Safety and Health Program Management forSafety and Health Program Management for Sheltered Workshops

Missouri Department of Labor and Industrial Relations

Daniel Stark, CIH – Program Managerd i l t k@l bdaniel.stark@labor.mo.gov

573-751-3403

Top 5 weirdest OSHA questions in 2006:2006:

#5: "Does OSHA regulate song lists played over a store's stereo?”#5: Does OSHA regulate song lists played over a store s stereo?

#4: "Does the word 'MUST' in OSHA standards mean I HAVE to do it?“

#3: "For employee bathrooms, what kind of toilet seat does OSHA require?”

#2: "How do you go about using hazardous warning labels on products that are not hazardous?“

#1: "Instead of respirators, is it okay if workers just hold their breath?"

Missouri On-site Safety and Health Consultation Program

Background

The need for OSHAThe need for OSHA Consultation

Section 21(d)(2) of OSHActSection 21(d)(2) of OSHAct

29 CFR 1908 - Consultation AgreementsAgreements

90%/10% funding

Consultation Programg

OSHA “mock” inspectionOSHA mock inspection

No fines, penalties, or citationsp

No cost

Consultation Program (continued)

Completely Confidential!

Serious hazards/Imminent danger

No referral since program’s inceptionNo referral since program s inception

Consultation Program - Visit

Opening Conference

Analysis of Safety and Health Programsg

Walk through

Interim Protections

Closing Conference

Consultation Program – Visit (continued)g ( )

Written Reportp

Hazard Corrections

Follow-up (optional)

Close Case

Safety and Health Achievement Recognition Program (SHARP)Recognition Program (SHARP)

What’s SHARP?

Up to a two year exemption from OSHA’s general inspection schedule

Fatalities/catastrophes formalFatalities/catastrophes, formal employee complaints, and imminent dangers still fair game

Pre-SHARP

Safety and Health M t S t (SHMS)Management System (SHMS)

Safety and Health Management y gSystem Elements

1. Management Leadership and Employee Involvement

2. Workplace Analysis

H d P ti d C t l3. Hazard Prevention and Control

4 Safety and Health Training4. Safety and Health Training

5. Program Evaluation/Improvement (I2P2 Addition)

Element #1 - Management Leadership and EmployeeLeadership and Employee

Involvement

Top management commitment essential!

Policy statement

Goals and objectives

Management example

Good management example???Good management example???

Management Leadership and E l I l t ( ti d)Employee Involvement (continued)

Assign safety and health responsibilities

Provide authority and resources

Accountability

Management Leadership and E l I l tEmployee Involvement

Safety and healthSafety and health inspections

Safety suggestions vs. Safety incentives

System review

Element #2 - Worksite AnalysisElement #2 Worksite Analysis

Baseline and periodicBaseline and periodic safety and health surveys

Hazard reporting systemsystem

Analyze new yprocesses, buildings, materials, equip.

Worksite AnalysisWorksite Analysis

Job safety and health yanalysis

Expert hazardExpert hazard analysis

Accident & incident investigation, near misses

Trend analysis

Job Hazard Analysis (JHA’s)Job Hazard Analysis (JHA s)

Three Simple Steps:1. Break the task down in steps2. Identify the hazards in each step3. Identify the control measures in each step

Ex. Employees who handle parts are experiencing cuts.

JHA - Remove Burr From Cast PartJob Step

1 Reach into

Hazard

1 Sharp b rrs on

Control

1. Reach into metal box to right of machine grasp

1. Sharp burrs on part could cause laceration

1. Use gloves or hand tool (clamp) to pick-

tmachine, grasp 15 pound casting, and carry to wheel.

laceration. up part.

carry to wheel.

2. Push casting against wheel

2. Metal fragment could get in eye

2. Use safety glasses in metal grinding

to grind off burr.

3. Place finished i i b

eye.

3. Reaching,

operations.

3. Body mechanics casting in box to left of machine.

g,twisting, lifting heavy part = back strain.

ytraining; adjustable work stations.

Element #3 - Hazard Prevention d C t land Control

Controls – Source, Path, Receiver

Engineering, Administrative, PPE controls

Safety and health rules and work practices

OSHA mandated programs

Source ReceiverPath

Hazard Prevention and ControlHazard Prevention and Control

Hazard trackingHazard tracking

Preventive maintenance

Emergency drills

Medical programMedical program

Element #4 - Safety and Health Training

N Hi E lNew-Hire Employees

Existing Employees

Periodic Training Needs

DOCUMENT!

Tailor training for: EmployeesSupervisorsSupervisorsManagers

Why good detailed trainingWhy good detailed training is important…..

OSHA C liOSHA Compliance

OSHA RegulationsOSHA RegulationsThere are three primary OSHA regulations with which

you must comply:you must comply:

◦ 29 CFR 1904—OSHA’s Recordkeeping p gStandards◦ 29 CFR 1910—OSHA’s General Industry

StandardsStandards◦ 29 CFR 1926—OSHA’s Construction Industry

Standards

Top 10 Sheltered Workshop Hazards f d b MO O it C lt tifound by MO On-site Consultation

1 1910 305 Electrical1. 1910.305 Electrical2. 1910.305 Electrical3 1910 120 0 Hazard Communication3. 1910.120 0 Hazard Communication4. 1910.212 Machine Guarding5. 1910.304 Electrical (Grounding)( g)6. 1910.178 Forklifts7. 1910.334 Electrical8. 1910.157 Fire Extinguishers9. 1910.132 PPE

1910 147 L k t/T t10. 1910.147 Lockout/Tagout

OSHA 300 log (29 CFR 1904)OSHA 300 log (29 CFR 1904)Annual log of recordable injuries and illnesses

300A posted from February 1 to April 30.

301 – Injury and Illness I id t R tIncident Report

Medical TreatmentMedical Treatment

What is medicalWhat is medical treatment?

It d t i l dIt does not include:◦ Visits to a PLHCP

solely for observation yor counseling◦ Diagnostic

proceduresprocedures◦ First aid

Cases that are not recordable -Fi t AidFirst Aid

Using nonprescription medication at nonprescription strengthp p g

Tetanus immunizations

Cl i fl hi kiCleaning, flushing, or soaking surface wounds

Wound coverings, butterfly b d St i St ibandages, Steri-Strips

Hot or cold therapy

Non-rigid means of support

Temporary immobilization device used to transport accident victimsused to transport accident victims

Cases that are not recordable - First AidAid

Drilling of fingernail or toenail draining fluid from

Finger guardsMtoenail, draining fluid from

blisterEye patchesRemoving foreign bodies

MassagesDrinking fluids for relief of heat stress

Removing foreign bodies from eye using irrigation or cotton swabRemoving splinters orRemoving splinters or foreign material from areas other than the eye by irrigation, tweezers, cotton

b th i lswabs or other simple means

OSHA Sit S ifi POSHA Site-Specific Programs

OSHA Poster

Must be displayed p ywhere workers can see it

Explains worker and employer rightsemployer rights

Downloadable from OSHA’s website

Emergency Action Plan(29 CFR 1910.38)

STEP #1 Wh t th “ bl f bl ” iSTEP #1--What are the “reasonably foreseeable” emergencies that my company is exposed to?

STEP #2 What do I want mySTEP #2—What do I want my employees to do in the event of each of these emergencies?

STEP #3—If you have 11 or more employees, the plan has to be in writing.

STEP #4—Train your employees. This isDay #1 (new-hire) information.

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Six Elements of Emergency Action PlanSix Elements of Emergency Action Plan1. Procedures for reporting a fire or

other emergencyother emergency 2. Procedures for emergency

evacuation (type of evacuation ( ypand exit route assignments)

3. Critical facility operations before evacuationevacuation

4. Accounting for employees5 Procedures for rescue or medical5. Procedures for rescue or medical

duties6. Company POC for additional

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information

Emergency Action PlanningEmergency Action PlanningAlarm System◦ Must be able to hear it above

ambient noise◦ Distinctive/recognizable◦ Maintained and Tested

Supervised = AnnuallyNon-Supervised = Every 2 Months

T i i E lTraining - Every employee must know their role!Re-TrainingRe Training◦ New Plan/New Employee◦ Revised Plan

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Fire Prevention Plan (29 CFR 1910 39)(29 CFR 1910.39)

Depending upon your process and fire extinguisher

List of all major fire hazards

policies, you might need a FPP.

Proper handling and storage procedures for g phazardous materials

Potential ignition sources gand their control

Type of fire protection yp pequipment necessary to control each hazard

Fire Prevention Plan (29 CFR 1910 39)(29 CFR 1910.39)

5. Procedures to control flammable/combustible waste materials (housekeeping)(housekeeping)

6. Maintenance procedures for heat-producing equipment

POC f i t7. POCs for equipment maintenance and fuel hazards

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Personal Protective Equipment(29 CFR 1910 132)(29 CFR 1910.132)

1. Hazard Assessment

2. Written Certification

3. Employee Training) Wh PPE ia) When PPE is necessary

b) What PPE is necessaryc) How to properly don doff adjust and wear PPEc) How to properly don, doff, adjust and wear PPEd) Limitations of PPEe) Proper care, maintenance, useful life and

di ldisposal

Hazard Communication (29 CFR 1910.1200)

1 Inventory/list of hazardous1. Inventory/list of hazardous materials

2. SDS for each hazardous material

3. SDS available on all shifts

Every private sector employer, regardless of size,

44

must comply with HAZCOM!

Hazard Communication (continued)Hazard Communication (continued)

4. Labeling - primary and secondary containers

5. Independent contractors

6. Non-routine tasks

7. Employee Training

45

Major revisions to the Hazard Communication StandardCommunication Standard

1. Hazard classification: Provides specific criteria for classification of health and physical hazards, as well as p yclassification of mixtures.

2. Labels: Chemical manufacturers and importers will be required to provide a label that includes a harmonized signalrequired to provide a label that includes a harmonized signal word, pictogram, and hazard statement for each hazard class and category. Precautionary statements must also be provided.

3. Safety Data Sheets: Will now have a specified 16-section format.

4 Information and training: The Revised HCS requires4. Information and training: The Revised HCS requires that workers be trained by December 1, 2013 to facilitate recognition and understanding of the new labels and safety data sheets.

GHS Pictograms

Explosive Flammable Oxidizer Compressed Gas

!!Acute Toxicity Corrosive Chronic Health Irritanty

Hazard

Dates To RememberEmployers by December 1, 2013:

I iti l l t i i i t h d◦ Initial employee training on pictograms, hazard statements and signal words◦ Minimal training on new SDS formatMinimal training on new SDS formatEmployers by June 1, 2015:◦ Continue to maintain the updated SDSs

Lockout/Tagout Program (29 CFR 1910.147)

Energy Control Procedure—protects employees who:◦ Perform maintenance◦ Perform maintenance◦ Operate machinery

Excluded Operations:◦ Cord/Plug equipment (if plug is

controlled)

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Lockout/Tagout Program (29 CFR 1910 147)(29 CFR 1910.147)

Written Energy Control Program1. Locks or Tags acceptable

a) Durableb) St d di db) Standardizedc) Substantial

2. Written start-up/shut-down procedures for:

a) Hard-wired machinesb) Two or more sources of energy

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Lockout/Tagout Program (29 CFR 1910.147)

3. Periodic Inspections of Lockout/Tagout Procedures◦ At least annually

E l t tif ( hi◦ Employer must certify (machine, date, employee observed, inspector name)

4. Authorized/Affected Employee T i iTraining◦ Must ensure employee has

knowledge and skillsknowledge and skills◦ Retraining Requirements

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Bloodborne Pathogen Program (29 CFR 1910.1030)

Applies if employees have exposure to blood or otherexposure to blood or other infectious materials

Exposure Control Plan

Universal Precautions

Hepatitis B VaccinationsHepatitis B Vaccinations

Communication of Hazards to Employees

Training

NOTE: “Good Samaritan” acts are not considered

occupational exposure!

Respiratory Protection Program(29 CFR 1910 134)(29 CFR 1910.134)

Voluntary UseVoluntary Use

Procedures forProcedures for selection

Medical Evaluations

Fi T iFit Testing

Respiratory Protection P ( ti d)Program (continued)

Cleaning, disinfecting and storage

Training

Evaluation of programprogram effectiveness

Hearing Conservation Program(29 CFR 1910 95)(29 CFR 1910.95)

Required above 85 dBA for 8 hours

Monitoring Program

Audiometric testing

Training

Other OSHA ProgramsOther OSHA ProgramsDepending upon your process, you might also need:

Forklift Operators Training Program

C fi d S PConfined Space Program

Fall Protection ProgramFall Protection Program

Mechanical Power Press Programg

Electrical Worker Training

Self-Inspection Programs

Why do we need a Self-I ti P ?Inspection Program?

More safe and healthful workplace

C i t t l f h d f th k lConsistent removal of hazards from the workplace

Increased productivityIncreased productivity

Better employee moralep y

OSHA Compliance

Inspection programs by themselves will t k! Wh ?not work! – Why?

For example:

How does this hazard involve the “breakdown” of the four elements of safetythe four elements of safety and health program management?

Keep in mind……

Inspections are not the Safety Manager’s

Keep in mind……

responsibility

Everybody is an inspector

Safety committees vs. no safety committees

Self-Inspection Checklist(OSHA’s Handbook for Small Business pub. #2209)( p )

Covers the following:Posting and RecordkeepingSafety and Health ProgramMedical Services and First AidFire Protection

Welding, Cutting and BrazingCompressed airCompressed Gas CylindersHoistse o ec o

PPEGeneral Work EnvironmentWalkwaysFloor and Wall Openings

o s sForkliftsSpraying OperationsConfined SpacesEnvironmental ControlsFloor and Wall Openings

Stairs and StairwaysElevated SurfacesExiting or EgressLadders

Environmental ControlsFlammable and CombustiblesChemical ExposuresHazcomLadders

ToolsMachine GuardingLOTO

HazcomElectricalNoiseMaterial HandlingVentilationVentilation

How about some pictures ofHow about some pictures of hazards?

NOTE: This presentation does not include all hazards possible in a facility.

Good tools for self-inspectionsAC Sensor

Good tools for self inspections

Tic Tracer

Outlet Tester

Gotcha stick

Helpful Web Sites

http://www.labor.mo.gov/ls/safetyconsultation

http://www osha govhttp://www.osha.gov

Questions?Questions?