OSHA Regulations often applied to commercial office & schools

1. OSHARegulations often applied to commercial office & schools Rob Rottersman, MS, CIH 847.685.9266 rrottersman@boelter-yates.com

2. Illinois Non-Public Buildings/Employees • OSHA has jurisdiction Public Buildings (including municipal and schools) • Illinois Department of Labor (IDOL) has jurisdiction • IDOL has adopted OSHA standards

3. Most Frequent Citations (National)October 2004 – September 2005 • Scaffolding (9,558) • Hazard Communication (7,564) • Fall Protection (6,483) • Respiratory Protection • Hazardous Energy/Lockout Tagout (2,281) Total Citations (1 year) = 113,362 $103,923,102 in fines

4. Scaffolding OSHA 29CFR1910.27 Subpart D “Walking – Working Surfaces” Defined – “Any temporary elevated platform and its supporting structure used for supporting workmen or materials or both” Regulations depend on scaffold type

5. Powered Platforms & Manlifts OSHA CFR1910.66 Specific for Building Maintenance • Regulations specific for type of lift • Includes standards for harnesses, use, inspection & training • Protection from falling objects

7. Hazard Communication OSHA 29CFR 1910.1200 http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_id=10099&p_table=STANDARDS Or Google Search “OSHA 1910.1200” • Who has a hazard communication program? • Is it compliant with the standard?

8. Purpose PURPOSE – Why do we need all this? • Ensure chemical hazards are evaluated • Information passed on to employee • Allow for safe use and handling • Emergency response (spills/exposure)

9. Key Elements • Written Program • Material Safety Data Sheets (MSDS) • Chemical Inventory • Training • Labeling

10. Written Program How the School will Meet Requirements: • Labeling/warning information • MSDS • Employee Information and Training • List of Hazardous Chemicals • Hazards of “non-routine” tasks • Outside contractor/visitor communication *Program must be available upon request

11. Labeling Container Labels Must Contain: • Identity of hazardous chemicals • Appropriate hazard warnings • Name & address of manufacturer Manufacturers label should be sufficient

12. When do you need to label? • Chemical transferred to other container and NOT used by 1 employee on 1 shift • Spray bottles are often overlooked • Science and art rooms often forgotten • Manufacturer’s labels is worn/illegible • Label is not in English

13. Labeling Exemptions • Articles = Not gas, liquid or particle item with “end use function” (i.e. solid parts) • Materials regulated by other agencies - Pesticides (but label required by EPA) • Food, Drugs, Cosmetics • Alcohol • Agricultural or vegetable seeds • Wood or wood products • Biological hazards • Radiation

14. Material Safety Data Sheets (MSDS) Must have a MSDS for every “hazardous” chemical in the school OSHA Hazardous – “Any chemical which is a physical or health hazard” “All substances are poisons; there is none that it is not a poison. The right dose differentiates a poison from a remedy” Paracelsus 1493-1541

15. MSDS Contents • Name – Product Identity • Physical & chemical characteristics • Physical hazards • Health hazards • Routes of entry • Whether or not it can cause cancer • Precautions for safe handling • Control measures (ventilation, PPE, etc) • Emergency & first aid • Date of MSDS preparation and revision • Contact info. for manufacturer

16. Exposure Standards – Alphabet Soup • Permissible Exposure Limits (PEL) • OSHA Standard – enforceable • Subject to industry lobbying • Recommended Exposure Limit (REL) • National Institute of Occupational Safety and Health (NIOSH) • Research based – not enforceable • Threshold Limit Value (TLV) • American Conference of Govt. Industrial Hygienists (ACGIH) • Recommended but not enforceable

17. Health Considerations • Review significant routes of entry • Skin contact, inhalation, ingestions • Chronic vs. Acute • Chronic – delayed response • i.e. cancer, cirrhosis • Acute – effect short time after exposure • Irritation, headaches, dizziness, allergic

18. Obtain from chemical manufacturer MSDS must be readily & immediately accessible to employees Electronic files are permitted if employees have access Keep current – periodic review for updates MSDS Maintenance

19. MSDS Recommendations • Establish & maintain a new product introduction program • Have 1 person designated to approve all new products brought onto school grounds • Approval requires submitting MSDS sheet, review for hazards & training if needed

20. List of all “hazardous” chemicals found in the facility Must include the name used on the MSDS sheet Consider using as an MSDS index Chemical Inventory List

21. Training • All employees who use or could come in contact with “hazardous” chemicals must be trained • At the time of hiring • Before beginning a new assignment/job change • Whenever there is a new hazard that was not included in previous training • Whenever new hazards are discovered for an existing product

22. Non-routine Tasks • Often overlooked • could be significant health and safety hazards • Examples in schools could include • Cleaning, using chemicals in confined space such as crawlspaces • Handling cooling tower treatment chemicals • Chemicals to remove graffiti • Inventory old chemicals from science & art rooms

23. Outside Contractors/Vendors • Must inform of hazards associated with products they use or may come in contact with • Notify them of written program and location of MSDS sheets • Provide training as needed

24. Chemicals Used by Vendors at Your School Janitorial cleaning crews, contractors, pesticide applicators, etc. • Make sure they have provided you with MSDS sheets • Review to ensure they are complete & up to date • KNOW THE LOCATION of their MSDS sheets AND inform your employees

25. Fall Protection Multiple references in the standard OSHA CFR1910.21-1910.27 Appendix D • Guards and rails • Floor openings, uneven floor surfaces, etc. • Ladders & Stairs • Wood vs. metal & fixed vs. permanent

26. Respiratory Protection OSHA CFR1910.134, .139 Respirators as a “last resort” for reducing chemical exposures to safe levels. Better Options: - Eliminate hazard (product substitution) - Engineering controls (ventilation)

27. Respirator Programs If employees use respirators an OSHA respirator program must be in place • Appropriate Respirator Selection • Annual Training • Annual Fit Testing • Medical Evaluations • Exposure Assessments

28. Dust Mask Exemption OSHA CFR1910.134(c)(2)(i)(ii) Dust Mask (filtering face piece) may be worn if: • Use is voluntary (not required by employer) • The respirator itself will not create a hazard • Employer provides employee with information contained in OSHA Appendix D • “Information for Employees Using Respirators When Not Required Under the Standard”

29. Respirator Selection

30. Safety Shoes 29CFR1910.136 • Required when danger of injury from falling or rolling objects, objects may pierce the sole or feet are exposed to electrical hazard

31. Eye Protection 29CFR1910.133 Eye & face protection shall be worn when exposed to eye or face hazards from flying particles, molten metal, liquid chemicals, acids or caustics, chemical gases or vapors or injurious light radiation

32. LockOut/TagOut(Control of Hazardous Energy) OSHA 29CFR1910.147 “Covers the servicing and maintenance of machines and equipment in which the unexpected start up or release of stored energy could cause injury to employees”

33. LO/TO Requirements Written Program/Policy Define “Authorized” employees • Understand the machines & energy • Trained in LO/TO • Authorized to install & remove locks/tags Define Effected Employees • Employees who may operate locked or tagged out equpment

34. Actions Requiring LO/TO • Removing or bypassing a safety device • Any part of the body is placed in harm’s way • Exposure to hazardous energy

35. OSHA Record Keeping 29CFR1904 AKA: 300 Log Includes: • Determining if injuries are “recordable” • Logging injuries (300 Form) • Investigate cause (301 Form) • Post summary - Feb-April (300-A Form)

36. Blood Borne Pathogens 29CFR1910.1030 • Program required when there are employees with potential exposure • Health care • First Responders/First Aid Providers • Janitorial (restroom cleaning) • Annual training required • Post exposure vaccination program • Hepatitis B Virus

37. Safety Quiz: Who’s Liable? Bob dropped a banana peel, slipped and fractured his skull, who’s at fault? • Bob • Bob’s school district & supervisor • Floor wax manufacturer • Banana importer • Grocery store • Newspaper that advertised banana sale • The Banana farmer

38. You Know an IDOL Inspection is going bad when- • IDOL sets up temp. housing in your parking lot • The officer mutters “this is unbelievable” • They call in a professional film crew for documentation and you recognize Walter Jacobson • Officer is wearing a moon suit and respirator your staff is in jeans and tennis shoes • Officer begins inspection with “you have the right to remain silent” • Officer asks a specific question about a note in your files (before you show him the file) • Officer knows all your staff by their first names • Officer is a former science teacher that you fired

39. Speaker Contact Information Rob Rottersman, MS, CIH Senior Environmental Consultant Boelter & Yates, Inc. 1300 Higgins Rd. Ste 301 Park Ridge, IL 60068 rrottersman@boelter-yates.com IASBO Booth #432