OSHA Compliance for Temp Agencies and Host Employers

COMPLIANCE WITH OSHA HEALTH STANDARDS:

OVERVIEW

GEORGIA TECH’S SAFETY AND HEALTH

CONSULTATION PROGRAM

OSHA Compliance for Temp Agencies and Host Employers

Basic Scope of IH Compliance Hazard Communication (Chemical) Hearing Conservation Air Contaminants

Permit-Required Confined Spaces Respiratory Protection Personal Protective Equipment First Aid & Bloodborne Pathogens

HAZARD COMMUNICATION

STANDARD

Compliance with OSHA Health Standards

4

“CHEMICAL” Hazard

CommunicationStandard

LABEL

MSDS

HCP

5

Purpose To insure that the hazards of all chemical

produced in or imported into the U.S. are evaluated

Hazards transmitted to employers employees

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Basic Program Elements Chemical Hazard Inventory MSDS’s Labeling Employee Training Contractor Training Written Program

HazardCommunication

Program

Temp Workers and HazCom: Shared Responsibility

Staffing Agency Generic Policies

Host Company Specific Chemicals

Global Harmonization System (GHS)

Final Standard: March 2012 Implementation Period: December 2013

through June 2016 Hazard Communication Changes

Labels, Pictograms Safety Data Sheets Employee Training

Four Major Changes in GHS9

1. Hazard Classification (changed from hazard determination)

2. Labels3. Safety Data Sheets (changed

from MSDS)4. Information and Training Will affect nearly 40 million workers and 5 million workplaces.

Principles Of Harmonization

Consistent Classification (both intra- and inter-nationally)

Harmonized across agencies: OSHA, Consumer Protection Agency, EPA,

DOT Both code Words and Pictograms Warnings are based on intrinsic hazards

of chemicals Identify the Severity of exposure

HEARING CONSERVATION

Compliance with OSHA Health Standards

Monitoring Requirements(Dosimetry)

Initial Monitoring required if employer has indications of full-

shift exposure at or above 85 dBA (Action Level)

Rule of Thumb for estimating 85 dBA Host and Staffing Agency Duties

Who will conduct noise monitoring? Default assumption of 85 dBA What are high range exposures?

Hearing Conservation Program:Who Implements Basic Elements?

Provide hearing protection Train workers on noise effects (annual) Provide baseline and annual audiometric

testing Retain exposure and audiometric

measurements

Hearing Conservation Documentation

Copy of Written Guidelines and Policies (Recommended)

Noise Measurement Data and Annual Audiograms

Standard Threshold Shifts Documentation and Notification Letters

OSHA 300 Hearing Loss Records Which employer records an incident?

AIR CONTAMINANTS

Compliance with OSHA Health Standards

Evaluating Host Companies for Air Contaminants

GASES: low density molecules, rapid diffusion

VAPORS: liquids with high vapor pressure

DUSTS: solid particles FUMES: recondensation of vaporized

solids MISTS: liquid droplets, (aerosols) SMOKE: complex combustion products FIBERS: 3 to 1 length to width ratio

Chemical Mixtures

Anticipate Potential Air Hazards Review plant layout and chemical flow Observe air flow patterns Identify existing controls Temp Workers and high hazard work

Restrictions on job assignments?

Understanding Exposure Limits PEL TLV REL WEEL EU Standards MRG

OSHA PEL(Regulatory in US)

Permissible Exposure Limit—PEL

(Or)

“Impermissible” Exposure Limit

Categories of OSHA PEL’s

1. The PEL Lists (~400 chemicals) Current PEL’s are based on 1968

ACGIH-TLV’s

2. The “Substance Specific” Standard E.g., lead, asbestos, cadmium,

methylene chloride, etc. Relatively few substance specific

chemicals regulated

Occupational Exposure Limits (OELs) (Non-Regulatory)

American Conference of Governmental Industrial Hygienists—Threshold Limit Value (ACGIH –TLV)

National Institute for Occupational Safety and Health —Recommended Exposure Limit (NIOSH REL)

American Industrial Hygiene Association—Workplace Environmental Exposure Limit (AIHA WEEL)

European Union standards Manufacturer’s Recommended

Guidelines

0 200 400

Time-Weighted Average (TWA) Exposure

TIME (min)

PPM

800

700

600

500

400

300

200

100

0

Example: Acetone, PEL = 1000 PPM, TWA

TWA = 200 ppm

Evaluating Exposures Pre-screening Passive sampling Active IH sampling

STEL Measurements (Short Term) TWA Measurements (Full Shift) Acute Exposures (Confined Space)

Initial Screening of Exposure

Passive Samplers

Organic Vapor Sampler Inorganic Mercury Sampler

Full Shift Breathing Zone Exposures

Air Contaminants in Permit-Required Confined Spaces (Evaluate Acute Air Hazards)

Host and Staffing Agency Who conducts evaluations? Who keeps records? Who has access to records? Medical surveillance (lead, cadmium,

asbestos, methylene chloride, etc) Who conducts biological monitoring? Who keeps records?

RESPIRATORY PROTECTION

Compliance with OSHA Health Standards

Organize the Program

Respirator Program Elements Selection of respirators Define use and application Medical evaluation Fit testing Training Maintenance and care Breathing air quality and use Program evaluation

Host and Staffing Agency Will Temp Workers be assigned to use

respirators? Who will manage the Respirator

Program? Medical evaluation for use Fit Testing Training Recordkeeping

PERSONAL PROTECTIVE EQUIPMENT

Compliance with OSHA Health Standards

Certification of Personal Protective Equipment Hazard Assessment

COMPANY NAME:___________________________________ DEPARTMENT(S) EVALUATED:________________________________ NAME/TITLE:_______________________________________ DATE:____________________________

Job Hazards PPE Required

Personal Protective Equipment

PPE HAZARD ASSESSMENT SURVEY 

Job/Task Evaluated:________________________

Date(s): _____________________ Conducted

By:_________________________________(Name and Title)

PPE Hazard AssessmentI. Hazards to the Head Potential Hazard Yes No Specifications for PPE*

a. Falling equipment or materials

b. Moving equipment or materials

c. Low overhead clearance

d. Electrical shock hazard

e. Welding

PPE Hazard AssessmentII. Hazards to the Eyes and Face

Potential Hazard Yes No Specifications for PPE*

a. Particulates in air

b. Hazardous liquids in air or potentially airborne (splashed)

c. Irritant dusts in air

d. Ultra violet, Infrared, or Laser radiation

e. Compressed air/liquid

f. Electrical arcing

PPE: Host and Staffing Agency Review the job hazards Review the PPE requirements Review work conditions for PPE use

When Where What processes

Paying for PPE

BLOODBORNE PATHOGENS

Compliance with OSHA Health Standards

Applications General Industry/Manufacturing

Designated First Aid responders BBP standard does not cover “Good

Samaritan” acts in which an employee voluntarily provides first aid to a fellow employee

Medical and Human Services Offices Any employee whose job involves contact

with blood or other potentially infectious materials (OPIM)

Universal Precautions All human blood/OPIM are treated as if

known to be infectious for bloodborne pathogens, regardless of the perceived “low risk” status of a patient or patient population

Exposure Control Plan(Gradient of Complexity)

General Industry/Manufacturing Relatively simple (First Aid): written policy,

PPE, training

Medical Providers/Human Services Relatively complex (Medical interventions):

many program elements to manage; treatment procedures; cleaning schedules; compliance with changing guidance on Sharps; awareness and compliance with CDC infection control practices.

Host and Staffing Agency Review Exposure Control Plan (ECP) Identify job positions included in ECP Provide training for Bloodborne

Pathogens Restrict access to specific areas of

facility Identify special PPE requirements Specify required vaccinations

Summary(Host and Staffing Agency shared duties)

Hazard Communication (Chemical) Hearing Conservation Air Contaminants

Permit-Required Confined Spaces Respiratory Protection Personal Protective Equipment First Aid & Bloodborne Pathogens