In FY 2015, responding to requests from small employers looking to create or improve their injury and illness prevention programs, OSHA’s On-site Consultation Program conducted approximately 28,000 visits to small business worksites covering over 1.4 million workers across the nation.
OSHA’s Safety & Health Achievement Recognition Program (SHARP) grants small businesses that maintain exemplary injury and illness prevention programs an exemption from OSHA programmed inspections for up to two years.
“As safety professionals, we’re always working. Our eyes are always looking for things. It’s impossible to turn that off,” says Matt Hardy, construction safety consultant at WorkWISE NH, OSHA’s on-site consultation resource for the state, as he tours a construction site in Bedford, as reported in an article in the New Hampshire Business Review.
“As a generality, we’re really looking at anything fall related, so anything to do with fall protection, ladders, aerial lifts, scaffolds,” he explains.
Although Hardy and the rest of his team are sometimes confused with OSHA inspectors, they are part of a federal resource aimed at helping businesses prevent OSHA violations and fines by taking advantage of on-site walk-throughs.
“It’s basically a free service for any small business in the state,” says WorkWISE NH Program Manager Rick Rumba.
The program has been around for decades, but only in recent years has it been run by Keene State College. The switch occurred in 2011, when the New Hampshire legislature cut state funding, leading the state Department of Environmental Services to hand off the program to another organization. Although the program is 90 percent federally funded, the organization that runs it covers 10 percent.
With a bachelor’s and master’s program in occupational safety and health applied Sciences, Keene State College decided to take on the program, which it renamed WorkWISE NH.
Drumming up PPE business
“We probably visit 150 businesses a year,” says Rumba, who is part of a team of four. “If somebody needs something that’s more in-depth than what we can provide, we’ll work with the academic program to get them a student intern.”
With the business’ permission, students taking an industrial hygiene class sometimes attend walk-throughs and even participate in taking duplicate air samples, learning how it’s done in the field.
For their senior capstone, a group of five students recently worked with a manufacturer to create a lockout-tagout program, says Rumba, to ensure no employee would get caught in a machine that is being serviced.
“It’s a long involved process, and we normally couldn’t do that for a small company,” says Rumba. “It got the students the field experience of working with a real company and addressing a real problem, and the company got it free from soon-to-be graduates, saving them thousands of dollars.”
Rumba says businesses that utilize the WorkWISE consultation services will come back every year or every other year.
“Right now, we probably have an almost two-to-three-month backlog of people looking for us to come in. A visit takes, on average, a half a day, and then we write a report and things like that. It’s a lot more than just spending an hour,” he says.
Rumba tries to prioritize the schedule, sometimes asking businesses that had a visit the year before to wait a few months or moving a business up in the schedule if there’s an urgent need.
The program is geared toward small businesses, with 250 employees or fewer at one site and fewer than 500 employees in total. But, as specified on the WorkWISE NH’s website, businesses of all sizes can reach out with questions about the safe use of a specific piece of equipment or if they’re looking to establish a workplace safety program.
“We can’t say no to anyone,” says Rumba.
However, WorkWISE NH cannot perform walk-throughs for businesses that have been recently cited by OSHA and are going through the process of working out a fee payment.
“We have to wait until they’re done with OSHA before we go in,” says Rumba.
Three main clients
About 40 percent of WorkWISE NH’s clients are construction firms, while manufacturers make up another 40 percent and the last 20 percent is health care organizations, which Rumba says is one of the industries with the highest injury rates, mainly due to back injuries from improperly handling and moving patients. “We work a lot with health care – with doctor’s offices, dentist offices and nursing homes,” he says.
“Manufacturers have been dealing with OSHA longer than some of the other industries so they’re probably more up to speed, because they’re the traditional company that OSHA is focused on,” says Rumba. “But we still have a lot of manufacturers and we do get a lot of questions.”
A common mishap is improper machine guarding, he says.
“If you’re using saws or lathes, or machinery like that – things for cutting metal – they have to be properly guarded so you don’t end up losing a finger in the machine. It’s especially an issue with companies with older equipment; they have to retrofit the older equipment. Most of the new equipment comes with that,” Rumba explains
Chemical exposure is another common area of concern.
“People work with a lot of different chemicals and solvents and things like that and [the manufacturers] have to ensure people aren’t being exposed to it and breathing vapors,” says Rumba. “We try to get them to use the least harmful chemical they can and protect workers with respiratory protection.”
One benefit of global trade, manufacturing has become safer due to European regulations.
“If you want to manufacture lipstick, if you sold it in the U.S., there aren’t many regulations to see if it will cause harm. But Europe, there’s a ton of regulations,” says Rumba. “So now that we’re manufacturing products to comply with European regulations, they become safer here too.”
OSHA, however, has several regulations regarding roof work and fall protection. Fall protection remains a major issue not only for constructions firms, but all types of businesses.
“Remember all the snow we had last winter? A lot of people were hiring people to shovel snow off their roofs, not just residential, but big commercial buildings, and there were lot of OSHA violations,” Rumba says.
According to OSHA, no one under the age of 17 can work on a roof, but several companies utilized teen labor during winter vacations. One kid got hurt shoveling snow off of Frugal Fannie’s clothing store in Massachusetts, says Rumba. He fell through the skylight and, fortunately, landed on a rack of clothes.
“We can look at their fall protection, if they have any. If they don’t, we can tell them what to get. If they don’t know how to use it, we’ll train them to use it properly,” he says.
“You can’t remember everything”
“Unfortunately, the way I found out about [WorkWISE NH] was to be stung by OSHA,” says William “Gus” Gustafson, construction manager/site supervisor of Manchester-based A.W. Rose Construction. His team was working with split block masonry and removed the staging without putting 2-by-4 boards on the windows, so there was no protection. OSHA informed him if he utilized WorkWISE NH, he could reduce his fine, which it was, to a minuscule amount, he says.
Hardy and Keene return to Gustafson’s construction site, currently an apartment complex being built in Bedford, every six weeks or so.
“Take a look at what’s going on here. You can’t remember everything,” says Gustafson. “They do the same thing OSHA would do, except they don’t give me a fine.”
“We can go to a construction site six, eight times a year, maybe, but general industry we’ll max out at two,” says Hardy, who also graduated from Keene State’s safety program. “With the way things change, there’s always different subcontractors and job tasks and things like that going on, so it’ll be a whole different site tomorrow than it is right now.”
Following up on recommendations
After a site visit, WorkWISE’s team writes up a confidential report that is sent back to the company. The company has about a month to remedy violations and then writes back a response indicating what was corrected, which WorkWISE verifies. During the process, OSHA cannot inspect that job site unless there’s an accident or employee complaint.
Hardy says there is some resistance from businesses, which aren’t pleased they have to spend money to make corrections, but most businesses want to “do the right thing.”
“It becomes part of their system, which we’re hoping will happen. You can tell the contractors who do things because OSHA tells them,” he says. “We’re all on that common goal, that everyone goes out as they come in.”
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