​The ETS generally applies to all employers that are under OSHA’s authority and jurisdiction and currently have more than 100 employees firm-wide/corporate-wide. Employers who are exempt from this standard include:

• Employers with less than 100 employees
• Employers covered under the Safer Federal Workforce Task Force COVID-19 Workplace Safety
• Healthcare services and support services subject to the Healthcare ETS (29 CFR 1910.502)
• Employee exemptions including:
  • Employees who do not report to a workplace (work from home)
  • Employees who work exclusively outdoors

​For those employers who are not exempt from the ETS, a policy regarding vaccination or testing will be required.

For employers who decide to enforce a mandatory COVID-19 vaccination policy, they will be required to:

• Determine the vaccination status of each employee
• Obtain proof of vaccination and maintain a record and roster of each employee’s vaccination status
• For employees who have yet to be vaccinated:
  • Support vaccination by providing reasonable time (up to four hours paid) to receive each vaccination
  • Provide reasonable time and paid sick leave to recover from side effects

 
For employers who permit non-vaccinated employees to work, they will be required to:

• Adhere to the policies set forth above (for those who wish to be vaccinated)
• Require weekly testing or within the last 7-days before returning to work
• Require employees to wear face coverings when indoors or when occupying vehicles with others

​When implementing either policy, employers will be required to:

• Require employees to promptly provide notice of a positive COVID-19 test or diagnosis (regardless of vaccination status)
• Immediately remove employee from the workplace and keep them removed until proper criteria are met for return

​Benjamin Franklin very accurately stated that “if you fail to plan, you plan to fail.” Emergency Action Planning is planning not to fail in the event of an emergency evacuation, severe weather event, fire, or other emergency. A great Emergency Action Plan (EAP) will reduce confusion, result in fewer and less severe injuries, and produce less damage if executed effectively. OSHA requires that every employer have an EAP for each workplace. To successfully develop an EAP, a workplace assessment should be done to identify all potential and likely threats and emergencies at your workplace.

​The purpose of an EAP is to facilitate and organize employer and employee actions during workplace emergencies. The written plan shall be kept at the workplace and made available for employee review. The EAP plan should cover at a minimum:

• A preferred method for reporting fires and other emergencies
• An evacuation policy and procedure
• Emergency escape procedures and route assignments (maps and visuals are most effective here)
• Names, titles, departments, and telephone numbers of individuals both within and outside your company
• Procedures for employees who remain to perform or shut down critical plant operations, operate fire extinguishers, or perform other essential services
• Rescue and medical duties for any workers designated to perform them

 
Upon initial assignment, the employer must review the plan with each employee. The most common method is during an employee orientation. As conditions or roles change the employer is required to review the EAP and determine if responsibilities, or requirements need to change as well. It is best practice to also review annually to make sure something was not missed throughout the year.

Before implementing the EAP, the employer is responsible for designating and training a sufficient number of employees to assist in the safe and orderly emergency evacuation of employees. Examples of employee roles in an emergency evacuation could include: fire brigade, medical team, emergency action coordinator, chemical response team, etc. Reasons for evacuation could include: fire, severe weather, acts of violence, chemical spills, or civil disturbance. The employer shall designate what signal will be used to warn employees and to designate rally points throughout the jobsite. Likewise, employees are responsible to know their role and all tasks associated with that role. When the EAP signal has been given (horn, strobe light, siren, etc.) employees must calmly proceed to the rally point or evacuate quickly. 

Good Emergency Action Plans will have an associated Fire Prevention Plan, but great EAPs will also have detailed plans for explosions, toxic releases, civil disturbances, and workplace violence. Depending on where in the country you may be located, plans for additional natural disasters like floods, earthquakes, hurricanes, tornados, wildfires, and winter weather should be considered.

For more information on EAPs, OSHA standards can be found in CFR 1926.35(e) alongside a designated page for EAPs and different situations (https://www.osha.gov/emergency-preparedness). To keep the conversation going, download the Emergency Action Plan Toolbox Talk (TBT) or comment below.

​When it comes to employer Health & Safety Plans, the minimum requirements for an accident prevention program should include inspections of the workplace for potential hazards, training and evaluation of employees for tools and equipment on the job, and personal protective equipment (PPE) training and use practices. While these three components are important, many safety and health managers will agree that there are additional elements that should be included. Here are STAC’s six elements to a proper Health & Safety Plan:
 
Leadership Involvement
An effective prevention program must start from the top. With C-Suite and managing directors actively participating, tracking, and committing time and resources to your plan, this will leave a lasting impression for all employees involved and help reinforce positive behaviors mirrored in your plan. Studies have shown that management involvement in your program have a direct impact on reducing your DART and TRIR rates.
 
Worker Participation
Once management has helped create and implement the safety plan, it is up to the employees to participate in processes to help identify workplace hazards. Types of employee participation can include:

• Accident, Illness, Injury, and Near-Miss tracking and investigations
• Hazard Monitoring and Employee Exposure Reports
• Creating a Process to plan, evaluate, and implement Hazard Controls
• Conduct Workplace Inspections and Investigations
• Conduct Surveys of Work-Related Health Problems
• Make Recommendations for Workplace Improvement (ex. Stop Work)

 
Hazard Identification & Assessment
With employees actively participating in identifying workplace hazards, an assessment can be made with a Job Hazard Analysis to help identify ways to prevent and control the hazards. An example of a Job Hazard Analysis can be found here: OSHA JHA Sample Form
 
Hazard Prevention & Control
Once hazards are identified, employers can look to eliminate or control the hazards using OSHA’s Hierarchy of Controls:

• Eliminate Hazard – the most effective and efficient way to control hazards, but can be the most difficult to implement
• Substitute Hazard – if designing a process, substitute hazards out by changing equipment or changing procedures
• Engineering Controls – eliminate the hazard at its source by removing the hazardous condition with equipment/tools or by placing a barrier between the hazard and the employee
• Administrative Controls – while less effective than the controls above, administrative controls can include changes in work policies, schedules, or rules to help reduce the exposure to hazards
• PPE – the last type of control aimed at directly protecting the worker from hazards

 
Education & Training
Providing employees with the proper education about the workplace hazards and specific training on how to prevent, eliminate, and control these hazards are pivotal to keeping employees safe. Education can include orientation, safety manuals, and SDS sheets for the different chemicals and materials they will be handling. Workplace specific training should be done by a qualified employee and be given to those who operate equipment and machinery for their job.
 
Program Evaluation
The final element in the program is to evaluate how well your plan eliminates, prevents, and controls hazards. Different types of evaluations can include:

• Workplace Inspections and Training – frequent inspections of the jobsite, materials, and equipment from competent employees can help identify hazards not being controlled by the program
• Measurements and Tests of Worker Exposure – monitoring the health of your employees will identify if acceptable levels of hazards are found in your workplace
• Record Accidents, Illnesses, Injuries, and Near Misses – recording all types of incidents will help you review where and how employees are getting hurt to identify any changes that need to be made
• Record Hazard Identification and Removal/Control of Hazards – keeping a record of the hazards eliminated will help you see if any hazards continue to persist after controls have been implemented
• Compliance with Federal and State Law – staying compliant helps reduce the risk of OSHA inspections, fines, and shutdowns.

 
While Health & Safety Plans can have many different elements, the goal of all plans are to help keep employees safe and reduce the risk of injuries in your workplace. Remember, safety is everyone’s responsibility. To keep the conversation going, download the Health & Safety Plan Toolbox Talk (TBT) below or click on the QR code to see how STAC can be part of your plan.

Training in the construction industry is a LEADING INDICATOR AND PREVENTION OF INJURY AND DEATH IN THE WORKPLACE. Not only is proper training good practice, it is also one of OHSA’s most common citations. Proper training and the documentation of that training can save thousands of dollars in fees, lost time and insurance claims.
OSHA requires recordkeeping in two areas; Injuries & Illnesses and Safety Training.
 
Injury & Illness Reporting Requirements
OSHA requires construction employers with 10 and more employees to keep a record of serious work-related injuries and illnesses.

What is considered a recordable injury?

• Any work-related fatality
• Any work-related severe injury
• Any work-related injury or illness that results in loss of consciousness, days away from work, restricted work, or transfer to another job
• Any work-related diagnosed case of cancer, chronic irreversible diseases, fractured or cracked bones or teeth, and punctured eardrums
• There are also special recording criteria for work-related cases involving: needlesticks and sharps injuries; medical removal; hearing loss; and tuberculosis
• Any work-related injury or illness requiring medical treatment beyond first aid

 
What is considered First Aid?

• Using a non-prescription medication at non-prescription strength
• Administering tetanus immunizations
• Cleaning, flushing or soaking wounds on the surface of the skin
• Using wound coverings such as bandages, Band-Aids™, gauze pads, etc.
• Using hot or cold therapy
• Using any non-rigid means of support, such as elastic bandages, wraps, non-rigid back belts, etc. that does not immobilize the injured area
• Using temporary immobilization devices while transporting an accident victim
• Drilling of a fingernail or toenail to relieve pressure, or draining fluid from a blister
• Using eye patches
• Removing foreign bodies from the eye using only irrigation or a cotton swab
• Removing splinters or foreign material from areas other than the eye by irrigation, tweezers, cotton swabs or other simple means
• Using finger guards
• Using massages
• Drinking fluids for relief of heat stress

 
What does OSHA consider a severe injury?
A severe injury includes a fatality, amputation, loss of eye, or hospitalization (formal admission to hospital for treatment). In the case of a fatality, OSHA must be notified within (8) hours of the incident. In the cases of amputation, loss of eye, or hospitalization, OSHA must be notified within (24) hours of the incident.
 
How do you record these injuries and illnesses?

• OSHA 300 Form – Log of Work-Related Injuries & Illnesses
• OSHA 300A Form – Summary of Work-Related Injuries & Illnesses
• OSHA 301 Form – Injury & Illness Incident Report

Construction is considered a high hazard industry by OSHA therefore companies with 10 or more employees are required to maintain the forms listed above. The OSHA 300, 300A and 301 forms must be updated each year and posted by location. OSHA requires these forms to be kept for a minimum of (5) years after their expiration.

​*A recent update (2/25/2019) now does not require companies with more than 250 employees to electronically submit their OSHA 300/301 forms. They are still required to maintain these records each year and continue posting by location.
 

​Training Reporting Requirements (29 CFR 1910/1926)
It is the employer’s responsibility to initiate and maintain programs for accident prevention.
Training is both task and hazard specific. Below is an example of when training is required:

• Prior to beginning work (orientation) to recognize unsafe conditions, hazards, and potential injuries/illnesses
• Prior to operating machinery
• Prior to handling hazardous materials and/or flammable liquids
• Working within a confined space

​How often in training required?
OSHA requires that some trainings be repeated after a certain period of time. Below are several of those trainings. 

Here is a complete list of Training Standards
 
When are refresher trainings required?
Refresher trainings are required to reiterate the most important aspects of a training and also to incorporate any changes made pertaining to the specific topic. Refresher trainings should be implemented when one of the following instances occur:

• Post-Accident or Injury
• When an employee is observed using equipment improperly
• Upon failing an annual equipment evaluation
• When new equipment is implemented
• When workplace conditions change

Companies can also provide their own refresher requirements as long as they meet or exceed OSHA standards.
 
What kind of information should be recorded for training?
Training documentation should include:

• Name/Signature of trainer
• Trainee Name
• Date of training
• Subject of training
• Proof of competency (written exam or practical evaluation)
• Date of evaluation

OSHA requires these documents be available to employees upon request.
 
The best ways to keep your employees safe in the workplace is to provide them with the proper tools and training to get the job done correctly without putting them in danger. STAC emphasizes this by assisting in recording injuries & illnesses and tracking your employee safety trainings and certifications. By having real-time access to these important records, you can have the peace of mind knowing your employees have been given the proper training that is up to date with current standards.
 
Additional Resources:
PART 1904 - RECORDING AND REPORTING OCCUPATIONAL INJURIES AND ILLNESSES
PART 1926 - SAFETY AND HEALTH REGULATIONS FOR CONSTRUCTION
Training Requirements in OSHA Standards

​HEAT STROKE
Heat stroke is a medical emergency. You can die from it. Your body has used up all its water and salt and cannot cool itself. Your temperature rises to dangerous levels.
Symptoms:

• confusion and irrational behavior
• convulsions
• unconsciousness
• no sweating—hot, dry skin
• high body temperature—104°F or more.

Treatment

• Call the local emergency number or get the worker to a hospital.
• Take aggressive steps to cool the worker down (immerse in a tub of cool water or cool shower, spray with a hose, wrap in cool, wet sheets and fan rapidly).

If the worker is unconscious, don’t give anything to drink.

CONTROLS:
Here’s how to avoid heat stress in the first place:

• Wear light, loose clothing that allows sweat to evaporate. Light-colored garments absorb less heat.
• Drink small amounts of water (8 oz) every half hour. Don’t wait until you’re thirsty.
• Avoid coffee, tea, beer, or other drinks that make you go to the bathroom frequently.
• Avoid eating hot, heavy meals that increase your body temperature.

Remember that your physical condition can reduce your ability to deal with the heat. Age, weight, fitness, health conditions (heart disease or high blood pressure), recent illness, or medications can all affect your ability to withstand high temperatures.