2016 Tighe & Bond Breakfast Seminar Series

2017 NEWEAWhats New in Health & Safety?

January 24, 2017Boston, MA

David P. Horowitz, P.E., CSP, Project Manager

Slideshare@dphorowitz

1

Agenda

OSHA State PlansMA DLS Shout OutRecent DLS ActivityOSHA Changes

State Plans Public & Private

AlaskaNew MexicoArizonaNorth CarolinaCaliforniaOregonHawaiiPuerto RicoIndianaSouth CarolinaIowaTennesseeKentuckyUtahMaineVermontMarylandVirginiaMichiganWashingtonMinnesotaWyomingNevada

State Plans Public Only

ConnecticutIllinoisNew JerseyNew YorkVirgin Islands

State Plans

State PlanPublic & PrivateNo State PlanNo State PlanNo State PlanState PlanPublic & PrivateState PlanPublic

First .. A plug for DLS

Recent DLS Activity

Written Warning And Order To Correct

Recent DLS Activity - Respirators

Written Respiratory Protection Plan

Courtesy of Maine Department of Labor

Recent DLS Activity Lo/To

Provide Lo/To Program

Recent DLS Activity Lo/To

Recent DLS Activity PPE

Conduct/Perform Hazard Assessment

Courtesy of ConnOSHA

Recent DLS Activity

Recent DLS Activity

Recent DLS Activity

Regulatory Updates Safety & Health

Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015

Recording and Reporting of Occupational Injuries and Illnesses regulations

Regulatory Updates Safety & HealthFederal Civil Penalties Inflation Adjustment Act Improvements Act of 2015Translation: Higher OSHA FinesHighlights:Serious$7,000 $12,741 per violationOther Than Serious$7,000 $12,741 per violationFailure to Abate $7,000 $12,741 per dayWillful or repeat$70,000 $124,709 per violation

Effective August 1, 2016First increase in over 25 yearsAllows future increases by January 15 every yearPlan states may not follow

Regulatory Updates Safety & HealthRecording and Reporting of Occupational Injuries and Illnesses regulationsHighlights:Large Businesses ( 250 employees)Electronically file OSHA 300 / 300A / 301 forms with OSHABegins July 1, 2017Small (High Risk) Industries (20 249 employees)By SIC Code (e.g., utilities, construction, manufacturing)Electronically file OSHA 300A forms with OSHABegins July 1, 2017

Injury / Illness data will be available to the publicEmployers can not retaliate for injury reportingAutomatic drug testing can be a form of retaliationElectronic reporting is being challenged and may be modified

Planning for 2017 Safety & HealthPeriodic Safety & Health RequirementsPost OSHA 300A Log: Post from Feb 1 through April 30

Initial Training:LoTo, Emergency Action Plan, HazCom, PPE, Hearing Protection

Refresher Training:Annual: Hearing Protection, Respirators, Access to Medical Records3-Year: Powered Industrial Trucks

Planning for 2017 Safety & HealthPeriodic Safety & Health RequirementsMandatory Program Reviews:Exposure Control Plan (BB Pathogens), Confined Space, LoTo

Annual Evaluations:Audiograms, Respirator Fit Tests

Process Changes:Training, Program Updates, Hazard Reviews, PPE Assessments

Reasons to Conduct an AuditManage risk

New/Updated operations

Employee turnover

Common Regulatory VisitsDepartment of Labor Standards Public Works

Occupational Safety & Health Administration (OSHA) Emphasis Programs

Environmental Protection Agency (EPA) Risk Management Planning

Planning for Future AuditingInternal AuditingChecklistsIn houseOutsourced

Planning for 2017 Auditing

Self Audit Policy EPAeDisclosureTimelines to discloseTimelines to correct findingsSome relief from penalties

Department of Labor StandardsCommon Audit findings at Public Works Facilities:

Lock out/Tag outRespiratory Protection PlanWritten PPE Certification

OSHACommon Audit Findings at Facilities7 of 10 are general industry3 of 10 are construction

EPACommon Audit Findings at chlorination facilities:Gaseous ChlorineRisk Management PlanningProcess Safety Information (PSI)SignageManagement of Change (MOC) issuesEmployee Training3 Year Audit Cycle5 Year Process Hazard Analysis Cycle

Questions