Safety Net | November 2021

THE SAFETY NET CO N SU LTA N T S

•

DESIGNERS

•

ENGINEERS

NOVEMBER 2021

IT’S ALWAYS SAFETY FIRST. •

CO N STRUCTO RS

VOLUME 15 ISSUE 11

‘Tis the Season for Holiday Cooking Safety John Hopkin: Health by Scott Hultman, M.B.A., M.D.

Long lines at the grocery store, package deliveries piling up on doorsteps — yes, it’s beginning to look a lot like the holidays.

All the hectic preparations may prove distracting when it comes to safety in the kitchen, leading to accidental burns or scalds. According to the National Fire Protection Association, winter holidays are peak days for home cooking fires.

“With the end of the year approaching and the holiday festivities upon us, this is a good time for families to review their fire safety plan,” says Scott Hultman, M.D., M.B.A., director of the Johns Hopkins Burn Center, Maryland’s only regional burn

SAFETY FIRST.

center. The center provides a comprehensive, world-renowned program of care for both local and international patients with burn injuries.

Austin employees have

“Perhaps the two most important parts of such a plan are knowing the best route to

worked 4,465,742 hours

evacuate your house or dwelling, and knowing the location of your fire extinguisher,”

without a Lost Time Accident

Hultman continues.

through 09/2021.

HOLIDAY COOKING SAFETY Whether you’re hosting a festive gettogether or just bringing along a dish, prevent kitchen fires and cook safely with these tips in mind: • Keep flammable items away from

— and out of the kitchen — by setting up activities such as games, puzzles or books in another room.

HOW TO TREAT A BURN No matter how careful one may be, accidents still happen. Should you experience a painful

the stovetop, including oven mitts,

burn, contact your doctor or go to the

potholders, food packaging and

emergency room for care.

dishtowels. Avoid wearing loose clothing, which could catch fire on burners.

• Do not leave cooking unattended. When using the stovetop, stay in the kitchen so you can keep an eye on the food. If you have something in the oven, check on it frequently; set a timer as a reminder.

• Keep the floor clear of any tripping hazards, such as bags or toys. Pets should be kept in another room where they won’t risk getting underfoot.

• It’s important to be alert while cooking on the stove, so if you’re tired or have consumed alcohol, it may be best to let someone else take over.

• Exercise caution when handling hot liquids and foods, as steam or splashes can cause serious burns, as well as the trays, pans and serving dishes they are in.

When it is time to set the table, place hot liquids and foods in the center of the

WHAT TO DO IF THERE IS A COOKING FIRE When a fire ignites in the kitchen, our first instinct may be to pick up the flaming pot or pan and attempt to move it into the sink or outside. However, this is dangerous and can result in splashing hot oil on yourself and your home, spreading the fire further.

Should a small fire ignite, follow these safety guidelines: • Do not pour water on it. Water can cause oil to splash, which can not only hurt you but also spread the fire.

• Slide a lid over the pan to smother the fire and turn off the stovetop, leaving the pan covered until it has completely cooled; alternatively, baking soda can also be used to extinguish small grease fires.

• If there is an oven fire, turn off the heat and keep the oven door closed.

table, where they are less likely to be

“For larger fires with extensive smoke and

knocked over.

heat that are rapidly spreading, get out!”

KIDS IN THE KITCHEN

says Hultman. Leave the kitchen and close

The kitchen can be a precarious place

Once you are safe, call 911 or a local

for children, especially amid the chaos of

emergency number.

holiday preparations. From hot foods and liquids to knives and dangling electric cords, there are lots of dangerous things a child can grab off the counter. Maintain a safe environment by keeping hazardous items toward the back of the counter and out of easy reach.

To avoid any accidental burns or scalds, children should stay at least 3 feet away from the stove. Keep them entertained

the door behind you to contain the flames.

“Take your loved ones with you, but do not re-enter your home to get your cellphone, computer or other personal belongings,” says Hultman. “You may not have a second chance to get out safely.”

With these in mind, you and your loved ones are apt to have a happy — and safe — holiday season from the kitchen to the table.

Mindful Approaches to Workplace Wellness 10.14.2021 | EHS Today by Jonathan Katz Employers are ramping up mental health awareness

In the past, mental health was primarily recognized as

programs as they cope with pandemic-related stress.

diagnosed conditions, such as depression, but it may

Jacob Aqua and Marshall Kupka-Moore begin every

also encompass other emotional issues and life-changing

meeting with a breathing exercise. During our Zoom call, he

events, such as grief, stress and divorce, Harvey says.

led a brief guided meditation, asking us to close our eyes

CREATING AWARENESS

and take a few deep breaths.

“We start our meetings with a little bit of centering into the space that we can all arrive at and fully be present for the work,” Aqua explains after the short session.

Harvey started Made of Millions in 2016 after struggling with obsessive-compulsive disorder while working as the owner of an ad agency. It took him nearly 30 years of suffering before he knew his diagnosis. He would like to see the

Aqua and Kupka-Moore are co-founders of Source

workplace fill a gap in health education.

Wellness, an organization that helps businesses develop

“If we are able to use the corporation as a device or

mental health programs focused on mindfulness techniques. As EHS Today research shows, more companies are incorporating stress-reduction practices, such as mindfulness and yoga, into their corporate health programs to address employee wellness.

Nearly one-third of employers responding to the EHS Today Mental Health in the Workplace 2021 survey conducted earlier this year say they offer meditation, mindfulness or yoga programs at their company. The pandemic has many companies rethinking the importance of mental health as part of their overall wellness programs.

distribution vehicle to give people the psychoeducation that they need to better understand what’s going on, they can then better navigate a very broken healthcare system,” he says.

Harvey also serves as an advisor for Mind Together, a coalition of brands led by Verizon Media working to address mental health and set a new standard in how employees are supported at work. The growth in mental health awareness in the corporate world is more evident since the pandemic, says Dr. Michelle Riba, a professor of psychiatry at the University of Michigan and codirector of workplace

“One thing the pandemic did was it broadened the

mental health solutions at the school’s Eisenberg Family

definition of mental health,” says Aaron Harvey, who

Depression Center.

founded a mental health advocacy group called Made

“We recently had a major conference on this topic, with

of Millions.

over 300 attendees throughout the country and Canada ...continued on next page 3

from employers small and large, and mental health is

Calm is another meditation app that employers can

clearly a growing and major issue for the workplace and all

distribute to employees, Riba notes. Calm offers a

ages and genders,” she says.

business-specific plan that employers can purchase. Other

When it comes to addressing mental health in the

educational tools include webinars or lectures from mental

workplace, employers need to create an environment

health professionals, she says.

where workers are comfortable talking about it, experts

While employers have ethical reasons to address mental

say. One participant in the EHS Today survey wrote,

health, it also has an impact on their bottom line.

“Employees are depressed, and issues are never addressed in time. There are no clear communication lines between management and staff.” Harvey says employers must go beyond sloganeering to foster a culture of mental health awareness.

“It’s very expensive for employers to have to fill positions and we know that we’re seeing many service industries are hurting very badly because they don’t have enough employees,” Riba says. “So it’s very important to think about not only recruitment but retention, and part of

“It can’t just be like, ‘Hey, we understand mental health

that is they’re learning many Millennials, for example, are

is tough; if you’re struggling reach out to us,’” he says.

looking at jobs and asking about whether or not there are

“You have to do the work behind the scenes first, having

mental health days, and asking very important questions

strategic alignment with the management team, HR

about this topic.”

team and even the legal team, and then going out and messaging it.”

MORE RELAXED, MORE PRODUCTIVE Technology is one way employers can encourage staff to manage stress and keep tabs on their mental health. For example, Insight Timer is an app that sends reminders to perform breathing exercises at regular intervals, says Aqua, whose title at Source Wellness is chief mindfulness officer.

“Everyone has time to take deep breaths because we have to breathe throughout the day,” he says. “It’s not like you’re taking time off breathing when you’re working.”

Kupka-Moore explains that many large, multinational companies are incorporating mindfulness programs into their organizations because they recognize the productivity benefits.

“We’re starting to realize that our mental health heavily impacts our physical health, and our mental and physical health together very heavily impact our productivity,” says Kupka-Moore, CEO of Source Wellness. “Once people can see there is a very, very clear connection between the amount of money you can make and the amount of effectiveness you can derive from mindfulness, it’s going to be impossible for them not to take on that approach.”

What Not to Do 10.20.2021 | EHS Today by Nicole Stempak Sometimes, putting everything down on paper can help

I admit that it is incredibly satisfying to cross something off a

you get organized. Other times, it’s best to toss the to-do list.

to-do list. That strikethrough line serves as a visual indication

I was fortunate enough to be a student worker in college.

of progress. Conversely, not being able to cross anything

One day, I don’t remember the circumstances, but I

off my to-do list is incredibly frustrating and can often be a

happened to overhear two staff talking.

source of stress for me.

Janice* was relaying a story about how she shared some

Over the years, I have read countless articles about how to

good news with Dr. Li*, a world-renowned expert who is also a prolific writer and has been awarded numerous

better manage my time, be more productive and organize my day. Some tricks worked for a while, but eventually the

grants. In response, Dr. Li said something to the effect of,

to-do list starts to pile up again.

“Congratulations. Now what are you going to do next?”

This has been especially challenging of late as the

Janice was miffed that she couldn’t simply enjoy her success.

COVID-19 pandemic has hindered my ability to get things

Instead, she was encouraged to push herself even further.

done. I complained to my therapist about this, and she

Both Janice and Dr. Li are knowledgeable, competent

responded by saying, “So what?”

and respected by their peers. They have a good working

In fact, she said that measuring myself against an ambitious

relationship. To my knowledge, there was no malice or

and ever-growing list of tasks is dangerous to my mental

animosity because of this conversation, and I doubt either

and physical health. Every item I add to the list reinforces

even remember it.

the belief that I need to spend more hours per day

I am not sure why this interaction has stuck with me for

working. Worse, I start to measure my self-worth by my

years, but only recently have I been able to parse its deeper

accomplishments, so not enough items crossed off makes

meaning. I believe this conversation reveals a difference

me feel like a failure.

in understanding about productivity at an individual and

I was relieved to discover an article from Harvard Business

societal level—and the repercussions it can have for both.

Review entitled, “You’re Never Going to Be ‘Caught Up’ at

Our ideas of productivity seem to be conflated with our

Work. Stop Feeling Guilty About It.” Author Art Markman

sense of accomplishment and even self-worth.

writes that it’s easy to feel guilty or ashamed about what you ...continued on next page 5

have not yet completed. While guilt or shame can at times be helpful, he cautions that you must be proactive to avoid the negative effects of these feelings. He instead advises you focus on your accomplishments and feel good about what you have already done.

That supports some advice from an article The New York Times published earlier this year entitled, “The Other Side of Languishing is Flourishing. Here’s How to Get There.” Psychologists recommend that to flourish—a state of thriving that describes mental, physical and emotional fitness—we need to celebrate and savor small moments, share tiny victories and appreciate the good things around us. I suspect the reason this can be so challenging is that because we are

America’s Safest Companies 2021: CJ Drilling 10.19.2021 | EHS Today by Nicole Stempak

so often focused on lofty, ambitious

CJ DRILLING, INC. | CONSTRUCTION | DUNDEE, IL

goals, we fail to acknowledge

125 EMPLOYEES | 4 SITES | 4 EHS PROFESSIONALS

steady, incremental progress.

Knowing this, I am all the more

To say management at CJ Drilling is committed to safety might be an understatement.

thankful that Dr. Li stopped me as

At the beginning of the COVID-19 pandemic, President and Owner/Operator

I was heading to the convocation

Tammie Johnson donated all the company’s N95 masks to a local hospital that

center for my graduation ceremony.

was unable to attain any. CJ Drilling quickly procured more personal protection

I was surprised by how excited she

equipment inventory to help keep workers safe. The company also built and

was for me; I had only taken one

deployed portable hand washing stations and eliminated the practice of

class with her. I was flabbergasted

multiple employees traveling in the same vehicle, a decision that required

when she asked if she could take

additional resources.

a picture with me. I was so focused on getting in line and starting a new chapter of my life that I didn’t let it sink in that I was graduating.

Now, that photo serves as a visual reminder for me to pause, smile and celebrate my accomplishments in the moment.

There will always be more things to do, but sometimes, we have to remember it’s OK to stop doing and just be.

Over the years, CJ Drilling has turned down work because of unsafe working conditions. Once, an operator and foreman walked away from a jobsite because of a grave safety concern. When Johnson learned about the incident, she selfterminated the contract.

“We know our specialty work, and we know what we need to complete it safely without injuring anyone or causing unnecessary damage,” says Marty Mohr, director of safety and risk management. “Our employees are the most important asset to the company, and there is no job or task that cannot be done safely.”

That attitude has helped CJ Drilling, a contractor in the electrical transmission and distribution industry, amass an impressive array of safety awards in the past decade, including being named one of America’s Safest Companies in 2015.

Fifty-six percent of employees have taken OSHA’s 10-hour construction course.

Each new or newly promoted supervisor is required to attend a training that includes OSHA’s 30-hour construction course, for which the company boasts a completion rate of 20%.

But still, Mohr explains that wasn’t enough training for CJ Drilling. OSHA provides limited examples to define safe work practices specific to CJ Drilling’s core tasks, drilling deep shaft foundations, so the company developed its own on-site training facility for drill rig operators. That includes a safe drilled shaft excavation set up to address OSHA’s Focus Four Hazards: falls, struck by, caught by/between and electrocution.

CJ Drilling also established an underground damage prevention permit as a hold point before beginning an excavation. The permit allows the employee completing the work to compare physical site conditions to the dig ticket information in the local 811 system to identify any lapses. Employees have, on several occasions, found indicators of an underground utility that had not been marked.

Moreover, employees visit a jobsite at least one week prior to beginning work to ensure there are no hidden safety traps that may not be disclosed in the contract documents, such as low hanging power lines or obstructed sites.

Employees begin each workday with a daily task analysis meeting where tasks are defined, hazards are identified and safe practices are discussed. CJ Drilling also created a Good Catch Program to reward employees for discovering and correcting hazards before an incident occurs.

“Without these proactive elements, we would certainly never realize the rewards in our lagging indicators,” Mohr says.

7

America’s Safest Companies 2021: Ampirical 10.18.2021 | EHS Today by Dave Blanchard

AMPIRICAL | UTILITY ENGINEERING AND CONSTRUCTION | COVINGTON, LA 262 EMPLOYEES | 6 SITES | 7 EHS PROFESSIONALS At Ampirical, a perfectly planned and budgeted project is still considered a complete failure if someone gets hurt.

In the construction industry, it’s always good when a company finishes a project ahead of schedule and under budget. But as Rod Courtney, HSE manager with Ampirical, points out, neither of those things matter much if you can’t also say, “We finished the project without hurting anyone or the environment.”

At Ampirical, a perfectly planned and budgeted project is still considered a complete failure if someone gets hurt, Courtney explains. “We perform all our work knowing errors will occur, and we build that into the process and allow our employees to fail safely. We don’t try to fix the worker; we fix the work.”

Every employee is responsible for identifying actual and potential hazards, and every employee, subcontractor and visitor to a job site receives appropriate health and safety instructions before entering a job site, and any activity undertaken must first take safety into consideration.

“Preventing accidents and injuries is not only in the best interest of our employees and subcontractors; it is also in the best interest of the company as a whole,” Courtney says.

To keep employees—especially those working from home—focused and engaged throughout the pandemic, Ampirical developed a Safety Committee Charter, which aims to: • Involve all employees in achieving a safe, healthy workplace; • Have all safety-related incidents, injuries, accidents, and illnesses promptly reviewed; • Conduct bi-monthly workplace inspections, identify hazards, and recommend methods to eliminate or control the hazards; • Annually evaluate workplace safety and health, and recommend improvements to management.

Safety managers frequently lament that they’re not involved in significant decisions at the corporate level, but not so at Ampirical, where the HSE department is involved early on in the construction and engineering process.

“As the HSE manager, I attend pre-bid meetings with clients and potential clients long before any work starts,” Courtney says. “This not only allows us to ensure our programs are aligned, but also shows our clients how important safety is to our leaders.”

You cannot eliminate injuries by managing statistics better,” says Matthew Saacks, the company’s president. “We will not be satisfied with our performance on any job unless we can say the job was done accident-free and without jeopardy to the health and safety of all those involved.

9

NSC 2021: The Key to Resilience Is a Simple Four-Letter Word 10.12.2021 | EHS Today Staff by Dave Blanchard Those who love their jobs are the most successful and

engagement, culminating in a global survey of 26,000

resilient in the workplace.

workers in 25 countries. The goal of the survey, he notes,

One of the reasons frequently cited to explain why

was to help leaders become more engaged and resilient,

employees are so slow to adapt to new procedures and

while also learning how to build engagement and resilience

technologies—whether it be in the area of EHS or any other

in their employees.

part of their daily work life—is that they’re afraid of change.

As the keynote speaker at the National Safety Council’s

An entire cottage industry has emerged over the past

2021 NSC Congress and Expo in Orlando, Fla., Buckingham

several decades focusing on change management, and

addressed the whole nature of workplace studies. “If you

on helping bring employees up to speed on the latest and

want to learn about something, you go study that thing

greatest ways their senior leadership intends to fix whatever

in the real world. That may sound obvious, but in business

is preventing the company from achieving excellence.

we tend to do the opposite. We study failures, and then

As Marcus Buckingham sees it, though, that’s inverted

conclude we should do the opposite. But excellence isn’t

thinking at its worst. “People don’t fear change,” he asserts.

the opposite of failure,” he emphasized. “Fixing something

“They fear the unknown.”

that isn’t working is not the way to excellence.”

As a researcher at Gallup, Buckingham helped create

Coinciding with the emergence of the COVID-19

the popular StrengthsFinder tool, and since going on his own he’s become a well-known author and consultant

pandemic, the survey revealed an unsettling development: Only 17% of the world’s workers feel highly resilient in their

specializing in what he calls the Strengths Revolution. For

jobs and their lives.

the past few years he’s headed up a research initiative

Through the course of his work with ADP, Buckingham’s

at ADP Research Institute focusing on resilience and

team developed a list of 10 workplace questions to

determine how resilient or vulnerable an employee is, as well as their level of leadership within the company: 1. I have all the freedom I need to decide how to get my work done.

2. No matter what else is going on around me, I can stay focused on getting my work done.

3. In the last week, I have felt excited to work every day.

4. I always believe that things are going to work out for the best.

5. My team leader tells me what I need to know before I need to know it.

6. I trust my team leader.

7. I am encouraged to take risks.

8. Senior leaders are one step ahead of events.

9. Senior leaders always do what they say they are going to do.

10. I completely trust my company’s senior leaders.

Federal Contractor Vaccine Guidance Issued 10.05.2021 | EHS Today by David Sparkman

According to Buckingham, there isn’t a significant gender discrepancy, as both men and women reported similar levels

Guidance does not apply to all contractors or right

of resilience. Age didn’t seem to matter much either. What did

away to those it does.

matter, though, was how close the respondent has been to COVID, whether personally affected, or a family member, or close friend. “The closer you are to COVID,” he observed, “the more likely you’ll be resilient.”

President Biden’s Executive Order requiring private employers of over 100 workers to have all of their employees vaccinated is wending its way through the bureaucracy before being issued by the Occupational

Another finding from the survey points directly to the

Safety and Health Administration (OSHA) as an

effectiveness of leadership in communicating its messages to

Emergency Temporary Standard (ETS). In the meantime,

the workforce. “If you trust your co-workers, supervisors and

the administration lost little time telling federal

senior leaders, you’re 42 times more likely to be highly resilient,”

contractors and subcontractors how they are expected

Buckingham said. The more often that a leader checks in with

to get with the program.

their team, the more resilient that team will be. “Frequency trumps quality when it comes to employee check-ins,” he emphasized.

On Sept. 24, the Safer Federal Workforce Task Force issued guidance that requires certain federal contractor employees to be fully vaccinated against COVID-19

So how does somebody actually become resilient at work?

by Dec. 8. Although calling the announcement a

Admitting that the concept might sound a bit odd, Buckingham

“guidance” may cause some confusion, the reality

nevertheless insisted that the key is a simple four-letter word: love.

is that this is considered a binding order, not just a

“The most resilient and successful people find love in their work,”

suggested course of action.

Buckingham asserted. In other words, he explained, they find

Vaccine mandates have become highly controversial

something that they love to do in their work lives every single

in the wake of Biden’s announcement and reports that

day. To become more resilient, he said, find those things and

thousands of teachers and healthcare workers are

activities in your job that give meaning to your life, and then

losing their jobs for refusing to be vaccinated, in many

make sure you do those things at work every day, whether

cases because they already have the antibodies or can

you’re a line employee, a supervisor, or a senior leader. “Focus

cite medical reasons supplied by their doctors.

on what you love to do, and what you can control in your life.”

In regard to a recent controversy that strikes at the very core of the mandate, the guidance offers no recourse to those who do not wish to be vaccinated because they have already had the disease and therefore

11

possess natural immunity. The guidance in fact specifically

related to masking and physical distancing while in

states that prior COVID-19 infection does not exempt an

covered contractor workplaces.

employee from the mandate.

• Designation by covered contractors of a person or

The only exceptions are for those legally entitled to an

persons to coordinate COVID-19 workplace safety efforts

accommodation because of a disability or a sincerely held

at covered contractor workplaces.

religious belief. However, the guidance doesn’t provide direction about how to evaluate accommodation requests and states only that an employer receiving a request “should review and consider what, if any, accommodation it must offer.”

To make matters murkier, the guidance does not lay out how the government plans to enforce the mandate or explain what the government intends to impose in the way of fines or penalties. There also is uncertainty surrounding how the Federal Acquisition Regulatory (FAR) Council will incorporate the vaccine, masking and social distancing requirements into contract language, and actions it will take to discipline contractors found to have violated those terms.

Attorneys Christopher Durham, Jonathan Segal and Meredith Gregston of the Duane Morris law firm note that even if an employee does not perform any work on or in connection with a covered contract, they will be subject to the vaccine mandate if they work at a location where any other employee performs work in connection with the contract.

“Remote employees who work on a covered contract but never go to a federal worksite or into an office nonetheless are required to be fully vaccinated in accordance with the mandate (though the employee would not be subject to the other safety requirements applicable to covered contractor workplaces),” they point out.

That will need to be done through a formal rulemaking

WHAT EMPLOYERS SHOULD DO

proceeding, which is expected to be initiated in early

In addition to mandating employee vaccination, covered

October. And then, of course, there are the penalties that

contractors must also implement additional workplace

could arise from an eventual OSHA ETS pronouncement.

COVID-19 safety measures, explain attorneys Durham,

For an employer to come under the federal contractor vaccine mandate, it must enter into certain government contracts or “contract-like instruments” that were defined

Segal and Gregston, including implementation of masking and social distancing requirements, and naming of COVID-19 safety person staff.

in the President’s Sept. 9 Executive Order on or after Nov.

Contractors are required to implement and enforce masking

14, 2021, if their contracts meet or exceed the simplified

and physical distancing requirements published by the

acquisition threshold, which is currently set at $250,000.

Centers of Disease Control and Prevention (CDC), including

Contract-like instruments are defined as “awards and notices of awards; job orders or task letters issued under basic ordering agreements; letter contracts; orders, such

sector-specific CDC guidance applicable to certain kinds of settings, including healthcare, transportation, correctional and detention facilities, and schools.

as purchase orders, under which the contract becomes

Because proper safety protocols (such as mask

effective by written acceptance or performance; exercised

requirements for fully vaccinated employees) can differ

contract options; and bilateral contract modifications.”

based on the level of community transmission where a

The vaccine mandate does not apply to grants; contracts with Native American tribes under the Indian Self-Determination and Education Assistance Act; employees who perform work outside the United States; or subcontracts solely for the provision of products.

Covered contractors and subcontractors will be required to conform to the following workplace safety protocols: • COVID-19 vaccination of covered contractor employees, except in limited circumstances where an employee is legally entitled to an accommodation.

• Compliance by individuals, including covered contractor employees and visitors, with the guidance

workplace is located, the guidance requires contractors to check the CDC’s COVID-19 Data Tracker County View website for community transmission information in all areas where they have a covered contractor workplace at least weekly to determine proper workplace safety protocols.

Contractors also must designate a person or persons to coordinate implementation and compliance with the guidance at workplaces, including the workplace safety protocols set forth in the guidance. Those people also are responsible for communicating workplace safety protocols to employees and “all other individuals likely to be present at covered contractor workplaces,” which includes posting signage.

Attorney Andrew R. Turnbull of the law firm of Morrison

notes. Also, they should devise plans for complying with

& Foerster offers employers advice on specific steps

confidentiality and privacy protections when implementing

they should take right away. Recognizing that coverage

these requirements.

issues remain murky and difficult, he recommends companies should: • Compile a list of the contracts that are anticipated to be entered, modified, or extended after Oct. 15, 2021, that could be covered by the order.

• Assess which employees work on or in connection with those contracts.

• Track where those employees work to understand the work locations that may be covered by the masking and social distancing requirements.

Employers, Turnbull says, should create plans for ensuring employees who work on or in connection with a covered contract are fully vaccinated by Dec. 8, 2021, which includes: • Determining which covered employees are fully vaccinated and not fully vaccinated.

• Creating systems for obtaining and maintaining actual proof of vaccination status and processes for employees to obtain proof of vaccination if they have lost their vaccine documentation.

• Developing contingency plans for ensuring covered employees who are not fully vaccinated either become fully vaccinated by Dec. 8 (unless eligible for an accommodation), or if possible transferred to work on contracts not covered by the order.

Also, designate a person or persons to oversee implementation and compliance, and plan for training human resource personnel and managers responsible for implementing the requirements.

In addition, create plans for masking and social distancing in accordance with CDC guidance for all individuals in workplaces where covered employees work. Monitor other federal and state laws that may impose additional requirements, including the rules for contractor employees working at federal facilities and the upcoming OSHA vaccination standard for employers with 100-plus employees.

Last but certainly not least, Turnbull suggest, make sure records of cost increases related to complying with the order are appropriately tracked and maintained, in order to support requests for cost reimbursements or equitable adjustments.

Federal agencies are being encouraged to to broadly apply these requirements to nearly all federal contracts, which Turnbull says emphasizes the need for contractors to remain watchful.

“All contractors—even those not explicitly covered by the order—should ensure that their employees who handle federal contracts and subcontracts are informed about the order and guidance, and are ready to scrutinize all

Employers also should review and, if needed, update

contracts issued, modified, or extended after Oct. 15 to

procedures for addressing accommodation requests for

see whether the government is trying to subject them to

disabilities and sincerely held religious beliefs, Turnbull

these requirements.”

13

Safety21: Back in the Saddle Again 10.06.2021 | EHS Today by Dave Blanchard The safety profession has done itself proud during the

Frederick ended up appearing virtually rather than in

pandemic and is ready to make up for lost time.

person, and in his prepared remarks he completely

That hootin’ and hollerin’ you may have heard coming

avoided commenting on the ETS. However, he did say,

out of Austin, Texas, back in September wasn’t due to any country music festival—it was the cheers of the safety community finally getting to attend a major event again: ASSP’s Safety21. Yes, attendance was down a bit from typical in-person ASSP shows in the past, but the overwhelming feeling within the session rooms and exhibit hall was one of relief mixed with celebration. It just felt good

“Vaccination is the ultimate step to protect workers, and our priority is the safety and health of workers.” Frederick also noted that OSHA has requested a $73 billion budget increase and 362 additional employees, as he said the agency’s biggest need was to add more enforcement and compliance personnel. So that gives you some idea of how OSHA inspectors may be planning for a dramatic increase

to see a gathering of safety professionals again, even with

in caseloads.

social distancing and masked-up protocols.

Although COVID-19 was understandably on every

Just days before Safety21 began, President Joe Biden

attendee’s mind at Safety21, Wendy Burkett, global safety

announced that he had directed OSHA to write an Emergency Temporary Standard (ETS) that would require businesses employing 100 or more to insist employees either get vaccinated or undergo weekly testing for COVID.

director with Ford Motor, pointed out that, “Safety incidents didn’t stop happening at Ford just because we were in a pandemic. People still get hurt and things still fall, so we had to keep our focus on core safety events even as we also

So with Jim Frederick, acting head of OSHA, already

focused on keeping everyone safe from COVID.”

announced as a keynote speaker, the buzz around the

Speaking on a panel focusing on business continuity efforts

show speculated on how much Frederick would say about

at large companies, Burkett reminded the audience that

exactly how the agency planned to enforce the mandate.

the automotive industry was shut down for two months

in the early days of COVID last year, and like other

Perhaps no company has been more visible throughout

manufacturers, Ford pivoted to making PPE such as face

the pandemic than retail giant Amazon, whose parcel

masks, face shields, gowns and ventilators. The company’s

delivery business more than doubled in 2020. Amazon, in

Project Apollo initiative produced more than 140 million

fact, has quickly become the third-biggest deliverer of

units of PPE, most of which went to healthcare workers and

parcel shipments in the U.S., ahead of FedEx (USPS and UPS

communities, but some also to Ford’s own employees.

are still numbers 1 and 2). That kind of growth led to a lot of

“Manufacturing facilities aren’t designed and set up

process changes for Amazon—150, in fact, according to

for people to work 6 feet apart,” Burkett notes, “so the

Heather MacDougall, VP, worldwide of workplace health

creativity and ingenuity of the automobile manufacturers

and safety.

to adapt to social distancing was nothing short of amazing.

“We invested $1.5 billion to react to COVID,” she explained.

The auto industry really came together to emphasize

“We built our own COVID testing lab for our employees. We

workplace safety.”

provided on-site vaccination events. We developed and

Another sector that’s had to reinvent itself during the

then began selling face shields and developed the Distance

pandemic is the waste management industry. Jim Olson,

Assistant to monitor social distancing at our facilities.”

VP of safety with Republic Services, a $9 billion solid waste

Amazon, MacDougall added, wants to be known not only

collection and disposal company, described how quickly

as Earth’s Best Place to Work, but also Earth’s Safest Place

his business changed. “Instead of people generating a

to Work, and to that end the company will focus heavily on

lot of waste while at businesses, they started creating it

community and the environment.

at home,” he related, which meant shifting Republic’s business model. “We had to train our drivers on different types of trucks that would go into neighborhoods rather than to companies.”

Burkett observed that COVID has thrust the safety profession to the forefront of business planning. “We now have a voice in the room, and I think we’ll continue to have that voice going forward. The way safety professionals performed during the pandemic has been a proud moment for us.”

FALL PROTECTION: Impalement weeklysafety.com Ironworkers have identified impalement as one of the Deadly Dozen Hazards1 and a leading cause of injury on construction sites.

Contributing factors that can lead to impalement incidents include: • Unprotected rebar dowels • Reliance on mushroom caps, which don’t protect workers from impalement • Improper wooden trough installment • Inadequate precautions when working over dowel covers • Inattention to other impalement hazards besides rebar This safety topic provides general safety guidance to consider when impalement hazards are a risk on the construction site.

Because impalement is so serious and often catastrophic, or deadly, it’s important that all crew members understand and follow all safety guidelines that pertain to working with rebar and preventing impalement hazards. State OSHA plans and project specific guidelines may be more strict than federal OSHA requirements.

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There are three OSHA Standards that provide the regulations to protect workers from all impalement hazards on the job site.

1. There is one OSHA standard that very specifically

• Plastic mushroom caps that are not reinforced with steel are not adequate enough to protect against impalement.

• All workers should be able to recognize when rebar becomes a hazard.

applies to rebar impalement hazards.

OSHA Standard 1926.701(b) All protruding reinforcing steel, onto and into which employees could fall, shall be guarded to eliminate the hazard of impalement.

2. Housekeeping issues can increase impalement risk if hazards are not managed throughout the workday.

OSHA Standard 1926.25(a) During the course of construction, alteration, or repairs, form and scrap lumber with protruding nails, and all other debris, shall be kept cleared from work areas, passageways, and stairs, in and around buildings or other structures.

3. It’s important to remember that rebar is not the only impalement hazard found on construction sites. Other impalement hazards not specifically mentioned in the OSHA standard, like protruding pipes, bolts, reinforcing wire, and cables are covered under the General Duty Clause.

OSHA General Duty Clause 5(a)(1) Each employer shall furnish to each of his employees employment and a

Common ways to guard rebar to prevent impalement:

place of employment which are free from recognized

• Steel-Reinforced Rebar Caps

hazards that are causing or are likely to cause death or

• Carnie Caps

serious physical harm to his employees.

OSHA states that protective devices capable of

• Wooden Troughs • Bending Rebar

withstanding at least 250 pounds dropped from a height

If the rebar caps being used on site are too narrow, not

of ten feet will eliminate the hazard of impalement in most

steel-reinforced, or do not meet OSHA’s requirements for

cases. However, as long as a protective device guards

protection, the caps will not protect workers from impalement.

protruding rebar enough to eliminate the hazard of

If a worker falls on rebar with these ineffective caps the

impalement, it satisfies the requirements of the standard.2

impact pressure can still cause a deadly impalement.

• When employees are working at any height above

Rebar caps that are designed to prevent impalement are

exposed rebar, fall protection and/or fall prevention

typically larger than mushroom caps, square in shape, and

needs to be in place.

fabricated with steel inside that prevents the rebar dowel

• Limit access to the work area where formwork, protruding rebar, and rebar cages are present.

• Guarding on rebar impalement hazards must be done when workers will be working around or at any height above exposed rebar, including work situations where the rebar is below grade or in a basement.

from penetrating the protective cover.

Rebar of any length, any diameter, and any direction (horizontal or vertical) must be guarded when there is the hazard that a worker could fall onto the bar and be impaled (skin pierced).

Wooden or metal troughs can be an effective method to provide impalement protection, but they should be designed and tested to ensure that impalement protection has been documented.

Impalement hazards are not limited to protruding rebar. Any projection on the job site that is an impalement risk must be guarded.

Angle iron and other impalement hazards on site may not be suitable for protective covers so consideration must be given to how workers will be protected from impalement risk while the hazard exists during construction.

FOOTNOTES 1 Deadly Dozen; ironworkers.org/news-magazine/ironworker-magazine/archives/articles/2012/07/10/preventingimpalement-one-of-the-deadly-dozen-hazards 2 OSHA Standard Interpretation Letter Re: Impalement Protection; osha.gov/laws-regs/standardinterpretations/2014-08-26-0

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