The Risk Management Tool Box Blog

Wyoming Rules on Fire Retardant Clothing

Graham Marshall - Wednesday, April 10, 2013

The Wyoming Department of Workforce Services (DWS) Occupational Safety and Health Administration (OSHA) is implementing rules that require flame-resistant (FR) clothing be worn by all workers within 75 feet radius of a well bore.

An additional new rule also that mandates emergency shut-down devices be installed on all diesel engines used on a drilling rig. 

The rules were proposed by the Wyoming Occupational Safety and Health Commission in October 2012. 

The new rules incorporate recommendations from a broad range of stakeholders and considered public comments received during a public hearing in October and input received over a 90-day public comment period. 

For more information about DWS’s OSHA division and services such as the Wyoming Safety Fund or the longstanding OSHA safety consultation program, call (307) 777-7786.

Simple Steps to Prevent Eye Injury

Graham Marshall - Sunday, March 17, 2013

There are a half-million eye injuries reported in the USA each year.  About 70,000 of these injuries occur in work places and result in lost time and increased costs.

But there are simple steps that every worker, and people in their own homes can take to keep eyes free from harm.

+   Firstly, keep workplace and household chemicals locked away from children;

+   Store chemicals in the appropriate container;

+   Almost anything that can splash into the eye can damage it, so make sure to wear appropriate eye-protection;

+   Always use safety guards which are fitted to powered equipment;

+   Pick up yard debris before using lawn-mowing equipment;

+   Wear eye-protection when cutting the grass and during other general gardening activity;

+   Use sports-specific eye-protection to avoid eye injury during sport activity; and

+   Always make sure protective eyewear fits properly and is replaced if damaged.

Simple Steps to Prevent Noise-induced Hearing Loss

Graham Marshall - Saturday, March 16, 2013

Hearing loss due to exposure to industrial noise is the number one disability in the World; which is sad since it is so easily prevented.

Noise-induced Hearing Loss (NIHL) occurs when sounds which are greater than 85-decibels (dB) damage the delicate, sensitive structures within the human ear.

Common causes of NIHL result from exposure to noise from chainsaws, hammer-drills, bull-dozers, powered lawn-mowers, motorbikes, diesel trucks, and factory machinery.

The Keys to preventing NIHL include:

+   Remain aware of noise as a hazard and take measures to protect yourself from high noise (above 85 dB);

+   If possible, remove or relocate noisy equipment from the working zone;

+   Limit the period of exposure to noise above 85 dB; and

+   If you must work in a noisy environment, always wear appropriate hearing protective devices, including earplugs, ear-muffs or noise-cancelling head-phones.


Is high-visibility clothing really necessary?

Graham Marshall - Sunday, March 10, 2013

There is no doubt that in some jobs high visibility clothing is absolutely necessary.

Anywhere that people and vehicles are in close proximity, for example.

At the roadside; on railways; or in maritime situations with a risk of "man overboard".

But is hi-vis really needed in offices?

Or for workers who visit people's homes or work in children in playgrounds?

What's the logic behind wearing hi-viz in those low-risk situations?

As Judith Hackitt, head of the UK Health and Safety Executive has recently identified, the spread of hi-viz clothing is symptomatic of the wider over-application of health and safety regulations.

It's a symptom of people presuming that something which is good and necessary in one circumstance must be good and necessary in all situations.

Except it isn't.

The need to clothe all adults and children in protective clothing has no basis in law.

Health and Safety Regulations covering protective clothing were introduced to help manage real risk, not as part of unthinking, blanket policies.

If you work in a high risk workplace, then hi-viz may be necessary.

But if there is little risk, then the law does not require you to wear hi-viz

We all need to be able to distinguish when it is necessary and when it is not.

UK PPE Regulations (2002)

Graham Marshall - Monday, March 04, 2013

In the United Kingdom, the Personal Protective Equipment Regulations (2002); and the Personal Protective Equipment at Work Regulations (1992, as amended) provide the main requirements to be met for Personal Protective Equipment (PPE) at work.

Other special regulations cover hazardous substances (including lead and asbestos), and also noise and radiation.

In the UK, every employer has a duty (where necessary) regarding the provision and use of PPE.

PPE is equipment that will protect workers against known hazards at work.

PPE can include items such as safety helmets, gloves, eye protection, high-visibility clothing, safety footwear and safety harnesses.

It also includes respiratory protective equipment (RPE).

Even where engineering controls and safe systems of work have been applied, some hazards might remain. These include hazards which could impact on:

+  The lungs (e.g., hazardous substances);

+  The head and ears (e.g., kinetic hazards and noise);

+  The eyes (e.g., kinetic hazards, radiation hazards (UV) or chemicals);

+ The skin (e.g., hazardous substances such as acids); and

+  The body, hands and feet (kinetic hazards, chemicals, bio-hazards, radiation sources, etc).

So, if PPE is still needed after implementing other controls, employers must provide the PPE for employees free of charge.

Employers must also choose the PPE carefully and ensure employees are trained to use it properly, and know how to detect and report any faults in the PPE.

In selecting and using PPE, the employer should ask: Who is exposed to the hazards and what type? How long are they exposed to the hazards? How much hazard are they exposed to?

When selecting and using PPE, make sure to select products which are CE marked in accordance with the PPE Regulations (2002).

Purchase only from reputable suppliers who can advise you on PPE equipment that suits the user. If in doubt, seek further advice from a specialist.

Employers must never allow exemptions from wearing PPE for those jobs that ‘only take a few minutes'.

And ensure that PPE is properly looked after and stored when not in use.

If the PPE is reusable, it must be cleaned and kept in good condition and regularly inspected according to a schedule.

Also ensure to use the correct replacement parts which match the original (e.g., respirator filters).

Types of PPE

Graham Marshall - Saturday, March 02, 2013

In the United Kingdom, the Personal Protective Equipment Regulations (2002); and the Personal Protective Equipment at Work Regulations (1992, as amended) provide the main requirements to be met for Personal Protective Equipment (PPE) at work.

Other special regulations cover hazardous substances (including lead and asbestos), and also noise and radiation.

In the UK, every employer has a duty (where necessary) regarding the provision and use of PPE.

PPE is equipment that will protect workers against known hazards at work and there are several specific types of PPE that can be used to protect specific parts of the human body.  These types are highlighted below.

+   Eyes - safety spectacles, goggles, face screens, face-shields, and visors. Make sure the eye protection chosen has the right combination of impact/dust/splash/molten metal eye protection for the task and fits the user properly.

+  Head and neck - industrial safety helmets, bump caps, hairnets and fire-fighters' helmets. Some safety helmets incorporate or can be fitted with specially-designed eye or hearing protection.  Don't forget neck protection, (e.g., scarves for use during welding).  And remember to replace head protection if it is damaged.

+   Ears - earplugs, earmuffs, noise-cancelling headphones, and semi-insert/canal caps.  Make sure to provide the correct hearing protectors for the type of work, and make sure workers know how to use them. Choose protectors that reduce noise to an acceptable level, while allowing for safety and communication.

+  Hands and arms - gloves, gloves with a cuff, gauntlets and sleeving that covers part or all of the arm.  Avoid gloves when operating machines such as bench drills where the gloves might get caught.  Some materials are quickly penetrated by chemicals so take care in selecting the correct gloves for the task.  Seek specialist advice if need-be.  Note that barrier creams may provide additional protection, but their use is unreliable and they should not be used instead of appropriate PPE protection.  Also note that wearing gloves for long periods can make the skin hot and sweaty, leading to skin problems. Using separate cotton inner gloves can help prevent this.

+   Feet and legs- safety boots and shoes with protective toecaps and penetration-resistant, mid-sole wellington boots and specific footwear (e.g., foundry boots or chainsaw boots).  Footwear can have a variety of sole patterns and materials to help prevent slips in different conditions, including oil- or chemical-resistant soles. It can also be anti-static, electrically conductive or thermally insulating.  In all cases, appropriate footwear should be selected for the identified hazards within the work being conducted.

+   Lungs – respiratory protective equipment (RPE).  Some respirators rely on filtering contaminants from workplace air. These include simple filtering face-pieces and respirators and power-assisted respirators.  Make sure any respirator in use fits properly.

There are also types of breathing apparatus which give an independent supply of breathable air (e.g., fresh-air hose, compressed airline and SCBA - self-contained breathing apparatus). The correct type and size of respirator filter must be used as each is effective for only a limited range of substances.

Filters have only a limited life. Where there is a shortage of oxygen or any danger of losing consciousness due to exposure to high levels of harmful fumes, only use breathing apparatus – never use a filtering cartridge

+   Whole body PPE- conventional or disposable overalls, boiler suits, aprons, chemical suits. The choice of materials includes flame-retardant, anti-static, chain mail, chemically impermeable, and high-visibility clothing.

And don't forget other protection, like safety harnesses or life jackets where these are needed.

+   There may also be a requirement to provide emergency equipment.  Careful selection, maintenance and regular and realistic operator training is needed for PPE equipment for use in emergencies, like SCBA, respirators and safety ropes or harnesses.

Find out more information by searching online for the following:

+  Respiratory protective equipment at work: A practical guide HSG53; and

A short guide to the Personal Protective Equipment at Work Regulations 1992 Leaflet INDG174 PDF.

Temperature Regulations in the UK

Graham Marshall - Tuesday, February 26, 2013

In the UK, the Workplace Regulations (Health, Safety and Welfare, 1992) outline particular requirements for most aspects of the working environment, including for temperature.

Regulation 7 deals specifically with the temperature in indoor workplaces and states that:

"During working hours, the temperature in all workplaces inside buildings shall be reasonable."

The application Regulation 7, however, depends on the type of workplace, such as a bakery, a cold store, an office, or a warehouse.

The associated Approved Code of Practice (ACOP) goes on to explain:

"The temperature in workrooms should provide reasonable comfort without the need for special clothing. Where such a temperature is impractical because of hot or cold processes, all reasonable steps should be taken to achieve a temperature which is as close as possible to comfortable.

'Workroom' means a room where people normally work for more than short periods.

The temperature in workrooms should normally be at least 16 degrees Celsius unless much of the work involves hard physical effort.  Under such circumstances, the temperature should be at least 13 degrees Celsius.

These temperatures may not, however, ensure reasonable comfort, depending on other factors such as air movement and relative humidity."
If the temperature in a workroom is uncomfortably high because of hot processes, the design of the building, or other environmental factors, then all reasonable steps should be taken to achieve a reasonably comfortable temperature, for example by:

+   Insulating hot plant, process equipment  or pipes;

+   Providing air-cooling plant;

+   Shading windows; 

+   Moving workstations away from places subject to radiant heat; and/or

+   Application of local cooling using air-conditioning.

In extremely hot weather fans and increased ventilation may be used instead of local cooling.

Where, despite the provision of those methods, temperatures are still not reasonable, suitable protective clothing, roster, and rest facilities should be provided.

Typical examples of suitable protective clothing would be ice vests, or air/water fed suits.

The effectiveness of these PPE systems may be limited if used for extended periods of time with inadequate rest breaks.

Where practical there should be systems of work (for example, task rotation) to ensure that the length of time for which individual workers are exposed to uncomfortable temperatures is limited.
HSE previously defined thermal comfort in the workplace, as: 'An acceptable zone of thermal comfort for most people in the UK lies roughly between 13°C (56°F) and 30°C (86°F), with acceptable temperatures for more strenuous work activities concentrated towards the bottom end of the range, and more sedentary activities towards the higher end.'

Preventing Sharps Injuries in the Healthcare Sector

Graham Marshall - Saturday, February 16, 2013

The UK Health and Safety Executive (UK HSE) has published a consultation document on proposed regulations to implement Council Directive 2010/32/EU on preventing sharps injuries in the hospital and healthcare sector.

The consultation document establishes the UK HSE’s proposals for new regulations that are titled "The Health and Safety (Sharp Instruments in Healthcare) Regulations" (2013).

The new regulations are required under European Union legislation.

The new regulations will require employers in the healthcare sector to introduce arrangements for the safe use and disposal of medical sharps, to provide information and training to employees, and to record, investigate and take action following a sharps injury.

The regulations will also introduce a duty on healthcare workers to promptly report any sharps injury to their employer.

The consultation seeks views on:

1. Whether the proposed regulations enable healthcare businesses and workers to identify what they need to do?

2. The initial assessment of the costs and benefits of the proposed changes; and

3. How the regulations should be supported by guidance and who is best placed to provide that guidance?

 A consultation questionnaire is available from Martin Dilworth at the UK Health and Safety Executive:

5S2 Redgrave Court
Merton Road
L20 7HS
Tel No: 0151 951 4335      
Fax: 0151 951 4575

Dangerous Use of Scaffolding

Graham Marshall - Monday, February 11, 2013

Regulation 6(3) of the UK Work at Height Regulations (2005) states: "Where work is carried out at height, every employer shall take suitable and sufficient measures to prevent, so far as is reasonably practicable, any person falling a distance liable to cause personal injury".

So why on earth did Stretford Scaffolding Ltd allow its workers onto an unsafe scaffold outside this row of terraced shops in Oldham (UK)?


As you can see, neither of the two men on the scaffold are wearing harnesses, despite working up to six metres above the ground.

There are also no guard rails on parts of the scaffold to prevent the workers falling.

Thankfully, this shoddy situation was spotted by a passing inspector from the UK HSE who issued an immediate Prohibition Notice and got the workers out of the danger zone.

Stretford Scaffolding Ltd, was then prosecuted and received a 12-month conditional discharge and was ordered to pay costs of £1,849 after admitting a breach of the Work at Height Regulations 2005.

Safety Alert for Completions Rig Work At Height

Graham Marshall - Wednesday, December 05, 2012

This safety alert from APPEA in Australia highlights how a Floorman went to the derrick monkey board to put a stand of drill pipe in the elevators.

He attached the hold back line but failed to transfer from the crown fall arrestor to the monkey board fall arrestor.

During the operation the blocks were lowered, snagging the secondary line.

This resulted in the Floorman being pulled forward onto his knees parting his lanyard.

Thankfully, no injuries sustained during the incident.

The investigation illustrated that the relevant procedure was not reviewed before task was performed.

The key learnings were identified as being the need to review procedure for the task prior to starting and to ensure procedures are up to date and include installing safety devices.

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