Safety Tidbit #2.25 - Lead Control

Safety Tidbit #2.25 – Lead Control

Sources:           OSHA Lead Control Standard 1910.1025

OSHA’s Standard on Lead came about in 1996. Just about since that time they have had a National Emphasis Program to gain access to work sites to enforce this standard. The national emphasis program persists to this day. First, lead is not very prevalent in the workplace anymore. However, if it identified a few initial items must be in place. Let’s review the basics that must be in place once you have identified that lead is present

1. The employer shall assure that no employee is exposed to lead at concentrations greater than fifty micrograms per cubic meter of air (50 µg/m³) averaged over an 8-hour period. [1910.1025(c)(1)]

2. Monitoring for the initial determination may be limited to a representative sample of the exposed employees who the employer reasonably believes are exposed to the greatest airborne concentrations of lead in the workplace. [1910.1025(d)(3)(ii)]

3. If workers are exposed to lead above the PEL for more than 30 days per year exposures must be reduced using engineering and administrative controls. [1910.1025(e)(1)(i)] However, prudently I recommend reducing to below the Action Level (0.030 mg/m3) and always reduce the exposure even if it’s for less than 30 days per year.

4. Anytime the exposure is above 50 µg/m³ (the PEL and prudently the action level 30 µg/m³) you need to supplement any controls with respiratory protection. [1910.1025(e)(2)] This means implementing a whole respiratory protection program. Yes, more standards to follow!

Next is the real kicker.

5. If you have the lead exposure you must establish and implement a written compliance program to reduce exposures to or below the permissible exposure limit, and interim levels if applicable, solely using engineering and work practice controls. [1910.1025(e)(3)(i)]

The Written must include at least the following:

·       A description of each operation in which lead is emitted; e.g. machinery used, material processed, controls in place, crew size, employee job responsibilities, operating procedures and maintenance practices;

·       A description of the specific means that will be employed to achieve compliance, including engineering plans and studies used to determine methods selected for controlling exposure to lead;

·       A report of the technology considered in meeting the permissible exposure limit;

·       Air monitoring data which documents the source of lead emissions;

·       A detailed schedule for implementation of the program, including documentation such as copies of purchase orders for equipment, construction contracts, etc.;

·       A work practice program which includes items required under paragraphs (g), (h) and (i) of this regulation;

·       An administrative control schedule required by paragraph (e)(6), if applicable;

·       Written programs shall be submitted upon request to the Assistant Secretary and the Director and shall be available at the worksite for examination and copying by the Assistant Secretary, Director, any affected employee or authorized employee representatives.

·       Written programs must be revised and updated at least annually to reflect the current status of the program. This part is often neglected.

When ventilation is used to control exposure, measurements which demonstrate the effectiveness of the system in controlling exposure, such as capture velocity, duct velocity, or static pressure shall be made at least every 3 months. [1910.1025(c)(4)(i)] You know, once you put ventilation in place and quantitatively document that it is effectively controlling exposure to below the PEL (and really the Action Level and for more safety-minded companies below 10% of the PEL) a Magnehelic gauge can be installed for continual monitoring. This will exceed the every 3-months monitoring required by this section.

Hope this was helpful and thanks for reading my Safety Tidbits ~ Bryan

Safety Tidbit #2.24 – What falls under Process Safety Management

Safety Tidbit #2.24 – What falls under Process Safety Management

Sources:           OSHA Process Safety Management of highly hazardous chemicals

            1910.119, Appendix A

OSHA’s Process Safety Management of highly hazardous chemicals standard (1910.119) applies to all processes involving chemicals in Appendix A of the standard and for flammable materials (flashpoint less than 100 degrees Fahrenheit) in excess of the 10,000 pounds. Appendix A lists about 150 chemicals with applicable reportable quantities at which point the Standard kicks in. So how do you know if the employer has a chemical that falls under OSHA’s Process Safety Management standard?

First, the most common chemical from the list is ammonia as this is used for industrial refrigeration. If your client has a refrigerated facility or warehouse always ask about the refrigerant. If they use ammonia, ask how much their system uses. I have found facilities that started with one unit and did not fall under the standard but after they grew they added a second system and now exceed the 10,000-pound threshold onsite. Also, I have had clients that use diesel fuel in their product (e.g. roofing products) and have in large tanks to feed their process. They exceed the 10,000-pound threshold however the flashpoint of diesel fuel is greater than 100 degrees Fahrenheit.

A couple of good rules of thumb are, as you drive up to the facility, if you see tanks outside with process materials ask what the contents are and verify against Appendix A. If they have large tanks outside they may have enough chemical to exceed the threshold limits. Second, once inside the facility, if there is piping inside moving process chemicals around the facility ask what is in the piping and again verify against the list. Most likely if the employer is piping the chemical around they do not wish to handle it any more than necessary which is a good indicator that the chemical is not very nice.

Ultimately, use of the principles of PSM is just a robust hazard assessment so following the requirements of PSM is never a bad idea. So whether required or not everyone should:

·      understand the hazards of the chemicals that are used,

·      how to maintain the engineering controls to ensure proper functioning.

·      how to safely handle the chemicals

·      how to protect themselves from exposure

·      how to render aid if exposure happens

·      how to respond if a spill occurs

Hope this was helpful and thanks for reading my Safety Tidbits ~ Bryan

Safety Tidbit #2.23 - Synthetic Web Slings

Safety Tidbit #2.23 – Synthetic Web Slings

Source:            (a) OSHA’s Guidance on Safe Sling Use

                        (b) OSHA Materials Handling – Slings 1910.184

Most every industrial and many commercial sites I visit are involved in moving materials or products. Equipment such as powered industrial trucks, cranes, hoists, and derricks are used to aid in the movement of materials (especially large, bulky, or heavy loads). These types of equipment use slings to hold their suspended loads. Often these activities lead to injuries and most can be avoided by using safe materials handling practices. To avoid sprains, strains, muscle pulls or more severe injuries including death, whenever possible, ensure that safe mechanical means are used to move heavy, bulky objects.
I oftentimes see synthetic web slings. These slings are made of nylon- or polyester-type yarns. They strong, convenient, provide load protection and are economical.

Each employer that uses slings must designate a qualified person to inspect slings each day before use for damage or defects [1910.184(d)]. Although OSHA's sling standard does not require you to make and maintain records of inspections, the ASME standard contains provisions on inspection records. Make a thorough inspection of slings and attachments. Items to look for include:

• Missing or illegible sling identification,
• Acid or caustic burns,
• Melting or charring of any part of the sling,
• Holes, tears, cuts, or snags,
• Broken or worn stitching in load bearing splices,
• Excessive abrasive wear,
• Knots in any part of the sling,
• Discoloration and brittle or stiff areas on any part of the sling,
• Pitted, corroded, cracked, bent, twisted, gouged, or broken fittings, and
• Other conditions that cause doubt as to continued use of a sling.

Where any such damage or deterioration is present, remove the sling or attachment from service immediately [1910.184(i)(9)]. And just a quick reminder all employees are to be kept clear of all loads about to be lifted and/or are suspended.  Also, keep hands and fingers out from between the sling and the load while tightening the load.

I hope this information was helpful and thanks for reading my Safety Tidbits ~ Bryan

Safety Tidbit #2.22 – Nine Steps to Help You with your Safety Program

Safety Tidbit #2.22 – Nine Steps to Help You with your Safety Program

Sources:          (a) Recommended Practices for Safety and Health Programs in Construction

Nine simple steps to help you get your safety and health program up and running:

1. Always set safety and health as the top priority – Tell your workers that making sure they finish the day and go home safely is the way you do business. Assure them that you will work with them to find and fix any hazards that could injure them or make them sick.

2. Lead by Example – Practice safe behaviors yourself and make safety part of your daily conversations with workers.

3. Implement a Reporting System – Develop and communicate a simple procedure for workers to report any injuries, illnesses, incidents (including near misses/close calls), hazards, or safety and health concerns without fear of retaliation. Include an option for reporting hazards or concerns anonymously.

4. Provide Training – Train workers on how to identify and control hazards.

5. Conduct Inspections – Inspect the job site with workers and ask them to identify any activity, piece of equipment, or material that concerns them. Use checklists and other resources to help identify problems.

6. Collect Hazard Control Ideas – Talk with workers about ideas on safety improvements throughout the project.

7. Implement Hazard Controls – Assign workers the task of choosing, implementing, and evaluating the solutions.

8. Address Emergencies – Identify foreseeable emergency scenarios and develop instructions on what to do in each case. Meet to discuss these procedures and post them in a visible location at the job site.

9. Make Improvements – Set aside a regular time to discuss safety and health issues, with the goal of identifying what to improve the program.

I hope this information was helpful and thanks for reading my Safety Tidbits ~ Bryan