Transcript Kelly Bubolz, OSHA

OSI
OSHA Update
Changes and Compliance
for FY 2014
Kelly Bubolz
Appleton, Area OSHA Office
April 17, 2014
Topics
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What’s up in Washington
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Recent News
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We’re working!!!
Hazard Communication
Initiatives and Emphasis for FY14
Inspections
Resources
Robert Bonack
The NEW
Appleton OSHA
Area Director
New Area Office Team Leaders
Charles Shelton
Dave Schott
From Washington
Regulatory Agenda
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Injury and Illness Prevention Program
Confined Spaces in Construction
Silica
PELs (Permissible Exposure Limits)
Recent News
HazCom 2012
On March 26, 2012 OSHA
adopted a large portion of
GHS, the Globally Harmonized
System of Classification and
Labeling of Chemicals.
December 1, 2013 Intro Completed
GHS Notable Changes
Primary Changes in HazCom
1. Container Labeling
2. Material Safety Data Sheets
3. Employee Training
Written Program
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OSHA did not modify the written hazard
communication requirements except for
minor terminology edits.
Labels
Product identifier
 Signal words
 Hazard
statements
 Pictograms
 Precautionary
statements
 Name, address,
and telephone
number of the
chemical
manufacturer,
importer, or
other responsible
party
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Pictograms
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Red borders required
No blank pictograms
Safety Data Sheets
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16-section safety data sheet (SDS)
Several sections will not be mandatory since
they address information outside OSHA’s
jurisdiction (Sections 12-15)
A new Appendix D, Safety Data Sheets,
provides the details of what is to be included in
each section
Safety Data Sheet Format
1. Identification of the substance or mixture and of the supplier
2. Hazards identification
3. Composition/information on ingredients
4. First-aid measures
5. Fire-fighting measures
6. Accidental release measures
7. Handling and storage
8. Exposure controls/personal protection.
9. Physical and chemical properties
10. Stability and reactivity
11. Toxicological information
12.
13.
14.
15.
Ecological information (non-mandatory)
Disposal considerations (non-mandatory)
Transport information (non-mandatory)
Regulatory information (non-mandatory)
16. Other information, including date of preparation or last
revision
Safety
Data
Sheet
Example
GHS Implementation Dates
Silica Standard
Proposed
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OSHA's Notice of
Proposed Rulemaking
(NPRM) for
Occupational Exposure
to Respirable Crystalline
Silica was published in
the Federal Register on
September 12, 2013.
Crane Standard
Digger Derrick
Exemption Expanded
 Setting Pad Transformers
is exempted
 Telecommunication work
exempted
Proposed Certification
Extension: May 22,2013
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WASHINGTON – The
Occupational Safety and
Health Administration has
announced that it will propose
to extend the compliance date
for the crane operator
certification requirement by
three years to Nov. 10, 2017.
The proposal would also
extend to the same date the
existing phase-in requirement
that employers ensure that
their operators are qualified to
operate the equipment.
Emphasis Programs in WI
General Industry for FY 2014
• Amputations
• Nursing Homes
• Shipbreaking
• Lead
• Flavorings
• Silica
• Primary Metals
• Dairy Farms
• Falls: GI & Con
• Grain Handling
• Hex Chrome
• Combustible Dust
• Powered Industrial Vehicles (PIVs)*
• Site Specific Targeting (SST)
• Chemical Plants/Process Safety
• Federal Agencies High Rate of Lost Time Injuries
• Isocyanates
* Complaint Based or Observed During an Inspection
Emphasis Programs in WI
Construction for FY 2014
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Lead
Silica
Falls
Trenching/Excavation
Hex Chrome
Isocyanate
Powered Industrial Vehicles (PIVs)*
* Complaint Based or Observed During an Inspection
2014 Initiatives
Heat Campaign
Falls in Construction
 Plan ahead before
starting each and every
job.
 Provide the right
equipment.
 Train workers to
properly use equipment
when on roofs, ladders,
and scaffolds.
 Drink water often, take
breaks, and limit time in
the heat to help
prevent heat illness.
 Educate workers on
Heat Stress.
 Acclimate workers to
work in hot conditions.
Incentive Programs:
Performance Metrics
Attitudes
(set up conditions,
behavior)
- Perception
surveys
Program
Elements
- Training
- Accountability
- Communications
- Planning &
Evaluation
- Roles &
Procedures
- Incident
Investigations
Leading Trailing
Metrics Metrics
Physical
conditions
-Inspections
-Audits
_Risk
assessments
-Prevention &
control
Behavior
(action)
-Observations
-Feedback
loops
ORC Worldwide Metrics Taskforce
Incident
or Near
Miss
- OSHA
Recordables
- Lost
Workdays
- Restricted
Workdays
Temporary and
Vulnerable Workers
“The Expendables”
Staffing Agencies +
Youth
Older Worker
Foreign Born
Distracted Driving
Most Frequently Cited Standards
Top 10 For 2013
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#1 Fall Protection; 8,241
#2 Hazard communication: 6,156 (refers
mainly to labeling hazard chemicals);
#3 Scaffolding: 5,423;
#4 Respiratory protection: 3,879;
#5 Electrical, wiring methods: 3,452;
Most Frequently Cited Standards
Top 10 For 2013
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#6 Powered industrial trucks: 3,340;
#7 Ladders: 3,311;
#8 Lockout/tagout: 3,254 (refers to
protecting employees from hazardous
energy sources on machines and
equipment);
#9 Electrical, general requirement: 2,745;
#10 Machine guarding: 2,701
Inspection Process
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Every establishment
covered by the OSH
Act is subject to
inspection by OSHA
Compliance Safety and
Health Officers
(CSHO's)
Most inspections are
conducted without
advance notice
Inspection Process
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CSHO displays
official credentials
Opening
conference
Walkaround
inspection
Closing conference
Conducting the Walkaround
Inspection
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CSHO and accompanying representatives
(employer and employee) inspect the
establishment for potentially hazardous
working conditions
CSHO discusses possible corrective
actions with the employer
CSHO may consult, at times privately,
with employees
Closing Conference
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Held with management (and employee
representative) after the inspection.
CSHO will discuss apparent violations and
ways to abate them.
Set abatement dates.
Review the Employer’s Rights and
Responsibilities after an inspection.
Will not discuss amount of penalties.
What happens after an
OSHA Inspection?
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OSHA may or may not issue citations
Citations inform employer and employees of
the regulations and standards allegedly
violated and of the proposed time for
abatement
Employer must post a copy of each citation at
or near place where violation occurred, for 3
days or until violation is corrected, whichever
is longer
OSHA Inspection Priorities
Priority
1st
Category of Inspection
Imminent Danger:
Reasonable certainty an immediate danger exists
2nd
Fatality/Catastrophe:
Reported to OSHA; inspected ASAP
3rd
Complaints/Referrals:
Worker or worker representative can file a complaint
about a safety or health hazard
4th
Programmed Inspections:
Cover industries and employers with high injury and
illness rates, specific hazards, or other exposures.
Citations and Penalties
VIOLATION TYPE
PENALTY
WILLFUL
A violation that the employer intentionally and knowingly
commits or a violation that the employer commits with plain
indifference to the law.
OSHA may propose penalties of up to
$70,000 for each willful violation, with
a minimum penalty of $5,000 for each
willful violation.
SERIOUS
A violation where there is substantial probability that death
or serious physical harm could result and that the employer
knew, or should have known, of the hazard.
There is a mandatory penalty for
serious violations which may be up to
$7,000.
OTHER-THAN-SERIOUS
A violation that has a direct relationship to safety and health,
but probably would not cause death or serious physical
harm.
OSHA may propose a penalty of up to
$7,000 for each other-than-serious
violation.
REPEATED
A violation that is the same or similar to a previous violation.
OSHA may propose penalties of up to
$70,000 for each repeated violation.
Eau
Claire
Madison
Appleton
Milwaukee
Wisconsin Compliance Assistance Specialists
Kelly Bubolz
U. S. Dept. of Labor - OSHA
1648 Tri Park Way
Appleton, WI 54914
(920) 734-4521
Leslie Ptak
U. S. Dept. of Labor - OSHA
4802 E. Broadway
Madison, WI 53716
(608) 441-5388
Mary Bauer
U. S. Dept. Of Labor - OSHA
1310 W. Clairemont Ave
Eau Claire, WI 54701
(715) 832-9019
Jim Lutz
U. S. Dept. of Labor - OSHA
310 W. Wisconsin Ave
Milwaukee, WI 53203
(414) 297-3315
Sources of Help
OSHA CONSULTATION SERVICE
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Through the free consultation service,
employers can:
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Find out about potential hazards at their
worksites,
Improve their occupational safety and health
management systems, and
Perhaps qualify for a one-year exemption
from routine OSHA inspection.
The service is delivered by state governments
using well-trained professional staff.
Primarily targeted for smaller businesses, this
safety and health consultation program is
completely separate from the OSHA inspection
effort.
No citations are issued or penalties proposed.
800-947-0553
Wisconsin OSHA
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Questions