Occupational safety and health simplified for the industrial workplace

Occupational Safety and
Health Simplified for the
Industrial Workplace

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Occupational Safety and
Health Simplified for the
Industrial Workplace
Frank R. Spellman

BERNAN

Lanham • Boulder • New York • London

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Published by Bernan Press
An imprint of The Rowman & Littlefield Publishing Group, Inc.

4501 Forbes Boulevard, Suite 200, Lanham, Maryland 20706
www.rowman.com
800-865-3457;
Unit A, Whitacre Mews, 26-34 Stannary Street, London SE11 4AB
Copyright © 2016 by Bernan Press
All rights reserved. No part of this book may be reproduced in any form or by any electronic or
mechanical means, including information storage and retrieval systems, without written permission
from the publisher, except by a reviewer who may quote passages in a review.
British Library Cataloguing in Publication Information Available
Library of Congress Cataloging-in-Publication Data Available
ISBN 978-1-59888-809-6 (pbk. : alk. paper)
∞ ™ The paper used in this publication meets the minimum requirements of American National
Standard for Information Sciences—Permanence of Paper for Printed Library Materials, ANSI/
NISO Z39.48-1992.
Printed in the United States of America

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Contents

Introductionvii
1 Occupational Safety and Health Practice

1

2 Safety and Health Terminology and Hispanic Outreach

25

3 Regulatory Requirements

49

4 Occupational Safety and Health Management

61

5 Industrial Hygiene Concepts—Including Ventilation and Noise Controls

85

6 Worker Right-To-Know

111

7 Emergency Response and Process Safety

129

8 Industrial Facility Design

157

9 Ergonomics and Manual Lifting

193

10 Toxic Substances and Hazardous Wastes

209

11 Noise Control

245

12 Fire, Welding, and Hot-Work Safety

257

13 PPE, First Aid, and Thermal Hazards

277

14 Confined Space Entry

301

15Lockout/Tagout

333

16 Electrical Safety

339

17 Fall Protection

349

18 Pressure Vessel Safety

357

19 Rigging and Material Handling Safety

367

v

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viContents

20 Radiation Safety

389

21 Machine Guarding

395

22 Worksite Security

411

23 Violence in the Industrial Workplace

421

24Recordkeeping

435

Appendix: Sample Confined Space Certification Exam

441

Index451
About the Author

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Introduction

In the past (and even to a degree in the present), very little discussion took place or
was emphasized on industrial worker safety and health—and even less emphasis was
placed on developing a consciousness for worker safety and health as an integral part
of industrial operations. This trend has been changing, however—as it should. One
of the most significant changes has taken place in colleges and universities. Safety

and environmental health and other safety-related courses and curriculums have been
added to the pertinent fields of study, where occupational safety and health has been
approached as a science with well-defined goals and objectives, not as an exercise in
lip service and sloganeering. With the new demands for maintaining a violence-free
workplace and in compliance with Homeland Security requirements, the demand, in
many cases, for highly trained occupational safety and health professionals has also
increased.
Still, a problem exists. Many of these relatively recent training courses and curriculums have focused on the purely theoretical and scientific aspects of safety, health, and
related topics. You want proof? Hire a recent graduate from one of these programs.
Hiring a highly educated safety and health graduate who is well grounded in logic and
logic systems such as Boolean algebra, systems analysis, and design for safety is not
unusual—however, this same student may be lacking in what is really required: a fundamental grounding in the concepts of real-world safety and health practice. In other
words, a real gap exists between what our undergraduate and graduate students are
typically taught, and in what is really required in the work world—the real world.
What is really required is a combination of education and common sense delivered in
a simplified approach to problem solving. Occupational Safety and Health Simplified
for the Industrial Workplace is designed to help fill this gap. This text is based on
more than 50 years of occupational and safety health practice where mistakes were
made and proper actions were taken, and learning resulted from both.
Clearly written in everyday English with an understandable, accessible, and direct
and conversational style, this text provides easy access to a wealth of practical and
substantial information. It emphasizes developing a consciousness for instituting safe
work practices and maintenance of good health as an integral part of industrial work
practice, and also addresses industry’s responsibility to curtail workplace violence and
to incorporate clear communication with non-English-speaking employees. The principles in this book (if conscientiously applied) can prevent the devastating effects of
vii

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viiiIntroduction

improper or unsafe practices in the creation and delivery of work outputs and work
activities.
Before we proceed with discussing the nuts and bolts of the occupational safety and
health profession it is important to issue a word of caution to the reader and to anyone
who has ambitions to become an occupational safety and health practitioner: although
this book can be used as a how-to-do-it guide—a kind of cookbook of recipes on how
to mix and blend various regulations, standards, common safety and health work practices, and simply doing the right thing to protect industrial workers from on-the-job
hazards and toxic exposures—the success of mixing and blending these ingredients
to cook positive results requires the occupational safety and health professional to
possess a strong will combined with a great deal of fortitude and persistence.
Why?
You might think that workers (and others) will automatically do all that needs to be
done to protect their own personal safety and health. And to a point this is usually the
case. However, complying with safety and health rules and regulations is not always
easy; it can be very uncomfortable. For example, when it comes to wearing clumsy
safety shoes, or using uncomfortable safety glasses, or donning a heavy hard hat, or
putting on some other type of unwanted and uncomfortable personal protective gear,
some workers will simply not use this protective equipment. Or, in another example
of workers’ failure to abide by established safety and health rules or regulations: a
worker may fall back on that natural human tendency—the tendency to always look
for the easy way of accomplishing certain work tasks. That is, many of us have the
tendency to bypass safety rules and/or devices to finish a task quickly and with as little
effort as needed. Unfortunately, bypassing safety and health rules for convenience has
led to many injurious and fatal consequences too lengthy to list in any text.
Throughout this book, the focus is placed on the need for professionalism, scientific
analysis of risks and safety measures, concern for human and environmental needs,

and real-world examples of effective occupational safety and health management.
Materials included within the text include pertinent terminology and information, case
studies, and sections on management aspects; Hispanic outreach; indoor air quality;
thermal stress; security and vulnerability assessment; preventing workplace violence;
and much more.
Frank R. Spellman
Norfolk, Virginia

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Chapter 1

Occupational Safety and Health Practice

Fatality Incident (9/22/87): The service technician was “changing out” a pole, that is,
securing a cable television line from an old pole to a new pole nearby. He was working
from the bucket of an uninsulated aerial lift. He had attached a “come along” to the
cable to hold it in place while he transferred it from the old pole to the new pole. The
electrical conductor on the old pole was about three and a half inches from the new
pole. The new pole contacted the 20 KV (phase to ground) power line. The employee
was apparently in contact with the new pole and the cable TV line. He received an
electrical shock and fell out of the bucket approximately 23 feet to the ground. He
suffered no broken bones. The cause of death was electrocution. He was not wearing
a safety belt and was not tied off.
OSHA Standards Cited During Fatal Incident Investigation:
• 1910.67(b)(4)(iii)—the owner of the electric power line or his authorized representative was not notified and provided with all pertinent information before operation
of aerial lifts in close proximity to electrical power lines.

• 1910.268(n)(11)(iv)—insulated gloves were not worn.
• 1910.67(c)(2)(v)—a body belt was not worn with a lanyard attached to a boom or
bucket when working from an aerial lift.
• 1910.268(b)(6)—inspection of support structure of aerial lift before use.
• 1910.67(c)(2)(ix)—controls were not marked.
• 1910.268.(c)—employer did not assure that employee was not engaged in telecommunication work until employee was properly trained in precautions and safe
practices (OSHA, 2014).
Safety often is viewed largely as a simple matter of applying specific routines. In many
cases the routines are repeated regularly despite obvious signs of their inadequacies.
Greatly needed is an understanding that the sources of harm, which the safety specialty
should be able to control, have basic origins although their consequences will differ in
character and severity. This view furnishes the realization that hazards are not simply the
agents most closely identified with injuries. Merely regulating them is not the sure way
to limit their effect.
Grimaldi and Simonds, 1994
1

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2

Chapter 1

THE OCCUPATIONAL SAFETY AND HEALTH PROFESSIONAL
When new acquaintances are asked standard questions (where they live, where they
are from), sooner or later in the conversation the question arises, “What do you do
for a living?”

If the answer is “I’m a professional,” we might be impressed, but the question isn’t
completely answered. Professional? What type of professional? Many different professional disciplines or specialties are possible, from locomotive operators to “flight
engineers” to custodial personnel (“sanitation professionals”).
So what kind of professional is our professional? Unless he or she answers with a
specific professional specialty, the natural tendency will be for the questioner to ask,
“What kind of professional are you?” or “What type of profession are you involved
with?”
The respondent may offer an answer we might expect—“I am a mechanical professional or maybe a civil, aeronautical, chemical, electrical, industrial, administrative,
accounting, finance, or environmental professional.” Or the respondent might answer,
“I am an occupational safety and health professional.” Unless you are familiar with the
occupational safety and health profession, you might be taken aback by this statement.
Occupational safety and health professional? What is that? What does it involve?
Simply put, the occupational safety and health professional is a Jack or Jill of
many engineering, scientific, and other professions. Does this mean that the occupational safety and health professional is an expert in all engineering, scientific,
and the other disciplines? Good question. The short answer is no. The long answer
depends on your definition of “expert.” If you define expert as does Webster’s
Dictionary (Expert—A person with a high degree of skill in or knowledge of a
certain subject), the answer is yes, because safety and health professionals should
possess a high degree of skill in or knowledge of occupational safety and health.
But this really doesn’t answer our question, does it? To better answer the original
question, “Is the occupational safety and health professional an expert in all engineering, scientific, and other disciplines?,” two words in this question need to be
changed to render a more accurate answer. The words “expert” and “all” should
be changed—“Expert” status denotes that the safety and health professional knows
everything about safety—something no one could do. To accomplish this amazing
feat, the occupational safety and health professional would have to be an “expert”
in law, engineering, technical equipment, manufacturing processes, behavioral sciences, management, health sciences, finance and insurance, human behavior—as
they relate to safety and health issues—to name just a few fields. While true that the
occupational safety and health professional is typically an “expert” in a particular
area of workplace safety and health, it is also true that he or she can’t be expected
to be an “expert” in everything (who can be?). With regard to the word “all,” no one

person knows all or can know all; that’s a given.
Let’s take a look at what the occupational safety and health professional really is.
The occupational safety and health professional is knowledgeable in many aspects
of engineering, scientific, and other related disciplines—simply stated: again, a Jack
or Jill of many engineering, scientific, and other disciplines. While an occupational
safety and health professional isn’t an expert in all diverse fields, he or she should be

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Occupational Safety and Health Practice

3

expert in how safety and health issues affect these many fields, and in how to eliminate, reduce, or control workplace hazards for these fields.
The occupational safety and health professional is devoted to the application of
engineering and scientific principles and methods to the elimination and control of
hazards. They must know a lot about many different engineering and scientific fields.
The occupational safety and health professional specializes in the recognition and control of hazards through the use of knowledge and skill related to engineering, scientific
and other disciplines.
Major Accidents and Disasters
Major advances (Herculean advances in some respects) in technology have been made
in recent decades. These include advances in nuclear power, electronics, chemical
processing, transportation, management information systems, and manufacturing processes, digital this and that, to name just a few of hundreds of growth industries and
processes. Modern society’s attempts to ensure “the good life” for us all, have, at the
same time generated many perils that are also responsible for many of the woes that

beset us. Why? With technological advances come technological problems, many of
which have direct or indirect impact, not only on the safety and health of employees,
but also on the public and the environment.
When a process or operation has been correctly engineered (properly designed and
constructed), it will show clear and extensive evidence that the design included attention to safety. Such a process or operation, under the watchful and experienced eye of
a competent safety engineer, can continue to operate in a way that reduces the chance
of occupational injuries, illnesses, public exposure, and damage to the environment.
An occupational safety and health professional, one well versed in the basics of
civil, industrial, mechanical, electrical, chemical and environmental principles, takes
information pertinent to workplace safety and health from each of these disciplines.
Exactly what will such exposure afford the safety and health professional, our environment and us? Let’s take a look at some examples.
• Civil engineering exposure. Safety and health professionals who have had exposure to this field understand the need for safe and sanitary handling, storage, treatment, and disposal of wastes. They have knowledge of the controls needed for air
and water pollution. They understand the need for structural integrity of bridges,
buildings, and other constructed facilities. They understand the planning required to
build highways that are safe to use.
• Industrial engineering exposure. Industrial engineering tries to fit tasks to people,
rather than people to tasks. By doing this, they make work methods and environments physically more comfortable and safer. Occupational safety and health professionals need to understand the concepts involved with human factor engineering
and ergonomics.
• Mechanical engineering exposure. The student of occupational safety and health
soon discovers that the mechanical engineering field really got the ball rolling
toward incorporating safety requirements for machines such as boilers, pumps, air
compressors and elevators, and many other types of mechanized equipment and

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4

Chapter 1

facilities. The safety engineer must understand the operation and limitations of
mechanized machines and ancillary processes.
• Electrical engineering exposure. Electrical engineering is concerned with the
design of electrical safety devices such as interlocks and ground-fault interrupters
and other items. Electrocution and fire caused by faulty electrical circuitry in the
workplace are more common than you might think. The occupational safety and
health professional must be cognizant of these potential hazards and know what
needs to be done to prevent and correct such deficiencies.
• Chemical engineering exposure. Chemical engineering applies system safety techniques to process design through the design of less hazardous processes, using less
hazardous chemicals, chemicals that produce less waste, or that produce waste that
can be easily reclaimed.
• Environmental engineering exposure. Like safety engineering, environmental
engineering is a broad-based, interrelated discipline that incorporates the use of environmental science, engineering principles and societal values. The occupational safety and health professional must have a good background in environmental science
and environmental engineering practices, primarily because protecting the environment from pollution is often one of the safety and health practitioner’s chief duties.
Preventing major workplace accidents, disasters and illnesses is a primary responsibility of the occupational safety and health professional. Major conflagrations, explosions, catastrophic failures of equipment such as boilers or airplanes, and prevention
of chemical releases and spills are just a few of the important responsibilities included
in workplace safety and health practice.
Major accidents and disasters are terrible, obviously, to those directly affected.
Serious injury, illnesses, or death resulting from such incidents take their toll; they
have impact in ways we cannot imagine until we actually experience them ourselves.
The point is with proper, complete, and careful planning, accidents and human-made
disasters can be prevented.
The results, consequences, impact, and horror involved when “things go wrong”
(when workplace safety and health management take a back seat to other “more
important” concerns) can kill or maim are all within reach of the site—and what is
within reach of the site is dependent upon the nature of the disaster and the physical
conditions of the site, as well as weather: elements beyond our control.
The potential for risks involved with many industrial chemical processing operations is extreme. Bhopal, India, is not alone in the historical records detailing the

horrors of major accidents and disasters (the Chernobyl and Three Mile Island Unit 2
nuclear power incidents are other famous examples). This book’s intent is not to point
the finger of blame at anyone for these incidents, but rather to point out that they do
and did occur. More importantly for our concerns, these horrific events trumpet the
need for proper occupational safety and health practices in the workplace. What is
hardest to bear in these and all other tragic incidents is that we recognize that they
could have been prevented—and we fear that the same greed, carelessness, and/or
disregard for human life may someday affect us as well.
In one respect, the United States has been fortunate. Two of the world’s most terrible industrial accidents—accidents that changed how nations handled the very concept

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Occupational Safety and Health Practice

5

of industrial safety—had United States counterparts. The difference? The accidents
in the United States were on a far less serious scale. Only months after OSHA’s postBhopal study on the U.S. chemical industry’s chances of producing a similar incident,
OSHA reported the possibility of such an event occurring in the United States as very
unlikely. Yet a similar spill did occur, in Institute, West Virginia, and more than 100
people became ill, but no deaths. The result? The chemical manufacturing industry
swiftly cleaned up its act. Three Mile Island terrified the American public into a morethan-healthy respect for the potential harm a nuclear reactor represents. Even with
no deaths or injuries from Three Mile Island, in the incident aftermath, no aspect of
nuclear power operations is treated casually here. Moreover, the United States again
reassessed its regulatory standards after Chernobyl, using, as they should have, the

hard-bought lessons in industrial safety Chernobyl had to teach.
Regulatory Influence
Over the years, several changes related to safety and health in the workplace in the
United States have come about because of regulations enacted by the U.S. Congress
(most of which, at their conception at least, were based on the British example).
The impetus for Congressional action in this area was prompted by increased pressure
on legislators (by the public) to force businesses to adopt safety measures, and to provide hazard-free work places. The strong influence of governmental authority in regulating the safety and health of workers in the workplace cannot be overlooked. One of
the most important pieces of legislation that directly affected the push for a safer and
healthier workplace was the advent of workers’ compensations laws. The main intention of the proponents of workers’ compensation legislation was to advance occupational safety programs, which in turn sparked the need for highly trained occupational
safety and health professionals to design, implement, and manage them.
Occupational Safety and Health Act (OSH Act) of 19701
Congress created the Occupational Safety and Health Act (OSH Act) to assure safe
and healthful conditions for working men and women by setting and enforcing standards and providing training, outreach, education, and compliance assistance. Under
the OSH Act, employers are responsible for providing a safe and healthful workplace
for their workers.
Coupled with the efforts of employers, workers, safety and health professional,
unions and advocates, OSHA and its state partners have dramatically improved workplace safety.
The OSH Act clearly mandates that employers MUST provide their workers with
a workplace that does not have serious hazards and must follow all OSHA safety and
health standards. Employers must find and correct safety and health problems. OSHA
further requires that employers must first try to eliminate or reduce hazards by making feasible changes in working conditions rather than relying on personal protective
equipment (PPE) such as masks, gloves, or earplugs (PPE is always considered the
last resort in protecting workers). Switching to safer chemicals, enclosing processes
to trap harmful fumes, or using ventilation systems to clean the air are examples of
effective ways to eliminate or reduce risks.

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6

Chapter 1

Employers MUST also:
• prominently display the official OSHA Job and Safety and Health—“It’s the Law”
poster that describes rights and responsibility under the OSH Act (see Figure 1.1).
• inform workers about chemical hazards through training, labels, alarms, colorcoded systems, chemical information sheets and other methods.
• provide safety training to workers in a language and vocabulary they can understand.
• keep accurate records of work-related injuries and illnesses.
• perform tests in the workplace, such as air sampling, required by some OSHA
standards.
• provide required personal protective equipment at no cost to workers.*
• provide hearing exams or other medical tests required by OSHA standards.
• post OSHA citations and injury and illness data where workers can see them.
• as of January 1, 2015, notify OSHA within 8 hours of a workplace fatality or within
24 hours of any work-related inpatient hospitalization, amputation, or loss of an eye:
(800)321-OSHA (6742).
• not retaliate against workers for using their rights under the law, including their
right to report a work-related injury or illness.
*Employers must pay for most types of required personal protective equipment.
Employers are not required to pay for the following items:
• non-specialty safety toe protective footwear
• prescription safety eyewear (except when special use lenses must be used inside a
respirator face piece—employers must pay for the lenses–inserts)
• lineman boots
• logging boots that are required under SEC 1910.266 (d)(1)(v)
• everyday clothing such as long pants and long-sleeved shirts
• everyday work boots and work shoes

• dust masks/respirators that are under voluntary use provisions in SEC 1910. 134
• back belts
• everyday rainwear
Workers have the right to:
• work in conditions that do not pose a risk of serious harm.
• file a confidential complaint with OSHA to have their workplace inspected.
• receive information and training about hazards, methods to prevent harm, and the
OSHA standards that apply to their workplace. The training must be done in a language and vocabulary workers can understand.
• receive copies of records of work-related injuries and illnesses that occur in their
workplace.
• receive copies of the results from tests and monitoring done to find and measure
hazards in their workplace.
• receive copies of their workplace medical records.

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Occupational Safety and Health Practice

7

Figure 1.1  OSHA Job Safety Health It’s the Law! Poster. From www.osha.gov.

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8

Chapter 1

• participate in an OSHA inspection and speak in private with the inspector.
• file a complaint with OSHA if they have been retaliated against by their employer
as the result of requesting an inspection or using any of their other rights under the
OSH Act.
• file a complaint if punished or retaliated against for acting as a “whistleblower”
under the 21 additional federal laws for which OSAH has jurisdiction.
OSHA Standards
OSHA’s General Industry standards protect workers from a wide range of serious
hazards. Examples of OSHA standards include requirements for employers to:
• provide fall protection
• prevent trenching cave-ins
• prevent exposure to some infectious diseases
• ensure the safety of workers who enter confined spaces
• prevent exposure to harmful chemicals
• put guards on dangerous machines
• provide respirators or other safety equipment
• provide training for certain dangerous jobs in a language and vocabulary workers
can understand
General Duty Clause of the OSH Act
29 U.S.C § 654 Section 5 (a) of Public Law 91–596 of December 29, 1970, Occupational Safety and Health Act (OSH Act) requires that each employer:
1. shall furnish to each of his employees employment and a place of employment
which are free from recognized hazards that are causing or are likely to cause death
or serious physical harm to his employees;
2. shall comply with occupational safety and health standards promulgated under this

Act.
Did You Know?
It sometimes shocks employees to find out that they have obligations in the workplace also; that is, under 29 U.S.C. § 654, 5(b): each employee must comply with
occupational safety and health standards and all rules, regulations, and orders
issued pursuant to the Act which are applicable to his own actions and conduct.

Final Note on Standards, Regulations, Laws, and Rules
No matter the number of standards, regulations, laws and rules that are made to
ensure workers’ safety and health and no matter how experienced and/or motivated
the organization’s designated safety and health official is, they are powerless without

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Occupational Safety and Health Practice

9

strong support from the highest levels of management. Simply put, without a strong
commitment from upper management, the safety and health effort is doomed. On the
other hand, when organizational management states that it is the company’s objective
to place “Safety First”—even before productivity and quality—then the proper atmosphere is present for the safety and health official to accomplish the intended objective. That is, the safety and health official will be able to provide a safe and healthy
workplace for all employees to work in.
When assigned the duty as the organization’s safety and health official, the first
thing to be done is to meet with upper management and determine what the safety
objective is. The newly appointed safety and health official should not start on the

plant’s safety program until he or she is quite certain what is expected of them. The
pertinent matters that need to be addressed during this initial meeting include development of a written safety policy, a safety budget, exactly what authority the safety
official has and to whom does he or she report. In addition, the organization’s safety
rules and safety committee structure must be formulated as soon as possible.
THE ORGANIZATION’S SAFETY POLICY—THE TICKET TO RIDE
The organization’s safety and health official should propose that an organizational
safety policy be written and approved by the CEO, General Manager, or other top
industry manager. A well-written organizational safety policy should be the cornerstone of organization’s safety and health program. Moreover, a properly written and
disseminated safety policy statement is the safety and health professionals “Ticket to
Ride”—to ride to success. Why? Simply, if the occupational safety and health professional does not have the support and backing of the organization’s top manager, he or
she is wasting their time in trying to put together a program that will ensure the safety
and health of all employees. After more than 50 years in the safety and health profession, I can assure you that this is the case; it absolutely is the case!
There are several examples of safety and health policies used by Fortune 500 companies and others to model your organization’s safety and health policy after. The key
to producing a powerful, tell-it-like-it-is safety policy is to keep it short, to the point,
and germane to the overall goal. Many organizational safety and health policies are
well written but are too lengthy, too philosophical. The major point to remember is
that the organization’s safety and health policy should be written not only so that it
might be understood by every employee but also so that all employees will actually
read it. An example of a short, to the point, and hard-hitting safety policy is provided
in Figure 1.2.
Workplace Safety and Health Provisions: The Legal Ramifications
Whenever laws or regulations or rules are enacted, soon the legal profession is called
in. New regulation means eventual testing of the law, regulation, or rule through the
court system—for safety regulation, this meant to provide legal services for workers’
complaints against employers for hazarding their safety and health, and other related
on-the-job concerns. This, of course, is what has happened, and it had a profound effect

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10

Chapter 1

NO JOB IS SO CRITICAL AND NO SERVICE
IS SO URGENT—THAT WE CANNOT
TAKE THE TIME TO PERFORM OUR
WORK SAFELY
While it is true that the major emphasis is on efficient operations, it is also true
that this must be accomplished with a minimum of accidents and losses. I cannot overemphasize the importance that the organization places on the safety and
health and well-being of each and every employee. The organization’s commitment to occupational safety and health is absolute. The organization’s safety and
health goal is to integrate hazard control into all operations, including compliance
with applicable standards. I encourage active leadership, direct participation, and
enthusiastic support of the entire organization in supporting our safety and health
programs and policies.
________________________
CEO/COO/General Manager
Figure 1.2  Sample Organizational Safety Policy

in the workplace. In the old days (before OSHA) the employer hired and expected his
employee to work long, hard hours without getting injured (see Case Study 1.1). If the
employee was injured, the employer simply showed him the door and that was that.
Thankfully, times have changed. Thus the goal of most employers quickly became
to prevent such legal actions—because they are costly both in money and time. The
primary way in which employers avoid expensive litigation is by ensuring compliance
with applicable workplace safety and health laws and regulations. They most often
accomplish this by assigning the responsibility for ensuring workers’ safety and health
on the job to a designated occupational safety and health official; often this designated

safety official is a fully qualified occupational safety and health professional.
Case Study 1.1: A Stitch in Time
The working conditions of the seamstress in nineteenth-century England received a
great deal of concern and attention in the media of the day, but actual reform came
very slowly. Victorian women had little choice of career—nanny or governess positions, shop positions, servant occupations, certain kinds of factory work, and dressmaking were often the only legitimate jobs a woman might be qualified (or allowed)
to do. Of these, dressmaking was frequently the only choice possible, because while
educational effort was seldom spent on girls until mandatory educational requirements
went into effect around the turn of the century, virtually every girl learned how to
sew and do fancy needlework. Without a father, brother, or husband to protect or support her, a woman with limited education and means might be forced into a difficult
choice—servant work, dressmaking, or prostitution.

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Because these women all could sew, the potential labor force was huge. In London,
in 1851, there were between 15,000 and 20,000 seamstresses working. Since competition for jobs was steep, and because people wanted to buy their goods as cheaply as
possible, wages were often inadequate—too small to live on. Working conditions were
generally dreadful (only the first-rate houses cared to treat their employees well—they
hired top quality workers and expected to keep them), and by the nature of the profession, many women gained little more than life-long ill health from their labor.
Comfortable hand sewing requires only a few necessities: good lighting and ventilation, comfortable straight furniture, and frequent chances for movement. But
nineteenth-century custom houses frequently ignored these considerations. The custom houses fed, housed, and worked their apprenticed help as they pleased, in conditions that ranged from reasonable in first-class establishments, to places with living
quarters where the women slept five to a bed. At the height of the social season, when

the houses were at their busiest, women would commonly work 18–20-hour days for
weeks on end, to finish overbooked orders. To finish special projects, they might work
around the clock and into the next day. With bad light, stuffy quarters, no chance for
exercise, and little food, the health of these women was affected.
High fashion also created seamstress problems. When the sewing machine came
into general use in the mid-1860’s, a logical expectation might be that more could be
accomplished faster—but as soon as the sewing machine came into use, it was used
to create clothing with more fine detail—if not handwork, then decoration: pleats,
ruffles, lace, braid, and trimmings—as a display of caste and wealth. Production time
actually went up.
Their work caused many of the health problems prevalent within the group. Lack of
fresh air (the gaslights used for illumination consumed as much of the available air as
five adults—for each light), no exercise, the bent-over posture, as well as breathing lint
and fiber particles caused many women to develop respiratory problems, sometimes
compounded by organic poisoning from inhaled toxins. Tuberculosis was quite common, and internal distresses caused by bad posture, tight corseting, and bad food gradually worsened the workers’ health. Blindness, headaches, nervous exhaustion, anemia,
faintness, and chronic fatigue were other side effects. In The Ghost in the Looking
Glass, author Christina Walkley quotes nineteenth-century medical experts, who agree
that “no life style was better calculated to destroy health and induce early death” (p. 32).
The upbringing that most Victorian women shared also created part of their problems. Brought up to depend on men, these women were terribly unsophisticated when
dealing for money and for their rights. They had no organized lobby behind them.
They really didn’t know how to complain—or have anyone effective to complain to.
Factories employed larger numbers of people, and had a formal internal structure,
with a recognizable chain of command. Custom houses were generally run by a single
owner with only a few employees on site. Many seamstresses relied on piecework
employment, and often the only way to find piecework would involve a middleman,
who could easily skim his portion of already meager wages. Since often this was a
woman’s only possible source of income, and the job market was full, she had little
recourse. She could work at the wages offered—or starve. Often a slave would have
been physically better off, because a slave was valuable property. The seamstress was
an expendable worker.

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Over and over again, the journal Punch brought the seamstress’s plight to England’s attention. In 1843, Punch published Thomas Hood’s “Song of the Shirt” (a
poem which inspired much pity), but little toward reform could be accomplished.
Between the private homes that housed the custom houses, the amount of untraceable piecework farmed out to individuals, and the fear of job loss for those who were
working, concrete proof significant enough to pass legislation was difficult to obtain.
Conditions did not become easier until long after the turn of the century, when World
War I changed clothing styles radically enough to allow factory-made clothing to
become the norm. By 1918, the Trade Boards Acts established hour and wage regulations. But even today, immigrant workers in the United States suffer many of the
same sweatshop conditions as those Victorian seamstresses, with as little recourse.
Sweatshop factories exist in most third world countries, often using children to produce fashionable clothing inexpensively for companies in industrialized nations. Nike,
a popular clothing line associated with Kathy Lee Gifford at WalMart, and others have
been tied to sweatshops and third world children’s labor, and stories about the plight
of deaf Mexican immigrants in U.S. sweatshops have all made national news.
***
After laying the above foundational information for this book, now it is time to get
down to the bricks and mortar that make up a viable occupational safety and health
program. I begin with a discussion of accident prevention signs and tags and labels,
and, more specifically, with signal words.
EMPLOYEE TRAINING
Throughout this book, I stress again and again the importance of employee safety
and health training. This emphasis is for good reason. For it is without a doubt that

providing routine safety and health training for workers is probably one of the most
important job duties the occupational safety and health official has in the industrial
(or any other) workplace. Indeed, most managers know the importance of safety and
health training, but it is not well known that specific training requirements are detailed
in OSHA, DOT, and EPA regulations. Under OSHA regulations, for example, it is
stated or implied that the responsibility of the employer is to provide training and
knowledge to the worker. Moreover, employees are to be apprised of all hazards to
which they are exposed, relevant symptoms and appropriate emergency treatment, and
proper conditions and precautions of safe use or exposure.
Throughout this book I feature several different OSHA safety and health standards
or programs. Employers must comply with these standards and must also require
workers to comply. More than 100 OSHA, DOT, and EPA safety and health regulations contain training requirements.
It is interesting to note that although OSHA requires training, it does not always
specify exactly what is required of the employer or entity which provides the training.
However, information and instruction on safety and health issues in the workplace are
foundational to building a viable organizational safety and health program. Workers

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cannot be expected to perform their assigned tasks safely unless they are aware of the
hazards or the potential hazards involved with each job assignment.

For years safety and health professionals have spoken about the “three E’s” of
occupation safety and health management: Engineering, Enforcement, and Education. While it is true that the best solution to control any hazard is to engineer out the
problem, and while it also true that enforcement is critical to maintaining execution
of proper safe work practices, it is also true that the safety education aspect is equally
important.
Education in the form of providing information and training is one of the most
vital elements in safety simply because a worker cannot be expected to comply with
safe work practices unless they have been informed of and trained on the proper
procedures.
Experts in the occupational safety and health field have differing points of view on
this topic. One element points out that safety is not a behavioral issue, instead, it is
technical—meaning that safety can be accomplished by engineering out the hazard.
It should be remembered, however, that if there is a possibility for something to go
wrong, workers will find the way to make it happen. Even workplaces that have stateof-the-art engineering safety devices and strong enforcement programs do not always
have effective hazard control programs unless the workers and supervisors understand
the hazards and the potential for hazards that arise from not observing routine safe
work practices. A worker’s work routine and attitude cannot be engineered—workers
are not robots.
Worker safety and health training should begin right after the employee is hired.
New Employee Safety and Health Orientation Training programs can be effective
if correctly structured and presented early in the worker’s tenure. Simply, New
Employee Safety and Health Training gets the new worker off to the right start. This
training should be tailored to satisfy several OSHA requirements. For example, OSHA
requires that workers be trained on the Hazard Communication Standard prior to their
beginning work with or around hazardous materials.
Before sending new employees to safety and health orientation training it must
be determined who needs what training. Two approaches are typically used in making this determination. First, the industrial occupational safety and health official in
conjunction with the personnel manager, work center supervisors, and safety council
should determines specific safety and health training for each job classification. This
can be accomplished by conducting a “needs assessment” (sometimes called “needs

analysis”). The idea behind the needs assessment is to ensure that job classifications
requiring confined space training, for example, receive this critical training. At the
same time, the needs assessment also functions to ensure that the plant clerk who
needs hazard communication training but who does not enter confined spaces, for
example, does not receive confined space training. Second, an industrial organization
can simply choose to send all new employees to all the training presented during New
Employee Safety and Health training. Based on experience, this second approach
might be the best method. The thinking seems to be that when it comes to an employee’s safety and health in the workplace, employees can’t be over trained.
Depending upon the organization’s turnover rate, the frequency of conducting New
Employee Safety and Health Orientation Training can vary from presenting a session

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Chapter 1

each week, every other week, once a month, or as required, depending upon the historical hiring pattern.
It is critical to keep and maintain and update records of any and all employee safety
and health training. When OSHA arrives to audit a facility, one of the first items
they want to see is proof of employee safety and health training. In OSHA and a
court of law’s view, if you do not have a record of training, then you did not conduct the training. You MUST keep and maintain accurate training records.
In addition to providing New Employee Safety and Health Orientation Training
presented to all new employees, another technique for verifying new employee safety
and health knowledge is a system known as Personnel Qualification Standard
(PQS) for plant safety and health and industrial operations. PQS is a term that comes
from the United States Navy. The Navy has been using PQS to qualify its personnel for several years. Like the Navy’s PQS program, industrial operation’s PQS has

proven to be an excellent training instrument. Not only does it provide a guide of what
is to be learned, it also provides documentation to show that the training was actually
completed. Additionally, this industrial PQS system is suitable for any and all industrial applications and for just about any other workplace application.
When attempting to implement a PQS program at your organization, keep in mind
that there are several requirements that must be completed prior to the new employee
being fully PQS qualified for his or her assigned position. These qualifications should
also include a tour of all worksite facilities including knowing the names of all buildings, process unit machinery, and chemical storage locations. In addition to naming
various components within the industrial plant site, the worker must show where all
first-aid kits, fire extinguishers, fire hoses and standpipes, emergency equipment storage lockers, Hazard Communication Right-To-Know Stations, and emergency evacuation routes are located. After completing PQS training, the employer must ensure that
the employee signs some company document acknowledging the training they have
received. It is important to include in this acknowledgment form that the employee
fully understood this training (see Figure 1.3). This simple but crucial document can
save employers and managers a lot of drama, pain, fines, possible imprisonment, and,
at the very least, embarrassment in a court of law and from OSHA.
The benefits of using safety and health training PQS or some other training system
or technique for new workers cannot be overemphasized. Consider the new employee
hired to operate a piece of heavy road building equipment, for example. The hiring
authority should ensure that the equipment operator hired is qualified to operate the
equipment in a responsible and safe manner. PQS is a viable way of ensuring the
viability of the potential new employee’s operating ability and skill sets. Again, by
utilizing PQS or some other similar safety and health indoctrination process, the
supervisors are ensured of training their personnel and creating an accurate record of
the initial operations and safety and health training. Experience has shown that this
PQS system is dynamic, constantly changing, and constantly improving.
Safety begins with awareness. Awareness is gained through training and experience. Whichever type of safety training that is decided upon, it is important to

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Figure 1.3  Acknowledgment of Training and Understanding Statement

Did You Know?
Along with certifying an employee’s training and operational proficiency by having the newly trained employee sign some type of acknowledgment of training and
understanding form, it may be advisable to video new employees’ actual training
and their demonstration of proficiency. I have found that video evidence of actual
training and or demonstration of operator proficiency has saved on legal ramifications that might develop in the future.
remember to assess the program’s effectiveness. Workers who attend safety training
should be asked their opinions of the training. I have found that worker input is important. Through the use of questionnaires, for example, it can be determined whether the
approach being used is relevant and appropriate. Supervisors are another good source
of information. They are in a good position to determine if the safety training is paying off. Improvements should also be noticeable in the workplace. Reduced numbers
of injuries on-the-job along with improved product quality and worker productivity
are excellent indicators of the effectiveness of the plant’s safety training program.
Finally, as stated previously, proper safety training can be accomplished but if it is not
documented—the training was never done.
CONTRACTOR TRAINING
Outside contractors hired by any industrial operation are in the business to make
money; that is, to make a profit (aren’t we all?). The problem is that in order to make

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Chapter 1

a profit a contractor might have to cut corners, many corners. Unfortunately, when
this happens, usually it is the safety and health provisions and programs designed to
protect the workers that is cut. No one ever said that providing a viable safety and
health program to and for employees is cheap. Cheap it is not. Critical it is. The problem is that the safety and health of employees is often viewed as nice to have and nice
to acknowledge but in terms of the bottom line, the safety and health of employees
does not contribute to it. This is, unfortunately and based on personal experience, the
convoluted and sadly incorrect thinking or attitude of many employers, and especially
many contractors. I have spent a lifetime on the lecture circuit and in many of the
pages on safety and health that I have had published trying to explain to employers
that safety is not cheap, but at the same time asking how much is a human life or
disability worth? In this day of “let me sue you before you sue me,” this question is
germane.
Part of the problem with such a sour attitude toward safety and with compliance
with OSHA regulations stems from the diverse nature of the construction industry
itself. Some construction entities are nothing more than fly-by-night, skeleton crew
operations, whose only goal is to procure a contract to construct projects in the least
amount of time, at the lowest possible cost, and with the largest possible profit margin.
Obviously, such entities are often more concerned with the bottom line (making a
return on their work) than with complying with anybody (other than mandated building codes, that is). Cutting corners to cut costs is the mantra by which such entities
operate. Safety? For such operations, safety is a burden—and one the operation management may not find is the “right” thing to do. Only when OSHA (or other regulatory
agencies) cites such entities does such a company’s attention focus on compliance
with regulations. Otherwise, “get the job done as quickly and cheaply as possible” is
the only important mandate to many of them.
There are other contractor industry problems associated with compliance with
OSHA. For example, many construction outfits hire subcontractors to complete parts

of the work. Many of these subcontractors look at safety compliance as an additional,
unnecessary, costly burden. Many of them do not have safety programs and do not
comply with safety regulations.
Hiring practices cause another common problem in contractor noncompliance with
safety regulations. This is the age of hiring “temporary” employees because of the
Affordable Care Act (Obamacare) and other cost-saving reasons. Of course, this practice presents some obvious advantages. In the first place, temporary employees are
normally cheaper to hire—the employer doesn’t have to make any long-term financial
commitments to such employees. Moreover, they usually do not have to be paid costly
benefits. Secondly, temporary workers are “temporary”—short-term employees who
might be hired to work one shift, one day, one week, one hour, and so on. The contractor employer might feel that to provide such temporary workers with the training that
OSHA requires is a waste of time and money—especially since, by the time OSHA
might show up for inspection, the temporary employee will be long gone. Out of sight
and definitely out of the former employer’s mind.
As sad as it might be, some companies involved as contractors take a dim view,
not only of OSHA, but also with any compliance effort that costs them time and
money—worker safety and well-being are not a consideration. This is not the case

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