For me the surprise was what standard people thought OSHA should work on next, the results are below.
Silica | 6 (5%) | |
Ergonomics | 5 (4%) | |
Diacetyl | 32 (29%) | |
Combustable dust | 11 (10%) | |
PELs | 15 (13%) | |
Confined Space in Construction | 12 (11%) | |
Safety & Health Program | 28 (25%) |
Diacetyl? Really? I understand how bad popcorn lung is, but more people die every year from silicosis, or confined spaces in construction, or long term exposure to chemicals because of out dated PELs, than from diacetyl. Besides, if we had a S&H program requirement companies would be required to address this anyway.
For those who voted for diacetyl, leave a comment, I would like to know what your thoughts are.
If you have any ideas for another poll, leave a comment. And thanks to everyone who voted, that was the first poll with over 100 votes.
I suspect that diacetyl is the IH topic du jour, with the accompanying attention. My vote goes to Safety & Health Program. Hands down, we'd get more bang for our buck if we had a written program requirement that included training, communication, inspections, and responsible person like California's IIPP regulation, T8 CCR Section 3203.
ReplyDeleteHate to not directly answer the question, but when does that ever happen on this blog?
T8 is the standard to shoot for. The key difference in T8 is the word "effective". It is nice that a citation is written for not having an EFFECTIVE written program, as opposed to simply not having a written program. A lot of consultants can write a program, but implementing is a whole different ballgame.
ReplyDeleteI think you are a victim of "Vote for the worst Idol" in the poll.
ReplyDeleteSomeone who wanted diacetyl got others to sign on and vote. It was lagging way behind before that. It is a serious hazard. Questionable whether there is sufficient information to establish a PEL. S & H program standard would have more impact--and allow some coverage of things like ergo.
ReplyDeleteHow about a poll on IMIS coding on OSHA 1's? Does anyone besides me think there are far too many codes? Is there a way to get the number of codes down to a manageable and meaningful level? How confident are CSHO's in the accuracy of the data that management is now gaining from the system?
ReplyDeleteEveryone thinks there are too many IMIS codes, the poll results would look like this:
ReplyDelete108 - Too Many Codes
2 - Just the Right Number
0 - Not Enough
And the two people who voted for "Just the Right Number" would be contrarians.
I have no confidence in my coding, I can't keep up with them.
In my business, Comdust is the most critical element needing work by OSHA, along with safeguarding, hotwork, lockout-tagout, and housekeeping.
ReplyDelete-Jeff Nichols http://industrialfireprevention.blogspot.com/
Hmmm. OSHA has the resources to send all its Compliance Officers and Consultants out to address Diacetyl -- the Hazardous Chemical of the year! Get real! OSHA has snail's disease (terminal bradykinesia) on promugating new standards and enforcing them. New -updated PELs based on the most current scientific data are sorely needed, and have been for over 30 years. Many of the other categories can be subsumed under a valid S & H program, that includes appropriate hazard assessment, evaluation, and control. In Construction, silica exposure and noise exposure has not been adequately addressed by enforcement Industrial Hygienists. Confined Space is still an issue, and must be addressed when evaluating either a Construction or General industry S & H Program. Too many numbers (inspections and visits) not enough quality addressing the salient hazards at hand. Shame on OSHA! Not CSHOs, but administration that rewards numbers "numbers game" and not real S & H inspections and Consultation Visits.
ReplyDeleteI call bullshit on OSHA and the Assistant Secretary of Labor -- nope I did not say lair did I. I am sick of all you pretenders. I would like to have an open question and answer session with the so called superiors, State Plan State Directors, Federal OSHA Director of Standards and Enforcement. Please, explain to me how Tenn. can take on DOE Labs and Radiation Safety for Particle Accelerators, Industrial Radiography, Nuclear Medicine, Radio-pharmacy, PET, X-ray, Fluorescent Imaging, CT Scans, Cargo Screening with Z-back-scatter etc., X-ray Diffraction etc (open beam) OSHA is not competent in this area. Now, lets throw in fissile material! Get the drift. OSHA is not qualified by training or experience. What a crock! When is 1910.1096 going to be updated so that it is compatible with the Doe and NRC Radiation Standards. The NRC has changed its Medical Radiation Standards to keep up with advancing technologies and techniques. OSHA is in the Dark ages in this regard. Why am I posting this? Because if OSHA presumes to be qualified in the world of radiation safety, then lets see 1910.1096 be updated so that it is commensurate with current scientific knowledge and good radiation practices predicated on the ALARA Concept. The performance of the OSHA Teams assigned to the Congressionally mandated Audits of the DOE Labs was laughable in that qualified OSHA Radiation Professionals were sidelined and over-ridden by Private Contractors, who also made twice the pay. (sounds like Iran eh) Real radioactive source material security issues were swept under the carpet at Brookhaven National Lab. and Criticality issues were not addressed, but over ridden by the Pacific North West National Lab Safety Personnel, who succeeded in intimidating OSHA officials due to their naivete. In effect, Highly trained OSHA Health Physicists were relegated to the status of technicians with their hands tied behind their backs. They were not allowed to use their calibrated radiation detectors for the audit safety surveys. Folks who hand waved were rewarded, and those that performed their jobs by adhering to high professional standards of excellence and ethics in radiation safety were side-lined and eventually terminated. Now that we must seriously entertain the including nuclear energy in a balanced and rational energy plan, OSHA and the NRC must coordinate their efforts. MOA are great, but the appropriate division of labor in terms of over-sight must transcend egos, and be predicated on knowledge,training, and experience. Currently, who is overseeing the Cargo Screening that involves radiation exposures at our ports and airports. The TSA folks are so full of themselves that they refuse to give OSHA training records for cargo and baggage screeners. The Bush-Cheney arrogance is still alive and well whereby these federal agencies related that have role in Home Land Security (HLS) think they are above accountability. Now OSHA, get real - prioritize according to realistic hazard evaluations and agency expertise. IF the agency is not quailifed, then either hire and/or train current employees for the wave of the future, or defer to the NRC etc.
ReplyDeleteRegards,
With too many Cooks in the Kitchen don't stumble on the Kickers that split your beam before striking the dump in that rastered pattern with the hopes of discovering the
pentaquark.
Regards,
Cosmic Cowboy
OK OK You got us. OSHA is a joke! You found us out. It was fun while it lasted. It's politics not technical competence, but you already know that. Psssst, don't tell anyone else though so we can stay in business!
ReplyDeleteWow! I know what you mean. PNNL fractionates everything partly due to the Union. They really are full of themselves. I have a friend who participated in the 2003-2004 audits. They would not allow them to use his Ludlum Survey Meter claiming that the check source in the particular bldg and room where OSHA was stationed did not permit it. You guessed it, this was the only room where allegedly an exempt check source (uCi quanity) was not allowed on the entire Lab grounds and facilities. A really damned if you do and damned if you don't in that the check source was required to conduct the daily (before use) operational check of the instrument. If the OSHA Health Physicist had not brought and used the source to check their instrument, they would have been faulted. By the way, they did not want the HP to conduct any further radiation surveys because they discovered discovered that Cesium - 137 (Gamma emitter) was stored in such a way that non-radiation users were being exposed, who where not monitored with film or TLD badges. OSHA was intimidated by the Lab officials and did not want to ruffle any feathers. In addition, the Lab was found to in violation of several OSHA Safety and Health Standards. There were issues related to criticality due the geometries involved in the storage of fissile material, as well as the gloves for the glove boxes not being tested for holes. HF was being used with expired Calcium Gluconate, which is extremely hazardous. The number of electrical hazards was very high as well. Now, we really don't want to get into the contamination of the river and ground water do we.
ReplyDeleteGamma-man
PS -- AUM... The sound that all the electrons make while madly flying around the Nuclei of Atoms- Joseph Campbell
ReplyDeleteOk, I give up, Plutonium vs Diacetyl! Both explode and both are of mythic character -- Pueblo Indians -- in the beginning there was Popcorn!
ReplyDeleteO'Shaman
Transmute OSHA - AHSO - and there is symmetry at the quantum level eh.
ReplyDeleteNeo
OSHA needs to transform its paradigm!
ReplyDeleteThe Alchemist
Anonymous said...
ReplyDelete"OK OK You got us. OSHA is a joke! You found us out. It was fun while it lasted. It's politics not technical competence, but you already know that. Psssst, don't tell anyone else though so we can stay in business!"
You said OSHA is a joke -- your words -not mine! OSHA is not joke, simply needs new blood! Needs new Vision, Direction, and Leadership! OSHA has a sacred duty!
Batman
So- Anonymous - what serious hazard did you neglect to address because of your arrogance and complacency. You know, the same kind of tunnel vision or indifference that you judge employers to possess.
ReplyDeleteLawman
I wonder what the unions and their cronies Barab and Solis will say when their policies increase fatality counts instead of decreasing them. Using their logic, I guess that would make THEM accomplices to murder...? Sadly, a little more than 5000 died while on the job. Lets see what that number is in 2010, 2011, and 2012. My bet ---- higher if they continue down this path.
ReplyDeleteI just deleted a comment, it was a political statement and had next to nothing to do with safety and health. Please, this is not a political forum, at least not beyond who politics impact OSHA and S&H. The last comment is borderline.
ReplyDeleteI have a few comments on some of the comments, but that has to wait.
It is unfortunate that "Our" President was attacked on political grounds for calling for unification in service to our fellow human beings during his speech on this "day of infamy. In relation to this, I would like to clarify that my previous post should not be interpreted to mean that OSHA is Joke. It should be recognized that the dedication and moral stance of the majority OSHA Compliance Officers and OSHA Consultants in their striving for consistency in service with respect to protecting the nations employees has been par excellence. Whether they be here legally or illegally, the assumption is that all lives of of infinite worth, and therefore it follows that every worker deserves a safe and healthful workplace. Hence, to call bullshit on a long history of misguided leadership and counterproductive policies is not meant to diminish or to denigrate the sacred duty of our organization, belittle our efforts, nor to ignore the day to day (in the trenches) commitment of our staff and employees with respect to ensuring the very best service to the nations workers and employers. A heart felt thanks to our OSHA Family for their undying and unwavering faith and/or belief that we are knights of infinite faith that will never truly know the full impact or results of our work, but nevertheless, we keep on keepin' on! This being said, I do not relish the belt-way bandits (Private Consulting Firms) making such cancerous in roads into our organization to fill in the gaps of our knowledge and expertise. Why you ask? Because the knowledge assets of our organization become reduced, and therefore, we have private Firms and their employees performing the services without the philosophical and moral framework of OSHA. Further, it makes us dependent on outside resources, since we fail to develop the expertise in house and/or fail to retain it. It also cheats tax payers, since the private consultants make twice what their OSHA counterparts make, and this comes out of tax dollars. What have others experienced in this regard? What should our focus be to improve our service? My experience was that private consultants competed with the OSHA personnel and seized every opportunity to make them look bad in order to justify their existence. The OHSA Managerial Staff were all too willing to relinquish control due to their insecurity borne of lack of experience.
ReplyDeleteCosmic Cowboy
Hi Cowboy. I agree, and have observed similar things related to "Belt-way" Bandits. Just look at how the private contractors conducted them selves in Iraq, and the differential in pay they received compared to our Military Service Personnel combat pay structure. I have a friend that was seriously maligned by a so called contracted professional because the contracted employee was "shaking down" DOE employees during one of the Congressionally mandated audits, and the OSHA CSHO gently admonished them not to continue this kind of behavior. In essence, the contracted employee was on the verge of calling the employee's "liars". It is interesting to note that the contracted individual had previously been fired from the DOE, and by their own admission, could not get along with others. The Irony is that this contracted employee was a consummate manipulator, and got the OSHA CSHO fired. The CSHO went onto to win the admiration an respect of not only his next employer, their colleagues, and within the Safety and health Community. In addition, this individual had several years of experience as an effective professional inspector, and was noted for their humanity and person-ability. This goes to show you how micro-politics and manipulation of others influences our organization. This not an example of "OSHA eating its own", but of OSHA allowing misfits outside the agency to exert a negative influence on our agency by maligning dedicated professionals.
ReplyDeleteKanabal
Response to: "This not an example of "OSHA eating its own", but of OSHA allowing misfits outside the agency to exert a negative influence on our agency by maligning dedicated professionals".
ReplyDeleteKanabal
I like the play on your moniker Kanabal and the line or observation about: "OSHA eating its own"
I have observed OSHA cannibalizing itself, and have developed the following hypothesis: CSHOs cannot turn off their discerning eyes and minds, which are calibrated to detect bullshit and insincerity when they see or here it. Thus, we are very critical of our own, as well as a bit competitive because of the "numbers game". The only empowerment we can find solace in is our ability to generate a high number of inspections and interventions (emphasis on inspections, since many OSHA Regions do not value interventions), as well as our ability to master the standards in certain areas so we can claim more than core competence. (knowledge is power) This fine, but it is not always for the purpose of doing an excellent job, but at times the underpinning is to have power some place and some way. That is OK too, when tempered. By the way, it was intimated in a previous post that we should not "wake up the fool", but my position is that on some level we are all fools or one kind or another, which is a manifestation of both our individual and collective "shadow(s)". We are in this together! What say you? Should we unite, or stand alone like straw-men/women in the wind?
O'Shaman
O'Shaman & Kanabal. You don't have to answer this, but I suspect that you both work in the National Office. If you are who I think you are, your open mindedness is applaudable. Nevertheless, I am not convinced that either of you can walk the walk. Its not your fault, since you do have your bosses to answer to. We must upgrade our PELs in order to be compatible with current scientific data, as well as the NFPA, NEC, ISO, NRC, DOE, ANSI, ASHRAE, ASME, etc. The Directorate of Standards must be more action oriented and progressive, which is going to require overcoming bureaucratic Inertia and politics. In addition, the with-holding of information that I observed in the National Office for the purpose of securing personal power (Ace up the sleeve one-upmanship etc) needs to stop. What do I mean? For example, my friend was directed to duplicate in one day a Gap analysis of the difference between the NRC, DOE, and OSHA Radiation Standards/Regulations in one day that took several months and thousands of dollars for a private contractor to conduct. (Talk about games and waste of resources). My friend found this out during a meeting related to updating 1910.1096 - 0.75 decades ago, which still hasn't been accomplished. A shining example of molasses moving in January? (hmm fast or slow) The 911 event should have been instructive about the sharing of information that is vital to National Security, worker safety, and Emergency Responders. Both intra-agency and inter-agency cooperation and coordination should not only have been underscored, but should be SOP by now, but it isn't. Why? Turf Wars and politics. In my opinion, all of the agencies have good intentions and very talented people, so... We met at the Forestall{(sp) but good pun, eh} Building, and outlined our individual agency assets did we not. Where are we now? By the way, did we ever include the Native American Nation and Tribes in the National Emergency Response Plan? I recommended this, but then again, I don't believe that the plumes from Dirty Bombs (radiological) or Chemical releases respect or obey ethnic-geo-political boundaries. By the way, some of the salient issues that are imperative to good practice in Emergency Response are the following: A plan, Recognizing and Respecting jurisdictional authority, Training on the implementation of "the Plan", interoperability of instruments, unification with respect to radiological units (old vs new international SI units:(RAD & REMS Vs GRAYS & SIEVERTS). It would really benefit OSHA if they learned to use calibrated instruments, since the NRC and DOE will laugh and mock you if you don't. I distinctly remember being told that this was not the case. I have since collaborated this, so the Folks involved with Emergency Response at OSHA like the HRT and SRT should ensure that their instruments are calibrated and in conformance with industry standards, manufacturers recommendations, or OSHA standards. NO MORE HYPOCRISY eh. for example, the HRT is not part of enforcement, but their instruments should be calibrated and the level of training would be assumed to be higher for them, as opposed to someone where it is not incumbent to respond to Emergencies, Catastrophes, and industrial accidents. How many of the Ionizing Radiation, Non-ionizing Radiation, and basic Industrial Hygiene Instruments (assets) do they have that are not currently in calibration? Is Federal OSHA Above the Law and good industry practice. This points to the need for more oversight and implementation of professional standards, which requires more training within the agency, does it not. Square the Circle!
ReplyDeletePi Engineer
Pi -- today is 911 - and you surely dropped an intellectual and professional bomb on those that are not forthright and conscientious in the agency or within the safety and health profession. Good show mate. These yanks can learn from us,eh.
ReplyDeleteDoggie Doray
Cosmic Cowboy, Pi Engineer, and Doggy, your responses indicate that you have a great deal of fist hand knowledge about the workings of the agency on a multitude of levels. Where do we go from here?
ReplyDeleteHitch-hiker
Hi Hitch-Hiker. I will let my illustrious colleagues address this, since my opinions would be too passionate and long winded, even for a retired "fool". I still care about the fate of the agency and the accomplishment of "mission"!
ReplyDeleteRetired and you still care about OSHA? What is that about?
ReplyDeleteYep! You can take the CSHO out of OSHA, but not the OSHA out of the retired CSHO -- it is in our blood!
ReplyDeleteLMS
For those who think our precious and limited resources should be allocated to diacetyl, please indicate how many workers are potentially affected based on the SIC - NAICS and other industry data to warrant a whopping 29% vote. How long have you been with the agency and how much IH experience do you have. Have you considered the epidemiology of popcorn lung disease? Please edify us about why you think this should supersede updating our PELs in general.
ReplyDeletePi Engineer
I think a little help in this area may be warranted -- oftentimes, there is a lag-time with respect to long term chronic exposure and employees presenting with symptoms of disease when it comes to chemical exposures. However, I don't know much about diacetyl with respect to the acute and chronic effects. Someone please help us understand this more fully.
ReplyDeleteCoyote
Well, there does seem to be a dichotomy between macroscopic physical effects and acute and chronic physiological and genetic effects,eh.
ReplyDeleteThe PELS apply to the health effects, which can be impacted by updating both the PELS and an emphasis on S & H Programs. The S & H Programs has an impact on both S & H. Silica and Diacetyl are related to PELS and S & H Programs. As a matter of fact, all of the hazards mentioned can be controlled by a combination of updating PELS and placing an emphasis on required OSHA programs, i.e., they can be subsumed under these general rubrics, eh.
Doggie Doray
Wow! I voted for popcorn and got Nuclear Physics. My head is spinning!(Where did I put my nuclear physics dictionary so I can try to follow this thread?). You guys are a lot smarter than my OSHA bosses. But, if you guys are so smart in the OSHA National Office, why does the OSHA program do such DUMB policy things? (I know it is always "politics"). I am not a dummy myself but OSHA as a program is totally clueless(OSHA does not focus on REAL RESULTS but uses phoney numbers of process only) and I do know some big fixes because I have higher level management experience but I would not go into OSHA management for anything because they as an organization are hopeless. There is so much broken or bogus assumptions that are not reality based that one would not know where to begin. Since I have business experience(decades worth as a manager and a business owner-yes I know what it is like to meet a payroll and I doubt you whiz bang nuclear physics guys have done that) I believe that a Capitalism approach(even with some unavoidable corruption) can do a far far better job of lowering death and injury in the workplace.You just gotta know how to apply the power of positive motivation and miracles happen in results. Government(i.e. Socialist approach of OSHA in its current form has a lock on failure and always will). That's my opinion based on O&E (Observation & Experience). Trying to fix OSHA in its current form is equivalent to banging your head against the wall to fix a headache. It ain't gonna ever ever ever (yes 3 times) work! Oh yes, I've studied logic circuits and formal problem solving and OSHA is a tangled web of total nonsense.(Studied some nuclear physics too!Worked on some MIRV nuclear missles in my time also)
ReplyDeleteDoggie, I believe your position was articulated eloquently in another post, but we are getting some focus are we not on where we should be directing our attention. Hey, Abel, please weigh in on this.
ReplyDeleteCheers,
Gamma Man
Good Night OSHANAUTS -- we will make it to the celestial planet of safety and health for everyone! See y'all in the Dreamtime.
ReplyDeleteSoooo many comments, not all related to this tread.
ReplyDeleteCosmic Cowboy and Gamma-man went nuclear on us;
The Alchemist used a buzzword but didn't tell us how to change;
Batman thinks us old farts are in the way;
Anonymous #9 (I think) thinks injury and fatalities will go up (a future topic for me);
Cosmic Cowboy had to do some spin control and then pointed out some problems with contracting out;
Shaman asks if we should unite, and I say yes (although I doubt we will);
Pi Engineer talked about ionizing radiation and my eyes glazed over;
Hitch-hiker asked a great question: "Where do we go from here?";
Anonymous X is retired and I'm jealous;
Pi Engineer and Coyote asked the same question I did: "Why diacetyl?" and still no response from those who voted for it;
Anonymous XXX got awfully close to being deleted for getting into a capitalism vs socialism debate, but still didn't answer one of my very first questions: "If you want to be results oriented, how do we measure REAL RESULTS?";
And finally, Gamma Man is right the focus has been lost on this thread (my fault, I've been too busy to respond to the comments).
This is why I tried to create the forum, which apparently is a failure (see my comment there).
The question for this thread is which standards should OSHA work on and why. I guessing Cosmic Cowboy thinks ionizing radiation.
Abel -Abel -Abel- you are being way to self critical! This thread was really most refreshing! We need to look at other dimensions of safety and health. Radiation Safety is exciting!!!
ReplyDeleteI agree that we need to look at other dimensions of S&H, just not here on the back pages. We need a better place.
ReplyDeleteCowboy, I think you meant MOU memorandum of Understanding and not MOA.
ReplyDeleteRegards,
Gamma Man
This was interesting.
ReplyDeleteI just wanted to applaud Abel in the original post for questioning the results of the poll in context of a cost benefit approach to priority.
And to everyone else in here bickering....
YOU WONDER WHY SOME OF US BUSINESSES DON'T KNOW EXACTLY WHAT'S GOING ON AND THEN YOU HAVE THE GUTS TO PASS OUT WILLFUL CITATIONS FOR SOME OF THIS STUFF.
YOU EXPECT US TO BE ON TOP IF THIS?
GET IT TOGETHER!
"Why diacetyl?"
ReplyDeletebecause it IS all about the buzz.
insert more integrity here ________________ .