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Environmental Health and Safety Committee 4-30 Health & SAFETY Update Lee Wilmot TTM Technologies April 2009
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Health & SAFETY Update 2007 BLS Injury Rate Data Review OSHA Citations for PCB & PCBA Latest Inspections Regulatory Agenda Actions
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Health & SAFETY Update BLS Injury Data While injury rates are prime focus, the BLS database contains average employment data by industry Industry2004200520062007 Goods Producing 22.656M22.897M23.285 M23.501M 334 Computer & electronic products 1.315M1.311M1.305M1.294M 334412 PCB Manufacturing 63.1K60.5K57.9K55.5K 334419 PCBA Assembly - 52.8K56.4K
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Health & SAFETY Update BLS Injury Rates
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Health & SAFETY Update OSHA Citations Oct’07 to Sept’08 SIC 3672 Printed Circuit Boards 17 inspections down from 12, 13, 18 & 21 in prior years 86 citations down from 65, 63, 88 & 123 in prior years $24,262 in penalties Down from $21.6K, $145K, $26,5K & $69K SIC 3679 Electronic Components 32 inspections 172 citations $91,213 in penalties
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Health & SAFETY Update OSHA Citations Oct’07-Sept’08 SIC 3672 Top Standards Cited (Inspections/ Citations/ $ Penalties) Hazard Communication 8 / 14 / $5720 >> Compares to 8/19/$5960 06-07 and 5/9/$2400 05-08 Respiratory Protection 4 / 13 / $1990 >> Compares to 7/23/$9668 06-07 and 2/5/$425 05-06 Spraying Flammable Liquids 2 / 5 / $1670 – 1 st time in top five Lead 5 / 5/ $338 >> Down from 6 / 11/ $3660 in 06- 07 but about same as 3/5/$1750 in 05-06
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Health & SAFETY Update OSHA Citations Oct’07-Sept’08 SIC 3679 Top Standards Cited Inspections/Citations/$Penalty Wiring 12/ 20/ $7213 >> New to top 5 Respiratory Protection 6 / 18/ $6385 v 6 / 12/ $4206 in 06-07 LockOut / TagOut 10/16/$8099 v 6/12/$$6825 in 06-07 Machine General Req’ts 8 / 12 / $7085 >> New to top 5 Wiring General Req’ts 10 / 11 / $6508
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Health & SAFETY Update OSHA Inspections of 3672 plants OSHA inspections of PCB industry during CY2008 46 total, versus 25 in ’07, 48 in ‘06 & 46 in ‘05 23 complaints – versus 13 in ’07 & 26 in ‘06 18 planned inspections, versus 6 in ’07 & 17 in ‘06 1 referral, versus 4 in ‘07; only 1 accident 14 complete inspections; 21 partial and 1 records 146 violations, versus 65 in ’07, 189 in 2006 and 107 in 2005 violations
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Health & SAFETY Update OSHA Inspections Notable OSHA inspections of 3672 shops in CY2008 16 violations at CA plant (complaint, partial) in Sept 11 violations at GA plant (complaint, complete) Feb 11 violations at CA plant (complaint, partial) in Mar. 11 violations at MN plant (planned, complete) in Oct 9 violation at WI plant (complaint, partial) in April 7 violations at CO plant (planned, complete) in Jan. 7 violations at OK plant (complaint, partial) in March
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Health & SAFETY Update OSHA Inspections - 334418 plants OSHA inspections of PCBA industry during CY2008 61 total, versus 9 in ’07, 14 in ‘06 and 17 in ‘05 23 complaints v 6 in ’07, 7 in ‘06 and 5 in ‘05 30 planned inspects v 2 in ’07, 4 in ‘06 & 8 in ‘05 1 accident v 1 in ’07, 0 in ‘06 and 1 in ‘05 14 complete inspections v 1 in ’07, 5 in ‘06 and 7 in ‘05 212 violations, versus 27 in ’07, 14 in ‘06 & 26 in ‘05
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Health & SAFETY Update OSHA Inspections OSHA inspections of 334418 plants in 2008 14 violations at IL plant (referral, partial) in March 7 violations at PA plant (planned, complete) in Nov 5 violations at OR plant (planned, complete) in Dec 4 violations at FL plant (referral, partial) in Sept 3 violations at MA plant (complaint, partial) in Feb.
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Health & SAFETY Update OSHA Semiannual Regulatory Agenda Agenda Published 11/24/2008 Completed Rules Employer Provided PPE & Training Employees Adopt Nat’l Consensus Stds for C2H4 & PPE Proposed Rule Stage Abbreviated Portacount Quantitative Fit Testing Haz Com >> Global Harmonization System Walking Working Surfaces & Fall Protection Prerule Stage Emergency Response & Prepardness Update Standard for Power Presses Methylene Chloride
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Health & SAFETY Update OSHA Regulatory Completed Rules Clarify Employer Duties to Provide PPE and Train Employees Clarifies OSHA’s ability to issue per instance violations for each employee not provided required PPE or train employees in proper PPE use. Final Rule published December 2008
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Health & SAFETY Update OSHA Semiannual Regulatory Agenda Completed Actions Adopt Consensus National Standards OSHA plans direct final rule (DFR) covering updates to nat’l standards for Referenced for acetylene PPE Final Rule planned December 2008 Abbreviated Quantitative Fit Testing Adopts current fit testing technology Test reduced 8 to 6 and 60 sec to 40 sec Proposed rule published 1/21/2009
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Health & SAFETY Update OSHA Semiannual Regulatory Agenda Proposed items Update of Walking Working Surfaces and Fall Protection Standards Current standards do not include available technologies & procedures to protect EEs from slip, trip & fall hazards NPRM and hearing in 1990. Re-opened record in 2003. Comment period ended 7/31/2003. Second NPRM projected in March 2009 Hazard Communication Adopt Global Harmonization System
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Health & SAFETY Update OSHA Semiannual Regulatory Agenda Pre-Rule Stage Update Standards for Power Presses Expands rule to cover hydraulic and pneumatic presses Emergency Response & Prepardness Current stds do not include updates adopted by NFPA and ANSI Methylene Chloride (1910.1052) Began review 12/01/06. Stakeholder meetings projected April 2007. Request for comments on 7/10/07
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Health & SAFETY Update Keep in Touch with EHS Issues Visit the Website at www.ipc.org under “Legislative and Regulatory Affairs” Subscribe to the EHS Update Join Compliance Net email forum Contact: Fern Abrams, IPC Director of Environmental Policy (703) 522-0225, fabrams@ipc.orgfabrams@ipc.org Or Lee Wilmot, EHS Committee Chairman (860) 870-2639, lee.wilmot@ttmtech.comlee.wilmot@ttmtech.com Or Kelly White, EHS Committee Vice-Chairman (727) 803-7560, Kelly_White@Jabil.comKelly_White@Jabil.com
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