Director’s Corner 3 Take a Stand Day 5 MVPP Best Pracces 6 Significant Case Study - Transportaon Equipment Manufacturing 8 MIOSHA Training Instute 8 FAQs 9 Partnerships, Awards and Alliances Too often, warning signs of heat stroke, heat exhaustion, and to a lesser extent, headache, nausea and dizziness, comes from employees after they have already suffered overexposure to the elements. Monitoring the heat index is an important pre-emptive tool that can be used toward implementing additional preventive options (i.e., more water and rest breaks, shade, rescheduling non-essential work, etc.). I invite you to take a look at the new OSHA-NIOSH Heat Safety Tool App. This new app, available for both Android and iPhone, is a collaborative effort between OSHA and NIOSH to help combat heat sickness. Both supervisors and workers can access life-saving information on when to take precautions on a hot day at the worksite. This extremely useful resource helps employers plan outdoor work activities based on how hot it feels throughout the day. It features real-time heat index and hourly forecasts, specific to the work location, as well as precautionary occupational safety and health recommendations, signs and symptoms, and first aid information for heat- related illnesses. Volume 22, Issue No. 3, Summer 2017 inside this issue Bart Pickelman, CIH, Director MIOSHA will be adopting major changes to the requirements for walking-working surfaces and fall protection in general industry. Walking-working surfaces include floors, aisles, stairways, runways, ladders, ramps, elevated platforms, roofs, and scaffolds. Because walking-working surfaces are found in every workplace, all places of employment in general industry will be affected. The MIOSHA rule revisions are in response to changes in the federal OSHA rules that occurred earlier this year. In January 2017 OSHA updated its general industry standards for slip, trip, and fall hazards (OSHA Subpart D, Walking-Working Surfaces) and added requirements for personal fall protection systems (in OSHA Subpart I, Personal Protective Equipment). Under the agreement that allows Michigan to operate a state plan, the MIOSHA standards must be at least as effective as the federal OSHA regulations. Purpose of Revisions The rule changes are intended to reduce the number of fatalities and lost-workday injuries due to slips, trips, and falls. They incorporate advances in technology, national consensus standards, and industry best practices since the last time these rules were revised, which was more than 25 years ago. The rule revisions make the regulations more cost effective. With regards to fall protection methods, the updates provide greater flexibility. The revisions harmonize requirements between construction and general industry and between different general industry regulations so employers can use the same fall protection practices, systems, and equipment across more worksites. New Rules: Walking - Working Surfaces and Fall Protection in General Industry Continued on next page Adrian Z. Rocskay, Director, General Industry Safety and Health Division (GISHD) The heat is on! It’s that time of year to reacclimate working during hot summer months by continually reassessing and preparing for the dangers of heat-related illnesses to keep workers safe. Employers are responsible for protecting workers from extreme heat by establishing a complete heat illness prevention program.
Transcript
Director’s Corner
3 Take a Stand Day 5 MVPP Best Practices 6 Significant Case Study - Transportation Equipment Manufacturing 8 MIOSHA Training Institute 8 FAQs 9 Partnerships, Awards and Alliances
Too often, warning signs of heat stroke, heat exhaustion, and to a lesser extent, headache, nausea and dizziness, comes from employees after they have already suffered overexposure to the elements. Monitoring the heat index is an important pre-emptive tool that can be used toward implementing additional preventive options (i.e., more water and rest breaks, shade, rescheduling non-essential work, etc.). I invite you to take a look at the new OSHA-NIOSH Heat Safety Tool App. This new app, available for both Android and iPhone, is a collaborative effort between OSHA and NIOSH to help combat heat sickness. Both supervisors and workers can access life-saving information on when to take precautions on a hot day at the worksite. This extremely useful resource helps employers plan outdoor work activities based on how hot it feels throughout the day. It features real-time heat index and hourly forecasts, specific to the work location, as well as precautionary occupational safety and health recommendations, signs and symptoms, and first aid information for heat-related illnesses.
Volume 22, Issue No. 3, Summer 2017
inside this issue
Bart Pickelman, CIH, Director
MIOSHA will be adopting major changes to the requirements for walking-working surfaces and fall protection in general industry. Walking-working surfaces include floors, aisles, stairways, runways, ladders, ramps, elevated platforms, roofs, and scaffolds. Because walking-working surfaces are found in every workplace, all places of employment in general industry will be affected.
The MIOSHA rule revisions are in response to changes in the federal OSHA rules that occurred earlier this year. In January 2017 OSHA updated its general industry standards for slip, trip, and fall hazards (OSHA Subpart D, Walking-Working Surfaces) and added requirements for personal fall protection systems (in OSHA Subpart I, Personal Protective Equipment). Under the agreement that allows Michigan to operate a state plan, the MIOSHA standards must be at least as effective as the federal OSHA regulations.
Purpose of Revisions The rule changes are intended to reduce the number of fatalities and lost-workday injuries due to slips, trips, and falls. They incorporate advances in technology, national consensus standards, and industry best practices since the last time these rules were revised, which was more than 25 years ago. The rule revisions make the regulations more cost effective. With regards to fall protection methods, the updates provide greater flexibility. The revisions harmonize requirements between construction and general industry and between different general industry regulations so employers can use the same fall protection practices, systems, and equipment across more worksites.
New Rules: Walking-Working Surfaces
and Fall Protection in General Industry
Continued on next page
Adrian Z. Rocskay, Director, General Industry Safety and Health Division (GISHD)
The heat is on! It’s that time of year to reacclimate working during hot summer months by continually reassessing and preparing for the dangers of heat-related illnesses to keep workers safe. Employers are responsible for protecting workers from extreme heat by establishing a complete heat illness prevention program.
New Rules: Walking-Working Surfaces and Fall Protection in
Affected Standards The centerpiece of the MIOSHA revisions is the adoption of the new OSHA Subpart D in its entirety as the new GI Part 2, Walking-Working Surfaces. The revisions to OSHA Subpart I relating to personal fall protection systems will be incorporated into GI Part 33, Personal Protective Equipment. As a result, the current MIOSHA rules for walking-working surfaces will be struck from GI Part 1 General Provisions; GI Part 2 Floor and Wall Openings, Stairways and Skylights; GI Part 3 Fixed Ladders; GI Part 4 Portable Ladders; and GI Part 5 Scaffolding. In the process, GI Part 2 will be renamed and its rules replaced with the new OSHA Subpart. GI Parts 3 and 4 will be completely eliminated. GI Part 5 will be renamed Powered Platforms for Building Maintenance with only the rules for these platforms remaining in the standard. In addition, 14 other MIOSHA general industry standards with provisions for walking-working surfaces and fall protection will experience small updates so they are in line with the new requirements in OSHA Subpart D and OSHA Subpart I.
Major Changes The significant changes to the rules include:
Fall protection methods – new options – Rather than installing guardrails, employers will be able to choose other fall protection methods, such as safety net systems or personal fall arrest, travel restraint, and positioning systems. These other fall protection methods will be available for unprotected sides and edges, hoist areas, holes, near dangerous equipment, and at wall openings. On low-slope roofs for work that is temporary and infrequent, employers will be able to use designated areas. Employers will be able to use fall protection plans on residential roofs when they demonstrate guardrail, safety net, or personal fall protection systems are not feasible or create a greater hazard.
Elimination of Michigan-specific rules – MIOSHA will cancel many
MIOSHA-unique rules that are now obsolete, duplicative, or in conflict with the new OSHA rules. After the MIOSHA standards are revised, the Michigan requirements will be consistent with most other states in the United States so multi-state employers will not have to comply with a different set of regulations when doing business in Michigan.
Scaffold requirements – The general industry scaffold standards are replaced with the requirement that employers comply with OSHA's construction scaffold standards.
Fixed ladders – phase-in of ladder safety systems or personal fall arrest systems – Over the next 20 years, the
revisions will phase in a requirement to equip fixed ladders (that extend more than 24 feet above a lower level) with ladder safety or personal fall arrest systems. The revisions will bar the use of cages and wells as a means of fall protection after the phase-in deadline. The revisions grandfather in cages and wells on existing ladders during the phase-in period, but require that employers equip new ladders and replacement ladders with ladder safety or personal fall arrest systems.
Rope descent systems – General requirements are added for rope descent systems used to perform elevated work. Previously, rope descent systems were regulated only through an OSHA memorandum. At heights greater than 300 feet above grade, employers will be prohibited from using rope descent systems unless they can demonstrate other means are not feasible or pose a greater hazard above that height. Permanent anchorages for rope descent systems will have to be tested and certified as capable of supporting at least 5,000 pounds per employee attached.
General Industry (Continued)
Continued on next page
Adrian Z. Rocskay, Director, GISHD
PAGE 3
Personal fall protection systems – performance and use requirements – Requirements are added for the performance, inspection, use, and maintenance of personal fall protection systems.
Body belts – Body belts are now prohibited to be used as part of a personal fall arrest system.
Inspection of walking-working surfaces – Employers will have to inspect walking-working surfaces regularly. If hazardous conditions are found, they must be corrected before an employee can use the surface again.
Training – Employers will have to train employees who use personal fall protection systems on fall hazards and on the use of the personal fall protection equipment.
Effective Dates
The estimated date of promulgation in Michigan is late 2017. Most of the provisions will have an immediate effective date.
For a few provisions, the compliance deadline is delayed. These are for worker training (four months after the effective date); testing and certifying of permanent anchorages (10 months after); installation of personal fall arrest systems, ladder safety systems, cages, or wells on existing fixed ladders (one year and 10 months after); installation of personal fall arrest systems or ladder safety systems on new fixed ladders (November 19, 2018); and installation of personal fall arrest systems or ladder safety systems on all fixed ladders (November 18, 2036).
Additional Resources
Employers are strongly advised to read the regulations in advance to ensure compliance on the effective dates. The full regulatory text of the new federal rules can be found at the federal OSHA webpage for walking-working surfaces (https://www.osha.gov/walking-working-surfaces/). The OSHA webpage also features a fact sheet, questions and answers, and the publication of the rule in the Federal Register. At the MIOSHA website, an announcement will be posted when the revised rules are issued in Michigan.
Continued on next page
General Industry (Continued)
New Rules: Walking-Working Surfaces and Fall Protection in
Adrian Z. Rocskay, Director, GISHD
Sherry Scott, Program Manager, Consultation Education and Training (CET) Division
Take a Stand Day
MIOSHA REBRANDED Rebranding is a marketing strategy in which a new name, term, symbol, design, or combination thereof is created for an established brand with the intention of developing a new, differentiated identity in the minds of consumers, investors, competitors, and other stakeholders.
Fourteen years ago MIOSHA, like our federal progenitor OSHA, was characterized as an organization dedicated to compliance audits and penalties, an organization disliked, feared, and disconnected from the industry sectors it regulated. MIOSHA needed a new image, and as an organization embarked on rebranding. Rebranding is a very risky and costly business venture. MIOSHA is a governmental agency. Why would a governmental agency venture into business territory? MIOSHA needed to be renowned for “connecting with industry” in a way that was distinctive, relevant, effective and valuable.
Take a Stand Day (Continued) Sherry Scott, Program Manager, CET Division
Connecting to Industry MIOSHA’s operational model, “Educate Before We Regulate,” includes an arsenal of services promoting and supporting voluntary compliance in public and private industry sectors. MIOSHA expanded its services, promotion, and growth by partnering with stakeholders. The collaboration culminated in many improvements to positively affirm MIOSHA’s standing with industry. One service that has significantly changed the way MIOSHA connects to industry is MIOSHA’s “Take-A-Stand Day” (TASD).
The inaugural installment of TASD was in September 2005. One day annually, ALL MIOSHA staff, both enforcement and consultation, provide employers a consultative inspection/survey with NO CITATIONS or PENALTIES being issued for identified hazards. This unique event offers employers an opportunity to work with knowledgeable professionals to develop and/or improve their Safety and Health Management System (SHMS).
Distinction and Relevance Since the inception of TASD, more than 2,500 employers have participated! Industry participation spans a broad range of work operations, with special promotional emphasis to high hazard industries, small employers and first time participants. As a primary condition of participation in TASD, employers agree to correct any serious hazards identified.
Effectiveness and Value Participating employers are asked to complete a short survey at the close of their TASD visit. Overall survey comments cited employer appreciation for MIOSHA staff’s professionalism and expertise, and identified many safety improvements integrated into employers’ work operations and workflow. Some of the things employers have said:
“We think of TASD as one of MIOSHA's best programs.”
“MIOSHA staff did an outstanding job identifying concerns and was very prompt with information.
“I would like to do it quarterly. I feel that it is a great way for our business, and our employees to work together with MIOSHA. It is very difficult for a small business to keep up on all of the changing rules and regulations. This program allows us the opportunity to create a safer workplace for our employees.”
“I feel it was very worthwhile participating in the TASD and would do it again.”
Survey respondents had one recurring recommendation for TASD improvement:
“Let more people know that it is available.”
Continuous Improvement TASD has helped improve MIOSHA’s image and is now a premier event for “Connecting MIOSHA to Industry.” Most importantly, TASD has provided an increased opportunity for our agency to provide guidance and access to education and training resources that will enhance workplace safety and health. Employers today are better informed and amenable to a partnership with MIOSHA that includes sharing information with industry safety and health professionals regarding best practices and effective approaches; and working to resolve specific workplace safety and health issues. Working with employers and employees in a collaborative manner is value added for everyone.
PAGE 5
MVPP Best Practices Doug Kimmel, Safety Consultant/MVPP Specialist, CET Division
The DTE Energy River Rouge Power Plant located in River Rouge, MI has been part of the Michigan Voluntary Protection
Program (MVPP) since 2009. It was the first coal-fired electricity generating power plant in the state to receive the award.
Safety is a Core Value at DTE Energy and their goal of zero occupational injuries and illnesses requires constant vigilance and
focus on safety. DTE’s policy is 200 percent accountability, meaning that employees are accountable for themselves as well as
their fellow employees when it comes to safety.
Recently, DTE initiated a charge to renew the company’s focus on safety. To do this, they performed data analysis and benchmarked with high performing companies. From this, seven “critical” safety standards were identified. Meaning, if there were an accident or procedural violation of one of the critical safety standards, the consequences could result in a serious injury or fatality.
DTE has maintained 37 Corporate Safety Standards and the seven that have now been identified as critical have always been a part of them. However, now that these standards have been determined to be critical, additional focus has been placed on them and they are now known as Life Critical Safety Standards. The Life Critical Safety Standards include:
Hot Work
Confined Space
Vehicle Safety
Lifting and Supporting Loads
Working at Heights
Trenching and Excavation
Control of Hazardous Energy
In 2015, DTE chose the River Rouge Power Plant to lead the company in a pilot program to introduce the Life Critical Standards. Life Critical Standards narrow the focus on specific work activities to ensure that employees have the necessary training, are able to recognize and eliminate/control hazards, and have the correct tools to perform the activity safely and without incident or injury.
The introduction and implementation of the Life Critical Standards was accomplished through the use of pre-job briefs, toolbox talks, Stop Work Cards, and Safe Worker Observation Checklists for each of the Life Critical Standards.
Pre-job briefs were held at the beginning of each shift. During the briefs the crews discussed the specifics of the work they would be doing, including what hazards they may encounter and the countermeasures they could utilize to decrease the possibility of an incident.
Toolbox talks were used help to get dialogue going about Life Critical work that the employees would be doing. During the talks information about prior incidents involving the type of Life Critical work to be done was discussed. This helped to heighten awareness and ensure that the employees remained vigilant and protected themselves from potential hazards.
River Rouge Power Plant Continued on next page
PAGE 6
MVPP Best Practices (Continued)
Doug Kimmel, Safety Consultant/MVPP Specialist, CET Division
Stop Work Cards are available on the DTE internal website and all employees have access. Stop Work Cards are in place for each of the seven Life Critical Standards and are used to identify the required safety criteria involving the life critical activity. They also provide an opportunity for guided conversation about the Life Critical work to be performed. If all of the applicable criteria listed on the Stop Work Card is not met, the job is stopped and employees are instructed to get additional guidance from a supervisor, site leader, or a subject matter expert (SME). All DTE employees have the authority to stop any job if there are safety concerns. Safe Worker Observation Checklists have been in place for some time at DTE. Safe Worker Observations focus on the safety aspects of the work and aid in the identification of hazards. With the advent of the Life Critical Standards, additional questions were added to specifically address the Life Critical Standards. The checklists are used whenever an observation is being performed. Training on how to properly perform an observation is available to new employees. Company safety representatives often provide hands-on training in the work environment. Observations may or may not involve Life Critical operations. At the conclusion of the pilot, updates were made based on findings from the implementation of the program and employee feedback. The pilot demonstrated that the Life Critical Standards program is effective. Therefore, it has been rolled out to the entire company and continues to be an important tool in DTE’s efforts to reduce injuries and ensure the safety of all employees.
Transportation Equipment Manufacturing, North American Industrial Classification System (NAICS) 336, is one of the 11 high-hazard industries targeted by MIOSHA for enforcement and outreach activities during 2014-2018 because of high injury and illness rates in the industry. According to the 2015 U.S. Bureau of Labor Statistics data, the nonfatal occupational injury and illness incidence rate for this NAICS in Michigan is 5.2 compared to the average rate of 3.3 for all private industry in Michigan. GISHD recently performed three inspections at a facility that manufactures motor vehicle transmissions and power-train parts (NAICS 336350). Two inspections were in response to complaints. The third inspection was a programmed inspection under the reinspection program. A reinspection is a mandatory inspection done one to three years after an inspection that resulted in five or more serious citations. A previous inspection done at this facility in 2014 had five serious citations.
The three inspections resulted in a total of 13 grouped serious citations; one grouped repeat-serious citation; nine grouped oth-er-than-serious citations; and six repeat other-than-serious citations. The initial fine for the three inspections totaled $137,600. Several of these citations were grouped; grouped citations carry a single penalty amount.
The serious and serious-repeat violations identified during the inspection include:
Part 1, General Provisions
408.10111(b) Employer authorized an unsafe process, machine, or equipment. 408.10015(3) Oil and mats posed trip hazards on floor. 408.10021(1) Staged objects encroaches on an aisle pedestrian/vehicle traffic. 408.10034(3) No guards were installed on point of operation. 408.10034(9) Guards were missing at pinch points other than point of operation.
Significant Case Study—Transportation Equipment Manufacturing
Loris Copeland, WSR, GISHD
Part 2, Floor and Wall Openings, Stairways and Skylights
408.10220(1) Inadequate means of access to heights.
Part 12, Welding and Cutting
408.11282(4) Inadequate guard or device for pinch points on a welder.
Part 14, Conveyors
408.11442(2) Inadequate guard on a conveyor nip point.
Part 21, Powered Industrial Trucks
408.12152(4) Inadequate evaluation for permit renewal for fork truck operation. 408.12187 Truck forks raised excessively without a load during travel.
Part 26, Metal Working Machinery
408.12617(3) Broken emergency stop button on bolt press. 408.12635(1) Inadequate or missing guards on band saws. 408.12646 Safeguards lacking on part clamp pinch points on metal working machinery.
Part 85, The Control of Hazardous Energy Sources (Lockout/Tagout)
1910.147(c)(4)(i) Inadequate lockout procedures. 1910.147(c)(6)(i) Inadequate inspection of lockout procedures. 1910.147(c)(7)(i)(A) Inadequate lockout training for authorized personnel. 1910.147(c)(5)(ii)(B) Lockout padlock not standardized. 1910.147(c)(5)(ii)(C)(1) Lockout padlock not substantial. 1910.147(c)(5)(ii)(D) Lockout padlock not identified to individual who applied it. Part 33, Personal Protective Equipment
408.13310(1) Damaged gloves on a sand blaster.
Several citations issued for other-than-serious violations with no penalty and repeat other-than-serious violations with minor penalties are not listed here. All standards cited by federal OSHA for this industry are listed on the OSHA website.
Between August 1, 2014, and May 16, 2017, MIOSHA GISHD staff have inspected 443 establishments in this NAICS. The most frequently cited standards (in descending order) in these inspections were Part 85 The Control of Hazardous Energy Sources (Lockout/Tagout), Part 92 Hazard Communication, Part 1 General Provisions, Part 26 Metalworking Machinery, Part 39 Design Safety Standards for Electrical Systems, Part 33 Personal Protective Equipment, Part 21 Powered Industrial Trucks, Part 6 Fire Exits, and Part 7 Guards for Power Transmissions.
In addition to enforcement actions, GISHD and the CET Division promotes SHMS and work with industry groups on Partnerships and Alliances.
CET Division’s outreach activities include conducting promotional events and awareness campaigns for establishments in targeted industries (e.g., mass mailings, TASD, Coffee with MIOSHA, forums, presentations at conferences, etc.). CET also holds education and training seminars, and encourages CET grant awards for projects in the targeted industries. Consultation is available to employers so they may take steps voluntarily to correct hazards and comply with current safety and health regulations and practices. Employers can contact CET at 517-284-7720 for a free evaluation of their workplace.
On October 1, 2009, the CET Division introduced scholarship opportunities for students attending MTI. The program was designed to assist employers, employees and others needing safety and health training to obtain valuable training and certificates. The scholarships cover half the cost of an MTI class anywhere in the state. Past, current, and new students are eligible to apply.
For fiscal year 2017, MIOSHA dedicated $40,000 for funding MTI scholarships. But money does go fast! As of June 12, 2017, MIOSHA had exhausted the year’s scholarship budget; scholarships that have been awarded will be honored. New funding will become available on October 1, 2017. Beginning July 1, 2017, scholarship applications for October classes will be accepted.
Here are some numbers you may find of interest regarding MTI scholarships:
From October 1, 2016, to September 30, 2017, approximately $40,000 for 751 scholarships was awarded to MTI students.
From October 1, 2009, to May 31, 2017, more than $310,000 for 5,210 scholarships have been awarded to MTI students.
Do MIOSHA compliance officers and consultants uniformly
interpret and implement standards?
Answer: The goal of MIOSHA is to have our compliance officers and our
CET Division consultants interpret and apply the MIOSHA standards consistently and uniformly. Many of our CET consultants began their careers with MIOSHA in one of the compliance divisions. Those who have not, go through extensive training to ensure that standards are being applied consistently. All compliance officers and consultants participate in ongoing training to help ensure consistency. The compliance divisions work closely with the CET Division, frequently attend each other's division training, attend similar ongoing training, and participate on consistency workgroups to help achieve this goal.
PAGE 9
Director:
Barton G. Pickelman, CIH
Editor:
Jeannie Vogel
MIOSHA Hotline:
800-866-4674
Fatality Hotline:
800-858-0397
General Information:
517-284-7777
Michigan Department
of Licensing and
Regulatory Affairs (LARA)
Michigan Occupational Safety
and Health Administration
(MIOSHA)
LARA is an equal opportunity employer/program.
The Mission
of the MIOSHA Program is:
To Protect the Safety and
Health of Michigan Workers.
The MIOSHA News is a publication of the
MIOSHA program.
Its purpose is to educate Michigan employers and
employees about workplace safety and health; we encourage reprinting.
Cintas Cleanroom Resources Recognized as “Rising Star” for Exceptional Occupational Safety and Health Management Cintas Cleanroom Resources – Location K15, an industrial launderer located in Westland, was awarded status as a RISING STAR participant in the Michigan Voluntary Protection Program (MVPP) in April 2017.
Eaton Aerospace Earns Highest Award as MVPP “Star” Participant Eaton Aerospace, LLC, in Grand Rapids, has been recognized for its ergonomic innovations that significantly reduce the potential for ergonomic hazards. In June 2017, MIOSHA awarded Eaton Aerospace status as a STAR participant in the Michigan Voluntary Protection Program (MVPP).
Holly Construction Receives Renewed “Star” Workplace Safety and Health Status
Holly Construction Company, Inc., in Belleville, received renewal of MIOSHA’s highest workplace safety and health designation as a STAR participant in the Michigan Voluntary Protection Program for Construction (MVPPC) in April 2017.
NuCon Corporation Awarded Continued MSHARP Certification NuCon Corporation, a manufacturer of bladed components located in Livonia, was awarded a three-year extension of the prestigious Michigan Safety and Health Achievement Recognition Program (MSHARP) award from MIOSHA in June 2017.
Royalton Manor Receives Gold Award for Excellent Safety and Health Performance
Royalton Manor, a skilled nursing center in St. Joseph, was awarded the Consultation Education and Training Gold Award at a presentation in June 2017.
Walbridge Ford Dearborn Campus Transformation Project Awarded as “Rising Star” in Construction Walbridge Ford Dearborn Campus Transformation Project in Dearborn, was awarded status as a Rising Star participant in the Michigan Voluntary Protection Program for Construction (MVPPC) in June 2017.
