Safety Tidbit 4.13 - Winter Driving Safety

Safety Tidbit 4.13 – Winter Driving Safety

Reference:       OSHA/NHTSA Winter Driving Safety

                        AAA Exchange – Winter Driving Tips

Well, it’s not quite Thanksgiving and the first snow of the season has hit. For my friends in central New York, around Syracuse, your snow machine has been turned on so look out. For those in Mechanicsburg, PA a few of you were stranded at your offices or almost caught in your cars trying to get home. One friend said a typical 30-minute commute took nearly five hours yesterday evening. Maybe I’m a little late however, I thought a quick look at emergency planning for snow driving might be in order.

OSHA and the National Highway Traffic Safety Administration (NHTSA) published a one-page Safe Winter Driving tips bulletin. Also, AAA has compiled a nice list of Winter Driving Tips on their Exchange website. OSHA and NHTSA promote the three P’s – Prepare, Protect, and Prevent.

Prepare – Plan your route and check, maintain your car, and my favorite practice. So, OSHA is advocating going out during daylight hours and doing donuts with your car to get a feel for how it responds?  Well not exactly but they do say go to an empty lot and steer into a skid. AAA advises to ensure your car is maintained properly and not leaving your tank drop below halfway.

Protect – Seatbelts! – Seatbelts! -- Seatbelts!! Children are to be in the back seat and appropriately buckled in. Cold weather gear or blankets should be in the car.

Prevent – Practice driving in the snow, don’t accelerate up hills or brake suddenly. Don’t drink alcohol and drive in wintery weather. Slow down and allow plenty of space between you and the car in front of you.

A few items you might consider for your winter emergency kit:

·      Hi-vis vest

·      Blanket(s)

·      Flashlight

·      Energy Bar

·      First Aid Kit

·      Cell phone (charged)

·      Portable power (charged)

·      Small shovel/scraper/car broom

·      Gloves/Hat/Boots

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

P.S. If you have a new safety or health question, please let me know.

Safety Tidbit 4.12 - PPE Assessment

Safety Tidbit 4.12 – PPE Assessment

Reference: OSHA 1910.132 – Personal Protective Equipment

This week’s Safety Tidbit comes from a text I received yesterday from an attorney. “Are PPE Assessments or their certifications due annually?” I replied “Quick answer No.” But then went on to validate my answer on the OSHA website.

Under OSHA’s General Industry Standards, Subpart I, Personal Protective Equipment 1910.132(d)(1): “The employer shall assess the workplace to determine if hazards are present, or are likely to be present, which necessitate the use of personal protective equipment (PPE). If such hazards are present, or likely to be present, the employer shall:”

And 1910.132 (d)(1)(2):  “The employer shall verify that the required workplace hazard assessment has been performed through a written certification that identifies the workplace evaluated; the person certifying that the evaluation has been performed; the date(s) of the hazard assessment; and, which identifies the document as a certification of hazard assessment.”

I don’t see where OSHA defines a frequency that the assessment must be reassessed. Going a little further, I took a look the respirator standard. Paragraph 1910.134(d)(1)(iii) states “The employer shall identify and evaluate the respiratory hazard(s) in the workplace; this evaluation shall include a reasonable estimate of employee exposures to respiratory hazard(s) and an identification of the contaminant's chemical state and physical form.” Again, I don’t see a frequency of reevaluation.

Interestingly, the respirator standard does have a provision in paragraph 134(l) for overall program evaluation which states “… requires the employer to conduct evaluations of the workplace to ensure that the written respiratory protection program is being properly implemented, and to consult employees to ensure that they are using the respirators properly.”

And further in the subsequent paragraph (1910.134(l)(1)) “The employer shall conduct evaluations of the workplace as necessary to ensure that the provisions of the current written program are being effectively implemented and that it continues to be effective.” The respirator standard does require annual fit-testing and training of respirator users, so it seems logical to conduct a program evaluation and ask users for their input on program effectiveness at that time. However, as you can see, OSHA does not explicitly require it annually.

If I was to hazard a guess, OSHA does not specify a frequency for reassessment or revaluation to keep the implementations cost down. Because each time they specify a frequency their economists must factor that in and it takes time and therefore money. After all, we are trying to reduce paperwork, aren’t we? But how OSHA determines the economic feasibility of their standards is a topic for a future Safety Tidbit.

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

P.S. If you have a new safety or health question, please let me know.

Safety Tidbit 4.11 - Prevention through Design

Safety Tidbit 4.11 – Prevention through Design

Reference: NIOSH PtD – Prevention through Design

Wouldn’t it be great if safety hazards could be eliminated during the design phase of a building? As an industrial hygiene consultant, I am always looking for ways to engineer out hazards at existing facilities. Often, I tour a facility right after it was completed. The owner, proactively, invites me in just before production was scheduled to get started to walk around and have a look. Unfortunately, everything is in place and making changes now is very difficult and costly. I usually commend them for thinking about their workers’ health and safety and then say if I had been brought in a just little bit earlier, I could have reviewed the construction plans and possibly (most likely) saved them energy (time and money) by assisting with the anticipation part of industrial hygiene and making recommendations for controls of the hazards.

This week, I was at the PA Governor’s Occupational Safety and Health Conference in Hershey. It was a great time, and hopefully, a few of our students can attend next year. Dr. Michael Toole, now at the University of Toledo as Dean for the School of Engineering presented on Prevention through Design or PtD. I knew Mike when he was a professor at Bucknell University where a few years ago we invited him to speak on the same topic at our much smaller conference at the Nittany Lion Inn. The Central PA Safety Association, along with the local sections of ASSE, and AIHA host a health and safety conference every spring. Dr. Toole described what PtD was and how it can save time and money (and lives) through the life of the structure. I was curious how this might work into my research on how to get employers to review their airborne hazards and minimize worker exposures without the use of personal protective equipment – namely respiratory protection. You see, I too was presenting at the conference on how employers assess your workplace for silica hazards and complete the Exposure Control Plan as required by the OSHA Respirable Crystalline Silica standard.

NIOSH has a national initiative “to prevent or reduce occupational injuries, illnesses, and fatalities through the inclusion of prevention considerations in all designs that impact workers.” Most of the examples that Dr. Toole used in his presentation involved ergonomic issues and incorporating anchorages into the design of the structure so that building the facility was safer and future maintenance workers had the means to connect their fall arrest systems.

During Professor Toole’s presentation, my thoughts ran to how we design the facility anticipating the airborne hazards and therefore protecting the workers before they ever set foot on the job? I don’t want the workers to have to use personal protective equipment which can be cumbersome and oftentimes, ineffective. Actually, the better question is how can I affect the decision-making process, so the employer uses their agency to protect their workers by taking charge of the hazard right from the start instead of relying on the workers’ proper use of personal protective equipment (again namely respirators)?

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

P.S. If you have a new safety or health question, please let me know.

Safety Tidbit 4.10 – Air Quality

Safety Tidbit 4.10 – Air Quality

What happens if you spill a container of paint stripper with xylene that you bought at Lowes or Home Depot? Alternatively, you applied the paint stripper on your kitchen cabinets that you are refinishing. Let’s do a little “back of the envelope” calculations. Scenario: Determine the final air concentration in ppm in a 18 ft x 25 ft x 9 ft space, say something like your garage . And say the space (garage) nominally has  five air changes per hour (your garage door is open). Assume after 30 minutes, 1-liter or about a quarter of your 1-gallon container of paint stripper spills and evaporates (or, you applied the stripper to your kitchen cabinets). After all, the manufacturer says it evaporates quickly and to use it in a well-ventilated area or outdoors.

We’ll assume that all of the stripper evaporates and diffuses rapidly within the space. However, in practice there will be areas of high concentration and areas of low concentrations based the configuration of the space. Now let’s go through the steps:

·      Determine the room volume in cubic feet (V). Answer - 4.050 ft3 or 114.696 m3

·      Convert the volume of xylene spilled into mass using specific gravity. Answer - 880 grams

·      Determine how many mg/m3 of xylene are in the air (Ci). Answer - 7,672 mg/m3

·      Next, using the Ideal Gas Law and the molecular weight, convert mg/m3 to ppm. Answer - 1770 ppm.

·      Calculate the air flow (Q), given 5 air changes per hour. Answer - 337.5 cfm.

·      Rearrange the steady-state formula and calculate the air concentration (C) after 30 minutes

Steady-state formula = or  C=Ci*〖0.5〗^((T/0.693)*(Q/Vr) )

Answer: 145 ppm

OSHA PEL = 100 ppm

I think a respirator may be in order or better yet engineer out the problem and get a good fan and get more dilution ventilation.

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

P.S. If you have a new safety or health question, please let me know.

Safety Tidbit 4.09 - Machine Guarding

Safety Tidbit 4.09 – Machine Guarding

 

Reference:     

I love OSHA’s machine guarding standard. It’s so absolute. 1910.212(a)(3)(ii) reads: “The point of operation of machines whose operation exposes an employee to injury, shall be guarded. The guarding device shall be in conformity with any appropriate standards therefor, or, in the absence of applicable specific standards, shall be so designed and constructed as to prevent the operator from having any part of his body in the danger zone during the operating cycle.” In other words, keep your workers safe, identify the point of operation of your machines and guard them.

The standard has an added benefit to employers. It does not dictate what control they are to use just that they be in conformity with “any appropriate standards.” So, OSHA leaves it up to the discretion of the employer as to what might work best given the employer’s particular circumstances. ANSI helps out a bit here to give some options for the employers to choose from. ANSI says there are guards and devices. A guard is a physical barrier whereas, a device may be a safeguarding device that detects or prevents inadvertent access to a hazard. Or, the device may generate a noticeable (distinctive by sound or intensity) audible or visual signal to warn of an approaching or present hazard. ANSI further describes the use of safe work practices during the following:

·      tasks are complex

·      tasks have high risk;

·      training, skill or work experience is limited;

·      other safeguarding is removed or bypassed;

·      required to augment other safeguarding

To help employers keep their workers safe they can use complimentary equipment such as safety blocks, chain locks, locking pins, work holding equipment, stopping performance monitor. These don’t really get rid of the hazard, but they do help keep unprotected fingers and hands out of harm’s way.

So simply put, protection of the workers is most important. OSHA doesn’t care if the piece of equipment is 100 years old and didn’t come with guards or bought overseas and doesn’t have guarding, the employer must abate the hazard. But hey, they can use their imagination and design something that works well.

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

P.S. If you have a new safety or health question, please let me know.

Safety Tidbit 4.08 - Silica Enforcement

Safety Tidbit 4.08 – Silica Enforcement

 

Reference:      Interim Enforcement Guidance June 25, 2018

I was working on a homework project for my IH students. The topic is silica. I have been presenting on Silica to the Mid-Atlantic Masonry Association since OSHA passed its new Respirable Crystalline Silica standard. My emphasis has been to teach the mason, hardscapers, ready-mix operators, and precast/architectural plant owners how to formulate their exposure control plan for the operations.

I start each class asking how many of them currently have workers in respiratory protection and the follow-on question who likes to wear a respirator all day?  Usually I quite a few hands of companies that are using respirators, but no one ever says they like to wear a respirator (even for short periods of time). I use this as a hook because if they perform the risk assessment in their plant and create a good exposure control plan they will find that they don’t need to use respirators after some very reasonable process modifications.

Creating an exposure control plan uses the hierarchy of controls but also requires the employer to review all their potential exposure to silica. The hierarchy of control is the process of the eliminating a hazard by using a decreasing less effective protective measures. First, try to eliminate the hazard all together.  Second, substituting the hazardous substance for something less hazardous. Third, engineering out the hazard, traditionally, by using ventilation or wetting the dust, Fourth, administratively controlling the hazard through work practices. And lastly, having the worker wear personal protective equipment (PPE) or in our case respirators to protect themselves.

By systematically profiling the workplace, the employer learns where their worst exposures can occur and take steps to reduce the emissions. I have employers that are worried about controlling exposures to tasks that occur infrequently and for short durations (less than 10 minutes) and miss the bigger exposure that affects more workers.

I never really thought that an employer, giving respirators to workers, was really protecting the workers. More, they were giving the employee the means to protect themselves. Personal protective equipment protects only as well as it is put on and that means the worker is the ultimate decider of the effectiveness of the respirator since they are ones putting it on.

So how does this relate to OSHA enforcement and the silica standard? I was reviewing the new enforcement document for silica that OSHA published during the summer. In the document, the first item a compliance officer is to ask the employer for during an inspection is the see their Exposure Control Plan. So, all that we teach about hazard recognition, evaluation and control is the basis of the Exposure Control Plan. The biggest difference for the silica is that it’s required for any potential exposure versus in the Lead Standard it’s required after exposures reach the permissible exposure limit.

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

P.S. If you have a new safety or health question, please let me know.

Safety Tidbit 4.07 - Mold

Safety Tidbit 4.07 – Mold

 

Reference:      OSHA Mold Hazards Disaster Cleanup

Okay, enough with the waterworks already. I am so tired of rain. As a homeowner, with rain comes the chance of water coming into my home where I don’t want it. Mold is a type of fungi as you well know. Most molds reproduce by forming spores which are released into the air. When spores land on a suitable moist surface they begin to grow, can penetrate porous materials (e.g., carpeting, drywall, wood, in other words, pretty much most things in our homes) and release chemicals. Most molds are harmless. However, some can cause infections, allergy symptoms and produce toxins. But let’s not forget that we need molds and fungi to breakdown all the leaves that are falling outside.

What do you do when the water brings mold into your home, and it takes over? The first rule in mold cleanup is to control the source of moisture. Drying can involve the use of fans, blowers and/or dehumidifiers. However, the more humid the air, the less effective the blowers will be. It is often more cost-effective to remove and replace the building materials than to dry and clean mold-contaminated materials.

While cleaning up mold affected areas use engineering controls, work practices, and personal protective equipment (PPE). Sounds a bit like the use of the hierarchy of controls (e.g., Elimination, Substitution, Engineering Controls, Warnings, Administrative Controls, Personal Protective Equipment). Inhalation is the route of exposure of most concern to cleanup workers. OSHA gives a few suggestions:

Engineering Controls

•       Re-wetting materials with a mist of water to suppress spores, dust and debris.

•       Wrap and seal the items that will be discarded in plastic bags or sheets to reduce the spread of spores.

•       Provide natural or local exhaust ventilation during all cleaning steps.

Work Practices

•       Avoid breathing dust.

•       After an area has been cleaned and is completely dry, vacuum the area with a HEPA vacuum.

•       HEPA vacuums are also recommended for cleaning up dust that may have settled on surfaces outside the work area.

•        

I’m a little confused though, OSHA has a very generic work practice to “avoid breathing dust” (are we to hold our breath?).  I like that they recommend moistening the affected areas during remediation to avoid creating dust. Also, putting debris in sealed or plastic bags makes good sense. All of their recommendations are examples of good old-fashioned industrial hygiene practices and engineer out the hazard if possible (wet it and/or vacuum it).

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.