A new year always brings changes to health and safety regulations and requirements. The number of OSHA inspections increased in 2021 from the previous year, and this trend is likely to continue into 2022. It is therefore imperative to ensure that your facility’s safety programs are up to date, safety training is being routinely conducted, and records are being properly kept. A good way to ensure that the safety programs are in order is to conduct a thorough safety audit of all programs, procedures, trainings, and records to ensure that the facility is in compliance with OSHA requirements.
In 2022, OSHA is expected to focus on heat illness prevention. As global temperatures continue to rise, it can be easy to succumb to job-related heat stress while working. Heat is the leading cause of death among all weather-related phenomena, and excessive heat can cause heat stroke or exacerbate existing health problems like asthma, kidney failure, and heart disease. Because of this, OSHA announced that it will begin implementing an enforcement initiative on heat-related hazards and will develop a National Emphasis Program (NEP) on heat inspections. OSHA area directors are expected to perform the following:
- Prioritize inspections of heat-related complaints, referrals and employer-reported illnesses and initiate an onsite investigation where possible.
- Instruct compliance safety and health officers to conduct an intervention (e.g. providing the agency’s heat poster/wallet card, discuss the importance of easy to access cool water, cooling areas and acclimatization) or opening an inspection when they observe employees performing strenuous work in hot conditions while on site visits.
- Expand the scope of other inspections to address heat-related hazards where worksite conditions or other evidence indicates these hazards may be present.
In addition, OSHA published an Advance Notice of Proposed Rulemaking for Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings on October 27, 2021 that will prioritize activities occurring where the heat index exceeds 80 degrees Fahrenheit.
Because of this new emphasis on heat-related illness, you should conduct a hazard assessment to identify potential heat-related risks and implement controls to help protect your workers from outdoor and indoor heat exposure. The following can be done to protect your workers from heat illness:
- Ease new employees into work. Nearly 3 out of 4 fatalities from heat illness happen during the first week of work because workers have not built tolerance to heat (acclimatized). Because of this, new employees should take frequent breaks and should work no more than 20% of the shift’s duration at full intensity in the heat on their first day. Increase the duration by no more than 20% a day until workers are used to working in the heat.
- Provide employees with cool drinking water and instruct employees to drink cool water, even if they aren’t thirsty.
- Provide cool or shady rest areas and instruct employees to take sufficient breaks.
- Ensure employees are dressed for the heat. Hats and lightly-colored, loose-fitting, and breathable clothing should be worn if possible.
In addition to heat-related illness, OSHA is continuing to focus on combustible dust hazards at industrial facilities. Facilities are being inspected for housekeeping procedures, fire prevention, and electrical fixtures in areas with combustible dust accumulations, and OSHA is checking if facilities have completed the required dust hazard analysis (DHA) in accordance with the National Fire Protection Association (NFPA). Many insurance companies are also requiring their insured facilities to have a DHA conducted. Consensus standard NFPA 652 states that a DHA should have been completed by September 7, 2020 for most general industry facilities. Agricultural and food processing facilities refer to NFPA 61 which states that a DHA was to be completed by January 1, 2022. Once a DHA is complete, both NFPA 61 and 652 require DHAs to be recertified every five years. This DHA is the due diligence needed for a facility to counter any claims by an OSHA inspector of combustible dust hazards.
Also in 2022, OSHA will begin more training and briefings on robot safety in industrial settings. They will be asking for a facility’s risk assessment of the robot systems, as required by ANSI R15.06-2012. Their training will include how to review a risk assessment to ensure it is adequately comprehensive and properly covers potential risks in a robot system, corresponding to the tasks performed by and within the system. Violations related to this can include lockout/tagout, machine guarding, electrical fixtures, slips, trips, falls, and the general duty clause for not properly identifying workplace hazards. CTI is actively participating in the formation of these training to ensure we are up to date with that OSHA will be looking for.
OSHA’s schedule and priorities are always subject to change as the year goes by. If you would like help ensuring you are in compliance with all OSHA requirements, please contact CTI at (770) 263-6330.