OSHA Safety Training and YOU

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OSHA Safety Training and YOU

• Wisconsin SHRM State Conference
• September 28-30, 2005

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• Norm Arendt, CHS-III, CFEII, PhD
• Safety Director - SEH

OSHA Authorized Instructor Homeland Security
Team Water Vulnerability Assessment Team Fire
Explosion Investigator/Instructor Pyrotechnician E
xpert Witness Smith System Instructor
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Federal vs State Plan

• Coverage
• Laws
• Enforcement
• 4000 Regulations

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Most Frequently Cited - 2005

• 62(d)(1)(i) Lead Exposure assessment (58)
• 50(c) First Aid Training (46)
• 55(a) Gases, vapors, fumes, dusts mists -
  Employee Exposure (46)
• 55(b) Gases, vapors, etc. Administrative/Enginee
  ring controls (38)
• 62(d)(1)(iii) Lead Representative personal
  sampling (29)

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Most Often Cited 2005

• 1. Scaffolding Compliance Training
• 2. Haz Com Training
• 3. Fall Protection Training
• 4. Respiratory Protection
• 5. LO/TO
• 6. Powered Industrial Trucks Training
• 7. Electrical Wiring
• 8. Machine Guarding Training
• 9. Electrical Generation
• 10. Ladders Training

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The General Duty Clause

• OSH Act Public Law 91-596 Dec. 29, 1970
• Section 5 (a) (1)
• Each employer shall furnish to each of his
  employees, employment and a place of employment,
  which is free from recognized hazards that are
  causing or are likely to cause, death or serious
  physical harm to employees

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G.D. C. (cont.)

• 5(b) Each employee shall comply with occupational
  safety and health standards and all rules,
  regulations, and orders issued pursuant to this
  act which are applicable to his own actions and
  conduct.

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Incorporation by Reference

• Other standards mandatory provisions have the
  same force and effect of law as OSHA standards,
  i.e., ANSI, NEC, NFPA

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New Changes

• expands to include requirements for
  high-visibility headwear, criteria for knit or
  woven fabrics, and additional user guidance.  

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Changes cont.

• In the absence of clinic, hospital that is
  reasonably accessible (3-4 Minutes) to the
  worksite, a person who has a valid certificate in
  First Aid training must be available

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Defensive Driving

• Leading cause of fatalities in the work place
• Cost employers 31 Billion annually
• Insurance issue
• Cell phones
• Smith System or NSC

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Changes cont.

• Brown Recluse Spider
• West Nile Virus
• Rocky Mountain Spotted Fever
• Lymes
• Ehrlichiosis
• Rift Valley Fever
• Flu
• Tularemia
• Bird Flu (H5N1)

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Brown Recluse Spider Bites
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Medical and First Aid

• Must post emergency numbers in locations where
  911 is not available

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Housekeeping

• Combustible scrap and debris must be removed at
  regular intervals
• Form and scrap lumber with protruding nails and
  all other debris, shall be cleared from work
  areas, passageways, and stairs
• Containers shall be provided for waste, trash,
  oily and used rags.
• Cubicles shall be clean and orderly

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Required Personnel(Key OSHA Terms)

• Competent Person
• Qualified Person
• Designated Person
• Authorized Person

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Competent Person

• One who is capable of identifying existing and
  predictable hazards in the surroundings or
  working conditions which are unsanitary,
  hazardous, or dangerous to employees, and who has
  authority to take prompt corrective measures to
  eliminate them

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Qualified Person

• One who, by having a recognized degree,
  certificate, or professional standing, or who by
  extensive knowledge, training, experience, has
  successfully demonstrated his ability to solve or
  resolve problems relating to the work
• I.e., a Professional Engineer

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Authorized Person

• A person approved or assigned by the employer to
  perform a specific type of duty or duties, or be
  at a specific location or locations at the
  jobsite
• (Same definition for Designated Person)

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Examples of Areas WithCompetent Person
Requirements

• Fall Protection
• Scaffolding
• Trench Excavation
• Respirator Use
• Cranes Derricks
• Ladders
• Hearing Protection
• Welding Cutting

• Electrical
• Concrete forms Shoring
• Demolition
• Lead
• Ionizing and Non-Ionizing Radiation

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Words

• Shall
• Should
• May

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Department of Commerce

• Adopted OSHA 2003
• Forms
• Training Requirements
• Inspections
• Investigations

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Managing Programs Include

• Recordkeeping
• Required Programs
• Inspections
• Training
• Documentation
• Schedules and Budgets
• Files

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Recording and Reporting Occupational Injuries and
Illness 29 CFR 1910.1904

• New Forms OSHA 300 300A
• 301A Summary
• Posting February 1 April 30
• www.osha.gov (download forms and regs)
• Hearing loss reportable in 2004

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Bloodborne Pathogens (Exposure Control Plan) 29
CFR 1910.1030

• Determination Job Hazard Analysis
• Full and Part Time Employees Included
• Job Task Change Determination Updated
• Hep B Program
• Review Program Annually

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Hepatitis

• C, B, A, D, E and G
• All cause inflammation of the liver
• Order of severity
• Fatigue, lack of appetite, nausea, vomiting,
  jaundice, fever 100, joint pain

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Control of Hazardous Energy (LOTO) 29 CFR 1910.147

• Evaluation of Machines and Equipment
• New Machines or Equipment Evaluation Updated
• Periodic Certification of Authorized Employees
• Review Program Annually

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Emergency Action Plans 29 CFR 1910.38

• Determine Evacuation Plans for Facilities
• Designate Coordinators for Evacuation
• Construction Changes will Require Updated
  Evacuation Plan
• Plan Should Cover Fires, Natural Disasters,
  Threats, Etc.

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Emergency Response Plans29 CFR 1910.120

• Determine if Employee Will Control Or Use Outside
  Source
• Will Chemical Release Affect Surrounding
  Population (RMP)
• Determine Required Personal Protective Equipment
• Review Program Annually

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Hazard Communication 29 CFR 1910.1200

• Chemical Inventory Determination computer
  Spread Sheet Product/Common Name
• MSDS Determination Match Inventory
• New Chemicals Updated Inventory New MSDS
• Full Part Time Employees Included
• Include any labs
• Program Review Annually

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Personal Protective Equipment29 CFR 1910.132

• Hazard Assessment Certifications
• Identify Hazard (Impact Penetration
  Compression Chemical Heat Harmful Dust Light
  Radiation
• Identify Head Protection
• Eye Face Protection
• Hand Protection
• Foot Protection
• Protective Clothing

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Personal Protective Equipment29 CFR 1910.132

• PPE Training on Equipment
• Use
• Care
• Limitations
• Fitting
• Warnings
• Etc

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Respiratory Protection29 CFR 1910.134

• Facility Evaluation for Respiratory Hazards
• List Types of Respirators
• Determine IDHL Areas
• Determine Program Administrator
• Fit Testing Annually
• Medical Evaluations Physicians Determines
• Review Program Annually

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Hearing Conservation29 CFR 1910.95

• Noise Evaluation Communicate Results to
  Employees
• Annual Hearing Test
• New Equipment Will Require Noise Evaluation

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Noise cont.

• Hours Sound Level
• 8 90
• 6 92
• 4 95
• 3 97
• 2 100
• 1 ½ 102
• 1 105
• ½ 110
• ¼ or less 115

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Noise cont.

• Pneumatic Chipping Hammer 110 - 113 dBA
• Jackhammer 102 - 111 dBA
• Concrete Joint Cutter 99 - 102 dBA
• Bulldozer 93 - 96 dBA
• Crane 90 - 96 dBA
• Gradeall 87 - 94 dBA
• Front End Loader 86 - 94 dBA
• Backhoe 84 - 93 dBA

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Confined Space Entry

• All employees required to enter into confined
  spaces must be trained regarding hazards,
  precautions, and use of protective and emergency
  equipment
• Confined Space
• .any space having limited means of egress,
  subject to accumulation of toxic or flammable
  contaminants or oxygen deficient atmosphere

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Permit-Required Confined Spaces29 CFR 1910.146

• Confined Space Evaluation Even if Not Entering
• Determine Retrieval Equipment
• Determine Rescue Equipment
• Permits Retained For 1 Year
• Review Program Annually

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MULTIEMPLOYER WORKSITE POLICY

• Field Inspection Reference Manual Chapter II

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Affirmative defense employer can use to challenge
an OSHA citation
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Multiemployer Worksites

• Both construction and non-construction
• Citation normally issued to exposing employer
• Employers may be cited whether or not their own
  employees are exposed

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Multiemployer Worksites Citable Employers

• Employer who actually creates the hazard
  (creating employer)
• Employer responsible by contract
• Employer who has authority for ensuring hazardous
  conditions are corrected (controlling employer)
• Employer who has responsibility for correcting
  the hazard (correcting employer)

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Affirmative Defense - Exposing Employer

• Did not create the hazard
• Did not have the responsibility or authority to
  have hazard corrected
• did not have ability to correct or remove the
  hazard
• Specifically notifies controlling/correcting
  employer of the hazard
• Instructed employees to recognize and avoid the
  hazard
• Took appropriate steps to protect employees
• In extreme circumstances, removes employees

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Affirmative Defense (cont.)

• If employer meets all these defenses, the
  employer shall not be cited
• If all employees on worksite meet these
  conditions, only employers responsible for
  creating the hazard or in the best position to
  correct hazard may be cited
• Employers will be cited even though no employers
  are exposed
• All employees shall be trained in the policy

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Two Steps

• Determine whether creating, exposing,
  controlling, correcting employer
• Determine if the employers actions were
  sufficient to meet regulations
• (Extend of actions required varies based on the
  category)

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30 Day Inspections

• Emergency Respirators SCBA SARs
• Retrieval Equipment (Manufacturer Requirements)
• Fire Extinguishers Safety Inspections
• Overhead Crane Inspections

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Annual Inspections

• Fire Extinguishers Maintenance Inspection
• Overhead Crane Inspections
• Control of Hazardous Energy Periodic Inspections
  (Authorized Employees)
• Retrieval Equipment Competent Person Inspection
• Retractable Lifelines Manufacturer Inspection

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Periodic Inspections

• Work Place Job Tasks, Work Areas, Etc
• Weekly, Bi-weekly or monthly
• Inspection Should Include
• Personal Protective Equipment
• Flammable and Combustible Materials
• Portable Power Tools
• Lockout/Tagout
• Confined Spaces Equipment

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Periodic Inspections cont.

• Electrical
• Walking-Working Surfaces
• Chemicals
• Fire Protection
• Housekeeping

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Other Issues to Consider

• RF Training Cellular Carriers Proof on person
• Dust Emissions on YOUR property
• Hydrant Painting - 29CFR1926.62
• Chip Analysis
• Make sure the inspectors you hire are qualified
  and not just low bid!!!

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Certifications

• OSHA Authorized Outreach Trainers
• Certified Inspector National Association of
  Corrosion Engineers (NACE)
• Certified Protective Coatings Specialist w/
  Society for Protective Coatings (SSPC)
• Certified Associate Welding Inspector w/ American
  Welding Society (AWS)

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Schedule

• Annually
• Fit Testing
• Possible Medical Evaluations (Physician)
• Hearing Test
• Site-Specific Training Program Reviews
• Confined Space Entry Permit Review
• Confined Space Rescue Training

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Budget

• Annual
• Annual Training Refresher Rescue
• Air Monitoring Calibration Gas
• Retractable Lifelines Inspection
• Fire Extinguisher Maintenance Inspection
• Respirator Fit testing
• PPE

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Training Schedule

• Description
• Employee Emergency Plans
• Fire Prevention Plans
• Occupational Noise Exposure
• Emergency Response
• PPE
• Respiratory Protection

• Training
• Initial, Annual, Hands-on
• Initial, Annual
• Initial, PPE Purchased
• Initial, Annual, Hands-on
• Initial on Certifications, PPE Purchased Hands-on
• Initial, Annual Program Review, Annual Hands-on

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Training Schedule

• Permit-Required Confined Space
• Control of Hazardous Energy

• Initial, Annual Program Review, Annual Permit
  Review, Rescue Annual
• Initial, Annual Program Review, Periodic
  Certification Determines

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Training Schedule

• Fire Protection
• Portable Fire Extinguishers
• Welding, Cutting, Brazing
• Oxygen-Fuel Gas Welding Cutting
• Arc Welding Cutting

• Annual
• Annual
• Initial Training
• Initial Training
• Initial Training

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Training Schedule

• Electrical
• Bloodborne Pathogens
• Hazard Communications
• Scaffolding/Ladders

• Initial Training
• Initial, Annual Program Review
• Initial, Annual Program Review, Initial MSDS
• Initial Training

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Training Documentation

• Certification
• Date of Training
• Employer Include Department
• Employee
• Instructor Name Signature
• Agenda Description of Training

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Documentation Required

• All Training
• Reviews
• Respiratory Fit Testing
• Name/Identification of the Employee Tested
• Type of Fit Test Performed
• Make, Model, and Size of the Respirator Tested
• Date of the Fit Test
• Pass/Fail Results, Qualitative/Quantitative Fit
  Test

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Files

• Injury Illness Records
• Written Safety and Health Procedures
• Medical Records
• Training Records
• Inspection Records
• Fit Testing Records
• Chemical Inventory/MSDS
• Confined Space Entry Permits
• PPE Hazard Assessment Certificates

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Program Management

• Organization
• Planning
• Budget
• Communication
• Posters
• Safety Meetings
• Videos
• Commitment
• Management Participation

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Trainers

• Qualifications
• OSHA Authorized
• MSHA Authorized
• Other Certifications
• Presentation Ability What do YOU need
• Competent Persons
• Qualified Persons
• Authorized Persons

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What Can We Do For You

• Safety Manuals
• Training
• Plans Including RMP, ERP, Etc..
• Job Hazard Analysis
• Safety Audits
• What do you need