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OSHA

Mod 1.

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Fatality/Catastrophe Reporting
Only fatalities that appear to be work related.
Covers many fields, incl. religious workers for secular purposes.
Can't propose fines for federal agencies.
Excludes miners, some truckers, atomic energy workers.
Regulations, inspections, reports, materials.
Approves state job safety plans; some plans cover limited pools of employees (state employees only in CT and NY)
Notice of rights/duties must be posted in workplace.
Right to safe workplace, raise concerns, be informed of hazards, seek OSHA inspection, participate in inspection; file complaint, see citations, get copies of records.
Employer obligations to provide safe workplace, notify OSHA of workplace death within 8 hours or work-related hospitalization, display poster, post citations near alleged violation
Safe workplace
Hazards removed
Workers trained
Protection provided
Exit routes, evacuation plans, noise level controls and hearing tests
Bloodborne pathogens
Hazardous chemicals
Containers must be labeled, data sheets available, list hazardous chemicals in area, inform other employers (e.g. contractors)
GHS (Globally Harmonized System of labelling chemicals)
Includes symbols and pictograms indicating hazards

SDS (safety data sheet)

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Product identifier on label
Other ID
Recommended use
Manufacturer contact info
4 First aid measures, grouped by route of exposure
5 Firefighting measures
6 Accidental release methods
7 Handling and storage
8 Permissible exposure limits, engineering controls
9 Physical/chemical properties
10 Stability/reactivity, conditions to avoid, incompatible materials
11 Toxicological information; symptoms from exposure (long and short term)
12 Ecological info (non-mandatory)
13 Disposal considerations (non-mandatory)
14 Transport info (non-mandatory)
15 Regulatory info (non-mandatory)
16 Other information, should include date of preparation

ANSI SDS (Z400.1)

Manufacturer must provide to customers.

Rights

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Right to Info
Employers with more than 10 workers must keep a log of injuries/illnesses
Must indicate lost workdays, restricted work/transfers, incident requiring more than first aid treatment
Employees may review current log, logs for past 5 years, annual summary
Right to complain
29 CR 1977.9(c): employees can complain without retaliation; 11(c) of OSH Act also prohibits retaliation.
Right to training relevant to workplace
Right to exposure/medical records
Employers must measure exposure levels, employees can observe
Right to refuse unsafe work
30 days to report retaliation
Worker responsibilities
Employees must follow safety/health rules, wear protective gear
Recordkeeping
Part 1904 form requirements
OSHA 300 Log (work-related injuries/illnesses)
OSHA Form 301 (specific injury/illness report); can subst. Worker's Comp. form.
OSHA Form 300A - summary of events for the year; must be posted.
Log must note name (or [Privacy case]); job title, place injury occurred; specific kind of injury.
Log needs to identify business, city, state, log year.
Nondiscrimination against workers who exercise rights
Firing, laying off, demoting
Must report discrimination within 30 days
Others
Post citations
Provide/pay for PPE
Maintain PPE quality
Employees should take care of their PPE
Employee who loses/intentionally damages PPE may be required to replace it.

Responsibilities

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Employers must maintain a safe working environment.
Conditions/practices to protect workers.
Know and comply with standards; ensure workers have appropriate PPE.
General Duty Clause
General training requirement
Safety/health aspects of job.
Use of chemicals that will be used on the job.
Electric/Hazardous materials each require their own training; HazMat = 24 hour initial training, 8 hour annual refresher.
New training whenever a new hazard is introduced.
PPE
Determine if needed, if so what kind.
Train employees who must use PPE (1910.132(f)).
Recordkeeping
Reporting system must be established
Provide logs on request, post annual summary, report fatality within 8 hrs, hospitalization within 24 hrs.
Low-hazard industries (e.g., an accountant's office) are exempt from recordkeeping, but must still report.
Part 1904 form requirements
OSHA 300 Log (work-related injuries/illnesses)
OSHA Form 301 (specific injury/illness report); can subst. Worker's Comp. form.
OSHA Form 300A - summary of events for the year; must be posted.
Log must note name (or [Privacy case]); job title, place injury occurred; specific kind of injury.
Log needs to identify business, city, state, log year.

OSHA Standards

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Four categories:

  • General industry
  • Construction
  • Maritime
  • Agriculture

Standards for specific hazards (infectious diseases; toxic substances; electrical, fall, machine, fire, explosion, atmosphere)

Everything else falls under OSHA 5(a)(1), the General Duty Clause.

OSHA standards are in Title 29.

Inspections

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Priorities
1. Immanent danger - reasonable certainty danger exists; inspection within one day
2. Fatality/Catastrophe - inspection following an incident
3. Complaints/Referrals - complaint is from worker/rep; referral is from agency
Follow-ups/monitoring following previous issues
4. Programmed
Stages
Presenting credentials
Employer can require OSHA to get a warrant
Opening conference
Separate conferences if employee/rep objects
Why is OSHA inspecting? What are they looking for? Get info on company. Is the company exempt from inspection?
Checks records
Workers may designate a rep (or may already have one)
If no worker rep, reasonable number of workers must be questioned
Walkaround
Review the site, check for noise levels, etc.
Interview workers in private (or with a union rep)
Closing conference
Again can be separate if workers object (in which case worker conference will be first)
Observations will be discussed
Citations/penalties
After inspecting worksite, inspector will write a report proposing citations/penalties
Penalty types
Willful (intentionally and knowingly, or wanton indifference), up to 75,000 penalty
Serious violation - up to $7,000 per violation
Other-than serious violation - relationship to safety, but not immediate threat of harm
Repeat violations
Failure to abate, 7k
Falsifying info, fine of up to 10k or 6 months in jail
Posting violations
Appeals
Workers may disagree with/appeal citation
May request informal conference
Can contest abatement time (with evidence), but can not contest citations/penalties
Employer can contest abatement date if abatement can not be done in time allotted.

Sources for help

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Regulations (Standards - 29 CFR)
Regulations (Standards - 29 CFR) 1910
Safety Administration Pre & Post Test
  • Supervisors, coworkers, worker reps
  • Labels and warning signs
    • Label on a hazardous piece of machinery is not enough if the machine can be better secured
    • Signs must be bilingual if other-language speakers on site
    • Employee orientation manuals and training materials
    • Written job/task instructions for specific machinery procedures
  • OSHA website
    • Factsheets
    • QuickCards (small laminated cards)
    • Publications link on home page, with, e.g. factsheets
  • NIOSH website (National Institute for Occupational Safety and Health)
    • OSHA sister agency
    • Health Hazard Evaluations, if workers get sick from unknown or unregulated cause; worker with signatures of two other workers can request inspection
  • OTIEC (OSHA Training Institute Education Centers)
  • COSH (National Council for Occupational Safety and Health) groups

Options to file OSHA complaint

  • Form on website, mail, fax, or online
  • Phone or visit local regional or area office
  • OSHA must have reasonable grounds to act
  • Basic questions:
    • Worker/coworkers have injuries/health complaints?
    • Who has them, when did they arise, where in the workplace, what is causing them?
    • Description of hazardous conditions is most important
    • [Do not reveal my name] box

Walking and working surfaces

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15% of all accidental deaths are due to trips, slips, and falls.

  • Wet spots/spills
  • Floor openings/holes
  • Ladders (must be securely held open)
  • Obstructions

Surface = "Any surface on which an employee walks or works in order to perform their duties".

Hazard = "A situation in the workplace where accidents or injuries such as slips, trips, or falls may occur".

  • Highly polished surfaces
  • Transitions
  • Wet/greasy spots
  • Uneven/damaged floors
  • Holes
  • Obstructions

Slips = insufficient friction/traction

Spills on surface
Changes in traction
Loose coverings

Trips = foot strikes unexpected object

Clutter
Uneven surfaces
Unfamiliar paths
Obstructed views

Falls = loss of center of balance

Same level
Lower level

Injuries commonly include sprains, strains, bruises/contusions/abrasions, fractures, often to extremities, joints, hips, back, and head

Prevention:

Clear out obstructions
Clean spills
Fix broken lights
Be alert
PPE

Contributing factors include age, fatigue, inattentiveness (cell phone), poor eyesight, and improper footwear

NIOSH top ten hazards

  1. • Contaminants on the Floor
  2. • Indoor Walking Surface Irregularities
  3. • Outdoor Walking Surface Irregularities
  4. • Weather Conditions: Rain, Ice and Snow
  5. • Inadequate Lighting
  6. • Stairs and Handrails
  7. • Stepstools and Ladders
  8. • Tripping Hazards: Clutter, Loose Cords, etc.
  9. • Improper Use of Floor Mats and Runners
  10. • Poor Drainage: Pipes and Drains

So, clean up spills/clutter, use floor mats properly, make sure drainage is aligned to prevent spills. Proper footwear.

Employer responsibilities
Written housekeeping program
Clean, dry floors
Warning signs
Inspect frequently
Ice/snow removal plans
Mats/footwear where appropriate
Weather alerts
Adequate lighting
Stairs/handrails
Visual cues of elevation; slip-resistant treads; clean, free of snow
Handrails where less than four steps, 34-38", 12" beyond step, on both sides
Training
Appropriate footwear, level surfaces, ensure ladder is fully open, three points of contact
Right equipment to bundle cords
Guard floor openings, wall openings over 4 feet high
Insure integrity of scaffolding, keep workers off during ice/snow

Exit Routes, Emergency Action Plans, Fire Prevention

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Definitions
Major types
Self-protection
Employer obligations

Exit route:

Must be unobstructed
Doors must be unlocked
Fire extinguished is only for small fires
Exit must have clearly visible sign

Exit route= "continuous, unobstructed path from a point in a building to a point of safety"

Typically 2 per workplace; can vary by size of building, number of employees, floorplan
Hazards
  1. Not clearly marked
  2. Locked, barricaded, or blocked door
  3. Exits only on one side of building
  4. Not enough (insufficient routes for number of people)
  5. Doors not side hinged
  6. Doors must be 7.5" tall, 28" wide
  7. Absence of fire-resistant materials along the way
  8. Lockable doors
  9. Discharge does not lead directly outside
  10. Not permanent
Three parts:
Access
Exit - portion that leads out of the building
Discharge

Fire hazard = "anything that could easily catch fire or start a fire"

Employers must train about safety, hazards, what to do
Employees must observe fire safety requirements
Exit routes
Lack of an alarm
Exit routes that go through hazardous areas
Temporary routes
Blockages (either permanent or temporary)
Locked doors; doors must always be able to open from inside.
Must be easy to identify, well it, permanent
have an "EXIT" sign
at least six inches high
brightly colored
reliably lit
Must be enough exit routes; up to employer to determine
"must support the maximum permitted occupant load for each floor served"
Can have only one if that one will always allow everyone to evacuate safely
Keep explosive and highly flammable materials away from exit
Fire resistant materials
Up to three floors = 1-hour fire-resistance rating
More than three floors = 2-hour fire-resistance rating
Flammable/Combustible Materials
Workplaces storing such materials must have adequate fire control
At least one fire extinguisher outside the door where stored
For storage of category 1, 2, or 3 liquids, fire extinguished 10-25 feet from area
Must be a way to dispose of leakage quickly
Exit route must not require people to walk towards combustible or poisonous materials
Store hazardous materials away from ignition sources/hot surfaces/sparks
Electricity is a fire hazard
Damaged/worn cords
Faulty wiring
Poorly grounded
Use ground fault interrupters
Exposed receptacle boxes are non-conductive
Plugs and receptacles prevent energization until insertion complete
Label fuse boxes
Train workers on these
Employees must follow instructions, keep enough space around them, ground anything used near water
Take damaged receptacles and equipment out of service
Dry hands before working with electronics
Self-protection from exit route/fire hazards
Know the emergency action plan
Recognize and report issues (know who to report to)
Recognize emergency quickly and respond quickly; employees with duties should be ready to perform them
Employee should know
responsibilities
what to do if you see something
how to evacuate
is path unobstructed
who to communicate with
proper precautions around flammable materials
how to use a fire extinguisher
Emergency Action Plan
In writing, kept in workplace, available for employees to review (if fewer than 10 employees can be oral)
contains procedures, map of escape route, actions to be taken
covers fires, explosion, toxic chemicals, hurricane, tornado, blizzard, flood
Employee action
Take immediate action
Call 9-1-1, internal emergency number, fire alarm, alert other employees
Some employees are only responsible for evacuating the building
Others have specific responsibilities
Calling 9-1-1
Notification/evacuation/assisting the disabled
Rescue/medical duties; shut off machinery; counting heads
Know the map, should be posted in the workplace
Conditions, chain of command, specific procedures, incl. for disabled, non-English speakers
Emergency response coordinator (and backup) should be designated
Directs emergency activities
Order evac, contact emergency services
Point of contact for info
Designates head-counter
OSHA standards
Med assist for injuries
Designated person to communicate with emergency services
Communicate with employees after emergency is over
Alternately let employees know where to go
Flammable liquids
Label "Flammable – Keep Fire Away"
No more than 25 gallons in a building unless in safety cabinets
Transfer requires proper device (closed piping, safety cans, device drawing through top; approved self-closing valve)
Fire Detection System
Correctly installed
Routine testing/maintenance/cleaning
On at all times
Able to alert everyone to be alerted
Supervised system
Repaired or replaced by someone qualified
Fire extinguishers
For small fires/temp control
Must be mounted in identified and accessible locations
Within 75 feet of employees
Maintained, fully charged, working right
Where they are supposed to be unless in use
Employees trained in their use
Type must be approved by a testing lab
Employer responsibilities
Effective emergency action plan (in writing if more than 10 employees)
Emergency prep
Employers can be held responsible for worker deaths due to failure to meet standards
Exit routes must be protected by self-closing fire doors
Emergency Action Plan
(c) Minimum elements of an emergency action plan. An emergency action plan must include at a minimum:
(1) Procedures for reporting a fire or other emergency;
(2) Procedures for emergency evacuation, including type of evacuation and exit route assignments;
(3) Procedures to be followed by employees who remain to operate critical plant operations before they evacuate;
(4) Procedures to account for all employees after evacuation;
(5) Procedures to be followed by employees performing rescue or medical duties; and
(6) The name or job title of every employee who may be contacted by employees who need more information about the plan or an explanation of their duties under the plan.
Fire Prevention Plan
1910.39(c) Minimum elements of a fire prevention plan. A fire prevention plan must include:
(1) A list of all major fire hazards, proper handling and storage procedures for hazardous materials, potential ignition sources and their control, and the type of fire protection equipment necessary to control each major hazard;
(2) Procedures to control accumulations of flammable and combustible waste materials;
(3) Procedures for regular maintenance of safeguards installed on heat-producing equipment to prevent the accidental ignition of combustible materials;
(4) The name or job title of employees responsible for maintaining equipment to prevent or control sources of ignition or fires; and
(5) The name or job title of employees responsible for the control of fuel source hazards.

Electrical hazards

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Outlets
Lamps (leave dead bulb in until replaced)
Power cord
Water (carries electrical currents)
Identify by type, learn to avoid, know employer obligations
Dangers = burns, electrocution, shock, arc flash/blast, fire, explosion

Most common injury = burns; three types

Electrical, from flow of current
Arc/flash, from arc or explosion
Thermal contact with hot equipment

Electrocution = death (4k injuries per year, 7% of occupational fatalities, 4th leading cause)

Shut off power, make sure lines are not live
Release stored energy; follow "lock-out/tag-out procedures"
Prep shutdown
Shutdown
Isolate
Locks and tags
Control
Verify
OSHA adopted National Fire Protection Assoc. standards for electricity for all post 3/15/72 equipment

Shock = body becomes part of the circuit

Arc flash = release of electrical energy in the air

Fire = mostly faulty outlets/wiring

Power lines
10 feet plus 4 inches per 10k volts over 50k
All equipment operating at over 50 volts must be guarded
Covers, dead fronts

Strength of current = volts/resistance, which yields milliamps (used to gauge danger/damage)

  • e.g., 120 milliamps causes extreme pain, possibly death
Protecting yourself
Safe distance from power lines
Ground-fault circuit interrupter
Receptacle fits in the outlet
Portable built into extension cord
Circuit breaker, on main circuit board (test monthly)
GFCI testing - after installation, once per month, after power outage, and per mfg/employer instructions
Must be used for any 120V, single phase, 15- and 20+ambere temp outlets used in construction
Inspect tools/cords
Appropriate used of energized tools/equipment
Proper guarding
Lock-out/tag-out
  • WAC 296-307-36815(2): All pull boxes, junction boxes, and fittings must have covers approved for the purpose. All metal covers must be grounded. In completed installations each outlet box must have a cover, faceplate, or fixture canopy. A cover of an outlet box with holes through which a flexible cord pendant passes must have bushings designed for the purpose or have a smooth, well-rounded surface for the cord to run on.
  • AEGCP (assured equipment-grounding conductor program) = written procedure requiring periodic testing of all equipment-grounding conductors of cords/plugs used by employees. Test records must be maintained and a competent person designated to enforce.
  • Qualified Persons shall at a minimum be trained and familiar with the following:
1. Skills and knowledge necessary to distinguish exposed live parts from other parts of electric equipment;
2. Skills and techniques necessary to determine nominal voltage of exposed parts; and,
3. The clearance distances specified in 1910.333(C) and the corresponding voltages to which the qualified person will be exposed.
First Aid training for a sufficient number of employees to deal with potential emergencies

HazMat

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Hazard Communication = identifying hazardous chemicals in the workplace

OSHA HCS
Manufacturers/importers are required to evaluate products and document hazards

Bloodborne pathogens

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Risks

Improper disposal of regulated waste
Contact with blood or bodily fluids
Gloves should be worn
Never wash/decontaminate/reuse disposable gloves
Contaminated garments should be removed in a way that voids contact

What are bloodborne pathogens

Pathogenic microorganisms that are present in human blood
Hep A (1.8%)
Hep B (6-30% risk from needlestick/cut)
HIV (0.3%; 0.1 from exposure to eye/nose/mouth)
No case of HIV from blood on intact skin

Case study:

Absence of training
lack of specific procedures
failure to update program with changing tech
failure to train workers exposed to Traysol (stabalizing chemical for shipping blood samples)
Hep B
Hep B virus (HBV)
Acute or chronic illness
Infants = 90% chance of infection (adults only 2-6%)
Can lead to cirrhosis or liver cancer
Hep C
Hep C virus (HCV)
Chronic for 70-85% of infected
Long term health problems/death
No vaccine
HIV
AIDS; affects immune system, makes sufferer vulnerable to infection/illness
No vaccine, no cure
Vulnerable workers include healthcare, housekeeping

Occupational exposure = "Reasonably anticipated skin, eye, mucous membrane"

Universal precautions
Treat all blood/potentially infectious material as if protected
Always wear PPE
Engineering controls
Limit employee exposure
Disposable containers for sharps
Self-resheathing
Safety features
Work practice controls
Facilities to wash hands immediately
Wash hands after removing gloves
Dispose of used instruments in puncture-resistant leak-proof containers
PPE
Gloves, gowns, lab coats, eye protection, face masks/shields
Exposure incident
Wash (soap and water)
Irrigate eyes (water/saline)
Flush splashes to noes/mouth/skin
Report
Get treatment
Employer responsibilities
Vaccine, records, training
Hep B vaccination
Three doses over six month period, given by licensed professional/lab, made available w/in 10 days of assignment
Not needed for employees who already have antibodies/have contraindication
Employees who decline must sign declination form; must still be able to get vaccine if they change their mind
Records must be kept separate from other employee records
Name/SS#
Vaccination status
Results of exams/testing/follow-up
Healthcare professional opinion
Records must be kept for 30 years after employment ends
Exposure incident report
As early as possible; employer must evaluate circumstances
Sharps injury log to evaluate devices being used; must be evaluated annually
Kept for five years, no employee names
Training, at time of assignment, annually, and when changes occur
Training records must be kept for three years
Controls
Engineering controls - must be evaluated annually
Work practice controls - way tasks are performed
Exposure control plan
Identify jobs/tasks
Outline protection used
Procedure to evaluate exposure
Note how employer will provide Hep B vaccinations