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R&R Insurance Blog

John Brengosz

Recent Posts

Industrial Hygiene Testing - Where to Start?

Posted by John Brengosz

industrial hygiene testingBack in the day, many national insurance companies had their own industrial hygiene departments and/or specialists - some even had their own laboratories!  It was widely perceived to be a competitive advantage.  However over time, the cost started to outweigh the value of services.  From the travel to the perceived value of the surveys to results, industrial hygiene screenings became highly scrutinized.

Fast forward to today and there are (3) potential avenues for industrial hygiene testing:

  1. Select insurance companies continue to perform surveys for select situations, generally at no cost to the policyholder
  2. R&R Insurance can assist for often less cost than the insurance company
    • Quarterly, R&R rents 5 dosimeters and will conduct full day noise surveys for customers at no cost. We also can borrow air testing pumps from the State of Wisconsin at no cost with the customer paying for the lab fees charged by the State to analyze the media used.
  3. 3rd party companies specializing in industrial hygiene
    • Contact us for recommended vendors
    • Services begin at $2,500

No matter the method, be cautious that costs can rise very quickly.  From the number of spaces being tested to the frequency & length of time testing; there is definite process of screening, testing, and resolving the issue(s).

I think we may need industrial hygiene testing - where do I start?

Start by asking a few questions:

  • Why is there a concern?
  • Have there been employee complaint (s)?
  • Is there an odor issue?
  • Do you just want to know?
  • Has there been any previous testing?
  • Be prepared to have your Safety Data Sheets (SDS) for the chemical(s) in question - it can help us do front-end evaluation and will be required for anyone doing testing

Testing is just the beginning of the "process".  If levels come back over OSHA limits, the work is just starting!  Things like increased ventilation and/or redesigned ventilation could be a suggested solution.  This is a true science and one that would expand beyond industrial hygiene specialists.

"Industrial hygiene: is the science of protecting and enhancing the health and safety of people at work and in their communities. Health and safety hazards cover a wide range of chemical, physical, biological and ergonomic stressors."

Contact your KnowledgeBroker to discuss if a survey is right for you.

OSHA 300 Log Electronic Reporting Deadline: July 1, 2018

Posted by John Brengosz

OSHA.jpgDeadline approaching: employers have until July 1, 2018 to submit their OSHA 300 log data electronically directly to OSHA.

Reporting Requirements
  • Companies with 20-249 employees and in select NAICS codes (primarily construction and manufacturing) need to submit their OSHA 300 data by July 1, 2018 for their 2017 OSHA 300 log totals. 

“Covered establishments with 250 or more employees are only required to provide their 2017 Form 300A summary data. OSHA is not accepting Form 300 and 301 information at this time. OSHA will issue a notice of proposed rulemaking (NPRM) to reconsider, revise, or remove provisions of the "Improve Tracking of Workplace Injury" rule, including the collection of the Forms 300/301 data.

Covered establishments with 20-249 employees must electronically submit information from OSHA Form 300A." – www.osha.gov

Submission Year

 Establishments with 250 or More Employees

 Establishments with 20-249 Employees

 Submission Deadline

 2017

 Form 300A

 Form 300A

 July 1, 2018

2018

Forms 300A, 300, 301

Form 300A

March 2, 2019


How can we help?

The world of OSHA reporting can be complex and confusing, specifically when it comes to electronic reporting. R&R’s Professional Services team can help you navigate not only when to have your 300 submitted, but also what should be included on the log.  Many companies actually over-report injuries on their 300 log which results in inflated incident or Frequency rates.

We invite you to listen to a previously recorded webinar regarding OSHA 300 hosted by John Brengosz. For additional information and resources contact Safety@rrins.com.

Topics: OSHA

OSHA 300 Log Electronic Reporting - Due Dec. 1, 2017

Posted by John Brengosz

OSHA.jpgNew Information Surrounding OSHA 300 Log Electronic Reporting

Over the summer, OSHA announced beginning August 1, 2017 employers can submit their OSHA 300 log data electronically directly to OSHA, via the OSHA website.  Although the OSHA website will allow companies to upload injury data starting August 1, 2017 the deadline for uploading this data remains December 1, 2017.

What does this mean for you?

Essentially, companies with more than 20 employees and in select NAICS codes (primarily construction and manufacturing) would need to submit their data between August 1 and December 1 of 2017 for their 2016 OSHA 300 log totals. 

“Covered establishments with 250 or more employees must electronically submit information from OSHA Forms 300 (Log of Work-Related Injuries and Illnesses), 300A (Summary of Work-Related Injuries and Illnesses), and 301 (Injury and Illness Incident Report). Covered establishments with 20-249 employees must electronically submit information from OSHA Form 300A.” – www.osha.gov

How can we help?

The world of OSHA reporting can be complex and confusing, specifically when it comes to electronic reporting. R&R’s Professional Services team can help you navigate not only when to have your 300 submitted, but also what should be included on the log.  Many companies actually over-report injuries on their 300 log which results in inflated incident or Frequency rates.

With this most recent update, R&R recommends taking the reporting process slowly and not feeling pressured by the December 1, 2017 date. We invite you to listen to a previously recorded webinar regarding OSHA 300 Logs or attend our upcoming webinar on November 7th hosted by John Brengosz.

Click here to register for the live webinar or email Safety@rrins.com for additional information and resources.

Topics: OSHA

OSHA Delays Enforcement of Crystalline Silica Standard

Posted by John Brengosz

On April 6, 2017 the U.S. Department of Labor’s OccupationalOSHA.jpg Safety and Health Administration announced a delay in enforcement of the crystalline silica standard that applies to the construction industry in order to conduct additional outreach and provide educational materials and guidance for employers.

The agency has determined that additional guidance is necessary due to the unique nature of the requirements in the construction standard. Originally scheduled to begin June 23, 2017, enforcement will now begin Sept. 23, 2017.

OSHA expects employers in the construction industry to continue to take steps either to come into compliance with the new permissible exposure limit, or to implement specific dust controls for certain operations as provided in Table 1 of the standard. Table 1 matches common construction tasks with dust control methods, so employers know exactly what they need to do to limit worker exposures to silica.

Construction employers should also continue to prepare to implement the standard’s other requirements, including exposure assessment, medical surveillance and employee training.

For more information, visit www.osha.gov or contact a Knowledgebroker.

Topics: OSHA Compliance, OSHA, OSHA standards, Construction

OSHA | New Electronic Recordkeeping Requirements

Posted by John Brengosz

OSHA-Recordkeeping.jpgUpdated June 29, 2017: OSHA Delays Electronic Recordkeeping Deadline to December 1, 2017

 

Mandatory reporting of OSHA is just around the corner! Be sure you are completing your OSHA 300 log accurately because you will very likely be sending the information to OSHA in 2017.

OSHA has updated the rules that pertain to the reporting of workplace injuries and illnesses. The new rule requires certain employers to electronically submit injury and illness data beginning in 2017. The goal is to encourage employers to better identify hazards, address safety issues, and prevent future injuries and illnesses.

New Requirements:

  • Employers with 20-249 employees in high-hazard industries must electronically submit their OSHA 300A form for the year 2016. – Effective December 1, 2017 (originally July 1, 2017)
    • These same employers must electronically submit their OSHA 300A information for 2017 by July 1, 2018. Beginning in 2019, these employers must submit their OSHA 300A information (for 2018) by March 2, 2019.
    • These same employers must electronically submit their OSHA 300A, OSHA 300 and 301 forms. – Effective July 1, 2018.
    • Beginning in 2019, these employers must submit OSHA information (for 2018) by March 2, 2019.
  • Employers with 250 or more employees in industries covered by the record-keeping regulation must electronically submit their OSHA 300A form for the year 2016. – Effective December 1, 2017 (originally July 1, 2017)

 

Submission Year

 Establishments with 250 or More Employees

 Establishments with 20-249 Employees

 Submission Deadline

 2016

 Form 300A

 Form 300A

December 1, 2017

 2017

 Forms 300A, 300, 301

 Form 300A

 July 1, 2018

2018

Forms 300A, 300, 301

Form 300A

March 2, 2019

 

In addition to these upcoming requirements, the information submitted will also be posted publically on the OSHA website. For more information about the new OSHA recordkeeping requirements, contact a Knowledge Broker or register for our upcoming webinar.

Topics: OSHA, osha 300 log recordkeeping, OSHA requirements, OSHA 300 webinar, OSHA 300 log, OSHA recordkeeping, recordkeeping requirements

OSHA Reporting | New for 2015

Posted by John Brengosz

OSHA 2015 ReportingWhat is currently required to be reported to OSHA?

  • All work related fatalities
  • Work-related hospitalizations of 3 or more employees

Starting 1-1-2015, what will employees have to report to OSHA?

  • All work-related fatalities (within 8 hours of finding out about them)
  • All work-related inpatient hospitalizations of 1 or more employees
  • All work-related amputations
  • All work-related losses of an eye

Important note on who is covered by this ruling
All employers under OSHA jurisdiction must report the 4 events listed above and this includes even small employers with less than 10 employees. (who are exempt from OSHA record-keeping)

How soon must these be reported?

  • Fatality: within 8 hours of finding out about it or if the death occurs within 30 days of a work-related incident.
  • For inpatient hospitalization, amputation and eye loss, employers must report within 24 hours of learning about it. (employers only have to report an inpatient hospitalization, amputation, or loss of an eye that occurs within 24 hours of a work-related incident.)

How do I report one of these events to OSHA?

  • CALL: Your local OSHA office or use the 24 hour hotline at 1-800-321-6742
  • ELECTRONICALLY: OSHA is working to have this in place soon! (www.osha.gov)

What information do I need to report?

For fatality, inpatient hospitalization, amputation or loss of an eye, report the following:

  • Company name
  • Location of the incident
  • Time of the incident
  • Type of injury sustained
  • Number of employees who suffered the event
  • Names of the employees involved
  • Contact person and his/her phone number
  • Brief description of the work related incident

Employers DO NOT have to report an event if it:

  • Resulted from a motor vehicle accident on a public street or highway. (it does need to be reported if the event happened in a construction work zone)
  • Occurred on a commercial or public transportation system (airplane, subway, bus, ferry, streetcar, light rail or train)
  • Occurred more than 30 days after the work-related incident if a fatality or more than 24 hours after the work related incident in the case of an inpatient hospitalization, amputation, or loss of an eye.

What about heart attacks?

Employers do have to report an inpatient hospitalization due to a heart attack, if the heart attack resulted from a work-related incident.

2015 OSHA reporting explained: download flow chart

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NOTE: In the same ruling, OSHA has also changed the list of occupations that are now required to complete the OSHA 300 log. It is important to note that employees who had fewer than 10 employees in a calendar year are still exempt from having to complete an OSHA 300 log.

For the new list of industries now required to complete a 300 log as well as additional information can be found at: www.osha.gov/recordkeeping2014.

 

Have additional questions? Contact your knowledgebroker.

Topics: Safety, OSHA, Accident Investigation, OSHA 2015, OSHA requirements, Business Insurance

Beat the Heat: Preventive Measures to Avoid Heat Exhaustion for Your Employees

Posted by John Brengosz

Best practices for employers with outdoor workers:

  • Train employees and supervisors in heat illness prevention, as well as how to recognize the symptoms of heat-related illness and what to do if someone exhibits symptoms
  • On days when temperatures require preventive measures, increase the volume of water available to employees. California suggests one quart per hour. It is not enough to simply provide it - workers must be encouraged to drink the water.
  • Have shade available for outdoor workers and allow frequent breaks - at least 5 minutes of rest when an employee believes they need a preventative recovery period.
  • Have the ability to appropriately respond to any employee with symptoms of illness
  • Allow gradual acclimation for workers unaccustomed to working outside - it can take 4 to 14 days
  • Know where the nearest hospital is and directions to your work site in case emergency medical attention is needed

Heat-related resources

Topics: Safety, Risk Management, heat stroke, Resource Center, heat stress, heat exhaustion, Business Insurance, outdoor heat exposure, heat realted injuries for employees

Combustible Dust: An Explosion Hazard

Posted by John Brengosz

Combustible Dust PentagonHere are five examples of deadly incidents that were caused by dust, and ways businesses can eliminate the risk of a dust explosion happening in their facility.

  1. In February 1999, a deadly fire and explosion occurred in a foundry in Massachusetts killing 3 and injuring 9. A fire initiated in a shell molding machine from an unknown source and then extended into the ventilation system ducts by feeding on heavy deposits of phenol formaldehyde resin dust. A small primary deflagration occurred within the ductwork, dislodging dust that had settled on the exterior of the ducts. The ensuing dust cloud provided fuel for a secondary explosion which was powerful enough to lift the roof and cause wall failures.
  2. In January 2003, devastating fires and explosions destroyed a North Carolina pharmaceutical plant that manufactured rubber drug-delivery components. Six employees were killed and 38 people injured. An accumulation of a combustible polyethylene dust above the suspended ceilings fueled the explosion. The CSB was unable to determine what ignited the initial fire or how the dust was dispersed to create the explosive cloud in the hidden ceiling space.
  3. In February 2003, a Kentucky acoustics insulation manufacturing plant was the site of a dust explosion killing 7 and injuring 37 employees. The likely ignition scenario was a small fire extending from an unattended oven which ignited a dust cloud created by nearby line cleaning. This was followed by a deadly cascade of dust explosions throughout the plant.
  4. In October 2003, an Indiana plant where aluminum auto wheels were machined experienced an incident which killed one and injured one employee. Aluminum dust was involved in a primary explosion near a chip melting furnace, followed by a secondary blast in dust collection equipment.
  5. February 10, 2008 a deadly explosion ripped through a sugar refinery blast killing at least 6 workers and sent 62 to the hospital. “As far as we know it was a sugar dust explosion,” authorities said the day after the explosion. The blast occurred in a storage silo where refined sugar is stored until it is packaged. Sugar dust is combustible. Static electricity sparks from metal tools, or a cigarette can ignite explosions.

Elements Needed for a Dust Fire (the familiar "Fire Triangle"):

  1. Combustible dust (fuel);
  2. Ignition source (heat);
  3. Oxygen in air (oxidizer);
  4. Dispersion of dust particles in sufficient quantity and concentration;
  5. Confinement of the dust cloud

There are several ways these explosions can take place. Two primary scenarios are:

  1. A dust cloud (diffused fuel) is ignited within a confined or semi-confined vessel, area, or building, and burns very rapidly or explodes. The safety of employees is threatened by the ensuing fires, additional explosions, flying debris, and collapsing building components.
  2. An initial explosion in an area were fugitive dust has accumulated may shake loose more accumulated dust, or damage a containment system (such as a duct, vessel, or collector). As a result, if ignited, the additional dust dispersed into the air may cause one or more secondary explosions. These can be far more destructive than a primary explosion due to the increased quantity and concentration of dispersed combustible dust.

What action can employers take to reduce their exposure?

If one of the elements of the explosion pentagon is missing, a catastrophic explosion can not occur. Two of the elements in the explosion pentagon are difficult to eliminate: oxygen (within air), and confinement of the dust cloud (within processes or buildings). However, the other three elements of the pentagon can be controlled to a significant extent.

OSHA Fact Sheet on Combustible Dust Explosions

 

Topics: Safety, Loss Prevention, Risk Management, dust fires, fire triangle, OSHA explosion pentagon, Resource Center, dust cloud, combustible dust, Business Insurance, deadly explosions

Electronic Reporting of OSHA 300 Log? Be Careful What You Record!

Posted by John Brengosz

On Nov. 7, 2013, the Occupational Safety and Health Administration (OSHA) announced a proposed rule to require certain employers to submit injury and illness reports electronically. The proposed rule does not create additional recordkeeping or reporting duties for employers. Rather, it would dictate how this information must be submitted to OSHA. Summary of OSHA's proposal to require electronic submission of injury and illness reports.

Even though this is only in the proposal stage, you can believe that the information will be used to generate inspections in an attempt to “help”, and will create more targeting of "compliance assistance and enforcement"! The importance of completing the 300 log ACCURATELY will never be more important if/when mandatory submissions start. The main point we stress in our OSHA 300 Log webinars is that most companies are actually over-reporting their injuries on the 300. This was bad to do in the past, but would really be problematic if we get to the point where EVERYBODY is submitting their 300 log to OSHA. (currently not the case)

300 Log webinars:
Gain control over your OSHA 300 Log! Basic questions about the OSHA 300 log will be answered along with tips to keep your recordkeeping compliant and accurate. R&R offers free annual webinars - click here to register.

 


Originally published November 2013; last updated August 2015

Topics: Safety, OSHA, Risk Management, OSHA electronic reporting, 300 Log, Resource Center, osha 300 log recordkeeping, John Brengosz, Business Insurance, control your osha 300 log

OSHA 300 Log: The Importance of Recordkeeping

Posted by John Brengosz

According to OSHA, the importance of recordkeeping is a critical part in employer's safety and health efforts for a few reasons:

  1. Keeping track of work-related injuries and illnesses can help you prevent them in the future.
  2. Using injury and illness data helps identify problem areas. The more you know, the better you can identify and correct hazardous workplace conditions.
  3. You can better administer company safety and health programs with accurate records.
  4. As employee awareness about injuries, illnesses, and hazards in the workplace improves, workers are more likely to follow safe work practices and report workplace hazards. OSHA compliance officers can rely on the data to help them properly identify and focus on injuries and illnesses in a particular area. The agency also asks about 80,000 establishments each year to report the data directly to OSHA, which uses the information as part of its site-specific inspection targeting program. The Bureau of Labor Statistics (BLS) also uses injury and illness records as the source data for the Annual Survey of Occupational Injuries and Illnesses that shows safety and health trends nationwide and industrywide.

To help guide you through OSHA recordkeeping, R&R Insurance provides a complimentary guide to the OSHA 300 Log.

Additional OSHA 300 Log resources:

Email our knowledgebroker OSHA expert John Brengosz for additional information.