Safety Lines

The Newsletter of Minnesota OSHA

Number 51 Spring 2006
www.doli.state.mn.us

Excavation, trenching: dig ing-in to OSHA regulations

g
By Diane Amell, MNOSHA Training Officer

Excavation and trenching are among the most

hazardous of construction operations. In 2005,
Minnesota OSHA (MNOSHA) investigated four
accidents involving excavation work that resulted
in death or serious injury. The requirement that
employees in an excavation "shall be protected
from cave-ins by an adequate protective system,"
1926.652(a)(1), was among the top 10 most
cited standards by MNOSHA in the construction
industry during 2005.

What do MNOSHA investigators (OSHIs)

look for when inspecting an excavation site?
In general, the OSHI has these objectives on a Above: Employees working in an excavation moments before a cave-
jobsite: in. Below: The same excavation after the cave-in. The employees
evacuated the trench prior to the mud slide. No one was hurt.

• determine whether the protective system in use

is adequate, in good repair and not in danger of
failure;

• verify that sloping, where used, is at least 1.5:1;

• identify the basis that the employer used to

determine the proper employee protection
system (e.g., proper sloping, bracing);

• check around the edges of the trench to assure

the spoil pile and any tools or equipment are at
least two feet away or are otherwise prevented
from falling on the employees working below;

• interview employees to establish their level of training and how the proper use of sloping or the
protective system is enforced;

• identify key personnel, such as the competent person on site or the registered professional engineer
who designed the system;
Excavation, continues ...
Excavation, continued ...
• determine whether periodic inspections are being performed;

• evaluate the effectiveness of employee training and inspection procedures, including the corrections
taken after any accidents or near misses; and

• identify other apparent violations.

One of the excavation issues where there is often confusion is what makes someone a "competent
person." A competent person is someone who:

• has had training and is knowledgeable about soils analysis, the use of protective systems and the
requirements of the excavation standard;

• is capable of identifying existing and predictable hazards in excavation work; and

• has the authority to take prompt measures to abate these hazards.

Most frequently cited standards

in excavation and trenching,
2001 through 2005

Standard Description Total

1926.652(a)(1) Use of sloping or protective systems 295

1926.651(c)(2) Means of egress 107

1926.651(j)(2) Protection from material falling or rolling into the excavation 100

1926.651(k)(1) Inspections of excavation operations by a competent person 99

Other issues the OSHI will address on-site include:

• which aspects of the employee protection program were designed or approved by a registered
professional engineer;

• whether there is a safe means of egress from the excavation;

• whether any underground utility installations are properly protected, supported or removed;

• whether surface encumbrances, such as trees, rocks or pavement, have been removed or supported to
safeguard employees (this includes protection of the employees working above the excavation, as well
as those down in it);
Excavation, continues ...
Safety Lines 2 Spring 2006
Excavation, continued ...
• whether a hazardous atmosphere can develop within the excavation and, if so, that air quality tests are
conducted, there is emergency rescue equipment on-site and the employer is in compliance with other
requirements specified in Minnesota Rules 5207.0300-.304 Confined Spaces;

• whether employees are working under loads handled by lifting or digging equipment, in violation of
the standard; and

• whether an adequate warning system is in place and operational whenever mobile equipment is used
near the excavation.

In addition to 29 CFR 1926 Subpart P, excavators must be in compliance with Minnesota Rules
5207.1000 Operation of Mobile Earth-Moving Equipment. This standard requires employees operating
or working near mobile equipment receive training and wear high-visibility garments, such as vests. The
standard also requires such equipment be equipped with back-up alarms or that a signal person be used.
Headlights and rear lights must be used in low-light conditions.

Visit www.osha.gov/SLTC/trenchingexcavation/index.html, the federal OSHA Trenching and

Excavation topics page, for more information.

The Construction Health And Safety

CONSTRUCTION HEALTH AND SAFET Y EXCELLENCE
www.doli.state.mn.us/chaseprogram.html
Excellence (CHASE) Minnesota
program is a major safety initiative
implemented by the Department of
Labor and Industry in 2003 to reduce
the number of injuries, illnesses and
fatalities at participant construction
industry employers.

The partnership charter acknowledges

the importance of providing a safe,
healthful work environment in
construction and seeks a working
relationship that creates mutual trust
and respect among all parties, including
project owners and construction
workers, involved in the construction
process.

Certificates of achievement were

presented to participant employers
Above (l to r): Tyrone Taylor and Jeff Isakson, Minnesota OSHA; Chris Jan. 19, during an Associated General
Tschida, M.A. Mortenson Company, Minneapolis; Don Rachel, Rachel Contractors (AGC) of Minnesota
Contracting, LLC, Blaine, Minn.; and Bruce W. Engelsma, Kraus-Anderson
Construction Co., Minneapolis. breakfast event in St. Paul, Minn.

Safety Lines 3 Spring 2006

 Lockout/tagout Q&A: frequently answered questions
By James Krueger, OSHA Management Team Director

Minnesota OSHA (MNOSHA) Compliance often

receives calls for interpretations of standard 29
CFR 1910.147, the control of hazardous energy
(lockout/tagout). Below are answers to several of
the most frequently asked questions.

Q We have some unique, custom equipment

that was designed and manufactured to our
specifications. Does each piece of equipment
require a specific procedure?

A MNOSHA believes a specific, documented

procedure is necessary in most energy control
situations, because of the number of variables
involved in controlling hazardous energy and
the need for authorized employees to carefully
follow the sequential steps in the energy
control procedure.

However, employers are not necessarily

required to develop a separate procedure for
every machine or piece of equipment. In
appropriate situations, similar machines or
pieces of equipment (i.e., those having the
same type and magnitude of stored energy),
which have the same or substantially similar
types of controls, can be covered with a single
procedure. A common procedure must include
a method of identification (e.g., by type,
location or model number) that ensures an
authorized employee can determine which
energy control procedure applies to a particular
machine or piece of equipment.
Q We understand the machine-specific lockout
procedures need to be reviewed annually. Does
an audit of every procedure need to be
performed annually for compliance?
A Under the requirements of paragraph
1910.147(c)(6)(i), the employer is required to
conduct a periodic inspection of the energy
control procedures. MNOSHA interprets this to
mean that each energy control procedure must
be inspected at least annually.
In addition, MNOSHA agrees that a separate
procedure does not have to be developed for
each and every machine or piece of equipment,
and that a comprehensive (generic) energy
control procedure, with supplemental checklists
or appendices, may very well address the steps
necessary to perform servicing and maintenance
work safely. Such a procedure would not have
to be repeated on every applicable machine.
However, MNOSHA believes there are also
situations that require a unique energy control
procedure to deal with the servicing and
maintenance hazards.

Safety Lines 4 Spring 2006

Lockout/tagout, continues ...
 Lockout/tagout, continued ...
MNOSHA will carefully examine the energy
control procedure of any employer who claims
that only one comprehensive procedure is
necessary to ensure the single procedure is,
indeed, adequate. The goal of any procedure is
to ensure it does not become so complex that
service and maintenance employees cannot
easily follow it. To qualify as one procedure,
the supplemental checklists or appendices must
support the comprehensive energy control
procedures by having the same:
1. intended uses for different machines or
equipment;
2. procedural steps for shutting down,
isolating, blocking and securing machines or
equipment to control hazardous energy;
3. procedural steps for the placement, removal
and transfer of lockout or tagout devices,
and the responsibility for each of them; and
4. requirements for testing a machine or
equipment to determine and verify the
effectiveness of lockout devices, tagout
devices and other energy control measures.
The annual inspection required to be
performed on an energy control procedure is
intended to ensure:
• the procedure is being followed;
• the employees involved know their
responsibilities under the procedure;
• the procedure provides the necessary
protection, with respect to servicing and
maintenance activities; and
• any needed changes are identified.
Q Does the requirement for written, machine-
specific lockout procedures apply to the
manufacture and assembly of custom
machines that are not permanently housed
in the facility? These machines are assembled
and tested in the facility, then shipped to an
end user.
A Under 1910.147(a)(1)(i), the scope of the
standard covers all equipment in which the
“unexpected” energization, start up or release
Safety Lines
of stored energy could cause injury to
employees. MNOSHA interprets this to cover
any machinery that may cause injury. In
addition, 1910.147(c)(1) states the employer is
required to establish an energy control
program, which includes procedures, training
and periodic inspections, before an employee
performs any servicing or maintenance activity
where there may be exposure to injury from
hazardous energy. This paragraph, as well as
1910.147(d)(3), further stipulates the machine
or piece of equipment must be isolated from
the energy source and rendered inoperative
prior to performing such work, including
emergency servicing and maintenance
operations.
Q Does each employee who is trained on
machine-specific lockout procedures need to
be audited for their compliance annually,
and can auditing be accomplished by using
a representative number of people and
procedures?
A inspection
The employee performing the periodic
does not have to observe every
authorized employee implementing the energy
control procedure on every machine on which
he or she is authorized to perform servicing
and maintenance to meet the review
requirements under paragraph
1910.147(c)(6)(i)(C) and (D).
The inspector participating in the review needs
to observe a representative number of such
employees implementing the procedure and
talk with all other authorized employees, even
though they may not be implementing an
energy control procedure.
This review may be completed in one or more
meetings in which all authorized employees
will be in attendance to review the specific
energy control procedures. MNOSHA believes
these reviews, which will need to be performed
during the periodic inspections, will assure
employees follow and maintain proficiency in
5 Lockout/tagout, continues ...
Spring 2006
Lockout/tagout, continued ...

the energy control procedure and the inspector

will be better able to determine whether
changes are needed.

MNOSHA does not believe that, by itself,

“annual refresher training” for all authorized
employees, even if it includes a review of
lockout/tagout responsibilities for each
authorized employee, satisfies the periodic
inspection review requirements of paragraph
1910.147(c)(6)(i)(C) and (D). This is because
certain benefits are expected to be derived
from the talks with individual employees that
may not be achieved in group training. Some of the
advantages include: identifying energy control procedure deficiencies, misinterpretation and
deviations; evaluating task proficiency of the authorized employees; providing immediate feedback
regarding procedure implementation; and assessing the need for specific retraining.

Group training sessions can be an effective way of partially accomplishing the periodic inspection
reviews, during which employee knowledge of the hazards and the necessity for the protective
procedures is reinforced. Employees must recognize they need to follow the procedures carefully to
ensure the safety of all. Other review methods include random audits, planned visual observations
and modified plant safety tours.

Under paragraph 1910.147(c)(7)(iii)(A), retraining must be provided for all authorized and affected
employees whenever there is a change in their job assignments, a change in machines, equipment or
processes that present a new hazard or when there is a change in the energy control procedure.
MNOSHA will continue to evaluate periodic inspection protocols to ensure all energy control
procedures are inspected and that each involved employee has an opportunity to review his or her
energy control procedure responsibilities.

For further assistance, please contact any MNOSHA area office.

MNOSHA area offices

St. Paul Duluth
(651) 284-5050 (218) 733-7380
1-800-342-5354
OSHA.Compliance@state.mn.us Mankato
(507) 389-6507

Safety Lines 6 Spring 2006

Research highlights:
Minnesota Safety Report
By Brian Zaidman, Research Analyst
Research and Statistics

The number of workplace injuries and illnesses continued to decline during 2004. The latest
occupational injury and illness figures show there were an estimated 105,500 recordable injury and
illness cases in 2004; about 28,700 cases involved one or more days away from work. The comparable
figures for 2003 were 111,600 total cases and 29,900 days-away-from-work cases. There were 80 work-
related fatalities in 2004, up from 72 in 2003, but below the 81 fatalities that occurred in 2002.

Later this spring, the Department of Labor and Industry will release its annual Minnesota Workplace
Safety Report, detailing injury and illness rates and workplace fatalities for 2004. The report is based on
the U.S. Bureau of Labor Statistics’ Survey of Occupational Injuries and Illnesses and Census of Fatal
Occupational Injuries (CFOI) and on OSHA activity reports. The report will be available online at
www.doli.state.mn.us/rsreport.html.

Following are the major highlights from that report.

Nonfatal occupational injuries and illnesses

• Minnesota’s total rate of workplace injuries and illnesses was 5.3 cases per 100 full-time-equivalent
(FTE) workers in 2004. This represents a 4 percent decrease from the 2003 rate of 5.5 cases per 100
FTE workers.

• The rate of cases with days away from work (the most severely injured workers) was 1.5 per 100
FTE workers in 2004 and 2003.

• Minnesota’s industry sectors with the highest total injury and illness rates per 100 FTE workers
were:
1. construction (8.6);
2. agriculture, forestry, fishing and hunting (8.6); and
3. transportation and warehousing (7.6).

• Four of the 10 industry subsectors with the highest total case rates were in private-sector and public-
sector health care and social assistance.

• The industry subsectors with the highest numbers of cases with days away from work were specialty
trade contractors (1,970 cases) and private-sector nursing homes (1,800 cases). The top 10 industry
groups accounted for 12,510 days-away-from-work cases, 44 percent of the total.

Additional statistics about the characteristics of the injured workers, the characteristics of their injuries
and the amount of time away from work are available for cases with days away from work.

• Sprains and strains accounted for 43 percent of the cases with days away from work. The second-
highest category was soreness and pain, with 10 percent of the cases.

• The back and lower extremities were the most commonly injured body parts, accounting for nearly
half the cases. Safety report, continues ...
Safety Lines 7 Spring 2006
Safety report, continued ...
• Overexertion – often while lifting people or objects, falls and contact with objects and equipment
were the most common injury events.

• "Floors and ground surfaces" was the most frequent source of injury category, followed by the
injured worker’s own motion or bodily position.

Fatal occupational injuries

The CFOI covers all fatal work injuries in the private and public sectors, regardless of program
coverage; thus, it includes federal workers and self-employed workers, along with all others. However,
fatal illnesses (such as asbestosis) are excluded.

• In 2004, 80 Minnesotans were fatally injured on the job. For 2000 through 2004, Minnesota had an
average of 75 fatal work injuries a year, consisting of approximately 59 wage-and-salary workers
and 17 self-employed people.

• Among industry sectors, agriculture, forestry, fishing and hunting recorded the highest number of 2004
worker fatalities, with 19. Construction, with 16 cases, had the second-highest number of fatalities.

• The most frequent causes of Minnesota’s fatal work injuries for 2004 were: highway transportation
accidents (36 percent); contact with objects and equipment (23 percent); falls to a lower level (14
percent); and assaults (14 percent).

Minnesota OSHA activities

During federal fiscal-year 2005 (October 2004 through September 2005), Minnesota OSHA:

• conducted nearly 2,600 compliance inspections affecting the workplaces of 128,000 workers;

• found violations resulting in the assessment of more than $4 million in penalties;

• conducted nearly 1,000 worksite consultations, affecting the workplaces of 73,000 workers, and
helped employers avoid more than $4 million in penalties; and

• provided 98 safety and health seminars, plus many other safety presentations and on-site training
visits.

Coming soon to a site near you:

crane-operator regulation
Effective July 1, 2007, no individual may operate a crane, with the lifting
capacity of five tons or more, on a construction site unless that person
has a valid crane-operator certificate. The certificate must be issued by a
nationally recognized and accredited certification program.

For more information, see New crane-operator regulations – an overview

(page 6) in the Winter 2006 edition of Safety Lines, available online at
www.doli.state.mn.us/pdf/5006sl.pdf.

Safety Lines 8 Spring 2006

Guthrie Theater worksite:
Construction safety show takes curtain call

Above: DLI Commissioner Scott Brener and Assistant Commissioner Roslyn Wade joined Andy Smoka, MNOSHA Workplace Safety Consultation, and
Brock Kiecker, McGough, on a walk-through of the Guthrie on the River Theater site in Minneapolis. The tour included many views to remember, because
the site overlooks the city and the Mississippi River.

Construction of the new Guthrie on the River Theater has been completed, ending the monthly safety and
health visits by MNOSHA Workplace Safety Consultation (WSC). Most of the construction work was
completed by mid-February and the theater will open this summer.

At its peak, 271 workers were on-site each day. During the project’s 28 months, WSC visited the site 20
times. The results were six recordable injuries and no lost-time claims for approximately 750,000 total
construction work hours.

Career The Minnesota Occupational Safety and Health

(MNOSHA) program, administered by the Minnesota
opportunities Department of Labor and Industry, was established by
the Minnesota Legislature in 1973.

Working for MNOSHA can be a very rewarding

job. Minnesota’s economy has a great variety of
industries and its business leaders are often at
the forefront of new technology. Keeping up with
new developments is challenging and exciting.
And MNOSHA investigators are one of the very few
individuals with the authority to affect improvements
in working conditions for all Minnesotans.

If you wish to speak to someone about jobs with

Minnesota OSHA, contact a MNOSHA supervisor at:
• (651) 284-5050; or
• toll-free at 1-877-470-6742.

www.doli.state.mn.us/mnosha.html
osha
DEPARTMENTOFLABORANDINDUSTRY

Safety Lines 9 Spring 2006

Employers reducing the number of injuries to teenage workers
By Brian Zaidman, Research Analyst
Research and Statistics

Summer approaches, and so does the teenage worker

injury season. Since 1995, 36 percent of all injuries to
workers 14 to 18 years of age have occurred during
the months of June, July and August. Employers are
responsible for providing a workplace that protects
workers from injury, disease and fatalities. These
responsibilities are even more important when there
are teenage workers, who may not fully appreciate the
potential dangers of work situations.

Minnesota’s employers have made great progress in

reducing the number of injuries to teenagers. From
1998 through 2002, there was an annual average of 664 workers’ compensation indemnity claims for
teenagers. For the 2003 through 2005 period, there has been an annual average of 336 indemnity claims,
a 51 percent decrease. While there has been a slight decrease in the youth employment rate since 2000, it
cannot account for this large a decrease in injured workers.

Workers’ compensation indemnity claims require a work disability of more than three days, and only
about one-fifth of all workers’ compensation claims reach this level of severity. Thus, there are an
estimated 1,700 to 2,000 claimed injuries to workers age 14 to 18 years old annually.

Workers’ compensation
Indemnity claims for workers 14 to 18 years old indemnity claims from workers
aged 14 to 18, for injuries that
800
occurred between January
700 2003 and August 2005, were
600
analyzed to provide the most
common features of these
500
injured workers and their
400 injuries.
300
• Older teenagers dominated
200 the injury statistics; 57
100 percent of the injured
0
teenagers were 18-year-olds
1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005
and 27 percent were 17-year-
olds.

• Workplace injuries were more likely among male workers, who accounted for 61 percent of the
claims. Females accounted for 52 percent of employed Minnesotans age 16 to 19 in 2004.

• As expected among this population, 58 percent of the injured teenagers had part-time or seasonal jobs.
Employers, continues ...

Safety Lines 10 Spring 2006

Employers, continued ...
• Only 41 percent of the injured teenagers lived in the
Twin Cities metropolitan area, compared to 48
percent among all indemnity claimants. As might be
expected, injuries to teenagers were more common
in the resort areas, which employ many youths
during the summer months. The central lakes
region, which includes the areas around Brainerd
and Alexandria, accounted for 11 percent of the
teenagers with claims, while only 6 percent of all
workers’ compensation claimants lived in that area.

• Teenager injuries were reported most frequently in

the accommodations and food services industry (20 percent of claims) and in retail trade (19 percent
of claims).

• The two most common occupation types among injured teenagers were food preparation and serving
occupations, and transportation and material moving occupations (mostly unskilled general laborers).
Each occupation group accounted for 21 percent of the claims.

• About 33 percent of teenager claims were for burns, cuts or fractures; 29 percent were for sprains and
strains. This compares to 18 percent and 42 percent, respectively, among all workers.

• Consistent with the types of injuries, the arms and hands were the most frequent body parts injured,
accounting for 36 percent of the claims.

• The types of events causing the injuries were most

commonly bodily reaction and exertion and contact with
objects and equipment. Each category accounted for 35
percent of the claims. Bodily reaction and exertion includes
injuries caused by overexertion in lifting, pulling or pushing
objects, and injuries due to movements such as bending,
crawling or twisting. Some common events in the contact
with objects and equipment category include being struck
by falling or flying objects and being caught in running
equipment.

The OSHA Web site includes information for teenage workers

and their employers at www.osha.gov/SLTC/teenworkers/
index.html. The Web site includes online tools that describe
common hazards and potential safety solutions for teen
workers and employers in the restaurant and agriculture
industries.

The Department of Labor and Industry’s Web site includes

child labor standards information that summarizes state and federal laws concerning child labor and
contains a list of prohibited work for minors under 18 years of age. The Web site is at www.doli.state.
mn.us/childlbr.html.
Safety Lines 11 Spring 2006
 Minnesota businesses achieve MNSHARP status
MNOSHA Workplace Safety Consultation
recently recognized three Minnesota
businesses as Minnesota Safety and
Health Achievement Recognition Program
(MNSHARP) worksites:

• Scott Equipment Company, New Prague;

• Anchor Block Company, Shakopee; and
• Reynolds Food Packaging, Rogers.

For more information about MNSHARP, visit

www.doli.state.mn.us/mnsharp.html.

Scott Equipment Company, New Prague, Minn.

Reynolds Food Packaging, Rogers, Minn. Anchor Block Company, Shakopee, Minn.

Workplace Safety Consultation, IBM sign alliance agreement

In March, Minnesota OSHA Workplace
Safety Consultation (WSC) signed an alliance
agreement with IBM, Rochester, Minn.

Forming an alliance with WSC enables

organizations committed to workplace safety
and health to collaborate with MNOSHA to
prevent injuries and illnesses in the workplace.

WSC and its allies work together to reach out

to, educate and lead Minnesota employers and
their employees in improving and advancing
workplace safety and health.

Visit www.doli.state.mn.us/alliances.html for

Clockwise from lower left: Michael Mueller, senior well-being manager, more information about WSC alliances.
IBM; Dave Ferkul and James Collins, Workplace Safety Consultation;
and DLI Assistant Commissioner of Workplace Services Roslyn Wade.

Safety Lines 12 Spring 2006

 'DON'T CALL ME LATE FOR BREAKFAST'
Construction Breakfast season winding down
By Gary Robertson, MNOSHA Training Officer

Winter is winding down and so are the sessions

of the Minnesota OSHA Construction Breakfast
program.

This newsletter is too late to get you to the March

21 program, "A hands-on AWAIR program that
works," but chances are the May 16 program,
"Tubular welded-frame scaffold safety," can
be added to your calendar. The Construction
Breakfast seminars offer information that is
relevant to worksite safety and are a positive
addition to continued safety education.

The March 21 breakfast program outlined how

easy it is to understand and use the "A Workplace
Accident and Injury Reduction" (AWAIR)
program, a required safety program. Sixty-
two participants heard – step by step – how to
customize the AWAIR program to fit an individual
company's safety needs and how to be in
compliance with MNOSHA.

In May, the “workhorse” of scaffolds – the tubular

welded-framed scaffold – is the subject of the last
breakfast of the season.

Micki Hentges, owner of Scaffold Services Inc.,

will discuss the hazards associated with the
erection, use and dismantling of this scaffold.
She will explain what must be done to assure the
safety of employees working with each process.
MNOSHA Training Officer Gary Robertson speaks about the
importance of structured worksite safety, during the March 21
Construction Breakfast in St. Paul. Sixty-two people attended the
breakfast seminar, "A hands-on AWAIR program that works."

Chuck Logan, MNOSHA principal safety investigator, will briefly discuss related citation statistics associated
with the use of this scaffold.

To register, visit www.doli.state.mn.us/brkfst.html or call (651) 284-5375.

Program topics presented this year were chosen by a steering committee of Minnesota’s construction
stakeholders. This new approach to MNOSHA's Construction Breakfast program is the reason for the
outstanding success and attendance this season. The committee continues to meet and is already selecting next
year’s safety topics and presenters.

Stay tuned ...

Safety Lines 13 Spring 2006
Minnesota OSHA citations, 2005
Following a Minnesota OSHA workplace inspection, citations and penalties may be issued. Such
citations indicate specific areas where an employer has been found to be in violation of regulations
regarding worker safety or health. The following lists are of the top 10 most frequently cited standards
for 2005; the first list is general industry and the second is construction specific.

To learn how MNOSHA inspections are conducted, visit www.doli.state.mn.us/oshinsp.html.

Minnesota OSHA's top 10 most frequently cited standards, 2005

Description Frequency
A Workplace Accident and Injury Reduction (AWAIR) program 183
Development and use of lockout/tagout procedures 161
Emergency eyewash/shower facilities 139
Employee Right-To-Know written program 134
Employee Right-To-Know training frequency 128
General duty clause – unsafe working conditions 124
Overall Employee Right-To-Know training program 109
Periodic inspections of energy control procedures (lockout/tagout) 104
Machine guarding – general requirements 104
Energy control program training 103
Forklifts – employee exposure monitoring for carbon monoxide 96
– To see more of the list or for more information, visit www.doli.state.mn.us/gicited.html. –

Minnesota OSHA's top 10 most frequently cited standards in the

construction industry (SIC codes 1521 through 1799), 2005
Description Frequency
Fall protection on scaffolds above 10 feet 93
Fall protection in residential construction 90
General duty clause – unsafe working conditions 85
Fall protection – general requirements 82
A Workplace Accident and Injury Reduction (AWAIR) program 71
Hard hats in construction 53
Use of sloping or protective systems to prevent excavation cave-ins 44
Railings on stairways 31
Fall protection for roofing work on low-slope roofs 29
Fall protection near wall openings 29
High visibility personal protective equipment near mobile earth-moving equipment 29
Scaffold platform not fully planked or decked 26
– To see more of the list or for more information, visit www.doli.state.mn.us/concited.html. –

Safety Lines 14 Spring 2006

Nursing-home project update
By Dave Ferkul and Jolyn Crum, MNOSHA Workplace Safety Consultation

In 2004, Minnesota OSHA Workplace Safety Consultation (WSC) began a

long term, collaborative project established to assist Minnesota nursing-home
facilities to reduce the severity and occurrence of
musculoskeletal injuries that occur to the
members of the nursing staff, particularly the
nursing assistants. (See Safety Lines, Fall 2005, at
www.doli.state.mn.us/safeline.html.)

In December, WSC presented training sessions –

in Duluth, St. Paul and Mankato – to further
educate administrators and safety managers about
reducing ergonomic risks in the workplace.
Employees from 23 of the facilities that are
participating in the project attended.

Guest speakers provided additional information Above: Dave Ferkul, MNOSHA, leads an ergonomics training
about programs and processes that are working at session in Duluth, Minn., in December, for employers taking part in
their facilities: the MNOSHA Workplace Safety Consultation nursing-home project.
• evaluating and controlling a known high-risk Below: Sue Gluth and Laurie McPhee, New Ulm Medical Center,
work task, presented by Wayne Lindberg, discuss their facility's successful injury management program during
the Mankato, Minn., seminar in December.
Louisiana-Pacific (Duluth session);
• injury reporting and management, presented
by Brad Honl and Christy Flaspeter,
Grandview Ministries (St. Paul session); and
• injury management program, presented by
Sue Gluth and Laurie McPhee, New Ulm
Medical Center, a WSC MNSTAR worksite
(Mankato session).

Some of the attendees also offered summaries of

the activities and best practices implemented in
their facilities, including pilot projects involving:
• the installation of ceiling lift systems;
• use of repositioning aids;
• involvement of rehabilitation staff members in resident assessments;
• purchasing used lift equipment at discounted prices;
• use of peers to assist with on-the-job training;
• job-task analysis;
• and injury reporting.

Additional training sessions and networking opportunities are planned,

including a partial tour of the New Ulm Medical Center to observe patient
handling equipment, gain insight about choosing the equipment and listen to
comments from staff members who use the equipment.
 Recordkeeping 101: Part 6
Summarizing the injury and illness log
By Brian Zaidman, Research Analyst, Research and Statistics
Editor's note: This is the sixth installment of a series about using the OSHA Form 300 and summarizing its results. This
information is directed to people who are new to OSHA recordkeeping activities, who are unfamiliar with the 2002 recordkeeping
changes or who want to review their recordkeeping practices. This installment deals with the annual log summary. The previous
installments are available at www.doli.state.mn.us/recordkeeping.html.
This installment covers how to
avoid errors when creating the
annual log summary. The
previous five installments of this
series discussed how to fill in the
log (OSHA form 300). At the end of
each year, you must complete an annual
log summary (OSHA form 300A). Every
establishment that keeps a log must create an
annual summary, even if there are no log entries.
Completing the summary will help you realize the
full potential of keeping the log. Information from
the annual review can be used to educate
employees, keep upper management apprised of
safety and health issues, set goals for the coming
year and prioritize safety committees activities.
OSHA recordkeeping requirements list four
required actions for the annual summary:
• review the log entries;
• create the summary;
• certify the summary; and
• post the summary.
To best follow this installment, it would help to
have an OSHA log and a summary form available.
The forms are available on the federal OSHA
recordkeeping Web site at www.osha.gov/
recordkeeping/RKforms.html. Please note that the
average employment and total hours worked
worksheets are not available on the Excel version
of the forms.
What to summarize
Instructions on the annual aummary form ask you
to summarize only recordable cases. (See
Recordkeeping 101: Part 1.) If you make log
entries for all reported cases, do not include the
nonrecordable cases in the summary. It may help
Safety Lines
to draw a line through the nonrecordable cases or
highlight the recordable ones.
Sometimes, an OSHA log entry for an injury or
illness that has been filed as a workers’
compensation claim is denied workers’
compensation benefits. A denial of workers’
compensation benefits has no effect on the
recordability of a log entry. Each state runs its own
workers’ compensation system, with its own set of
laws, and liability determinations vary greatly
among the states. The OSHA log is a federal
recordkeeping tool and the OSHA recordkeeping
requirements are the only rules in effect. A denial
of workers’ compensation benefits is not a reason
to remove an entry from the log.
Review
Carefully review all the log entries. Verify that
each entry is complete and accurate, and correct
any deficiencies. If you need help with this task,
review Recordkeeping 101: Parts 2 through 5.
• Each case must have a
description. Re-read each
description to make sure
it makes sense and fill in
any missing information.
• Each case must have only one
box checked in columns G, H, I or J (case
classification). Mark the correct classification if
the status of a case has changed since it was
originally entered and correct the counts of days
away from work and days with job transfer or
restriction.
• For each case with a check mark in column H
(days-away-from-work case), there must be at
16 Spring 2006
 Recordkeeping 101: Part 6
least one day entered in column K (number of
days away from work). There can be no cases
with entries in column K that do not also have a
check mark in column H.
• For each case with a check mark in column I
(job transfer or restriction case), there must be at
least one day entered in column L (number of
days on job transfer or restriction). Each case
with an entry in column L must have a check
mark in either column H or I.
• Each case must have one box checked in column
M (injury or type of illness).
Total the columns
After all the cases have been reviewed, counting
the entries and totaling the days becomes an easy
task. Remember to include each page of the log if
more than one page was needed to record all the
cases. Enter “0” in the total if there are no cases
(or days) in that column.
• The sum of columns G, H, I and J must equal
the sum of columns M1 to M6.
• The total number of days away from work
(column K) must not be less than the number
of cases entered in column H.
• The total number of days of job
transfer or restriction (column L)
must not be less than the number of
cases entered in column I.
Establishment information
The right side of the summary asks for some basic
information about the work establishment,
including the average annual number of workers
and their total hours of work.
• Fill in the establishment’s name and address,
and provide a brief description of the work done
at that establishment.
• Provide the industry classification code for the
establishment. You should already have a six-
CONTACT MNOSHA
Minnesota OSHA Compliance (MNOSHA)
(651) 284-5050
1-877-470-6742
Workplace Safety Consultation (WSC)
(651) 284-5060
1-800-657-3776
Recordkeeping packet
(651) 284-5042
1-800-342-5354
digit North American Industry Classification
System (NAICS) code, the same NAICS code
used to report employment and wages for
unemployment insurance. NAICS codes are
online at www.census.gov/epcd/naics02 and can
be obtained from the Minnesota Department of
Employment and Economic Development at
(651) 297-2242.
• Computing the annual average number of
employees who worked for the establishment
during the year can be complicated for some
businesses. A worksheet is provided on the back
of the annual summary form. While the
worksheet focuses on payroll employees,
the OSHA recordkeeping rules also
include as employees those nonpayroll
workers that you supervise on a day-
to-day basis. Owners of sole
proprietorships and partners of
partnerships are not considered
employees.
• The average annual number of employees is not
the same as the number of full-time-equivalent
workers. Do not calculate the number of full-
time-equivalent workers for this summary.
• The total hours worked by all employees, both
those on the payroll and those nonpayroll
workers subject to day-to-day supervision by
your establishment, does not include paid time
away from work. If you do not have ready
access to this number, use the worksheet
provided on the back of the form.
 Recordkeeping 101: Part 6

Certify the summary establishments, it may be necessary to post more

Because the annual summary is an official federal
form for business establishments, it is necessary
for an officer of the business to sign the form to
certify it is a correct and complete set of
information about that establishment.
Post the summary
The summary must be posted in a conspicuous
place so that all employees can see their worksite’s
injury and illness record and understand their
worksite’s health and safety environment.
• A copy of the completed summary must be
posted no later than Feb.1 of the year following
the year covered by the log. The summary must
be kept posted until April 30.
• A copy of the summary must be posted in each
work establishment. In some large
than one copy. Post a copy in a conspicuous
place where other notices to employees are
customarily posted. You will need to
periodically check that the summary is not
altered, defaced or covered by other material.
Completing the annual summary does not mean
the injuries and illnesses from the prior year can be
put to rest. Once summarized, the injury and
illness data becomes a tool for monitoring and
improving your establishment’s safety. There will
be more on this in the next installment.
The OSHA log, the summary, any privacy case list
and case incidence reports must be saved for five
years following the end of the year that the records
cover. This means that the log and summary for
2005 injuries and illnesses must be kept through
2010.

Next installment:
Using your
log results

ONLINE RESOURCES
Federal OSHA recordkeeping resources
• www.osha.gov/recordkeeping/index.html
MNOSHA recordkeeping resources
• www.doli.state.mn.us/recordkeeping.html
MNOSHA WSC recordkeeping training
• www.doli.state.mn.us/osheven.html
Survey of Occupational Injuries and Illnesses
• www.bls.gov/iif
• www.doli.state.mn.us/dlistats.html
Packet of recordkeeping forms, instructions
• www.osha.gov/recordkeeping/RKforms.html
Booklet: Minnesota OSHA recordkeeping requirement
• www.doli.state.mn.us/pdf/recordkeepingstandard.pdf

Safety Lines 18 Spring 2006