Safety Tidbit 3.36 - Exit Routes

Safety Tidbit 3.36 – Exit Routes

Reference:      OSHA Means of Egress

                        OSHA Fact Sheet – Emergency Exit Routes

OSHA states: “The number of exit routes must be adequate.” Next, they say “at least two exit routes must be available in a workplace to permit prompt evacuation of employees and other building occupants during an emergency. The exit routes must be located as far away as practical from each other so that if one exit route is blocked by fire or smoke, employees can evacuate using the second exit route.” [1910.36(b)(1)]

This all makes perfect sense however, what happens when our client leases the space and it only has one exit and the only other exits are out through the adjacent areas of the building which are leased by other tenants? Furthermore, our client happens to only have 5 employees. OSHA does permit a single exit route where the number of employees, the size of the building, its occupancy, or the arrangement of the workplace is such that all employees would be able to evacuate safely during an emergency. Unfortunately, our client has an office space by the entrance (the only fire exit) and at the other end of their space they have a high hazard operation as well as all through-out their space there are potential flammables and other hazards.

Interestingly, OSHA goes on to require “exit routes must be arranged so that employees will not have to travel toward a high hazard area, unless the path of travel is effectively shielded from the high hazard area by suitable partitions or other physical barriers.”  Furthermore, “Exit routes must be free and unobstructed. No materials or equipment may be placed, either permanently or temporarily, within the exit route. The exit access must not go through a room that can be locked, such as a bathroom, to reach an exit or exit discharge, nor may it lead into a dead-end corridor. Stairs or a ramp must be provided where the exit route is not substantially level.” Also, “if the direction of travel to the exit or exit discharge is not immediately apparent, signs must be posted along the exit access indicating the direction of travel to the nearest exit and exit discharge.”

So how do I advise my client to get a second exit? As an interim protective measure, our client must specify the emergency exit route through the part of the building they do not lease and ensure it is readily labeled and unobstructed. Our client must coordinate with the other tenants and ensure all hazards are removed from the route and that the route remains open. They need to make routine and random inspections to validate the exit route through the spaces they do not control are functional. Lastly, our client must train the employees and practice the use of the exit route as part of the emergency action plan. As a permanent fix to our dilemma, I recommended they speak to the landlord about installing a new exit in the area that our client leases, so the employees can readily evacuate if the need arises. Ultimately, the client needs to refer to NFPA 101 – Life Safety Code.

Hope this was helpful and thank you 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 3.35 - Consumer Product Labeling

Safety Tidbit 3.35 – Consumer Product Labeling

Reference:      OSHA Hazard Communication Standard

The funny thing about writing standards, there always seems to be at least two ways to approach the same item. I recently visited an employer that manufactures paints. They batch mix the specific colors using a recipe and then package the paints in various containers and tubes. These various tubes and bottles are then sold retail to artists all over the world. You can imagine the consumer labeling nightmare these folks have with all the different languages and country requirements. However, as I was touring the facility, I notice a whole room with cabinets full of 2-4-ounce bottles with numbers on them. Each bottle containing a sample of a batch that they created. The employer explained that they keep a sample just in case a client requests a future run and does not have any of their old paint left.

So, in accordance with OSHA’s Hazard Communication standard is a batch number that corresponds to an ingredient list sufficient? Or, do they need to label every container in storage? I initially thought well maybe they’re exempt as 1910.1200(b)(5)(v) states: “Any consumer product or hazardous substance as those terms are defined in the Consumer Product Safety Act (15 U.S.C. 2051 et seq.) and Federal Hazardous Substances Act (15 U.S.C. 1261 et seq.) respectively, when subject to a consumer product safety standard or labeling requirement of those Acts, or regulations issued under those Acts by the Consumer Product Safety Commission.”  This would seem to apply to their tubes and bottles they are shipping out but not the sample bottles. Paragraph 1910.1200(f)(6)(ii) states: “Product identifier and words, pictures, symbols, or combination thereof, which provide at least general information regarding the hazards of the chemicals, and which, in conjunction with the other information immediately available to employees under the hazard communication program, will provide employees with the specific information regarding the physical and health hazards of the hazardous chemical.” This might work if the employer put the basic hazard information (e.g., pictograms) and had the SDS readily available. Unfortunately, most containers only had the cryptic batch number hand-written on the bottles. Also, the SDSs were not readily available (that was another issue I cited). Since this company already was well acquainted with labeling of their containers they decided to put the appropriate information as required by 1910.1200(f)(6)(i) including the Product identifier; Signal word, Hazard statement(s), Pictogram(s), Precautionary statement(s), and the Name, address, and telephone number of the chemical manufacturer, importer, or other responsible party on each container. Furthermore, they are looking at a way to incorporate as much information onto their consumer labels so their products are safer going out into the marketplace whether that be a home or a business. Considering they ship world-wide I think my visit has impacted a lot of people.

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 3.34 - Cord Repair

Safety Tidbit 3.34 – Cord Repair

Reference: OSHA Letter of Interpretation dated September 9, 1997 to Mr. Yotz

I received an email yesterday out of blue from one of my better client’s asking:

“Is it ok/legal for my maintenance folks to repair broken plugs on cords or tools? How about replacing a damaged cord on a tool or fan? Our maintenance guys have been to electrical courses.”

This client was in general industry (vs. Construction) so we’ll only look at OSHA’s General Industry standards.

As OSHA states in their 1997 Letter of Interpretation, “Under paragraph 1910.303(a), electrical conductors and equipment are acceptable for use in the workplace only if approved. An electrical appliance which is certified by a NRTL is considered to be approved by the Occupational Safety and Health Administration (OSHA) as long as it is used in accordance with the condition(s) of NRTL certification.” However, the letter later states: “Repair or replacement of the flexible cord is required when the outer jacket is penetrated or the conductors or their insulation, inside are damaged. Flexible cord not less than No. 12 American Wire Gauge (AWG) may be repaired by splicing the conductors with a suitable vulcanized or molded splice. Please note that removing a damaged section of a flexible cord on an appliance and installing an attachment plug and a cord connection on the two ends would not be allowed. Such a repair would result in an extension cord between the flexible cord of the appliance and the installed building receptacle. Under paragraph 1910.305(a)(2)(i), this extension cord would be considered temporary wiring which is not permitted for workplace use.”

Looking at this problem from a liability angle and the latter part of my client’s email message, if someone is injured because the piece of equipment fails due to the repair who is responsible for the injury - the manufacturer, the employer, or the maintenance person (who has been to electrical courses)? The employer will be responsible. My take - is the piece of equipment so expensive that repairing it is better than replacing it? If so, get the manufacturer representative to repair it so the liability if it fails falls back on them and not you. Otherwise, discard the piece of equipment and buy a new one. And, oh by the way, do an investigation to learn why the piece of equipment became broken in the first place.

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 3.33 - Respirable Dust

Safety Tidbit 3.33 – Respirable Dust

Reference:      OSHA Respirable Crystalline Silica Standard

                        Thoracic and respirable particle definitions for human health risk assessment

This week I attended the Central PA Safety Conference at the Nittany Lion Inn in State College. This local venue conference is always fun as I get to see friends that I may not have seen in a while but more importantly, the conversations and networking that happens. A few of us were discussing sampling for respirable crystalline silica and I mentioned that we a PA OSHA use the aluminum SKC cyclone, but I am looking at other means that have a higher flow rate to accommodate specific short duration task evaluation. The discussion led to a few other particle samplers then the everyone paused when one asked if OSHA will accept the newer sampling methods.

I pulled up the OSHA website to see what guidance was available in the standard. Luckily, the answer was easy to find. In the definitions section of the RCS standard OSHA specifies: “Respirable crystalline silica means quartz, cristobalite, and/or tridymite contained in airborne particles that are determined to be respirable by a sampling device designed to meet the characteristics for respirable-particle size-selective samplers specified in the International Organization for Standardization (ISO) 7708:1995: Air Quality-Particle Size Fraction Definitions for Health-Related Sampling.” Therefore, if the method meets the ISO 7708-1995 specifications for respirable-particle samplers we’re golden (and of course, you must use the sampler the way the manufacturer demands).

After a quick internet search for the samplers, all the samplers we were discussing met the ISO 7708-1995 requirements. Remember, sampling for respirable dust requires the pump to calibrated to the specified airflow (e.g. 1.7, 2.2, 2.5, 4, 8 liters per minute) so the dust collected meets the aerodynamic diameter. OSHA typically will use the Dorr-Oliver nylon cyclone with a median cut point of 3.5 microns however the SKC cyclone’s cut point is 4 microns. Both meet the ISO 7708:1995 requirements but the SKC cyclone results tends to be a bit more protective as they collect a slightly larger sample size. The next problem: can you find a pump that will pull enough air and can still be worn by the worker.

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.