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​Ignorance Of The Law Is Still No Excuse

4/24/2018

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PictureThe courts agree: Knowledge of OSHA regulations is essential to safe work without serious citations.
​Last week, a federal appeals court upheld an OSHA penalty against a Georgia contractor who failed to provide proper fall protection to an employee who later died as a result of an on-the-job accident. The judgement of the court was that “ineffective training”, as the ruling called it, could not be used as an excuse against serious OSHA fines.
 
The ruling came from The U.S. Court of Appeals for the 11th Circuit, and was directed at Martin Mechanical Contractors of Athens, GA. Martin was cited for a willful violation and fined $49,000 by OSHA after an investigation into the death of an employee in late 2015. The worker fell through a ceiling opening where a skylight would be installed later. The opening was only covered by a plastic sheet, and the worker was not wearing any fall protection, even though his supervisor had the correct PPE on-site. The fall was to a concrete floor from a height of 15 feet, and the worker died in the hospital from his injuries. 
 
Martin Mechanical claimed that the job foreman was unaware of the regulations that apply to this kind of work, and the company sought relief from the OSHA penalty on this basis. The federal court and a preceding administrative law judge both dismissed this claim, making it clear that a claimed ignorance of the regulations is no excuse for those rules to not have been followed.
 
Findlay All Hazards’ familiarity with the case ends with what has been reported in articles like this one. But we believe the most severe result of this situation, the loss of a life, could have been avoided if safety training were taken to heart. Some link in the information chain, between the creation of the fall-protection regulations (which were recently updated) and the worksite, was broken… Or perhaps never forged. And sometimes, what seems like a short fall distance (in this case, just 15 feet) is sadly not treated as a high risk, because it seems like a height that would not cause serious injury. The Georgia case proves otherwise. 
 
And the OSHA regulations disagree, too: “OSHA requires that fall protection be provided at elevations of four feet in general industry workplaces, five feet in shipyards, six feet in the construction industry and eight feet in longshoring operations,” according to OSHA.gov (see 29 CFR 1926 for the construction industry specifics). The height of the skylight in Martin Mechanical incident was two and one-half times the minimum height where fall protection standards should have been applied. 
 
With ignorance of the rules clearly not an acceptable means to defend against citations, and with lives in danger even from fall distances that may appear tolerable to some, contractors of all nature must engage and depend upon clear, complete training to stay legal and safe. Simply posting the regulations and acquiring PPE is not sufficient. Workers need to be taught the safety mindset, so that there is never a question or hesitation about when to don the right safety gear. 
 
Findlay teaches thousands every year how to protect themselves and their crews from terrible incidents. We can help you train your entire team to work safer every day and everywhere. Talk to a Findlay All Hazards program manager today. 

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Scan In, Scan Out

4/17/2018

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PictureResponse teams can't function at full strength unless everyone is accounted for all the time.
One challenge of emergency response scenarios can be keeping track of those responders, administrators, and volunteers who are attending to the incident. Who is on-site? Is the haz-mat team that was here an hour ago still engaged in a hot zone as the clean-up phase begins elsewhere?
 
Using simple tech to scan the IDs of personnel arriving at the scene is a great way to stay aware of everyone involved. Another way to manage the on-site team is to issue color-coded badges to each person who responds to the incident before they start their tasks. Emergency managers everywhere might take a lesson from their counterparts in Nebraska, who have developed a color-badge system as part of their planning for future weather catastrophes. And they’re wise to plan: Nebraska is a storm-prone state, chalking up over 2,600 tornadoes between 1953 and 2013, with the month of June alone accounting for about 1 in 3 of those storms, according to ustornadoes.com. Imagine trying to manage a disaster scene as large as a tornado might cause without good coordination of everybody in the response team. 
 
Badges of a certain color might indicate the job classification and work zone that pertains to the person with that badge. A unique ID code on the badge corresponds to the badge-holder’s name and other vital information about that person. So, not only does a quick scan of the badge or card log in the responder or manager, it denotes where that person is permitted to go. Gatekeepers at certain points can quickly spot a badge of a color that is not allowed in their zone and redirect them to the area where they are needed. 
 
And keeping tabs on the people on-site can be done with existing identification cards, too, including the one ID most any responder is likely to have – their driver’s license. Companies like Infinite Peripherals and eSeek make magnetic stripe scanners, some that work as an add-on to mobile phones. That means an Incident Commander or his or her adjutant can rely on their handiest piece of technology to scan in the arriving personnel. They can then give them the color-coded badge that allows them into the proper zone. If that responder needs to be located, the database will show that they are on-site, and the zone where they should be working. 
 
Scanning out helps solve the problems that can come from teams exiting a disaster scene without notifying the command center. Many times, radio traffic and the demands of the emergency management team clutter up communication in the final phases of an incident. Personnel that are ready to leave try to check out with the Incident Commander, but they cannot locate that person or have trouble reaching them by radio. If there is a central card-scanning point connected to a local network, exiting teams can scan out there as they are released by their department head. The database can notify the Incident Commander that some responders are now moving off-site, and that means they are accounted for, without a merry-go-round of radio calls and ‘look-and-see’.
 
Finding the right technology is part of preparing for emergencies. Another part is training and drills, and Findlay All Hazards trains thousands of people to respond to a range of incidents and crises each year. How can we help you be better prepared? Talk with a Findlay manager today. 

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Better Emergency Communication Pathways

4/10/2018

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At Findlay, we’re in the last steps of preparing for an active shooter drill for a large US appliance manufacturer. Our team will be working with the plant’s security managers, state and local law enforcement, fire services, EMS, and others to stage a mass evacuation as would happen in the event of a person using a firearm at the factory. This is full-scale simulation: The drill will take place on a workday, with hundreds of employees in the plant.
 
As we get ready for this exercise, we look very carefully at how the local community would be alerted if an emergency of this scale ever happened. Obviously, in an active shooter scenario, the public has to be warned to stay away from the crisis zone. Once the story breaks, family members of the company’s employees will be desperate to get updates, and certain parts of the response teams will also depend on public communication to be sure they are in the right place at the right time. 
 
Traditionally, information about an ongoing crisis of this kind would come from a Public Information Officer and a company representative appearing before the media, in a press conference style setting. The advent and growth of the Internet changed this drastically, and much urgent information in crises is now disseminated via websites, social media platforms, and text message lists, in addition to press briefings. 
 
Even with the ubiquity of Facebook and Twitter, however, depending on social media and other app-based messaging as the chief means to update the public may not be the best strategy. A recent article at govtech.compoints out that each time that emergency managers initiate an update for the public, the effort might take as long as an hour and twenty minutes to complete. Getting a new message to the media, then posting to a website, and following that with social media and email or text alerts – all with proper gatekeeping – could indeed take some time. Synchronous delivery, careful coordination, and practice can certainly improve the time predicted by the article. Regardless, the recommended alternative is one that all local emergency managers, as well as EHS and security heads, should know: a mass notification system that works with a Federal Emergency Management Agency communication conduit known as IPAWS. 
 
IPAWS stands for Integrated Public Alert and Warning System, and as the govtech.com piece says, it provides “the distribution of messages to national emergency communication channels, such as the emergency alert system (EAS), weather radios, and the wireless emergency alert (EAS) system. Through the use of these non-subscription based channels, public safety officers can reach travelers and other non-citizens who may be in danger.” Think of IPAWS as a one-step messaging platform that forwards your alert to government-authenticated means of reaching the public. These include the Emergency Alert System, which puts the message on radio and television (as it would for a tornado or other natural disaster), and the Commercial Mobile Alert System, which broadcasts messages to cell phones. Internet pathways are also included. 
 
IPAWS is the same system that the Federal government would employ to notify the country of a national disaster. But it also can be used by a local authority to geo-target a particular area when a regional crisis occurs. To take advantage of IPAWS, local officials must apply for access and train to use it. Corporate EHS and security managers can insert information about an emergency that originates at their facility into IPAWS only through that local authority. 
 
Certain businesses allow for the idea that their manufacturing processes represent a greater potential danger to their neighbors and community. A petroleum refinery, for example, does present a greater risk to its area than, say, a furniture manufacturing plant. That’s why refineries will have a very comprehensive emergency plan, including public information. But history tells us that both the energy company and the furniture maker could suffer from an active shooter event. And should that dire circumstance happen, they both need to advise the community about the situation. All best means should be used in that case, and that includes knowing who is connected to IPAWS and being ready to work with that person or team. 
 
Findlay All Hazards teaches companies of all kinds how to respond to an active shooter emergency across all facets. Prevention, evacuation, communication, and all else. Find out more by talking with a Findlay expert today. 
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Bug-Out Or Hunker Down?

4/3/2018

 
PictureWhether fleeing a disaster or sheltering in place, do you have all you need to survive until help arrives?
Here in Ohio, we deal with a consistent threat of serious impact from bad weather. Like the rest of the Midwest, we think about the consequences of snow and ice in the winter, and flash floods, tornadoes, and extreme heat in the summer months. And as some locals say, “Spring and fall ain’t always picnics, either.”
 
Of course, people in almost any part of the U.S. can offer the same comment. Extreme weather takes a number of forms, depending on geography and the time of year. And storms and other harsh conditions are only one category of adverse effects on industry. Emergencies that can shut down your plant and strand employees can come in many forms. A big winter storm can shut down your facility, and so might a local industrial accident – say, a toxic release from a nearby manufacturer, or a derailment.
 
An article in one of Ohio’s many fine small-town newspapers caught our eye this week. Writer Ron Brohm talks about the utility of “bug-out bags”… That collection of essential items that a well-prepared person has ready for a time when they may need to suddenly leave their environs and survive for as much three days without other support. As Brohm says, bug-out bags are recommended by FEMA, and might contain a myriad of items, from non-perishable food to solar battery chargers. The list is principally dictated by a circumstance like those people in the gulf states faced in 2005 in the aftermath of Hurricane Katrina: One where an evacuee might have to take care of themselves for three days until local authorities, the National Guard, or the Red Cross can reach them to offer care.
 
Keeping a bug-out bag at the home or office is a good idea, certainly. But what if the condition that effects your facility is one where shelter-in-place is a good strategy? A flash flood might be a good example – or a blizzard. 40 years ago, Ohio was hit by a winter storm that locals speak of to this day, with recollections of being trapped at their workplaces for two or three days in the aftermath. In conditions like that, especially in rural areas, do your employees have items near them that would help get them through a 72-hour period of isolation and duress? Fire extinguishers are strategically placed throughout any manufacturing plant, along with other tools for incident control and remediation – safety showers, battery-powered lighting, etc. Why not a wall cabinet with blankets, water, external cell-phone batteries (and various adapters) and a compact assortment of other inexpensive survival items? The cabinet can be soft-sealed with tape that identifies the contents as for emergencies only. So, opening the cabinet or box would be about the equivalent of breaking glass on a fire alarm.
 
Some of Findlay All Hazards’s clients have large ‘spill cabinets’ in various points in their facilities. These rolling cases contain what the customer needs if there is an accidental release of fluid in that area. Cabinets like these might also have the ‘hunker-down box’ inside.
 
At Findlay, sometimes we like to think inside the box… What can we put in a nearby container that helps your employees remain safe and comfortable during a stressful incident? Sometimes the answer is a boom and absorbent kit, for cleaning up a spill. Sometimes, it’s a case of energy bars.
 
Strategies for emergency response are part of great EHS training. Talk to Findlay today about your business and the means to protect your people in any circumstance. 

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