Worker Health and Safety
ILTA members have built a strong safety record and continuously work to promote safe working conditions in their terminals. Many companies are recognized for their outstanding safety and health performance. These companies have achieved success in promoting and practicing safety awareness and minimizing workplace incidents and injuries.
ILTA Safety Survey and Recognition Program
ILTA promotes worker health and safety through its Safety Survey and Recognition Program, which captures company injury and illness rates as recorded on OSHA form 300A. ILTA publishes an extensive report on the findings to the companies that participated in the survey. The report features analysis and comparison of the injury and illness data against national averages. ILTA further recognizes companies that demonstrate a strong safety culture.
Walking-Working Surfaces and Fall Protection
In 2016, OSHA issued its final rule updating the general industry walking-working surfaces and fall protection standards, which among other things, set requirements for regular inspection and maintenance of walking-working surfaces, and training of workers on fall and equipment hazards. It added flexibility for employers in providing fall protection, and notably, it did not include specific requirements for fall protection from rolling stock and motor vehicles. ILTA had earlier testified at an OSHA hearing advising the agency against promulgating a prescriptive, one-size-fits-all requirements to cover falls from rolling stock and motor vehicles.
In early 2017, ILTA submitted requests for clarification on provisions contained in the final rule and met with OSHA to discuss concerns on those issues. In July, OSHA responded to the requests for clarification. Importantly, the letter of interpretation to ILTA confirmed that terminal facilities would not be required to retrofit stair rails installed prior to the effective date that were in compliance with the old standard.
OSHA Process Safety Management
The Occupational Safety Health Administration’s Process Safety Management (PSM) program establishes requirements for the management of hazards associated with certain processes using highly hazardous chemicals. ILTA’s Process Safety Working Group is examining the use of safety management systems as another step in reducing risks and enabling safer and more reliable terminal operations. OSHA is considering revisions to the PSM standard, and several ILTA member companies participated on a Small Business Administration advocacy panel to better inform policymakers on how the agency’s draft framework would impact the terminal industry.