Managing OSHA Health Programs WITC – New Richmond April 14, 2011 Mary Bauer CIH, CSP Compliance Assistance Specialist Eau Claire, WI 54701 715-832-9019
Download ReportTranscript Managing OSHA Health Programs WITC – New Richmond April 14, 2011 Mary Bauer CIH, CSP Compliance Assistance Specialist Eau Claire, WI 54701 715-832-9019
Slide 1
Slide 2
Managing OSHA Health
Programs
WITC – New Richmond
April 14, 2011
Mary Bauer
CIH, CSP
Compliance Assistance Specialist
Eau Claire, WI 54701
715-832-9019
Slide 3
My Background
Mary Bauer
25 years w/ OSHA
20 Compliance Officer
5 Compliance Assistance Specialist
IH/ Safety
CIH: Certified Industrial Hygienist
CSP: Certified Safety Professional
1000 + Inspections
Slide 4
Today’s Agenda
What are OSHA Health Programs?
How do I know if I need one?
Required Documentation
Maintenance/Retention of Records
Exposure and Medical Records
Tips on Record Maintenance
Slide 5
“Paperwork Reduction Act”
1942, 1980 & 1995
1980 Created “Office of Info & Regulatory
Affairs”
“Burdent Hours”: Time & Expense to Fill Out
Forms
The purposes of this chapter are to:
minimize the paperwork burden for individuals,
small businesses, educational and nonprofit
institutions, Federal contractors, State, local
and tribal governments, and other persons
resulting from the collection of information by
or for the Federal Government;
Slide 6
“Older” vs. “Newer” Standards
Older Standards
Require a “program”
Don’t Require it written
1910.95: Hearing Conservation Program
Newer Standards
Requires a Written Program
Bloodborne Pathogens
Respirator
Written Program
Periodic Review
Slide 7
Industrial Hygiene from an OSHA
Perspective
Focus on workplace health hazards
Goal: reduce or eliminate hazards that
can cause sickness or impaired health
Identify & analyze workplace health
hazards
* chemical
* physical
* ergonomic
* biological
Slide 8
Health Hazards:
Air Contaminates
Skin Contact - Dermal
Hearing Loss
Ringing in the Ear
Bloodborne
Irritant
Burns
Noise
Lungs
Central Nervous System
Internal Organs
Blood
Hepatitis…..B and C
HIV/AIDS
Spill/Leak of Chemical
Immediate or
Chronic (Long Term)
Effects
Slide 9
Health Standards
List is NOT Complete
1910.95: Hearing Conservation / Noise
1910.120: Emergency Response
1910.132: Personal Protective Equipment
1910.134: Respiratory Protection Program
1910.1001-1910.1052
Expanded Health Standards
Slide 10
Expanded Standards:
Asbestos
Coal Tar Pitch Volatiles
13 Carcinogens
Alpha-Naphthylamine
Methy Chloromethyl Ether
3,”-Dichlorobenzidine
Bis-Chloromethyl ether
Beta-Naphthylamine
Benzidine
4-Aminodiphenyl
Ethyleneimine
Beta-Propiolactone
2-Acetylaminoflurorene
4-Dimethylaminoazobenzene
N-Nitrosodimethylamine
Vinyl Chloride
Inorganic Arsenic
Lead
Hexavalent Chromium
Cadmium
Benzene
Coke Oven Emissions
Cotton Dust
1,2-dibromo-3-chloropropane
Acrylonitrile
Ethylene Oxide
Formaldehyde
Methylenedianiline
1,3-Butadiene
Methylene Chloride
Slide 11
Health Standards
1910.1020: Formerly 1910.20
Access to Exposure and Medical Records
1910.1030:
1910.1096:
1910.1200:
1910.1450:
Labs
Bloodborne Pathogens
Ionizing Radiation
Hazard Communication
Chemical Hygiene Plan -
Slide 12
Standards: Construction
1926.50: Medical Services and First Aid
1926.51: Sanitation
1926.52: Occupational Noise
1926.53: Ionizing Radiation
1926.55: Gases, Vapors, Fumes, Dusts
and Mists
1926.56: Illumination
1926.57: Ventilation
1926.59: Hazard Communication:
REFERENCES: General Industry 1910.1200
Subpart C:
1926.33: Access to Medical and Exposure
Records
References General Industry: 1910.1020
Slide 13
Standards: Construction
Subpart D: Continued
1926.60: Methylenedianiline
1926.62: Lead
1926.64: Process Safety Management
1926.65: Haz Waste Operation & Emer
Response
1926.66: Spray Booths
Subpart Z:
1926.1101-.1152: Expanded Standards
Slide 14
Related Standards
PPE
1910.132: General
1910.133: Eye & Face
1910.138: Hand
Ventilation: 1910.94
Flammable: 1910.106
LEL/UEL vs. PEL
Emergency Response: 1910.120
PSM: 1910.119
Medical Services and First Aid: 1910.151
Slide 15
Expanded Standards:
Common Paragraphs
Scope and Application
Definitions
AL / PEL / STEL / Action Level
Monitoring
Initial & Subsequent
Ees Access
Regulated Areas
Method of Compliance
Respiratory Protection
Slide 16
Expanded Standard: Common
Paragraphs
Training
Medical Surveillance
Hygiene / Work Clothing / Showers
Signs / Labels / Warnings
Records / Recordkeeping
Appendices
Written Compliance Plan
Emergencies / Spills
Effective Dates
Slide 17
How Do I Evaluate the Hazard?
MSDS
Observation: Smell, Taste, See, Feel
Screening – Next Session
Direct Reading Instruments
Short Term Sampling- Next Session
TWA Sampling – Next Session
Bulk Sampling
Interviews: Mgmt – Ees
Slide 18
Hazard Review
Chemical or Hazard:
What’s used?
How Much?
How Often?
Previous Sampling?
Controls?
Existing?
Determined Effective?
Changes in Process since Determined
Maintained?
Measured? (Manometer)
Slide 19
Sampling: Only way to really know!
Qualified Person
State Consultation
Insurance Carrier
Private Consultant
OSHA: Enforcement!
Appropriate
Instrument
Duration of sampling
Pre and post
calibration
Slide 20
Slide 21
How to you Attack the Problem?
Hierarchy of Controls
Engineering
Administrative
Personal Protective
Equipment
Training
Slide 22
Controls or Abatement Methods
Classic Hierarchy:
Product Substitution / Elimination
Methylene Chloride: Have Avoided at all costs!
Asbestos – Limited to No Mfg or Product
Containing
Engineering Control
Ventilation
Barrier / Distance / Automation
Administrative Controls: Rotation
Prohibited for Some Contaminates (Pb)
PPE
Respirator
Hearing Protection
Slide 23
Noise: 1910.95(m)
Exposure Measurements
Sound Level or Dosimeter Readings
Retain for 2 Years
* HOWEVER, Need to Show Monitoring Results *
Audiograms:
Employee Info
Testing Equipment Information
Duration of Affected Employee’s Employment
Includes Specific Information
Slide 24
Occupational Noise Exposure
Assess your workplace!
Monitor areas of concern
Sample worker’s full-shift noise
exposure
Engineering Controls or Hearing Protection???
Slide 25
Hearing Conservation Requirements
Monitoring
Employee Notification
Audiometric Testing
Hearing Protectors
Training
Access To Records
Recordkeeping
Slide 26
Noise Sampling – Some Tools
Industrial Hygienists Use:
Sound level meter: Spot Checks
Noise dosimeters: Exposure Determination
Slide 27
Occupational Noise Exposure
If full-shift noise exposure averages
above the OSHA PEL of 90 dBA
(decibels A-weighted)
Hearing protection must be provided &
used
If full-shift noise exposure averages
above OSHA Action Level of 85 dBA
A hearing conservation program must
be implemented
Slide 28
Hearing Conservation Program (HCP)
Purpose: prevent
or reduce
progression of
noise-induced
hearing loss
HCP must include:
Noise monitoring
Hearing protection
Hearing testing
(audiograms)
Training
Recordkeeping
NRR: EPA Rating
Slide 29
Audiometric Testing
New Hires
Annual
Standard Threshold Shifts
Testing Equipment
Notification to Employee
Revised Baselines or Retesting
VAN EXEMPTION
Slide 30
Respiratory Protection
1910.134
Written Copy of Respiratory Program
1910.134( c)(1)(i)-(ix)
Written PLHCP Opinion
Fit Testing
Certification / Inspection Emergency Use
Slide 31
Respiratory Protection
When must you
provide your workers
with respiratory
protection?
When they are
exposed to a
chemical in excess of
the OSHA PEL
Until engineering,
administrative, &
work practice
controls have been
implemented to
control exposures (&
re-sampling shows
exposures in
compliance with PEL)
Slide 32
Respirator-Use Requirements per 29 CFR 1910.134(c)
Slide 33
Voluntary Respirator Use
What if air sampling results are
below the PEL & you only allow
voluntary use of filtering face piece
dust masks?
You must inform workers about
Appendix D of 1910.134
("Information for Employees Using
Respirators When Not Required
Under the Standard")
Slide 34
Voluntary Respiratory Use:
Other than “dust mask”
What if you allow voluntary use of
other types of respirators?
Must have written respirator
program that provides for:
medical evaluation,
cleaning, maintenance & storage of
respirators
Slide 35
What if your workers are required to
wear respirators?
Written program
Respirator selection
Medical Evaluations
Fit testing
Proper use of respirators
Continued effectiveness
Must be appropriate for hazard
If selecting a gas or vapor cartridge respirators,
must develop cartridge change-out schedule (unless
it has an ESLI)
Cleaning, disinfecting, storage
Training
Slide 36
Medical Evaluation
You must provide an evaluation
before respirator use and before fit
testing
You need to identify a professional
Licensed Health Care person to
conduct an evaluation through using
a medical questionnaire or an initial
medical examination that contains
the same information.
Slide 37
Medical Evaluation-cont.
Medical evaluations need to contain
the information requested in the
questionnaire in Section 1 and 2,
Part A of Appendix C of 1910.134
Slide 38
Follow up examinations
Follow up examinations
A positive response to any question 1-8 of
section 2 OR
Initial medical exam demonstrates the need
for a follow up
Slide 39
Fit Testing
Slide 40
Fit Testing
Qualitative
Quantitative
Next Session
PortaCount Rep &
Equipment
Slide 41
Fit Testing
Before the use of any negative or
positive TIGHT FITTING face piece
respirator
Slide 42
No Fit Testing Required
Hoods, helmets and loose-fitting
facepieces
Escape-only respirators
Voluntary use respirators
Hood
Helmet
Loose-fitting
Slide 43
User Seal Check
Slide 44
Non-Air Contaminate/Expanded Std.
1910.1020: Access to Med & Exp
Records
1010.1030: Bloodborne Pathogens
1910.1096: Ionizing Radiation
1910.1200: Hazard Communication
1910.1450: Chemicals in
Laboratories
Slide 45
Access to Medical and Exposure Records
1910.1020
Formerly 1910.20 –
WRONG in OSHA Standards to this day!
Where it says to keep MSDS for 30 years!
Sampling Data
Medical: Audiograms
Medical Access Order is Related: 1913.10
http://www.osha.gov/SLTC/medicalaccessorder/index.html
http://www.osha.gov/pls/oshaweb/owadisp.sh
ow_document?p_table=STANDARDS&p_id=10
207
Slide 46
Availability of Med & Exp Records
1913.10(b)(3) This section does not apply to OSHA
access to, or the use of, aggregate employee medical
information or medical records on individual employees
which is not in a personally identifiable form. This section
does not apply to records required by 29 CFR Part 1904,
to death certificates, or to employee exposure records,
including biological monitoring records treated by 29 CFR
1910.1020(c)(5) or by specific occupational safety and
health standards as exposure records.
1913.10(b)(4) This section does not apply where OSHA
compliance personnel conduct an examination of
employee medical records solely to verify employer
compliance with the medical surveillance recordkeeping
requirements of an occupational safety and health
standard, or with 29 CFR 1910.1020. An examination of
this nature shall be conducted on-site and, if requested,
shall be conducted under the observation of the
recordholder. The OSHA compliance personnel shall not
record and take off-site any information from medical
records other than documentation of the fact of
compliance or non-compliance.
Slide 47
Access to Medical and Exposure Records
1910.1020
Inform Upon Initial Hire and
Annually There after….NOT TRAINED
Posting
Wisconsin Council of Safety Example
Producing the Record after
Requested
What is a request
Who can request
15 days
Slide 48
Access To Exposure & Medical Records:
1910.1020
Exposure Record
Medical Records
MSDS
Industrial Hygiene Monitoring
Medical Surveillance Results
Written Medical Opinions
WCS Website w/ sample program:
http://www.doa.state.wi.us/docs_view2.asp?docid=2510
Slide 49
Access To Exposure & Medical Records:
1910.1020
Retention Time:
Unless specified in a “vertical” standard
"Employee medical records." The medical record for
each employee shall be preserved and maintained
for at least the duration of employment plus thirty
(30) years, except that the following types of
records need not be retained for any specified
period:
The medical records of employees who have worked
for less than (1) year for the employer need not be
retained beyond the term of employment if they are
provided to the employee upon the termination of
employment.
"Employee exposure records." Each employee
exposure record shall be preserved and maintained
for at least thirty (30) years, except that:
Slide 50
BLOODBORNE PATHOGENS
1910.1030
Written Exposure Control Plan
Training
Reviewed at least annually
Date(s)
Content or Summary
Names and Qualifications of Trainer
Names and Titles of Attendees
Retained for 3 Years
Training Materials
Sharps Log
Slide 51
Coverage
Standard applies to all occupational
exposure to blood or other
potentially infectious materials
Slide 52
If you answer NO
Develop a policy stating that there
are no first aid responders or
cleanup and that the company will
rely on 911 for any type of response
to injuries
Slide 53
If you answer YES
Develop and implement all elements
of a written bloodborne pathogens
program
•Exposure Control Plan must provide:
•Engineering controls (where applicable)
•Hygiene (hand washing)
•PPE (e.g., gloves, CPR masks)
•Housekeeping
•Disposal of regulated waste
•Hepatitis B vaccine
•Post-exposure evaluation & follow-up
•Training
Slide 54
Exposure Control Plan
Requires employers to:
identify potentially exposed workers
those who need training
PPE
Vaccination
Engineering Controls (Safer Needle
Devices)
Required to be reviewed and updated
annually with Employee Input
Slide 55
Bloodborne Pathogens
Are your employees going to be
exposed or have the potential to be
exposed to Bloodborne Pathogens
or other potentially infectious
materials?
Who performs cleanup of blood or
fluids?
Are you going to appoint designated
first aid responders?
Slide 56
Bloodborne Pathogens
1990’s
Effective Date: March 6, 1992
1993 FAQ – One of the First
Latex Allergies Surfaced and Addressed
Collateral Duty Clause:
Directive to Use any / all standards + 5a1
First Aid as additional responsibility
All Other Provisions in Place
After Opportunity to Perform 1st Aid
Offer Hep B Vaccination
Region V Policy for BBP
Sharps Log /Safer Needle Devices: 2001
Slide 57
Revisions to 1910.1030 as a result of the
Needlestick Safety and Prevention Act:
Paragraph 1910.1030(d)(2)(i) requires the use of
engineering and work practice controls to eliminate or
minimize employee exposure to bloodborne pathogens.
Employers must keep a Sharps Injury Log for the
recording of percutaneous injuries from contaminated
sharps [1910.1030(h)(5)(i)].
The Exposure Control Plan (1910.1030(c)(1)(i)) shall:
Reflect changes in technology that eliminate or reduce
exposure to bloodborne pathogens
[1910.1030(c)(1)(iv)(A)].
Document annually consideration and implementation of
appropriate commercially available and effective safer
medical devices designed to eliminate or minimize
occupational exposure [1910.1030(c)(1)(iv)(B)].
Solicit input from non-managerial employees responsible
for direct patient care, who are potentially exposed to
injuries from contaminated sharps, in the identification,
evaluation, and selection of effective engineering and
work practice controls and shall document the solicitation
in the Exposure Control Plan [1910.1030(c)(1)(v)].
Slide 58
Methods of Compliance
Universal Precautions
Engineering Controls
Personal Protective Equipment
Housekeeping
Handling of regulated waste
Slide 59
Training Employees
All employees (including part-time
and temporary) must receive initial
and annual training
Must be conducted in the language the
employee understands
Must be “interactive”
14 Points
Qualified Trainer
Slide 60
1910.1200
Hazard Communication / “Right to Know”
“Right to Know”
MN Terminology: St. Croix Valley Companies
Previously: State of WI
The Four Stages of the Program
Material Safety Data Sheets (MSDSs)
Labeling and Marking Systems
Employee Training
Written Plan
Slide 61
Hazard Communication
1910.1200
Written Program
Program
MSDS
Labeling
Training
MSDS: Material Safety Data Sheets
30 years after you stop using it
Slide 62
Hot Topics:
Article
Brick / Block = Article
Silica = Chemical Exposure if Sawn
Electronic Access – Readily Available
Devices must be readily accessible in workplace
Workers must be trained in their use
Must be back-up system to address emergencies
Slide 63
Labeling
Target Organ
Compromises: Additional Training
Placarding Allowed
HMIS: Paint Industry
NFPA
Welding Areas
Color Coded Bottles
Secondary Containers Primary
Problem
If not used w/in the shift
Slide 64
Labeling and Marking Systems
HMIS Labels
Blue = Health
Red = Flammability
Yellow = Instability
White = Personal
Protective Equipment
or special protection
information
Numerical Rating of 04
Slide 65
Labeling and Marking Systems
NFPA Diamonds
4= Deadly Hazard
3= Severe Hazard
2= Moderate Hazard
1= Slight Hazard
0= No Hazard
Color coded,
numerical rating
system
Will be located near
main entrances, fire
alarm panels, or on
outside entrance
doors
Provide at-a-glance
hazard information
Slide 66
What Documents Should I NOT
Possess?
Slide 67
What Documents Should I NOT
Possess?
Specific findings or diagnoses unrelated to
occupational exposure - Do NOT Possess:
Instead - Possess “Written Opinions” from:
Pass/Fail or Satisfactory/Unsatisfactory on Medical Tests
Medications, Blood Pressure, History, etc.
Ee Completed Appendix C: Respirator Medical Evaluation
Respirator Medical Evaluations
Emergency Response Medical Evaluations
Bloodborne Pathogen Test Results, etc.
HIPAA: http://www.hhs.gov/ocr/hipaa/
Provisions for Confidentiality if Medical Records are Kept.
Plant Nurse or Health Department
Slide 68
Written Opinion vs.
Medical Test Results
Written Opinion: No Specific Results
Can Perform Duties
Can Not Perform Duties
Can Perform Duties w/ Following Limitations
Medical Tests: ER Needs to Know Results
Audiograms to Determine STS
Worker Comp and OSHA Log Info - Diagnosis
Biological Indicators for Chemicals
Blood Lead Test Results and other Metal Test
Results
Slide 69
More Common Standards
List is NOT Complete:
1903: Abatement Verification
1904: Injury & Illness Log
1910.38 & .39: Emergency Action & Fire Plan
1910.95: Hearing Conservation / Noise
1910.119: Process Safety Management (PSM)
1910.120: Emergency Response -HAZWOPPER
1910.132: Personal Protective Equipment- PPE
1910.134: Respiratory Protection Program
1910.146: Permit-Required Confined Spaces
Slide 70
Most Common Standards
1910.147:
1910.157:
1910.178:
1910.179:
1910.180:
1910.184:
1910.217:
1910.266:
1910.268:
1910.269:
1910.401:
Lockout - Tagout
Portable Fire Extinguishers
Powered Industrial Trucks
Overhead and Gantry Cranes
Crawler Locomotive & Truck Cranes
Slings
Mechanical Power Presses
Logging
Telecommunications
Power Gen, Trans, & Distribution
Commercial Diving
Slide 71
Most Common Standards
1910.1001-1910.1052
1910.1020: Formerly 1910.20
Expanded Health Standards
Access to Exposure and Medical Records
1910.1030: Bloodborne Pathogens
1910.1200: Hazard Communication
1910.1450: Chemical Hygiene Plan Labs
Slide 72
Maintain in What Form?
Readily Accessible
On or Off Site
24/7/365
How to access
Withstand Changing Technology
Electronic Forms Constantly Changing
Need 30 Plus Years
Software Changes
Slide 73
What about your Contractors?
Do your outside contractors have
the required documentation of their
safety and HEALTH program?
Do you ask?
Do you receive copies?
What programs would you ask for?
Slide 74
Slide 75
Eau
Claire
Madison
Appleton
Milwaukee
Slide 76
For More Help
Kelly Bubolz,
Madison Area Office
4802 E. Broadway
Madison, WI 53716
608-441-5388
Appleton Area Office
1648 Tri Park Way
Appleton, WI 54914
920-734-4521
Mary Bauer,
Eau Claire Area Office
1310 West Clairemont
Eau Claire, WI 54701
715-832-9019
Leslie Ptak,
Pat Ostrenga, Jim Lutz
Milwaukee Area Office
310 W. Wisconsin Ave. Rm 1180
Milwaukee, WI 53203
414-297-3315
Slide 77
QUESTIONS
Slide 78
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 or hazards, 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.
Slide 79
Slide 2
Managing OSHA Health
Programs
WITC – New Richmond
April 14, 2011
Mary Bauer
CIH, CSP
Compliance Assistance Specialist
Eau Claire, WI 54701
715-832-9019
Slide 3
My Background
Mary Bauer
25 years w/ OSHA
20 Compliance Officer
5 Compliance Assistance Specialist
IH/ Safety
CIH: Certified Industrial Hygienist
CSP: Certified Safety Professional
1000 + Inspections
Slide 4
Today’s Agenda
What are OSHA Health Programs?
How do I know if I need one?
Required Documentation
Maintenance/Retention of Records
Exposure and Medical Records
Tips on Record Maintenance
Slide 5
“Paperwork Reduction Act”
1942, 1980 & 1995
1980 Created “Office of Info & Regulatory
Affairs”
“Burdent Hours”: Time & Expense to Fill Out
Forms
The purposes of this chapter are to:
minimize the paperwork burden for individuals,
small businesses, educational and nonprofit
institutions, Federal contractors, State, local
and tribal governments, and other persons
resulting from the collection of information by
or for the Federal Government;
Slide 6
“Older” vs. “Newer” Standards
Older Standards
Require a “program”
Don’t Require it written
1910.95: Hearing Conservation Program
Newer Standards
Requires a Written Program
Bloodborne Pathogens
Respirator
Written Program
Periodic Review
Slide 7
Industrial Hygiene from an OSHA
Perspective
Focus on workplace health hazards
Goal: reduce or eliminate hazards that
can cause sickness or impaired health
Identify & analyze workplace health
hazards
* chemical
* physical
* ergonomic
* biological
Slide 8
Health Hazards:
Air Contaminates
Skin Contact - Dermal
Hearing Loss
Ringing in the Ear
Bloodborne
Irritant
Burns
Noise
Lungs
Central Nervous System
Internal Organs
Blood
Hepatitis…..B and C
HIV/AIDS
Spill/Leak of Chemical
Immediate or
Chronic (Long Term)
Effects
Slide 9
Health Standards
List is NOT Complete
1910.95: Hearing Conservation / Noise
1910.120: Emergency Response
1910.132: Personal Protective Equipment
1910.134: Respiratory Protection Program
1910.1001-1910.1052
Expanded Health Standards
Slide 10
Expanded Standards:
Asbestos
Coal Tar Pitch Volatiles
13 Carcinogens
Alpha-Naphthylamine
Methy Chloromethyl Ether
3,”-Dichlorobenzidine
Bis-Chloromethyl ether
Beta-Naphthylamine
Benzidine
4-Aminodiphenyl
Ethyleneimine
Beta-Propiolactone
2-Acetylaminoflurorene
4-Dimethylaminoazobenzene
N-Nitrosodimethylamine
Vinyl Chloride
Inorganic Arsenic
Lead
Hexavalent Chromium
Cadmium
Benzene
Coke Oven Emissions
Cotton Dust
1,2-dibromo-3-chloropropane
Acrylonitrile
Ethylene Oxide
Formaldehyde
Methylenedianiline
1,3-Butadiene
Methylene Chloride
Slide 11
Health Standards
1910.1020: Formerly 1910.20
Access to Exposure and Medical Records
1910.1030:
1910.1096:
1910.1200:
1910.1450:
Labs
Bloodborne Pathogens
Ionizing Radiation
Hazard Communication
Chemical Hygiene Plan -
Slide 12
Standards: Construction
1926.50: Medical Services and First Aid
1926.51: Sanitation
1926.52: Occupational Noise
1926.53: Ionizing Radiation
1926.55: Gases, Vapors, Fumes, Dusts
and Mists
1926.56: Illumination
1926.57: Ventilation
1926.59: Hazard Communication:
REFERENCES: General Industry 1910.1200
Subpart C:
1926.33: Access to Medical and Exposure
Records
References General Industry: 1910.1020
Slide 13
Standards: Construction
Subpart D: Continued
1926.60: Methylenedianiline
1926.62: Lead
1926.64: Process Safety Management
1926.65: Haz Waste Operation & Emer
Response
1926.66: Spray Booths
Subpart Z:
1926.1101-.1152: Expanded Standards
Slide 14
Related Standards
PPE
1910.132: General
1910.133: Eye & Face
1910.138: Hand
Ventilation: 1910.94
Flammable: 1910.106
LEL/UEL vs. PEL
Emergency Response: 1910.120
PSM: 1910.119
Medical Services and First Aid: 1910.151
Slide 15
Expanded Standards:
Common Paragraphs
Scope and Application
Definitions
AL / PEL / STEL / Action Level
Monitoring
Initial & Subsequent
Ees Access
Regulated Areas
Method of Compliance
Respiratory Protection
Slide 16
Expanded Standard: Common
Paragraphs
Training
Medical Surveillance
Hygiene / Work Clothing / Showers
Signs / Labels / Warnings
Records / Recordkeeping
Appendices
Written Compliance Plan
Emergencies / Spills
Effective Dates
Slide 17
How Do I Evaluate the Hazard?
MSDS
Observation: Smell, Taste, See, Feel
Screening – Next Session
Direct Reading Instruments
Short Term Sampling- Next Session
TWA Sampling – Next Session
Bulk Sampling
Interviews: Mgmt – Ees
Slide 18
Hazard Review
Chemical or Hazard:
What’s used?
How Much?
How Often?
Previous Sampling?
Controls?
Existing?
Determined Effective?
Changes in Process since Determined
Maintained?
Measured? (Manometer)
Slide 19
Sampling: Only way to really know!
Qualified Person
State Consultation
Insurance Carrier
Private Consultant
OSHA: Enforcement!
Appropriate
Instrument
Duration of sampling
Pre and post
calibration
Slide 20
Slide 21
How to you Attack the Problem?
Hierarchy of Controls
Engineering
Administrative
Personal Protective
Equipment
Training
Slide 22
Controls or Abatement Methods
Classic Hierarchy:
Product Substitution / Elimination
Methylene Chloride: Have Avoided at all costs!
Asbestos – Limited to No Mfg or Product
Containing
Engineering Control
Ventilation
Barrier / Distance / Automation
Administrative Controls: Rotation
Prohibited for Some Contaminates (Pb)
PPE
Respirator
Hearing Protection
Slide 23
Noise: 1910.95(m)
Exposure Measurements
Sound Level or Dosimeter Readings
Retain for 2 Years
* HOWEVER, Need to Show Monitoring Results *
Audiograms:
Employee Info
Testing Equipment Information
Duration of Affected Employee’s Employment
Includes Specific Information
Slide 24
Occupational Noise Exposure
Assess your workplace!
Monitor areas of concern
Sample worker’s full-shift noise
exposure
Engineering Controls or Hearing Protection???
Slide 25
Hearing Conservation Requirements
Monitoring
Employee Notification
Audiometric Testing
Hearing Protectors
Training
Access To Records
Recordkeeping
Slide 26
Noise Sampling – Some Tools
Industrial Hygienists Use:
Sound level meter: Spot Checks
Noise dosimeters: Exposure Determination
Slide 27
Occupational Noise Exposure
If full-shift noise exposure averages
above the OSHA PEL of 90 dBA
(decibels A-weighted)
Hearing protection must be provided &
used
If full-shift noise exposure averages
above OSHA Action Level of 85 dBA
A hearing conservation program must
be implemented
Slide 28
Hearing Conservation Program (HCP)
Purpose: prevent
or reduce
progression of
noise-induced
hearing loss
HCP must include:
Noise monitoring
Hearing protection
Hearing testing
(audiograms)
Training
Recordkeeping
NRR: EPA Rating
Slide 29
Audiometric Testing
New Hires
Annual
Standard Threshold Shifts
Testing Equipment
Notification to Employee
Revised Baselines or Retesting
VAN EXEMPTION
Slide 30
Respiratory Protection
1910.134
Written Copy of Respiratory Program
1910.134( c)(1)(i)-(ix)
Written PLHCP Opinion
Fit Testing
Certification / Inspection Emergency Use
Slide 31
Respiratory Protection
When must you
provide your workers
with respiratory
protection?
When they are
exposed to a
chemical in excess of
the OSHA PEL
Until engineering,
administrative, &
work practice
controls have been
implemented to
control exposures (&
re-sampling shows
exposures in
compliance with PEL)
Slide 32
Respirator-Use Requirements per 29 CFR 1910.134(c)
Slide 33
Voluntary Respirator Use
What if air sampling results are
below the PEL & you only allow
voluntary use of filtering face piece
dust masks?
You must inform workers about
Appendix D of 1910.134
("Information for Employees Using
Respirators When Not Required
Under the Standard")
Slide 34
Voluntary Respiratory Use:
Other than “dust mask”
What if you allow voluntary use of
other types of respirators?
Must have written respirator
program that provides for:
medical evaluation,
cleaning, maintenance & storage of
respirators
Slide 35
What if your workers are required to
wear respirators?
Written program
Respirator selection
Medical Evaluations
Fit testing
Proper use of respirators
Continued effectiveness
Must be appropriate for hazard
If selecting a gas or vapor cartridge respirators,
must develop cartridge change-out schedule (unless
it has an ESLI)
Cleaning, disinfecting, storage
Training
Slide 36
Medical Evaluation
You must provide an evaluation
before respirator use and before fit
testing
You need to identify a professional
Licensed Health Care person to
conduct an evaluation through using
a medical questionnaire or an initial
medical examination that contains
the same information.
Slide 37
Medical Evaluation-cont.
Medical evaluations need to contain
the information requested in the
questionnaire in Section 1 and 2,
Part A of Appendix C of 1910.134
Slide 38
Follow up examinations
Follow up examinations
A positive response to any question 1-8 of
section 2 OR
Initial medical exam demonstrates the need
for a follow up
Slide 39
Fit Testing
Slide 40
Fit Testing
Qualitative
Quantitative
Next Session
PortaCount Rep &
Equipment
Slide 41
Fit Testing
Before the use of any negative or
positive TIGHT FITTING face piece
respirator
Slide 42
No Fit Testing Required
Hoods, helmets and loose-fitting
facepieces
Escape-only respirators
Voluntary use respirators
Hood
Helmet
Loose-fitting
Slide 43
User Seal Check
Slide 44
Non-Air Contaminate/Expanded Std.
1910.1020: Access to Med & Exp
Records
1010.1030: Bloodborne Pathogens
1910.1096: Ionizing Radiation
1910.1200: Hazard Communication
1910.1450: Chemicals in
Laboratories
Slide 45
Access to Medical and Exposure Records
1910.1020
Formerly 1910.20 –
WRONG in OSHA Standards to this day!
Where it says to keep MSDS for 30 years!
Sampling Data
Medical: Audiograms
Medical Access Order is Related: 1913.10
http://www.osha.gov/SLTC/medicalaccessorder/index.html
http://www.osha.gov/pls/oshaweb/owadisp.sh
ow_document?p_table=STANDARDS&p_id=10
207
Slide 46
Availability of Med & Exp Records
1913.10(b)(3) This section does not apply to OSHA
access to, or the use of, aggregate employee medical
information or medical records on individual employees
which is not in a personally identifiable form. This section
does not apply to records required by 29 CFR Part 1904,
to death certificates, or to employee exposure records,
including biological monitoring records treated by 29 CFR
1910.1020(c)(5) or by specific occupational safety and
health standards as exposure records.
1913.10(b)(4) This section does not apply where OSHA
compliance personnel conduct an examination of
employee medical records solely to verify employer
compliance with the medical surveillance recordkeeping
requirements of an occupational safety and health
standard, or with 29 CFR 1910.1020. An examination of
this nature shall be conducted on-site and, if requested,
shall be conducted under the observation of the
recordholder. The OSHA compliance personnel shall not
record and take off-site any information from medical
records other than documentation of the fact of
compliance or non-compliance.
Slide 47
Access to Medical and Exposure Records
1910.1020
Inform Upon Initial Hire and
Annually There after….NOT TRAINED
Posting
Wisconsin Council of Safety Example
Producing the Record after
Requested
What is a request
Who can request
15 days
Slide 48
Access To Exposure & Medical Records:
1910.1020
Exposure Record
Medical Records
MSDS
Industrial Hygiene Monitoring
Medical Surveillance Results
Written Medical Opinions
WCS Website w/ sample program:
http://www.doa.state.wi.us/docs_view2.asp?docid=2510
Slide 49
Access To Exposure & Medical Records:
1910.1020
Retention Time:
Unless specified in a “vertical” standard
"Employee medical records." The medical record for
each employee shall be preserved and maintained
for at least the duration of employment plus thirty
(30) years, except that the following types of
records need not be retained for any specified
period:
The medical records of employees who have worked
for less than (1) year for the employer need not be
retained beyond the term of employment if they are
provided to the employee upon the termination of
employment.
"Employee exposure records." Each employee
exposure record shall be preserved and maintained
for at least thirty (30) years, except that:
Slide 50
BLOODBORNE PATHOGENS
1910.1030
Written Exposure Control Plan
Training
Reviewed at least annually
Date(s)
Content or Summary
Names and Qualifications of Trainer
Names and Titles of Attendees
Retained for 3 Years
Training Materials
Sharps Log
Slide 51
Coverage
Standard applies to all occupational
exposure to blood or other
potentially infectious materials
Slide 52
If you answer NO
Develop a policy stating that there
are no first aid responders or
cleanup and that the company will
rely on 911 for any type of response
to injuries
Slide 53
If you answer YES
Develop and implement all elements
of a written bloodborne pathogens
program
•Exposure Control Plan must provide:
•Engineering controls (where applicable)
•Hygiene (hand washing)
•PPE (e.g., gloves, CPR masks)
•Housekeeping
•Disposal of regulated waste
•Hepatitis B vaccine
•Post-exposure evaluation & follow-up
•Training
Slide 54
Exposure Control Plan
Requires employers to:
identify potentially exposed workers
those who need training
PPE
Vaccination
Engineering Controls (Safer Needle
Devices)
Required to be reviewed and updated
annually with Employee Input
Slide 55
Bloodborne Pathogens
Are your employees going to be
exposed or have the potential to be
exposed to Bloodborne Pathogens
or other potentially infectious
materials?
Who performs cleanup of blood or
fluids?
Are you going to appoint designated
first aid responders?
Slide 56
Bloodborne Pathogens
1990’s
Effective Date: March 6, 1992
1993 FAQ – One of the First
Latex Allergies Surfaced and Addressed
Collateral Duty Clause:
Directive to Use any / all standards + 5a1
First Aid as additional responsibility
All Other Provisions in Place
After Opportunity to Perform 1st Aid
Offer Hep B Vaccination
Region V Policy for BBP
Sharps Log /Safer Needle Devices: 2001
Slide 57
Revisions to 1910.1030 as a result of the
Needlestick Safety and Prevention Act:
Paragraph 1910.1030(d)(2)(i) requires the use of
engineering and work practice controls to eliminate or
minimize employee exposure to bloodborne pathogens.
Employers must keep a Sharps Injury Log for the
recording of percutaneous injuries from contaminated
sharps [1910.1030(h)(5)(i)].
The Exposure Control Plan (1910.1030(c)(1)(i)) shall:
Reflect changes in technology that eliminate or reduce
exposure to bloodborne pathogens
[1910.1030(c)(1)(iv)(A)].
Document annually consideration and implementation of
appropriate commercially available and effective safer
medical devices designed to eliminate or minimize
occupational exposure [1910.1030(c)(1)(iv)(B)].
Solicit input from non-managerial employees responsible
for direct patient care, who are potentially exposed to
injuries from contaminated sharps, in the identification,
evaluation, and selection of effective engineering and
work practice controls and shall document the solicitation
in the Exposure Control Plan [1910.1030(c)(1)(v)].
Slide 58
Methods of Compliance
Universal Precautions
Engineering Controls
Personal Protective Equipment
Housekeeping
Handling of regulated waste
Slide 59
Training Employees
All employees (including part-time
and temporary) must receive initial
and annual training
Must be conducted in the language the
employee understands
Must be “interactive”
14 Points
Qualified Trainer
Slide 60
1910.1200
Hazard Communication / “Right to Know”
“Right to Know”
MN Terminology: St. Croix Valley Companies
Previously: State of WI
The Four Stages of the Program
Material Safety Data Sheets (MSDSs)
Labeling and Marking Systems
Employee Training
Written Plan
Slide 61
Hazard Communication
1910.1200
Written Program
Program
MSDS
Labeling
Training
MSDS: Material Safety Data Sheets
30 years after you stop using it
Slide 62
Hot Topics:
Article
Brick / Block = Article
Silica = Chemical Exposure if Sawn
Electronic Access – Readily Available
Devices must be readily accessible in workplace
Workers must be trained in their use
Must be back-up system to address emergencies
Slide 63
Labeling
Target Organ
Compromises: Additional Training
Placarding Allowed
HMIS: Paint Industry
NFPA
Welding Areas
Color Coded Bottles
Secondary Containers Primary
Problem
If not used w/in the shift
Slide 64
Labeling and Marking Systems
HMIS Labels
Blue = Health
Red = Flammability
Yellow = Instability
White = Personal
Protective Equipment
or special protection
information
Numerical Rating of 04
Slide 65
Labeling and Marking Systems
NFPA Diamonds
4= Deadly Hazard
3= Severe Hazard
2= Moderate Hazard
1= Slight Hazard
0= No Hazard
Color coded,
numerical rating
system
Will be located near
main entrances, fire
alarm panels, or on
outside entrance
doors
Provide at-a-glance
hazard information
Slide 66
What Documents Should I NOT
Possess?
Slide 67
What Documents Should I NOT
Possess?
Specific findings or diagnoses unrelated to
occupational exposure - Do NOT Possess:
Instead - Possess “Written Opinions” from:
Pass/Fail or Satisfactory/Unsatisfactory on Medical Tests
Medications, Blood Pressure, History, etc.
Ee Completed Appendix C: Respirator Medical Evaluation
Respirator Medical Evaluations
Emergency Response Medical Evaluations
Bloodborne Pathogen Test Results, etc.
HIPAA: http://www.hhs.gov/ocr/hipaa/
Provisions for Confidentiality if Medical Records are Kept.
Plant Nurse or Health Department
Slide 68
Written Opinion vs.
Medical Test Results
Written Opinion: No Specific Results
Can Perform Duties
Can Not Perform Duties
Can Perform Duties w/ Following Limitations
Medical Tests: ER Needs to Know Results
Audiograms to Determine STS
Worker Comp and OSHA Log Info - Diagnosis
Biological Indicators for Chemicals
Blood Lead Test Results and other Metal Test
Results
Slide 69
More Common Standards
List is NOT Complete:
1903: Abatement Verification
1904: Injury & Illness Log
1910.38 & .39: Emergency Action & Fire Plan
1910.95: Hearing Conservation / Noise
1910.119: Process Safety Management (PSM)
1910.120: Emergency Response -HAZWOPPER
1910.132: Personal Protective Equipment- PPE
1910.134: Respiratory Protection Program
1910.146: Permit-Required Confined Spaces
Slide 70
Most Common Standards
1910.147:
1910.157:
1910.178:
1910.179:
1910.180:
1910.184:
1910.217:
1910.266:
1910.268:
1910.269:
1910.401:
Lockout - Tagout
Portable Fire Extinguishers
Powered Industrial Trucks
Overhead and Gantry Cranes
Crawler Locomotive & Truck Cranes
Slings
Mechanical Power Presses
Logging
Telecommunications
Power Gen, Trans, & Distribution
Commercial Diving
Slide 71
Most Common Standards
1910.1001-1910.1052
1910.1020: Formerly 1910.20
Expanded Health Standards
Access to Exposure and Medical Records
1910.1030: Bloodborne Pathogens
1910.1200: Hazard Communication
1910.1450: Chemical Hygiene Plan Labs
Slide 72
Maintain in What Form?
Readily Accessible
On or Off Site
24/7/365
How to access
Withstand Changing Technology
Electronic Forms Constantly Changing
Need 30 Plus Years
Software Changes
Slide 73
What about your Contractors?
Do your outside contractors have
the required documentation of their
safety and HEALTH program?
Do you ask?
Do you receive copies?
What programs would you ask for?
Slide 74
Slide 75
Eau
Claire
Madison
Appleton
Milwaukee
Slide 76
For More Help
Kelly Bubolz,
Madison Area Office
4802 E. Broadway
Madison, WI 53716
608-441-5388
Appleton Area Office
1648 Tri Park Way
Appleton, WI 54914
920-734-4521
Mary Bauer,
Eau Claire Area Office
1310 West Clairemont
Eau Claire, WI 54701
715-832-9019
Leslie Ptak,
Pat Ostrenga, Jim Lutz
Milwaukee Area Office
310 W. Wisconsin Ave. Rm 1180
Milwaukee, WI 53203
414-297-3315
Slide 77
QUESTIONS
Slide 78
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 or hazards, 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.
Slide 79