. Reports stated that he had navigated the route many times but was on the early shift only a few weeks.

Sleep deprivation can also affect our daily lives. Besides the increased risk of occupational injury, studies have shown that sleep deprivation and fatigue can have dramatic effects on personal health including:

  • Decreased Performance and Alertness: Reducing nighttime sleep by as little as one and a half hours for just one night could result in a reduction of daytime alertness by as much as 32%.
  • Memory and Cognitive Impairment: Decreased alertness and excessive daytime sleepiness impair memory and your ability to think and process information.
  • Stress Relationships: Disruption of a bed partner’s sleep due to a sleep disorder may cause significant problems for the relationship (for example, separate bedrooms, conflicts, moodiness, etc.).
  • Poor Quality of Life: As an example, being unable to participate in certain activities that require sustained attention, like going to the movies, attending your child’s school event, or watching a favorite TV show.
  • Automobile Injury: The National Highway Traffic Safety Administration (NHTSA) estimates that each year drowsy driving is responsible for at least 100,000 automobile crashes, 71,000 injuries, and 1,550 fatalities.

There is no questioning the importance of getting enough sleep. But the lack of awareness of sleep deprivation is an important safety topic that is seldom discussed in meetings but needs to be. As mentioned, sleep deprivation can increase the danger in the workplace but many workers suffering from it are not even aware of the risks. They may think they are functioning well enough but they are susceptible to falling into a potentially deadly form of sleep, called “microsleep.”

Microsleep is brief, unintended episodes of loss of attention associated with events such as blank stare, head snapping, and prolonged eye closure which may occur when a person is fatigued but trying to stay awake to perform a monotonous task like driving a vehicle or watching a computer screen. If you’ve ever driven somewhere and not remembered part of the trip, you may have experienced microsleep. One wrong move or lack of attention or alertness can cause a serious accident. So it is important that we in the safety community recognize the warning signs of sleep deprivation so that we can prevent accidents.

Warning Signs of Sleep Deprivation

The following are the warning signs to watch for if you are not getting enough sleep:

  • You’re more impulsive.
  • You’re forgetful.
  • You’re hungrier.
  • You’re clumsier.
  • You’re arguing more with your significant other.

If you find that you are sleep deprived—­you know what to do.

Recommendations For Getting a Good Night’s Sleep

Sleep requirements vary across the age groups but according to the National Sleep Foundation, adults require 7-9 hours of sleep per night. Senior adults tend to sleep more lightly and may wake up more often during the night because they may have more medical problems, which affect quality sleep and can lead to daytime napping.

Like eating well and being physically fit, getting a good night’s sleep is important to your well-being. Here are some tips:

  • Avoid caffeine and nicotine. The stimulating effects of caffeine in coffee, colas, teas, and chocolate can take as long as 8 hours to wear off fully. Nicotine is also a stimulant.
  • Stick to a sleep schedule. Go to bed and wake up at the same time each day—even on the weekends.
  • Exercise is great but not too late in the day. Avoid exercising closer than 5 or 6 hours before bedtime.
  • Avoid alcoholic drinks before bed. A “nightcap” might help you get to sleep, but alcohol keeps you in the lighter stages of sleep. You also tend to wake up in the middle of the night when the sedating effects have worn off.
  • Avoid large meals and beverages late at night. A large meal can cause indigestion that may interfere with sleep. Drinking too many fluids at night can cause you to awaken frequently to run to the bathroom.
  • Avoid medicines that delay or disrupt your sleep, if possible. Some commonly prescribed heart, blood pressure, or asthma medications, as well as some over-the-counter and herbal remedies for coughs, colds, or allergies, can disrupt sleep patterns.

Conclusion

Sleep will always be important for overall health and wellness and studies have shown that having a good night’s sleep improves memory, alertness, decreases stress, and the risk of accidents on the job. Lack of sleep can even affect even our interpretation of events. This will affect our ability to make sound judgments because we may not assess potentially dangerous situations accurately and act on them correctly.

These positive health benefits equate to employees being happier, safer, and more productive. The challenge is to get employees to realize the importance of getting enough sleep and how getting an adequate amount of sleep can have a positive impact not only in their lives but in the lives of those around them.

Happy sleeping.

 

References:

  • Breus, Michael.  Sleep Habits:  More Important Than You Think:  Chronic Sleep Deprivation May Harm Health, WebMD.  Accessed 8/7/14.
  • Harris, Phil.  “Warning Signs that you’re Not Getting Enough Sleep”, K104.7FM.  Accessed 7/9/14.
  • How Much Sleep Do We Really Need? National Sleep Foundation. Accessed 7/9/14.
  • Why is Sleep Important? National Heart, Lunch and Blood Institute, US Dept. Of Health & Human Services. Accessed 7/9/14.
  • Your Guide to Healthy Sleep.  NHLBI Health Information Center.  Accessed 7/9/14.

Conducting Your Annual Lockout/Tagout Inspections

Posted: Aug 07, 2014

By Renee Witherspoon, CSP, CIH, CHMM, South Plains Chapter President

Example of the lockout device for an ordinary electrical switch.

Are you surprised to learn that there is an annual lockout/tagout (LOTO) inspection requirement?  As part of OSHA’s Control of Hazardous Energy standard (29 CFR 1910.147) or lockout/tagout employers are required to “conduct a periodic inspection of the energy control procedure at least annually to ensure that the procedure and the requirements of this standard are being followed.”

Many are familiar with LOTO standard and have lockout/tagout procedures at their facility, but may not be as familiar with the annual inspection and certification requirements.

Overview of the Standard

OSHA’s LOTO standard applies to all types of energy both potential and kinetic including electrical, mechanical, hydraulic, pneumatic, chemical, etc.  An employer is required to establish procedures and train their personnel to de-energize equipment and apply a lockout/tagout device before performing maintenance or servicing operations.  This prevents unexpected energization, start-up, or release of these stored energy hazards that could cause a disabling injury or even death.

This standard has two key definitions, an “authorized” employee and an “affected” employee.

An “authorized” employee may do any or all of the following tasks:

  • Perform energy source isolation;
  • Implement lockout and/or tagout on machines or equipment;
  • Dissipate potential (stored) energy;
  • Verify energy isolation;
  • Implement actions to release LOTO; or
  • Test or position machines or equipment.

An “affected” employee is a person whose job requires him or her to:

  • Operate or use a machine or equipment on which servicing or maintenance is being performed under lockout/tagout, or
  • Work in an area in which servicing or maintenance is being performed.

Servicing and maintenance of equipment begins only after an authorized employee has placed his or her own lock and/or tag on the energy isolation device(s).  The equipment then can only re-energized and restarted after that employee removes their lock and/or tag.

Although LOTO appears to be a very broad-based standard it is not required for certain operations including:

  • Construction, agriculture or maritime employment;
  • Oil and gas well drilling and servicing;
  • Installations under the exclusive control of electric utilities for power generation transmission and distribution;
  • Exposure to electrical hazards from work on, near or with conductors or equipment in electric use installations (covered by Subpart S of the OSHA standard), and;
  • Work performed with electronic equipment that is connected to its energy source by a cord and plug.

Conducting the Periodic Inspection

To comply with the periodic inspection portion of the standard an authorized employee must observe another authorized employee implement each LOTO procedure once per year.  Why is this not done at some facilities?  Many times supervisors are either unaware of the requirements of the standard or, they may have simply misinterpreted what it says.

OSHA states in §1910.147(c)(6)(i) that “the employer shall conduct an inspection of the energy control procedure.” This singular use of the word “procedure” is easily misinterpreted as requiring review of only one LOTO procedure on a single piece of equipment.

According to the OSHA Compliance Directive (CPL 02-00-147), which provides enforcement policy and inspection procedures, an authorized person (or persons) shall conduct a periodic inspection of one (or more) authorized person(s) implementing each of the employer’s machine-specific LOTO procedures (or group of like procedures).

In this directive OSHA explains that each energy control procedure required by §1910.147(c)(4) must be separately inspected annually to ensure that the procedure is adequate and that is it properly implemented by the authorized employee(s).  Each of the LOTO annual inspections must include a demonstration of the procedures and must be performed while the authorized employee(s) performs the servicing and/or maintenance activity on the designated machine or equipment.  If deficiencies are identified, retraining must also be completed.

The requirement for “separate inspections annually” may seem like a daunting task especially if there are multiple pumps or machinery.  Fortunately, OSHA does allow a facility to group machine-specific LOTO procedures into one procedure for purposes of compliance, so long as the machines or equipment have the same or similar types of control measures.  OSHA also allows for representative sampling when performing an inspection.  As an example, if there were 20 employees authorized to perform a LOTO, OSHA would require an inspection or review of a representative number of them to comply with the standard instead of all 20 employees.

Grouping is a method to decrease the number of required annual inspections.  To take advantage of this, each LOTO procedure must all be listed or identified in the scope of the energy control procedure, and should include:

Grouping is a method to decrease the number of required annual inspections.  To take advantage of this, each LOTO procedure must all be listed or identified in the scope of the energy control procedure, and should include:

  • Procedural steps for shutting down, isolating, blocking, securing, and dissipating stored energy in machines or equipment;
  • Procedural steps for the placement, removal, and transfer of the lockout or tagout devices and the responsibility for them; and,
  • Requirements for testing a machine or equipment to determine and verify the effectiveness of LOTO devices and other control measures.

Once the inspection is completed the standard requires that a review of the procedures be completed “between the inspector and each authorized and affected employee” and then “certified”.  The employer, according to OSHA, is responsible for certifying that the periodic inspection(s) have been performed.

A certification must include at least the following information:

  • Identity of the machine or equipment on which the energy control procedure was being utilized;
  • The date of the inspection;
  • The employees included in the inspection; and,
  • Person performing the inspection.

Conclusion

OSHA’s LOTO standard has many components that we are familiar with.  The requirement for periodic inspection is sometimes overlooked and at times easily misinterpreted because of the singular language used in this standard.  For insight on the interpretation of this regulation a review of the Compliance Directive is needed.  In this directive the requirement for periodic inspections becomes more clear.  

An authorized person(s) will conduct a periodic inspection of other authorized person(s) implementing each one of the organizations LOTO procedures or grouped procedures. 

Once the inspection is completed, that procedure must be reviewed with both authorized and affected employees and then certified by the employer.  If any deficiencies are identified, retraining must also be completed.

If you are concerned about compliance with this regulation, don’t reinvent the wheel.  There are free LOTO certification forms available on the internet as well as generic lockout procedures that can be used as a template for developing your facilities site-specific LOTO program.

June is National Safety Month, so celebrate by preventing injuries from unexpected machine start-ups.  Review and update your LOTO program!

References:

  • Chambers, Curtis.  “OSHA’s Annual LOTO Procedure Inspection Requirements.” www.oshatraining.com Accessed:  5/12/14
  • OSHA Standard 29 CFR 1910.147 “The Control of Hazardous Energy (lockout/tagout)”
  • OSHA Standard 29 CFR 1910.147 “The Control of Hazardous Energy (lockout/tagout)” Appendix A – Typical minimal lockout procedures
  • OSHA Instruction CPL 02-00-147, Effective Date:  2/11/08, Subject:  The Control of Hazardous Energy – Enforcement Policy and Inspection Procedures