New England Healthcare Engineer’s Society 2012 Annual Fall Conference Steven Jalowiec, PE, CHFM

“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.”

• • 

High-hazard industries

o o industries deemed to be of a high-hazard nature healthcare or construction, will be subject to more frequent routine inspection.

Employee complaints/referrals

o o result of a whistleblower incident referral from another observing government agency

High DART Rate

o o days away from work, days of restricted work activity or job transfer Higher than peer industries locally or nationally

  

Imminent danger

o o violation out in the open and highly visible seen by concerned individuals or compliance officer.

Fatalities/catastrophic accidents

o incident resulting in a fatality or hospitalization of three or more persons must be reported to OSHA within 8 hours. o serious events will necessarily prompt an investigation .

Special emphasis programs (SEP)

o OSHA’s regulatory agenda always includes areas of particular concern, such as exposure to lead and combustible dust.

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

Standard 19101030 19101200 19100305 # Cited 440 97 26 21 # Insp Penalty 83 $353,792 29 15 $124,064 $16,350 13 $6,400 19100303 19040029 19100134 19100147 19040007 19100037 19261101 20 19 19 16 14 14 13 13 9 9 9 5 11 6 $11,985 $8,480 $5,390 $10,850 $6,330 $3,500 $22,100 Description TOTAL ALL CITATIONS Bloodborne pathogens.

Hazard Communication.

Wiring methods, components, and equipment for general use.

General requirements.

Forms.

Respiratory Protection.

The control of hazardous energy (lockout/tagout).

General recording criteria.

Maintenance, safeguards, and operational features for exit routes.

Asbestos

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

• • • •

Arc Flash - 1910.333 (NFPA 70E ) Control of Hazardous Energy

o LOTO 1910.147

Personal Protective Equipment

o PPE -1910.132

Electrical Safety 1910.301-399

o

(301-308, 333-335, 399)

• • • • •

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

• • •

Training is required for everything.

best practice regular training maintain records tip for compliance o weekly job box meetings

ARC FLASH POLICY OUTLINE

ARC FLASH POLICY OUTLINE

ARC FLASH POLICY OUTLINE

Typical LOTO PROCEDURE

NOTE: Additional Procedures for each source: Electrical Water Steam Natural Gas Oil Blow Down

Typical LOTO PROCEDURE

• • • • • •

Assessment

o o o 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

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.

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.

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.

• Engineering Controls o o fume hoods equipment specific exhaust systems • o 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

•

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?

• • • • • • Guarding floor and wall openings and holes, 1910.23

o Skylights Portable wood ladders, 1910.25

Portable metal ladders, 1910.26

Fixed ladders, 1910.27

Safety requirements for scaffolding, 1910.28

HVAC/Rooftop Equipment

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.

FALL PROTECTION

Two Skylight Tragedies End in Jail Sentences, Apr 28, 2009

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

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

Also see SawStop

YES NO

• • • • • • • Written Program Inventory MSDS Right to Know Spill Response PPE Training

"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.

SIGN: FIRE PUMP

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

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 [email protected]

203-228-3480