SLIDE 1 Safety and Health Program Management for Safety and Health Program Management for Sheltered Workshops
Missouri Department of Labor and Industrial Relations Daniel Stark, CIH – Program Manager d i l t k@l b daniel.stark@labor.mo.gov 573-751-3403
SLIDE 2 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?"
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Missouri On-site Safety and Health Consultation Program
SLIDE 4 Background
The need for OSHA
The need for OSHA
Consultation Section 21(d)(2) of OSHAct
Section 21(d)(2) of OSHAct 29 CFR 1908 - Consultation
Agreements Agreements
90%/10% funding
SLIDE 5 Consultation Program g
OSHA “mock” inspection OSHA mock inspection No fines, penalties, or citations
p
No cost
SLIDE 6 Consultation Program (continued)
Completely Confidential! Serious hazards/Imminent danger No referral since program’s inception No referral since program s inception
SLIDE 7 Consultation Program - Visit
Opening Conference Analysis of Safety and
Health Programs g
Walk through Interim Protections Closing Conference
SLIDE 8 Consultation Program – Visit (continued) g ( )
Written Report
p
Hazard Corrections Follow-up (optional) Close Case
SLIDE 9 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 formal
Fatalities/catastrophes, formal employee complaints, and imminent dangers still fair game
Pre-SHARP
SLIDE 10
Safety and Health M t S t (SHMS) Management System (SHMS)
SLIDE 11 Safety and Health Management y g System Elements
1.
Management Leadership and Employee Involvement
2.
Workplace Analysis H d P ti d C t l
3.
Hazard Prevention and Control
4
Safety and Health Training
4.
Safety and Health Training
5.
Program Evaluation/Improvement (I2P2 Addition)
SLIDE 12 Element #1 - Management Leadership and Employee Leadership and Employee Involvement
Top management commitment essential! Policy statement Goals and objectives Management example
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Good management example??? Good management example???
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Management Leadership and E l I l t ( ti d) Employee Involvement (continued)
Assign safety and health responsibilities Provide authority and resources Accountability
SLIDE 15 Management Leadership and E l I l t Employee Involvement
Safety and health
Safety and health
inspections
Safety suggestions
System review
SLIDE 16 Element #2 - Worksite Analysis Element #2 Worksite Analysis
Baseline and periodic Baseline and periodic
safety and health surveys
Hazard reporting
system system
Analyze new
y processes, buildings, materials, equip.
SLIDE 17 Worksite Analysis Worksite Analysis
Job safety and health
y analysis
Expert hazard Expert hazard
analysis
Accident & incident
investigation, near misses
Trend analysis
SLIDE 18 Job Hazard Analysis (JHA’s) Job Hazard Analysis (JHA s)
Three Simple Steps:
- 1. Break the task down in steps
- 2. Identify the hazards in each step
- 3. Identify the control measures in each step
- Ex. Employees who handle parts are
experiencing cuts.
SLIDE 19 JHA - Remove Burr From Cast Part
Job Step
1 Reach into
Hazard
1 Sharp b rrs on
Control
1. Reach into metal box to right of machine grasp
part could cause laceration
hand tool (clamp) to pick- t machine, grasp 15 pound casting, and carry to wheel. laceration. up part. carry to wheel. 2. Push casting against wheel
could get in eye 2. Use safety glasses in metal grinding to grind off burr. 3. Place finished i i b eye. 3. Reaching,
- perations.
- 3. Body mechanics
casting in box to left of machine. g, twisting, lifting heavy part = back strain. y training; adjustable work stations.
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Element #3 - Hazard Prevention d C t l and Control
Controls – Source, Path, Receiver Engineering, Administrative, PPE controls Safety and health rules and work practices OSHA mandated programs
SLIDE 22
Source Receiver Path
SLIDE 23 Hazard Prevention and Control Hazard Prevention and Control
Hazard tracking Hazard tracking Preventive
maintenance
Emergency drills
Medical program
Medical program
SLIDE 24 Element #4 - Safety and Health Training
N Hi E l
- New-Hire Employees
- Existing Employees
- Periodic Training Needs
- DOCUMENT!
- Tailor training for:
Employees Supervisors Supervisors Managers
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Why good detailed training Why good detailed training is important…..
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OSHA C li OSHA Compliance
SLIDE 27 OSHA Regulations OSHA Regulations
There are three primary OSHA regulations with which you must comply: you must comply:
- 29 CFR 1904—OSHA’s Recordkeeping
p g Standards
- 29 CFR 1910—OSHA’s General Industry
Standards Standards
- 29 CFR 1926—OSHA’s Construction Industry
Standards
SLIDE 28 Top 10 Sheltered Workshop Hazards f d b MO O it C lt ti found by MO On-site Consultation
1
1910 305 Electrical
1.
1910.305 Electrical
2.
1910.305 Electrical
3
1910 120 0 Hazard Communication
3.
1910.120 0 Hazard Communication
4.
1910.212 Machine Guarding
5.
1910.304 Electrical (Grounding) ( g)
6.
1910.178 Forklifts
7.
1910.334 Electrical
8.
1910.157 Fire Extinguishers
9.
1910.132 PPE 1910 147 L k t/T t
- 10. 1910.147 Lockout/Tagout
SLIDE 29 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 t Incident Report
SLIDE 30 Medical Treatment Medical Treatment
What is medical
What is medical treatment? It d t i l d
It does not include:
solely for observation y
procedures procedures
SLIDE 31 Cases that are not recordable - Fi t Aid First Aid
- Using nonprescription medication
at nonprescription strength p p g
Cl i fl hi ki
- Cleaning, flushing, or soaking
surface wounds
- Wound coverings, butterfly
b d St i St i bandages, Steri-Strips
- Hot or cold therapy
- Non-rigid means of support
- Temporary immobilization device
used to transport accident victims used to transport accident victims
SLIDE 32 Cases that are not recordable - First Aid Aid
Drilling of fingernail or
toenail draining fluid from
Finger guards
M toenail, draining fluid from blister
Eye patches Removing foreign bodies Massages Drinking fluids for relief of
heat stress
Removing foreign bodies
from eye using irrigation or cotton swab
Removing splinters or
Removing splinters or foreign material from areas
irrigation, tweezers, cotton b th i l swabs or other simple means
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OSHA Sit S ifi P OSHA Site-Specific Programs
SLIDE 37 OSHA Poster
Must be displayed
p y where workers can see it
Explains worker and
employer rights employer rights
Downloadable from
OSHA’s website
SLIDE 38 Emergency Action Plan (29 CFR 1910.38)
STEP #1 Wh t th “ bl f bl ” i STEP #1--What are the “reasonably foreseeable” emergencies that my company is exposed to? STEP #2 What do I want my STEP #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 is Day #1 (new-hire) information.
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SLIDE 39 Six Elements of Emergency Action Plan Six Elements of Emergency Action Plan
1.
Procedures for reporting a fire or
- ther emergency
- ther emergency
2.
Procedures for emergency evacuation (type of evacuation ( yp and exit route assignments)
3.
Critical facility operations before evacuation evacuation
4.
Accounting for employees
5
Procedures for rescue or medical
5.
Procedures for rescue or medical duties
6.
Company POC for additional
39
information
SLIDE 40 Emergency Action Planning Emergency Action Planning
Alarm System
- Must be able to hear it above
ambient noise
- Distinctive/recognizable
- Maintained and Tested
Supervised = Annually Non-Supervised = Every 2 Months
T i i
E l
Training - Every employee
must know their role!
Re-Training
Re Training
- New Plan/New Employee
- Revised Plan
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SLIDE 41 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 p hazardous materials
Potential ignition sources
g and their control
Type of fire protection
yp p equipment necessary to control each hazard
SLIDE 42 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 t
7.
POCs for equipment maintenance and fuel hazards
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SLIDE 43 Personal Protective Equipment (29 CFR 1910 132) (29 CFR 1910.132)
- 1. Hazard Assessment
- 2. Written Certification
- 3. Employee Training
) Wh PPE i a) When PPE is necessary b) What PPE is necessary c) How to properly don doff adjust and wear PPE c) How to properly don, doff, adjust and wear PPE d) Limitations of PPE e) Proper care, maintenance, useful life and di l disposal
SLIDE 44 Hazard Communication (29 CFR 1910.1200)
1
Inventory/list of hazardous
1.
Inventory/list of hazardous materials
2.
SDS for each hazardous material
3.
SDS available on all shifts Every private sector employer, regardless of size,
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must comply with HAZCOM!
SLIDE 45 Hazard Communication (continued) Hazard Communication (continued)
4.
Labeling - primary and secondary containers
5.
Independent contractors
6.
Non-routine tasks
7.
Employee Training
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SLIDE 46 Major revisions to the Hazard Communication Standard Communication Standard
1.
Hazard classification: Provides specific criteria for
classification of health and physical hazards, as well as p y classification of mixtures.
2.
Labels: Chemical manufacturers and importers will be
required to provide a label that includes a harmonized signal required 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 requires
4.
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.
SLIDE 47 GHS Pictograms
Explosive Flammable Oxidizer Compressed Gas
!
Acute T
Corrosive Chronic Health Irritant y Hazard
SLIDE 48 Dates To Remember
Employers 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 format
Minimal training on new SDS format
Employers by June 1, 2015:
- Continue to maintain the updated SDSs
SLIDE 49 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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SLIDE 50 Lockout/Tagout Program (29 CFR 1910 147) (29 CFR 1910.147)
Written Energy Control Program
1.
Locks or Tags acceptable
a) Durable b) St d di d b) Standardized c) Substantial
2.
Written start-up/shut-down procedures for:
a) Hard-wired machines b) Two or more sources of energy
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SLIDE 51 Lockout/Tagout Program (29 CFR 1910.147)
3.
Periodic Inspections of Lockout/Tagout Procedures
E l t tif ( hi
- Employer must certify (machine,
date, employee observed, inspector name)
4.
Authorized/Affected Employee T i i Training
knowledge and skills knowledge and skills
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SLIDE 52 Bloodborne Pathogen Program (29 CFR 1910.1030)
- Applies if employees have
exposure to blood or other exposure to blood or other infectious materials
- Exposure Control Plan
- Universal Precautions
- Hepatitis B Vaccinations
Hepatitis B Vaccinations
- Communication of Hazards to
Employees
NOTE: “Good Samaritan” acts are not considered
SLIDE 53 Respiratory Protection Program (29 CFR 1910 134) (29 CFR 1910.134)
Voluntary Use
Voluntary Use Procedures for Procedures for
selection
Medical Evaluations
Fi T i
Fit Testing
SLIDE 54 Respiratory Protection P ( ti d) Program (continued)
Cleaning, disinfecting
and storage
Training Evaluation of
program program effectiveness
SLIDE 55 Hearing Conservation Program (29 CFR 1910 95) (29 CFR 1910.95)
Required above 85
dBA for 8 hours
Monitoring Program Audiometric testing Training
SLIDE 56 Other OSHA Programs Other OSHA Programs
Depending upon your process, you might also need:
Forklift Operators Training Program
C fi d S P
Confined Space Program Fall Protection Program Fall Protection Program Mechanical Power Press Program
g
Electrical Worker Training
SLIDE 57
Self-Inspection Programs
SLIDE 58 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 l
Consistent removal of hazards from the workplace Increased productivity Increased productivity Better employee morale
p y
OSHA Compliance
SLIDE 59
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 safety the four elements of safety and health program management?
SLIDE 60
Keep in mind……
Inspections are not the Safety Manager’s
Keep in mind……
responsibility
Everybody is an inspector Safety committees vs. no safety committees
SLIDE 61 Self-Inspection Checklist
(OSHA’s Handbook for Small Business pub. #2209) ( p )
Covers the following:
Posting and Recordkeeping Safety and Health Program Medical Services and First Aid Fire Protection
- Welding, Cutting and Brazing
- Compressed air
- Compressed Gas Cylinders
- Hoists
e
PPE General Work Environment Walkways Floor and Wall Openings
- s s
- Forklifts
- Spraying Operations
- Confined Spaces
- Environmental Controls
Floor and Wall Openings Stairs and Stairways Elevated Surfaces Exiting or Egress
Ladders
- Environmental Controls
- Flammable and
Combustibles
- Chemical Exposures
- Hazcom
Ladders Tools Machine Guarding LOTO
Hazcom
- Electrical
- Noise
- Material Handling
- Ventilation
- Ventilation
SLIDE 62 How about some pictures of How about some pictures of hazards?
NOTE: This presentation does not include all hazards
possible in a facility.
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SLIDE 108 Good tools for self-inspections
AC Sensor
Good tools for self inspections
Tic Tracer Outlet Tester Gotcha stick
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SLIDE 111 Helpful Web Sites
http://www.labor.mo.gov/ls/safetyconsultation http://www osha gov http://www.osha.gov
SLIDE 112
Questions? Questions?