Author: [email protected]

Back when I played football I was on the “hands team.” The hands team was sent out on the field whenever there was the slightest chance our opponent would attempt an onside kick.  I don’t recall our opponents ever attempting an onside kick, but that didn’t stop our coach from practicing this every Thursday before our Friday night match up. He wanted us to be prepared for every scenario. A workplace emergency, similar to an onside kick, isn’t something that happens every day, but you want to be prepared regardless.

A workplace emergency is any unforeseen situation that threatens employees, customers, or the public, disrupts or shuts down operations, or causes physical or environmental damage. These emergencies can be human-caused or natural. Examples include floods, hurricanes, tornadoes, fires, toxic gas or chemical spills and releases, explosions, or workplace violence.

What Is An Emergency Action Plan?

An emergency action plan covers designated actions employers and employees must take to ensure employee safety from the types of emergencies that could impact the facility. The first step when developing an emergency action plan is to perform a hazard assessment to determine if any hazards in the workplace could cause an emergency. For instance, the presence of suspended combustible dust at certain concentrations in enclosed structures or equipment coupled with an ignition source can result in a dust explosion, hazardous chemicals when released can cause physical and health hazards to employees and the surrounding community, and natural disasters can occur about anywhere. At a minimum, each facility’s emergency action plan should include:

• The preferred method for reporting fires, explosions, chemical releases, and other emergencies.
• An evacuation procedure.
• Emergency escape procedures and route assignments such as floor plans, workplace maps, and safe refuge areas (evacuation points).
• The names, titles, departments, and telephone numbers of individuals both within and outside the company to contact for additional information or explanation of duties and responsibilities under the plan.
• Procedures for employees designated to perform or shut down critical plan operations, operate fire extinguishing equipment, or perform other essential services.
• Rescue and medical duties for trained employees designated to perform them.

The plan must also include the method for alerting employees of the emergency so that they can evacuate or take appropriate action. Employees can be notified by public address systems, portable radio units, or other types of visual or audible alarms. If alarms are used, they must be able to be heard, seen, or otherwise perceived by everyone in the workplace.

Developing an Emergency Action Plan

When developing the emergency action plan, it is important to determine the conditions requiring an evacuation, a clear chain of command, and a designated person or persons at your location authorized to order an evacuation or shutdown. Specific evacuation procedures must be incorporated to include designated emergency exit routes, exits, and evacuation point(s). It is also important to designate which employees will continue to shut down critical operations during the evacuation and an accountability system to ensure that facility personnel are safely evacuated.

The plan must designate a primary coordinator to lead and coordinate the implementation of emergency procedures including notification of first responders. There should also be another who can fill in if the primary coordinator is not available. The coordinator is responsible for determining:

• whether an emergency exists that requires the activation of the emergency procedures within the plan,
• supervising response efforts, coordinating with emergency services such local fire departments,
• and directing plant shutdown operations.

Employee Understanding and Training

Employees must understand the function and elements of the emergency action plan. This includes the types of emergencies that could happen at the facility, reporting procedures, types of alarm and notification systems used, evacuation procedures including evacuation points and shutdown procedures, and any special hazards at the facility. Employee training should address:

• Individual roles and responsibilities.
• Notification, warning, and communication procedures.
• Emergency response procedures.
• Evacuation, shelter, and accountability procedures.
• The locations of emergency equipment.
• Emergency shutdown procedures.

Training should be conducted annually with all employees and whenever new employees are hired.  Training should include:

• new equipment, materials or processes that affect evacuation routes,
• any changes in the layout or design of the facility,
• and whenever emergency procedures are updated or revised.

It is also recommended that emergency evacuation drills be performed routinely throughout the year for the specific types of emergencies identified within the plan such as fires, hazardous chemical releases, and severe weather.

Conclusion

Developing an effective emergency action plan is a critical step in the emergency planning process. Review your plan annually. Ensure that it covers the potential emergencies that could happen at your facility and practice your response procedures. Emergencies can come when you least expect it, be ready for the onside kick.

Related Links:

• Don’t Get Caught In The Line of Fire
• Preventing and Responding to Grain Dryer Fires
• Full Course Catalog – Safety Made Simple

Sources:

The Occupational Safety and Health Administration. How to Plan for Workplace Emergencies and Evacuations. US Department of Labor, 2001. https://www.osha.gov/sites/default/files/publications/osha3088.pdf

 

Joe Mlynek is a partner and subject matter expert at Safety Made Simple, LLC. He has over 25 years of experience in safety at the corporate level and as a consultant. He is a Certified Safety Professional (CSP) and Occupational Safety and Health Technician (OHST). Joe can be reached at [email protected]

Grain dryer fires pose unique hazards to the grain handling industry. These fires can result in downtime, lost revenue, injury and possible death. It is imperative that each facility engaged in grain drying, develop and document an effective emergency response plan to deal with these incidents.

Causes

Grain dryers move high volumes of air through perforated screens that allow air to flow through the grain. Grain dryer fires are often caused by lack of operator training, lack of operating oversight, inadequate cleaning and running the dryer at high temperatures. It is imperative that each operator is properly trained on the operation of the dryer. Established operating procedures can be found in the equipment’s operations manual.

Prevention

Implementing a grain dryer preventive maintenance program reduces the likelihood of a dryer fire. The dryer’s operations manual includes preventive maintenance schedules that should be followed. Each grain dryer should have its own maintenance schedule utilizing a maintenance checklist. Preventive maintenance should be performed prior to, during, and after the drying season. Many dryer fires are the result of improper in-season maintenance. In-season maintenance activities should include routine cleaning of the dryer screens and inspection of emergency controls and associated equipment.

Emergency Response

Each facility engaged in grain drying should develop an emergency response plan specific to fires. The response plan will vary based on the type, manufacturer and model of grain dryer. The response plan should be included in the facility’s emergency action plan. Generally accepted emergency response actions include the following:

Notify the Fire Department

The first step when responding to a dryer fire involves notifying the local fire department. Many dryer fires are small in nature and can be extinguished quickly by facility personnel. However, some dryer fires spread rapidly and require additional resources. Regardless of the size of the fire, it is important to have the fire department on stand-by when implementing the dryer’s emergency response plan. This saves valuable response time should the fire spread rapidly beyond control.

Isolate the Equipment

Grain dryers are equipped with emergency shut-offs located at the dryer control panel or at the PLC controls. The emergency-stop button will shut-off critical equipment such as the gas supply, burner, blower/fans, unload conveyors and the wet and dry legs. Grain should never be cooled with fans. This supplies the fire with more oxygen causing it to spread rapidly. After depressing the emergency-stop button, verify that the appropriate equipment is isolated. Some dryers may require manual shut-down of both the electrical and fuel supply. Consider locking and tagging out all associated electrical isolating devices and the gas supply in order to isolate the equipment during emergency response activities.

Determine the Location of the Fire

In the event that the fire is small, it may be extinguished with an at-hand fire extinguisher, fire hose, or by removing the grain through the dryers unloading system. When using the unloading system, it is important to drain the column impacted by the fire as well as the adjacent columns. Opening dryer discharge gates can expose employees and first responders to hot material. Using long handled tools to actuate column discharge gates can prevent exposure to extreme temperatures. Proper PPE, such as turn-out gear or heat resistant personal protective equipment (PPE), should be worn. If the facility does not have the appropriate PPE, consider requiring the fire department to open the discharge gates. Avoid using conveyance and bucket elevators to move smoldering grain. Smoldering or hot material reclaimed from the dryer should be extinguished under the direction of facility management or the responding fire department.

Inspect Attached Equipment and Implement a Fire Watch

Attached equipment including the destination bin, conveyance, bucket elevator legs, etc. should be inspected to ensure that hot material is not present. Implement an adequate “fire watch” for the remainder of the operating period to identify any hot spots within the system.

Conclusion

Establishing an effective preventive maintenance program can prevent dryer fires. Should a fire occur, a documented response plan can prevent the fire from spreading, protect property and eliminate the potential for injury. If your facility does not have a dryer fire response plan, consider developing one with the assistance of the dryer’s manufacturer, property insurer, and the local fire department. Once the plan is established, invite the local fire department to the facility. Discuss prevention strategies and the procedure for responding to a dryer fire. The time to get to know the local fire department is prior to an incident, not during it. Remember, safety doesn’t have to be difficult, simple steps, such as establishing a routine cleaning and maintenance schedule, can prevent grain dryer fires.

Related Links:

• Off The Job Safety Programs
• Emergency Action Plans
• Full Course catalog – Safety Made Simple

 

Joe Mlynek is a partner and subject matter expert at Safety Made Simple, LLC. He has over 25 years of experience in safety at the corporate level and as a consultant. He is a Certified Safety Professional (CSP) and Occupational Safety and Health Technician (OHST). Joe can be reached at [email protected]

Mobile cranes are used in various industries for maintenance and construction related projects. Whether you work for a construction company or host employer, it is important to understand the basic requirements. This blog will discuss several important operating requirements outlined in OSHA 1926, Subpart CC, Cranes and Derricks in Construction.

Ground Conditions

Ground conditions can negatively affect a mobile crane’s capacity and stability resulting in collapse, employee injuries, and property damage. The ground must be firm, drained, and graded. Supporting materials such as blocks, mats, or cribbing must be used in certain situations to ensure stability.

The OSHA standard places the responsibility for ensuring adequate ground conditions with the “controlling entity” at the site. This entity can be the general contractor, construction manager, or other legal entity with overall responsibility for the project’s planning, quality, and completion. The controlling entity must also inform the mobile crane user and operator of hazards beneath the equipment including voids, tanks, and utilities.

Power Lines

Electrocutions can be caused by a mobile crane, load, or load line contacting a power line. The OSHA standard contains specific procedures that employers must follow when operating mobile cranes near power lines. Prior to operating a crane on a work site, the employer must evaluate whether power lines are present in the work area and whether crane operations will come within 20 feet of a power line. If operations will not come within 20 feet during the project, no further precautions are required. If the initial plan for the crane’s use changes, the work zone must be reevaluated.

The standard also provides an alternate requirement if the lines voltage is known. Line voltage is determined by contacting the utility provider. Once the lines voltage is determined, the minimum clearance distance in OSHA 1926.1408, Table A can be used:

Should any part of the mobile crane, load, or load line come closer to the power line than the minimum clearance distance (either 20 feet or Table A clearance) the line must be de-energized and grounded, or specific steps must be identified and implemented to maintain the required minimum clearance distance. Required steps include conducting a pre-planning meeting, using non-conductive tag lines, erecting and maintaining an elevated warning line, barricade, or line of signs with flags or similar high-visibility markings at the minimum clearance distances. In addition, at least one of the following measures must be implemented: use of a dedicated spotter, use of a proximity alarm, use of a range control warning device, use of a device that automatically limits the crane’s range of movement, or use of an insulating link or device installed between the end of the load line and the load.

Rated Capacity Compliance

Mobile cranes can collapse when their rated capacity is exceeded. The term rated capacity is defined by the OSHA standard as the maximum working load permitted by the manufacturer under specified working conditions. These working conditions typically include a specific combination of factors such as equipment configuration, radii, boom length and other use parameters. The weight of the load must be determined prior to the lift and the crane must never be operated in excess of its rated capacity.

Conclusion

Mobile crane operations can negatively affect workers’ safety and result in property damage and regulatory exposure. This blog highlighted several, but not all, of OSHA’s requirements for employers. The information within this article, as well as additional crane requirements, can be found in OSHA 1926 Subpart CC, Cranes and Derricks in Construction. Another excellent resource is OSHA’s Small Entity Compliance Guide for the Final Rule for Cranes and Derricks in Construction.

Additional Links:

• Fall Protection Calculations
• Don’t Get Caught In The “Line of Fire”
• Full Course Catalog – Safety Made Simple

 

Joe Mlynek is a partner and subject matter expert at Safety Made Simple, LLC. He has over 25 years of experience in safety at the corporate level and as a consultant. He is a Certified Safety Professional (CSP) and Occupational Safety and Health Technician (OHST). Joe can be reached at [email protected]

The National Institute for Occupational Safety and Health (NIOSH) estimates that about 2,000 U.S. workers sustain job-related eye injuries requiring medical treatment each day. While many of these injuries are caused by small particles striking or abrading the eye, many are also caused by exposure to hazardous chemicals. Emergency eyewash and shower units play a significant role in minimizing the severity of eye injuries resulting from exposure to hazardous chemicals.

OSHA and ANSI Requirements

In the United States, the Occupational Safety and Health Administration (OSHA) requires that “where the eyes or body of any person may be exposed to injurious corrosive materials, suitable facilities for quick drenching or flushing of the eyes and body shall be provided within the work area for immediate emergency use.” The American National Standards Institute (ANSI) similarly requires that employers provide eyewash and shower equipment where employees are exposed to hazardous materials. It is up to the employer to determine their level of exposure and the need for emergency equipment such as an eyewash or emergency shower.

Emergency Eyewash stations and showers are either connected to a continual source of potable water or self-contained, gravity fed units. Self-contained units contain their own flushing fluid that must be refilled or replaced after use. According to ANSI, emergency eyewashes and showers must be located in an area that requires no more than 10 walking seconds to reach or within 55 feet of the hazard, located in a well-lit area identified with a sign, located on the same level as the hazard, and equipped with enough tepid water for 15 minutes of continuous use. If shut off valves are installed in the unit’s supply line for maintenance purposes, provisions must be made to prevent unauthorized shut-off.

Accessibility

It is important that emergency showers and eyewash units are accessible. Obstacles in the travel path can delay response time. Seconds count when the eyes and skin are exposed to corrosive or caustic liquids or other hazardous materials. Some hazardous chemicals take only 6 to 8 seconds to penetrate the outer membrane of the eye. For skin exposure, a worker might have between 10 to 15 seconds before severe damage occurs.

Inspection

Emergency eyewash and shower units must be inspected and tested on a routine basis. Without regular maintenance, inspection and testing, the water required to flush a worker’s body or eyes could become contaminated with particulates or chemicals or fail to function all together. When inspecting emergency eyewash and shower units, the inspector should make sure the unit is accessible and the unit’s sign is visible. The unit’s water source must be turned on and the water flow must be adequate, clear. The unit must remain on until the unit is turned off. The water should also be tepid. Tepid is considered as a temperature between 60- and 100-degrees Fahrenheit (16-38 degrees Celsius). Temperatures higher than 100 degrees Fahrenheit can enhance a hazardous chemical’s interaction with both the skin and eyes.

Educating Employees

Employees must have a good understanding of emergency eyewash and shower use. This can be achieved with a simple five-minute discussion and demonstration. When using an eyewash station or emergency shower the process involves:

1. Pushing or pulling the handle to activate the water flow.
2. Removing contact lenses and clothing if applicable. Contact lenses can trap hazardous chemicals in the eyes and prevent the eyewash from washing out the hazardous chemical. Similarly, clothing can trap hazardous chemicals close to the skin. The eyes will naturally want to close. Holding the eyes open will allow adequate flushing.
3. Flushing the eyes and skin for at least 15 minutes.
4. Seeking further medical attention.

It is also important for workers to understand how to respond when another employee’s eyes or skin are exposed to hazardous chemicals. In the event of an emergency, coworkers should help the exposed worker get to the eyewash or shower and turn it on. Help the exposed worker hold their eyes open, remove contaminated clothing, and call for medical assistance. While it can seem like an eternity, they must make sure to flush the eyes and skin for at least 15 minutes. In the event that emergency services are called, noting the chemical’s name, and providing the appropriate safety data sheet is helpful for those administering treatment.

Conclusion

Emergency equipment such as eyewashes and showers are no substitute for safe work procedures and personal protective equipment. However, should the unthinkable happen, properly maintained equipment can minimize injuries resulting from chemical exposure. Remember, safety doesn’t have to be difficult. Simple steps such as inspecting and maintaining emergency eyewashes and showers, can prevent serious injuries.

Related Links:

• Root Cause Analysis:  The Five Why’s
• Commitment vs Compliance
• Full Course Catalog – Safety Made Simple

References:

• EHS Today “Protecting Those Peepers: A Guide to Eye Wash and Emergency Shower Stations”
• Paul Lawton, “What Workers Need to Know About Eyewashes and Safety Showers” March 25,2014
• EHS Today “A Logical Approach to Emergency Shower and Eyewash Choices” www.ehstoday.com/print/content/21915183

Hazard monitoring equipment can prevent grain dust explosions, save lives, and protect your facility from collateral damage. I have always referred to these systems as “cheap insurance.” The up-front investment pales in comparison to the impacts an explosion has on employees, facility infrastructure, and business interruption.

Ignition Sources

There are three primary ignition sources that can ignite suspended dust within the confinement of a bucket elevator. These ignition sources include heat generated by the belt slipping on the head pulley, the belt rubbing against the bucket elevator’s casing, and overheated bearings. Research indicates that the majority of grain dust explosions can be traced back to these three ignition sources.

Belt Slip

Belt slip occurs when the belt is loose or overloaded. It can only be detected by monitoring the speed directly from the belt or indirectly by monitoring the boot pulley rotations per minute (rpm). A 3-phase induction motor runs at a constant speed independent of its load. Therefore, a single sensor can be used to detect belt speed. The sensor is usually mounted by the boot pulley to detect the rpm of a target attached to the shaft or on the casing to detect the speed of the passing bucket’s bolts.

OSHA establishes requirements for belt speed detection in standard 1910.272 – Grain Handling Facilities. The standard requires employers to equip inside bucket elevators with a motion detection device that will shut down the bucket elevator when the belt speed is reduced by no more than 20% of the normal operating speed. An inside bucket elevator is a bucket elevator that has the boot and more than 20 percent of the total leg height (above grade or ground level) inside the grain elevator structure. Bucket elevators with leg casings that are inside of rail or truck dump sheds, with the remainder of the leg outside of the grain elevator structure, are not considered inside bucket elevators.

The OSHA requirement for belt speed detection does not apply to grain elevators having a permanent storage capacity of less than one million bushels, provided that daily visual inspection is made of bucket movement and tracking of the belt.

Belt Rubbing

Bucket elevators have sidewalls or casings that misaligned belts can rub against. Heat generated by the frictional rubbing can ignite dust inside the bucket elevator. Limit switches, brass rub blocks, optical sensors, non-contact sensors, and solid-state touch switches are used to detect improper alignment. OSHA standard 1910.272 – Grain Handling Facilities requires that inside bucket elevators be equipped with a belt alignment monitoring device which will initiate an alarm to employees when the belt is not tracking properly.  Or, be equipped with a means to keep the belt tracking properly. The requirement for belt alignment monitoring does not apply to grain elevators having a permanent storage capacity of less than one million bushels. This is provided that daily visual inspection is made of bucket movement and tracking of the belt.

Bearings

Bearings create frictional heat when running. When properly lubricated, bearings usually run below the temperatures needed to ignite grain dust. If the bearing’s lubricant fails, heat can build up rapidly. This can ignite dust that has accumulated on or around the bearing or transfer heat to the interior of the bucket elevator. Bearing temperature monitoring systems monitor bearing temperature continuously. These systems consist of a bearing sensor mounted to the bearing housing and wired to an alarm control panel or programmable logic controller (PLC).

OSHA standard 1910.272 (link)

Grain Handling Facilities requires that bearings on inside bucket elevators be mounted externally to the leg casing. If this is not the case, the bearing must be equipped with temperature monitoring, vibration monitoring, or other means to monitor the condition of those bearings mounted inside or partially-inside the leg casing.

There are additional exceptions within the standard that negate the requirement for belt speed, belt alignment, and bearing temperature monitoring. One exceptions is for bucket elevators equipped with an operational fire and explosion suppression system capable of protecting at least the head and boot section of the bucket elevator.  Another exception is when bucket elevators are equipped with pneumatic or other dust control system methods that keep the dust’s concentration inside the bucket elevator. The concentration inside the bucket elevator must be at least 25% below the lower explosive limit at all times during operation.

Today’s hazard monitoring systems can incorporate inputs from a number of different sensors such as belt speed, belt alignment, and bearing temperature. The system can be read from a wall mounted control panel, computer, and even a mobile phone app. Systems can also be interlocked to shut down the bucket elevator leg as well as upstream and downstream equipment. Hazard monitoring systems require regular preventive maintenance and inspection to ensure proper operation. The system should be tested in accordance with the equipment manufacturer’s requirements.

Conclusion

It is important that operations employees understand the purpose and importance of hazard monitoring equipment. It may save their life. Train employees to shut down equipment when the hazard monitoring system indicates a hazardous condition. Employees should also:

• refrain from bypassing or turning off the system,
• notify management if the system is not working correctly or damaged during housekeeping and maintenance activities, and,
• never disregard an alarm or hazardous condition.

Hazard monitoring systems are an effective means to prevent grain dust explosions. Many companies have expanded these systems to include exterior bucket elevators and interior/exterior conveyance. These systems provide a greater level of safety and a form of “cheap insurance.”

Related Links:

• Harvest Safety Strategies
• Combustible Dust in Agriculture and Processing Facilities
• Full Course Catalog – Safety Made Simple

 

Joe Mlynek is a partner and subject matter expert at Safety Made Simple, LLC. He has over 20 years of experience in safety at the corporate level and as a consultant. He is a Certified Safety Professional (CSP) and Occupational Safety and Health Technician (OHST). Joe can be reached at [email protected]

 

The following information is part of a report released by Purdue University’s Agricultural Safety and Health Program. This report is on reported agricultural confined space incident related injury and fatality cases documented during 2022. The program has documented and, entered into Purdue’s Agricultural Confined Space Incident Database, more than 2,460 fatal and non-fatal agricultural confined space cases since 1977.

Historical Statistics by OSHA Region

Agricultural confined space-related cases have occurred in every OSHA region but tend to be concentrated in regions 5 and 7.

• Region 5 has accounted for 43.8% of all agricultural confined space cases (1,017), with 58.3% of those cases being grain entrapments, and 12.6% being falls.
• Region 7 accounted for 560 cases (24.1% of the U.S. total) with grain entrapments, asphyxiation, and entanglements representing 83.2% of those cases.
• Region 1 represented the region with the smallest number of grain entrapments while Region 6, interestingly, represented the region with the highest percentage of total documented cases being grain entrapment cases (71%).

Agricultural confined case distribution by OSHA region from 1962-2022.

Grain Entrapments

There were 42 fatal and non-fatal grain entrapment cases documented in 2022. This represented a 44.8% increase from the 29 recorded in 2021 and substantially higher than the 5-year average (34.8 cases/year). The total of combined fatal and non-fatal grain entrapment cases was the highest annual frequency over the past decade. Nevertheless, the 5-year running average continues to be below its peak of 40.4 in 2011. Of the reported entrapment cases in 2022, 35.7% resulted in a fatality, lower than the five-year average. In 2022, the state with the most documented grain entrapments (fatal and non-fatal), was Iowa with nine. Minnesota followed with five, and both Indiana and Missouri had four cases each. Overall, grain entrapments were documented in 16 states in 2022. The majority of grain entrapment cases occurred in the Midwest, or Corn Belt states (64.3%).

Gender and Age

All documented grain entrapment cases in 2022 involved males. Five (12%) involved youth under the age of 21, a demographic that has represented up to 20% of cases in the past. The oldest victim of grain entrapment was 75. The average age was 41.3 years old, and the median age was 42. In over 52.4% of the cases, the specific age could not be documented. However, a review of the reports strongly indicates that nearly all were adults.

 

With over two-thirds of U.S. grain storage capacity being on farms that are exempt from OSHA injury reporting requirements, it is highly likely that this summary does not encompass all grain-related entrapments, whether resulting in death or not.

Contributing Factors

As found by Kingman nearly 20 years ago, there is a direct relationship between the probability of an entrapment in grain and the presence of out-of-condition, or spoiled grain. For many years, the term “flowing grain” was used to identify the entrapment hazards associated with grain storage and handling, when in fact it is non-flowing grain that poses the greatest risk. Nearly all cases examined in 2022, in which adequate details were available, involved grain that was non-flowing due to spoilage.

Contributing factors included attempting to store grain at moisture content levels above 14%, improper in-bin drying practices such as rewetting grain using moist outside air, and leaks in the structure that allowed moisture to have access to dry grain. In other words, far more grain-related entrapments could have been prevented (and lives saved) by promoting proper storage techniques than could be achieved with providing training on emergency grain rescue strategies.

Non-Grain Bin Related Incidents

Injuries and fatalities involving agricultural waste storage and handling facilities, transport equipment, and other livestock waste-related operations have been monitored as part of Purdue’s Agricultural Confined Spaces-related Incident Database (PACSID). These operations include aerobic digesters, bio-gas generators, and other confined spaces used to store and process waste. Approximately 505 related fatalities or serious injuries have been documented in the PACSID.

Findings

Findings gathered between 1975 and 2021 were summarized by Nour, et al. (2021). This summary analyzed a total of 409 incidents involving 486 individuals, out of which 288 (59%) were fatal. Of the total, 85% of these victims were male. Their average age was 37, remarkably younger than the average age of U.S. farmers. This indicates that youth and less experienced farmers were more prone to agricultural waste-related incidents.

The most frequently identified incidents involved underground and underfloor manure storage facilities, above-ground manure storage tanks, sump pits, ponds, lagoons, manure digesters, and manure transport vehicles such as portable tankers, applicators, and spreaders. Fifty-three of the incidents, or approximately 11% of all cases documented, involved multiple victims.

Breakdown

Historically, there were 11 injuries and fatalities documented in 2020 related to livestock waste, out of which 5 (45%) were reported as fatal. The number of cases documented in 2021 jumped to 13 incidents involving 16 individuals (cases). Of these cases, 12 were fatal (75%). This doubled the number of fatalities documented in 2020.

In 2022, 11 incidents involving 11 individuals were documented. Out of the 11, 8 cases were fatal (73%). All the victims were male, including a 16-year-old youth. The ages of four of the victims were undetermined. The oldest victim was age 74. Three of these incidents occurred in Wisconsin, and two in California. Ohio, New York, Minnesota, Indiana, Maryland, and Pennsylvania each reported one case in 2022. In addition, there were 8 non-fatal roadway collision incidents involving livestock waste transport vehicles.

The most frequently identified activity causing confined space incidents injuries or fatalities in 2022 was performing maintenance tasks in or around manure storage structures, such as pump repairs or service. This has been the most frequent activity identified in all cases documented since 1975.

We would like to thank Dr. Bill Field, Professor at Purdue’s Agricultural and Biological Engineering Department, and his staff for the information provided and their continued efforts to prevent injuries and fatalities in agricultural confined spaces.

Related Links:

• Confined Space Entry Training
• Oxygen Deficiency in Confined Spaces
• Full Course Catalog – Safety Made Simple

 

Joe Mlynek is a partner and subject matter expert at Safety Made Simple, LLC. He has over 25 years of experience in safety at the corporate level and as a consultant. He is a Certified Safety Professional (CSP) and Occupational Safety and Health Technician (OHST). Joe can be reached at [email protected]

I once had a conversation with a safety manager that ended with, “I’m sorry, but I have to cut our call short. One of our managers just fell off a railcar.” Imagine falling 15 feet to the ground below. The very thought brings to mind images of debilitating injuries and possibly death. Fortunately, fixed horizontal railcar fall protection systems can prevent these types of incidents.

Fall Protection Systems

Fixed horizontal railcar fall protection systems can be rigid or flexible. Flexible systems use a pliable horizontal lifeline, such as steel cable or synthetic rope, secured at each end by an anchorage. A rigid system utilizes a solid structure such as a pipe, channel, or I-beam to provide continual anchorage. Both rigid and flexible systems require the worker to connect the dorsal D-ring of their body harness to a self-retracting lifeline (SRL) attached to the system. Once attached, they can safely access and traverse the top of a car or string of cars.

SRLs come in a variety of lengths. A carabiner connects the SRL to the sliding connection on the horizontal system. An SRL has an automatic retraction system, similar to the seatbelt in a vehicle. SRLs are spring-loaded to prevent the build-up of slack. During a fall, impact, or load the internal braking mechanism of the SRL will lock. This happens when the lifeline retracts at a speed of four and a half feet per second. The braking mechanism remains locked until the tension is released.

Preventing Injuries

Workers cannot only be injured falling from a car but also when climbing railcar ladders or stepping onto cars. Therefore, workers should connect to the SRL prior to climbing the car’s ladder or stepping onto the car from a platform or gangway. While on top of cars, workers are encouraged to use the “tug and walk” technique. This requires the worker to grab the SRL’s cable just above the snap hook and give it a firm tug to engage the braking system. Once engaged, the worker can travel along the top of the car while maintaining their balance and keeping the overhead connection above the head to eliminate swing fall hazards. To minimize swing fall hazards, workers should never walk more than five feet from the overhead connection.

Inspections and Best Practices

It is important to routinely inspect the components of the railcar fall protection system. A competent person should inspect each SRL and system components at least annually. Workers must inspect both the body harness and SRL before and during the work shift. Harnesses must be checked for mildew, damage, and deterioration. The SRL must be inspected for proper retraction and braking, cracks or distorted parts, damage to the lifeline, proper operation of the snap hook and load indicator activation. SRL units are equipped with load or impact indicators. Many load indicators are located at the swivel part of the snap hook. The swivel eye will elongate and expose a red indicator when exposed to the forces associated with a fall. When a load shocks an SRL, it must be taken out of service and returned to the manufacturer for repair and recertification.

The SRL lifeline should be fully retracted when not in use. Workers must avoid attaching the snap hook to handrails or other attachment points. Storing the unit in this manner can cause the retraction springs to fatigue. Tag lines can be used to allow the unit to fully retract into the housing and to retrieve the snap hook for accessing the ladder, platform, or gangway.

Conclusion

Fixed horizontal railcar fall protection systems aren’t cheap, but they are well worth the investment. If you have a system at your facility, make sure to inspect the system and components routinely and make sure that employees understand the system’s purpose, components, the tug and walk technique, as well as the importance of inspecting their harness and the SRL. Remember, safety doesn’t have to be difficult, simple steps can prevent injuries and save lives.

Related Links:

• Fall Protection Equipment Inspections
• Fall Protection Calculations
• Full Course Catalog – Safety Made Simple

 

Joe Mlynek is a partner and subject matter expert at Safety Made Simple, LLC. He has over 25 years of experience in safety at the corporate level and as a consultant. He is a Certified Safety Professional (CSP) and Occupational Safety and Health Technician (OHST). Joe can be reached at [email protected]

Ask any well-trained employee entering confined spaces what their main concern is, and they will most likely say, “oxygen deficiency.” Notice the use of the words “well-trained.” Oxygen deficiency in confined spaces isn’t something we can see with our eyes. However, if we can educate employees on the causes, symptoms, and health effects oxygen deficiency as well as the importance of atmospheric monitoring, we can send them home safely.

The air we breathe contains approximately 20.9% oxygen, 78% nitrogen, and smaller quantities of gases such as argon and carbon dioxide. The immediate effects of low oxygen environments can be traced to the body’s oxygen transport system. Blood absorbs oxygen from air in the lungs to fuel cells in the body. The body organ most sensitive to lack of oxygen is the brain. A person will immediately begin to feel the health effects associated with lack of oxygen with decreases of 1 to 2 percent.

Healthy individuals are unable to work strenuously or lose coordination when oxygen levels are between 15 and 19 percent. When oxygen levels are between 10 to 12 percent respiration increases, lips turn blue, and judgement is impaired. Fainting and unconsciousness occur when oxygen levels are between 8 and 10 percent. Death can occur within eight minutes if the oxygen level is between 6 and 8 percent. These values may vary based on several factors including the person’s health, the level of physical activity, and the environment.

OSHA Respiratory Protection Standard 1910.134

The Occupational Safety and Health Administration’s (OSHA) Respiratory Protection Standard 1910.134 defines oxygen deficiency as an atmosphere with an oxygen content below 19.5% by volume. OSHA’s Permit Required Confined Space Entry Standard 1910.146 and Grain Handling Standard 1910.272 also recognize that an atmosphere with less than 19.5% oxygen is hazardous. Many safety professionals agree that entry into any hazardous space or other area where oxygen deficiency may exist requires the oxygen levels to be as close to normal as possible. For instance, an atmospheric level of 20.5%, while still acceptable to OSHA, signals that there is an issue that needs to be investigated and addressed.

Causes

A number of factors can cause oxygen deficiency when in confined spaces. In general, oxygen deficiency occurs when another gas displaces oxygen in a poorly ventilated space. For example, decomposition of organic material or smoldering grain can consume oxygen within a space such as a grain bin, silo, or tank. Grain that is high in moisture or poor in quality can result in elevated levels of carbon dioxide. Carbon dioxide can displace oxygen within spaces such as grain bins, silos, tanks, and even flat storage buildings. Carbon Dioxide is denser than air. Therefore, it can also accumulate in low-lying areas adjacent to confined spaces.

Identification

A worker cannot see, taste, or even smell an oxygen deficient atmosphere in a confined space. The only way to identify oxygen deficiency is to test the air with a calibrated atmospheric monitor. According to OSHA, calibration refers to an instrument’s measuring accuracy relative to a known traceable concentration of test gas. Atmospheric monitors must be calibrated according to manufacturer guidelines. Keep in mind that calibration gases have an expiration date. Calibration gases that have expired should be replaced immediately.

In addition to calibration, a “bump test” should be performed prior to each use. According to OSHA, a bump test is a qualitative function check in which a challenge gas is passed over the sensor(s) at a concentration and exposure time sufficient to activate all alarm settings. The purpose of this check is to confirm that gas can get to the sensor(s) and that all the instrument’s alarms are functional. The bump test does not provide a measure of the instrument’s accuracy.

Conclusion

Both OSHA’s Permit Required Confined Space and Grain Handling Standards require atmospheric testing prior to entry into hazardous spaces. Many safety professionals agree that performing a pre-entry test alone is not adequate. The atmosphere in an area where oxygen deficiency may exist should be continually monitored throughout the entry. Atmospheres within confined spaces can change. Monitoring the atmosphere continually during entry is the best way to protect employees working in confined spaces.

Remember, safety doesn’t have to be difficult, simple steps, such as training employees on the causes, symptoms, and health effects of oxygen deficiency, and implementing pre-entry and continual atmospheric monitoring can send employees home safely.

Related Links:

• Confined Space Entry Training
• Root Cause Analysis: The Five Whys
• Full Course Catalog – Safety Made Simple

References

• Pearce, Nancy. “Oxygen Deficient Environments in Confined Spaces”. Web blog post. nfpa.org. NFPA today, 13, Nov. 2012.
• Naranjo, Edward. “Oxygen Deficiency: The Silent Killer.” EHS Today, 12 Dec. 2007.
• Nolte, Jim, Wisconsin Agribusiness Association. High Moisture New Crop Corn Has Potential to Generate Low Oxygen and High Carbon Dioxide Levels in Boot Pits, Bins and Basements.

 

Joe Mlynek is a partner and subject matter expert at Safety Made Simple, LLC. He has over 25 years of experience in safety at the corporate level and as a consultant. He is a Certified Safety Professional (CSP) and Occupational Safety and Health Technician (OHST). Joe can be reached at [email protected]

Workers in grain elevators as well as milling and processing facilities are no stranger to combustible dust. Many have experienced the power of these tiny particles first-hand or have seen pictures of the damage caused by dust explosions. If you’ve ever wondered the determining factors that make dust combustible, you’ve come to the right place.

Defining Combustible Dust

The National Fire Protection Association (NFPA) defines combustible dust as a “combustible particulate solid that presents a fire or deflagration hazard when suspended in air, or some other oxidizing medium, over a range of concentrations, regardless of particle size or shape.” The NFPA further defines combustible dust as “a finely divided organic or metal material, typically 420 microns or smaller.” Combustible dust is capable of causing an explosion when adequate oxygen is present, the dust is suspended in air at the right concentration, a sufficient source of heat is present, and when confined within a structure such as a bin, silo, tank, building, or piece of equipment.

Dust Explosion Chain Reactions

Combustible dust from commodities including wheat, milo, oats, soybeans, rice, hops (malted) and barley can create an explosion under the right conditions. In addition to these materials dust from other agricultural derived materials are also explosive. These materials include wheat and oat flour, cottonseed, sugar, rice starch, potato flour, rye flour, corn meal, corn starch, and semolina. These types of materials are generally handled in facilities that process products for human or animal consumption.

Components of Combustible Dust

There are three key components that determine the combustibility of dust. The components include the Minimum Ignition Energy (MIE), Minimum Explosive Concentration (MEC), and the Deflagration Index, commonly referred to as the Kst value. The Minimum Ignition Energy (MIE) is the smallest amount of heat or electrical energy that is needed to ignite a dust in air mixture. The MIE is measured in millijoules. The table below indicates the millijoules required to ignite a dust in air mixture based on the commodity or product listed. The lower the MIE the more volatile or explosive the material.

The Minimum Explosive Concentration (MEC) is the minimum concentration of combustible dust suspended in air, measured in mass per unit volume that will support deflagration. Deflagration is defined as combustion that propagates through a gas or across a surface of an explosive at subsonic speeds, driven by the transfer of heat. Put simply, deflagration is the heating of a substance until it burns away rapidly. The MEC is dependent on the size of the particle, the ignition temperature, and the amount of oxygen in the air. In order for a dust explosion to occur, the dust concentration must be between the lower explosive limit and upper explosive limit. Depending on the type of dust and the size of the particles research suggests that the MEC range for grain dust is approximately 50 to 150 grams per cubic meter.

Deflagration Index (Kst Value)

The Deflagration Index (Kst Value) indicates how large an explosion would be by measuring the maximum rate of pressure rise for most favorable dust in air mixtures. The larger the Kst value, the more violent the explosion. For example, the generally accepted Kst value for grain dust is 89 bar-meters per second and the Kst value for corn starch is 202 bar-meters per second. Particle size has a direct relationship to the Kst value in this example. Refined corn starch particles are smaller than grain dust.

Testing dust to determine the Kst value is essential for equipment design. Kst values are used by manufacturers and engineers to validate the design of protection systems including spark detection, deflagration venting, and explosion suppression and explosion containment. Understanding the Kst value is particularly important in processing facilities where commodities are processed or milled. These processes create smaller particle sizes that directly correlate to explosion severity.

Conclusion

Understanding dust combustibility is the first step to preventing dust explosions. With this understanding an organization can identify engineering and administrative controls that can help prevent grain dust explosions and send employees home safely.

Suggested Links:

• Grain Dust Explosion Prevention
• Grain Dust Explosions
• Course Catalog – Safety Made Simple

References

Occupational Safety and Health Administration (OSHA), Hazard Communication Guidance for Combustible Dusts, 2009.

Jones, Carol. Oklahoma State University, Division of Agricultural Sciences and Natural Resources. Preventing Grain Dust Explosions. Stillwater, OK. Oklahoma State University.

Jarc, Christopher. A. Article Title: Combustible Dust Basics. Retrieved from www.hixson-inc.com.

Truck drivers carry a great deal of responsibility on the roads. Having the right skills and knowledge to safely operate their vehicles keeps them safe and protects other motorists. While truck drivers undergo a specific exam to get their commercial driver’s license, additional trucking safety and compliance training can upskill drivers to operate their vehicles with added confidence.

Trucking Safety Training

Truck drivers face unique challenges on the roads. They must drive large vehicles with care and comply with Federal Motor Carrier Safety Administration (FMCSA) standards to keep everyone on the road safe. Trucking safety training focuses on the issues that professional truck drivers face and provides them with skills and defensive strategies to avoid accidents and truck-related incidents.

After completing a truck driver safety program, drivers can navigate the roads more safely. Enrolling in this training can reduce your truck driver-related risks and teach drivers how to better manage any situation they may face.

Essential topics of professional truck driver safety include:

• Collisions: This area covers how to avoid crashes under various circumstances and environments.
• Backing up: Drivers learn how to avoid backing, and if a driver does need to back their truck up, they are made aware of the hazards.
• Following distance: The safe following distance will vary depending on the weather conditions. It’s essential that truck drivers know how to measure this distance.
• Bad weather: Poor weather conditions require extra care and drivers to pay attention to traction and visibility.
• Lane changing: This topic covers procedures like signaling well in advance and correctly checking blind spots.==Workplace Situational Awareness==

Workplace Situational Awareness

Truck Safety and Compliance Standards

If your truck drivers are traveling from one state to another, they must be aware of the rules and regulations in each state. Most states follow the safety rules and regulations implemented by the FMCSA. Having a clear understanding of the laws will keep your truck drivers safe on the roads.

While the FMCSA has many important rules that govern carrier, vehicle and driver safety, the following are essential for truck driver safety:

1. Commercial Driver’s License (CDL)

A professional truck driver must have a commercial driver’s license to drive a large truck. Operating a commercial vehicle like a truck requires expertise and mental and physical abilities that are tested through an appropriate exam and driving test. Business owners must also ensure that drivers don’t have a history of negligence or reckless driving.

2. Driver’s Log Book or Electronic Logging Device (ELD)

Truck drivers are only allowed to drive for a maximum of 11 hours following 10 off-duty hours and may not drive for more than 70 hours over eight consecutive days. The drivers record the hours worked and the miles traveled in the log book or ELD.

3. Vehicle Maintenance

Maintaining the truck is required by the FMCSA and keeps your truck drivers safe while traveling. Truck drivers need to be aware of the condition of components like tires and lighting devices and the braking system must be in working order. Cargo must be secure, mirrors and vision assistance must be available, and emergency equipment needs to be on hand.

Truck Driver Safety Issues

Education and awareness of potential safety issues help you and your drivers prepare for what may come. Safety training for trucking companies should cover concerns like:

1. Weight Limits

Federal weight limits clearly state how much weight trucks may carry. Overloading a truck, even by a small amount, makes a big difference. The regulations are in place to ensure your vehicles can safely transport their weight in any environment and weather condition. Securing the load is also important. Loose cargo is a hazard that can cause injury or accidents.

2. Speed Limit

It’s tempting for truck drivers to exceed the speed limit to make deliveries quickly. Trucks are significantly heavier than motor vehicles, which makes braking at high speeds challenging. Maintaining the correct speed limit keeps truck drivers and other motorists safe.

3. Fatigue

Driving for a long time is unsafe for any driver, especially commercial truck drivers. Fatigued drivers are more likely to have an accident, which is why adequate rest and breaks are vital. Truckers must find a safe place to pull over and take a break at the first sign of fatigue.

4. Driver Distraction

Driving a large truck requires concentration. Being on the phone or texting distracts truck drivers and puts the lives of others at risk. Staying informed on the roads is essential, but drivers need to take care that telecommunications don’t take their attention away from the road.

Safety Tips for Truck Drivers

Before heading onto the road, truckers need to feel comfortable and confident operating their vehicles. The better equipped they are to face the challenges on the road, the safer they can be. Safety tips include:

• Always wear a seat belt: Safety starts with wearing a seatbelt. It helps prevent injuries and fatalities should an accident happen.
• Check blind spots: Vehicles in a truck’s blind spot aren’t immediately visible. Drivers must check their mirrors every 8-10 seconds.
• Consider stopping distance: Leaving a distance of up to two football fields between the truck and the car in front gives drivers enough space to stop safely.
• Make wide turns: A large truck needs more space and time to make a wide turn. Drivers should carefully slow down and signal in advance to safely make a wide turn.
• Always signal: Truck drivers must signal well in advance to show their intent.
• Plan ahead: Being prepared can help your drivers arrive safely. They can plan their trip by looking up the weather, road conditions, detours, and height and weight restrictions.
• Remain calm: Other cars may cut off your driver on the road. It may be tempting to react, but road rage never solves anything. Encourage your drivers to stay calm and create distance between themselves and the angry driver.
• Prepare for emergencies: Long-distance travel is unpredictable. Drivers may encounter bad weather, a breakdown or road closures. Drivers can prepare for their trip with emergency kits, refreshments, and an overnight bag with toiletries and a change of clothes.
• Do pre- and post-trip inspections: The FMCSA requires these inspections. To help protect the safety of your drivers, it is wise to enroll them in training to help them carry out these inspections thoroughly.

 

View Our Driver Safety Courses Today

Enrolling your truckers in a truck driver safety program helps provide them with added skills and knowledge, such as defensive driving for commercial drivers, which can decrease their risk of being in an accident. Safety Made Simple offers safety training to equip your drivers with the necessary knowledge and expertise. Check out our courses online to enroll today.

Joe Mlynek is a partner and subject matter expert at Safety Made Simple, LLC. He has over 20 years of experience in safety at the corporate level and as a consultant. He is a Certified Safety Professional (CSP) and Occupational Safety and Health Technician (OHST). Joe can be reached at [email protected]

Communicating is something we all do. But when did you last consider how effective your communication is in the workplace? What would your employees say? Getting communication right is something you can achieve — it just takes consideration and intentionality. Let’s look at the steps you can take to become an excellent and effective communicator.

What Is Effective Communication?

Effective communication gets your point across in a clear and understandable way. Communicating effectively in the workplace is the foundation of all you do. Everyone must be on the same page to work together as a team and meet your business goals. Effective communication goes much deeper than the words you say or the emails you send out to your team. As a supervisor, your goal is to figure out whether each employee understands your communication and is on board.

Employees feel they belong when there is a common understanding within your team. It boosts engagement and improves job satisfaction. Many believe that effective communication ends with eloquent words and easy-to-follow directives, but you truly become an effective communicator once you actively listen.

5 Types of Effective Communication

You may be familiar with the four types of communication — verbal, non-verbal, written and visual — but one other form needs to be utilized: active listening. An effective communicator can successfully use these five types of communication in the appropriate workplace situations.

1. Verbal Communication

Verbal communication is all about the words you say and how you speak. Some verbal communication methods in the workplace include presentations, in-person meetings, phone calls and even casual conversations.

How do you make your team feel when you speak? When presenting the company goals, are you enthusiastic in your delivery? Your tone is contagious and plays a role in how your team will respond to your communication. Verbal communication is a two-way street, so make sure you leave time for employees to ask questions and give feedback.

2. Non-Verbal Communication

Effective communicators know body language is just as important as words. Preparing an excellent presentation and saying what your team wants to hear may be easy, but the true meaning of what you say is communicated through your body language.

Research shows that 55% of effective communication is done through body language. Non-verbal communication involves posture, facial expressions, eye contact and and physical behavior. When your non-verbal communication matches your verbal communication, your message is sincere and is better received.

3. Written Communication

Written communication includes emails, messages, notices and any other written formats you may have in the workplace. Similar to verbal communication, keeping written messages concise and clear helps improve understanding and ensure the message is well received.

Pay attention to grammar, punctuation and spelling. Errors in written communication can distract readers from the essence of the message.

–Effective Communication Approachs–

4. Visual Communication

Visual communication is helpful when you need to communicate a complicated message. Charts, graphs, videos and infographics help break down complex information into a message that is easier for individuals to understand.

5. Active Listening

Active listening is essential for supervisors and other team members. Often, the focus is on speaking, but effective communication and active listening go hand-in-hand. Actively listen to your team to gain a deeper understanding and lead by example.

Give the individual your full attention and acknowledge that you are listening through non-verbal communication, such as nodding and eye contact. Pay attention to their body language for greater context to the true meaning. If you have questions, wait until they finish speaking, and show you understand by paraphrasing what they said. Active listening improves relationships with your team and shows you support and value their opinions.

Benefits of Effective Communication

To reach a common goal as a team, you need everyone to be on the same page. Effective communication unites and creates a supportive environment for employees to work together toward a common goal. Let’s take a look at some of the benefits:

• Reduces conflict: Miscommunication is how many conflicts begin. Team members can better understand and empathize with one another by practicing clear and effective communication.
• Improves working relationships: When employees feel understood and valued, it strengthens the bond within your team.
• Increases loyalty: When you value your employees, you want them to remain for the long term. Employees who feel valued and heard will uphold their commitment to your business.
• Encourages engagement: If you show your employees their contribution matters, it encourages them to continue speaking up. Team members want to see their valuable ideas accepted and implemented.
• Drives morale: Workers are motivated to do well when they understand how their roles contribute to the business’s success. When you communicate the importance of their work and provide constructive feedback, employees are empowered to carry out their roles effectively.

Workplace Communication Tips

Now you know what effective workplace communication is and why it’s essential for achieving success in your business, but how do you implement it in your workplace?

1. Keep It Clear and Concise

You want your team to understand and remember the important information from your communication. If it is filled with unnecessary details, they might lose interest or disregard the message completely. You can get straight to the point and be clear and accurate to avoid confusion.

Planning and creating a communication strategy will help you highlight the main points and stay on topic. Keep your goals in mind before you begin communicating, whether you want to educate your team on safety measures or change their minds about something.

2. Choose the Right Time

Schedule a meeting if you need a long time to communicate an important messa

ge. Your message will be lost if you approach an employee when they are busy. If you need their full attention, it’s better to set up a time that works for both of you.

3. Follow Up

Continue to ask questions after the initial meeting. Ensure employees understand how the communication affects them and reassure them that their contribution matters. If there are any misunderstandings, address them sooner rather than later to prevent any conflict or resentment from building up.

4. Give Feedback

Employees also need to know when they are doing well! Positive feedback helps to improve morale, shows workers they are valued and encourages more open communication. If you want your employees to give their best effort and approach their work positively, offer encouraging feedback.

Check out Safety Made Simple’s Workplace Communication Courses Today

We want to help you create a better work environment by improving your workplace communication. When you know how to communicate with your employees effectively, you can work together and achieve success for your business. Check out our workplace communication courses online!

Joe Mlynek is a partner and subject matter expert at Safety Made Simple, LLC. He has over 25 years of experience in safety at the corporate level and as a consultant. He is a Certified Safety Professional (CSP) and Occupational Safety and Health Technician (OHST). Joe can be reached at [email protected]

I recently assisted a company with their annual fall protection equipment inspections. It was a tedious and monotonous task but well worth it. Throughout the process we removed numerous body harnesses, connectors, self-retracting lifelines, and safety ropes. Each piece of equipment removed from service was a reminder of the importance of the pre-use and annual inspection process. In theory, if users were effectively inspecting the equipment, we would not remove anything from service. Although I am optimistic, I have yet to see this happen.

According to OSHA…

According to the Occupational Safety and Health Administration (OSHA) 1910.140 Personal Fall Protection Systems (General Industry): “Personal fall protection systems must be inspected before initial use during each work shift for mildew, wear, damage, and other deterioration, and defective components must be removed from service.” Similarly, for those in the Construction Industry, OSHA 1926.502 Fall Protection requires that “personal fall arrest systems shall be inspected prior to each use for wear, damage and other deterioration, and defective components shall be removed from service.”

Fall Protection Calculations

In addition to pre-use inspections, ANSI Z359.1 requires that fall protection, including rescue equipment, be inspected on a regular basis not to exceed one year (or more frequently if required by manufacturer’s instructions) by a competent person or a competent rescuer, as appropriate, to verify that the equipment is safe for use. While ANSI standards are considered voluntary or “best practice” it is strongly recommended that fall protection equipment be inspected at least annually by a competent person. ANSI considers a competent person an individual knowledgeable of fall protection equipment, including manufacturers recommendations and instructions for proper use, inspection, storage, and maintenance. The competent person must also be capable of identifying hazards and have the employer’s authority to take prompt corrective action to the eliminate or control those hazards, and is knowledgeable of the laws, regulations, and standards regarding fall protection equipment and systems.

Pre-Use Inspections

OSHA does not require documentation of pre-use inspections. Keep in mind that during an inspection an OSHA compliance officer could ask employees about pre-use inspection practices. Many companies choose to document pre-use inspections or incorporate inspections into their daily hazard analysis processes to ensure completion.

As mentioned earlier, annual competent inspections required by the ANSI standard are considered voluntary or “best practice.” It is strongly encouraged that annual competent person inspections be documented in an effective manner. This can be as simple as having the competent person initial and date the equipment’s inspection tag or label. The preferred option would be to also document the inspection to include the name of the inspector, date of the inspection, description of the equipment to include model number and serial number, manufacture, date of manufacture, whether the equipment passed or failed the inspection along with the reason, and the outcome (i.e., removal from service, sent to manufacture for repair, etc.). This option also provides the organization with detailed records and an inventory of equipment currently in service.

Service Life

A common question around fall protection equipment, particularly body harnesses and connectors, is how long they are good for or whether they expire. OSHA and ANSI do not reference a maximum service life for synthetic fiber products. They do require that the user remove the equipment from service if it has been subjected to the forces associated with arresting a fall. Similarly, both ANSI and OSHA standards reference that when an inspection reveals defects or damage that the equipment be removed from service.

Some manufacturers still define an estimated or recommended service life, usually five years. Many organizations adhere to these recommendations and remove equipment after the five-year service life while others rely on pre-use and annual competent person inspections to determine whether equipment is fit for duty.

Conclusion

When establishing fall protection equipment inspection requirements at your organization, consider requiring an annual competent person inspection along with effective documentation. This will result in the removal of unsafe equipment from the work environment and evaluate the effectiveness of pre-use inspection activities. Remember, safety doesn’t have to be difficult, simple steps, such as incorporating fall protection equipment inspections into daily hazard analysis processes, can prevent injuries and save lives.

Here at Safety Made Simple, our team of safety experts create content and courses that help send your people home safely. Check out our Safety Scoop newsletters to see some of the topics we cover!

Joe Mlynek is a partner and subject matter expert at Safety Made Simple, LLC. He has over 25 years of experience in safety at the corporate level and as a consultant. He is a Certified Safety Professional (CSP) and Occupational Safety and Health Technician (OHST). Joe can be reached at [email protected]

Core Elements of an Effective Program

The Occupational Safety and Health Administration (OSHA) promulgated the standard for The Control of Hazardous Energy (Lockout Tagout), Title 29 Code of Federal Regulations (CFR) Part 1910.147 in 1982. The standard is responsible for preventing numerous injuries and fatalities since it went into effect in 1989. Lockout tagout is defined as specific practices and procedures to safeguard employees from unexpected energization or start-up of machinery or equipment or the release of hazardous energy during servicing or maintenance. This blog will discuss the core elements of an effective lockout tagout program.

Lockout Tagout Basics

Energy Control Procedures

The OSHA standard requires employers to develop a program consisting of energy control procedures, employee training, and periodic inspections. Energy control procedures must be developed and utilized for the control of potentially hazardous energy during servicing or maintenance. The energy control procedures must be equipment specific unless all of the following elements exist:

• The machine or equipment has no potential for stored or residual energy or re-accumulation of energy after shut down.
• The machine or equipment has a single energy source which can be readily identified and isolated.
• The isolation and locking out of that energy source will completely deenergize and deactivate the equipment.
• The machine or equipment is isolated from the energy source and locked and tagged out during servicing and/or maintenance.
• A single lockout device will achieve a locked-out condition.
• The servicing or maintenance does not create hazards for other employees.
• The employer has had no accidents involving the unexpected activation or re-energization of the machine or equipment during servicing or maintenance.

If energy control procedures are required, they must:

• clearly outline the scope, authorization, rules, and techniques utilized to control the hazardous energy,
• include a specific statement of the intended use of the procedures, and
• specific procedural steps for shutting down, isolating, blocking, or securing machines or equipment to control hazardous energy.

The procedure must also include specific steps for placement, removal, and transfer of lockout devices, tagout devices, and other energy control measures.

Periodic Inspections

Employers are required to conduct periodic inspections of the energy control procedure(s) at least once per year. The purpose of the inspection is to ensure that the procedure(s) is being followed. The inspection must be performed by an authorized employee other than the one(s) utilizing the energy control procedure being inspected. Any inadequacies or deficiencies identified during the inspection must be corrected immediately. In addition, periodic inspections must include a review between the inspector and each authorized employee to include that employee’s responsibility under the control procedure being inspected. Inspection documentation must include the identity of the machine or equipment, date of inspection, names of employees included in the inspection, and the person performing the inspection.

Required Training

Employers are also expected to ensure that employees have knowledge and skills required for safe application, usage and removal of energy controls. Training must focus on the recognition of applicable hazardous energy sources, the types and magnitude of the energy available in the workplace, and the methods and means for energy isolation and control. The employer is expected to provide training specific to the needs of the employee with a focus on both the authorized and affected employee.

An affected employee operates or uses a machine or equipment on which servicing or maintenance is being performed under lockout tagout. An authorized employee is a person who locks or tags out machines or equipment in order to perform servicing or maintenance. Affected employees must be trained on the purpose of the energy control procedure(s), recognition of when an energy control procedure is being used and understand the importance of not tampering with lockout or tagout devices and not starting or using equipment that has been locked and tagged out. Authorized employees must be trained to ensure that they have knowledge and skills necessary for the safe application, use, and removal of energy isolating devices, the ability to recognize hazardous energy, the type(s) and magnitude of hazardous energy sources in the workplace and the energy control procedure(s). Authorized and affected employees must be retrained when there is a change in job assignments, equipment or processes that present a new hazard, a change in energy control procedures, or a periodic inspection that reveals shortcoming with employee knowledge or use of energy control procedures.

Conclusion

An effective energy control program can prevent employee injuries and fatalities. The core elements of an effective program include procedures, training, and periodic inspections. In addition to the core program elements, consider program language to address key elements such as contractor coordination, group lockout tagout requirements, lockout device removal, and continuity of lockout tagout during shift changes. Remember, safety doesn’t have to be difficult, simple steps, like inspecting lockout tagout procedures to ensure effectiveness, can prevent injuries and save lives.

Suggested Links

• Hierarchy of Controls
• Routine Safety Inspections
• Course Catalog – Safety Made Simple

Joe Mlynek is a partner and subject matter expert at Safety Made Simple, LLC. He has over 20 years of experience in safety at the corporate level and as a consultant. He is a Certified Safety Professional (CSP) and Occupational Safety and Health Technician (OHST). Joe can be reached at [email protected]

Grain dust explosions often result in fatalities, injuries, and significant property damage. OSHA’s Grain Handling Standard 29 CFR Part 1910.272 addresses grain dust explosion prevention and includes a requirement for a written housekeeping program to address fugitive grain dust.

Why Does Grain Dust Explode?

Secondary explosions occur when the blast or pressure wave from the primary explosion causes layers of dust to become suspended in a confined space and a flame wave ignites these concentrations resulting in powerful secondary explosions.

Secondary Explosions

One of the primary goals of OSHA’s housekeeping program requirement is to reduce the potential for secondary explosions. Secondary explosions occur when the blast or pressure wave from the primary explosion propagates into areas such as gallery floors, tunnels, and intermediate floors of the headhouse causing layers of dust to become suspended. The pressure wave travels away from the primary explosion at approximately 1,000 feet per second followed by the flame wave at 10-100 feet per second. The pressure wave places dust into suspension and the slower flame wave ignites these concentrations resulting in powerful secondary explosions. Primary explosions generate pressures around two psi while secondary explosions can generate pressures in excess of 100 psi. For reference, the rupture strength of equipment such as bucket elevator legs and conveyance is around two psi while the rupture strength for concrete is roughly 25 psi.

Explosion Prevention Safety Course

Housekeeping Programs

OSHA requires that the housekeeping program be documented and specifies the frequency and cleaning methods used, such as vacuuming or sweeping, to effectively reduce dust accumulation. Keep in mind that portable vacuums must be rated for Class II, Group G hazardous locations. The standard also requires that the housekeeping program immediately address dust accumulations at priority areas using an action level of 1/8 inch (.32 cm) of accumulated dust. Priority areas are defined as floors within 35 feet of an inside bucket elevator, floors of enclosed areas containing grinding equipment, and floors of enclosed areas containing grain dryers inside the facility. An inside bucket elevator means a bucket elevator that has the boot and more than 20 percent of the total leg height inside the grain elevator structure. Bucket elevators with leg casings that are inside of rail or truck dump sheds with the remainder of the legs outside of the grain elevator structure are not considered inside bucket elevators.

In addition, the housekeeping program should define schedules for cleaning dust accumulations from motors, critical bearings, and other ignition sources in the work area. Areas around bucket elevators, milling machinery, and similar equipment should be prioritized in the cleaning schedule. Housekeeping efforts must also address “hard-to-reach” areas. This may include upper surfaces of equipment, spouting, ledges, and walls. These efforts often require the availability of work platforms, portable ladders, mobile scaffolding, and long handled tools.

Using compressed air for cleaning is acceptable but does pose significant risk since these efforts place dust into suspension. For this reason, OSHA requires that the use of compressed air to blow dust from ledges, walls, and other areas only be permitted when all machinery that presents an ignition source is shut down, and all other known potential ignition sources in the area are removed or controlled. While not required, many companies implement the use of “blow down” or compressed air cleaning permits. The permit requires an evaluation of the housekeeping area, identification and elimination of ignition sources, equipment shutdown, and management approval prior to use of compressed air for cleaning inside of enclosed areas (tunnels, boot pits, headhouse, gallery floors, etc.).

Written housekeeping programs should also specify the schedules and control measures for controlling dust emitted from grain handling systems. This includes efforts for identifying and addressing point sources of dust such as holes in spouting, bucket elevator casings, pneumatic dust collection system piping, and conveyance.

• Companies should evaluate their program on a routine basis to ensure that it:
• Defines the frequency and methods used to remove grain dust accumulation.
• Determines the locations of priority areas as defined by the OSHA standard including the requirements for cleaning “hard-to-reach” areas and critical equipment that can pose an ignition source.
• Requires documentation of housekeeping inspections and cleaning efforts.
• Establishes routine inspections to identify and correct point sources of fugitive dust.
• Requires employee training on the requirements within the program.

Prevent Secondary Explosions Today

Grain dust explosions are preventable. Review your housekeeping program to ensure that it provides an effective strategy for addressing grain dust accumulations at your location(s). After the strategy is developed, it all comes down to execution.

Suggested Links

• Grain Dust Explosion Prevention
• Combustible Dust in Agricultural and Processing Facilities
• Course Catalog – Safety Made Simple

Joe Mlynek is a partner and subject matter expert at Safety Made Simple, LLC. He has over 20 years of experience in safety at the corporate level and as a consultant. He is a Certified Safety Professional (CSP) and Occupational Safety and Health Technician (OHST). Joe can be reached at [email protected]

Written Program Requirements

The Occupational Safety and Health Administration’s Permit Required Confined Spaces standard 1910.146 establishes requirements for safe entry into confined spaces. According to the standard, employers requiring workers to enter confined spaces must develop and implement a written permit space program. The written program should contain guidance on space identification, entry procedures, the permit system, employee training, rescue, and contractors.

Confined Space Identification
Each workplace is expected to identify confined spaces in their work environment. A confined space is:

• Large enough and so configured that an employee can bodily enter and perform assigned work.
• Has limited or restricted means of entry or exit.
• Is not designed for continuous occupancy.

Confined Space Safety Course

Characteristics of a Confined Space

Permit required confined spaces have one or more of the following characteristics:

• Contains or has the potential to contain a hazardous atmosphere.
• Contains a material that has the potential to engulf an entrant.
• Has an internal configuration such that an entrant could become trapped or asphyxiated by inwardly converging walls or by a floor which slopes downward and tapers to a small cross-section.
• Contains any other serious safety or health hazard.

If the workplace contains permit spaces, the employer must inform exposed employees, by posting danger signs or by any other equally effective means, of the existence and location of and the danger posed by the permit spaces. A sign reading “DANGER – PERMIT-REQUIRED CONFINED SPACE, DO NOT ENTER” or using other similar language would satisfy the requirement for a sign.

Confined Space Entry Permit Requirements & Procedures

Employers are required to develop and implement the means, procedures, and practices necessary for safe permit space entry operations. The procedures should be specific to each type of space that is entered. Even subtle differences in spaces can increase exposure to employees. Procedures need to define acceptable entry conditions, the means for isolating the space, requirements for purging, inerting, flushing or ventilating to control atmospheric hazards and the means to secure the space against pedestrians and vehicles. The procedures also need to identify the means to verify that conditions in the space are acceptable throughout the duration of the entry as well as the types of equipment needed for entry. This may include atmospheric monitors, personal protective equipment, communications equipment, intrinsically safe lighting, rescue, and emergency equipment.

Permit System

The written program must include information regarding the permit system in place. This information instructs employees on the completion of the permit, roles and responsibilities of the entry team, the duration of entry, cancellation of the permit, and required documentation. The duration of a confined space entry must not exceed the time required to complete the assigned task or job identified. Permits must contain the following information at a minimum:

• Space to be entered
• Purpose of entry
• Date and duration of the entry permit
• Authorized entrants
• Persons by name serving as attendants
• Person by name serving as the entry supervisor
• Measures used to isolate, eliminate, or control permit space hazards
• Acceptable entry conditions
• Results of initial and periodic tests as well as the person performing the tests
• Rescue and emergency services and the means of contact
• Communication procedures used by authorized entrants and attendant during entry
• Required Equipment (PPE, testing, communications, rescue)

The employer must retain each canceled entry permit for at least one year to facilitate the review of the permit-required confined space program. Any problems encountered during an entry operation must be noted on the pertinent permit so that appropriate revisions to the permit space program can be made.

Confined Space Training Requirements

The written program must establish employee training requirements. Employees entering permit spaces must be trained and have the understanding, knowledge, and the skills necessary for safe entry. Employees must be trained prior to being assigned confined space entry duties or when there is a change in opera

tions that may present a new hazard. Training documentation is critical and should include the name and signature of the trainees, the name and signature of the trainer and the date of training. It is also recommended that the types of information used be noted as well (videos, handouts, policies, permits, online courses, etc.).

Rescue

The written program must address confined space entry rescue. An employer can train employees to perform rescue activities or utilize a trained third-party rescue service provider. This poses a challenge for many companies, particularly in rural locations. For this reason, it is advisable to identify means to eliminate entry or rely on non-entry rescue equipment.

Contractors

The written program must include provisions for contractors. The host employer must inform the contractor that the workplace contains permit spaces and that permit space entry is allowed only through compliance with the written permit space program. The host employer is responsible for communicating the elements of the program including the hazards identified in each applicable space as well as any precautions or procedures that the host employer has implemented for the protection of employees working in or near permit spaces. In addition, the host employer is responsible for coordinating entry operations with the contractor and debriefing the contractor at the conclusion of entry operations regarding the permit space program followed and any hazards confronted or created in permit spaces during entry operations.

Confined space entry poses a significant exposure to employees. Developing and implementing an effective confined space entry program can eliminate, reduce, or control exposure. Review your program and ensure that it has the necessary elements to send employees home safely.

Suggested Links:

• Oxygen Deficiency In Confined Spaces
• Lockout Tagout
• Course Catalog – Safety Made Simple

Joe Mlynek is a partner and subject matter expert at Safety Made Simple, LLC. He has over 20 years of experience in safety at the corporate level and as a consultant. He is a Certified Safety Professional (CSP) and Occupational Safety and Health Technician (OHST). Joe can be reached at [email protected]

Using a personal fall arrest system (PFAS) without evaluating fall clearance is like bungee jumping with a bungee cord that is too long. It places workers in a situation that can result in severe injury and death. Prior to using a PFAS employees must have a basic understanding of fall clearance.

Calculating fall clearance takes the following factors into account:

• The length of the connector including deceleration distance.
• The length of the worker’s body.
• An adequate safety factor.

Deceleration distance is the vertical distance a worker travels between the activation of the fall arrest system’s deceleration device and the final fall arrest (stop). A deceleration device, often referred to as an energy or shock absorber, is any mechanism that serves to dissipate energy during a fall. Deceleration distance cannot exceed 42 inches (3.5 feet).

Fall Protection Equipment Inspections

Fall Clearance Calculator

Assume that a six-foot worker is wearing a body harness attached to a six-foot connector with a deceleration device. The connector is attached to the body harness’s dorsal D-ring and a suitable anchorage point. The following calculation provides the fall clearance distance requirement.

Based on this example, the worker must ensure that the anchorage point is at least 18.5 feet above the lower level, obstruction, or dangerous machinery or equipment. If adequate clearance is not available, the worker should choose another suitable anchor point or consider using equipment such as an aerial lift, scaffold, or fall restraint system. A shorter connector may also decrease the required clearance distance.

Please take the time to make sure employees understand the importance of evaluating fall clearance. Failure to understand this basic concept is like bungee jumping with a bungee cord that is too long.

We develop safety courses so you can send your people home safe everyday. Our team of experts constantly create content based on the latest industry safety standards. Preview a course today!

Suggested Links

• Fall Protection:  Suspension Trauma
• Railcar Fall Protection – Fixed Systems
• Course Catalog – Safety Made Simple

Joe Mlynek is a partner and subject matter expert at Safety Made Simple, LLC. He has over 20 years of experience in safety at the corporate level and as a consultant. He is a Certified Safety Professional (CSP) and Occupational Safety and Health Technician (OHST). Joe can be reached at [email protected]

Harvest is the perfect storm, a critical state of affairs with negative and sometimes unpredictable factors including seasonal workers, combustible dust, equipment failure, worker fatigue, and vehicle traffic. While it is difficult to eliminate all of these factors, it is possible to define and implement strategies to control or reduce their impact. Strategies like incident and root cause analyses are good starts, but let’s get into specifics.

Seasonal Workers

Harvest often requires the use of seasonal labor. Consider managing the hiring process to allow adequate time for onboarding. Define the scope of the workers activities and train on items including the facility’s emergency procedures, personal protective equipment (PPE) requirements, the hazards of combustible dust, housekeeping procedures, truck dump/receiving operations, and moving vehicle hazards. Additional training may be required if seasonal workers engage in bin-entry, maintenance activities, working at heights, or rail operations.

PPE

PPE provides a barrier between workers and hazards. Ensure that there is an adequate supply prior to and during harvest. This may include items such as head protection, filtering face-piece respirators (dust masks), eye protection, gloves, and high visibility/reflective clothing.Preventive Maintenance
Perform scheduled maintenance prior to and during harvest. Scheduled maintenance should focus on critical equipment such as bucket elevator legs, grain dryers, dust collection systems, pressurization equipment, conveyance, and hazard monitoring systems. It is also advantageous to inventory maintenance related parts, equipment, and materials to ensure that adequate inventories are on hand should breakdowns occur.

Housekeeping

Dust generation will increase during harvest due to full equipment utilization and increased grain flow. Inspect and clean priority and non-priority areas on a consistent basis and avoid housekeeping techniques that place dust in suspension, such as the use of compressed air, since it will be difficult to shut-down and isolate equipment during this busy time.

Vehicle Traffic

The potential for a “struck-by” incident increases during harvest. Ensure that the facility has an effective traffic control plan. Define traffic routes with highly visible signs and instructions. Route traffic to eliminate or reduce the potential for vehicles and workers to cross paths. Consider developing and distributing a driver safety handout covering critical safety requirements such as designated traffic routes, PPE, No-Smoking, driver/vehicle positioning, hand signals (if appliable), cell phone prohibitions, and the facility’s emergency evacuation procedures.

Worker Fatigue

Working longer hours during harvest results in fatigue. Symptoms of fatigue include forgetfulness, apathy, reduced vigilance, poor communication, poor decision making, slower reaction time, and irritability.

Worker fatigue is caused by excessive intensity and duration of physical mental activity, hazardous work environments (noise, heat, dust, traffic, etc.), conflicts with coworkers and customers, long hours, shift work, sleep loss, poor nutrition, and dehydration.

Allow employees to take routine breaks and spend adequate time away from the facility. Focus on improving communication prior to and during the shift. Routinely discuss safety hazards and the importance of maintaining a safe work area, routine hydration, and rest breaks. In addition, allow employees the opportunity to voice their frustrations and concerns.

Routine Safety Training

Resist the urge to delay or eliminate routine safety training during harvest. If delivering classroom training is not feasible, consider having short pre-shift meetings to discuss specific tasks, hazards, and methods to eliminate, control or reduce these hazards.

Conclusion

Harvest is in fact the perfect storm. There is no other time of year quite like it. Consider implementing or improving upon the strategies discussed. Navigating safely through harvest will take effort, communication, and ample planning. The investment is well worth it.

Suggested Links

• Routine Safety Inspections
• Conversation-Based Safety
• Course Catalog – Safety Made Simple

Joe Mlynek is a partner and subject matter expert at Safety Made Simple, LLC. He has over 25 years of experience in safety at the corporate level and as a consultant. He is a Certified Safety Professional (CSP) and Occupational Safety and Health Technician (OHST). Joe can be reached at [email protected]

Commitment Changes Culture

As a consultant I’ve learned that companies approach safety in different ways. Some balance the need for compliance with commitment to their employees while others focus merely on compliance. It’s hard to argue that maintaining compliance with OSHA regulations shouldn’t be part of an organization’s approach. I’d argue that focusing merely on compliance only goes so far when it comes to the wellbeing of employees.

OSHA Guidelines

OSHA provides guidelines for creating and maintaining a safe work environment. Notice the use of the word guidelines, not playbook. There is not a page in the standards that we can turn to for every scenario that arises. Therefore, our safety efforts need to consult OSHA standards and include common sense approaches that focus on protecting employees. As leaders we need to be committed to eliminating exposure, fostering accountability, offering feedback and recognition, involving employees in safety conversations, and defining what being safe actually looks like. Our dedication to safety must be driven by our commitment to employees, not compliance alone.

The Value of Workplace Safety

Messaging

Early in my career I worked in a corporate safety department. I frequently referenced OSHA when communicating with employees. I believed that using OSHA as reinforcement would motivate them to take the right precautions and address hazards. Over time, I realized that the message I was sending did not express the level of commitment that the company had to their employees. Sure, we did not want to be cited for hazards or lack of programs, but the real reason for the safety effort was the well-being of the employee.

Upon reflection I started to think of the message from the employee standpoint. What do employees think when the management team starts fixing hazards in the work area solely because they may be “concerned about an OSHA inspection or possible citation.” Perhaps they believe that issues are being addressed for fear of a citation rather than concern for their well-being.

Conclusion

I encourage you to reflect on the messages being sent to employees when it comes to safety. Try to eliminate compliance from safety conversations. Focus on the “Why” and the commitment the organization has toward keeping people free from harm and eliminating hazards. It will take conscious focus at first, but in time it will become second nature. Compliance is important, but in the end, commitment changes culture.

Suggested Links

• Commitment Versus Compliance
• How Do You Build A Safety Culture
• Course Catalog – Safety Made Simple

Joe Mlynek is a partner and subject matter expert at Safety Made Simple, LLC. He has over 20 years of experience in safety at the corporate level and as a consultant. He is a Certified Safety Professional (CSP) and Occupational Safety and Health Technician (OHST). Joe can be reached at [email protected]