Workplace 911: Employer Telephone Systems May Need to be Revamped to Meet New and Pending Rules

By Seyfarth Shaw LLP on December 4, 2018

New state and federal laws and rules require employers to have compliant phones systems for 911 direct dialing and E-911.

Most large employers maintain multiline phone systems at their workplaces.  Along with emergency action plans and evacuation procedures, employers must take affirmative steps to ensure that employee phones provide adequate safety protections in the event of an emergency.  Some jurisdictions impose numerous regulations on those systems and their ability to dial 911, requiring onerous notifications, procedures, labels, and 911 dialing features.  And those requirements are constantly evolving, as 2018 marked a seminal shift in 911 regulations.

The federal government has passed a new law requiring that phones dial 911 directly, and has directed the Federal Communications Commission to undertake a rulemaking on Enhanced 911 regulations, also called “E-911.”  These federal and state developments may require employers to take action to ensure compliance, and revamp their emergency safety equipment and procedures.

New Federal Law Requires Direct Dialing of 911

In recent years, nine states and New York City have adopted rules requiring phones to be able to directly contact 911.  This means that any caller who dials 9-1-1 will be connected with emergency services, without a prefix (such as dialing 9 first) or going through an operator.  In 2018, President Trump signed a bipartisan new law which requires any phone to be able to directly contact 911, 47 U.S.C. § 623(b).  The federal law applies to all types of newly installed multiline phone systems.  State and local laws may require existing systems to be revamped by a compliance date.  Accordingly, employers replacing their phone systems or installing new systems will need to comply with these requirements.  Employers who operate phone systems that require an operator or dialing to get an outside line should review their systems and ensure that they comply.

Federal E-911 Legislation May Be Forthcoming

Federal and state governments have begun to require Enhanced 911 services for employers who use multiline phone systems.  States have enacted Enhanced 911 or E-911 requirements to multiline phone systems.  E-911 means that the telephone system automatically will transmit  phone number information or specific location information (building, floor, office number) to emergency services when a caller dials 911.

These restrictions vary by state, but can require employers to notify employees regarding E-911 capabilities, train employees on 911 dialing procedures, and provide written instructions near phones.  Some also require that the phones provide E-911 capabilities in terms of number and/or location information.  The President signed H.R. 4986 § 506 (March 7, 2018), which requires the Federal Communication Commission to consider adopting rules that ensure a “dispatchable location” is conveyed with 911 calls.  The statute requires the FCC to conclude a proceeding to consider adopting rules E-911 location rules by September 23, 2019.  Employers should monitor this process closely, as it could result in another unfunded mandate for employers to comply with E-911.

Employers should begin work now to ensure that their phone systems comply, and that their employees are properly trained on the new and pending federal and state laws and regulations. 


Machine Guarding Hazards

Moving machine parts have the potential to cause severe workplace injuries. Any machine part, function, or process that may cause injury must be safeguarded.

Industrial workplaces such as garage workshops, metal fabrication, and welding shops, and mechanical heavy manufacturing facilities will have a variety of machines and tools. Some of the tools may be as simple as a table saw or box fan and sometimes they can be complex and partially robotic and involve hazardous chemicals. Workers responsible to operate, repair, clean, or just work near these machines and tools must be protected from potential hazards.

Machine guards are critical to the safety of workers. Many times, workers do not realize the dangers that they are protected from because of a simple steel or acrylic guard. For this reason, workers should be familiar with the potential hazards introduced when machines with rotating parts, gears, or pulleys are used.

OSHA Standard 1910.212(a)(1) Types of guarding. One or more methods of machine guarding shall be provided to protect the operator and other employees in the machine area from hazards such as those created by point of operation, ingoing nip points, rotating parts, flying chips and sparks.

Recognizing the potential hazards of machines starts with understanding the first place where the potential for injury exists – this is the “point of operation.” According to OSHA the point of operation is the area on a machine where work is actually performed upon the material being processed. Workers have to be protected from point of operation hazards.

OSHA Standard 1910.212(a)(3)(i) Point of operation is the area on a machine where work is actually performed upon the material being processed.

Workers have to be protected from point of operation hazards, power transmission apparatus such as pulleys and chains, and other moving or rotating parts that pose danger to the operator. Workers should be familiar with the potential hazards introduced when machines with rotating parts, gears, or pulleys are used.

OSHA Standard 1910.212(a)(3)(ii) The point of operation of machines whose operation exposes an employee to injury, shall be guarded. The guarding… shall be so designed and constructed as to prevent the operator from having any part of his body in the danger zone during the operating cycle.

There are a variety of ways that workers could be protected from machine and point-of-operation hazards – some techniques require special training in order to ensure the safety of the operator.

Fixed Guards – made of acrylic, metal, or even plastic that are bolted, welded, or locked in place provide stable protection from moving parts.

Adjustable Guards – self-adjusting or manually adjustable guards that allow the material to be of multiple sizes or shapes but still protect the worker.

Interlocked or Sensors – sometimes combined with adjustable or removable guards, interlocks or sensors can be set to instantly shut off power to a machine. Sensors may be designed to shut off a machine or tool as soon as a visible or invisible barrier is broken.

Safety Trip Controls – similar to interlocks or sensors these devices can be in the form of metal bars, steel cables or wires, and floor mats or gates that are designed to trip and shut off power to a machine if a worker touches, steps, or enters a danger area.

Restraints and Pullbacks – devices such as wrist straps and safety ropes attached to specific points to keep the worker from getting too close to a point of operation hazard.

IMPORTANT: During the safety meeting or toolbox talk on Machine Guarding, it is important to emphasize that no one should ever tamper with or remove a machine guard, sensor or safety device. Only personnel that have received specific training and follow the correct procedures are authorized to remove, repair, or modify a machine guard. In addition, workers may need additional training in Lockout/Tagout procedures!

More information on Machine Guarding can be found on OSHA’s website at and at the specific links provided below.

Protect Yourself – Amputations Quick Card (English & Spanish)

Safeguarding Equipment and Protecting Workers from Amputations, OSHA Publication 3170

Hazards of Operating Unguarded Stone Cutters & Splitters inLandscaping and Other Worksites SHIB


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10 ways to give back with your family this Thanksgiving

Thanksgiving is time for showing gratitude. For being thankful for our blessings. And hopefully, for paying it forward for all the times someone has done a good deed for us.

Start an annual tradition where together as a family you give back over the holiday season. You don’t have to be rich, you just have to make the time.

Here are 10 ways to give back with your family this Thanksgiving

Volunteer at a soup kitchen

This might be the most obvious option, but it truly is a small way to make a big difference. And you’d be surprised at how much the people you serve impact your life. Here is a great tutorial on how to get started by

Create care packages for soldiers stationed overseas

Soldiers risk their lives every day for us. One way to show your appreciation is to help create care packages for them! Check out how to do it on Any Soldier.

Collect clothing and toys for the homeless

Go through all of your closets, toy boxes, and storage areas to find toys, clothing, shoes, jackets, and winter gear for the homeless. Recruit your friends, families, neighbors, and coworkers to do the same and deliver the goods to your nearest shelter.

Donate blood to the American Red Cross

What better way to give back than to save a life? Go to the American Red Cross website to find out how.

Visit hospital patients

Bring homemade cards and cookies, or even your pet (call to make sure it’s allowed first), to a local children’s hospital to help cheer up patients. The kids will love to play with the fur babies!

Play with animals at your local shelter

Pets need love, too! The Humane Society is always in need of volunteers to clean, play with, and walk the animals. Plus, who doesn’t love to snuggle with cute cats and dogs?

Participate in a charity 5K

From “gobble jogs” to “turkey trots” there are races in almost every corner of the country around Thanksgiving time! Research a local 5K near you that raises money for the needy and sign up yourself and your family members! Burning a few extra calories around the holidays can’t hurt either.

Spend time at a nursing home

Spend time with those who may not have family to visit them around the holidays. You can sing or read, play cards, or simply share stories and cookies together. Make lifelong connections with people who may not have anyone else. Read more about how to volunteer at a nursing home on How Stuff Works.

Invite someone to join you for Thanksgiving dinner

Invite that lonely coworker, elderly neighbor, or out-of-state college student to enjoy Thanksgiving dinner with you. No one should spend the holiday alone. Spread the love and all of the amazing food you’re going to prepare.

Clean up the environment

Over Thanksgiving weekend spend a few hours cleaning up your local community. You’ll be making your neighborhood a cleaner place for all. This is especially a task that the kids can help be a part of and enjoy.

May you live a life full of gratitude love joy peace health and appreciation


OSHA Guidelines for Retailers on Holiday Shopping and Crowd Management Safety


Employers should prepare for the holiday shopping season and protect their employees from harm and injuries.

As the holiday shopping season approaches, OSHA has previously reminded retail and hospitality employers of the importance of taking safety precautions during the holiday season’s major sales events, such as Black Friday.

Holiday shopping has increasingly become associated with violence and hazards. There have been numerous instances of riots, shootings, and pepper-spray attacks in crowds looking for holiday deals.  In one case, a worker was trampled to death while a mob of shoppers rushed through the doors of a store to take advantage of a Black Friday sales event.  Events of violence and shooting at malls and retail establishments have become all too common in our society.  Additionally, retail distribution centers that fill customer orders are exceedingly busy at this time of year and often staffed with new and/or temporary workers.  Such increased staffing levels can lead to increased workplace accidents.

Under OSHA’s general duty clause, “employers are responsible for providing a place of employment free of recognized hazards that are likely to cause serious injury or death.”  To minimize injuries in the workplace during the holiday season, OSHA’s website on Holiday Workplace Safety provides employers with recommendations for crowd management plans and safe practices for retail distribution centers.

Retailers are advised to review and implement the OSHA suggestions for crowd management. Adopting, implementing, and training store employees on the crowd management plan will both lessen the risk of employee and shopper incidents, and will assist the employer in fending off potential OSHA enforcement proceedings, should an accident occur.

Blastcrete Equipment offers a solution to OSHA regulations

Blastcrete Equipment’s dust suppression system, DustAway, limits dust exposure in industrial, construction, and mining applications. The system will help businesses meet OSHA regulations for crystalline silica dust, controlling dust within OSHA-permissible exposure limits (PEL).


The patent-pending DustAway system consists of a bulk bag design that is attached to a mixer, containing dust as the mixer fills. The bag also features a dust ruffle, which encapsulates airborne particles and helps to control respirable dust.

The system is the first of its kind and is designed to fit securely around mixer openings. The system is flexible, allowing customers using material packaged in paper bags to convey to small bulk bags, addressing OSHA directives. Companies are able to work with Blastcrete to design a removable lid for larger mixers, which fills the space where silica dust can escape.  Read More