Safety Moment: Back to School with OSHA - Recordable Injuries and Top Ten Walking Working Surfaces

Every September the kids go to school and begin to learn new things. This year employers are back to school with OSHA. Two new regulations are new this year for employers.

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    First, was the improved tracking of workplace injuries and illnesses – which emphasized the employee's right to report injuries and illnesses free from retaliation (29 CFR 1904.35). The new reporting requirements will be phased in over two years: OSHA proposed extending the compliance date for electronically submitting injury and illness reports from July 1 to December 1. Required employers can submit injury and illness data using an electronic reporting system. The anti-retaliation provisions become effective August 10, 2016, but OSHA delayed their enforcement Dec. 1, 2016. Establishments with 250 or more employees in industries covered by the recordkeeping regulation must submit information from their 2016 Form 300A by December 1, 2017. These same employers will be required to submit information from all 2017 forms (300A, 300, and 301) by July 1, 2018. Beginning in 2019 and every year thereafter, the information must be submitted by March 2.

    Establishments with 20-249 employees in certain high-risk industries must submit information from their 2016 Form 300A by December 1, 2017, and their 2017 Form 300A by July 1, 2018. Beginning in 2019 and every year thereafter, the information must be submitted by March 2. They have also posted frequently asked questions on the rule.


    The second major rule OSHA issued a final rule on Walking-Working Surfaces and Personal Fall Protection Systems that was effective Jan. 17, 2017. The final rule includes revised and new information that addresses everything from fixed ladders and fall protection systems to training and design requirements. The final rule updates and revises the outdated general industry Walking-Working Surfaces and Personal Protective Equipment (Fall Protection Systems) standards on slip, trip, and fall hazards, which are a leading cause of worker deaths and lost-workday injuries (29 CFR part 1910, subparts D and I). OSHA adopted the existing standards in 1971 and has not updated them since. The final rule also adds new requirements on personal fall protection systems (29 CFR part 1910, subpart I). OSHA estimates the final rule will prevent 29 worker deaths and 5,842 lost-workday injuries each year. Additionally, because the final rule harmonizes general industry requirements with OSHA's existing construction industry standard and many ANSI standards, the new rule will make compliance both easier and less costly. OSHA estimates the annual monetized benefits of the lives saved and injuries prevented will be $614.5 million (with net benefits of $309.5 million (benefits minus costs)).

    Here are 10 specific items that changed in the standard.

    1) Training required for exposed workers or equipment users by May 2017. This includes general for exposure, roof, equipment, and key individuals (authorized, competent, and qualified persons).

    2) Equipment requirements included changes to the test weights of snap hooks and carabineers, and requirements for self-retractable lanyards, including deceleration distances.

    3) Changed safe distance to roof edges as well as defining temporary and infrequent tasks on roofs.

    4) Modified ladders and stairs requirements starting in 2018 and required safety systems on all ladders by 2036. This includes requirements for spiral stairs and ships ladders.

    5) Guardrails are now aligned with construction industry and codified 19 inch opening requirements.

    6) Requires written certification of the workplace assessment to determine if hazards are present.

    7) Rope descent systems must comply with 1910.27(b)(1)(i).

    8) Documentation requirements include assessments, training, anchors, and walking working surface load rating.

    9) Updated definitions of competent and qualified person in subpart D and I.

    10) Important compliance dates for employee training May 17, 2017, certification of anchorages on Nov. 20, 2017, existing fixed ladders need cage well, ladder safety system or PFAs Nov. 19, 2018, new ladders with ladder safety system by Nov. 19, 2018, and all fixed ladders must be equipped with a ladder safety system or PFAS by Nov. 18, 2016.

    Employers should ensure compliance, safety, and risk management in all tasks. OSHA aligned fall protection requirements for general industry with those for construction, easing compliance for employers who perform both types of activities. For example, the final rule replaces the outdated general industry scaffold standards with a requirement that employers comply with OSHA's construction scaffold standards. OSHA has created a frequently asked questions guide for the standard.

    On September 13, 2017, Don Elswick, CSP, CET, CHMM with ELSMART Associates will be discussing both of these changes during the Northeast Ohio Safety Council meeting. If you have any specific questions you want addressed at the meeting contact Don Elswick at Looking forward to seeing you on September 13, 2017 at this important information session.

    Next up: Webinar: Security Tips for Small Businesses
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  • Webinar: Security Tips for Small Businesses

    Data security is a big buzzword today. How secure is your network? Get the knowledge you need to keep the bad guys at bay.

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    Next up: Shining a Light on the LED Alternative
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  • Shining a Light on the LED Alternative

    For more than 100 years, fluorescent bulbs have been the go-to lighting source for scores of businesses. But is it the best source? A recent report from Energy Focus, Inc., titled “LED Lighting Sets the New Standard” points out the many positives associated with LED lighting.

    For more than 100 years, fluorescent bulbs have been the go-to lighting source for scores of businesses. But is it the best source? A recent report from Energy Focus, Inc., titled “LED Lighting Sets the New Standard” points out the many positives associated with LED lighting.

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    Light-emitting diodes (LED) lighting are expected to replace nearly all artificial lighting in the United States by 2030. The cost of LEDs has been driven down in recent years, thus making them a more viable alternative. But a lower cost isn’t the only benefit to LEDs. The Energy Focus report points to other, perhaps less obvious, benefits of making the switch to LED lighting.

    Light distribution


    First, starting with basic aesthetics, LED lighting evenly distributes colors across a space. This results in more saturated, vivid, discriminable color and visual acuity. And the color rendering, temperature and efficiency (LEDs use about 80% to 85% less electricity than incandescent lighting) of LED lighting is continuing to improve.


    The improved lighting does more than just look good. LED lighting is used in the treatment of Seasonal Affective Disorder, and has been shown to improve mood, decrease stress, and create a generally healthier and happier environment because the lighting mimics natural sunlight. Mimicking sunlight also has a positive impact on the bodies’ Circadian Rhythm and can help keep individuals on a healthy sleep/wake cycle.

    Environmental benefits

    The LED bulbs contain no mercury or hazardous waste and are 100% recyclable. Further, they can last 20-times longer than any other artificial light source, reducing the time, cost and effort of maintenance.

    To read Energy Focus’ full report, click here. For more information on how LEDs can benefit your business, contact COSE’s Energy Team at 216-592-2205 or via email.

    Next up: Ship Smart and Save: 3 Reasons to Register for Our May Webinar
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  • Ship Smart and Save: 3 Reasons to Register for Our May Webinar

    The COSE WebEd Series - Ship Like A Pro - is less than a month away! Mark your calendars for May 3rd!

    We understand you are busy, but should that stop you from saving time and money? Think again! Why not take 30 minutes out of your day to learn about how to move your business forward by shipping like a pro?

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    Just like in our most recent webinar series, we want to provide you with all the necessary tools to become your company’s next shipping expert. Our webinar, hosted by Ascent Global Logistics, will be held at 11 a.m. on Thursday, May 3.

    You should register if you are looking for any of the following three things:


    Reason No. 1: You are looking to save time, money and resources

    • Are you familiar with general shipping best practices?
    • Do you know how to properly classify freight?
    • What are the pieces of essential shipping documentation?
    • What are the top ways to avoid common shipping errors?

    If you hesitated to answer any of these questions, this webinar is for you! In our webinar, we will provide you answers to these fundamental questions, and well as explore additional cutting-edge shipping topics.

    Reason No. 2: You are looking for free learning opportunities

    Speaking of registering, did you know this webinar is completely free for COSE members? If you or anyone else in your organization handles shipping, you will want to register! Why not take advantage of the chance to learn something new, for free?

    Reason No. 3: You are looking to connect with an industry expert

    Don’t let business opportunities that are outside of your comfort zone or geographical region hold you back! Instead, learn more than you ever thought was possible. By listening to an industry expert, you will not only learn the important questions to ask your customers, but also can create industry connections that will last a lifetime.

    Why wait? Click here to register.

    Next up: Shipper Insights: How Accurate NMFC’s Can Help Control Transportation Costs
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  • Shipper Insights: How Accurate NMFC’s Can Help Control Transportation Costs

    NMFC’s must be provided by the shipper so that carriers can determine shipping rates. Learn what shippers need to know about NMFC’s to control transportation-related costs.

    One of the most important steps when preparing a LTL (Less-than-Truckload) shipment is identifying the correct NMFC (National Motor Freight Classification). The NMFC is a numerical code which describes the freight, allowing the carrier to identify the commodity and provide a shipping quote.

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    The NMFC, along with the distance from origin to destination and the weight of the shipment, will factor into the rate shippers receive from the carrier. However, to obtain an accurate quote, the shipper must know and report the NMFC for its respective commodity.

    So, what is an NMFC?


    Essentially, NMFC’s standardize the comparison of commodities for pricing across the transportation industry. The NMFTA (National Motor Freight Traffic Association) publishes NMFC’s and provides updates on a quarterly basis to keep pace with changes throughout the industry. For example, the shift by many carriers to PCF (pounds per cubic foot) pricing has caused changes in NMFC’s for a number of products over the past couple of years.

    NMFC’s group commodities into one of 18 classes—from a low of class 50 to a high of class 500.

    NMFC’s are based on an evaluation of four transportation characteristics:

    • Density

    • Handling

    • Stowability

    • Liability

    Additionally, the NMFC provides specifications such as minimum packaging requirements, value thresholds, hazardous materials safety information and more.

    Why is NMFC accuracy important?

    Simply put, transportation costs could increase if shippers report an incorrect NMFC to the carrier. Two examples include:

    • Re-Classification Fees

    • Higher Shipment Cost due to a Change in Rate Per Hundred Pounds

    How can shippers ensure NMFC accuracy?

    Continuous education is one of the best ways shippers can ensure NMFC accuracy and manage transportation-related costs. Each quarter the NMFTA releases a list of commodities which will undergo an NMFC change. To see the spring 2017 NMFC changes, download the newest Ascent Global Logistics NMFC Upcoming Changes eBook here.

    Additionally, finding a strong logistics partner can help shippers consistently identify correct NMFC’s and avoid costly re-class fees. Partnering with a third party logistics company such as Ascent Global Logistics provides another layer of expertise when classifying freight. Professional 3PL’s have a deep understanding of NMFC’s to prompt proactive questions to ensure correct classifications. Furthermore, Ascent Global Logistics provides free NMFC assistance to all clients.

    Do you need further help with NMFC’s?

    Ascent Global Logistics offers comprehensive logistics solutions including domestic freight management, international freight forwarding and retail consolidation. Within our domestic freight management solutions, we have an entire team dedicated to LTL shipping and freight classifications.

    Contact our team of logistics professionals today to learn how we can help you reach peak logistics performance. Call us at 800-689-6255 Ext. 280 or visit us at

    Next up: Should You Allow Your Employees to Use Their Own Electronic Devices for Work?
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  • Should You Allow Your Employees to Use Their Own Electronic Devices for Work?

    Many companies are being faced with the decision to allow employees to use their personal electronic devices for work purposes. Have you considered this issue for your company? We are listing the pros and cons to BYOD (bringing your own device) to work and providing 15 tips on policy related to this issue.

    Small businesses are concerned with many things including security, costs, efficiency, technology, legal compliance and more. One area of increasing concern and questioning is allowing employees to use their own personal devices, such as laptops, phones, iPads, etc. at work. A recent study cited 74% of businesses are either currently allowing or planning to allow employees to use their own devices. Should you allow your employees to use their own devices for work and if so what security and monitoring and other issues do you need to address?

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    Many employees, including millennials, prefer using their own devices instead of using company issued equipment. While this can help lower your costs and improve morale, it can also bring a great deal of security and other issues with it. Let’s review some bring your own device (BYOD) pros and cons:


    Here are some of the benefits to allowing employees to bring their own devices to work.

    BYOD Pro No. 1: It can create a more efficient and relaxed environment.

    BYOD Pro No. 2: It can help a small business to save money by eliminating the need to provide employees devices and equipment.

    BYOD Pro No. 3: It has been known to boost morale and productivity by allowing employees to use devices they are familiar and comfortable with.

    BYOD Pro No. 4: It can also provide your business with the latest technology at little or no cost to you because many employees, especially millennials, will upgrade to the newest equipment on the market.

    While these pros are significant, there are also several negative qualities that go along with employees using their own devices.

    BYOD Con No. 1: Personal equipment can expand your risk to exposure of information. Allowing use of personal devices takes away your control of passwords, lock functions, protection of the equipment itself, unauthorized access to company data and more.

    BYOD Con No. 2: The issue of protection of the equipment itself can be unclear. Who is responsible if it is stolen or lost?

    BYOD Con No. 3: Employees may feel that using company issued equipment instead of their own increases your access to their personal information such as financial data, personal contacts, photos, etc. They may also worry that you can remove these things from their device and they lose all control. This is especially true when an employee is terminated.

    BYOD Con No. 4: Employees using their own personal devices may feel more secure using their equipment to hurt your company thru social media, texting, etc.

    BYOD Con No. 5: If nonexempt employees are asked to use personal devices for work, you may open yourself up to exposure under the federal Fair Labor Standards Act and state overtime and wage payment laws. Since nonexempt workers will have ready access to the technology, they may be put in the position to respond to emails and text messages or to otherwise engage in work activities outside their scheduled work hours.

    BYOD Con No. 6: It can be unclear how to handle expense reimbursement. State law may dictate how this is to be handled. Does the employer have to pay for the data plan?

    BYOD Con No. 7: It may be necessary to include methods to ensure that any business records stored on an employee’s personal device have been saved long enough to satisfy electronic discovery requests during litigation. Failing to retrieve information stored on a worker’s personal device that should have been produced may lead to consequences for you should you face any litigation.

    The importance of a Having a Good Company Policy

    Allowing employees to use their own devices for work requires a strong, concise policy addressing all issues. Make sure your policy includes detailed information on how to separate employee work product from personal data. And before implementing a BYOD policy at your business, develop a security plan with your IT department, HR department or consultant, and inside or outside legal counsel that outlines regulations employees must follow.

    Here are some tips for what should be addressed in your policy:

    Policy Tip No. 1: Include an explanation about how you will educate your employees on the importance of following these regulations, so you can avoid the risk of data being compromised. Have them sign a paper stating they received the policy and will abide by it.

    Policy Tip No. 2: Clearly state which devices are allowed and how your company will support them.

    Policy Tip No. 3: Mandate specific policy on security, anti-virus software, firewalls, use of unsecured wi-fi networks, passwords and access to your company data. Be specific and include punishment for not adhering to the rules.

    Policy Tip No. 4: Determine which devices will be permitted and supported and which types of company data people will be able to access from them.

    Policy Tip No. 5: Determine who in your business can use personal devices. You may want to decide this based on the job responsibilities and the level of the job.

    Policy Tip No. 6: Include guidelines for work hours. Be specific about when they are “on the clock” and when they are “off the clock” when using their own devices.

    Policy Tip No. 7: Be clear about your ability to access information on their devices. Make sure to state that company work product and data is owned by the company and cannot be utilized for any other purposes.

    Policy Tip No. 8: Be sure your policy addresses sexting, texting while driving, sexual harassment, inappropriate materials or downloads, bullying and other HR and possible liability issues.

    Policy Tip No. 9: Establish your right to access, monitor and delete information from employee-owned devices.

    Policy Tip No. 10: Determine and communicate whether you will introduce any new forms of monitoring, such as location-based tracking via GPS or other methods. If so, specify when the monitoring will be used by the employer and for what purpose.

    Policy Tip No. 11: State how your company will protect an employee’s personal information and identify what that information is and how it will be used and saved.

    Policy Tip No. 12: If you plan to delete information upon termination, determine what data will be wiped and give them notice.

    Policy Tip No. 13: Put in place a data protection clause that includes protocols for reporting lost or stolen devices, mandating certain antivirus and protective software, and requiring or strongly encouraging regular backups.

    Policy Tip No. 14: Include a policy on lost devices. Define who is responsible and address replacement issues.

    Policy Tip No. 15: Include in your policy who is responsible for authorizing work-related software and other downloads.

    While this may seem like a lot of work and expense for a small business, it is necessary to protect your business, your work product and possibly head off legal issues in the future.

    President, SACS Consulting & Investigative Services, Speaker, Trainer, Corporate Security ExpertTimothy A. Dimoff, CPP, president of SACS Consulting & Investigative Services, Inc., is a speaker, trainer and author and a leading authority in high-risk workplace and human resource security and crime issues. He is a Certified Protection Professional; a certified legal expert in corporate security procedures and training; a member of the Ohio and International Narcotic Associations; the Ohio and National Societies for Human Resource Managers; and the American Society for Industrial Security. He holds a B.S. in Sociology, with an emphasis in criminology, from Dennison University. Contact him at

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