By Dan Johnson, CSP
How current is your safety program? Do you have one of those old binders that has been stuck on the shelf for the past couple years collecting dust, or is your safety program an integral part of your operation?
There are a number of things that have changed for painting contractors over the past few years, such as licensing requirements, warranties, insurances costs, labor issues and many more. Those changes have kept everyone busy. Meanwhile, contractors are still trying to provide quality work at a competitive price. If you haven’t stayed up to date with OSHA changes, you may be in for a surprise.
Hazard Communication: In 2012, OSHA adopted a new Hazard Communication standard that aligns the US with the Global Harmonization System (GHS). These changes include: MSDS is now SDS, new labeling requirements, new hazard pictograms and many more. Training of employees is still an annual requirement, but make sure your program includes the updated SDSs and your containers have the new labels on them when you conduct your training.
Fall Protection: Whether you are in Construction or General Industry, OSHA has changed the fall protection rules. In construction, the residential fall protection guidelines are no longer available. It is a flat, 6-foot fall protection rule. If you are working on a roof, you will need fall protection. If you work in the general industry, OSHA changed the Walking and Working Surfaces rule which impacts painters quite a bit. Essentially this rule becomes similar to construction, with a few differences. Overall, painting contractors must analyze the workplace and determine what methods they will use to prevent falls from heights of 6 feet and less. Your safety program should reflect how you will protect your employees.
Electronic Reporting: This rule is much newer and requires employers of certain sizes to report their OSHA 300 log information electronically through a portal designed by OSHA. This injury information will then become public. If your establishment has 20-249 employees, you will only need to report your 300a summary data. This was due by December 15, 2017. If your establishment has 250+ employees, all data from the 300 logs must be reported. This now becomes an annual endeavor for contractors.
Cranes: Although most painting contractors are not affected by this new standard, if you use a crane to deliver products to a project, a qualified rigger must be used to rig the load to the crane. If that rigger is you or your employee, make sure you know the training requirements to ensure the rigger is qualified.
Safety Program Guidelines: This is not a standard, just guidelines, but be wary. OSHA has found ways to issue citations off guidelines in the past. These elements all should be considered in your safety program: Management Leadership, Worker Participation, Hazard Identification and Assessment, Hazard Prevention and Control, Education and Training, Program Evaluation and Training, and finally, Coordination and Communication on Multi-Employer Worksites.
Dan Johnson, CSP is the President of SFI Compliance, Inc. and a safety consultant with 23+ years of experience designing and implementing safety program. He recently wrote a new Safety and Health Program for the National Association of Home Builders. Johnson is also a safety training course author and subject matter expert for RedVector, a Vector Solutions brand.