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OSHA Emphasis Programs
in Florida
PRESENTED B: Joan M. Spencer Compliance Assistance Specialist Tampa Area Office 813-626-1177 spencer.joan@dol.gov
National Emphasis Programs
•Crystalline silica •Lead •Combustible dust •Oil refineries •Trenching •Amputations •Shipbreaking operations
National Emphasis Programs
•Primary Metal •Chemical plants •Hexavalent Chromium •Diacetyl •Federal Agencies •Nursing and Residential Care Facilities
Regional Emphasis Programs
• Lead • Silica • Noise • Sharps • Health Hazards in Scrap and Waste
Materials Recycling Operations
Regional Emphasis Programs
• Forklifts • Overhead Powerlines • Falls • Landscaping • Methylene Chloride • Sanitation and Clean-up operations
Food and Kindred Products.
Combustible Dust Explosions History
• January 29, 2003 -
West Pharmaceutical Services, Kinston, NC – Six deaths, dozens of
injuries – Facility produced rubber
stoppers and other products for medical use
– Plastic powder accumulated above suspended ceiling ignited
– Polyethylene dust
OSHA History
• November 2006 CSB issued a report on their Combustible Dust hazard Study – OSHA Recommendations
• Issue a standard • Revise Hazard Communication Standard • Communicate to European Union on GHS for
Combustible Dust • Provide Training • Implement a NEP
OSHA History
• October 2007 OSHA launches its Combustible Dust NEP – Focus – facilities that generate or handle
combustible dust which pose a deflagration/explosion hazard
• Winter 2008 – Imperial Sugar Dust explosion • March 2008 – OSHA revises combustible
dust NEP to better focus on most hazardous industries
Top Ten Industries Inspected under NEP
164
123
10386 80
6955
40 34 30
050
100
150
200
Wood
Prod
ucts
Food
Prod
ucts
Chem
ical
Indus
tries
Metal
Prod
ucts
Rubb
er/Pla
stic
Prod
Prim
ary M
etal
Elec/S
anita
rySe
rv.
Furni
ture
Trans
p. Eq
uip
Dur. G
oods
What is Combustible Dust?
NFPA 69 (2002), and 499 (2004) Definitions • Combustible Dust. Any finely divided
solid material 420 microns or less in diameter (i.e., material passing through a U.S. No 40 Standard Sieve) that presents a fire or explosion hazard when dispersed
Dust Control
• Design of facility & process equipment
• Contain combustible dust
• Clean fugitive dust • Regular program • Access to hidden areas • Safe cleaning methods
• Maintenance
Dust Layer Thickness Guidelines
• 1/8” in grain standard • Rule of thumb in NFPA 654
• 1/32” over 5% of area • Bar joist surface area ~ 5% • Max 20,000 SF • Idealized
• Consider point in cleaning cycle
Lab Tests and Results
• Percent through 40 mesh • Percent moisture content • Percent combustible material • Percent combustible dust • Metal dusts will include resistivity • Minimum explosive concentration (MEC) • Minimum ignition energy (MIE) • Class II test • Sample weight • Maximum normalized rate of pressure rise (dP/dt) – Kst
Test • Minimum ignition temperature
Ignition Source Control
• Electrical equipment • Static electricity control • Mechanical sparks & friction • Open flame control • Design of heating systems & heated
surfaces • Use of tools & vehicles • Maintenance
Damage Control Construction
• Detachment (outside or other bldg.) • Separation (distance with in same
room) • Segregation (barrier) • Pressure resistant construction • Pressure relieving construction • Pressure Venting • Relief valves • Maintenance
Damage Control Systems
• Specialized detection systems • Specialized suppression systems • Explosion prevention systems • Maintenance
Applicable Standards
• Existing OSHA Standards – 1910.22 – housekeeping – 1910.38 – emergency action plans – 1910.94 – ventilation – 1910.119 – process safety management – 1910.269 – electric power generation – 1910.272 – grain handling facilities
Applicable Standards
• Existing OSHA Standards (cont) – 1910.307 – hazardous locations – 1910.1200 – hazard communication
• Section 5(a)(1) – General Dusty Clause
– Applicable ANSI and NFPA standards
Combustible Dust Related Violations
130
167
36
133
206
48
151
35
0
50
100
150
200
2505(
a)(1
)
HazC
om
Fire
Extin
guish
ers
Elec
trica
l (H
az L
oc)
Hous
eKe
eping
Com
pres
sed
Air PP
E
Firs
t Aid
OSHA Findings Under the NEP
• Hazardous levels of dust accumulations in workplaces due to poor housekeeping
• Process equipment such as grinders, ventilation ducts, shakers, baghouses, and bagging equipment not designed or maintained to keep dust out of surrounding areas
OSHA Findings Under the NEP
• Electrical equipment and vacuums not approved for locations handling combustible dust
• Powered industrial trucks not approved for locations handling combustible dust
• Hot work performed in dust handling locations without hot work procedures
OSHA Findings Under the NEP
• Heating appliances with open flames used in dust handling or generating areas
• Lack of preventative maintenance on mechanical equipment – creating heat and friction
• Baghouses located inside buildings without proper explosion protection systems
OSHA Findings Under the NEP
• Dust work lacking in venting or explosion suppression systems
• Deflagration isolation systems not provided
• Rooms with no explosion relief systems
• Horizontal surfaces not minimized
OSHA Findings Under the NEP
• Explosions vents or suppression systems not provided on hoppers, silos, bucket elevators, and dust collectors
• Baghouses located indoors • Explosion venting directed into work
areas rather than to the outside
How is Cr (VI) Formed?
• Created during “hot work” processes such as welding on stainless steel or the melting of chromium metal – Chromium metal is ionized
into the fume high temperatures and chemical reactions temporarily oxidizes the chromium ion into a hexavalent (+6) state
Major Industries
• Electroplating • Welding on stainless
steel or Cr(VI) painted surfaces
• Painting – Aerospace – Auto body repair
• Chromate pigment and chemical production
• Chromium dye and catalyst production
• Glass manufacturing • Plastic colorant
production • Construction
– Traffic painting – Refractory brick
restoration – Paint removal from
bridges
Chrome 6 NEP Goals
• Significantly reduce the number of employees who are exposed to Cr(VI) and other toxic substances often found in conjunction with Cr(VI) at levels that exceed the applicable permissible exposure limits
• Control health hazards associated with such exposures
Inspection Procedures
• CSHO will consider and evaluate employee exposure and compliance in regard to : – Regular operations – Setup and preparation for regular operations – Making adjustments during operations – Cleaning of the process area – Scheduled and unscheduled maintenance – Implementation of engineering controls – Use of PPE – Medical Surveillance programs – Employee training and education
Inspection Procedures
Personal exposure monitoring required in all cases where exposure is present
• CSHO will take properly calibrated instruments and sampling media on first day of inspection
• Includes adequate materials to immediately ship Cr(VI) sampling media to lab
• If no monitoring conducted, explanation MUST be included in case file
• CSHO should NOT rely solely on employer sampling
Chrome 6 Findings
• FY11 – 155 Inspections Nationwide – 854 Citations – 43 Inspections Region wide (27%) – 259 Citations (30%)
Chrome 6 Findings
• FY11 – 29 1910.1026 citations for Region – Some 1910.1025 citations – Most citations were safety related
• Walking working surfaces • Machine guarding • LOTO • PPE • Electrical • PIT • and a couple of Hazwoper and PRCS citations
Health Hazards in Scrap Metal Recycling Operations REP
• 56 million tons of scrap iron and steel
• 1.5 million tons of scrap copper
• 2.5 million tons of scrap aluminum
• 1.3 million tons of scrap lead, • 300,000 tons of scrap zinc • 800,000 tons of scrap
stainless steel
Health Hazards in Scrap Metal Recycling Operations REP
• Private, nonferrous recycling industries in the U.S. employed approximately 16,000 employees in 2001.
• In 2001, those nonferrous recycling industries reported approximately 3,000 injuries and illnesses.
Health Hazards in Scrap Metal Recycling Operations REP
• The most common causes of illness were poisoning (e.g., lead or cadmium poisoning), disorders associated with repeated trauma, skin diseases or disorders, and respiratory conditions due to inhalation of, or other contact with, toxic agents.
Health Hazards in Scrap Metal Recycling Operations REP
• Reduce exposures to metal fumes, gases, noise, heat, radiation.
• Safety hazards from risk of fire, machine guarding, struck-by hazards.
Health Hazards in Scrap Metal Recycling Operations REP
• FY 2011 – Region conducted
103 inspections – Covered 1,690
employees –400 Citations –635,000 in penalties
REP Findings
• Heath related citations issued under: – Lead – Noise – Hazard
communication – Respiratory
protection
Health Hazards in Scrap Metal Recycling Operations REP
• Safety related citations issued under: – Walking working
surfaces – First-aid – Machine guarding – LOTO – Welding and cutting – Electrical – PIT – and one PRCS
Noise REP
• Ten million people in the U.S. have a noise-related hearing loss.
• Twenty-two million workers are exposed to potentially damaging noise each year.
• In 2008, approximately 2 million U.S. workers were exposed to noise levels at work that put them at risk of hearing loss.
• In 2007, approximately 23,000 cases were reported of occupational hearing loss that was great enough to cause hearing impairment.
• Reported cases of hearing loss accounted for 14% of occupational illness in 2007.
• In 2007, approximately 82% of the cases involving occupational hearing loss were reported among workers in the manufacturing sector. Source: OSHA Website
Noise REP
• Sawmills • Planning Mills • Wood Pallets and Skids Manufacturers • Concrete Products Manufacturers
(except block and brick) • Plastic Products Industry.
– SICs include 2421, 2448, 3272, and 3089.
Noise REP
• Findings: • 92 Inspections (mostly GA) • Mostly safety violations
– PIT – Machine guarding – Electrical – LOTO
• 24 noise violations
Lead REP
• OSHA's five-year strategic plan sets a performance goal of a 15% reduction in the average severity of lead exposure or employee blood lead levels in selected industries and workplaces.
• Scope includes all Industries which lead exposure is a potential
Lead REP
• All establishments that were cited for lead exposures within the past ten fiscal years shall be scheduled for inspection
• SICs selected by NEP
Inspection Procedures
• Personal air monitoring • Collect wipe samples. • Monitoring may not be necessary if the
employer provides reliable and recent data showing employees’ exposures are below the action level and the conditions in the work place are the same
Inspection Procedures
• Evaluation of engineering controls and administrative control for the processes where lead exposures above the permissible exposure limit occur.
• A detailed evaluation of the employer’s personal protective equipment (PPE) and respiratory protection programs will be conducted on every inspection where lead hazards exist.
Inspection Procedures
• The employer’s hygiene program will be reviewed to determine if hand-to- mouth contact may be contributing to employee exposure to lead.
• The housekeeping procedures and evaluation and use of PPE will be assessed and documented.
Lead REP Findings
• FY 11 – 74 Inspections – Covered 2,971 employees – 45 lead citations – $10,262 average penalty per inspection
• SICs selected by NEP
Silica REP
• Goal is to significantly reduce/eliminate employee overexposures to crystalline silica and, therefore, control the health hazards associated with such exposures.
Silica REP
• All industries were silica overexposure has been documented in the Region
• SICs selected by NEP
Inspection Procedures
• Employee exposure monitoring for respirable dust containing crystalline silica
• Bulk samples • Review any existing employer's silica
exposure monitoring records. • Citations for results over the PEL
regardless of PPE
Inspection Procedures
• Engineering and Work Practice Controls: – Location of employee(s) with respect to dust
generation source – Isolation (e.g., control room, enclosures, or
barriers) – Local exhaust ventilation (LEV) systems – Wet methods for cutting, chipping, drilling,
sawing, grinding, etc – Use of HEPA-equipped vacuums or wet
sweeping for cleaning.
Inspection Procedures
– Compressed air usage – Substitution with non-crystalline silica
material. – Use of tools with dust collecting systems. – Controls for abrasive blasting (specific
standard)
Inspection Procedures
• Respiratory Protection: – Minimum Respiratory Protection: N95 – Medical Evaluations for Respirator Use – Employees who refuse to be medically
evaluated cannot be assigned to work in areas where they are required to wear a respirator.
Inspection Procedures
• Hazard Communication: – Carcinogen warnings are required on
containers of materials containing more than 0.1 percent crystalline silica by weight or volume
– Bricks/Tiles/Cement boards not exempt – Vehicles hauling shipments of crushed stone
shall include hazard warnings concerning the carcinogenicity of crystalline silica on their shipping papers or bills of lading
Inspection Procedures
• Determine whether the employer's housekeeping and hygiene practices may contribute to overexposure. – Wet sweeping should be used to clean areas
if possible. – If vacuuming is used for cleaning, the
exhaust air should be properly filtered to prevent release of airborne silica back into the workroom.
Inspection Procedures
• Housekeeping and hygiene practices – There should be separate break areas for
consuming food, beverages, etc. that are kept free of silica.
– Clothes contaminated with silica should not be blown or shaken to remove dust.
• Employee Exposure and Medical Records • Abrasive Blasting has other special
considerations
Silica REP Findings
• FY 11 – 166 Inspections – Covered 2,109 employees – 4 silica citations – $3,705 average penalty per inspection
• SICs selected by NEP
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