Safety and Health Program Management for Sheltered Workshops

Transcription

1 Safety and Health Program Management for Sheltered Workshops Missouri Department of Labor and Industrial Relations Daniel Stark, CIH Program Manager

2 Top 5 weirdest OSHA questions in 2006: #5: "Does OSHA regulate song lists played over a store's stereo? #4: "Does the word 'MUST' in OSHA standards mean I HAVE to do it? #3: "For employee bathrooms, what kind of toilet seat does OSHA require? #2: "How do you go about using hazardous warning labels on products that are not hazardous? #1: "Instead of respirators, is it okay if workers just hold their breath?"

3 Missouri On-site Safety and Health Consultation Program

4 Background The need for OSHA Consultation Section 21(d)(2) of OSHAct 29 CFR Consultation Agreements 90%/10% funding

5 Consultation Program OSHA mock inspection No fines, penalties, or citations No cost

6 Consultation Program (continued) Completely Confidential! Serious hazards/imminent danger No referral since program s inception

7 Safety and Health Achievement Recognition Program (SHARP) What s SHARP? Up to a 3 year exemption from OSHA s general inspection schedule Fatalities/catastrophes, formal employee complaints, and imminent dangers still fair game Pre-SHARP

8 Shared Work is an alternative to layoffs that allows an employer to divide available work among affected employees who receive a portion of their unemployment benefits while working reduced hours. sharedwork.mo.gov WORK Employees working off the books, being paid under the table in cash or incorrectly treated as independent contractors are considered improperly classified. We can help make sure your workers are properly classified. labor.mo.gov/offthebooks We work to prevent discrimination by providing training on nondiscriminatory practices. We can also customize a training to fit your business. labor.mo.gov/training Our consultants assist businesses, at no cost, to be OSHA compliant by identifying hazards to make your workplace safer and save you money. labor.mo.gov/onsite SAFE

9 Safety and Health Management System (SHMS)

10 Safety and Health Management System Elements 1. Management Leadership 2. Worker Participation 3. Hazard Identification and Assessment 4. Hazard Prevention and Control 5. Education and Training 6. Program Evaluation and Improvement 7. Coordination and Communication on Multiemployer Worksites How to Find Document: Go to Click on A-Z Index (upper right corner) Look under S for Safety and Health Programs, Recommended Practices

11 Element #1 - Management Leadership Top management commitment essential! Policy Statement Goals and Objectives Provide resources Hold employees accountable

12 True or False - Good management example???

13 Element #2 Worker Participation Encourage it!! Report safety/health concerns Provide workers access to S&H information Involve workers in all aspects of the Program Remove barriers to participation

14 Element #3 Hazard ID & Assessment Collect information about workplace hazards Inspect the workplace Identify health hazards Perform incident investigations Hazards with emergency and nonroutine situations Classify hazards, develop controls, and prioritize corrections

15 Self-Inspection Checklist (OSHA s Handbook for Small Business pub. #2209) Covers the following: Posting and Recordkeeping Safety and Health Program Medical Services and First Aid Fire Protection PPE General Work Environment Walkways Floor and Wall Openings Stairs and Stairways Elevated Surfaces Exiting or Egress Ladders Tools Machine Guarding LOTO Welding, Cutting and Brazing Compressed air Compressed Gas Cylinders Hoists Forklifts Spraying Operations Confined Spaces Environmental Controls Flammable and Combustibles Chemical Exposures Hazcom Electrical Noise Material Handling Ventilation

16 Incident Investigations Must be fact-finding and not faultfinding! Must identify the root cause and result in corrective action. 5 Why s (worksheet)

17 Job Hazard Analysis (JHA s) Three Simple Steps (Handout): 1. Break the task down in steps 2. Identify the hazards in each step 3. Identify the control measures in each step

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19 Ex. JHA - Remove Burr From Cast Part Job Step 1. Reach into metal box to right of machine, grasp 15 pound casting, and carry to wheel. 2. Push casting against wheel to grind off burr. 3. Place finished casting in box to left of machine. Hazard 1. Sharp burrs on part could cause laceration. 2. Metal fragment could get in eye. 3. Reaching, twisting, lifting heavy part = back strain. Control 1. Use gloves or hand tool (clamp) to pick-up part. 2. Use safety glasses in metal grinding operations. 3. Body mechanics training; adjustable work stations.

20 Element #4 Hazard Prevention and Control

21 Element #4 - Hazard Prevention and Control Source Path Receiver

22 Element #4 Hazard Prevention and Control Identify control options Select controls Develop a hazard control plan (for longterm objectives) Select controls for non-routine operations and emergencies Implement selected controls Follow up to confirm that controls are effective

23 Element #5 - Safety and Health Training Provide program awareness training Train employers, managers and supervisors on their roles in the program Train workers on their specific roles in the safety program Train workers on hazard identification and controls

24 Why detailed training is important.

25 Element #6 Program Evaluation and Improvement (new) Monitor performance and progress Define success Collect, analyze and review performance data Track leading and lagging indicators Analyze trends Share results with all employees Verify program is implemented and operational Perform an annual audit Correct shortcomings and identify opportunities to improve

26 Element #6 Program Evaluation and Improvement Correct program deficiencies and identify opportunities to improve Were changes beneficial? Were goals met? If not, why not? (Do failure analysis!) Set new goals for next year.

27 Element #7 Communication and Coordination for Host Employers, Contractors, and Staffing Agencies(new) Establish effective communication Establish effective coordination

28 OSHA Compliance

29 OSHA Update Electronic Submission of Records A - Establishments with >250 employees are required to keep logs; in certain industries - Submission due July 1, Starting in 2019, March 2. Vocational Rehabilitation Services is on the list of certain industries New Silica Rule Max serious fine now $12,934

30 OSHA Regulations There are three primary OSHA regulations with which you must comply: 29 CFR 1904 OSHA s Recordkeeping Standards 29 CFR 1910 OSHA s General Industry Standards 29 CFR 1926 OSHA s Construction Industry Standards

31 Things to Report to OSHA Fatalities 8 hours Inpatient Hospitalization 24 hours Amputation 24 hours Loss of an eye 24 hours

32 OSHA 300 log (29 CFR 1904) Annual log of recordable injuries and illnesses 300A posted from February 1 to April Injury and Illness Incident Report

33 Medical Treatment What is medical treatment? It does not include: Visits to a PLHCP solely for observation or counseling Diagnostic procedures First aid

34 Cases that are not recordable - First Aid Using nonprescription medication at nonprescription strength Tetanus immunizations Cleaning, flushing, or soaking surface wounds Wound coverings, butterfly bandages, Steri-Strips Hot or cold therapy Non-rigid means of support Temporary immobilization device used to transport accident victims

35 Cases that are not recordable - First Aid Drilling of fingernail or toenail, draining fluid from blister Eye patches Removing foreign bodies from eye using irrigation or cotton swab Removing splinters or foreign material from areas other than the eye by irrigation, tweezers, cotton swabs or other simple means Finger guards Massages Drinking fluids for relief of heat stress

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39 OSHA Site-Specific Programs

40 OSHA Poster Must be displayed where workers can see it Explains worker and employer rights Downloadable from OSHA s website

41 Emergency Action Plan (29 CFR ) STEP #1--What are the reasonably foreseeable emergencies that my company is exposed to? STEP #2 What do I want my employees to do in the event of each of these emergencies? STEP #3 If you have 11 or more employees, the plan has to be in writing. STEP #4 Train your employees. This is Day #1 (new-hire) information. 41

42 Six Elements of Emergency Action Plan 1. Procedures for reporting a fire or other emergency 2. Procedures for emergency evacuation (type of evacuation and exit route assignments) 3. Critical facility operations before evacuation 4. Accounting for employees 5. Procedures for rescue or medical duties 6. Company POC for additional information 42

43 Emergency Action Planning Alarm System Must be able to hear it above ambient noise Distinctive/recognizable Maintained and Tested Supervised = Annually Non-Supervised = Every 2 Months Training - Every employee must know their role! Re-Training New Plan/New Employee Revised Plan 43

44 Should employees evacuate or be prepared to fight a small fire? Choosing to evacuate the workplace rather than providing fire extinguishers for employee use in fighting fires will most effectively minimize the potential for fire-related injuries to employees. In addition, training employees to use fire extinguishers and maintaining them requires considerable resources. However, other factors, such as the availability of a public fire department or the vulnerability of egress routes, will enter into this decision. Option 1 Option 2 Option 3 Option 4 Total evacuation of employees from the workplace immediately when alarm sounds. No one is authorized to use available portable fire extinguishers. Designated employees are authorized to use portable fire extinguishers to fight fires. All other employees must evacuate workplace immediately when alarm sounds. All employees are authorized to use portable fire extinguishers to fight fires. Extinguishers are provided but not intended for employee use. Requirement Requirement Requirement Requirement Establish an emergency action plan, fire prevention plan and train employees accordingly. Extinguishers are not existing and not required [29 CFR (b)(1)]. Establish an emergency action plan and train employees accordingly. Meet all general fire extinguisher requirements plus annually train designated employees to use fire extinguishers. Fire extinguishers in the workplace must be inspected, tested, and maintained [29 CFR (b)(2)]. If any employees will be evacuating, establish an emergency action plan and train employees accordingly. Meet all general fire extinguisher requirements plus annually train all employees to use fire extinguishers. Fire extinguishers in the workplace must be inspected, tested, and maintained [29 CFR (b)(2)]. Establish an emergency action plan, fire prevention plan and train employees accordingly. If fire extinguishers are left in the workplace, they must be inspected, tested, and maintained. Extinguishers are provided but not intended for employee use [29 CFR (a)].

45 Fire Prevention Plan (29 CFR ) List of all major fire hazards Proper handling and storage procedures for hazardous materials Potential ignition sources and their control Type of fire protection equipment necessary to control each hazard

46 Fire Prevention Plan 5. Procedures to control flammable/combustible waste materials (housekeeping) (29 CFR ) 6. Maintenance procedures for heat-producing equipment 7. Equipment maintenance and fuel hazards 46

47 Personal Protective Equipment (29 CFR ) 1. Hazard Assessment 2. Written Certification 3. Employee Training a) When PPE is necessary b) What PPE is necessary c) How to properly don, doff, adjust and wear PPE d) Limitations of PPE e) Proper care, maintenance, useful life and disposal

48 Hazard Communication (29 CFR ) 1. Inventory/list of hazardous materials 2. SDS for each hazardous material 3. SDS available on all shifts Every private sector employer, regardless of size, must comply with HAZCOM! 48

49 Hazard Communication (continued) 4. Labeling - primary and secondary containers 5. Independent contractors 6. Non-routine tasks 7. Employee Training 49

50 Major revisions to the Hazard Communication Standard 1. Hazard classification: Provides specific criteria for classification of health and physical hazards, as well as classification of mixtures. 2. Labels: Chemical manufacturers and importers will be required to provide a label that includes a harmonized signal word, pictogram, and hazard statement for each hazard class and category. Precautionary statements must also be provided. 3. Safety Data Sheets: Will now have a specified 16- section format. 4. Information and training: The Revised HCS requires that workers be trained by December 1, 2013 to facilitate recognition and understanding of the new labels and safety data sheets.

51 GHS Pictograms Explosive Flammable Oxidizer Compressed Gas! Acute Toxicity Corrosive Chronic Health Hazard Irritant

52 Lockout/Tagout Program (29 CFR ) Energy Control Procedure protects employees who: Perform maintenance Operate machinery Excluded Operations: Cord/Plug equipment (if plug is controlled) 52

53 Lockout/Tagout Program (29 CFR ) Written Energy Control Program 1. Locks or Tags acceptable a) Durable b) Standardized c) Substantial 2. Written start-up/shut-down procedures for: a) Hard-wired machines b) Two or more sources of energy 53

54 Lockout/Tagout Program (29 CFR ) 3. Periodic Inspections of Lockout/Tagout Procedures At least annually Employer must certify (machine, date, employee observed, inspector name) 4. Authorized/Affected Employee Training Must ensure employee has knowledge and skills Retraining Requriements 54

55 Bloodborne Pathogen Program Applies if employees have exposure to blood or other infectious materials Exposure Control Plan Universal Precautions Hepatitis B Vaccinations (29 CFR ) Communication of Hazards to Employees Training NOTE: Good Samaritan acts are not considered occupational exposure!

56 Respiratory Protection Program Voluntary Use (29 CFR ) Procedures for selection Medical Evaluations Fit Testing

57 Respiratory Protection Program (continued) Cleaning, disinfecting and storage Training Evaluation of program effectiveness

58 Hearing Conservation Program (29 CFR ) Required above 85 dba for 8 hours Monitoring Program Audiometric testing Training

59 Other OSHA Programs Depending upon your process, you might also need: Forklift Operators Training Program Confined Space Program Fall Protection Program Mechanical Power Press Program Electrical Worker Training

60 How about some pictures of hazards? NOTE: This presentation does not include all hazards possible in a facility.

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102 Good tools for self-inspections AC Sensor Tic Tracer Outlet Tester Gotcha stick

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105 Helpful Web Sites

106 Free Tools From OSHA! OSHA Web Site: A-Z Index E-Tools (Free On-line Training Classes) Publications (Links and On-line Order Form) Regulations and Interpretations MO Division of Labor Standards Web Site: Written Program Templates Consultation Services

107 Questions?