OSHA Update 2015 Jim Lutz Milwaukee Area OSHA Office August 2015

Topics What’s New? What’s New? Regulatory Agenda Regulatory Agenda Initiatives and Emphasis for 2015 Initiatives and Emphasis for 2015 Inspections and Inspection Data Inspections and Inspection Data Frequently Cited Standards Frequently Cited Standards Resources Resources

New OSHA Topics Updates to OSHA’s Recordkeeping and Reporting Rule OSHA has expanded the list of severe injuries & illnesses that employers must report & updated the list of industries who are partially exempt from routinely keeping OSHA records. The Final rule became effective January 1, 2015 for workplaces under Federal OSHA jurisdiction.

Expanded Reporting Requirements The rule expands the list of severe work-related injuries and illnesses that all covered employers must report to OSHA. Starting January 1, employers must report the following to OSHA: All work-related fatalities within 8 hours (same as current requirement) All work-related fatalities within 8 hours (same as current requirement) All work-related in-patient hospitalizations of one or more employees within 24 hours All work-related in-patient hospitalizations of one or more employees within 24 hours All work-related amputations within 24 hours All work-related amputations within 24 hours All work-related losses of an eye within 24 hours All work-related losses of an eye within 24 hours

Expanded Reporting Requirements If the injury or illness resulted in a fatality, hospitalization, amputation or loss of an eye, report to OSHA. If you are in an industry covered by OSHA’s updated recordkeeping requirements, also make a record of the injury or illness in the OSHA 300 Log.

By telephone to the nearest OSHA office during normal business hours. By telephone to the nearest OSHA office during normal business hours. By telephone to the 24-hour OSHA hotline ( OSHA or ). By telephone to the 24-hour OSHA hotline ( OSHA or ). Online: OSHA is developing a new means of reporting events electronically, which will be available soon at Online: OSHA is developing a new means of reporting events electronically, which will be available soon at How can Employers Report to OSHA?

OSHA’s Spring 2015 Regulatory Agenda Available at Reginfo.gov

Walking/Working Surface – SubPart D Walking/Working Surface – SubPart D Silica Silica Electronic Recordkeeping Electronic Recordkeeping From Washington Regulatory Agenda Current Focus

Sub-Part D - Walking Working Surfaces Proposed General Industry Walking-Working Surfaces: prescribes the use of fall protection systems to protect employees from falls. Performance-oriented standard 15 new ANSI standards being cited are designed to eliminate detailed specifications and facilitate compliance Proposed paragraph (a)(2) requires that each employee be trained by a qualified person on the nature of hazards and protective methods Includes walki ng/working surfaces such as rolling stock (trucks)

Silica Rule Workers can become ill if they inhale respirable crystalline silica Proposed Respirable particles are very small (1/100th the size of a grain of sand) Can penetrate deeply into the lungs Can’t be seen or smelled and must be measured using air sampling equipment

Silica Rule  Establishes new PEL of 50 μg/m 3  Includes provisions for: Measuring worker exposures to silica; Measuring worker exposures to silica; Limiting access to areas where workers could be exposed above the PEL; Limiting access to areas where workers could be exposed above the PEL; Use of dust controls; Use of dust controls; Use of respirators when necessary; Use of respirators when necessary; Medical exams for highly exposed workers; Medical exams for highly exposed workers; Worker training; and Worker training; and Recordkeeping. Recordkeeping. Proposed

Electronic Recordkeeping Rule New Recordkeeping Rule will require employers to: Submit specific injury and illness data electronically; On a quarterly or annual basis; Data will be posted in an online publicly searchable database. Under the rule, establishments with 250 or more employees will be required to submit injury and illness records on a quarterly basis to OSHA. Establishments with 20 or more employees in industries with high injury and illness rates (construction), will be required to submit a summary of their work-related injuries and illnesses electronically once a year. Proposed

Updated Beryllium Standard Proposed OSHA’s eight-hour permissible exposure limit for beryllium is 2.0 micrograms per cubic meter of air. Above that level, employers must take steps to reduce the airborne concentration of beryllium. OSHA’s proposed standard would reduce the eight-hour permissible exposure limit to 0.2 micrograms per cubic meter. The proposed rule would also require additional protections, including personal protective equipment, medical exams, other medical surveillance and training. Workers exposed to beryllium are in foundry and smelting operations, machining, beryllium oxide ceramics and composites manufacturing and dental lab work.

What Became Long-Term Action Injury and Illness Prevention Program Injury and Illness Prevention Program Combustible Dust Rulemaking Combustible Dust Rulemaking Backover Rules Backover Rules

HazCom 2012 Implementation Phase The major change is a switch from performance oriented requirements to specific requirements. Former Hot Topic

OSHA Briefs/Compliance Guide

Confined Spaces in Construction What’s New? Subpart AA – OSHA Construction Standards

Why do we have a new standard? Confined space hazards have led to numerous worker deaths: A worker lost consciousness, fell, and was killed while climbing down a ladder into an unventilated underground valve vault to turn on water valves. A worker who lost consciousness and died when he climbed into a sewer vault to retrieve a tool. His co- worker also died when he attempted a rescue. While repairing a natural gas leak, a worker entered a drainage pipe to retrieve survey equipment. The natural gas ignited, killing the worker.

Subpart AA Scope Subpart P still covers work in excavations Subpart P still covers work in excavations If there is a confined space within an excavation, such as a sewer pipe, and a worker enters the pipe to perform work, that is covered by Subpart AA If there is a confined space within an excavation, such as a sewer pipe, and a worker enters the pipe to perform work, that is covered by Subpart AA Subpart S still covers underground construction Subpart S still covers underground construction Work done in an underground space that does not involve altering the *structure* of the space is covered by Subpart AA (such as equipment installs) Work done in an underground space that does not involve altering the *structure* of the space is covered by Subpart AA (such as equipment installs)

Subpart AA Scope GI Standard, Plus A competent person must conduct worksite evaluation Employers using “alternate procedures” for permit space entry must prevent physical hazard exposures through elimination or isolation through methods such as LOTO Permits may be suspended instead of cancelled, provided the space is returned to permit conditions prior to re-entry

Subpart AA Scope, continued Continuous monitoring of atmospheric and engulfment hazards Continuous monitoring of atmospheric and engulfment hazards Employers relying on local emergency services for rescue must arrange for responders to notify in advance if local responders will be unavailable Employers relying on local emergency services for rescue must arrange for responders to notify in advance if local responders will be unavailable Specific information exchange requirements for multi-employer work sites Specific information exchange requirements for multi-employer work sites

Multi-Employer Worksites The Controlling Contractor, rather than the Host Employer, is the primary point of contact for information about permit spaces at the work site. The Host Employer must provide information it has about permit spaces at the work site to the Controlling Contractor, who then passes it on to the employers whose employees will enter the spaces (Entry Employers).

Definitions Confined Space: Confined Space: Is large enough for a worker to enter it; Is large enough for a worker to enter it; Has limited means of entry or exit; and Has limited means of entry or exit; and Is not designed for continuous occupancy. Is not designed for continuous occupancy. Permit-Required Confined Space: Permit-Required Confined Space: has a hazardous atmosphere, the potential for engulfment or suffocation, a layout that might trap a worker through converging walls or a sloped floor, or any other serious safety or health hazard. has a hazardous atmosphere, the potential for engulfment or suffocation, a layout that might trap a worker through converging walls or a sloped floor, or any other serious safety or health hazard.

Confined Space Hazards Atmospheric (respirable) hazards, such as hydrogen sulfide, carbon monoxide, low oxygen, excessive oxygen, and other toxic gases and particulates Atmospheric (respirable) hazards, such as hydrogen sulfide, carbon monoxide, low oxygen, excessive oxygen, and other toxic gases and particulates Explosive hazards, including flammable gases in concen- trations above 10% of the lower explosive limit (LEL), combustible dusts, and other explosive/flammable materials Explosive hazards, including flammable gases in concen- trations above 10% of the lower explosive limit (LEL), combustible dusts, and other explosive/flammable materials Physical hazards, including tripping hazards, fall hazards, struck-by hazards, and electrical hazards Physical hazards, including tripping hazards, fall hazards, struck-by hazards, and electrical hazards

Don’t Forget Biological Hazards

What are Employers Responsible for? Employers must determine whether confined spaces exist at the work site. Under the construction rule, a competent person must identify all confined spaces. Under the construction rule, a competent person must identify all confined spaces. The competent person must also identify all permit spaces – those workers who will enter, and those that will not. All permit spaces must be posted/identified in some way. The competent person must also identify all permit spaces – those workers who will enter, and those that will not. All permit spaces must be posted/identified in some way.

What must employers do? cont'd Next, an employer who has determined that workers will perform work in permit spaces must develop a permit space program. Appendix C - Examples of Permit-Required Confined Space Programs Next, an employer who has determined that workers will perform work in permit spaces must develop a permit space program. Appendix C - Examples of Permit-Required Confined Space Programs If workers will not perform work in permit spaces, the employer must ensure that the workers are prevented from entering the permit spaces. If workers will not perform work in permit spaces, the employer must ensure that the workers are prevented from entering the permit spaces.

What is a Permit Space Program? A Permit Space Program is a plan that includes: Identification and evaluation of the hazards in the permit space Identification and evaluation of the hazards in the permit space Measures that will be used to prevent unauthorized entry Measures that will be used to prevent unauthorized entry Means, procedures, and practices needed for safe entry, including: … Means, procedures, and practices needed for safe entry, including: …

Permit Space Program Specify acceptable entry conditions, including but not limited to; Specify acceptable entry conditions, including but not limited to; Atmospheric conditions such as oxygen levels, explosive substance limits, toxic substance limits Atmospheric conditions such as oxygen levels, explosive substance limits, toxic substance limits When and how the employer will provide each authorized entrant or their representative the chance to observe monitoring or testing of permit spaces; When and how the employer will provide each authorized entrant or their representative the chance to observe monitoring or testing of permit spaces; How the employer will isolate the permit space and physical hazards within the space, if needed; How the employer will isolate the permit space and physical hazards within the space, if needed;

Program Elements, cont'd Whether and how the employer will purge, inert, flush, or ventilate the permit space to eliminate or control atmospheric hazards; Whether and how the employer will purge, inert, flush, or ventilate the permit space to eliminate or control atmospheric hazards; Specify the use of a monitoring system or procedures that will detect hazardous changes in atmospheric conditions in time for entrants to safely exit the space; Specify the use of a monitoring system or procedures that will detect hazardous changes in atmospheric conditions in time for entrants to safely exit the space; Discuss the barriers that will be used to prevent entrants from external hazards and unauthorized entry; Discuss the barriers that will be used to prevent entrants from external hazards and unauthorized entry;