osha compliance for temp agencies and host employers
DESCRIPTION
Compliance with osha health standards: Overview Georgia Tech’s Safety and Health Consultation Program. OSHA Compliance for Temp Agencies and Host Employers. Basic Scope of IH Compliance. Hazard Communication (Chemical) Hearing Conservation Air Contaminants Permit-Required Confined Spaces - PowerPoint PPT PresentationTRANSCRIPT
COMPLIANCE WITH OSHA HEALTH STANDARDS:
OVERVIEW
GEORGIA TECH’S SAFETY AND HEALTH
CONSULTATION PROGRAM
OSHA Compliance for Temp Agencies and Host Employers
Basic Scope of IH Compliance Hazard Communication (Chemical) Hearing Conservation Air Contaminants
Permit-Required Confined Spaces Respiratory Protection Personal Protective Equipment First Aid & Bloodborne Pathogens
HAZARD COMMUNICATION
STANDARD
Compliance with OSHA Health Standards
4
“CHEMICAL” Hazard
CommunicationStandard
LABEL
MSDS
HCP
5
Purpose To insure that the hazards of all chemical
produced in or imported into the U.S. are evaluated
Hazards transmitted to employers employees
6
Basic Program Elements Chemical Hazard Inventory MSDS’s Labeling Employee Training Contractor Training Written Program
HazardCommunication
Program
Temp Workers and HazCom: Shared Responsibility
Staffing Agency Generic Policies
Host Company Specific Chemicals
Global Harmonization System (GHS)
Final Standard: March 2012 Implementation Period: December 2013
through June 2016 Hazard Communication Changes
Labels, Pictograms Safety Data Sheets Employee Training
Four Major Changes in GHS9
1. Hazard Classification (changed from hazard determination)
2. Labels3. Safety Data Sheets (changed
from MSDS)4. Information and Training Will affect nearly 40 million workers and 5 million workplaces.
Principles Of Harmonization
Consistent Classification (both intra- and inter-nationally)
Harmonized across agencies: OSHA, Consumer Protection Agency, EPA,
DOT Both code Words and Pictograms Warnings are based on intrinsic hazards
of chemicals Identify the Severity of exposure
HEARING CONSERVATION
Compliance with OSHA Health Standards
Monitoring Requirements(Dosimetry)
Initial Monitoring required if employer has indications of full-
shift exposure at or above 85 dBA (Action Level)
Rule of Thumb for estimating 85 dBA Host and Staffing Agency Duties
Who will conduct noise monitoring? Default assumption of 85 dBA What are high range exposures?
Hearing Conservation Program:Who Implements Basic Elements?
Provide hearing protection Train workers on noise effects (annual) Provide baseline and annual audiometric
testing Retain exposure and audiometric
measurements
Hearing Conservation Documentation
Copy of Written Guidelines and Policies (Recommended)
Noise Measurement Data and Annual Audiograms
Standard Threshold Shifts Documentation and Notification Letters
OSHA 300 Hearing Loss Records Which employer records an incident?
AIR CONTAMINANTS
Compliance with OSHA Health Standards
Evaluating Host Companies for Air Contaminants
GASES: low density molecules, rapid diffusion
VAPORS: liquids with high vapor pressure
DUSTS: solid particles FUMES: recondensation of vaporized
solids MISTS: liquid droplets, (aerosols) SMOKE: complex combustion products FIBERS: 3 to 1 length to width ratio
Chemical Mixtures
Anticipate Potential Air Hazards Review plant layout and chemical flow Observe air flow patterns Identify existing controls Temp Workers and high hazard work
Restrictions on job assignments?
Understanding Exposure Limits PEL TLV REL WEEL EU Standards MRG
OSHA PEL(Regulatory in US)
Permissible Exposure Limit—PEL
(Or)
“Impermissible” Exposure Limit
Categories of OSHA PEL’s
1. The PEL Lists (~400 chemicals) Current PEL’s are based on 1968
ACGIH-TLV’s
2. The “Substance Specific” Standard E.g., lead, asbestos, cadmium,
methylene chloride, etc. Relatively few substance specific
chemicals regulated
Occupational Exposure Limits (OELs) (Non-Regulatory)
American Conference of Governmental Industrial Hygienists—Threshold Limit Value (ACGIH –TLV)
National Institute for Occupational Safety and Health —Recommended Exposure Limit (NIOSH REL)
American Industrial Hygiene Association—Workplace Environmental Exposure Limit (AIHA WEEL)
European Union standards Manufacturer’s Recommended
Guidelines
0 200 400
Time-Weighted Average (TWA) Exposure
TIME (min)
PPM
800
700
600
500
400
300
200
100
0
Example: Acetone, PEL = 1000 PPM, TWA
TWA = 200 ppm
Evaluating Exposures Pre-screening Passive sampling Active IH sampling
STEL Measurements (Short Term) TWA Measurements (Full Shift) Acute Exposures (Confined Space)
Initial Screening of Exposure
Passive Samplers
Organic Vapor Sampler Inorganic Mercury Sampler
Full Shift Breathing Zone Exposures
Air Contaminants in Permit-Required Confined Spaces (Evaluate Acute Air Hazards)
Host and Staffing Agency Who conducts evaluations? Who keeps records? Who has access to records? Medical surveillance (lead, cadmium,
asbestos, methylene chloride, etc) Who conducts biological monitoring? Who keeps records?
RESPIRATORY PROTECTION
Compliance with OSHA Health Standards
Organize the Program
Respirator Program Elements Selection of respirators Define use and application Medical evaluation Fit testing Training Maintenance and care Breathing air quality and use Program evaluation
Host and Staffing Agency Will Temp Workers be assigned to use
respirators? Who will manage the Respirator
Program? Medical evaluation for use Fit Testing Training Recordkeeping
PERSONAL PROTECTIVE EQUIPMENT
Compliance with OSHA Health Standards
Certification of Personal Protective Equipment Hazard Assessment
COMPANY NAME:___________________________________ DEPARTMENT(S) EVALUATED:________________________________ NAME/TITLE:_______________________________________ DATE:____________________________
Job Hazards PPE Required
Personal Protective Equipment
PPE HAZARD ASSESSMENT SURVEY
Job/Task Evaluated:________________________
Date(s): _____________________ Conducted
By:_________________________________(Name and Title)
PPE Hazard AssessmentI. Hazards to the Head Potential Hazard Yes No Specifications for PPE*
a. Falling equipment or materials
b. Moving equipment or materials
c. Low overhead clearance
d. Electrical shock hazard
e. Welding
PPE Hazard AssessmentII. Hazards to the Eyes and Face
Potential Hazard Yes No Specifications for PPE*
a. Particulates in air
b. Hazardous liquids in air or potentially airborne (splashed)
c. Irritant dusts in air
d. Ultra violet, Infrared, or Laser radiation
e. Compressed air/liquid
f. Electrical arcing
PPE: Host and Staffing Agency Review the job hazards Review the PPE requirements Review work conditions for PPE use
When Where What processes
Paying for PPE
BLOODBORNE PATHOGENS
Compliance with OSHA Health Standards
Applications General Industry/Manufacturing
Designated First Aid responders BBP standard does not cover “Good
Samaritan” acts in which an employee voluntarily provides first aid to a fellow employee
Medical and Human Services Offices Any employee whose job involves contact
with blood or other potentially infectious materials (OPIM)
Universal Precautions All human blood/OPIM are treated as if
known to be infectious for bloodborne pathogens, regardless of the perceived “low risk” status of a patient or patient population
Exposure Control Plan(Gradient of Complexity)
General Industry/Manufacturing Relatively simple (First Aid): written policy,
PPE, training
Medical Providers/Human Services Relatively complex (Medical interventions):
many program elements to manage; treatment procedures; cleaning schedules; compliance with changing guidance on Sharps; awareness and compliance with CDC infection control practices.
Host and Staffing Agency Review Exposure Control Plan (ECP) Identify job positions included in ECP Provide training for Bloodborne
Pathogens Restrict access to specific areas of
facility Identify special PPE requirements Specify required vaccinations
Summary(Host and Staffing Agency shared duties)
Hazard Communication (Chemical) Hearing Conservation Air Contaminants
Permit-Required Confined Spaces Respiratory Protection Personal Protective Equipment First Aid & Bloodborne Pathogens