OSHA Compliance

1. OSHA Compliance National Assoc. of Chemical Distributors September 15, 2006 Indianapolis, Indiana Jeff Marks CSP, ARM AIG Consultants, Inc. Jeff.marks@aig.com Making A Difference

2. Goals • At the conclusion of this presentation participants will: • Gain a basic understanding of the regulatory compliance issues they may encounter in their business operations. • Know what to expect if OSHA knocks on your door. • Understand OSHA’s Hierarchy for hazard abatement. • Know where to go for additional assistance. Making A Difference

3. OSHA29 CFR 1910 • OSH Act of 1970 • Took effect April 29, 1971 • 1910 – General Industry • 1926 - Construction • 5(a)(1) – General Duty Clause • 2006 Targeted Inspections • 12 + with days away or restricted Making A Difference

4. OSHA Inspectionswhat to expect….. • Inspection Triggers • Fatality, EE compliant, BLS Survey, Random, National Emphasis Program. • Opening Conference • Reason for inspection. • Record Review • Inspection Tour • Specific area or wall to wall • Employee interviews • Instrument measurements Making A Difference

5. OSHA Inspections(cont) • Closing Conference • Discuss unsafe/unhealthy conditions • Time for Q & A • Appeal rights reviewed • Penalties not discussed Making A Difference

6. Citations & Penalties • Received by Certified Mail. • Posting • 3 days or until corrected. • Notice to Contest • Either the citation, time for abatement or the proposed penalty. • 15 days in writing to OSHA Area Dir. • Informal Conference Making A Difference

7. Citations & Penalties • Potential to reduce penalties by 95% exists • Size of business (up to 60% reduction) • Good Faith (up to 25% reduction) • History of Previous Violations (up to 10% reduction) Making A Difference

8. OSHA Recordkeeping • OSHA Forms for Recordkeeping • Work-related injuries & illnesses. • Form 300: The Log • Form 300A: The Summary • Form 301: Incident Report • Updated with in 7 calendar days. Making A Difference

9. Recordkeeping (cont) • What should you record? • Death • Loss of Consciousness • Days Away from Work • Restricted Work Activity • Medical Treatment Beyond 1st Aid • 1st Aid • Regulation specifies what is considered 1st Aid. If it is not on the list then it is considered medical treatment beyond 1st Aid. Making A Difference

10. Recordkeeping (cont) • Days Away / Restricted Work • Count the calendar days • Day of injury doesn’t count. • 180 day max for either or combination • Maintain the records for 5 years • Posting Requirements • Summary Feb. 1 through April 30 Making A Difference

11. Standards we’ll cover: HAZCOM Lockout/Tagout Powered Industrial Truck Confined Space Entry Respiratory Protection Other standards that may be applicable: Process Safety Mgmt. Machine Guarding Emergency Action Plans Hearing Conservation Specific 1910 Regulations Making A Difference

12. Most Frequently Cited Standards Making A Difference

13. HAZARD Communication1910.1200 • RTK: Right to Know • “EEs have both a need and right to know the hazards and identities of chemicals they are exposed to when working.” • “They also need to know what protective measures are available to prevent adverse health effects.” Making A Difference

14. HAZCOM (cont) • 4 Main Elements to Compliance • Written Program • Container Labeling • MSDS • EE Training Making A Difference

15. HAZCOM (cont) • The Written Program • Employers shall develop, implement, and maintain at each workplace a written HAZCOM Program • Labels and other forms of warning • MSDS • EE information and training • Hazardous Chemical List • Must be available to employees upon request. Making A Difference

16. HAZCOMWritten Program (cont) • The program must also identify the methods of communication for: • Multi-employer worksites • Labeling system in place • Precautionary measures to be taken • MSDS location Making A Difference

17. HAZCOMContainer Labeling • The chemical manufacturer, importer or distributor shall ensure that each container of hazardous chemicals leaving the workplace is labeled with: • Identity of the hazardous chemical • Appropriate hazard warnings • Name & address of the manufacturer, importer or distributor. • Satellite container exception Making A Difference

18. HAZCOMMSDS • Material Safety Data Sheet • Maintained for each hazardous chem. • Maintained in English • Made “readily accessible” • May be kept in any form but must contain the same information • Name, physical characteristics & hazards, routes of entry, health hazards, PEL, control measures, emergency & 1st aid procedures, etc………. Making A Difference

19. HAZCOMEE Training • Employers shall provide employees with effective information and training on hazardous chemicals in their work area at: • The time of their initial assignment • Whenever a new physical or health hazard the employees have not previously been trained about is introduced into their work area Making A Difference

20. HAZCOMEE Training (cont) • Employee training shall include at least: • Methods & observations that may be used to detect the presence or release of a hazardous chemical (monitoring devices, visual appearance or odor of chemical when released.) • The physical & health hazards of a chemical • Measure the employees can (must) take to protect themselves. • The details of the HAZCOM program (labels, MSDS, etc…) Making A Difference

21. Lockout/TagoutThe Control of Hazardous Energy • The standard covers general industry workers performing servicing or maintenance of machines and equipment who are exposed to unexpected startup, energization, or release of hazardous energy. • The purpose of the standard is to prevent the unexpected startup of a machine or the release of stored energy to prevent workplace injuries. Making A Difference

22. What is Lockout? • Lockout - The placement of a lockout device on an energy isolating device, in accordance with an established procedure, ensuring that the device and the equipment being controlled cannot be operated until the lockout device is removed • Energy sources include: mechanical, hydraulic, pneumatic, electrical, chemical, thermal, potential and any other energy. Making A Difference

23. Lockout/TagoutCompliance Highlights • The Lo/To standard requires: • A written energy control program • Machine specific energy control procedures • A periodic inspection • Employee training • Authorized EE training • Affected EE training Making A Difference

24. Lo/To Equipment • After January 2, 1990 all new or modified equipment or machines must be equipped with energy-isolating devices capable of accepting a lockout device. • Locks, tags, chains, gate & ball valve lockouts, group hasps, circuit breaker lockouts, etc…. Making A Difference

25. Lockout/TagoutOther Requirements • All locks must be individually keyed, no master key for locks. • A lock and tag must be placed on each energy source for the piece of equipment being serviced. • All employees working on the equipment must have their own lock on the equipment. • Locks shall not be used for any other purpose besides Lo/To Making A Difference

26. Powered Industrial Trucks • OSHA requires all employers using powered industrial trucks implement a program in accordance with 1910.178. Making A Difference

27. Powered Industrial TrucksCompliance Highlights • Written Program • Employee Training (site & truck specific) • Classroom training • Hands on training • Operator Evaluations • Initial & every 3 years • Refresher Training • Operators must be certified • Daily inspections • Trucks must be approved for atmosphere Making A Difference

28. Confined Space Entry • A confined space is a space that is: • Large enough and so configured that an ee can bodily enter and perform work. • Has a limited or restricted means of entry or exit. • Is not designed for continuous ee occupancy Making A Difference

29. Examples & Hazards of Confined Spaces • Tanks, manholes, boilers, furnaces sewers, silos, hoppers, vaults, etc… • Oxygen Deficiency • <19.5% or >23.5% • Combustibles • Methane, hydrogen, propane, acetylene • Toxic Materials • Carbon monoxide, welding fumes, etc.. • Electricity • Mechanical Hazards • Mixers Making A Difference

30. Permit Required Confined Space • A Permit Required Confined Space is a confined space that has one or more of the following characteristics: • Contains or has the potential to contain a hazardous atmosphere • Contains a material that has the potential for engulfing an entrant • Has an internal configuration such that an entrant could be trapped or asphyxiated by inwardly converging walls or by a floor which slopes downward and tapers to a smaller cross section • Contains any other recognized serious safety or health hazards. Making A Difference

31. Compliance Highlights • Permit required confined space program. • Prevent unauthorized entry • Identify and evaluate hazards of permit spaces • Develop and implement the means necessary for safe entry. • Entry conditions, ventilation, space isolation, air testing and continuous monitoring, PPE , lighting, communication equipment, emergency rescue… • Employee Training – Competent Person • Identify all permit spaces • Atmospheric testing • Entry attendant • Completion of the Written Permit Making A Difference

32. Atmospheric Testing • Before entry, testing is required • Oxygen content • Flammable gases & vapors • Potential air contaminants Making A Difference

33. Atmospheric Testing (cont) • NOTICE: • Anytime a limit is exceeded, no matter what the reason, all personnel shall immediately exit the space and no other employees shall enter the space until atmospheric conditions are returned to safe levels. Making A Difference

34. Confined Spaces Making A Difference

35. Respiratory Protection Making A Difference

36. Respiratory ProtectionCompliance Highlights • Written Respiratory Protection Program • Hazard Assessment • Selection of respirator & cartridges • Medical Surveillance • Employee Training • Fit Testing Making A Difference

37. Respirator Program • Must develop a written program with work-site specific procedures when respirators are necessary or required by the employer • The program must be updated as necessary to reflect changes in workplace conditions that affect respirator use • Must designate a program administrator who is qualified to oversee the program • Must provide respirators, medical evals. and training at no cost to employees Making A Difference

38. Respirator Selection • Filtering face piece – Dust mask • Air Purifying Respirator – Positive / Neg. • Supplied Air Respirator / SCBA Making A Difference

39. Respirator Selection (cont) • Only NIOSH approved respirators • Cartridges selected based on hazard assessment • Change schedules • End of service life indicator • IDLH Atmospheres • Where exposure can not be identified • Atmosphere is immeidate threat to life • Cause irreversible adverse health effects • Impair ee’s ability to escape from hazardous atmosphere Making A Difference

40. Medical Surveillance • A medical evaluation must be provided to determine the ee’s ability to use a respirator • Must identify a PLHCP to perform the medical evaluation using a medical questionnaire or initial medical exam. • Follow up medical exam is required for any ee that gives a positive response to any question 1-8 of section 2, part A of appendix C or whose initial medical exam demonstrates the need. • Annual review is not required however there are triggers that may warrant follow up testing • Ee reports medical signs from use of respirator • Changes in workplace conditions affect physiological burden on ee • Observations from fit testing indicates need. Making A Difference

41. Employee Training • Training is required for ee’s that use respirators • Employees must be able to demonstrate: • Use and limitations • Proper fit, inspection & cleaning • Maintenance & storage • Effective use in emergencies Making A Difference

42. Fit Testing • Fit testing is required prior to the ee’s use of a respirator • Must use same make, model, etc… • Qualitative Fit Testing • Quantitative Fit Testing • Numerical measurement for Fit Factor • User Seal Checks • Before every use Making A Difference

43. Questions Thank you! Making A Difference