By Phil Molé, MPH

OSHA recently shared its latest dataset of employer injury and illness records, containing statistics electronically submitted to OSHA via the Injury Tracking Application (ITA). The most recent data, for reporting year 2024, includes important information about numbers of overall occupational injuries and illnesses, as well as data on more severe incidents involving restricted duty and days away from work (DAFW). Still, it’s a lot of data, and it’s not necessarily easy draw insights, but today’s your lucky day, because we’ve done just that!

In what follows, we’ll break down some of the major trends from OSHA 2024 injury and illness data and leave you with some takeaways you can use to improve safety management.

The Background of OSHA’s Injury and Illness Statistics

It might be helpful to start with some background on injury and illness data, and how OSHA collects it from employers.

History and Purpose of the Recordkeeping Standard

The OSHA Recordkeeping Standard goes back to 1971, making it one of the earliest regulations issued by OSHA. The standard requires many US employers to maintain records of work-related injuries and illnesses that meet general or specific recording criteria. Specifically, employers covered by the Recordkeeping Standard need to complete and maintain three forms:

Form 300 (Log of Work-Related Injuries and Illnesses): This is the main record of workplace injuries and illnesses. It contains details about each incident such as the employee(s) involved, a classification of severity (e.g., whether it involved restricted duty or days away from work), and the number of days away from work or restricted duty work, if applicable.

Form 300A (Summary of Work-Related Injuries and Illnesses): This is a form that employers covered by the Recordkeeping Standard need to complete and post annually for the previous year’s injury and illness data. The 300A contains only summary-level data (i.e., there are no details about individual cases) such as the number of recordable incidents, the numbers of restricted duty and days away from work cases, and the numbers of specific incident types, like hearing loss cases. The employer needs to complete, sign, and post a copy of the 300A in an accessible location by February 1 of each year, and keep it up until April 30^th.

Form 301 (Injury and Illness Incident Report): The employer needs to complete Form 301 for each individual recordable injury and illness that occurs. The purpose of Form 301 is to capture more details about the incident—whether an emergency room visit or other medical treatment occurred, and the causes of the incident—so the employer has the information needed to prevent recurrence.

The details about information in Form 301 help us understand why OSHA prioritized issuing the Recordkeeping Standard so early in their history as an agency—they know that employers need an accounting system for workplace injuries and illnesses, so they can have the data needed to focus on prevention. OSHA also needs employee injury and illness data to assess which industry sectors seem to have elevated risks of injuries. This helps them determine the potential need for new regulations and evaluate how well current regulations are doing.

For many years, OSHA collected information from select employers through the Bureau of Labor Statistics (BLS) survey, or via the OSHA Data Initiative (ODI) program. This process was time-consuming and inefficient, which eventually led OSHA to consider more direct ways of receiving employer injury and illness data.

OSHA’s Electronic Injury and Illness Reporting Rule

OSHA issued a 2016 final rule requiring employers at some establishments to directly submit injury and illness data (specifically, electronic 300A data) to OSHA via a new web interface called the Injury Tracking Application (ITA). In 2023, OSHA revised electronic reporting requirements, and as a result, some establishments must also now electronically report data from Forms 300 and 301.

OSHA eventually began publishing employer-reported data on their website, with the goal of making the data more available to help employers and EHS professionals understand broader industry trends in injuries and illnesses. This brings us right up to the present, and OSHA’s release of 2024 employer data.

Total Reported Injury and Illness Cases for 2024

Let’s dive into the numbers, starting with total reported injuries and illnesses in reporting year 2024.

U.S. employers reported roughly 1.5 million work-related injury and illness cases for 2024. About 90% of these cases were injuries (the rest were illnesses), which marks a return to a pre-pandemic balance due to COVID-related illnesses subsiding.

The Departments/Roles Most Affected by Injuries and Illnesses in 2024

Figure: Top 5 sectors by total reported workplace injuries in 2024 (OSHA 300A data).

Healthcare and social assistance workplaces reported the highest number of injuries in 2024, reflecting the physical demands on caregivers and medical staff. This sector saw 308,000 injuries, the most of any industry. Transportation and warehousing came next (232,000 cases), followed by manufacturing (220,000) and retail trade (195,000). Construction, while lower in total cases (~65,000), still represents a significant injury count.

These findings align with long-standing data showing healthcare, transportation/warehousing, and manufacturing jobs have among the highest rates of injuries, including musculoskeletal injuries. The occupations most prone to such injuries include nursing assistants, freight and stock movers, and other laborers who perform frequent lifting and manual material handling.

Most Common Categories of Injuries and Illnesses

The chart below shows the most common categories of injuries and illnesses as reported in the 2024 OSHA injury and illness data.

The most common categories, from left to right, are respiratory conditions, hearing loss, skin disorders, poisonings, and deaths.

These categories don’t represent all possible types of injuries and illnesses, because they come from the category selections made by employers on Form 300A. However, the data reveals that a large number of work-related respiratory conditions were reported in 2024.

Respiratory illnesses in the workplace often result from exposure to occupational stressors such as particulate matter or chemical vapors, so the high number of these conditions points to a need for employers to take a more active role in assessing and controlling these exposures through industrial hygiene sampling. To run an effective IH program, employers must first have visibility of which chemical products in the workplace have established occupational exposure limits (OELs). Chemical management software that includes regulatory flagging capabilities alongside ingredient indexing services can provide employers with the visibility they need of chemicals with OELs in their inventory, so they can conduct sampling needed to measure and then reduce exposure levels and reduce numbers of respiratory illnesses.

Injury Severity and Outcomes

Top Industries by Restricted Duty Cases

Warehouses, clubs and supercenters came in first, followed by couriers and express delivery services, and general medical and surgical hospitals.

There are some characteristics of these jobs we can identify that contribute to higher numbers of restricted duty cases, including:

Lifting/material handling: Warehousing jobs involve a great deal of material handling, such as putting packages on or off of delivery trucks, and moving materials on and off of storage shelves. There’s significant potential for strains and overexertion in these tasks, especially because of the larger, more awkward package sizes and shapes and the common lack of optimal material handling equipment.

Transportation/vehicle related accidents: Courier and warehousing/distribution jobs involve a great deal of driving, often to unfamiliar locations. There are external factors beyond the driver’s control, including the weather, the condition of roads, and the behavior of other drivers.

Top Industries by Days Away from Work (DAFW)

There are some additional insights we can get from a side-by-side comparison of the highest numbers of restricted duty cases and DAFW cases, by industry, as shown in the chart below.

In general, we see that the same industries with high numbers of restricted duty cases also have high numbers of DAFW cases, which isn’t surprising, since the high level of risk in these industries makes serious injury and illness outcomes more likely. In most cases, industries have fewer DAFW cases than restricted duty cases, but the number of DAFWs for the courier and express delivery sector is actually higher than the number of restricted duty cases, and the number of DAFW cases in the scheduled passenger air transportation sector is almost as big as the number of restricted duty cases.

As previously mentioned, industries that involve significant time driving come with elevated risk levels due to the varied environments drivers must navigate and the lack of control over external factors, such as road and weather conditions.

Top Industries by Number of Fatalities

The chart below shows the top five industry sectors by numbers of reported fatalities, according to the OSHA 2024 injury and illness data.

The most common industry sectors, from left to right, are transportation and warehousing, construction, manufacturing, public administration, and administration/support and waste management remediation services.

There’s some overlap, as we’d expect, between the sectors that have the highest number of fatalities and the sectors with the highest numbers of restricted duty and DAFW cases. For example, the transportation and warehousing sector appears near the top of all those lists, for reasons already discussed.

Interestingly, though, we also see industries in the top five for fatalities that were not among the top industry sectors for DAFW and restricted duty cases. The construction industry is an example, because it came in second in overall fatalities. This datapoint tells us that there are many severe unassessed and controlled risks in the construction industry, because it has a higher proportion of injuries that result in the most severe outcome (fatality) rather than restricted duty and DAFW cases. This result highlights the importance of a proactive approach to safety, focused on identifying, prioritizing and controlling risks.

Musculoskeletal Disorder (MSD) Injuries

MSDs are injuries to joints, ligaments, muscles, nerves, and tendons caused by overexertion or awkward motions. Because MSDs are both common and commonly overlooked by employers, it’s useful to spend some time analyzing insights about MSDs we may be able to get from OSHA’s most recent dataset.

While the OSHA 2024 injury and illness data does not explicitly identify MSDs among the injuries (because there’s no category box to check for them on the 300A), it’s still possible to reach some general conclusions about the prevalence of MSDs based on the 2024 employer-reported injury and illness data.

For example, there is data available showing that nearly one-third of serious workplace injuries involve musculoskeletal disorders (sprains, strains, back injuries, etc.) In other words, ergonomic-related injuries are the single largest category of workplace injuries. This underscores how common strains and sprains are on the job.

Causes and Contributing Factors for MSDs

Work-related MSDs and sprain/strain injuries usually stem from ergonomic stressors on the job. Some common causes include:

• Overexertion in Lifting/Moving: Carrying or lifting heavy objects (or people, in healthcare) puts tremendous strain on workers’ backs and shoulders. Overexertion injuries—such as lifting beyond one’s capacity—have historically been the #1 cause of workplace injury costs.
• Repetitive Motions: Tasks that involve repeating the same motion (assembly line work, typing, tool use) can lead to chronic injuries like carpal tunnel syndrome or tendonitis. Even if each motion is low force, the cumulative effect causes wear on muscles and joints.
• Awkward Postures & Fatigue: Working in bent, twisted, or otherwise awkward positions (e.g. stretching overhead, stooping frequently) contributes to sprains/strains. Lack of ergonomic workstation setup or insufficient rest breaks can exacerbate this, as tired muscles are more injury prone.

These factors often interact. For example, a worker who is both fatigued and lifting awkwardly is at especially high risk of injury. The data reinforces that many jobs (from warehouse loading docks to hospital wards) impose these risk factors daily.

Severity of MSDs

Ergonomic injuries are not only frequent, but they can also be severe in their impact on workers’ health and productivity. In 2024, over half a million cases were serious enough to involve days away from work and an additional ~410,000 cases required job restrictions or transfers (light duty) instead of usual work. These serious injuries resulted in a staggering 18.5 million days of lost work (and 22.4 million days of restricted duty) in a single year.

The human toll is significant: an injured employee may endure pain, recovery time, and lost income, while their colleagues face the strain of understaffing. The business impact is also substantial. Lost workdays and workers’ compensation costs from MSD injuries run in the billions of dollars. In fact, MSDs cost U.S. businesses an estimated $18 billion annually in direct costs (medical treatment, comp claims, etc.), not including indirect costs like reduced productivity or training temporary replacements. This highlights why organizations are investing in ergonomics—preventing a single bad back injury can mean avoiding tens of thousands of dollars in costs and keeping an experienced worker on the job.

One notable trend is the focus on prevention programs: many industries with high MSD rates (like healthcare and logistics) have started implementing lift-assist equipment, ergonomics training, and fatigue management. Of course, implementing effective ergonomics programs depends on being able to complete accurate MSD risk assessments and using insights from those to implement effective corrective actions. Look into the ways that modern ergonomics software can help you more easily complete and use your ergonomics assessments so you can reduce MSD risks, and the high human and financial costs associated with them.

Takeaways for EHS Professionals from the OSHA 2024 Injury and Illness Data

Here are some key takeaways from the OSHA 2024 injury and illness data.

Understand the risks of your industry sector

One of the reasons that OSHA issued the Recordkeeping Standard in the first place is to collect data about injury and illness trends in specific sectors, because the agency always knew that certain industries inherently had more significant risks because of the nature of work conducted.

Since OSHA started directly collecting employer data through the ITA, the numbers have clearly borne out this fact. For example, the 2024 data shows that the medical industry and the warehousing sector have higher numbers of restricted duty cases, and the refrigerated warehousing sector has DAFW rates much higher than those of the closest runners-up.

Awareness of the injury and illness risks for your sector is an important prerequisite for building safety management maturity. You can use this knowledge to create more tailored inspection checklists to help you home in on industry-specific risks at your facility, so you can quickly develop and assign corrective actions to address identified hazards.

Focus on Preventing Respiratory Illnesses

The OSHA 2024 injury and illness data shows that respiratory illnesses were the single most commonly reported among the categories included on the 300A. Employers need to more actively identify chemical ingredients in their products that have established OELs so they can sample for these chemicals in their IH programs, and collect the information needed to reduce the exposure of their workers to harmful levels of airborne chemicals. Chemical management software can give you visibility of your inventory at the ingredient level, with regulatory cross-referencing capabilities to help you easily identify the chemicals you need to prioritize including in your IH program.

Don’t forget ergonomics!

Many employers underestimate the number and severity of MSD risks in their workplace and haven’t yet implemented a full ergonomics program. As a result, they’re putting their workforce at significant risk of MSDs, which can be costly not only in terms of the human toll on employees and their families, but also in terms of lost productivity and workplace morale. In fact, while the 2024 injury and illness statistics don’t explicitly delineate the contributions of MSDs to injury totals, we know that MSDs are an important factor behind the high injury rates in some industries, such as the DAFW numbers for the refrigerated warehousing sector.

Look into more effective ways to conduct ergonomics assessments, such as using 3-D motion capture software that you and your team can deploy from anywhere via a mobile device. Make sure the software you’re considering also has built-in expertise that helps you accurately identify root causes and select appropriate controls, so you can actually use your assessment results to reduce MSD risks.

Focus on injury and illness prevention

Effective EHS managers shift from a reactive approach to safety management to a proactive approach. In other words, instead of their safety program focusing on investigating and documenting injuries that already happened, it’s graduated to preventing the injuries that could happen, while prioritizing addressing the most significant risks.

There are a few key ingredients for success in this more mature management approach.

The first is that you need good injury and illness data, which means that you need to be sure you’re learning about, investigating and documenting all workplace injuries and illnesses. Another is that you need insights into your data, like visibility into patterns of injuries, including specific injury types, locations of injuries, and common root causes.

Make sure you’re in compliance with OSHA electronic reporting requirements!

In the midst of reviewing all this 2024 injury and illness data, it can be easy to forget that it’s only available because OSHA’s Recordkeeping Standard requires some employers to electronically submit injury and illness data to OSHA via the ITA. Make sure you know if these requirements apply to you. If they do, make sure you’ve submitted the required electronic reports to OSHA. It’s more important than ever to make sure you’re in compliance, because OSHA’s most recent Site-Specific Targeting Program (SST) prioritizes OSHA enforcement inspections at establishments covered by electronic reporting obligations that did not submit the required injury and illness data. Of course, it’s also only possible to submit digital injury and illness records if you’re correctly recording incidents and completing OSHA Forms 300, 300A and 301 in the first place.

Maintaining compliance with OSHA’s ITA submission requirements (and being able to document compliance) is easier with the right support. Look into safety management software that helps you and your team quickly and accurately complete incident investigations and generate Forms 300, 300A and 301. The best safety management software even helps you quickly generate a file containing electronic injury and illness data for all your establishments covered by ITA reporting obligations for fast, easy submission to OSHA.

Let VelocityEHS Help!

Our Safety Solution has incident management capabilities that can help you meet your Recordkeeping requirements, with mobile incident reporting and the ability to quickly attach photographs and other documentation to the inspection record. We also help you easily complete Forms 300, 300A and 301. Best of all, we make it easy to generate electronic versions of all three OSHA forms for easy transmission to OSHA via the Injury Tracking Application (ITA). And if you have reporting obligations for multiple establishments, you can cut down on reporting time by putting information for multiple establishments on a single .csv file.

Our Industrial Ergonomics software helps you ensure that you’re not ignoring MSD risks. You’ll get our industry-recognized 3-D motion capture, which provides the most comprehensive MSD risk assessment available, incorporating automatic scoring of wrist bending and back twisting, and even capturing data from hidden body segments. You’ll also be able to use your assessments better to reduce MSD risks, because the insights and experiences of our own board-certified ergonomists are baked into the capabilities. This helps you more accurately identify root causes and select effective corrective actions.

Finally, our Chemical Management software provides detailed insight into your chemical inventory at the ingredient level, along with regulatory indexing capabilities to help you identify chemicals with established OELs. This provides you with the information needed to reduce the risk of respiratory illnesses in your workplace.

All of these software capabilities are part of our VelocityEHS Accelerate® Platform, alongside our best-in-class Operational Risk software. With Accelerate®, you’ll have one software platform to manage it all, with a unified user experience via a single sign-on. Contact us today to learn more about how we can help you build safety management maturity and protect your workforce.

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OSHA Recordkeeping deadlines are quickly approaching. By February 1, employers in the U.S. covered by the rule are required to prepare, certify and post a signed hard copy of their Summary of Work-Related Injuries and Illnesses (Form 300A) in a location accessible to employees to view. Employers at some establishments will also need to submit electronic injury and illness data to OSHA by March 2.

Here’s a quick recap of the important things you’ll need to know to meet OSHA Recordkeeping deadlines.

Who is Covered by the Recordkeeping Rule?

OSHA’s Recordkeeping Rule covers all employers with 11 or more employees in the company at any time during the calendar year, unless their NAICS code is included on the Partially Exempt List of industries OSHA considers to be low hazard. All employers covered by the rule are required to keep occupational injury and illness records including the Log of Work-Related Injuries and Illnesses (Form 300), individual Injury and Illness Incident Reports (Form 301s) for each recordable injury or illness, and the Form 300A.

Employers covered by the Occupational Safety and Health Act with ten or fewer employees in the company or those who are in one of the low hazard industries listed on the partially exempt list are not required to maintain these forms but still must report any fatalities (within eight hours), hospitalizations of one or more employees (within 24 hours) and incidents involving amputation or loss of eye (within 24 hours). Employers have several options for reporting these incidents to OSHA, as described on OSHA’s “Report a Fatality or Severe Injury” page.

Do I Have to Post Form 300A, And How Long Must It Stay Up?

If your establishment is part of a company that is covered by the recordkeeping rule, you must complete and post a signed hard copy of form 300A summarizing your facility’s 2019 occupational injury and illness data by February 1 of each year.

It’s important to note here that many employers at small establishments with 10 or fewer employees mistakenly think that the “small employer” exemption applies to them, and they don’t need to maintain, sign, or post the 300A, but remember, Recordkeeping applicability depends on company size, not establishment size. This means, if you’re responsible for multiple establishments at a company covered by Recordkeeping, you need to ensure that each individual establishment maintains its own records and posts a signed copy of the 300A in an accessible location during the required timeframe.

For example, let’s say you’re a branch manager of a smaller establishment that had no more than 7 employees at any one time last year. Your branch is part of a company that has 200 or more employees at any time and is not “partially exempt” by NAICS code, so the company is covered by the Recordkeeping Standard. Should you be maintaining your own OSHA forms at your branch. And should you sign and post the 300A? If you answered “yes,” then well done. If you answered “no” or had no idea, please feel free to review the information in this post again or check out our on-demand webinar for a deeper dive into the Recordkeeping Standard.

The form must be posted in a location that is clearly visible to employees and new applicants and must remain up until April 30. As a general rule of thumb, you should post the 300A in a place where employees know important company announcements are shared.

Who Must Sign Form 300A?

OSHA requires a “company executive” to sign Form 300A prior to it being posted. This expresses OSHA’s intent that the signer is an individual with a high degree of responsibility and authority for the facility. Since the signature certifies that the information in the document is “true, accurate, and complete,” OSHA considers this a crucial step, and views unsigned forms as noncompliant.

The question is, who does OSHA consider to be a company executive for purposes of signing/certifying the 300A? The regulation itself provides context here. Specifically, 1904.32 (b)(4) says that a company executive can be “an owner of the company (only if the company is a sole proprietorship or partnership),” “an officer of the corporation,” “the highest-ranking company official working at the establishment,” or “the immediate supervisor of the highest-ranking company official working at the establishment.” The site’s EHS person could sign if she or he met one of those criteria.

Do I Have to Post Form 300A Even If There Were No Recordable Injuries or Illnesses?

Yes, OSHA is very clear about this. All covered employers must fill out and post the summary annually, even if no recordable work-related injuries or illnesses occurred during the reporting year.

Do I Need to Electronically Submit Data to OSHA?

Maybe. Not every employer covered by Recordkeeping also needs to electronically report, but some of them do. You’d need to understand OSHA’s 2023 electronic reporting final rule which went into effect in January 2024 to see if the requirements apply to you.

At a very high level, the OSHA final rule creates 4 different categories of electronic reporting obligations, depending on establishment size and industry sector, as shown in the chart below.

Here’s more detail about how requirements break down for each of the four categories of establishments listed in the table above.

Establishments with < 20 employees
If you have fewer than 20 employees at your establishment at any one time, you don’t need to do electronic injury and illness reporting, whether under current requirements or revised requirements. Just document your employee headcount, making sure it includes all eligible employees.

Certain establishments with 20-249 employees

Establishments with 20–249 employees in certain designated industries (listed in appendix A to subpart E) will continue to be required to electronically submit information from their Form 300A annual summary to OSHA once a year (final § 1904.41(a)(1)(i)).

Establishments with 100+ employees listed in the new Appendix B

Establishments with 100+ employees in certain designated industries (listed in new appendix B to subpart E) will be newly required to electronically submit information from their OSHA Forms 300 and 301 to OSHA once a year (final § 1904.41(a)(2)). The industries listed in new appendix B were chosen based on three measures of industry hazardousness.

Establishments with 250+ employees subject to Recordkeeping Standard

Establishments with 250+ employees in industries that are required to routinely keep OSHA injury and illness records will continue to be required to electronically submit information from the Form 300A to OSHA once a year.

What Reporting Period Should I Cover in My Electronic Reports?

The reporting period you’ll need to cover is the same as the reporting period reflected in the physical forms 300, 300A and 301 you need to maintain, specifically, the calendar year.

For both the physical Form 300A (which you need to complete, sign and post by February 1st) and your electronic submission of 300A data, if applicable, the reporting period is the calendar year. So, for example, if you’re required to make electronic submissions by the March 2, 2025 deadline, the data submitted would cover the 2024 calendar year, from January 1 through December 31, 2024.

How do I Submit Electronic Injury and Illness Data?

If you need to submit electronic injury and illness data to OSHA, you’ll use the Injury Tracking Application (ITA).

If you’ve never set up an ITA account, don’t worry much about it—you’ll probably find the process similar to setting up an online banking account. You’ll set up a user identification and an associated password, and you’ll get a confirmation email that will take you back to the login screen. From there you can start inputting establishment data.

The process is even easier if you already have a login.gov account for other federal government sites, because you can use the same login details for the ITA.

You can set up multiple people in your organization to be administrators within the ITA, and you can either enter your information manually or submit an electronic file in .csv format. The advantage of submitting a batch file is that you can submit a single file containing information for multiple establishments with reporting requirements and upload the information to the ITA in one shot.

Is There Any Way I Can Get Help Meeting OSHA Recordkeeping Deadlines?

Indeed, there is! Modern safety management software can help by making it easy for you and your workers to report incidents, document follow-up, and generate accurate OSHA forms. Even better, can access forms for multiple establishments from anywhere, at any time, and electronically submit forms to OSHA via the ITA.

If your current recordkeeping methods cause anxiety about meeting OSHA’s revised electronic reporting requirements, now’s the time to start looking for better alternatives.

Looking for Additional Information?

Hopefully, this blog will help you feel more prepared meeting your OSHA Recordkeeping deadlines, but if you feel like you need more information, we have you covered.

A great place to start would be to attend our on-demand webinar that takes a closer look at all facets of Recordkeeping compliance, from determining which workplace incidents are recordable or reportable, to completing the three required OSHA forms, to electronically submitting your data to OSHA if you’re covered by that requirement.

If, like many EHS professionals, you need more help with the basics of knowing which injuries and illnesses meet OSHA’s definition of “recordable,” you can download and use this handy cheat sheet.

Finally, if you have questions about electronic injury and illness reporting using the ITA, our electronic reporting FAQs eBook probably has the answers.

Be sure to follow this space for future updates about Recordkeeping and other areas of EHS and ESG management!

Let VelocityEHS Help!

You’ll have an easier time meeting your annual OSHA Recordkeeping deadlines and maintaining compliance with the Recordkeeping Standard throughout the rest of the year, if you have the right tools.

Our Safety Solution, part of our VelocityEHS Accelerate ® Platform, has incident management capabilities that can help you meet your OSHA Recordkeeping deadlines and other requirements, with mobile incident reporting and the ability to quickly attach photographs and other documentation to the inspection record. We also help you easily complete Forms 300, 300A and 301. Best of all, we make it easy to generate electronic versions of all three OSHA forms for easy transmission to OSHA via the Injury Tracking Application (ITA). And if you have reporting obligations for multiple establishments you can cut down on reporting time by putting information for multiple establishments on a single .csv file.

Visit our solution landing page for more information or just contact us anytime. And remember, incident management capabilities are only one way our VelocityEHS Accelerate ® Platform can help you, because you get plenty of other safety management capabilities, plus world-class ergonomics, chemical management and operational risk solutions, all in one platform offering an integrated user experience. Schedule a demo so you can see our platform in action for yourself!

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Workplace safety remains a top priority for organizations across industries in 2024. In an environment marked by a constrained labor market and increasing expectations from both employees and regulators, companies are making significant strides to reduce accidents, minimize associated costs, and enhance their safety cultures. Earlier this year, we conducted a State of the Market Report alongside EHSToday. Based on a survey of 478 responses, the report offers a comprehensive snapshot of the current state of workplace safety, and indicators we can use to determine the future of EHS. 

The State of Workplace Safety in 2024 

Safety is a shared responsibility in many organizations, involving a diverse range of roles, including EHS professionals, operations managers, and plant managers. One of the key takeaways from the report is the significance of safety budgets. Despite economic challenges affecting companies globally, nearly a third of organizations have increased their safety budgets, while only 10% reported a decrease. This signals a strong commitment to prioritizing safety even in uncertain times. 

However, the report also reveals that while organizations are maintaining or increasing their investment in safety, they are still facing significant challenges in improving safety performance. This includes struggling to stay on top of safety tasks, improve worker engagement, and effectively manage risk in increasingly complex work environments. Many companies are not fully leveraging available technology, particularly EHS software that could enhance their safety management efforts. 

EHS Staffing: A Vital Component of Safety Success 

EHS staffing levels are a crucial factor in safety program success, organizations with increased EHS staffing are more likely to meet their safety goals, particularly in areas such as recordable injury rates. Even though EHS staffing levels have largely stayed the same this year, companies that increased staffing cited reasons such as business growth, enhanced safety goals, and the need to address safety gaps. 

On the other hand, organizations that have reduced their EHS staff often struggle to meet their safety targets. Only 6% of companies that cut back on EHS staff were able to meet their injury rate goals, highlighting the critical role of having adequate personnel to manage and execute safety programs. 

Technology’s Role in Managing Safety 

Over the last few years, technology has emerged as an essential tool in managing safety programs. The survey highlighted that a significant majority (83%) of companies are using technology to deliver safety training, with 59% using it for chemical and safety data sheet (SDS) management, and 57% using it for incident reporting and investigations. 

However, there is still considerable room for improvement in adopting technology for other critical safety functions. For example, only 45% of companies use technology for hazard identification and risk assessments, and even fewer (27%) use it for managing work permits, which presents a major opportunity for improvement. Leveraging technology for these areas could help organizations proactively manage risks, identify trends, and improve overall safety outcomes. 

EHS software offers a streamlined, data-driven approach to managing safety, allowing organizations to automate processes, track safety performance, and gain real-time insights into potential hazards. The survey suggests that companies that are fully utilizing these technologies are better equipped to mitigate risks, reduce downtime, and ensure compliance with evolving regulations. 

EHS Standards: Certifying vs. Following 

The report also explored the role of safety management systems and certification standards such as ISO 14001, ISO 45001, and ANSI Z10. While many companies follow the guidelines of these standards, fewer are formally certified. For instance, 30% of respondents reported following the ISO 14001 framework, but only 25% were certified. This gap suggests that while companies understand the value of safety standards, they may not be fully committing to the rigorous process of certification, which requires audits, documentation, and a higher level of accountability. 

Certification to standards like ISO 45001, which is specifically focused on occupational health and safety management, has been shown to improve safety performance. Organizations that are certified often benefit from a more structured approach to risk management, greater engagement, and improved safety culture. 

Metrics: Leading vs. Lagging Indicators 

How the effectiveness of safety programs is measured is critical for ongoing improvement. The survey results show that most companies (89%) use leading metrics, such as safety audits, risk assessments, and inspections, to gauge the success of their safety management systems. Leading metrics focus on proactive actions, such as identifying hazards before they result in accidents. 

Lagging metrics, on the other hand, measure the outcomes of safety programs, such as incident rates, lost workdays, and workers’ compensation claims. While these metrics provide valuable insights into past performance, they do not offer the same predictive power as leading metrics. Nonetheless, companies that use both leading and lagging indicators are better positioned to track safety performance comprehensively and benchmark against their peers in the industry. 

Interestingly, the survey also revealed a lack of widespread adoption of impact metrics, which measure the broader business benefits of safety programs, such as increased productivity, reduced absenteeism, and improved employee engagement. Despite the potential of these metrics to demonstrate the return on investment in safety, 79% of companies are not using impact metrics. This presents a key opportunity for safety leaders to better quantify the value of their programs and secure greater support from top management. 

Safety and ESG: An Increasingly Integrated Role 

Workplace safety is increasingly being integrated into broader ESG initiatives. The survey found that 18% of organizations have safety teams leading their ESG efforts, while 29% report that safety is closely integrated with their sustainability programs. This trend highlights the growing recognition that health and safety are not only critical for regulatory compliance but also essential for meeting ESG goals. 

However, not all organizations are yet aligning safety with their ESG strategies. One-quarter of respondents reported having no formal sustainability or ESG initiatives, suggesting that there is still room for improvement in integrating these two critical areas. 

What’s Next? 

The 2024 State of Workplace Safety report highlights the significant strides organizations are making to improve safety but also highlights areas for further growth. While companies are investing in safety programs, staffing, and technology, many are not fully exploiting the potential of EHS software, ESG integration, or adopting impact metrics to measure the broader business benefits of safety. Companies that commit to formal safety certifications, adopt both leading and lagging metrics, and leverage technology are more likely to create a robust safety culture that leads to reduced incidents, lower costs, and greater employee engagement. 

Ultimately, the survey reveals a clear message – solid safety programs are the cornerstone of operational success, now and in the future. With plenty of room for improvement, we can expect to see organizations continue to implement health and safety as a strategic business advantage that ensures a sustainable future. 

Looking for a deeper dive into the insights from our State of the Market Report? Check it out here. 

The post Workplace Safety in 2024: Trends, Challenges, and the Future  appeared first on VelocityEHS.

By Phil Molé, MPH

The holidays are here! You’re likely making a list, checking it twice, and making plans to be with the special people in your life. And no doubt, you’re still hard at work right up to the holidays, which is all the more reason to make sure you’re not overlooking important safety hazards and risks in the workplace.

The last thing you want is for a workplace injury to interfere with your ability to be with and enjoy your time with those who matter most to you. Unfortunately, many companies report an uptick in accidents during this time of the year, due to a combination of factors ranging from winter weather conditions and short-staffing to distractions, and even dangers associated with holiday decorations.

In what follows, you’ll learn some holiday safety tips about common hazards to watch out for while working during this time of the year and get some key takeaways about how to make sure that you and your whole team leave work safely every day.

Holiday Safety Tip #1: Deck the Halls, But Don’t “Daisy Chain” the Lights

“Daisy chaining” refers to the process of connecting two or more extension cords or surge protectors, usually to plug in something we want to position farther away from our existing electrical outlet or surge protector. Most of us have probably resorted to daisy chain connections at some point in our lives, and the temptation to string those extension cords together grows around the holidays, when we may be trying to find creative ways to light up our decorations.

Why is daisy chaining dangerous? When you connect multiple cords or surge protectors, you’re placing more demand for electrical power on the outlet your motley chain of devices is connected to than the outlet is designed to provide. Overtaxing the outlet or surge protector that your daisy chained cords connect to creates an elevated risk for an electrical fire. This is why OSHA prohibits daisy chain connections in their general requirements in 1910.303 within Subpart S (Electrical), and why many other electrical standards prohibit the practice, as well.

While you’re at it, you should also make sure that no extension cords pass through doors or windows, because OSHA regulations don’t allow that, either. 1910.305 states that installations can only have cords that pass through doors, windows, or holes in walls on a temporary basis. Technically, “temporary” would apply to holiday decorations, but beware of being too lax here, for two reasons. The first reason is that people often get the idea of running cords through doors and windows while decorating for the holidays because they’re already doing it throughout the rest of the year. The second reason is that temporary installations have a way of becoming permanent, intentions to the contrary. Maybe the light-up Frosty the Snowman won’t be plugged into the cord flopping down through a window, but if someone took the trouble to string that cord through, there’s a good chance that the cord will stay there, and something will be plugged into it.

Check the condition of extension cords and power strips to be sure they’re ready for use. Don’t use any cords with damaged insulation or plugs. Also, make sure you’re not burying the extension cords you use underneath carpets and rugs in high traffic areas, which can lead to trip hazards.

Holiday Safety Tip #2: Beware of the Woes of “Santa Snow”

Spray-on artificial snow, often marketed under names like “Santa snow” or “Instant Xmas snow,” is commonly used for decorating indoor trees and windows. These products contain gas propellants, such as butane, propane, and heptane, which are held under pressure—creating a potential explosive hazard. Make sure you’re not placing decorations coated with “Santa Snow” or spraying the snow anywhere near ignition sources, such as sparking tools or ovens.

They also may contain alcohols such as ethanol or ethoxylated fatty alcohol, and solid additives such as titanium dioxide and calcium carbonate for texture and color. Because of these ingredients, these spray-on artificial snow products can cause skin or eye irritation in the event of contact. Make sure that any team members in charge of applying the spray-on snow are aware of these risks.

Access to emergency response services can provide an extra level of protection, because you may not have an SDS on hand for consumer products like “Santa snow.” Emergency response services give you access to a 24-hour support hotline with live experts, so you can get in-the-moment feedback on exposure symptoms and first aid measures to take.

Holiday Safety Tip #3: Manage the Challenges of Working with a Smaller Headcount

There are things about the holiday season to look forward to— having time off to spend with friends and family or just relaxing after a year of hard work. There are also some things you to avoid during the holidays, such as getting seasonal illnesses like the cold or the flu that may shelf you for a while and put a real damper on the holiday cheer.

The common denominator is that during this time of the year, there are a lot of reasons why some of the people you work with won’t be around, and that can have a negative impact on safety. There are really a couple of ways that reduced staff can create, or at least exacerbate, EHS risks.

People who know the right ways to do the work are missing in action, and no one else knows what to do. When all the information is in one person’s head, if they’re gone, the awareness of the right ways to do the job and associated safety measures are gone, too. In other words, the company has a person to manage safety, when they really need a system to manage safety.

Another issue that results from short-staffing is that there may not be enough people on hand to conduct the physical demands of the job. For example, work at an assembly table may involve lifting parts from the floor or the shelf onto the table, which may be easily done when two people are on hand. But if one of those two people is off work (due to illness, injury, or scheduled PTO), will the other person be tempted to try the lift alone? Quite possibly, especially if the person is feeling pressured to get things done as quickly as possible.

You’ll need to consider both of these trends related to a temporarily smaller headcount throughout the holidays. The end of this article will discuss some of the high-level takeaways to address these challenges, but the spoiler alert is that it boils down to proactive safety management.

Holiday Safety Tip #4: Preparing for Winter Weather Conditions

In at least some parts of the world, the winter season comes with colder and sometimes dangerous weather conditions. Snow and sleet cover sidewalks, streets and parking lots. Strong gusts of wind may occur, and windchill factors can create dangerous exposure conditions.

Some of the accidents and injuries that may occur from these winter hazards include:

Slips/falls: Parking lots and walkways at work may become slippery due to snow and “wintry mix” cover. As snow melts and then refreezes, some walking surfaces may also be covered with thin sheets of ice that may be difficult to see, especially when leaving work at night.

Auto accidents: Poor driving conditions due to snow, sleet and ice coverage may lead to vehicle accidents.

It’s worth a reminder, for those of us in the US, that some vehicle accidents may also be OSHA-recordable injuries if they occur outside of the normal commute and associated employee injuries meet OSHA recording criteria, such as days away from work, restricted duty work, hospitalization or other medical treatment. Additionally, some employers forget that slips/falls that occur on the employer’s property before or after work begins, or on breaks during the workday, are still considered to occur in the work environment and would be recordable if other recording criteria (medical treatment, days away from work, etc.) are met.

More information about OSHA’s Recordkeeping Standard is in our on-demand webinar.

Holiday Safety Tip #5: “Tis the Season for Managing Distractions

Your ability to work safely depends in part on your awareness of safety risks, and your awareness of safe work procedures.

You can probably remember some accidents that happened when people did not have their peak powers of concentration. For example, an employee who’s tired will be less attentive to the safety aspects of their job, such as ensuring that proper controls are in place. Another classic example is the employee who works a full day at work safely, but as soon as their workday is over, they get into an accident, such as by removing their safety glove and then setting their hand down on a sharp object or bumping into machinery on their way out of the facility.

There are plenty of opportunities for distractions during the holiday season. Some employees may be worrying about finding time to buy Christmas presents for their kids or worrying that they won’t have enough money to buy Christmas presents. They may be looking out the window at the falling snow and getting anxious about their evening commute. Or they may be stressed out because they’re working without the usual support they get from coworkers who are now out on vacation and aren’t sure they’ll be able to get through it all.

Being mindful that distractions can happen is the first step toward being able to manage them. The second step, as you’ll learn more about at the end of this article, is to have a proactive safety management approach that gives all of your employees the information they need about workplace risks and the controls they need to have in place to work safely.

Holiday Safety Tip #6: Weathering a Perfect Storm of Safety Risks

Winter weather conditions can be especially dangerous because sometimes, you don’t just get one bad weather condition in isolation. Sometimes, all the bad things come at once. For example, in a real storm, strong winds sometimes accompany massive amounts of snow and rapidly plummeting temperatures immediately after. Similarly, safety risks have ways of piggybacking and leading to more severe outcomes.

Here’s a typical holiday-season “perfect storm” scenario. Imagine that you’re working in an assembly department within a factory, and your normal job involves joining several components together to form a single product and then packaging the part for shipment in commerce. You normally have a partner working with you who helps “team-lift” the heavier parts onto the table, but your partner is out sick today, and your supervisor hasn’t provided any alternate instructions on how to conduct the job. You hope to just get through the day and head out right at the end of your usual shift time so you can pick up a pie you’ll be bringing to a family holiday dinner in a couple of days.

The day starts out alright, but without your partner, the work is slower, and you start to fall a little behind schedule. You’ve picked up a few of the larger pieces by yourself already without issue, and you think about going to look for material handling equipment to use for the rest, but you’re not sure where they’re at, and don’t want to waste time, so you continue performing the lift manually. But you’re increasingly in a hurry as you continue to fall behind schedule, and you bend at the waist to grab the part instead of at the knees, and you feel a slight twinge in your back. Not good.

Now, you do decide to look for a mechanical cart, and you find one and get back to work. But in early afternoon, you overhear a couple of coworkers talking about the snow forecast, and you walk over to the window, where you can see there’s already a first blanketing of snow on the cars in the parking lot. You try to put it out of your mind and go back to work, but there’s a part of your mind that’s thinking about that snow and thinking about how you’re running late on getting the work done, and wondering how long it will take to get to the bakery after work and get home.

By the time you’re done putting the last packaged part on the shelf and returning the mechanical cart, you’re a little over 30 minutes past your usual quitting time. You throw your jacket on and grab your bag and head out the door to the parking lot, where you can see that your car is pretty well covered with snow. You pitch your shoulders forward and break into a brisk stride to get your car and start sweeping the snow off, take about three steps, then suddenly find your foot flying up into the air as you slip on a patch of ice hidden by the snow. Part of the reason for your fall may be that your twinged back makes you less flexible than usual and more prone to falls—a trend borne out by a prospective study.

You land flat on your back, hard. Your thick winter coat cushioned your fall a bit, but you find that the slight twinge you felt earlier now feels like a full-blown strain, and your back is so stiff that you can barely get yourself upright. As a result, you wind up missing a couple of days of work, and getting a prescription for anti-inflammatory medication, which makes the incident an OSHA recordable injury in the United States.

What about the pie, you ask? Someone else was able to pick it up the next day, so you didn’t have to rush, after all, and if you hadn’t, you just might have avoided a slip and an injury.

It’s not one thing that led to this incident – it was many things. And a busy time like the holidays is when coworkers are more likely to be out,  winter weather conditions will often make a slippery mess of roads, and you’ll be nervous about all these things, and that one day will be when all the bad things happen together.

Key Takeaways About Workplace Safety During the Holiday Season

These holiday safety tips have hopefully reminded you that this time of the year isn’t all eggnog, hot cocoa and sliced turkey (or for the vegetarians out there, sliced tofurkey). But a big part of safety management concerns “lessons learned” when something bad happens, and there’s no point in talking about the bad things that can happen without discussing how to stop the bad things from happening. As Ebenezer Scrooge pleaded with the Ghost of Christmas Future: “Spirit! Are these the shadows of the things that will be, or are they shadows of the things that may be only? Why show me this, if I am past all hope?”

You’re not past all hope. Here are the key takeaways you’ll need for a safer and happier holiday season.

You Need an Active inspections Program

Inspections are one of the most common tools in the EHS professional’s toolkit, but you may not be using them as often or as effectively as you could be. Many EHS professionals fall into the habit of doing obvious regulatory-required inspections like forklift inspections or hazardous waste storage location inspections but fall down on doing other inspections related to lesser-known regulations or inspections to identify safety hazards, more generally.

For example, you read earlier in this article about possible fire risks from spray-on “Santa snow,” and potential electrical hazards from daisy chaining extension cords, or permanent wiring setups in which cords pass through doorways or windows. The best way to confirm that you don’t have these hazards in your workplace is to develop tailored inspection checklists you can use, for example, to confirm that no ignition sources are located near decorations containing “Santa snow,” or no wiring setups contain daisy chaining and other hazards.

Look into software that can help you easily create and deploy inspection checklists and access your inspection documentation from anywhere.

Risk Management

All EHS management really boils down to risk management. Your management system needs to focus more broadly on identification of hazards and risks, as outlined in the gold standard for occupational health & safety (OH&S) management, ISO 45001.

A job safety analysis (JSA) is a common type of risk assessment and is considered very effective because it breaks down a job into a number of constituent tasks, so there are fewer places for hazards and risks to hide. Involving front-line workers who do the job every day and understand the risks in the process of developing a JSA is a great way to ensure that you get good-quality input, and that everyone is familiar with the contents and purpose of the JSAs. This is especially true because one of the important purposes of a JSA is to identify and describe the controls in place. Controls are methods you use to lower risk exposure levels—reducing the likelihood of a specific bad thing happening or reducing the severity of the outcome if it does happen.

The benefit to doing JSAs and making them accessible to employees is that you’ll have a lot less uncertainty about the “right” way to do a job, and the safety controls that should be in place. Think back to our example of the person working at the assembly table during the holidays. There would have been less chance of confusion about how to do the work safely if the employee was familiar with the JSA, or even better, was involved in creating it.

The problem is that many EHS professionals are still doing JSAs on paper or on desktop applications. Their JSAs are gathering dust in a physical folder in a file cabinet or gathering virtual dust in an electronic file on a computer desktop, and aren’t fulfilling their intended purpose as active, living documents for guiding everyday safe work practices.

The right operational risk management software can help here by giving you and your team a standardized process for completing JSAs, even offering curated lists of applicable controls and their associated risk reduction factors. The software even automatically applies the risk reduction factors, so you and your employees can see what the overall risk rating looks like before and after implementing the controls, and by extension, understand the importance of conducting the job with the controls in place. You’ll also have access to all of your JSAs from a centralized location anytime you need it.

Ergonomics

One category of risks many EHS professionals don’t pay enough attention to concerns risks of musculoskeletal disorders (MSDs), which are injuries to the joints, ligaments, muscles and nerves that result from strains, overexertion, and awkward or repetitive motions while performing physical work. Many employers have not fully implemented an active ergonomics process focused on “designing out” MSD risks whenever possible and using high quality ergonomics assessments to identify existing MSD risks, determine root causes, and select and implement appropriate controls.

Recall the example of our anxiety-ridden employee working at the assembly table before the holidays. The “normal” way to do that job involved a two-person lift to get some of the larger parts onto the assembly table, but a better way would have been to design out the need to lift the part, or barring that, to have made use of mechanical handling devices the default way to do the job. The employee would certainly have had a happier time, and a happier back, if the employer had a robust ergonomics program that assessed the job task, measured their MSD risks, identified root causes, and implemented effective controls.

The most effective modern ergonomics software provides the support needed to do ergonomics right, with 3-D motion capture capabilities you can use on your mobile device to assess the physical forces exerted by employees performing job tasks.

Subject matter expertise from certified professional ergonomists (CPEs) baked into the software then provides a curated list of probable causes, and once the user selects a cause, the software then shows associated controls, so you can actually use your assessment results to start reducing MSD risks.

Proactive Safety Management is the Gift that Keeps on Giving!

Times like these show you a truth that applies not only during the holidays, but also all year long: You need a safety management system, not just a safety management person.

When you have a system, you have more efficient ways of completing your key tasks, like inspections and follow-up actions, with the direct involvement of your team. When you have a system, everyone knows safe ways to do their work, and they understand the importance of the controls. And when you have a system, your safety performance doesn’t fall apart when key people aren’t around, because the information doesn’t only exist in their heads.

Proactive safety management is truly the gift that keeps on giving, because it keeps your entire workforce safe all year long. You’ve learned above about some of the ways that EHS software can help. While software cannot in itself be a management system, because a management system consists of all the people, policies and places involved in safety management at your workplace, you’ll have an easier time being proactive when you have the right software support.

VelocityEHS can help you. Contact us anytime to learn more about the ways our software platform can provide support for your safety, operational risk, and ergonomics needs. Even better, schedule a demo so you can see our software in action for yourself. Start planning now to have the resources in place you need to have a safe and successful 2025.

From all of us to all of you, we wish you a happy holiday season and a wonderful New Year.

The post 6 Holiday Safety Tips: Managing Workplace Risks So You Can Enjoy the Season appeared first on VelocityEHS.

In the evolving world of risk management, understanding where your organization stands on the maturity curve is crucial for advancing your safety systems. 

At this year’s VelocityEHS User Conference, Jeff Sanford, Senior Global Enterprise Account Executive at VelocityEHS, moderated a panel discussion during, “Risk Management: Align Tactics to Each Point Along the Maturity Curve.” Featuring panelists Nancy Laurie, Occupational Health Manager at Wegmans Food Markets; Rahul Nair, HSE IT Strategy Leader at Cummins; and Willy Elizondo, Risk and Safety Administrator for the City of Goodyear, this conversation explored the journey from immature to mature safety processes. 

The risk management “maturity curve” refers to the progression from a basic, reactive approach—where safety is defined by minimizing failures and managing incidents after they occur—to a more advanced, proactive stance, where the focus is on anticipating risks and preventing issues before they arise. In this paradigm, a mature approach to safety is not just about avoiding problems but ensuring that as many things as possible go right, viewing humans as valuable resources rather than liabilities. 

The risk management maturity curve consists of four key stages: 

• Reactive: Compliance-driven with safety managed mainly by a Safety Manager. 

• Preventive: Increased awareness of risks and supervisor involvement. 

• Proactive: Commitment to standards with a focus on practice, habits, and individual recognition. 

• Advanced: Organizational pride, network contributions, and genuine care for others. 

Before you read the following conversation, reflect on your current safety processes. Where does your organization stand on the maturity curve? What steps can you take to move from reactive safety management to advanced risk management? This discussion will provide insights into advancing your system and enhancing safety culture across your organization. 

The following panel discussion has been condensed and edited for readership. 

The Elements of Planning a Safety Process Before Executing

To begin the discussion, an audience member asked, “You’ve all been in a position where you’ve had to initiate a process from scratch. What do you feel are the elements to planning before executing? And, what is one thing you would tell someone that has found themselves in that same position?”  

Nair: The biggest element is buy-in from every level of the organization. Specifically, middle management’s buy-in as they interact with multiple teams. The second-biggest element is communication; it’s a general concept, but it’s so important to continue communicating when things go wrong, or when red flags are seen before any incidents happen. The third-biggest element, specifically in our journey, is to ensure that you’re following any current processes. Find a balance between implementing new technology alongside the policies and processes that are already in place, ensuring that these three elements align with each other.   

Laurie: One of the biggest things when you’re first starting off is to understand what gap you’re trying to close. What is your problem statement that you’re trying to solve with this project? Secondly, and probably even more important, is to identify your stakeholders. Understand their point of view on that gap that you’re trying to close. That’s going to help you build your requirements documents, which become your third thing, your guidance. You’ll  you’re done when you have all the requirements laid out and have met them all. Over my career, I’ve learned that if you don’t have the right stakeholders at the table, and you didn’t hear what they truly needed and what requirements they have, your project could be set back months, if not years.  

Elizondo: Having that buy-in is crucial. When I started, we had about 50 employees, and now we’re up to 1,800. One key aspect was getting buy-in, especially from our city manager. Early on, I had to sell the idea of dedicating just one hour a week to safety, despite initial skepticism about whether it was feasible. Over time, this hour became a crucial part of our routine, and now safety discussions are ingrained in our operations. 

Advancing Ergonomics and Risk Management Programs with Diverse Teams and Roles  

The second question in the discussion was for Nancy Lauire, specifically. “The unique environment at Wegmans means you lead teams of health and safety professionals for various entities involved in a grocery chain, from distribution to stocking shelves to cashiers and everything between. Can you share how you moved your ergonomics and risk program through that maturity curve?”  

Laurie: You need to meet the business where it is currently to help it move up the curve. At Wegmans, each business unit—distribution, manufacturing, and stores—is at a different stage of maturity. There’s no one-size-fits-all approach to ergonomics across the company. I’ve learned that you need to meet each unit where it is, and introduce changes gradually. For example, we aimed for stores to complete 70% of incident investigations using paper forms in the first quarter, but they quickly exceeded this goal and are now ready for a new digital system. In stores, we started with basic steps, such as incident investigations, and are now moving towards more formal inspections and observations. Distribution centers, already advanced, are working on exoskeleton programs to improve ergonomics. For our engineers and designers, we focus on prevention through design. We’re still evolving and don’t have metrics for all areas, but we’re making progress one step at a time. We are working on educating senior leaders and refining our vision, but it’s an ongoing process of gradual improvement and communication. 

Conducting Analyses to Define the Future Vision for Safety and Ergonomics

At this point in the discussion, a member of the audience posed the question, “I lead continuous improvement in my organization and recently took on supporting ergonomics with our new VelocityEHS system. In continuous improvement, my goal is to demonstrate what excellence looks like so others can follow the journey. Have any of you conducted similar analyses to define the future vision for safety and ergonomics in your organization?” 

Nair: Over the past 20 years, we’ve used various tools and technologies to maintain a strong focus on safety and EHS improvements. Safety is a core company value, not just a priority, so it can’t be deprioritized. We’ve faced shifts in focus, such as the rise of ESG, sustainability, and behavior-based safety, but our main goal remains our public commitments—like achieving zero emissions by 2050 and reducing emissions by 50% by 2030. Despite these challenges, we generally meet our goals by setting clear targets and tracking progress through our project pipeline. However, the journey is not always smooth; it involves bumps and learning opportunities. For instance, while our robust program has been effective for years, change management remains a challenge. Employees accustomed to longstanding practices often struggle with change, requiring us to work closely with the learning and development team to coach them effectively. A recent example is our risk management program rollout, where we encountered issues despite training and providing minimum protective measures. Some employees were not seeing improvements in risk scores, highlighting that basic controls are not enough. We are leveraging AI and machine learning to better understand site-specific challenges and cultural issues. This data-driven approach helps us address underlying problems and move away from ineffective practices, such as repeating training without addressing root causes. 

Staying Organized While Managing Multiple Entities at Different Risk Management Maturity Levels

An audience member asked Elizondo specifically, “I couldn’t imagine trying to manage all the entities of a city and, of course like we talked about, probably all at different maturity levels. How do you stay organized?” 

Elizondo: Managing health and safety across various departments is challenging. To stay organized, I schedule meetings and use tools like VelocityEHS to track action items and deadlines. Despite this, keeping track of progress across departments—such as public works, parks, fire, police, and engineering—can be difficult, especially with varying levels of advancement. One effective approach has been setting clear goals with each team. For example, starting with weekly safety meetings and aiming for 85% attendance helps maintain focus. This goal allows for occasional absences due to emergencies while keeping progress on track. 

Culture Has an Impact on the Progression through the Risk Management Maturity Curve

For the final question of the discussion, Sanford posed this thought, “What is your role in the culture that you’re creating? What role do you see a culture playing in? The movement of your process through maturity, maturity curve, the culture, etc.” 

Elizondo: At our organization, we have “Wild Print Wednesday,” where everyone wears fun, patterned shirts. Today, I accepted a challenge from my team to wear mine here, so I did and sent them a picture. We encourage a culture of openness and accountability. Team members can call me out if they see me not following our values. If they spot issues or need support, I’m ready to help. This no-fear approach fosters honest communication and problem-solving. When I first introduced OSHA standards to our team, there was some resistance. It wasn’t until years later that I realized the cost savings from addressing OSHA’s findings could have funded critical resources like hiring staff or purchasing equipment. Demonstrating the financial impact of safety improvements has helped our team see the value of their efforts. I make it a point to be accessible, whether it’s chatting in the break room or addressing urgent needs from department leaders. If a department needs extra support, I’ll adjust my schedule to help them, even if it means shifting my priorities. 

Laurie: Wegmans is a value-oriented company where exceptional customer service is driven by taking care of our people’s needs. This includes their psychological, financial, physical health, and safety. We emphasize these needs as part of our culture to enhance our safety efforts. Early in my career, I worked with our unionized transportation group, which initially had an “us vs. them” attitude. A key moment came when we debated the best method for setting trailer landing gear. We decided to test both methods, and the safety analysis showed the drivers’ method was more effective. This experience led to greater ownership and collaboration, as drivers and safety teams worked together to implement and teach best practices, fostering a cultural shift towards shared goals and mutual respect. 

Nair: We foster a safety culture of interdependence where everyone is encouraged to call each other out on safety issues without fear of competition. Initially, we tried to quantify this by setting a goal of five issues resolved per month, but this approach led to problems with data quality and effectiveness. Instead, we now focus on ensuring that the quality of the work being completed is high and that sustainable processes are in place. For example, when installing a hoist based on an ergonomics assessment, it’s crucial that it remains in use and is understood by all employees, not just the person who initially requested it. The most important aspect is integrating safety into our manufacturing and operations. Safety indicators are embedded into our manufacturing performance metrics, making safety a visible and integral part of our operations. Each plant’s performance is transparent, and we publish this data externally to maintain accountability and transparency. Finally, safety isn’t just about calling out unsafe practices; it’s also about recognizing and affirming safe practices. If you see someone doing something correctly, let them know. 

Check out more events from VelocityEHS – in-person and virtual – on our Events page! 

The post VelocityEHS User Conference 2024 Digest – Risk Management: Align Tactics to Each Point Along the Maturity Curve appeared first on VelocityEHS.

By Phil Molé, MPH

It’s been a busy year for new regulations, so you might not have heard about MSHA’s 2024 respirable crystalline silica final rule that lowers exposure limits to respirable silica for mine workers and establishes new requirements for mine operators to protect the safety of their employees. The requirements of the final rule will affect many US mine operators and companies that have mining divisions, so it’s important for those organizations to understand their compliance obligations.

In what follows, we’ll break down MSHA’s 2024 respirable crystalline silica final rule and share some major takeaways to help mine operators prepare to meet the new requirements and, most importantly, to keep their workers safe from respirable crystalline silica exposure.

What is the Background of MSHA’s 2024 Respirable Crystalline Silica Final Rule?

Silica is a naturally occurring mineral found in the earth’s crust. There is a long history of humans mining silica to use in products such as glass, ceramics, bricks, and pottery, and consequently an equally long history of laborers having adverse health effects from working with silica.

The U.S. Department of Labor (DOL) notes that the material can cause lung and other diseases, like silicosis (a disease caused by inhalation of silica, characterized by inflammation and scarring in the form of nodular lesions), lung cancer, progressive massive fibrosis, chronic bronchitis and kidney disease. A mixture of respirable crystalline silica and coal mine dust can cause the infamous “black lung” disease, a condition resulting from long-term buildup of coal dust in the lungs, leading to inflammation of the walls of air sacs and eventually to fibrosis. The Associated Press (AP) reports that approximately one in five tenured miners in Central Appalachia has black lung disease, and the problem’s getting worse with dwindling mine capacity forcing miners to dig through more layers of rock to reach coal, generating more silica dust in the process.

Since the early 1970s, MSHA has maintained health standards to protect metal/nonmetal mine (MNM) workers and coal miners from harmful exposure to airborne contaminants, including respirable crystalline silica. MSHA had set the previous Permissible Exposure Limit (PEL) of 100 micrograms per cubic meter (µg/m³) based on the original American Conference of Governmental Industrial Hygienists (ACGIH) Threshold Limit Value (TLV) for silica, which was set in the late 1960’s.

OSHA also has a long history of addressing the hazards of occupational silica exposure. In 1974, OSHA’s sister organization National Institute of Occupational Safety and Health (NIOSH) published a report titled “Criteria for a Recommended Standard: Occupational Exposure to Crystalline Silica” that recommended moving away from using sand as an abrasive blasting agent to reduce worker exposures to respirable crystalline silica. In 1996, the Department of Labor (DOL) initiated a Special Emphasis Program intended to lower occupational exposure to crystalline silica and reduce the incidence of silicosis in the workplace.

In 2016, OSHA published two final rules for construction and general industry, to address common industry exposures from activities such as cutting and sawing of silica-containing materials.

The 2016 rules established a new exposure action level of 25 µg/m³ and reduced the PEL from 100 to 50 µg/m³ (both calculated as 8-hour Time-Weighted Averages, or TWAs). The standards also include requirements for installing exposure controls, implementing   to monitor workers’ health and exposure to respirable crystalline silica (RCS), and maintaining a written exposure control plan. OSHA’s 2016 rulemakings also motivated stakeholders to place increasing pressure on MSHA to issue their own rulemaking to improve worker protections from respirable crystalline silica.

MSHA’s rulemaking process began in 2019 with the publication of a Request for Information (RFI) to solicit feedback from stakeholders on respirable silica to inform a rulemaking process. The RFI specifically asked for feedback on new or developing technologies and best practices to protect miners from exposure to quartz dust, the engineering controls, administrative controls, and personal protective equipment that can be used, and any other feasible dust-control methods to reduce miners’ exposures to respirable quartz. MSHA received a significant amount of stakeholder feedback on these questions.

After several years of compiling and analyzing feedback from the RFI, MSHA published the notice of proposed rulemaking (NPRM) “Lowering Miners’ Exposure to Respirable Crystalline Silica and Improving Respiratory Protection” in the Federal Register in July 2023. There was a tremendous amount of interest in the NPRM, as evidenced by attendance at three public hearings organized by MSHA, which caused the agency to extend the public comment period. MSHA received 157 comments on the proposal and stated that they “carefully reviewed and considered the written comments on the proposed rule and the speakers’ testimonies from the hearings” during the process of developing the final rule.

What Does MSHA’s 2024 Respirable Crystalline Silica Final Rule Change?

The preceding discussion highlights that the final rule had been a long time coming, but it was finally published in the Federal Register on April 18, 2024. MSHA estimates that the provisions in their final rule will avoid 1,067 deaths and 3,746 silica-related illnesses.

Here are some of the most significant changes brought by MSHA’s 2024 respirable crystalline silica final rule

Establishes a Reduced, Uniform PEL and AL

MSHA’s final rule reduces the PEL from 100 micrograms per cubic meter (µg/m³) to 50 µg/m³ as measured as an 8-hour TWA. MSHA has also established an action level (AL) at half the PEL, or 25 ug/m3. Mine operators must conduct periodic sampling when miner exposures are at or above the AL but below the PEL.

Adoption of the reduced PEL and AL better aligns MSHA with OSHA, who as previously mentioned, established the same OELs for workers in general industry and construction via their 2016 final rules. Between 2016 and now, some companies have been in an awkward position, because (e.g.) they may have mining divisions covered by MSHA that extract raw materials including crystalline silica, and general industry facilities that process and distribute materials containing silica covered by OSHA, sometimes all on the same property. Technically, there was a gap in regulatory protections, in which a company could legally expose its mining sector workers to twice the concentration of silica as its general industry workers. In the 2016/2017 timeframe, VelocityEHS often gave presentations on the OSHA silica rules and advised attendees that if they had some workers subject to OSHA’s silica PEL and others to MSHA’s PEL, they should uniformly commit to keeping respirable silica exposures below the more protective OSHA PEL. Now that the MSHA final rule has aligned OELs for the mining industry with OSHA’s silica OELs for general industry and construction, there’s a much greater likelihood that all employees who work with silica will have the same exposure protections.

Requires Exposure Monitoring

Of course, setting OELS for respirable crystalline silica can only protect worker safety if employers are conducting   to determine if their employees are exposed to air concentrations above the OELs. That’s why MSHA’s 2024 respirable crystalline silica final rule requires mine operators to conduct air sampling to assess employee exposures to respirable crystalline silica.

The final rule also updates the standard for respirable crystalline silica sampling to ISO 7708: 1995(E), “Air quality— Particle size fraction definitions for health-related sampling.” MSHA adopted this standard by reference because it’s the international consensus standard defining sampling techniques for particle size fractions to be used in assessing potential health effects of airborne particle exposures on workers. Mine operators must conduct air sampling using respirable particle size-selective samplers that conform to ISO 7708:1995.

Mine operators should note that there are two very major differences between OSHA requirements regarding silica exposure monitoring and corresponding MSHA requirements, as follows:

PEL and TWA Calculation Method

There is a major variance between the ways employers can calculate TWA exposures between OSHA’s silica rules and the methodology allowed by the MSHA final rule. The differences center on how employers can sample exposures of employees who work longer than 8-hour shifts. MSHA’s 2024 respirable crystalline silica final rule requires the employer to sample over the duration of the full work shift.

Suppose that a miner exposed to respirable crystalline silica works a 10-hour shift. MSHA dictates that an operator cannot just sample for 8 hours to confirm that exposures are under the PEL or AL as an 8-hr TWA, explicitly stating “under Part 60, the PEL and the AL apply to a miner’s full-shift exposure, calculated as an 8-hour TWA.” This means that the employer must collect the dust sample for the miner who works 10-hour shifts over the entire 10 hours.”

OSHA has no such “full shift” provision for determining TWA in their silica regs.

There’s No “Table 1” in the MSHA Final Rule

OSHA’s silica rule for the construction industry includes a Table 1 that lists certain activities and associated control measures. The OSHA rules provide an allowance stating if construction employers conduct Table 1 tasks exactly as described in Table 1, they would not need to conduct exposure assessments since the controls would result in negligible respirable dust generated. OSHA’s rules also allow employers in general industry to use Table 1 to reduce exposure monitoring obligations if they not only conduct Table 1 tasks as described in the table, with all associated controls, but also abide by other provisions of OSHA’s more stringent silica rule for construction, rather than the provisions within the general industry silica rule.

However, there is no Table 1 or any analogous table provided in MSHA’s 2024 respirable crystalline silica final rule, which means that mine operators don’t have the available “outs” for exposure monitoring that employers in general industry and construction have.

MSHA had not specifically included provisions for a Table 1 in their NPRM, but the proposal sought comments on specific tasks and exposure control methods appropriate for a Table 1 approach for the mining industry that would adequately protect miners from risk of exposure to respirable crystalline silica.

Why didn’t MSHA adopt a variation of Table 1? According to the final rule, the stakeholder feedback MSHA received convinced the agency that a Table 1 approach would not provide the necessary protection for miners against overexposure to respirable crystalline silica under all mining conditions. MSHA also maintains that the changing nature of the mining environment necessitates exposure monitoring to ensure that controls are functioning effectively, properly maintained, and adjusted as needed to ensure compliance.

Requires Reporting and Corrective Actions for Overexposures

What if mine operators identify overexposures through their silica monitoring program? The MSHA final rule requires mine operators to take corrective actions needed to lower the concentrations of respirable crystalline silica to a level at or below the PEL. The operator must also conduct resampling to verify that control measures were effective at reducing concentrations and maintain records of all sampling conducted and corrective actions taken.

Many different regulations targeting harmful occupational exposures require employers to take corrective actions when sampling results indicate exposures above OELs. However, here’s where we encounter another major variance between OSHA and MSHA silica rules, this time concerning the obligation (or lack of one) to report measured employee exposures over the PEL.

OSHA’s silica rules don’t require employers to report exposures measured above the PEL to OSHA, but MSHA’s 2024 respirable crystalline silica final rule requires such reporting to MSHA, stating that mine operators must “immediately report all exposures above the PEL to the District Manager or to any other MSHA office designated by the District Manager.”

The final rule states that MSHA adopted this overexposure reporting provision in response to stakeholder feedback about the importance of the agency’s active involvement in operator sampling and awareness of all overexposures so they’re better prepared to take appropriate actions, including compliance assistance and enforcement.

Specifies Methods for Controlling Silica Exposure

All mine operators must install, use, and maintain feasible engineering controls as the primary means of controlling respirable crystalline silica. Operators may use administrative controls, when necessary, as a supplementary control method.

The key concept MSHA is using here is the hierarchy of controls, as shown in the image below.

Note that the hierarchy has the form of an inverted pyramid, showing the order that employers should use risk controls, with the most effective controls on top and the least effective on the bottom. It’s especially important to remember that the very bottom level is personal protective equipment (PPE), since there’s still a tendency for many employers to use PPE as a first line of defense rather than as a last resort, as intended. The levels of controls above PPE are more effective at reducing exposure, with the most effective being elimination/substitution since it eliminates exposure hazards at the source.

Of course, elimination or substitution is not often feasible in mines, where the nature of the work itself involves extracting minerals, so operators must use a combination of the next levels of controls. However, as you’ll soon see, MSHA is significantly limiting operator options to use PPE to reduce exposures.

Requires Temporary Use of Respirators at Concentrations Above PEL

What if sampling results identify areas where workers are exposed to concentrations of respirable crystalline silica above the PEL, but the mine operator still needs work to be conducted in that area before they can implement any controls?

MSHA’s 2024 respirable crystalline silica final rule states that MNM operators must use respiratory protection as a temporary measure when miners must work in areas with concentrations of respirable crystalline silica above the PEL while the employer is developing and preparing to implement engineering control measures.

It’s important to understand the significance of this requirement and how it differs from OSHA’s silica rules. While both MSHA and OSHA stress the importance of the hierarchy of controls discussed above, OSHA allows respirators as a compliance method as a last resort if other and better control methods have not reduced exposures to levels below the PEL. OSHA’s silica rules also include provisions requiring employers to limit access to areas with exposures above the PEL to employees with respirators, and to make employees aware of the restriction.

On the other hand, MSHA’s 2024 respirable crystalline silica final rule only allows respirator usage on a temporary basis while the employer is addressing reduction of exposures through other controls. That’s a MAJOR difference. This means, in practice, that once you identify exposures above the PEL in your mine workplace, you need to immediately start planning and implementing other controls to reduce exposure below the PEL. While it would not be surprising to see the mining industry collectively push back against this requirement, this is how the regulation is currently written, and operators need to start planning to comply with this provision.

Updates the Respiratory Protection Standard

The final rule incorporates by reference ASTM F3387-19 (Standard Practice for Respiratory Protection). ASTM F3387-19 is the most recent respirator practices consensus standard and provides more comprehensive and detailed guidance than previous standards. MSHA also states that this update will improve worker protections by requiring more mine operators to provide miners with NIOSH-approved respiratory equipment that has been fitted, selected, maintained, and used in accordance with recent consensus standards. MSHA has published a fact sheet to provide additional guidance on respirator selection and use under the final rule.

What kinds of respirators can mine operators provide to their employees? According to the final rule, mine employers must provide either NIOSH-approved atmosphere-supplying respiratory protection or NIOSH approved air-purifying respiratory protection equipped with particulate protection classified as 100 series or High Efficiency ‘‘HE’’ under 42 CFR part 84. 100 and HE refer to the NIOSH-approved particulate filter classification and level of filtration (i.e., 99.97% filtration efficiency). Air-purifying respirators are more commonly used in the mining industry. Mine operators can also assign employees with atmosphere-supplying respirators (e.g., supplied air respirators), depending on the task and hazard.

Mine operators must also develop and maintain a written respiratory protection program to protect miners from airborne contaminants, including respirable crystalline silica, in accordance with ASTM requirements, and ensure that employees assigned respirators receive adequate training and use the respirators properly.

It should be noted that there is some variance between the respiratory standard adopted by MSHA and the respirator selection guidelines adopted by OSHA’s silica final rules. OSHA’s rules name OSHA’s Respiratory Protection standard in 1910.134 as the means for employers to select appropriate respirators. 1910.134 (d) covers respirator selection, and states that employers must use the assigned protection factors (APFs) listed in a table (see below) to select an appropriate respirator for the exposure conditions.

Most relevant to our discussion here, Section 1910.134(d)(3)(iv) further clarifies that for particulate matter exposures, employers must either provide an atmosphere-supplying respirator or an air-purifying respirator equipped with a filter certified by NIOSH under 30 CFR part 11 as a high efficiency particulate air (HEPA) filter, or an air-purifying respirator equipped with a filter certified for particulates by NIOSH under 42 CFR part 84.

While respirator selection criteria under OSHA and MSHA’s final rule have no direct conflict and generally lead to the same types of respirators being selected (namely, atmosphere-supplying or air-purifying), the selection process between the two regulatory frameworks does have slight differences. Mine operators not yet familiar with the provisions of ASTM F3387-19 should ensure they understand and follow the standard when selecting respirators for employees exposed to respirable crystalline silica. If a company has operating locations in both general industry and the mining sector, they should try to select and uniformly assign the respirators that provide the highest level of protection to all employees across both sectors.

Requires Medical Surveillance at MNM Mines

MNM mine operators must provide all miners with periodic medical examinations performed by a physician or other licensed health care professional (PLHCP) or specialist. These examinations must be available at no cost to the miner, which means that the employer must cover all associated costs, including costs of travel to and from the PLHCP, if applicable. The intent of this requirement is to enable MNM miners to monitor their health and detect early signs of respiratory illness from silica exposure.

There’s yet another variance from OSHA’s silica rules here. Unlike OSHA’s rules, MSHA’s 2024 respirable crystalline silica final rule does not include a risk or exposure-based trigger for medical surveillance requirements, such as the provision in OSHA’s general industry silica rule that medical surveillance requirements only kick in when an employee has exposure to concentrations above the AL for 30 days in a year. MSHA states that they did not adopt an exposure trigger provision because they want to maintain consistency between the medical surveillance requirements for MNM and coal mines to ensure all miners have the information necessary for the early detection of silica-related disease.

The MSHA final rule also requires MNM mine operators to obtain a written medical opinion from a PLHCP or specialist regarding any recommended limitations on a miner’s use of respirators under § 60.15(e). The written medical opinion must contain the date of the medical examination, a statement that the examination has met the requirements of the section, and any recommended limitations on the miner’s use of respirators.

What happens if the PLHCP determines that a miner is unable to wear a respirator? The final rule states that the employer must provide that employee with a temporary job transfer to an area or to an occupation (within the same mine) where respirators are not required and provide the employee with compensation at least equal to the pay provided immediately prior to the transfer. Affected miners may only return to their initial work area or occupation when respirators are no longer required. Finally, the employer must maintain a copy of the PLHCP’s written determination must be maintained for the duration of the miner’s employment plus 6 months.

What is the Compliance Timeline for MSHA’s 2024 Respirable Crystalline Silica Final Rule?

The final rule is already in effect as of June 17, 2024, but on a phased-in compliance timeline. Coal mine operators must be in compliance with part 60 by 12 months after the publication date, while MNM operators must be in compliance by 24 months after the publication date.

The table below summarizes the compliance timeline for operators affected by MSHA’s 2024 respirable crystalline silica final rule.

What are the Major Takeaways on MSHA’s 2024 Respirable Crystalline Silica Final Rule?

As you’ve learned, there are a lot of moving parts to MSHA’s respirable crystalline silica final rule. Here are some high-level takeaways to help you prepare.

You’ll now have an easier time providing the same level of protection for all employees in your company. Here’s the good news. In general, there is now a higher level of protection from silica exposures for mining workers because of the reduced PEL and AL, which are the same levels as OSHA’s PEL and AL for general industry and construction. If your company contains both general industry and mining divisions, that means you’ll have an easier time providing the same level of protection to all employees across your organization.

Even so, there are variances between OSHA and MSHA requirements. MSHA has updated the respiratory protection standard used as the basis for their respirator selection criteria. Unlike OSHA, MSHA hasn’t adopted a Table 1 listing the tasks and controls which would negate the need for exposure monitoring if conducted as described and does not allow respirator usage as a long-term solution to exposures above the PEL, which means mine operators would have to proactively use better control methods such as engineering controls or administrative controls to address overexposures. Not only that, but mine operators will need to report exposures above the PEL to MSHA.

You have little room for error. Collectively, these provisions mean you have little margin for error and inefficiency in your management of respirable crystalline silica. For example, you need to know if you have sampling results indicating exposures above the PEL quickly, so that you can report the overexposure to MSHA, and begin planning and implementing controls to reduce exposures below the PEL. That, in turn, means you need easy and effective ways to select   to include in your sampling program, choose analytical laboratories, and easily access and share reports of sampling results. At the level of everyday safety, you also need to be able to create and deploy tailored inspection checklists to ensure, for example, that controls are in place and working effectively.

If you have worksites in the mining sector, now is the time to assess the tools you currently use for managing respirable crystalline silica exposure. You’ll need agile safety management tools to schedule and complete inspections, analyze results, and assign and manage corrective actions. Industrial hygiene ( can help streamline every aspect of your program management, from selection of SEGs to management of sampling results to tracking of respirator fit tests.

Let VelocityEHS Help!

To meet the deadlines of MSHA’s new respirable crystalline silica final rule, you need to start preparing now. Luckily, VelocityEHS can help you, because we designed our Industrial Hygiene software capabilities based on American Industrial Hygiene Association (AIHA) best practices, and the input of busy EHS managers like you.

Our software helps you create and manage SEGs and embeds IH lab sampling and analysis guides directly into your system to help ensure you always sample using the right techniques. You’ll also be able to streamline your tracking of samples from collection to analysis with automated chain of custody forms, get guidance selecting analytical laboratories, and have the option to share sampling results with laboratory representatives or third-party consultants.

If you need the support of world-class safety software to help you better create, conduct, and manage inspections and all of your resulting corrective actions, we can help you there, too. Check out our case study to see how a large mining company successfully used our software to provide a single, centralized system for their safety management needs.

Contact us today to learn more about how we can help you improve your IH program and build safety and sustainability maturity.

The post Understanding MSHA’s 2024 Respirable Crystalline Silica Final Rule appeared first on VelocityEHS.

OSHA recently released its eagerly awaited annual list of the Top 10 Most Frequently Cited Standards for 2024 at this year’s National Safety Council (NSC) Safety Congress & Expo. The OSHA Top 10 List of Most Frequently Cited Standards is highly anticipated because it provides valuable insights for safety professionals, employers, and other organizational stakeholders into OSHA’s enforcement activities and priorities during the previous year, trends in workplace health and safety risks, and clues as to where employers should focus their efforts to improve compliance and better protect workers.

OSHA Top 10 Most Frequently Cited Standards for 2024

Below is the full ranked list of OSHA’s Top 10 Safety Violations during FY 2024 between October 1, 2023, and September 5, 2024:  

1. Fall Protection—General Requirements (1926.501): 6,307 violations
2. Hazard Communication (1910.1200): 2,888 violations
3. Ladders (1926.1053): 2,573 violations
4. Respiratory Protection (1910.134): 2,470 violations
5. Lockout/Tagout (1910.147): 2,443 violations
6. Powered Industrial Trucks (1910.178): 2,248 violations
7. Fall Protection – Training Requirements (1926.503): 2,050 violations
8. Scaffolding (1926.451): 1,873 violations
9. Personal Protective and Lifesaving Equipment – Eye and Face Protection (1926.102): 1,814 violations
10. Machine Guarding (1910.212): 1,541 violations

OSHA Top 10 Citations: 2024 Trends & Statistics

The OSHA Top 10 Most Frequently Cited Standards for 2024 closely resembles last year’s list, featuring the same familiar standard violations that we continue to see on the list year after year. However, there are a couple of interesting shifts in the rankings compared to 2023. Here are a few takeaways and things to consider:

• For the fourteenth consecutive year, Fall Protection continues to hold the #1 spot on OSHA’s Top 10 for 2024.
• OSHA’s Hazard Communication Standard (HazCom) continues to rank #2 on the list for the third consecutive year (2022-2023), after falling to #4 in 2021.
• Somewhat surprisingly, OSHA’s Respiratory Protection Standard has returned to the fourth spot on the Top 10 list after falling to #7 in 2023. The Respiratory Protection Standard had ranked #3 in 2020 and 2022, and #2 in 2021, presumably due to increased Respiratory Protection Standard enforcement emphasis during the height of the COVID-19 pandemic.
• Citations for OSHA’s Ladders Standard remain the fourth most commonly cited standard for the second consecutive year, ranking fourth in 2022 to reach #3 in 2023. That rank has steadily risen over the past six years, having ranked seventh and eighth in 2013 through 2016.
• OSHA’s Control of Hazardous Energy Standard (Lockout/Tagout) rose from sixth on the list in 2023 to fifth in 2024, a nearly 24% increase in total number of citations over last year.
• 2024 saw a nearly 10% decrease across the board in terms of the total number of violations of OSHA’s Top 10 most frequently cited standards compared to 2023. It should be noted, however, that 2023 saw a similar increase in total citation numbers compared to 2022.

Improve Workplace Safety by Leveraging the OSHA Top 10 Most Frequently Cited Standards List 

With OSHA regularly re-organizing inspection and enforcement efforts and civil penalties increasing consistently every year, employers need to stay on top of compliance. The OSHA Top 10 Most Frequently Cited Standards list is a valuable resource to prioritize your compliance efforts and ensure your safety programs address the most common and serious workplace hazards.  

If you’re responsible for safety management at your company, here are some ways to take advantage of the OSHA Top 10 List: 

• Examine your safety program and identify potential hazards covered under OSHA Standards on the list that may be present in your workplace(s). 
• Evaluate your company’s past and present written safety programs, safety records, and compliance documentation to make sure they comply with OSHA standards. 
• Engage with your workforce to get insights and ideas into how safety can be improved in these most commonly cited areas of compliance, above and beyond your routine worker safety engagement efforts. 
• Have a solid training program in place and ensure all employees are up to date on their training, specifically training required within OSHA Standards including those listed in the OSHA Top 10. 

VelocityEHSCan Help! 

Velocity’s Safety software gives you the rapid access and clear visibility of safety data and trends needed to identify critical EHS issues, verify compliance, and optimize workplace safety performance. The solution scales to meet the needs of any size company across any industry. It provides an intuitive, user-friendly interface to engage and empower employees to play an integral role in your workplace EHS programs. With a solid EHS management software platform, you’ll have the foundation to pursue EHS maturity and Environmental, Social, and Governance (ESG) excellence.

Request a Demo today to learn how we can help you simplify compliance, improve workplace safety performance, and promote a stronger workplace safety culture.

The post OSHA Unveils Top 10 Most Frequently Cited Standards for 2024   appeared first on VelocityEHS.

VelocityEHS recently hosted the webinar “Regulatory Recap & Ways to Stay Compliant Using an ISO Approach to EHS Management,” presented by VelocityEHS Senior EHS & ESG Content Manager Greg Duncan, MELP, CSP and STP ComplianceEHS Director of Partnerships Shannon Major, BES(Hons), EP (CEA). Key themes and highlights from the discussion included:

• Core elements of management system standards like ISO 45001 and 14001, and their benefits and collective function in maintaining compliance.
• Recent changes to some of the most broadly applicable EHS regulations and what upcoming changes employers can expect, including:
  • New requirements for chemical manufacturers, suppliers, and employer end-users under the 2024 OSHA Hazard Communication Standard (HazCom) Final Rule
  • New and updated 2024 reporting requirements under EPA EPCRA 313 Toxics Release Inventory (TRI)
  • New employer classifications and reporting requirements under OSHA’s 2024 Injury and Illness Recordkeeping Final Rule
  • New and modified requirements within the 2024 EPA Risk Management Program (RMP) Rule
• Steps and best practices you can take today to improve your own EHS management systems and strengthen compliance.

What are the Relevant Elements of EHS Management System Standards?

International management system standards, namely the ISO 45001 Occupational Health and safety (OH&S) Management and ISO 14001 Environmental Management standards, are largely rooted in helping organizations to not only achieve compliance, but to provide agility and adaptability in the face of changing regulatory requirements.

ISO 14001

An Environmental Management System (EMS) designed to help organizations improve their environmental performance through more efficient use of resources and reduction of waste, gaining a competitive advantage and the trust of stakeholders.

ISO 45001

An Occupational Health and Safety Management System (OHSMS) that offers a single, clear framework for all organizations wishing to improve their OH&S performance. Directed at the top management of an organization, it aims to provide a safe and healthy workplace for employees and visitors.

In addition to laying the groundwork for building a safer and more sustainable business, ISO management system standards such 14001 and 45001 provide numerous advantages for organizations that commit to aligning to their guidance. For one, all ISO standards are built around a common framework that allows for integration of multiple management system standards within a unified structure. This greatly simplifies alignment and provides a consistent management system structure across the full range of ISO standards. In addition, all ISO standards are also rooted in the common underlying principle of risk management, meaning that organizations that implement ISO 45001 and/or ISO 14001 are provided with a systematic process to move their EHS programs from a more reactive, compliance-focused approach toward one that is more proactive and adaptable to changing requirements. Lastly, ISO management standards such as ISO standards 45001 or 14001 are voluntary, heavily focused on both “top-down” management involvement and “bottom-up” worker engagement, and involve taking a proactive, systematic approach toward reducing risk—meaning when companies choose to align or certify to them, it visibly demonstrates an organization’s genuine dedication to EHS management and continuous improvement.

What EHS Regulations are Changing?

Recent changes to EHS regulations not only present challenges for EHS professionals tasked with compliance but are a blaring signal of future directives and priorities for environmental and OH&S regulators. Here are some highlights from the big regulatory changes discussed during the session:

OSHA Hazard Communication (HazCom) Updates

OSHA’s 2024 Hazard Communication Standard (HazCom) Final Rule introduces new hazard classes and categories, GHS pictogram requirements, container labeling requirements, and multiple SDS information changes. In total, according to OSHA, 94.4% of SDSs and 64% of labels (non-small/very small) will need to be revised.

EPA EPCRA 313 (TRI/Form R) Reporting

2024 updates to EPA’s EPCRA 313 TRI reporting requirements include newly added chemicals to the TRI 313 list, most notably Per- and Polyfluoroalkyl substances (PFAS), as well as several updates to the TRI-ME Web online reporting portal.

OSHA Injury and Illness Record Keeping Final Rule

The 2023 updates to OSHA’s Injury and Illness Recordkeeping Rule revises the reporting requirements and applicability criteria for employers covered under the rule. It also expands electronic reporting requirements to include Form 300 and 301 injury and illness data, and the publication of these injury records.

EPA Risk Management Program (RMP) Rule

EPA’s 2024 updates to RMP requirements include Safter Technology and Alternatives Analysis (STAA) for Program 3 facilities to conduct practicality assessments for safer technologies. Updates also include new requirements for all RMP covered facilities to formally assess natural and adjacent hazards, implement prescribed methodologies for incident root cause analysis, assess need and feasibility of backup power systems for monitoring and control equipment, and submit to 3rd-party audits in the event of most hazardous chemical releases.

What can you do to Improve your EHS Management System?

In light of these significant regulatory changes on top of existing compliance obligations, EHS professionals are likely asking how they’re going to get ahead of their requirements. To address this most pressing question the presenters discussed several best practices and strategies EHS professionals can apply to help strengthen their compliance management processes and overall EHS management systems in line with ISO 14001 and 45001 management system standards, including:

• Nurture stakeholder engagement and involvement in ISO management system planning, implementation, review, and improvement processes.
• Leverage the capabilities of EHS software and regulatory content providers like STP ComplianceEHS in management system scoping and planning processes (and throughout the EHS program management process) to strengthen applicability analysis and ensure comprehensive recognition and completion of compliance requirements.
• Recognize that when knowledge and expertise in EHS compliance resides within individuals, the business can easily be disrupted if those individuals leave the organization. Prioritize both business continuity and resilience when implementing compliance management systems and strategies.
• Give special emphasis and sufficient consideration to Management of Change (MOC) processes as you adapt your EHS management system to changing risks and regulatory requirements. Ensure all affected stakeholders are involved in MOC processes and promoting visibility and accountability for successful change implementation. Review and improve MOC processes often!
• Implement systems that translate written compliance requirements into concrete compliance actions to promote high levels of accountability and ownership for compliance, and to better track compliance status.
• Recognize how EHS management functions, including compliance management, map onto the Continuous Improvement Process, and where tools and technologies can be implemented to simplify and enhance those EHS management functions.

Want to learn more? Watch the full webinar on demand.

VelocityEHS and STP ComplianceEHS Can Help!

Velocity’s Chemical Management and Safety software make it easy for you to maintain compliance with a wide range of EHS regulations, including OSHA HazCom, OSHA Injury and Illness Recordkeeping, EPA EPCRA TRI reporting and many more. You get intuitive tools that let you and your employees manage your chemical inventory and SDS library from anywhere 24/7, along with other core safety tasks including safety meetings, incident investigations, and corrective actions. You also get powerful Audit and Inspection capabilities which, when combined with STP ComplianceEHS AuditHub regulatory content integration, give you pre-built, auto-updated and customizable compliance checklists to simplify compliance and help you stay ahead of an ever-changing regulatory landscape.

Contact us today to learn how VelocityEHS and STP ComplianceEHS can help you!

The post EHS Regulatory Recap & Ways to Stay Compliant Using an ISO Approach to EHS Management: Velocity + STP Post Webinar Highlights appeared first on VelocityEHS.

By Phil Molé, MPH

Vehicle owners in Winston, Connecticut got quite a surprise when they returned to their car the morning of July 15, 2024. They heard the horn blaring and the radio blasting and saw a full-grown black bear and a cub trapped inside the car. The owners contacted state environmental conservation officials, who carefully opened one of the car doors, allowing both bears to run off into the woods. No people or bears were hurt in this incident, although pictures in the news story show that the bears did quite a number on the inside of the car before taking their leave.

This incident was the first of three episodes involving run-ins with bears in Connecticut over just six days—at least, three episodes we know about because someone reported them to state authorities.

Bear encounters in certain parts of the US are quite common. In fact, there was an incident last year in which a bear entered a bakery in Avon, Connecticut and ate 60 cupcakes before finally having its fill and leaving the store. (If my late father were around, he’d probably turn this story into a joke by adding, “A few days later, the bear sued the bakery, because he said the 60^th cupcake made him sick.”)

There are many other examples of incidents between people and wild animals, some of which have more serious consequences. For example, people who encounter wild bison sometimes experience life-threatening injuries. A bison in Yellowstone Park gored a 25-year old woman from Ohio in 2022 after the woman came within 10 feet of the animal—much closer than the 25-feet distance that park officials tell visitors to maintain. Yellowstone emergency medical professionals airlifted the woman from park grounds to a medical facility, where she received treatment for severe injuries. Earlier this year (2024), another gore incident happened at Yellowstone, this time involving an 83-year-old woman, but with many of the same details, — she got too close to a bison, was gored, and then airlifted to the same medical facility that treated the woman gored in 2022.

When Situations Change, Change Your Perception of Safety Risks

Why do so many people find themselves in unanticipated and often dangerous confrontations with wild animals? Part of the reason is there’s a wide range of public perceptions about the likelihood of such confrontations. Let’s call these baseline perceptions because they’re the ones we hold most of the time and are rooted in the experiences we have most often.

For example, people have a wide range of baseline perceptions when it comes to the potential for a face-to-face with a wild bear. As the great Texas-born singer songwriter Lyle Lovett sang in one of his signature songs, titled (appropriately enough) “Bears,” “some folks say there ain’t no bears in Arkansas/some folks never seen a bear at all,” but Lyle adds that “some got a bear across the hall.” (By the way, as a quick fact check, there are bears in Arkansas, so the hypothetical doubter in Lyle’s verse above is wrong. A helpful fact sheet published by University of Arkansas states that over 3,000 black bears live in wooded areas throughout the state.)

Another part of the explanation is that people don’t do a good enough job adjusting their baseline perception of safety risks when they’re in different situations that may increase the chances of a wild animal encounter.

Some real-world details may help explain this concept. I live in Chicago, Illinois. There are foxes around here, and coyotes, but there are no resident bear populations, so encountering a bear outside of a trip to a local zoo is extremely unlikely. Because of that, I have a very low baseline perception of the risk of running into a bear while I’m in my native Chicago, which is appropriate if I stay in Chicago. But the problem is, when I hop into a car or (maybe especially) a plane to travel someplace far away from my hometown, I take my low perception of a bear encounter with me along with my suitcases and suntan lotion, even when I’m going to places where a higher risk perception is warranted. I say “especially a plane” because the greatly reduced time to travel huge distances by airplane adds to the perception that your situation and its associated exposure risks couldn’t have changed much.

Risk exposure levels change significantly if you’re going someplace that has wild animals like bears, bison, cougars, or alligators which are not found where you normally live. To adjust baseline perception of safety risks to something more reflective of actual risk exposure, you need to do some work. Research the native wild animals at your travel destination. Learn the specific locations they’re found in (e.g., rain forests, swamps), and specific details about them (e.g., knowing that aggressiveness in bison increases during mating season, which typically lasts from mid-June to mid-August, can be helpful). Learning this information, keeping it top of mind, and using it to adjust your behavior will help you stay safe.

Another consideration is that many people have a baseline risk perception of animals based on entertainment experiences, such as going to zoos, where conditions are generally safer if existing safeguards are in place. Those experiences, and the expectations created by them, don’t help people understand the much greater risks of encountering wild animals in their native habitats.

These lessons apply to many other areas of life, and certainly apply to EHS management, because there are many occupational health & safety (OH&S) risks you need to manage, and many ways that risk exposures can change. When those risk exposures change, your perception of safety risks, as well as your strategies for controlling and managing risks, needs to change, too.

Let’s look at some of the tools available to help you assess and control risks, and to update your baseline risk perceptions when needed.

Inspections are Part of a Proactive Safety Management System

Inspections are one of your most important methods for confirming that you’re really doing the things you say you’re doing. They’re also a great way to learn that you’re not doing things you should be doing, or that you are doing things you shouldn’t be doing.

Inspections are also very useful for detecting when things have changed. Maybe the last time you were in a warehouse area, the hallways had no tripping hazards or obstructions. Is that still the case? The only way to find out is to do an inspection. If you do find that hallways are obstructed, you need to adjust your baseline perception of the risk of potential trips and falls accordingly, until or unless you remove the obstructions, address the root cause for the obstruction, and have enough subsequent observations to feel confident that you’ve addressed the cause of the obstructions and prevented future occurrences.

There are a couple of considerations involved in conducting effective inspections. First, you need to have inspection checklists tailored for your workplace, or a specific part of your workplace. In the warehouse hallways example, you could make a tailored inspection checklist for that area to confirm that there are no trip hazards or obstructions. You also need to make sure you have easy ways for employees to conduct the inspections using approved checklists and can access inspection results from anywhere. Traditional paper checklists make that difficult to do but inspection software capabilities can help you improve the ease and accuracy of your inspections, and let you review inspection results for all your facilities from one centralized online location.

That latter point is especially important because the whole point of conducting inspections is to use the information in them to improve safety. For example, you can identify walkways where raw material or tool storage is creating potential for trips and falls, work out strategies for keeping the walkways clear, and then develop a specifically tailored inspection checklist to ensure those walkways stay clear.

Using and tracking that checklist is a good example of a leading indicator (also sometimes called a “leading metric”), which is a metric associated with tracking a safety activity you have good reason to think is related to achievement of a primary safety goal. In the example discussed above, the primary goal is to reduce the number or rate of slip/fall injuries but use and review of the checklist is a leading indicator because using it would presumably help you achieve your goal by making sure walkways are unobstructed. Using tailored checklists is also a great way to quickly identify when risk exposures have changed because of new hazards, giving you a chance to adjust your perception of safety risks and your risk management strategies.

Methods for Conducting Risk Assessments

As useful as inspections are, they’re not enough by themselves to keep your perception of safety risks sharp. You need tools specifically designed to proactively and systematically identify risks. Luckily, there are several good methodologies available, including:

Hazard Identifications (HAZIDs): a method of breaking down workplace processes to identify hazards and controls and assess their effectiveness at reducing risks. You can think of HAZIDS as brainstorming exercises for identifying risks that help build workplace engagement around safety and lay a foundation for more detailed risk assessments to follow.

Job Safety Analysis (JSA): a risk assessment method that breaks down a job into its constituent tasks to enable better identification and control of risks. One of the advantages of JSAs is that they leave fewer places for unidentified risks to hide, because the process of breaking down jobs into tasks encourages you to look more closely for risks in more places.

Risk Bowties: a visual risk management tool that helps pull together relevant information about risk pathways: the logical connection between causes and the accident or adverse event we’re trying to avoid, and between the event and its consequences, as shown in the image below.

Risk bowties provide a great opportunity for employees to participate in operational risk management, and their easy-to-understand visual organization makes them an ideal tool for training employees about workplace risks and the importance of having risk controls in place.

The Importance of Management of Change

There’s an important caveat with these risk assessments directly connected to this article’s theme: to be effective, your risk assessment must change when situations change. The encounters with wild animals discussed earlier happened because the people involved didn’t change their baseline perception of safety risks after putting themselves in situations where risks of wild animal encounters were greater. Of course, changes in risk exposure need not involve a change in physical location, because they may also stem from changes to details about work or the work environment in your current location.

Any risk assessment captures a “moment in time.” If nothing changes about the important details, like the physical work environment, details about how employees conduct the work, or the hazardous chemicals involved, the assessment remains accurate. However, if you make these kinds of changes to work at your site and don’t make corresponding changes to your risk assessments, you’re not adequately identifying risks as they are today, and you certainly can’t be effectively controlling those risks or communicating them to your employees. Your risk assessments are frozen in the past, and this places the safety of your people at risk.

Here are a few examples of changes that can increase risk exposures in your workplace, and should result in updating your perception of safety risks:

Introducing new process chemicals. Hopefully, this will be obvious. Potential exposure to hazardous chemicals is always among the most significant risks in the workplace, but not all chemicals are equally hazardous. Some chemicals have established Occupational Exposure Limits (OELs), which define the average concentration of a chemical workers may be exposed to for certain durations of time, often expressed as 8-hour time weighted averages (TWAs). Chemicals may also pose environmental risks by becoming hazardous wastes or having enough potential to cause harm to merit placement on regulatory lists such as EPA’s Hazardous Air Pollutants (HAPs) or Toxics Release Inventory (TRI)-reportable chemicals.

Changes to physical workplace. Changing the relative placements of equipment and employees may increase the exposure of some employees to workplace stressors like noise, heat, or indoor air contaminants, because of possible factors like working closer to furnaces or chemical storage areas. Changes to the physical workspace can also create risks of musculoskeletal disorders (MSDs) due to lack of ergonomics assessments or introduce potential for fall or trip hazards.

New employee uniforms. Here’s an example based on a real-life situation familiar to the author that might not be an obvious place where you’d think to be mindful of potential risks. Suppose a company wants their shop floor employees to convey a professional appearance and opts to purchase uniforms. There’s no safety issue with that, right? Don’t be too sure.

In the real-life manufacturing facility where this situation unfolded, management signed a contract to purchase and distribute uniforms to several hundred plant employees without conducting any prior safety assessment of the uniforms. They only learned of risks associated with the uniforms after the fact, starting when a manual machinist got the loose sleeve of his uniform caught inside the gears of the mill he operated, pulling his arm partway into the machine. The operator fortunately came away with only a minor scape on his arm treatable as first aid, but it could have been so much worse—he could have significantly injured or even amputated his arm. The uniforms had other risks, too. The material was flammable, and the company management had assigned the uniforms to welders and operators of several furnaces on-site!

In the situations discussed above, plant management made changes that affected risk levels without doing any prior review that could have identified and mitigated those risks. Management of Change (MOC) is the name given to such a process. MOC engages key stakeholders in the systematic evaluation and management of potential risks associated with planned changes, including changes to operations (e.g., new chemicals, new equipment), your facility or physical work environment, or the ways work is conducted. MOC involves a structured approach for reviewing planned workflows to assess the impact of planned changes on safety, health, and environmental factors, and to be sure to get the right approvals and put appropriate controls in place before implementation.

Think about all the different situations discussed in this article, from wild animal encounters to workplace safety risks. The common denominator across them is that situations changed, and perception of safety risks and management practices didn’t change with them. In EHS management, MOC is a great way to stay ahead of these changes so you can anticipate and control risks before they’re present.

MOC also connects to your existing risk assessments, because as you learned already, every risk assessment captures a moment in time. When you review planned changes via your MOC process and use risk bowties, HAZIDS, JSAs or other methods to identify the risk controls you’ll need to have in place or changes to processes assessed, you should update those assessments to ensure they still reflect current operational risk management practices and risk exposure levels.

What Can EHS Professionals Learn from the Connecticut Bear Incident?

One of the tricks to good EHS risk management is to try to strike the right balance between specific takeaways and general takeaways.

The specific takeaway is that you can’t always assume there’s no bear in your car, because sometimes, there might be. Related to that, you should understand the circumstances in which encounters with bears become more likely, such as being in or near wooded areas in regions where bears are known to live and having food present that could attract hungry bears.

The more general takeaway is to be very aware when situations change, because very often risk exposures change with them. Sometimes the change may result from traveling from a place with low risks of a specific outcome to places with much higher risks, as in many real-life wild animal encounters. Many other times, these changes happen in the places you’re already in, and in EHS management, in the places your people work every day. The changes can happen unintentionally, when (e.g.) walkways become cluttered with trip hazards, or can happen as the result of intentional changes to the workplace or the nature of work that bypass a formal risk assessment process.

Better risk management starts with having better baseline perception of safety risks. Tap into the diversity of risk perceptions in your workplace by empowering front-line workers to perform key safety management tasks, such as inspections or completion of JSAs and risk bowties. More frequent and accurate inspections and more accessible inspection results also help you identify unexpected new hazards in your workplace so you can be aware of them and eliminate or control them.

Finally, you need to stay vigilant by using specialized risk assessment methods, like HAZIDS, JSAs and risk bowties to identify and communicate risks, and MOC to assess and control potential risks before they’re present in your workplace.

Stay safe from bears and other wild animals by adjusting your baseline risk perception while on vacation and keep your workers safe by conducting and updating risk assessments in the workplace. You’ll have an easier time when you have the right tools to easily complete and share responsibility for key safety and operational risk management tasks.

Let VelocityEHS Help!

First, here’s a disclaimer. Velocity can help you improve safety in many different ways, but we can’t actually keep bears out of your car.

Now that we have that out of the way, here’s how we can help you.

Our VelocityEHS Safety software makes it easy for you to develop specifically tailored inspection checklists you and your whole team can use to proactively look for hazards in your workplace. Our solution also helps you conduct program-level audits, schedule and manage safety meetings, and initiate and track corrective actions, including the ability to prioritize actions, assign them to specific team members, and send notifications when due dates are approaching or past due.

For additional management maturity, use our Operational Risk software to engage your employees in identifying and managing occupational safety and health risks, and facilitate completion and use of assessments such as risk bowties, JSAs and HAZIDs.

The post Improving Your Perception of Safety Risks (Or, “Why There Might Be a Bear in Your Car!”) appeared first on VelocityEHS.

By Phil Molé, MPH

After years of preparatory work, OSHA recently published a Notice of Proposed Rulemaking (NPRM) on heat injury and illness prevention that will affect many outdoor and indoor US worksites. Employers across different industries will need to understand the potential requirements in OSHA’s new heat injury and illness proposed rule and start planning changes to their workplace safety and risk management practices.

In what follows, you’ll get a break down of OSHA’s new heat injury and illness NPRM and learn key takeaways to prepare for the next steps.

What is the Background of OSHA’s New Heat Injury and Illness Proposed Rule?

It might be helpful to review some of the milestones on the road to OSHA’s new heat injury and illness prevention proposed rule.

OSHA’s 2021 Advanced Notice of Proposed Rulemaking (ANPRM)

OSHA has always had the authority to regulate hazards associated with indoor and outdoor heat exposure. Even in the absence of a specific regulation, they could issue violations to employers for unaddressed heat-related hazards under the General Duty Clause (GDC).

Even so, OSHA concluded that existing enforcement protocols were not sufficient to protect workers from exposure to indoor and outdoor heat hazards. As is often the case, OSHA was driven mostly by the injury and illness statistics. According to the U.S. Department of Labor’s Bureau of Labor Statistics (BLS), the effects of hazardous heat exposure resulted in an average of 35 fatalities per year and an average of 2,700 cases with multiple days away from work between 2015 and 2019. The actual numbers may be higher, because BLS indicates that heat-related fatalities may be underreported and improperly diagnosed due to failures to document when exposures to heat caused or contributed to “official” causes of death, such as heart attacks.

OSHA published an ANPRM in the Federal Register on October 27, 2021. For context, an ANPRM is a preparatory step in the rulemaking process to solicit feedback from experts and stakeholders that can lay a foundation for later steps. OSHA’s stated purpose in starting to work on a heat exposure standard, according to the landing page for the ANPRM, is to “more clearly set forth employer obligations and the measures necessary to more effectively protect employees from hazardous heat,” in light of the disturbing trends in heat related injury and illness numbers.

Another topic that OSHA sought stakeholder feedback on via the ANRPM is heat acclimatization planning. The term acclimatization refers to an employee’s build-up of resistance to heat exposure over time. There is a growing body of research and established best practices on heat acclimatization, including guidance published by Centers for Disease Control and Prevention (CDC). These existing guidelines have implications about how employers might use heat acclimatization as part of their plans to protect workers from harmful heat exposures. For example, because acclimatization takes time, employers should not assign a new employee who hasn’t yet built-up heat resistance to work a long shift in a hot environment.

OSHA’s Heat National Emphasis Program (NEP)

OSHA demonstrated that it was keeping the goal of protecting workers from heat exposures top of mind by rolling out a new NEP on “Outdoor and Indoor Heat-Related Hazards” on April 8, 2022. The NEP lays out OSHA’s inspection and enforcement priorities to support reduction of occupational illnesses and fatalities from heat exposure.

OSHA’s NEP contains an Appendix A of “Target Industries for the NEP” that lists the industry sectors, represented by North American Industrial Classification (NAIC) codes, that they’ll be focusing upon for inspections purposes.

How did OSHA decide which NAIC codes to include? According to the NEP, inclusion of an NAIC in Appendix A results from:

1) High numbers or high incidence rates of heat related illnesses from the Bureau of Labor Statistics (BLS) data;

2) Elevated number of days away from work (BLS) or high numbers of severe cases of heat-related illnesses, as indicated by death or hospitalization, from OSHA severe injury reports made by employers; or

3) the highest number of heat-related general duty clause 5(a)(1) violations and HALs over a 5-year period (1/1/2017 through 12/31/2021), or the highest number of OSHA heat inspections since 2017.

Not surprisingly, OSHA’s heat exposure NEP targets several subsectors of the construction industry, as seen in the image below.

The NEP is currently in effect and applies “OSHA-wide,” (everywhere that federal OSHA has jurisdiction). States that have federally approved state OSHA plans are not required to adopt the NEP, but if they do so, they must adopt provisions at least as stringent as the federal NEP.

OSHA’s 2022 Public Hearing

OSHA held a public hearing on May 3, 2022, to solicit stakeholder feedback on its efforts to develop a heat injury and illness standard, along with its other efforts to protect employees from heat exposure. There was much public interest in the hearing, with over 3,000 registrants, which forced OSHA to expand access through YouTube livestreaming in addition to the original Zoom virtual meeting. VelocityEHS virtually attended the hearing, which extended over a significant part of the day, and featured presentations by OSHA in addition to multiple 3-minute statements by stakeholders.

Stakeholders at the public hearing brought up the importance of heat acclimatization and  ensuring that any future OSHA standard stress the need for employers to include heat acclimatization policies in their heat illness reduction plans. OSHA representatives also talked about acclimatization in the context of their heat safety campaign video “Remembering Tim Barber.” Barber was a 35-year-old construction worker who died in July 2020 from heat-related illness on only his second day on the job. The video, which talks about the role that lack of time for acclimatization played in Barber’s very preventable death, includes very emotional testimony from Barber’s father.

Some commentators pointed out the connection of this issue with protection of vulnerable worker populations. For example, contracted and temporary workers may not work in the same place long enough to develop acclimatization, or may lose their acclimatization when shifted between worksites.

Which Workplaces Would OSHA’s NPRM Apply To?

OSHA’s efforts to protect workers from heat exposure risks based on stakeholder feedback have resulted in development an NPRM. At the time of this writing, OSHA’s new heat injury and illness proposed rule is still not published in the Federal Register, which means we don’t yet know the deadline for submitting comments, but interested readers can review the full text of the NPRM here, as submitted to the Office of the Federal Register (OFR).

The proposed requirements in OSHA’s new heat injury and illness proposed rule would apply to almost all workplaces with outdoor and indoor operations in the general industry, construction, maritime, and agriculture sectors, if those workplaces are covered under the Occupational Safety and Health (OSH) Act. The NPRM does have some exclusions, such as:

• short duration employee exposures to heat;
• emergency response activities;
• work at indoor sites kept below 80°F;
• telework; and
• indoor sedentary work activities

According to a preliminary economic analysis OSHA conducted for the NPRM, some of the industries likely to be affected by the proposed requirements include:

• Agriculture, Forestry, and Fishing;
• Building Materials and Equipment Suppliers;
• Commercial Kitchens;
• Construction;
• Drycleaning and Commercial Laundries;
• Landscaping and Facilities Support;
• Maintenance and Repair;
• Manufacturing;
• Oil and Gas;
• Postal and Delivery Services;
• Recreation and Amusement;
• Sanitation and Waste Removal;
• Telecommunications;
• Temporary Help Services;
• Transportation;
• Utilities; and
• Warehousing

Alongside the economic analysis, OSHA also conducted an equity assessment of the potential impacts of the final rule and concluded that the provisions of the NPRM would “have a positive impact on underserved populations (e.g., low income and Hispanic workers) by providing workplace protections from extreme temperatures that have a disproportionate impact on occupations held by individuals from underserved communities.” This assessment shows that OSHA considered and incorporated stakeholder feedback during the 2022 public hearing about the priority to protect the most vulnerable worker populations.

OSHA considers the industries listed above to be “core” sectors in their economic analysis, meaning that they’re industries where “employees have the most exposure to heat-related hazards, such as through exposure to high outdoor temperatures, radiant heat sources, or insufficient temperature control or ventilation in indoor work settings.” You’ll also see that there’s some overlap between these sectors and those targeted by OSHA’s heat exposure NEP discussed earlier.

Still, remember that not seeing your industry sector on this bulleted list doesn’t mean the NPRM’s proposed requirements won’t apply to you. The proposed requirements will apply to you if you have significant indoor or outdoor heat exposure in your workplace, and you’ll have specific things to do under certain conditions, as you’ll now learn.

What Would OSHA’s New Heat Injury and Illness Proposed Rule Require?

In general, OSHA’s new heat injury and illness proposed rule sets out proposed requirements that OSHA intends to establish consistent employer obligations to protect employees from the hazards of heat exposure in both indoor and outdoor work environments.

Below, you’ll find a discussion of some of the major proposed requirements in the NPRM.

Heat Injury and Illness Prevention Plan (HIIPP)

Employers must develop a site-specific HIIPP describing workplace measures to evaluate and control heat hazards.

Note the “site-specific” part, because that’s important. An already existing, widely applicable regulation with similar “site specific” plan requirements is the HazCom Standard, which requires employers to develop and maintain a site-specific written plan describing workplace HazCom practices. Similarly, the intention expressed in the NPRM is for the HIIPP to include specific details such as:

• A comprehensive list of the types of work activities covered by the plan;
• All policies and procedures necessary to comply with the requirements of this standard;
• An identification of the heat metric (i.e., heat index or wet bulb globe temperature) the employer will monitor to comply with their obligations; and
• The identity of one or more heat safety coordinators designated by the employer to implement and monitor the HIIPP.

If any employees wear vapor-impermeable clothing at the worksite, the employer must evaluate heat hazards from the clothing and implement policies and procedures to protect employees from increased heat injuries and illness risks associated with the clothing and describe these policies and procedures in the HIIPP. The NPRM defines “vapor-impermeable clothing as “full-body clothing that significantly inhibits or completely prevents sweat produced by the body from evaporating into the outside air,” including encapsulating suits, various forms of chemical resistant suits, and other forms of nonbreathable PPE.

If the employer has more than 10 employees at the worksite, the plan would need to be in writing. The NPRM also specifically proposes that the employer must develop and implement the HIIPP with the participation of “non-managerial employees,” language that echoes established safety management best practices in standards like ISO 45001, the international standard for occupational health & safety (OH&S) management systems. The NPRM also states that the employer would need to review and evaluate the effectiveness of the HIIPP whenever a heat-related illness or injury occurs that results in death, days away from work, medical treatment beyond first aid, or loss of consciousness, making updates as needed. The employer would also need to review and update the plan at least annually.

Finally, OSHA’s new heat injury and illness proposed rule states that the employer must make the HIIPP available to all employees at the worksite and must be available “in a language each employee, supervisor, and heat safety coordinator understands.”

Identification of Heat Hazards

OSHA’s new heat injury and illness proposed rule would require employers at both indoor and outdoor work sites to identify heat hazards, as follows:

Employers at outdoor work sites would need to monitor heat conditions by tracking local heat index forecasts or measuring heat index or wet bulb globe temperature (WBGT). You can think of WBGT as a measurement of how heat “feels” to humans and incorporates all four major environmental heat factors: air temperature, humidity, radiant heat (from sunlight or sources such as furnaces), and air movement (wind or ventilation).

Employers at indoor work sites would need to identify work areas with the potential for hazardous heat exposure, develop and implement a monitoring plan, and seek employee input.

General Employer Responsibilities

OSHA’s new heat injury and illness proposed rule would establish the following general requirements for all employers:

• Take steps if an employee is experiencing signs and symptoms of a heat-related illness or a heat emergency and develop a heat emergency response plan.

• Provide initial and annual refresher training for supervisors, heat safety coordinators, and employees, and supplemental training after changes in exposure to heat hazards, policies and procedures, or the occurrence of a heat injury or illness.

• Have and maintain, for a minimum of six months, written or electronic records of indoor monitoring data.

• Ensure that all requirements are at no cost to employees.

Control Measures at Initial Heat Trigger

The NPRM proposes a two-tiered system of triggers that works something like the Action Level (AL) and Permissible Exposure Limit (PEL) do in existing exposure standards. That is, certain requirements kick in for the employer when the first (lower tier) exposure criteria are present, and additional requirements kick in at the higher tier.

In OSHA’s new heat injury and illness proposed rule, the “initial heat trigger” represents the lower exposure tier. The NPRM defines the initial heat trigger as a heat index of 80°F or a wet bulb globe temperature equal to the NIOSH Recommended Action Limit (RAL). When employers identify that worksite temperatures are at or above the initial heat trigger, they must provide their employees with the following provisions:

• cool drinking water;
• break areas with cooling measures;
• indoor work area controls;
• acclimatization protocols for new and returning unacclimatized employees;
• paid rest breaks if needed to prevent overheating; and
• regular and effective two-way communication.

Control Measures at the High Heat Trigger

The second exposure tier in the NPRM is the “high heat trigger,” defined as conditions at or above a heat index of 90°F or wet bulb globe temperature equal to the NIOSH Recommended Exposure Limit (REL).

When workplace conditions meet or exceed the high heat trigger, the employer must provide employees with the following:

• mandatory rest breaks of 15 minutes at least every two hours (unpaid meal break may count as a rest break);
• observation for signs and symptoms of heat-related illness;
• a hazard alert to remind employees of key parts of the HIIPP; and
• warning signs at indoor work areas with ambient temperatures that regularly exceed 120°F.

Summary of Employer Responsibilities in OSHA’s New Heat Injury and Illness Proposed Rule

The chart below summarizes all proposed requirements for employers in OSHA’s new heat injury and illness proposed rule.

What Happens Next?

The public comment period for OSHA’s new heat injury and illness proposed rule is now open, and stakeholders may submit their feedback to OSHA via the docket. OSHA will then take some time to sort through the feedback en route to developing a final rule.

In the meantime, employers need to start preparing now. That means broadening your approach to safety and operational risk management to include exposure to heat hazards and prevention of heat injuries and illnesses. You’ll need to prepare inspection programs to confirm that indoor and outdoor work areas affected by the proposed requirements have necessary provisions in place, such as access to cool water, and functioning work areas controls like forced air cooling systems. It’s also important to reassess your incident management system to ensure it enables fast reporting of identified heat hazards, as well as any occupational injuries and illnesses that may occur, with the ability to quickly enter cases on OSHA Recordkeeping Forms.

Check this space often for additional updates about OSHA’s heat injury and illness NPRM as they happen!

Let VelocityEHS Help!

Preparing to meet the potential requirements in OSHA’s NPRM on occupational heat exposures involves many of the same safety management tasks you’re already doing. You just need the flexibility to adapt them, and the ability to make them easy enough to do consistently. Velocity’s Safety software allows you to develop site-specific checklists to confirm that supplies and PPE are on hand, and to use them in the field from a mobile device. You’ll also get the incident management control you need to document and follow up on heat illness cases, and to complete and access your OSHA recordkeeping forms.

Operational Risk software can also help you to improve your risk assessment acumen, with access to tools like hazard identification (HAZIDs), job safety analyses (JSAs), or risk bowties that can help you identify and control many kinds of hazards and risks, including those associated with heat exposure. You’ll also get enterprise-level visibility of hazards across your organization, and better ability to communicate risks and controls in place to all of your employees.

As always, please feel free to contact us anytime to learn more about how we can help your business become safer and more sustainable.

The post Understanding OSHA’s New Heat Injury and Illness Proposed Rule appeared first on VelocityEHS.