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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 the following:

  • 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 Occurs

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.

Emergency Procedures

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 necessary precautions.

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 conditions.

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
  • Horseplay
  • 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 through.

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 benefit.

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 belt safety.

Familiarize yourself with the following conveyor belt safety tips.

Before You Start a Conveyor

  • 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 in motion.

When Working at a Powered Conveyor

  • Ensure that you can see the system while you are operating the controls.
  • Follow all lockout and tagout procedures before performing maintenance.
  • Position yourself so that you will not be hit by moving objects.

When Working With an Aerial Conveyor

  • Make sure that machine guards are in place to protect against objects falling on workers below.

General Safety Recommendations

  • 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 specifications.

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.

Preventing Contamination

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 conditioning debris
  • Equipment and supplies, such as loose particles from friction, vibrations, brooms, mops, items brought into the cleanroom and cleanroom debris
  • Microorganisms, like viruses, bacteria and fungus
  • 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 cleanroom.

Take Precautions

To lower your cleanroom’s risk of contamination, take the following precautions:

  • 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 enclosing

Lower Costs by Implementing Safety Programs - August 2017

Across the 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.

In today’s 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.

Showing Value

Demonstrating 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 costs.

Since measuring 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:

1.       Direct (hard) costs, which include:

  • Safety wages
  • Operational costs
  • Insurance premiums and/or attorney’s fees
  • Accidents and incidents
  • Fines and/or penalties
  1. Indirect (soft) costs, which go beyond those recorded on paper, such as: 
  • Accident investigation
  • Repairing damaged machinery and line equipment
  • Administrative expenses
  • 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 share.

When calculating 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.

According to 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.

Prove ROI

OSHA studies indicate that for every $1 invested in effective safety programs, you can save $4 to $6 as 

illnesses, 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 categories:

  1. Organization
  2. Personnel
  3. Property
  4. Net income

The structure of your risk management program looks to help decrease your total cost of risk. To reach that goal, we help you:

  • Analyze your exposures
  • Implement control measures to those exposures
  • Determine risk transfer or financing options
  • Manage 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 those exposures.

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:

  • Average incurred costs per loss
  • Total incurred trends
  • Top loss drivers
  • Locations with high frequency issues
  • Fraud behaviors
  • Reporting lag time
  • Frequency vs. severity ratios
  • OSHA-recordable performance

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 measures. 

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 are work-related.  

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 as:


  • Identification processes (qualitative and quantitative);
  • Loss analysis tools to uncover exposures;
  • Implementation of pre- or post-loss initiatives that address cost containment;
  • Business continuation planning/disaster recovery;
  • Risk financing options, retained losses or transferred; and
  • Regulatory compliance issues.


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:

  1. Selective laser melting or direct metal laser sintering: A laser is used to fuse together metallic powder into the desired shape.
  2. Selective laser sintering: Lasers are used to fuse together small pieces of material like plastic or metal into the desired shape.
  3. Fused deposition modeling: Plastic or metal wiring is unspun from a coil and printed in layers to create the desired shape.
  4. Stereolithography: 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 the resin.
  5. 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, creativity grew.

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.

The Benefits

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.
  • One-of-a-kind 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.

The Risks

It’s also important to recognize the potential risks that this new technology poses:

  • Copyright 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 intellectual property.
  • 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 damage.
  • 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 and stroke.
  • 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.

The Future

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 operations.

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 guidelines.

To Whom Does the SPCC Apply?

A facility is covered by the SPCC rule if it fulfills the following requirements:

  • It has a total aboveground oil storage capacity greater than 1,320 gallons.
  • 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 properties separately.

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 double-walled tank.
  • 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 facility.
  • 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 following:

  • 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 the rule
  • 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 information:

  • Name and location of facility
  • Owner/operator name
  • Maximum storage/handling capacity of the facility and normal daily throughput
  • 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
  • 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 following occurs:

  • 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

Many manufacturers  are unfamiliar with or do not understand the Occupational Safety and Health Administration’s (OSHA) Hazardous Waste Operations and Emergency Response (HAZWOPER) standard.

Following 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.

Officials from 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).


Today, HAZWOPER 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 the hazard

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.

What qualifies 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 would apply:

  • 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

Training Under HAZWOPER

This standard 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 emergency response:

* 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:

  • 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
* First Responder Operations Level: 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:

  • 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
* Hazardous Materials Specialist: 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
  • Classification, identification and verification of known and unknown materials using advanced survey equipment
  • 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 response plan
  • Understanding of the hazards and risks associated with employees working in chemical protective clothing
  • Understanding of the importance of decontamination procedures

Some important 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.

HAZWOPER Emergency Response Plan

Another 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:

  • Pre-emergency planning
  • Personnel roles, lines of authority, training and communication standards
  • Emergency recognition and prevention
  • List of safe distances and places of refuge
  • Site security and control standards
  • Evacuation routes and procedures
  • Decontamination procedures
  • Emergency medical treatment and first aid procedures
  • Emergency alerting and response procedures
  • Critiques and follow-ups on previous emergency response situations

For more 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
  • Food
  • Grease or oil
  • Sawdust
  • Soap
  • Other manufacturing debris

Even small quantities are enough to make you fall.

Good Housekeeping Counts

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.

Practice Prevention

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.

General Recommendations

  • 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 hearing.
  • To protect your eyes, wear safety glasses and a dust mask or respirator to protect against dust particles that form when using grinding and sanding equipment.
  • 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.