COMPLIANCE WITH OSHA HEALTH STANDARDS: OVERVIEW ART WICKMAN, CIH GEORGIA TECH’S SAFETY AND HEALTH CONSULTATION PROGRAM

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 Communication Standard 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 äemployers äemployees

6 Basic Program Elements Chemical Hazard Inventory MSDS’s Labeling Employee Training Contractor Training Written Program HCP

Global Harmonization Final Standard: March 2012 Implementation Period: December 2013 through June 2016 Hazard Communication Changes – Labels, Pictograms – Safety Data Sheets – Employee Training

Principles Of Harmonization Comprehensible Information (both intra- and inter-nationally) All hazardous materials systems will be harmonized across agencies: OSHA, Cons. Protect. Agen., EPA, DOT Warnings conveyed in both words and pictures Warnings are based on intrinsic hazards of chemicals Consistent classification of Severity

Four Major Changes in GHS 1.Hazard Classification (changed from hazard determination) 2.Labels 3.Safety Data Sheets (changed from MSDS) 4.Information and Training Will affect nearly 40 million workers and 5 million workplaces. 9

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) Re-monitoring  required if changes in process or layout indicate exposures could be > 85 dBA  Recommend periodic remonitoring

Hearing Conservation Program: 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 Annual Audiograms Standard Threshold Shifts Documentation and Notification Letters OSHA 300 Hearing Loss Records Retain original hearing test records if changing audiometric providers.

AIR CONTAMINANTS Compliance with OSHA Health Standards

IH Air Contaminant Nomenclature 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 Hazards Plant layout and chemical flow Observe air flow patterns Observe job activities of a work area Study existing control measures Prioritize based on degree of hazard to workers and potential to do harm

Anticipate Potential Hazards (cont.) Understand the processes toxic chemicals present in raw materials by-products of chemical reactions by-products of work processes – Ex: chlorinated solvents for metal cleaning followed by welding (phosgene gas)

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 – Ex: 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 Etc, etc

Time-Weighted Average (TWA) Exposure TIME (min) PPM Example: Acetone, PEL = 1000 PPM, TWA TWA = 200 ppm

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)

RESPIRATORY PROTECTION Compliance with OSHA Health Standards

“And so you just threw everything together?… Matthews, a posse is something you have to organize.” Must Have a Respirator 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

Respirator Program Must be a written program with worksite- specific procedures Evaluate and update program as necessary – Per changes in the workplace Note: OSHA has prepared a Small Entity Compliance Guide that contains criteria for selection of a program administrator and a sample program.

PERSONAL PROTECTIVE EQUIPMENT Compliance with OSHA Health Standards

Personal Protective Equipment PPE HAZARD ASSESSMENT SURVEY Job/Task Evaluated:________________________ Date(s): _____________________ Conducted By:_________________________________ (Name and Title)

PPE Hazard Assessment

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.

Summary (OSHA Health Standards Overview) Hazard Communication (Chemical) Hearing Conservation Air Contaminants – Permit-Required Confined Spaces Respiratory Protection Personal Protective Equipment First Aid & Bloodborne Pathogens