Respiratory Protection Reminders

Respirator Fit TestingBy Rachel Morgan, MPH, ASP
EHS Specialist at Palmetto EHS

Nearly five million employees are required to wear respirators due to occupational exposure to airborne contaminates according to OSHA estimates. Respirators do one of two things to protect those wearing them – they can filter out contaminates in the air or they can supply clean/uncontaminated air from another source. Tight fitting respirators require fit testing prior to their use in the workplace, and annually thereafter, in order to verify that the respirator has a sufficient and acceptable fit to the face of the employee. Employees wearing tight fitting respirators must  be clean shaven and have no facial hair that interferes with the seal of the respirator. In order to ensure that employees can properly use a respirator, OSHA also requires annual respiratory protection training. OSHA’s Respiratory Protection Standard, 29 CFR 1910.134, details exactly what must be covered in the annual training. Another OSHA requirement prior to allowing or requiring employees to wear respirators in the workplace is a medical evaluation. This requirement is to be sure that your employees can medically wear a respirator before you put them in one. It is important to keep in mind that breathing while wearing a respirator is more difficult than without one and can put a larger physiological burden on the body. Lastly, a written respiratory protection program is required of employers with employees required to wear respirators (some elements are required for employers with employees voluntarily wearing respirators as well). The OSHA Respiratory Protection Standard also details what must be included in the written program. 

While engineering and work practice controls or substitution of materials are the ideal and preferred way of dealing with airborne contaminates in the workplace, sometimes it is not feasible or possible to reduce exposures below the occupational exposure limits and respirators must be used.

If you are in need of fit testing, medical evaluations, or respiratory protection training or written program, contact us.

OSHA’s New Beryllium Rule Takes Effect this Month

rachel photo-websiteBy Rachel Morgan, MPH, ASP
EHS Specialist with Palmetto EHS

OSHA has reduced the Permissible Exposure Limit (PEL) for beryllium from 2 μg/m3 to 0.2 μg/m3. The Short Term Exposure Limit (STEL) for beryllium has also been reduced from 5 μg/m3 (previously a Ceiling Limit) to 2 μg/m3. Both of the new exposure limits become effective on March 21, 2017, which was extended from March 10, 2017. Employers in general industry have until March 12, 2018 to become compliant with most of the requirements of the new rule, which is when it becomes enforceable by OSHA. The rule does give extended time for some of the provisions to be implemented, such as the requirements for some employers to have change rooms and showers for employees, and some of the required engineering controls.

Compliance with the reduced beryllium PEL is expected to reduce the risk of developing/dying from Chronic Beryllium Disease (CBD) and lung cancer. Some of the engineering controls to be used in order to obtain compliance include isolating the process, installing of ventilated enclosures, and using local exhaust ventilation. Employers should also evaluate employees work practices to control airborne and dermal exposure to beryllium, which may include using HEPA-filtered vacuums to keep work surfaces as free from beryllium as possible, and no longer dry sweeping dust/debris containing beryllium. In time, with compliance to the new rule, OSHA expects that 90 lives will be saved from diseases related to beryllium exposure per year, and 46 new cases of CBD will be avoided per year.

If you are in need of sampling employees exposed to beryllium, contact us.

Do Your Employees Have Exposure to Hexavalent Chromium?

Safety, industrial hygiene, OSHA compliance, training

By Rachel Morgan, MPH, ASP

Hexavalent chromium is a form of chromium that is present in many industrial operations and can cause a variety of illnesses. Welding on stainless steel is one of the main sources of hexavalent chromium exposure in the workplace. Other sources of exposure include smelting of ferro-chromium ore and chrome plating with chromic acid. Hexavalent chromium is a carcinogen and has the potential to cause lung cancer, respiratory tract irritation, and damage to the skin and eyes. Wheezing and shortness of breath are sometimes found in workers who become allergic to hexavalent chromium over time as well.

The Occupational Safety and Health Administration (OSHA) has both an Action Level (2.5 µg/m3) and a Permissible Exposure Limit (5.0 µg/m3) for hexavalent chromium. If initial monitoring of workers indicates that that they are exposed above the Action Level, employers are required to begin sampling every six months, however if workers are exposed above the Permissible Exposure Limit, employers are then required to sample every three months. If controls are put in place and resampling indicates that exposure has dropped below the Action Level, then the sampling can be discontinued if the results are confirmed by a second sampling event taking place a minimum of seven days later.

Any time conditions change in the workplace, such as a change in materials, equipment, ventilation, other control methods, processes, etc., the employer is required to perform sampling if they have any reason to believe that employee exposure is above the Action Level. In addition to the sampling requirements, OSHA’s Hexavalent Chromium standard also stipulates various other requirements, such as housekeeping, medical surveillance, hygiene areas, PPE, etc., when employees are exposed above OSHA limits.

If you are in need of initial sampling, periodic sampling, or sampling because you’ve implemented controls, contact us and we’ll be happy to help.

Are You GHS Compliant?

GHS

By Rachel Morgan, MPH, ASP, EHS Specialist

Are you GHS compliant?

June 1, 2016 has come and gone. Have you revised the labels on your chemicals, updated your Hazard Communication Program, and provided your employees training on any additional hazard communication items needed?

Labels must be placed on the container of every hazardous chemical in the workplace, and under the new GHS standard, they must contain the product identifier, signal word, hazard statement(s), pictogram(s), precautionary statement(s), and the name/address/phone number of the responsible party. Additionally, your Hazard Communication Program should have been updated include all aspects of the GHS standard, and your employees should have been trained on any additions to your Hazard Communication Program.

If you need assistance getting compliant with GHS, whether its getting all of your chemicals labeled appropriately, training your employees, or updating your Hazard Communication Program, contact us and we can provide these services for you.

OSHA’s Top 10 Violations for Fiscal Year 2015

rachel photo-website By Rachel Morgan, EHS Specialist with Palmetto EHS

These are the top ten OSHA violations for fiscal year 2015, which covers all violations cited by federal OSHA between October 1, 2014 and September 30, 2015. Note that the top 10 list was last updated by OSHA on January 5, 2016.

1. Fall Protection in Construction (1926.501) (1st in 2014)
Includes violations for failure to guard open sides and edges of platforms, to prevent falls from roofs, and to cover or guard floor and wall holes.

2. Hazard Communication (1910.1200) (2nd in 2014)
Includes violations for failure to have a written program, train employees on chemical hazards, SDS violations such as missing SDSs, and improper or no labels on containers.

3. Scaffolding in Construction (1926.451) (3rd in 2014)

Includes violations for scaffold construction issues, improper access to scaffolding work surfaces, and lack of guardrails, etc.

4. Respiratory Protection (1910.134) (4th in 2014)
Includes violations for missing written respiratory protection programs or program problems, poor fit test procedures and lack of fit testing, issues with respirator selection process, and lack of procedures for voluntary use of respirators.

5. Lockout/Tagout (1910.147) (5th in 2014)
Includes violations for lack of energy control procedures and specific procedures, inadequate worker training, group lockout provisions not met and periodic inspections not completed.

6. Powered Industrial Trucks (1910.178) (6th in 2014)
Includes violations for lack of, or inadequate, operator training and refresher training, inspections, and condition of forklifts.

7. Ladders in Construction (1926.1053) (8th in 2014)
Includes violations for damaged ladders, use of the top of the ladder as a step, using the wrong ladder for the job, and placing excessive loads on ladders.

8. Electrical – Wiring Methods (1910.305) (7th in 2014)
Includes violations for flexible cords and cables that were not used properly, violations related to extension cord usage, temporary wiring citations, and use of temporary wiring as permanent wiring.

9. Machine Guarding (1910.212) (9th in 2014)
Includes violations for missing guards, not anchoring fixed machinery, and exposure to blades and other point of operation hazards.

10. Electrical – General Requirements (1910.303) (10th in 2014)
Includes violations related to employee exposure to potential electric shock or electrocution.
For more information, please see https://www.osha.gov/Top_Ten_Standards.html.

OSHA’s Proposed Beryllium Rule

rachel photo-websiteBy Rachel Morgan, EHS Specialist

Beryllium is a necessary metal in various types of industry in the United States, ranging from the medical field to aerospace, defense, and electronics. It is a strong, yet lightweight metal that is frequently used as an alloy with other metals.

It is estimated that as many as 35,000 general industry workers are exposed to beryllium. Workers exposed to beryllium, through dermal contact or inhalation, can become sensitized to the metal. After sensitization, further exposure to beryllium can cause chronic or acute beryllium disease and increase workers risk of developing lung cancer. No cure is known for those who develop chronic beryllium disease and development of the disease can occur in workers exposed to beryllium below the current exposure limits.

The current OSHA PEL for beryllium is 2 μg/m3, however the agency has proposed a new rulemaking that would reduce the PEL to 0.2 μg/m3. The proposed rule would also require provisions such medical surveillance, regulated work areas, recordkeeping, training. OSHA estimates that the proposed PEL would prevent nearly 100 worker casualties every year. The agency also estimates that the proposed PEL would prevent 50 new cases of chronic beryllium disease each year.

Comments to OSHA about the proposed rule are due by November 5, 2015. For more information, please see https://www.osha.gov/dsg/beryllium/rulemaking.html.

Reminder: OSHA 300 Log Changes Take Place January 1, 2015

 

rachel photo-website

Article by Rachel Morgan, EHS Specialist at Palmetto EHS, LLC.

OSHA announced changes in late September to the recordkeeping regulations. The changes are being termed “severe injury and illness reporting,” and are geared towards helping OSHA more efficiently prevent work-related fatalities, injuries, and illnesses. These changes go into effect January 1st and all employers covered under the Occupational Safety and Health Act, as well as those exempt from keeping injury and illness records, must comply with the new severe injury and illness reporting requirements.

Requirements of the new rule include:

  • Employers must notify OSHA within 8 hours when there is an employee fatality on the job, or a fatality within 30 days of a work-related incident.
  • Employers must notify OSHA within 24 hours when one or more employees suffer a work-related in-patient hospitalization, amputation, or loss of an eye (only if it occurs within 24 hours of the work-related incident).

Employers will be required to report the following information:

  1. Name of establishment
  2. Work-related incident location and time
  3. Type of reportable event
  4. Number and names of employees affected
  5. Phone number of contact person
  6. Brief description of the incident

The list of employers partially exempt from recordkeeping requirements is also updated under the new rule. However, employers with 10 or fewer employees continue to remain exempt from the requirement of keeping worker injury and illness records.

To report fatalities, hospitalizations, amputations, and eye losses, employers need to call the nearest OSHA area office (normal business hours) or the 24 hour OSHA hotline (1-800-321-6742). They have plans to develop a Web portal so that employers can electronically submit reports at OSHA.gov in the future.

Palmetto EHS is available to assist employers with OSHA Recordkeeping training. Please contact us for more information.

OSHA’s Top 10 Violations for Fiscal Year 2014

rachel photo-website

Article by Rachel Morgan, EHS Specialist at Palmetto EHS, LLC.

These are the top ten OSHA violations for fiscal year 2014. Note that the top 10 list is considered preliminary since not all violations have been added to OSHA’s reporting system at this point. OSHA does not, however, expect the order to change once the reporting system is completely up to date.

1. Fall Protection in construction (1926.501) (1st in 2013)
Includes violations for failure to guard open sides and edges of platforms, to prevent falls from roofs, and to cover or guard floor and wall holes.

2. Hazard Communication (1910.1200) (2nd in 2013)
Includes violations for failure to have a written program, train employees on chemical hazards, improper or no labels on containers, and MSDS violations such as missing MSDSs.

3. Scaffolding in construction (1926.451) (3rd in 2013)
Includes violations for scaffold construction issues, improper access to scaffolding work surfaces, and lack of guardrails, etc.

4. Respiratory Protection (1910.134) (4th in 2013)
Includes violations for missing written respiratory protection programs or program problems, poor fit test procedures and lack of fit testing, issues with respirator selection process, and lack of procedures for voluntary use of respirators.

5. Lockout/Tagout (1910.147) (8th in 2013)
Includes violations for lack of energy control procedures and specific procedures, inadequate worker training, group lockout provisions not met and periodic inspections not completed.

6. Powered Industrial Trucks (1910.178) (6th in 2013)
Includes violations for lack of (or inadequate) operator training and refresher training, inspections, and condition of forklifts.

7. Electrical-wiring methods (1910.305) (5th in 2013)
Includes violations for flexible cords and cables that were not used properly, violations related to extension cord usage, temporary wiring citations, and use of temporary wiring as permanent wiring.

8. Ladders in construction (1926.1053) (7th in 2013)
Includes violations for damaged ladders, use of the top of the ladder as a step, using the wrong ladder for the job, and placing excessive loads on ladders.

9. Machine Guarding (1910.212) (10th in 2013)
Includes violations for missing guards, not anchoring fixed machinery, and exposue to blades and other point of operation hazards.

10. Electrical-general requirements (1910.303) (9th in 2013)
Includes violations related to employee exposure to potential electric shock or electrocution.

It is worth noting that the items on the top 10 list usually do not change, but they may rise or fall in rank each year depending on number of citations issued.

Indoor Firing Ranges and OSHA Compliance Part One – Lead

firing-range

Indoor firing ranges have been visited by OSHA recently under the National Emphasis Program for Lead.  Firing ranges and gun clubs generally fall under SIC Codes 7997 and 7999.  Both codes are listed in the National Emphasis Program.

Many gun club and firing ranges are small businesses without full time safety managers and their owners are not familiar with OSHA regulations required for their businesses. We have received many phone calls from concerned firing range owners in the past six months so I want to use this post to outline some basic OSHA compliance requirements that may apply to your business.

Lead

The first OSHA compliance issue that I will discuss is the OSHA Lead Standard.  The General Industry Standard 1910.1025 applies to firing ranges/shooting ranges and gun clubs.  The Lead Standard is exposure driven, which means that certain parts of the standard apply if employee exposure levels exceed either the OSHA Action Level (AL) of 30 ug/m3 or the OSHA Permissible Exposure Level (PEL) of 50 ug/m3.  You can think of the Action Level as the level at which you are required by law to take action.  Certain parts of the standard will kick in at this level but others will not.  Virtually the entire standard will apply if employee exposure levels reach the PEL.  In order to determine employee exposures, you need to do air sampling for lead.  Sampling should be conducted for multiple job tasks, but at a minimum, on workers who enter the range, perform cleaning activities in the range, and those who change out HVAC filters.

Once you conduct your sampling and receive your results you should do the following:

  1. Notify employees of their results.  This includes employees that do the same tasks that were not monitored.  The best way to handle this is to have a short team meeting to present and explain the results and have employees sign a summary of the sampling results to show that they received them.
  2. Determine compliance requirements based on the sample results, and implement these requirements.

Compliance requirements will fall under three categories, results less than the Action Level, results at or above the Action Level but below the PEL, and results at or above the PEL.

What You Have to Do When Lead Results are Below the AL

  • Train employees on Appendix A & B of the Lead Standard
  • Resample periodically to ensure that levels are below AL and PEL.  This is especially important if you have changes in the range (ventilation, number of ranges, etc.).
  • Personal protective equipment should be provided if necessary (disposable gloves and clothing if employees are exposed to lead dust during cleaning or changing of HVAC filters).
  • Follow good housekeeping procedures-HEPA vacuuming, etc. Dry sweeping and compressed air are not allowed for cleaning of lead dust.  Lead waste should be placed in sealed bags and disposed of based on state environmental requirements.

What You Have to do When Lead Results at or are Above the AL but less than the PEL

  • Train employees on Appendix A & of the Lead Standard
  • Resample for lead every six months.
  • Personal protective equipment should be provided if necessary (disposable gloves and clothing if employees are exposed to lead dust during cleaning or changing of HVAC filters).
  • Respirators should be provided if requested.
  • Medical Surveillance is required, and medical removal provisions apply if employees have elevated blood lead levels.
  • Follow good housekeeping procedures-HEPA vacuuming, etc. Dry sweeping and compressed air are not allowed for cleaning of lead dust.  Lead waste should be placed in sealed bags and disposed of based on state environmental requirements.

What You Have to do When Lead Results are at or Above the PEL

  • Train employees on Appendix A & of the Lead Standard
  • Resample for lead every three months.
  • Implement a lead compliance program to help reduce lead exposures in the workplace.
  • Personal protective equipment must be worn (disposable gloves and clothing and respirators).
  • Change facilities with showers must be provided and employees cannot wear lead contaminated clothing home.
  • Hand washing facilities and separate lunch rooms must be provided to ensure that employees do not accidentally ingest lead.
  • Medical Surveillance is required, and medical removal provisions apply if employees have elevated blood lead levels.
  • Follow good housekeeping procedures-HEPA vacuuming, etc. Dry sweeping and compressed air are not allowed for cleaning of lead dust.  Lead waste should be placed in sealed bags and disposed of based on state environmental requirements.

Additional safety and health resources for indoor firing ranges:

NIOSH indoor firing range page

NIOSH Workplace Solutions for Firing Ranges

If you need additional help with lead requirements for your firing range, contact us.

In Part Two of this blog post I will discuss other OSHA compliance issues which apply to firing ranges.