OSHA A Regulatory OVER view for Healthcare

1. OSHAA Regulatory OVER view for Healthcare New England Healthcare Engineer’s Society 2012 Annual Fall Conference Steven Jalowiec, PE, CHFM

3. Nov. 9, 2011 press release, Dr. Michaels, Assistant Secretary of Labor for OSHA, issued the following statement: “It is unacceptable that the workers who have dedicated their lives to caring for our loved ones when they are sick are the very same workers who face the highest risk of work-related injury and illness. These injuries can end up destroying a family’s emotional and financial security. While workplace injuries, illnesses and fatalities take an enormous toll on this nation’s economy – the toll on injured workers and their families is intolerable. “ “The rates of injuries and illnesses among hospital and health care workers underscore OSHA’s concern about the safety and health of these workers. OSHA is responding by launching, in the next few months, a National Emphasis Program on Nursing Home and Residential Care Facilities. Through this initiative, we will increase our inspections of these facilities, focusing on back injuries from resident handling or lifting patients; exposure to bloodborne pathogens and other infectious diseases; workplace violence; and slips, trips and falls.”

4. OSHA Inspection Triggers High-hazard industries industries deemed to be of a high-hazard nature healthcare or construction, will be subject to more frequent routine inspection. Employee complaints/referrals result of a whistleblower incident referral from another observing government agency High DART Rate days away from work, days of restricted work activity or job transfer Higher than peer industries locally or nationally

5. OSHA Inspection Triggers Imminent danger violation out in the open and highly visible seen by concerned individuals or compliance officer. Fatalities/catastrophic accidents incident resulting in a fatality or hospitalization of three or more persons must be reported to OSHA within 8 hours. serious events will necessarily prompt an investigation. Special emphasis programs (SEP) OSHA’s regulatory agenda always includes areas of particular concern, such as exposure to lead and combustible dust.

6. Top 10 Most Frequently Cited StandardsOct. 1, 2010 to Sept. 30, 2011ALL INDUSTRIES • 29 CFR - Code of Federal Regulations • 1926.451 – Scaffolding • 1926.501 – Fall Protection • 1910.1200 – Hazard Communication • 1910.134 – Respiratory Protection • 1910.147 – Control of Hazardous Energy • Lockout/Tagout • 1910.305 – Electrical, Wiring Methods • 1910.178 – Powered Industrial Trucks • 1926.1053 – Ladders • 1910.303 – Electrical, General Requirements • 1910.212 – Machine Guarding

7. Top Ten - SIC Code 8062 - Hospitals October 2010 through September 2011

8. PART 1910 -- OCCUPATIONAL SAFETY AND HEALTH STANDARDS Subpart A -- General Subpart B -- Adoption and Extension of Established Federal Standards Subpart C -- [Removed and Reserved] Subpart D -- Walking - Working Surfaces Subpart E -- Exit Routes and Emergency Planning Appendix to Subpart E of Part 1910 -- Exit Routes, Emergency Action Plans, and Fire Prevention Plans Subpart F -- Powered Platforms, Manlifts, and Vehicle-Mounted Work Platforms Subpart G -- Occupational Health and Environmental Control Subpart H -- Hazardous Materials Subpart I -- Personal Protective Equipment Subpart J -- General Environmental Controls Subpart K -- Medical and First Aid Subpart L -- Fire Protection Subpart M -- Compressed Gas and Compressed Air Equipment Subpart N -- Materials Handling and Storage Subpart O -- Machinery and Machine Guarding Subpart P -- Hand and Portable Powered Tools and Other Hand-Held Equipment. Subpart Q -- Welding, Cutting, and Brazing. Subpart R -- Special Industries Subpart S – Electrical Subpart T -- Commercial Diving Operations Subparts U -- Y [Reserved] Subpart Z -- Toxic and Hazardous Substances

9. FACILITY ISSUES • Arc Flash - 1910.333 (NFPA 70E ) • Control of Hazardous Energy • LOTO 1910.147 • Personal Protective Equipment • PPE -1910.132 • Electrical Safety 1910.301-399 • (301-308, 333-335, 399)

10. FACILITY ISSUES - continued • Fall Protection 1910.23-28 • Shop Tools 1910 Subpart P • Machine /Equipment Guards • 1910 Subpart O • Hazard Communication Program • 1910 Subpart Z 1910.1200 • Confined Space 1910.146

11. OSHA TRAINING REQUIREMENTS Training is required for everything. best practice regular training maintain records tip for compliance weekly job box meetings

12. ARC FLASH POLICY OUTLINE

13. ARC FLASH POLICY OUTLINE

14. ARC FLASH POLICY OUTLINE

15. Typical LOTO PROCEDURE NOTE: Additional Procedures for each source: Electrical Water Steam Natural Gas Oil Blow Down

16. Typical LOTO PROCEDURE

17. PPE PERSONAL PROTECTIVE EQUIPMENt Assessment assess the hazard engineering control select the necessary PPE Universal Precautions Hearing Conservation 1910.95 Eye & Face Protection 1910.133 Respiratory Protection 1910.134 Fall Protection

18. PPE -hearing Conservation 1910.95(d)(1) When information indicates that any employee's exposure may equal or exceed an 8-hour time-weighted average of 85 decibels, the employer shall develop and implement a monitoring program.

19. PPE - EYE AND FACE PROTECTION 1910.133(a)(1) The employer shall ensure that each affected employee uses appropriate eye or face protection when exposed to eye or face hazards from flying particles, molten metal, liquid chemicals, acids or caustic liquids, chemical gases or vapors, or potentially injurious light radiation.

20. PPE –Respiratory protection 1910.134(a)(1) In the control of those occupational diseases caused by breathing air contaminated with harmful dusts, fogs, fumes, mists, gases, smokes, sprays, or vapors, the primary objective shall be to prevent atmospheric contamination. This shall be accomplished as far as feasible by accepted engineering control measures (for example, enclosure or confinement of the operation, general and local ventilation, and substitution of less toxic materials). When effective engineering controls are not feasible, or while they are being instituted, appropriate respirators shall be used pursuant to this section.

21. PPE –Respiratory protection Engineering Controls fume hoods equipment specific exhaust systems testing for effectiveness 1920.134(c) Respiratory Protection Program This paragraph requires the employer to develop and implement a written respiratory protection program with required worksite-specific procedures and elements for required respirator use. Fit testing and medical clearance required for some types of respirators

22. Electrical safety Typical OSHA questions: Is there a description of the circuit or equipment at the job location? Is there a detailed job description of planned work? Were the workers performing the tasks qualified to do so? Can you justify why equipment cannot be de-energized or the job deferred until the next scheduled outage? The message is clear: never work on live circuits unless it is absolutely necessary. OSHA allows work on live circuits in some cases, but the reason cannot be simply that turning off the power is inconvenient or will interrupt production. What about patient care? Could the patient be moved?

23. FALL Protection Guarding floor and wall openings and holes, 1910.23 Skylights Portable wood ladders, 1910.25 Portable metal ladders, 1910.26 Fixed ladders, 1910.27 Safety requirements for scaffolding, 1910.28 HVAC/Rooftop Equipment

24. FALL PROTECTION • OSHA Regulation 29 CFR 1910.23 • Guarding Floor and Wall Openings and Holes. • (a) (4) Every skylight, floor opening, • and hole shall be guarded by a standard • skylight screen or fixed standard railing • on all exposed sides. • OSHA Regulation 29 CFR 1926.501 Duty to Have Fall Protection • (a) (2) The employer shall determine if the walking/working surfaces on which the employees are to work have the strength and structural integrity to support employees safely. Employees shall be allowed to work on those surfaces only when the surfaces have the requisite strength and structural integrity.(b) (4) Holes (i) Each employee on walking/working surface shall be protected from falling through holes (including skylights) more than 6 feet above lower levels by personal fall arrest systems, covers, or guardrail systems erected around such holes. (ii) Each employee on walking/working surface shall be protected from tripping or stepping in the holes (including skylights) by covers.

25. FALL PROTECTION • Two Skylight Tragedies • End in Jail Sentences, • Apr 28, 2009

26. OSHA requires installation of safety guard rails for the edge of any rooftop within 15 feet of rooftop HVAC equipment. FALL PROTECTION Horizontal Lifeline System

27. FALL PROTECTIONLadder Safety

28. SHOP Tool Safety Grinders Table Saws Shop Air, regulated to < 30 psig Welding Fastner guns, Nail Guns Don’t forget hand tools Enforce wearing of appropriate PPE gloves, safety glasses, dust masks, hearing protection, etc Enforce the use and maintenance of equipment guards Training

29. SHOP tool safety Also see SawStop

30. Machine/Equipment Guards YES NO

31. Hazard Communication Written Program Inventory MSDS Right to Know Spill Response PPE Training

32. CONfined Space "Permit-required confined space (permit space)" means a confined space that has one or more of the following characteristics: (1) Contains or has a potential to contain a hazardous atmosphere; (2) Contains a material that has the potential for engulfing an entrant;(3) 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; or (4) Contains any other recognized serious safety or health hazard.

33. SPOT THE PROBLEMEXCERCISE

43. SIGN: FIRE PUMP

45. RESOURCES OSHA http://www.osha.gov/ The National Institute for Occupational Safety and Health (NIOSH) http://www.cdc.gov/niosh/ State OSHA Departments

46. QUESTIONS

47. THANK YOU Special thanks to Fred Leffingwell, Assistant Director, Plant Engineering Waterbury Hospital and Peter Leszczak, PSL Engineering for their contributions to this presentation. Steven Jalowiec, PE, CHFM stevej06418@yaoo.com 203-228-3480