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Occupational Health and Safety Code Update. CSSE Meeting May 28, 2009. Sections to be Reviewed. Part 2: Involvement of workers in hazard assessment Part 4: OELs Mould Part 5: New definition of confined space and restricted space Part 6: Load calculations
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Occupational Health and Safety Code Update CSSE Meeting May 28, 2009
Sections to be Reviewed • Part 2: Involvement of workers in hazard assessment • Part 4: • OELs • Mould • Part 5: New definition of confined space and restricted space • Part 6: Load calculations • Part 9: New fall protection requirements • Part 14: • Health care facilities • Training requirements • Part 18: Requirements for biohazardous materials • Part 19: Concrete pump trucks • Part 21: Fatigue rating • Part 28: Overview • Part 35: Medical sharps
Why the New Edition? • Improve the requirements • create safer workplaces • make requirements current and relevant • eliminate unnecessary requirements • Correct errors
A Lengthy Process… • Create OHS Code Review Committee • Create technical committees to deal with specific areas (e.g. OELs, fall protection) • Collect suggestions for change • Prepare a draft for public consultation • Collect suggests from the public • Revise draft • See approval of OHS Council • OHS Council recommends final version to Minister • Minister approves final version via Ministerial Order
Highlights of Changes • Occupational Health and Safety (OHS) Code – Comparison of Requirements Between the OHS Code 2006 and OHS Code 2009 • http://employment.alberta.ca/documents/WHS/WHS-PUB_li029.pdf
Section 2.2 - Designated Person to Prepare Plan • Where the OHS Code requires a plan to be prepared • Must be prepared by a designated person who is competent in the principles and practices of the work described in the plan • Examples: • lead exposure control plan • emergency response plan • fall protection plan • hot tap plan • various mine plans • health and safety plan (if required by Minister) • rope access safe work plan
Section 3.1 – Referenced Standards • Listing of previous editions of referenced standards getting out of hand • To minimize this, Section 3.1 was created • allows older equipment to have been approved to, or have met the requirements of an earlier edition of a referenced standard • e.g. 142.2(1)An employer must ensure that a lanyard manufactured on or after July1,2009 is approved to (a) CSA Standard Z259.11‐05, Energy absorbers and lanyards, (b) ANSI/ASSE Standard Z359.1‐2007, Safety requirements for personal fall arrest systems, subsystems and components, or (c) CEN Standard EN 354: 2002, Personal protective equipment against falls from a height — Lanyards.
Changes to Part 2 • 7(5) A prime contractor must ensure that any employer on a work site is made aware of any existing or potential work site hazards that may affect the employer’s workers • 8(1) An employer must involve affected workers in the hazard assessment and in the control or elimination of the hazards identified
Section 7(5) Hazard Assessment • Duty on prime contractor to inform of any work site hazards that may affect an employer’s workers • Ensures that contractor workers coming onto a work site are made aware of existing site hazards that may affect their work but are not necessarily located within their immediate work area.
Involvement of Workers in Hazard Assessment • Change meant to emphasize worker involvement, but not beyond current requirements • To demonstrate compliance with this requirement, the employer should be able to indicate which workers were meaningfully involved and to what extent • workers should be able to confirm their involvement in the assessment, elimination, and control activities. • this must be documented
Changes to Part 4 • Section 16: OELs updated • Section 20: New methods allowed for exposure monitoring • Section 43(6) Allows the Director of Medical Services to require removal of a worker from a work site if the worker is diagnosed with blood-lead poisoning • Section 43.1: Provision for mould
Part 4: Updated Occupational Exposure Limits (OELs) • There are almost 800 substances with OELs • OELs currently in the Alberta OHS Code are based on 1999 ACGIH TLVs (with a few exceptions) and were adopted in 2003 • When the OELs were last reviewed, the Technical Working Group recommended that the review be repeated every 5 years.
OEL Review Process • Set up an OEL Review Working Group (representation from industry, labour and government) • In principle, 2006 ACGIH TLVs will be adopted • Working group to establish evaluation criteria to identify a short list of substances requiring review
Review Criteria • Available scientific documentation and rationale to ensure health and safety to workers • Availability of analytical methods • Limits set in other jurisdictions • Existing and potential compliance issues • Applicability to Alberta • Social expectations
Detailed Review • 43 Substances identified for detailed technical review • Rational for identifying these substances: • There was a significant difference between the current OEL and the 2006 TLV • The substance was suggested for review through the OEL questionnaire (mailed to 77 Associations) • The substance did not have an OEL
Changes • Coal dust OEL will be reduced, however a one-year implementation period is provided • For the most part, 2006 ACGIH TLVs will be adopted
Deviations from TLVs • Acetic anhydride: ceiling recommended instead of 8-hour exposure limit • Formaldehyde, hydrogen sulphide, PAPI, sulphur, ozone,1,1,1-trifluoro-2,2-dichloroethane variations to remain the same • Particulate Not Otherwise Regulated • Suphuric acid will remain the same as the current OEL
Deviations from TLVs • Inhalable limits for which the numerical value in the 2006 TLV is the same as the current OEL will remain the same (i.e. the total value will be used) • calcium sulphate • Captan • Diquat • EPN • glass fibres • molybdenum • nickel • silicon carbide, nonfibrous
Deviations from TLVs • Inhalable limits for which the ACGIH documentation supports total limits (which may or may not be the same as the inhalable limits) • flour dust (numerically the same) • natural rubber latex (numerically the same) • borates (half the inhalable limit)
Non-Consensus Items • Asphalt • 2,2-dichloropropionic acid • Magnesium oxide • Methane • p,p-oxybis • Trichlorophon • Wood dust
Expanded List of Analytical Procedures • Expands the range of acceptable methods for measuring/analyzing air contaminants for the purposes of complying with the OEL • In addition to NIOSH, the following are recognize: • U.S. OSHA • IRRSST (Quebec) • Health and Safety Executive of Great Britain • U.S. EPA • Sampling Guide of IRRSST of Quebec • ISO air quality standards and guides • DFG Deutsche Forschungsgemeinschaft
New Requirement for Mould • Purpose is to control worker exposure to mould • Where mould can create a work site hazard, it must be controlled in accordance with Section 9 • Best Practice drafted to assist with compliance to this section
New Definitions • “Confined Space” means a restricted space which may become hazardous to a worker entering it because of (a) an atmosphere that is or may be injurious by reason of oxygen deficiency or enrichment, flammability, explosivity, or toxicity, (b) a condition or changing set of circumstances within the space that presents a potential for injury or illness, or (c) the potential or inherent characteristics of an activity which can produce adverse or harmful consequences within the space • “Restricted space” means an enclosed or partially enclosed space, not designed or intended for continuous human occupancy, that has a restricted, limited or impeded means of entry or exit because of its construction
Restricted Space vs Confined Space • Under the current requirements, most trenches would be considered a confined space, but are not subject to the • permitting requirements • atmosphere monitoring • tending worker requirements • Why not? • the hazards have been eliminated or controlled
Restricted Space • Think of this as a work location in which the only hazard is the difficulty in getting into and out of the space • Other examples: • below-ground vaults used for telecommunication or electrical cables • interior inspection areas for wind turbine blades • ventilation system passages within buildings • some attics
Restricted Space • For entry into a restricted space the following are still required: • a hazard assessment must be completed prior to entry • workers must be trained to recognize the hazards in the confined space and work in a healthy and safe manner • a communication system must be available • entry of unauthorized personnel must be prevented • workers must be protected from hazards created by traffic • workers cannot enter or remain in the space unless an effective rescue can be carried out • a competent worker must be communication with the workers inside • a safe means of entry and exit must be provided
Changes to Part 6 • 59(2.1) A hoist may only be used for vertical lifting or lowering if it complies with this Part and is designed and manufactured for vertical lifting or lowering. • 68.1 An employer must ensure that a lift calculation is completed for any lift exceeding 75% of a crane’s rated capacity. • Section 70 requirements for tag lines to ensure that they are not used if they can become a hazard to workers
Section 68.1: Lift Calculation • Purpose is to ensure that cranes are not overloaded • Establishes a requirement to conduct a lift calculation for lifts expected to exceed 75% of a crane’s capacity • These are sometimes referred to as “critical lifts” • Applies to all cranes but most relevant to mobile and overhead cranes
Lift Calculation • A “lift calculation” is a process to ensure that relevant and applicable factors have been considered and calculated • Load information (total weight of item to be lifted, weight of rigging/attachments) • Crane information ( maximum radius, boom length/angle) • Calculated % of crane capacity • Sketch (crane placement, clearance to surrounding facilities like buildings and power lines)
Changes to Part 9 • Training requirements for worker training • Technical standards for equipment • Reduces fall arrest anchor strength requirements to 16 kilonewtons (kN) • Establishes fall protection requirements for fixed ladders and climbable structures • Limited allowance of procedures in place of fall protection equipment
Instruction of Workers • Section 141 establishes detailed training requirements for worker training • Specifies a detailed curriculum for fall protection training programs • Includes a practical, hands-on component
Instruction of Workers • Curriculum includes • fall protection methods a worker is required to use at a work site • identification of fall hazards • assessment and selection of specific anchors that the worker may use • instructions for the correct use of connecting hardware; • information about the effect of a fall on the human body • emergency response procedures
Equipment • Accepts international technical standards for equipment • CEN (European Committee for Standardization) EN standards • ANSI • NFPA • Why the change? • international products offer equal or greater protection • greater variety of products available in Alberta • Products must be “approved” • by nationally accredited third-party organization • products must bear an approval or certification mark • quality assurance
Anchor Strength • Fall arrest anchor strength reduced to 16 kN (3600 lbs-force) • Existing 22.2 kN (5000 lbs-force) requirement excessive • Now aligned with European value • Still retains a 2.7 safety factor based on a maximum arresting force of 6 kN
Fall Protection on Vehicles with Loads • Recognizes that at times it is not reasonably practicable to provide fall protection when a worker needs to climb onto a vehicle or load • Employer must eliminate or reduce the need for the worker to get onto the vehicle or load • After doing everything possible, the employer can use procedures in place of fall protection equipment
Procedures in Place of Fall Protection Equipment • Concept approved for use by WHS and described in OHS Code Explanation Guide 2006 • Procedures can be used in place of “hard” equipment in five cases. They are: • the installation or removal of fall protection equipment • roof inspection • emergency repairs • at‐height transfers between equipment and structures if allowed by the manufacturer’s specifications • situations in which a worker must work on top of a vehicle or load
Changes to Part 14 • Establishes site and program requirements for safe lifting of patients/clients/residents in healthcare facilities • Training requirements for specific measures to eliminate or reduce the possibility of musculoskeletal injury
Work Site Design – Health Care Facilities • Recognizes that the most significant injury to health care workers is back injury as a result of lifting or transfer of patients • Requires patient lift equipment to be installed in new and renovated health care facilities • Does not apply to health care facility construction, alterations, renovations or repairs started before July 1, 2009
Patient/Client /Resident (PCR) Handling • Employer must develop and implement a safe PCR handling program if workers are required to lift, transfer or reposition PCRs • Program must include an annual evaluation of its effectiveness at preventing worker injuries
Training to Prevent Musculoskeletal Injury (MSI) • Workers who may be exposed to the possibility of musculoskeletal injury must be trained in specific measures to eliminate or reduce that possibility (proactive approach) • Training must include • how to identify factors that could lead to an MSI • early signs and symptoms of MSIs and their potential health effects • preventive measures including • the use of altered work procedures • mechanical aids • personal protective equipment