1. Nick Gleiter For Alliance Occupational May 16, 2012

2.  3203 – Injury and Illness Prevention Program  3395 – Heat Illness Prevention  342 – Reporting Serious Injuries/Illnesses & Fatalities  1509 – IIPP Construction  5194 – Hazard Communication

3.  461 – Permits to Operate Air Tanks  2340.12 – Open Electrical Boxes, Cabinets, Equipment  6151 – Portable Fire Extinguishers  2340.16 - Workspace About Electrical Equipment  5162 – Eyewash Stations  3314 – Control of Hazardous Energy….aka Lockout – Tagout  4070 – Guarding V-belts and Pulley Drives

4.  Went into effect July of 1991  The most cited Cal/OSHA regulation  Required of all employers in California  Employer must establish (written), effective, implement, and maintain

5. Element by Element

6.  Authority and Responsibility  Methods of Compliance  Communication  Hazard Assessment  Correction of Unsafe Conditions  Accident Investigations  Training  Recordkeeping ◦ Safety Committee ◦ Hazard assessment & correction ◦ Training

7. 1. 3203 (a) no program!!! 2. 3203 (a) (4) procedures for identify and evaluating workplace hazards/scheduled periodic inspections 3. 3203 (b) (2) documentation of training records 4. 3203 (b) (1) documentation of scheduled/periodic inspections

8. 5. 3203 (a) (6) Include methods/procedures for correcting unsafe/unhealthy conditions, work practices/procedures in a timely manner based upon severity of hazard. 6. 3203 (a) (7) Providing training and instruction 7. 3203 (a) (1) Identify the person (s) with authority and responsibility for implementing the Program 8. 3203 (a) (2) Include a system for ensuring that employees comply with safe and healthy work practices. Substantial compliance with this provision includes recognition of employees who follow safe and healthful work practices, training and retraining programs, disciplinary actions, or any other such means that ensures employee compliance with safe and healthful work practices.

9.  (a) Effective July 1, 1991, every employer shall establish, implement and maintain an effective Injury and Illness Prevention Program (IIPP). The Program shall be in writing and, shall, at a minimum:  (1) Identify the person or persons with authority and responsibility for implementing the Program.

10.  (2) Include a system for ensuring that employees comply with safe and healthy work practices. Substantial compliance with this provision includes: ◦ recognition of employees who follow safe and healthful work practices, ◦ training and retraining programs, ◦ disciplinary actions, or any other such means that ensures employee compliance with safe and healthful work practices.

11.  (3) Include a system for communicating with employees in a form ◦ readily understandable by all affected employees on matters relating to occupational safety and health, ◦ including provisions designed to encourage employees to inform the employer of hazards at the worksite without fear of reprisal. ◦ Substantial compliance with this provision includes  meetings,  training programs,  postings,  written communications,  a system of anonymous notification by employees about hazards, labor/management safety and health committees,  or any other means that ensures communication with employees.

12.  EXCEPTION: Employers having fewer than 10 employees shall be permitted to communicate to and instruct employees orally in general safe work practices with specific instructions with respect to hazards unique to the employees' job assignments as compliance with subsection (a)(3).

13.  (4) Include procedures for identifying and evaluating work place hazards including scheduled periodic inspections to identify unsafe conditions and work practices. Inspections shall be made to identify and evaluate hazards.  (A) When the Program is first established;

14.  (B) Whenever new substances, processes, procedures, or equipment are introduced to the workplace that represent a new occupational safety and health hazard; and  (C) Whenever the employer is made aware of a new or previously unrecognized hazard.

15.  (5) Include a procedure to investigate occupational injury or occupational illness. Find facts, not fault!!  Who (was involved, else was there, are they)?  What (was the condition, equipment, materials involved, known hazards) ?  Where (did it happen, layout, temperature, environmental conditions)?  When (was the accident reported, time, day, date)?  How (did it happen, answers clear, ask more questions to ensure clarity of response) ?  Why (evolves from all the above questions/answers)?

16.  (6) Include methods and/or procedures for correcting unsafe or unhealthy conditions, work practices and work procedures in a timely manner based on the severity of the hazard:  (A) When observed or discovered; and,

17.  (B) When an imminent hazard exists which cannot be immediately abated without endangering employee's and/or property, remove all exposed personnel from the area except those necessary to correct the existing condition. Employees necessary to correct the hazardous condition shall be provided the necessary safeguards.

18.  (7) Provide training and instruction: ◦ (A) When the program is first established; ◦ (B) To all new employees; ◦ (C) To all employees given new job assignments for which training has not previously been received;

19. ◦ (D) Whenever new substances, processes, procedures or equipment are introduced to the workplace and represent a new hazard; ◦ (E) Whenever the employer is made aware of a new or previously unrecognized hazard; and, ◦ (F) For supervisors to familiarize themselves with the safety and health hazards to which employees under their immediate direction and control may be exposed.

20.  Same above elements plus: ◦ Code of Safe Practices - develop and post ◦ Tailgate safety meetings every 10 work days

21. AB 2774 - Connection to IIPP  Employee and supervisor training relevant to preventing employee exposure to the hazard or similar hazards (IIPP element #7)  Procedures for discovering, controlling access to and correcting the hazard or similar hazards (IIPP elements #4, #5 and #6)  Supervision of employees exposed or potentially exposed (IIPP elements #1 and #2)  Procedures for communicating to employees about the employer’s safety rules and programs (IIPP element #3)

22. IIPP Fleet safety program Fork lift safety program HazCom Emergency action plan Responsible Compliance/disciplinary actions Communication Hazard Assessment (Inspections) Hazard Correction Accident Investigation Training and Instruction Recordkeeping

23.  Prevent confusion  Increase understanding  Increase accountability  Maintain continuity through staff changes  Specific to your work www.dir.ca.gov/DOSH/PubOrder.asp

26. Effective Cal/OSHA Injury & Illness Prevention Program The Big Binder Safety Program 9-1-1 Program Root Causes Found/Fixed Near-Hits investigated Affirmative Defense Program never leaves the office PPE is a cell phone Same accident happens over & over Safety in the job description Clear and concisely written IIPP Safety orientation for new hires Golden Gate Recognition Training to recognize/respond to hazards VPP Program VPP Program Routinely finding/fixing hazards Supervisors confront/correct unsafe actions System recognizes safe actions Records used to detect patterns/direct future efforts Employees report near-hits to mgmt. CDAA/BOI DOSH Tailgates have doughnuts

27. Important Requirements and Commonly Cited Violations

28.  Hazard Communication is a training regulation using material safety data sheets (MSDS) and labels to communicate the chemical and physical hazards that employees maybe exposed to in the work environment.

29.  (b) Scope and application  (c) Definitions  (d) Requirements for hazard determination  (e) Required elements for a written hazard communication program  (f) Requirements for proper labeling of containers

30.  (g) Requirements for material safety data sheets  (h) Requirements for employee information and training  (i) Requirements for disclosing information on substances that are considered trade secrets

31.  (1) Program must be written and address: ◦ Labels ◦ MSDSs ◦ Employee information and training  (1)(A) List of hazardous substances  (1)(B) Methods to inform employees ◦ Non-routine tasks ◦ Substances in unlabeled pipes

32.  (2) methods used to inform employees sharing work area with substances ◦ (A) to provide access to MSDSs ◦ (B) to inform employees of precautionary measures ◦ (C) to inform other employers of labeling system used in workplace  (3) Program is available upon request

33.  No written program at all, or has not been implemented  Written program not kept at workplace where substances are located  No hazardous substance inventory list  Written program has no provisions to address hazards of non-routine tasks  Not informing other employers at multi- employers sites and appropriate measures

34.  (1) Manufacturer shall ensure labeling with ◦ (A) Identity of hazardous substance ◦ (B) Appropriate hazard warning ◦ (C) Name and address of manufacturer, responsible party  (4) Employer shall ensure proper labeling, except as provided in (f)(5) and (f)(6), with: ◦ (A) Identity of hazardous substance ◦ (B) Appropriate hazard warnings

35.  (f)(5) Use of signs, placards or other written materials can be used in lieu of labels as long as alternative identifies the containers is readily accessible  (f)(6) Labels not required for containers that are for immediate use

36.  Not labeled with identity of hazardous substance  Not labeled with appropriate health or physical hazard warnings  Label no longer legible  Secondary container does not meet exemption for immediate use

37.  (g)(1) Employer shall have MSDS for each hazardous substance  (g)(8) Employer shall have copies readily accessible  (g)(9) Centrally located MSDSs shall be immediately obtainable in an emergency

38.  Not having MSDS for each hazardous substance in the workplace  Not having copies accessible to employees in their work area  Not having copies accessible to COSHO  Not providing copies to employees upon request

39.  (h)(1) Employers shall provide with effective information and training ◦ Initial assignment ◦ Whenever new substance is introduced ◦ Relate to general classes “to extent appropriate” and “reasonably foreseeable exposure”

40.  (h)(2) Information and training shall consist of at least: ◦ (A) Employees shall be informed of requirements of this section ◦ (B) Information of any operations in their work area where hazardous substances are present ◦ (C) Information of the location and availability of HazComm program, list of hazardous substances and MSDSs

41.  (h)(2) Information and training shall consist of at least: ◦ (D) Methods and observations that can be used to detect presence or release of substance ◦ (E) physical and health hazards of substances in work area ◦ (F) explanation of details of HazComm including how to use it

42.  (h)(2) Information and training shall consist of at least: ◦ (G) Employers shall inform employee of following rights:  To personally receive information regarding substance  For their physician or collective bargaining agent to receive information  Against discharge or other discrimination due to exercising of these rights

43.  (h)(3) New or revised MSDS information shall be provided to employees on a timely basis

44.  Not providing employees with any information and training on substances they use  Not providing employees who do not directly use substances with information and training on substances in their work area  Not covering all the topics specified in Section 5194(h)(2)

45.  Employer telling an employee “There’s a material safety data sheet binder, you can read it if you have any questions” is NOT training.

46.  Section 1. Material Identification ◦ Name and synonyms ◦ Manufacturer’s address and phone number  Section 2. Ingredients and Hazard Data ◦ Composition in percentages ◦ PELs and TLVs

47.  Section 3. Physical and Chemical Properties ◦ pH: acidity/alkalinity of material ◦ Specific gravity and vapor density ◦ Boiling point and vapor pressure  Section 4. Fire and Explosion Data ◦ Flash point: <100 degrees F is “flammable” ◦ Autoignition temperature ◦ Flammable limits: LEL and UEL ◦ Fire extinguishing media and procedures

48.  Section 5. Reactivity Data ◦ Stability and incompatibilities ◦ Hazardous polymerization and decomposition products  Section 6. Health and Hazard Information ◦ Routes of entry ◦ Acute and chronic hazards, carcinogenicity ◦ Signs and symptoms ◦ First aid

49.  Section 7. Safe Use and Spill Response ◦ Procedures for handling, storing, spill response and waste disposal  Section 8. Control Measures and PPE ◦ Respiratory protection and ventilation ◦ Skin and eye protection  Section 9. Handling and Storage ◦ Special precautions

50.  Blood Borne Pathogen Program (exposure control plan)  Aerosolized Transmissible Diseases Program (source control, screening and referral and communication procedures)  Lockout/Tagout (Energy Control) Program  Confined Space Program  Heat Illness Prevention Program  Respiratory Protection Program

53.  Internet – http://www.dir.ca.govhttp://www.dir.ca.gov  Publications  Posters  Recordkeeping questions  Look up regulations  Look up enforcement policies and procedures  Ask questions  Locate enforcement and consultation offices

54. Call the local area office to request a free program review http://www.dir.ca.gov/dosh/consultation_offices.html