Pennsylvania Cooperative Education Conference Dale Glacken, Compliance Assistance Specialist October 16, 2008 Student Safety in Work-Based Education

Goals for this session Review OSHA purpose Look at where our accidents are occurring Discuss Ch 339 Review the Layout of OSHA Standards See what OSHA has been finding Top 10 List STAR Hazard Analysis Brief look at OSHA resources Questions and Answers

What does OSHA mean to you?

OSH Act of 1970 PURPOSE: "... to assure so far as possible every working man and woman in the Nation safe and healthful working conditions and to preserve our human resources."

OSHA and Pennsylvania Department of Education Prepare Youth for Safe Work Experience

§ 339.1a. Definitions. (a) The definitions in § 4.3 (relating to definitions) apply to this chapter. (b) The following words and terms, when used in this chapter, have the following meanings, unless the context clearly indicates otherwise: Diversified occupations program—A planned vocational program, which may be offered at either the AVTS or a comprehensive high school. The program prepares students from more than one vocational education area of instruction for gainful employment. The program is a partnership between a local business and industry and the school entity. A full range of career competencies are developed at the job training station site. The school, in a classroom setting, provides related academic and technical instruction, including safety.

§ Satellite program. A satellite vocational education program is a program established, maintained and administered by an area vocational-technical board in a participating school district facility as an integral part of the AVTS. The requirements for satellite programs are: (1) AVTS requirements. In school districts having approved satellite programs, the area vocational-technical board shall be required to: (i) Maintain school/industry articulation. (ii) Supervise vocational student organization activities. (iii) Conduct vocational advisory committee activities. (iv) Periodically review vocational education program needs in the attendance area and develop recommendations for continued growth and expansion of a coordinated vocational education system. (v) Develop recommendations that assist students in meeting their career needs without regard to sex, race or disability. (vi) Ensure that a program of safety is incorporated into the curriculum.

§ Vocational education safety. Vocational education shall be provided consistent with safety standards in the following areas: (1) Safety instruction shall be practiced in the laboratory and classroom. (2) Equipment guards and personal safety devices shall be in place and used. (3) Class enrollment shall be safe relative to classroom or laboratory size and number of workstations. (4) Workstations shall be barrier-free, assuring accessibility and safety under section 504 of the Rehabilitation Act of 1973 (29 U.S.C.A. § 794) and 34 CFR (a) (relating to existing facilities) and the Americans With Disabilities Act of 1990 (42 U.S.C.A. § § 12101—12213).

§ Vocational education safety. (cont.) (5) Provisions shall be made for safe practices to meet individual educational needs of handicapped persons under section 504 of the Rehabilitation Act of 1973, 34 CFR (b) (relating to free appropriate public education), OCR Guidelines, Title VI of the Civil Rights Act of 1964 (42 U.S.C.A. § § 2000d—2000d-4a) and 45 CFR Part 80 (relating to nondiscrimination under programs receiving Federal assistance through the Department of Health and Human Services effectuation of Title VI of the Civil Rights Act of 1964). (6) Storage of materials and supplies must meet 34 Pa. Code Part I (relating to Department of Labor and Industry). (7) Safety practices must meet State and Federal regulations.

FACILITIES § Learning environment. The requirements for the learning environment are as follows: (1) Size of laboratory. Shop laboratory size must be adequate as required by State licensing boards, accreditation providers and industry certification standards and take into consideration the recommendations of the occupational advisory committee. (2) Type of equipment. Refer to § 339.4(b)(5) (relating to program approval) for requirements related to equipment. (3) Number of workstations. Students assigned may not be greater than the number of workstations available. (4) Safety of students. Refer to § (relating to vocational education safety) for safety of students requirements.

OSHA Standards 29 CFR Part 1910 General Industry Part 1917 Marine Terminals Part 1918 Longshoring Part 1915 Shipyards Part 1908 Consultation Part 1926 Construction Part 1928 Agriculture Part 1904 Recordkeeping Part 1903 Inspections 5(a)(1)

Standards are Promulgated Notice of Proposed Rulemaking or Advance Notice of Proposed Rulemaking Draft Standard or Proposed Rule Final Standard or Rule 1911 Rules of Procedure for Promulgating, Modifying or Revoking OSHA Standards

Origin of OSHA Standards Consensus - Industry-wide Organizations ANSI or NFPA Proprietary - Societies or Associations Nat’l Grain Handlers Association Compressed Gas Association Page 1

Code of Federal Regulations (CFR), Select Titles (1 – 50) Title 1The President Title 10Energy (NRC) Title 29Labor (OSHA) Title 30Mineral Resources (MSHA) Title 40Protection of Environment (EPA) Title 42Public Health Title 49Transportation (DOT)

Parts of OSHA Standards (Select Title 29 CFRs) 1903Inspections, Citations and Proposed Penalties 1904 Recording and Reporting Occupational Injuries and Illnesses 1908 Consultation Agreements 1910 Occupational Safety and Health Standards (General Industry) 1917 Maritime 1926 Safety and Health Regulations for Construction 1928 Agriculture

1910 General Industry Subparts Subpart D -Walking-Working Surfaces Subpart E -Means of Egress Subpart F -Powered Platforms & Manlifts Subpart G -Health/Environmental Control Subpart H -Hazardous Materials Subpart I -Personal Protective Equipment Subpart J -Environmental Controls Subpart K -Medical and First Aid Subpart L -Fire Protection

1910 General Industry Subparts Subpart M -Compressed Gas and Air Equipment Subpart N -Materials Handling and Storage Subpart O -Machinery and Machine Guarding Subpart P -Hand and Portable Powered Tools Subpart Q -Welding, Cutting and Brazing Subpart R - Special Industries Subpart S - Electrical Subpart T - Commercial Diving Operations Subpart Z - Toxic and Hazardous Substances

1926 Construction Subparts Subpart C -General Safety and Health Provisions Subpart D -Occupational Health and Environmental Controls Subpart E -Personal Protective and Lifesaving Equipment Subpart F -Fire Protection and Prevention Subpart G -Signs, Signals, and Barricades Subpart H -Materials Handling, Storage, Use, and Disposal Subpart I -Tools – Hand and Power Subpart J -Welding and Cutting Subpart K -Electrical Subpart L -Scaffolds Subpart M -Fall Protection Subpart N -Cranes, Derricks, Hoists, Elevators, and Conveyors Subpart O -Motor Vehicles, Mechanized Equipment, and Marine Operations

1926 Construction Subparts Subpart P -Excavations Subpart Q -Concrete and Masonry Construction Subpart R -Steel Erection Subpart S -Underground Construction, Caissons, Cofferdams, and Compressed Air Subpart T -Demolition Subpart U -Blasting and the Use of Explosives Subpart V -Power Transmission and Distribution Subpart W -Rollover Protective Structures: Overhead Protection Subpart X -Stairways and Ladders Subpart Y -Diving Subpart Z -Toxic and Hazardous Substances

30 OSHA Most Frequently Cited Serious Violations General Industry - FY-2006

31 Most Frequently Cited Serious Violations in General Industry FY 2006 Machine Guards - General Eye & Body Flushing Facilities Point of Operation Open-Sided Floors Conductors Entering Cabinets/Boxes/Fittings Protected from Abrasion Lockout/Tagout - Program Grinders-Tongue Guards Hazard Communication – Information & Training Note: There were also 1222 Section 5(a)(1) General Duty Clause violations cited for all inspections during this period. Lockout/Tagout - Procedures Hazard Communication – Written Program

32 Subpart D - Walking/Working Surfaces ( ) Open-sided floors Housekeeping Wet floors Stair railings Floor holes Standard: 1910.

33 Subpart E – Exit Routes, Emergency Action Plans, and Fire Prevention Plans ( ) Exit route doors unlocked Exit marking Exit access signs Standard: “Not an Exit” signs Exit routes free & unobstructed

34 Subpart F - Powered Platforms ( ) Trained operators for aerial lift Standard: Body belt & lanyard when working from aerial lift Secure work position for employees in basket

35 Subpart G - Occupational Health ( ) Hearing conservation program Administrative/Engineering controls Standard: Audiometric testing program Training program Monitoring program

36 Subpart H - Hazardous Materials ( ) Standard: Spray booth – Air velocity Class I liquids - Dispensing Compressed gases - Handling, storage & use Spray areas – Approved wiring & equipment Sources of ignition - Precautions

37 Subpart I - Personal Protective Equipment ( ) Personal protective equipment Eye & face protection PPE hazard assessment Standard: Written respiratory protection program Medical evaluation to determine employee’s ability to use respirator

38 Subpart J - General Environmental Controls ( ) Lockout/Tagout - Program Lockout/Tagout - Training Lockout/Tagout - Procedures Lockout/Tagout - Content of energy control procedures Standard: Lockout/Tagout procedure - Periodic inspection

39 Subpart K - Medical & First Aid ( ) Eye & body flushing facilities First aid Standard: 1910.

40 Subpart L - Fire Protection ( ) Extinguishers - Training program Extinguishers - Initial & annual training Extinguishers - Provided & accessible Standard: Extinguishers - Annual checks Extinguishers – Charged & operable

41 Subpart M - Compressed Gas & Air Equipment ( ) Pressure gage/safety valve Safety valves tested Standard: 1910.

42 Subpart N - Materials Handling & Storage ( ) Standard: Powered Industrial Trucks – Operator competency Powered Industrial Trucks – Safe operating condition Secure storage Powered Industrial Trucks – Operator certification Powered Industrial Trucks – Examination for defects

43 Subpart O - Machinery & Machine Guarding ( ) Machine guards - General Grinders - Tongue guards Pulleys Point of operation Grinders - Work rests Standard: 1910.

44 Subpart P - Hand & Portable Powered Tools ( ) Compressed air for cleaning Portable grinders - Guards Standard: Condition of tools & equipment Portable grinders - General

45 Subpart Q - Welding, Cutting & Brazing ( ) Oxygen cylinder storage - Separation Cylinder storage - Inside of buildings Protection from arc welding rays Valve caps in place Arc welding/cutting - Maintenance of cables Standard: 1910.

46 Subpart R - Special Industries ( ) Standard: Logging – Foot protection Logging - First aid/CPR training current Logging – Written certification of training Logging – Face protection Logging – Employee training

47 Subpart S - Electrical ( ) Live parts Grounding path Electrical box covers Conductors entering cabinets/boxes/fittings protected from abrasion Standard: Proper installation & use of equipment

48 Subpart Z - Toxic & Hazardous Substances ( ) Hazard Communication - Written program Hazard Communication - Information & training Hazard Communication - Label identification Hazard Communication - Training initially & for new hazards Hazard Communication - Material Safety Data Sheets Standard: 1910.

Workers Compensation Insurance No fault remedy State specific law Purchased from carriers/state

Hazard Recognition Employer evaluation Self inspection / evaluation What is right from wrong Should not have to expose yourself to a hazard Common Sense, If it doesn’t feel right Tools to help when it is not obvious Can always ask if not sure Take care of yourself and others.

Priority Self Machine / Tools Final Product

STAR STOP THINK ACT RE-EVALUATE or Review

Overhead #15 Controlling Hazards Remove the Hazard (e.g., use safer chemicals) Work Policies and Procedures (e.g., assign enough people to do the job) Personal Protective Equipment (e.g., wear gloves, use a respirator) Training

JOB SAFETY ANALYSIS JOB: Sawing a board AUTHORIZED BY: DBG DATE: 3 Sept 2008 TASKHAZARDCONTROL 1. Stand in front of the saw table 2 REQUIRED TRAINING:REQUIRED PPE:

JOB SAFETY ANALYSIS JOB: Sawing a board AUTHORIZED BY: DBG DATE: 3 Sept 2008 TASKHAZARDCONTROL 1. Stand in front of the saw table 2 REQUIRED TRAINING:REQUIRED PPE: 1a. Tripping on Debris 1b. Slipping on the floor while cutting

JOB SAFETY ANALYSIS JOB: Sawing a board AUTHORIZED BY: DBG DATE: 3 Sept 2008 TASKHAZARDCONTROL 1. Stand in front of the saw table 1a. Tripping on Debris 1b. Slipping on the floor while cutting 2 REQUIRED TRAINING:REQUIRED PPE: 1b-1. Wear non-slip shoes 1b-2. Keep the floor dry 1b-3. Keep a rubber mat in front of the saw. 1a-1. Clear the floor

JOB SAFETY ANALYSIS JOB: Sawing a board AUTHORIZED BY: DBG DATE: 3 Sept 2008 TASKHAZARDCONTROL 1. Stand in front of the saw table 1a. Tripping on Debris1a-1. Clear the floor 1b. Slipping on the floor while cutting 1b-1. Wear non-slip shoes 1b-2. Keep the floor dry 1b-3. Keep a rubber mat in front of the saw. 2 REQUIRED TRAINING:REQUIRED PPE: Use of the Saw Lock out tag out

JOB SAFETY ANALYSIS JOB: Sawing a board AUTHORIZED BY: DBG DATE: 3 Sept 2008 TASKHAZARDCONTROL 1. Stand in front of the saw table 1a. Tripping on Debris1a-1. Clear the floor 1b. Slipping on the floor while cutting 1b-1. Wear non-slip shoes 1b-2. Keep the floor dry 1b-3. Keep a rubber mat in front of the saw. 2 REQUIRED TRAINING:REQUIRED PPE: Use of the Saw Lock out tag out Eye Protection Hearing Protection

JOB SAFETY ANALYSIS JOB: Sawing a board AUTHORIZED BY: DBG DATE: 3 Sept 2008 TASKHAZARDCONTROL 1. Stand in front of the saw table 1a. Tripping on Debris1a-1. Clear the floor 1b. Slipping on the floor while cutting 1b-1. Wear non-slip shoes 1b-2. Keep the floor dry 1b-3. Keep a rubber mat in front of the saw. REQUIRED TRAINING:REQUIRED PPE: Use of the SawEye Protection Lock out tag outHearing Protection Repeat for Step 2, and so forth

Picture of Student Shop JSAs

Top 10 most frequently cited standards in fiscal year Scaffolding, general requirements, construction (29 CFR )29 CFR Fall protection, construction (29 CFR )29 CFR Hazard communication standard, general industry (29 CFR )29 CFR Control of hazardous energy (lockout/tagout), general industry (29 CFR )29 CFR Respiratory protection, general industry (29 CFR )29 CFR Powered industrial trucks, general industry (29 CFR )29 CFR Electrical, wiring methods, components and equipment, general industry (29 CFR )29 CFR Ladders, construction (29 CFR )29 CFR Machines, general requirements, general industry (29 CFR )29 CFR Electrical systems design, general requirements, general industry (29 CFR )29 CFR

OSHA assessed the highest penalties in fiscal year Scaffolding, general requirements, construction (29 CFR )29 CFR Fall protection, construction (29 CFR )29 CFR Control of hazardous energy (lockout/tagout), general industry (29 CFR )29 CFR Excavations, requirements for protective systems, construction (29 CFR )29 CFR Machines, general requirements, general industry (29 CFR )29 CFR General duty clause (Section 5(a)(1) of the OSH Act)Section 5(a)(1) of the OSH Act 7.Powered industrial trucks, general industry (29 CFR )29 CFR Excavations, general requirements, construction (29 CFR )29 CFR Aerial lifts (29 CFR )29 CFR Guarding floor and wall openings and holes, general industry (29 CFR )29 CFR

Elements of a Comprehensive Safety and Health Management System Management Leadership and Employee Involvement Worksite Analysis Hazard Prevention and Control Safety and Health Training

Consultation reports generated: September 30, 2006 – Parameters: Private Sector, Closing Conference Date: October 1, 2005 – September 30, 2006 * Total includes 21(d) and 23(g) Consultation Project data

Aimed to help employers who want help in recognizing and correcting safety and health hazards and in improving their safety and health programs. Free, largely funded by OSHA Requirement: A commitment to correcting serious safety and health hazards Confidential, tailored to small business OSHA Consultation Service Indiana University of Pennsylvania

Safety and Health Achievement Recognition Program (SHARP) Contact Information: 1 – 800 – 382 – OSHA Consultation Service Indiana University of Pennsylvania

Screen capture of OSHA’s Training and Education Web page Training and Education Resources

After more than three decades, OSHA continues to offer extensive printed, electronic and face-to-face guidance to assist employers with all of their safety and health needs. For example, OSHA offers a free on-site consultation program to assist small businesses seeking to create and implement a safety and health program. In addition, the agency offers more than a dozen product lines to help keep employers and employees up-to-date on the latest issues in workplace safety and health. Our products include booklets, Pocket Guides and fact sheets, public service announcements, an electronic newsletter, and the OSHA website. The good news is this: it is all free. OSHA is committed to providing employers and employees with free and easy-to-read products. Our printed products are available simply by visiting OSHA’s publications page on the agency’s website at or they may be ordered through the OSHA publications office at from 9 a.m. – 5 p.m. (ET) Monday – Friday. (202) OSHA Product Lines and Services

OSHA RESOURCES Harrisburg Area Office: Full service area office Publications Audiovisual aids Technical assistance / Duty Officer Compliance Assistance

Pennsylvania OSHA Area Offices Allentown Area Office (610) Erie Area Office (814) Harrisburg Area Office (717) Philadelphia Area Office (215) Pittsburgh Area Office (412) Wilkes-Barre Area Office (570) Main OSHA Number: OSHA, Rev: 22 Sept 2006

Harrisburg Area Office (717) Duty Officer Hours 8:00 am - 4:30 pm Web Site: National Call Center: (800) 321-OSHA Additional Assistance

Questions and Answers