By Phil Molé, MPH

The term “mixed authentication” in the context of EHS (Environmental, Health, and Safety) software refers to the availability of multiple methods of user authentication to access the software platform.

While login and authentication may not be the first features companies consider when evaluating EHS software, it’s an important factor that can significantly impact implementation success and long-term usability.

This overview outlines common authentication methods used in EHS platforms and explains why mixed authentication should be a key consideration when choosing a solution.

What are Common Types of ‘Authentication’ in EHS Software?

You’re probably in the market for EHS software primarily because of the benefits the software brings for you and your team. Increased engagement of your employees in safety, improved efficiency in addressing risks, reduced rates of occupational injuries and illnesses, and better regulatory compliance.  Still, don’t forget that the way you access those capabilities is through user authentication — the means the software provides for authorized users to verify their identity and use the software.

Here are the most common authentication methods for users to access EHS software.

1. Single Sign-On (SSO) – For employees or internal users in the company’s IT infrastructure who log-in using company credentials.
2. Local/Native Login – For external users like contractors, suppliers, or auditors who are not part of the company directory. These users do require a username/password stored within the EHS system.
3. Multi-Factor Authentication (MFA) – An authentication method that involves an extra step, such as confirming a code sent by text to mobile or email. MFA is often used as an extra layer associated with a primary authentication method.
4. Social or Email-based Login – Used in rare cases, especially for external users (e.g., Google login, Apple ID, or custom link).

Why Should You Want EHS Software with Mixed Authentication?

Recall the earlier point that authentication is your means to access all the valuable tools and capabilities within an EHS software platform. If authentication isn’t flexible enough to accommodate different types of users, it becomes a roadblock instead of a smooth on-ramp.

There are times when a single authentication method just won’t cut it. For example, if you have distinct populations of employees such as payroll employees and contracted workers, you will quickly find that one authentication method won’t effectively serve both groups. The more contractors you have, the worse of a sticking point this can be. If it’s difficult for contractors to access the software they need to view safety data sheets (SDSs), conduct inspections, complete safety orientations, or perform other contractor safety tasks, you’re going to run into bottlenecks that not only waste precious time, but introduce risks that could cause or exacerbate incidents or injuries. Keep in mind, too, that the ability of all workers including contractors to participate in your safety program is a central ingredient of a successful management system as envisioned by international standards like ISO 45001.

Software with mixed authentication features can help get you unstuck by providing different authentication methods for different employee populations, such as SSO for payroll employees vs. username/password for contractors, vendors, and visitors.

This flexibility allows organizations to onboard users without needing them to be in their internal IT system, which allows parties such as contractors and vendors to access the necessary software, such as contractor safety management software used for induction and orientation, or self-serve portals that save time by letting contractors take responsibility for managing their qualification documents and records.

At the same time, host employers can still maintain control over access to data, protecting accuracy and privacy. In fact, industry-leading software including VelocityEHS Contractor Safety & Permit to Work, part of the Accelerate ® Platform, offers mixed authentication capabilities while also meeting global standards for cybersecurity and data privacy such as GDPR and SOC 2.

In short, mixed authentication enables access to EHS software for a wider range of user types, improving flexibility, security, and usability. Be sure to include mixed authentication as a key feature to look for on your EHS software shopping list as you vet the capabilities of software providers you’re considering.

Let VelocityEHS Help!

VelocityEHS understands the importance of mixed authentication to successful implementation of EHS software, especially if you use a significant number of contactors and vendors or have frequent visitors coming and going at your facilities. That’s why our Contractor Safety & Permit to Work software specifically provides for mixed authentication methods, allowing contracted workers to log into the software via a simple username and password instead of requiring full SSO access to view orientation and induction materials or manage documentation via the contractor self-serve portal. Our Accelerate ® Platform also gives you innovative, expert-designed capabilities for safety, chemical management, industrial ergonomics and operational risk management, with an integrated user experience and a single sign-on powered by mixed authentication.

If you’re ready to learn more, set up a meeting with us so you can see our software in action.

The post What is Mixed Authentication in EHS Software? Why Does it Matter? appeared first on VelocityEHS.

The 2024 VelocityEHS Accelerate User Conference took place in May and focused on four tracks:

• Safety
• Sustainability
• Resilience
• Strategic Gamechangers

Attendees were able to customize the sessions they attended based on the tracks that resonated with them to get the most out of the conference. During a Safety Track session, there was a Q&A where safety experts discussed common pitfalls and lessons learned, sharing valuable insights on behaviors of exceptional leaders. The panel focused on the power of omission and the strategic decisions and habits that build the foundation for a strong safety culture.

One of the experts on the panel was Daniel Sakrisson, Senior VP & Advisor with valued Velocity partner WSP. Daniel began his career as an EHS field consultant focusing on field safety, environmental sampling, auditing, and regulatory data collection. His role grew into advising on automating data collection within software systems and digital transformations. He currently leads WSP in its global service line that implements EHS & ESG software, overseeing hundreds of projects in multiple industries worldwide. His expertise has helped numerous customers meet regulatory requirements and enhance their operations.

Here are his expert insights to the questions asked:

1. What traits differentiate a manager from a leader?

“In my experience, a manager is someone who pushes people and a leader is someone who pulls people. As a leader, it’s our job to encourage folks to go out on their own while listening to them and their teams to foster growth. We are servants to our teams, and leaders are the ones who are willing to roll up their sleeves and help instead of telling their teams what to do.”

2. What are some common features or characteristics that great leaders leverage to ensure the strategy and tactics aren’t doomed to fail?

“Talking to your team, great leaders know there are people on their team much smarter than them, so talk to them, and get their input. Ask them where they think you should start; you’ll get great ideas from the collaboration. Great leaders know that the best ideas come from collaboration. Also, loosen up a little, there’s a TED Talk that touches on how appropriate joking in the workplace improves morale and increases productivity and collaboration.”

3. What are behavior and actions that are culture killers?

“Favoritism, different rules for different people is a huge culture killer. This creates a situation where people don’t know what the boundaries are in different scenarios. Then they have no trust in how they will be treated, and there ends up being no standard for the team in general. Not being transparent with goals is another culture killer. A great leader motivates, not punishes.”

4. How do exceptional leaders navigate the delicate balance between stepping-in vs. letting the process run its course?

“It’s important to try and foster an environment where creativity and experimentation are encouraged, allowing for calculated risk-taking to drive progress and innovation. You should assess the organization’s risk tolerance and make decisions, accordingly, balancing the potential benefits of action with the associated risks. Exceptional leaders recognize that each situation is unique and tailor their approach accordingly, taking into account, factors such as urgency, complexity, and potential impact. Make sure you prioritize open communication and collaboration among team members, ensuring that decisions are well-informed and aligned with organizational goals. Ensure that decisions are based on thorough analysis and consideration of available information, avoiding impulsive actions or undue haste.”

5. Do great leaders let people fail?

“There’s so much that can be learned from failure because it really teaches you to not make the same mistake twice, but what it really comes down to is risk assessment. If there is a really big or important initiative, you’ll want to make sure you communicate the expectations up front. You’ll want to make sure you lay out the checks and balances and who all is involved to help them succeed and not have to face failure. But if it’s more of an exploratory project, then sure, let them go out and possibly fail you can learn from what doesn’t work.”

The Velocity Accelerate User Conference provided a comprehensive platform for professionals to explore crucial aspects of workplace management. This panel discussion examined the critical elements of effective leadership in safety management, emphasizing the importance of fostering a strong safety culture through strategic decision-making and leadership behaviors.

These insights provide valuable guidance for current and aspiring leaders in the EHS field, highlighting the complex relationship between leadership style, organizational culture, and effective safety management. Don’t miss out on learning more about safety management through experts’ lens. The Velocity events team offers a variety of sessions throughout the year on top EHS & ESG topics check out the events calendar and webinar schedule to see what’s happening.

As Always: VelocityEHS and WSP are Here to Help!

 Velocity Safety management software helps you streamline your EHS program. You’ll have access to award-winning capabilities such as incident management, SDS management, audits, compliance management, inspections and more. Get the comprehensive support you’re looking for to reach your safety goals.

WSP is one of the world’s leading professional services and consulting firms, bringing together talented people from around the globe. Their 68,000 trusted professionals are united by the common purpose of creating positive, long-lasting impacts on the communities they serve through a culture of innovation, integrity, and inclusion. WSP consists of technical experts who design and provide strategic advice on sustainable solutions that will help societies grow for lifetimes to come.

The VelocityEHS partnership with WSP brings together Velocity’s industry-leading enterprise EHS & ESG software solutions, with one of the industry’s biggest advisory and software implementation consultancies. This collaboration gives you easy access to best-in-class, expert-backed software along with implementation support, EHS & ESG consulting services, and digital solutions wherever you operate—contact us today!

The post VelocityEHS User Conference 2024 Session Digest: Safety Track—Leading by Omission Q&A | WSP appeared first on VelocityEHS.

EHS professionals know that completing comprehensive job safety analyses (JSAs) is vital to the safety of the workplace, but an important factor in the effectiveness of JSAs that often goes overlooked is making sure you have the right team of people working together to complete them. Yes, you need a team of people to complete JSAs. You’ll never get the full picture of risk in your organization if you send one person around with a clipboard and call it done, and that’s especially true if you’re not involving the employees who actually perform the jobs covered by a specific JSA.  

It’s often the case that a person or two from corporate EHS, sometimes working with a consultant, have completed JSAs without the direct involvement and relevant experiences of the employees who do the job every day and are likely to have the greatest awareness of its hazards. This is an important consideration to consider when building your JSA team. You may also want involve employees from other parts of the facility who perform similar jobs, or if they have demonstrated skills in identifying occupational risks. Each member of your team will see things differently and bring their own experience and skills to the table. By building a diverse team, you’ll identify many more risks and safety best practices that you may have otherwise missed. 

Having a team of diverse voices and perspectives doesn’t complicate the job safety analysis process, it fuels it. When team members are involved in the JSA process, they develop a genuine sense of shared responsibility and accountability for safety, fostering a more proactive safety culture within the organization. Involving the employees who perform the job itself in the JSA process strengthens ownership, engagement, and a deeper understanding of safety procedures among the workforce. This involvement also strengthens buy-in to your safety management program and increases the likelihood that employees will contribute their time and experience to other key safety management tasks when needed. 

Who Should Be on a JSA Team?

When you’re building your JSA team, you should assemble a multi-disciplinary group made up of:  

• EHS supervisors 
• Front-line employees who perform the jobs covered by the JSA you’re doing 
• Employees from other areas or departments who have specific experience or skills relevant to the JSAs you need to conduct (These employees might be from departments including Production, Maintenance, Operations, and Quality)  

The key factor is that the front-line workers performing the job being assessed have the most intimate first-hand knowledge of the tasks and their hazards. While everyone’s input is important in a JSA, the insight that front-line employees can provide is vital to improving the safety of the job – they know what hurts or feels dangerous. Still, don’t overlook the insights that employees on your JSA team from other areas of the workplace can provide. For example, maintenance personnel will have valuable technical knowledge about the function of equipment, including its load capacity (if relevant) or potential hazards such as heat exposure, pinch points, or flying debris.

Once the JSA is complete, the EHS supervisor should incorporate the JSA findings including risk levels and corresponding risk controls into the job process and throughout the workplace. Also think about how you can use the JSAs as a training tool as part of your training program to increase awareness of hazards, controls, and safe work practices for all workers performing that job. Of course, if any details about how the job is performed change that affect its risks and associated controls, you should review and revise the JSA using the same team that created it previously, share the revised JSA with all employees who do that job, and make sure they understand the changes.

The Value of Risk Perception in JSA Teams

A crucial factor to consider when completing JSAs is how much risk employees are willing to accept. There’s a big difference between knowing that you could potentially cut yourself while working with a box cutter and knowing that you could potentially lose a limb from working a piece of equipment. Perceptions of risk severity are relatively consistent from person to person, but we must also consider differences in the perceptions employees have about the likelihood of those outcomes. Perceptions of risk likelihood can differ greatly from person to person and can have a profound on their level of comfort or tolerance with the job’s risks.

For example, employees who do DIY home repairs outside of work and routinely operate hazardous equipment like saws or other power tools and equipment may have a greater sense of security (and in many cases a misplaced sense of security) when it comes to similar jobs performed in the workplace. This is especially true if they’ve never been seriously injured when performing those tasks. An employee who has been injured doing those jobs will probably have a very different perception of the likelihood of those risks.

By building your JSA team to include employees from different backgrounds and experiences within the organization, you’ll be able to tap into those varying perceptions of risk severity and likelihood to make the workplace safer for everyone. They’ll each have a different perception of how high or severe the risk is, and if they understand that they’re working as a team to make the workplace safer for their coworkers and friends, your JSA team is more likely to have productive exchanges of ideas about how to make sure everyone goes home safely every day.

How Can You Continuously Improve Your JSAs?

Building your JSA team encourages the ongoing evaluation and improvement of safety procedures, leading to continuous improvement of workplace safety standards. Conversations will naturally evolve during and after the JSA process, as employees continue to work these jobs and subsequently reassess JSAs on a regular basis.

By pooling the knowledge, skills, and experiences of JSA team members, you can more effectively identify, assess, and mitigate risks associated with the job, leading to a safer work environment that prevents incidents rather than just reacting to them.

The new Job Safety Analysis (JSA) capability in VelocityEHS Operational Risk is designed to standardize JSA across your locations, simplifying and streamlining the process of JSAs to help you get more from much less effort.

The post Building Your JSA Team appeared first on VelocityEHS.

In the current era of digital transformation, making the right software investment can be a game-changer for your business. However, the journey to acquiring and successfully implementing a new software solution begins long before the actual purchase – it starts with building and maintaining stakeholder buy-in.

We interviewed several of our customers about their biggest internal challenges in the software procurement and implementation process. Combining their feedback with our own experience working with businesses like yours, we’ve developed this set of best practices to help address the most common roadblocks to successful adoption and implementation.

In this guide, you’ll discover key strategies to ensure your stakeholders are not just on board, but genuinely enthusiastic about the software purchasing and implementation process. We hope to provide you with actionable steps and insightful approaches to navigate challenges, foster stakeholder engagement, and align diverse interests toward a unified vision of workplace safety excellence.

#1 Lack of Stakeholder Engagement

In our interviews and interactions over the years, our customers often say that lack of stakeholder engagement can easily undermine a software purchasing process before it can get very far. One reason this happens is that the internal champion (a person leading the charge to get EHS software) has not fully identified and engaged all affected stakeholders early enough in the process, or sufficiently engaged them in the decision-making process. But how do you get started with identifying the most important stakeholders and setting a place for them at the table?

Understanding the Stakeholders Perspective: Stakeholder Analysis

Identify key stakeholders within your department and across the organization who will be impacted by implementation of the new software. From the strategic influence wielded by executives to the functional insights of department heads and the technical considerations of IT personnel, each stakeholder group holds distinct concerns, perspectives, priorities, and roles in the procurement process.

Creating a Power/Interest Grid could be a good place to start. This grid is a powerful tool used in stakeholder analysis to classify stakeholders based on levels of power and their level of interest in a particular project, decision, or initiative. Similar to a materiality matrix, the grid helps in understanding and prioritizing stakeholders based on their influence and involvement in the decision-making process.

Applying & Interpreting the Power/Interest Grid

The Power/Interest Grid features four quadrants that will help you to broadly categorize your stakeholders. These include:

• High Power, High Interest (Key Players): Stakeholders in this quadrant have both significant power and a high level of interest in the software purchasing process. Engaging with these individuals and addressing their interests is crucial for building buy-in as they have the greatest need for the software, as well as the greatest influence over other stakeholder groups.

• High Power, Low Interest (Keep Satisfied): Stakeholders here might hold significant power but have a lower interest in the software implementation specifics. They should be kept informed, and their interests addressed to prevent potential negative influence.

• Low Power, High Interest (Keep Informed): Stakeholders in this quadrant have lower power and influence but a high level of interest in the software purchasing process. These stakeholders need to be kept adequately informed to secure their buy-in. Their insights and perspectives can be valuable to the process, even if they lack direct decision-making authority.

• Low Power, Low Interest (Monitor): Stakeholders in this quadrant might not significantly impact the project and might not require extensive engagement. However, it’s essential to monitor their sentiments and involvement, as their opinions could change over time, and they also still have some degree of influence in the purchasing and subsequent implementation processes.

Adapted from Mendelow’s Matrix

Click here to download your own Power/Interest Grid.

#2 Loss of Champion

Your champions are indispensable assets in building and sustaining momentum toward a successful software implementation. Conversely, their departure can pose a significant risk to the continuity of the procurement process. If a champion leaves the company, they take with them not only their knowledge of the software but also the enthusiasm and momentum built around its adoption. This potential disruption can stall progress and jeopardize the success of the entire project.

To pre-emptively address this vulnerability, it’s imperative for organizations to anticipate the possibility of a champion exiting the organization and develop contingencies accordingly. Internal champions should proactively engage other crucial stakeholders in the software purchasing journey, ensuring that the knowledge and enthusiasm for the project are not concentrated in one person but are shared collectively. This approach to stakeholder engagement not only distributes the responsibility and ownership for the success of the project, but also establishes a network of individuals with a vested interest in the software’s success who can act interchangeably in the event a champion is lost.

In response to this potential challenge, organizations can implement the following measures:

• Succession Planning: Develop a well-defined succession plan within the purchasing and implementation team, identifying and positioning individuals who are capable of seamlessly assuming the role of champion if needed.

• Knowledge Dissemination: Facilitate regular knowledge-sharing sessions among team members to disseminate insights and understanding about the software across the organization.

• Cross-Functional Collaboration: Promote the formation of cross-functional teams and encourage collaboration and a sense of collective ownership of the software adoption initiative.

By openly addressing the risks posed by the departure of a champion, organizations can fortify their software procurement strategy, ensuring resilience and continuity even in the face of personnel changes.

#3 Weak Business Case

A strong business case serves to strategically support the rationale behind an investment; detailing the expected benefits, cost analysis, and potential returns. In the context of a software purchase and implementation, it becomes evident that many failures stem from the absence of a robust business case that communicates the right benefits to the right people, in the right language.

Building a Strong Business Case

To address this issue, it is crucial to truly embrace the idea that successful procurement hinges on the establishment of a compelling business case. By developing and sharing a comprehensive business case with your stakeholders, you’ll be able to align your stakeholders behind the common goal of software implementation and provide a clear understanding of how the proposed software purchase aligns with the organization’s procurement goals and objectives. 

Moreover, the business case plays a vital role in the decision-making process by highlighting how the new software solves existing challenges or inefficiencies and addresses business needs. It substantiates the need for the investment, offering a solid foundation for justifying budget allocation and resource utilization. Ultimately, a well-structured business case should be a tool for persuading and facilitating consensus among stakeholders, ensuring transparency, and laying the groundwork for successful software adoption and integration.

Business Case Template

A strong business case, regardless of the underlying investment, should address several essential elements. Using a template can give you a solid framework for your business case and make it as clear as possible. The chart below provides an example specifically related to procurement of Control of Work software.

Click here to download your own Business Case Template.

#4 Budget Constraints

Budget constraints can significantly hamper, if not totally derail the software procurement process. It’s crucial to strike a balance between meeting business objectives and staying within the allocated budget. This necessitates early planning, thorough research, and effective communication throughout the process.

A software budget proposal serves as a comprehensive plan and financial blueprint outlining the resources required for the acquisition, implementation, and utilization of new software within an organization. This strategic planning approach enhances the likelihood of securing necessary approvals and resources for the successful execution of the software procurement project.

Initiating a software budget proposal as early as possible in the fiscal year is imperative. This is commonly the time of year when budgets are being created and a proactive approach prevents the company from reaching the end of the year and hastily putting together a proposal, scrambling for buy-in at the last second. Early budget planning allows for a comprehensive and well-thought-out document, ensuring that the necessity, benefits, costs, and strategic implications of introducing or upgrading software systems are thoroughly articulated.

The chart below provides an example of a software budget proposal:

Click here to download your own Software Budget Proposal Template.

Final Thoughts

It’s vital to remember that stakeholder buy-in is not just about getting approvals; it’s about building a shared vision for how the software will enhance the company’s performance and achieve common objectives. By fostering open communication, addressing concerns proactively, and demonstrating a commitment to the project’s success, you can gain the backing of stakeholders and pave the way for a smoother software procurement and implementation process.
You’ve absorbed quite a bit of information in this guide, so to help you digest it all, here are the key takeaways:

Prioritize Stakeholder Engagement through Analysis:
• Identify stakeholders’ power and interest levels using the Power/Interest Grid to evaluate priority for engagement.
• Create a collaborative template based on this grid to empower stakeholders in mapping their positions.
• Engage key players, keep influential yet less interested parties satisfied, inform interested stakeholders, and monitor those with low power and interest.

Cultivate and Retain Champions:
• Identify influential champions who understand the software’s benefits and leverage their advocacy.
• Continuously reassess engagement of champions and potentially seek new champions to maintain project continuity and momentum.
• Engage senior management to obtain vital resources and support for the project.

Develop a Robust Business Case and Software Budget Proposal:
• Create a compelling business case highlighting the rationale, benefits, costs, and returns of the software investment.
• Outline a comprehensive software budget proposal aligning with company goals and financial constraints.
• Identify current organizational challenges that necessitate new software and specify objectives like increased efficiency or enhanced security.

Let VelocityEHS Help!

VelocityEHS has a wide range of innovative software solutions and built-in expertise to meet your toughest challenges. Talk to one of our experts and discover how software can help make it easier for you to manage, maintain, and ensure long-term success.

The post Why Companies Fail to Complete a Software Purchase: A Guide to Get Buy In From Stakeholders appeared first on VelocityEHS.

Federal civil penalties for non-compliance with federal regulations are once again going up in 2024…but not quite as bad as last year. It’s the new year and OSHA, EPA, MSHA, and all other US federal agencies have recently published their 2024 annual civil penalty adjustments under the requirements of the Federal Civil Penalties Inflation Adjustment Act of 2015. Under the Act, all federal agencies are required to revise and publish their schedule of civil penalties based on the previous year’s rate of inflation, which is calculated based on the US Bureau of Labor Statistics Consumer Price Index for all Urban Consumers (CPI-U). 2024 federal civil penalty adjustments are based on a published Consumer Price Index (CPI-U) multiplier of 1.03241.  In other words, all federal fines and penalties for non-compliance are going up by roughly 3.2%.

Let’s take a closer look at some of the updated civil penalty schedules for US federal agencies most relevant to EHS professionals to see how these changes could impact your business.   

OSHA Civil Penalties

On January 11, 2024, The US Department of Labor published its updated civil penalties in the Federal Register, including those issued and enforced by the US Occupational Safety and Health Administration (OSHA), which become effective January 16. The table below shows a brief comparison of 2023 and 2024 penalty amounts for violations of selected OSHA regulations.

EPA Civil Penalties

As of January 15, 2024, EPA fines have also increased 3.2%. The EPA’s published penalty adjustments provide additional details on how the changes affect penalty amounts under specific regulations. For example, the table below shows a comparison of 2023 and 2024 penalty amounts for violations of selected EPA regulations:

*2023 penalty amounts are or violations that occurred after November 2, 2015, where penalties were assessed on or after January 6, 2023, but before December 27, 2023

**2024 penalty amounts are for violations that occur or occurred after November 2, 2015, where penalties are assessed on or after December 27, 2023

MSHA Civil Penalties

Like OSHA, the Mine Safety and Health Administration (MSHA) operates under the purview of the US Department of Labor (DOL). MSHA has also updated its penalties to account for the 3.2% rise in CPI-U for 2024. The table below shows a comparison of 2023 and 2024 penalty amounts for violations of selected MSHA regulations:

Additional 2024 Federal Civil Penalties

Updated penalty amounts published by other important EHS regulatory agencies can be found at the links below:

Federal Aviation Administration (FAA)

Federal Motor Carrier Safety Administration (FMCSA)

Federal Railroad Administration (FRA)

Pipeline and Hazardous Materials Safety Administration (PHMSA)

Simplify Compliance and Avoid Costly Fines with VelocityEHS

Penalties for non-compliance are only going up and even a single violation can quickly turn into a significant financial blow that could sink your business. Velocity offers a comprehensive suite of EHS & ESG software solutions that make it easier to manage compliance with a wide range of EHS regulations, helping you to avoid penalties for noncompliance and protect worker health and safety, and the environment.

Request a demo today to learn more about the VelocityEHS Accelerate^® Platform’s range of EHS & ESG solutions and see how we can help you simplify compliance, automate complex and time-consuming compliance tasks, and build a safer and more sustainable workplace.

The post OSHA, EPA, and Other Federal Civil Penalties Increase for 2024 appeared first on VelocityEHS.

We’ve come to the final installment in our VelocityEHS Blog Series on OSHA’s Top 10 Most Frequently Cited Standards for 2022, where we’ll discuss number ten on the list, the OSHA Machine Guarding Standard. Don’t let the tenth-place ranking fool you. Machine hazards are severe, often resulting in serious injury, amputation, and even death.

Here, we’ll take a closer look at OSHA’s Machine Guarding Standard, including the most commonly cited provisions of the Standard, key enforcement initiatives and directives you should have on your radar, along with best practices and tools you can use to simplify and strengthen compliance.

OSHA’s Machine Guarding Standard Requirements: A Persistent Compliance Challenge for Employers

In case you missed the list, here’s a quick recap of OSHA’s Top 10 Most Frequently Cited Standards for FY 2023:

1. Fall Protection – General Requirements (1926.501): 7,271 violations
2. Hazard Communication (1910.1200): 3,213 violations
3. Ladders (1926.1053): 2,978 violations
4. Scaffolding (1926.451): 2,859 violations
5. Powered Industrial Trucks (1910.178): 2,561 violations
6. Lockout/Tagout (1910.147): 2,554 violations
7. Respiratory Protection (1910.134): 2,481 violations
8. Fall Protection – Training Requirements (1926.503): 2,112 violations
9. Personal Protective and Lifesaving Equipment—Eye and Face Protection (1926.102): 2,074 violations
10. Machine Guarding (1910.212): 1,644 violations

OSHA’s Machine Guarding Standard has consistently ranked among the Top 10 Most Frequently Cited Standards for years, and it’s important to think about why. One potential root cause is the surprising brevity and arguably intentional vagueness of the Machine Guarding Standard. The entire body of text of the Machine Guarding Standard is just 388 words, and that includes the section numbers, and yet it is so critical in protecting workers from machine hazards.

We say the Machine Guarding Standard is intentionally vague because we believe OSHA anticipated the applicability of the Standard to a virtual universe of machine types and configurations used in the industry. Similar to its Control of Hazardous Energy Standard (Lockout/Tagout), the Machine Guarding Standard was written broadly enough to cover as great a variety of machine types and configurations as possible, including those yet to be designed or invented. As a consequence of this vagueness, there continues to be a great deal of confusion among employers as to how to apply the Machine Guarding Standard, and how to ensure compliance. In fact, OSHA has published 152 Letters of Interpretation (LOIs) since the original Standard was published in 1973, with each LOI addressing specific employer questions and concerns regarding the specifics of compliance. Despite this ongoing confusion and the continuing evolution of industrial operations and technologies, OSHA is not formally considering any updates to the Machine Guarding Standard as of its recently published Fall 2023 Regulatory Agenda.

OSHA Machine Guarding Standard Enforcement

As we mentioned in the first installment of our blog series, OSHA’s Fall Protection Standard was, by far, the most frequently cited OSHA Standard in 2023. While it is last on OSHA’s Top 10 List, the OSHA Machine Guarding Standard is certainly not least. If you look at the total numbers of violations cited under the OSHA Machine Guarding Standard relative to others on the Top 10 list, there’s not a great difference among OSHA’s Powered Industrial Trucks, Fall Protection Training Requirements, and Personal Protective and Lifesaving Equipment—Eye and Face Protection Standards, meaning it remains a strong priority for OSHA’s enforcement efforts.  

This is supported by the fact that OSHA is currently pursuing two separate National Emphasis Programs (NEPs) aimed specifically at addressing machine hazards. These include:

• OSHA Instruction – CPL 03-00-026 – National Emphasis Program on Warehousing and Distribution Center Operations – 07/13/2023 – PDF
• OSHA Instruction – CPL 03-00-022 – National Emphasis Program on Amputations in Manufacturing Industries – 12/10/2019 – PDF

OSHA also establishes numerous Regional Emphasis Programs (REPs) across the US, many of which are focused, at least in part, on addressing machine hazards and Machine Guarding Standard enforcement. Examples include:

• Region 1 – CT, ME, MA, NH, RI, VT
  • CPL-04-00-026 – Local Emphasis Program for the Seafood Processing Industry – PDF
• Region 4 – AL, FL, GA, KY, MS, NC, SC, TN
  • CPL 23/09 (CPL 04) – Regional Emphasis Program (REP) for Poultry Processing Facilities – PDF
  • CPL 23/10 (CPL 04) – Regional Emphasis Program (REP) for Safety Hazards in Auto Parts Industry – NAICS 3363XX (Motor Vehicle Parts Manufacturing) – PDF
• Region 5 – IL, IN, MI, MN, OH, WI
  • CPL 04-05-2304 – Local Emphasis Program for the Wood Pallet Manufacturing Industry – PDF
  • CPL 04-05-2306 – Regional Emphasis Program for Food Manufacturing Industry – PDF
  • CPL 04-05-2301 – Regional Emphasis Program for Grain Handling Facilities – PDF
• Region 6 – AR, LA, NM, OK, TX
  • CPL 2 02-00-028B – Regional Emphasis Program for Grain Handling Facilities – PDF
• • CPL 2 02-00-030B – Regional Emphasis Program for Poultry Processing Facilities – PDF
• Region 7 – IA, KS, MO, NE
  • CPL 02-11-03J – Kansas Local Emphasis Program (LEP) for Grain Handling Facilities – PDF
  • CPL 2-13-001I – Nebraska Grain Handling Industry Local Emphasis Program (LEP) – PDF
  • CPL 02-16-05E – Nebraska Local Emphasis Program (LEP) for Meat Processing Industries – PDF
• Region 8 – CO, MT, ND, SD, UT, WY
  • CPL 20-06 (04-01) – Regional Emphasis Program for Automotive Services – PDF
  • CPL 20-03 (04-01) – Regional Emphasis Program for Grain Handling Facilities – PDF
  • CPL 23-01 – Regional Emphasis Program for Wood Manufacturing and Processing Facilities – PDF
  • CPL 2022-01 – Regional Emphasis Program on Silica in Cut Stone and Slab Handling – PDF
• Region 9 – AZ, CA, HI, NV, and American Samoa, Guam and Northern Mariana Islands
  • CPL 04-09-2401 – Regional Emphasis Program on Amputations – PDF
• Region 10 – AK, ID, OR, WA
  • 21-05 (CPL 04) – Local Emphasis Program for Inspections in the Grain Handling Industry – PDF

OSHA’s current NEPs and REPs targeting Machine Guarding Standard compliance and enforcement, span a wide range of industry types, but if we look at the most recent enforcement numbers for FY 2023, we can see that the vast majority of citations (80% of 1,638 total violations in 2023) were given to employers in the manufacturing industries (NAICS 31-33).   

Analyzing OSHA’s Most Cited Machine Guarding Standard Provisions

Of the 1,644 violations cited under OSHA’s Machine Guarding Standard in FY 2023, here are the five most commonly cited provisions of the Standard:  

1. 1910.212(a)(1): “Types of guarding. One or more methods of machine guarding shall be provided to protect the operator and other employees in the machine area from hazards such as those created by point of operation, ingoing nip points, rotating parts, flying chips and sparks.” –1,089 violations
2. 1910.212(a)(3): “Point of operation guarding.” –402 violations
3. 1910.212(a)(2): “General requirements for machine guards. Guards shall be affixed to the machine where possible and secured elsewhere if for any reason attachment to the machine is not possible. The guard shall be such that it does not offer an accident hazard in itself.” –60 violations
4. 1910.212(b): “Anchoring fixed machinery. Machines designed for a fixed location shall be securely anchored to prevent walking or moving.” –57 violations
5. 1910.212(a)(4): “Barrels, containers and drums. Revolving drums, barrels and containers shall be guarded by an enclosure that is interlocked with the drive mechanism, so that the barrel, drum or container cannot revolve unless the guard enclosure is in place.” –13 violations

If we look at the numbers, we find that the five most common violations here account for 98% of all violations of OSHA’s Machine Guarding Standard.

The Costs of Non-Compliance

Penalties for violations of OSHA’s Machine Guarding Standard (and all OSHA Standards) can quickly pile up, with a single inspection or workplace injury often resulting in multiple citations. That’s because in addition to OSHA’s continuing focus on machine hazards and strong enforcement of Machine Guarding Standard requirements, OSHA announced earlier this year that it would expand the application of “Instance by Instance” (IBI) citations.

Employers should also be conscious of the fact that federal civil penalties for non-compliance with federal regulations have gone up in 2023…way up. In January, OSHA published their 2023 annual civil penalty adjustments as required under the Federal Civil Penalties Inflation Adjustment Act of 2015. Under the Act, all federal agencies are required to revise and publish their schedule of civil penalties based on the previous year’s rate of inflation, which is calculated based on the US Bureau of Labor Statistics Consumer Price Index for all Urban Consumers (CPI-U). 2023 federal civil penalty adjustments are based on a published Consumer Price Index (CPI-U) multiplier of 1.07745.In other words, all federal fines and penalties for non-compliance went up by 7.7%—roughly equal to the average rate of inflation faced by all consumers in the US during 2022.

January 2024 will bring new annual inflation-adjusted penalty increases across OSHA and all federal agencies, and even though rate of inflation in the US has contracted significantly compared to 2022, preliminary CPI figures from the BLS for November 2023 place that number around 3.1%, and the reference point agencies will use to calculate 2024 inflation adjustments will likely be around this amount.

Machine Guarding-Related Injury & Illness Statistics: The Human Costs

The financial penalties for non-compliance with OSHA’s Machine Guarding Standard can certainly damage your business’ bottom line, as well as its reputation in the eyes of customers, partners, investors, and other stakeholders. Sadly, it’s all too easy to overlook the cost to your business’ most important resource…your workers. Great companies focus on protecting the safety and health of their workers and the physical and mental costs of failure to do so, rather than worrying about the regulatory risks and compliance costs of OSHA Machine Guarding Standard violations.

The monetary costs of these injuries are difficult to quantify, but OSHA’s Safety Pays calculator allows us to calculate estimated costs of a wide range of occupational injury and illness types. For example, a simple laceration that can be caused by improper or faulty machine guarding is estimated to have direct costs of $21,872 and indirect costs of $24,059 for a total of $45,931. That’s quite a lot for just a cut, and this estimate does little to account for the ongoing legal and workers’ compensation costs that could arise because of a potential disability and associated injury claims.

Machine Guarding Best Practices

Fortunately, OSHA’s enforcement data and enforcement priorities (vis a vis OSHA’s NEPs and REPs) allow us to see where some of employers’ greatest weaknesses lie and draw some general assumptions about what provisions of the OSHA Machine Guarding Standard employers should focus on to help strengthen the compliance of their own machine guarding programs.

Unlike a lot of other Standards on OSHA’s Top 10 List of Most Frequently Cited Standards, the OSHA Machine Guarding Standard is primarily directed at the design features and specifications of machines and machine guarding devices, and has little to say about training, inspection, or other personnel-related requirements as many other OSHA Standards. In that way, the Machine Guarding Standard is primarily a technical standard. Therefore, verifying that machine hazards are identified and assessed, and that sufficient/compliant machine guarding devices and machine hazard controls are installed are the fundamental basis of compliance.

Fortunately, there are several aspects of your existing safety management system that will be instrumental in performing these machine hazard assessments and control verification tasks. Here are a few to focus on:

Inspections

You need to establish inspection systems that allow you to identify inspection targets (i.e., machines and machine guarding devices) and schedule periodic and regular inspections for each individual target. This includes:

• Identifying the assigned/responsible inspector roles and personnel
• Verifying that inspectors possess the necessary knowledge, training, and qualifications to perform that inspection
• Developing inspection checklists for each machine/machine guard configuration and being able to integrate OSHA Machine Guarding Standard requirements and other regulatory/design requirements into those checklist criteria
• The ability to quickly report and respond to checklist discrepancies/non-conformances
• The ability to create and assign corrective actions for individual checklist discrepancies/non-conformances
• Visibility of inspection activities and performance to verify inspection programs and procedures are being implemented, and that they are effective

For additional information on inspection program management, check out our on-demand webinar “Beyond Checklists: A Systems-Based Approach to Inspection Program Management.”

Hazard Identification & Observations

Everyone throughout the workplace, especially machine operators, maintenance personnel, supervisors, and safety managers, should possess sufficient knowledge and training to identify machine hazards, and to identify non-compliance of machine guarding devices with OSHA Machine Guarding Standard requirements. They also require rapid, real-time ability to document and report these hazards, and to have visibility into the corrective action planning and implementation process to confirm that hazards are being identified, assessed, and controlled.

And it’s not just about identifying hazards. It’s also about observing employee behaviors, both safe and unsafe. Many machine guarding-related injuries occur because workers bypass functional machine guards so that they can clear the point of operation, perform some sort of quick maintenance or repair, or just to get the job done faster because of pressure from supervisors or managers. That’s never acceptable.

It’s the responsibility of the employer to provide comprehensive work instructions on how to clear jams or resolve other types of maintenance issues safely, and ensure workers are trained and knowledgeable in how to effectively operate machines and machine guarding devices. It’s also the responsibility of workers to remain vigilant and not think of observing unsafe actions or behaviors as “calling out” their co-worker but reporting an unsafe behavior that others might repeat in the future. Though they might get away with it unscathed this time, the next time could result in a life-altering injury. On the flip side of that coin, we also want to be capturing and documenting safe behaviors that help us better understand how to do things safely, and even recognize opportunities for how to be safer.

The key is being able to capture and report these hazards and behaviors and put them on the map so that safety managers and others can learn from them, and that means having a system to document them in real-time where and when they occur.

Task Hazard Assessment (THA)

THA is a type of pre-job inspection designed to evaluate job-specific hazards and ensure appropriate safety precautions, controls, operator training and qualifications, and other preventive measures are in place prior to beginning the job. THA is an invaluable method for machine operators to verify the proper function and design of machine guarding devices and should, ideally, be performed before every work shift to verify this. If they are not in conformance with the THA, operators should be reporting any unrecognized or insufficiently controlled hazards to responsible employees so corrective actions, including installation of sufficient machine guards or repair to existing controls, can be performed.

Also, if an operator identifies a faulty or insufficient machine guarding device, that worker (and all workers) should be clearly delegated with “stop work authority”. This authority strengthens the quality of your workplace safety culture. No worker should feel pressure to continue using a machine with recognized hazards, nor should they feel like they do not have the right to refuse unsafe work.  

Job Safety Analysis (JSA)

A JSA is a comprehensive job evaluation designed to fully assess and control hazards during the job design phase, and periodically thereafter. It involves breaking jobs down into individual tasks or steps and carefully analyzing potential hazards at each step that may be introduced by the tools, equipment, work environments, and work practices used. Once hazards are identified, risks are qualitatively evaluated, prioritized, and corrective actions are taken to manage individual hazards and risks.

You should perform JSAs prior to start-up of any machine in your workplace to clearly identify, assess, and implement effective machine design and hazard controls before work ever begins. The JSA should be readily accessible to operators and other potentially affected employees to provide clear guidance on the hazards of a given job and is also invaluable as a training tool for machine operators. You should periodically and regularly evaluate the JSA to ensure it fully addresses the hazards of the job, especially after you’ve made any alterations or modifications to the machine in question. Also, you should perform JSAs in collaboration with operators, supervisors, maintenance personnel, safety managers, and other impacted employees so you get a full perspective on the hazards presented by a given machine and given job.

For more information on how to optimize your hazard identification practices and programs, task hazard assessments, and JSAs, download our guide Hazard ID & Observation, Task Hazard Assessment (THA), & Job Safety Analysis (JSA).

For additional guidance on OSHA Machine Guarding compliance and safety best practices, check out OSHA’s Machine Guarding eTool.

Final Thoughts…

We hope you’ve enjoyed our VelocityEHS Blog Series on the OSHA Top 10 Most Frequently Cited Standards for 2023 and learned some valuable insights on how to not only improve compliance with OSHA Standards, but more importantly, protect the health and safety of your people. Follow us on LinkedIn and stay tuned to the VelocityEHS blog page for further information on the EHS topics that impact businesses like yours, and to learn how VelocityEHS can help you surpass your compliance challenges and achieve EHS & ESG excellence.

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The #9 most frequently cited standard for 2023, was one again Personal Protective and Lifesaving Equipment—Eye and Face Protection. According to the Bureau of Labor Statistics (BLS), workers suffered 18,510 eye-related injuries and illnesses in 2020. That means there were roughly 1.7 cases per 10,000 full-time workers. OSHA states thousands of people are blinded each year from work-related eye injuries. Preventing eye and face injury can be achieved with the proper selection and use of eye and face protection.

There are two personal protective equipment (PPE) standards for eye and face protection put in place by OSHA. One is 29 CFR 1910.133, which concentrates on safety regulations in the general industry, and the other 29 CFR 1926.102 that centers on the constructions industry. Although, they are similar, they have some industry-specific nuances. In this blog, the focus will be on 29 CFR 1926.102.

OSHA’s Personal Protective and Lifesaving Equipment—Eye and Face Protection (1926.102) Overview

This standard applies to the construction industry. It requires employers to ensure that all their employees use appropriate eye or face protection when they are exposed to eye or face hazards such as:

• Flying Particles
• Molten Metal
• Liquid Chemicals
• Acids or Caustic Liquids
• Chemical Gases or Vapors
• Potentially Injurious Light Radiation

PPE for the eyes and face is designed to prevent or lessen the severity of injuries to your team members when engineering or administrative controls are not feasible or effective in reducing these exposures to acceptable levels.

When it comes to PPE, it’s important to make sure your team members are aware what different types of eye and face protection are available to them. They’re properly trained on how to use this equipment, and the PPE fits them correctly and comfortably.

What Are the Top PPE Citations for Eye and Face Protection?

There are many individual provisions within OSHA’s PPE for Eye and Face Protection Standard. In 2023, OSHA issued 2,074 violations. Among these, the top four types of violations were:

1. 1926.102(a)(1)—2,034 violations: “The employer shall ensure each affected employee uses appropriate eye or face protection when exposed to eye or face hazards from flying particles, molten metal, liquid chemicals, acids or caustic liquids, chemical gases or vapors, or potentially injurious light radiation.”
2. 1926.102(a)(2)—32 violations: “The employer shall ensure each affected employee uses eye protection that provides side protection when there is a hazard from flying objects. Detachable side protectors (e.g., clip-on or slide-on side shields) meeting the pertinent requirements of this section are acceptable.”
3. 1926.102(b)(1)—6 violations: “Protective eye and face protection devices must comply with any of the following consensus standards.”
4. 1926.102(a)(3)—2 violations: “The employer shall ensure that each affected employee who wears prescription lenses while engaged in operations that involve eye hazards wears eye protection that incorporates the prescription in its design, or wears eye protection that can be worn over the prescription lenses without disturbing the proper position of the prescription lenses or the protective lenses.”

Protecting your team members’ eyes and faces is necessary because loss of sight or injury to either is a life-changing event. Many of your members are unaware of the potential hazards in their work environments, making them vulnerable to injury. The use of PPE helps to prevent these life-changing hazards. Although the use of PPE, according to the hierarchy of controls, is viewed as the “last line of defense,” it still helps to keep your team members safe, when selected and used properly.

Tips to Help You Maintain Compliance with OSHA’s PPE Eye and Face Standard

OSHA notes in its updated Personal Protection Equipment Guide that many occupational eye injuries occur because team members are not wearing any eye protection, while others result from wearing improper, inadequate, or poorly fitting eye protection or eye protection without a prescription when the person wears glasses. Be sure that your team members wear appropriate eye and face protection. They know how to select properly fitting the eye and face protection appropriate for the work being performed.

OSHA also recommends management of PPE through a shared effort between employers and employees, to ensure the greatest possible protection for your team members. A team effort will help establish and maintain a safe and healthy work environment.

According to OSHA, employers are responsible for:

• Performing a “hazard assessment” of the workplace to identify and control physical and health hazards
• Identifying and providing appropriate and adequate PPE for employees
• Training employees in the use and care of the PPE
• Maintaining PPE, including replacing worn or damaged PPE
• Periodically reviewing, updating, and evaluating the effectiveness of the PPE program

According to OSHA, team members are responsible for:

• Wearing PPE properly
• Attending training sessions on PPE
• Caring for, cleaning, and maintaining PPE provided to them
• Informing a supervisor of the need to repair or replace PPE

Promoting the use of PPE has many advantages. These advantages include maintaining compliance and avoiding fines and citations, while also encouraging confidence in your team members. Confidence is instilled fist because they know they can safely perform their jobs, and second because they see you investing in their safety. It also helps to improve workplace morale and overall productivity. When your members see that you value and prioritize their health and safety, they feel more valued, experience less stress, and have an overall more positive attitude to the work they do—that should be enough to have an effective PPE management program in place.

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Having safety management programs in place is just one aspect of cultivating a strong safety culture. The VelocityEHS Accelerate^® Platform includes a wide range of innovative software solutions and built-in expertise to meet your toughest EHS and ESG challenges. Talk to one of our experts and discover how software can help make it easier for you to manage, maintain, and ensure long-term success.

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As we continue our ongoing VelocityEHS Blog series on OSHA’s Top 10 Most Frequently Cited Standards in 2023, we come to number seven, down form number four in 2022, on the list, the Respiratory Protection Standard. The US Centers for Disease Control and Prevention (CDC) and National Institute for Occupational Safety and Health (NIOSH) estimates that in 2020, more than 5 million US workers are required to wear respiratory protection as part of their regular work duties. Respirators are often the last and only line of defense between workers and exposure to potentially lethal respiratory hazards, making proper respiratory protection a literal matter of life and death for millions of workers. It’s no wonder why OSHA takes such a serious stance toward compliance and enforcement of the Respiratory Protection Standard.   

Here, we’ll take a closer look at OSHA’s Respiratory Protection Standard, including the most commonly cited provisions of the Standard, key enforcement initiatives and directives you should have on your radar, and best practices and tools you can use to simplify and strengthen compliance.

OSHA’s Respiratory Protection Standard: A Persistent Compliance Challenge for Employers

As a quick recap of OSHA’s Top 10 Most Frequently Cited Standards for FY 2023:

1. Fall Protection – General Requirements (1926.501): 7,271 violations
2. Hazard Communication (1910.1200): 3,213 violations
3. Ladders (1926.1053): 2,978 violations
4. Scaffolding (1926.451): 2,859 violations
5. Powered Industrial Trucks (1910.178): 2,561 violations
6. Lockout/Tagout (1910.147): 2,554 violations
7. Respiratory Protection (1910.134): 2,481 violations
8. Fall Protection – Training Requirements (1926.503): 2,112 violations
9. Personal Protective and Lifesaving Equipment – Eye and Face Protection (1926.102): 2,074 violations
10. Machine Guarding (1910.212): 1,644 violations

As we mentioned in the first installment of our blog series, OSHA’s Fall Protection Standard was, by far, the most frequently cited OSHA standard in 2023. Coming in at number seven, the Respiratory Protection Standard may have dropped on the list but there was still a 3% increase in citations issued in 2023 up from 2,412 in 2022.

When we look at how frequently OSHA’s Respiratory Protection Standard was cited in 2023, as well as in 2020, 2021, and 2022, one conclusion we might make is that many of these violations were related to workplace requirements for use of N95 respirators and other respiratory protection during the COVID-19 pandemic. N95 masks are classified as a tight-fitting facepiece respirator under OSHA’s Respiratory Protection Standard, meaning employers must comply with requirements for respirator use under the Standard. With virtually every worker in every US workplace required to wear an N95 or equivalent respirator during the COVID-19 pandemic, you can imagine how citations under the Standard could skyrocket.

This makes sense if we look at recent data for recordable workplace injury and illness cases caused by exposure to harmful substances or environments. The National Safety Council (NSC) notes in its 2020 Injury Facts report that the number of recordable non-fatal injuries and illnesses due to exposure to harmful substances or environments rose from an average of around 40,000 cases per year between 2011-2019, to 424,360 cases in 2020. (Figure 1) This is more than a 1000% increase in recordable non-fatal injury and illness cases due to exposure to harmful substances or environments, making it the single most common cause of workplace injuries and illnesses that year. (Figure 2) When we break down the causes of these cases even further, NSC’s 2020 Injury Facts report shows that nearly 92% of all workplace illness cases with days away were attributed to COVID-19 (Figure 3).

Figure 1: NSC Injury Facts 2020

Figure 2: NSC 2020 Top Workplace Injuries & Illnesses by Type

Figure 3: Harmful Exposure Injuries & Illnesses by Nature, Part of Body, and Industry

However, if we look even further back in time at OSHA’s Top 10 Most Frequently Cited Standards, we can see that the Respiratory Protection Standard has consistently ranked on the Top 10 list since at least 2018, well before the beginning of the COVID-19 pandemic.

• 2023: Respiratory Protection: 2,481 violations
• 2022: Respiratory Protection: 2,430 violations
• 2021: Respiratory Protection: 2,527 violations
• 2020: Respiratory Protection: 2,649 violations
• 2019: Respiratory Protection: 2,450 violations
• 2018: Respiratory Protection: 3,118 violations

This enforcement trend is a clear signal that OSHA maintains a long-standing focus on respiratory protection and Respiratory Protection Standard compliance and will continue to maintain that focus for the foreseeable future, regardless of COVID-19 workplace respiratory protection requirements.

Analyzing OSHA’s Most Cited Respiratory Protection Standard Provisions

Of the 2,481 violations cited under OSHA’s Respiratory Protection Standard in 2023, here are the five most commonly cited provisions of the Standard:  

1. 1910.134(e)(1): “The employer shall provide a medical evaluation to determine the employee’s ability to use a respirator, before the employee is fit-tested or required to use the respirator in the workplace. The employer may discontinue an employee’s medical evaluations when the employee is no longer required to use a respirator.” –505 violations
2. 1910.134(f)(2): “The employer shall ensure an employee using a tight-fitting facepiece respirator is fit-tested prior to initial use of the respirator, whenever a different respirator facepiece (size, style, model or make) is used, and at least annually thereafter.” –359 violations
3. 1910.134(c)(1): “In any workplace where respirators are necessary to protect the health of the employee or whenever respirators are required by the employer, the employer shall establish and implement a written respiratory protection program with worksite-specific procedures. The program shall be updated as necessary to reflect those changes in workplace conditions that affect respirator use.” –358 violations
4. 1910.134(c)(2): “Where respirator use is not required[…]” –244 violations
5. 1910.134(f)(1): “The employer shall ensure employees using a tight-fitting facepiece respirator pass an appropriate qualitative fit test (QLFT) or quantitative fit test (QNFT) as stated in this paragraph.” –132 violations

The Costs of Non-Compliance

Penalties for violations of OSHA’s Respiratory Protection Standard (and all OSHA Standards) can quickly pile up, with a single inspection or workplace injury often resulting in multiple citations. That’s because in addition to OSHA’s continuing focus on respiratory hazards and strong enforcement of Respiratory Protection Standard requirements, OSHA announced earlier this year that it would expand the application of “Instance by Instance” (IBI) citations.

Since 1990, OSHA has applied its IBI citation policy in scenarios where an inspection revealed multiple violations of an individual OSHA Standard provision. When applying the IBI policy, OSHA issues separate citations and penalties for each instance of non-compliance, rather than a single citation for multiple violations. Until earlier this year, OSHA only applied the IBI citation policy in cases where violations were found to be ‘willful’ in nature. That is no longer the case. As of January 2023, OSHA Regional Administrators and Area Directors have been granted discretion to apply the IBI citation policy in cases where one or more of the following factors are involved:

• The employer has received a willful, repeat, or failure to abate violation within the past five years where that classification is current
• The employer has failed to report a fatality, inpatient hospitalization, amputation, or loss of an eye pursuant to the requirements of 29 CFR 1904.39
• The proposed citations are related to a fatality/catastrophe
• The proposed recordkeeping citations are related to injury or illness(es) that occurred as a result of a serious hazard

Employers should also be conscious of the fact that federal civil penalties for non-compliance with federal regulations have gone up in 2023…way up. In January, OSHA published their 2023 annual civil penalty adjustments as required under the Federal Civil Penalties Inflation Adjustment Act of 2015. Under the Act, all federal agencies are required to revise and publish their schedule of civil penalties based on the previous year’s rate of inflation, which is calculated based on the US Bureau of Labor Statistics Consumer Price Index for all Urban Consumers (CPI-U). 2023 federal civil penalty adjustments are based on a published Consumer Price Index (CPI-U) multiplier of 1.07745.In other words, all federal fines and penalties for non-compliance went up by 7.7% — roughly equal to the average rate of inflation faced by all consumers in the US during 2022.

Respiratory Protection Injury & Illness Statistics: The Human Costs

The financial penalties for non-compliance with OSHA’s Respiratory Protection Standard can certainly damage your business’ bottom line, as well as its reputation in the eyes of customers, partners, investors, and other stakeholders. Sadly, it’s all too easy to overlook the cost to your business’ most important resource…your workers. An injury or illness due to missing or improper respiratory protection can be life-altering, even life ending.

The monetary costs of these injuries are difficult to quantify, but OSHA’s Safety Pays calculator allows us to calculate estimated costs of a wide range of occupational injury and illness types. For example, a respiratory disorder resulting from exposure to gases, fumes, chemicals, or other respiratory hazards is estimated to have direct costs of $41,013 and indirect costs of $45,114 for a total of $86,127. That’s quite a lot, and this estimate does little to account for the ongoing costs resulting from chronic health effects of exposure to respiratory hazards.

In fact, the Journal of American Medicine (JAMA) and CDC reported in 2020 that annual expenditures for workplace respiratory disorders among US workers totaled $7 billion for asthma care and $5 billion for chronic obstructive pulmonary disease (COPD). The study also noted that workplace exposures to respiratory hazards contribute to an estimated 44% of asthma cases and half (50%) of COPD cases among US workers.  

Available data also suggests that the number and rate of chronic occupational illnesses and associated deaths due to respiratory exposures is far greater than most of us would even imagine. For example, BLS and NSC data shows that in 2021 there were 5,190 work-related fatalities. Now compare this to data from CDC and NIOSH which estimates that occupational disease is responsible for between 26,000 and 72,000 deaths in the United States every year.

 Here are some additional chronic occupational illness statistics:

• Estimates published by the International Labor Organization (ILO) have found that exposure to hazardous substances claims the lives of almost 1 million workers annually. This translates to at least one worker dying every 30 seconds due to occupational chemical exposure.
• Cancer is the main cause of work-related death, and more than 200 different substances have been identified as known or probable human carcinogens, with many of these exposures occurring in the workplace. 
• ILO data shows in the EU alone, occupational cancer was responsible for 102,500 deaths in 2011 and 106,300 in 2015, and occupational cancer now represents one of the primary causes of work-related deaths globally.

Respiratory Protection Best Practices

If we look at the numbers, we find that the five most common citations under OSHA’s Respiratory Protection Standard account for close to two-thirds (64%) of all violations of the Standard in 2023. That leaves nearly a third of all citations, more than 800 violations, that were issued for other provisions of the Standard not listed above. This tells me that US employers continue to struggle with a wide range of Respiratory Protection Standard requirements.

However, OSHA’s enforcement data allows us to draw some general assumptions about what provisions of the OSHA Respiratory Protection Standard employers should focus on to help strengthen the compliance of their own respiratory protection programs. The biggest areas of concern relate to the initial assessment and documentation of workers’ fitness for use of respirators and respiratory fit testing, and the development and documentation of formal workplace respiratory protection programs.

Medical Evaluation & Respirator Fit Testing (RFT)

The two most common provisions cited under the OSHA Respiratory Protection Standard have much to do with ensuring workers are sufficiently fit and capable to use respirators, and ensuring proper selection and fitting of respirators for workers who require them.

Employers must ensure that prior to requiring workers to use respirators, those workers are in a good condition of health and physical fitness to use them. If workers do not meet specific standards of health and fitness, they must not be placed into job roles that require respirator use. Under section 1910.134(e)(1) of OSHA’s Respiratory Protection Standard, employers must “provide a medical evaluation to determine the employee’s ability to use a respirator before the employee is fit tested or required to use the respirator in the workplace.”

This medical evaluation must be performed by a physician or other licensed health care professional (PLHCP) who shall apply the evaluation criteria listed in Appendix C of the Respiratory Protection Standard. Following the evaluation, the employer must obtain and retain a written recommendation regarding the employee’s ability to use the respirator from the PLHCP. The recommendation shall provide the following information:

• Any limitations on respirator use related to the medical condition of the employee, or relating to the workplace conditions in which the respirator will be used, including whether or not the employee is medically able to use the respirator
• The need, if any, for follow-up medical evaluations based on employee responses to the medical evaluation questionnaire
• A statement that the PLHCP has provided the employee with a copy of the PLHCP’s written recommendation

If a PLHCP provides a positive medical recommendation indicating a worker is fit to wear a respirator, you then need to ensure that workers are properly fitted for the size and type of respirators they will be using. Under Respiratory Protection Standard, OSHA requires the use of specific respirator fit testing (RFT) methods and procedures based on the type of respirator in question. Generally, these testing methods and procedures can be classified as either quantitative (QNFT) or qualitative (QLFT). QLFT test methods tend to be less technically complex than QNFT methods, but both are quite procedurally complex. Nonetheless, these RFT methods must be applied precisely to ensure compliance and safeguard worker health.

As far as when and how often to perform RFT, employers must ensure that employees using tight-fitting facepiece respirators are fit tested prior to initial use of the respirator, whenever a different respirator facepiece (size, style, model or make) is used, and at least annually thereafter. In addition, employers must perform subsequent RFT whenever “the employee reports, or the employer, PLHCP, supervisor, or program administrator makes visual observations of changes in the employee’s physical condition that could affect respirator fit. Such conditions include, but are not limited to, facial scarring, dental changes, cosmetic surgery, or an obvious change in body weight.” All RFT activities and results must be documented and retained at least until the next fit test is performed, but as a best practice, they should retained indefinitely as OSHA’s Respiratory Protection Standard requires that all “written materials required to be retained under this paragraph shall be made available upon request to affected employees and to the Assistant Secretary or designee for examination and copying.”

Employers should consider implementing a software system that coordinates the scheduling, documentation and follow up of your required medical evaluation and fit testing protocols and activities. This is particularly true for employers who need to manage fit testing compliance across multiple locations, or for large numbers of employees who use respirators in the workplace. If you can quickly and easily determine which employees use which types of respirators, what fit testing protocols are required for those respirator types, when fit tests must be performed, and then collect and document fit test results within a single software system, you’ll be well on your way to ensuring compliance with fit testing requirements.

Respiratory Protection Program Documentation

The other major category that Respiratory Protection Standard citations fall into would be failure to develop, document, and maintain a written respiratory protection program. Specifically, the failure to meet requirements under 1910.134(c)(1) that lay out what information what must be included in the written respiratory protection program, and failure to maintain a written respiratory protection program when respirator use by workers is voluntary, but not strictly required, as defined in 1910.134(c)(2). Let’s take a closer look at these two provisions to see how we can improve compliance.

To meet the requirements for written respiratory protection programs laid out in the OSHA Respiratory Protection Standard at 1910.134(c)(1), your written program must include the following information:

• Procedures for selecting respirators for use in the workplace
• Medical evaluations of employees required to use respirators
• Fit testing procedures for tight-fitting respirators
• Procedures for proper use of respirators in routine and reasonably foreseeable emergency situations
• Procedures and schedules for cleaning, disinfecting, storing, inspecting, repairing, discarding, and otherwise maintaining respirators
• Procedures to ensure adequate air quality, quantity, and flow of breathing air for atmosphere-supplying respirators
• Training of employees in the respiratory hazards to which they are potentially exposed during routine and emergency situations
• Training of employees in the proper use of respirators, including putting on and removing them, any limitations on their use, and their maintenance
• Procedures for regularly evaluating the effectiveness of the respiratory protection program

Section 1910.134(c)(2) of the Respiratory Protection Standard concerns the development and maintenance of written respiratory protection programs where respirator use by workers is voluntary, but not strictly required. Employers may provide respirators at the request of employees or permit employees to use their own respirators. If the employer determines that any voluntary respirator use is permissible, the employer essentially assumes all the requirements under the Respiratory Protection Standard for workplaces where respirator use is mandatory, including developing and implementing all the elements of a written respiratory protection program noted above. Additionally, employers must provide those employees with the information contained in Appendix D of the Respiratory Protection Standard “Information for Employees Using Respirators When Not Required Under the Standard”, and they must provide respirators, training, and medical evaluations at no cost to the employee, even where respirator use is voluntary.

The requirements at 1910.134(c)(2) can place an additional burden on employers that they might not necessarily anticipate, so it’s understandable why some struggle with compliance. Again, employers should consider implementing a purpose-built software system that is capable of documenting and communicating respiratory protection program information, tracking respirator use (users, types, locations, RFT results, medical evaluations, etc.,) and performing all the various respiratory program compliance tasks within a single, centralized system.   

Next in our series…

Follow us on LinkedIn and stay tuned to the VelocityEHS Blog for the next installment of our series on OSHA’s Top 10 Most Frequently Cited Standards in 2023 where we’ll take a look at #8 on the list, OSHA’s Fall Protection—Training Requirements.

Simplify Compliance & Strengthen Workplace Respiratory Protection with VelocityEHS

The VelocityEHS Health Solution and its Industrial Hygiene (IH) management capabilities, part of our Accelerate Platform, gives IH and EHS professionals intuitive, yet powerful software tools to manage respirator fit testing (RFT), exposure assessments and sampling activities, medical evaluation and surveillance, and the full range of respiratory protection and IH program management functions.

To see for yourself how Velocity can simplify compliance and strengthen workplace respiratory protection, Request a Demo today.

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Continuing our rundown of OSHA’s Top 10 List of Most Frequently Cited Standards for 2023, we’ve reached number four, OSHA’s Scaffolding Standard. 

Working at heights is serious business. The safety risks are higher…quite literally. That’s why the OSHA Scaffolding Standard is such a technically detailed regulation.  

OSHA defines a scaffold as, “an elevated, temporary work platform. There are two basic types of scaffolds: Supported scaffolds, which consist of one or more platforms supported by rigid, load- bearing members, such as poles, legs, frames, outriggers, etc.” 

It’s obvious that it’s important to keep employees safe when working on scaffolds, yet there were 2,859 citations of the Scaffolding Standard during fiscal year 2023. Moreover, OSHA’s Scaffolding Standard has consistently ranked in the top five on OSHA’s Top 10 List of Most Frequently Cited Standards since at least 2016. So, where are these citations happening, and how can the issues be resolved to help maintain compliance, keep employees safe, and minimize regulatory risks to your business? 

What is OSHA’s Scaffolding Standard? 

OSHA’s Scaffolding Standard aims to prevent accidents and injuries associated with the use of scaffolds in construction work. The standard provides comprehensive guidelines for the proper erection, use, and disassembly of scaffolding to ensure the safety of workers at elevated heights. 

Construction and maintenance work often requires employees to operate at elevated heights, making scaffolding an essential part of these activities. However, work performed on scaffolds can be hazardous if scaffolds are not appropriately erected and used. 

Common hazards associated with scaffolds include:   

• falls from elevation, due to lack of fall protection  
• the collapse of the scaffold, caused by instability or overloading  
• being struck by falling tools, work materials, or debris  
• electrocution, due to the proximity of the scaffolds to overhead power lines 

To protect workers and prevent potential accidents, the OSHA has developed strict regulations regarding scaffolding. In this blog post, we will break down OSHA’s scaffolding standard to understand its key components and ensure that safety remains a top priority in construction and related industries. 

General Requirements of OSHA’s Scaffolding Standard

While the OSHA Scaffolding Standard itself is a very detailed document, there are a number of key areas of requirements that we can focus on to help simplify compliance:

Capacity 

The capacity requirements within the standard are intended to ensure scaffolds are designed and in sufficient condition to support employees and their tools as they work. It specifies that, “each scaffold and scaffold component shall be capable of supporting, without failure, its own weight and at least 4 times the maximum intended load applied or transmitted to it.” 

Scaffold Platform Construction 

The platform construction requirements of the OSHA Scaffolding Standard prescribe how scaffolding should be assembled and connected, stating that scaffolding must be “fully planked or decked between the front uprights and the guardrail supports.” 

Supported Scaffolds 

The most commonly used type of scaffold, ‘supported scaffold requirements cover aspects like scaffold construction, tie-ins, bracing, and the use of devices to prevent scaffold movement.  

Suspension Scaffolds 

Commonly used in window cleaning and exterior maintenance, OSHA’s standard mandates additional safety measures such as the use of complete and independent support systems, counterweights, and tiebacks to ensure stability. 

Access  

The standard requires that employees have safe and easy access to all scaffolds for work, whether via portable, hook-on, attached or stairway-type ladders, s or stair towers/rails. The official standard includes specific requirements per each type of ladder/stair and their handrails.  

Use 

The standard includes specifications for the safest use of scaffolds and scaffold components, such as: 

• Scaffolds shall not be loaded in excess of their maximum intended loads or rated capacities—whichever is less.  

• Prohibiting the use of shore or lean-to scaffolds. 

Fall Protection 

The Scaffolding Standard includes requirements for keeping employees safe from fall hazards, such as the use of a personal fall arrest and guardrail systems. 

Falling Object Protection 

The standard specifies that along with hardhats, “each employee on a scaffold shall be provided with additional protection from falling hand tools, debris, and other small objects through the installation of toeboards, screens, or guardrail systems, or through the erection of debris nets, catch platforms, or canopy structures that contain or deflect the falling objects.” 

Where are the Citations Happening? 

Many aspects of the Scaffolding Standard listed above include their own specific design and construction/erection requirements. It’s very possible—dare we say probable—that in many workplaces where scaffolding is used, that scaffolding may not be to the exact measurements that OSHA specifies in the Scaffolding Standard.  

We see that essentially all of the top 5 most cited provisions within the OSHA Scaffolding Standard are related to these design and construction/erection requirements, representing 72% of the 2,859 total violations under the Scaffolding Standard in 2023. These provisions are listed below:  

1. 1926.451(g)(1):  “Each employee on a scaffold more than 10 feet above a lower level shall be protected from falling to that lower level.” –813 violations 

2.  1926.451(e)(1):  “When scaffold platforms are more than 2 feet above or below a point of access, portable ladders; hook-on ladders; attachable ladders; stair towers (scaffold stairways/towers); stairway-type ladders (such as ladder stands); ramps; walkways; integral prefabricated scaffold access; or direct access from another scaffold, structure, personnel hoist or similar surface shall be used. Cross braces shall not be used as a means of access.” –372 violations 

3.  1926.451(b)(1):  “Each platform on all working levels of scaffolds shall be fully planked or decked between the front uprights and the guardrail supports.” –357 violations

4. 1926.451(c)(2):  “Supported scaffold poles, legs, posts, frames and uprights shall bear on base plates and mud sills or other adequate firm foundation.” –324 violations 

5. 1926.451(g)(4):  “Guardrail systems installed to meet the requirements of this section shall comply with the following provisions (guardrail systems built in accordance with Appendix A to this subpart will be deemed to meet the requirements of paragraphs (g)(4)(vii), (viii) and (ix) of this section).” –190 violations 

It’s easier said than done for employers to scour their workplaces to inspect all scaffolding systems, compare each measurement of the standard to what’s present in the worksite, and verify that every piece of the scaffolding system meets the specifications listed in the standard. However, that’s precisely what the Scaffolding Standard requires. With improved methods and processes for overseeing scaffolding construction and inspecting scaffolding systems, and a stronger focus on prevention through design (PtD) of scaffolding systems, many of these types of technical standard violations could be avoided in the future.  

The Costs of Non-Compliance

We can see from how often the OSHA Scaffolding Standard is cited, year after year, that OSHA views it an essential regulatory tool for protecting workers from fall-related injuries while working at elevated heights. By adhering to the specifications set forth in the standard, employers can ensure the safety of their workers and minimize the risk of injuries or fatalities in the workplace, while also protecting themselves from civil and potentially criminal liability for non-compliance.

Under the Federal Civil Penalties Inflation Adjustment Act of 2015, fines for non-compliance with federal standards and regulations across all federal executive agencies continue to rise annually. In 2023, OSHA’s maximum penalties for serious and other-than-serious violations increased from $14,502 per violation to $15,625 per violation. The maximum penalty for willful or repeated violations will increase from $145,027 per violation to $156,259 per violation. One of the larger OSHA penalties for Scaffolding Standard violations occurred in 2020 when a scaffolding contractor was fined $300,370 after a laborer fell to his death from a seven-story building. During the investigation, authorities found two willful and two serious safety violations of OSHA regulations. Citations were issued for breaches of fall protection and scaffolding safety standards, as well as failing to adequately train workers about fall risks connected with scaffolding work.

More than the fines and penalties for regulatory violations are the human costs of fall-related injuries, and the value of human lives saved by keeping workers safe from incidents, injuries, and fatalities. Safety should always come first, no matter at what height you’re working. Adherence to OSHA’s Scaffolding Standard not only promotes a safer work environment but also boosts productivity and fosters a positive working culture within the industry and boost the bottom line.

Simplify Compliance & Strengthen Scaffolding Safety with VelocityEHS 

Our Safety Solution, part of the VelocityEHS Accelerate^® Platform, gives EHS professionals like you advanced software tools to manage inspections, incidents, injury and illness recordkeeping, training, safety observations, corrective actions, and the full range of safety management functions you need to implement and maintain not only a highly effective scaffolding safety program, but your entire safety management system. To see for yourself how VelocityEHS can simplify compliance and strengthen worker protection, contact us today and schedule a demo with one of our in-house experts.

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It’s important to us here at VelocityEHS that you have up-to-date information and expert advice you need to help build your knowledge, skills, and understanding of what’s happening in the world of EHS and environmental, social, and governance (ESG). Throughout the year we’ve shared around 75 blogs covering different topics to keep you informed in your EHS and ESG journey. We’ve rounded up the 2023 top five most-read blogs for you to revisit and share with others who can benefit from these insights.

1.    Canada Issues Final Rule Updating Hazardous Products Regulations (HPR)

Get a better understanding of the update to Health Canada’s HPR final rule to align with the seventh revised edition of the United Nations Globally Harmonized System of Classification and Labelling of Chemicals (GHS). This blog reviews the background of the final rule, summarizes the key changes, and gives insights about what comes next. Read more.

2.    What is Management of Change?

Many people are convinced they understand the meaning of Management of Change, but what actually goes into managing change? This blog gives an overview of what Management of Change is and how it’s an essential part of safety management. Learn more.

3.    OSHA Recordkeeping: Answering Your Frequently Asked Questions

Sharpen your understanding of the OSHA Recordkeeping Standard, with answers from EHS and ESG Expert Phil Molé on some of the most frequently asked questions he receives during webinars and in-person speaking events, along with some other helpful resources. See the FAQ and answers.

4.    Why Should ESG Matter to Me? Part One: EHS and Safety Managers 

This blog helps to connect the dots between EHS and ESG, unpacking the ways ESG connects to the things EHS professionals are already doing now and explaining how building ESG maturity can make EHS management easier. Read on.

5.    OSHA, EPA, Other Federal Civil Penalties Rise in 2023

Get a closer look at some of the 2023 updated civil penalties and fines from US federal agencies. This blog gives you the low down on why meeting compliance regulations is important, the rising costs for non-compliance, and how these changes could impact your business. Read the blog.

Remember, VelocityEHS Can Help in More Ways than One!

Having robust EHS and ESG management programs in place is just one aspect of cultivating a strong sustainable health and safety culture. The VelocityEHS Accelerate^® Platform includes a wide range of innovative software solutions and built-in expertise to meet your toughest EHS and ESG challenges. Talk to one of our experts and discover how software can help make it easier for you to manage, maintain, and ensure long-term success.

The post 2023 Top Five Most-Read Blogs! appeared first on VelocityEHS.