The U.S. Department of Labor issues an OSHA National News Release that announces new enforcement guidelines that could exponentially increase penalties for companies who prioritize profits over safety. Specifically, OSHA addresses the expanded application of instance-by-instance citations and non-grouping of violations in certain cases that will go into effect on March 27th of this year.

Originally published in October 1990, CPL 02-00-080, also known as the “egregious or violation-by-violation penalty procedure,” was intended to “create large aggregate penalties” for willful citations in order to “provide an incentive to employers to prevent safety and health violations in their workplace”. In the first memo, OSHA expands the scenarios that “instance-by-instance” citations may be issued for “high-gravity serious violations of standards specific to falls, trenching, machine guarding, respiratory protection, permit-required confined spaces, lockout tagout, and other-than-serious violations specific to recordkeeping”. If you haven’t noticed, these closely align with OSHA’s “Top 10 Most Frequently Cited Standards”. The scope of this directive applies to general industry, construction, maritime, and agriculture; in other words, this applies to everything under OSHA’s jurisdiction.

So, what does the expanded use for instance-by-instance citations include?

According to OSHA, a decision to use instance-by-instance should be based on the consideration of one or more of the following factors and does not preclude the use of other OSHA initiatives, directives, or emphasis programs.

• The employer has received a willful, repeat, or failure to abate violation within the past five years where that classification is current.
• The employer has failed to report a fatality, inpatient hospitalization, amputation, or loss of an eye pursuant to the requirements of 29 CFR 1904.39.
• The proposed citations are related to a fatality/catastrophe.
• The proposed recordkeeping citations are related to injury or illness(es) that occurred as a result of a serious hazard.
  
  

This is intended to be a targeted strategy for those employers who repeatedly choose to put profits before their employees’ safety, health and well-being.

According to statements released by Doug Parker, Assistant Secretary for OSHA, “Smart, impactful enforcement means using all the tools available to us when an employer ‘doesn’t get it’ and will respond to only additional deterrence in the form of increased citations and penalties.” He goes on further to state that “This is intended to be a targeted strategy for those employers who repeatedly choose to put profits before their employees’ safety, health and well-being. Employers who callously view injured or sickened workers simply as a cost of doing business will face more serious consequences.”

References

https://www.osha.gov/news/newsreleases/national/01262023-0

https://www.osha.gov/enforcement/directives/cpl-02-00-080

https://www.osha.gov/memos/2023-01-26/application-of-instance-by-instance-penalty-adjustments

https://www.osha.gov/top10citedstandards

https://www.osha.gov/memos/2023-01-26/exercising-discretion-when-not-to-group-violations

https://www.osha.gov/enforcement/directives/cpl-02-00-164/chapter-4

Additional Resources

• Want a Safer Workplace? Get Employees Involved!

• How to Make an Impact as Safety Professionals

We are proud to announce that once again Roco has been reapproved as an OSHA VPP Star Worksite organization. VPP Star is the highest level of recognition awarded by OSHA. VPP participants serve as models for other employers, workers, and unions by operating excellent safety and health management programs. Roco has been a VPP Star worksite since 2013 and is excited to continue this tradition of raising the bar on its journey of maintaining an excellent safety and health program.

To earn this distinction, we implemented a comprehensive safety program and underwent a rigorous onsite evaluation by a team of OSHA safety and health experts. The “Star” designation is reserved for companies that “demonstrate exemplary achievement in the prevention and control of occupational safety and health hazards, as well as the development, implementation and continuous improvement of safety and health management systems.”

To our knowledge, we are the only rescue training, services and equipment company to achieve the VPP Star designation. The process of earning and renewing our VPP Star is an important way for us to get external feedback and confirm that we are “walking the walk” as an organization.

Roco’s Total Recordable Incident Rate (TRIR) and Days Away Restricted or Transferred (DART) were 100% below the national average for our industry. Having maintained our status as a VPP Star Worksite for another year has once again validated that we are living up to the highest standards of OSHA’s Voluntary Protection Program. This achievement would not be possible without a dedicated commitment to safety by all Roco employees.

Additional Resources

• Is OSHA VPP a Good Fit for Your Company?
  
  
  
  

As part of our efforts to support municipal emergency responders, Roco Rescue will be offering quarterly scholarships to our open-enrollment 50-hour Rescue Essentials Courses conducted at the Roco Training Center in Baton Rouge, Louisiana. To be considered, applicants will complete an online form and explain why they are interested in attending a course and how it will benefit them and their department. One student will be selected per quarter. 

Urban/Industrial Rescue Essentials™ Course:

• This 50-hour course is the starting point for rescuers working on rope and in confined spaces. This hands-on training course is for rescuers who respond to emergencies ranging from the depths of a confined space to the heights of an elevated structure or industrial platform.
• Participants will be provided an opportunity to become proficient at utilizing some of the most current equipment in the rescue world while learning and practicing safe, efficient, and proven rescue techniques. These skills will allow them to perform effectively in the rigorous environments faced by urban and industrial rescuers.
• Courses will be conducted at the Roco Training Center (RTC), participants will practice rescue operations from all six (6) confined space types including rescues from elevated vessels and towers. Simulated rescues from IDLH-type atmospheres that require the use of breathing air (SCBA) will also be included. These realistic scenarios can be used to document annual practice requirements as required by OSHA 1910.146.

Roco Rescue hopes that this free training will help broaden the range of skills in confined space and rope rescue for firefighters and their departments.

Offer valid for USA-based emergency responders only based on space availability. Must be 18 years or older and physically fit to participate in hands-on rescue exercises. Offer is valid for limited time and subject to change without notice. 

Additional Resources

• Roco Rescue Videos 
• Using Local Emergency Services vs Contracted Rescue Services
  

Safety professionals want to make sure all workers get home safely, but what are the best ways to do that?

Ask any safety professional what drives or motivates them to get out of bed in the morning and you’ll probably get 1,000 different answers. Some people may be motivated by their experience working in the industry, some may be motivated by combat experience, some may be motivated by their desire to help people and some may be motivated by money; the point is, we’re all motivated by something. While it’s great to know what motivates you, it’s even more important to ask yourself, “what impact do I want to make today?” 

Click here to read the full article by our own Chris McGlynn that was originally posted on OH&S’s website recently: https://ohsonline.com/articles/2022/12/05/how-to-make-an-impact.aspx?admgarea=news

Chris McGlynn is the Director of Safety/VPP Coordinator for Roco Rescue. He is a Certified Safety Professional (CSP) through the Board of Certified Safety Professionals as well as a Certified Confined Space and Rope Rescue Technician, and a Nationally Registered Paramedic. As Director of Safety, Chris oversees all corporate safety initiatives, ensuring that employees at Roco have the tools and training that they need to do their work safely and effectively. He is also responsible for managing Roco's Safety Services Division, which provides trained safety professionals for turnarounds and other special projects. Finally, Chris serves as the VPP Coordinator for Roco, continuing Roco’s long-standing commitment to excellence in safety and health. Roco has been an OSHA VPP Star Worksite since 2013.

Follow Chris 

Additional Resources

• Roco’s Professional Safety Services
• Want a Safer Workplace? Get Employees Involved!
  
  
  

There are so many angles to talk about in rope rescue but for now, let’s focus on Low Angle vs. Steep Angle vs. High Angle rescue.

We hear these terms utilized often in the rescue community, but it is not always clear what each term defines. Each one comes with a degree of slope range, something like;

• 0-15 degree slope is flat terrain
• 15-29 degrees is considered low angle
• 30-50 degrees is steep angle
• anything above 50 degrees is high angle

You may have heard some different numbers associated with each and that’s ok because, in reality, they are just guidelines to help us make informed decisions about what kind of systems to use in a given scenario. If I’m being honest, I don’t really care what the angle is because I still haven’t carried around a protractor in my rescue kit to tell me what degree slope I am working on. I have my own internal protractor, my eyes, my experience, and my level of training. All I am really concerned about is the steeper the ground, the more difficult and the more technical the rescue becomes.

It is not just the degree of slope that tells me what I need to do, it is also the terrain and the condition of the terrain that makes a BIG difference. The terrain AND the slope are going to be major factors in deciding what rope systems to use as well as how many personnel are involved in the rescue. Some examples of terrain that may push you to utilize ropes in a rescue situation would include loose rock/scree, mud, snow, or any other debris that could cause bad footing and an unstable rescue for the patient. Ropes may have to be used to gain access to the victim, to support the team members and the patients during the rescue and remove them from the rescue site.

It is not just the degree of slope that tells me what I need to do,
it is also the terrain and the condition of the terrain that makes
a BIG difference.

So, our size-up goes something like this.

• Can rescuers move freely across the terrain without assistance and manage patient movement effectively and safely? Yes = no ropes
• Do rescuers need assistance to safely and/or more efficiently move themselves or the patient, but the ground is predominately supporting the load? Yes = 1 rope system
• Are rescuers and the patient fully supported by the system or a single rope failure would cause catastrophic results? Yes = 2 ropes.

Each one of these scenarios presents its own set of challenges and the systems used can vary greatly. The goal for all of us is to provide for the safety of our teams and the people we are there to help.

Additional Resources

• 11mm Rope and NFPA Requirements
• Rescue Compliance...Is Your Team Ready?