The changing face of OSHA

OSHA is starting to show teeth!


You may have heard the rumors. OSHA is stepping up their enforcement activities. In addition to increasing the financial cost of civil penalties, they are increasing the criminal penalties for any employer who willfully violates a standard that causes the employee’s death or serious injury.

With the Obama administration comes new faces and directions for the Department of Labor. OSHA is hiring up to 500 new compliance officers and is back in the enforcement business. The days of voluntary programs and alliances are coming to a close.

OSHA is formulating a “Severe Violators Inspection Program” focused on large companies with a violation history, focuses on mandatory follow up inspections, additional locations within the same company now also targeted and enhanced settlement demands.

With the increased enforcement activity, employer’s need to make sure that they are “doing right by their employees” and can document their compliance.

Scenario Role Playing

I was teaching a group of firefighters this past weekend.  We had the final incident for the Hazmat class on Sunday.  During this incident, I got the chance, as i try to do for every class, to role play.  I am not silver screen quality, but I enjoy myself. 

This time I was an owner of a transport company that employed a driver named Fred.  Fred started his daily delivery by not only going to the wrong location, but managed to drop off (literally) two drums of hazardous chemicals without knowing he had done so.  Fred was probably in the CB radio, since he does not have a phone.  He is my sisters cousin, so what's a guy to do!!

While role playing, I got to interact with several of the students with leadership positions in the drill.  The more questions they asked, the more information I gave them, most of which had no bearing on the information they were trying to get out of me.  I finally gave in and gave them bits of information that they needed for sucessful completion of the drill.  It is always interesting to see how people react when they ask you a serious question, and your reply is not only drawnout, but has no bearing on their question.  I kept them tied up for 10 minutes with just continuous rambling and off topic discussions. 

When role playing, I play particular attention to the questions and terminology that are used.  For example, a placard on a truck can either mean the DOT placard for hazmat or to not hazmaters, it could be the signs on the trucks that are used for identification.  It depends on the information that you are looking for. 

Role playing is a great way to enhance your training and can be used for a variety of topics.  It allows the students to put in to practice what they have learned in the classroom. 

I have been studying all day for a professional certification test that is scheduled for later this week.  The certification is for a Certified Hazardous Materials Manager.  There is a lot of regulations that come into play when dealing with hazardous materials.  In addition to their specific language, each regulation has their own terminology for Hazmat.  For instance, here is what I mean.

Hazardous Materials (U.S. DOT)
Hazardous Chemicals (OSHA)
Hazardous Substances (CERCLA)
Hazardous Waste (U.S. EPA & DOT)
Extremely Hazardous Substances (U.S. EPA)

It would be much easier if everyone spoke the same language.  The chemicals have not changed, just the way each regulatory agency views its' interaction with chemicals. 

I am relatively new to blogging, so with time, my posts will include pictures and if I am really ambitious, some videos.
 
One last thought, before hitting the books.  Even though powerpoints as a training tool are a necessary evil, I like to provide my students and clients with hands on skills testing and problem solving.  If you have any thoughts or ideas in this area, please let me know.  I would love to learn about them. 

Thanks to ckempt for a blog mention.   His blog is on my blog roll, "life under the lights".  Check it out

Stay safe,

Basic Chemistry for the First In Crews

Responding to day to day emergency incidents can sometimes turn into scenes involving release of hazardous materials. Recognition of these scenes may not always be obvious. Occupancy and location signs such as industrial, commercial or transportation can give clues as to what types and quantities of hazardous materials may be involved. Once on the scene has been isolated, the next step is to try to identify the product or products involved. Communication with property owners, law enforcement and eye witnesses involved can aid in identification. Basic resources such as the Emergency Response Guidebook (ERG) can give important basic information including health and fire precautions and evacuation distances, but are not always chemically specific. Another key component of hazmat determination is basic chemistry of the material that is released.

If the chemical is known, the basic chemistry of the product must be determined and understood. One of the first pieces of information to gather is whether the material is a solid, liquid or gas. By determining the state of matter, the path of exposure can be predicted, monitoring protocol can be established and the proper PPE can be selected. A solid that is spilled will usually stay where it was spilled, with only the weather factors such as wind and rain effecting the spread. Liquids tend to following the contour of the land and takes on the shape of their containers. Gasses want to dispererse or mix with the air and will be effected by wind currents. Gases will be the most mobile of the states of matter.

When dealing with solids, chemical properties of solubility, bulk density and melting point will help to determine if weather factors of rain, wind or temperature will effect the spread. Water is known as the universal solvent. A chemical that is soluble in water will dissolve when exposed to rain. Simply covering the material may allow for isolation until the material can be removed. The bulk density of a product relates how much a known volume of the product weighs, and can be expressed in pounds per cubic feet. For instance, a material such as flour, with a low bulk density, will be easily spread by a light wind. A material such as sand that has a high bulk density, will not. The melting point is the temperature at which a solid will become a liquid. Those substances with low melting points may be solids in the winter, but liquids in the summer. An example of this is water.

For spills involving liquids, land contour may allow the material to run and pool to low places. Chemical properties like solubility, specific gravity, vapor pressure and pH can aid in determining who to mitigate the problem. Solubility, as expressed in percent (%), is the amount of the material that can be dissolved in water. Specific gravity, when compared to water where water is given the value of one, will determine if the material will sink or float with respect to water. A liquid with a specific gravity of less than one will float on water, such as gasoline. Vapor pressure relates to how much vapor will be given off by the liquid from the surface. The larger the surface area of the spill, the greater the potential for vapors to be given off before the spill is mitigated. The pH of a liquid, which is a measure of corrosivity, determines whether the material is an acid or base. This is very important to know prior to monitoring, since corrosive vapors can wreak havoc on sensitive electronic instruments.

Vapor density and flammable range are useful for characterization of spills involving gasses. The vapor density of gases is similar to the specific gravity of liquids, only the comparison is air. Gasses with a vapor density greater than one will sink, where as gases with a vapor density of less than one will rise, with respect to air. Flammable ranges, which can used to characterize the vapors given off from a flammable liquid or a gas. The flammable range is defined as the difference between the upper and lower flammability limits. If the concentration is too lean to burn, it is below the lower limit. If the concentration is too rich to burn, it is above the upper explosive limit.

The chemical characteristics of pH and Flammability can be measured on scene with the appropriate instruments. Other properties such as vapor density, specific gravity and boiling point, to name a few, can be found in resource material such as the NIOSH pocket guide.

Knowing what material you are dealing with and understanding some of the basic chemical properties will enable the first in engine or responders to make a more informed decision as to initial isolation and personal protection.

For more information, contact us at our website, http://www.allrisktraining.com/