Happy Memorial Day

Happy Memorial Day!  Sorry, No Safety Tidbit this week.  Headed out camping with friends.

Enjoy yourself and be safe with those grilles!

~Bryan

Safety Tidbit #42 – Exposure Control Plan something new??

Safety Tidbit #42 – Exposure Control Plan something new??

Silica - One of the oldest occupational hazards finally have its own standard and on June 23, 2016. Ultimately, the Construction Industry has one year to completely implement all provision of the standard and General Industry establishments have two years.

As an industrial hygienist, I think the coolest thing about OSHA’s new Respirable Crystalline Silica standard is the requirement for a written exposure control plan. OSHA doesn’t make much fanfare about it and as with most things in the government, this is not a new concept. Several health standards (e.g., asbestos, inorganic arsenic and lead, cadmium, benzene, ethylene oxide, to name a few) all have a written compliance program requirement. So what makes the exposure control plan in the silica standard special? Well, I’ll tell you, it doesn’t wait until the employer has determined if the worker is exposed above the PEL before it gets written down. Also, the exposure control plan is designed to identify the potential of the hazard and consists of the following minimum elements:

1.     A description of the tasks in the workplace that involve exposure to respirable crystalline silica

2.     A description of the engineering controls, work practices, and respiratory protection used to limit employee exposure to respirable crystalline silica for each task

3.     A description of the housekeeping measures used to limit employee exposure to respirable crystalline silica

However, in my humble opinion, I would add to the plan the following:

4.     Results of air monitoring conducted to assess airborne concentrations,

5.     Course outline and roster for training of employees as to the hazards of crystalline silica,

6.     Frequency of medical surveillance (respiratory protection or silica),

7.     The availability of the exposure control plan, and

8.     An annual review and update of the exposure control plan.

I have been promoting this process for most of my career to all of my clients for any health hazard they have in their workplace (e.g., asbestos, lead, cadmium, etc.).  I tell them it’s a great to have all of the information in one place.  So, if they are ever audited or inspected everything is together. Also, if it’s written down the logic they used to assess the hazard can be reproduced and expanded on as operations change or the company grows.  Using OSHA’s 2002 Job Hazard Analysis Publication 3071 can help you create your Exposure Control Plan. 

Use the process for all of your health hazards.  I think this is just good business. But what do I know I’m just an industrial hygienist. Also, I think we may hear more about this requirement as enforcement dates draw near.

Thanks for reading.  ~Bryan

Safety Tidbit # 41 – OSHA Recordkeeping Changes

Safety Tidbit # 41 – OSHA Recordkeeping Changes

I was conducting a visit at a client this week, and I asked for a copy of his OSHA 300A form for 2015, which I do at each visit.  The representative said we didn’t have any recordable injuries last year, so we didn’t think we had to fill out the form.  So I verified their NAICS code with him to ensure they were not listed on OSHA’s list of Partially Exempt Industries (they were not) and I asked how many employees they had in 2015. The representative answered 16, but a few had to be laid off recently so now they were down to 12 or 13.  I explained that all employers not specifically exempted by OSHA must complete the OSHA 300A Summary of Injuries and Illnesses and post it from February 1 thru April 30 for employees to review and comment on.

I followed up the conversation on the 300A form and asked did you have any incidents that although they did not end in “recordable” injuries required first aid or maybe made the employee or others around them take pause?  The representative said they had one laceration, but he didn’t lose any time from work.  So we had another training opportunity, I asked if he sought medical attention outside the facility and if so, what care was rendered.  The employer said yes the worker went to the emergency room and received stitches.  I said well that sounds like care beyond first aid as not many can put in stitches. Now, had the emergency room put on a “butterfly” closure for the laceration the care still may have been considered first aid.

While on the topic of injury reporting, I asked if he was aware of the 2015 changes to the reporting requirements.  He just stared at me and said he was glad he asked consultation in to help get them on track.  I let him know that for amputations, loss of an eye or inpatient hospitalizations of one or more employees that OSHA must be called within 24 hours (see OSHA’s Web page). I also reminded him that fatalities must still be reported within 8 hours. 

To further complicate matters, I told him that very soon some employers will need input their OSHA 300 information online annually (see OSHA’s Web page).  All establishments with at least 250 employees must log into the web page and enter their data. Also, for employers with specific NAICS, as defined by OSHA list in the standard, and 20 or more employees must also report their injury information to OSHA via the webpage.  Which, his company happened to fall into, but he is currently under the 20 employee requirement.  However, I reminded him this employee count takes in all part-time and temporary and seasonal employees.  We discussed how this will impact construction as they may only have a few permanent employees but hire many part-time, temporary or seasonal employees as the job requires and will easily go above the 20 employee threshold set by OSHA. 

The last topic in recordkeeping that we discussed was the need to involve employees in the recordkeeping system. Specifically, they must be informed as to how they are to report work-related injuries or illnesses.  You must tell each employee that:

(A) Employees have the right to report work-related injuries and illnesses; and
(B) Employers are prohibited from discharging or in any manner discriminating against employees for reporting work-related injuries or illnesses.

Thus started my visit and why so many small employers are grateful for the assistance PA OSHA Consultation provides to them.  When they ask for it.  Thanks for reading!  ~Bryan

Safety Tidbit #40 – Hazardous Atmospheres and Entry into the PRCS

Safety Tidbit #40 – Hazardous Atmospheres and Entry into the PRCS

I recently had a client that brewed limited runs of specialty beers for themed events (I know tough duty!).  However, as a health and safety professional, I have to focus on the hazards.  For instance, the brewer must clean out the primary fermentation vat at the end of each batch. The fermentation vat contains an access port at the bottom he uses to clear out all solids before running a sanitizing solution through it. During fermentation, the vat is sealed and oxygen removed and carbon dioxide are monitored to ensure proper fermentation.

First, is this a confined space?  OSHA defines a confined space as a space that:

- Is large enough and so configured that an employee can bodily enter and perform assigned work; and

- Has limited or restricted means for entry or exit (for example, tanks, vessels, silos, storage bins, hoppers, vaults, and pits are spaces that may have limited means of entry.); and

- Is not designed for continuous employee occupancy.

I think we can all agree that the vat meets the definition of a confined space. And, based on a 1999 OSHA Letter of Interpretation, entry means all extremities as well has head and torso.  Now, is the confined space a permit-required confined space? Again, OSHA defines a permit-required confined space to be a confined space that has one or more of the following characteristics:

- Contains or has a potential to contain a hazardous atmosphere;

- Contains a material that has the potential for engulfing an entrant;

- 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

- Contains any other recognized serious safety or health hazard.

Well, given the anoxic environment in the vat, it definitely contains a hazardous atmosphere. So, the vat is a permit-required confined space. 

Theoretically, the brewer is only required to put his hands and arms into the vat and should only meet the very minimal definition of entry. However, it is natural that at any given time the brewer might want to pop his head inside the vat to inspect the cleanliness of the vat.  But, does the employer need to create a complete permit entry program? If the only hazard in the vat is the hazardous atmosphere and forced air ventilation alone can maintain the vat safe for entry, then the complete program need not be created [1910.146(c)(5)(i)].  Ultimately, the employer must develop monitoring and inspection data that supports the demonstrations that the space is safe for occupancy using forced-air ventilation.

I hope this was informative.  Thanks for reading! Please share my blog with others.