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OSHA Hawai`i Workshop 05/20/2009 1 HIOSH’s Most Frequently Cited Health Conditions Tin Chao, Manager Occupational Health Branch
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OSHA Hawai`i Workshop 05/20/2009 2 Most Frequently Cited Occupational Health Citations Respiratory Protection - §1910.134 Respiratory Protection - §1910.134 Hazard Communication - §1910.1200 Hazard Communication - §1910.1200 Asbestos in Construction - §1926.1101 Asbestos in Construction - §1926.1101 Bloodborne Pathogens - §1910.1030 Bloodborne Pathogens - §1910.1030
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OSHA Hawai`i Workshop 05/20/2009 3 Respiratory Protection §1910.134 (Respiratory protection program) is the #1 most frequently cited standard §1910.134 (Respiratory protection program) is the #1 most frequently cited standard
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OSHA Hawai`i Workshop 05/20/2009 4 Respirators: Top 3 Cited Items No written RESPIRATORY PROTECTION PROGRAM No written RESPIRATORY PROTECTION PROGRAM Employees not provided MEDICAL EVALUATION Employees not provided MEDICAL EVALUATION FIT TESTING not performed annually FIT TESTING not performed annually
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OSHA Hawai`i Workshop 05/20/2009 5 Written Program Responsible Person: Responsible Person: –Program Administrator –Name –Duties
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OSHA Hawai`i Workshop 05/20/2009 6 Written Program How respirators were selected How respirators were selected Medical Evaluations – what employees, how often and where do they go Medical Evaluations – what employees, how often and where do they go Fit Testing procedures Fit Testing procedures Procedures for proper use – routine and emergency Procedures for proper use – routine and emergency
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OSHA Hawai`i Workshop 05/20/2009 7 Written Program (cont.) Respirator Maintenance Respirator Maintenance Training on the hazards for which respirator use is necessary Training on the hazards for which respirator use is necessary Employee training on use and care Employee training on use and care Procedures for program evaluation Procedures for program evaluation
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OSHA Hawai`i Workshop 05/20/2009 8 Respirator Medical Evaluations Medical evaluation on whether employee can: 1. Safely use the respirator; and 2. Safely perform the work.
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OSHA Hawai`i Workshop 05/20/2009 9 Respirator: Medical Evaluation When:BEFORE assignment requiring use of respirators When:BEFORE assignment requiring use of respirators Required for ALL employees where employer has determined respirator use is REQUIRED Required for ALL employees where employer has determined respirator use is REQUIRED How often: As often as health care provider determines is necessary How often: As often as health care provider determines is necessary
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OSHA Hawai`i Workshop 05/20/2009 10 WHO PAYS? ANSWER: EMPLOYER Pays for: –Respirator –Medical Evaluation –Fit Testing –Cleaning and Maintenance –Training –Time to do these things – on work time!
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OSHA Hawai`i Workshop 05/20/2009 11 Respirator Fit Testing Before Doing Work requiring respirators Before Doing Work requiring respirators When conditions change When conditions change At least annually At least annually Even Disposables Need to be Fit-Tested!
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OSHA Hawai`i Workshop 05/20/2009 12 Resources HIOSH Consultation & Training HIOSH Consultation & Training –586-9135 –http://hawaii.gov/labor/hiosh/hiosh-links- 2/consultation.shtml http://hawaii.gov/labor/hiosh/hiosh-links- 2/consultation.shtmlhttp://hawaii.gov/labor/hiosh/hiosh-links- 2/consultation.shtml OSHA website OSHA website –www.osha.gov
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OSHA Hawai`i Workshop 05/20/2009 13 More Resources OSHA E-tools OSHA E-tools –http://www.osha.gov/SLTC/etools/respira tory/index.html http://www.osha.gov/SLTC/etools/respira tory/index.htmlhttp://www.osha.gov/SLTC/etools/respira tory/index.html Interpretation Letters Interpretation Letters –http://www.osha.gov/pls/oshaweb/oware s.do_search http://www.osha.gov/pls/oshaweb/oware s.do_searchhttp://www.osha.gov/pls/oshaweb/oware s.do_search
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OSHA Hawai`i Workshop 05/20/2009 14 E-Tool
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OSHA Hawai`i Workshop 05/20/2009 15 Interpretation Letters
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OSHA Hawai`i Workshop 05/20/2009 16 Respiratory Protection
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OSHA Hawai`i Workshop 05/20/2009 17 Respirator Use
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OSHA Hawai`i Workshop 05/20/2009 18 Would you use this respirator ?
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OSHA Hawai`i Workshop 05/20/2009 19 Contaminated Respirator & Ear muff
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OSHA Hawai`i Workshop 05/20/2009 20 Hazard Communication Standard HIOSH: §12-203.1 HIOSH: §12-203.1 §29 CFR 1910.1200 §29 CFR 1910.1200
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OSHA Hawai`i Workshop 05/20/2009 21 HazCom: Top 3 Cited Items No PROGRAM No PROGRAM Employees not TRAINED Employees not TRAINED Missing Material Safety Data Sheets (MSDS) Missing Material Safety Data Sheets (MSDS)
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OSHA Hawai`i Workshop 05/20/2009 22 HazCom Program In WRITING In WRITING HOW company will comply with HazCom Standard HOW company will comply with HazCom Standard –Labels –MSDS –Training –Who is responsible
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OSHA Hawai`i Workshop 05/20/2009 23 HazCom Program (cont.) LIST of Hazardous Chemicals LIST of Hazardous Chemicals How employees will be informed of hazards of NON-ROUTINE tasks How employees will be informed of hazards of NON-ROUTINE tasks
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OSHA Hawai`i Workshop 05/20/2009 24 HazCom Resources OSHA – Topics OSHA – Topics –http://www.osha.gov/SLTC/hazardcomm unications/index.html http://www.osha.gov/SLTC/hazardcomm unications/index.htmlhttp://www.osha.gov/SLTC/hazardcomm unications/index.html Interpretations Interpretations –http://www.osha.gov/pls/oshaweb/oware s.do_search http://www.osha.gov/pls/oshaweb/oware s.do_searchhttp://www.osha.gov/pls/oshaweb/oware s.do_search
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OSHA Hawai`i Workshop 05/20/2009 25 Hazard Communication
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OSHA Hawai`i Workshop 05/20/2009 26 Asbestos in Construction
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OSHA Hawai`i Workshop 05/20/2009 27 §1926.1101 Applies to: Applies to: –Demolition –Construction/alteration/repair –Accidental Release and Clean-Up “Presumed Asbestos Containing Material” “Presumed Asbestos Containing Material” –Buildings built before 1980
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OSHA Hawai`i Workshop 05/20/2009 28 Asbestos: Top 3 cited items No Exposure Assessment – No Exposure Assessment – –No monitoring No or inadequate Personal Protective Equipment (PPE) No or inadequate Personal Protective Equipment (PPE) No or Inadequate Employee TRAINING No or Inadequate Employee TRAINING
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OSHA Hawai`i Workshop 05/20/2009 29 Hazard Assessment Presumed Asbestos Containing Material (PACM) Presumed Asbestos Containing Material (PACM) For buildings before 1980: Unless you can prove it’s NOT asbestos – IT IS! Take Samples – Approved Laboratory Take Samples – Approved Laboratory Monitor Employee Exposure Monitor Employee Exposure
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OSHA Hawai`i Workshop 05/20/2009 30 Personal Protective Equipment (PPE) Depends on Class of Work being performed Depends on Class of Work being performed –READ and UNDERSTAND Standard –If no assessment – presumed worst case –May need Self Contained Breathing Apparatus and “Moon” Suit until you can show not needed.
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OSHA Hawai`i Workshop 05/20/2009 31 Removal of Insulation: Class I Work
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OSHA Hawai`i Workshop 05/20/2009 32 Employee Training Prior to Work involving asbestos Prior to Work involving asbestos At least annually thereafter At least annually thereafter Hazards of Asbestos and of smoking Hazards of Asbestos and of smoking Protective Measures Protective Measures
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OSHA Hawai`i Workshop 05/20/2009 33 OSHA Safety & Health Topics: Asbestos
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OSHA Hawai`i Workshop 05/20/2009 34 Asbestos in Construction
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OSHA Hawai`i Workshop 05/20/2009 35 Bloodborne Pathogens §1910.1030
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OSHA Hawai`i Workshop 05/20/2009 36 Bloodborne Pathogens: Top 3 Cited Items EXPOSURE CONTROL PLAN EXPOSURE CONTROL PLAN –Lack of or inadequate Inadequate Employee TRAINING Inadequate Employee TRAINING Deficient Post Exposure Follow-Up Deficient Post Exposure Follow-Up
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OSHA Hawai`i Workshop 05/20/2009 37 Exposure Control Plan List of all job classifications with occupational exposure to blood or bodily fluids List of all job classifications with occupational exposure to blood or bodily fluids How company will comply How company will comply Reviewed and updated at least ANNUALLY Reviewed and updated at least ANNUALLY Hawaii Standard applies to CONSTRUCTION too Hawaii Standard applies to CONSTRUCTION too Exposure Control Plan
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OSHA Hawai`i Workshop 05/20/2009 38 Employee Training Initial Initial At least Annually At least Annually Opportunity for INTERACTIVE Q&A Opportunity for INTERACTIVE Q&A Watching a video is NOT good enough! Watching a video is NOT good enough!
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OSHA Hawai`i Workshop 05/20/2009 39 Post-Exposure Follow-Up Confidential Medical Evaluation Confidential Medical Evaluation How incident occurred How incident occurred Source person’s consent Source person’s consent Post-exposure prophylaxis Post-exposure prophylaxis Counseling Counseling
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OSHA Hawai`i Workshop 05/20/2009 40 Hepatitis B vaccination Antibody Testing (post vaccination) must be performed within 1-2 months of last shot Antibody Testing (post vaccination) must be performed within 1-2 months of last shot For employees “at high risk for continued percutaneous or mucosal exposure to blood or body fluids” For employees “at high risk for continued percutaneous or mucosal exposure to blood or body fluids” Reason: Determine immunity or non- response Source: CDC and OSHA (must follow CDC)
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OSHA Hawai`i Workshop 05/20/2009 41 Resources HIOSH Consultation & Training HIOSH Consultation & Training –586-9135 –http://hawaii.gov/labor/hiosh/hiosh-links- 2/consultation.shtml http://hawaii.gov/labor/hiosh/hiosh-links- 2/consultation.shtmlhttp://hawaii.gov/labor/hiosh/hiosh-links- 2/consultation.shtml OSHA website OSHA website –www.osha.gov
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OSHA Hawai`i Workshop 05/20/2009 42 OSHA Safety & Health Topics
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OSHA Hawai`i Workshop 05/20/2009 43 CONSULTATIONS By Request Only By Request Only Priority to Small, High-Hazard Employers Priority to Small, High-Hazard Employers Confidential Confidential FREE FREE NO Citations/Penalties NO Citations/Penalties Call 586-9135 Call 586-9135
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