Safety Net | December 2021

THE SAFETY NET CO N SU LTA N T S

•

DESIGNERS

•

ENGINEERS

DECEMBER 2021

IT’S ALWAYS SAFETY FIRST. •

CO N STRUCTO RS

VOLUME 15 ISSUE 12

Worldwide Food Service Safety Month

SAFETY FIRST. Worldwide Food Service Safety Month is an annual designation observed in December. The goals of this month are to focus on keeping food safe as it’s prepared

Austin employees have

in the service industry, as well as reminding us to be safe and cook properly when we

worked 4,522,900 hours

are making our own food at home. This month, the holidays are in full swing; so what

without a Lost Time Accident

better a time than now to practice safety while cooking?

through 10/2021.

Did you know more than 200 diseases are spread through food alone? One in ten people become sick every year from eating contaminated food, and 420,000 people are killed from these illnesses every year. These types of illnesses can cause long-term health problems if they don’t kill you, so it’s very important to be adamant about consuming safely prepared food. Children younger than 5 years old are at the highest risk. The good news is, proper food preparation can prevent almost all foodborne illnesses. Remember, everyone has a role in keeping food safe.

It’s a shared responsibility among the government, producers, food service industries, and consumers.

HOW TO OBSERVE Use #WorldwideFoodServiceSafetyMonth (we know, it’s long) to post on social media about how you are participating in WFSSM. Here are some food hygiene tips for next time you’re cooking a meal at home.

1. Wash your hands with warm water and soap before handling food and make sure you thoroughly wash them again when you’re done.

2. If you have any cuts on your fingers, hands, or wrists, cover them with bandages before handling food.

3. Thoroughly wash your fruits and veggies with clean, warm water before use.

4. Make sure your cooked foods are separate from raw foods to avoid harmful bacteria cross-contamination.

5. Use fresh utensils when switching from raw meat to other foods during preparation.

6. Regularly wash your dishcloths and towels in the kitchen using hot water to keep as clean as possible.

7. Do not undercook your meat. Use a thermometer to make sure you get it right!

HISTORY Worldwide Food Service Safety Month has been recognized since December 1994 to remind everyone that food safety is crucial when cooking for others and ourselves.

Control Noise Sources Before Using Hearing Protection 10.25.2021 | Safety Management Suite A noisy workplace may conjure images of hearing

Path controls involve isolating, blocking, diverting,

protection, but OSHA requires employers to consider

absorbing, or otherwise reducing noise intensity before it

engineering and work practice controls before using

reaches employees’ ears. Examples include:

personal protective equipment. Reducing or eliminating

• Moving noisy equipment away from employees (noise

noise can decrease the number of workers in a hearing conservation program. This not only protects workers’ hearing, but can save the company money.

To get started, conduct a noise assessment. Focus on areas where communication is difficult in a normal voice. Identify all noise sources and determine how the sound is transmitted to the room (it’s often amplified by vibration). Noise sources include motors, gears, belts,

intensity decreases with distance).

• Using sound-absorbing acoustical tiles and blankets on floors, walls, and ceilings.

• Enclosing equipment within barriers designed to absorb noise or deflect it in harmless directions, such as toward ceilings covered with sound absorbent material.

• Even if hearing protection is still necessary, source and

points of operation, and any other moving parts. Resonant

path controls that reduce total noise will also reduce the

transmitters include the frames, footings, and housings of

risk of hearing loss.

equipment. First, consider engineering controls to reduce noise levels.

SOURCE AND PATH CONTROLS

WORK PRACTICE CONTROLS If engineering controls still don’t reduce noise to acceptable levels, consider work practice controls. These

Source controls reduce the amount of noise generated.

are changes in schedules or production such as operating

Examples include:

noisy machinery on a second or third shift when fewer

• Maintaining motors and all moving parts in top operating condition.

people are exposed, or rotating employees through quieter

• Reducing operating speeds to the lowest level consistent with production goals.

• Ensuring that equipment is not in contact with other equipment or with walls.

jobs to reduce noise exposure time.

Work practice controls are limited because changing jobs or production schedules is often not possible. In addition, rotating employees between jobs may increase the risk of small hearing loss in many workers.

• Isolating noisy equipment using springs or rubber footings.

• Applying vibration-reducing materials and constructing sound-absorbent hoods around points of operation.

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Construction Lighting: Ins & Outs of Illuminating Your Worksite 01.09.2020 | CONSTRUCTCONNECT by Ellie Batchiyska Proper construction lighting is a critical component

• Five foot-candles – General construction area lighting.

to worksite safety, not unlike the equipment and gear

• Three foot-candles – Concrete placement,

used by workers. It improves nighttime visibility, making workers less prone to hazards in the evening, and also ensuring the safety of passersby in high-traffic zones.

To ensure lighting is up to code for a construction site, the Occupational Safety and Health Administration (OSHA) has outlined a set of specific standards. OSHA standard 29 CFR 1926.56 for construction areas sets minimum requirements, measured in foot-candles, for workers to navigate and avoid hazards.

A foot-candle is a standard level of light emitted from one candle falling on a one-square-foot area one foot away. The term remains a little vague and antiquated even by OSHA’s reckoning. Light, today, is typically measured as a lumen or lux. For the sake of simplicity, one foot-candle can be equated to one lumen per square foot.

excavation and waste areas, access ways, active storage areas, loading platforms, refueling, and field maintenance.

• Five foot-candles – Indoors: warehouses, corridors, hallways, and exit ways.

• Five foot-candles – Tunnels, shafts, and general underground work areas. Exceptions apply: for shaft and tunnel heading, ten foot-candles is the requirement for mucking, drilling and scaling.

Bureau of Mines-approved cap lights are also acceptable.

• Ten foot-candles – In general shops or construction plants such as screening plants, batch plants, carpenter shops, mechanical and electrical equipment rooms, rigging lofts, active storerooms, mess halls, and indoor toilets and workrooms.

LIGHTING STANDARDS & TYPES

• Thirty foot-candles – first aid stations, infirmaries, and offices.

In OSHA standard 1926.56(a), the minimum foot-

For industrial areas not covered by the OSHA

candles for each area of operation are outlined.

These include ramps, runways, storage areas, and work sites. Their requirements break down as follows:

standards, construction managers can refer to the American National Standard A11. 1-2965, R1970. This includes industrial lighting for warehouses, shipyards,

loading docks, and other such circumstances.

Moving to LED can result in an aggregate savings of

While there is no one implementation or solution

thousands of dollars. On top of that, electricity rates

for construction lighting, there are ideal fixtures

continue to rise while onsite lighting runs nonstop,

depending on the kind of work being conducted.

night and day. Logistics play a part as well. LEDs cover

LIGHT TOWERS Light towers are versatile, capable of covering a wide area, and are the most common lighting application in construction sites. They typically consist of an adjustable mast, a generator, and a group of lighting components at the top that can rotate 360 degrees from as high as 30 feet.

In recent developments, solar-powered light towers last as long as 36 hours and work without generators, making them simple to relocate.

HIGH MAST LIGHTS As opposed to temporary fixtures, these are semipermanent installations. A light pole—as much as 100 feet tall—supports a luminaire ring, typically

more area at an 80 percent lower rate of consumption.

Again, lower rates for the developer means more work for the contractor. Standard string lighting is extra work to install and difficult to keep and reuse.

Furthermore, incandescent and CFL bulbs continually need replacing, resulting in dedicated labor costs and wasted materials.

One LED light, however, covers the same area as a 250-foot stretch of string lights, which reduces installation and maintenance logistics from 25 lights to one. Some designs are plug and play, which means less wiring work. They’re also easy to relocate, so they move with changes in jobsite configuration instead of getting in the way.

With the potential to reduce energy consumption

composed of four to eight lights covering a large area.

by 60 to 90 percent, LEDs are one of the best options

NITE LIGHTS

LED floodlights, specifically, can provide optimal

Nite lights are another recent development approved for construction sites. They consist of metal halide

for a cost-effective reduction in CO2 emissions. visibility for an otherwise dim construction site. Their illumination spans between 50 to 120 degrees of light,

lamps running at 400 watts covered by a diffusing

creating a large beam that can cover a vast area.

cloth, creating a softer effect while providing sufficient

Thus, the efficacy of worksite lighting comes down

lighting levels.

not only to the fixture-type but the bulb-type. With

BALLOON LIGHTS

tall, ample fixtures boasting LED light bulbs scattered

Balloon lights typically apply to workstations or mount

easy to meet OSHA illumination standards.

throughout your construction site, it should be fairly

onto equipment or vehicles. The lights have air or helium-inflated covers made of light-diffusing material placed on stands.

LED LIGHTING LEDs have transformed the lighting industry. They have a longer lifespan, are more efficient, and are better for the environment. Since standard, CFL lighting is cheaply-made, worksite lighting has traditionally served as disposable equipment after job completion.

It costs in terms of labor and waste, with only 20 percent on-average salvageable.

LED lighting, however, is designed as a reusable asset.

It saves on energy, material, and labor for each project, leading to decreased charges for temporary lighting per project. Good sets can last five years, running around the clock.

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Some Observations About Safety Efforts 11.08.2021 | EHS Today by Terry L. Mathis Great safety efforts don’t focus on best practices, but instead continuously look for better practices.

After 28+ years of heading ProAct Safety, and a corporate career prior to that, I have some institutional knowledge of safety practices that might be helpful or even diagnostic for your own safety efforts. No generalization is universally true, including these, but there are patterns that emerge after being exposed to hundreds of organizations, leaders, managers and programs.

I have heard that experience is what helps you to recognize a mistake when you are making it again, and I have seen these mistakes multiple times. After exposing these potential flaws, I will also point out some examples of excellence I have encountered along the way.

OBSERVATION #1: MOST SAFETY LEADERS DON’T LEAD SAFETY. My good friend and fellow pursuer of safety excellence, Earl Blair, wrote an article for Professional Safety Journal titled, “Great Leaders Do Not Solve Problems.” By that very definition, most safety leaders are not “great.” Of course, Earl was pointing out that great leaders get ahead of safety issues rather than waiting to get ambushed by them. Few of the safety leaders I have consulted with actually do that, and some who try to do so fail.

National Safety Council gives an award called CEOs Who ‘Get It.’ They are talking about leaders who have a deep enough understanding of safety to do a great job leading it. Most safety leaders will not get that award.

OBSERVATION #2: PEOPLE DON’T KNOW WHAT THEY DON’T KNOW. A frustrated client once pointed out to me that she had administered an expensive perception survey to her entire workforce, and the results were not conclusive. One of the perceptions measured was stated as, “I have everything I need to perform my job safely.” Workers were asked to agree or disagree with this statement. The vast majority agreed, yet the safety manager was aware of numerous deficits in training and safety equipment that she wanted to address. The survey was not supporting her agenda.

The problem is that people don’t know what is missing. Perceptions are not necessarily reality; they are merely how people perceive reality, and their perceptions are only based on the knowledge they possess. When you ask people what they don’t know, they can only base their answer on their own limited knowledge.

OBSERVATION #3: MOST SAFETY TRAINING SUCKS. I don’t think this observation needs a lot of elaboration for most safety professionals. Most organizations have followed the path of least resistance in required refresher training, opting for mind-numbing computer-based training (CBT) and abandoning hands-on training. Meanwhile, new employee orientation is often like drinking from a fire hose with entirely too much information to absorb, much less remember.

I have preached the principle that if you can’t get it in their heads, you won’t get it in their habits. Most safety information is not readily available in the heads of workers even after they are “trained.”

OBSERVATION #4: MOST SAFETY METRICS ARE HOPELESSLY REACTIVE. The realization that measuring accident rates and severity is descriptive but not predictive is finally becoming apparent. In reaction to this realization, many organizations are actively seeking to find what they are calling leading indicators. While this is taking them from one-dimensional thinking to two-dimensional thinking, the fact remains that the world is a threedimensional place. Most of what are being called leading indicators are simply measures of safety activities or efforts.

Activities do not directly impact results. Effective safety activities improve competence and culture. Competence and culture improve performance. Performance improves results. Organizations need to develop a balanced scorecard for safety and measure at each of these stages to truly understand how to improve safety. This is what W. Edwards Deming called “profound knowledge” of a process.

If you think of safety as a linear cause-and-effect model, you are missing the point. Safety is a process that involves multiple stages of progress, and if you don’t have metrics along the way, you will not see where your successes or failures are occurring.

OBSERVATION #5: SAFETY EXCELLENCE IS OFTEN ELUSIVE. Trying to drive all the variation out of safety efforts is a daunting task. Most workplaces are changing in one way or another: new employees, new processes, new products or services, and new management or supervision. And if the workplace is not offering enough change, the world away from work is.

Many organizations struggled to adapt to the COVID-19 pandemic and then struggled to get back to normal and are now struggling to adapt to the new surge. Home lives have been radically changed for many by these and other events.

The pursuit of safety excellence is a process, not an event. It is a continuously moving target, and organizations that achieve and maintain excellent safety performance are dynamic. They have learned to assess changes and develop new game plans regularly. They realize that the same thinking and actions that got them excellence last year or last month might not be sufficient anymore. As Marshall Goldsmith pointed out, “What got you here won’t get you there.”

Great safety efforts recognize success because of some of their actions and in spite of others. Just because a strategy is working doesn’t mean it is perfect or that it will continue working. Great safety efforts don’t focus on “best practices.” They continuously look for “better practices,” knowing that no best is ever so good you can’t conceive a better one.

Those pursuing safety excellence often benefit from observing others who have attained excellence, but never by simply imitating them. Every organization—and even every site within an organization—is unique and needs to focus on its individuality as well as its goals.

All progress begins with thinking differently. I know that these musings will not instruct or prescribe how you or your organization can achieve safety excellence. Instead, they are offered to help you break out of current patterns of thinking and open up to new possibilities. If you think you have all the answers, ask yourself how that is working for you. When you open your mind, there is almost always a better way.

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Top 10 standards most frequently cited by OSHA 11.11.2021 | Weeklysafety.com Every year OSHA releases the infamous Top 10 list and every year there is little change. Why is this list important and why should top management quit ignoring it?

During the National Safety Council 2021 Congress & Expo, OSHA released the results of the Top 10 standards most frequently cited for violations across all industries for which OSHA standards apply. OSHA issued over 21,000 citations in its Top 10 categories during 2021.

Deputy director of OSHA’S Directorate of Enforcement Programs, Patrick Kapust, notes that the results haven’t changed much over the years. While it may feel like a broken record playing over and over again, it’s really an opportunity for employers to change their tune about workplace safety by proactively identifying hazards and training employees to work safely.

Kapust recommends business owners and employers take a simple approach when reviewing this list of violations.

“Employers need to make sure their employees are protected,” Kapust said during the presentation. “The Top 10 tells us what OSHA is finding over and over again on a routine basis. Employers, use the list as a tool to assess your own workplace.”

HERE ARE THE TOP OSHA STANDARDS MOST OFTEN CITED FOR VIOLATIONS DURING 2021.

This list doesn’t vary greatly from year to year and this list always includes both Construction (1926) and General Industry (1910) standards.

Although several of these standards swapped places from last year, the standards that make up the Top 10 list remains unchanged from 2020.

1. FALL PROTECTION 1926.501 Fall Protection has been the number one most cited violation for the past several years. The fall protection standard is designed to prevent falls, which, according to statistics, account for just about 40 percent of deaths in the construction industry. Not surprisingly, most fall accidents happen on residential work sites where there is little oversight given to fall protection requirements.

To prevent fall injuries and fatalities, it is critical that employers supply their workers with guardrail systems, safety net systems or personal fall arrest systems when working at heights is required. In addition to just providing proper fall protection, the employer is also responsible for ensuring that all employees are trained on how to properly use fall protection and know when to use it.

OSHA has set requirements for employers to provide fall protection for their workers that are working on unstable surfaces or work sites that have unprotected sides and edges. Employers can provide fall prevention training by a competent person or they may prefer that their workers complete construction training courses that cover fall hazards and prevention at regional OSHA Training Institute Education Centers.

The sections of the Fall Protection standard that are most often cited for violations include residential construction, unprotected sides or edges, roofing work and floor holes including skylights.

2. RESPIRATORY PROTECTION 1910.134 OSHA’s Respiratory Protection standard directs employers on establishing and maintaining a respiratory protection program in the workplace. All aspects of respiratory protection are covered in this standard including procedures, administration, selection, training, fit testing, evaluation, use, cleaning, maintenance and repair.

Employers should be familiar with OSHA’s requirements for voluntary use of respirator dust masks too!

The sections of the Respiratory Protection standard that are ...continued on next page 9

most often cited for violations by OSHA include medical evaluations, respiratory protection requirements, fit testing, failure to establish a necessary respiratory protection program and identifying respiratory hazards in the workplace.

3. LADDERS 1926.1053 Working with ladders on the job can be hazardous, especially if the ladders are not functioning properly or not used correctly. Many injuries caused by ladders are serious enough to require time off the job. OSHA rules apply to all ladders used in construction, alteration, repair, painting, decorating and demolition of worksites covered by OSHA’s construction safety and health standards.

The sections of the Ladder Safety standard that are most often cited for violations by OSHA include failure to extend an extension ladder at least 3 feet above the upper landing surface, using ladders in an unsafe manner, and continuing to use ladders after they are broken or found to be defective.

4. SCAFFOLDING 1926.451 The OSHA Scaffolding standard covers safety requirements for scaffolding, which should be designed by a qualified person and constructed exactly in accordance with that design. Employers are required to protect all workers that use scaffolding from falls and falling objects. In addition, all scaffolds should be inspected by a competent person before use by the workers. The workers affected the most by scaffolding hazards include those in charge of framing, roofing, siding, and masonry.

The sections of the Scaffolding standard that are most often cited for OSHA violations include fall protection including guardrail systems, use of cross-braces for access, and planking/decking.

5. HAZARD COMMUNICATION 1910.1200 The Hazard Communication standard addresses chemical hazards produced or used in the workplace. OSHA’s standard for hazard communication is in line with the international standard but remains on the top 10 list year after year. The hazard communication rule has not been properly implemented by a large percentage of businesses and it’s clear that many workers are not being trained on the new standards that went into effect in 2013.

The sections of the Hazard Communication standard

that are most often cited for violations by OSHA include implementation of the hazcom program, training on hazardous materials, and requirements to develop and maintain Safety Data Sheets.

6. LOCKOUT/TAGOUT 1910.147 Lockout/Tagout (LOTO) affects workers that service, repair and maintain equipment or machines. Hazards exist if the equipment being handled can suddenly become energized or started during work.

For companies that require LOTO procedures, these are the sections of the LOTO standard that OSHA has cited most often for violations: general procedures, energy control program, periodic inspections, and training.

To round out the Top 10 list, standards with the most cited OSHA violations in 2021 were:

7. FALL PROTECTION - TRAINING REQUIREMENTS 1926.503 8. EYE AND FACE PROTECTION 1926.102 9. POWERED INDUSTRIAL TRUCKS 1910.178 10. MACHINE GUARDING 1910.212 “As an employer, what this list can do is give you a place to start,” Kapust says. “You can take a look at this list, identify root causes, perform analysis and stop an injury before it occurs.”

Thanks for being an awesome member and for putting #SafetyFirst! To login to your membership area at anytime to grab a new safety topic or toolbox talk for your next meeting, just go to our homepage at weeklysafety.com and the Login link is at the top of the page.

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Will OSHA Require Unvaccinated Workers to Pay for COVID Testing?

10.29.2021 | EHS Safety News America by Jordan Barab Throughout its 51 year history, OSHA has required employer

time in OSHA’s history that the agency has issued a safety

to pay for equipment, tests and items required by OSHA

or health standard with such an exemption. (Some OSHA

standards (with some minor exceptions). Yesterday, intrepid

recordkeeping and reporting regulations exempt small employers.)

Bloomberg reporter Ben Penn reported that anonymous

It is unclear how OSHA will legally justify the small business

sources had revealed that :

exemption. It seems clear that OSHA will not be able to

The Biden administration’s highly anticipated vaccine

argue that workers in small businesses are at less “grave

mandate rule for private-sector employers will allow

danger” than workers in larger businesses. True, small

businesses to force workers who refuse to get the Covid-19

business employees may be exposed to fewer potentially

shot to pay for required weekly tests and masks….

infectious co-workers. but many small businesses deal

The emergency rule…will give employers the option of

with the public. So even if you’re only exposed to 3 co-

paying for testing and masks for unvaccinated workers or

workers, you could be exposed to dozens or hundreds of

compelling those employees to foot the bill themselves….

unvaccinated, unmasked customers every day.

Employers will be required to absorb testing and mask

OSHA could justify the small businesses exemption by

costs in cases where a worker qualifies for an exemption to vaccination under federal law.

arguing that it is economically infeasible for small businesses to pay for testing (and masking) of their unvaccinated

The employer would have the option of paying for the

employees. But relieving employers of that obligation,

test instead of the workers, which should provide room for

which now seems to be OSHA’s intention, would seem to

bargaining in unionized facilities. And for those employees

undermine the feasibility argument as well.

who receive religious or other legal exemptions from

Neither of these are new ideas. Businesses have never

vaccination, the employer would pay for weekly testing and masks.

BAD IDEAS This is yet another bad idea coming out of OSHA related to this standard. OSHA has always required employers to pay for any personal protective equipment, testing or other measures required by OSHA standards, with the narrow exception of protective footwear and prescription safety eyewear. Allowing employers to require workers to pay for testing and masks would be unprecedented.

We’ve already know that this standard will exempt small businesses under 100 employees, which will mark the first

liked paying for employees’ equipment and small business interests have always argued that small businesses should be exempted from OSHA regulations. Small businesses even have an early bite of the apple with the SBREFA process that requires OSHA (and a few other federal agencies) to assess the impact of a planned standard on small businesses even before the official proposal is issued for public comment. (Labor, you may note, gets no similar early bite of the apple.)

But over the last half century, OSHA has managed to fight off these attacks. Until now.

Congratulations!

A Bloodborne / First Aid / CPR/AED class was conducted at the Lockheed Martin Project in Mississippi.

Congratulations to all.

(Shown Left to Right)

Gary Everett Robert Gomex (Jacobs) Duane Lofdahl Mark Downs Andrew Loveless Craig Herndon 13

Your Company’s DART Rate Explained! #WorkplaceSafety #WorkplaceInjuries 11.12.2021 | EHS Safety News America by Jack Benton Understanding your organization’s DART rate is a critical

determining whether you are selected for an unwelcome

aspect of compliance, and it can have various implications

visit from OSHA. The lower the rate, the better off your

on your business. Vendors and customers are increasingly

organization will be. The good news is you may be able to

requesting DART rates as part of the selection process, and

lower this rate even further by making sure it’s calculated properly.

the Occupational Safety and Health Administration (OSHA) uses your DART rate to make determinations on your safety

HOW TO CALCULATE A DART RATE

record and workers’ compensation — the safer your work

Your organization’s DART rate is calculated in the following way:

environment, the lower your rate will be.

1. Add up the number of workplace injuries that

Let’s unravel what a DART rate is, how to calculate it and

are severe enough to warrant days away from

the financial impact it can have on your business. Then,

work, restricted work activities and/or job transfers

we’ll look at strategies for lowering your DART rate and

encountered throughout the year.

improving worker safety.

WHAT IS A DART RATE? DART stands for Days Away, Restricted or Transferred. The

2. Divide that number by the total number of hours worked for all employees in that year.

3. Multiply this summation by 200,000.

DART rate is an OSHA calculation that determines how safe

Here’s an example:

your business has been in a calendar year in reference

Let’s say your organization experienced a total of five

to particular types of workers’ compensation injuries. It’s determined by how many workplace injuries and illnesses resulted in employees missing work, required restricted work activities or resulted in them being transferred to another job.

recordable workplace injuries throughout the year, and all employees — including management, temporary and leased workers — accumulated 645,000 hours worked in that year. Given this scenario, here is how your

OSHA issued new reporting requirements, and companies

organization’s DART rate would be calculated:

are now required to submit DART rates electronically.

5 / 645,000 = .0000077 x 200,000 = 1.54 DART Rate

Results are heavily monitored and play a very critical role in

HELPFUL TIPS WHEN CALCULATING YOUR DART RATE

IMPLICATIONS OF A HIGH DART RATE

• Do not include vacation, sick leave or holidays when

your organization. Many businesses now request DART

calculating the total number of hours worked during the year.

• Be sure to include all “eligible” hours worked in the IR calculation. When calculating IR, the denominator (total

A high DART rate can have a major financial impact on rate information from their suppliers and subcontractors to ensure they’re working with companies that have acceptable safety standards. A high rate could put your

hours worked) must be accurate. Basic algebra reveals

organization in a negative light and result in lost sales.

that the higher the denominator, the lower the rates will be.

A high DART rate could also trigger a comprehensive OSHA

It’s important when determining the total hours worked

inspection of your safety programs, record keeping, training

to not overlook clerical staff, maintenance personnel, temporary workers or employees who are exempt (e.g., salaried). Also, when estimating hours worked for exempt employees, it’s essential to closely examine these numbers and avoid any potential miscalculations.

programs and more. This is especially important now that the new electronic reporting law is in effect and OSHA can immediately be alerted about companies with high DART rates. An OSHA inspection is not only an inconvenience that can take time away from your operations, it could also

For example, if an exempt employee worked 50 hours

expose potential violations and lead to fines or corrective actions.

per week on average and took three weeks of vacation

Perhaps one of the biggest financial implications is the

last year, their estimated hours worked should be

effect a high DART rate has on your workers’ compensation

calculated to 2,450 (50 hours x 49 weeks) as opposed

insurance premiums. Your DART rate is an indicator

to 2,080 hours (40 hours x 52 weeks). This is a common

of how safe your work environment is, which impacts

mistake that employers make when calculating hours

your Experience Modification Factor, a major factor in

worked for exempt employees.

determining work comp premiums. Work comp claims that

• Ensure that new rules for electronic submission of forms are followed. Provide proper training for those

have lost time or wages can cost employers approximately three times more than having the claim be considered

responsible for recordkeeping and maintaining OSHA

“medical only.”

logs. Also, contractors should review their logs to make

STRATEGIES FOR MAINTAINING A LOW DART RATE

sure only those cases involving medical treatment — not first aid — are recorded.

• Compare your DART rate with the average for your standard industrial classification, which is published annually by the Bureau of Labor Statistics. This will determine the effectiveness of your safety management program.

• Implement a return-to-work program to minimize the

There are numerous “Best practices” regarding injury prevention to lower your Dart Rate. The majority of successful companies will cite their well communicated, company-wide safety culture as the key to their success.

The culture is developed by consistent messaging and behaviors throughout the company, such as: safety

number of lost workday cases. Recording a “restricted/

committee meetings, safety posters as visual reminders,

transfer” case is preferable to recording a “lost workday”

strong accident investigation programs, job safety analysis

case. While it’s not ideal to have either case on your log,

for each job, early return to work program and many others.

a “restricted/transfer” case is considered less severe.

Educate those in supervisory positions on the benefits of a return-to-work program.

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