The Dentist, a Colonoscopy and… OSHA?
After reading the title, you might be wondering what all this has to do with health and safety? Well, we want to avoid all three of these things, or at least put them out of our minds for now. Some of us put them out of our minds until we have symptoms, like a toothache, or until one of our employees has a small accident. Then we say, “You know - maybe we should have safety meetings once a week.” Does this sound familiar?
My name is Ron Valega. I am an IICRC instructor for water, fire, odor and health and safety. I owned a Servpro franchise for about 25 years before selling my business to become a full-time instructor. When did I get serious about health and safety? Not until I started to get into workmen’s comp issues - small accidents. Not that my parent company didn’t have that information, I just chose to focus on other things like sales, production and the everyday issues of running a business. So I want to make a big statement here and I believe this 100% - I don’t believe there is an owner out there who wants to hurt anyone. The problem is we just don’t know what we don’t know! The word “OSHA” to me was like the KBG! I was scared to death of them!
Then I was asked to become the Technical Advisor Committee chairperson for the IICRC for Health and Safety. That meant I had to take a class through OSHA called the “OSHA Outreach Trainer course.” Then, and only then, did I realize that OSHA is there to help us, not frighten us. It opened my eyes and the fear was gone. In fact, OSHA has a consultation program and they will come out to your business, conduct a walk through and not fine you. When I teach the IICRC Health and Safety, I convince the students to call for their free Full Service Safety Survey.
Let’s talk about some key issues that all restoration contractors must deal with regarding safety. Whether you have one employee or 50, following are the items you must have in place:
Hazard Communication Program
You must have a written Hazard Communication Program (HCS) in your place of business. This standard is based on a simple concept - that employees have both a need and a right to know the hazards and identities of the chemicals they are exposed to when working. They also need to know what protective measures are available to prevent adverse effects from occurring.
The Hazard Communication Program is designed to provide employees with the information they need. OSHA has provided a simple summary of the HCS in a pamphlet entitled “Chemical Hazard Communication, OSHA Publication Number 3084.” A copy may be obtained from your local OSHA-area office or at their website, osha.gov. If OSHA inspects your workplace, they will want to see a copy of your written program.
Other items in this program deal with identifying hazardous chemicals, how to prepare and implement the program, material safety data sheets, employee information and training, labels and other forms of warning. Most of us who own a restoration business make the same mistake over and over, and that is we don’t always hire people the right way. We hire when we get slammed! If you have a valid driver’s license and could pass a drug test, we throw you out on the truck the next day. You’re going to love this - according to the OSHA Standards for General Industry (29 CFR 1910) in the Hazard Communication Standard 1910.1200(h), employers shall provide employees with effective information and training on hazardous chemicals in their work area at the time of their initial assignment. Maybe we need to rethink this and have at least a one-day orientation program in place where we can go over the chemicals they are going to be using, show them how to read a material safety data sheet and make sure they understand them.
Respiratory Protection Program
OSHA requires the employer to develop and implement a written respiratory protection program with required worksite-specific procedures and elements for required respirator use. The employer shall provide respirators, training and medical evaluations at no cost to the employee. The employee must fill out a medical evaluation questionnaire of 20 questions and it must be reviewed by a health care professional to make sure they can wear a respirator. Once you are cleared, you then must do mandatory fit testing procedures on each employee. From teaching the water class and the fire class, I’m shocked at the students that have not been fit tested. You can’t just throw them a respirator and say go to work. I need to add here that some states may have different OSHA regulations so you need to check if your state has their own program, which is supposed to be just as strong or stronger than the Federal OSHA. Once again, see osha.gov.
We might as well talk about osha.gov. It’s a great website and very user friendly. It has free hand outs and all the posters that you are required to have are on there too. YouTube presentations that are well put together are available. When I teach the IICRC Health and Safety class, I try to make it industry specific to the restoration industry and cleaning industry. The IICRC is in the process of trying to make the new exam to fit all countries. The requirements of this new section are intended to be consistent with the provisions of the United Nations system of classification and labeling of all chemicals. Stay tuned! Our goal is to put together an exam that all countries can use.
Blood Borne Pathogens Written Program
If you clean sewage, this is a must. This section applies to all occupational exposure to blood or other potentially infectious materials. Each employer having employees with occupational exposure shall establish a written exposure control plan designed to eliminate or minimize employee exposure. All of these programs must be made available to the OSHA inspector upon request, and must be updated annually. This section talks about how your equipment must be cleaned and decontaminated with the appropriate disinfectant. This section also explains your Hepatitis B vaccinations information. Example - the employer shall make available the Hepatitis B vaccination series to all employees who have occupational exposure. This must be made available at no cost to the employee.
These are just the major items we need to be concerned with in our business. There are several OSHA 10-hour courses available, however they are not specific to our industry and I feel the IICRC Health and Safety class is. Plus, when you take the IICRC Health and Safety class, you get a 10 hour completion card from OSHA and you get to take the IICRC exam and get that certification added to your IICRC card.