Safety Tidbit 2.35 - Is a spray booth necessary?

Safety Tidbit 2.35 – Is a spray booth necessary?

Reference:       OSHA Letter of Interpretation July 14, 2009

                        OSHA Ventilation Standard (1910.94)

                        OSHA Spray Finishing of Flammable and Combustible materials 1910.107

A colleague recently asked me when is a booth necessary for spray painting operations? His example was that the employer periodically spray applies flammable paints (not aerosol cans) on signs and the back of large construction trucks. The operation lasts less than 15-20 minutes and uses a quart or less of paint at a time.

OSHA’s 1910.94(c)(2) states that spray booths or spray rooms are to be used to enclose or confine all spray finishing using organic or inorganic materials. Since the primary purpose of 1910.94(c) is to protect health, this is not a big deal if the appropriate PEL in Subpart Z of Part 1910 is not exceeded.

Therefore, if no OSHA PEL is exceeded during spray finishing operations, the operation falls under the OSHA standard at 1910.107. That standard does not have an enclosure provision like 1910.94(c) requiring that all spray finishing using flammable and combustible materials be confined to spray booths or spray rooms. However, the 1910.107(g)(1) requires that "[spraying shall not be conducted outside of predetermined spraying areas." Paragraph 1910.107(a)(2) defines a "spraying area" as "[any area in which dangerous quantities of flammable vapors or mists, or combustible residues, dusts, or deposits are present due to the operation of spraying processes." OSHA interprets "dangerous quantities of flammable vapors or mists" in 1910.107(a)(2), to be areas with concentrations exceeding 25% of the lower flammable limit (LFL) of any chemical used at any time during the spray finishing operations, without the benefit of ventilation required under the standard.

Example: To determine the lower explosive limits of the most common solvents used in spray finishing, see Table G-11 of 1910.94. Column 1 gives the number of cubic feet of vapor per gallon of solvent and column 2 gives the lower explosive limit (LEL) in percentage by volume of air. Note that the quantity of solvent will be diminished by the quantity of solids and nonflammables contained in the finish.

To determine the volume of air in cubic feet necessary to dilute the vapor from 1 gallon of solvent to 25 percent of the lower explosive limit, apply the following formula:

Dilution volume required per gallon of solvent =

4 X (100 - LEL) X (cubic feet of vapor per gallon) / LEL

Using toluene as the solvent.

1. LEL of toluene from Table G-11, column 2, is 1.4 percent.

2. Cubic feet of vapor per gallon from Table G-11, column 1, is 30.4 cubic feet per gallon.

3. Dilution volume required =

4 X (100 - 1.4) X 30.4 / 1.4 = 8,564 cubic feet/gallon.

4. To convert to cubic feet per minute of required ventilation, multiply the dilution volume required per gallon of solvent by the number of gallons of solvent evaporated per minute.

Therefore: If the operation uses one quart of paint over 15 minutes.

(0.25 gallons/15 minutes) = 0.0167gallons/minute or GPM

or in other words, one gallon will evaporate every approx. 60 minutes

5. 8,564 CF/gal X 0.0167 GPM = 143 CFM

However, 25 percent of the LEL or in our example above 1.4%/25 equals 0.056%. Converted to parts per million (PPM) is 0.056%X10,000=560 PPM. OSHA’s acceptable ceiling concentration for Toluene is 300 PPM and OSHA’s acceptable maximum peak above the acceptable ceiling concentration for an 8-hr shift is 500 PPM. All provided the total 8-hour time-weighted average stays below 200 PPM.

So back to the original question of whether a spray booth was necessary. More information is needed (SDS) and an industrial hygiene evaluation of the work area.

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

Safety Tidbit 2.34 – Exit Routes

Safety Tidbit 2.34 – Exit Routes

Reference: OSHA Means of Egress Standard 1910.36

Recently my visits have been at some pretty small locations. One was in a leased garage space in an industrial complex.  The owner opened the large overhead door to enter as well as let us in. He had to remove the two, panel trucks that were inside so we could meet. Once the trucks were out of the way, he promptly hit the button and shut the overhead door, as he said: “to keep the heat in.” As the door closed, I thought, now how do I get out of here in an emergency? There were no exit signs, and the two man-doors were either blocked or bolted shut. I thought this is a good topic for this week’s Safety Tidbit – What is an Emergency Exit?

First, an exit route must be a permanent part of the workplace and separated by fire resistant materials (a one-hour fire resistance rating is fine in most of my clients as they are just tiny spaces and one story). Here come the good parts:

The number of exits must be adequate. Typically, we like two doors in case fire blocks the first one. However, one is acceptable 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. For more information to help you determine the necessary number of exit routes check out NFPA 101.

Each of your exit discharges must be unlocked, able to open without any keys, tools, or specialized knowledge and they must lead directly outside or to a street, walkway, refuge area, public way, or open space with access to the outside. Here’s the kicker the exit door must be a side-hinged door. Therefore, the garage door in our opening example is not adequate. Another important point, the door that connects any high-hazard room to an exit route, must swing out in the direction of exit travel.

An exit route must meet minimum height and width requirements. The ceiling of an exit route must be at least seven feet six inches (2.3 m) high. Any projection from the ceiling must not reach a point less than six feet eight inches (2.0 m) from the floor. An exit access must be at least 28 inches (71.1 cm) wide at all points. Where there is only one exit access leading to an exit or exit discharge, the width of the exit and exit discharge must be at least equal to the width of the exit access. Furthermore, objects that project into the exit route must not reduce the width of the exit route to less than the minimum width requirements for exit routes.

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

Safety Tidbit #2.33 - Housekeeping

Safety Tidbit 2.33 – Housekeeping

Reference: OSHA Walking-Working Surfaces

My home office is my inspiration for this week’s Safety Tidbit. If you pan across my home office, you see piles of papers and books for various research projects on this topic or that. I have sampling equipment plugged into the walls and a computer, iPad, phone, etc. And that doesn’t include the whole other room with other sampling equipment that I have stored as excess for the department. And this is just my home office where there is no one else here but me.

As I looked around, I reflected on the worksites I have visited over the years, thinking why don’t they keep their workplaces tidier? Shoot, I can’t even keep my home office neat. How many accidents or near-miss incidents happen because the workplace is in disarray and there is “stuff” laying all around? OSHA’s revised Walking-Working Surfaces Standard (November 2016) specifies that the employer must keep all places of employment, passageways, storerooms, service rooms, and walking-working surfaces clean, orderly, and in sanitary condition [1910.22(a)(1)].

Specifically, the employer is to ensure the working surface:

•       is clean and dry [1910.22(a)(2)]

•       is maintained free of hazards such as sharp or protruding objects, loose boards, corrosion, leaks, spills, snow, and ice [1910.22(a)(3)]

•       can support the maximum intended load for that surface [1910.22(b)].

Additionally, the employer must regularly and as necessary inspect the walking-working surfaces to ensure they are maintained in a safe condition [1910.22(d)(1)]. And obviously, any hazardous conditions on walking-working surfaces must be corrected or repaired before an employee uses it again. Furthermore, if you cannot make the correction or repair immediately, the hazard must be guarded to prevent employees from using the walking-working surface until the hazard is corrected or fixed [1910.22(d)(2)].

I believe this standard may become my new best friend when I am out and about. If my clients just clean up their workplaces they would get rid of a lot of additional hazards (e.g., hazardous materials that have been around for years).

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

Safety Tidbit 2.32 – Special Emphasis Programs

Safety Tidbit 2.32 – Special Emphasis Programs

Reference: OSHA Field Operations Manual

In industries with potentially high injury or illness rates, OSHA coordinates custom inspections they call Special Emphasis Programs. SEPs are also based on potential exposure to health hazards. Special emphasis programs may also be used to develop and implement alternative scheduling procedures or other departures from national procedures. Special emphasis programs can include National Emphasis Programs, Regional Emphasis Programs and Local Emphasis Programs.

Below is a list of OSHA’s active National Emphasis Programs:

·      COMBUSTIBLE DUST      OSHA Instruction CPL 03-00-008 –

National Emphasis Program on Combustible Dust (Reissued) (Date: 03/11/2008)

·      HAZARDOUS MACHINERY       OSHA Instruction CPL 03-00-019 –

National Emphasis Program on Amputations (Date: 08/13/2015)

·      HEXAVALENT CHROMIUM      OSHA Instruction CPL 02-02-076 –

National Emphasis Program - Hexavalent Chromium (Date: 02/23/2010)

·      LEAD             OSHA Instruction CPL 03-00-009 –

National Emphasis Program on Lead (Date: 08/14/2008)

·      PRIMARY METAL INDUSTRIES          OSHA Instruction CPL 03-00-018 –

National Emphasis Program - Primary Metal Industries (Date: 10/20/2014)

·      PROCESS SAFETY MANAGEMENT     OSHA Instruction CPL 03-00-021 –

PSM Covered Chemical Facilities National Emphasis Program (Date:1/17/2017)

·      SHIPBREAKING     OSHA Instruction CPL 03-00-020 –

National Emphasis Program on Shipbreaking (Date: 03/07/2016)

·      SILICA          OSHA Instruction CPL 03-00-007 –

National Emphasis Program on Crystalline Silica (Date: 01/24/2008)

·      TRENCHING & EXCAVATION  OSHA Instruction CPL 02-00-069 –

Special Emphasis Program on Trenching and Excavation (Date: 9/19/1985)

Use of the Strategic Emphasis Programs gives OSHA probable cause to enter your company. Remember, the employer always has the right to request a warrant. However, requesting to see the emphasis program to understand why OSHA wishes to inspect your workplace and then reducing their scope to the nature of the emphasis program is prudent. Ultimately, OSHA only wishes to ensure the safety and health of the workers, not to make the employer’s life miserable.

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

Safety Tidbit 2.31 – Training for Bloodborne Pathogens Program

Safety Tidbit 2.31 – Training for Bloodborne Pathogens Program

Reference:       OSHA Bloodborne Pathogens Standard

For all workers with occupational exposure to bodily fluids, the employer shall train each employee as per the OSHA Bloodborne Pathogens Standard. Such training must be provided at no cost to the employee and during working hours. The employer shall institute a training program and ensure employee participation in the program [1910.1030(g)(2)(i)].

Accomplish training at the time of initial assignment to tasks where occupational exposure may take place and at least annually after that. Provide annual training for all employees within one year of their previous training. Additionally, when there are modifications of task or procedures that affect occupational exposures, new training must be completed. Furthermore, perform all training in content and vocabulary appropriate to the workers (e.g., educational level, literacy, etc.).

OSHA dictates the following minimum elements:

·      An accessible copy of the regulatory text of this standard and an explanation of its contents;

·      A general explanation of the epidemiology and symptoms of bloodborne diseases;

·      An explanation of the modes of transmission of bloodborne pathogens;

·      An explanation of the employer's exposure control plan and how the employee can obtain a copy of the written plan;

·      An explanation of the appropriate methods for recognizing tasks and other activities that may involve exposure to blood and other potentially infectious materials;

·      An explanation of the use and limitations of methods that will prevent or reduce exposure including appropriate engineering controls, work practices, and personal protective equipment;

·      Information on the types, proper use, location, removal, handling, decontamination and disposal of personal protective equipment;

·      An explanation of the basis for selection of personal protective equipment;

·      Information on the hepatitis B vaccine, including information on its efficacy, safety, method of administration, the benefits of being vaccinated, and that the vaccine and vaccination will be offered free of charge;

·      Information on the appropriate actions to take and persons to contact in an emergency involving blood or other potentially infectious materials;

·      An explanation of the procedure to follow if an exposure incident occurs, including the method of reporting the incident and the medical follow-up that will be made available;

·      Information on the post-exposure evaluation and follow-up that the employer is required to provide for the employee following an exposure incident;

·      An explanation of the signs and labels and, if appropriate, color coding required by the standard; and

·      An opportunity for interactive questions and answers with the person conducting the training session.

Furthermore, the person conducting the training must be knowledgeable in the subject matter covered by the elements contained in the training program as it relates to the workplace that the training will address.

A final note, this standard is from 1992, and while HIV is still very much a problem, Hepatitis is waning due to childhood vaccines.  I recommend, if you work in a healthcare setting, you broaden the scope of the annually required training. Try including any new infectious diseases (e.g., avian flu, Ebola, TB, Zika Virus, etc.) and discuss that disease’s relationship to your worksite (identification, exposure, control).

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

Safety Tidbit 2.30 - Recording Hearing Loss on the OSHA 300 Form

Safety Tidbit 2.30 - Recording Hearing Loss on the OSHA 300 Form

Reference:       OSHA Recordkeeping Standard

                        OSHA Letter of Interpretation dated April 29, 2016

I figured another Safety Tidbit on Recordkeeping would not be bad as it is that time of year.  OSHA’s Recordkeeping standard in 1904.10(a) requires: “If an employee's hearing test (audiogram) reveals that the employee has experienced a work-related Standard Threshold Shift (STS) in hearing in one or both ears, and the employee's total hearing level is 25 decibels (dB) or more above audiometric zero (averaged at 2000, 3000, and 4000 Hz) in the same ear(s) as the STS, you must record the case on the OSHA 300 Log." Initially, you must ask, is the injury work-related? As defined by OSHA Recordkeeping Standards, an injury or illness is work-related if an event or exposure in the work environment either caused or contributed to the resulting condition or significantly aggravated a pre-existing injury or illness.

We usually presume work-relatedness for injuries and illnesses resulting from events or exposures occurring in the work environment [1904.5(a)]. If you are exposing the worker to noise levels more than 85 dBA for eight hours (or the adjusted amounts if you work shifts longer than eight hours), then you potentially caused or contributed to the hearing loss injury. Furthermore, an employer must determine their implementation of their hearing conservation program. In additional to assessing the level of protection of the worker's hearing protector, work related determination should also consider whether the given worker actually used the protection and the effectiveness of the employee training in wearing the protection.

A question arose this week whether to include the injury on the OSHA 300 log or not when the worker’s hearing level was already above 25 decibels. Remember what I put in above, the injury is work-related if work caused or contributed to the condition or significantly aggravated a pre-existing injury.  Since the worker was already impaired, as their hearing is above 25 dBA then a significant threshold shift is a further exacerbation of the condition or work conditions “significantly aggravated a pre-existing injury.”

Remember, the purpose of a hearing conservation program is to conserve hearing. If the worker continues to lose her/his hearing, then the program is not working properly.  Also, the purpose of the 300 log is to track and trend injuries so that you can make changes to reduce risk and therefore reduce injuries.  Lastly, as part of the hearing conservation program, once a worker has a loss of their hearing, as shown in the annual audiogram, certain specific follow-up is necessary (1910.95(g)(7)(iii)].

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

Safety Tidbit #2.29 – They all must add up

Safety Tidbit #2.29 – They all must add up

Sources:          OSHA Injury and Illness Recordkeeping Requirements

Well, it’s that time of year again when we all must post our Summary of Injury and Illnesses from the previous year or the OSHA 300A form [1904.32(a)(5)].  If you have been maintaining your log all year long, the summary is a piece of cake. Further, if you use the cool Excel or PDF versions, that OSHA has available, the Summary is created for you. However, you must verify your 300-log’s validity [1904.32(a)(2)], and after you create the Summary you must certify it [1904.32(a)(4)].

Recently I have noticed a few misunderstandings as to how to complete the OSHA 300A form.  Namely entries in Blocks G, H, I, and J for Number of Cases and, also the entries in the Injury and Illness Types in the six blocks for M. First, easy enough, the totals of Blocks G thru J must equal the totals in the M blocks.

Second, each injury only gets counted once.  Blocks G thru J are a continuum from most severe (Block G) to least severe (Block J). I use an analogy to illustrate how this might work. Consider a worker getting bit by a spider on their hand. At first, it’s just an annoyance the worker goes home and nothing but maybe cleaning out the wound and a Band-Aid. First aid only it’s not recordable and life goes on.  About Day Three, the bite site is getting red and puffy, so the employee heads to the doctor to get it checked out. Behold, the wound is infected, and the doctor prescribes some antibiotics.  It’s recordable now, right? Agreed, however, no loss time or change in work duties (Block J). Unfortunately, the employee isn’t too reliable about taking their medicine subsequently the bite site gets worse, and the wound keeps them from doing their regular duties (Block I).

Time moves on, and the worker’s hand gets worse and red lines start up their arms. They head back to the hospital and get admitted since now they have a serious infection and possibly gangrene. Now the worker is a lost time case (Block H). Also, don’t forget, a call to OSHA will be required since the hospital admitted the employee. Unfortunately, the worker’s constitution is not very good, and they end up dying in the hospital. Now, the case is a fatality (Block G), and if OSHA hasn’t come to your company, which they probably won’t, you need to call them again to let them know the worker died. Ultimately, the injury only gets listed once on the OSHA 300A and is listed in Block G as a death.

There are many such analogies and I’m sure you have a favorite one of your own. However, I hope this analogy illustrates how one injury ultimately is recorded as one fatality on the OSHA 300A form. Even though all the days transferred to other duties (Block L) or lost (Block K) are also captured.

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