Bonus Episode! Safety Unscripted: Your Questions, Expert Answers

Jill James:

This is the Accidental Safety Pro brought to you by HSI. This episode was recorded February 5th, 2026. My name is Jill James, HSI's Chief Safety Officer. As an EHS professional, have you ever wished there was some kind of hotline where you could call a certain number and EHS professionals would be on standby to answer any question you had? Kind of like how Butterball Turkey does that around Thanksgiving every year, you can call the Turkey Hotline and ask any question you want about cooking a turkey. Well, back on January 28th of this year, my longtime friend and colleague, Dr. Todd Loushine, who's associate professor at the University of Wisconsin-Whitewater, and I did exactly that. No, it wasn't about turkey, though I have worked in that industry. It was a webinar where any EHS professional could ask us anything about EHS they wanted, and we answered what we could, as fast as we could. Hundreds of questions came in through the registration and during the live event. We sorted like with like and tried to bulk answer where we could. It was fun and a little intimidating. As podcast listeners, I bet many of you have the same kinds of questions. So we're sharing portions of the webinar recording with you all here for this special episode of the podcast. Webinar attendees asked for a part two, so we scheduled a second session for Wednesday, February 25th. If you want to attend and see what this is all about and ask your own question, a registration link is in the show notes. Enjoy today's show. Hi everybody. My name is Jill James. I'm Chief Safety Officer here at HSI. And with me today is my almost lifelong friend. Todd, you want to introduce yourself?

Todd Loushine:

Oh, am I frozen?

Jill James:

You were. Yeah, you were.

Todd Loushine:

Okay.

Jill James:

We can hear your voice.

Todd Loushine:

Everybody. I'm Todd Loushine. I'm an associate professor at the University of Wisconsin-Whitewater. Glad to be here.

Jill James:

Yeah. Todd and I have been ... Literally, we've known one another for ... Oh, Todd just dropped out. Coming back in. There it goes. You're active now. Yeah. Glitching. It's cold outside. Todd and I have known each other for 32, 33 years. We started out our careers together working as investigators with OSHA, and we come back together several times a year, regardless of where we're working in our careers, to be able to do things like this because it's professional fun for us and a way for us to give back to the profession. So our format today, I want to say, if Christie, if you want to go to the next slide. When we asked everyone who registered to submit a question if they had one, you did. You did. And we have over a hundred questions. Over a hundred questions came through, thoughtful questions. Thank you all so much for that. So what we did with those questions is we put them into buckets or groups, and you can see those on the screen right now so that we, instead of trying to take one at a time and never being able to get through all of them today, we just put them into groups so we could answer things kind of in mass and be able to go along. So our format for today is we are going to cover number one through four in the first about 40-ish minutes of the webinar. And then the remainder we will answer on a part two of this that's coming in February and we'll give you the date at the end of this broadcast. And then the last about 20 minutes or so of our time together today, you'll be able to submit your questions through the Q&A and put Todd and I in the hot seat and we'll do our best to be able to answer your questions. So that's the format for our time together today. And thanks again for everything that you submitted to us. It was really fun reading all your questions. All right. Should we get into it? All right, all right, all right. So our first group about program building and governance and core safety systems. So I'll take this first question. Someone saying, "I'm new to the role and I've never done a fire drill. Where do I go? What do I do? How do I start that?" I would start by using someone in your own community who can help you with this. And by in your own community, I mean go to the fire department, get to know your fire chief or the deputy chief and say, "Hey, I haven't done a fire drill before. Can you give me some best practices? Or do you even want to come into our facility and do something with us and guide me through that?" When I first started out, I got to know my chief immediately. Another reason to know your fire chief in your community is that they have access to other regulations that you might not have access to that you have to pay for, like ANSI standards. Todd, I know that's what I did. I would go and sit in the chief's office and read regulations that the government wasn't paying for me to have access to at the time, so it was good. Let's see. What else? Learning about ... Todd, do you want to take the next one?

Todd Loushine:

Yeah. So this one is kind of a broad response because everybody is going to have different types of responsibilities depending on what company they're in. My recommendation, because I'm teaching freshmen about getting into a career in safety, that if you are out there on your own trying to figure this stuff out, you need help. This isn't something that you can completely do on your own. I would recommend that you start a project planner. Step one would be, what are the risk centers for my organization? What should I really be focusing on? Because you want to prioritize your focus, but then you should have a separate one for professional development. Now, whether it's tapping into resources like HSI, whether it's joining a local safety group, you got a lot of work ahead of you. This is lifelong learning. Jill and I are still learning. We're going to teach you how we will find answers based on some of the questions you pose to us. But step one is try to figure out what are the main risks or issues you need to focus on because that's where a majority of your energy should go. Secondly, what are you going to do to increase your own professional development? And that is lay out certain milestones as you go through. But as far as us being able to predict to say, "Well, if you get A, B, and C, you should be able to do this." You can't do that. We don't have that in the books yet. Jill?

Jill James:

Yeah. Yeah. So the third bullet there, super new to the position, looking at information on the basics of the job. So when this session is over, Christie will share with you a landing page that we've created for you with resources that we have collected to share with you, and you'll also get them emailed to you as well. And so for that one, we have a white paper that we've had for a long time that Christie and I actually co-wrote together called The Five Essential Elements of Workplace Health and Safety. And it really is just going over what are the minimum compliance things that you need to have in place in order to do this work. And so that resource is available for you and all of the things you need to know about it. So that would be a place to start there. All right. Todd, you want to take another one?

Todd Loushine:

Yeah. Do you want me to take the leading indicator one?

Jill James:

Oh, sure. Yeah, do that.

Todd Loushine:

Okay. So somebody asks, right at the bottom, everybody, how do you determine whether a leading indicator is actually predictive of risk? A leading indicator are the things you do to affect an outcome. So we'd have to narrow the scope to really provide you some sort of context here, but if you're only measuring things that are outcomes, an injury, an accident, a leading thing to those is that you're doing something to mitigate the exposure or mitigate what the outcome might be. Now, that may be verifying that people are able to do the job the way as designed or to wear the PPE as designated because doing that should mitigate what that exposure might be. You'd have to go measure those things. So again, a leading is what will actually mitigate an exposure or the potential of an outcome, measure that kind of thing. That is a leading indicator. And if you do enough of the good stuff, less of the bad stuff should happen.

Jill James:

Mm-hmm. Great. And then two last things that I'll talk about before we move on to the next slide. Someone put a selfish, selfl- ... a plug for HSI in that bullet point about what tools does HSI have online. And so again, you'll be getting those ... Shameless plug was the word I was looking for. You'll be getting those in the landing page afterward. And also I'd like to draw your attention to, if you go to hsi.com, the resources tab has tons of information, including the recordings of all webinars Todd and I have ever done together, as well as others, lots of tools there. That's a good source for you. And then I guess I would like to just close out this slide by saying, when you're starting out and throughout your career, look to resources that can help you. So there's three that I always recommend. One is your insurance providers. And so when I say insurance providers, I mean workers' compensation provider, property, liability, casualty providers, an insurance broker if your company has a broker that's helping you source all of your other insurance companies. They have people that they employ just like Todd and I. They have health and safety professionals, they have industrial hygienists, and you are likely paying a premium and they probably owe you services, they're just not knocking on the door saying, "Hello, did you know that there's free things that you can get from us or discounted things?" If you need someone to do some air sampling, as an example, you could do that through insurance companies. So I really encourage you to find out who those partners are. Often in the insurance industry, they're called risk control professionals, to find out who they are and they can be your partner and so you don't have to reinvent the wheel on things. And then also encourage you to be part of a professional organization like ASSP, the American Society of Safety Professionals, and they exist to be able to support our work and to help educate us. And then finally, I would say industry groups. So if you're part of a particular kind of industry, often those industries have their own groups that have health and safety divisions within them. So for example, I've worked in the poultry industry for a number of years and they had their own national group for EHS professionals who worked in the poultry industry. And so I was able to be with a particular cohort from where I worked and was able to share information, ask questions within my own industry. So I'd recommend that as well. Todd, anything before we move on here?

Todd Loushine:

Nope. Next one.

Jill James:

Okay. All right. Into operational hazards and technical safety scenarios. Are there any standards for lone workers? So OSHA themselves doesn't have anything specific on lone worker safety. That doesn't mean that you shouldn't be trying to protect employees who work alone and looking at the risks that they're exposed to. From a compliance OSHA perspective, wherever there isn't an actual vertical standard as it's called, but there are known hazards, then OSHA leans into the general duty clause to cite employers for that. But that doesn't really answer your question like. How can I find out more information about what do I need to know about one worker safety? NIOSH, the National Institute for Occupational Safety and Health, has some information and help on lone worker safety. And then there are actually vendors that create products and guidance for employers who have employees who work alone. So I would look at vendors as well from that perspective. I'll take this next one on arc flash as well. Arc flash is a complex, that's a complex subject. And what's interesting about it is when we think about OSHA and arc flash, and where did all of that come from? So the National Fire Protection Agency has a regulation on arc flash and arc flash protection, and that would be one of those things I would go to my local fire chief and say, "Hey, chief, can I look at the NFPA regulations?" Those are the ones that he always had that I would read. And so what OSHA did was they said, "Okay, we're going to look at the NFPA regulation on this and what are we going to take and apply and turn into something that we're going to use for compliance in OSHA?" And what they did was they said, "We're going to enforce the personal protective equipment piece of it." The rest of it, yeah, we support that, but we're going to enforce the personal protective equipment piece of it. So that's where that gets a little confusing. And so you have to know about the NFPA rules around arc flash and the visual inspections and the gear that you have to wear and all of that business. And the only way you'd know that is through the NFPA or using a vendor that specializes in that. And in terms of, is an EHS professional qualified to assess arc flash hazards? Well, if you happen to be an electrical engineer, then the answer is yes. If you're not, probably not. So they have to do these really complex calculations to figure out what is an arc flash hazard and it starts at where the energy source comes into the community. And then there are all these calculations from it enters your community, it goes through these stages, it comes into your facility, and then it goes to these individual pieces of equipment, and then calculations are done to assess what is the risk, what is the hazard, what is the likelihood, and what is the level of personal protective equipment or the type of tools that have to be used? And those are things that are over my head, over Todd's head. Todd is a chemical engineer, not an electrical engineer, but those are the kind of calculations that are done by electrical engineers. All right.

Todd Loushine:

Hey, Jill. One of the members provided, I think, a response to help you out. I'll just say what they said. They said NFPA 70 is for electrical safety. NFPA 70B is for equipment maintenance. So for that-

Jill James:

There you go. Thank you.

Todd Loushine:

I didn't ask for permission to say who it was, so I'm just going to say thank you to that individual.

Jill James:

Thank you. All right.

Todd Loushine:

Do I [inaudible 00:15:31] next one?

Jill James:

Yes.

Todd Loushine:

All right. So the question is, under fall restraint versus fall arrest, what force must PFAS withstand? So what I did in preparation for this is I was taking your question and just dropping it into a search engine and seeing what would come up and then I'd verify. And what's interesting is the first one that came up was the OSHA technical manual, section five, chapter four, fall protection and construction. And under that particular standard, I got to re-click as it goes right to it, is that obviously the anchors need to be rated for at least 5,000 pounds, but the personal fall arrest itself needs to be able to only put into the worker 1,800 pounds. That's basically what it says. There are other measures as far as how far someone can fall. Is it possible that they could strike something and hurt themselves? Do you have a rescue plan? And there are other references as well. But for that answer, it's 5,000 for the connector, the anchor, and it's 1,800 pounds is the maximum resting force a worker can withstand. That's the limit.

Jill James:

Yeah, good. Keep going. Next two.

Todd Loushine:

Next question. Is there an OSHA or ANSI standard regarding anchoring warehouse racking? There isn't specifically one, but there is an ANSI standard out there. Let me click on it real quick. So it's ANSI RMI MH16.1 for rack columns. Yes, they do say you should. OSHA doesn't specifically require it, but it's a good idea. And it depends on the type of racking, I mean, and whether they can be bumped and somehow shifted or possibly damaged. I mean, if the shifting of a shelf itself could allow things to fall down or actually affect the capacity of the shelves, then yeah, you got to secure them and you might even have to put up some sort of protection or barrier so there isn't incidental bumping. So if you've got forklifts zooming in and out, yeah, you should really screw those things down. But I will always refer to the manufacturer's recommendations for installation first and foremost.

Jill James:

Exactly. Exactly.

Todd Loushine:

Should I take the next one too?

Jill James:

Yes, please.

Todd Loushine:

What are the pros and cons of using exoskeletons? Well, I actually sat through a two-hour seminar last semester and what was interesting is that, one, they're expensive, $5,000 and up. The other is they tend to be designed, one, for a resistance assist, so like a rubber band or something that's elastic or like a spring that will provide some ... Once you've activated, will provide the feedback itself. But then there's also some that require like an electrical charge and they provide some mechanical assistance through small engines or small motors. They tend to be ... No, an exoskeleton isn't something like the Iron Man suit or that really cool suit they used on Aliens. It's specific for a task, whether it's to reduce the amount of force on your low back or reduce the amount of force you put into your shoulders if you're going to be working overhead, whether it's grip strength, whether it's when you're walking, it actually reduces the forces of your gait. So it's specific. But what you can find is if you're in like a manual assembly or heavy assembly and there is a particular position or movement that is causing 80% of your issues, then I would explore some form of exoskeleton maybe as a currently what could we try versus completely automating it. That's my answer.

Jill James:

Perfect. Thank you. Christie, would you mind taking us to the OSHA website now and I'll answer the next three questions. So when Todd was talking earlier about places he was looking for things, this is the OSHA website. So OSHA.gov, this is what Todd and I always go to as our initial source of truth for everything. This is where we live and breathe. It's where we start for everything. And if you learn nothing else today, it's the power of the A to Z index that Christie's showing you right now on the OSHA website. So Todd mentioned earlier when he was geeking out about fall protection and said he went to the OSHA technical manual. If we click on the letter T and you're like, "What is the technical manual?" That would be the instructions that OSHA investigators like we used to be would follow for specific things. And so the technical manual is here. You can find what Todd was citing a minute ago through the technical manual. And then Christie, if you'll go back to the A to Z index, the next three questions, one of them was about what are the key elements of an effective emergency response plan for manufacturing? So again, going back to the OSHA website, we click on the letter E and that should take us to emergency response and emergency response planning, preparedness and response. And that landing page will give you a lot of resources and like what goes into a response plan? What are the things we should be thinking about? They'll give you resources and things that you can use for that. The other two questions, one was about AEDs. And so if we go back to the A to Z index and we look for AEDs, there we go. AEDs is right there. So the question was about what training requirements are required when placing an AED on site. You're going to be able to find your answers right here. So part of what we're doing today is also teaching you how to fish. And one of those really good fishing sites, a fish-rich environment is the A to Z index. And then the last question was about ladders, specifically a lot of questions about ladders. Again, A to Z index, we go to the ladder area. Ladders is ladders in there. Todd, where are the ladders? I thought we had ladders in there. All right. So now we'll find Christie's searching in there. So the ladder regulation is actually quite dense because it's broken down by type of ladder, if it's a fixed ladder or an extension ladder. We can just search the OSHA website for ladders, Christie. I mean, if we're really big geeks, Todd, we can probably cite the ladder standard off the top of our head. So yes, lots of different types of ladders, and you'll be able to find your information about placing, setting, inspecting, climbing, when do you need fall protection? What about cages? When does the cage start? It's all there. Do you want to wax poetic on anything on ladders? Christie's showing us the actual ladder regulation right now. You're muted, Todd.

Todd Loushine:

Sorry, I'm responding to somebody.

Jill James:

Oh, okay. You're good? Nothing to talk about with ladders? All right. All right. So A to Z index is your friend, is your friend. All right. Are we ready to move on? Okay. Training effectiveness and learning design, one of our other topics today. So how much training should be given to new employees in their first week? Gosh, I get asked this question a lot. Todd, I don't know about you, but this question gets asked a lot. Yeah. So the answer to that question is all of the training they need for the hazards they're going to be exposed to before they are exposed to those hazards. Okay. So does that sound like holy crap, am I going to have to do everything if we're going to drop them into this particular job and they're going from day one? Yes. Yes. Then they would need everything. If you're slowly ramping employees and they're doing a particular job task in a period of time and then they're moving on to something else, they're moving on to something else as you're ramping that employee, then the training would be matched with the exposures they have for those particular job tasks. Does that make sense? So the employees have to have the training before the exposure. If you need something to confirm that in your minds or something to share with maybe your safety department, your HR department, if you've heard of a documentary called Day's Work, the Day's Work, it's about a man named Day Davis who lost his life on the job in the first day, in the first hour of his temporary job because he didn't have the training needed for the types of hazards he was exposed to. I believe a Day's Work, and you can find it on a bunch of different resources. It's a documentary. It's very powerful. I interviewed the documentarian for the podcast that I host, the Accidental Safety Pro, as well. Okay. Todd, should we tackle PPE and these couple of PPE ones together?

Todd Loushine:

Yeah. I'm going to just comment on what you had said. Yes. You got to figure out what they need to know to start out their job, but also realize if you overload them, they'll remember nothing.

Jill James:

Right.

Todd Loushine:

So you need to keep it as basic as possible and it should integrate into basic aspects of how to do their job right away. And then you're just going to have to make sure you come back and revisit them or have a supervisor observe them so that they can actually incorporate what you're trying to train them to do to keep them safe. You don't want to leave them to themselves, to their own laurels, because if they observe a coworker who's experienced, but they've got the tribal knowledge, so they know how to avoid, but they're not following the training as prescribed, they are going to mimic that other worker almost 100% of the time. That's the natural way we learn is we tend to mimic others because then we feel like we're involved, we're part of that group. Okay. So yeah, next one. What PPE course do you suggest for retail and office workers? What sort of PPE do you think they'd be needing? Because anytime you prescribe any form of PPE, you have to do a JHA, or a job hazard analysis, to determine what is there and how the PPE will protect them. You may actually have to refer to ANSI standards to make sure you're choosing the correct one. My recommendation, and maybe Jill will follow up on this, is that if you find a vendor, what they'll do is they'll do that for you, and maybe they'll let you try out different forms. But when it comes to PPE and retail and office, Jill, help me out. What are you thinking? I'm struggling to try to figure out-

Jill James:

Yeah. I mean, what I am thinking is about what you had mentioned. So the personal protective equipment regulation, OSHA's regulation requires all employers to do an assessment of their workplace to determine if any of the jobs require personal protective equipment. And then if they do, if you determine that through your assessment, then it's what type of personal protective equipment is acceptable for that job. So PPE, retail. All right, here's what I'm thinking, Todd. You're working in a hardware store and your job involves cutting keys. You're going to cut keys. What do you need? Eye protection, right? So I'm thinking like retail, I'm thinking about that. I'm also thinking about the back room of the shoe store that I worked in in college and you had to climb a ladder, a rolling ladder to be able to access racks of things. Okay, that doesn't have to do with PPE, but it did when I had to dye the shoes. The chemicals in the shoe dye would fall under the hazard communication regulation and I would've needed hand protection and eye protection for the dye that I was using to die wedding shoes at the time. So again, it really depends on the type of work environment, the industry you're in. Retail to retail is different, office to office is different. The important part is the assessment that you're doing. All right, let's see. I guess, Todd, I can start out with the next one. Compliance, employee compliance with PPE requirements. How can we get employees to use their personal protective equipment? I'll start, and maybe Todd, you can wrap this one up. So you need to have policies that are enforceable in your workplace. So if the job requires employees to use particular personal protective equipment, then you need a policy that says, "If you're not using your personal protective equipment or following our lockout/tagout procedures or whatever confined space entry procedures, whatever it is, what is your progressive discipline plan?" Just like you would have if someone weren't showing up for work or weren't showing up for work on time. Same thing goes with safety, because the employee doesn't get to decide when they're not using the protective equipment that you determined they need. The buck stops with you. And so your job is to enforce the use of it. Todd, do you want to offer the softer side of that?

Todd Loushine:

Yeah. So if you find that workers aren't complying with your PPE requirements, why? They're not trying to get hurt on purpose. What is the reason for it? Is it uncomfortable? Is it getting in their way? Is it snagging on something? I know that there's been research out there that show the safety people tend to focus on, here's the hazard, let's fix the hazard or correct, mitigate. But the thing is, I think the way we should be practicing is helping the workers be effective in their job with as minimal risk as possible, and hopefully they elicit satisfaction from what they do. So we need to understand why they're not complying with the PPE. Is it uncomfortable? Is it getting in the way? Whatever it might be. There may be a compromise there, but you really need to talk to the workers to find out what's ... thinking it's okay to remove PPE when it's supposed to be there to protect them.

Jill James:

Yeah. The next one is about how do I convince field employees to go from paper forms to electronic forms? Yeah. Okay. So my snarky first response is take away the paper. Okay. How do we do that and how do you do that so it's not abrupt? What is the off-ramp plan that you have for that? To say our three-month, our six-month, our two-week, whatever it is plan to go from this to this and the stated reasons why you're going to go into electronic forms for consistency so information gets to people faster so that we can address issues that need to be addressed in a faster way rather than fill out the paper form, put it in something, wait for it to go, blah, blah, blah, all the different places. So what is the off-ramp to get people to move from that and being able to give employees an amount of time to adjust to that with engagement with them along the way on stopping points? It's not the, "We're squeezing off the faucet tomorrow," but here's why we're doing it and here's how you're going to engage with these electronic forms and this is what the benefits are to you and to our company. All right. Let's see. Todd, do you want to take this next one?

Todd Loushine:

The challenges about training, about remote?

Jill James:

Yeah.

Todd Loushine:

So the way I envision that is that these are people who are not coming into the office or into a particular work site. So therefore it's either virtual like this or it's pre-recorded or asynchronous. You're right, it is more difficult. It's very difficult to replicate classroom learning because there is both direct and indirect learning. There is-

Jill James:

Says the college professor who does both. Yeah. Sorry.

Todd Loushine:

Right, exactly. So it takes a lot more work. I mean, there's more responsibility on the individual to handle the material coming in and maybe self-reflection and assessment. I think whenever somebody goes, "Okay, let's do the training. We'll make it asynchronous so we're not wasting time at work. Here, watch this video, complete this true/false quiz." They learned nothing. All they did was try to get through it as fast as possible. You'd have to actually increase how you're assessing their learning. And there should be both qualitative and actually maybe some applied practical experience that they demonstrate to ensure that they know it. So just because it seems easier, it is not. And this is coming from someone who does a lot of online training both for undergrads and grads. It is so much more work when you're the trainer because how can you prove it? It's about all I got to say about that.

Jill James:

Sure. Next question is, what is the best type of LMS for comprehension? So LMS stands for learning management system. And so there's two thi- ... I want to just kind of break that apart. So an LMS, a learning management system, is where online courses would sit with or be housed within the learning management system. And so in terms of comprehension, it wouldn't be the LMS itself. It would be the type of courses that are within the LMS. And there's different learning modalities, different types of courses that could be within an LMS. You could have a basic video, right? Just a basic talking head kind of video. You could have a video that has a test or a quiz. You could have interactive courses. That would be a different type of learning modality where there's maybe threaded storytelling throughout an online course that stops at different points to test people's comprehension along the way with a final exam at the end. So in terms of best type, it would be best type for the learners that you have in terms of comprehension, understanding that there's a lot of different learning modalities that are out there. Now, when it comes to the learning management system where those learning modalities, those types of courses sit, then the question is, what do you need to get out of that learning management system? Are you using it for many, many employees throughout many different locations? What kind of reports do you want to get out of it? Is it a learning management system that's going to recommend a training for your employees based on the exposures they have? Is there some AI capabilities built into it that's going to make suggestions for you? Question that we get asked quite often at HSI because we do have courses and we have a learning management system is when they're being audited. When an employer is being audited, "Oh my gosh, I have to be able to ... They want to know this group of employees at this location and their training history for the last five years or their training history on this particular topic." So you want to be able to, if you're using an LMS, know what kind of information are you going to want to be able to get out of it from a reporting perspective for an audit, but also for you to be able to do your work with onboarding new employees or who has taken training or can you log training that's in person like Todd was talking about with in-person training before. And so do you have the flexibility to upload your own things that you're doing in person and to be able to have that record of employee training that was done within the LMS itself? And so two separate things with that one. Todd, should we maybe tackle the multiple languages and training dilemma?

Todd Loushine:

Yeah, I'll let you take a little break here. So when it comes to your biggest challenges in your training is that 80% of your crew is not fluent in English. Well, then you have to provide it in their language. There are some very user-friendly language learning software programs out there right now. You don't have to learn everything, just enough to be able to speak to them back and forth. That or you get an interpreter. I had to create some surveys and do some training in Spanish. I chose one of the safety committee members who was fluent both in English and Spanish, and they helped me. Sometimes they interpreted for me. Sometimes what they did is they helped me write the program so that people could read it and understand it. You must, you must do that. And I do think with AI now, it's getting a lot easier to translate, but if your crew is non-English speaking, you either teach them to speak English or you got to learn their language. That's required. You have to be able to communicate effectively. They have to be able to understand you.

Jill James:

Yeah. I think this particular dilemma, and it is a dilemma, and it is difficult, and yes, you are responsible for providing employees information in the language that they understand, per the OSHA regulations. I think this has gotten better. A number of years ago, I was working in the poultry industry. I've mentioned that. They had six different languages in the company that I worked for and I was part of the larger, remember I said poultry industry health and safety committee, and I would go there and I'd say, "I have six languages." And someone else would say, "I have 25 and a new one walking in the door every day." That is a huge challenge. And so going back to that question about learning management systems and courses and modalities that are online now, there are so many more opportunities than there were even just a few years ago for multiple language courses. So if you're going to buy training from somewhere, ask which languages they have and if they have the languages that you need and they're supported. So that is one way for you to do that. Yes, I've used interpreters. Yes, I've done the pass the microphone thing, interpreter to interpreter to interpreter. Oh my gosh, that's not scalable. So I guess I would really lean into what is repeatable so that same message is getting out. So if you're using courses that have been developed by subject matter experts and they have been translated into multiple languages, you know that the employees are getting the same information and you would want to find out through interpreters you have and your employees, like, is this actually landing? Is this the native language that I speak? So when I worked in the poultry industry, the employees we had from Myanmar, there wasn't a word in their language for turkey. So we had to come up with how are we going to describe the white big fluffy thing, right? So we need to do that if we're going to do exception management training, in-person training, that we're taking all those things into account as well. Navigating continued training. I want to pay attention to the time here. Continuing training. Yeah, right. So the OSHA regulations are really interesting on how often do you have to do training. And it's written regulation by regulation on when training is required to be repeated. So some of the regulations will say annual, like fire extinguisher training. Some will have a whole list of if-then statements. If this happens, then retrain. If that happens, then retrain. If that happens, then retrain. And some don't say anything, they're not addressing it at all and it's left to your discretion. A number of years ago, Christie, who's with us here today and driving the slides, she and I came up with an assessment tool that we call the OSHA safety training assessment. It'll be linked in the resources that you get. We read every single regulation. Yes, every single OSHA regulation. We mapped it to a question set where you can take an assessment to find out what kind of training you need. But what we did when we were working on that is we captured the frequency with which training has to be repeated for that subject if the regulation stated that. And so that's one way to get that information. Todd, do you want to take that last one?

Todd Loushine:

Well, can I really comment on some ... We've got some people who are on the webinar who are providing great examples of things they've done. One said that they "implemented a field training program where new hires shadow seasoned workers and a checklist is signed off by both. Our reporting improved when I began to explain why I needed documentation. Basically, I included them in the process. Now they report everything." So you can do this. So thank you for that. The other one said that, "I use ChatGTP to translate all my slides. Last thing I tell ChatGPT is five slides of what I've said in English and Spanish."

Jill James:

Beautiful.

Todd Loushine:

There you go. Thank you both for sharing that. And I both gave them kind of like a kudos for that. So the last question, and I know we want to get to the live stuff here, is looking for ways to improve our safety training for new hires and finding the balance between encouraging reporting and cracking down on infractions. Well, here's the thing. When people are afraid to report things because you're going to blame them and not look beyond them as the cause, they're going to stop reporting things. So there's a deeper issue here than trying to encourage these things. When I did new employee orientation at a plant that I was at, I was very cordial. I was very empathetic to what they're going to be getting into. And I just talked about the things they needed to know, but realized that if you ever have a question, you could talk to your supervisor or please come to me. And if I don't do my job, call OSHA on me. That I'm committed to not only helping you getting your job done effectively, but we're going to try to reduce the risk the best we can and I want you to enjoy working here. So that's the best way to take it is ... But here's the thing. You may have underlying perceptions of you're going to be blamed or treated unfairly out on the work floor, then you got your work cut out for you. So I think this is more of a psychosocial issue than an actual compliance or program issue. Jill?

Jill James:

Yeah. And I support reporting things early and often and creating a culture around early and often. Report everything. I don't care how minuscule it is. I want to see it. I want to see it. I want to hear it. I want to know about it through whatever electronic system you have or however you're collecting information from employees, because you as the professional will be able to assess, is this actually a thing? Because perception is ... People don't know. Employees don't know, is this really a thing or is it like, oh, we just do that one thing once a year. Is that really a problem? Report early and often, let them know that you'll help them. You'll let them know, is this something to worry about or not something to worry about? And that'll help build your culture as well. All right. Shall we move on? I can see Todd is answering questions. He can multitask better than I. Thanks, Todd. Appreciate it. That's why we partner. So our last topic that you sent questions in about is about leadership buy-in and management tension and business alignment. Oh my gosh, 32 years into this career, it is the age-old question. And Todd and I actually talk about this quite often at national conferences, this whole topic. And so in the landing page that we've created for you today, we are giving you resources on things that we've already done, presentations that we've already done, including one called Telling Isn't Selling, where we partnered with a sales professional to teach EHS professionals on how to get buy-in from leadership using sales techniques, whether it was for a budget or an initiative. It's really fun with some pretty great techniques learned from sales executives who have been doing convincing for a lot longer than we have. All right. So I think we are at the time, Christie, where we can start going to live questions. Todd, do you see something that you want to take?

Todd Loushine:

Yeah, there was one that I found interesting. I'm just going to paraphrase so I'm not scrolling too much. Question about in California, are you required to secure flammable liquid storage cabinets to the wall? And I searched it. And what's interesting is the gist for it is earthquakes.

Jill James:

Oh, sure.

Todd Loushine:

Yeah. So if you have seismic activity that could cause flammable liquids that are stored in the cabinet and that cabinet to spill over, then yeah, you should secure it. Now, it doesn't say specifically OSHA requires it, but they highly recommend it. And as Jill and I both know, if they recommend or highly recommend something, but then something goes wrong, then they're going to require it because it kind of falls under the general duty clause. So if you have the potential for seismic activity in a particular plant, then you should be securing things to prevent them from falling over because that would then cause leaks and spills and possible combination of things that shouldn't be combined. So-

Jill James:

I would also lean on the manufacturer's recommendation and they're going to tell you when it should be anchored and when it shouldn't. Seismic activity, maybe traffic in the location with forklift activity, who knows? And then also if it needs to be secured, the manufacturer is going to tell you the right way to do that so that you're not ruining the integrity of the flammable liquid cabinet itself. Make sense? All right. Someone asked, "What's the OSHA requirement for the frequency of safety meetings? Is it once a week, twice a month, once a month?" Oh, well, guess what? There isn't an OSHA regulation that requires you to have safety meetings, unless you have a state-specific regulation. So State of Minnesota, for example, where Todd and I did work as OSHA investigators, there was a statute. There is a statute that requires employers over a certain size to have a safety committee, and it has to be joint labor and management. And then the frequency with which you have to do that training is spelled out in the statute. So you may, if you're in a state plan OSHA state, meaning the state has jurisdiction over the feds, you might have a requirement like that. Safety committees, probably in the A to Z index, I'm just glancing really quickly. There might be guidance on it, but there isn't an actual law on it. Safety committees. I don't see safety committees in the A to Z index. All right. Todd, you want to pick another one?

Todd Loushine:

I'm just searching. There's a question on how often should wildfire training be done in California. In California, wildfire training for professionals such as annual fire safety refresher, RT-130, must be conducted annually. Off the top of my head, I would say if there is a risk, yeah, annual training, especially refresher training, if anything's changed, it should be done. Yeah.

Jill James:

Yeah. Todd, let's tackle this one together. Question is, are spare propane tanks used for forklifts not allowed to be stored inside? I couldn't find and still can't find a solid black and white answer on this.

Todd Loushine:

Yeah. I've had been asked this before, and yes, they need to be stored outside because a leaking propane tank, it basically can explode. I don't know if it's under the OSHA standards or under the propane something society. And I think [inaudible 00:48:00]-

Jill James:

Yeah, yeah, right.

Todd Loushine:

... the standard.

Jill James:

And you could go to your forklift company, like if you're renting your forklifts or whoever, actually not that company, but whoever you're getting your propane for, they likely have the standard that Todd's talking about. The consensus, it would be a consensus-building organization on that. And of course you want to keep those propane tanks away from oxygen tanks. That is in the OSHA standard. You want to keep flammable liquids away from oxygen. All right, let's see. What else do we have here?

Kristi (Moderator):

There's a question in here about the 300A forms that need to be posted on February 1st, which is [inaudible 00:48:48].

Todd Loushine:

Oh, I [inaudible 00:48:49] that one. Yeah, that was a [inaudible 00:48:51]-

Kristi (Moderator):

So do all employee injuries should be reported?

Todd Loushine:

Yeah, here was a question, Jill. So if you've got people who are doing shipping, drivers, which 300A do the drivers go on?

Jill James:

Yeah, because they don't have a fixed location is the question, right? Okay, so just review for everyone really quickly. 300 logs are tied to physical addresses. So you have to have a separate log for each physical address you have. So when you have a mobile workforce, where do those employees go? They would go back to your main headquarters is the answer that I would give. Todd, concur?

Todd Loushine:

Yes. Yes.

Jill James:

Yeah. And then someone else just said it was the Compressed Gas Association, Jill and Todd. Yes, that's the one we were looking for. Perfect.

Todd Loushine:

That's the one.

Jill James:

Wonderful. All right. Let's see. Todd, do you have another one you want to pick out?

Todd Loushine:

Oh, were you finished with the one regarding the 300A?

Jill James:

Oh, Christie, read us the question again. Sorry.

Todd Loushine:

I've got it. It says, "Does all employee injuries, should they be reported for the site?" Yes. "We are only reporting our non-drivers since our drivers are rolling up to the parent company since the merger. Does that not seem right?" Yeah, I would say if your drivers tend to be based out of a particular building or that's where maybe their hub is, that's where they would start out or go back to, then I would include the drivers onto that 300A, not to every single site. Now, I tend to overdo it when it comes to OSHA reporting. So anybody who may go to a site, I may have two separate 300As, one for, I would say, site non-drivers, the other would be drivers not on site, but that may seem like overkill. If OSHA asks, you have two hours to furnish it really, other than it should be posted. If you just have the site posted, you're covered there. If they want to see something additional, as long as you can give it to them within two hours, that's usually considered acceptable.

Jill James:

Yeah. Most reasonable investigators will do that. All right. We have a question about toeboards on mezzanines. When are they required? All right. So, yeah, that's a fun one. So mezzanine, if someone listening doesn't know what a mezzanine is, maybe an easiest way to think about it is you're in a facility and an office has been erected within the factory floor, for example. And on top of the roof of that office, there's a space and someone has decided to store the Christmas decorations or extra rolls of paper, whatever it is, on top of the roof of that building within the building. That would be considered a mezzanine. So there's regulations around ... Actually, I think Todd, am I correct? Minnesota is the one that says you have to have a posting for how much weight can be stored on a mezzanine. I think that's a Minnesota-specific law if I'm-

Todd Loushine:

Yeah, the placard. But no, I've actually used it here, too. I'm pretty sure if you have overhead storage and it's not part of the building, it's something you assemble, you can hire an engineer and they can take the materials it's made out of, the spacing of all the structural elements, and they should be able to calculate-

Jill James:

How many pounds per square inch you can store up there. Okay. And then getting to the toeboard question. A, if human beings are going to go up there for any reason, like if you're storing things and human beings are going to go up there, you have to have a reliable access for them. So again, we go back to that ladder regulation unless you're building stairs to make sure you have the right kind of ladder for that access point. And then if human beings are going to be there, you have to have a standard guardrail system around the whole thing. And if you have things stored up there that when that human being is going up there to get the things down, could be kicked onto an employee who might be working directly below, or maybe it's over the office in the middle of the factory, it could be plopped onto somebody's head when they're walking out of the door, absolutely, toeboards would be appropriate in that use case. All right. What else?

Kristi (Moderator):

There's some that are related to topics that we're going to cover in a future webinar for sure. So we definitely have plans for a part two that we'll be sharing with you all in a moment. Let's see, let's see, let's see. Just in general, because I'm noticing a few questions about state-specific, can you just give a review of Cal/OSHA versus OSHA versus the various sort of where you're going to get regulations from different areas?

Jill James:

Yeah, sure. And so, Christie, would you mind going to the OSHA.gov website again and then do what I know you already know how to do and do state plan state in the search bar, state. Yeah, there you go, that works too. All right. So when OSHA was invented in 1970, the federal government said this is going to be the law of the land. We're going to enforce 1910, 1926, the agriculture standards, yada, yada, unless of course the states want to have their own OSHA program. And if you do, it has to be as good or better than the federal government. So about half the states in the country decided they were going to have their own OSHA program. And so that's what you're seeing on the map right here. And the states that are in the lighter shade of blue are states that said, "Okay, federal OSHA, we've got this, we've got jurisdiction. We are going to adopt all of the federal standards to be as good as the federal government and we are going to have this applicable to all employees in that particular state unless those employees work for the federal government. In that case, it goes back to federal OSHA." The darker blue states, like you're seeing with Illinois, Maine, their state programs only cover state employees. So city, county, state employees. So everything else falls to the federal government. Now this particular map, I love this map because it takes you right to the state plan OSHA state and shows you what's different about regulations. So yeah, Christie, go ahead and click on my home state below, Minnesota. And all of these landing pages are created exactly the same. We're going to scroll down a little bit and it's going to show you what's different about that state regulation. So past coverage, unique standards to that state. So you can see all of the unique standards for Minnesota. And so federal is in place. You have to comply with federal. And then the unique standards for that state are right here. Now, if we flip back to California, which everyone thinks is the hardest one because they say they have the most. Hmm. Do they really have the most regulations? Now, when California said they were going to adopt the federal regulation, they did, but they don't call them 1910 and 1926. They call them Cal/OSHA this, Cal/OSHA that. Now look at those unique standards. Do you see how small that list is compared to Minnesota? Mm-hmm. Yeah, right? Yeah. That's where it gets confusing because there really aren't as many unique standards. If we want to go really crazy, let's look at Oregon.

Kristi (Moderator):

And actually one, before I leave this, if you want to go to the ... When you click on a state, this pop-up box you're seeing gives you OSHA's webpage summarizing that state. But if you want to really dig into the Cal/OSHA website, they also link directly to the state. Oregon or Washington? Which one did you want?

Jill James:

Washington.

Kristi (Moderator):

So we're going to go to OSHA's page on Washington, but you can go directly to Washington's website, which is getting it from the horse's mouth for the most part.

Jill James:

Look how many unique standards Washington State has compared to Minnesota compared to California. Anybody out there from Washington? You've got a lot of unique regulations. All right. I feel like ... Gosh, can we answer one more, Christie, or do we need to share resources with people?

Kristi (Moderator):

We wanted to really quickly ... I just want to move on and let you all know that, again, so many questions came in during registration and during the webinar that we weren't able to cover everything, of course. So we focused on a few topic areas. We have already set up, in a month, part two of our Safety Unscripted, and really want to dig more into these four topic areas. So again, this information will be sent to you. We have this fantastic landing page that we've created that has additional information. So this URL, or if you want to scan the QR code to get to this page, I can show it to you as well. This page has a link to register. It'll have a recording of the webinar added to it tomorrow. And then some of the resources that we've talked about today, that you've heard Jill and Todd talking about, are listed in here, including a link to the documentary. I know a few of you were talking about that in the question box. And a great page that really digs into in more detail via short, easy to watch and follow videos of navigating OSHA.gov, where to uncover some of that great information and the resources in there. So please feel free to look at the follow-up information. Let me give you that URL and QR code. You will get an email tomorrow with a recording, a link to that page, and where to register for the webinar on the 25th of February, where we will continue this conversation. So as we're getting to the end, and I know how important and valuable everyone's time is on this call, I just want to thank you all for being here. Thank you, Jill and Todd, for sharing your knowledge, your expertise, your how to go out and find it if I don't know, which might be one of the most important skills. And I guess everyone have a wonderful rest of the week.

Jill James:

And you can ask us questions. You see our contact information there, and someone's already goading us to do a session two and three, Todd. So it looks like we're going to be at this for a while, because, oh my gosh, you asked us so many questions today that we couldn't even get to. Thank you all so much for all the smart questions you asked.

Kristi (Moderator):

Yes. All righty. Take care everybody. Bye-bye.

Todd Loushine:

Bye everyone. Thank you.

Jill James:

Thank you for spending your time listening today. And more importantly, thank you for your contribution toward the common good. May your employees and those we influence know that our profession cares deeply about human wellbeing, which is the core of our practice. If you aren't subscribed and want to hear past and future episodes, you can subscribe in any podcast player, or you can find us and read the transcript and listen at hsi.com. We'd love it if you could leave a rating and review on iTunes. It really helps us connect the show with more and more EHS professionals like Dr. Loushine and I. Special thanks to Emily Gould, our podcast producer. And until next time, thanks for listening.