Federal Regulations Cancel The title field is required!

1. David Hebermehl

   

   0 posts
   
   11/8/2017 6:11 AM

   We just had a speaker tell a group of about 50 of us about a federal law none of knew about pertaining to OSHA rules. Specifically that there is a protocol for reporting injuries that is against federal law if not followed correctly. OSHA Form 300 is the one I'm talking about. Got me thinking. What other federal laws are out there we don't know about. Surely there's something somewhere about the environment, fuel usage/storage, or chemical applications. Also makes me wonder why none of us knew about this and who should've reached out to us.

   
   
   
   
2. Andy Jorgensen

   

   1 posts
   
   11/8/2017 7:11 AM

   And to make things better, the OSHA 300 law is changing what injuries need to be reported. Makes the case even stronger to have a safety manager and/or hire a company to manage your safety program.
   
   OSHA also requires proof of training. So, if you simply show someone how to do a job, and there is no proof you trained them when an injury occurs, you can be held accountable. A signature on a piece of paper could be the difference between a fine and no fine. Also can prevent a lawsuit.
   
   I don't know about Federal, but there is a law in Florida for Tier II reporting of any hazardous substance above threshold limits. For the most part, this only includes your fuel if over a certain gallonage, but probably also includes your lead acid batteries in your carts at the pro shop if you have quantities above the reporting threshold. This law is more of an emergency response mechanism that lets first responders know what you have on site. In our case, they have physically inspected the locations to know what they are up against.
   
   As for fuel, there are all kinds of laws down here to follow. Anything over 550 gallons has to be licensed and is routinely inspected. Containment areas have to be sealed with a certain type of product and documented monthly inspections by your staff have to occur. There is also a ton of forms that have to be completed.

   
   
   
   
3. Christopher Thuer

   

   101 posts
   
   11/8/2017 11:11 AM

   I have had the OSHA 300 log posted for years. Even though there are years without anything to report, it has to be posted. Ours is on the now large board with the posters that everyone should have by law. Wage/hour, family leave, EEOC, etc. We have all posters in English and Spanish and it took up a 4 x 8 sheet of plywood screwed to the wall.
   
   The SARA Title 3 is the chemical storage an community right to know. It has been years since but I went through our entire product list and found that we store no reportable quantities (at least for Indiana) of any of the active ingredients that we use. Each state may have different reportable quantities, not sure. I just had a visit from our regional state chemist office inspector 2 weeks ago and he asked about it. I told him of my findings as to the reportable quantities on site and he concurred. He did suggest that although we don't have to report, again for Indiana, it would be a good idea to have an MSDS list and floor plan of our buildings with what is kept where, like oil, fuel cans, torch set, chem and fert, etc. at the fire dept HQ. This just for the safety of the fire fighters and maybe for where to put water and where not to.

   
   Chris Thuer, CGCS, Bear Slide Golf Club, Cicero, IN
   
   
4. Andy Jorgensen

   

   1 posts
   
   11/8/2017 12:11 PM

   Christopher Thuer, CGCS said: He did suggest that although we don't have to report, again for Indiana, it would be a good idea to have an MSDS list and floor plan of our buildings with what is kept where, like oil, fuel cans, torch set, chem and fert, etc. at the fire dept HQ. This just for the safety of the fire fighters and maybe for where to put water and where not to.

   
   
   Also if you have a dedicated storage room or building for your chemicals, you must have the diamond placard indicating the highest level of product you have, and also, I would advise, to have the W with a line through it indicating no water. This prevents the fire department from dumping millions of gallons of water on melted chemical containers which in turn would contaminate waterways as it runs off. The cleanup would be your responsibility. Always tell them to foam your storage room.

   
   
   
   
5. Christopher Thuer

   

   101 posts
   
   11/8/2017 5:11 PM

   One speaker suggestion I have had for the Midwest Regional Turf Conference is someone talking about the most common OSHA violations and what to expect during an inspection. Maybe the same for the GIS would be good. Not necessarily by an OSHA official so as to not call attention to golf maintenance but someone who knows a lot and is familiar with what we do. Maybe an insurance company loss prevention specialist would be helpful.
   
   I invited a loss prevention specialist for our insurance company walk through our building many years ago. He pointed out things to the crew like extension cords and air hoses not wound up and off the floor, tools laying around, smoking while fueling mowers, hearing protection and safety glasses, putting the caps back on the acetylene and oxygen bottles when not in use, oil spills not quickly cleaned up etc. Things that I had harped about. Him saying it did help get the crew to be more aware.
   
   My brother was the OSHA compliance Officer for a large mechanical contractor in Indianapolis. He still works for them but as project manager. They do large projects like the Fieldhouse where the Pacers play, hospitals, schools, etc. At his suggestion I bought an OSHA compliance book. It was huge, thousands of pages. There is no way we can do everything. He said it is impossible to comply with every little detail and the inspectors like to find something during an inspection. The harder they have to look for something the more frustrated and determined they get then it usually results in a fine instead of a warning.

   
   Chris Thuer, CGCS, Bear Slide Golf Club, Cicero, IN