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OSHA Regulations often applied to commercial office

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Exposure Standards Alphabet Soup. Permissible Exposure Limits (PEL) ... Chemicals to remove graffiti. Inventory old chemicals from science & art rooms ... – PowerPoint PPT presentation

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Title: OSHA Regulations often applied to commercial office


1
OSHARegulations often applied to commercial
office schools
  • Rob Rottersman, MS, CIH
  • 847.685.9266
  • rrottersman_at_boelter-yates.com

2
Illinois
  • Non-Public Buildings/Employees
  • OSHA has jurisdiction
  • Public Buildings (including municipal and
    schools)
  • Illinois Department of Labor (IDOL) has
    jurisdiction
  • IDOL has adopted OSHA standards

3
Most Frequent Citations (National)October 2004
September 2005
  • Scaffolding (9,558)
  • Hazard Communication (7,564)
  • Fall Protection (6,483)
  • Respiratory Protection
  • Hazardous Energy/Lockout Tagout (2,281)
  • Total Citations (1 year) 113,362
  • 103,923,102 in fines

4
Scaffolding
  • OSHA 29CFR1910.27 Subpart D
  • Walking Working Surfaces
  • Defined Any temporary elevated platform and
    its supporting structure used for supporting
    workmen or materials or both
  • Regulations depend on scaffold type

5
Powered Platforms Manlifts
  • OSHA CFR1910.66
  • Specific for Building Maintenance
  • Regulations specific for type of lift
  • Includes standards for harnesses, use, inspection
    training
  • Protection from falling objects

6
(No Transcript)
7
Hazard Communication
  • OSHA 29CFR 1910.1200
  • http//www.osha.gov/pls/oshaweb/owadisp.show_docum
    ent?p_id10099p_tableSTANDARDS
  • Or Google Search OSHA 1910.1200
  • Who has a hazard communication program?
  • Is it compliant with the standard?

8
Purpose
  • PURPOSE Why do we need all this?
  • Ensure chemical hazards are evaluated
  • Information passed on to employee
  • Allow for safe use and handling
  • Emergency response (spills/exposure)

9
Key Elements
  • Written Program
  • Material Safety Data Sheets (MSDS)
  • Chemical Inventory
  • Training
  • Labeling

10
Written Program
  • How the School will Meet Requirements
  • Labeling/warning information
  • MSDS
  • Employee Information and Training
  • List of Hazardous Chemicals
  • Hazards of non-routine tasks
  • Outside contractor/visitor communication
  • Program must be available upon request

11
Labeling
  • Container Labels Must Contain
  • Identity of hazardous chemicals
  • Appropriate hazard warnings
  • Name address of manufacturer
  • Manufacturers label should be sufficient

12
When do you need to label?
  • Chemical transferred to other container and NOT
    used by 1 employee on 1 shift
  • Spray bottles are often overlooked
  • Science and art rooms often forgotten
  • Manufacturers labels is worn/illegible
  • Label is not in English

13
Labeling Exemptions
  • Articles Not gas, liquid or particle item with
    end use function (i.e. solid parts)
  • Materials regulated by other agencies
  • - Pesticides (but label required by EPA)
  • Food, Drugs, Cosmetics
  • Alcohol
  • Agricultural or vegetable seeds
  • Wood or wood products
  • Biological hazards
  • Radiation

14
Material Safety Data Sheets (MSDS)
  • Must have a MSDS for every hazardous chemical
    in the school
  • OSHA Hazardous Any chemical which is a
    physical or health hazard
  • All substances are poisons there is none that
    it is not a poison. The right dose differentiates
    a poison from a remedy
  • Paracelsus 1493-1541

15
MSDS Contents
  • Name Product Identity
  • Physical chemical characteristics
  • Physical hazards
  • Health hazards
  • Routes of entry
  • Whether or not it can cause cancer
  • Precautions for safe handling
  • Control measures (ventilation, PPE, etc)
  • Emergency first aid
  • Date of MSDS preparation and revision
  • Contact info. for manufacturer

16
Exposure Standards Alphabet Soup
  • Permissible Exposure Limits (PEL)
  • OSHA Standard enforceable
  • Subject to industry lobbying
  • Recommended Exposure Limit (REL)
  • National Institute of Occupational Safety and
    Health (NIOSH)
  • Research based not enforceable
  • Threshold Limit Value (TLV)
  • American Conference of Govt. Industrial
    Hygienists (ACGIH)
  • Recommended but not enforceable

17
Health Considerations
  • Review significant routes of entry
  • Skin contact, inhalation, ingestions
  • Chronic vs. Acute
  • Chronic delayed response
  • i.e. cancer, cirrhosis
  • Acute effect short time after exposure
  • Irritation, headaches, dizziness, allergic

18
MSDS Maintenance
  • Obtain from chemical manufacturer
  • MSDS must be readily immediately accessible to
    employees
  • Electronic files are permitted if employees have
    access
  • Keep current periodic review for updates

19
MSDS Recommendations
  • Establish maintain a new product introduction
    program
  • Have 1 person designated to approve all new
    products brought onto school grounds
  • Approval requires submitting MSDS sheet, review
    for hazards training if needed

20
Chemical Inventory List
  • List of all hazardous chemicals found in the
    facility
  • Must include the name used on the MSDS sheet
  • Consider using as an MSDS index

21
Training
  • All employees who use or could come in contact
    with hazardous chemicals must be trained
  • At the time of hiring
  • Before beginning a new assignment/job change
  • Whenever there is a new hazard that was not
    included in previous training
  • Whenever new hazards are discovered for an
    existing product

22
Non-routine Tasks
  • Often overlooked
  • could be significant health and safety hazards
  • Examples in schools could include
  • Cleaning, using chemicals in confined space such
    as crawlspaces
  • Handling cooling tower treatment chemicals
  • Chemicals to remove graffiti
  • Inventory old chemicals from science art rooms

23
Outside Contractors/Vendors
  • Must inform of hazards associated with products
    they use or may come in contact with
  • Notify them of written program and location of
    MSDS sheets
  • Provide training as needed

24
Chemicals Used by Vendors at Your School
  • Janitorial cleaning crews, contractors, pesticide
    applicators, etc.
  • Make sure they have provided you with MSDS sheets
  • Review to ensure they are complete up to date
  • KNOW THE LOCATION of their MSDS sheets AND inform
    your employees

25
Fall Protection
  • Multiple references in the standard
  • OSHA CFR1910.21-1910.27 Appendix D
  • Guards and rails
  • Floor openings, uneven floor surfaces, etc.
  • Ladders Stairs
  • Wood vs. metal fixed vs. permanent

26
Respiratory Protection
  • OSHA CFR1910.134, .139
  • Respirators as a last resort for reducing
    chemical exposures to safe levels.
  • Better Options
  • - Eliminate hazard (product substitution)
  • - Engineering controls (ventilation)

27
Respirator Programs
  • If employees use respirators an OSHA respirator
    program must be in place
  • Appropriate Respirator Selection
  • Annual Training
  • Annual Fit Testing
  • Medical Evaluations
  • Exposure Assessments

28
Dust Mask Exemption
  • OSHA CFR1910.134(c)(2)(i)(ii)
  • Dust Mask (filtering face piece) may be worn if
  • Use is voluntary (not required by employer)
  • The respirator itself will not create a hazard
  • Employer provides employee with information
    contained in OSHA Appendix D
  • Information for Employees Using Respirators When
    Not Required Under the Standard

29
Respirator Selection
30
Safety Shoes
  • 29CFR1910.136
  • Required when danger of injury from falling or
    rolling objects, objects may pierce the sole or
    feet are exposed to electrical hazard

31
Eye Protection
  • 29CFR1910.133
  • Eye face protection shall be worn when exposed
    to eye or face hazards from flying particles,
    molten metal, liquid chemicals, acids or
    caustics, chemical gases or vapors or injurious
    light radiation

32
LockOut/TagOut(Control of Hazardous Energy)
  • OSHA 29CFR1910.147
  • Covers the servicing and maintenance of machines
    and equipment in which the unexpected start up or
    release of stored energy could cause injury to
    employees

33
LO/TO Requirements
  • Written Program/Policy
  • Define Authorized employees
  • Understand the machines energy
  • Trained in LO/TO
  • Authorized to install remove locks/tags
  • Define Effected Employees
  • Employees who may operate locked or tagged out
    equpment

34
Actions Requiring LO/TO
  • Removing or bypassing a safety device
  • Any part of the body is placed in harms way
  • Exposure to hazardous energy

35
OSHA Record Keeping
  • 29CFR1904
  • AKA 300 Log
  • Includes
  • Determining if injuries are recordable
  • Logging injuries (300 Form)
  • Investigate cause (301 Form)
  • Post summary - Feb-April (300-A Form)

36
Blood Borne Pathogens
  • 29CFR1910.1030
  • Program required when there are employees with
    potential exposure
  • Health care
  • First Responders/First Aid Providers
  • Janitorial (restroom cleaning)
  • Annual training required
  • Post exposure vaccination program
  • Hepatitis B Virus

37
Safety Quiz Whos Liable?
  • Bob dropped a banana peel, slipped and fractured
    his skull, whos at fault?
  • Bob
  • Bobs school district supervisor
  • Floor wax manufacturer
  • Banana importer
  • Grocery store
  • Newspaper that advertised banana sale
  • The Banana farmer

38
You Know an IDOL Inspection is going bad when-
  • IDOL sets up temp. housing in your parking lot
  • The officer mutters this is unbelievable
  • They call in a professional film crew for
    documentation and you recognize Walter Jacobson
  • Officer is wearing a moon suit and respirator
    your staff is in jeans and tennis shoes
  • Officer begins inspection with you have the
    right to remain silent
  • Officer asks a specific question about a note in
    your files (before you show him the file)
  • Officer knows all your staff by their first names
  • Officer is a former science teacher that you fired

39
Speaker Contact Information
  • Rob Rottersman, MS, CIH
  • Senior Environmental Consultant
  • Boelter Yates, Inc.
  • 1300 Higgins Rd. Ste 301
  • Park Ridge, IL 60068
  • rrottersman_at_boelter-yates.com
  • IASBO Booth 432
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