Silica Enforcement Delayed for those in Construction 

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By Rachel Morgan, MPH, ASP
EHS Specialist at Palmetto EHS

The enforcement date for OSHA’s new Crystalline Silica in Construction Standard has been delayed from June 23, 2017 until September 23, 2017. The delay in enforcement is in order to give OSHA more time for the “development of additional guidance materials” as well as to give them “the opportunity to conduct additional outreach to the regulated community and to provide additional time to train compliance officers.” OSHA has released Fact Sheets about the new respirable crystalline silica rule for both construction and general industry employers, however at this time a Small Entity Compliance Guide has only been released for those covered by the construction standard. Sometime in the spring of 2017, they are expected to also release a Small Entity Compliance Guide for those covered under the general industry and maritime standards. Although enforcement of the written Silica Exposure Control Plans for those in construction will not commence until September 23, 2017, it is advisable that those covered by the new rule begin the development and implementation of Exposure Control Plans now. If you need help writing your Exposure Control Plan or sampling for respirable crystalline silica, contact us.

For more information about the delay of enforcement, see , and for more information from OSHA about the new silica rule, see

Beryllium Rule Effective Date Delayed

In February, we posted an article about OSHA’s final rule on beryllium in the workplace and noted that the the effective date of the final rule had been pushed back from March 10, 2017 to March 21, 2017. That effective date has now been postponed to May 20, 2017. The delays in the effective date of the final beryllium rule are due to the “Regulatory Freeze Pending Review” memorandum and is intended to give OSHA more time to review, evaluate, and asses the rule. Although the effective date of the beryllium rule has been pushed back, the compliance dates within the rule will not change, and most of the rule becomes enforceable on March 12, 2018. Contact us if you need help becoming compliant with the final beryllium rule.

OSHA Issues Final Rule on Walking-Working Surfaces and Fall Protection Standards

rachel photo-websiteBy Rachel Morgan, MPH, ASP
EHS Specialist with Palmetto EHS

The update to the Walking-Working Surfaces and Personal Fall Protection Systems Standards is expected to prevent 29 deaths each year and is meant to help employers performing both construction and general industry activities, as it aligns some of the general industry requirements for fall protection with those already in place for construction. Workers will be better protected under the new rule because it incorporates consensus standards, best practices in the industry, as well as advances in technology to update and clarify the standards, as well as add requirements for employee training and inspections. The new rule allows employers more flexibility in their selection of fall protection, it requires that exposed workers be trained on fall hazards, existing fixed ladders (over 24 feet) must be equipped with a cage, well, personal fall arrest system, or ladder safety system, among other requirements. While the effective date of the final rule was January 17, 2017, a few of the requirements have staggered effective dates. Most of the staggered effective dates range from 6 months to two years, however the requirement for replacing cages and wells on all fixed ladders (over 24 feet) that have personal fall arrest systems or ladder safety systems does not become effective for another 20 years. For more information and to see all of the requirements included in the final rule, see

OSHA Top 10 Violations for Fiscal Year 2016

OSHA’s Top Ten Violations for Fiscal Year 2016

These are the top ten OSHA violations for fiscal year 2016, which covers all violations cited by Federal OSHA from October 1, 2015 to September 30, 2016.

  1. Fall Protection in Construction (1926.501) (1st in 2014 and 2015)
  2. Hazard Communication (1910.1200) (2nd in 2014 and 2015)
  3. Scaffolding in Construction (1926.451) (3rd n 2014 and 2015)
  4. Respiratory Protection (1019.134) (4th in 2014 and 2015)
  5. Lockout/Tagout (1910. 147) (5th in 2014 and 2015)
  6. Powered Industrial Trucks (1910.178) (6th in 2014 and 2015)
  7. Ladders in Construction (1926.1053) (8th in 2014, 7th in 2015)
  8. Machine Guarding (1910.212) (9th in 2014 and 2015)
  9. Electrical – Wiring Methods (1910.305) (7th in 2014, 8th in 2015)
  10. Electrical – General Requirements (1910.303) (10th in 2014 and 2015)

If your company needs help addressing issues related to these highly cited violations, contact us.

Do Your Employees Have Exposure to Hexavalent Chromium?

Safety, industrial hygiene, OSHA compliance, training

By Rachel Morgan, MPH, ASP

Hexavalent chromium is a form of chromium that is present in many industrial operations and can cause a variety of illnesses. Welding on stainless steel is one of the main sources of hexavalent chromium exposure in the workplace. Other sources of exposure include smelting of ferro-chromium ore and chrome plating with chromic acid. Hexavalent chromium is a carcinogen and has the potential to cause lung cancer, respiratory tract irritation, and damage to the skin and eyes. Wheezing and shortness of breath are sometimes found in workers who become allergic to hexavalent chromium over time as well.

The Occupational Safety and Health Administration (OSHA) has both an Action Level (2.5 µg/m3) and a Permissible Exposure Limit (5.0 µg/m3) for hexavalent chromium. If initial monitoring of workers indicates that that they are exposed above the Action Level, employers are required to begin sampling every six months, however if workers are exposed above the Permissible Exposure Limit, employers are then required to sample every three months. If controls are put in place and resampling indicates that exposure has dropped below the Action Level, then the sampling can be discontinued if the results are confirmed by a second sampling event taking place a minimum of seven days later.

Any time conditions change in the workplace, such as a change in materials, equipment, ventilation, other control methods, processes, etc., the employer is required to perform sampling if they have any reason to believe that employee exposure is above the Action Level. In addition to the sampling requirements, OSHA’s Hexavalent Chromium standard also stipulates various other requirements, such as housekeeping, medical surveillance, hygiene areas, PPE, etc., when employees are exposed above OSHA limits.

If you are in need of initial sampling, periodic sampling, or sampling because you’ve implemented controls, contact us and we’ll be happy to help.

Emergency Preparedness

By Rachel Morgan, MPH, ASP, EHS Specialist at Palmetto EHS

While we all hope to never have to act upon our emergency action plans, there will be times when it will be unavoidable. In October of 2015, South Carolinians had to deal with the “1000 Year Flood,” and last week, in the midst of hurricane season, Hurricane Matthew. Preparing for an emergency, such as a hurricane, prior to the event saves lives, and is one of the many reasons why OSHA requires employers to have emergency action plans.

Although the training requirements vary based on the processes at the workplace, the materials on site, the number of employees, etc., one of the vital components of the emergency action plan includes training of employees on evacuation plans, shutdown procedures, alarms, reporting procedures, etc. In addition to this type of training, employers should also be conducting drills (at least annually) so that what to do in the case of an emergency is not a question for employees. Remember the saying “proper preparation prevents poor performance?” That applies here as well – if your employees have been prepared for what to do in the case of an emergency, their performance will result in fewer injuries and less confusion during and after the evacuation and/or incident. Following a drill is the best time to evaluate the efficacy of the drill and the emergency action plan, and to make the appropriate changes needed.

OSHA’s “Evacuation Plans and Procedures eTool” outlines the minimum requirements of the emergency action plan and include the following:

  • Means of reporting fires and other emergencies
  • Evacuation procedures and emergency escape route assignments
  • Procedures for employees who remain to operate critical plant operations before they evacuate
  • Accounting for all employees after an emergency evacuation has been completed
  • Rescue and medical duties for employees performing them
  • Names or job titles of persons who can be contacted.

For more information on hurricane specific information, visit and contact us if you need help developing an emergency action plan of your own.

Respiratory Protection: Are You in Compliance?

Respirator Fit TestingBy Rachel Morgan, ASP
EHS Specialist at Palmetto EHS

Respiratory protection in general industry was the 4th most frequently cited OSHA standard by Federal OSHA in fiscal year 2015. With 5 million workers estimated to be wearing respirators, we thought it would be a good time to talk about achieving or remaining in compliance with OSHA’s Respiratory Protection Standard.

To begin, employers must have a written Respiratory Protection Program in place for employees using voluntary or required respirators (the written program is not required if employees are wearing dust masks voluntarily).

Employers must also ensure that employees are medically able to wear the respirator through a medical evaluation using a medical questionnaire that includes all of the information contained in Appendix C of OSHA’s Respiratory Protection Standard.

After employees have been medically cleared to wear the respirator, they must then be fit tested for all tight fitting facepiece respirators. It is also important, and required by OSHA, that the fit test be conducted with the same make, model, style, and size of the respirator that the employee will be using in the workplace. The fit testing can be performed quantitatively or qualitatively.

Once these steps have been completed, the employer must ensure that the respirators are being maintained appropriately, which includes cleaning and disinfecting, storage, inspection, and repair of the respirators.

Employees wearing respirators must also go through training about the respirators and their use. OSHA’s Respiratory Protection Standard outlines the topics that employees must be able to demonstrate knowledge about after going through training. The fit testing and training aspects are annual requirements required by OSHA.

If it has been more than a year since your employees were fit tested and trained, or if you need medical evaluations or help developing a written Respiratory Protection Program, contact us and we’ll help you get into compliance.

For more information on specifics regarding respiratory protection, please visit

Protecting Workers from Exposure to Zika

mosquitoBy Rachel Morgan, MPH, ASP, EHS Specialist at Palmetto EHS
Locally transmitted mosquito-borne Zika cases are slowly edging their way closer to South Carolina. Four cases were reported in Florida last week and mosquitoes in two areas within Miami-Dade County, including part of Miami Beach, are spreading the virus. Aedes aegypti and Aedes albopictus mosquitoes, both found in the southern United States, can carry the Zika virus and are aggressive daytime bitters (however, they will also bite at night). If bitten by one of these mosquitoes carrying the virus, roughly one out of five people will develop symptoms between two and seven days following the transmission. Symptoms include red/pink in the eyes, joint pain, rash, fever, and sometimes muscle pain and headaches as well.

Workers that spend most of their time outdoors likely have the greatest risk for exposure to the Zika virus. Because of this, OSHA has recommended the following for outdoor workers:

  • Inform workers about their risks of exposure to Zika virus through mosquito bites and train them out to protect themselves.
  • Provide insect repellents and encourage their use. (Appropriate insect repellents will contain an EPA-registered active ingredient.)
  • Provide workers with, and encourage them to wear, clothing that covers their hands, arms, legs, and other exposed skin. Consider providing workers with hats with mosquito netting to protect the face and neck.
  • In warm weather, encourage workers to wear lightweight, loose-fitting clothing. This type of clothing protects workers against the sun’s harmful rays and provides a barrier to mosquitoes. Always provide workers with adequate water, rest, and shade, and monitor workers for signs and symptoms of heat illness.
  • Get rid of standing water whenever possible to reduce or eliminate mosquito breeding areas. Train workers about the importance of eliminating areas where mosquitos can breed at the worksite.

If requested by a worker, consider reassigning anyone who indicates that she is or may become pregnant, or who is male and has a partner who is or may become pregnant, to indoor tasks to reduce their risk of mosquito bites.

In addition to outdoor workers, healthcare workers and those that work in labs who may be exposed to blood or other bodily fluids containing the virus are also at an increased risk for exposure to the Zika virus. OSHA has also released guidelines to help protect these workers as well. To see these guidelines and recommendations, as well as get more information about workers and the Zika virus, please visit!tab1.

Are You GHS Compliant?


By Rachel Morgan, MPH, ASP, EHS Specialist

Are you GHS compliant?

June 1, 2016 has come and gone. Have you revised the labels on your chemicals, updated your Hazard Communication Program, and provided your employees training on any additional hazard communication items needed?

Labels must be placed on the container of every hazardous chemical in the workplace, and under the new GHS standard, they must contain the product identifier, signal word, hazard statement(s), pictogram(s), precautionary statement(s), and the name/address/phone number of the responsible party. Additionally, your Hazard Communication Program should have been updated include all aspects of the GHS standard, and your employees should have been trained on any additions to your Hazard Communication Program.

If you need assistance getting compliant with GHS, whether its getting all of your chemicals labeled appropriately, training your employees, or updating your Hazard Communication Program, contact us and we can provide these services for you.

OSHA’s Revised Record Keeping Rule Requires Online Reporting

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By Rachel Morgan, MPH, ASP, EHS Specialist at Palmetto EHS

OSHA’s Recording and Reporting Occupational Injuries and Illnesses regulation has been revised under a new OSHA final rule that becomes effective January 1, 2017. The rule was proposed in 2013 and includes requirements for electronic submission of injury and illness data as well as anti-retaliation protection for employees. The injury and illness data that employers in specific industries will now have to submit electronically is data that they are already required to record on their OSHA Injury and Illness forms. Under the new rule, the type of industry and the number of employees determines how often and what specific information each employer must submit electronically. Currently, OSHA estimates that it will take 20 minutes to create an account and enter the required information for establishments with 20 to 249 employees, and 20 minutes plus another 12 minutes per injury or illness recorded on the OSHA 300 and 301 Forms for establishments with 250 or more employees. The data submitted will be posted on a website that is available to the public with the hope that it will urge employers to focus on reducing workplace injuries and illnesses as well as provide timely data to researchers with the goal of improving workplace safety and health. Employers will also be able to use this data as a benchmark for their safety performance with other companies in the same industry, something employers have not been able to do in the past.

In order for the objectives of the new rule to be met, employees must not be concerned about retaliation from employers for reporting workplace injuries and illnesses. Consequently, the new rule also requires employers to not retaliate against employees for reporting injuries and illnesses (incorporates the existing statutory prohibition), to “inform workers of their right to report work-related injuries and illnesses free from retaliation,” and clarifies the current requirement to have practical methods for employees to report injuries and illnesses that will not dissuade employees from doing so.

OSHA expects that the new rule will help improve the health and safety of workplaces across the United Sates.

For more information please visit: