OSHA Regulations often applied to commercial office & schools

OSHA

Regulations often applied to commercial office & schools

Rob Rottersman, MS, CIH

847.685.9266

rrottersman@boelter-yates.com

Illinois

Non-Public Buildings/Employees• OSHA has jurisdiction

Public Buildings (including municipal and schools)• Illinois Department of Labor (IDOL) has

jurisdiction

• IDOL has adopted OSHA standards

Most Frequent Citations (National)October 2004 – September 2005

1. Scaffolding (9,558)

2. Hazard Communication (7,564)

3. Fall Protection (6,483)

4. Respiratory Protection

5. Hazardous Energy/Lockout Tagout (2,281)

Total Citations (1 year) = 113,362

$103,923,102 in fines

Scaffolding

OSHA 29CFR1910.27 Subpart D

“Walking – Working Surfaces”

Defined – “Any temporary elevated platform and its supporting structure used for supporting workmen or materials or both”

Regulations depend on scaffold type

Powered Platforms & Manlifts

OSHA CFR1910.66

Specific for Building Maintenance

• Regulations specific for type of lift

• Includes standards for harnesses, use, inspection & training

• Protection from falling objects

Hazard Communication

OSHA 29CFR 1910.1200http://www.osha.gov/pls/oshaweb/

owadisp.show_document?p_id=10099&p_table=STANDARDS

Or Google Search “OSHA 1910.1200”

• Who has a hazard communication program?• Is it compliant with the standard?

Purpose

PURPOSE – Why do we need all this?

• Ensure chemical hazards are evaluated

• Information passed on to employee– Allow for safe use and handling

• Emergency response (spills/exposure)

Key Elements

• Written Program

• Material Safety Data Sheets (MSDS)

• Chemical Inventory

• Training

• Labeling

Written ProgramHow the School will Meet Requirements:1. Labeling/warning information2. MSDS 3. Employee Information and Training4. List of Hazardous Chemicals 5. Hazards of “non-routine” tasks6. Outside contractor/visitor

communication*Program must be available upon request

Labeling

Container Labels Must Contain:

• Identity of hazardous chemicals

• Appropriate hazard warnings

• Name & address of manufacturer

Manufacturers label should be sufficient

When do you need to label?

• Chemical transferred to other container and NOT used by 1 employee on 1 shift– Spray bottles are often overlooked– Science and art rooms often forgotten

• Manufacturer’s labels is worn/illegible• Label is not in English

Labeling Exemptions• Articles = Not gas, liquid or particle item with

“end use function” (i.e. solid parts)• Materials regulated by other agencies

- Pesticides (but label required by EPA)– Food, Drugs, Cosmetics – Alcohol– Agricultural or vegetable seeds– Wood or wood products– Biological hazards– Radiation

Material Safety Data Sheets (MSDS)

Must have a MSDS for every “hazardous” chemical in the school

OSHA Hazardous – “Any chemical which is a physical or health hazard”

“All substances are poisons; there is none that it is not a poison. The right dose differentiates a poison from a remedy”

Paracelsus 1493-1541

MSDS Contentsi. Name – Product Identityii. Physical & chemical characteristicsiii. Physical hazardsiv. Health hazardsv. Routes of entryvi. Whether or not it can cause cancervii. Precautions for safe handlingviii.Control measures (ventilation, PPE, etc)ix. Emergency & first aidx. Date of MSDS preparation and revisionxi. Contact info. for manufacturer

Exposure Standards – Alphabet Soup

• Permissible Exposure Limits (PEL)– OSHA Standard – enforceable– Subject to industry lobbying

• Recommended Exposure Limit (REL)– National Institute of Occupational Safety and Health

(NIOSH)– Research based – not enforceable

• Threshold Limit Value (TLV)– American Conference of Govt. Industrial Hygienists

(ACGIH)– Recommended but not enforceable

Health Considerations

• Review significant routes of entry– Skin contact, inhalation, ingestions

• Chronic vs. Acute– Chronic – delayed response

• i.e. cancer, cirrhosis

– Acute – effect short time after exposure• Irritation, headaches, dizziness, allergic

MSDS Maintenance

• Obtain from chemical manufacturer

• MSDS must be readily & immediately accessible to employees

• Electronic files are permitted if employees have access– Keep current – periodic review

for updates

MSDS Recommendations

• Establish & maintain a new product introduction program– Have 1 person designated to approve all

new products brought onto school grounds

– Approval requires submitting MSDS sheet, review for hazards & training if needed

Chemical Inventory List

• List of all “hazardous” chemicals found in the facility

• Must include the name used on the MSDS sheet

• Consider using as an MSDS index

Training

• All employees who use or could come in contact with “hazardous” chemicals must be trained– At the time of hiring– Before beginning a new assignment/job

change– Whenever there is a new hazard that was

not included in previous training– Whenever new hazards are discovered for

an existing product

Non-routine Tasks

• Often overlooked – could be significant health and safety

hazards

• Examples in schools could include– Cleaning, using chemicals in confined space such

as crawlspaces– Handling cooling tower treatment chemicals– Chemicals to remove graffiti – Inventory old chemicals from science & art rooms

Outside Contractors/Vendors

• Must inform of hazards associated with products they use or may come in contact with

• Notify them of written program and location of MSDS sheets

• Provide training as needed

Chemicals Used by Vendors at Your School

Janitorial cleaning crews, contractors, pesticide applicators, etc.

• Make sure they have provided you with MSDS sheets• Review to ensure they are complete & up to date• KNOW THE LOCATION of their MSDS sheets AND

inform your employees

Fall Protection

Multiple references in the standard

OSHA CFR1910.21-1910.27 Appendix D

• Guards and rails– Floor openings, uneven floor surfaces, etc.

• Ladders & Stairs– Wood vs. metal & fixed vs. permanent

Respiratory Protection

OSHA CFR1910.134, .139

Respirators as a “last resort” for reducing chemical exposures to safe levels.

Better Options:- Eliminate hazard (product substitution)- Engineering controls (ventilation)

Respirator Programs

If employees use respirators an OSHA respirator program must be in place

• Appropriate Respirator Selection

• Annual Training

• Annual Fit Testing

• Medical Evaluations

• Exposure Assessments

Dust Mask Exemption

OSHA CFR1910.134(c)(2)(i)(ii)Dust Mask (filtering face piece) may be worn if:

• Use is voluntary (not required by employer)• The respirator itself will not create a hazard• Employer provides employee with information

contained in OSHA Appendix D– “Information for Employees Using Respirators When

Not Required Under the Standard”

Respirator Selection

Safety Shoes

29CFR1910.136

• Required when danger of injury from falling or rolling objects, objects may pierce the sole or feet are exposed to electrical hazard

Eye Protection

29CFR1910.133

Eye & face protection shall be worn when exposed to eye or face hazards from flying particles, molten metal, liquid chemicals, acids or caustics, chemical gases or vapors or injurious light radiation

LockOut/TagOut(Control of Hazardous Energy)

OSHA 29CFR1910.147

“Covers the servicing and maintenance of machines and equipment in which the unexpected start up or release of stored energy could cause injury to employees”

LO/TO Requirements

Written Program/Policy

Define “Authorized” employees• Understand the machines & energy• Trained in LO/TO• Authorized to install & remove locks/tags

Define Effected Employees• Employees who may operate locked or tagged

out equpment

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

OSHA Record Keeping

29CFR1904

AKA: 300 LogIncludes:• Determining if injuries are “recordable”• Logging injuries (300 Form)• Investigate cause (301 Form)• Post summary - Feb-April (300-A Form)

Blood Borne Pathogens

29CFR1910.1030• Program required when there are employees with

potential exposure– Health care – First Responders/First Aid Providers– Janitorial (restroom cleaning)

• Annual training required• Post exposure vaccination program

– Hepatitis B Virus

Safety Quiz: Who’s Liable?

Bob dropped a banana peel, slipped and fractured his skull, who’s at fault?

1) Bob2) Bob’s school district & supervisor3) Floor wax manufacturer4) Banana importer5) Grocery store6) Newspaper that advertised banana sale7) The Banana farmer

You Know an IDOL Inspection is going bad when-

• IDOL sets up temp. housing in your parking lot• The officer mutters “this is unbelievable”• They call in a professional film crew for documentation and you

recognize Walter Jacobson• Officer is wearing a moon suit and respirator your staff is in

jeans and tennis shoes• Officer begins inspection with “you have the right to remain

silent”• Officer asks a specific question about a note in your files

(before you show him the file)• Officer knows all your staff by their first names• Officer is a former science teacher that you fired

Speaker Contact Information

Rob Rottersman, MS, CIH

Senior Environmental Consultant

Boelter & Yates, Inc.

1300 Higgins Rd. Ste 301

Park Ridge, IL 60068

rrottersman@boelter-yates.com

IASBO Booth #432