osha compliance for private fleets this webcast will cover... introduction to osha requirements,...

OSHA Compliance for Private FleetsThis webcast will cover ...• Introduction to OSHA Requirements,• Industry Best Practices,• GNC Corporate Safety,• GNC Driver Safety Training, and• Question & Answer

ModeratorDr. Gary Petty, President & CEO, NPTC

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PanelistsMark Stromme, Editor - Workplace Safety, J. J. Keller & Associates, Inc.Tom Moore, Vice President of Education, NPTCJohn Koch, Corporate Safety Manager, General Nutrition CentersBill Hartman, Manager of Private Fleet Operations, General Nutrition Centers

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Introduction

Dr. Gary Petty

President & CEO

National Private Truck Council

Gary Petty National Private Truck Council

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Introduction• Introduction to OSHA Requirements - Mark Stromme• Industry Best Practices - Tom Moore• GNC Corporate Safety - John Koch• GNC Driver Safety Training - Bill Hartman• Housekeeping issues:

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Cautions• The content in this webcast is intended for

information purposes only and should not be construed as providing legal advice.

• This is an introductory course and is intended to highlight critical safety and compliance topics. Time constraints limit our ability to go in depth.

• This program may mention Worker’s Comp and presenters may answer Worker’s Comp questions, but we do not have time to cover Worker’s Comp in depth.

• Some ideas suggested by presenters could raise other legal questions (e.g., HIPPA). Review all policies with your legal counsel.



Introduction to OSHA Requirements

Mark StrommeEditor - Workplace Safety

J. J. Keller & Associates, Inc.

Mark StrommeJ. J. Keller &

Associates, Inc.


AuthorityDOT, OSHA or both?• Trucking companies must comply with

OSHA regulations• 29 CFR 1910 General Industry regulations• 29 CFR 1904 Recordkeeping regulations• OSHA’s jurisdiction isn’t limitless • OSHA is prevented by Section 4(b)1 of the

OSH Act from enforcing its regulations if a working condition is regulated by another Federal agency



Associates, Inc.

OSHA’s General Duty Clause

General Duty Clause—Section 5(a)(1)— used by OSHA uses to cite when there isn’t a specific standard that applies to a situation:•Provide a place of employment free from recognized hazards•Comply with safety and health standards


Associates, Inc.


Hazardous Areas

• Warehouses• Terminals• Maintenance facilities


Associates, Inc.


What Can Trigger An Inspection?

1. Imminent danger

2. Accidents and fatalities

3. Employee complaints

4. Programmed inspections

5. Follow-up Inspections

Your DART rate can trigger a letter warning. The DART rate looks at days away from work, restricted work activity, or job transfer for every 100 full-time employees


Associates, Inc.


http://www.osha.gov/as/opa/foia/hot_11.html

When You MustCall OSHA

• You must report by telephone to OSHA within 8 hours if either of the following work-related incidents occur: There is a fatality Three or more employees are hospitalized as a result of a

single incident

• These injuries must also be recorded on your OSHA injury and illness records


Associates, Inc.


OSHA Inspections• Notice on arrival• Opening conference• Inspection tour—access to facilities/records• Closing conference—no proposed penalties

discussed• Citation letter sent by certified mail by OSHA area

director• OSHA has published a document describing your

rights after an inspection


Associates, Inc.


http://www.osha.gov/Publications/osha3000.pdf

Required Documentation

• The OSHA 300 log• OSHA 301 posting – 300A and “3165” • Employee chemical exposure • Hazard communication• OSHA offers a recordkeeping handbook• A tip on managing the OSHA Inspection:

Ask for list of documents requested at opening conference Bring documents to them


Associates, Inc.


http://www.osha.gov/recordkeeping/handbook/index.html

OSHA 300 Log Recordable Injuries and Illnesses

• Death • Days away from work• Restricted work or transfer to another job• Medical treatment beyond first aid• Loss of consciousness• Diagnosis of a “significant” injury/illness


Associates, Inc.


First Aid Exemptions

First aid—14 first aid exemptions1. Using non-prescription medications at

non-prescription strength

2. Administering tetanus immunizations

3. Cleaning, flushing, or soaking wounds on the skin surface

4. Using wound coverings

5. Using hot or cold therapy

6. Using any totally non-rigid means of support

7. Using temporary immobilization devices

8. Drilling a fingernail or toenail to relieve pressure, or draining fluids from blisters

9. Using eye patches


Associates, Inc.


First Aid Exemptions

First aid—14 first aid exemptions10. Using simple irrigation or a cotton swab to remove

foreign bodies not embedded in or adhered to the eye

11. Using irrigation, tweezers, cotton swab or other simple means to remove splinters or foreign material from areas other than the eye

12. Using finger guards

13. Using massages

14. Drinking fluids to relieve heat stress


Associates, Inc.


OSH State Plans• Four states with their own distinctive OSH

standards California Minnesota Oregon Washington


Associates, Inc.


OSH State PlansThe following states have approved State Plans:• Alaska • Arizona • California • Connecticut • Hawaii • Indiana • Iowa • Kentucky • Maryland • Michigan • Minnesota

NOTE: The Connecticut, New Jersey, New York and Virgin Islands plans cover public sector (State & local government) employment only.

• Nevada • New Jersey • New Mexico • New York • North Carolina • Oregon • Puerto Rico • South Carolina • Tennessee • Utah • Vermont

• Virgin Islands • Virginia • Washington • Wyoming



Associates, Inc.

Other Areas of Concern for Private Fleets

1904, Recording and reporting occupational injuries and illness• 1904.2, Log and summary of occupational injuries and illnesses• 1904.7, General recording criteria

General Industry (29 CFR 1910) 1910 Subpart D, Walking-working surfaces • 1910.23, Guarding floor and wall openings and holes

1910 Subpart H, Hazardous materials • 1910.106, Flammable and combustible liquids• 1910.120, Hazardous waste operation and emergency response

1910 Subpart J, General environmental controls• 1910.141, Sanitation• 1910.146, Permit-required confined spaces

1910 Subpart K, Medical and first aid• 1910.151, Medical services and first aid

1910 Subpart N, Materials handling and storage• 1910.176, Materials handling, general• 1910.177, Servicing multi-piece and single piece rim wheels

1910 Subpart R, Special Industries• 1910.272, Grain handling facilities



Associates, Inc.

http://www.osha.gov/pls/oshaweb/owastand.display_standard_group?p_toc_level=1&p_part_number=1904

http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9633




http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9715&p_text_version=FALSE














OSHA’s Top 10 Transportation Industry Citations

1. 1910.178, Powered industrial trucks

2. 1910.1200, Hazard communication

3. 1910.305, Wiring methods, components, and equipment for general use

4. 1910.37, Maintenance, safeguards, and operational features for exit routes

5. 1910.303, General requirements (electrical)

6. 1910.157, Portable fire extinguishers

7. 1910.132, General requirements (personal protective equipment)

8. 1910.23, Guarding floor and wall openings and holes

9. 1910.147, The control of hazardous energy (lockout/tagout)

10.1910.134, Respiratory protection



Associates, Inc.


Industry Best Practices

Tom Moore, CTP

Vice President of Education

National Private Truck Council

Tom MooreNational Private Truck Council


Why the Misunderstanding?

• Poorly understood regulations • Not my job • Heavy penalties



Total Number of Fatalities



Trucking accounts for a disproportionate

share

Costs of Injured Employees• Lost efficiency of injured employees• Impact on other employees• Cost of hiring and/or training replacements• Investigation time• Overtime• Extra supervisory time• Downtime• Legal fees• Negative public image• Damages to buildings, equipment and products• Customer service



A New Attitude• Compliance benefits• Reduced liability• Good business practices



Raising the BarShort Term

• Mock Audits• Include terminal/location managers• Work with employees to understand the

physical nature of the job• Communicate appropriately and effectively • Understand your exposure



Total Recordable Case Rate



Lost Workday Case Rate



Primary Injury Types



Primary Injuries



Raising the BarLong Term

• Be more selective in your hiring process

• Conduct job safety analyses and functional capacity testing

• Communicate around a common goal

• Recognize and reward accomplishments

• Encourage accountability

• Measure to improve understanding

• Implement operational changes

• Make equipment modifications



GNC Driver Safety Training

Bill HartmanManager of Private Fleet Operations

General Nutrition Centers


Bill Hartman General Nutrition

Centers

GNC Fleet Operations• Fleet consists of :

87 Class 8 Tractors 20 – 53’ Trailers 96 – 48’ Trailers w/ tailgates 5 – 36’ Trailers w/ tailgates

• 4,800 Locations• 85% of distribution is to

the floor.



Centers

GNC Corporate Safety

John Koch, CHMM, CFPS, CSPCorporate Safety ManagerGeneral Nutrition Centers


John Koch General Nutrition

Centers

Hierarchy of Compliance

1. Determine applicability

2. Eliminate the hazard

3. Engineer a solution

4. Personal Protective Equipment

5. Administrative Controls


Centers


GNC’s “Engineered”OSHA Solutions

• The Best Solution is to Eliminate the Hazard GNC does not transport any hazardous materials GNC’s products are exempt from the Hazard

Communications Standard GNC’s fleet is maintained by a vehicle leasing

company – GNC personnel do not perform maintenance



Centers

OSHA Compliance or Good Safety Practice?

• Why does injury recordkeeping matter?

• What benefits are there, besides avoiding a fine?

• What does the OSHA 300 reveal?


Centers


*As of May 27, 2009

Driver Injuries 2007-Present Types of Injuries



Centers



Centers

Obviously, we had a problem with trailer liftgates.

We had a sudden “cluster” of driver injuries

occurring during truck entry/exit.

*As of May 5, 2009

Driver Injuries 2007-Present Injury Causes

*As of May 5, 2009



Centers

Driver Injuries 2007-Present What Hurts?

Focusing on truck loading practices as a

result

40

Driver Study Results:Who Are We?

• The “Average” GNC Driver: 52.2 years old 10.7 years of experience Has had:

1.5 vehicular collisions0.47 injuries

Driven 696,583 miles



Centers

Driver Study Results:Who Are We?

2%

11%

31%

33%

18%

5%

Age Distribution of GNC Drivers - by Age Decade

20's

30's

40's

50's

60's

70's



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7%

47%35%

11%

Driver Age at Time of Injury - by Age Decade

30's

40's

50's

60's

Driver Study Results:When Do We Get Hurt?



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Note the absence of any 20-somethings or

70-somethings

Driver Study Results:Injury Count by Age



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0

1

2

3

4

5

6

33 38 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 58 59 60 61 62

Inju

ry C

ou

nt

Age

Driver Study Results: Years of Service When Injured



Centers

0

1

2

3

4

5

6

7

0 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40

Nu

mb

er o

f In

juri

es

Years of Service

Driver Study Results:Collisions vs. Age

0

2

4

6

8

10

12

25 28 31 34 37 40 43 46 49 52 55 58 61 64 67 70 73 76 79

Col

lisio

ns

Age (Years)

Non-Preventable Vehicular AccidentsPreventable Vehicular Accidents



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0

2

4

6

8

10

12

14

16

18

20

0 5 10 15 20 25 30 35 40

Col

lisio

ns

Years of Service

Non-Preventable Vehicular Collisions

Preventable Vehicular Collisions



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Driver Study Results: Collisions vs. Years of Service

Note : - 43% of all collisions

occur in the first 5 years of service

- 74% of all collisions occur in the first 10 years of service

GNC Driver Training• Corporate safety identifies key areas for

improvement through trend analysis• Training is developed collaboratively by

Corporate Safety and Fleet Manager• Training is presented at quarterly meetings• OBC Communications to coach drivers on individual

basis



Centers

GNC Driver Training: Falls

Simply jumping to the ground from a three (3) foot elevation will load your back (and knees and ankles) with a load that is greater than three times your body weight!


No!! – Don’t Jump!!!!Bill Hartman

General Nutrition Centers

Lessons from Isaac Newton…

…A brief word of caution for Drivers, Forklift and General Warehouse Workers

DON’T JUMP!DON’T JUMP!



Centers



GRAVITY OF THE SITUATIONGRAVITY OF THE SITUATIONNewton’s Laws of Motion1. A body in motion will stay in

motion or at rest unless acted upon by an unbalanced force

2. The force of an object is equal to its mass times its acceleration (F = MA)

3. For every action there is an equal and opposite…(what?)

What does this mean to me?



Centers


So what does this mean to me?• Have you every jumped from the back of a

trailer, off a dock, from your truck cab or off a forklift? How often?

• Jumping from heights increases risk of injury• Perhaps 10-15% of our injuries

Ankle and knee sprains Low back pain or strains High force on bones & joints Repetitive loading over time (micro-strains)

• Message is – Don’t Jump! • Here’s why


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Oh, to be young again….Jumping• Good when you’re young or an

athlete Repetitive impact increases bone

density…only to a point

• Not so good when you’re older Loss of bone density Weaker muscles, slower reaction time Increased risk of injury Especially when fatigued or out of shape


Centers


The shortest distance

between two points is a

straight line--typically

downward--where gravity

is our friend until the 1st

and 3rd Laws of Motion

come into play. The safest

distance though, might not

be a straight line, nor the

fastest way down.



Centers


Newton’s Laws

• Body in motion…

• For every action…

• F = Ma



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Mass

DistanceAcceleration

(Gravity)

Force(Ground

Reaction)

4 to 12 times your body weight!!!


Centers



The amount of force exerted on the back of a 200 pound driver when (s)he jumps from:

3' 3

"

1' 5

"

4'

13' 6

"

• 1 Foot = 346 Pounds• 3 Feet = 727 Pounds• 4 Feet = 917 Pounds

• 6 Feet = 1,298 Pounds• 13 Feet 6 Inches = 2,725 Pounds

Source: Don't Jump - The potential effects of jumping from heights - by William M. Montante, CSP - Professional Safety, July 2008F=((0.6 X Weight) (9.81 m/s^2) (1 + (jump height/0.25 m))) X 130 % X 0.2248 = Resulting Force on Body in Pounds


Centers

LaddersSteps &Handholds

3PointContact


GNC Driver Training: Falls3-Point Contact at ALL Times!

• Always FACE the truck while getting in and out. This increases your control.

• Keep three limbs (one hand and two feet or two hands and one foot) in contact with the handholds or the steps.

• Put your paperwork on the seat! Reach for it from the ground.

• Your feet work best faced forward!• Remember – “Slippery When Wet”• Ice is even slipperier than water!


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LaddersSteps &Handholds

3PointContact



Question & Answer

Please submit questions to “Q&A”

using the Q&A tool





Associates, Inc.


Centers


Centers

Closing Remarks• Checkout the archive of past topics at:

http://www.jjkeller.com/nptcinfo PowerPoint slides up in 1-2 days Recording up in 1 week

• Topics for 2009: October 21 – Accident Management: A Nuts and Bolts

Approach



osha compliance for private fleets this webcast will cover... introduction to osha requirements,...

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