Subcontractors….why worry??? Presented by: Jessie Atencio Acting Director CET Program Manager

Objectives ADOSH VPP Program What VPP Manual and CFR state What type of contractors on our sites What Standards are applicable Common Problems on VPP sites Questions

Who is ADOSH????? State Run OSHA Plan Jurisdiction over all employers with the exception of; Nations United States Post Office Compliance Section Address Imminent Danger, Fatality/Catastrophe, Complaints, Referrals, Planned, Follow-up and Emphasis Consultation & Training Section Service Small employers (250 employees and less), High Hazard Industries, Targeted Industries Free training to employers with 10 or more employees on site SPANISH AND ENGLISH AWARENESS TRAINING CERTIFICATE

ADOSH VPP & C-VPP Program Adopted Federal VPP Manual 2008 C-VPP Manual 33 Sites – 3 pending recommendations for a total of 36 3 Construction and 30 Manufacturing/Gener al Industry Settings ONLY OBSERVE STAR STATUS

What does the VPP Manual say? Definition of contractor: Contract Employees. Those individuals who are employed by a company that provides a service under contract to the VPP applicant or participant, usually at the VPP applicant’s or participant’s worksite. RESIDENT CONTRACTORS Non-resident, but may have 500 hrs in a quarter to be included in the site

What are types of contractors on site? Resident: Food Service Maintenance/Housekeeping Electrical Contractor Employee contractor Non-resident: Electrical Construction Contractor Plumbing Contractor IT personal

Types….

What about non-resident contractors?

Painters

Steel Erectors

What OSHA standard will address your contractor (resident or non) Do they fall into 1910 General Industry Standards? Do they fall into 1926 Construction Standards? Or is there an ANSI or Consensus Standard that they need to follow?

How to decide General Industry vs Construction General Industry Routine Maintenance, servicing or type of work within workplace setting Construction Alteration, and/or repair, including painting and decorating.

Letter of Interpretation show_document?p_table=INTERPRETATI ONS&p_id=24789 Letter explains that there is no definition for maintenance, but defined in dictionaries as a condition of routine, scheduled, or anticipated fashion

Letter of Interp. cont’d….. Based on the information you have provided, the complete replacement of entire tanks and sections of structural support are large- scale projects, both with respect to time and material. In addition, you specifically state that the work being performed on both the steel tanks and the structural steel supports was undertaken because both had already reached a state of failure. The act of completely replacing the deteriorated tanks and support structures is an activity that goes beyond mere "refurbishment" and requires constructing replacements for structures (tanks) and plant components (structural supports). Also, unlike the scenario of replacing a single utility pole in a system of hundreds of poles, the tank replacements you describe form a significant portion of the system involved -- a system that will be significantly disrupted due to the work. Taking these factors together, the act of replacing the tanks and supports would be considered construction work under 29 CFR (g) and (b).55

Multi-employer Jobsite Policy Controlling Creating Correcting Exposed Fall into one of the four categories and a company can be equally cited for the apparent violation/hazard ECTIVES&p_id=2024

What issues do we see… Site specific safety and health programs: Not site specific MSHA BBP Respiratory Electrical Excavation Hazard Communication

What we see cont’d…. BBP – no training – no hep “b” offereing Annual training Respiratory Training – fit test – medical eval Fall Protection Construction or General Industry or (c)(1) Training Cranes (Construction) Qualified or certified operator Qualified rigger Certified Hand Signal Person Site ownership – ground conditions

What we see cont’d… Confined space Employer not providing information to contractor about the space LO/TO What is required before entering where it is a permit or non-permit required confined space Lockout/Tagout Training Whether or not employer is requiring contractor to use site’s or his own Regardless affected employees must know

What is a site to do???? Pre-plan the activity with key personnel where work is to be conducted Assign a Safety Rep/Committee member to the contractor Provide Hazard Recognition training though Review the site specific safety and health program for applicability to work activity Develop a checklist of typical hazards that are found on these types of operations

What is a site to do cont’d… Federal OSHA website has OSHA Publications blications/publication.html asdf

INCENTIVE PROGRAMS FOR CONTRACTORS Recent findings at VPP sites Resident Contractor 250 every month that they go without an injury/illness Time off for not having injury/illness Non-Resident Contractor Bonus for completion of site without injury/illness All receive just for not having KEY IS IF THEY HAVE IT IN THEIR S & H PROGRAM IT WILL FOLLOW TO YOUR SITE

How to have an incentive program that is not a disincentive? Promote active involvement with the safety and health program to receive incentive New employee orientation Training Promote active employee involvement that recognizes hazards and therefore an incentive may be awarded

Thank You & Any Questions?

ADOSH Happenings….. Heat Stress Awareness Water Rest Shade FEDERAL OSHA SITE Residential Fall Protection SB 1441 – Residential Construction ONLY No Residential Alike FEDERAL OSHA SITE Nail Gun Safety Publication Hazard Communication/GHS ADOSH Training FEDERAL OSHA SITE Nursing Home NEP Letters by our Office/Nationally ADOSH Training FEDERAL OSHA SITE Toll-Free Telephone Number

SB 1441 Residential Fall Protection Residential Construction Only ADOSH will not use (b)(10), (b)(11) and (b)(13) to address fall hazards in residential construction Outreach-Training Bill Cooper – training and speeches ADOSH Advocate Article

Federal OSHA Site English & Spanish Posters Fact Sheet Videos Fall Hazards in Construction PLAN – PROVIDE – TRAIN s/index.html

ADOSH Happenings…. Heat Stress Awareness Water/Rest/Shade Recognize the signs and symptoms Develop a procedure for employees to use when they suspect another employee of having a heat related issues LTC/heatillness/index. html

Federal OSHA site English & Spanish Posters Heat Prevention Lesson Plan Smartphone App Wallet Card Quick Cards Fact Sheet OSHA-NIOSH Heat Illness Info Sheet All May Be Downloaded for Free eatillness/edresources.html

Federal OSHA site Frequently Asked Questions Fact Sheet Quick Cards com/index.html

Federal OSHA site Hazards & Solutions Nursing Home etool Enforcement Procedures Safety & Health Programs rsinghome/index.html

ADOSH Standard Updates CPL “Enforcement Procedures for Investigating Workplace Violence Incidents” Adopted 11/19/11 CPL “Compliance Policy for Manufacturing, Storage, Sales, Handling, Use, and Display of Pyrotechnics” Adopted 11/19/11 National Emphasis Chemical Facilities NEP for chemical facilities to protect workers from catastrophic releases of highly hazardous chemicals Inspections in workplaces that are covered by OSHA’s process safety management (PSM) standard. National Emphasis on Nursing Homes Hazard Communication/GHS

HAZARDS…….

Multi-employer Jobsite Policy Controlling Creating Correcting Exposed Fall into one of the four categories and a company can be equally cited for the apparent violation/hazard ECTIVES&p_id=2024http:// ECTIVES&p_id=2024

Health Hazards cont’d Hazard Communication (e)(1) Employers shall develop, implement, and maintain at each workplace, a written hazard communication program which at least describes how the criteria specified in paragraphs (f), (g), and (h) of this section for labels and other forms of warning, material safety data sheets, and employee information and training will be met, and which also includes the following: MSDS Chemical Labeling Training PPE

Common Hazards…. Compressed gases Secured Machine guarding Rotating belts & pulleys

Common Hazards cont’d Training/Fit Test/Medical Evaluation Maybe Voluntary Faceplate missing

Hazards cont’d…. Fire Extinguishers Exits Fire Sprinklers PPE

Typical Violations cont’d…

What we see….

ADOSH Fatalities/Accidents

ADOSH Fatalities/Accidents cont’d… June ‘11 – Present One employee was working inside a large air handling unit and was electrocuted when he made contact with the energized duct heater coils Victim was driving a Honda Rancher four wheel recreational vehicle on a dirt road, he had crossed a public highway, and struck a metal cable at the neck level while crossing a cattle guard One employee was fatally injured when he fell from a 29’ high concrete tile roof One employee was fatally injured when he fell from a 10’ high ladder One employee passed out from heat exhaustion while installing handrails One employee was injured when he fell 34’ from a steel joist One employee was fatally injured when he fell from a fixed ladder 18’ above the ground level One employee was fatally injured when he fell from a 15’ high residential roof One employee was fatally injured when he fell from a television cable ladder 17’ above the ground level

ADOSH Fatalities/Accidents cont’d… More than 3 employees taken to hospital for ammonia exposure One employee was crushed by pallet of material when unloading from a semi- trailer with a forklift One employee amputated finger One employee was crushed by a granite slab ** MOST OF FATALITIES/ACCIDENTS INVOLVE A FALL FROM HEIGHT**

Consultation & Training

ADOSH Safety Summits Tucson March ‘13 Prescott Second Quarter East Phoenix Third Quarter Kingman Fourth Quarter

How May We Help You? Free Onsite Training and Education No citations or penalties Site training where 10 or more employees exist Voluntary programs RRAP – 6 Employers SHARP – 22 Employers VPP/C-VPP – 32 Employers Phoenix Spanish/English Training Safety and Industrial Hygiene Tucson Spanish/English Training Safety and Industrial Hygienists

ADOSH Consultation & Training: Tucson: Phoenix: Toll Free #: ICA & ADOSH Homepage: ADOSH Advocate (free quarterly newsletter) ADOSH Training Schedule (free OSHA classes) Assistance

Thank You & Any Questions?