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OSHA Update and
Outlook for 2008
George B. Flynn MS, CIH
Compliance Assistance Specialist
OSHA Englewood Area Office
Local Injury Statistics and
Frequently Cited Violations
FY 07 Colorado Statistics*
(10/1/06 – 9/30/07)
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1336 total inspections
787 construction inspections
~59% construction
493 Fall REP inspections
170 Trench NEP inspections
57 Workzone LEP inspections
91%
• *Source IMIS database – includes “no inspection” activity
Colorado Inspections (FY 2007)
900
800
700
600
All Other Industries
500
400
300
Construction
41%
59%
200
100
0
Source: www.osha.gov
Inspections by Industry Type
(Colorado–FY 2007)
800
700
600
500
400
300
200
100
Construction
Manufacturing
Transportation
Wholesale Trade
Retail Trade
Services
Mining
0
Source: www.osha.gov
Frequently Cited Violations
(2007)
FY 2007 Top 10 Nationwide
(Construction)
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1926.451 – scaffold general requirements
1926.501 – duty to have fall protection
1926.1053 – ladders
1926.453 – aerial lifts
1926.503 – fall protection training requirements
1926.20 – safety and health programs
1926.100 – hard hats
1926.651 – specific excavation requirements
1910.1200 – chemical hazard communication
1926.454 – scaffold training requirements
FY07 Top 10 – Denver Area Office
(Construction)
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1926.501(b)(13)
1926.503(a)(1)
1926.501(b)(1)
1926.454(a)
1926.20(b)(2)
1926.20(b)(1)
1926.451(e)(1)
1926.21(b)(2)
1926.451(g)(1)
1926.652(a)(1)
Residential Falls
Fall Protection – Training *
General Fall Protection – (ie, 6 ft.) *
Scaffolds – Training *
Safety Program – Inspections *
Safety Program *
Scaffolds – Access *
Safety Program - Training
Scaffolds – Fall Protection *
Trench – Protective Systems
* National Top 10
FY07 Top 10 – Englewood Area Office
(Construction)
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1926.451
1926.501(b)
1926.651(k)
1926.652(a)
1926.1052/1053
1926.100(a)
1926.102(a)
1926.200(g)
1926.502(b)
1926.503(c)
Scaffolds *
General Fall Protection – (ie, 6 ft.) *
Trench – Specific Reqs. *
Trench – Protective Systems
Ladders *
Head Protection *
Eye and Face Protection
Workzone
Guardrails
Fall Protection – Training *
* National Top 10
FY07 Top 10 – Englewood Area Office
(General Industry)
• 1910.305
Electrical – Wiring Method, Components and
Equipment *
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Respiratory Protection *
1910.134
1910.1200
1910.303
1910.212
1910.132
1910.23
• 1910.1030
• 1910.219
• 1910.178
HazComm *
Electrical – General Requirements *
Machine Guarding – General *
PPE – General Requirements
Guarding Floor and Wall Openings and
Holes
Bloodborne Pathogens
Machine Guarding – Mechanical
Power-Transmission
Powered Industrial Trucks *
* National Top 10
What’s New for 2008?
New and Upcoming OSHA
Standards and Regulations
• New Standards and Regulations
– Hexavalent Chromium (Final Rule Feb. ’06)
– Respiratory Protection: Assigned Protection Factors (Final Rule
Aug. ’06)
– Electrical Installation Standards (Subpart S) (Final Rule Feb. ‘07)
• Upcoming Standards and Regulations
– Explosives and Blasting Agents
– Employer Payment for Personal Protective Equipment (Final Rule
Nov. ’07)
• Other Rules in Development
– Hazard Communication Standard (Globally Harmonized System
of Classification and Labeling of Chemicals)
– Cranes and Derricks
– Confined Spaces in Construction (Proposed Rule Nov. ’07)
PPE Final Rule (11/15/07)
PPE Final Rule
• 1926.95(d)(1) – (d)(7)
• Employer must pay for PPE used to
comply with OSHA standards
– Exceptions:
• Non-specialty safety toe footwear and safety
eyewear if employer permits use off the job
• Metatarsal protection if external metatarsal guards
provided
• Everyday clothing
PPE Final Rule
• Replacement PPE must be paid for by the
employer unless
– Lost by employee
– Intentionally damaged by employee
• Employee-owned PPE
– Use cannot be required by employer, but OK if
voluntary (not reimbursable)
• Effective Date – February 13, 2008
• Enforcement Date – May 15, 2008
Subpart S – General Industry
• Updates general industry electrical
installation requirements to the 2000
edition of NFPA 70E for new construction
Focus for 2008
Focus for 2008
Enforcement Emphasis
Programs
• NEP
– Trenching and
Excavation
• REP
– Highway Work Zone
Safety
– Falls from Elevation in
Construction
– Oil and Gas
Operations
Colorado Fatalities
(2003-2007)
40
35
30
25
20
15
10
5
0
2003
2004
2005
2006
2007
Source: www.osha.gov
FY07 Region 8 Fatalities (to date)
2
5
Trans. (6)
3
Details
Colorado Fatalities
(Construction** vs. All Other Industries)
120
1997-2002
100
58%
80
All Other Industries
60
42%
Construction
2003-2005
40
20
52%
48%
59%
0
** Comprises 7% of
Colorado Workforce
2007
41%
OSHA Enforcement Emphasis
Programs (EPs)
George B. Flynn, MS, CIH
OSHA Compliance Assistance Specialist
ASSE Colorado Chapter - February 13, 2007
Colorado Enforcement Emphasis Programs
• General Industry
– Amputations (Statewide)
– Silica and Slab Handling in Natural Stone
Shops (Denver)
– Oil and Gas Well Drilling and Servicing
(Statewide)
– Pharmaceutical Manufacturers (Denver Area
Office)
– Site-Specific Targetting (SST) (Nationwide)
Amputations
Nationwide
Purpose
To identify and to reduce workplace and equipment hazards which are causing or
likely to cause amputations.
SIC
Numerous manufacturing industries (ie, SICs 20-39)
Scope
• Focus on machinery and equipment associated with amputations
• Other hazards in plain view
Selection
• Master list provided by National Office
• Random selection of 10 establishments
• Verify presence of amputation-causing machinery/equipment at opening
Adds
• Local knowledge (eg, amp injuries and/or fatalities last 5 years)
Deletes
• No amputation-causing machinery or equipment
• Inspected within previous 24 months and no known amputations
• 10 or fewer employees
Outreach
Mailings to listed establishments
Inspection Results (EAO)
FY 2006
37 Inspections Conducted
59 Attempted
22 I/C
75% Serious violations
Top Violations
1910.212(a) Machine Guarding
(General Reqs)
1910.213(c) Hand-fed Ripsaws
1910.305(b) Electrical (Wiring –
Cabinets, Boxes, Fittings)
1910.147(c) Lockout/Tagout
1910.305(g) Electrical (Wiring –
Flexible cords and cables)
FY 2007
52 Inspections Conducted
59 Attempted
22 I/C
75% Serious violations
Top Violations
1910.212(a) Machine Guarding
(General Reqs)
1910.213(c) Hand-fed Ripsaws
1910.305(b) Electrical (Wiring –
Cabinets, Boxes, Fittings)
1910.147(c) Lockout/Tagout
Silica
Denver Area Office (DAO)
Englewood Area Office
(EAO)
Purpose
Reduce illnesses related to silica exposures and
hazards associated with slab handling
Same
SIC
Cut Stone and Stone Products (3281)
Same
Scope
• Silica related hazards
• Handling/moving slabs of stone and marble
• Includes establishments with 10 or fewer
Same
Selection
• Search InfoUSA by SIC
• Random selection of 10 establishments
• Search InfoUSA by SIC
• Select 29 establishments
Adds
• Local knowledge
Complaints and referrals in
targeted SICs
Deletes
• Wrong SIC
• Inspected for silica hazards since Oct. 2004 and
I/C related to silica hazards
Same
Complaints
• Expand to cover silica hazards even in nontargeted SIC
Outreach
• Mailings to targeted SICs in 2005
Inspection Results (EAO)
FY 2006
15 Inspections Conducted
21 Attempted
7 I/C
83% Serious violations
Top Violations
1910.134(c) Respirator Program
1910.134(e) Medical
Evaluation
1910.305(b) Electrical Wiring
1910.178(l) PIT Training
1910.1200(e) Written Hazcom
Program
1910.1000 Overexposures (6 of
15)
5(a)(1) Slab Handling (5 of 15)
FY 2007
12 Inspections Conducted
12 Attempted
5 I/C
79% Serious violations
Top Violations
1910.134(c) Respirator Program
1910.95(c) Hearing Conservation
1910.213(c) Machine Guarding
1910.178(l) PIT Training
1910.1200(e) Written Hazcom
Program
1910.1000 Overexposures (1 of
7)
5(a)(1) Slab Handling (1 of 7)
Oil and Gas Well Drilling and Servicing
Region VIII (MT, CO, WY, UT, ND, SD)
Purpose
Reduce the rate of injuries, illnesses and and fatalities
SIC
Oil and Gas Exploration (1382) Well Drilling (1381) and Servicing (1389)
Scope
• Safety hazards focus
• Any observed health hazards
• Excludes establishments with 10 or fewer
Selection
• Utilizes RigData reporting service
• DAO counties: Garfield; Mesa, and Weld
• EAO counties: Las Animas; La Plata and San Miguel
Adds
• CSHO Observation
• Physical search within defined geographical area (EAO/Drill Rigs)
Deletes
Programmed inspection within last 90 days
Complaints
Expand to comprehensive if facility is on current inspection cycle
For SIC 1382
and 1389
CSHO will proceed to office of selected employer and conduct opening
conference. CSHO will identify active sites and select 1 at random to
inspect.
Inspection Results (EAO)
FY 2006
5 Inspections Conducted
14 Attempted
8 I/C
77% Serious violations
Top Violations
1910.132(d)(1) PPE Hazard
Assessment
1910.184 Slings
5(a)(1) General Duty Clause
FY 2007
52 Inspections Conducted
65 Attempted
29 I/C
95% Serious violations
Top Violations
1910.23 Guarding Floor and Wall
Openings
Subpart S - Electrical
5(a)(1) General Duty Clause
1910.184 - Slings
Subpart Q - Welding, Cutting and
Brazing
Subpart I - PPE
2006 Site-Specific Targeting (SST)
Nationwide
Database
2005 OSHA Data Initiative
Primary List
Threshold
• DART at or more than 12.0 (Nat’l avg.= 2.5)
• DAFWII at or more than 9.0 (Nat’l avg.=1.4)
• Approximately 4,250 sites
• Includes 175 low-rate establishments
Secondary List
Threshold
• DART 7.0 or greater but < 12.0
• DAFWII 5.0 or greater but < 9.0
Tertiary List
Except that no establishment with a DART rate of 5.0 or lower and a DAFWII
rate at or below 2.8 will be included
Other
Only a comprehensive safety inspection is required.
Health inspections will be limited to:
1.
Focused for SIC 805 (Long-term care facilities)
2.
CSHO referral
3.
Area Director discretion
Colorado
Enforcement Emphasis Programs
• Construction
– Construction Fall Hazards (Regionwide)
– Roadway Workzone Safety (Statewide)
– Trenching (Nationwide)
– Dodge List Construction (Nationwide)
Fall Hazards in Construction
Region VIII (MT, CO, WY, UT, ND, SD)
Purpose
Eliminate exposures to fall hazards in commercial and residential
construction
SIC
N/A
Scope
• Normally limited to fall hazards and serious hazards in electrical, struck by
and caught/in between
• Additional serious hazards observed
Selection
• CSHO self referrals
• Whenever OSHA receives info on fall hazards by any other means
Adds
Whenever OSHA receives info on fall hazards by any other means
Deletes
Inspected within past 30 days; previous inspection included meaningful
inspection of fall hazards and no observed serious hazards at the current site
Inspection Results (EAO)
FY 2006
FY 2007
183 Inspections Conducted
227 Inspections Conducted
191 Attempted
232 Attempted
62 I/C
67 I/C
83% Serious violations
88% Serious violations
Top Violations
Top Violations
1926.501(b) Unprotected Sides and
Subpart M – Fall Protection (202)
Edges (85 of 183)
Subpart L – Scaffolds (153)
1926.1053(b) Improper Ladder Use
Subpart E – PPE (97)
1926.451 Scaffolding
Subpart X – Ladders (90)
(f) Platforms overloaded
(g) Fall protection
(c) Lack of Bracing
(b) Platform construction
1926.503(a) Fall Protection Training
Highway Workzone Safety
Denver Area Office (DAO)
Englewood Area Office
(EAO)
Purpose
Reduce injuries/fatalities related to street and
highway work zone activities
Same
SIC
N/A
N/A
Scope
Comprehensive inspections
Same
Selection
• Develop list of roadway work zones from CDOT
Scheduled Lane/Road Closures
• Random selection of 1 WZ per month
• Same
• Select 4 WZs/month
Adds
CSHO-observed hazard in roadway WZ
Same
Deletes
Programmed inspection within last 90 days (unless
serious hazard is observed)
Same
Outreach
• Training at CCA
• Letter sent to covered employees
Training at CCA
Inspection Results (EAO)
FY 2006
43 Inspections Conducted
57 Attempted
15 I/C
96% Serious violations
Top Violations
1926.501(b)(15) Fall Protection
1926.200(g)(2) Traffic Signs &
Devices
5(a)(1) General Duty Clause
1926.100 (a)(1) Head Protection
1926.102 (a)(1) Eye Protection
FY 2007
45 Inspections Conducted
52 Attempted
12 I/C
92% Serious violations
Top Violations
1926.200 (g)(2) Traffic Signs and
Devices
1926.201(a) Signals for Flaggers
1926.451 Scaffolds
1926.651/652 Excavations
5(a)(1) General Duty Clause
- Live lanes
- Placing/Removing cones
Trenching and Excavation Results (EAO)
FY 2006
FY 2007
83 Inspections Conducted
97 Inspections Conducted
86 Attempted
101 Attempted
13 I/C
33 I/C
90% Serious violations
84% Serious violations
Top Violations
Top Violations
1926.652 (a)(1) Protective Systems
1926.652 (a)(1) Protective Systems
(62 of 83)
(46 of 97)
1926.651 (k)(1) Daily Inspections
1926.651 (k)(1) Daily Inspections
by Competent Person
by Competent Person
1926.651 (j)(2) Spoil Pile < 2 ft.
1926.651 (j)(2) Spoil Pile < 2 ft.
From Edge
From Edge
1926.651 (c)(2) Insufficient Means
1926.652 (g) Shield Systems
of Egress (ie, ladders)
1926.200 (g) Traffic Signs and
1926.21 (b)(2) General Safety
Devices
Training
OSHA’s Cooperative Programs
• Alliance Program
• Strategic Partnership Program
• Voluntary Protection
Programs (VPP)
• Consultation Program & Safety
and Health Recognition
Program (SHARP)
Alliance Program Goals
Trinidad State Junior
College (2/6/07)
• OSHA and the participating
organizations must define,
implement, and meet a set of
short- and long-term goals
that fall into three categories:
– Training and education
– Outreach and communication
– Promoting the national dialogue
on workplace safety and health
Red Rocks Community
College (2/27/07)
Expired
OSPP Statistics
(as of March 31, 2007)
• 161 active Partnerships
• More than 10,000 employers
and 585,000 employees
impacted
• Average 52 new
Partnerships/year
• 8 National Partnerships
New VPP Concepts
• OSHA Challenge
• VPP Corporate
• VPP Construction
Disclaimer
•
This information has been developed by an OSHA Compliance Assistance
Specialist and is intended to assist employers, workers, and others as they
strive to improve workplace health and safety. While we attempt to
thoroughly address specific topics, it is not possible to include discussion of
everything necessary to ensure a healthy and safe working environment in
a presentation of this nature. Thus, this information must be understood as
a tool for addressing workplace hazards, rather than an exhaustive
statement of an employer’s legal obligations, which are defined by statute,
regulations, and standards. Likewise, to the extent that this information
references practices or procedures that may enhance health or safety, but
which are not required by a statute, regulation, or standard, it cannot, and
does not, create additional legal obligations. Finally, over time, OSHA may
modify rules and interpretations in light of new technology, information, or
circumstances; to keep apprised of such developments, or to review
information on a wide range of occupational safety and health topics, you
can visit OSHA’s website at www.osha.gov.