module14 osha safety compliance

8/4/2019 Module14 OSHA Safety Compliance

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The SOCMA Chemical Process Operator Training Course

OSHA Safety Compliance 14-1

Revised: March, 2009

SECTION 14: OSHA SAFETY COMPLIANCE

Of the many different types of workplace environments, the chemical manufacturing facility can be one ofthe more dangerous. There are all the hazards normally associated with any manufacturing environment,such as hazards from machinery, hot surfaces, slippery surfaces, welding and noise, plus the hazardsassociated with the handling of hazardous chemicals. The added risks to the employees become addedrisks to the employer as well, since injured workers can translate into lost production, potential problemswith OSHA, costly medical and insurance expenses and decreased morale. Complying with OSHASafety Regulations is crucial to the successful operation of a chemical manufacturing facility.

These safety regulations cover nearly every aspect of the workplace. OSHA safety regulations forgeneral industry are found in 29 CFR 1910, which contains nearly 700 pages of regulatory text pertainingto general workplace safety and over 350 pages of regulations concerning hazardous chemicals.Dedicated and coordinated efforts are required to achieve safety compliance in any workplaceenvironment, but especially in a chemical manufacturing facility. OSHA safety compliance cannot be fullyachieved by a "Safety Manager" or by management alone. It demands the informed and willing

cooperation of every employee.

Achieving health and safety compliance is not a one time action but an ongoing process which requiresattention and continuous effort. The compliance process can be broken down into 7 steps:

Determining the applicable regulations

Identifying the requirements of the applicable regulations

Evaluating the operations in light of regulatory requirements

Developing a well thought out, prioritized action plan

Creating written programs, procedures and plans.

Taking predetermined and definite actions

Monitoring for compliance

Determining the applicable regulations - This is usually done by someone knowledgeable of OSHAregulations to ensure that all aspects are considered. It may require an informal interview and a walk-through inspection of the facility or a formalized audit.

Identifying the specific requirements - The requirements of each regulation should be listed separately atfirst. Later, common elements will be identified to avoid unnecessary efforts. This may also require theassistance of someone who is knowledgeable about OSHA regulations.

Evaluating facility operations - The compliance status of the facility must be determined by regulation. Itis important to be thorough, critical and honest in the evaluation so that a true picture of the facility

compliance status is obtained. Obtain input from all areas of the facility. As part of the evaluation, besure to also consider situations that have the potential to result in non-compliance. This may save youheadaches later.

Developing a prioritized action plan - Actions must be prioritized and scheduled within reasonable timelimits in order to effectively use available resources. Situations where employees are put at unreasonablerisk would require immediate action. Developing procedures or training employees are examples ofactions which can be scheduled at later times. Determine where the greatest risks to employee safetyare and also where there is the greatest liability. Some actions which require minimal effort and expense(purchase of safety equipment, installing guard rails, putting up signs) can be done immediately. Other


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14-2 OSHA Safety Compliance


actions such as training and developing procedures may require months to accomplish. The action planshould take these considerations into account. Responsibilities must be defined and realistic goalsshould be set.

Creation of written programs and procedures - These describe how compliance will be achieved andmaintained, and by whom. They will serve as a reference point and will provide for the communication ofthe requirements of the facilitys safety program in detail. The written procedures will also form the basisfor compliance with OSHAs record keeping and documentation requirements.

Taking predetermined and definite actions - This could involve training, addition or revision of equipment,new systems and/or documentation of activities. Careful follow-through and diligence are necessary inorder to achieve full compliance. Be sure that each item on the action list is completed and approvedbefore checking it off the list. It is vital that what is written down on the action plan be carried outaccurately and completely.

Monitoring for compliance - Self-audits and inspections should be conducted to assess progress anddetermine if further actions are needed. Getting into compliance is only the first step; staying incompliance is the ultimate goal. This will require regular and consistent attention.

Completing this 7 step process can take anywhere from weeks to several years depending on the size ofthe facility, the number of employees, the number of and complexity of the applicable regulations and theexisting compliance status of the facility. The most important thing is to get the process started.Eventually, this process must become part of normal operations, just like any other part of the business.When this is the case, things will be well on the way toward the successful operation of the chemicalprocessing facility.

Although there are many regulations affecting the chemical process industries, there are a few keyregulations which are of primary concern. It is important to have at least a basic understanding of theirrequirements. Once these requirements are understood, the operator can be better prepared to fulfillhis/her role in the companys OSHA compliance programs. The key OSHA regulations which apply tochemical plant process operators can be categorized by breaking these regulations into three groups:

CHEMICAL - those regulations that relate to the handling, storage and use of hazardouschemicals.

PLANT PROCESS - those regulations which are related to working in or around plant processes.

OPERATOR - those regulations that are not directly related to the plant processes and which arerelated to the safety of and the responsibilities of the operator.

Listed below are some of the applicable OSHA regulations identified by these three categories:


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Table 14-1 Applicable OSHA Regulations by Category

Chemical Plant Process Operator

Subpart Z Hazardous/Toxic

Materials

Confined Space Entry Emergency Action Plans

Hazard Communication Electrical Safety/Lockout-Tagout Fire Extinguisher Safety

Personal Protective Equipment Forklift/Materials Handling Safety Committees

Respiratory Protective Equipment Machine Guarding Hearing Conservation

The Chemical Hygiene Plan Hotwork/Cutting and Brazing Hazwoper

Fall Protection Ergonomics

P R O C E S S S A F E T Y M A N A G E M E N T

The Process Safety Management regulation cuts across all the categories and is in itself anextensive regulation. In this section we will concentrate on the other OSHA regulations, sinceprocess safety management is covered in another section of this course.

14.1 CHEMICAL REGULATIONS

14.1.1 Subpart Z - Toxic and Hazardous Substances

29 CFR 1910 Subpart Z (1910.1000 to End) Toxic and Hazardous Substances, addressesemployee exposure to listed hazardous air contaminants. 29 CFR 1910.1000 Tables Z-1-A, Z-2,and Z-3 identify these air contaminants and establish their Permissible Exposure Limits (PEL).Permissible exposure limits are expressed as a Time Weighted Average (TWA), Short TermExposure Limit (STEL) and/or a Ceiling or Excursion Limit (Ceiling).

A TWA is the employee's average airborne exposure in any 8-hour work shift of a 40-hour work

week which is not to be exceeded. A STEL is the employee's 15-minute time weighted averageexposure which shall not be exceeded at any time during a work day unless another time limit isspecified, in which case the TWA over that time period shall not be exceeded during the workingday. A Ceiling Limit is the employee's exposure which shall not be exceeded during any part ofthe work day.


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Table 14-2 Subpart Z Regulated Chemicals

Chemical nameRequirement

Section

Air Contaminants (29 CFR 1910.1000)Asbestos (29 CFR 1910.1001)

4-Nitrobiphenyl (29 CFR 1910.1003)

alpha-Naphthylamine (29 CFR 1910.1004)

Methyl Chloromethyl Ether (29 CFR 1910.1006)

3,3'-Dichlorobenzidine (29 CFR 1910.1007)

bis-Chloromethyl Ether (29 CFR 1910.1008)

beta-Naphthylamine (29 CFR 1910.1009)

Benzidine (29 CFR 1910.1010)

4-Aminodiphenyl (29 CFR 1910.1011)

Ethyleneimine (29 CFR 1910.1012)beta-Propiolactone (29 CFR 1910.1013)

2-Acetylaminofluorene (29 CFR 1910.1014)

4-Dimethylaminoazobenzene (29 CFR 1910.1015)

N-Nitrosodimethylamine (29 CFR 1910.1016)

Vinyl Chloride (29 CFR 1910.1017)

Inorganic Arsenic (29 CFR 1910.1018)

Lead (29 CFR 1910.1025)

Cadmium (29 CFR 1910.1027)

Benzene (29 CFR 1910.1028)

Coke Oven Emissions (29 CFR 1910.1029)Blood Borne Pathogens (29 CFR 1910.1030)

Cotton Dust (29 CFR 1910.1043)

DBCP (29 CFR 1910.1044)

Acrylonitrile (29 CFR 1910.1045)

Ethylene Oxide (29 CFR 1910.1047)

Formaldehyde (29 CFR 1910.1048)

4,4'-Methylenedianiline (29 CFR 1910.1050)

Methylene Chloride (29 CFR 1910.1052)

Table Z-1-A (1910.1000) lists several hundred air contaminants, from acetaldehyde to zirconium

compounds, and their PELs and STELs. Subpart Z also regulates toxic and hazardoussubstances for which specific regulations apply (1910.1001 to end). To achieve compliance andlimit employee exposure, an employer that uses any of the listed chemical substances mustperform initial air monitoring in the workplace to determine the level of employee exposure. Ifmonitoring indicates employee exposure levels above the established limits, administrative orengineering controls must be determined and implemented. When such controls are not feasible,or are unable to reduce exposure to below the limit, personal protective equipment must be usedto reduce exposure to below the established limit.


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Subpart Z initial monitoring determines if employee exposure is above the action level. Theaction level refers to a level of exposure which initiates certain required activities, includingmedical surveillance and periodic monitoring. The action level is one half the PEL.

Table 14-3 Subpart Z Chemicals with Monitoring Requirements

Chemical name Requirement Section

Asbestos (29 CFR 1910.1001)

Vinyl Chloride (29 CFR 1910.1017)

Inorganic Arsenic (29 CFR 1910.1018)

Lead (29 CFR 1910.1025)

Cadmium (29 CFR 1910.1027)

Benzene (29 CFR 1910.1028)

Coke Oven Emissions (29 CFR 1910.1029)

DBCP (29 CFR 1910.1044)

Cotton Dust (29 CFR 1910.1043)

Acrylonitrile (29 CFR 1910.1045)

Ethylene Oxide (29 CFR 1910.1047)

Formaldehyde (29 CFR 1910.1048)

4,4-Methylenedianiline (29 CFR 1910.1050)

Methylene Chloride (29 CFR 1910.1052)

Initial results will indicate what level of response is necessary. Three basic scenarios may occur.

1) Identified chemical is not detected or is below the action level.

2) Identified chemical is above action level but below PEL.

3) Identified chemical is above PEL.

Those chemicals that are above the action level or PEL may require action steps in the followingareas:

Periodic monitoring. If employee exposures are above the action level, a program fordetermining exposures must be established. The initial level of exposure will determinehow often to repeat the monitoring. For example, if vinyl chloride concentrations exceedthe PEL, monitoring will be repeated monthly, and if vinyl chloride concentrations exceedthe action level, monitoring will be quarterly.

Establishment of regulated areas. A regulated area means any area where airborneconcentrations exceed or can reasonably be expected to exceed, the PEL. Access toregulated areas must be limited to authorized personnel.

Compliance programs. A written program must be established and implemented thatreduces employee exposure to or below the PEL.

Respiratory and personal protection programs. These can include requirements toprovide respirators or other PPE, as well as requirements for respirator fit testing andtraining.

Medical Surveillance. The employer may be required to have regular medicalexaminations including chest x-rays, bloodwork, or other testing to monitor employeehealth.


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Hazard communication and training. Requires a program to keep employees aware ofhazardous materials.

Record keeping. Certain records must be kept for a designated period of time.

Employee notification. Ensures that employees are aware of their rights and

responsibilities.

A complete Subpart Z program must be implemented that integrates components of eachapplicable regulation (determined by the results of the initial monitoring program). Most of thetime this will mean reexamining a program that is already in place, with adjustments being madewhere needed. If on-going monitoring is required, an in-house air monitoring program should bedeveloped. This program must be documented, and all affected employees must be informed ofthe program and its contents.

Table 14-4 Permissible Exposure Limits for Subpart Z Chemicals

Chemical Name TWA Ceiling Action Level

Asbestos (29 CFR 1910.1001) 0.1 f/cc 1 f/cc 0.05 f/cc

Vinyl Chloride (29 CFR 1910.1017) 1 ppm 0.5 ppm

Inorganic Arsenic (29 CFR 1910.1018) 10 ug/m3 5 ug/m3

Lead (29 CFR 1910.1025) 50 ug/m3 30 ug/m3

Cadmium (29 CFR 1910.1027) 5 ug/m3 2.5 ug/m3

Benzene (29 CFR 1910.1028) 1 ppm 0.5 ppm

Coke Oven Emissions (29 CFR1910.1029)

150 ug/m3

Cotton Dust (29 CFR 1910.1043) 200 ug/m3 Varies

DBCP (29 CFR 1910.1044) 1 ppb

Acrylonitrile (29 CFR 1910.1045) 2 ppm 10 ppm 1 ppm

Ethylene Oxide (29 CFR 1910.1047) 1 ppm 5 ppm 0.5 ppm

Formaldehyde (29 CFR 1910.1048) 0.75 ppm 0.5 ppm

4,4'-Methylenedianiline (29 CFR1910.1050)

10 ppb 5 ppb

Methylene Chloride (29 CFR 1910.1052) 25 ppm 12.5 ppm

14.1.2 The Hazard Communication Standard

The hazard communication standard is OSHAs regulation pertaining to an employees "Right-to-

Know" of the chemical related hazards faced in the workplace. This regulation provides thefoundation for all other chemical related safety regulations, and is one of the most important for achemical operator to understand. The hazard communication standard, found in 29 CFR1910.1200, is the most frequently violated OSHA regulation, and is often the mostmisunderstood. The requirements upon the employer are extensive, with one of the greatestchallenges being the effective communication of the nature, extent and characteristics of thehazards of the chemicals in use at their facility.


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Table14-5 lists the most frequently cited violations of the OSHA standards. Three of the top 25violations in 2007 involved the Hazard Communication Standard.

Table 14-5 Top 25 Most Cited Violations of OSHA 1910 -- 2007

Subject Standard Total violations

Hazard communication - Written program 1910.1200(e)(1) 2,272

Machine guarding - Types of guarding 1910.212(a)(1) 1,576

Hazard communication - Employer must providehazard information and training

1910.1200(h)(1) 1,141

Guarding floor openings, platforms, and runways 1910.23(c)(1) 841

Machine guarding - Point of operation guarding 1910.212(a)(3)(ii) 786

First aid - Eye wash/emergency shower facilities not innear proximity to employees

1910.151(c) 757

Lockout/tagout - Written energy control procedures 1910.147(c)(4)(i) 752

Abrasive wheel machinery - Exposure

adjustment/safety guards 1910.215(b)(9) 723

Electric - Wiring methods, components and equipment-Cabinets, boxes/Conductors

1910.305(b)(1) 695

Lockout/tagout - Establish an energy control program 1910.147(c)(1) 681

Hazard communication - MSDS available for eachhazardous chemical

1910.1200(g)(1) 675

Respiratory protection - Provide medical evaluationprior to fit test and respirator use

1910.134(e)(1) 654

Respiratory protection - Establish a written program 1910.134(c)(1) 636

Powered industrial trucks - Operator training 1910.178(l)(1)(i) 632

Electrical-Equipment must be installed according to

instructions

1910.303(b)(2) 601

Lockout/tagout - Annual procedure inspection 1910.147(c)(6)(i ) 526

Mechanical power transmission - Pulley guarding 1910.219(d)(1) 520

Personal protective equipment - Written certification ofhazard assessment

1910.132(d)(2) 508

Electric-Wiring methods, components and equipment -Cabinets, boxes/Covers

1910.305(b)(2) 497

Abrasive wheel machinery - Work rests 1910.215(a)(4) 494

Personal protective equipment - Must conduct a hazardassessment

1910.132(d)(1) 491

Lockout/tagout - Training and communication 1910.147(c)(7)(i ) 491

Eye and face protection - Use of appropriate eye andface protection 1910.133(a)(1) 489

Compressed air - Reduce to less than 30 p.s.i. 1910.242(b) 481

Personal protective equipment - Provide, use, maintainequipment in a sanitary and reliable condition

1910.132(a) 480


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This regulation establishes requirements for employers to:

Evaluate all chemicals present on the site to determine which are hazardous, and toevaluate the nature, extent and characteristics of the hazards in relation to potential risksto employees.

Inform employees about the presence and location of all hazardous chemicals.

Develop a written hazard communication program which includes a list of all thehazardous chemicals and their locations, along with explanations of the steps thecompany will take to comply with the requirements of the standard.

Generate or obtain, and make available MSDS for all hazardous chemicals.

Develop a labeling program which ensures that containers of hazardous chemicals areclearly identified and that proper hazard warnings are displayed.

Train affected employees concerning all the elements of the program. This includestraining employees to understand how to read an MSDS, how to understand hazardwarnings on labels, and all the details of the companys written hazard communication

program. Inform contractors of their requirements under the standard.

This regulation also establishes some employee rights:

The "right-to-know" about the hazardous chemicals an employee is required to work withor around and about related health and safety information.

The right of access to any MSDS for such hazardous chemicals.

The right to see, review and have a copy of the site written hazard communicationprogram.

Communication is the key concept underlying the requirements of this standard. This

communication takes place through Material Safety Data Sheets (MSDS), labels, training andwritten procedures. In order to be sure that employees understand the information contained inMSDS, labels etc., employers must educate the employees about the contents of an MSDS andthe meaning of systems used to communicate hazards, such as the NFPA diamond and theHazardous Materials Identification System (HMIS) labels. Employees must be able to recognizeand locate any hazardous material in their workplace and understand how to protect themselvesfrom the hazards of the material.

Employees shall be informed of the requirements of the regulation, any operations in their workarea where hazardous materials are present and the location and availability of the employers'written hazard communication program. Employees must be trained to recognize and detect thepresence of a release. They must also be trained to know the physical and health hazards of anyhazardous chemicals on the site and the measures taken by the employer to protect employees

from these hazards.

Training must be conducted at the beginning of the employee's assignment and periodicallywhenever there are changes to the program or if new hazardous chemicals are in use. Manyemployers conduct annual refresher training.

Containers of hazardous chemicals in a facility are to be labeled with the hazardous chemicalidentity, and an appropriate hazard warning. Container labels prepared by the chemicalmanufacturer, importer, or distributor should never be removed or defaced. Incoming hazardouschemicals must be checked to verify that the appropriate identification and hazard warnings are


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present and in English. Included in this check will be confirmation that the following information ispresent on the label:

1) Chemical identity;

2) Appropriate hazard warnings, such as HMIS, NFPA or written warnings; and

3) Name and address of the chemical manufacturer.

Portable containers (that is, containers into which hazardous chemicals are transferred fromlabeled containers) are not required to be labeled if the container will only be used by theemployee who transferred the hazardous chemical into it, and the container will be empty by theend of the shift of that employee. Otherwise it is the responsibility of the individual using theportable container to obtain and apply a label that indicates the chemical identity and hazardwarning information. Stationary process units, including storage tanks and reaction vessels,containing hazardous chemicals will be labeled with the identity of the hazardous chemical(s)contained in the process unit, with appropriate hazard warnings.

14.1.2.1 Labeling Systems

There are several different hazardous labeling systems. These labeling systems have been

developed by organizations in order to help standardize the information presented on labels.Three of the most common systems presently in use include the:

1. National Fire Protection Association (NFPA) 704 Standard;

2. American National Standards Institute (ANSI) Standard Z129.1; and

3. National Paints and Coatings Association Hazardous Materials Information System(HMIS).

The NFPA system uses hazard ranking and pictographs within a distinctive three colordiamond to convey health, reactivity and flammability hazard information. The NFPA'shazard ranking and identification system rates hazards by severity on a 0 to 4 scale (4 beingthe most hazardous). Since this system does not include chemical identity information, itcannot be used alone for compliance with the Hazard Communication Standard.

The ANSI standard recommends the use of signal words such as caution, warning anddanger to convey the degree of hazard. Standard language is also used to convey chemicalhazards, precautions for chemical storage and use, and first aid procedures.

The Hazardous Materials Information System is similar to the NFPA system in that the health,flammability and reactivity hazards are rated by severity on a 0 to 4 scale with the same colorscheme. However the HMIS label is rectangular rather than diamond shaped and containsthe identity of the hazardous material as listed on the material safety data sheet. At thebottom of a HMIS label is a pictograph which indicates what personal protective equipmentshould be worn with the hazardous material. This information is very useful for remindingemployees what personal protective equipment is needed to handle a hazardous chemical.

14.1.2.2 Material Safety Data Sheets

The Material Safety Data Sheet (MSDS) is the backbone of chemical safety managementand is the key resource for obtaining health and safety information about hazardouschemicals. Far too often, the MSDS is underutilized or misunderstood.

Material safety data sheets must be obtained for all hazardous chemicals within the facility.MSDS for hazardous chemicals are made available by the manufacturer, distributor orimporter upon initial shipment of each hazardous chemical and with the first shipment after anupdate is made to the information on the MSDS. If possible, MSDS should be obtained prior


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to the initial shipment, enabling the hazards to be assessed, permitting the review of safehandling and disposal procedures, and allowing facility employees to have hazard informationbefore the chemical arrives and is stored or used.

Material safety data sheets must be available to employees in the workplace during theemployee's work shift. Material safety data sheets can have many different formats and maybe kept in any form. Regardless of which format is selected, the required information mustbe provided for each hazardous chemical entering the facility. MSDSs are required to be inEnglish and contain at least the following information:

Manufacturer Information,

Exposure Limits,

Identity Information,

Carcinogenicity,

Physical and Chemical Characteristics,

Precautions for Safe Handling and Use,

Physical Hazards,

Control Measures,

Health Hazards,

Emergency and First Aid Procedures,

Primary Routes of Entry, and

Preparation Date.

14.1.2.3 Contractor Safety

Contractors must be informed of the hazards of any chemicals that they may handle or beoccupationally exposed to during their work at the facility. Procedures must be developed

and followed any time a contractor or subcontractor is hired to work at the facility in an areawhere hazardous chemicals may be used or are present.

Contractors are not to bring onto the grounds of the facility any substance that may beconsidered hazardous without prior consent. Contractors should not dispose of, in anymanner, substances that may be considered hazardous within the facility without priorconsent. The following factors will be considered in the determination to allow the use of anyhazardous substance by contractors at the facility:

Relative hazards of its use,

Disposal of the substances,

The potential for employee exposure, and

Availability of substitutes.

Any equipment used by the contractor in areas where flammable materials are stored orprocessed must be explosion proof. Questions concerning chemicals or equipment that maybe hazardous should be thoroughly investigated. Contractor errors and mistakes havecontributed to a substantial number of serious accidents. It is the responsibility of theemployer to insure that a program is in place to address these contractor issues.


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Contractor and contractor personnel should be provided with appropriate hazard informationand training. Information and training are to include the following:

Potential chemical and physical hazards for the area in which contract operations arebeing conducted;

Location and availability of Material Safety Data Sheets; Detection of the presence of hazardous chemicals;

Facility precautions and safety procedures;

Emergency information concerning evacuation procedures and signals, location ofthe emergency/first aid station, alarms, deluge showers, eyewash stations, and otheremergency equipment;

Hazardous chemical labeling system; and

Directions to and appropriate locations for eating, drinking, smoking, and sanitationfacilities.

Contractor personnel shall sign a Contractor Certification Statement verifying that they have

received and understand the information presented.

14.1.2.4 Visitors or Other Non-employee Personnel

Visitors will be made aware of the potential hazards in areas where they will visit on site.They will also be made aware of policies designed to avoid hazards and protect their healthand safety. The objective of the following procedures is to transmit information to visitors toensure their safety as well as the safety of facility employees.

The following procedures should apply to visitors:

Visitors should not be allowed to proceed anywhere within the facility withoutsupervision. Areas to be excluded will be pointed out.

Visitors must observe safety procedures and warning signs. Depending on the areasto be visited, personal protective equipment will be provided.

Visitors will be briefed on emergency information concerning evacuation procedures,locations, and signals.

Visitors will be made aware of the emergency/first aid equipment, emergency alarms,and other emergency equipment available in the areas to be visited.

Visitors will be briefed on the location and availability of material safety data sheetsand the chemical labeling system used.

Visitors will be informed of appropriate locations for eating, drinking, smoking, andsanitation facilities.

14.1.3 Personal Protective EquipmentOSHAs regulations related to Personal Protective Equipment (PPE) are found in 29 CFR 1910Subpart I (1910.132 to 1910.140). Employers are required to evaluate the workplace todetermine where the use of PPE will be required. This is called the Hazards Assessment, and itforms the foundation of the employers PPE Program. It is important to note that the PPEprogram is only a part of the employers overall health and safety program, and that the correctuse of PPE does not negate the employers responsibility to provide workers with a workplacefree from recognized health and safety hazards. OSHAs real emphasis is on the elimination ofhazards through engineering or administrative controls. The use of PPE is appropriate only after


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such controls have been investigated, and the employer is in the process of implementing thesecontrols, or the implementation of such controls is not feasible.

Once PPE has been selected and identified for use for a particular job or work area based uponthe information gathered in the hazards assessment, employers must provide this PPE toemployees free of charge in most cases. Employees are then required to wear and use the PPEproperly.

Employers must train employees concerning the proper use, care, maintenance, inspection anddisposal of each type of PPE used. Employees must know when PPE is necessary and whatPPE is necessary. Employees must also be informed of the limitations of the particular PPE to beused and be instructed in how to obtain a proper fit. Additionally, employees should learn how torecognize when PPE needs to be replaced and how to properly store and clean different types ofPPE.

An employer must certify in writing that the workplace has been evaluated, and also certify thatemployees have been trained as mentioned above. An employee who demonstrates that they donot know how to properly utilize their assigned PPE will be selected for retraining, and then mustagain be certified by the employer. The employer is also required to document the work areas

where PPE is required and must identify, in writing, the particular PPE to be used by employeesin each work area. This can be in the form of a chart, table, or standard operating procedure.

The goal of OSHA regulations is worker protection. PPE regulations identify requirements forassessing the workplace for hazards, selecting appropriate PPE, and training in the proper useand care of PPE.

14.1.3.1 Types of Personal Protective Equipment

The main function of Personal Protective Equipment (PPE) is to form a barrier between thehazard and the worker. The correct use of PPE does not eliminate the hazard, it onlyprevents the hazard from reaching the worker. The types of PPE are based upon the typesof hazards which are faced in the workplace. There are hazards from heat, light, sound,abrasive or sharp surfaces, electricity, chemicals, pinching, crushing, puncturing and flying

objects. Based on the types of hazards, employees may use one or a combination of thefollowing types of PPE:

Table 14-6 Types of Personal Protection Equipment (PPE)

GlovesEye

protectionHead

protectionFoot protection

Hearingprotection

Other

Leather gloves Safety glasses Class A. B. or Chardhats

Steel toed shoes Ear plugs Aprons

Rubber gloves Safety goggles Type I or Type IIbump caps

Steel toed boots Ear muffs Chaps

Vinyl or PVC

gloves

Splash shields Rubber boots Leggings

Latex gloves Shoes withmetatarsal guards

Rubbermatting

Chain-knitgloves

Torsoprotection

Asbestos or heatresistant gloves


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There are many variations in design, materials of construction, size and application. During theselection process, carefully read the manufacturers recommendations and consult with otherusers to determine the right PPE for any particular situation.

14.1.4 Respiratory Protective Equipment

Because of the nature of respiratory hazards and the potential for occupational diseases frominhalation of dusts, fogs, fumes, mists, gases, vapors and sprays, respiratory protectiveequipment (RPE) can be the most important type of PPE. Persons required to utilize RPE oftendo so because of the presence of toxic and potentially lethal gases or vapors in the workplace air.Failure to properly select, use and maintain RPE can have serious implications.

The OSHA standard for respiratory protective equipment is found in 29 CFR 1910.134.Employers have to develop a written RPE program which identifies what they will do to complywith the requirements found in this section. As with the general requirements for PPE, a hazardsassessment must be conducted to evaluate the workplace for actual or potential respiratoryhazards. After the assessment, appropriate respirators must be selected for the nature, extentand characteristics of the hazard(s).

14.1.4.1 Selection of RespiratorsThe selection of RPE involves the following basic steps:

Identification of the hazard;

Evaluation of the hazard; and

Selection of appropriate RPE based on the first two considerations.

The following are types of respirators that can be selected for use:

A half face negative pressure air purifying respirator with appropriate cartridges;

A full face negative pressure air purifying respirator with appropriate cartridges;

A positive pressure powered air purifying respirator with appropriate cartridges;

An atmosphere supplying respirator. This type of respirator may be either an air linerespirator with positive pressure, or a self contained breathing apparatus (SCBA),with the pressure demand regulator set for positive pressure.

All respirators selected must be tested and certified by the National Institute for OccupationalSafety and Health (NIOSH) as being effective against the contaminant for which it isdesigned. Respirators are certified as specific units by the manufacturer. Interchangingparts from different respirator manufacturers is strictly prohibited.

Note that air purifying respirator cartridges must be selected on the basis of the chemicalhazard which is, or may be, present. An air purifying respirator cannot be worn when workingwith materials which cannot be perceived by odor or which may react with the cartridgematerial. If a chemical odor is perceived, work must be stopped immediately. In a cleanarea, the respirator cartridges must be discarded and replaced with a new set.

14.1.4.1.1 Half Face Negative Pressure RespiratorThe half face negative pressure respirator is an air purifying device that covers the nose,mouth, and chin. It is equipped to handle various types of cartridges that capture gases,vapors, dust particles, mists, and fumes. Since it provides no eye protection, safetyglasses or goggles are required when wearing this type of respirator. The half facerespirator may be worn when exposure levels are expected to be minimal.


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CAUTION: The half face respirator does not protect against oxygen deficiency,temperature extremes, or hazards not listed on the cartridge label.

14.1.4.1.2 Full Face Negative Pressure RespiratorThe full face negative pressure respirator is an air purifying device that covers the nose,mouth, and chin, with the addition of a face piece to protect the eyes and face. It shouldfit snugly around the face and eyes. A full face respirator should be worn when chemicalhazards are present to the eyes. If the hazard is present in the form of splashing liquid,additional personal protective equipment may be required.

CAUTION: The full face respirator does not protect against oxygen deficiency,temperature extremes, or hazards not listed on the cartridge label.

14.1.4.1.3 Positive Pressure Powered Air Purifying RespiratorsThe Powered Air Purifying Respirator (PAPR) is a modified air purifying respirator. Anelectric motor attached to the wearers belt pulls air through 2 air purifying cartridges,blowing this purified air into a headpiece which fits loosely around the face and chin. Apositive air pressure is maintained to keep contaminants out. This type of respirator isnot designed for use around particularly toxic contaminants or with heavy exertion by the

wearer.

14.1.4.1.4 Atmosphere Supplying RespiratorsAtmosphere supplying respirators, either air line or self contained, must be used inenvironments where the contaminants are unknown and/or the rate of evolution is rapid.This respirator must be used if the possibility of an oxygen deficient or "ImmediatelyDangerous to Life or Health" (IDLH) atmosphere exists.

Air line respirators supply clean air through a hose attached to an ambient air breathingpump or compressor, or from a tank of compressed air. The SCBA allows greatermobility since you carry clean air in a tank on your back. The clean air is supplied fromthe tank through a regulator to the mask.

14.1.4.2 Respirator UseA tight respirator to face seal is required when conditions mandate respirator usage. Underno circumstances must an employee be allowed to work if facial hair prevents a tight sealwhen using RPE. This means no beards. Any mustache and all hair must be kept trimmedso as not to interfere with the sealing of RPE. If a respirator does not seal, it is useless.

The respirator to face seal is the most critical factor in the proper use of any negativepressure respirator. There are specific protocols to be followed when fit testing a respiratorfor use. Properly trained individuals should be consulted to ensure that proper fit testing isconducted.

14.1.4.3 Corrective eye lenses

If the temple bars of eyeglasses extend through the sealing edge of the respirator, a properseal cannot be made. Glasses with either short or no temple bars may be taped to thewearers head. A specially designed pair of prescription safety glasses which fit inside therespirator can be obtained for those employees needing them, provided that the individualpresents a current eye prescription.


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Respirator TrainingEvery new employee that will be working in a position which may require them to wear RPEat any time during their employment should be given formal instructions in the use and careof respirators. The training must include at a minimum the following:

How and when to wear a respirator;

Proper fit test procedures;

Respiratory hazards;

Proper cleaning, maintenance, and storage;

Inspection procedures; and

Donning and doffing procedures.

Each employee will also receive a pulmonary function test in order to certify his ability to wearRPE. This testing will be done during their physical, which is done prior to the first day ofemployment.

14.1.4.4 Cleaning and StorageRespirators should be cleaned after each use regardless of the duration; however, it issuggested that they be cleaned and disinfected monthly. RPE should be inspected duringcleaning. Before leaving a work area, gross contamination shall be removed from therespirator, and used cartridges should be discarded. Respirator cleaning may involvedisassembly of the respirator and washing in warm water and mild detergent. Once clean,the respirator should be thoroughly rinsed and allowed to air dry.

Respirators must be protected from dust, sunlight, temperature extremes, excessivemoisture, and damaging chemicals. Respirators should be kept in carrying cases or cartonsand stored in a cool dry place. Plastic ziplock bags are ideal for protecting the respiratoragainst contamination. Respirators should be packed and stored so that the facepiece andexhalation valve will rest in a normal position and function will not be impaired by the

elastomer setting in an abnormal position. Respirators placed at stations and work areas foremergency use should be quickly accessible at all times.

14.1.4.5 Inspections

Respiratory protective equipment must be regularly inspected. Respirators used routinelyshould be inspected before each use and after each cleaning. Non-routine respirators keptfor emergency use or backup shall be inspected after each use and at least monthly. SCBAsshould be inspected monthly to ensure air and oxygen cylinders are fully charged, and thatthe regulator and warning devices are working properly.

The respirator inspection should consist of checking the following items:

Face shield for cracks and wear;

Facepiece for warping, pliability, cracks, and wear;

Valves, gaskets, and filter elements for pliability, wear, warping, and proper seating;and

Headbands for elasticity and wear.

Defects must be reported, and action should be taken to ensure that each employee whoneeds a respirator has one that is in good working condition. Defective or broken parts


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should be replaced by qualified personnel, or the entire respirator must be replaced ifnecessary.

14.1.4.6 Medical Evaluation

When conditions require the use of respirators, employees are required to be evaluated by a

physician to determine if they are physically able to perform and use the equipment. As apart of this examination, a pulmonary function test should be conducted to measure theirforced vital capacity and forced expiratory volume to demonstrate their lung capacity andidentify any obstructions of restrictive airways. A written conformation from the examiningphysician certifying their ability to work while using RPE should be placed into the employeefiles.

14.1.5 Chemical Hygiene Plan

The Chemical Hygiene Plan (CHP) is the OSHA Hazard Communication Program forlaboratories. The regulation, which is found in 29 CFR 1910.1450 (Occupational exposure tohazardous chemicals in laboratories) is also called the Laboratory Right-to-Know Standard. Itapplies to employers engaged in the laboratory use of hazardous chemicals, except forprocedures that may be or may simulate parts of a production process. The CHP must be

written, and must set forth procedures, equipment, PPE and work practices which are capable ofprotecting employees from health hazards of hazardous chemicals used in the laboratory.

Implementing a CHP involves air monitoring to determine employee exposure to hazardouschemicals; development of specific procedures and control measures to minimize chemicalexposures (such as the proper use and maintenance of laboratory fume hoods); employeetraining; medical consultation and surveillance; use of PPE and RPE; and record keeping of allmonitoring and measurements taken, and the results of medical surveillance tests. Thelaboratory should have its own PPE and RPE program, as well as its own Hazardous ChemicalInventory and MSDS program.

Finally, the employer has to designate a qualified person to be the company Chemical HygieneOfficer (CHO). The CHO will be responsible for the implementation of all aspects of the CHP andwill provide technical guidance and support.

14.2 PLANT PROCESS REGULATIONS

14.2.1 Confined Space Entry

Confined spaces can be deadly. OSHAs confined spaces standard (29 CFR 1910.146) defineswhat a confined space is and identifies requirements for employers to:

Identify and mark confined spaces in the workplace,

Establish a permit system for any work to be done in certain confined spaces,

Set up rescue procedures and obtain equipment where necessary,

Identify individuals at the worksite who are responsible for implementing confined spaceprocedures and define their duties in writing, and

Develop and carry out a training program for all employees.

Each employer must determine if there are confined spaces on their site. If there are, they mustbe marked and identified and employees must be advised of their presence and location. Theconfined spaces must be evaluated to determine if they are "permit required confined spaces"which will require a formal permitting procedure to be implemented before anyone can be allowedto work in the space. This permitting program ensures that any work to be done in the space can


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be done safely and that all safety precautions are taken to guarantee the safety of the workers.Under this program, the positions and duties of the persons responsible for its implementationmust be identified.

Employers will be required to obtain or utilize equipment, at no cost to employees, to test theatmosphere of the confined spaces for oxygen level and for the presence of toxic and/orflammable gases. Where applicable, employers will have to obtain rescue equipment and trainworkers concerning proper rescue procedures. Procedures must be in place to preventunauthorized entries and to provide for sign-off of all activities. Confined space permits and allrelated records must be kept.

14.2.1.1 Confined Space Safety Programs

Before any work may begin, the workplace shall be evaluated to decide if any spaces arepermit required confined spaces. Permit required confined spaces have the potential forchemical and physical hazards that make entry immediately dangerous to life and health.The atmosphere may be oxygen deficient, toxic, flammable, or explosive. The confinedspace also may contain hazards such as slippery or uneven floors. Entry can only beauthorized when acceptable entry conditions are obtained. The Entry Permit is mandatory forany operation that requires an employee to enter or work inside a confined space.

14.2.1.2 Responsibility and duties

A permit required confined space entry requires the approval of an Entry Supervisor. TheEntry Supervisor is responsible for determining if acceptable entry conditions are present, forauthorizing and overseeing entry operations, and for terminating the entry. The duties of theEntry Supervisor include the following:

Knows the hazards that may be faced during entry, including information on themode, signs or symptoms, and consequences of chemical exposure;

Before endorsing the permit and allowing entry to begin, verifies that all testsspecified by the permit are conducted and that all procedures and equipmentspecified by the permit are in place;

Verifies that rescue services are available and that the means for summoning them isoperable;

Removes unauthorized individuals who enter or who attempt to enter the permitspace during entry operations;

Determines that entry operations remain consistent with terms of the entry permit andthat acceptable entry conditions are maintained; and

Terminates the entry and cancels the permit as warranted.

Attendants, stationed outside the permit space, monitor the Authorized Entrants and areresponsible for their safety. Attendant duties include the following:

Know the hazards that may be faced during entry, including information on the mode,

signs or symptoms, and consequences of the exposure;

Be aware of possible behavioral effects of hazard exposure in Authorized Entrants;

Continuously maintain an accurate count of Authorized Entrants in the permit spaceand ensure that the means used to identify entrants accurately identifies who is in thepermit space;

Remain outside the permit space during entry operations until relieved by anotherAttendant;


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Communicate with Authorized Entrants as necessary to monitor entrant status and toalert entrants to evacuate the space;

Monitor activities inside and outside the space to assess safety for the entrants toremain in the space;

Summon rescue and other emergency service when determined that the AuthorizedEntrants may need assistance to escape from permit space hazards;

Prevent unauthorized entry into confined space;

Perform non-entry rescues; and

Perform no duties that might interfere with the Attendant's primary duty to monitorand protect the Authorized Entrant.

Authorized Entrants, those employees authorized to enter a permit space, duties include thefollowing:

Know the hazards that may be faced during entry, including information on the mode,signs or symptoms, and consequences of the exposure;

Properly use any needed equipment;

Communicate with the Attendant as necessary to enable the Attendant to monitorentrant status and to enable the Attendant to alert entrants of the need to evacuate;

Alert the Attendant whenever the entrant recognizes any warning sign or symptom ofexposure to a dangerous situation or the entrant detects a prohibited condition; and

Exit from the permit space as quickly as possible whenever an evacuation order isgiven, or whenever the entrant recognizes any warning sign or symptom of exposureto a dangerous situation or when the entrant detects a prohibited condition.

Rescue Personnel, those employees designated to perform rescue operations from permitspaces, duties include:

Know the configuration and potential hazards of each permit space;

Develop appropriate rescue plans;

Participate in simulated rescue operations; and

Know Authorized Entrant duties and responsibilities.

14.2.1.3 The Confined Space Permit

Before entry is authorized, a Confined Space Entry Permit must be completed, documentingthe spaces safety and completion of safety measures. The completed permit will be madeavailable at the time of entry to all Authorized Entrants by posting it at the entry portal or byother equally effective means. This will confirm to the entrants that pre-entry preparation hasbeen completed, and will remain posted as long as the permit is valid. The duration of the

permit may not exceed 8 hours or the assigned task or job identified on the permit.

The Confined Entry Permit, completed by the Entry Supervisor, includes the followinginformation:

Permit space identification;

Entry Purpose;

Date and duration of permit;


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Names of Authorized Entrants;

Names of current Attendants;

Name and signature of original and current Entry Supervisor;

Hazard(s) in the permit space;

Isolation measures and means of eliminating or controlling hazards;

Acceptable entry conditions;

Test results, including initials of person performing the tests;

Rescue and emergency services and means to summon them;

Communications procedures for Attendants and Authorized Entrants;

Required equipment; and

Any additional information and permits.

The Entry Supervisor will terminate entry and cancel the permit when the entry operations

covered by the permit are completed or when a condition that is not allowed under the permitarises in or near the permit space. Canceled entry permits shall be retained for a period of atleast one year for the purpose of reviewing the program depending on facility retention policy.Problems encountered during an entry operation will be noted on the pertinent permit so thatappropriate program revisions can be made.

14.2.1.4 Pre-entry Preparation

The specific design or nature of a confined space will determine what practical and commonsense precautions shall be taken. Adequate safety measures to protect the worker frompossible dangers will be evaluated based on current conditions and circumstances.

Danger signs, posted near permit required confined spaces, notify employees of the locationof permit spaces and state that unauthorized entry is prohibited. The confined space must be

sufficiently barricaded to protect entrants from external hazards. This may be accomplishedby roping off the area, using saw horse barricades, or other applicable methods.

The confined space must be cleaned, flushed, or purged to the maximum extent possibleprior to entry. Atmospheric hazards will be eliminated by purging, inerting, flushing, orventing. The confined space will be isolated by the following means:

Following Lockout/Tagout procedures, all electrically operated equipment or electricallines connected to the confined space must be taken out of service before entry;

All process lines connected to the confined space must have their valves chainedand locked in the closed position or blanked with a solid flange, and identified with a"Danger" Tag; and

Instrument leads, blow back lines, purge connections, drains and possible sources ofcontaminating material must be physically disconnected, blanked, or chained andlocked in the closed position.

After cleaning and isolation, the permit space conditions must be evaluated. The internalatmosphere will be tested with a calibrated direct-reading instrument to determine ifacceptable entry conditions exist. Entry conditions shall be continuously monitored in theareas where Authorized Entrants are working to determine if acceptable conditions are beingmaintained during the course of operations. The atmosphere will be tested for oxygen


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content, flammable gases or vapors, and potential toxic air contaminants. Entry will beauthorized when the following conditions are met:

Atmospheric concentrations of oxygen are above 19.5% and below 23.5%;

Flammable gas, vapors, or mist is below 10% of its Lower Explosive Limit (LEL);

Atmospheric concentrations of substances for which a Permissible Exposure Limit(PEL) is published in 29 CFR Subpart G or Z have been feasibly reduced byengineering controls; and

Other atmospheric conditions that are immediately dangerous to life and health havebeen eliminated.

All equipment must be adequately prepared and maintained to protect the workers involved.Before entry, Authorized Entrants and Attendants will be provided with the necessaryequipment and training to do the job safely. The following equipment may be used during anentry:

Atmospheric testing and monitoring equipment;

Ventilation equipment, as needed, to obtain acceptable entry conditions; Communications equipment that enables the Attendant to monitor entrant status and

to enable the Attendant to alert entrants of the need to evacuate the space;

Personal protective equipment if feasible engineering and work practice controls donot adequately protect employees;

Lighting equipment needed to enable employees to see well enough to work safelyand exit the space quickly in an emergency;

Barriers and shields as necessary to protect entrants from external hazards;

Equipment, such as ladders, needed for safe ingress and egress by AuthorizedEntrants;

Rescue and emergency equipment; and

Any other equipment necessary for safe entry into and rescue from permit spaces.

For the duration of entry operations, at least one Attendant shall be stationed outside thepermit space into which entry is authorized. Attendants may be stationed at any locationoutside the permit space to be monitored as long as their duties can be effectively performedfor each monitored permit space.

When entry operations have been completed or a condition that is not allowed under theentry permit arises in or near the permit space, the Entry Supervisor shall close the permitspace and cancel the permit. Canceled permits shall be retained for a period of at least oneyear. Entry operations will be reviewed if there is reason to believe that the measures takenunder the confined space permit program may not have protected the employee. The

program will be revised to correct any deficiencies before subsequent entries are authorized.

The Permit Required Confined Space Program will be reviewed annually, covering all entriesperformed during a 12 month period. The program will be revised as necessary to ensurethat employees participating in entry operations are protected from permit space hazards.


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14.2.1.5 Rescue and Emergency Services

If the Attendant determines that activities inside or outside the confined space make it unsafefor entrants to remain in the space, evacuation orders will be given immediately. TheAttendant shall summon help by using the emergency communications and will provide

immediate assistance to the entrant(s), without entering the confined space or jeopardizingtheir own life.

14.2.1.6 Confined Space Rescue

Rescue personnel must receive specialized and extensive training in order to be qualified toperform rescue operations. Rescue operations involving confined spaces can be dangerousand risky, especially if the rescue requires entry into the confined space. Non-entry rescueprocedures are often preferred. This involves the use of harnesses and extraction lines bythe entrants, enabling personnel outside of the confined space to extract or rescue theentrant without entering the confined space. Communication is critical in performing this kindof operation so that the attendant maintains contact with the entrant at all times, either verbal,visual or by some other effective means. The attendant is not authorized to enter theconfined space unless he is relieved by another attendant. The role of the attendant is to

"attend" to the entrant, and to be sure he/she is safe.

Whenever non-entry rescue procedures are utilized, the roles of all personnel involved mustbe clearly defined and understood. All procedures and responsibilities are to be documented.

If at any time during entry operations there is a questionable action or non-movement by theAuthorized Entrant inside, a verbal check shall be made. If there is no response, the workerwill be removed immediately. If the entrant is disabled because of falling or impact, theentrant will not be removed unless there is immediate danger to life and health. The on-siterescue service shall be notified immediately and will implement emergency procedures to fitthe situation. The Attendant may enter the confined space in case of an emergency (wearingappropriate personal protective equipment) only after being relieved by another attendant. Asafety belt or harness with attached lifeline shall be used by all workers entering the spacewith the free end of the line secured outside the entry opening. The Attendant shall attemptto remove disabled entrant via his lifeline before entering the space.

When entry must be through a top opening, the safety belt shall be of the harness type thatsuspends a person upright and a hoisting device or similar apparatus shall be available forlifting entrants out of the space. In any situation where their use may endanger the entrant,use of a hoisting device or safety belt and attached lifeline may be discontinued.

14.2.1.7 Training

Training must be provided to all employees involved in confined entry operations. Thetraining provides employees with the understanding, knowledge, and skills necessary for thesafe performance of their duties. Training is provided to each affected employee:

Upon initial assignment;

Whenever there is a change in assigned duties;

Whenever there is a change in permit space operations that presents a hazard aboutwhich an employee has not been previously been trained; and

Whenever there are deviations from the permit program or that there areinadequacies in the employee's knowledge of use of the program.

Rescue service personnel also need to practice and be trained in the following:


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Proper use of rescue and personal protective equipment necessary for makingrescues;

Assigned rescue duties;

Authorized Entrant duties and responsibilities;

Basic first aid and CPR; and

Simulated rescue operations.

14.2.1.8 Contractors

When contractors are employed to perform work that involves permit space entry, they will beinformed and apprised of the following:

The presence of permit spaces and that entry is allowed only through compliancewith the Permit Required Confined Space Entry Program;

Available information regarding the elements, including the hazards identified, andexperience with the permit space; and

Precautions and procedures that have been implemented for the protection ofemployees in or near the permit space where contractor personnel will be working.

Entry operations will be coordinated when both the host and contractor personnel will beworking in or near the permit space. The contractor will be debriefed at the conclusion ofentry operations regarding the permit space program and any hazards confronted or createdduring entry operations.

14.2.2 Lockout / Tagout - The Control of Hazardous Energy

The Control of Hazardous Energy Standard is also referred to as the Lock Out/Tag Out standard,because it involves the actions of locking out and/or tagging out energized equipment. Everyyear, hundreds of accidents occur as a result of failure to properly lock out equipment beforeattempting to service or work on it. The purpose of this standard is to protect workers from the

hazards of energized equipment in the workplace.

The standard, found in 29 CFR 1910.147, applies to those who must work on energizedequipment. The employer must evaluate the workplace to identify the location and type of energysource (electrical, steam, pneumatic) for all workplace equipment and then identify all the energyisolating devices which are part of each machine. An energy isolating device is a device whichphysically prevents the transmission or release of energy (circuit breakers, disconnect switches,valves, etc.).

When work must be conducted on equipment the energy source must be "locked out"; in otherwords, a lock must be placed on the energy isolating device so that the equipment cannot beenergized. In addition, the same device is tagged out; a tag is placed on the device which clearlyand noticeably states "Do not energize this equipment!" If an energy isolating device is not

capable of being locked out, the employers energy control program shall utilize a tagout system.To ensure safety, there is a definite step by step procedure to follow, and each employee who is

authorized to work on equipment will have his own locks and keys.

Employers are responsible to provide training about the regulation and its requirements. Theemployer must also educate employees about the dangers of servicing energized equipment andconcerning the specific responsibilities of employees related to this standard. Employees whoare authorized to service equipment will be identified and all other affected employees will beinformed.


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14.2.2.1 The Lock Out/Tag Out or Energy Control Program

The Energy Control Program contains practices and procedures that will protect employeesfrom the hazards associated with the servicing and maintenance of machines and equipment,and complies with 29 CFR 1910.147. The program applies to the control of energy only

during maintenance and/or servicing of machines and equipment in which the unexpectedenergization or start-up of the machines or equipment, or release of stored energy, couldcause injury. Normal production operations are not covered unless:

An employee must remove or bypass a guard or other safety device; or

An employee must place any part of his/her body into an area on a machine or pieceof equipment where work is performed such as the point of operation, or any zonewhere the machine or equipment may present a hazard if unexpectedly energized.

14.2.2.2 Definitions

Authorized Employees - Those employees who the facility authorizes to perform the lockout/tag out before service or maintenance.

Affected Employees - Those employees who use or work near machines or equipment that islocked or tagged out during service or maintenance. This also includes employees who willconduct the service or maintenance.

Other Employees- Those employees who may be in the area.

14.2.2.3 The Lockout Permit

The Lockout Permit is a document that must be completed prior to any equipment service ormaintenance. The signature of an Authorized Employee is required. The followinginformation must be on the Lockout Permit:

Signatures of Affected Employees;

Permit expiration date; and

Signatures of Authorized Employees.

The Lockout Permit expires when the job is complete or there is a change in work crews. Anew Lockout Permit is required at each change of work crew. When the original AuthorizedEmployee is relived, but the Affected Employees are the same, the oncoming AuthorizedEmployee must countersign the permit within thirty (30) minutes of assuming responsibility forthe job. The expired Lockout Permit will be retained based on facility retention policy.

14.2.2.4 Responsibilities

It shall be the responsibility of the department that operates the equipment to initiate theLockout Permit. The Authorized Employee is responsible for shutting down equipment andmaking it safe to work on. The Authorized Employee is the first to tag and lock out theequipment.

The Affected Employee is responsible for satisfying himself that the conditions under whichhe is working and the conduct of his work is safe for himself and his fellow workers. He mustsign the tag and apply his lock to the equipment immediately after the Authorized Employee.


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14.2.2.5 Procedures

A double responsibility procedure will be used to ensure maximum protection. Wheneverwork is performed on equipment, the tag and locks shall be applied by the AuthorizedEmployee. No person will be allowed to work on power driven equipment or connectedaccessories unless the equipment or machine can be locked and tagged. The Authorized

Employee initiates the lockout in the following manner: Before an employee performs any servicing or maintenance on a machine or

equipment, the machine must be isolated and rendered inoperative. Switch off theequipment according to the manufacturer's instructions. This must be done withoutcreating new hazards.

Turn the equipment power off at all energy isolating devices needed to control theequipment or machine. Sometimes energy is stored in parts like springs, rotatingflywheels, or water pressure systems. If so, that energy must be dissipated orrestrained with such techniques as blocking and bleeding.

The Authorized Employee must attach a "DANGER--DO NOT OPERATE" tag on thepower control unit switch in the "off" position. The Authorized Employee who placedthe "DANGER" tag must completely fill out the tag, including the date and their

signature.

The Authorized Employee will then attach a multiple lockout adapter to the switchand put the first lock on the adapter. Methods of attaching the adapter to the switchwill vary according to the type of switch to be locked out. Each Affected Employeewho is to work on or in the equipment must verify that the equipment is clear andinoperable by placing his signature on the tag, and lock on the lockout adapter. Thismust be done in the presence of the Authorized Employee who is responsible fortagging operations on that shift.

The starter button must be tried to insure that the correct switch has been used andto determine that the equipment or machine is inoperable and fully de-energized.

Conditions may arise that make it impossible for a repairer to remove his lock. The

Authorized Employee may authorize lock removal. The lock may be removed by the person placing it on or by his authorized relief, after

ensuring that all work is complete and after all other locks are removed.

When work is interrupted, the lock and the "DANGER" tag shall be left on the switchgear.

In instances where frequent and repetitive starting and stopping of motor drivenequipment may be required as part of the servicing or maintenance, or where it wouldbe impractical for a supervisor or designate to attend the repetitive locking andunlocking sequences the following precautions shall be taken:

o All tools and materials must be removed from the area. Affected and otheremployees also must leave the area.

o When frequent starting/stopping becomes necessary, the AuthorizedEmployee may remove his lock, leaving the "DANGER--DO NOTOPERATE" tag and repair locks on the switch. Affected Employees willremove their locks only when it is necessary to jog or move the equipment,reattaching the locks when such moving is complete and beforerecommencing work on such equipment.

o Specific cleaning or inspection routines, performed frequently, may requireexceptions to this procedure. Always, authorization shall be obtained inwriting.


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14.2.2.6 Release of Lock Out/Tag Out

Before lock out or tag out devices are removed and energy is restored to the machine orequipment, the Authorized Employee must ensure the following:

The work area must be inspected to ensure that all nonessential items have beenremoved and the machine or equipment is operationally intact.

All Affected Employees must be notified that the lock out/tag out devices have beenremoved.

Each lock out/tag out device must be removed from each energy isolating device bythe Affected and Authorized Employee(s) who applied the devices.

The equipment must be tested to ensure that it is safe to operate prior to beginningproduction.

Once the equipment passes the test, it may be placed back into full production.

14.2.2.7 Training

Employees will be trained to ensure that the purpose and function of the Energy Control

Program are understood and that the knowledge and skills required for the safe application,usage, and removal of the energy control are acquired. Training includes the following:

Authorized Employees receive training in the recognition of hazardous energysources, the types and magnitude of the energy available in the workplace, and themethods and means necessary for energy isolation and control.

Affected employees are instructed in the purpose and use of the energy controlprocedures.

All other employees whose work operations are or may be in an area where energycontrol procedures may be utilized, will be instructed about the procedure, and aboutthe prohibition relating to attempts to restart or re-energize machines or equipmentwhich are locked or tagged out.

When tag out systems are used, employees are trained in the following limitations of tags:

Tags are essentially warning devices affixed to energy isolating devices, and do notprovide restraint on those devices that is provided by a lock.

When a tag is attached to an energy isolating means, it is not to be removed withoutauthorization of the Authorized Employee responsible for it, and it is never to bebypassed, ignored, or otherwise defeated.

Tags must be legible and understandable by all Authorized Employees, AffectedEmployees, and all other employees whose work operations are or may be in thearea, in order to be effective.

Tags and their means of attachment must be made of materials which will withstandthe environmental conditions encountered in the workplace.

Tags may evoke a false sense of security, and their meaning needs to be understoodas part of the overall Energy Control Program.

Tags must be securely attached to energy isolating devices so that they cannot beinadvertently or accidentally detached during use.

Retraining will be provided for Authorized and Affected Employees whenever there is achange in their job assignments, a change in machines, equipment or processes that presenta new hazard, or when there is a change in the energy control procedures.


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14.2.3 Forklift Safety

Forklifts, or powered industrial trucks, are widely used throughout general industry. There are avariety of models, styles, sizes and functions and without them business productivity would suffergreatly. At the same time, forklifts pose a serious health and safety hazard to those employeesworking with or around them. Accidents and injuries involving forklifts are often serious, and

there have been many fatalities as a result of accidents.

Forklift safety regulations are needed to ensure that employers develop procedures andprograms to train employees concerning safe operation. OSHAs Powered Industrial Trucksregulation (29 CFR 1910.178) requires that "...only trained and authorized operators...bepermitted to operate a powered industrial truck." Employers must have a formal program oftraining and instruction for forklift operators. This training must instruct employees concerning thesafe operation of forklifts and enable forklift operators to understand the potential safety hazards.

An effective forklift operator training program should contain safety training and proceduresrelated to the following elements:

General Operating Instructions,

Pre-Startup Daily Inspections, Traveling and Cornering,

Transporting a Load,

Loading and Unloading of Vehicles, and

Fueling, Charging and Maintenance.

An operator must fully understand and be able to safely use all the functions of the forklift he orshe must operate. It is recommended that the Owners Operating Manual be reviewed as part ofthe training. A forklift must be in safe operating condition before it can be safely operated. Dailyor pre-startup inspections will ensure that forklifts which are not in safe operating condition arenot operated. Records must be kept of these inspections.

Operators must know how to safely navigate a forklift in any circumstance encountered in theworkplace, such as loading, unloading, cornering, traveling, etc. The employers forklift safetyprogram must identify those to be trained. It should also indicate how and when they will betrained. The content of the training should be customized to each workplace.

14.3 OPERATOR REGULATIONS

14.3.1 Emergency Action Plans

Emergencies can occur at any time and anywhere. In order to ensure that employers provide foremployee safety during workplace emergencies such as fires, explosions, and weather relatedemergencies, OSHA requires certain employers to prepare an Emergency Action Plan.

The Emergency Action Plan (EAP) will identify what the employer and employees will do in anemergency. The employees will evacuate the workplace according to the instructions given in theEAP. This usually involves knowing the means by which the employer will notify the employeesof an emergency, such as a fire alarm, intercom announcements, or flashing lights. Additionally,employees will need to know the location of all exits, including the location of the exit closest toeach work area. The employer will assign certain employees to account for everyone to ensurethat everyone has evacuated safely after an alarm.


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Phone numbers of emergency services will be identified and instruction will be given as to whowill contact those services and when they are needed. Employees will receive training to reviewthe details of the EAP for their particular facility.

The requirements for emergency action plans are found in 29 CFR 1910.32. In some cases, afacility is already required to have an Emergency Response Plan because of other OSHAregulations such as Process Safety Management or the HAZWOPER standard, or because ofEPA requirements. A separate EAP will not be required or necessary in these cases.

14.3.2 Fire Extinguisher Safety

Fire extinguishers, when properly used, become a vital part of a companys fire preventionprogram. It is much easier to deal with a fire when it is in its beginning stages and is smallenough to be extinguished with a portable fire extinguisher. However, there are inherent dangersassociated with any fire and even with the use of fire extinguishers. Using a fire extinguishersafely and effectively is critical and requires training and education. OSHA standard 29 CFR1910.157 details requirements for employers.

Whenever an employer plans to have and use fire extinguishers, OSHA requires that the fireextinguishers be properly distributed so that 1) there are enough fire extinguishers for use, and 2)the fire extinguishers are spaced so that they can be easily reached from any point in theworkplace.

In addition, all fire extinguishers must be inspected regularly and be properly maintained andtested. The employer must keep a list of all site fire extinguishers. The employer also must trainemployees expected to use fire extinguishers concerning the proper and safe use of fireextinguishers along with the hazards of dealing with small fires in the workplace.

14.3.3 Hearing Conservation

OSHAs standard on occupational noise exposure, 29 CFR 1910.95, requires employers toprovide protection against the effects of noise exposure in the workplace. Where noise exposureis detected, an employer must write an effective hearing conservation program, with requirementsfor monitoring, audiometric testing and evaluation, training, provision of hearing protectiondevices and record keeping. The action level at which the standard becomes effective is an eighthour TWA (time weighted average) of 85 decibels on the A scale, or 85 dBA. If the 8 hour TWAis at or above 90 dBA, feasible administrative or engineering controls must be implemented toreduce noise levels. If these controls do not reduce the TWA below 90 dBA, or where use ofsuch controls is economically or mechanically infeasible, then personal protective equipment(hearing protection devices) must be provided by the employer and used by the employee toreduce their exposure to less than the 90 dBA 8 hour TWA.

29 CFR 1910.95 requires that a hearing conservation program be implemented for employeesexposed to noise levels above the 85 dBA TWA. This program requires:

Baseline and annual audiometric exams,

Provision of a variety of hearing protection devices for employee selection and use,

Periodic monitoring of the work areas,

Training covering proper use of hearing protection devices and the nature of soundinduced hearing loss,

Record keeping, and

Establishment of a written program explaining the hearing conservation activities as listedabove.


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Areas with noise levels near 85 dBA should be periodically monitored using a dosimeter tomeasure the 8 hour TWA for affected employees.

14.3.4 The HAZWOPER Standard

"Hazwoper" is an acronym which stands for the Hazardous Waste Operations and Emergency

Response Standard drafted by OSHA, effective since 1991. The standard can be found in 29CFR 1910.120. It consists of 2 parts: Hazardous Waste Operations and Emergency Response.It was developed by a joint effort of both OSHA and EPA and was intended to address thosepersons involved in cleaning up hazardous wastes or responding to emergencies. Regulationswere already in place for industrial settings, but the particular circumstances involved withcleanups and emergency response was not adequately addressed. Hence, Hazwoper came intobeing.

The section of the standard on "hazardous waste operations" applies mainly to Permitted TSD(Treatment, Storage and Disposal) facilities and to operations involving the cleanup of hazardouswastes as a result of RCRA corrective actions or actions under CERCLA. The EmergencyResponse section, however, is much broader in scope and applies to the majority of generalindustry. In particular, if you have hazardous substances on your site (including any hazardouswaste) and your employees work in an area where the substances are present and therefore maywitness a release or spill of those substances and must take any actions, the standard will apply.The exception would be where the employer does not allow any employee to take any action toclean up any spill or release of any hazardous substance, and the employer has implemented anEmergency Action Plan as required in 29 CFR 1910.38.

Applying this exemption may be a desirable option for some employers, mainly because of thefact that they are exempted from the requirements of the standard. These employers could alsoargue that they are preventing possible employee exposures to hazardous substances. On theother hand, many employers prefer the advantages of being able to take certain basic, defensiveactions during an emergency spill or release in order to minimize the severity of a spill and itsimpact on other workers and the environment. Decisive actions can often prevent a spill orrelease from escaping the site and potentially exposing neighbors or the surrounding communityto hazardous substances. An appropriate first response to an emergency situation can often be

the difference between a major catastrophe and a relatively minor incident.

Under section (q) of the standard, there are substantial requirements which include training,development and/or implementation of emergency response or emergency action plans, recordkeeping, and medical surveillance. There is also some overlap with other OSHA standards andalso with DOT and RCRA standards pertaining to the handling of hazardous materials.

The requirements for general industry are mainly related to the emergency response portion ofthe standard for employee training. Varying levels of training are required based on anemployees potential level of involvement in an emergency. An employee who is expected torecognize when a particular release constitutes an emergency would get a minimum of whatOSHA calls "awareness level" training. An employee taking defensive actions to prevent thespread of a release would be required to have a minimum of "operations level" training (8 hour

training). Those employees who must take offensive actions to approach the point of releaserequire a minimum of 24 hours of training at the "hazardous material technician" level.

Hazwoper training requirements are also performance based. This means that the employeesmust obtain the required hours of training and master the competencies referred to in thestandard. Employees must be retrained annually to maintain competency levels.


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14.3.5 Emergency Response Staff

14.3.5.1 First Responder (Awareness Level)

Will witness or discover a release of hazardous materials, and has the following training:

Knows what a hazardous material is and understands the risks associated with themin an incident.

Understands the potential outcome associated with a hazardous material incident.

Can recognize the presence of hazardous material in an emergency.

Can identify the hazardous material, if possible.

Understands the contingency plan and its implementation.

Able to notify the proper authorities.

14.3.5.2 First Responder (Operations Level)

Responds to releases of hazardous material in a defensive manner. Does not try to stop therelease. Has the f

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