Transcript OSHA Regulations often applied to commercial office & schools

OSHA
Regulations often applied to
commercial office & schools
Rob Rottersman, MS, CIH
847.685.9266
[email protected]
Illinois
Non-Public Buildings/Employees
• OSHA has jurisdiction
Public Buildings (including municipal and schools)
• Illinois Department of Labor (IDOL) has
jurisdiction
• IDOL has adopted OSHA standards
Most Frequent Citations (National)
October 2004 – September 2005
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2.
3.
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5.
Scaffolding (9,558)
Hazard Communication (7,564)
Fall Protection (6,483)
Respiratory Protection
Hazardous Energy/Lockout Tagout (2,281)
Total Citations (1 year) = 113,362
$103,923,102 in fines
Scaffolding
OSHA 29CFR1910.27 Subpart D
“Walking – Working Surfaces”
Defined – “Any temporary elevated platform and its
supporting structure used for supporting
workmen or materials or both”
Regulations depend on scaffold type
Powered Platforms & Manlifts
OSHA CFR1910.66
Specific for Building Maintenance
• Regulations specific for type of lift
• Includes standards for harnesses, use,
inspection & training
• Protection from falling objects
Hazard Communication
OSHA 29CFR 1910.1200
http://www.osha.gov/pls/oshaweb/owadisp.show_docume
nt?p_id=10099&p_table=STANDARDS
Or Google Search “OSHA 1910.1200”
• Who has a hazard communication program?
• Is it compliant with the standard?
Purpose
PURPOSE – Why do we need all this?
• Ensure chemical hazards are evaluated
• Information passed on to employee
– Allow for safe use and handling
• Emergency response (spills/exposure)
Key Elements
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Written Program
Material Safety Data Sheets (MSDS)
Chemical Inventory
Training
Labeling
Written Program
How the School will Meet Requirements:
1. Labeling/warning information
2. MSDS
3. Employee Information and Training
4. List of Hazardous Chemicals
5. Hazards of “non-routine” tasks
6. Outside contractor/visitor communication
*Program must be available upon request
Labeling
Container Labels Must Contain:
• Identity of hazardous chemicals
• Appropriate hazard warnings
• Name & address of manufacturer
Manufacturers label should be sufficient
When do you need to label?
• Chemical transferred to other container and NOT
used by 1 employee on 1 shift
– Spray bottles are often overlooked
– Science and art rooms often forgotten
• Manufacturer’s labels is worn/illegible
• Label is not in English
Labeling Exemptions
•
Articles = Not gas, liquid or particle item with
“end use function” (i.e. solid parts)
Materials regulated by other agencies
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Pesticides (but label required by EPA)
Food, Drugs, Cosmetics
Alcohol
Agricultural or vegetable seeds
Wood or wood products
Biological hazards
Radiation
Material Safety Data Sheets
(MSDS)
Must have a MSDS for every “hazardous”
chemical in the school
OSHA Hazardous – “Any chemical which is a
physical or health hazard”
“All substances are poisons; there is none that it is not
a poison. The right dose differentiates a poison from
a remedy”
Paracelsus 1493-1541
MSDS Contents
i. Name – Product Identity
ii. Physical & chemical characteristics
iii. Physical hazards
iv. Health hazards
v. Routes of entry
vi. Whether or not it can cause cancer
vii. Precautions for safe handling
viii.Control measures (ventilation, PPE, etc)
ix. Emergency & first aid
x. Date of MSDS preparation and revision
xi. Contact info. for manufacturer
Exposure Standards – Alphabet
Soup
• Permissible Exposure Limits (PEL)
– OSHA Standard – enforceable
– Subject to industry lobbying
• Recommended Exposure Limit (REL)
– National Institute of Occupational Safety and Health
(NIOSH)
– Research based – not enforceable
• Threshold Limit Value (TLV)
– American Conference of Govt. Industrial Hygienists
(ACGIH)
– Recommended but not enforceable
Health Considerations
• Review significant routes of entry
– Skin contact, inhalation, ingestions
• Chronic vs. Acute
– Chronic – delayed response
• i.e. cancer, cirrhosis
– Acute – effect short time after exposure
• Irritation, headaches, dizziness, allergic
MSDS Maintenance
• Obtain from chemical
manufacturer
• MSDS must be readily &
immediately accessible to
employees
• Electronic files are permitted if
employees have access
– Keep current – periodic review
for updates
MSDS Recommendations
• Establish & maintain a new product
introduction program
– Have 1 person designated to approve all
new products brought onto school
grounds
– Approval requires submitting MSDS sheet,
review for hazards & training if needed
Chemical Inventory List
• List of all
“hazardous”
chemicals found in
the facility
• Must include the
name used on the
MSDS sheet
• Consider using as
an MSDS index
Training
• All employees who use or could come
in contact with “hazardous” chemicals
must be trained
– At the time of hiring
– Before beginning a new assignment/job
change
– Whenever there is a new hazard that was
not included in previous training
– Whenever new hazards are discovered for
an existing product
Non-routine Tasks
• Often overlooked
– could be significant health and safety
hazards
• Examples in schools could include
– Cleaning, using chemicals in confined space such
as crawlspaces
– Handling cooling tower treatment chemicals
– Chemicals to remove graffiti
– Inventory old chemicals from science & art rooms
Outside Contractors/Vendors
• Must inform of hazards associated with
products they use or may come in
contact with
• Notify them of written program and
location of MSDS sheets
• Provide training as needed
Chemicals Used by Vendors at
Your School
Janitorial cleaning crews, contractors,
pesticide applicators, etc.
• Make sure they have provided you with MSDS sheets
• Review to ensure they are complete & up to date
• KNOW THE LOCATION of their MSDS sheets AND
inform your employees
Fall Protection
Multiple references in the standard
OSHA CFR1910.21-1910.27 Appendix D
• Guards and rails
– Floor openings, uneven floor surfaces, etc.
• Ladders & Stairs
– Wood vs. metal & fixed vs. permanent
Respiratory Protection
OSHA CFR1910.134, .139
Respirators as a “last resort” for reducing
chemical exposures to safe levels.
Better Options:
- Eliminate hazard (product substitution)
- Engineering controls (ventilation)
Respirator Programs
If employees use respirators an OSHA
respirator program must be in place
• Appropriate Respirator Selection
• Annual Training
• Annual Fit Testing
• Medical Evaluations
• Exposure Assessments
Dust Mask Exemption
OSHA CFR1910.134(c)(2)(i)(ii)
Dust Mask (filtering face piece) may be worn if:
• Use is voluntary (not required by employer)
• The respirator itself will not create a hazard
• Employer provides employee with information
contained in OSHA Appendix D
– “Information for Employees Using Respirators When
Not Required Under the Standard”
Respirator Selection
Safety Shoes
29CFR1910.136
• Required when danger of injury from
falling or rolling objects, objects may
pierce the sole or feet are exposed to
electrical hazard
Eye Protection
29CFR1910.133
Eye & face protection shall be worn when
exposed to eye or face hazards from flying
particles, molten metal, liquid chemicals,
acids or caustics, chemical gases or
vapors or injurious light radiation
LockOut/TagOut
(Control of Hazardous Energy)
OSHA 29CFR1910.147
“Covers the servicing and maintenance of
machines and equipment in which the
unexpected start up or release of stored
energy could cause injury to employees”
LO/TO Requirements
Written Program/Policy
Define “Authorized” employees
• Understand the machines & energy
• Trained in LO/TO
• Authorized to install & remove locks/tags
Define Effected Employees
• Employees who may operate locked or tagged
out equpment
Actions Requiring LO/TO
• Removing or bypassing a safety device
• Any part of the body is placed in harm’s way
• Exposure to hazardous energy
OSHA Record Keeping
29CFR1904
AKA: 300 Log
Includes:
• Determining if injuries are “recordable”
• Logging injuries (300 Form)
• Investigate cause (301 Form)
• Post summary - Feb-April (300-A Form)
Blood Borne Pathogens
29CFR1910.1030
• Program required when there are employees with
potential exposure
– Health care
– First Responders/First Aid Providers
– Janitorial (restroom cleaning)
• Annual training required
• Post exposure vaccination program
– Hepatitis B Virus
Safety Quiz: Who’s Liable?
Bob dropped a banana peel, slipped and
fractured his skull, who’s at fault?
1)
2)
3)
4)
5)
6)
7)
Bob
Bob’s school district & supervisor
Floor wax manufacturer
Banana importer
Grocery store
Newspaper that advertised banana sale
The Banana farmer
You Know an IDOL Inspection is
going bad when• IDOL sets up temp. housing in your parking lot
• The officer mutters “this is unbelievable”
• They call in a professional film crew for documentation and you
recognize Walter Jacobson
• Officer is wearing a moon suit and respirator your staff is in
jeans and tennis shoes
• Officer begins inspection with “you have the right to remain
silent”
• Officer asks a specific question about a note in your files
(before you show him the file)
• Officer knows all your staff by their first names
• Officer is a former science teacher that you fired
Speaker Contact Information
Rob Rottersman, MS, CIH
Senior Environmental Consultant
Boelter & Yates, Inc.
1300 Higgins Rd. Ste 301
Park Ridge, IL 60068
[email protected]
IASBO Booth #432