Safety Tidbit 3.27 - Commercial Safety Cans

Safety Tidbit 3.27 – Commercial Safety Cans

Reference:       OSHA Flammable Liquids – 1910.106

                        OSHA Flammable Liquids – 1926.152

                        OSHA Letter of Interpretation - 1996

An interesting question came up at a job site this week about the use of safety cans for gasoline. Where I was I found an old can with a broken top that was duct tape together. I told the employer to get rid of the can and get a new can that meets the OSHA requirements: “Safety can shall mean an approved container, of not more than 5 gallons capacity, having a spring-closing lid and spout cover and so designed that it will safely relieve internal pressure when subjected to fire exposure. [1910.106(a)(29)]” The client asked me if the plastic containers that you can buy at any home improvement or hardware store would be acceptable. I was on a general industry site, however the question made me wonder if it was the same for construction sites.

The OSHA Construction Standard 1926.152(a)(1) states “only approved containers and portable tanks shall be used for storage and handling of flammable liquids. Approved safety cans or Department of Transportation approved containers shall be used for the handling and use of flammable liquids in quantities of 5 gallons or less, except that this shall not apply to those flammable liquid materials which are highly viscid (extremely hard to pour), which may be used and handled in original shipping containers. For quantities of one gallon or less, the original container may be used, for storage, use and handling of flammable liquids.”

Luckily, back in 1996, someone asked about this issue and OSHA wrote a letter of interpretation.

“By its terms, §1926.152(a)(1) requires the use of an approved metal safety can (approved by a nationally recognized testing laboratory) for the handling and use of flammable liquids. Further, a safety can by definition is a container with a capacity of 5 gallons or less and equipped with a spring-closing lid and spout cover, a means to relieve internal pressure, and flash-arresting screen. However, we believe that DOT approved containers of 5 gallon capacity or less, although not meeting these requirements, pose very little hazard and meet the basic intent of the standard. Consequently, we have decided to exercise prosecutorial discretion and consider employer use of DOT approved containers of 5 gallon capacity or less for storage, use, and handling of flammable and combustible liquids to be de minimis noncompliance which should not be cited. “

This interpretation was written in 1996. I think the employers can afford an approved metal safety can versus a plastic one from Lowes or Home Depot. Actually, I’ve seen the metal cans right next to the plastic ones so why not get the right item to begin with?

Hope this was helpful and thanks for reading my Safety Tidbits! Comments and questions are always welcome. ~ Bryan

P.S. If you have an interesting safety or health question please let me know.

Safety Tidbit 3.26 - Fall Protection on Truck Trailers

Safety Tidbit 3.26 – Fall Protection on Truck Trailers

Reference:       1910.28 – OSHA Walking Working Surfaces

                        OSHA 2007 Letter of Interpretation

I attended the OSHA 501 course this week. This is the certification course enabling me to teach the OSHA 10- and 30- hour outreach training classes. There was a discussion about the new walking-working surfaces standard. OSHA’s definition is Walking-working surface means any horizontal or vertical surface on or through which an employee walks, works, or gains access to a work area or workplace location. The top of a semi-truck bed seems to fit that definition. Thus, the discussion began since some folks have trucks that move supplies from a warehouse to a job site.

1910.28(a) requires: “employers to provide protection for each employee exposed to fall and falling object hazards. Unless stated otherwise…” Now on the Construction side in 1926 OSHA gives a specific exemption for trucks [1926.500(b)(2)]. However, in General Industry the exemptions include:

·       Portable ladders;

·       When employers are inspecting, investigating, or assessing workplace conditions or work to be performed prior to the start of work or after all work has been completed. This exemption does not apply when fall protection systems or equipment meeting the requirements of 1910.29 have been installed and are available for workers to use for pre-work and postwork inspections, investigations, or assessments;

·       Fall hazards presented by the exposed perimeters of entertainment stages and the exposed perimeters of rail-station platforms;

·       Powered platforms covered by 1910.66(j);

·       Aerial lifts covered by 1910.67(c)(2)(v);

·       Telecommunications work covered by 1910.268(n)(7) and (8); and

·       Electric power generation, transmission, and distribution work covered by 1910.269(g)(2)(i).

We could not find a letter of interpretation on the topic. Therefore, the take home message became, if you have trucks that move supplies from a warehouse or other storage location, that falls under General Industry standards, and the workers working on/from the trucks are 4 feet or more above the ground, they must be protected from falling by one or more of the following:

·       Guardrail systems;

·       Safety net systems; or

·       Personal fall protection systems, such as personal fall arrest, travel restraint, or positioning systems.

However, once on the construction site the employer is exempt from having to protect them from falling.

Hope this was helpful and thanks for reading my Safety Tidbits! Comments and questions are always welcome. ~ Bryan

P.S. If you have an interesting safety or health question please let me know.

Safety Tidbit 3.25 - Flushing of Eyewashes

Safety Tidbit 3.25 – Flushing of Eyewashes

Reference: OSHA Factsheet on Eyewashes

What do you do when something splashes into your eyes at work?  SCREAM! Well, hopefully, you go to the eyewash, and a fellow worker is there to help you flush out your eyes (or better yet, your fellow worker enables you to get to the eyewash.  I have written a few Safety Tidbits about eyewashes specifically about the flow rate, distance to an eyewash (10-second rule), and having temperate water.

This week I saw two occurrences where the plumbed in eyewashes were covered with dust and looked horrible. I asked when the last time they had been flushed the representatives had no idea. I explained that the good the bad and the ugly of what might be lurking in their eyewash.

Water found in improperly maintained eyewash stations is more likely to contain organisms (e.g., Acanthamoeba, Pseudomonas, Legionella) that thrive in stagnant or untreated water and are known to cause infections. When a worker uses an improperly maintained eyewash station, organisms in the water may come into contact with the eye, skin, or inhaled.

Eyewash station manufacturer instructions provide direction on how often and how long to activate specific plumbed systems to reduce microbial contamination and reference the American National Standards Institute (ANSI) standard Z358.1-2014. Employers should consult the manufacturer’s instructions for the required maintenance procedures of self-contained eyewash units. Maintenance includes flushing the system and using only solutions appropriate for flushing eyes.

Ultimately, after I talked to the safety representative and a few of the workers about the good, the bad and the ugly of contaminated eyewashes, they walked directly over to the eyewashes and turned them on. I guess they understood.

Hope this was helpful and thanks for reading my Safety Tidbits! Comments and questions are always welcome. ~ Bryan

P.S. If you have an interesting safety or health question please let me know.

Safety Tidbit 3.24 - Spray Booth Ventilation

Safety Tidbit 3.24 – Spray Booth Ventilation

Reference: Spray Finishing using Flammable and Combustible Materials

Lately, it seems that I have been noticing spray booths with a build-up of overspray. As I look closer at spray booths, I find insufficient ventilation, poor paint application practices, or just too many parts for the size booth. I can talk to the painter about their practices and help with the client’s flow of materials through the enclosure to reduce the paint overspray problem. However, what concerns me is when there is an insufficient airflow in the booth. Lack of ventilation is a potential health concern.

How many of you have seen a spray booth when turned on the motor makes a lot of noise, but there is only a negligible movement of air? Or, the airflow is out of the booth versus into it? Minimally, OSHA [1910.107(b)(5)(i)] requires “spraying operations shall be so designed, installed and maintained that the average air velocity over the open face of the booth (or booth cross section during spraying operations) shall be not less than 100 linear feet per minute.” So, naturally, I ask the question “when was the last time you checked the airflow for the booth?” Unfortunately, I usually get blank stares.

Next, I ask, is the booth equipped with a gauge? The second part of the minimum OSHA standard requires “visible gauges or audible alarm or pressure activated devices shall be installed to indicate or ensure maintenance of the required air velocity.” Often, I got a nod and shown a manometer on the side of the booth. Sometimes, they even have it marked with a note telling the worker to change filters when the pressure reaches a certain level. Unfortunately, there is no indication on the gauge telling them when the booth is operating correctly. I have seen indicators that register zero (meaning no change in static pressure across the filters) when the enclosure is in operation. If there is no change in static pressure across the filters are the filters doing their job?

A better design would be to have a vaneometer installed in addition to the manometer, so airflow can quickly and accurately be determined. Furthermore, periodically performing a thorough evaluation of the airflow across the entire cross-section of the booth is a prudent practice. An industrial hygienist can help out with this. Ultimately, if the client complies with the last part of the OSHA standard “filter rolls shall be inspected to ensure proper replacement of filter media” the airflow should be even across the booth opening. Provided they don’t have “stuff” blocking the airflow. Hmm, never saw that either…J

Hope this was helpful and thanks for reading my Safety Tidbits! Comments and questions are always welcome. ~ Bryan

P.S. If you have an interesting safety or health question please let me know.