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Learn How to Handle Chemical Spills Safely - December 2017
Working with chemicals on the manufacturing floor puts all
employees at serious risk for injuries due to explosions. For this reason, the
Occupational Safety and Health Administration (OSHA) requires worksites where
hazardous chemicals are used to have an emergency action plan (EAP). takes this
requirement seriously, as employee safety in the workplace is our top priority.
The EAP describes the procedures to follow during an
emergency, such as a chemical spill, leak or explosion, including the following:
- Who to notify
- Who is in charge and who else has responsibilities
in responding to the incident
- Who is responsible for each task
- How to evacuate the site
OSHA also requires all employees to be trained in EAP
procedures, so that everyone is prepared in the event of an emergency. Notify
your supervisor if you have not yet had training in EAP procedures or if you would
like a refresher.
The first priority when working with chemicals is to try and
prevent a spill, leak or explosion. You can contribute to that goal by doing
- Knowing and understanding the chemicals you’re
working with, including any hazards—refer to the appropriate Safety Data Sheet
(SDS) or ask questions if you are unsure
- Following all safety precautions and wear proper
personal protective gear
- Helping to make sure all chemicals are properly
labeled in their container
When an Incident
To determine if a chemical spill, leak or explosion is
hazardous or requires special cleanup procedures, do the following:
- Identify the chemical(s) involved.
- Refer to the SDS for any chemical involved to
find out how flammable and/or reactive it is, what protective equipment is
needed and spill cleanup procedures.
- For chemicals resulting in a hazardous fire or
explosion, refer to the SDS also for firefighting instructions.
In the event of a chemical spill, leak or explosion, be sure
to do the following:
- Immediately notify your supervisor.
- Notify other workers on the floor.
- Activate emergency alarms.
- Call 911.
- Keep people out of the area.
- Leave the area if the spill cannot be readily
contained, or if it presents an immediate danger to life or health.
- Follow the evacuation rules in the EAP.
- Leave cleanup to trained personnel, such as a
Hazardous Materials team.
Do not try to do the following:
- Rescue or help injured people unless you are
sure you will be safe
- Clean up a spill yourself, except where permitted
or required by site rules and the EAP
OSHA requires these safety measures, and so do we. It is our
hope that an accident like this never happens, but all employees should be
prepared in case it does. Make sure you learn these precautions and follow them
if you ever must respond to a hazardous chemical spill, leak or explosion, to
help keep yourself and your co-workers safe.
Avoid Accidents on the Plant Floor - November 2017
While manufacturing is a much safer industry now than it was
in the past, there are still hazards within the workplace. However, many
on-the-job accidents can be avoided by focusing on safe practices and taking
Most accidents are caused by an unsafe act, an unsafe
working condition or a combination of the two.
For example, removing a protective guard from a machine is an unsafe act
that can easily cause an accident. On the other hand, a spill on the floor
could cause someone to fall and get injured, and that accident would be due to
an unsafe condition. In either instance, the accident could have been prevented
by either following proper safety procedure or being alert to unsafe working
Hazards You May Encounter
Your job always has some potential for danger, so it’s
important to understand what causes accidents so that you can avoid them
whenever possible. While it is impossible to list all of the hazards you may
encounter while working, common ones include the following:
- Not wearing proper personal protective equipment
- Removing guards from machinery
- Using machines or tools improperly
- Unsafe handling of materials or chemicals
- Debris or spills that are not cleaned up
- Wearing hanging jewelry or belts that could be
caught in equipment
Safe Steps to Avoid Accidents
The first step to keeping yourself and co-workers safe is to
stay alert on the job and don’t let routine or familiarity lure you into
carelessness. This can be challenging, especially if you do a repetitive task
throughout the day. Always observe safety precautions before and during a task,
even if those precautions make the task more inconvenient or take longer to
complete. Cutting corners may not seem like a big deal, but doing so is a
primary cause of accidents.
Next, know your job. The more you know about your job, the
safer you’ll be. Know the proper procedures and safety precautions for any task
you do, and if any questions arise during your work day, be sure to talk to
your supervisor. Be on the lookout for unsafe conditions near your workstation.
And finally, make a personal contribution. A good way to
start this is to follow all safety rules and always wear required uniform and
protective equipment, even if you think they are unnecessary or slow you down.
Certain rules in the workplace are made for your protection, so follow them. Also,
just because an unsafe act is not specifically prohibited, it doesn’t mean you
should do it. Use your common sense when evaluating if an act is safe or
not—there may be a very easy way to make it safer if you stop to think it
Focus on Good Habits
It’s human nature to work yourself into habits, and when you
break a safety rule, you’ve taken the first and most influential step in
forming a bad habit—a habit that can lead to an injury. Good habits, such as
noticing unsafe conditions, correcting them immediately or calling them to the
attention of a supervisor, are just as easy to form.
Develop a safe attitude! This is probably one of the most
difficult things to face because most of us have the mistaken notion that it’s
always someone else who gets hurt, never us. If we all do our share in
observing safety rules and staying alert for unsafe conditions, everyone will
Safe Conveyor Belt Use - October 2017
Unnecessary workplace accidents can occur when employees do
not think before they act or avoid taking precautions to prevent accidents.
Keeping safety top of mind is especially important when working with potentially
dangerous machinery like conveyor belts. In fact, the Occupational Safety and
Health Administration (OSHA) frequently cites conveyor belt accidents as one of
the top preventable accidents in the workplace.
For example, employees at a paper corporation were removing
wood and bark chips from underneath a moving conveyor belt and shoveling them back
onto the conveyor. An employee went into a narrow opening to remove bark that
had accumulated under the belt. When the worker did so, the shovel caught
between a roller and the underside of the moving conveyor, and pulled the
worker into the machinery. The worker died as a result of the accident. This is
an example of an accident that could have been prevented by exercising conveyor
Familiarize yourself with the following conveyor belt safety
Before You Start a
- Inspect the area to ensure that no one is performing
maintenance, is under the conveyor or within the fall zone.
- Make sure all guards are fitted and that the emergency
stop switch is working properly.
When Working at or
Near a Conveyor
- Wear a hat and safety shoes. Avoid wearing loose-fitting clothes
or jewelry, and make sure that your hair is short or pulled back.
- Do not walk under a moving conveyor.
- Never clean belts, pulleys or drums while the machine is on.
- Do not perform maintenance or repairs while the conveyor is
When Working at a
- Ensure that you can see the system while you are operating
- Follow all lockout and tagout procedures before performing
- Position yourself so that you will not be hit by moving
When Working With an
- Make sure that machine guards are in place to protect
against objects falling on workers below.
- Always know the location of start and stop controls.
- Never step, climb, sit or ride on a conveyor belt.
- Never alter or remove machine guards.
- Never overload a conveyor outside of its design limits.
- Always report unsafe practices to your supervisor.
We’re Counting on You
Conveyor belts make our jobs easier, but must be used in a
safe manner at. If you have any questions or concerns about conveyor belt
safety or operation, contact your supervisor.
Safety Standards for Cleanrooms - September 2017
The use of cleanrooms is commonly required for manufacturers
of sensitive electronic equipment, pharmaceuticals, sterile medical devices and
in any other critical manufacturing environment where the contaminants present
in outside air could destroy the product’s functionality.
Though cleanrooms are critical parts of the manufacturing
environments in which they are used, they are surprisingly unregulated by the
U.S. government. In fact, the only federal standard that regulated cleanrooms
was canceled in 2001, though manufacturers still widely use the standard as a guideline.
It is important to keep in mind that the Food and Drug Administration (FDA)
does have Quality Systems Regulations in place that require manufacturers to
use structures that ensure their products meet provisions, and that the
business follows good manufacturing practices; however, this does not specifically
address cleanroom conditions.
The International Organization for Standardization (ISO), of
which the United States is a member, covers the classification of air purity in
cleanrooms, and specifies the requirements for testing and monitoring cleanrooms
to prove compliance. But from an employer’s perspective, it is not ISO 14644-1
and ISO 14644-2 standards that should determine how to treat your cleanroom
facility; rather, it makes the most business sense for you to treat your
cleanroom with the utmost care to ensure that the facility stays up to
What Does Clean Mean?
Individual subsets of industries set their own standards for
just how “clean” companies’ cleanrooms must be. For example, integrated circuit
manufacturers must operate in a cleanroom of no more than ISO 4, which does not
allow any particles greater than 5 micro-meters in size, or one-thousandth of a
millimeter. Depending on the type of manufacturing that is performed at your
workplace, your ISO rating can vary. Check your industry cleanroom standards to
determine the proper ISO rating.
Standards aside, a cleanroom is only useful if it is maintained
properly. Many employers are unaware of the fact that a particle 200 times
smaller than the width of a human hair can cause a major contamination disaster
in a cleanroom. Contamination will not only cost your company because of
expensive downtime while the problem is fixed, but it will also result in
increased product costs. For example, many electronic products produced in a
contaminated cleanroom will not function properly and will result in product
recall, while medical devices manufactured in a contaminated cleanroom will not
meet FDA regulations.
Building a cleanroom properly is the first step to saving money
in the long run, since it is much easier to eliminate the possibility of contamination
as the facility is being built. Removing contamination after the fact is not only
extremely difficult, but also enormously costly in both time and money. It is
important to warn your employees that contamination can come from many unexpected
sources, including the following:
- Other elements of the building or facility that
hold the cleanroom, including walls, floors, ceilings, paint, coatings and air
- Equipment and supplies, such as loose particles
from friction, vibrations, brooms, mops, items brought into the cleanroom and
- Microorganisms, like viruses, bacteria and
- People are often the largest source of contamination.
This can come from skin flakes and oil, hair, saliva, cosmetics or perfume, and
clothing debris like lint and fibers. However, it can also come simply from
peoples’ presence; a motionless person, standing or seated, generates 100,000
0.3 micron-sized particles each minute, and a person walking at a swift pace
will generate 10,000,000 particles per minute.
Ensuring that the facility meets the accurate air quality standards
starts with requiring employees to wear the proper equipment while inside the
To lower your cleanroom’s risk of contamination, take the
- Warn employees about the danger to the company in
bringing personal items—such as wallets and phones—out while in the cleanroom.
- Encourage employees to make as subtle and slow
of movements as possible while in the cleanroom.
- Check periodically for leakages in the shell
Lower Costs by Implementing Safety Programs - August 2017
country, employers pay almost $1 billion per week for direct workers’
compensation costs alone, which comes straight out of company profits. In fact,
lost productivity from injuries and illnesses costs companies roughly $63
billion each year.
According to the
Occupational Safety and Health Administration (OSHA), workplaces that establish
safety and health management systems can reduce their injury and illness costs
by 20 to 40 percent. Safe environments also improve employee morale, which
positively impacts productivity on the manufacturing line.
business climate, these safety-related costs for manufacturers can be the
difference between reporting a profit or a loss. Industry studies report that
companies who focus on safety as a core business strategy come out ahead. The
American Society of Safety Engineers reports that implementation of an OSHA
consultation program reduced losses at a forklift manufacturing operation from
$70,000 to $7,000 per year.
Use these tips
to understand how implementing safety programs will directly affect your
company’s bottom line.
the value of safety to management is often a challenge because the return on
investment (ROI) can be cumbersome to measure. Your goal in measuring safety is
to balance your investment vs. the return expected. Where do you begin?
There are many different approaches to measuring the cost of safety, and the way
you do so depends on your goal. Defining your goal helps you to determine what
costs to track and how complex your tracking will be.
For example, you
may want to capture certain data simply to determine what costs to build into
the price of your products, or you may want to track your company’s total cost of
safety to show increased profitability, which would include more specific data
collection like safety wages and benefits, operational costs and insurance
can be time consuming, general cost formulas are available. A Stanford study
conducted by Levitt and Samuelson places safety costs at 2.5 percent of overall
costs, and a study published by the Economist Intelligence Unit (EIU) estimates
general safety costs at about 8 percent of payroll.
If it is
important for your organization to measure safety as it relates to
profitability, more accurate tracking should be done. For measuring data,
safety costs can be divided into two categories:
Direct (hard) costs,
- Safety wages
- Operational costs
- Insurance premiums
and/or attorney’s fees
- Accidents and
- Fines and/or
- Indirect (soft)
costs, which go beyond those recorded on paper, such as:
- Repairing damaged
machinery and line equipment
- Worker stress in the
aftermath of an accident resulting in lost productivity, low employee morale
and increased absenteeism
- Training and
compensating replacement workers
- Poor reputation,
which translates to difficulty attracting skilled workers and lost business
soft costs, minor accidents costs are about four times greater than direct
costs, and serious accidents about 10 to 15 times greater, especially if the
accident generates OSHA fines or litigation costs.
IRMI, just the act of measuring costs will drive improvement. In theory, those
providing the data become more aware of the costs and begin managing them. This
supports the common business belief that what gets measured gets managed. And,
as costs go down, what gets rewarded gets repeated.
OSHA studies indicate that for every $1 invested in
effective safety programs, you can save $4 to $6 as
injuries and fatalities decline. With a good safety program in place, your
costs will naturally decrease. It is important to determine what costs to
measure to establish benchmarks, which can then be used to demonstrate the
value of safety over time.
Also, keep in
mind that your total cost of safety is just one part of managing your total
cost of risk. When safety is managed and monitored, it can also help drive down
your total cost of risk.
Considering the statistics, safety experts believe
that there is direct correlation between safety and a company’s profit. We are
committed to helping you establish a strong safety, health and environmental
program that protects both your workers and your bottom line. Contact us today
at (619) 297-3160 to learn more about our value-added services.
Managing Your Total Cost of Risk - July 2017
As a manufacturer, how do you quantify your true cost of
risk? For example, if you are faced with a recall, how do you calculate your
loss of reputation or market share? It is difficult, at best, to quantify this
scenario. In contrast, other components of your cost of risk are easily
identified, such as insurance premiums, or lost production costs caused by
downtime of a custom piece of machinery.
Total cost of risk is an insurance term describing the cost
of both pure and speculative risk. It is synonymous with price — the price of
your risk management program. We take a total cost of risk approach to
positively affect your price by protecting the following four main asset
The structure of your risk management program looks to help
decrease your total cost of risk. To reach that goal, we help you:
control measures to those exposures
risk transfer or financing options
current and future exposures
Identification of Exposures
As part of our risk management interview process, we look to
confirm that your risk management approach supports your overall business
objectives and plans for your company’s future. How would your income or cash
flow be affected if there were unforeseen depletions of capital or a shutdown
in the plant? Discussing the qualitative aspects of your business provides the
important details needed to solidify a plan to help your business succeed, even
if the worst happened. Risks can be both qualitative and quantitative. Analyses
into both offer the foundation for developing forward-thinking approaches to
What is your viewpoint on risk? Is your company risk-averse?
Is it in a financial position to take on more risk versus transferring that
risk to another party or contractually to a carrier? To help determine your
risk aversion, it helps to assess your company history. For example, if you are
a start-up company, cash flow and funds are typically tight, so you are more
likely to be adverse to risk to protect the financial viability of your
start-up organization. Conversely, if your company has a 20-plus year history,
there are also risks, including becoming obsolete, stagnant or too conservative
with your business plan.
Additionally, we consider norms in the manufacturing
industry, your market position and competition to position your risk management
solution to the changing needs of your business.
Quantitative analysis supports the qualitative interview. We
look at the “hard numbers” and prior losses to identify trends in your
performance. We also analyze those losses to identify:
incurred costs per loss
- Top loss
with high frequency issues
vs. severity ratios
The results of our in-depth analysis will reveal
opportunities to approach the critical areas driving your total cost of risk.
We will isolate the root causes of these problematic areas and look to
implement control measures to mitigate this exposure.
Implementation of Control Measures
Identifying exposures directs us to focus our resources on
delivering the best control measures. An
estimated 75 percent of commercial insurance expenses are claims-driven. We
look to control and reduce this percentage through pre- and post-loss control
A comprehensive loss control evaluation uncovers your
strengths and weaknesses. A company may have strong management leadership
behind his or her initiatives but have no employee buy-in or participation. CMR
Risk & Insurance Services, Inc. has the solutions to establish a safety
committee, delivering a comprehensive employee safety education campaign to
address your exposures.
There are many post-loss or cost containment strategies. A
proactive and effective Return to Work program is one strategy that positively
affects your bottom line: offering a bank of modified duty jobs for employees
and informing the doctor there is modified work available. Also, establishing a
relationship with a local occupational medicine clinic can help manage costs.
Interview the staff to learn about their services and tour their facilities.
Invite the physicians into your business to get a first-hand look and
understanding of your operations. By providing them with the details of your
operations, they can accurately evaluate reported injuries to confirm if they
Fraudulent claim behavior can drive the cost of risk out of
control. Anti-fraud tactics include educating employees on the effects of
insurance fraud through payroll stuffers and worksite posters, and offering
safety incentives for solid performance. Also, keeping a motor vehicle accident
kit in company vehicles, along with a disposable camera, allows you to document
evidence, providing stronger subrogation results.
An active loss control program and post-loss procedures are
elemental to cost containment. Our agency offers comprehensive resources to
employ the most appropriate strategies for your business.
Risk Transfer and Financing
Once we have identified exposures and created control
measures, we can focus on the remaining exposures to transfer and/or finance.
You will want to address questions such as: How much risk can I afford to
assume in-house? How can CMR Risk & Insurance Services, Inc. assist in
contractually transferring risk to a third party? Lastly, what portion of the
exposures do I want to finance through an insurance policy?
Addressing these questions offers a direction as to how to
approach the financing of your risk. Think about current cash flow needs. Are
account receivables current? If there is a lag, how long is it, and are there
resources to correct it?
Considerations involve self-insured retentions if you have a
mature loss control program and the financial reserves to cover shock losses
that occur. Therefore, a combination of insurance and non-insurance strategies
should be considered.
Manage Your Exposures
Roughly 25 percent of businesses that sustain a major
catastrophe are no longer in business within a year’s time. If there is an
interruption in your operations, are you prepared?
We have the resource for you to develop a comprehensive
business continuity plan. This involves backing up your policies and
procedures. Through, we offer 24/7 Web access to your critical risk management
information, employee education resources and tools to drive down your cost of
regulatory compliance; all are ID- and password-enabled for your protection.
Cost of Risk Resources
To develop the most appropriate risk management program for
your organization, CMR Risk & Insurance Services, Inc. approaches
“insurance” through a variety of insurance and non-insurance strategies, such
processes (qualitative and quantitative);
analysis tools to uncover exposures;
of pre- or post-loss initiatives that address cost containment;
continuation planning/disaster recovery;
financing options, retained losses or transferred; and
We work with you to develop a strategic action plan, assist
in the execution of the designed risk management program, and are committed to
the monitoring and support of these initiatives. If you are interested in
reviewing your risk management strategies, contact us today at (619) 297-3160
to speak with one of our insurance experts.
3-D Printing - June 2017
3-D printing has taken off in recent years. An
additive manufacturing technique, it is the process of printing layers of
material on top of one another to “grow” a product. Product creation relies on
computer-aided design (CAD) files. Stereolithography software reads the CAD
file and uses a material such as paper, powder or metal to print the shape. The
number of printing materials available is constantly growing and currently
includes thermoplastics, edible materials, rubber, clay, porcelain, metal,
ceramic powders, plaster, paper and even human tissue.
There are five unique printing processes:
- Selective laser
melting or direct metal laser sintering: A laser is used to fuse together
metallic powder into the desired shape.
- Selective laser sintering:
Lasers are used to fuse together small pieces of material like plastic or metal
into the desired shape.
- Fused deposition
modeling: Plastic or metal wiring is unspun from a coil and printed in
layers to create the desired shape.
Ultraviolet-curable resin is laid down and built up, layer by layer.
Ultraviolet light is shone on each layer after it has been put down to solidify
- Laminated object
manufacturing: Layers of material are laid down and glued to one another
and then shaped with a laser or knife.
The technology for 3-D printing has been around for nearly
30 years, but it wasn’t until fairly recently that printers and printing
materials became an affordable option for businesses. Because of the high
demand for the technology, the price dropped from about $20,000 in the 1980s to
around just $1,000 today, leading to a rise in sales. And as the price dropped,
Printers that were originally used just for prototyping
began to be used to print manufacturing materials, such as molds. Today,
companies in a variety of industries, including architecture, construction,
automotive, dental and medical, engineering, biotechnology, fashion and
education are experimenting with using 3-D printing to manufacture end products.
This innovative practice comes with its share of benefits and risks.
3-D printing has a number of benefits:
- Less waste:
Unlike more traditional subtractive manufacturing techniques that remove
material by cutting or sawing to form a product, 3-D printing builds the
product from the ground up, resulting in significantly less material waste.
- Reduced overhead:
Printing materials and a CAD file are all that is required to create a product.
It’s not necessary to purchase molds, create custom manufacturing materials,
hire laborers or even have a designated manufacturing facility.
- Intricate details: Almost any shape imaginable can be printed, including shapes with complex
detail that would be costly and difficult—in some cases too difficult—to create
with subtractive manufacturing.
products: Some products, such as hearing aids and prosthetic limbs, are
time-consuming and expensive to create with traditional manufacturing
techniques because they must be customized to fit a single end user.
- Reduced warehousing
costs: Offering long-term warranties for replacement parts is much more
efficient for companies that utilize 3-D printing. The company can simply save
a CAD file for each product part and then print the part on an as-needed basis
instead of storing older parts in a warehouse.
It’s also important to recognize the potential risks that
this new technology poses:
infringement: CAD files that infringe on patents and design rights are
already beginning to show up on the Internet. The piracy of digital design
files will likely be widespread and difficult to police. Companies will need to
insure themselves against this risk and find innovative ways to guard
- Compromised supply
chain: Widely available CAD files mean that compromised parts could enter
the supply chain. Even if a company is not using 3-D printing in its own
operations, it is still at risk of manufacturing products with defective or
unsafe 3-D-printed components, and of being held liable for the resulting
- Exposure to ultrafine
particles (UFPs): Printers without proper ventilation can expose users to
the UFPs that are released during the printing process. Inhaled UFPs can cause
adverse health effects, including an increased risk of asthma, heart disease
- Global public safety:
Currently, no legislation exists to regulate 3-D printing, so anyone,
anywhere can download anything. In 2012, Defense Distributed, a company based
in the United States, created a CAD file for a 3-D printable gun. Soon after,
the U.S. Department of Homeland Security called for the file to be taken down,
but not before it had been downloaded by more than 100,000 people in places as
far away as Germany, Spain and Brazil. There are more opportunities for
obtaining banned products with 3-D printing.
Like any technology, 3-D printing is not without risks, many
of which are yet to be discovered. Despite these risks, companies are looking
to 3-D printing technology to rethink processes and improve business
Industry experts predict that 3-D printing will transform
manufacturing as we know it. Exciting projects like rebuilding coral reefs,
growing functioning organs and body parts and replicating priceless artifacts
for scientific study will continue to capture the attention of the public and
encourage further innovation.
Have you considered the impact of 3-D technology on your
business? Contact CMR Risk & Insurance Services, Inc. today at (619)
297-3160 to learn more.
The SPCC and Oil Spill Prevention - May 2017
Using oil at your facility can represent a risk for the
environment and a hazard to your workers as well as your property. The
Environmental Protection Agency (EPA) regulates facilities’ spill-prevention
measures with the Oil Spill Prevention, Control and Countermeasure (SPCC) Rule,
which sets specific requirements for facilities that meet certain criteria
regarding the risk of spills. The regulation specifies actions required for the
prevention of, preparedness for and response to oil discharges. According to
recent modifications to the rule, all covered facilities must prepare and
implement a SPCC Plan. To ensure you are in compliance, review the following
To Whom Does the SPCC Apply?
A facility is covered by the SPCC rule if it fulfills the
- It has a total aboveground oil storage capacity greater than
- It stores, transfers, uses or consumes oil or oil products
including diesel fuel, gasoline, lube oil or hydraulic oil.
- It could reasonably be expected to discharge oil to waters
of the United States or adjoining shorelines, such as interstate waters,
intrastate lakes, rivers and streams.
Those with operations on multiple pieces of property need
not combine the number of containers on separate properties for the purposes of
this rule. In fact, if you identify adjacent pieces of property as separate
based on operations, you can advantageously count the containers on the two
What Does the SPCC Rule Require?
If the rule applies to your property, you are required to
prepare and implement an SPCC Plan or adequately maintain your plan if you
already have one. You need not submit the plan to the EPA unless it is
requested, but you should maintain the plan at the facility. Your
responsibilities include the following:
1. Prevent oil spills. Following are some prevention measures
that could be included in your plan.
- Use containers that are appropriate for the oil stored. For
example, use a container designed for flammable liquids to store gasoline.
- Provide overfill prevention (e.g., high-level alarms or
audible vents) for oil storage containers.
- Provide secondary containment for bulk storage containers,
such as a dike or remote impoundment. It must hold the container’s full capacity plus
possible rainfall. The dike may be constructed of earth or concrete, e.g., a
- Provide general secondary containment (e.g., sorbent materials,
drip pans and curbing) to catch the most likely oil spill, where oil is transferred
to and from containers and for mobile refuelers and tanker trucks.
- Inspect and test pipes and containers regularly. Visually
inspect aboveground pipes and oil containers according to industry standards,
and test buried pipes for leaks when they are installed o repaired.
2. Prepare and implement a SPCC Plan. The owner or operator of
the facility must develop and implement a SPCC Plan that describes oil handling
operations, spill prevention practices, discharge or drainage controls, and the
personnel, equipment and resources at the facility that are used to prevent oil
spills from reaching navigable waters or adjoining shorelines. Each SPCC Plan
is unique to the facility, but there are certain elements that must be detailed
in every plan, including the following:
- Operating procedures used to prevent oil spills at the
- Control measures (e.g., secondary confinement) installed to
prevent oil spills from entering navigable waters or adjoining shorelines.
- Countermeasures to contain, clean and mitigate the effects
of an oil spill that has impacted navigable waters or adjoining shorelines.
Certifying the Plan
If your facility meets the following criteria, you may be
eligible to self-certify your SPCC Plan.
- Aboveground oil storage capacity of 10,000 gallons or less
- No discharge of more than 1,000 gallons of oil to navigable
waters or adjoining shorelines in the last three years, or no two discharges
more than 42 gallons in the last 12-month period.
If you are not eligible to self-certify, your plan must be
certified by a licensed professional engineer (PE), who will confirm the
- Familiarity with the requirements of the rule
- Visit and examination of the facility
- SPCC Plan in accordance with good engineering practices,
including consideration of applicable industry standards and requirements of
- Existence of procedures for required inspections and testing
- Adequacy of the SPCC Plan for the facility
In Case of Spill
If your facility experiences a spill, you are required to
follow certain federal reporting requirements. Anyone in charge of an onshore
or offshore facility must notify the National Response Center (NRC) immediately
after receiving notice of the discharge. You will need the following
- Name and location of facility
- Owner/operator name
- Maximum storage/handling capacity of the facility and normal
- Corrective actions and countermeasures taken, including
equipment repairs or replacements
- Adequate description of the facility, including maps, flow
diagrams and topographical maps
- Cause of the discharge to navigable waters, including a
- Failure analysis of the system where discharge occurred
- Additional preventive measures taken or planned to take to
minimize discharge reoccurrence
It is important to know that you must also comply with state
and local reporting requirements. It often makes sense to call 911 when there
is an oil spill, especially if it is flammable or combustible.
You must also report spills to the EPA when one of the
- More than 1,000 gallons of oil is discharged to navigable
waters or adjoining shorelines in a single event
- More than 42 gallons of oil in each of two discharges to
navigable waters or adjoining shorelines occurs within any 12-month period.
Mitigating Your Risk Through Risk Management
Experiencing an oil spill can be devastatingly expensive. In
addition to ensuring compliance through the development of an SPCC Plan, work
with the insurance professionals at CMR Risk & Insurance Services, Inc. to
ensure you have purchased appropriate insurance coverage.
Understanding the HAZWOPER Standard - April 2017
manufacturers are unfamiliar with or do
not understand the Occupational Safety and Health Administration’s (OSHA)
Hazardous Waste Operations and Emergency Response (HAZWOPER) standard.
HAZWOPER requirements and regulations not only protects the health and safety
of your employees, but it also saves you from expensive litigation you could
face if you accidentally expose the outside environment and nearby residents to
the potentially hazardous toxins at your facility.
OSHA, the U.S. Environmental Protection Agency (EPA) and the National Institute
for Occupational Safety and Health (NIOSH) all have input on HAZWOPER’s
regulations because of the widespread effect hazardous waste has on the population
as a whole, not just the industries’ workforces. This document will help you
understand the basic requirements of HAZWOPER and determine whether you are in
compliance. For a complete list of HAZWOPER requirements or to read the
standard in its entirety, visit www.OSHA.gov
and search HAZWOPER (Standard 29 CFR 1910.120).
applies to the following types of operations, unless the employer can
demonstrate that the operation does not involve the reasonable possibility of
employee exposure to safety or health hazards:
- Cleanup operations required by a government body
(federal, state or local) involving hazardous substances conducted at
uncontrolled hazardous waste sites
- Corrective actions
involving cleanup operations at sites covered by the Resource Conservation and
Recovery Act (RCRA)
- Voluntary cleanup
operations at sites recognized by government bodies (federal, state or local)
as uncontrolled hazardous waste sites.
- Operations involving
hazardous waste conducted at treatment, storage or disposal facilities
- Emergency response
operations for releases of hazardous substances regardless of the location of
It is the final
type of employer, emergency response operations, that is often unfamiliar with
HAZWOPER because the employees at these facilities are not directly exposed to
hazardous substances every day. However, minor, incidental releases of
hazardous substances would not require an emergency response effort under
HAZWOPER. Also, employers who immediately evacuate employees from danger zones
and do not expect them to assist in handling the emergency in any way are exempt
from HAZWOPER, though they still must be in accordance with 29 CFR 1910.38.
as an emergency under HAZWOPER can vary, and you should consider the nature of
your operation and the extent of your employees’ training. For example, small
acid spills in a facility that routinely handles acids would not be an
emergency; however, the same situation might be considered an immediate hazard
in a facility where employees have less training, equipment or experience. In
the event that employees are in the following situations, the HAZWOPER standard
- Presence of high
concentrations of toxic substances
- Any situation
involving hazardous substances that is life- or injury-threatening
- Environments that
present imminent danger to life and health (IDLH situations)
- Accidents that
present an oxygen-deficient atmosphere
- Conditions that pose
a fire or explosion hazard
- Any situation that
requires the evacuation of an area or that requires immediate attention because
of the danger posed to employees in that area
provides specific safety regulations, emergency procedures and training guidelines
for employers to follow in facilities that handle hazardous waste or who have
the potential for accidental release of dangerous chemical substances.
HAZWOPER’s main goal is to get employers to think about how they would handle a
spill before it occurs.
The bulk of the
HAZWOPER standard deals with proper cleanup at hazardous waste sites. It is the
last section that covers emergency response and discusses the necessary length
of training, which is also the most misunderstood section of the standard.
HAZWOPER sets five basic training levels related to chemical emergency
response, and training requirements for these five groups vary depending on how
closely they work with the hazardous material spill. All training must be
completed upon hiring for any employee that is expected to participate in
* First Responder Awareness Level: Individuals likely to witness a
hazardous substance release and whose only responsibility would be notifying
the proper authorities. These individuals must have sufficient training to
demonstrate the following:
* First Responder Operations Level
- Understanding of
what hazardous substances are and the risks associated with them in an incident
- Understanding of the
potential outcomes associated with a hazardous substance emergency
- The ability to
recognize the presence of hazardous substances
- The ability to
identify the hazardous substances, if possible
- The ability to
realize the need for additional resources and make appropriate notifications
: Individuals who respond to releases
of hazardous substances for the purpose of protecting nearby people, property
or environment from damage. They should respond defensively by containing the
release and keeping it from spreading. These individuals must have eight hours
of training or sufficient experience to demonstrate the following:
- Knowledge of hazard
and risk assessment
- Knowledge of proper
personal protective equipment (PPE) use
- Knowledge of basic
control, containment and/or confinement operations
- Understanding of
standard operating procedures
* Hazardous Materials Technician: Individuals who responds to
releases with the purpose of actively and aggressively stopping it. They will
attempt to plug, patch or otherwise stop the hazardous substance release. They
must have at least 24 hours training, all the first responder operations
knowledge and the following:
* Hazardous Materials Specialist:
- Knowledge of how to
implement the employer’s emergency response plan
- Ability to classify,
identify and verify known and unknown materials by using survey equipment
- Knowledge of how to
select and use specialized chemical PPE
- Have the ability to
perform advanced control, containment and/or confinement operations with the
resources and PPE available
- Knowledge of basic
chemical and toxicological terminology and behavior
Individuals who respond with and
provide support to hazardous material technicians, but with more specific
knowledge of various hazardous substances. They also acts as the site liaison
with government authorities. They must have 24 hours of training, all
technician-level knowledge and employer-certified knowledge on the following:
- The local, state and
federal emergency response plan
identification and verification of known and unknown materials using advanced
- The implementation
of decontamination procedures
- Advanced chemical,
radiological and toxicological terminology and behavior
* On-scene Incident Commander: Individuals who assume control of the
incident site. They must have 24 hours of training and employer-certified
competency in the following areas:
- Ability to implement
the employer’s incident command system
- Ability to implement
the employer’s emergency response plan and the local/state/federal emergency
- Understanding of the
hazards and risks associated with employees working in chemical protective
- Understanding of the
importance of decontamination procedures
notes on training regulations in the HAZWOPER standard are that measurements of
a qualified trainer can be met by academic degrees, completed training courses
and/or work experience. Also, HAZWOPER specifically addresses the use of video
or online training to satisfy requirements, saying that computer-based systems
are an incomplete solution and must be supplemented.
important section of the HAZWOPER section you should take note of is the need
for an emergency response plan with regard to hazardous substance releases.
HAZWOPER gives the following guidelines for employers’ emergency response
plans, saying it should at least include the following:
- Personnel roles,
lines of authority, training and communication standards
recognition and prevention
- List of safe
distances and places of refuge
- Site security and
- Evacuation routes
- Emergency medical
treatment and first aid procedures
- Emergency alerting
and response procedures
- Critiques and
follow-ups on previous emergency response situations
information on how you can further implement HAZWOPER loss control methods,
contact CMR Risk & Insurance Services, Inc..
Practicing Slip and Fall Prevention - March 2017
A janitorial employee was scrubbing the steps and floors
with water and a cleaning agent. An observant worker realized that soon, dozens
of employees would be going down these steps for their lunch break. This person
then took the proper action to avert this potentially dangerous situation and
set up a wet floor sign.
Do Your Safety Part
An unguarded wet floor is only one of the many causes that
account for millions of work-related injuries every year. Which is why it is
important to spot unsafe conditions that could lead to slips and falls, and do
what you can to prevent them.
There are various ways to suffer slips and falls while
working. You can slip and lose your balance, you can trip over objects left
improperly in your walkway, or you can simply fall from an elevated position to
the ground. To avoid slips and falls, be on the lookout for foreign substances
on the floor. Watch for:
- Deposits of water
- Grease or oil
- Other manufacturing debris
Even small quantities are enough to make you fall.
When entering a building from the outdoors or from debris
areas, clean your footwear thoroughly. Snowy and rainy weather require a
doormat at each entrance to allow for complete wiping of shoes. Avoid running,
walk safely and do not change directions too sharply.
Beware of tripping hazards. Trash, unused materials or any
object left in aisles designed for pedestrian traffic invites falls. Extension
cords, tools, carts and other items should be removed or properly barricaded
off. If equipment or supplies are left in walkways, report it. Let the proper
personnel remove it. And keep passageways clean of debris by using trash
barrels and recycling bins.
Walk in designated walking areas. Short cuts through machine
or other manufacturing areas can cause accidents. Concentrate on where you are
going—horseplay and inattention leaves you vulnerable to unsafe conditions.
Hold on to handrails when using stairs or ramps. They are there to protect you
should a fall occur. If you’re carrying a heavy load that hampers your ability
to properly ascend or descend stairs, use the elevator or find help.
The worst falls are from elevated positions such as ladders,
and can result in serious injury or death. Learn and practice ladder safety and
the proper use of scaffolding. For example, when climbing, use a ladder of
proper length that is in good condition. Keep it placed on a firm surface. Do
not climb a ladder placed on machinery, crates, stock or boxes. Keep the
ladder’s base one foot away from the wall for every four feet of height. Don’t
over-reach. Always have control of your balance when working from a ladder.
Never climb a ladder with your hands full, and always transport tools in their
proper carrying devices.
Slips and falls occur every day. The extent of injuries and
their recurrence can be minimized through proper safety knowledge, good
housekeeping and practicing prevention.
Recognizing Spray Paint Hazards - February 2017
Spray painting is an efficient and effective way to cover
large areas or irregular surfaces with even coats of primer, paint, sealers and
other coatings. When you are using spray paint, it is important to recognize and
guard against potential hazards.
Why it is Dangerous
Many paints, coatings, catalysts, sealers, hardeners and
solvents contain hazardous chemicals to which you could be exposed during
mixing, spraying, grinding and sanding tasks. Overexposure can cause nausea,
rash, asthma, dermatitis or even lung cancer. In addition, some coatings contain
flammable substances, which are released into the air when you use high-pressure
equipment. As they build up, these vapors can create an explosion hazard. To protect
yourself from these and other health hazards, study the following guidelines to
safe spray painting practices.
Ways to Protect Yourself
Before beginning a new task, consult the Safety Data Sheets
(SDS) for each product you will use. You will find information specific to that
chemical, including its hazards, appropriate personal protective equipment (PPE),
proper handling, transport, storage and disposal.
- Use a spray booth to avoid breathing in spray paint vapors
and debris. Regularly maintained and cleaned spray booths also provide maximum
protection against explosion hazards.
- Wear hearing protection when working with air-powered tools.
Extended exposure to loud noises can result in irreversible damage to your
- To protect your eyes, wear safety glasses and a dust mask or
respirator to protect against dust particles that form when using grinding and
- Wear a combination type HEPA air filter and organic vapor
respirator with breathing air lines to protect yourself from hazardous fumes.
- Wear lightweight, disposable coveralls, or launder reusable
coveralls separately from street clothes.
- Never eat, drink, smoke or apply cosmetics while working
with spray paint. Store food and other belongings in a separate area.
- Store paints and their solvents carefully in ventilated,
nonsmoking areas to prevent the possibility of ignition and explosion.
- Since you may have to hold full paint pots while spraying,
you must keep ergonomics in mind while on the job. Use balanced spray guns that
fit in your hand or use a hoist and dolly to move materials instead of holding
them. Take frequent, short breaks throughout the workday to stretch to avoid
unnecessary strains and sprains.
Keep Safety in Mind
Keeping safety in mind when working in and around spray
painting operations will help you avoid dangerous hazards and keep you injury-free
on the job. If you have any doubt about your safety, regarding spray painting or
any other issue, talk to your supervisor. Your safety is our top priority at.