“How do I keep OSHA from showing up at my resort?” is a question resorts commonly ask. The answer is simple: avoid the workplace incidents that can trigger a visit, or that would trigger an in-depth audit.
Knowing the potential hazards employees could be exposed to is a start. How does one identify all the hazards in the workplace? First, look at areas of high injury rates, and catalog jobs or activities with high-consequence hazards. Then develop procedures and solutions to minimize the risks. It’s worth the effort, both for your employees and your bottom line: reducing workplace hazards can help cut workers’ comp costs.
Job Hazard Analysis
One approach is to examine near-miss or “band-aid” reports to spot injury trends that may lead to a higher-order injury. Recurring band-aid incidents may indicate a problem area and suggest the need for more training and better controls. An area that has many little injuries may just be waiting for that “big one” to happen.
Another approach is to examine the high-consequence areas, such as fall hazards, excavations, or electrical work, where death or severe injury are possible if something goes very wrong. Break these jobs down to small steps, identify the job tasks, evaluate every possible hazard, and then determine how to reduce or eliminate each of those hazards.
Both these approaches provide the basics of doing a job hazard analysis (JHA), which OSHA requires for many tasks. The National Ski Areas Association has created generic JHAs for some tasks and departments; these can be easily modified to an individual resort’s procedures. JHAs are not a “one size fits all” guideline; JHAs have to take into account any hazards that exist and how to eliminate or reduce the hazard for a specific site or task. The JHA will help you analyze what safety equipment, controls, and training you will need to implement for hazardous job tasks. And employees should use the JHAs any time they prepare for a task. The gear and procedures suitable for a particular project or job may not be the same as on another that appears to be similar.
That’s why training employees to be aware of job hazards and how to prevent injury is one of the most important steps to reduce injuries. Lack of training is often cited by OSHA as a cause of injury incidents. Training needs to be done in a structured format, and fully documented. cont.
OSHA emphasis programs are another point of attention. Typically, emphasis programs are geared toward new standards, high injury rates, high hazard tasks, and high hazard workplaces. Examples include working with powered industrial trucks; high-hazard elevated work, where fall protection is needed; or work tasks subject to relatively new standards, such as hazardous materials communications and labeling.
Emphasis programs highlight the regulations an OSHA compliance officer will look at more closely. If an OSHA compliance officer shows up at your resort to inspect a complaint or accident, he can request to inspect areas related to emphasis programs.
Emphasis programs can vary regionally across the U.S. There are also local emphasis programs that are determined by the area OSHA offices. And some are national. For example, currently, OSHA has a national emphasis program on trenching and excavation hazards.
The newly-updated hazardous communication standard aligns the U.S. with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). The updates include specific labels and safety data sheets (SDS), formally known as MSDS, and specific training requirements for employees. Training for employees was required as of Dec. 1, 2013, and the chemical manufacturers have until June 1, 2015 to implement all parts of the rule—except for labeling, which becomes effective Dec. 1, 2015. New labels and SDS may be implemented prior to these dates, so employees should be trained on what they may observe in the workplace. Since all employees may potentially be exposed, all employees must be trained.
Recent Ski-Area History
A review of the OSHA records publicly available from the last six years for snowsports resorts includes a range of violations from minor (such as failure to have a blood-borne pathogen program or hazard communication program in place) to severe (such as accidents that resulted in severe injuries or deaths). OSHA records show that work-related deaths and severe injuries resulted from avalanches, falls from heights, and use of mechanical equipment on the hill.
OSHA penalties in the last six years’ publicly available data for snowsports resorts ranged from a low of $325 to a high of more than $25,000. Violations can be costly!
During this period, OSHA has cited violations at mountain resorts involving:
• fall hazard protection
• electrical wiring
• lockout/tagout (LOTO)
• personal protective equipment
• fire protection
• exit routes
• hazard communication
• blood-borne pathogens
• powered industrial trucks
• machine guarding
• general duty clause
Standards of Note
While the exit routes, hazardous communication and blood-borne pathogens type standards are easy to implement, other standards may not be, such as fall hazard protection, lockout/tagout, machine guarding, and excavations. Plus, some hazards are site-specific and job-specific. These regulations typically lead to higher consequences when not followed. All the OSHA regulations are available on the Internet at the agency website, www.osha.gov.
OSHA standards for fire protection and powered industrial vehicles (PIV) are basic and essential to bring your business into compliance. The big challenge with a standard like PIV is getting employees trained properly, implementing the proper inspections or repairs, and getting employees to always follow the proper procedures. For a standard such as fire protection, it may involve something as simple as having fire extinguishers positioned properly, or as complicated as installing a fire suppression system. Reading and understanding the OSHA regulation(s) will assist with being in compliance.
Cold stress injuries are of particular concern for resorts, since areas typically have many outside employees working in cold and wet conditions. Cold stress can include immersion, trench foot, frostbite and hypothermia. Cold stress injuries can be avoided by making sure employees are dressed for the conditions they are working in, and making them aware of the cold stress symptoms.
Injuries and accidents that are not covered under a specific regulation will be cited under the “General Duty Clause,” which states each employer “shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees.” Accidents that are cited under the general duty clause will typically fall under other standards, such as ANSI. Accidents at ski resorts that have been cited under the general duty clause include employees killed in avalanches and in vehicle rollovers. These types of accidents have often been found to stem from a lack of proper training.
If the resort safety program has not matured, management needs to lay out a plan to begin improving workplace safety and prioritize the job tasks to focus on. Form a safety committee that includes top management, middle management, supervisors, and line staff. To be successful, management must be committed to any workplace program improvements, and line staff should be involved with creating programs. The aim is to devise a plan that protects the area and its employees, and that is achievable.