OSHA / DOT / Homeland Security Onsite Training
On January 30, 1970, President Richard M. Nixon signed the Occupational Safety & Health Act (OSH Act) into law. Foremost among the reasons for passage of the Act was the preponderance of evidence that the workplace in U.S. industry was not only hazardous but also costly in lost time from work because of illness and injury. Housed within the Department of Labor, the Occupational Safety and Health Administration (OSHA) regulates and enforces workplace safety and health laws, officially referred to as “standards.”
UN’s Globally Harmonized System (GHS)
OSHA’s Hazard Communication Standard now mandates Industry’s conformance with the United Nations’ Globally Harmonized System (GHS).
In conforming to GHS, Industry must fulfill OSHA’s ‘Hazard Classification Mandate’ (or Chemical Hazard Evaluation) to train all employees on their exposure to chemical hazards in the workplace, including carcinogens, mutagens and teratogens. This is the essence of HazCom.
Industry is mandated by OSHA to follow the new GHS system for labeling containers, featuring pictograms and signal words for packaging and shipping; and
- The terminology, ‘Material Safety Data Sheet’ has been changed to just ‘Safety Data Sheet (SDSs)’, which requires the new 16-point format for uniformity of chemical classification & labeling worldwide. All MSDSs were to be modified to the new SDS system by June 1, 2015. The ultimate deadline for 100% SDS compliance with GHS was June 1, 2016.
Below are some important deadlines for Industry to note. Employees must be trained to the new standards and label their containers with GHS-compliant labels. Industry must comply with these deadlines by upgrading their OSHA compliance programs to meet the bar raised by OSHA’s adoption of GHS. OSHA inspectors generally expect that workplace compliance programs, including employee training, are no more than one year old. Thus, annual compliance with all standards is the safest policy for employers to follow.
- December 1, 2013 was the deadline for training employees on new label elements and the 16-point SDS format.
- June 1, 2015 was the deadline for compliance with all modified provisions of OSHA’s final rule, including conformance with the Globally Harmonized System.
- Past December 1, 2015, distributors are not allowed to ship containers labeled by the chemical manufacturer or importer unless it has a GHS-compliant label.
- June 1, 2016 was assigned as the deadline for updating alternative workplace labeling and hazard communication programs, as necessary and any additional employee training for newly-identified physical or health hazards.
It is important to note that the United Nations revises the GHS every two years, meaning OSHA will expect Industry to continually update and upgrade their safety and health compliance programs in the workplace in order to keep pace with regulatory compliance mandates nationwide and worldwide.
On August 14, 2017, the United Nations has formally published Revision 7 of its Globally Harmonized System of Classification and Labelling (GHS). Revision 7 features several important updates, including:
- Revised criteria for categorization of flammable gases within Category 1
- Amendments intended to clarify the definitions of some health hazard classes
- Additional guidance to extend the coverage of section 14 of safety data sheets to all bulk cargoes transported under instruments of the International Maritime Organization (IMO), regardless of their physical state
- Revised and further rationalized precautionary statements in Annex 3
- A new example in Annex 7 addressing labelling of small packages with fold-out labels This revision is of particular significance as OSHA has recently communicated its intent to update the HazCom 2012 standard to align with the GHS Revision 7. In particular, OSHA indicated it was considering modifications to Appendix A (Health Hazard Criteria), Appendix C (Label Elements), and Appendix D (SDS Requirements). OSHA expressed interest in moving forward as quickly as the administrative regulatory processes would allow. Link to GHS Revision 7 (United Nations Economic Commision for Europe)
OSHA’s Blockbuster on Training in the Workplace. A link is provided here for OSHA’s 270-page guide on the Agency’s “Training Requirements in OSHA Standards.”
Hazard Communication Training
OSHA's HazCom Standard is driven by one overriding philosophy: it is the responsibility of the employer to communicate chemical hazards in the workplace to all employees. "HazCom" must have two essential, interlinking elements for good standing on OSHA’s HazCom Standard:
- It must fulfill what OSHA describes as the Hazard Classification Mandate in order to evaluate all chemical hazards within the workplace for qualitative data, which provides employees with an understanding of adverse exposures on the job;
- A site-specific Hazard Communication (HazCom) employee training program in the workplace is mandated by law.
The only way to make a HazCom Program site-specific is to conduct the hazard classification/evaluation on a regular basis. All chemical hazards must be determined relative to the physical and health hazards associated with employee exposure in the workplace. OSHA's compliance requirements for an effective 365-day-a-year Hazard Communication Program are founded in the five major components listed below.
An effective and compliance HazCom program will encompass the OSHA-mandated “Hazard Classification/Evaluation” for all chemical hazards, including carcinogens; Written HazCom Program, with Conformance to GHS directives; Safety Data Sheets (SDSs), adapted to 16-point GHS system; GHS-Compliant Container Labeling; Employee Information & Training (Onsite & Site-Specific); and Administrative Records to track all participants being trained, plus the dates trained.
OSHA’s Lockout/Tagout Standard covers the servicing and maintenance of machines and equipment whose unexpected energization, start up, or release of stored energy could cause injury or death to employees. OSHA requires employers to establish a written program, site-specific procedures, minimum performance standards for affixing appropriate lockout and/or tagout attachments to energy isolating devices and to otherwise disable machines or equipment from unexpected release of hazardous energy in order to prevent accidents in the workplace. Here, OSHA focuses on the machine-specific "Control of Hazardous Energy" through the implementation of Lockout/Tagout procedures with subsequent emphasis on employee instruction. In other words, the concentration is on machinery lock and tag procedures which then must be followed by relevant training of appropriate employees in terms of “authorized” employees (those that actually perform maintenance and repair on machinery), “affected” employees (those who actually operate that machinery in the workplace) and “other” employees. Employee instruction shall include Administrative Records to track all participants being trained, plus the dates they are trained.
Hazardous Waste Operations and Emergency Response (HAZWOPER)
Under the authority of SARA Title I [not Title III] (1986), EPA and OSHA promulgated identical health and safety standards to protect workers engaged in hazardous waste operations and emergency response. This OSHA Standard became effective on March 6, 1990. The EPA regulations incorporate the OSHA standards by reference. HAZWOPER affects employers whose employees are engaged in emergency response operations without regard to location, where there is a release, or a substantial threat of a release of a hazardous substance.
The EPA and OSHA employee protection standards for HAZWOPER apply to five groups of workers, two of which fit mainstream industry in the manufacturing sector. These two are called: 1. Mandatory Cleanups at Uncontrolled Hazardous Waste Sites and 2. Voluntary Cleanups at Uncontrolled Hazardous Waste Sites. A “hazardous waste site” is commonly understood to be a facility in which hazardous waste is generated as a part of its operations. The other three groups are associated with RCRA "Treatment, Storage, Disposal Facilities,” typically known as TSDFs.
Unlike HazCom Training, where all employees are to be trained about hazardous chemicals in the workplace, HAZWOPER applies only to employees who have the potential to be exposed to the release of hazardous substances. HAZWOPER contains general and specific requirements for health and safety programs, site characterization and analysis, site control, emergency response team training, medical surveillance, engineering controls and work practices, personal protective equipment, heat stress and cold exposure monitoring, informational programs, handling drums and chemical containers, hazardous waste/material handling, decontamination and emergency procedures for catastrophic events.
To further highlight the challenges, spills of hazardous waste always pose a significant threat to employees and adverse impact to the environment. Hazardous waste is a serious safety and health problem that continues to endanger people, animal life and environmental quality. Hazardous waste – discarded chemicals that are toxic, flammable, or corrosive – can cause injury, illness, fires, explosions and environmental pollution. Unless hazardous waste is properly treated, stored, or disposed of, it will continue to do great harm to all living things that come into contact with it now or in the future. It is because of the seriousness of safety and health hazards related to hazardous waste operations that OSHA issued its HAZWOPER Standard, specifically developed to protect employees in the workplace and to help them handle hazardous wastes safely and effectively.
Specifically, HAZWOPER Training for industrial settings require a 24-hour inaugural training function, to be followed by an 8-hour “refresher” training annually thereafter. When turnover of personnel assigned to an organization’s HAZWOPER Team occurs, consideration must be given to reinstating the 24-hour training event before continuing the “refresher” phase of HAZWOPER Training.
Contingency Plan Relating To HazWastes
OSHA, in conjunction with the U.S. EPA, requires a Contingency Plan to prevent or minimize hazards to human health or the environment in the event of fire, explosion, or any unplanned sudden or non-sudden release of hazwaste or its constituents to air, soil, groundwater, or surface water. The provisions of this Plan must be implemented immediately upon knowledge that one or more of the aforementioned events could threaten human health or the environment.
At all times, there must be at least one employee on the facility’s premises, or on call for rapid response, with the responsibility for coordinating all internal emergency response measures. This/these employee(s) shall be designated as the emergency coordinator (EC). The EC must maintain full responsibility for activation and control of the Contingency Plan and should be thoroughly familiar with:
- The facility's Contingency Plan for effective, efficient and appropriate emergency response;
- All operations and activities at the facility;
- The location and characteristics of any hazardous materials;
- The location of all records within the facility, including SDSs; and
- The physical layout (site map) of the facility.
Additionally, the EC will have the authority to commit the resources needed to implement this Contingency Plan, as it must be a "working document." The nature of the incident may also dictate the EC obtain assistance from outside agencies to provide emergency services to the facility as the EC deems appropriate, especially as it might relate to the management of hazardous wastes and its constituents.
Specifically, Large Quantity Generators of hazardous waste are required to install and train to a Contingency Plan. Small Quantity Generators are required to install and train to an Emergency Response Plan.
Industrial Hygiene (IH)
According to the American Industrial Hygienists Association, “Industrial Hygiene is the science of anticipation, recognition, evaluation and control of environmental factors or stresses arising in or from the workplace that may cause sickness, impaired health and well-being, or significant discomfort among workers or among the citizens of the community.”
IH mandates include Noise Monitoring, Hearing Conservation, Indoor Air Monitoring/Quality, Respiratory Protection, Confined Space, Personal Protective Equipment, Accident/Incident Investigation & Recordkeeping, Bloodborne Pathogens, Pandemics, Infectious Agents, Heat Stress, Fire Prevention/Emergency Action Plan, Exposure Compliance Programs for the 40 Chemicals having their own OSHA Standards, Laboratory Safety/Chemical Hygiene, Fall Protection, Ergonomics, Sick Building Syndrome, RCRA Hazwaste-related issues and more. Here are some evaluative questions to review for potential need of IH compliance services:
- Noise / Hearing Protection
- Has the company performed noise level monitoring to ensure all operations are not exceeding the 85 decibel action level?
- Does the company have high noise level areas or operations?
- Does the company have a Hearing Conservation Program, written program and annual audiometric testing provided for its employees?
- Respirators and Air Monitoring
- Has air monitoring been done by a qualified IH to determine whether respirators are needed?
- If respirators are required, has air monitoring been done to ensure the correct respirators are being used for the contaminant concentrations?
- Does the company use respirators, including dust masks?
- Are respirators required or provided as optional by the company?
- Is there a written respiratory protection program?
- Are medical evaluations and approval given before respirators are assigned to employees?
- If air supplied respirators are used, is the supplied air tested for Grade D Quality?
- Have new chemicals, products, operations, or processes been added since the testing?
- Is all testing documented and on file for inspection by an OSHA IH inspector?
- Are products containing any of the chemicals having their own OSHA Standards being used at the facility (crystalline silica, methylene chloride, lead, cadmium, inorganic arsenic, etc.)?
- Confined Space Permit and Rescue
- Has an evaluation for permit-required confined spaces been completed and documented?
- If confined spaces have been identified for employee entry, is there a written confined space entry program?
- Is training being done and documented?
- Personal Protective Equipment (PPE)
- Has a PPE hazard assessment been conducted at the facility?
- Is written documentation providing date, person conducting evaluation and results on file?
- Has PPE training been conducted and documented?
OSHA “45” Stand-Alone Chemical Standards
OSHA has determined that 45 specific chemical hazards are so adverse to employees in the workplace, that stand-alone standards have been enacted to protect employees through preventative exposure strategies, including analyses, written programs and employee training. Through its Compliance Gap Analysis, Vanguard screens for these specific hazards, along with virtually all other workplace hazards.
Process Safety Management (PSM)
Effective May 26, 1992, OSHA mandated its Process Safety Management (PSM) standard aimed at protecting millions of employees in the workplace at nearly 100,000 facilities against toxic, flammable and reactive chemical hazards "used, stored, manufactured, or transported onsite" in conjunction with processes, machinery, equipment, or activities.
Affected facilities were to conduct Process Hazard Analyses (PHA’s) of at least 25% of their affected processes by May 26, 1994. At least an additional 25% of the analyses were to be completed each successive year by the annual deadline so that employers would have evaluated every affected process and implemented safety measures within five years of the original effective date in 1992. The ultimate deadline, therefore, was May 26, 1997.
Basically, the standard mandates employee participation in PSM programs and sets requirements stemming from 14 elements, including:
- written operating procedures
- employee training
- pre-startup reviews
- equipment maintenance
- written procedures for managing process change
- "hot work" permit
- emergency action plans
- compliance audits
- incident investigation involving releases or near releases of covered chemicals
OSHA chose the list of 130 Highly Hazardous Substances in which coverage is triggered if any specified Threshold Quantities (TQ’s) are being used in a single process at one point in time (not aggregated over a period of time as in Sec. 313 of SARA Title III); or coverage is also triggered by any other toxic or flammable substance in excess of 10,000 lbs. when connected to a process. A "process" is defined to mean any activity involving a highly hazardous substance inclusive of any use, storage, manufacturing, or onsite movement. Also, included as a single process, is any group of vessels which are interconnected and separate vessels which are located such that the chemical could be released.
Important Note: For optimum and accurate results, PSM should be performed in conjunction with EPA's Risk Management Program for Chemical Accidental Release Prevention, as both programs were planned by Federal OSHA and EPA authorities to be meshed or intertwined for implementation.
Mechanical Integrity and PSM
Pursuant to OSHA's PSM, it is highly probable that a facility may need to engage in a program of Mechanical Integrity (MI) in order to support the efficacy of its ongoing PSM program and related compliance directives from the Federal Government. MI is a companion program to its PSM service, but yet separate in its own scope, objectives and work structure. MI can be defined as the ongoing study, maintenance, management and anticipated replacement of plant equipment – as well as adequacy and fitness for service – (including pressure vessels, tanks, pumps, relief devices, heat exchangers, piping, etc.), as it is used to process, store, or handle a chemical substance at any point in time connected to the process. Understandably, a facility may have one or more processes under the definition above, for which PSM and MI are concurrently required. While the above MI definition aligns with PSM regulations, this does not preclude the possibility that the client may wish to engage in some form of MI to increase reliability of systems or piping, even though some of the factors relative to the above regulatory compliance definition may not actually exist. MI changes the maintenance and reliability theme from reactive to proactive. Downtime is decreased and becomes a scheduled event. Scope of repairs is based on condition/risk criteria, not a fix/crisis event of chaos.
Indoor Air Quality
An air contaminant is any substance which is accidentally or unwillingly introduced into the air, having the effect of rendering the indoor atmosphere toxic or harmful to some degree. The greatest concern when dealing with hazardous materials, including their byproducts, fumes, residues, etc., is with air contamination.
Through inhalation, airborne dust, fumes, vapors, mists, smoke and gases (many of which can be invisible) may all be taken into the body. These particles can then irritate the skin, eyes, nose, throat and lungs, or they may also be absorbed into the bloodstream and transported to affect other organs.
Airborne contaminants can present a significant threat to worker health and safety. Thus, identification and quantification of these contaminants through air monitoring is an essential component of every company's health and safety program. Reliable measurements of airborne contaminants are useful for:
- Selecting personal protective equipment;
- Delineating areas where protection is needed;
- Assessing the potential health effects of exposure;
- Determining the need for specific medical monitoring;
- Develop written programs and standards for Employee Training;
- Redesign processes for improved elimination of air contaminants to the workplace.
Note: The issue of indoor air quality is a matter relative to Employee Health and Safety as regulated under laws pursuant to OSHA and should not be mistaken for issues related to environmental air emissions regarding air permitting and reporting under the U.S. EPA and state departments of environmental quality.
What are PELs and TLVs?
Based on current, accurate scientific information at the time, air contaminant values were established in 1968. The American Conference of Governmental Industrial Hygienists (ACGIH) developed exposure limits called Threshold Limit Values (TLVs). TLVs are unique to ACGIH. TLVs represent the levels of chemicals in the air that are believed most workers can be exposed to day after day without harm. Permissible Exposure Limits (PELs) are those TLV employee exposure limits of toxic chemicals published by OSHA as legal standards.
Two different types of measurement are used by PELs. Concentrations of gases and liquids in the air is measured in parts per million (ppm). Solids or liquids, in the form of mists, dusts, or fumes, are measured in milligrams per cubic meter (mg/m3). The very first health standards were the 8-hour time-weighted average (TWA) values of air contaminants from the 1968 research. They now have the force of law. Today there are a total of 547 regulated air contaminants under the Indoor Air Quality Standard. OSHA requires employers to measure contaminants, maintain records and notify employees of overexposures and the corrective action planned to be taken for all future health standards. Moreover, it is important that the employer understands the importance of the action level concept. OSHA defines the action level as typically one-half the PEL. Where exposures reach or exceed the action level, additional requirements apply, including medical surveillance and a full air-monitoring program. Exposures to an airborne concentration, above the PEL trigger even further requirements, including reduction of exposures to (or below) the PEL by means of engineering controls supplemented by work practice controls, use of specified respirators, and use of other appropriate protective clothing and equipment.
Employee Protection from Air Contaminants
OSHA decided as a policy matter that the action level, which triggers the measurement requirements, be set below the PEL to better protect employees from overexposure. OSHA reasoned that this method was the most reasonable approach to a recurring problem, that is, how to provide the maximum employee protection necessary with the minimum burden to the employer. It has been determined, therefore, that three key duties should be triggered when an action level is reached: 1. exposure measurement; 2. medical surveillance; 3. employee training. All three actions are considered necessary by OSHA before employee exposure reaches the PEL. It is important to initiate measurement procedures periodically (generally assumed to be annual updating) to monitor whether levels are approaching the PEL. One must do so to ensure that employee exposure does not exceed it. Similarly, employees should be screened for preexisting medical conditions and trained in suitable precautions against dangerous properties of the substance when there is some chance that their exposure will become significant.
Powered Industrial Trucks (Forklift Training)
OSHA requires very specific operator training with regard to Powered Industrial Trucks (Forklifts) for the safety and welfare of drivers, as well as employees whose work orientation requires they be in the presence of forklift operations. OSHA requires that "only trained and authorized operators shall be permitted to operate a powered industrial truck."
Training shall include topics on:
trucks / railroad cars
gases / fumes
driver knowledge & skills
This regulation and mandated training has proven to save lives, prevent property damage and prevent accidents and injury involving drivers and other employees in the workplace. Many states require that drivers undergo rigorous driver testing and be issued a license upon successful completion of the course and driver exam.
Materials for instruction should include the written program, class roster, quizzes, instructional manual and actual driving scenarios which provide defensible documentation for compliance in the event of an enforcement inspection.
Respirator Training for Oxygen-Deficient Atmospheres
OSHA requires very specific training in the proper use of respirators in the workplace, as changing conditions and chemically-oriented atmospheres may have an adverse effect on the safety and health of employees. Therefore, Respirator Training becomes an integral part of a company's overall OSHA compliance program.
The Respirator Training program satisfies OSHA's requirements in the use of respirator equipment for personal protection against breathing contaminated air. Such equipment is typically used as a part of accident cleanup, internal emergency response, confined spaces and other situations in which hazardous environments may exist. OSHA requires the training to include:
- instruction on awareness of OSHA compliance regulations related to the proper use of respirators;
- recognition of conditions which would require breathing protection;
- the four types of respirator equipment to be used for specific environmental conditions;
- proper fitting of respirators specific to each individual;
- activities to be performed while using respirator equipment; and
- written policy and procedures site-specific to the use of respirators in the company's facility.
Bloodborne Pathogens (BBP) Program and Training
On December 6, 1991, the OSHA published the "Occupational Exposure to Bloodborne Pathogens" Standard. The purpose of this regulation is to "eliminate or minimize occupational exposure to Hepatitis B Virus (HBV), Human Immunodeficiency Virus (HIV – i.e., AIDS Virus) and other Bloodborne Pathogens." The regulation went into effect on March 6, 1992.
The BBP Standard applies to facilities or operations where exposure to human blood or other potentially infectious materials is possible. The original thrust of the regulation was aimed at healthcare facilities such as hospitals, clinics, nursing homes, medical laboratories and bloodbank / Plasma Centers. However, the Standard has also affected virtually ALL INDUSTRIAL FACILITIES since 1992, since employees are often exposed to blood or blood-contaminated materials in a number of situations, including:
- Internal “First Responders” on HazMat teams, fire brigades, first aid teams, etc;
- Cleaning up first aid and rescue equipment after use;
- Company medical offices and first aid stations;
- Trash containing contaminated band-aids, bandages and feminine hygiene products;
- Cleanup of industrial accidents where employees are injured.
Like most OSHA regulations, the BBP Standard is "performance oriented," meaning the accomplishment of certain prescribed outcomes must occur. A 3-pronged outline of components essential to BBP is provided as follows:
The written "EXPOSURE CONTROL PLAN.” All vitally important data regarding the facility and employee participants must be gathered so as to develop the written Plan site-specific to the client's facility. The Plan is comprehensive in scope, encompassing:
- Establishing program management and performance criteria;
- Exposure determination;
- Methods of accomplishing compliance;
- HIV and HBV bloodborne pathogens;
- Hepatitis B vaccination, post-exposure evaluation and follow-up;
- Labels and signs;
- Information and training.
- EDUCATION AND TRAINING. Training shall consist of the following:
- Bloodborne Pathogens Standard;
- Overview of epidemiology and symptoms of bloodborne diseases;
- Understanding how bloodborne pathogens are transmitted;
- Instruction on the facility's Exposure Control Plan;
- Recognizing how tasks and activities may involve exposure to blood and other infectious materials;
- Review of the methods that will prevent or reduce exposure to bloodborne pathogens, such as work practices and the use of personal protective equipment;
- Review of proper labels, signs and container "color coding."
- Contingency plans and emergency response to emergencies involving blood or other potentially infectious materials, including procedures for and "exposure incidents."
- RECORDKEEPING, DOCUMENTATION AND QUIZZES. A part of the overall compliance mandate is to substantiate through documentation those very objectives accomplished as a part of the program. Appropriate records, documents and employee participation logs should be filed and readily accessible in the event of an enforcement inspection.
Hearing Conservation for Occupational Noise Exposure
Noise, or unwanted sound, is one of America's most wide-spread workplace health problems. It is a by-product of many industrial processes. Sound consists of pressure changes in a medium (usually air), caused by vibration or turbulence. These pressure changes produce sound waves emanating away from the turbulent or vibrating source. Exposure to high levels of noise causes hearing loss and may cause other harmful health effects as well. The extent of damage depends primarily on the intensity of the noise (measured in decibels) and the duration (based on an 8-hour time weighted average (TWA)) of the exposure. Noise-induced hearing loss can be temporary or permanent. Temporary hearing loss results from short-term exposures to noise, with normal hearing returning after a period of rest. Generally, prolonged exposure to high noise levels over a period of time gradually causes permanent damage.
OSHA's Hearing Conservation Standard is designed to protect workers with significant occupational noise exposures from suffering hearing impairment even if they are subjected to such noise exposures over their entire working lifetimes. By the authority of the U.S. Congress and the Department of Labor, OSHA mandated "Hearing Conservation for Occupational Noise Exposure," effective April 7, 1983. The law requires Hearing Conservation programs for all employees whose exposure to workplace noise "equals or exceeds an 8-hour Time Weighted Average (TWA) of 85 decibels." The following summarizes the required components of OSHA's Hearing Conservation Program.
- Noise Level Monitoring. It is the employer's responsibility to monitor noise exposure levels in a manner that will accurately identify employees who are exposed to noise at or above 85 dB over an 8-hour TWA. The exposure measurement must include all continuous, intermittent and impulsive noise within 80 to 130 dB range and must be taken during a typical work situation. It is wise to select the monitoring method (or combination of methods) best suited to the employer’s workplace in order to achieve compliance with this performance-oriented standard. Monitoring must be repeated when changes in production, process, or controls increase noise exposure. Such changes may mean that an existing hearing conservation program no longer complies with OSHA's intended objective of hearing protection. The employer is required to notify employees about the results of noise exposure monitoring, albeit the method for notification is left to the discretion of the employer.
- Audiometric Testing. Audiometric testing not only monitors the sharpness or acuity of an employee's hearing over time, but allows employers to educate employees about their hearing and the need to protect it. The employer must establish and maintain an audiometric testing program. The important elements of an audiometric testing program include baseline audiograms, annual audiograms, training and follow up procedures. OSHA requires that audiometric testing must be made available at no cost to all employees who are exposed to an actual level of 85 dB or above, on an 8-hour TWA. The follow-up procedure indicates whether hearing loss is being prevented by the employer's hearing conservation program. Audiometric testing must be supervised by a certified audiologist; however, the professional does not have to be present when a qualified technician is conducting testing. Audiometric tests must be conducted in a room meeting specific background levels and with calibrated audiometers that meet American National Standards Institute (ANSI) approval.
There are two types of audiograms required in hearing conservation: Baseline and Annual audiograms. The Baseline audiogram is that with which future audiograms are compared. Baseline audiograms must be provided within 6 months of an employee's first exposure at or above an 8-hour TWA of 85 dB. Employees should not be exposed to workplace noise for 14 hours preceding the baseline test; however, appropriate hearing protectors can serve as a substitute for this requirement and can be worn during this time period. Annual audiograms must be conducted within 1 year of the baseline. It is important to test hearing on an annual basis to identify deterioration in hearing so that protective follow-up measures can be initiated before hearing loss progresses, or in other words, a Standard Threshold Shift (STS) has occurred. STS is an average shift in either ear of 10 dB or more at 2000, 3000, or 4000 hertz. This averaging method avoids false readings of hearing ability.
- Audiogram Evaluation. If an STS is identified, employees must be fitted or refitted with adequate hearing protectors, shown how to use them and required to wear them. Employees must be notified within 21 days from the time the determination is made that their test results showed an STS. Some employees with an STS may be referred for further testing if it is thought that their test results are questionable or if they have a medical problem related to the wearing of hearing protection.
- Hearing protection. Hearing protection must be available to all workers exposed to 8-hour TWA noise levels of 85 dB or above. This requirement will ensure that employees have access to protection before they experience a loss in hearing. Hearing protectors must be worn by: (1) employees for any period exceeding 6 months from the time they are first exposed to 8-hour TWA noise levels of 85 dB or above until they receive their baseline audiograms; (2) employees who have incurred STS’s since they have demonstrated that they are susceptible to hearing loss through workplace noise; (3) employees exposed to the permissible exposure limit of 85 dB over an 8-hour TWA. Employees must be shown how to use/care for their protectors and supervised on the job to ensure they continue to wear them correctly.
- Training & Recordkeeping. Employee training is very important. When workers understand the reasons for the hearing conservation program's requirements and the need to protect their hearing, they will be better motivated to participate actively in the program and to cooperate by wearing their protectors and taking audiometric tests. Employees exposed to TWA’s of 85 dB and above must be trained, at least annually, in the effects of noise; the purpose, advantages and disadvantages of various types of hearing protectors; the selection, fit and care of protectors; and the purpose and procedures of audiometric testing.
Workplace noise exposure records must be kept for 2 years. Audiometric test records must be maintained for the duration of employment for each affected employee. Audiometric test records must include the name of the employee, job classification, date of the last acoustic or exhaustive calibration, measurements of the background sound pressure levels in audiometric test rooms and the employee's most recent noise exposure measurement.
Confined Space Permitting and Rescue Team
Confined Space Permitting & Rescue Team became effective April 15, 1993. Here is an outline of elements pertinent to this Standard.
A. Evaluation of permit-required confined spaces in the workplace
B. Permit-required Confined Space Program (Written Program)
- Specified equipment
- Attendant station procedures
- Rescue team and methods
- Permitting system / supervisor authorization methods
- Danger signs
- Hazardous atmosphere evaluation and sampling (actual and potential)
- Continuous forced air ventilation
- Monitoring and inspection data
- Entrance covers
- Internal atmosphere tests
C. 14 step permitting process
- Identification of a confined space
- Purpose of entry
- Date/duration of permit
- Authorized entrants document
- Current attendants and Entry Supervisor
- Hazards Determination
- Space isolation and elimination or control of hazards
- Acceptable entry conditions
- Test results and performance
- Rescue and emergency summoning
- Attendant / entrant communication
- Required equipment
- Written comments on danger
- Related Permits (i.e., Hot Work, etc.)
D. Training and employee records
- Authorized entrants
- Entry supervisors
- Rescue teams
- Equipment: Personal Protective Equipment (PPE) and Rescue-related Equipment
- First aid, including CPR
- Rescue simulation drills done at annual refresher
- Emergency contingencies / SDS information prepared for hospital and emergency medical
- Contractor procedures
- Alternative protection procedures
OSHA 300, 300A and 301 Log
OSHA published a Final Rule to amend its recordkeeping regulation to remove the requirement to electronically submit to OSHA information from the OSHA Form 300 (Log of Work-Related Injuries and Illnesses) and OSHA Form 301 (Injury and Illness Incident Report) for establishments with 250 or more employees that are required to routinely keep injury and illness records. Covered establishments are only required to electronically submit information from the OSHA Form 300A (Summary of Work-Related Injuries and Illnesses). The requirement to keep and maintain OSHA Forms 300, 300A, and 301 for five years is not changed by this Final Rule.
Many employers with more than 10 employees are required to keep a record of serious work-related injuries and illnesses. Minor injuries requiring first aid only do not need to be recorded. information helps employers, workers and OSHA evaluate the safety of a workplace, understand industry hazards, and implement worker protections to reduce and eliminate hazards preventing future workplace injuries and illnesses.
Maintaining and Posting Records
The records must be maintained at the worksite for at least five years. Each February through April, employers must post a summary of the injuries and illnesses recorded the previous year. Also, if requested, copies of the records must be provided to current and former employees, or their representatives.
Electronic Submission of Records
The Injury Tracking Application (ITA) is accessible from OSHA’s ITA launch page, where you can provide the Agency your OSHA Form 300A information. The date by which certain employers are required to submit to OSHA the information from their completed Form 300A is March 2nd of the year after the calendar year covered by the form.
Severe Injury Reporting
Employers must report any worker fatality within 8 hours and any amputation, loss of an eye, or hospitalization of a worker within 24 hours. To report serious events, you can contact your nearest OSHA office or call their 24-hour hotline 1-800-321-6742(OSHA). You can also report online using OSHA’s Severe Event Reporting Online Form… Link: https://www.osha.gov/pls/ser/serform.html
Safety Data Sheets (SDSs) – Document OriginationBloodborne Pathogens (BBP) Program and Training
When an organization originates a chemically-oriented product for commerce – liquid, solid, or gas – to be used, stored, processed, manufactured, imported, or resold, OSHA requires that proper health and safety information (specifically related to the chemical constituents of the product) become documented for HazCom purposes to all human beings that could become exposed to such hazards. This especially applies to those persons exposed to the hazards of the product prior to end-use by the consumer. However, any end-use consumer has the right to know of the hazards contained within a product also and, therefore, may request an SDS at the time of purchase from any outlet, even retail. The activity of SDS Origination must be established for those companies originating (creating, producing, etc.) one or more products that require the SDS document as regulated by OSHA.
OSHA's HazCom Standard of 1987 clearly states that a supplier or manufacturer of an original product must provide a Safety Data Sheet (formerly called Material Safety Data Sheets) with each product upon its initial delivery and then provide an update of the product's SDS at which time the product undergoes any changes, improvements, or compositional change. Moreover, the law provides that any employer that uses, stores, processes, produces, manufactures, or imports a chemically-oriented product must acquire an SDS from the product's originator, creator, or supplier so as to make it accessible to all employees at all times in the employer's workplace.
OSHA has allowed for the product originator's potential need for protection of trade secret and proprietary information. SDSs must now follow the 16-point system under the UN’s Globally Harmonized System (GHS), as has been adopted and required by OSHA since 2012.