OSHA Checklists For COBRA Teams

1. OSHA Checklists For COBRA Teams Presented by: Labor Relations Staff December 2, 2004

2. Main Purpose of Presentation • To arm COBRA teams with basic OSHA-related checklists for use on the ground at any FAA facility. • To provide supporting legal and regulatory authority as well as additional resources that the COBRA teams may utilize to fine tune and enhance the basic checklists.

3. Secondary Purpose of Presentation • To walk the COBRA teams through the procedural steps and potential ramifications of any formal OSHA inspection that may be triggered by their review of the facility. • To familiarize the teams with the whistleblower protections currently available to FAA employees.

4. Agenda • Overview of OSHA – 10 minutes • Other Relevant Authority – 10 minutes • Review of Checklists, Supporting Legal Authority, and Sources of Additional Information – 45 minutes • OSHA Inspection Process – 15 minutes • Employee Whistleblower Protections – 15 minutes • Questions and Discussion – 25 minutes

5. Part 1 - OSHA Overview • The Act • The General Duty Clause • Executive Order 12196 • 29 CFR 1900-1910 • 29 CFR 1960

6. OSHA Overview – The Act (Slide 1) • Occupational Safety & Health Act of 1970 (The Act) • 29 USC 651 et seq. • 29 CFR Parts 1900, 1910, and 1960 • Administered by OSHA at DOL

7. OSHA Overview – The Act (Slide 2) • The Act covers all employers and their employees in the 50 states, the District of Columbia, Puerto Rico, and other US territories. • The Act is administered by both Federal and State OSHA programs. • For Federal employees, Section 19 of the Act requires that each Agency establish and maintain an effective OSH program consistent with private-sector OSH standards.

8. OSHA Overview – The General Duty Clause • The “general duty clause” (Section 5(a)(1) of The Act) covers FAA employees. • It states that “each Employer shall furnish . . . a place of employment which is free from recognized hazards that are causing or are likely to cause death or serious physical harm to employees.”

9. OSHA Overview – Executive Order 12196 • Executive Order 12196 was signed by President Carter in 1980 and is still in effect. • It requires all federal agencies to comply with all standards issued under the Act.

10. OSHA Overview – Major Requirements of E.O. 12196(Slide 1) • 1) Furnish employees with conditions and places of employment that are free from recognized hazards. • 2) Assure prompt abatement of unsafe or unhealthy working conditions. • 3) Periodic inspections to identify hazards. • 4) Assure anonymity to employees reporting hazards. • 5) No reprisals against employees making reports.

11. OSHA Overview – Major Requirements of E.O. 12196(Slide 2) • 6) Establish Safety Committees. • 7) Allow for Union representation on Safety Committees and during inspections of workplaces. • 8) Maintain records. • 9) Provide health & safety training to supervisors and employees.

12. OSHA Overview – 29 CFR 1900-1910 • The heart of OSHA, these parts of the CFR contain the specific OSHA standards and are the main source for the checklist items. • The standards are grouped into Subparts by category, for example, 29 CFR 1910, Subpart L (Sections 1910.155 through 1910.165) covers Fire Protection. • The appendices incorporate numerous industry standards by reference (some mandatory and some non-mandatory) and are a good source of additional information for enhancing your checklists.

13. OSHA Overview – 29 CFR 1960 (Slide 1) • This Section of the CFR provides extensive regulations for management of OSH programs at all agencies of the Executive Branch, including procedures for inspections and abatement. • The regulations apply to all federal employees including those who may work in a private sector or privately-owned workplace. • In instances where other federal standards (i.e EPA, NIOSH, GSA, etc.) conflict with the OSHA standards, Part 1960 requires agencies to comply with the more protective of the conflicting standards.

14. OSHA Overview – 29 CFR 1960 (Slide 2) • Other subject matter covered by Part 1960: • Administration of OSH programs • Inspection and abatement procedures • OSH Committees • Allegations of reprisal against employees • Training • Record-keeping and reporting • Evaluation of OSH programs

15. Part 2 - Other Relevant Authority • EPA Regulations • GSA Regulations • The NATCA-FAA CBA (“The Contract”) • FAA Order 3900.19B • Locally Negotiated MOUs

16. Other Relevant Authority – EPA Regulations (Slide 1) • All regulations issued by the EPA are compiled in Title 40 of the CFR. • EPA regulations are focused on protecting the environment and the general public, not on worker and workplace safety. • EPA does not routinely inspect and enforce these regulations in workspace occupied by federal employees without a request.

17. Other Relevant Authority – EPA Regulations (Slide 2) • Acts or statutes that direct EPA regulation: • Toxic Substances Control Act (TSCA) • Resource Conservation and Recovery Act (RCRA) • Clean Air Act Amendments of 1990 (CAAA) • Clean Water Act (CWA) • Superfund (CERCLA) • Federal Insecticide, Fungicide, & Rodenticide Act (FIFRA) • Superfund Amendments and Reauthorization Act (SARA) • Safe Drinking Water Act (SDWA)

18. Other Relevant Authority – GSA Regulations • Chapter 102 of the Federal Management Regulations lays out the safety and environmental management standards applied by the General Services Administration (GSA) to all federal agencies operating in GSA space pursuant to a GSA delegation of authority. • The GSA standards utilize OSHA and EPA standards as their base (i.e. floor) requirements.

19. Other Relevant Authority – The Contract(Slide 1) • Article 53, Occupational Safety & Health, includes the following provisions: •Section 6 which requires that the Agency maintain first aid kits at a certain standard of readiness. •Section 7 which requires evacuation plans. •Section 8 which requires that at least one person per crew receive accredited first aid and CPR training. •Section 12 which requires periodic drinking water testing.

20. Other Relevant Authority – The Contract(Slide 2) • Article 77, Asbestos, includes the following provisions: •Section 1 which requires testing of the air every six months in certain facilities. •Section 2 which requires the development of model contingency plans for certain facilities.

21. Other Relevant Authority – FAA Order 3900.19B • “Establishes the policy framework and assigns responsibility for an effective agency-wide employee safety and health program.” • The Order is intended to meet all OSHA-mandated health and safety requirements and tracks the language of 29 CFR 1910 and 1960. • The Order specifically states that the FAA has adopted all of the OSHA “general industry” standards for application to FAA workplaces.

22. Other Relevant Authority – Locally Negotiated MOUs • Check with the local facility safety representative to determine whether or not any local MOUs exist that may require the facility managers to provide a higher or different standard of safety than the standard otherwise required by OSHA for one or more of the subject matter areas. • Example: a local MOU which requires that the facility be tested on a bi-monthly basis for radon gas due to a previous exposure incident.

23. Part 3 – The Checklists • The lists are split into two groups: • “Boots On the Ground” checklists are meant to be utilized during physical, walk around inspections of facilities to identify tangible, physical anomalies, hazards, or violations of OSHA and other related regulations (a number of these checklists are attached and we will discuss them). • “Administrative” checklists are meant to be utilized to identify failures of management in the areas of record-keeping, information sharing, training, and other administrative responsibilities required by OSHA or any other regulations (these checklists have not been provided).

24. The Checklists – A Couple Of Notes • Most (but not all) checklist items are required by OSHA, EPA, or other federal regulation. Check local and state law to see if additional standards may apply. • Some of the checklists items are not mandatory but that does not mean you cannot use them to your advantage when confronting management (i.e. mixing and matching mandatory and non-mandatory items will keep management on their toes). • The checklists provided are NOT exhaustive and you should feel free to supplement them with additional items prior to or during your review of the facility.

25. The Checklists – “Boots on the Ground” Categories Covered (Slide 1) • “Boots on the Ground” categories to be reviewed utilizing the checklists include: • Walking-Working Surfaces • Confined Space Entry Hazards • Elevated Heights & Fall Protection • Exit Routes, Means of Egress/Escape • General Fire Requirements • Emergency Action (Evacuation) Plans • Blood Borne Pathogens • Ventilation & Indoor Air Quality

26. The Checklists – “Boots on the Ground” Categories Covered (Slide 2) • Excessive Noise/Hearing Conservation • Medical & First Aid • Fire Extinguishers, Standpipes & Hose Systems • Fire Alarms • Flammable & Combustible Materials • Fire Protection & Prevention Plans For Construction • Hazardous Energy Control (Lock Out-Tag Out) • Radiation Safety

27. The Checklists – “Boots on the Ground” Categories Covered (Slide 3) • Asbestos • Lead • Pesticides • Electrical Safety • Hazard Communication Program • Thermal Stress Prevention • Respiratory Protection • Personal Protective Equipment • Toxic & Hazardous Substances Exposure Control

28. Walking – Working Surfaces Checklist (Page 1) • Is a documented, functioning housekeeping program in place? • Are all worksites clean, sanitary, and orderly? • Is combustible scrap, debris, and waste stored safely and removed from the worksite properly? • Are accumulations of combustible dust routinely removed from elevated surfaces including the overhead structure of buildings, etc.? • Are aisles and passageways kept clear? • Are aisles and walkways marked as appropriate? • Are wet surfaces covered with non-slip materials? • Are holes in floors or other walking surfaces repaired properly, covered or otherwise made safe? • Is there safe clearance for walking in aisles where motorized or mechanical handling equipment is operating? • Are materials or equipment stored in such a way that sharp projectives will not interfere with the walkway? • Are spilled materials cleaned up immediately? • Are changes of direction or elevation readily identifiable?

29. Walking – Working Surfaces Checklist (Page 2) • Are aisles or walkways that pass near moving or operating machinery arranges so employees will not be subjected to potential hazards? • Is adequate headroom provided for the entire length of any aisle or walkway? • Are standard guardrails provided wherever aisle or walkway surfaces are elevated more than 30 inches above any adjacent floor or the ground? • Are floor openings guarded by a cover, a guardrail, or equivalent on all sides (except at entrance to stairs or ladder)? • Are toeboards installed around the edges of permanent floor openings? • Are skylight screens of such construction and mounting that they will withstand a load of at least 200 pounds? • Is the glass in the windows, doors, glass walls, etc., which are subject to human impact, of sufficient thickness and type for the condition of use? • Are grates or similar type covers over floor openings such as floor drains of such design that foot traffic or rolling equipment will not be affected by the grate spacing? • Are floor or wall openings in fire resistive construction provided with doors or covers compatible with the fire rating of the structure and provided with a self-closing feature when appropriate?

30. Walking – Working Surfaces Checklist (Page 3) • Are standard stair rails or handrails on all stairways having four or more risers? • Are all stairways at least 22 inches wide? • Do stairs have landing platforms not less than 30 inches in the direction of travel and extend 22 inches in width at every 12 feet or less of vertical rise? • Do stairs angle no more than 50 and no less than 30 degrees? • Are step risers on stairs uniform from top to bottom? • Are steps on stairs and stairways designed or provided with a surface that renders them slip resistant? • Are stairway handrails located between 30 and 40 inches above the leading edge of stair treads? • Do stairway handrails have at least 3 inches of clearance between the handrails and the wall or surface they are mounted on? • Where doors or gates open directly on a stairway, is there a platform provided so the swing of the door does not reduce the width of the platform to less than 21 inches? • Do stairway landings have a dimension measured in the direction of travel, at least equal to the width of the stairway? • Is vertical clearance above the stair tread to an overhead obstruction at least 7 feet measured from the leading edge of the tread? See 29 CFR 1910.22 et seq. and 1926 et seq. for further detail.

31. Confined Space Entry Hazards Checklist (Page 1) • Are confined spaces thoroughly emptied of any corrosive or hazardous substances, such as acids or caustics, before entry? • Are all lines to a confined space containing inert, toxic, or flammable or corrosive materials valved off and blanked or disconnected and separated before entry? • Are all impellers, agitators, or other moving parts and equipment inside confined spaces locked out if they present a hazard? • Is either natural or mechanical ventilation provided prior to confined space entry? • Are appropriate atmospheric tests performed to check for oxygen deficiency, toxic substances and explosive concentrations in the confined space before entry? • Is adequate illumination provided for the work to be performed in the confined space? • Is the atmosphere inside the confined space frequently tested or continuously monitored during conduct of work? • Is approved respiratory equipment required if the atmosphere inside the confined space cannot be made acceptable? • Is all portable equipment used inside confined spaces either grounded and insulated, or equipped with ground fault protection?

32. Confined Space Entry Hazards Checklist (Page 2) • If employees will be using oxygen-consuming equipment such as salamanders, torches, and furnaces, in a confined space, is sufficient air provided to assure combustion without reducing the oxygen concentration of the atmosphere below 19.5 percent by volume? • Whenever combustion-type equipment is used in a confined space, are provisions made to ensure the exhaust gases are vented outside of the enclosure? • Is each confined space checked for decaying vegetation or animal matter which may produce methane? • Is the confined space checked for possible industrial waste which could contain toxic properties? • If the confined space is below-ground and near areas where motor vehicles will be operating, is it possible for vehicle exhaust or carbon monoxide to enter the space? See 29 CFR 1910.146 and Chapter 11, FAA Order 3900.19B for further detail.

33. Elevated Heights & Fall Protection Checklist (Page 1) • Do walking and working surfaces have the strength and structural integrity to support people safely? • Are employees prohibited from working on surfaces that cannot support them safely? • Is every open-sided floor or platform that is 4 feet or more above the adjacent floor ground level guarded by a standard railing on all open sides? • Is every runway guarded by a standard railing on all open sides that are 4 or more feet above the floor or ground level? • Regardless of height, are all open-sided floors, walkways, platforms, or runways guarded with a standard railing and toeboard if they are above or adjacent to any dangerous equipment or operation? • Is every open-sided floor or platform that is 4 feet or more above the adjacent floor ground level guarded by a toeboard if, beneath the open sides, a) persons can pass, b) machinery is moving, or c) equipment could create a hazard of falling materials? • Is every wall opening from which the drop is more than four feet guarded with a standard railing or other barrier? • Is every window wall opening guarded by slats, grill work, or standard railing if a) it is at a stairway, landing, floor, platform, or balcony from which the drop is more than 4 feet, and b) the bottom of the opening is less than 3 feet above the platform or landing?

34. Elevated Heights & Fall Protection Checklist (Page 2) • If wooden railings are used as guardrails, are the posts at least 2 inches by 4 inches and spaced less than 6 feet apart? • If pipe railings are used, are posts and top and intermediate rails at least 1 ½ inches nominal diameter with posts spaced less than 8 feet on centers? • If structural steel is used for guardrails, are the posts and top and intermediate rails a) at least 2 inches by 2 inches by 3/8 inch angle irons, or b) other metal shapes of equivalent bending strength with posts spaced not more than 8 feet on center? • Is the guardrail anchored and of such construction that it is capable of withstanding a load of at least 200 pounds applied in any direction at any point on the top rail? • Are handrails constructed so that they can easily be grasped? • Are wall opening barriers (rails, rollers, picket fences, and half doors) constructed and mounted so that the barrier is capable of withstanding a load of at least 200 pounds applied in any direction at any point on the top rail or corresponding member? • For fixed ladders, is the distance between rungs 12 inches or less and uniform throughout the length of the ladder?

35. Elevated Heights & Fall Protection Checklist (Page 3) • For fixed ladders, is the minimum clear length of rungs or cleats at least 16 inches? • Are the rungs, cleats, and steps free of splinters, sharp edges, burrs, or other projections that are hazards? • Are the rungs of ladders designed so that the foot cannot slip off the end? • Are the rungs of metal ladders at least three-fourths of one inch in diameter? • Do siderails that might be used as a climbing aid provide adequate gripping surface without sharp edges, splinters, or burrs? • Are metal ladders painted or treated to protect them from corrosion and rusting when location demands? • Is the perpendicular distance from the center line of the rungs to the nearest permanent object on the climbing side of the ladder 36 inches for a pitch of 76 degrees and 30 inches for a pitch of 90 degrees? • Is the distance from the center line of the rung, cleat, or step to the nearest permanent object behind the ladder at least 7 inches? • Is the distance from the center line of the grab bar to the nearest permanent object behind the grab bar at least 4 inches?

36. Elevated Heights & Fall Protection Checklist (Page 4) • Is the step-across distance from the nearest edge of the ladder to the nearest edge of the equipment or structure not more than 12 inches and not less than 2 ½ inches? • Are the siderails of ladders extended at least 3 ½ feet above the landing? • Are all ladders inspected regularly and maintained in a safe condition? See 29 CFR 1926.501 to 503 and Chapter 10, FAA Order 3900.19B for further detail.

37. Exit Routes, Means of Egress/Escape Checklist (Page 1) • Are exits provided to permit the prompt escape of occupants in cases of fire or other emergency? • Is every exit, way of approach, and way to travel from the exit to the street continuously maintained free of all obstructions or impediments? • Are exits maintained so as to provide free and unobstructed egress or escape when the room is occupied? • Does every building or area have two exits if one exit could be blocked because of a fire, smoke, or other emergency? • Do exits discharge directly onto a street, yard, court, or other open space that gives safe access to a public way? • Do exit doors swing in the direction of travel when an area is occupied by more than 50 people or where hazardous operations are conducted? • Are all exit doors and paths of exits 28 inches or more in width? • Are means of egress or exit designed and maintained to provide adequate head room, with the ceiling height at least 7 ½ feet and any projections from the ceiling more than 6 feet 8 inches from the floor? • Is every exit clearly visible and the route to it conspicuously indicated so that everyone readily knows the direction of escape from any point?

38. Exit Routes, Means of Egress/Escape Checklist (Page 2) • In areas equipped with artificial illumination, do all exit paths have adequate and reliable illumination? • Are exits prohibited through bathrooms or other rooms subject to locking? • Is storage of flammable or combustible materials in exit corridors prohibited? • Is the use of highly flammable furnishings or decorations prohibited/ • Are the exit routes a permanent part of the workplace? • Are the exit discharge areas large enough to accommodate the building occupants likely to use the exit route? • Are exit stairs that continue beyond the level on which the exit discharge is located interrupted at that level by doors, partitions, or other effective means that clearly indicate the direction of travel leading to the exit discharge? • Are all exit doors unlocked from the inside and free of devices or alarms that could restrict use of the exit route if the device or alarm fails? • Do all exit doors connecting to exit routes have side hinges? • Do all exit routes support the maximum permitted occupancy for each floor served? • Does the capacity of an exit route decrease in the direction of exit route travel to the exit discharge? (It should not).

39. Exit Routes, Means of Egress/Escape Checklist (Page 3) • Do all outdoor exit routes meet the minimum height and width requirements for indoor exit routes? • Do all outdoor exit routes have guardrails to protect unenclosed sides if a fall hazard exists? • Are they covered if snow or ice is likely to accumulate, unless the employer can demonstrate that accumulations will be removed before a slipping hazard exists? • Are they reasonably straight with smooth, solid, substantially level walkways? • Do they not have a dead-end longer than 20 feet? • Are all fire exist separated by fire resistant materials? • Are all fire exits protected by a self-closing, approved fire door that remains closed or automatically closes in an emergency? • Is access to exits marked by readily visible signs and arrows when the way to reach it is not immediately visible? • Are doors, passageways or stairways that are neither exits nor a way to an exit, and which can be mistaken for an exit, marked with a sign reading “Not An Exit” or similar designation?

40. Exit Routes, Means of Egress/Escape Checklist (Page 4) • Are exit signs clearly visible, distinctive in color, and easily distinguished from decorations, interior finish, and other signs? • Is every exit sign illuminated by a reliable light source? • In areas where reduction of normal illumination is permitted, are exit signs internally illuminated? • Does every exit sign have the word “Exit” in plainly legible letters not less than 6 inches high, with the principal strokes of letters not less than ¾ inches wide? • Are all exit routes and exit signs maintained during times of construction, repairs, or alterations? See 29 CFR 1910.36 and 37 for further detail.

41. General Fire Requirements Checklist (Page 1) • Are all fire escapes, stairs, passageways, doors, and windows free of obstructions that would interfere with the evacuation of the building or the operation of the fire department? • Are all fire doors tight fitting and in good operational condition? • Are openings in the walls, floors, or ceilings that would contribute to the spread of fire from one room to another repaired? • Is the vertical clearance between sprinklers and material below (such as head deflectors) at least 18 inches? • Are accumulations of flammable or combustible waste materials (i.e. stored empty cardboard boxes, open boxes of paper) and residues removed so that they will not contribute to a fire? • Is adequate clearance maintained between stored materials and light fixtures to prevent possible ignition? • Does the employer have a fire prevention plan? • Is it available for employee review? • Does it include housekeeping procedures for storage and cleanup of flammable materials and flammable waste? • Does it cover procedures for controlling workplace ignition sources?

42. General Fire Requirements Checklist (Page 2) • Does the plan inform workers of the potential fire hazards of their jobs and plan procedures? • Does it list all major fire hazards and the type of fire protection equipment necessary to control each hazard? • Does the plan contain procedures for the regular maintenance of safeguards installed on heat-producing equipment in order to prevent the accidental ignition of combustible materials? • Does the plan contain the name or job title of the employee(s) responsible for maintaining equipment to prevent or control sources of ignition or fire? • Does the plan contain the name or job title of the employee(s) responsible for the control of fuel source hazards? • Does the plan require that it be reviewed with all new employees or with all employees whenever the plan is changed? See 29 CFR 1910.36, 38, and 159 and Chapter 24, FAA Order 3900.19B for further detail.

43. Emergency Action (Evacuation) Plan Checklist (Page 1) • Does the employer have a written plan (required to be in writing for a workplace with 10 or more employees)? • Does the plan contain procedures for reporting fires or other emergencies? • Does it contain emergency evacuation procedures, including the type of evacuation and exit route assignments? • Does it contain procedures for employees performing rescue or medical duties? • Does it contain procedures to account for all employees after an evacuation? • Does it include procedures for evacuating disabled employees? • Does it address the evacuation of employees who stay behind to continue critical workplace operations or equipment? • Does it include the preferred means of alerting employees to a fire emergency? • Does it provide for an employer alarm system throughout the workplace? • Does it require an alarm system that includes voice communication or sound signals such as bells, whistles, or horns? • Does it make clear to employees what the evacuation signal will be?

44. Emergency Action (Evacuation) Plan Checklist (Page 2) • Does it ensure emergency training for employees designated to assist in any evacuation? • Does it require employer review of the plan with new employees and with all employees whenever the plan is changed? • Does it contain the name or job title of employees to contact for detailed plan information? • Does it identify a safe location away from the workplace and in an area where employees can assemble without interfering with emergency response teams at to which all employees should proceed to post-evacuation? • Is the evacuation plan posted prominently on each floor? • Are emergency evacuation drills conducted periodically? • Are there regular tests of all back-up systems and safety systems, such as emergency lighting and communication systems? • Are there systems in place to ensure that during off-hour periods, any off-hour occupants at the workplace are able to be notified, evacuated, and accounted for if an emergency occurs? See 29 CFR 1910.36, 160, and 164 for further detail.

45. Blood Borne Pathogens Checklist • No checklist yet developed. See 29 CFR 1910.1030 for detail. • Refer to FAA Order 3900.19B, Chapter 17, entitled “Blood Borne Pathogens Control Program” for details of FAA regulations and requirements in this area. • See also Medical & First Aid checklist.

46. Ventilation & Indoor Air Quality Checklist (Page 1) Please note that these checklist items are mostly recommendations and not requirements of Federal or state law. You may want to use this as a general checklist to help identify problems that you can then pursue more aggressively with the help of additional, category-specific, detailed information. • Is someone designated to develop and implement an indoor air quality management plan for the workplace? • Does your workplace already have an indoor air quality management plan that includes steps for preventing and resolving indoor air quality problems? • Has your workplace been tested for radon, and have radon-mitigation systems been installed where needed? • Have painted surfaces in your workplace been tested for lead-based paint, and has a lead control or removal program been implemented? • Are the workplace facilities inspected once or twice each year for conditions that may lead to indoor air quality problems? • Is a preventative maintenance schedule established and in operation for the heating, ventilation, and air conditioning systems? If so, what standards are utilized for the maintenance program? • Are water leaks that could promote the growth of biologic agents promptly repaired?

47. Ventilation & Indoor Air Quality Checklist (Page 2) • Are microbial contaminants removed from ductwork, humidifiers, other HVAC and building system components, and from building surfaces such as carpeting and ceiling tiles when found during regular inspections, emergency maintenance, or visual inspections? • Is general or local exhaust ventilation used where housekeeping and maintenance activities could reasonably be expected to result in exposure to hazardous substances above applicable exposure limits? • When a contaminant is identified in the make-up air supply, is the source of the contaminant eliminated, or are the make-up inlets or exhaust air inlets relocated to avoid entry of the contaminant into the air system? • If buildings do not have mechanical ventilation, are windows, doors, vents, stacks, and other portals used for natural ventilation operating properly? • Are complaints properly investigated that may involve a building-related illness? • Is the maintenance schedule updated to show all maintenance performed on the building systems? • Are employees properly protected from airborne hazards during renovation work or new construction?

48. Excessive Noise/Hearing Conservation Checklist (Page 1) Note that the OSHA permissible exposure limit (PEL) for noise is 90 dBA. NIOSH, however, has a more stringent standard. The FAA may have even stronger standards due to the nature of FAA work. • Have all operations or equipment believed to exceed an 8 hour time-weighted average of 85 dBA been measured to determine their noise levels? • If noise levels exceed 85 dBA, has personal noise dosimetry been performed on exposed persons to determine their 8-hour time-weighted-averages? • Does the workplace administer a continuing, effective hearing conservation program when noise exposures equal or exceed 85 dBA as an 8-hour time-weighted average? • Are hearing protectors available at no cost to all persons exposed to noise levels at or above 85 dBA? • Have feasible engineering or administrative controls been used to reduce operations or equipment noise levels to below 90 dBA? • Are noise measurements repeated when a change in operations or equipment may increase noise exposure? • Are employees permitted to observe noise measurements? • Are employees notified of noise monitoring results when exposures equal or exceed 85 dBA?

49. Excessive Noise/Hearing Conservation Checklist (Page 2) • Are noise measurement records maintained for at least two years? • Are hearing protectors evaluated to verify that they effectively reduce noise to levels below 85 dBA? • Are employees hearing test records maintained for the duration of employment? • Is a copy of the OSHA noise standard available to employees, with a copy posted in the workplace? • Do all employees exposed to 85 dBA or more receive hearing conservation training when they begin work and annually thereafter? See 29 CFR 1910.95, applicable NIOSH regulations, and Chapter 21, FAA Order 3900.19B for further detail.

50. Medical & First Aid Checklist • Are medical personnel readily available for advice and consultation on work-related health issues? • If a hospital, clinic, or infirmary is not proximate to the areas where employees are located, is at least one person available who is adequately trained to render first aid? • Are adequate first aid supplies readily available? • Does the First Aid kit contain body fluid clean up material and CPR pocket masks? • Are alcohol wipes for ear pieces available? • Is one person per crew or shift trained by the Employer in how to handle blood borne pathogens? • Are suitable facilities for quick drenching or flushing of the eyes and body available in work areas where the eyes or body may be exposed to corrosive materials? • Do all employees handling blood and bodily fluids in an emergency follow universal precautions? See 29 CFR 1910.151 and 1030 and Chapter 22, FAA Order 3900.19B for further detail.