From: Monona Rossol <actsnyc**At_Symbol_Here**>
Subject: Re: [DCHAS-L] Disciplinary actions for graduate students for failure to wear appropriate PPE
Date: Tue, 22 Oct 2013 19:25:13 -0400
Reply-To: DCHAS-L <DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU>
Message-ID: 8D09D9517D7B6DA-19D4-3BA89**At_Symbol_Here**

Some years ago, there was an interesting OSHA citation pf a construction company for failure to enforce the hard hat rule.  The OSHA inspector wrote that the company policy consisted of three steps:  1) informing the person they should be wearing a hard hat; 2) verbally abusing the worker for not wearing a hard hat; and 3) laying the worker off when he was no longer needed and job was ending anyway.
If you have no written enforcement policy that imposes meaningful penalties and no evidence that enforcement is actually done, you have no program.
Monona Rossol, M.S., M.F.A., Industrial Hygienist
President:  Arts, Crafts & Theater Safety, Inc.
Safety Officer: Local USA829, IATSE
181 Thompson St., #23
New York, NY 10012     212-777-0062

-----Original Message-----
From: James Keating <jameskeating1944**At_Symbol_Here**GMAIL.COM>
Sent: Tue, Oct 22, 2013 4:32 pm
Subject: Re: [DCHAS-L] Disciplinary actions for graduate students for failure to wear appropriate PPE

Your occupational health and safety management system must include a discipline section. Furthermore, you must be able to demonstrate and document that employees are indeed disciplined for safety violations. Appeals court decisions require demonstrable enforcement in cases where the employer alleges that the employee was injured because he willfully violated a safety rule. The courts have ruled that if the employer dose not enforce safety rules then is no reasonable expectation of employees complying.
Jim Keating
Jim Keating
On Oct 1, 2013 10:59 AM, "Keane J. Leitch" <kjl44**At_Symbol_Here**> wrote:
I am interested in learning about approaches folks are using to ensure that graduate researches comply with PPE policies.  Most of the information out there stipulates that disciplinary actions will be taken against individuals who fail to comply with gowning policies but such information doesn't explicitly state the nature and type of disciplinary action.   
Keane Leitch
Safety Manager
Physical Sciences Facilities Management
121 baker Lab
Ithaca, NY 14850
607-255-8773 (Office)
607-592-7079 (Mobile)

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