Safety Tidbit #2.28 – Is that respirator really working?

Safety Tidbit #2.28 – Is that respirator really working?

Sources:          OSHA Respirator Standard 1910.134

In the control of those occupational diseases caused by breathing air contaminated with harmful dusts, fogs, fumes, mists, gases, smokes, sprays, or vapors, the primary objective shall be to prevent atmospheric contamination. This shall be accomplished as far as feasible by accepted engineering control measures (for example, enclosure or confinement of the operation, general and local ventilation, and substitution of less toxic materials). When effective engineering controls are not feasible, or while they are being instituted, appropriate respirators shall be used pursuant to this section. [1910.134(a)(1)]

A respirator shall be provided to each employee when such equipment is necessary to protect the health of such employee. The employer shall provide the respirators which are applicable and suitable for the purpose intended. The employer shall be responsible for the establishment and maintenance of a respiratory protection program, which shall include the requirements outlined in paragraph (c) of this section. The program shall cover each employee required by this section to use a respirator. [1910.134(a)(2)] The program must include the following:

·      Procedures for selecting respirators for use in the workplace

·      Medical evaluations of employees required to use respirators

·      Fit testing procedures for tight-fitting respirators

·      Procedures for proper use of respirators in routine and reasonably foreseeable emergency situations

·      Procedures and schedules for cleaning, disinfecting, storing, inspecting, repairing, discarding, and otherwise maintaining respirators

·      Procedures to ensure adequate air quality, quantity, and flow of breathing air for atmosphere-supplying respirators

·      Training of employees in the respiratory hazards to which they are potentially exposed during routine and emergency situations

·      Training of employees in the proper use of respirators, including putting on and removing them, any limitations on their use, and their maintenance

·      Procedures for regularly evaluating the effectiveness of the program.

The employer shall select respirators from a sufficient number of respirator models and sizes so that the respirator is acceptable to, and correctly fits, the user. [1910.134(d)(1)(iv)]

[1910.134(g)] requires employers to establish and implement procedures for the proper use of respirators. These requirements include prohibiting conditions that may result in facepiece seal leakage, taking actions to ensure continued effective respirator operation throughout the work shift. For instance, the employer shall not permit respirators usage by employees who have:

·      Facial hair that comes between the sealing surface of the facepiece and the face or that interferes with valve function; or

·      Any condition that interferes with the face-to-facepiece seal or valve function.

The employer must ensure that employees perform a user seal check each time they put on the respirator. In short, once the employer determines a respirator is needed and requires its use they must ensure the workers use them properly.

My recommendation is that each time you see a respirator being used, ask the user to remove respirator, take a close look at it, then ask them to put it back on and watch what they do. Most simply, ensure the positive and negative fit checks are good or they are out of compliance with the standard and the workers are being exposed to the chemical in question.

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

Safety Tidbit #2.27 – Forklift Attachments

Safety Tidbit #2.27 – Forklift Attachments

Sources:          OSHA Powered Industrial Truck Standard (1910.178)

                        OSHA Letter of Interpretation dated April 11, 1997

On occasion, while touring job sites, I notice various attachments for use on the company forklift. I understand the need for them as they extend the use of the forklift. I have seen attachments for picking up workers to handling long rolls of product or materials. Usually, I find them tucked back in a corner, but on occasion, their use is in plain sight while I am there. On examination, the attachments appear to be well made and sturdy.  Sometimes, they are even powder coated with decals, although most attachments are homemade contraptions made for a particular application.

When I ask the employer if forklift manufacturer has approved the attachment for use with their forklift? Remember the employer is to train the worker on the safe and proper use of the forklift in accordance with the manufacturer’s requirements. Unfortunately, the typical responses include “Does it have to be?” or “We use it infrequently” or “We have not had any problems in the past.” OSHA’s Powered Industrial Truck standard [1910.178(a)(4)] states:

“Modifications and additions which affect capacity and safe operation shall not be performed by the customer or user without manufacturer's prior written approval. Capacity, operation, and maintenance instruction plates, tags, or decals shall be changed accordingly.”

Furthermore, OSHA as written several letters of interpretation about this circumstance the oldest letter is from 1997. You can imagine the reluctance of many forklift manufacturers to grant authorization to use an attachment on their forklift. I wish to share the response from the letter’s second question:

“With regard to compliance with 1910.178(a)(4), employers must seek written approval from powered industrial truck manufacturers when modifications and additions affect the capacity and safe operation. However, if no response or a negative response is received from the manufacturer, OSHA will accept a written approval of the modification/addition from a Qualified Registered Professional Engineer. A Qualified Registered Professional Engineer must perform a safety analysis and address any safety and/or structural issues contained in the manufacturer’s negative response prior to granting approval. Machine data plates must be changed accordingly.”

Another subtler point, I had a client with a personnel carrier cage made by the forklift company. It even had company logo decals on it. However, the rating for the forklift did not include personnel carrier use. In fact, the forklift the company had prohibited the specific forklift from personnel carrier use as was written right in the owner’s manual. Ultimately, if you are going to use an attachment on your forklift, get approval first.

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

Safety Tidbit #2.26 – Focus Four

Safety Tidbit #2.26 – Focus Four

Sources:           OSHA Construction Focus Four Training

 

Falls, Caught-in or Between, Struck-by, and Electrocution, the four leading killers on Construction Sites. Region 3 has started a campaign in an attempt to reign in these hazards. However, these have been the Focus Four for about ten years now. And actually, OSHA has been focusing their inspections on construction sites to those areas for nearly that long.  

Falls – any time a construction worker working six feet up requires protection from falling.  However, also, think about stairs, or any uneven walking surfaces. All can lead to falling and injury or even death.

Caught-in or Between – this could be machine guarding and getting caught in a belt or pulley system. Or, it could be a trench cave-in. Or, how about being caught between two loads of supplies moved by a forklift or a crane.

Struck-by – This hazard is sometimes similar to Caught-in or Between listed above. However, being struck by a moving vehicle, fly-debris or suspended loads are good examples. One that you might not think of as a struck-by hazard is nails from nail guns. Used extensively in residential construction.

Electrocution – Openings on junction boxes, breaks in the wiring, missing ground pins, working too closely or on electrical wires. These all seem to be obvious and easy to identify.

Easy right?! So why are these four hazards still killing workers and more so why after all this time does OSHA’s Region 3 feel it necessary to have a campaign for them?  Simple isn’t it? Workers need awareness of the hazard and a method to control the risk. No kidding, so are there ways to reduce the incidence of falls, getting caught in or between moving objects or not getting electrocuted? Sure there are! More to the point why aren’t these controls being used? Easy, everyone is in a rush to get the job done no time to pay attention to the job site. Profit! Profit! Profit! – Time is money!  

To help with this several years ago, I put together a mini site risk assessment conducted by the workers. See my Safety Tidbit #22 (back then safety brief) from December 2015 titles Take 5 – Stay Alive! I just wanted the workers to take five minutes at the start of the day, job, or task and discuss the hazards and how they were controlling it. 

Many companies pride themselves on conducting Toolbox Talks. I go onto a job site and ask about their training they show me these nicely printed sheets from all different vendors. But when I ask the workers what was on the sheet most (pretty much all of them) could not tell me. Not to mention their ability to internalize the information and realize how it may be important to them specifically.

Bottom line, construction workers are still getting killed by four common foes. We need to take 5 minutes to think about what could hurt us and how to reduce or eliminate the risk. Especially starting with these four hazards: Falls, Caught-in or Between, Struck-by, and Electrocution.

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

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