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Category Archives: Risk Management
IESO Presenting at Clean Gulf Conference
Dr. Scott Harris is presenting in two sessions of the upcoming 2011 Clean Gulf conference in San Antonio. On November 30, Preparing the Florida Keys for Deepwater Horizon will detail the collaborative planning efforts that went into identifying and protecting the unique cultural and natural resources found in the Keys from the threat of one of the largest oil spills in history. On December 1, Oil on the Kalamazoo will review the response efforts following a July 2010 pipeline rupture that released nearly a million gallons of oil into the Kalamazoo River near Marshall, MI. Over 2,500 responders worked to contain and recover oil from 35 miles of river and shoreline.
Scott was a member of the O’Brien’s Response Incident Management Team for both of these events, and had a unique view of the daily challenges and operations. Following the conference presentations, slides will be posted here for download by our web visitors.
The Free “OSHA in Healthcare” Webinar
Dr. Scott Harris will present “OSHA in Healthcare: Out of Sight and Out of Mind?” in a free webinar sponsored by PureSafety on Thursday, October 20, 2011 at noon central time. Registration is open to all interested parties.
What does OSHA think about safety efforts in the healthcare sector? Hint: “a weak culture of worker safety…” Who is getting inspected and what are they finding? How exactly does OSHA apply to Healthcare settings? Does The Joint Commission cover applicable OSHA standards? Healthcare incident rates are double the national average? Is there a new standard coming on infection control? Does a reported 99,000 patient deaths per year from healthcare-acquired infections have something to do with that?
IESO Presenting at 2011 PureSafety Conference
On Tuesday September 14, 2011, Dr. Scott Harris will present ”OSHA in Healthcare: Out of Sight & Out of Mind?” at the 2011 PureSafety Conference in Nashville, TN. He is one of a handful of industry speakers invited to participate in the event. Our web visitors can download sneak preview slides of Scott’s presentation here. A technical paper on this presentation is scheduled for publication in OSHATracker in September. Sorry, no release until then, but we will post it here as soon as it’s out.
So what is all the fuss about? Based on a number of generally accepted myths about OSHA, members of the healthcare community may think that management would be justified in taking little or no additional action to prevent the spread of occupationally acquired infectious diseases or deal with other OSHA issues. The facts say otherwise.
Posted in Health and Safety Compliance, Hot List, Risk Management
Tagged "Dr. Scott Harris", "healthcare industry", "ieso llc", "iesollc", "Joint Commission", "kenneth Harris", "Kenneth Scott Harris", "public health", "Scott Harris PHD", "Scott Harris", "The Joint Commission", IESO, nosocomial, nosocomials, OSHA, oshatracker, puresafety, RFI, TJC
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Asking for it: Have Healthcare OSHA Myths Created a Storm?
How can so many healthcare professionals think that healthcare is exempt from OSHA requirements or that compliance with The Joint Commission covers it? Does OSHA even inspect hospitals? How often and where? Will you get cited for violations, and what about penalties? How much and for what? Who’s doing more healthcare inspections – States or Feds? What are the top findings? What about complaints? The highest illness and injury rates IN THE NATION? 99,000 patient deaths per year from things they caught at the hospital?? You can’t be serious! Not at MY hospital!
Posted in Health and Safety Compliance, Hot List, Risk Management
Tagged "Dr. Scott Harris", "healthcare myths", "ieso llc", "iesollc", "Joint Commission", "kenneth Harris", "Kenneth Scott Harris", "public health", "Scott Harris PHD", "Scott Harris", "The Joint Commission", FOSC, healthcare, hospital, hospitals, IESO, ISO, OSHA, stats, storm, TJC
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IESO Supporting the 2011 KY Governor’s Safety Conference
IESO is working hard to support the upcoming 27th Annual Safety and Health Conference in Louisville, KY. On Tuesday, May 10, Drs. Keith Spencer and Scott Harris will conduct an 8-hour HAZWOPER refresher as a pre-conference workshop available at no cost to all registered conference attendees. Class size is limited, so register early. Successful attendees will receive a joint certificate from IESO, LLC and UNC-Chapel Hill.
On Wednesday, May 11, Dr. Harris will present “OSHA in Healthcare – Is a Storm Coming?” OSHA claims nosocomials to be among the leading causes of death in the United States, accounting for an estimated 1.7 million infections and 99,000 associated deaths in 2002. If accurate, hospital-acquired infections, these things you catch while you’re there for something else, kill more people in the U.S. every year than AIDS, drug overdoses, food-borne illness, murder, highway, rail and plane crashes, lightning, tornadoes, West Nile Virus and workplace fatalities COMBINED. This workshop explores OSHA coverage for Healthcare workers, the 2010 RFI, inspection rates and results and why OSHA may now be considering Healthcare a high-hazard general industry sector.
Posted in Health and Safety Compliance, Hot List, Risk Management
Tagged "Dr. Scott Harris", "general industry", "governors conference", "ieso llc", "iesollc", "Keith Spencer", "kenneth Harris", "Kenneth Scott Harris", "Scott Harris", "west nile virus", aids, healthcare, ky, nosocomials, OSHA, PhD", training, UNC
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Healthcare NIMS: Do You Speak the Language?
By Presidential Directive the National Incident Management System (NIMS) is the “common language” for all Federal, state and local responders. Healthcare personnel within a response structure should have completed four specific FEMA courses (IS-700.a, IS-800.b, IS-100.HCb and IS-200.HCa) by 2009 if they received FY 2008 ASPR funding. Many, if not most, failed to meet this requirement, leaving a huge preparedness gap. The goal is to strengthen medical surge capacity, and it is not optional. HHS requires hospitals to implement 14 specific NIMS objectives ranging from formal adoption to updated EOPs to mutual aid agreements, training and exercises. The courses take only two days and complete two of the 14 steps for your NIMS implementation effort. An experienced instructor is critical. Download the informational brochure here.
The New OSHA 30-Hour Class for Healthcare – Should We Care?
OSHA claims nosocomials to be “among the leading causes of death in the United States, accounting for an estimated 1.7 million infections and 99,000 associated deaths in 2002.” If accurate, hospital-acquired infections, these things you catch while you’re there for something else, kill more people in the U.S. every year than AIDS, drug overdoses, food-borne illness, murder, highway, rail and plane crashes, lightning, tornadoes, West Nile Virus and workplace fatalities COMBINED.
OSHA has publicly stated, “The healthcare sector as a whole experiences 1.3 times the injury and illness rate for private industry, with hospitals even higher, at 1.8, and nursing homes fully double.” They describe healthcare as having “a weak culture of worker safety” related to a lack of data on the prevalence of infections among healthcare workers (HCWs) and “a lack of effort by healthcare employers” in tracking or documenting them. OSHA thinks too many of an estimated 16.5 million HCWs are getting sick at work and that voluntary standards are not working, largely due to poor safety programs and lack of regulatory oversight.
Posted in Health and Safety Compliance, Hot List, Risk Management
Tagged "Dr. Scott Harris", "healthcare industry", "healthcare practice specialty", "healthcare workers", "ieso llc", "iesollc", "kenneth Harris", "Kenneth Scott Harris", "nosocomial infection", "osha 30-hour", "outreach trainer", "outreach trainers", "public health", "Scott Harris PHD", "Scott Harris", ASSE, HCW, healthbeat, healthcare, hospital, HPS, IESO, nosocomial, nosocomials, OSHA
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Join Us in Fort Lauderdale in January!
The 31st annual UNC Winter Institute is scheduled for January 31 to February 4, 2011 in Fort Lauderdale, FL. The Institute is designed for industrial hygienists, safety and environmental managers, occupational physicians and nurses and anyone else involved in EHS management. 25+ courses will cover everything from regulations to industrial hygiene to environmental health, all eligible for recertification points toward your CHMM, CIH, CSP and other professional certs.
IESO will be there instructing Fundamentals of Environmental Health and the all-new OSHA 30-Hour General Industry for Healthcare course. Many healthcare personnel have noted that the standard 30-hour OSHA course has little in common with their needs, and so this course was designed from the ground up by IESO to meet the specific needs of the healthcare industry. Our first-of-its-kind course will familiarize you with applicable OSHA standards while focusing on hazard recognition and prevention. Special emphasis is placed on those areas that are the most hazardous, using OSHA standards as a guide. It meets all OSHA requirements for time and content, and attendees who successfully pass the course will receive their 30-hour completion card.
Posted in Health and Safety Compliance, Hot List, Risk Management
Tagged "Dr. Scott Harris", "environmental health", "general industry", "healthcare industry", "ieso llc", "iesollc", "Joint Commission", "kenneth Harris", "Kenneth Scott Harris", "osha 30-hour", "osha 511", "Scott Harris PHD", "Scott Harris", "winter institute", chmm, cih, healthcare, hospital, IESO, OSHA, TJC, UNC
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Healthcare Presenters Needed for ASSE 2012 PDC
Dr. Scott Harris of IESO, L.L.C. is chairing the search committee for healthcare speakers at the 2012 ASSE Professional Development Conference (PDC) scheduled for June 3-6 in Denver, CO. The Healthcare Practice Specialty (HPS) serves safety, health and environmental (SH&E) professionals who work in healthcare institutions such as hospitals and nursing homes and other segments of the healthcare industry. Potential topics might include hazmat for healthcare, mass casualty planning, National Integrated Accreditation for Healthcare Organizations (NIAHO), ISO management systems, patient handling ergonomics, nosocomials and infection control, electrical safety and arc flash studies or any other relevant topics of interest to healthcare SH&E representatives. You do not have to be an ASSE member or healthcare employee to present.
Posted in Health and Safety Compliance, Hot List, Management Systems, Risk Management
Tagged "ASSE 2012", "ASSE PDC", "Dr. Scott Harris", "healthcare accreditation", "healthcare industry", "ieso llc", "iesollc", "kenneth Harris", "Kenneth Scott Harris", "Scott Harris PHD", arcflash, ASSE, DNV, HPS, IESO, NIAHO, OSHA, PDC
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IESO Responds to the Deepwater Horizon Spill
In support of BP’s response to the 2010 Deepwater Horizon oil release, Dr. Scott Harris served as the Planning Specialist embedded with the U.S. Coast Guard in Sector Key West. As part of the O’Brien’s Response Incident Management Team (IMT), he successfully integrated resource Trustees, including the National Park Service and U.S. Fish and Wildlife, into the planning process to develop site-specific tactical response plans for protection of the Dry Tortugas National Park, the Marquesas Islands, the Lower, Middle and Upper Keys and the southern Everglades. 
The plans, which became addendums to the Area Contingency Plan (ACP), addressed a multitude of threatened and endangered species, refuges, marine sanctuaries, cultural artifacts and sensitive ecosystems unique to the Keys.
Posted in Hot List, Risk Management
Tagged "Area Contingency Plan", "BP oil spill", "coast guard", "Deepwater Horizon", "Dr. Scott Harris", "Dry Tortugas", "ieso llc", "iesollc", "kenneth Harris", "Kenneth Scott Harris", "key west", "Marquesas Islands", "oil spill", "Scott Harris PHD", ACP, DRTO, DWH, everglades, florida, gulf, IESO, keys, oil, USCG
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Arc Flash: Who’s Training the Trainers?
Whether giving or getting arc flash training, have you considered whether the trainer is “qualified,” “effective,” “proficient” or “competent” for the job? Is the training content “adequate?” How can we tell? Does it matter?
Many OSHA standards require employee training, but are vague on trainer qualifications. HazCom requires only “effective” training. HAZWOPER specifies that trainers have “the training and/or academic credentials and instructional experience necessary to demonstrate competent instructional skills and a good command of the subject matter.” The Bloodborne Pathogens standard requires only that the training record include “the names and qualifications of the persons conducting the training.” No definition of credentials or “effective” training other than by performance failures, i.e., accidents. “Competent” or “proficient” are often decided by incident investigations or lawsuits. Remember, paperwork is the first place “they” look!
Posted in Health and Safety Compliance, Management Systems, Risk Management
Tagged "accident investigation", "arc flash", "Dr. Scott Harris", "electrical safety", "ieso llc", "iesollc", "kenneth Harris", "Kenneth Scott Harris", "nfpa 70e", "OHSAS 18001", "safety alert", "Scott Harris PHD", "Scott Harris", "train the trainer", arcflash, competent, credentials, hazcom, IESO, lawsuit, litigation, NFPA, nfpa70e, OSHA, proficient, qualified, training
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Joint Commission Requirements for NIMS in Healthcare
A Presidential Directive established the National Incident Management System (NIMS) as the “common language” for coordinated multi-agency responses for all Federal, state and local responders, including healthcare. Hospitals are required by The Joint Commission (TJC) to implement 17 specific NIMS activities ranging from formal adoption to updated EOPs to mutual aid agreements, training and multi-agency exercises. Coordination, planning and communication are key elements.
TJC specifies certain FEMA courses (IS-700, IS-800, ICS 100 and ICS 200), with the intended role of the responder dictating the type and depth of training required. Trainers should have demonstrated experience as an Incident Commander in a NIMS environment. HICS (Healthcare Incident Command System) training alone does NOT meet the NIMS requirements, but can supplement the program. HICS incorporates standard Incident Command System (ICS) principles, but with modifications for healthcare. IESO recommends “NIMS for Executives” for healthcare executives who need a working awareness of NIMS and their correct role in an event as facilitators.
Posted in Health and Safety Compliance, Management Systems, Risk Management
Tagged "Dr. Scott Harris", "FEMA courses", "healthcare accreditation", "healthcare industry", "ICS 100", "ICS 200", "ieso llc", "iesollc", "Incident Commander", "IS 700", "IS 800", "iso 14001", "Joint Commission", "kenneth Harris", "Kenneth Scott Harris", "NIMS for Executives", "OHSAS 18001", "proposed rule", "public health", "Scott Harris PHD", "Scott Harris", "The Joint Commission", audit, auditing, EOP, FEMA, HICS, hospital, IC, IESO, NIMS, OSHA, TJC, training
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OSHA Looking Hard at Healthcare Worker Infectious Diseases
In the May 6, 2010 Federal Register, OSHA published a Request for Information (RFI) to collect information from the healthcare industry on “occupational exposure to infectious agents in settings where healthcare is provided.” This includes hospitals, outpatient clinics, clinics in schools and correctional facilities and “healthcare-related” settings ranging from laboratories that handle potentially infectious materials to medical examiner offices to mortuaries. OSHA is specifically interested in current infection control strategies and practices and will use the information to “determine what action, if any, the Agency may take to further limit the spread of occupationally-acquired infectious diseases in these settings.” The deadline for comments is August 4, 2010. Download our Healthcare Alert for a brief summary.
Posted in Health and Safety Compliance, Hot List, Management Systems, Risk Management
Tagged "Cal-OSHA", "culture of safety", "Dr. Scott Harris", "exposure control", "healthcare accreditation", "healthcare industry", "healthcare worker", "healthcare workers", "hospital acquired infection", "ieso llc", "iesollc", "infection control", "infectious agent", "iso 14001", "kenneth Harris", "Kenneth Scott Harris", "management systems", "nosocomial infection", "occupational exposure", "proposed rule", "public health", "safety culture", "Scott Harris PHD", "Scott Harris", "The Joint Commission", "winter institute", "worker training", ADT, HAI, HCW, IESO, infection, nosocomial, OSHA, RFI, TJC, training
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Arc Flash Alert for Healthcare
Hospitals are covered under the OSHA/NFPA 70E requirements. Arc flash/blast incidents can cause severe employee injury and loss of electrical power to key functions of patient care, while the cost of injury treatment may exceed $1,000,000 per case with permanent disability and probable litigation. As one Director of hospital engineering services recently told us, “There are systems in the hospital that we just can’t shut down, and must perform our inspections on live parts.”
We recently published an article on our website in which we continue to recommend the rigorous analysis prescribed by IEEE 1584, and warn against “quickie” or generic 70E arc flash solutions. An industrial facility asked IESO to evaluate arc flash results from another firm that reportedly used a customized program for arc flash analysis. The facility management was concerned about the lack of time the consultant spent on-site, the minimal review of electrical components and the generic results. Our review revealed highly inaccurate information on 90% of the labels including incident energy ratings underestimated by 200-450%, clearly endangering employee safety.
Posted in Download Center, Health and Safety Compliance, Risk Management
Tagged "arc blast", "arc flash analysis", "arc flash", "Dr. Scott Harris", "electrical safety", "healthcare accreditation", "healthcare industry", "ieee 1584", "ieso llc", "iesollc", "iso 14001", "Keith Spencer", "kenneth Harris", "Kenneth Scott Harris", "nfpa 70e", "safety alert", "Scott Harris PHD", "Scott Harris", arcflash, audit, hospital, hospitals, IESO, nfpa70e, OSHA, training
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IESO Presenting at 2010 KY Governor’s Safety Conference
Dr. Scott Harris has been accepted to present at the 2010 Governor’s Safety and Health Conference in Louisville, KY. On May 5 Scott will present “Macdona, TX Derailment and Chlorine Release.” Our web visitors can download an exclusive copy of Scott’s presentation, including audio from 911 and emergency dispatch calls.
So, what happened in Macdona? On June 28, 2004 a predawn train collision and derailment just outside of San Antonio released 60 tons of chlorine in less than three minutes. Misunderstood initial 911 calls sent responders on a “smoke run,” nearly killing the first arriving units. Misinformation, fatalities,
Posted in Hot List, Risk Management
Tagged "chlorine cloud", "chlorine release", "cost recovery", "Dr. Scott Harris", "ieso llc", "iesollc", "kenneth Harris", "Kenneth Scott Harris", "macdona crossing", "macdona tx", "public health", "san antonio", "Scott Harris PHD", "Scott Harris", "train derailment", "train wreck", "Union Pacific", "UP railroad", bnsf, chlorine, derail, derailment, EPA, FOSC, IESO, koerber, macdona, osc, PRP, PRPs, RP, texas, train, tx, UP
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OSHA Regulation Alert: Combustible Dust Rule is coming
On October 21, 2009 OSHA announced a proposed rule to address combustible dust explosions. The rule would cover an estimated 16 million employees at approximately 426,000 facilities. OSHA first addressed this issue in 1987 by promulgating 29 CFR 1910.272 for grain handling facilities. In the 10 years prior to adopting that rule, there were 20.5 grain handling-related dust explosions per year in the U.S. For the next 10 years there were 10.3, and from 1998-2007 there were 6.3 per year.
Following the 2008 Imperial Sugar explosion in Georgia, which killed, hospitalized or severely burned numerous employees, OSHA has been aggressively working toward drafting a comprehensive rule to address the larger issue of dust explosions in general industry, not just grain handlers. Between 2007-2009, OSHA conducted 813 targeted inspections on affected facilities, issuing 3,662 citations primarily via the General Duty Clause. In summarizing their findings, OSHA noted that 32 industry or consensus standards (i.e., NFPA, ASME, ANSI) address combustible dust, but that no single, comprehensive rule or standard exists.
Posted in Health and Safety Compliance, Hot List, Risk Management
Tagged "combustible dust explosion", "combustible dust explosions", "combustible dust", "Dr. Scott Harris", "dust assessment", "dust explosion", "general duty clause", "grain dust", "hazard assessment", "ieso llc", "iesollc", "kenneth Harris", "Kenneth Scott Harris", "nfpa 484", "nfpa 654", "osha inspection", "proposed rule", "Scott Harris PHD", "Scott Harris", assessment, audit, auditing, audits, dust, explosion, IESO, inspection, inspections, ISO, OSHA
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IESO Presenting at 2010 ASSE Conference
Dr. Scott Harris, PhD, Global Risk Manager for IESO, has been accepted to present at the 2010 ASSE Professional Development Conference in Baltimore, MD. On June 14 Scott will present “Chalmette, LA: First Katrina, Then the Oil…” Our web visitors can download an exclusive copy of both Scott’s presentation slides and proceedings paper with the first-hand story right from the front line. UPDATE: Download the audio of Scott’s presentation.
So, what happened in Chalmette? Following Hurricane Katrina, over one million gallons of crude oil from the Murphy Oil USA (MOUSA) Refinery in Meraux, LA released into a populated area. Search and
Posted in Download Center, Hot List, Risk Management
Tagged "Dr. Scott Harris", "hurricane katrina", "ieso llc", "iesollc", "kenneth Harris", "Kenneth Scott Harris", "murphy oil", "new orleans", "oil spill", "oil spills", "pdc 2010", "Scott Harris PHD", "Scott Harris", "search and rescue", "st. Bernard Parish", "winter institute", ASSE, chalmette, EPA, FOSC, IESO, katrina, mereaux, mousa, nola, oil, oiled, PRP, refinery, spill
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Is Your Lightning Protection Really Protecting You?
Do you have structures with lightning protection? Is it properly installed? How can you tell? While conducting a recent mock VPP audit, IESO discovered that a lightning protection system being installed did not comply with NFPA 780, the Standard for the Installation of Lightning Protection Systems.
Down-conductors were exposed inside the structure and improperly bonded to surrounding ground systems, which could have caused a sideflash during a strike. Anchor points were set in mortar joints,
rather than brick and concrete, and numerous down-conductors had bends of 90 degrees in less than the required 8-inch span. These “tight” bends greatly reduce carrying efficiency and increase the risk of sideflash as the bolt attempts to “find the path of least resistance.” Imagine the system doing exactly what it should do by capturing a strike, then routing several hundred million volts and 20,000 amps INSIDE your facility fully exposed to employees, equipment and raw and finished materials, in this case flammable liquids!
IESO Client Receives First-of-its-Kind State Grant for OHSAS 18001
Philips Lighting in Danville, KY will develop and implement their OHSAS 18001 program using in-part the first-ever Bluegrass State Skills (BSSC) grant awarded for a health and safety management system. The $25,000 grant from the Kentucky Cabinet for Economic Development was the product of a cooperative effort between IESO and BSSC and their legal department. Historically the grant program excluded health and safety from eligibility, but IESO successfully negotiated a great outcome for our client.
Posted in Health and Safety Compliance, Hot List, Management Systems, Risk Management
Tagged "bluegrass skills", "bluegrass state skills", "Dr. Scott Harris", "health and safety", "ieso llc", "iesollc", "kenneth Harris", "Kenneth Scott Harris", "OHSAS 18001", "philips lighting", "Scott Harris PHD", "Scott Harris", "tax credit", "tax credits", bssc, grant, health, IESO, inspection, inspections, ohsas, OSHA, safety
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Arc Flash Safety Alert!!!
IESO, LLC recently published an arc flash article (http://iesollc.com/wordpress/2009/06/22/arc-flash-safety-history-and-requirements/) on our website. We continue to recommend the rigorous analysis proscribed by IEEE 1584, and warn against “quickie” or generic solutions. This safety alert illustrates a real-world example of why that is.
An industrial facility recently asked IESO, LLC to evaluate arc flash results from another consultant who reportedly used a customized program developed in-house. The facility management team was concerned about the lack of time that the consultant spent on-site (less than five hours), the minimal review of electrical components and the generic results. Labels for all electrical components were identical whether for buss plugs, MCC panels or substation switchgears, and the facility staff had serious doubts that they got what they paid for.
Outbreaks and Getting Back Online
It seems the news these days often 
carries stories about viral, bacterial and related disease outbreaks. We all hear and worry about the “usual suspects” such as Norwalk Virus on cruise ships (“cruise ship virus”) or whether we can catch TB, flu or other diseases on an airplane (yes). Even hospitals are not safe from these threats. Johns Hopkins Hospital had a Norwalk outbreak in 2004, described as “one of at least 24” in Maryland in just the first half of that year. That incident lasted three months, sent 13 employees to the emergency room or the hospital, and cost JHH over $650,000. Across the country hospitalized patients are contracting clostridium difficile (c. diff), with up to 438 patients dying every day.
Posted in Download Center, Hot List, Risk Management
Tagged "antibiotic resistant", "clean up", "cleanup office", "cleanup school", "cruise ship virus", "Dr. Scott Harris", "ieso llc", "iesollc", "kenneth Harris", "Kenneth Scott Harris", "national decon team", "norwalk virus", "outbreak coverage", "return to service", "Scott Harris PHD", "Scott Harris", "staph infection", "super bugs", anthrax, biohazard, cleanup, decon, decontamination, disease, disinfect, disinfection, flu, FOSC, FOSCs, germs, hospital, IESO, mdr-tb, mrsa, ndt, norwalk, office, osc, OSCs, outbreak, outbreaks, school, staph, tb, who, xdr-tb
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Another IESO Client Receives State Grant to Pay for ISO 14001
An IESO client in southcentral KY will develop and implement their ISO 14001 Environmental Management System (EMS), joining world-class operations around the globe in embracing progressive, reliable environmental management. Luvata – Franklin will be the first facility in their corporation to implement the EMS, and expects real benefits from their new program.
Luvata is a world-leader in metal fabrication, component manufacturing and related engineering and design services, with around 8,000 employees in 18 countries. The Franklin facility is a leading producer of copper and specialty tubing products for the residential and commercial HVAC industry.
Posted in Environmental Compliance, Hot List, Management Systems, Risk Management
Tagged "bluegrass skills", "bluegrass state skills", "Dr. Scott Harris", "environmental management system", "environmental management systems", "environmental management", "iesollc", "iso 14001", "kenneth Harris", "Kenneth Scott Harris", "luvata franklin", "Scott Harris", bssc, EMS, IESO, ISO, iso14001, luvata
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Pending “Drinking Water System Security Act of 2009″
A new bill covering drinking water facility security is being considered by the House Energy and Commerce Committee, and will shortly be introduced. Until now, water facilities have been exempt from the requirements of Chemical Facility Anti-Terrorism Standards (CFATS), which expires in late 2009. The Drinking Water System Security Act of 2009 will apparently replace or update those requirements and remove the water facility exemption.
At most water facilities the “substance of concern” is gaseous chlorine, frequently held in one-ton cylinders. Like many hazardous substances, chlorine is a very useful material that also poses significant risk. In this case it is a long-established component of clean drinking water, providing disinfection. It creates the “bleach” smell we might note in our tap water. On the other hand, both sides also used it as a weapon in WWI, though not a particularly effective one.
Posted in Hot List, Management Systems, Risk Management
Tagged "chemical facility", "chemical of concern", "Dr. Scott Harris", "drinking water security act", "drinking water security", "drinking water system security act of 2009", "drinking water system security act", "drinking water", "iesollc", "kenneth Harris", "Kenneth Scott Harris", "public health", "risk management", "rmp chlorine", "Scott Harris PHD", "Scott Harris", "vulnerability assessment", "vulnerability assessments", "water system security", "water systems", cfats, chlorine, csat, EPA, IESO, rmp
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Plastics in Construction? Talk with Your Carrier!
Some insurance companies, for example IF Group (http://www.if-insurance.com/web/industrial/Pages/default.aspx), recently added a “Plastics in Construction” clause to their coverage requirements for industrial clients. They are concerned about composite panels with combustible isolation materials such as polyurethane (PU), polystyrene (EPS) or polyisocyanureate (PIR), and indicate recent severe losses related to this.
In the case of IF Group, the new clause is still a recommendation, but it looks certain to become a requirement, since they are already referring to it as a “regulation.” Other Carriers may or may not follow suit, but if they see risk or exposure on the issue, expect them to aggressively manage it with this or a similar tool. Either way, none of us want plastics fires in the workplace, and those that have seen them especially understand that.
Posted in Health and Safety Compliance, Hot List, Risk Management
Tagged "composite panels", "Dr. Scott Harris", "iesollc", "insurance carriers", "insurance clause", "kenneth Harris", "Kenneth Scott Harris", "non-combustible", "plastics in construction", "Scott Harris", carriers, composite, EPS, fire, IESO, insurance, PIR, plastics, polyisocyanureate, polystyrene, polyurethane, PU, sandwich
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Guidance on the Use of Chemical Countermeasures on Inland Oil Spills
Guidance on the Use of Chemical Countermeasures on Inland Oil Spills
The U.S. Environmental Protection Agency (USEPA) recognizes the major role of local government responders, such as firefighters, as the first line of defense for mitigating threats to public health and the environment from spills of oil and hazardous substances, and tries to provide them with the tools necessary to safely and effectively mitigate such incidents. Chemical countermeasures (CCMs) are one of those tools, but their use must be authorized and carefully managed. This article describes that process where countermeasures are proposed for use on inland events such as fuel spills that may affect navigable waters. These may include surface waters and conduits to them, including road ditches and storm drains, though the exact definition remains in flux.
Posted in Environmental Compliance, Resources, Risk Management
Tagged "chemical countermeasure", "Chemical Countermeasures", "Dr. Scott Harris", "first responder liability", "fuel spill", "fuel spills", "iesollc", "inland oil spill", "inland oil spills", "kenneth Harris", "Kenneth Scott Harris", "navigable waters", "oil spills", "product schedule", "Scott Harris PHD", "Scott Harris", "subpart j", CCM, CCMs, dispersant, dispersants, EPA, IESO, ncp, nrc, osc, rrt
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Healthcare and ISO?
The U.S. healthcare industry has only barely noticed ISO or similar internationally recognized EHS management approaches. Reports are that only a handful of these facilities are accredited to the ISO 14001 (Environmental Management System) or the OHSAS 18001 (occupational safety and health) standards. This is an industry that would benefit greatly from what the rest of us already know — that good environmental, health and safety management systems work, and much better than traditional “catch and release” compliance audits and inspections.
On page 11 of this ASSE Newsletter, (healthbeat-newsletter-20091) there is an excellent article (“An Ever-Changing Environment”) comparing the “management system versus inspection” approach. The author, who sits on the ASSE Healthcare Practice Speciality Committee, makes a strong case for the use of a reliable EMS.
Posted in Hot List, Management Systems, Risk Management
Tagged "Dr. Scott Harris", "healthcare accreditation", "healthcare industry", "kenneth Harris", "Kenneth Scott Harris", "management systems", "Scott Harris PHD", "Scott Harris", "Tony Stewart", accredited, ASSE, DNV, EMS, healthcare, ISO, PhD"
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On Being an EPA Superfund PRP
On Being an EPA Superfund PRP
CERCLA, more commonly known as Superfund, allows EPA’s Emergency Response Program to take or compel action by others at sites contaminated or potentially contaminated by hazardous substances, pollutants or contaminants, and then recover costs associated with those activities. Whether an emergency response or a longer-term investigation and cleanup, EPA uses an Enforcement First Policy (EFP) to identify potentially responsible parties (PRPs) to cover the cost of any action underway or anticipated. The hunt for you will be thorough, and there is a specific 381-page manual to guide it. There is even a directory of Agency experts (PRP Search Enhancement Team) available to support the effort.
Posted in Environmental Compliance, Resources, Risk Management
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