Hierarchy of Safety Controls

The hierarchy of control involves the following steps: Elimination – removes the cause of danger completely. Substitution – controls the hazard by replacing it with a less risky way to achieve the same outcome. Engineering Controls protect workers by removing hazardous conditions or by placing a barrier between the worker and the hazard. Administrative Controls are fairly simple: warning alarms, for example, are just that – alarms that let you know when something isn’t right. The last control is PPE, Personal Protective Equipment, which really is exactly what the name implies: protection you use personally.

Elimination, the top of the hierarchy, is the complete elimination of a hazard, the most effective way to protect workers. For example, bad housekeeping. The best practice would be to eliminate the hazard by picking up or moving what’s in the walking path to prevent a slip, trip or fall. Establish travel paths or walkways through work areas. The concept of elimination isn’t as simple as it sounds. If elimination fixed every hazard, everyone would be doing it. However, if elimination is on the table and is available to an employer, they should use elimination for taking care of the hazard. If elimination doesn’t work, you move on down to the substitution.

Substitution identifies a hazardous situation and uses a different product or piece of equipment that is not hazardous. An example would be, instead of sandblasting, use a non-silica containing abrasive material. The downfalls of substitution are the quality and cost, such as replacing lead-based paint with titanium white. The product must not produce unintended consequences, such as airborne dust, due to inhalation and accumulation of particles in the lungs that can lead to occupational lung disease. Basically, if you can substitute a smaller product with a larger product, that has a larger particle, then that should be your aim.

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Engineering controls are designed to get as close to eliminating the hazard as possible, without eliminating it completely. This is done by designing something in the facility or a piece of equipment to reduce the hazard or employee’s exposure to the hazard. The design must be used properly and be certified by ANSI. A glove box for handling hazardous material and chemicals is an example of isolation and engineering control. The box allows the employee to do the work while not being exposed to the material/chemical due to the material being in the box. Engineering controls don’t work out for everyone, they must be used perfectly if used. Engineering controls are the best option when the hazard cannot be eliminated.

Administrative controls (written policies & procedures) are at the point where you identify the hazard and recognize the hazard as one that can be tolerated or lived with as long as there are boundaries and precautions in place, so levels of exposure are not exceeded. Administrative controls can be used in conjunction with engineering controls or PPE such as planning the day job in the evening time in the summer due to heat stress and dehydration of workers.

Finally, PPE. Of all of the controls in the Hierarchy of Controls, Personal Protective Equipment (PPE) is the one most people are familiar with.  Why?  Well, PPE is quick, easy, often less expensive than other options, and readily available. You should know that PIOSH and OSHA consider PPE a “last resort.” So while a personal fall arrest system is considered PPE, a guardrail is not. While a respirator is considered PPE, ventilation is not. PPE includes material that must be worn on a job site such as earplugs, gloves, hard hats, safety glasses, steel toe boots, or reflective vests. PPE is not a game of guesswork. You must know what PPE is sufficient and insufficient such as earplugs rated for noise reduction. There must be a noise survey done to determine what kind of earplugs will reduce the noise to acceptable levels. PPE must be taken care of and used properly. A full-body harness could save your life, but also could cause serious internal bodily harm if it’s not worn properly.

In a nutshell, take your time and observe the areas around you. If you see a hazard go through the steps of the hierarchy of control to see which level will best suit the hazard to prevent the worker from getting injured. Safety is common sense and we can learn to manage hazards better by using the hierarchy of controls.

City of Weatherford: A CMOM Success Story

The Oklahoma Supreme Court has stated that “The maintenance and repair of [city] sewers is a corporate or proprietary function of a city and the city is liable for injuries sustained because of its failure to maintain and repair sewers properly.”  Oklahoma law requires municipalities “to use reasonable diligence and care to see that such sewer is not clogged ... and is liable for negligence in the performance of such duty to a property owner injured thereby after reasonable notice of the clogged condition of its sewer.”[1]

During 2004, the City of Weatherford had 48 sanitary sewer overflow claims resulting in a Consent Order from the Oklahoma Department of Environmental Quality (DEQ). Included in the Consent Order was the development of a CMOM (Capacity, Management, Operations, and Maintenance) Program to control their sanitary sewer overflows (SSOs).

The 2005 implementation of Weatherford’s CMOM program included the purchase of a trailer-mounted jetter and a dedicated crew of two full-time employees tasked with sanitary sewer collection system maintenance and record keeping for annual reports to OK-DEQ. Today their program has grown to three full-time employees, two trailer-mounted jetters, two vacuums, and a rover CCTV camera complete with a van. Weatherford has gone from having 48 SSOs in 2004 to averaging less than 2 per year from 2005 through 2018. Liability costs are greatly diminished and quality of life for the residents of Weatherford has improved.

The City of Weatherford’s sewer maintenance crew cleans over 250,000 feet of sewer line per year and video inspects about 3,400 feet per year. Their CCTV camera (OMAG has a grant for CCTV camera purchase assistance) removes the guesswork in determining what obstructs the line (roots, grease, debris, line collapse, etc.) and where exactly the problem is in the line. Then they can develop a plan to fix the problem and service the line. Weatherford uses root foam on about 7,000 feet of line per year (OMAG has a grant for Dukes Roots purchase assistance). Larry McKillip and his crew recommend using a Warthog jetting nozzle when jetting lines especially if they contain root balls. Larry says the Warthog is much more effective than mechanical cutters and saws, because the saws get stuck and are hard to dislodge, resulting in the need to dig up a line and break the pipe to retrieve the tool.

Trent Perkins, Public Works Director for Weatherford stated, “maps are critical for productivity.” That is why the city contacted their local COG (Council of Government)- SWODA for assistance in locating and mapping their water and sewer lines.  Through a grant (COG provides grant assistance for REAP and CDBG programs provided by the Oklahoma Department of Commerce,) the city has a viable computerized map showing the locations of all their water and sewer lines as well as manhole locations. OMAG can also assist member municipalities in gaining helpful information about their sewer systems using the SL-Rat (Sewer Line -Rapid Assessment Tool). This tool is loaned to cities and towns to quickly assess and map their sewer lines and determine what areas of town need maintenance, repair, or replacement, so municipal leaders can formulate a plan and budget for said infrastructural improvements. It is our belief the SL-Rat is an excellent tool for municipalities to use if they are seeking a REAP or CDBG grant.

Since sanitary sewer overflows are the most frequent liability claim filed against municipalities and authorities annually, and the cost of SSO claims continues to increase each year, OMAG recommends our cities and towns investigate utilizing resources to rehabilitate their aging sewer infrastructure.

A CMOM or any sewer line maintenance program is a costly start-up investment in time, staffing, and money, but it will quickly pay for itself by reducing sanitary sewer back-up claims. Citizens like to see capital improvements like new fire trucks, police cars, parks, and ballfields (the stuff we can see), but it’s also true they don’t like to have raw sewage running into their homes and businesses. Oklahoma leaders have been talking about our aging and disintegrating infrastructures for years. It is time to start making plans for major overhauls of these systems. Don’t wait for a consent order from OK-DEQ - take advantage of the resources available to you and start making the changes now.

According to Trent Perkins, “Personnel is the most important factor in the success of a sewer maintenance program, that and having the proper equipment, but support from the city’s mayor and council is key to our success.” Mike Brown, Mayor of Weatherford stated, “The City of Weatherford is thankful and proud that OMAG recognizes our efforts utilizing the CMOM program. Trent Perkins and his crew do an outstanding job maintaining our water and sewer lines. We appreciate the partnerships with SWODA and OMAG working with Weatherford to provide the best services available to our citizens.”

For more information about borrowing an SL-Rat from OMAG or to inquire about a CCTV camera or Duke’s Root Control grants contact William Sheppard or Kip Prichard at (800) 234-9461.

[1] Spencer v. City of Bristow, 2007 OK CIV APP 67, ¶ 12, 165 P.3d 361, 364

Wind Chill Temperature: A Guide for Employers

Outdoor workers exposed to cold, wet, windy conditions are at risk for cold stress. Both air temperature and wind speed affect how cold they feel. Remember that not everybody experiences cold conditions the same way. Some people are more sensitive to the cold than others. Their body temperature may be lower than 98.6 degrees to start off with -they are known as “cold-natured”; Others’ body temperature may be more “warm-natured” having a body temperature above 98.6 degrees. Take this into consideration when assigning work outdoors in the winter.

Windchill is the term used to describe the rate of heat loss from the human body, resulting from the combined effect of low air temperature and wind speed. The windchill temperature is a single value that takes both air temperature and wind speed into account. For example, when the air temperature is 40 degrees F, and wind speed is 35 mph, the wind chill temperature is 28 degrees F; This measurement is the actual effect of the environmental cold on exposed skin. Add moisture (rain, snow, high humidity) to the mix and it further increases the risk of cold stress illness.

Remember to watch your local weather forecasts and take measures to protect your employees working outdoors. A little preventive planning can save time, money, and suffering.

Stay Hydrated in Cold Weather

Losing excessive amounts of body fluid is not usually a hazard associated with cold weather. Most people associate dehydration with summer heat and humidity, but winter can drain the body of essential fluids for several reasons:

• In winter, people tend to go longer without water, not realizing that breathing cold/dry air causes the body to lose significant amounts of fluid.

• When we perspire in cold weather, the sweat turns into vapor and isn’t directly on the skin, so there is not the excessive perspiration that acts as a visual cue for us to drink.

• In winter, people feel approximately 40% less thirsty, even though the body needs the same amount of water all year round.

• Because we don’t feel thirsty as much as in the summer, we’re less likely to keep water handy in cold-weather months.

Dehydration is a danger to the body any time of the year. Most people don’t realize the hazards it poses to the heart. We need at least six 8-ounce glasses of water each day or we become dehydrated and have less blood volume, the heart must beat faster to keep oxygen and nutrients supplied to other vital organs.

Why is it so important to heart health that the body stay adequately hydrated? Consider these numbers: The body is 70% water. It is essential to health to maintain that level of water to regulate metabolism and stay healthy. For example, if a person weighs 100 pounds, 70 pounds of that weight should be water. If this ratio drops, the heart is deprived of fluid, and has to pump harder to get blood circulating and blood volume decreases. To preserve itself the body directs flow to the body core and organs. As a result, the blood vessels in the extremities (arms, hands, legs, and feet) stiffen up and constrict, putting the person at greater risk of frostbite and hypothermia.

There is a natural loss of fluid during the day from respiration and perspiration. If you are physically active in any way, you need to drink 32 ounces of fluid to maintain a healthy proportion of water in the body. If dressed in warm clothing, you sweat more and require even more fluid intake during the day. The combination of wearing warm clothing and high-intensity activity (exercise) leads to increased sweating and the possibility of dehydration. You may not feel thirsty in cold weather because your body chemistry impairs the brain’s ability to tell you when to hydrate.

One group of people who often become dehydrated is firefighters, because they are working strenuously in heavy layers of clothing. They must make themselves drink fluids even though they don’t feel thirsty.

To avoid dehydration in cold weather:

• Take fluids with you when you leave the house.

• If you don’t feel like drinking water, drink warm non-caffeinated drinks like tea, juice, or coffee to help the body stay hydrated.

• Drink often, even if you are not thirsty.

• Remember, certain fluids dehydrate the body. These include alcohol and carbonated or caffeinated drinks, including sports and energy drinks - avoid these.

• Monitor the color and amount of urine your body is producing. Your urine should be light yellow or clear. If it is darker, drink more water.

• Familiarize yourself with other common symptoms of dehydration including fatigue, feeling lightheaded, and irritability.

Any responsible person that does a lot of heavy manual labor and activity in the winter must keep their body hydrated. You are doing your body a great favor when you are conscious of your body’s need to stay hydrated in winter.

How to Dress for Cold Weather

On days when the air is cold, the wind is blowing, and the humidity is high or it’s raining, your clothing strategy is key to keeping you from getting a cold stress injury. Here are some tips for how to dress when the temperatures drop.

Layering lets you adjust your body’s temperature by putting on and removing items of clothing and maintaining an even comfort level as conditions or your exertion levels change. To dress for cold weather, you need three layers for maximum warmth and protection.

• Base layer: Your long underwear needs to keep your skin as dry as possible.

• Middle layer: Your fleece or puffy jacket needs to preserve as much body heat as possible.

• Outer layer: Your rain gear needs to protect you from rain and wind.

 Choosing your base/underwear layer

Warm skin starts with dry skin, so long underwear’s job is to wick perspiration away from you. Synthetic fabrics like polyesters are great at both wicking and drying. Wool is a good natural fiber option that holds its insulating abilities even when wet. Avoid cotton fabrics, as they do not retain their insulating abilities when they get wet.

Think about the fit. Wicking cannot occur in places where fabric is not touching skin, so you want a comfortably snug (not tight) fit everywhere.

Thickness or weight: Heavyweight makes sense for sub-freezing temps and low activity levels. Midweight is a good all-around choice. Lightweight is left to milder conditions.

Choosing your middle/insulating layer

This is the layer most people think about in cold conditions, so it’s not surprising that this layer’s job is to retain warmth.  Insulating materials like fleece are a good start. Make sure your jacket is a heavyweight fleece. When you are working outdoors in serious cold weather conditions, then a puffy jacket/coat should come into play. Down coats and jackets are a good standard if you are not working in wet conditions. They lose their insulating ability when they get wet. Puffy jackets/coats with synthetic fills are a better option when conditions get damp.

Insulating thickness can be tricky because you can’t rely on thickness to indicate warmth level when insulation types differ. Temperature ratings on labels are not reliable because there are too many variables (wind, rain, activity level, etc.) You can eyeball 2 jackets with identical insulation specs though and conclude that puffier equals warmer.

Full coverage: Don’t just think about jackets/coats - save some love for the legs. Keep some insulated or fleece pants with you, so your lower half can stay as warm as your top half.

Choosing your outer layer (shell coat and pants)

This is our outer line of defense. Even though it’s often referred to as “rainwear”, this layer’s job is to shield the underneath layers from snow, sleet, rain, and wind. There are 3 important attributes to consider when choosing your outer layer.

•  Precipitation protection: A wicking base layer can’t keep your skin dry if moisture is soaking you from the outside. In winter you don’t want to sacrifice any warmth to evaporation cooling. Wear a shell that is “waterproof” rather than merely “water resistant”.

• Breathable protection: Perspiration wicked by your base layer needs a way to escape. Wear a shell that is breathable, or moisture can build up inside it and soak you. You don’t need the most expensive GORE-TEX rainwear – any shell that is designated as “waterproof/breathable” should work fine.

• Windchill protection: The good news is that any shell that is “waterproof” is also “windproof”.

Shell pants- Cold, wet ankles are no fun, so be sure your boot tops are covered. If your pants don’t cover your ankles, then consider wearing a pair of gaiters.

Keeping Your Head, Hands, and Feet Warm

To prevent extremities from getting cold, cover up everywhere. The warmest options in hats, gloves, and footwear do the same thing as layers elsewhere: wick, insulate, and block rain/wind.

Hats- Wool or synthetic beanies work well, and you can rely on your shell jacket/coat’s hood for rain coverage. Full-on winter hats will have insulation inside the shell material. Make sure your headwear covers your ears. If your face is uncomfortably cold, wear a balaclava.

Gloves- Fleece gloves provide basic warmth. Insulated gloves, especially ones with waterproof/breathable shells are better. Mittens are warmer than gloves, because they share finger warmth.

Boots- with thick non-cotton socks can provide warmth when conditions are merely cold, but not wet or snowy. Waterproof boots are the next step up. Winter boots, in addition to offering traction on snow and ice, will also include insulation.

A Warmer Coat- Think of this as a twist on “cold hands, warm heart”. If your heart is warm and toasty, then it has plenty of warm blood to pump out to the hands and feet. Choose a well-insulated waterproof winter coat.

Chemical Warming Packets- Add warmth by slipping hand and foot warmers inside your gloves and socks. They come in a variety of sizes.

Additional Layering Tips for Cold Weather

Don’t wait to adjust layers: Throw on a shell at the first sign of rain or wind and remove your insulating jacket the minute you start to sweat. Staying warm and dry is easier than warming up or drying out.

Cotton is a no-no in any layer: Set aside your love of cotton flannel (or anything cotton) because it soaks up moisture and takes forever to dry out. That is a recipe for hypothermia.

Layers should play well together: Middle and outer layers need to glide on and off. When they fit too tightly over the layers beneath them, adjustments become cumbersome and you risk constricting circulation. Purchase middle and outer layers that are big enough to provide another layer (that of air) between them. This layer of air stays warm and keeps you warmer.

Taking time to make some smart decisions about your winter clothing will keep your warm and toasty and safer this winter.

Airborne Diseases

You can catch some diseases simply by breathing. These are called airborne diseases. Airborne diseases can spread when an infected person coughs, sneezes, laughs, or even talks, spewing nasal and throat secretions into the air in particles of moisture. These particles take flight and land on people or surfaces, contaminating them. When you breathe airborne organisms in, they take up residence inside you. You also can pick up viruses or bacteria when you touch an infected surface and then touch your eyes, nose, or mouth. Because these diseases travel in the air, they are hard to control.

Some of the airborne diseases contracted by millions of people each year are: The Common Cold, Influenza, Chickenpox, Mumps, Measles, Whooping Cough, Tuberculosis, and Diphtheria.

Treatment for Common Airborne Diseases

For most airborne diseases the best treatment is getting plenty of rest and fluids and letting the illness run its course. Some diseases like chickenpox have no targeted treatment, but medications and other supportive care can help relieve symptoms.

Some, such as flu, can be treated with antiviral drugs. Treatment for infants with whooping cough can include antibiotics, but hospitalization is often needed. There are drugs to treat and cure tuberculosis, although some strains of TB are drug resistant. Failure to complete a course of medication can lead to drug resistance and a return of the illness. If caught early enough diphtheria can be successfully treated with antitoxins and antibiotics.

With our world being so easily accessed today with air travel, airborne disease can potentially affect everyone in a brief period of time. Diseases are spread easily in close quarters such as airplanes, schools, malls, and church gatherings. Take precautions: get plenty of rest, exercise, keep your immune system up by using supplemental vitamins, and avoid large populated areas when there is a known outbreak of disease. If you become ill, take some time off from work so you don’t spread the illness.

Municipalities Must Take GHS-HazCom Training Seriously

The final GHS (Global Harmonization System) deadline is now long past. OSHA’s alignment of the HazCom (Hazardous Communication Standard) to GHS has provided a wakeup call to millions of companies across the U.S. to do a better job with their HazCom programs, especially when it comes to training. Unfortunately, not all Oklahoma municipalities have embraced this new standard. HazCom violations remain the number 2 violation on OSHA’s top 10 list of violations.

This article provides four steps employers can take to ensure employees understand the chemical hazards present in their work environments and to comply with GHS updates to HazCom.

• Step One: Build a Training Program Focused on Usefulness

  • While OSHA, and here in Oklahoma, the Department of Labor’s PEOSH division don’t specify how to do training, they do state that training must be effective. Employees must carry their learning into the workplace and be able to put it to use. HazCom has two key components: 1) providing employees with a basic understanding of the HazCom standard (OMAG works with many of our cities and towns to provide this understanding.); and 2) training employees on the specific hazards of the chemicals to which they are exposed and providing protection through administrative controls, engineering controls, and personal protective equipment (These are the responsibility of the employer and its departmental supervisors.)

  • In the past, HazCom with GHS focused on training workers to understand the new SDS (safety data sheets) and labeling formats accompanied with GHS adoption. However, many employers lacked a basic level of understanding about HazCom (municipalities included), making it difficult for them to comprehend and address the changes brought by the new GHS alignment. As a result, workers were never adequately trained on HazCom in the first place or had been trained so long ago that what they learned had been forgotten. It is critical that employers continue to emphasize basic HazCom training, which now includes GHS information to ensure employees are able to use the information in their day-to-day activities.

  • The second component of an effective HazCom training program focuses on the individual hazards employees face. Departmental supervisors must train their employees on the specific chemicals used and their hazards. The key here is to provide employees with a deeper understanding of the dangers and emergency situations they face, and counter them by following written policies and procedures.

• Step Two: Deliver Training So Employees Can Understand It

  • When OSHA first published the HazCom Standard in 1983, it followed the concept of the employee’s “right to know” about the hazards to which they might be exposed. A primary driver for OSHA’s adoption of the GHS has been the desire to improve employee comprehension of critical chemical safety information.

  • With GHS, OSHA is indicating it’s not enough for workers to just know about the hazards; instead they have the “right to understand” those hazards and know what related safety precautions to take.

  • The pre-GHS employee “right to know” concept often translated into giving workers access to MSDSs and labels and making sure they were aware of the hazards that existed from chemicals in their work environment. This approach didn’t always translate to employees understanding the safety and health information being conveyed on the MSDS and labels. GHS adoption helped solve this issue by bringing harmonization and consistency to the structure of the safety data sheets (formerly MSDS, now SDS) and labels. Use of standardized hazard communication elements, such as pictograms, make it possible for workers to more easily understand the hazards associated with chemicals workers use or are around. This simplified approach to communicating hazard information makes it possible to protect workers of all backgrounds. For instance, pictograms make it easier for illiterate and non-English speaking employees to understand the nature of a product’s hazardous properties.

  • The “right to understand” concept compliments OSHA’s rule on employee HazCom training – that it must be presented in a manner all employees can comprehend and retain. When applied to HazCom training, this means that employees who work with or around hazardous chemicals must receive training in a language they can understand, even if the documents (SDSs and labels) are only required in English.

• Step Three: Provide Easy Access to SDSs

  • A key aspect of HazCom training is to make sure employees know how to get direct access to Safety Data Sheets (SDSs) and other hazardous chemical information. Some employers are using electronic solutions to help employees retrieve information from their inventory of SDSs. If this is true with your municipality, it is incumbent on you to make sure employees are made aware of the system, how to access it, and how to use it. Without that access, in the event of an emergency, even an employee that has received adequate training on labels and SDSs will still be at risk should a chemical event occur that requires quick action. For that reason, many employers are taking advantage of technological advancements and using mobile solutions to put SDSs in the hands of their employees. The best Environmental, Health, and Safety (EHS) software solutions today leverage the cloud to make critical chemical safety information available anywhere, any time. One problem with using technology solutions, however, is many municipalities don’t have the financial resources to provide such innovative techniques. Therefore, keeping updated SDSs available to workers in a binder within the work environment of the workers may still be the best way to provide them with quick environmental, safety, and health information when a chemical event occurs. These binders can be kept in trucks, shops, and offices - wherever the employee has access to them.

• Step Four: Keep It Consistent

  • While OSHA and OK DOL-PEOSH don’t require employee training to be performed in specific intervals of time, regular training (at least annually) is a best practice to help ensure your employees better retain HazCom with GHS information. Other instances for training may include newly hired employees, temporary employees, visiting contract workers, or when a new chemical is introduced to a department. This helps ensure that employees who might work with or around a hazardous chemical understand its potential hazards.

It is vitally important to view HazCom and GHS training as an ongoing obligation. Over my years of travel around the state performing inspections and trainings for OMAG shareholders (cities and towns), I have personally noted frequent inadequacies with regard to HazCom and GHS training and information resources. The safety of your employees must be a priority in your day-to-day operations for their sake, for your municipality’s sake, and for the health and welfare of the state of Oklahoma.