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As managers that oversee large custodial departments, we need to examine the major components of OSHA regulations and their applicability to our industry. It is essential to understand what we need to implement into our cleaning operations and to mitigate any deficiencies in an effort to improve safety in the workplace. From there, we are obligated to develop an effective training curriculum that addresses the hazards and exposures in our job sites.
But first we need to examine the underlying principle of safety in the workplace as defined by OSHA. In referencing the General Duty Clause in the regulations, we find the following mandates in Section 5:
The employer: “Each Employer shall furnish to each of his employees, employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees.
“Each employer shall comply with occupational safety and health standards promulgated under this Act.”
The employee: “Each employee shall comply with occupational safety and health standards and all rules, regulations, and orders issued to this Act which are applicable to his own actions and conduct.”
To sum it up: The employer must provide a safe work environment, free from recognized hazards. In return, the employee must comply with the rules and regulations.
The reality is, you cannot ignore safety in the workplace and you can’t afford for your staff to ignore it either. The organization will be held accountable, and a proactive manager would be smart to also extend that accountability to employees.
When communicating the importance of safety in the workplace, be up front with employees and address the consequences to noncompliance. The employee must be disciplined and understand that those who do not follow the safe work practices mandated could face termination. The interpretation of these clauses is basic and a good human resource policy should be established to support your efforts.
The threat of termination might seem severe, but it is necessary. Compliance of OSHA standards is only successful if all workers are on board and properly trained. That said, there are three times when you must train and provide information to the employee.
Primary training occurs when the employee is initially hired or placed into a new job assignment. This training covers the occupational exposures they may encounter. The second round of training happens when there are changes within the job — modifications of tasks or procedures, or the introduction of new tasks, procedures or chemicals. Lastly, there should be annual safety training for all employees.
The type of training and when it occurs should all be part of the facility safety plan. According to regulations, the plan should be well documented and readily accessible. If a department were to be audited, OSHA allows only four hours to produce all training papers.
Develop A Plan For Safety In The WorkplaceTo help pull a safety plan together, it is very important to first conduct a Job Hazard Analysis (JHA) — a necessary component of the Hazard Communication Standard (Right-to-Know) in your organization. The JHA requires managers to observe employees in their respective job function, as well as review previous accidents and health incident reports (OSHA Log 300-301 — an annual posting requirement).
To analyze, organize the job classification of your employees by job function, then look for accident trends. This report is a good starting point to identify known hazard exposures.
Continue to categorize the tasks in each job category: restroom cleaner, utility cleaner, floor technician, general cleaner, etc. In each category you will need to list the job duty and hazards associated with that task. Then determine how to avoid exposure to the hazard. The hazards could be: eye splash while filling a chemical bottle; slip on an unmarked wet floor; lifting heavy trash liners from barrels or trash carts; negative interaction with another employee; fire escape routes not provided; ladder falls; needle stick in handling trash; first aid training; etc. You want to be specific and take action to remove or mitigate the exposure of these hazards.
Managers that require help or are developing a plan for the first time should visit the OSHA website and look up Hazard Communication Standard plans. This will help in accomplishing your analysis and documentation.
On the topic of documentation, OSHA requires as part of the Hazard Communication Standard (HCS) that every department must maintain an inventory of all chemicals on site. If the chemicals are hazardous, it is imperative that they are identified as such. OSHA also requires that all personnel that may come in contact with these chemicals are familiar with the Material Safety Data Sheets (MSDS), soon to be Safety Data Sheets (SDS), handling precautions and correct application, appropriate personal protective equipment (PPE), and health hazards associated with the chemical.
It is good practice that you designate an employee to monitor and maintain chemical inventory, as well as a current MSDS notebook that includes information for every chemical at each of your job sites.
OSHA Updates For 2013
Developing a safety plan and appropriate training will be important as OSHA implements updates to existing laws. For example, effective in 2013, the Material Safety Data Sheets will be changing to Safety Data Sheets and all departments will be required to adopt the Global Harmonized System (GHS). Managers will need to implement training for all employees no later than December 1, 2013. This training will reflect the changes brought about by the GHS — how to identify hazards of chemicals and proper handling procedures, to name a few. For suggestions on how to comply with this emerging regulation, visit the OSHA website at www.osha.gov.
Additional information on GHS is available in the one-hour webcast titled, “OSHA’s New GHS Chemical Standard — Are You Ready?” Access this at www.cleanlink.com/webcasts.
John M. Poole, Jr. is an authorized OSHA Outreach Training consultant and holds the following designations: Master Registered Executive Housekeeper, Registered Building Service Manager, ISSA Certification Expert, and Assessor for the Cleaning Industry Management Standard.
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