Cleaning & Decontamination of Ebola Pt 3

Follow applicable OSHA standards

• Employers must ensure that they comply with OSHA’s Bloodborne Pathogens standard, 29 CFR 1910.1030, to protect workers who may be exposed to blood or other potentially infectious materials.
• OSHA’s Personal Protective Equipment (PPE) standard, 29 CFR 1910.132, provides additional information about how to select and use appropriate PPE, training and other requirements.
• Employers must comply with OSHA’s Hazard Communication standard, 29 CFR 1910.1200, when their workers use certain chemicals for cleaning and decontamination.
• In some cases where a specific OSHA standard doesn’t apply, the General Duty Clause (Sec. 5(a)(1)) of the Occupational Safety and Health Act (OSH Act) requires employers to furnish to each employee employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to employees.

Assistance for employers

OSHA’s On-site Consultation Program offers free and confidential advice to small and medium-sized businesses in all states across the country, with priority given to high-hazard worksites. On-site Consultation services are separate from enforcement and do not result in penalties or citations. Consultants from state agencies or universities work with employers to identify workplace hazards, provide advice on compliance with OSHA standards, and assist in establishing safety and health management systems. To locate the OSHA On-site Consultation Program nearest you, call 1-800-321-6742 (OSHA).

Cleaning & Decontamination of Ebola on Surfaces Pt 2

Guidelines for waste disposal

• Soak materials and PPE used in cleanup and decontamination in disinfectant, double-bag, and place in a leak-proof container to further reduce the risk of worker exposure. Use a puncture-proof container for sharps.
• It may be necessary to dispose of contaminated objects with porous surfaces that cannot be disinfected.
• Dispose of waste from surface cleanup in accord with CDC guidelines and the U.S. Department of Transportation’s (DOT) Hazardous Materials Regulations (HMR), at www.cdc.gov/vhf/ebola/hcp and phmsa.dot.gov/hazmat/transporting-infectious-substances.

Use appropriate respiratory protection

• In instances where workers may be exposed to bio-aerosols (e.g., as a result of spraying liquids or air during cleaning) suspected of or known to contain Ebola virus, additional respiratory protection is needed. In these cases, medically qualified workers must use, at a minimum, a NIOSH-approved, fit-tested N95 respirator.
• Wearing a respirator for extended periods of time can be uncomfortable. Workers who need respirators for long durations may find powered air-purifying respirators more tolerable.
• Respirators or face masks used for protecting workers against Ebola virus may not be effective for also protecting them from exposure to certain toxic chemicals used for cleaning and decontamination. To learn more about the requirements for selecting an appropriate respirator to protect against chemical exposure (elastomeric respirator with appropriate chemical cartridges or a supplied-air respirator), consult OSHA’s Respiratory Protection standard, 29 CFR 1910.134, and the manufacturer’s Safety Data Sheet (SDS) for the specific chemical(s) that workers are using. See OSHA’s Respiratory Protection web page: www.osha.gov/SLTC/respiratoryprotection.

Cleaning & Decontamination of Ebola on Surfaces

Guidance for Workers and Employers in Non-Healthcare/Non-Laboratory Settings

Workers tasked with cleaning surfaces that may be contaminated with Ebola virus, the virus that causes Ebola hemorrhagic fever (EHF), must be protected from exposure. Employers are responsible for ensuring that workers are protected from exposure to Ebola and that workers are not exposed to harmful levels of chemicals used for cleaning and disinfection.

Guidelines for cleaning and disinfection
• Immediately clean and disinfect any visible surface contamination from blood, urine, feces, vomit, or other body fluids that may contain Ebola virus.
• Isolate areas of suspected Ebola virus contamination until decontamination is completed to minimize exposure to individuals not performing the work.
• Cover spills with absorbent material (e.g., paper towels), then pour disinfectant on to saturate the area, and allow bleach to soak into spills for at least 30 minutes before cleaning to allow it to kill any virus or other infectious agents that may be present.
• Treat any visible contamination or bulk spill matter with a suitable disinfectant (described on p. 2) before cleaning up and removing bulk material.
• After disinfecting and removing bulk material, clean and decontaminate the surface using the disinfectant.
• Ensure adequate ventilation in areas where workers are using disinfectants, including by opening windows and doors, or using mechanical ventilation equipment.
• In some cases, the use of chemical disinfectants may require an employer to train workers about how to protect themselves against chemical hazards and comply with OSHA ‘s Hazard Communication, 29 CFR 1910.1200, and other standards.
• Use tools, such as tongs from a spill kit, as much as possible rather than doing cleanup work directly with gloved hands.
• After cleaning and disinfection work is complete, remove PPE as follows: gloves,
face shield/goggles, gown, and then mask/respirator. Wash hands with soap and water, or use an alcohol-based hand gel if no running water is available.
• Avoid cleaning techniques, such as using pressurized air or water sprays, that may result in the generation of bio-aerosols (aerosolized droplets containing infectious particles that can be inhaled).

OSHA launches dialogue on hazardous chemical exposures and PEL

 OSHA launches national dialogue on hazardous chemical exposures
and permissible exposure limits in the workplace

WASHINGTON – The U.S. Department of Labor's Occupational Safety and Health Administration today announced it is launching a national dialogue with stakeholders on ways to prevent work-related illness caused by exposure to hazardous substances. The first stage of this dialogue is a request for information on the management of hazardous chemical exposures in the workplace and strategies for updating permissible exposure limits.

OSHA's PELs, which are regulatory limits on the amount or concentration of a substance in the air, are intended to protect workers against the adverse health effects of exposure to hazardous substances. Ninety-five percent of OSHA's current PELs, which cover fewer than 500 chemicals, have not been updated since their adoption in 1971. The agency's current PELs cover only a small fraction of the tens of thousands of chemicals used in commerce, many of which are suspected of being harmful. Substantial resources are required to issue new exposure limits or update existing workplace exposure limits, as courts have required complex analyses for each proposed PEL.

"Many of our chemical exposure standards are dangerously out of date and do not adequately protect workers," said Assistant Secretary of Labor for Occupational Safety and Health Dr. David Michaels. "While we will continue to work on updating our workplace exposure limits, we are asking public health experts, chemical manufacturers, employers, unions and others committed to preventing workplace illnesses to help us identify new approaches to address chemical hazards."

OSHA is seeking public comment regarding current practices and future methods for updating PELs, as well as new strategies for better protecting workers from hazardous chemical exposures. Specifically, the agency requests suggestions on:
  • possible streamlined approaches for risk assessment and feasibility analyses and
  • alternative approaches for managing chemical exposures, including control banding, task-based approaches and informed substitution.
The goal of this public dialogue is to give stakeholders a forum to develop innovative, effective approaches to improve the health of workers in the United States. In the coming months, OSHA will announce additional ways for members of the public to participate in the conversation.

The comment period for the RFI will continue for 180 days. Instructions for submitting comments are available in the Federal Register, Docket No. OSHA-2012-0023, at https://federalregister.gov/a/2014-24009. For more information, please visit the OSHA Chemical Management Request for Information Web page at http://www.osha.gov/chemicalmanagement/index.html.

Under the Occupational Safety and Health Act of 1970, employers are responsible for providing safe and healthful workplaces for their employees. OSHA's role is to ensure these conditions for America's working men and women by setting and enforcing standards, and providing training, education and assistance.

Mexican Consolate Health Fair in Atlanta

Representatives from OSHA and the Department of Labor’s Wage and Hour Division were among 25 exhibitors at a mobile Mexican Consulate Health Fair in Gainesville, Ga., from August 19 – 22. The four-day event was attended by more than 2,000 visitors, many of them workers in the poultry and construction industries. OSHA personnel provided information in English and Spanish on workplace safety, workers’ rights and how to file a complaint. 

OSHA has an alliance with the Consulate General of Mexico in Atlanta, which provided consular identification cards and passports at the event. The health fair was a joint effort between OSHA’s Atlanta Area Offices, Emory University Rollins School of Public Health/Ventanilla de Salud Atlanta and Cielos Abiertos Christian Church.

Bilingual OSHA staff at Mexican Consulate Health Fair 
Bilingual OSHA staff at the Mexican Consulate Health Fair in Gainesville, Ga. From left: Presidential Management Fellow Ethel Moreno and Compliance Officers Francine Cruz, Maria Martinez and Hector Julian-Camacho

Initiative to help employers protect workers from occupational noise

“Buy Quiet” is a prevention initiative launched by the National Institute for Occupational Safety and Health to help companies buy, rent or design quieter machines and tools for their workplaces. Each year millions of U.S. workers are exposed to noise loud enough to be hazardous to their health.

Buy Quiet

Overview

Noise-induced hearing loss is the most common work-related illness in the United States. Each year approximately 22 million U.S. workers are exposed to noise loud enough to damage their hearing. To create a more healthful workplace, the National Institute for Occupational Safety and Health (NIOSH) recommends preventing hazardous noise through controls for noise exposure and encourages business owners to create Buy Quiet programs as a first step.

What is Buy Quiet? 

Buy Quiet is a prevention initiative which:
  • Encourages companies to purchase or rent quieter machinery and tools to reduce worker noise exposure. This is accomplished when new businesses start up or when older equipment is replaced.
  • Provides information on equipment noise levels, so companies can buy quieter products that make the workplace safer.
  • Encourages manufacturers to design quieter equipment by creating a demand for quieter products.

Why Buy Quiet?

Noise-induced hearing loss can't be reversed, but it is 100% preventable. NIOSH recommends that workers should not be exposed to noise at a level that amounts to more than 85 decibels (dBA) for 8 hours. Buy Quiet can help you stay below the recommended exposure level for noise.
Play the audio files and compare two same sized yet different circular saws cutting a 1 inch thick piece of oak board. Can you hear the difference?

 Benefits of Buy Quiet?

  • Reducing the risk of hearing loss.
  • Reducing the long-term costs of audiometric testing, personal protective equipment, and workers compensation. Conservative estimates provide $100 per dBA of savings when purchasing the quieter product.1 This savings is applicable across a wide variety of machinery and equipment.
  • Helping companies comply with OSHA and other noise regulation requirements.
  • Reducing the impact of noise on the community.

OSHA, NIOSH Publish recommended practices

OSHA and the National Institute for Occupational Safety and Health recently released Recommended Practices (PDF*) for staffing agencies and host employers to better protect temporary workers from hazards on the job. The Recommended Practices publication highlights the joint responsibility of the staffing agency and host employer to ensure temporary workers are provided a safe work environment.

“An employer's commitment to the safety of temporary workers should not mirror these workers' temporary status,” said Assistant Secretary of Labor for Occupational Safety and Health Dr. Michaels. “Whether temporary or permanent, all workers always have a right to a safe and healthy workplace. Staffing agencies and the host employers are joint employers of temporary workers and both are responsible for providing and maintaining safe working conditions.”

The new guidance recommends that staff agency/host employer contracts clearly define the temporary workers’ tasks and the safety and health responsibilities of each employer. Staffing agencies should maintain contact with temporary workers to verify that the host has fulfilled its responsibilities for a safe workplace. For more information the news release below.

Trade News Release Banner Image

Aug. 25, 2014
Contact: Office of Communications
Phone: 202-693-1999


OSHA, NIOSH announce recommended practices to protect temporary
workers' safety and health

WASHINGTON – The Occupational Safety and Health Administration and the National Institute for Occupational Safety and Health today released Recommended Practices for staffing agencies and host employers to better protect temporary workers from hazards on the job.

Assistant Secretary of Labor for Occupational Safety and Health Dr. David Michaels made the announcement today at the Voluntary Protection Programs Participants' Association annual conference in National Harbor, Md. The new Recommended Practices publication highlights the joint responsibility of the staffing agency and host employer to ensure temporary workers are provided a safe work environment.
"An employer's commitment to the safety of temporary workers should not mirror these workers' temporary status," said Dr. Michaels. "Whether temporary or permanent, all workers always have a right to a safe and healthy workplace. Staffing agencies and the host employers are joint employers of temporary workers and both are responsible for providing and maintaining safe working conditions. Our new Recommended Practices publication highlights this joint responsibility."

Temporary workers are at increased risk of work-related injury and illness. OSHA's Temporary Worker Initiative, launched last year, includes outreach, training and enforcement to assure that temporary workers are protected in their workplaces. In recent months, OSHA has received and investigated many reports of temporary workers suffering serious or fatal injuries, some in their first days on the job. The Recommended Practices publication focuses on ensuring that temporary workers receive the same training and protection that existing workers receive.

"Workers sent by a staffing agency to a worksite deserve the same level of protection from workplace hazards as the host employer's workers do," said NIOSH Director Dr. John Howard. "Recognizing that temporary workers are often new to the workplace to which they are sent, we believe these recommended practices will provide a strong foundation for host employers and staffing agencies to work together to provide a comprehensive program that protects the safety and health of all workers."

The new guidance recommends that staff agency/host employer contracts clearly define the temporary worker's tasks and the safety and health responsibilities of each employer. Staffing agencies should maintain contact with temporary workers to verify that the host has fulfilled its responsibilities for a safe workplace.

Impalement hazards on construction sites

March 18, 2014

Eric M. Dean
General Secretary
International Association of
Bridge, Structural, Ornamental and Reinforcing Iron Workers
Suite 400
1750 New York Ave. NW
Washington, DC 20006

Dear Mr. Dean:

Thank you for your March 12, 2013, letter to the Occupational Safety and Health Administration (OSHA). You asked for clarification regarding impalement hazards on construction worksites. Specifically, whether OSHA recognizes objects other than reinforcing steel as impalement hazards and, if so, what standards are applicable?

Yes. OSHA recognizes that there are objects other than reinforcing steel that can present potential impalement hazards. OSHA has two construction standards which apply to impalement hazards.
29 CFR 1926.701(b) applies to reinforcing steel. It states:
All protruding reinforcing steel, onto and into which employees could fall, shall be guarded to eliminate the hazard of impalement.
29 CFR 1926.25(a) applies to protruding nails. It states:
During the course of construction, alteration, or repairs, form and scrap lumber with protruding nails, and all other debris, shall be kept cleared from work areas, passageways, and stairs, in and around buildings or other structures.
In addition, with respect to impalement hazards not covered by these standards, the General Duty Clause (section 5(a)(1)) of the Occupational Safety and Health Act requires employers to furnish a workplace which is free from recognized hazards that are causing or are likely to cause death or serious physical harm. Therefore, employers are required to protect employees exposed to the hazard of impalement by sharp objects. For example, where steel stakes and metal conduit pose a recognized impalement hazard and there are feasible means of protection, the employer is required to implement protective measures that eliminate or materially reduce the hazard.

OSHA answered similar questions in a letter to Mr. Paul Resler, dated August 3, 1999. We have attached a copy of the letter. You can also find the letter on OSHA's website at: http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_id=23267&p_table=INTERPRETATIONS

Thank you for your interest in occupational safety and health. We hope you find this information helpful. OSHA's requirements are set by statute, standards, and regulations. Our letters of interpretation do not create new or additional requirements but rather explain these requirements and how they apply to particular circumstances. This letter constitutes OSHA's interpretation of the requirements discussed. From time to time, letters are affected when the Agency updates a standard, a legal decision impacts a standard, or changes in technology affect the interpretation. To ensure that you are using the correct information and guidance, please consult OSHA's website at http://www.osha.gov. If you have further questions, please feel free to contact the Directorate of Construction at (202) 693-2020.

Sincerely,

James G. Maddux, Director
Directorate of Construction

OSHA helps workers, employers beat the heat with smart phone app and other resources



Every year, dozens of workers are killed by heat, and thousands more experience heat-related illnesses. With summer heat on the rise across the nation, workers and employers are turning to OSHA's Heat Safety Tool for help staying safe in the heat. In all, more than 148,000 users have downloaded this life-saving app since its launch in August 2011.
Heat Illness Prevention campaign
OSHA, state and local government and corporate representatives meet in Phoenix July 1 to promote "Water. Rest. Shade."
As temperatures soared well past 100 degrees in Phoenix on July 1, OSHA staff joined representatives from the Phoenix City Council, Clear Channel Outdoor, Lamar Advertising, Christy Signs, the American Society of Safety Engineers, and the Arizona Division of Occupational Safety and Health to promote OSHA’s "Water. Rest. Shade." campaign. Lamar and Clear Channel have posted heat campaign billboards across the country.

In a July 7 article in The Washington Post, Assistant Secretary of Labor for Occupational Safety and Health Dr. David Michaels explained employers' obligation to protect construction crews, road workers, farm workers, trash collectors and others who are working outdoors this summer in high heat — including temporary workers who often are not used to working in heat and need to be acclimated. The Post article highlighted OSHA's interactive map that plots heat-related fatalities among outdoor workers between 2008 and 2013.

OSHA Trade News - New directive to keep communication tower workers safe

Trade News Release Banner Image


July 24, 2014
Contact: Office of Communications
Phone: 202-693-1999

OSHA issues new directive to keep communication tower workers safe

WASHINGTON - The Occupational Safety and Health Administration has updated its Communications Tower directive regarding the use of hoist systems used to move workers to and from workstations on communication towers. This follows an alarming increase in preventable injuries and fatalities at communication tower work sites.

More fatalities occurred in this industry in 2013 than in the previous two years combined. This disturbing trend appears to be continuing, with nine worker deaths occurring so far in 2014.

"This directive ensures that communication tower workers are protected regardless of the type of the work they are doing on communication towers," said Dr. David Michaels, assistant secretary of labor for occupational safety and health. "Employers and cell tower owners and operators must make sure workers are properly trained and protected."

The directive outlines the proper use of hoist and other fall arrest systems and includes detailed information on how to hoist people safely. The directive updates a 2002 enforcement policy, which only covered the hoisting of workers to workstations during new tower erection activities. The updated policy covers any work on a communication tower - including both maintenance and new construction - that involves the use of a hoist to lift workers from one elevated workstation to another.

The release of the new directive is the latest in a series of actions OSHA has taken to improve cell tower safety. The agency is collaborating with the National Association of Tower Erectors and other industry stakeholders to ensure that every communication tower employer understands how to protect workers performing this high-hazard work.

OSHA sent a letter to communication tower employers urging compliance and strict adherence to safety standards and common-sense practices. OSHA has also created a new Web page targeting the issues surrounding communication tower work. This outreach follows a November 2013 memo to OSHA's compliance officers and regional administrators mandating increased attention, education and data collection on the industry. OSHA continues to investigate past incidents and will issue the results as they become available. Communication towers are on the agency's regulatory agenda and OSHA expects to issue a Request for Information later this year.

Under the Occupational Safety and Health Act of 1970, employers are responsible for providing safe and healthful workplaces for their employees. OSHA's role is to ensure these conditions for America's working men and women by setting and enforcing standards, and providing training, education and assistance. For more information, visit www.osha.gov.

Regional News Release - ND high-hazard industries

Trade News Release Banner Image


Region 8 News Release: 14-1277-DAK
July 15, 2014
Contact: Scott Allen      Rhonda Burke
Phone:       312-353-6976
Email: allen.scott@dol.gov      burke.rhonda@dol.gov

US Department of Labor's OSHA launches focused enforcement program to
prevent injuries and fatalities in North Dakota’s high-hazard industries

BISMARCK, N.D. – Since January 2012, 34 North Dakota workers in the oil and gas and construction industries have died because of work-related injuries. During that period, their deaths accounted for 87 percent of all North Dakota fatalities investigated by the U.S. Department of Labor's Occupational Health and Safety Administration. OSHA launched an enforcement emphasis program this month to address continued concerns about worker safety in these North Dakota industries that temporarily brings in additional investigators from throughout the United States to increase OSHA's field presence in North Dakota.
OSHA's Oil and Gas Well Drilling eTool: Site Map, Site Preparation, Drilling, Well Completion, Servicing, Plug & Abandon, General Safety
OSHA's Oil and Gas Well Drilling eTool
"These industries are inherently dangerous, and workers are exposed to multiple hazards every day. Their safety must not be compromised because demand for production keeps increasing," said Eric Brooks, OSHA's area director in Bismarck. "Workers are coming to these growing industries to find jobs, not catastrophic injury and preventable death. These employers have a legal responsibility to protect every employee that works for them."

Of the 34 fatalities since 2012, 21 workers died while working on and servicing drilling rigs or conducting production support operations in the oil and gas industry. Workers are exposed daily to serious hazards, such as fires, explosions and equipment-related dangers. Additionally, 13 construction workers have died because of falls, struck-by hazards and trench cave-ins. Fall hazards in construction remain the leading cause of death in the industry, with hundreds of lives lost nationally each year. 

OSHA has had a local emphasis program for the oil and gas industry for the last three years, which outlines hazards and allows for increased enforcement. The enforcement program includes chemical sampling of fracking and tank gauging operations to test for atmospheric hazards, violations found in recent inspections. In addition, OSHA's Oil and Gas Well Drilling eTool identifies common hazards and possible solutions to reduce incidents that could lead to injuries or fatalities. 

OSHA has also participated in outreach events with oil and gas employers, including a multistate stand-down with the Montana-North Dakota chapter of the National Service, Transmission, Exploration and Production Safety Network in which more than 160 employers and 1,000 workers voluntarily ceased operations for one day to discuss hazards and effective means to address them. 

"Since we started the original emphasis program, we have seen improvement in North Dakota's oil fields, and the fatality rate has decreased. But no death is ever acceptable, and these industries are still hazardous for North Dakota's workers," Brooks said. "OSHA will continue to use its full enforcement authority-along with these new outreach efforts-to achieve the goal of every worker going home safely each day to their loved ones."

Under the Occupational Safety and Health Act of 1970, employers are responsible for providing safe and healthful workplaces for their employees. OSHA's role is to ensure these conditions for America's working men and women by setting and enforcing standards, and providing training, education and assistance. For more information, visit http://www.osha.gov.
Trade News Release Banner Image


June 26, 2014
Contact: Office of Communications
Phone: 202-693-1999

OSHA urges increased safety awareness in fireworks industry in advance of July 4 celebrations

WASHINGTON - The Occupational Safety and Health Administration is urging the fireworks and pyrotechnics industry to be vigilant in protecting workers from hazards while manufacturing, storing, transporting, displaying and selling fireworks for public events.

"As we celebrate the July 4 holiday with fireworks and festivities, we must also be mindful of the safety of workers who handle pyrotechnics," said Assistant Secretary of Labor for Occupational Safety and Health Dr. David Michaels. "Employers are responsible for keeping everyone safe on the job and taking appropriate measures to protect workers from serious injuries or death."

Washington state occupational safety and health officials are investigating an explosion that occurred last week at a fireworks facility, killing one worker and injuring two more. In another recent incident, a worker suffered fatal burns caused by an explosion at a fireworks facility. OSHA cited the company more than $45,000 for safety violations relating to explosive hazards.

OSHA's Web page on the pyrotechnics industry addresses retail sales of fireworks and fireworks displays. Information on common hazards and solutions found in both areas of the industry, and downloadable safety posters for workplaces are available at http://www.osha.gov/SLTC/pyrotechnic/index.html. It also includes a video, available at http://www.osha.gov/video/fireworks/index.html, which demonstrates best industry practices for retail sales and manufacturers based on National Fire Protection Association consensus standards.

Under the Occupational Safety and Health Act of 1970, employers are responsible for providing safe and healthful workplaces for their employees. OSHA's role is to ensure these conditions for America's working men and women by setting and enforcing standards, and providing training, education and assistance. For more information, visit www.osha.gov.

Job Hazard Analysis Part 7

Why should I review my job hazard analysis?

Periodically reviewing your job hazard analysis ensures that it remains current and continues to help reduce
workplace accidents and injuries. Even if the job has not changed, it is possible that during the review process you will identify hazards that were not identified in the initial analysis.

It is particularly important to review your job hazard analysis if an illness or injury occurs on a specific job.
Based on the circumstances, you may determine that you need to change the job procedure to prevent similar incidents in the future. If an employee’s failure to follow proper job procedures results in a “close call,” discuss the situationwith all employees who perform the job and remind them of proper procedures. Any time you revise a job hazard analysis, it is important to train all employees affected by the changes in the new job methods, procedures, or protective measures adopted.

When is it appropriate to hire a professional to conduct a job hazard analysis?

If your employees are involved in many different or complex processes, you need professional help conducting your job hazard analyses. Sources of help include your insurance company, the local fire department, and private consultants with safety and health expertise. In addition, OSHA offers assistance through its regional and area offices and consultation services. Contact numbers are listed at the back of this publication.

Even when you receive outside help, it is important that you and your employees remain involved in the process of identifying and correcting hazards because you are on the worksite every day and most likely to encounter these hazards. New circumstances and a recombination of existing circumstances may cause old hazards to reappear and new hazards to appear. In addition, you and your employees must be ready and able to implement whatever hazard elimination or control measures a professional consultant recommends.

Job Hazard Analysis Part 6

How do I correct or prevent hazards?

After reviewing your list of hazards with the employee, consider what control methods will eliminate or reduce them. For more information on hazard control measures, see Appendix 1. The most effective controls are engineering controls that physically change a machine or work environment to prevent employee exposure to the hazard. The more reliable or less likely a hazard control can be circumvented, the better. If this is not feasible, administrative controls may be appropriate. This may involve changing how employees do their jobs.

Discuss your recommendations with all employees who perform the job and consider their responses carefully. If you plan to introduce new or modified job procedures, be sure they understand what they are required to do and the reasons for the changes.

What else do I need to know before starting a job hazard analysis?

The job procedures discussed in this booklet are for illustration only and do not necessarily include all the
steps, hazards, and protections that apply to your industry. When conducting your own job safety analysis, be sure to consult the Occupational Safety and Health Administration standards for your industry. Compliance with these standards is mandatory, and by incorporating their requirements in your job hazard analysis, you can be sure that your health and safety program meets federal standards. OSHA standards, regulations, and technical information are available online at www.osha.gov.

Twenty-four states and two territories operate their own OSHA-approved safety and health programs and may have standards that differ slightly from federal requirements. Employers in those states should check with the appropriate state agency for more information.

Job Hazard Analysis Part 5

Example Job Hazard Analysis Form

Job Location:
Metal Shop
Analyst:
Joe Safety
Date:
Task Description: Worker reaches into metal box to the right of the machine, grasps a 15-pound casting and carries it to grinding wheel. Worker grinds 20 to 30 castings per hour.
Hazard Description: Picking up a casting, the employee could drop it onto his foot. The casting's weight and height could seriously injure the worker's foot or toes.
Hazard Controls:
1. Remove castings from the box and place them on a table next to the grinder.
2. Wear steel-toe shoes with arch protection.
3. Change protective gloves that allow a better grip.
4. Use a device to pick up castings.

Job Location:
Metal Shop
Analyst:
Joe Safety
Date:
Task Description: Worker reaches into metal box to the right of the machine, grasps a 15-pound casting and carries it to grinding wheel. Worker grinds 20 to 30 castings per hour.
Hazard Description:Castings have sharp burrs and edges that can cause severe lacerations.
Hazard Controls:
1. Use a device such as a clamp to pick up castings.
2. Wear cut-resistant gloves that allow a good grip and fit tightly to minimize the chance that they will get caught in grinding wheel.

Job Location:
Metal Shop
Analyst:
Joe Safety
Date:
Task Description: Worker reaches into metal box to the right of the machine, grasps a 15-pound casting and carries it to grinding wheel. Worker grinds 20 to 30 castings per hour.
Hazard Description: Reaching, twisting, and lifting 15-pound castings from the floor could result in a muscle strain to the lower back.
Hazard Controls:
1. Move castings from the ground and place them closer to the work zone to minimize lifting. Ideally, place them at waist height or on an adjustable platform or pallet.
2. Train workers not to twist while lifting and reconfigure work stations to minimize twisting during lifts.

Repeat similar forms for each job step.

Job Hazard Analysis Part 4

• How likely is it that the hazard will occur? This determination requires some judgment. If there have
been “near-misses” or actual cases, then the likelihood of a recurrence would be considered high. If the pulley is exposed and easily accessible, that also is a consideration. In the example, the likelihood that the hazard will occur is high because there is no guard preventing contact, and the operation is performed while the machine is running. By following the steps in this example, you can organize your hazard analysis activities.

The examples that follow show how a job hazard analysis can be used to identify the existing or potential hazards for each basic step involved in grinding iron castings.

Grinding Iron Castings: Job Steps Step

Step 1. Reach into metal box to right of machine, grasp casting, and carry to wheel.
Step 2. Push casting against wheel to grind off burr.
Step 3. Place finished casting in box to left of machine.

Job Hazard Analysis Part 3

How do I identify workplace hazards?

A job hazard analysis is an exercise in detective work. Your goal is to discover the following:
• What can go wrong?
• What are the consequences?
• How could it arise?
• What are other contributing factors?
• How likely is it that the hazard will occur?

To make your job hazard analysis useful, document the answers to these questions in a consistent manner.
Describing a hazard in this way helps to ensure that your efforts to eliminate the hazard and implement hazard controls help target the most important contributors to the hazard.
Good hazard scenarios describe:
• Where it is happening (environment),
• Who or what it is happening to (exposure),
• What precipitates the hazard (trigger),
• The outcome that would occur should it happen (consequence), and
• Any other contributing factors.

A sample form found in Appendix 3 helps you organize your information to provide these details.

Rarely is a hazard a simple case of one singular cause resulting in one singular effect. More frequently, many contributing factors tend to line up in a certain way to create the hazard. Here is an example of a hazard scenario:
In the metal shop (environment), while clearing a snag (trigger), a worker’s hand (exposure) comes into contact with a rotating pulley. It pulls his hand into the machine and severs his fingers (consequences) quickly.
To perform a job hazard analysis, you would ask:
What can go wrong? The worker’s hand could come into contact with a rotating object that “catches” it and pulls it into the machine.
What are the consequences? The worker could receive a severe injury and lose fingers and hands.
How could it happen? The accident could happen as a result of the worker trying to clear a snag during
operations or as part of a maintenance activity while the pulley is operating. Obviously, this hazard scenario
could not occur if the pulley is not rotating.
What are other contributing factors? This hazard occurs very quickly. It does not give the worker much
opportunity to recover or prevent it once his hand comes into contact with the pulley. This is an important factor, because it helps you determine the severity and likelihood of an accident when selecting appropriate
hazard controls. Unfortunately, experience has shown that training is not very effective in hazard control when
triggering events happen quickly because humans can react only so quickly.

Job Hazard Analysis Part 2

What jobs are appropriate for a job hazard analysis?

A job hazard analysis can be conducted on many jobs in your workplace. Priority should go to the following types of jobs:
• Jobs with the highest injury or illness rates;
• Jobs with the potential to cause severe or disabling injuries or illness, even if there is no history of previous
accidents;
• Jobs in which one simple human error could lead to a severe accident or injury;
• Jobs that are new to your operation or have undergone changes in processes and procedures; and
• Jobs complex enough to require written instructions.

Where do I begin?

1. Involve your employees. It is very important to involve your employees in the hazard analysis process.
They have a unique understanding of the job, and this knowledge is invaluable for finding hazards. Involving
employees will help minimize oversights, ensure a quality analysis, and get workers to “buy in” to the solutions because they will share ownership in their safety and health program.
2. Review your accident history. Review with your employees your worksite’s history of accidents and
occupational illnesses that needed treatment, losses that required repair or replacement, and any “near
misses” —events in which an accident or loss did not occur, but could have. These events are indicators that the existing hazard controls (if any) may not be adequate and deserve more scrutiny.
3. Conduct a preliminary job review. Discuss with your employees the hazards they know exist in their
current work and surroundings. Brainstorm with them for ideas to eliminate or control those hazards. If any hazards exist that pose an immediate danger to an employee’s life or health, take immediate action to protect the worker. Any problems that can be corrected easily should be corrected as soon as possible. Do not wait to complete your job hazard analysis. This will demonstrate your commitment to safety and health and enable you to focus on the hazards and jobs that need more study because of their complexity. For those hazards determined to present unacceptable risks, evaluate types of hazard controls. More information about hazard controls is found in Appendix 1.
4. List, rank, and set priorities for hazardous jobs. List jobs with hazards that present unacceptable risks, based on those most likely to occur and with the most severe consequences. These jobs should be your first priority for analysis.
5. Outline the steps or tasks. Nearly every job can be broken down into job tasks or steps. When beginning a job hazard analysis, watch the employee perform the job and list each step as the worker takes it. Be sure to record enough information to describe each job action without getting overly detailed. Avoid making the breakdown of steps so detailed that it becomes unnecessarily long or so broad that it does not include basic steps. You may find it valuable to get input from other workers who have performed the same job. Later, review the job steps with the employee to make sure you have not omitted something. Point out that you are evaluating the job itself, not the employee’s job performance. Include the employee in all phases of the analysis—from reviewing the job steps and procedures to discussing uncontrolled hazards and recommended solutions. Sometimes, in conducting a job hazard analysis, it may be helpful to photograph or videotape the worker performing the job. These visual records can be handy references when doing a more detailed analysis of the work.

Job Hazard Analysis Part 1

Who is this for?

This booklet is for employers, foremen, and supervisors, but we encourage employees to use the information as well to analyze their own jobs and recognize workplace hazards so they can report them to you. It explains what a job hazard analysis is and offers guidelines to help you conduct your own step-by-step analysis.

What is a hazard?

A hazard is the potential for harm. In practical terms, a hazard often is associated with a condition or activity that, if left uncontrolled, can result in an injury or illness. See Appendix 2 for a list of common hazards and descriptions. Identifying hazards and eliminating or controlling them as early as possible will help prevent injuries and illnesses.

What is a job hazard analysis?

A job hazard analysis is a technique that focuses on job tasks as a way to identify hazards before they occur.
It focuses on the relationship between the worker, the task, the tools, and the work environment. Ideally, after you identify uncontrolled hazards, you will take steps to eliminate or reduce them to an acceptable risk level.

Why is job hazard analysis important?

Many workers are injured and killed at the workplace every day in the United States. Safety and health can add value to your business, your job, and your life. You can help prevent workplace injuries and illnesses by looking at your workplace operations, establishing proper job procedures, and ensuring that all employees are trained properly. One of the best ways to determine and establish proper work procedures is to conduct a job hazard analysis. A job hazard analysis is one component of the larger commitment of a safety and health management system.

What is the value of a job hazard analysis?

Supervisors can use the findings of a job hazard analysis to eliminate and prevent hazards in their workplaces. This is likely to result in fewer worker injuries and illnesses; safer, more effective work methods; reduced workers’ compensation costs; and increased worker productivity. The analysis also can be a valuable tool for training new employees in the steps required to perform their jobs safely. For a job hazard analysis to be effective, management must demonstrate its commitment to safety and health and follow through to correct any uncontrolled hazards identified. Otherwise, management will lose credibility and employees may hesitate to go to management when dangerous conditions threaten them.

Injury & Illness Prevention Program - FAQs

Why does OSHA want employers to have an Injury and Illness Prevention Program? What will this initiative do?

The Bureau of Labor Statistics reports that 12 workers are killed every day on the job and more than 3.3 million suffer a serious work related injury or illness each year. The direct cost of the most serious injuries and fatalities is about $1 billion per week. These injuries and illnesses are preventable.
OSHA believes that workers will be better protected if each employer develops a proactive program to help them find hazards in their workplaces and develop a process to fix those hazards so that employees don't get hurt. This would not be a one-size-fits-all requirement. Employers would tailor the program to the size and nature of their workplace.
OSHA has learned much from the variety of approaches taken by 15 states that have required such programs of some or all of their employers. OSHA is basing its proposal on the real world experience of employers and the substantial data on reductions in injuries and illnesses from employers who have implemented similar programs - including the companies in our Voluntary Protection Programs. OSHA will develop a flexible proposal that is appropriate to large and small businesses.

What is the status of the proposal?

OSHA's proposal is in its very early stages. We have conducted 5 stakeholder meetings all across the country. The next step is for us to gather comments from small businesses during the small business review process. That process will be followed by the publication of a proposal, a notice and comment period and extensive public hearings. We encourage anyone who has questions, concerns or experience to participate actively in this process.

Is this rule really an ergonomics standard or other new hazard regulation?

No. This standard is not an ergonomics standard and is not a new hazard regulation.
The Injury and Illness Prevention Program standard will simply require employers to develop a program to help them find and fix hazards in their workplaces.
This initiative does not allow OSHA to cite employers for not addressing any hazards that are not now covered by OSHA standards. OSHA's General Duty Clause (Section 5(a)(1)) already covers recognized hazards for which OSHA does not have standards. Since its creation 40 years ago, OSHA has cited employers under the General Duty Clause when workers are exposed to serious recognized hazards that have a feasible means of abatement. The Injury and Illness Prevention Program standard will not change that in any way.

Will a violation of an OSHA standard also be cited as a violation of the Injury and Illness Prevention program or vice versa?

No. A citation for violating an existing OSHA standard or for violating the General Duty Clause does not mean that an employer will also be cited for violating the Injury and Illness Prevention Program standard.

What if I already have a manageable, common sense injury and illness prevention program in place?

We are aware that many small and large businesses already have effective injury and illness prevention programs. Our primary goal in our proposal is to reach those employers that do not have an effective program. Fifteen states already have requirements for such programs—and OSHA has learned much from the variety of approaches taken by these 15 states.
It is not the agency's intention to require that employers who have previously implemented effective programs that share the basic elements of OSHA's rule to make unnecessary changes. We plan to issue a proposal that is sufficiently flexible to allow those programs to continue uninterrupted. OSHA has not written this proposal yet, and we are still engaging with stakeholders and listening to their concerns.

I understand that OSHA has held stakeholder meetings on this rule. Is that accurate?

OSHA has held five stakeholder meetings: in New Jersey, Texas, California, and two in the District of Columbia. In total, 217 participants registered for these meetings and 263 observers were present. Participants included large and small employers, professional and trade associations, labor representatives and individual workers. Summaries of these stakeholder meetings can be found here.

Protecting Workers from the Effects of Heat

At times, workers may be required to work in hot environments for long periods. When the human body's unable to maintain a normal temperature, heat-related illnesses can occur and may result in death. This fact sheet provides information to employers on measures they should take to prevent worker illnesses and death caused by heat stress.

Factors that May Cause Heat-related Illness

  • High temperature and humidity
  • Low fluid consumption
  • Direct sun exposure (with no shade) or extreme heat
  • Limited air movement (no breeze or wind)
  • Physical exertion
  • Use of bulky protective clothing and equipment
  • Poor physical condition or ongoing health problems
  • Some medications
  • Pregnancy
  • Lack of previous exposure to hot workplaces
  • Previous heat-related illness

Health Problems Caused by Hot Work Environments

Heat Stroke is the most serious heat-related health problem. Heat stroke occurs when the body's temperature regulating system fails and body temperature rises to critical levels (greater than 104°F).This is a medical emergency that may result in death! The signs of heat stroke are confusion, loss of consciousness and seizures. Workers experiencing heat stroke have a very high body temperature and may stop sweating. If a worker shows signs of possible heat stroke, get medical help immediately, and call 911. Until medical help arrives, move the worker to a shady, cool area and remove as much clothing as possible. Wet the worker with cool water and circulate the air to speed cooling. Place cold wet cloths, wet towels or ice all over the body or soak the worker’s clothing with cold water.

Heat Exhaustion is the next most serious heat-related health problem. The signs and symptoms of heat exhaustion are headache, nausea, dizziness, weakness, irritability, confusion, thirst, heavy sweating and a body temperature greater than 100.4°F. Workers with heat exhaustion should be removed from the hot area and given liquids to drink. Remove unnecessary clothing including shoes and socks.
Cool the worker with cold compresses to the head, neck, and face or have the worker wash his or her head, face and neck with cold water. Encourage frequent sips of cool water. Workers with signs or symptoms of heat exhaustion should be taken to a clinic or emergency room for medical evaluation and treatment. Make sure that someone stays with the worker until help arrives. If symptoms worsen, call 911 and get help immediately.

Heat Cramps are muscle pains usually caused by physical labor in a hot work environment. Heat cramps are caused by the loss of body salts and fluid during sweating. Workers with heat cramps should replace fluid loss by drinking water and/or carbohydrate-electrolyte replacement liquids (e.g., sports drinks) every 15 to 20 minutes.

Heat Rash is the most common problem in hot work environments. Heat rash is caused by sweating and looks like a red cluster of pimples or small blisters. Heat rash usually appears on the neck, upper chest, in the groin, under the breasts and in elbow creases. The best treatment for heat rash is to provide a cooler, less humid work environment. The rash area should be kept dry. Powder may be applied to increase comfort. Ointments and creams should not be used on a heat rash. Anything that makes the skin warm or moist may make the rash worse.

Engineering Controls to Prevent Heat-related Health Effects

The best way to prevent heat illness is to make the work environment cooler. In outdoor situations, this may be done by scheduling activities during the cooler times of the day. However, very early starting times may result in increased fatigue. Also, humidity tends to be higher in the early morning hours. Provide air conditioned or shaded areas close to the work area and allow frequent rest breaks.
Indoor workplaces may be cooled by using air conditioning or increased ventilation, assuming that cooler air is available from the outside. Other methods to reduce indoor temperature include: providing reflective shields to redirect radiant heat, insulating hot surfaces, and decreasing water vapor pressure, e.g., by sealing steam leaks and keeping floors dry. The use of fans to increase the air speed over the worker will improve heat exchange between the skin surface and the air, unless the air temperature is higher than the skin temperature. However, increasing air speeds above 300 ft. per min. may actually have a warming effect. Industrial hygiene personnel can assess the degree of heat stress caused by the work environment and make recommendations for reducing heat exposure.

Work Practices to Prevent Heat-related Health Effects

  • Train workers and supervisors about the hazards leading to heat stress and ways to prevent them.
  • Allow workers to get used to hot environments by gradually increasing exposure over a 5-day work period. Begin with 50% of the normal workload and time spent in the hot environment and then gradually build up to 100% by the fifth day. New workers and those returning from an absence of two weeks or more should have a 5-day adjustment period.
  • Provide workers with plenty of cool water in convenient, visible locations close to the work area. Water should have a palatable (pleasant and odorfree) taste and water temperature should be 50- 60°F if possible.
  • Remind workers to frequently drink small amounts of water before they become thirsty to maintain good hydration. Simply telling them to drink plenty of fluids is not sufficient. During moderate activity, in moderately hot conditions, at least one pint of water per hour is needed. Workers should drink about 6 ounces or a medium-sized glass-full every 15 minutes. Instruct workers that urine should be clear or lightly colored.
  • Be aware that it is harmful to drink extreme amounts of water. Workers should generally not drink more than a total of 12 quarts of fluid in 24 hours.
  • Reduce the physical demands of the job, such as excessive lifting, climbing, or digging with heavy objects. Use mechanical devices or assign extra workers.
  • Monitor weather reports daily and reschedule jobs with high heat exposure to cooler times of the day. When possible, routine maintenance and repair projects should be scheduled for the cooler seasons of the year.
  • Schedule frequent rest periods with water breaks in shaded or air-conditioned recovery areas.
  • Workers are at an increased risk of heat stress from personal protective equipment (PPE), especially from wearing semi-permeable (penetrable) or impermeable clothing (such as Tyvek or rubber), when the outside temperature exceeds 70°F, or while working at high energy levels. These types of clothing materials trap heat close to a worker’s body. Workers should be monitored by establishing a routine to periodically check them for signs and symptoms of overexposure.

Fall protection on finished bridge decks

September 3, 2013

Mr. Larry F***
Tampa, Florida  33624

Dear Mr. F***:

Thank you for your letter dated April 5, 2013 to the Occupational Safety and Health Administration (OSHA). In your letter you discussed safe guarding for employees required to work next to finished concrete barriers commonly used in highway construction. Most of these barriers are only 32 inches high. Employees could be exposed to falls of 6 feet or more when performing ancillary tasks, such as painting or removal of concrete curing material. You stated that the vast majority of Department of Transportation Contracts through the Federal Highway Administration have contract specifications that do not permit the use of systems such as anchorages for a personal fall protection system if there is a need to penetrate the surface of decks or barrier walls. While it's an accepted practice to use job-fabricated wooden built-up rail systems, you point out that this could entail tens of thousands of circular saw cuts. You contend that exposure to cuts and ergonomic considerations of these systems create greater hazards to employees than that of a fall exposures. Given your scenario we paraphrased above, you asked the following question:
Would the use of high visibility warning stripes placed on the decking during construction and subsequent use of permanent pavement markings in conjunction with training and enforcement meet the requirements for protection of workers having to walk and/or travel along decks between the offset markings when the edges are protected with a finished 32 inch high barrier wall?

Answer:
No. Using a 32" high concrete barrier to serve as a guardrail to protect employees doesn't comply with minimum top edge requirement of the guardrail system to be 42 inches high plus or minus 3 inches.

The fabricated plywood saddle system described in your letter is one of many systems that can be used. On May 10, 2013, we briefly discussed alternatives such as c-clamp guardrail systems that are easily transportable and available for rent. We also discussed OSHA's alternative uses of warning line systems meeting the requirements defined in 29 CFR 1926.502(f)(2) providing it's use maintains a "no entry" 15 foot setback from an edge or hole 6 feet or more above a lower level. You indicated that your employees would need to work within the 15 foot restriction and thus a warning line system would be infeasible. See the attached Letter of Interpretation. This letter can also be found on OSHA's website at the following link: http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=24802

Enforcement policy for proximity alarm & insulating link use

March 31, 2014
MEMORANDUM FOR: REGIONAL ADMINISTRATORS
FROM:    JAMES G. MADDUX

SUBJECT:   Temporary Enforcement Policy for Proximity Alarm and Insulating Link Use with Cranes and Derricks in Construction

Effective April 30, 2014, until further notice, the Occupational Safety and Health Administration (OSHA) intends to follow the temporary enforcement policy described below for use of proximity alarms and insulating links with cranes or derricks while engaged in construction activities near power lines. OSHA initially adopted a temporary enforcement policy for the use of these devices in a June 25, 2012 memorandum, and it was effective July 26, 2012 through November 8, 2013. This memorandum supersedes OSHA's June 25, 2012 memorandum.
The Cranes and Derricks in Construction standard, 29 CFR 1926 Subpart CC ("cranes standard"), includes several options for cranes and derricks performing construction activities near power lines. Some of the options involve proximity alarms or insulating links/devices. Section 1926.1401 of the cranes standard defines "proximity alarm" and "insulating link/device" as devices that warn of proximity to power lines or that insulate against electricity and that have been "...listed, labeled or accepted by a Nationally Recognized Testing Laboratory in accordance with § 29 CFR 1910.7" ("NRTL requirements"). These pieces of safety equipment must meet the performance requirements and the NRTL requirements as defined in § 1926.1401-Definitions to be used on cranes and derricks in construction.
To date, no proximity alarm or insulating link/device meets the NRTL requirements. Additionally, at this time, no NRTL is recognized by the Agency to perform the required testing to list, label or accept either type device. Proximity alarms and insulating links/devices which do not meet the NRTL requirements continue to be available, as they have for decades. These versions have not been "...listed, labeled or accepted by a Nationally Recognized Testing Laboratory." OSHA does not anticipate proximity alarms or insulating links/devices which meet the NRTL requirements to be available in the near future.
Because there are no compliant proximity alarms or insulating links/devices, OSHA intends to follow the temporary policy noted below until further notice and will engage in rulemaking to address the unavailability of proximity alarms and insulating links/devices which meet these NRTL requirements. The temporary policy is for:
  • proximity alarm use under § 1926.1407-Power line safety (up to 350 kV)-assembly and disassembly;
  • proximity alarm and insulating link use under § 1926.1408-Power line safety (up to 350 kV)-equipment operations;
  • proximity alarm and insulating link use under § 1926.1409-Power line safety (over 350 kV) through §§ 1926.1407 and 1926.1408; and
  • insulating link/device use under § 1926.1410-Power line safety (all voltages)-equipment operations closer than the Table A zone.
Proximity Alarms

Because no current proximity alarms meet the NRTL requirements, employers may not rely solely on proximity alarms to comply with the requirements of the cranes standard. However, an employer may use a crane/derrick in construction with a proximity alarm in conjunction with another appropriate "measure" from §§ 1926.1407(b)(3) or 1926.1408(b)(4), such as a "dedicated spotter" or "range control warning device." If these conditions are met, the employer will not be considered to be in violation of either §§ 1926.1407(b)(3) or 1926.1408(b)(4), including situations where voltages are over 350 kV as referenced in § 1926.1409.

Insulating Links/Devices

Because no current insulating links/devices meet the NRTL requirements in the § 1926.1401 definition for "insulating link/device," employers may not rely solely on an insulating link/device to comply with requirements of the cranes standard. However, an employer may use a crane/derrick in construction with an insulating link in conjunction with another appropriate "measure" from § 1926.1408(b)(4), such as a "dedicated spotter" or "range control warning device." If these conditions are met, the employer will not be considered to be in violation of § 1926.1408(b)(4), including situations where voltages are over 350kV as referenced in § 1926.1409. Additionally, OSHA will not cite any employer for a violation of § 1926.1410(d)(4) (requirement that an insulating link/device be "installed at a point between the end of the load line (or below) and the load") if an employer is using an insulating link/device manufactured on any date, as specified in § 1926.1410(d)(4)(v)(A), and in conjunction with the additional protections in § 1926.1410(d)(4)(v)(B), such as insulated gloves rated for the voltage involved.

Informal hearing on proposed extension of crane operator certification deadline

Trade News Release Banner Image


April 15, 2014
Contact: Office of Communications
Phone: 202-693-1999

OSHA schedules informal hearing on proposed extension of crane
operator certification deadline

WASHINGTON – The Occupational Safety and Health Administration today scheduled an informal public hearing to discuss OSHA’s proposed rule to extend the compliance date for the crane operator certification requirement and the existing phase-in requirement that employers ensure that their operators are qualified to operate the equipment. The hearing will be held May 19, 2014, in Washington, D.C.

On Feb. 10, 2014, OSHA issued a Notice of Proposed Rulemaking proposing to extend the deadline for operator certification by three years to Nov. 10, 2017, and to extend the existing employer duties for the same period. The public had 30 days to submit comments on this issue. The comment period closed on March 12, 2014. The agency received 60 comments from the public in response to the NPRM, one of which requested a hearing. 

The purpose of the hearing is to gather additional information related to whether OSHA should extend the requirement by three years or not at all.

The public hearing will be held at 9:30 a.m., Monday, May 19 in the auditorium of the U.S. Department of Labor, 200 Constitution Ave., NW, Washington, DC 20210. Individuals who wish to testify must submit a notice of intention to appear by April 25. Submissions may be made electronically at http://www.regulations.gov, the Federal e-Rulemaking Portal, by mail or facsimile. See the Federal Register notice for submission details.

"Qualified Rigger"

March 18, 2014

Eric M. D*** 
Washington, DC 20006

Dear Mr. D***:

Thank you for your March 12, 2013, letter to the Occupational Safety and Health Administration (OSHA). You asked a question regarding the determination of whether an employee may be considered a "qualified rigger" under 29 CFR 1926 Subpart CC (Cranes and Derricks in Construction).

We have paraphrased your question as follows:

Question: Can a labor-management joint apprenticeship training program that is a "qualified evaluator (third party)" for purposes of ensuring that signal persons meet qualification requirements also provide training regarding "qualified rigger" status?

Answer: Yes, but the employer is responsible for ensuring that any employee who rigs materials is a qualified rigger. The employer may consider determinations made by a third party, such as completion of a joint labor management apprenticeship training program, in assessing whether an employee is in fact a "qualified rigger." While such programs generally provide high-quality classroom and hands-on instruction, the employer must ensure that an employee assigned to rig a load is a qualified rigger with respect to that specific lift.
29 CFR 1926.1401 defines a "qualified rigger" as:
[A] rigger who meets the criteria for a qualified person.
29 CFR 1926.1401 defines a "qualified person" as:
[A] person who, by possession of a recognized degree, certificate, or professional standing, or who by extensive knowledge, training, and experience, successfully demonstrated the ability to solve/resolve problems relating to the subject matter, the work, or the project.
The level of experience, knowledge, and skill needed to perform a rigging job safely depends on the type of rigging and worksite conditions. The employer must ensure that the rigger has the ability to recognize and resolve any issues relating to the specific rigging work to be performed.
The cranes standard does not require or refer to third party evaluators with respect to qualified riggers. The standard's provisions regarding riggers differ in this respect from those regarding signal persons, to which your letter refers, under which documentation from a "qualified evaluator (third party)" is an alternative means of compliance. As noted, the employer may consider determinations made by a third party such as a joint apprenticeship program, but it retains responsibility for ensuring that any employee assigned to rig a load is qualified.
This interpretation is consistent with OSHA's discussion of qualified riggers in a letter to William K. Irwin, Jr., dated January 9, 2012, available here:
https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=28268.

Amended Hazcom Standard regarding Petroleum Streams

March 4, 2014
Erik C. B***
Washington, DC 20005

Re: Request for Interpretation OSHA's Amended Hazard Communication Standard (HCS 2012) regarding Petroleum Streams

Dear Mr. B***:

This letter is being issued to API to provide guidance on how to apply the March 26, 2012, revisions to OSHA's Hazard Communication Standard (HCS 2012). Classifiers may rely on the following guidance in applying the classification and SDS requirements of HCS 2012 to petroleum streams.
For purpose of this letter, a petroleum stream includes crude oil and anything derived from crude oil that is:
  • a well-defined chemical compound defined by a Chemical Abstracts Service Number, such as butane or propane, aside from impurities and stabilizers; or
  • a Substance of Unknown or Variable composition, Complex reaction products or Biological materials (UVCBs) defined by a Chemical Abstracts Service Number.
Petroleum Stream Classification
The obligation to classify the health hazards of petroleum streams under the Hazard Communication Standard may be satisfied by following the below guidance, in conjunction with the general guidance found in A.0.1-A.0.3, in the application of the classification criteria in Appendix A of the standard.
  1. For hazard classes other than carcinogenicity, germ cell mutagenicity, and reproductive toxicity ("CMR"), a petroleum stream shall be classified as follows:

    (a) Where test data are available for the petroleum stream, the classification of the stream will always be based on those data.

    (b) Where test data are not available for the stream itself, the classification may be based on a toxicologically appropriate read across from test results of a substantially similar stream. A substantially similar stream is one that has a similar starting material, production process, and range of physico-chemical properties (e.g., boiling point and carbon number) and similar constituent compositions.

    (c) If test data are not available either for the stream itself or a substantially similar stream, then the method(s) described in each chapter of Appendix A for estimating the hazards based on the information known will be applied to classify the stream (i.e., application of cut-off values/concentration limits).

  2. For the CMR hazard classes:

    (a) When reliable and good quality data are available to classify a petroleum stream-based on testing of the stream or the toxicologically appropriate read-across to a substantially similar stream-a weight of evidence analysis supported by that data may be relied upon for classification regardless of whether a CMR constituent is present in the stream. A substantially similar stream is one that has a similar starting material, production process, and range of physico-chemical properties (e.g., boiling point and carbon number) and similar constituent compositions.

    (b) To be reliable and good quality test data, the data must be from one or more tests that reflect appropriate study design and performance. The study or studies must appropriately take into account dose and other factors such as duration, observations, and analysis (e.g. statistical analysis, test sensitivity) so as to conclusively exclude the possibility that the lack of effect(s) is due to a poor study design, e.g., insufficient dose or number of subjects. A study (or studies) is conclusive in this sense if, when viewed in conjunction with all relevant information about the chemical, its results are consistent with the relevant information and allow a strong inference that the lack of effects is not due to a poor study design.

    (c) Where reliable and good quality data are not available on the stream or a substantially similar stream, then the method(s) described in each chapter of Appendix A for estimating the hazards based on the information known will be applied to classify the stream (i.e., application of cut-off values/concentration limits).

Safety Data Sheet Disclosure
Many petroleum streams are of unknown or variable concentration, and cannot be represented by unique structures, molecular formulas, or fixed concentration percentages. In addition, petroleum industry test data are largely based on the testing of streams rather than the hundreds or thousands of individual constituents of those streams. In light of these facts, application of the disclosure requirements in Section 3 of table D.1 to petroleum streams may be infeasible and/or undermine the usefulness of the SDS. Thus, SDSs for petroleum streams that are in accordance with the following guidance will be considered to be in compliance with the standard for enforcement purposes.
  1. When dealing with petroleum streams, it may be more important for the user to know the concentrations of particular groups of constituents that are toxicologically similar. For example, in the classification of a petroleum stream, it may be more relevant to know the total concentration of a class of constituents such as polycyclic aromatic hydrocarbons (PAH) to understand the health hazards of the stream, rather than knowing the concentration of each particular PAH. Further, information about the presence and concentration of particular constituents of the group might not be available, or even if it were, inclusion of every one could lead to the listing of hundreds of constituents. This is likely to undermine the effectiveness of the disclosure requirements in Section 3. Thus, where the classifier can show that it is toxicologically appropriate to treat a particular set of constituents as a group, and all of the toxicologically useful information about the constituents in that group is conveyed by treating them as a group, SDS need only include the name and concentration of that group in Section 3 if present above the cut-off/concentration limit (or if the group presents a health risk below the cut-off/concentration limit). The foregoing example of PAHs is designed to assist in better understanding the concept of this paragraph. It is not intended to limit the application of this approach to any particular type or group of constituents.
  2. Other constituents, such as benzene or n-hexane, that are known to be present in the stream, and that present classified health hazards, must be listed individually in Section 3 along with their concentrations if present above the cut-off/concentration limit (or if the constituent presents a health risk below the cut-off/concentration limit).
  3. Where there is "reliable and good quality" data supporting a weight of evidence determination that a constituent in a petroleum stream poses no health risk (as per A.0.4.3.3) in a downstream use of the stream, it need not be disclosed on the SDS.
  4. Where the classifier does not know the exact concentration of a constituent or group of constituents included in Section 3 of the SDS, it may use a range of concentrations instead. Concentration ranges, if used, must be based on the information available to the classifier, such as analysis results, product specifications, or nature of the process, and the high end of the range reported may not affect the reported hazard classification.

Application of Amended HCS 2012 to Combustible Dust

March 4, 2014
Erik C. B***
Washington, DC 20005

Re:   Request for Interpretation of Application of OSHA's Amended Hazard Communication Standard (HCS 2012) to Combustible Dust

Dear Mr. B***:

This letter is being issued to API to clarify how the March 26, 2012, revisions to OSHA's Hazard Communication Standard (HCS 2012) apply to combustible dust. Below I summarize each of your questions and provide our response to it.
  1. Modification of Required Hazard Statement. Under HCS 2012, chemicals that have been classified as combustible dusts must include the following hazard statement on their labels and safety data sheets (SDSs): "May form combustible dust concentrations in air." You ask whether, for chemicals that pose a combustible dust hazard when processed but not in the current shipped form, the responsible party1 may include additional language with the hazard statement. You propose two alternatives (indicated by italics):

    1. If converted to small particles during further processing, handling, or by other means, may form combustible dust concentrations in air.
    2. If small particles are generated during further processing, handling or by other means, may form combustible dust concentrations in air.
    OSHA RESPONSE: Paragraph C.3.1 of Appendix C to HCS 2012 states that the responsible party may provide additional information on a label "when it provides further detail and does not contradict or cast doubt on the validity of the standardized hazard information." OSHA views either of the alternatives you propose as falling within C.3.1 because they provide additional detail and do not contradict or cast doubt on the validity of the required hazard statement where the chemical does not present a combustible dust hazard in the form shipped. Similarly, the required elements listed in Appendix D for SDSs are the minimum information required and OSHA believes that additional information that satisfies C.3.1 may be included in Section 2 of the SDS if the additional information concerns hazard identification. Therefore, it would be acceptable to OSHA if responsible parties included either alternative in conjunction with the required hazard statement on labels and SDSs for such chemicals.
  2. Safety Data Sheets.

    1. Your first question concerns a chemical that is not a combustible dust in the form shipped, and does not present any other hazard under HCS 2012 in the form shipped, and will not present a combustible dust hazard or any other hazards under HCS 2012 in normal conditions of use or foreseeable emergencies unless they are processed by a downstream user in such a manner which reduces its particle size. You ask whether, for such a chemical, the responsible party may include the following additional language at the beginning of the SDS:

      This product is not hazardous in the form in which it is shipped by the manufacturer, but may become hazardous through downstream activities (e.g. grinding, pulverizing) that reduce its particle size. Those hazards are described below.

      OSHA RESPONSE: Yes. These types of additional statements may be added to the SDS so long as they are relevant and do not contradict or cast doubt on the validity of the classification or other information in the SDS.
    2. You ask whether Section 2 of the SDS for a chemical posing a combustible dust hazard may include precautionary statements about the combustible dust hazard although none are specified by Appendix C of HCS 2012.

      OSHA RESPONSE: Yes. OSHA has no required precautionary statements for combustible dust, and therefore none is required in Section 2 of the SDS. Responsible parties may add their own precautionary statements to Section 2 so long as they are relevant and do not contradict or cast doubt on the validity of the other information in the SDS.
    3. You ask whether Section 2 of the SDS for a chemical posing a combustible dust hazard may include Hazard Management Information System (HMIS) and National Fire Protection Association (NFPA) ratings.

      OSHA RESPONSE: Yes. Responsible parties may include HMIS and NFPA ratings in Section 2 of the SDS as long as they do not contradict or cast doubt on the HCS 2012 classification.
  3. Labels on shipped containers

    1. You ask whether it is acceptable for a shipped container containing a chemical that presents a combustible dust hazard to include an HMIS label in addition to the information required by 1910.1200(f)(1) and C.4.30.

      OSHA RESPONSE: Yes, so long as the ratings in the HMIS label do not contradict or cast doubt on the validity of label information required by HCS 2012 (C.3.1) or impede the user's ability to identify the information required by HCS 2012 (C.3.2).
    2. Appendix C.4.30, footnote 2, states that where chemicals are not shipped in a dust form but may be processed under normal conditions of use by a downstream user in such a way as to create a combustible dust hazard, the responsible party may provide labels in accordance with Section 1910.1200(f)(4). That provision allows labels to be provided once to downstream users, either with the initial shipment or with the SDS for the chemical. You ask whether, when Section 1910.1200(f)(4) applies, the shipped container may bear a label containing only product identifiers, manufacturer name and address, and an emergency phone number.

      OSHA RESPONSE: Yes, where Section 1910.1200 (f)(4) applies and the HCS 2012 label has already been provided by other means, it is acceptable to provide only this information on a shipped container. In fact, OSHA encourages responsible parties to provide product identifier and contact information on each shipped product whenever they take advantage of the Section 1910.1200 (f)(4) option. However, any information that appears may not contradict or cast doubt on the validity of the label information required by HCS 2012.
    3. Finally, you ask whether, under footnote 2 to C.4.30, the Section 1910.1200 (f)(4) partial labeling exemption is available for a liquid that under normal conditions of use may (by evaporation or other process) turn into a solid form that presents a combustible dust hazard.

      OSHA RESPONSE: Yes, assuming the liquid in its shipped form presents no other hazards that would be classified under HCS 2012. If the liquid presents any other hazards, then (f)(4) would not apply. Again, OSHA encourages responsible parties to provide the product identifier and contact information on each such product.

  4. Workplace labels. This issue concerns the workplace labeling requirements under Section 1910.1200(f)(6) in situations where a chemical is not a combustible dust in the form shipped, but may become one when processed by a downstream user. Your first question is whether, when the responsible party provides the label in accordance with Section 1910.1200 (f)(4), the downstream user must label any containers containing the chemical in the workplace. Second, you ask that we clarify the labeling obligations of the downstream user once the product is processed in a way to create the combustible dust hazard.
OSHA RESPONSE:

(1) The one-time label rule of Section 1910.1200(f)(4) applies when the product is a solid metal, solid wood, solid plastic or whole grain, and is not limited to chemicals whose only downstream hazard is the combustible dust hazard. In addition, under footnote 2 to C.4.30, the Section 1910.1200 (f)(4) exemption is also available to other products, including liquids, that present only a combustible dust hazard under normal conditions of use and foreseeable emergencies, but not in the form shipped (as discussed in section 3.c of this letter above).

(2) In situations where a chemical is not a combustible dust in the form shipped, but may become one when processed or handled by a downstream user, and the responsible shipper-party provides the one-time container label in accordance with Section 1910.1200(f)(4), the downstream user's obligation to label any workplace containers of that chemical are determined as follows:

(a) If the chemical will not be processed or handled in a way that creates a combustible dust hazard or any other hazard that would be classified under HCS 2012, there is no Section 1910.1200(f)(6) labeling requirement.

(b) If the chemical will first be placed in a stationary process container (e.g., grinder) where it will be processed in a way that creates a combustible dust hazard, the downstream user would be required to label the stationary process container with the Section 1910.1200(f)(6) label, or may comply with the alternative labeling methods provided by Section 1910.1200(f)(7), and need not label the shipping container.

(c) If the chemical will first be placed in a non-stationary process container where it will be processed in a way that creates a combustible dust hazard, the downstream user would be required to label the non-stationary process container with the Section 1910.1200(f)(6) label, but not the shipping container.

(d) If the chemical will be processed or handled in a way that creates a combustible dust hazard before it is placed in a process container, the chemical would be subject to the Section 1910.1200(f)(6) labeling requirement once the chemical is brought into the work area where it will be processed in a way to create the combustible dust hazard. If the chemical is not in a container when brought into the area where it will be processed, no Section 1910.1200(f)(6) labeling would be required prior to processing.

(e) Finally, the workplace labeling requirements in Section 1910.1200(f)(6) apply only to chemicals that are in containers2 . Thus, individual boards or pipes that might create a combustible dust hazard when cut do not need to be labeled under Section 1910.1200 (f)(6). It is permissible (and OSHA encourages) the use of signs or placards to advise workers of the hazard in such circumstances, but signs and placards are not required.