Safety In the Building Services Industry

Joann Natarajan

OSHA

Austin Area Office

OSHA Laws that Affect This Industry

• Aerial Lifts

• Hazard Communication

• Permit Required Confined Space

• Personal Protective Equipment

• Bloodborne Pathogens

• Respirators

Aerial Lifts

• Must be tied off with a body harness/lanyard when in basket

• Required to have both upper controls and lower controls

• Worker training

Aerial Lifts

• Worker’s feet to remain on floor of basket

• Lift controls checked each day before use

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Hazard Communication: What’s the point?

• Purpose." (a)(1) To ensure that the hazards of all chemicals produced or imported are evaluated, and that information concerning their hazards is transmitted to employers and employees.

Hazard Communication

Program

Container Labeling

Material SafetyData Sheet

M.S.D.S.Program

Label

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Hazard Communication The Basic Requirements Are:

• (a)(2) This occupational safety and health standard is intended to address comprehensively the issue of evaluating the potential hazards of chemicals, and communicating information concerning hazards and appropriate protective measures to employees

– Developing and maintaining a written hazard communication program for the workplace

– Lists of hazardous chemicals present;

Hazard Communication The Basic Requirements Are:– Labeling of containers of chemicals in the

workplace,

– Containers of chemicals being shipped to other workplaces;

– Preparation and distribution of material safety data sheets to employees and downstream employers;

– Development and implementation of employee training programs

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Hazard Communication. • (e) "Written hazard communication

program."

Employers shall develop, implement, and maintain at each workplace, a written hazard communication program which at least describes how the requirements for labels and other forms of warning, material safety data sheets, and employee information and training will be met.

(f) "Labels and other forms of warning."(g) "Material safety data sheets."(h) "Employee information and training."

Haz Com Program

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Hazard Communication.

• A list of the hazardous chemicals known to be present using an identity that is referenced on the appropriate material safety data sheet (the list may be compiled for the workplace as a whole or for individual work areas); and,

• The methods the employer will use to inform employees of the hazards of non-routine tasks (for example, the cleaning of reactor vessels), and the hazards associated with chemicals contained in unlabeled pipes in their work areas.

• NOTE: The written program is your policy statement for how the program will be implemented.

(e) "Written hazard communication program." (continued)

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Hazard Communication.

• "Multi-employer workplaces." – The methods the

employer will use to provide the other employer(s) information on Haz Com, of any precautionary measures that need to be taken, to inform the other employer(s) of the labeling system.

– The employer may rely on an existing hazard communication program

(e) "Written hazard communication program." (continued)

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Hazard Communication. • (e)(4) The employer shall

make the written hazard communication program available, upon request

• (e)(5) Where employees must travel between workplaces during a workshift, i.e., their work is carried out at more than one geographical location, the written hazard communication program may be kept at the primary workplace facility.

OSHA

Providing MSDS’s

• If you have workers that travel between sites and use chemicals at those site, the employee should have an MSDS in his vehicle to provide to those other employers where he is bringing the chemical to perform work.

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Hazard Communication.

• (f) "Labels and other forms of warning." The chemical manufacturer, importer, or distributor shall ensure that each container of hazardous chemicals leaving the workplace is labeled, tagged or marked with the following information:– Identity of the hazardous chemical(s);– Appropriate hazard warnings; and– Name and address of the chemical

manufacturer, importer, or other responsible party.

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Hazard Communication. • (f)(5) Ensure that each container

of hazardous chemicals in the workplace is labeled, tagged or marked with the following information:– Identity of the hazardous

chemical(s)– contained therein; and,

Appropriate hazard warnings, or alternatively, words, pictures symbols, or combination thereof,

Unlabeled Containers

Labeling Systems

• You can use a labeling system, but you must train workers on the system. It is not required to use a labeling system.

Other Items that Must Have Labels

• Equipment or machinery that contains a chemical (like tanks) must be labeled to indicate the name and hazard of the chemical contained.

• Fuel tanks for internal combustion engines do not have to have labels.

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Hazard Communication.

• (g) "Material safety data sheets." Chemical manufacturers and importers shall obtain or develop a material safety data sheet for each hazardous chemical they produce or import. Employers shall have a material safety data sheet in the workplace for each hazardous chemical which they use.

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Hazard Communication.

• (h) "Employee information and training." – Employers shall provide employees with

effective information and training on hazardous chemicals in their work area at the time of their initial assignment, and whenever a new physical or health hazard the employees have not previously been trained about is introduced into their work area.

What Are We Looking For in Training?

• Employees need to know how to get and use the information they need to avoid chemical exposure.

• They should know: Where is the MSDS book?

• What are the hazards of the chemical they are using?

• How do they know what PPE to wear with a particular chemical?

• If the employee can not answer these questions, then OSHA would argue training was not EFFECTIVE

• If workers do not speak and read English, training must be the language they understand, and someone who is bilingual must be available to translate MSDS’s if they have questions.

Permit Required Confined Space

• A Confined Space is:• Big enough to enter• Has limited means of

access/egress• Not designed for

continuous occupancy

Confined Space

• A permit space is one that is a confined space plus has a safety hazard (physical, atmospheric, or mechanical)

Confined Space

• Typical confined spaces are AHU’s, crawl spaces, tanks.

• Spaces must be evaluated for the potential to be permit required confined spaces

Confined Space

• Written program

• Designated entrants

• Air monitoring prior to entry

• Entry permit

• Rescue and retrieval

Personal Protective Equipment (PPE)

• Evaluate the workplace, specify PPE for each job task.

• Train the workers on when PPE is required, and how to don and use PPE

• Workers must sign off they were trained.

Bloodborne Pathogens

SCOPE

• Applies to all occupational exposure to blood or other potentially infectious materials.

Exposure Control

• Written exposure control plan to include the exposure determination, schedule and methods of implementation of paragraphs (d) to (h), procedure for the evaluation of circumstances of exposure incidents.

Exposure Control

• Copy of written plan accessible to employees.

• Updated at least annually.

• Employer to determine who has exposure and list job classifications and tasks and procedures that involve occupational exposure.

Exposure Determination

• Exposure determination to be made without regard to the use of personal protective equipment.

Housekeeping – What the Host Employer is Supposed to Do

• An appropriate written schedule for cleaning and decontamination is required.

• All equipment and environmental/working surfaces shall be cleaned after contact with blood/OPIM and at the end of the shift.

Regulated & Non-Regulated Waste

• Regulated waste shall be disposed of in accordance with applicable state and county regulations.

• Non-regulated waste can be disposed of in regular trash, however, it will contain biohazardous materials. Wear gloves when disposing of the trash in medical offices.

Hepatitis B Vaccination

• All employees with occupational exposure shall be offered the Hep B series at no cost within 10 days of employment.

• Post exposure evaluation and follow up shall be offered to employees occupationally exposed to blood/OPIM.

Hep B Vaccination

• Employees can accept or decline the Hep B vaccination series, if they decline, they must sign the declination in Appendix A.

• The employer shall not make participation in a prescreening program a prerequisite for receiving the Hep B series.

Post Exposure Evaluation

• A post exposure evaluation and follow up must be immediately available to the exposed employee.

• If the source individual can be identified, the source individual’s blood shall be tested if consent can be obtained and the results released to the exposed employee.

Post Exposure Evaluation

• The employee’s blood shall be collected and tested after consent is obtained.

• Post exposure prophylaxis, counseling and an evaluation of reported illness shall be made available to the exposed employee.

• Documentation of the routes of exposure, and circumstances surrounding the exposure incident, as well as the source individual’s

Post Exposure Evaluation

• and medical records relevant to the employee’s treatment shall be provided to the health care professional.

• The health care professional shall provide the employer with a written opinion, stating if the employee has received the Hep B vaccination.

Communication of Hazards

• Warning labels shall be affixed to regulated waste, refrigerators/freezers containing blood/OPIM, and other containers.

• Labels shall be orange, with the biohazard symbol.

• Red bags may be used instead of labels.

Training

• Employees shall be trained upon employment, and annually thereafter.

• Training to cover the regulation, epidemiology and symptoms, exposure control plan, hazard recognition, PPE, Hep B vaccine, post exposure and follow up procedures, labeling, with an opportunity to ask questions.

Training

• The person conducting the training shall be knowledgeable in the subject matter.

• Training must be certified.

Respirators

• If respirators are given to workers-

• They must be provided with NIOSH approved equipment

• Worker must fill out the medical questionnaire which is reviewed by a physician

• Workers must be trained

Questions?