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OSHA Update May 2008

OSHA Update May 2008. Richard T. Gilgrist, CIH Area Director Cincinnati Area Office OSHA. Today’s Agenda. What’s HOT Trends Ohio Stats National/Regional/Local Programs Corporative Efforts Looking Forward. WHAT’S HOT. Hexavalent Chromium Pay for Personal Protective Equipment

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OSHA Update May 2008

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  1. OSHA UpdateMay 2008 Richard T. Gilgrist, CIH Area Director Cincinnati Area Office OSHA

  2. Today’s Agenda • What’s HOT • Trends • Ohio Stats • National/Regional/Local Programs • Corporative Efforts • Looking Forward

  3. WHAT’S HOT • Hexavalent Chromium • Pay for Personal Protective Equipment • Combustible dust

  4. Hexavalent Chromium

  5. Gentleman, I think we’ve had a little too much chromium exposure!!

  6. Welding • Overexposures are likely when welding stainless steel and high chrome steel • Stainless steel has between 10.5% - 27% chromium • Nickel is also present in some types of stainless • Potential for overexposure when welding CARBON steel in an enclosed space • Anywhere the welding fume is more confined, example could be welding in a tight corner • Reason 10% of carbon steel has chromium in more than trace amounts

  7. Welding • Stick welding: High likelihood of overexposure to Cr VI • 50% of total Cr produced is Cr VI ( FR pg 10262 col 3) • TIG generates lower fume amounts • Submerged arc generates lower fume amounts • MIG has lower fume amounts • 4% of total Cr produced from MIG is Cr VI • MIG and TIG • @ 800 degrees C above action level • @ 500 degrees C levels fairly low • Conclusion: Switch to MIG from stick if you can

  8. Chromium (VI) Directive Start-Up Dates & Enforcement • May 30, 2006: Effective date of Chromium (VI) standard. • November 27, 2006: (>=20 employees) All sections of the standard, except engineering controls are citable. • May 30, 2007: (<20 employees) All sections of the standard, except engineering controls are citable. • May 31, 2010: (All employers) Until Deadline—Engineering controls not enforceable. Respirators required to comply with PEL. After Deadline—Engineering controls enforceable. If exposures, cite applicable violations of Cr(VI) PEL & engineering controls.

  9. PPE Payment • Final published November 2007 • Requires employers to pay for most PPE • Does not require payment for uniforms, items worn to keep clean, or other items that are not PPE • Contains exceptions for ordinary safety-toe wear, ordinary prescription safety eyewear, everyday clothing and ordinary weather-related gear, and logging boots

  10. Types of Dust Involved in incidents

  11. Types of Industries Involved in Dust Incidents

  12. NEP/ Industry Application • Agriculture • Chemicals • Textiles • Forest and furniture products • Metal processing • Tire and rubber manufacturing plants • Paper products • Pharmaceuticals • Wastewater treatment • Recycling operations (metal, paper, and plastic.) • Coal dust in coal handling and processing facilities.

  13. WHAT’S NEW • A new Compliance Assistance Specialist has been added: GAYE JOHNSON

  14. Fatality Data Trends Totals Manufacturing

  15. Fatality Trends: REGION V

  16. Total Fatalities in Region V

  17. Fatalities by Company Size: Region V

  18. Fatalities by Company Size in Manufacturing FY 2004 – FY 2006

  19. Total Fatalities by Event: Region V

  20. Ohio Inspection Activity FY 07

  21. Programmed Emphasis Areas

  22. Emphasis Programs: OHIO FY 07

  23. NEPs Under Development • Oil and Gas Well Drilling • Flavorings • Chemical Plants • Primary Metals

  24. Primary Metals NEP • Foundries and primary metals • Significant cases in the last several years • Continue to find over exposures to: • Lead • Silica • Other metals • Other air contaminants such as benzene • Noise

  25. Primary Metals NEP • Foundries and primary metals • Continue to find violations related to: • Respiratory protection • Engineering controls for air contaminants • Personal protective equipment • Hazard communication • Hearing protection and conservation program

  26. Other Fatality Hazard Emphasis Areas • Falls • Trenching • Road Construction • Powered Industrial Vehicles

  27. Inspections Coded PIT/PIV Region V Programmed Local Emphasis Powered Industrial Vehicles

  28. Top 20 Standards Citedfor General Industry

  29. Top 20 Standards Cited in FY 07General Industry: Cincinnati Area Office 1910.212(a)1 Machine Guarding 1910.147(d)4(i) Lockout or Tagout Devices 1910.147(c)7(i) LOTO Training and Communication 1910.147(c)4(i) LOTO Energy Control Procedure 1910.147(c)6(i) LOTO Periodic Inspection Cincinnati Area Office October 1, 2003 thru December 31, 2004

  30. Top 20 Standards Cited in FY 07General Industry: Cincinnati Area Office 1910.1200(h)1 HazComm Training & Information 1910.132(a) Protective Equipment 1910.147(d)3 LOTO Machine or Equipment Isolation 1910.212(a)3(ii) Point of Operation Guarding 1910.219(e)3(i) Vertical and Inclined Belt Guards Cincinnati Area Office October 1, 2003 thru December 31, 2004

  31. Top 20 Standards Cited in FY 07General Industry: Cincinnati Area Office 1910.303(g)2(ii) Enclosures or Guards to Prevent Damage 1910.1200(e)1 Written HazComm Program 1910.1200(f)5(ii) HazComm Hazard Warnings 1910.147(c)4(ii) LOTO Energy Control Procedure 1910.1200(f)5(i) HazComm Labeling Cincinnati Area Office October 1, 2003 thru December 31, 2004

  32. Top 20 Standards Cited In FY 07General Industry: Cincinnati Area Office 1904.29(a) Manually Propelled Mobile Ladder Stands and Scaffolds 1910.23(c)1 Open-sided Floor or Platform 4 Feet or More 1910.147(c)5(i) LOTO Protective Materials and Hardware 1910.151(c) Suitable Facilities For Quick Drenching or Flushing of The Eyes and Body 1910.219(f)3 Sprocket And Chain Guards

  33. Ohio Statistics FY 07 Number of Inspections: 2649 Percentage Construction 54.9% Complaints Received 2284 SST Inspections Conducted 208 Significant Cases (Over $100,000) 14 Percent Serious, Willful, Repeat, FTA81.3% Average Violations per Inspection 2.6 Penalty per Serious Violation $996.50

  34. Ohio Statistics FY 07 Percent “In Compliance” 24.2% Number of Fatalities Inspected 58 New VPP STAR sites 21 New Partnerships 4 New Alliances 2 Whistleblower Investigations 176

  35. Ohio Compliance Assistance Goals2008

  36. Outreach Emphasis Areas • Hispanic Employees and Employers • Homeland Security • Youth • Arc Flash, NFPA 70-E • National Federation of Independent Businesses • Combustible Dust • Pandemic Flu • “Bottom Line” Safety and Health

  37. Pandemic Flu Preparation • Continuity of Operations • Remote Access • Training • PPE

  38. LOOKING FORWARD • CONFINED SPACE FOR CONSTRUCTION • DIACETYL STANDARD? • COMBUSTIBLE DUST STANDARD OR ETS? • GUIDANCE DOCUMENTS • THE ELECTION AND WHAT GETS DONE BEFORE JANUARY

  39. Health Issues on the Reg Agenda • Crystalline silica • Beryllium • Hearing conservation in construction • Ionizing radiation • Standards Improvement Project III • Emergency response and preparedness • Hazard communication • Diacetyl

  40. Hazard Communication • Considering adoption of the Globally Harmonized System of Classification and Labeling of Chemicals (GHS) • Published an advance notice of proposed rulemaking (ANPR) 9/12/2006 • Accepted comments until 11/13/2006 • Working on a proposed standard

  41. Diacetyl and Food Flavorings Containing Diacetyl – Recent Activities • Initiated a National Emphasis Program for microwave popcorn processing plants • Denied the request for an Emergency Temporary Standard but announced our intent to move forward with regular 6(b) rulemaking • Issued guidance • SHIB on respiratory disease in microwave popcorn manufacturing • Hazard Communication Guidance on diacetyl and food flavorings containing diacetyl • Held a stakeholder meeting 10/07

  42. Diacetyl and Food Flavorings Containing Diacetyl – Next steps/issues • Initiate SBREFA Review • Issues • Scope • Analytical method • PEL

  43. Completed Guidance Projects Motor vehicle safety Combustible dust (SHIB) Fire services manual Fireworks poster Ergonomics – nursing homes, grocery stores, poultry processing, and draft shipyards document Indoor air (mold) Glutaraldehyde Perchloroethylene Abrasive blasting in shipyards Marine hanging staging Hurricane quick cards Diacetyl hazard communication

  44. Guidance Projects in Development Hazards of scrap metal recycling Hazard communication/GHS PPE for emergency response Controls for silica exposure in construction Ergonomics in Shipyards Fireworks video Working Safely with Portland Cement Pocket Guide for Respiratory Protection Stockpiling respirators foran influenza pandemic

  45. OTHER POTENTIAL EMPHASIS AREAS • MRSA!! • GUT/REHAB

  46. Don’tForget • www.osha.gov • Compliance Assistance • Specialists (6 in Ohio) • On-site Consultation • BWC- Div of S&H • Quick Takes

  47. Don’tForget • To call your local Area Office with Questions! • 513 841-4132

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