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OSHA Update
George B. Flynn, MS, CIH OSHA Compliance
Assistance Specialist
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Disclaimer

• This information has been developed by an OSHA
  Compliance Assistance Specialist and is intended
  to assist employers, workers, and others as they
  strive to improve workplace health and safety.
  While we attempt to thoroughly address specific
  topics, it is not possible to include discussion
  of everything necessary to ensure a healthy and
  safe working environment in a presentation of
  this nature. Thus, this information must be
  understood as a tool for addressing workplace
  hazards, rather than an exhaustive statement of
  an employers legal obligations, which are
  defined by statute, regulations, and standards.
  Likewise, to the extent that this information
  references practices or procedures that may
  enhance health or safety, but which are not
  required by a statute, regulation, or standard,
  it cannot, and does not, create additional legal
  obligations. Finally, over time, OSHA may modify
  rules and interpretations in light of new
  technology, information, or circumstances to
  keep apprised of such developments, or to review
  information on a wide range of occupational
  safety and health topics, you can visit OSHAs
  website at www.osha.gov.

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Topics

• Whats New?
• Colorado Construction Emphasis Programs
• Roadway Workzone Safety
• Hexavalent Chromium (Cr VI)
• QA

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Topics

• Whats New?
• Colorado Construction Emphasis Programs
• Roadway Workzone Safety
• Hexavalent Chromium (Cr VI)
• QA

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FY 06 Colorado Statistics

• 1483 total inspections
• 871 construction inspections
• 60 construction (Note Construction comprises
  only 7 of CO workforce)
• 445 Fall REP inspections
• 146 Trench NEP inspections
• 87 Workzone LEP inspections
• Source IMIS database includes no inspection
  activity

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Topics

• Whats New?
• Colorado Construction Emphasis Programs
• Roadway Workzone Safety
• Hexavalent Chromium (Cr VI)
• QA

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FY06 Trenching and Excavation Program
Summary(EAO)

• 83 Inspections Conducted
• 86 Attempted
• 13 I/C
• 90 Serious violations
• Top Violations
• 1926.652 (a)(1) Protective Systems (62 of 83)
• 1926.651 (k)(1) Daily Inspections by Competent
  Person
• 1926.651 (j)(2) Spoil Pile lt 2 ft. From Edge
• 1926.651 (c)(2) Insufficient Means of Egress (ie,
  ladders)
• 1926.21 (b)(2) General Safety Training

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Fall Hazards in Construction
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FY06 Fall Hazards in Construction Program
Summary(EAO)

• 183 Inspections Conducted
• 191 Attempted
• 62 I/C
• 83 Serious violations
• Top Violations
• 1926.501(b) Unprotected Sides and Edges (85 of
  183)
• 1926.1053(b) Improper Ladder Use
• 1926.451 Scaffolding
• (f) Platforms overloaded
• (g) Fall protection
• (c) Lack of Bracing
• (b) Platform construction
• 1926.503(a) Fall Protection Training

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Highway Workzone Safety
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FY06 Highway Work Zone Program Summary(EAO)

• 43 Inspections Conducted
• 57 Attempted
• 15 I/C
• 96 Serious violations
• Top Violations
• 1926.501(b)(15) Fall Protection
• 1926.200(g)(2) Traffic Signs Devices
• 5(a)(1) General Duty Clause
• 1926.100 (a)(1) Head Protection
• 1926.102 (a)(1) Eye Protection

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Topics

• Whats New?
• Colorado Construction Emphasis Programs
• Roadway Workzone Safety
• Hexavalent Chromium (Cr VI)
• QA

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Highway Workzone Safety

• Using the Manual on Uniform Traffic Control
  Devices

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History

• Early 70s FHWA assumed from ANSI responsibility
  for publishing the MUTCD
• MUTCD has a major rewrite every 10-20 years
• MUTCD is amended every 2-3 years

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MUTCD

• Millennium Edition
• Published 12/2002
• States required to adopt by 01/2003
• 2003 Edition
• Published 11/2003
• States required to adopt by 12/2005

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MUTCD

• Recognized as the national standard
• Effective minimum, States adopt and add
  supplements

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MUTCD

• 23 States have adopted the 03 Edition
• Including Montana, North Dakota, South Dakota,
  and Wyoming
• 22 States have adopted the 03 Edition while
  incorporating a supplement
• Including Colorado and Utah

• Effective September 14, 2004
• CDOT Standard Plans
• Standard Specs (ie, the Blue Book)

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MUTCD- Part 6 Temporary Traffic Control ZONES
(TTCZ)

• 6B.01 Fundamental Principles of TTC
• Road user and worker safety in TTC should be
  an integral and high priority element of every
  project from planning through design and
  construction

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KEY CONCEPTS

• TYPICAL APPLICATIONS (TAs) ARE USED TO GIVE
  BASIS FOR GOOD JUDGEMENT
• FUNDAMENTAL DATA CHARTS AND FORMULAS DETERMINE
  TTCZ CONFIGURATIONS
• ALL DISTANCE RELATED ELEMENTS OF THE TTCZ ARE
  RELATED TO ROADWAY SPEED

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Components of a Temporary Traffic Control Zone

• Advance Warning Area
• Transition Area

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Components of a Temporary Traffic Control Zone

• Activity Area
• Work space
• Traffic space
• Buffer space
• Termination Area

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Types of TTC Applications

• Each TTC zone is different, 46 MUTCD TAs are
  generic approaches to general conditions
• Many variables affect the requirements of each
  Traffic Control Plan (TCP)
• Location of work
• Duration of work
• Highway type
• Geometrics
• Vertical and horizontal alignment, intersections,
  interchanges, etc.
• Road user volumes
• Road vehicle mix (buses, trucks, and cars) and
  road user speeds

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Worker Safety Considerations (External)

• Key elements that SHOULD be considered to improve
  worker safety MUTCD 6D.03
• Planning for worker safety
• Training
• Worker safety apparel (ANSI-107-2004)
• Law enforcement
• Separation of activity area
• Buffer zones
• Truck mounted Attenuators (positive protection)
• Speed reduction measures

Worker safety apparel
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Worker Safety Considerations (Internal)
A PLAN in the ACTIVITY AREA

• Hazard assessments to minimize worker exposure to
  risk
• Job classifications in the activity area
• Plan complies with OSHA standards
• Develop internal traffic control plans for all
  operations complimentary to external TCP

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Work Zone Traffic Control

• MUTCD provides minimum requirements
• Situations may require
• exceeding the minimum
• Nighttime work
• Inclement weather conditions
• Unusual roadway geometry and environment
• Combinations of the above

No physical separation between work space and
traffic lane
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OSHA Enforcement of Work Zone Hazards

• 29 CFR 1926
• MUTCD

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Sub-Part GSign, Signals, Barricades

• Standard became effective 12/11/2002
• Incorporated through Reference the 1988 Revision
  3 (1993) and the Millennium Edition MUTCD

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OSHA STANDARDS

• 1926.200(g)(2) Traffic control signs and
  devices used for the protection of
  worker
• 1926.201(a) Signaling by flaggers
• 1926.202 Barricades used for the protection
  of workers

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Other OSHA STANDARDS

• 1926.56 Illumination
• 1926.100s PPE
• 1926.52 Noise
• 1926.600 Equipment
• 1926.651 Excavations
• 5(a)(1) Warning vests for workers other
  than flaggers
• Cone Setting (ie, from back of P.U.)
• 2003 Edition MUTCD

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Sample Citation

• 29 CFR 1926.200(g)(2) All Traffic control signs
  or devices used for the protection of
  construction workers did not conform to Part VI
  of the Manual of Uniform Traffic Control Devices
  (MUTCD)
• a) On or about October 23, 06, and at times
  prior, the employer did not comply with section
  6D.01 of the MUTCD, in that the Traffic Control
  Supervisor (TCS) did not take into consideration
  employee safety for when employees
  worked-in/crossed live-lanes of traffic

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Abatement

• Written procedures
• Use of Flaggers
• Buddy System

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Compliance Officers Perspective on Workzone Safety
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ENTRY

• Drive The Site All Ways
• Checking For
• SIGNS
• Right Order Spacing
• Visible Clean - Vegetation

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ENTRY

• CONES BARRELS PANELS
• Spacing Tapers Tangents
• Repair Cleaning
• Delineation of Work Zone - Shoulder - Hazards

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ENTRY

• FLAGGERS
• Flagger Ahead Sign
• PPE Vest Hardhats - Safety Glasses - Boots
• Training Certificate
• Lighting Of Station At Night
• Flagging Correctly
• Orientation

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ENTRY

• Equipment
• How used Pinch or Push
• Exposure to Health Hazards
• Crossing or Using Live Lanes
• P.U. Trucks Parking Across Live Lanes

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DOCUMENTATION TO EXAMINE

• Flagger Training Cards
• TCP MHT
• Required Approval Note Changes
• DOT Logs
• Safety Meetings
• Pre-job Meetings
• Field Engineering Log
• Wage Hour Documents
• Daily TCS Reports

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Topics

• Whats New?
• Colorado Construction Emphasis Programs
• Roadway Workzone Safety
• Hexavalent Chromium (Cr VI)
• QA

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OSHAs new standard for occupational exposure to
hexavalent chromium (CrVI)

• Published Feb. 28, 2006
• Sets a new permissible exposure limit of 5 µg/m3
  
• Covers 558,000 workers in general industry,
  construction and shipyards
• Will result in 40-145 avoided lung cancers per
  year among exposed workers
• Cost employers 282 million per year

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OSHAs previous standards for CrVI

• General Industry
• PEL of 52 µg/m3 as a ceiling concentration
• Adopted in 1971 from a 1943 ANSI standard
• No ancillary provisions
• Construction
• PEL of 52 µg/m3 as an 8-hour TWA
• Adopted in 1971 from 1970 ACGIH TLV
• No ancillary provisions

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What is hexavalent chromium ?

• Stable form of chromium metal that is generally
  man-made
• Exists as many different types of CrVI compounds
  that vary in their solubility and use
• Used in many industrial applicationsprimarily
  for its anti-corrosive properties
• Created during certain hot work processeswhere
  the original form of chromium was not hexavalent

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Major industries or operations covered by the
final Cr(VI) standard

• Electroplating
• Welding on stainless steel or Cr(VI) painted
  surfaces
• Painting
• Aerospace
• Autobody repair
• Chromate pigmentand chemical production

• Chromium dye and catalyst production
• Glass manufacturing
• Plastic colorant production
• Construction
• Traffic painting
• Refractory brick restoration
• Paint removal from bridges

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Major Health Effects

• Lung cancer
• Nasal septum ulcerations and perforations
• Asthma
• Skin ulcers
• Allergic and irritant contact dermatitis

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Three Separate Final CrVI Standards

• 1910.1026 General Industry
• 1926.1126 Construction
• 1915.1026 Shipyards

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Major Provisions of the Final Rules

• Scope
• Permissible Exposure Limit (PEL)
• Exposure Determination
• Regulated areas
• Methods of Compliance
• Respiratory Protection
• Protective Work Clothing and Equipment
• General industry only

• Hygiene Areas and Practices
• Housekeeping
• Medical Surveillance
• Communication of Hazards
• Recordkeeping
• Dates

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Major differences between the proposed and final
CrVI standards

• Proposed PEL was 1 µg/m3. The final PEL is 5
  µg/m3.
• Expanded the exclusion for portland cement to
  general industry and shipyards
• Added an exemption for employers who can
  demonstrate that exposures are below 0.5 µg/m3
  under any condition of use
• Added exposure determination provisions for
  construction and shipyards including a
  performance-oriented option for all industry
  sectors
• Added an engineering control limit of 25 µg/m3
  for certain aerospace painting operations
• Increased time for employers to comply with the
  final standards

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New Permissible Exposure Limit

• 5 micrograms per cubic meter air (5 µg/m3) as a
  8-hour time-weighted average (TWA)
• All CrVI compounds
• Action level 2.5 µg/m3

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Scope What types of exposures are covered by
the final standards?

• All occupational exposures to CrVI compounds
  except
• Exposures that occur in the application of
  pesticides
• Exposures to portland cement
• Exposures where employers have objective data
  demonstrating that a material containing chromium
  or a process involving chromium cannot release
  CrVI in concentrations at or above 0.5 µg/m3
  under any expected condition of use

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Exposure Determination What are employers
requirements for monitoring employee exposures?

• Two options allowed for characterizing employee
  exposures
• Scheduled monitoring option
• Performance-oriented option

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Scheduled monitoring option

• Lays out a set schedule for conducting initial
  and periodic monitoring
• Initial monitoring to determine if exposures are
  below or above the action level (AL)
• If initial monitoring indicates exposures are
• Below the AL monitoring can be discontinued
• At or above the AL monitor every 6 months
• Above the PEL monitor every 3 months

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Performance-oriented option

• Exposures characterized using any combination of
  air monitoring data, historical monitoring data
  or objective data
• No fixed schedule for performing periodic
  monitoring

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Methods of Compliance What methods must
employers use to achieve the new PEL?

• Establishes engineering and work practice
  controls as the primary means of achieving the
  PEL
• Exceptions
• Painting aircraft or large aircraft parts
• Use engineering and work practice controls to
  achieve 25 µg/m3 and supplement with respirators
  to achieve the PEL
• Tasks or operations that do not result in
  exposures above the PEL for 30 or more days per
  year
• Use of respirators alone allowed to achieve the
  PEL

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When must employers comply with provisions of the
final standards?

• Effective date May 30, 2006
• Start-up dates
• All provisions except engineering controls
• For employers with 19 or fewer employees May 30,
  2007
• For all others Nov. 27, 2006
• Engineering Controls
• For all employers May 31, 2010

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Questions/Comments
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