MASWM Conference October 7, 2014 - Sheltered workshop 2014 MASWM OSHA POWER POINTS.pdfWorkshop...

OSHA UpdateMASWM Conference

October 7, 2014

Mike Minicky, CSPCompliance Assistance Specialist

St. Louis OSHA [email protected]

Todd SielemanCompliance Assistance SpecialistKansas City OSHA [email protected]

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 [email protected]

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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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)


Examination of Written Programs: All programs if inspection

scope is comprehensive Select programs if partial

inspection


Workplace Walk-through: All areas if inspection scope is comprehensive Select areas if partial inspection


Documentation of Noted Hazards: Photographs Sketches Interviews


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


(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


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


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.


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

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.

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


What should employees do?

https://www.osha.gov/dcsp/compliance assistance/sampleprograms.html


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


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


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


MASWM Conference October 7, 2014 - Sheltered workshop 2014 MASWM OSHA POWER POINTS.pdfWorkshop...

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