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OSHA UpdateMASWM Conference
October 7, 2014
Mike Minicky, CSPCompliance Assistance Specialist
St. Louis OSHA Officeminicky.michael@dol.gov
Todd SielemanCompliance Assistance SpecialistKansas City OSHA Officesieleman.todd@dol.gov
Talking PointsOSHA history & mission Safety & health data Employer responsibilitiesOSHA inspectionsCommon Violations Safety and health resources
OSHA stands for the Occupational Safety and Health Administration, an agency of the U.S. Department of Labor
OSHA’s responsibility is worker safety and health protection
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On December 29, 1970, President Nixon signed the OSH Act
This Act created OSHA, the agency, which formally came into being on April 28, 1971
History of OSHA
OSHA’s Mission
The mission of OSHA is to save lives, prevent injuries and protect the health of America’s workers.
Some of the things OSHA does to carry out its mission are: ◦ developing job safety and health standards and
enforcing them through worksite inspections,◦ maintaining a reporting and recordkeeping system to
keep track of job-related injuries and illnesses, and◦ providing training programs to increase knowledge
about occupational safety and health.
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Topic 2:What Rights Do Employees Have Under OSHA? The right to:◦ A safe and healthful workplace ◦ Know about hazardous chemicals◦ Information about injuries and illnesses in your
workplace ◦ Complain or request hazard correction from employer ◦ Training◦ Hazard exposure and medical records◦ File a complaint with OSHA◦ Participate in an OSHA inspection◦ Be free from retaliation for exercising safety and
health rights
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Provide a workplace free from recognized hazards and comply with OSHA standards
Provide training required by OSHA standards Keep records of injuries and illnesses Provide medical exams when required by OSHA
standards and provide workers access to their exposure and medical records
Not discriminate against workers who exercise their rights under the Act (Section 11(c))
Post OSHA citations and abatement verification notices Provide and pay for PPE
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What Are Employer Responsibilities Under OSHA?
FY 2007 – FY 2013Inspections Conducted
39,324 38,667 39,004 40,993 40,648 40,96137,917
0
10,000
20,000
30,000
40,000
50,000
FY07 FY08 FY09 FY10 FY11 FY12 FY13
The OSH Act authorizes OSHA compliance safety and health officers (CSHOs) to conduct workplace inspections at reasonable times.
OSHA conducts inspections without advance notice, except in rare circumstances (e.g. Imminent Danger)
In fact, anyone who tells an employer about an OSHA inspection in advance can receive fines and a jail term.
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Priority Category of Inspection1st Imminent Danger:
Reasonable certainty an immediate danger exists
2nd Fatality/Catastrophe:Reported to OSHA; inspected ASAP
3rd Complaints/Referrals:Worker or worker representative can file a complaint about a safety or health hazard
4th Programmed Inspections:Cover industries and employers with high injury and illness rates, specific hazards, or other exposures.
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VIOLATION TYPE PENALTY
WILLFULA violation that the employer intentionally and knowingly commits or a violation that the employer commits with plain indifference to the law.
OSHA may propose penalties of up to $70,000 for each willful violation, with a minimum penalty of $5,000 for each willful violation.
SERIOUSA violation where there is substantial probability that death or serious physical harm could result and that the employer knew, or should have known, of the hazard.
There is a mandatory penalty for serious violations which may be up to $7,000.
OTHER-THAN-SERIOUSA violation that has a direct relationship to safety and health, but probably would not cause death or serious physical harm.
OSHA may propose a penalty of up to $7,000 for each other-than-serious violation.
REPEATEDA violation that is the same or similar to a previous violation.
OSHA may propose penalties of up to $70,000 for each repeated violation.
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FY 2007 – FY 2013Average Current Penalty Per
Serious Violation
$918 $998 $970 $1,053
$2,133 $2,153$2,008
$0
$500
$1,000
$1,500
$2,000
$2,500
FY07 FY08 FY09 FY10 FY11 FY12 FY13
Data Source: OIS Insp. Summary Rpt. Dated 9/17/13
St. Louis Area Office Local/Regional/National Emphasis Programs
General IndustryAmputations ForktruckGrain HandlingLogging/SawmillsPrimary MetalsNoise & Respiratory Hexavalent ChromiumNo Comprehensive 02Recycling/Scrap Metal
Nursing HomesChemical Plants
Site-Specific Targeting Program
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Some Common Violations
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29 CFR Part 1904Recording and Reporting Occupational
Injuries and Illnesses
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Purpose (of the Rule)
To require employers to record and report work-related fatalities, injuries and illnesses– Note: Recording or reporting a work-related
injury, illness, or fatality does not mean the the employer or employee was at fault, an OSHA rule has been violated, or that the employee is eligible for workers’ compensation or other benefits.
OSHA injury and illness recordkeeping and Workers’ Compensation are independent of each other
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1904.4 – Recording Criteria
Covered employers must record each fatality, injury or illness that:– is work-related, and– is a new case, and– meets one or more of the criteria contained in
sections 1904.7 through 1904.11.
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1904.7 – General Recording Criteria
An injury or illness is recordable if it results in one or more of the following:– Death– Days away from work– Restricted work activity– Transfer to another job– Medical treatment beyond first aid– Loss of consciousness– Significant injury or illness diagnosed by a PLHCP
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1904.32 – Annual Summary
Review OSHA Form 300 for completeness and accuracy, correct deficiencies
Complete OSHA Form 300A Certify summary Post summary
Major Revisions to the Hazard Communication Standard
Hazard classification: Provides specific criteria for classification of health and physical hazards, as well as classification of mixtures.
Labels: Chemical manufacturers and importers will be required to provide a label that includes a harmonized signal word, pictogram, and hazard statement for each hazard class and category. Precautionary statements must also be provided.
Safety Data Sheets: Will now have a specified 16-section format.
Information and training: The Revised HCS requires that workers be trained within two years to facilitate recognition and understanding of the new labels and safety data sheets.
GHS Pictograms
!Explosive Flammable Oxidizer
Acute Toxicity CorrosiveChronic Health
Hazard
Irritant
Compressed Gas
A sample GHS compliant label
OSHA Office of Training & Education 32
Control – Isolate Electrical Parts -Cabinets, Boxes & Fittings
Conductors going into them must be protected, and unused openings must be closed
OSHA Office of Training & Education 33
Hazard – Improper Grounding
• Tools plugged into improperly grounded circuits may become energized
• Broken wire or plug on extension cord
• Some of the most frequently violated OSHA standards
Questions?
ALL ABOUT OSHA Missouri Association of Sheltered
Workshop Managers
October 7, 2014
Todd SielemanCompliance Assistance Specialist
Kansas City Area Officesieleman.todd@dol.gov
What to Expect from OSHA
Types of inspections Inspection Process (step-by-step) Types of citations Post inspection activity
What’s new
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Reporting fatalities/severe injury requirements
GHS - changes in Hazard Communication Standard
What’s on the horizon
Injury Illness RecordkeepingProposal
Written Programs
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Hazardous Energy Control (Lockout Tagout)
Electrical Safety Hazard Communication Personal Protective Equipment
(PPE) Blood-Borne Pathogens Machine Guarding
Types of InspectionsAccident/Fatality Self Reporting Media referral Law Enforcement
Types of Inspections Targeted Enforcement National Emphasis Programs: Hazardous Machinery (reduce workplace hazards likely to cause amputations) Process Safety Management Site-Specific Targeting
Types of Inspections Targeted Enforcement Local Emphasis Programs: Falls, Overhead Power Lines Powered Industrial Truck Grain Handling Industries Construction Following a Severe Weather Event Logging and Sawmill Industries Missouri Work Comp Silica
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u:\ips master templates\best work product\presentation suite\construction presentation suite 2012\proposal presentation.potx
u:\ips master templates\best work product\presentation suite\construction presentation suite 2012\proposal presentation.potx
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Types of Inspections Observed Hazard
In Public View: Generally construction activity
Types of InspectionsComplaint driven Formal
Informal
Types of Inspections Complaint DrivenFormal Current employee (or employee agent) signed complaint Onsite inspection conducted Partial inspection involving listed complaint items only Inspection scope can be enlarged if plain view hazards are noted
Types of Inspections Complaint DrivenInformal Not an employee (may be any source) No onsite inspection Phone/fax Determination of abatement
What to Expect in an Inspection
Opening conference: Credentials displayed Union participation (if applicable) Purpose and inspection scope defined Copy of inspection complaint (if applicable) Advisement of employer and employee rights 11c protection Private interviews with employees (union rep may be present if employee desires) Proprietary/confidential information Photography Personal Protective Equipment Request for OSHA Injury and Illness Logs (300 and 300a)
What to Expect in an Inspection
Examination of Written Programs: All programs if inspection
scope is comprehensive Select programs if partial
inspection
What to Expect in an Inspection
Workplace Walk-through: All areas if inspection scope is comprehensive Select areas if partial inspection
What to Expect in an Inspection
Documentation of Noted Hazards: Photographs Sketches Interviews
What to Expect in an Inspection
Closing Conference: Noted Hazards Abatement date Citation posting (3 days or until hazard corrected) Employer and employee rights
Post Inspection Activity
Agreement with citation issuance and payment of assessed penalty Informal conference Contest citation After 15 working days all citations become final order
What’s new
Reporting fatalities/severe injury requirements
(Old) Fatality or hospitalization of 3 or more employees reported within 8 hours(New) Fatality within 8 hours. Any hospitalization, amputation, loss of
an eye - 24 hours. Starting in 2015, employers will have to report the following to OSHA: • All work-related fatalities • All work-related inpatient hospitalizations of one or more employees • All work-related amputations • All work-related losses of an eye
What’s new
Reporting fatalities/severe injury requirements
All employers under OSHA jurisdiction must report all work-related fatalities, hospitalizations, amputations and losses of an eye to OSHA, even employers who are exempt from routinely keeping OSHA injury and illness records due to company size or industry.
An amputation is defined as the traumatic loss of a limb or other external body part. Amputations include a part, such as a limb or appendage, that has been severed, cut off, amputated (either completely or partially); fingertip amputations with or without bone loss; medical amputations resulting from irreparable damage; and amputations of body parts that have since been reattached.
What’s new
Globally Harmonized System
Aligning HazCom with United Nations’ global chemical labeling system
What’s new
Globally Harmonized System
Employers must train workers on the new label requirements; signal word “Warning” or “Danger”, Pictograms and SDS format by December 1, 2013
Chemical manufacturers, importers, distributors and employees must comply with all modified provisions of the final rule by June 1, 2015. Distributors may ship under old system until December 1, 2015
June 1, 2016, all program elements in place
GHS Pictograms
!Explosive Flammable Oxidizer
Acute Toxicity CorrosiveChronic Health
Hazard
Irritant
Compressed Gas
A sample GHS compliant label
What’s on the Horizon
What’s on the Horizon
Recordkeeping
OSHA issued proposed rule (Stage 3) in Nov 2013 to add requirements for electronic submission of injury and illness information employers are already required to keep under existing standards, Part 1904.
What’s on the Horizon
Recordkeeping The Proposal would require: Employers with more than 250 workers to electronically submit
data on a quarterly basis Those with 20 to 250 workers to e-file annually11 to 20; e-file if notified.
Under the proposed new rule, around 440,000 companies will be subject to requirement to report injury and illness rates. Approximately 220,000 currently report
All data from the OSHA log would be public information EXCEPT the employee name
Stage 1Making the Decision: Conducting Preliminary Rulemaking Activities
12-36 mos
Stage 2Developing the Proposed Rule
12-36 mos
Stage 3Publishing the Proposed Rule
2-3 mos
Stage 4Developing & Analyzing the Rulemaking Record
6-24 mos
Stage 6Publishing the Final Rule
2-3 mos
Stage 5Developing the Final Rule
18-36 mos
Stage 7Post Promulgation Activities
4-12 mos 12.5 years…
Semi Annual Regulatory Agenda June 2014
Written Program Requirements
Hazardous Energy Control (Lockout Tagout) Electrical Safety Hazard Communication Personal Protective Equipment (PPE) Blood-Borne Pathogens Machine Guarding Powered Industrial Truck
Hazardous Energy Control 1910.147
Hazardous Energy Control
Hazardous Energy Control
Note: Exception: The employer need not document the required procedure for a particular machine or equipment, when ALL of the following elements exist: (1) The machine or equipment has no potential for stored or residual energy or reaccumulation of stored energy after shut down which could endanger employees; (2) the machine or equipment has a single energy source which can be readily identified and isolated; (3) the isolation and locking out of that energy source will completely deenergize and deactivate the machine or equipment; (4) the machine or equipment is isolated from that energy source and locked out during servicing or maintenance; (5) a single lockout device will achieve a locked-out condition; (6) the lockout device is under the exclusive control of the authorized employee performing the servicing or maintenance; (7) the servicing or maintenance does not create hazards for other employees; and (8) the employer, in utilizing this exception, has had no accidents involving the unexpected activation or reenergization of the machine or equipment during servicing or maintenance.
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Electrical Safety 1910.333 - 334- 335
Electrical Safety
https://www.osha.gov/dte/grant_materials/fy07/sh-16615-07/train-the-trainer_manual2.pdf
Electrical Safety
Electrical Safety
1910.303(b)(2)Installation and use. Listed or labeled equipment shall be installed and used in accordance with any instructions included in the listing or labeling.
1910.303(b)(6)Deteriorating agents. Unless identified for use in the operating environment, no conductors or equipment shall be located in damp or wet locations; where exposed to gases, fumes, vapors, liquids, or other agents that have a deteriorating effect on the conductors or equipment; or where exposed to excessive temperatures.
1910.303(b)(7)Mechanical execution of work. Electric equipment shall be installed in a neat and workmanlike manner
1910.303(b)(7)(i)Unused openings in boxes, raceways, auxiliary gutters, cabinets, equipment cases, or housings shall be effectively closed to afford protection substantially equivalent to the wall of the equipment
Electrical Safety
1910.303(b)(7)(iv)There shall be no damaged parts that may adversely affect safe operation or mechanical strength of the equipment, such as parts that are broken, bent, cut, or deteriorated by corrosion, chemical action, or overheating.
1910.303(b)(8)(i)Electric equipment shall be firmly secured to the surface on which it is mounted
1910.303(g)(1)(ii)Working space required by this standard may not be used for storage. When normally enclosed live parts are exposed for inspection or servicing, the working space, if in a passageway or general open space, shall be suitably guarded.
1910.304(g)(5)Grounding path. The path to ground from circuits, equipment, and enclosures shall be permanent, continuous, and effective
1910.305(b)(1)(i)Conductors entering cutout boxes, cabinets, or fittings shall be protected from abrasion, and openings through which conductors enter shall be effectively closed
1910.305(b)(1)(ii)Unused openings in cabinets, boxes, and fittings shall be effectively closed.
Hazard Communication 1910.1200
Hazard Communication
Written PlanAll workplaces where employees are exposed to hazardous chemicals must have a written plan that describes how the standard will be implemented in that facility.
LabelsAll containers of hazardous chemicals must be labeled, tagged, or marked with the identity of the material and appropriate hazard warnings
Safety Data Sheets (SDSs)Chemical manufacturers and importers obtain or develop an SDS for each hazardous chemical they produce or import.
Distributors provide their customers copy of these SDSs.
Employers must have an SDS for each hazardous chemical they use.
Hazard Communication
TrainingEach employee who may be exposed to hazardous chemicals when working must be provided information and trained prior to initial assignment to work with a hazardous chemical, and whenever the hazard changes.
Personal Protective Equipment 1910.132 https://www.osha.gov/Publications/osha3151.pdf
Personal Protective Equipment
Personal Protective Equipment
What should employees do?
Personal Protective Equipment
Personal Protective Equipment
Personal Protective Equipment
https://www.osha.gov/dcsp/compliance assistance/sampleprograms.html
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u:\ips master templates\best work product\presentation suite\construction presentation suite 2012\proposal presentation.potx
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Machine Guarding General Requirements 1910.212
1910.212(a)(1)Types of guarding. One or more methods of machine guarding shall be provided to protect the operator and other employees in the machine area from hazards such as those created by point of operation, ingoing nip points, rotating parts, flying chips and sparks. Examples of guarding methods are-barrier guards, two-hand tripping devices,electronic safety devices, etc.
What hazards exist?
Crushed by or drawn into equipmentStruck by moving partsStruck by failed components or particles
Key parts of machines
1. Point of operation: where work is performed on the material, such as cutting, shaping, boring, or forming of stock.
2. Power Transmission Device: transmits energy to the part of the machine performing the work Includes flywheels, pulleys, belts, connecting rods,
couplings, cams, spindles, chains, cranks, and gears.
Key parts of machines
3. Operation Controls: Control mechanisms4. Other moving parts: can include reciprocating,
rotating, and transverse moving parts, feed mechanisms, and auxiliary parts of the machine
Hazards to be Guarded
Things to guard includeIn-running nip pointsRotating equipmentFlying chips or sparksBelts or gearsParts that impact or shear
Rotating Parts
Can grip hair or clothing Can force the body into a dangerous positionProjecting pieces increase risk
In-Running Nip Points
Between 2 rotating partsBetween rotating and tangential partsBetween rotating and fixed parts which shear,
crush, or abrade
Reciprocating Parts
Risk of being struck between stationary and moving part
Transverse motion
Continuous straight line motionWorker struck or caught in pinch or shear
point
Cutting action
Direct injury from cutting actionFlying chips or sparksSaws, drills, lathes, mills
Punching action
Ram stamps materialsDanger at point of operation
Shearing action
Powered blade that shears materialsHazard at point of operation
Bending action
Power applied to a slide to stamp/shape materialsHazard at point of operation
Guarding Principles
Prevent contact between hazardous moving parts and body or clothingSecure guard: not easily removedProtect from objects falling into machineryNo new hazards: sharp/rough edgesNo interference with job/comfort/speedAllow safe lubrication: without removing guards
if possible
Guarding Methods
Location / distanceGuardsFixedInterlockedAdjustableSelf-adjusting
Guarding Methods
DevicesPresence sensingPullbackRestraintSafety controls (tripwire cable, two-hand control, etc.)Gates
Guarding Methods
Feeding & ejection methodsAutomatic and/or semi-automatic feed and ejection
RobotsMiscellaneous aidsAwareness barriersProtective shieldsHand-feeding tools
Fixed Guard
Barrier is a permanent part of machinePreferable over other types
Interlocked Guard
Stops motion when guard is opened or removed
Interlocked guard on revolving drum
Adjustable Guard
Barrier may be adjusted for variable operationsWhat are the drawbacks?
Bandsaw blade adjustable guard
Self-Adjusting Guard
Adjusts according to size/position of material
Circular table saw self-adjusting guard
Pullback Device
Cables attached to operator’s hands or wristsRemoves hands from
point of operation during danger periodWhat are the drawbacks?
Restraint Device
Cables attached to fixed point and wrists or handsAdjustable to let
hands travel in predetermined areaMay be accompanied
by hand-feeding tools
Safety Tripwire Cable
Device located around the perimeter of or near the danger areaOperator must be
able to reach the cable to stop the machine
Two-Hand Control
Requires constant pressure on both pads to activate the machineHands on controls at
safe distance while machine is in dangerous cycle
Gate
Must close fully to protect user before cycle will start
Gate Open Gate Closed
Safeguarding by Location/Distance
Location of hazardous parts that is inaccessible or not a hazard during normal operationMust maintain safe distanceTraining, warning, communication necessary
Protective Shields
Protection from flying particles or splashing fluidsDo not protect
completely frommachine hazards
1910.212(a) Machine guarding
1. One or more types of guarding to protect from hazards. Barrier guards Two-hand tripping devices Electronic safety devices Etc.
2. Affixed to machine where possible Guard must not cause its own hazard
1910.212(a) Machine guarding
3. Point of operation guarding:ii. Guarded if exposes employee to injury
Keep any part of body out of danger zoneiii. Hand tools to permit material handling – in
addition to guards, not insteadiv. Examples of machines requiring guards on
point of operation
1910.212(a) Machine guarding
4. Revolving barrels, drums, containers guarded by interlocked enclosure (cannot turn without guard in place)
5. Exposure to fan blades: guard openings 1/2 inch
1910.212(b) Anchoring fixed machinery
Machines designed for fixed location must be anchored to prevent moving
This pedestal grinder is designed for
anchoring, but is not anchored
1910.215(a) General requirements
Abrasive wheels must be guarded, with exceptionsGuard design
dependent on type of work and type of wheel
1910.215(a) General requirements
Work rests: Rigid, clamped in place securelyAdjusted to within 1/8 inch of wheelNever adjusted while in motion
Work rest is closelyadjusted
1910.215(b)(9) Exposure adjustment
For type where operator stands in front of opening: Adjustable for decreasing wheel sizeAdjustable tongue guard
must never be more than ¼ inch from wheel
1910.215(d) Mounting
Inspect for damage and ring test immediately before mountingTap with light nonmetallic implement (screwdriver, wooden mallet)If sound is dead, cracked ring may not be usedCheck spindle speed against maximum for wheel
Compliance Assistance
State Onsite ConsultationDuty OfficerWebsite: www.osha.gov
QUESTIONS
www.osha.gov
Kansas City Area Office 816-374-9572
Confined Space
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