OSHA Regulations often applied to commercial office

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OSHARegulations often applied to commercial
office schools

• Rob Rottersman, MS, CIH
• 847.685.9266
• rrottersman_at_boelter-yates.com

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Illinois

• Non-Public Buildings/Employees
• OSHA has jurisdiction
• Public Buildings (including municipal and
  schools)
• Illinois Department of Labor (IDOL) has
  jurisdiction
• IDOL has adopted OSHA standards

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Most Frequent Citations (National)October 2004
September 2005

• Scaffolding (9,558)
• Hazard Communication (7,564)
• Fall Protection (6,483)
• Respiratory Protection
• Hazardous Energy/Lockout Tagout (2,281)
• Total Citations (1 year) 113,362
• 103,923,102 in fines

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Scaffolding

• OSHA 29CFR1910.27 Subpart D
• Walking Working Surfaces
• Defined Any temporary elevated platform and
  its supporting structure used for supporting
  workmen or materials or both
• Regulations depend on scaffold type

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Powered Platforms Manlifts

• OSHA CFR1910.66
• Specific for Building Maintenance
• Regulations specific for type of lift
• Includes standards for harnesses, use, inspection
  training
• Protection from falling objects

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Hazard Communication

• OSHA 29CFR 1910.1200
• http//www.osha.gov/pls/oshaweb/owadisp.show_docum
  ent?p_id10099p_tableSTANDARDS
• Or Google Search OSHA 1910.1200
• Who has a hazard communication program?
• Is it compliant with the standard?

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Purpose

• PURPOSE Why do we need all this?
• Ensure chemical hazards are evaluated
• Information passed on to employee
• Allow for safe use and handling
• Emergency response (spills/exposure)

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Key Elements

• Written Program
• Material Safety Data Sheets (MSDS)
• Chemical Inventory
• Training
• Labeling

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Written Program

• How the School will Meet Requirements
• Labeling/warning information
• MSDS
• Employee Information and Training
• List of Hazardous Chemicals
• Hazards of non-routine tasks
• Outside contractor/visitor communication
• Program must be available upon request

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Labeling

• Container Labels Must Contain
• Identity of hazardous chemicals
• Appropriate hazard warnings
• Name address of manufacturer
• Manufacturers label should be sufficient

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When do you need to label?

• Chemical transferred to other container and NOT
  used by 1 employee on 1 shift
• Spray bottles are often overlooked
• Science and art rooms often forgotten
• Manufacturers labels is worn/illegible
• Label is not in English

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Labeling Exemptions

• Articles Not gas, liquid or particle item with
  end use function (i.e. solid parts)
• Materials regulated by other agencies
• - Pesticides (but label required by EPA)
• Food, Drugs, Cosmetics
• Alcohol
• Agricultural or vegetable seeds
• Wood or wood products
• Biological hazards
• Radiation

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Material Safety Data Sheets (MSDS)

• Must have a MSDS for every hazardous chemical
  in the school
• OSHA Hazardous Any chemical which is a
  physical or health hazard
• All substances are poisons there is none that
  it is not a poison. The right dose differentiates
  a poison from a remedy
• Paracelsus 1493-1541

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MSDS Contents

• Name Product Identity
• Physical chemical characteristics
• Physical hazards
• Health hazards
• Routes of entry
• Whether or not it can cause cancer
• Precautions for safe handling
• Control measures (ventilation, PPE, etc)
• Emergency first aid
• Date of MSDS preparation and revision
• Contact info. for manufacturer

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Exposure Standards Alphabet Soup

• Permissible Exposure Limits (PEL)
• OSHA Standard enforceable
• Subject to industry lobbying
• Recommended Exposure Limit (REL)
• National Institute of Occupational Safety and
  Health (NIOSH)
• Research based not enforceable
• Threshold Limit Value (TLV)
• American Conference of Govt. Industrial
  Hygienists (ACGIH)
• Recommended but not enforceable

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Health Considerations

• Review significant routes of entry
• Skin contact, inhalation, ingestions
• Chronic vs. Acute
• Chronic delayed response
• i.e. cancer, cirrhosis
• Acute effect short time after exposure
• Irritation, headaches, dizziness, allergic

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MSDS Maintenance

• Obtain from chemical manufacturer
• MSDS must be readily immediately accessible to
  employees
• Electronic files are permitted if employees have
  access
• Keep current periodic review for updates

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MSDS Recommendations

• Establish maintain a new product introduction
  program
• Have 1 person designated to approve all new
  products brought onto school grounds
• Approval requires submitting MSDS sheet, review
  for hazards training if needed

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Chemical Inventory List

• List of all hazardous chemicals found in the
  facility
• Must include the name used on the MSDS sheet
• Consider using as an MSDS index

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Training

• All employees who use or could come in contact
  with hazardous chemicals must be trained
• At the time of hiring
• Before beginning a new assignment/job change
• Whenever there is a new hazard that was not
  included in previous training
• Whenever new hazards are discovered for an
  existing product

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Non-routine Tasks

• Often overlooked
• could be significant health and safety hazards
• Examples in schools could include
• Cleaning, using chemicals in confined space such
  as crawlspaces
• Handling cooling tower treatment chemicals
• Chemicals to remove graffiti
• Inventory old chemicals from science art rooms

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Outside Contractors/Vendors

• Must inform of hazards associated with products
  they use or may come in contact with
• Notify them of written program and location of
  MSDS sheets
• Provide training as needed

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Chemicals Used by Vendors at Your School

• Janitorial cleaning crews, contractors, pesticide
  applicators, etc.
• Make sure they have provided you with MSDS sheets
• Review to ensure they are complete up to date
• KNOW THE LOCATION of their MSDS sheets AND inform
  your employees

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Fall Protection

• Multiple references in the standard
• OSHA CFR1910.21-1910.27 Appendix D
• Guards and rails
• Floor openings, uneven floor surfaces, etc.
• Ladders Stairs
• Wood vs. metal fixed vs. permanent

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Respiratory Protection

• OSHA CFR1910.134, .139
• Respirators as a last resort for reducing
  chemical exposures to safe levels.
• Better Options
• - Eliminate hazard (product substitution)
• - Engineering controls (ventilation)

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Respirator Programs

• If employees use respirators an OSHA respirator
  program must be in place
• Appropriate Respirator Selection
• Annual Training
• Annual Fit Testing
• Medical Evaluations
• Exposure Assessments

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Dust Mask Exemption

• OSHA CFR1910.134(c)(2)(i)(ii)
• Dust Mask (filtering face piece) may be worn if
• Use is voluntary (not required by employer)
• The respirator itself will not create a hazard
• Employer provides employee with information
  contained in OSHA Appendix D
• Information for Employees Using Respirators When
  Not Required Under the Standard

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Respirator Selection
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Safety Shoes

• 29CFR1910.136
• Required when danger of injury from falling or
  rolling objects, objects may pierce the sole or
  feet are exposed to electrical hazard

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Eye Protection

• 29CFR1910.133
• Eye face protection shall be worn when exposed
  to eye or face hazards from flying particles,
  molten metal, liquid chemicals, acids or
  caustics, chemical gases or vapors or injurious
  light radiation

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LockOut/TagOut(Control of Hazardous Energy)

• OSHA 29CFR1910.147
• Covers the servicing and maintenance of machines
  and equipment in which the unexpected start up or
  release of stored energy could cause injury to
  employees

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LO/TO Requirements

• Written Program/Policy
• Define Authorized employees
• Understand the machines energy
• Trained in LO/TO
• Authorized to install remove locks/tags
• Define Effected Employees
• Employees who may operate locked or tagged out
  equpment

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Actions Requiring LO/TO

• Removing or bypassing a safety device
• Any part of the body is placed in harms way
• Exposure to hazardous energy

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OSHA Record Keeping

• 29CFR1904
• AKA 300 Log
• Includes
• Determining if injuries are recordable
• Logging injuries (300 Form)
• Investigate cause (301 Form)
• Post summary - Feb-April (300-A Form)

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Blood Borne Pathogens

• 29CFR1910.1030
• Program required when there are employees with
  potential exposure
• Health care
• First Responders/First Aid Providers
• Janitorial (restroom cleaning)
• Annual training required
• Post exposure vaccination program
• Hepatitis B Virus

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Safety Quiz Whos Liable?

• Bob dropped a banana peel, slipped and fractured
  his skull, whos at fault?
• Bob
• Bobs school district supervisor
• Floor wax manufacturer
• Banana importer
• Grocery store
• Newspaper that advertised banana sale
• The Banana farmer

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You Know an IDOL Inspection is going bad when-

• IDOL sets up temp. housing in your parking lot
• The officer mutters this is unbelievable
• They call in a professional film crew for
  documentation and you recognize Walter Jacobson
• Officer is wearing a moon suit and respirator
  your staff is in jeans and tennis shoes
• Officer begins inspection with you have the
  right to remain silent
• Officer asks a specific question about a note in
  your files (before you show him the file)
• Officer knows all your staff by their first names
• Officer is a former science teacher that you fired

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Speaker Contact Information

• Rob Rottersman, MS, CIH
• Senior Environmental Consultant
• Boelter Yates, Inc.
• 1300 Higgins Rd. Ste 301
• Park Ridge, IL 60068
• rrottersman_at_boelter-yates.com
• IASBO Booth 432