Happy New Year. First, let me address the annual issue of OSHA recordkeeping and posting requirements.
Each year, most companies with more than 10 employees are required by Federal OSHA to maintain injury and illness records on a calendar year basis. Establishments with 250 or more employees that are currently required to keep OSHA injury and illness records, and establishments with 20-249 employees that are classified in certain industries (includes construction and metal fabrication shops) with historically high rates of occupational injuries and illnesses need to electronically submit their 2023 OSHA data by March 2024. As a reminder, the OSHA 300A summary of 2023 recordable cases needs to be posted and available for employee review from February 1 through April 30, 2024.
With an election year and all the national and international news (good and bad), 2024 promises to be “interesting.” For safety and health, the December 2023 SNIPS News safety article discussed how to address OSHA compliance in the coming year. But, as detailed in prior articles, safety and health is much more than OSHA compliance. To find out more about what’s “in the cards” for 2024, I turned to two current safety professionals to get their opinions on opportunities and challenges for the future.
In my working career, I had the good fortune of working with Justin Crandol and Raffi Elchemmas. Justin is the Safety Director for Sheet Metal and Air Conditioning Contractors' National Association (SMACNA) and Raffi is the Executive Director of Safety, Health and Risk Management for Mechanical Contractors Association of America (MCAA). Both gentlemen have extensive experience in the field and offered the following regarding issues facing the industry in 2024. Contractors would do well to research these topics and incorporate them into safety and health culture development.
The opportunity for contractor participation in local and state level regulatory processes, such as heat stress, can have numerous benefits for the company and the industry. Justin highlighted OSHA/ANSI Advocacy including SMACNA efforts to shape the new ANSI A10.50 Heat standard and the participation of a SMACNA safety committee member in the OSHA Small Business Regulatory Enforcement Fairness Act (SBREFA) panel, aiming to establish a comprehensive heat standard. Raffi agreed, stating, “We will see regulation in the coming years on this issue and contractors should prepare to implement policies around heat stress.”
For Raffi, one topic for opportunity to improve safety in the industry relates to the research and benefits of head protection and the movement from “hardhats” to “helmets.” The use of a chin strap on the helmet can be a lifesaver during a fall. Raffi asserts, “As our industry makes a shift from type 1 to type 2, the need for objective data to allow contractors to make purchasing decisions has never been more important. MCAA has partnered with several researchers to offer expanded data that will empower contractors to make informed decisions about head protection.”
As far as challenges in the upcoming year, complacency is at the top of the list for Justin. “This topic addresses the importance of machine guarding and safe usage of common construction tools, emphasizing the need to overcome complacency in workplace safety practices.”
Justin and Raffi both agree that efforts to address the growing mental health crisis will continue in 2024, as we discussed in several 2023 SNIPS NEWS articles. SMACNA works closely with the Sheet Metal Occupational Health Institute Trust (SMOHIT) on these issues including a Member Assistance Program (MAP), and collaboration with the Center for Construction Research and Training (CPWR) on related resources. Justin also wanted me to mention that The Construction Industry Alliance for Suicide Prevention (CIASP) is an organization with helpful resources to address mental health in the industry.
As Raffi stated, “While the industry is doing more than ever to focus on mental health awareness and suicide prevention in construction there is still so much more work to do. Contractors should focus on offering awareness and making the topic conversational.” MCAA created a partnership with the UA to create a 22-minute video following the life of an industry vet and released several other resources to help contractors.
Justin knows how critical Fleet Safety addresses safety, risk management and liability issues for contractors. As Justin states, “It covers the understanding and implementation of Department of Transportation (DOT) requirements, and strategies to influence driver behavior for improving safety in regular fleet operations.” SMACNA has a model Driver Safety / Fleet Management Program available to members.
In the area of personal protective equipment (PPE), Raffi promotes awareness of the many examples of accidents that could have been prevented by the simple use of PPE. From cuts, punctures, and lacerations to eye injuries and dropped objects, many common job site injuries that happened in 2023 could have been prevented with PPE. Contractors should strive for excellent safety culture and policies that promote hazard awareness and injury prevention. MCAA has created a series of 3-minute videos that showcase the risks and benefits of PPE with jaw dropping demonstrations.
Finally, Emerging Technologies will continue to push contractors to “think out of the box”. According to Justin, “This includes the adoption of advanced technologies in the industry, such as Learning Management Systems (LMS), wearable technologies, microburst learning, and the use of robots and their impact on enhancing safety and efficiency.”
The good folks at CPWR, with Chris Trahan Cain as Executive Director, have produced tons of helpful resources and materials in the past. For 2024, it looks like projects they will pursue will address exoskeletons, mentorship for female workers, the OSHA 10-hour training and more. A new program focuses on older, aging construction workers including a “data dashboard” and hazard assessment / prevention tools.
Pre-planning for 2024 means forecasting the issues and challenges for your safety and health culture including, but not limited to, the topics we discussed in this article. I strongly encourage all contractors to go to the SMACNA, MCAA, and CPWR websites. Be prepared. They have A LOT of information and tools that will assist you in many safety and health areas. I encourage all sheet metal and HVAC contractors to take some time now to research these issues and discuss the future of safety and health at all levels including management, supervisors, and workers. Forecasting and addressing the industry opportunities and challenges before they become problems is one step towards safety and health culture success.