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Managing OSHA Health
Programs
WITC – New Richmond
April 14, 2011
Mary Bauer
CIH, CSP
Compliance Assistance Specialist
Eau Claire, WI 54701
715-832-9019
My Background

Mary Bauer

25 years w/ OSHA
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20 Compliance Officer
5 Compliance Assistance Specialist
IH/ Safety
CIH: Certified Industrial Hygienist
CSP: Certified Safety Professional
1000 + Inspections
Today’s Agenda

What are OSHA Health Programs?
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How do I know if I need one?
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Required Documentation
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Maintenance/Retention of Records
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Exposure and Medical Records
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Tips on Record Maintenance
“Paperwork Reduction Act”

1942, 1980 & 1995
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1980 Created “Office of Info & Regulatory
Affairs”
“Burdent Hours”: Time & Expense to Fill Out
Forms
The purposes of this chapter are to:

minimize the paperwork burden for individuals,
small businesses, educational and nonprofit
institutions, Federal contractors, State, local
and tribal governments, and other persons
resulting from the collection of information by
or for the Federal Government;
“Older” vs. “Newer” Standards

Older Standards
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Require a “program”
Don’t Require it written
 1910.95: Hearing Conservation Program
Newer Standards
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Requires a Written Program
 Bloodborne Pathogens
 Respirator
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Written Program
Periodic Review
Industrial Hygiene from an OSHA
Perspective
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Focus on workplace health hazards
Goal: reduce or eliminate hazards that
can cause sickness or impaired health
Identify & analyze workplace health
hazards
* chemical
* physical
* ergonomic
* biological
Health Hazards:

Air Contaminates
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Skin Contact - Dermal
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Hearing Loss
Ringing in the Ear
Bloodborne
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Irritant
Burns
Noise
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Lungs
Central Nervous System
Internal Organs
Blood
Hepatitis…..B and C
HIV/AIDS
Spill/Leak of Chemical
Immediate or
Chronic (Long Term)
Effects
Health Standards
List is NOT Complete

1910.95: Hearing Conservation / Noise
1910.120: Emergency Response
1910.132: Personal Protective Equipment
1910.134: Respiratory Protection Program
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1910.1001-1910.1052
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Expanded Health Standards
Expanded Standards:
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Asbestos
Coal Tar Pitch Volatiles
13 Carcinogens
Alpha-Naphthylamine
Methy Chloromethyl Ether
3,”-Dichlorobenzidine
Bis-Chloromethyl ether
Beta-Naphthylamine
Benzidine
4-Aminodiphenyl
Ethyleneimine
Beta-Propiolactone
2-Acetylaminoflurorene
4-Dimethylaminoazobenzene
N-Nitrosodimethylamine
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Vinyl Chloride
Inorganic Arsenic
Lead
Hexavalent Chromium
Cadmium
Benzene
Coke Oven Emissions
Cotton Dust
1,2-dibromo-3-chloropropane
Acrylonitrile
Ethylene Oxide
Formaldehyde
Methylenedianiline
1,3-Butadiene
Methylene Chloride
Health Standards
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1910.1020: Formerly 1910.20
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Access to Exposure and Medical Records
1910.1030:
1910.1096:
1910.1200:
1910.1450:
Labs
Bloodborne Pathogens
Ionizing Radiation
Hazard Communication
Chemical Hygiene Plan -
Standards: Construction
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1926.50: Medical Services and First Aid
1926.51: Sanitation
1926.52: Occupational Noise
1926.53: Ionizing Radiation
1926.55: Gases, Vapors, Fumes, Dusts
and Mists
1926.56: Illumination
1926.57: Ventilation
1926.59: Hazard Communication:

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REFERENCES: General Industry 1910.1200
Subpart C:

1926.33: Access to Medical and Exposure
Records
 References General Industry: 1910.1020
Standards: Construction

Subpart D: Continued
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1926.60: Methylenedianiline
1926.62: Lead
1926.64: Process Safety Management
1926.65: Haz Waste Operation & Emer
Response
1926.66: Spray Booths
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Subpart Z:
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1926.1101-.1152: Expanded Standards
Related Standards
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PPE
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1910.132: General
1910.133: Eye & Face
1910.138: Hand
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Ventilation: 1910.94
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Flammable: 1910.106
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LEL/UEL vs. PEL
Emergency Response: 1910.120
PSM: 1910.119
Medical Services and First Aid: 1910.151
Expanded Standards:
Common Paragraphs
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Scope and Application
Definitions
AL / PEL / STEL / Action Level
Monitoring
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Initial & Subsequent
Ees Access
Regulated Areas
Method of Compliance
Respiratory Protection
Expanded Standard: Common
Paragraphs
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Training
Medical Surveillance
Hygiene / Work Clothing / Showers
Signs / Labels / Warnings
Records / Recordkeeping
Appendices
Written Compliance Plan
Emergencies / Spills
Effective Dates
How Do I Evaluate the Hazard?
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MSDS
Observation: Smell, Taste, See, Feel
Screening – Next Session
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Direct Reading Instruments
Short Term Sampling- Next Session
TWA Sampling – Next Session
Bulk Sampling
Interviews: Mgmt – Ees
Hazard Review
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Chemical or Hazard:
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What’s used?
How Much?
How Often?
Previous Sampling?
Controls?
Existing?
 Determined Effective?
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Changes in Process since Determined
Maintained?
 Measured? (Manometer)
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Sampling: Only way to really know!
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Qualified Person
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State Consultation
Insurance Carrier
Private Consultant
OSHA: Enforcement!
Appropriate
Instrument
Duration of sampling
Pre and post
calibration
How to you Attack the Problem?
Hierarchy of Controls
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Engineering
Administrative
Personal Protective
Equipment
Training
Controls or Abatement Methods
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Classic Hierarchy:
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Product Substitution / Elimination
Methylene Chloride: Have Avoided at all costs!
 Asbestos – Limited to No Mfg or Product
Containing
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Engineering Control
Ventilation
 Barrier / Distance / Automation
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Administrative Controls: Rotation
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Prohibited for Some Contaminates (Pb)
PPE
Respirator
 Hearing Protection
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Noise: 1910.95(m)
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Exposure Measurements
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Sound Level or Dosimeter Readings
Retain for 2 Years
 * HOWEVER, Need to Show Monitoring Results *
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Audiograms:
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Employee Info
Testing Equipment Information
Duration of Affected Employee’s Employment
Includes Specific Information
Occupational Noise Exposure
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Assess your workplace!
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Monitor areas of concern
Sample worker’s full-shift noise
exposure
Engineering Controls or Hearing Protection???
Hearing Conservation Requirements
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Monitoring
Employee Notification
Audiometric Testing
Hearing Protectors
Training
Access To Records
Recordkeeping
Noise Sampling – Some Tools
Industrial Hygienists Use:
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Sound level meter: Spot Checks
Noise dosimeters: Exposure Determination
Occupational Noise Exposure
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If full-shift noise exposure averages
above the OSHA PEL of 90 dBA
(decibels A-weighted)
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Hearing protection must be provided &
used
If full-shift noise exposure averages
above OSHA Action Level of 85 dBA
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A hearing conservation program must
be implemented
Hearing Conservation Program (HCP)
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Purpose: prevent
or reduce
progression of
noise-induced
hearing loss
HCP must include:
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Noise monitoring
Hearing protection
Hearing testing
(audiograms)
Training
Recordkeeping
NRR: EPA Rating
Audiometric Testing
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New Hires
Annual
Standard Threshold Shifts
Testing Equipment
Notification to Employee
Revised Baselines or Retesting
VAN EXEMPTION
Respiratory Protection
1910.134
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Written Copy of Respiratory Program
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1910.134( c)(1)(i)-(ix)
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Written PLHCP Opinion
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Fit Testing
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Certification / Inspection Emergency Use
Respiratory Protection
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When must you
provide your workers
with respiratory
protection?
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When they are
exposed to a
chemical in excess of
the OSHA PEL
Until engineering,
administrative, &
work practice
controls have been
implemented to
control exposures (&
re-sampling shows
exposures in
compliance with PEL)
Respirator-Use Requirements per 29 CFR 1910.134(c)
Voluntary Respirator Use
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What if air sampling results are
below the PEL & you only allow
voluntary use of filtering face piece
dust masks?
You must inform workers about
Appendix D of 1910.134
("Information for Employees Using
Respirators When Not Required
Under the Standard")
Voluntary Respiratory Use:
Other than “dust mask”
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What if you allow voluntary use of
other types of respirators?
Must have written respirator
program that provides for:
medical evaluation,
cleaning, maintenance & storage of
respirators
What if your workers are required to
wear respirators?
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Written program
Respirator selection
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Medical Evaluations
Fit testing
Proper use of respirators
Continued effectiveness
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Must be appropriate for hazard
If selecting a gas or vapor cartridge respirators,
must develop cartridge change-out schedule (unless
it has an ESLI)
Cleaning, disinfecting, storage
Training
Medical Evaluation
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You must provide an evaluation
before respirator use and before fit
testing
You need to identify a professional
Licensed Health Care person to
conduct an evaluation through using
a medical questionnaire or an initial
medical examination that contains
the same information.
Medical Evaluation-cont.

Medical evaluations need to contain
the information requested in the
questionnaire in Section 1 and 2,
Part A of Appendix C of 1910.134
Follow up examinations
Follow up examinations
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A positive response to any question 1-8 of
section 2 OR
Initial medical exam demonstrates the need
for a follow up
Fit Testing
Fit Testing
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Qualitative
Quantitative
Next Session
PortaCount Rep &
Equipment
Fit Testing
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Before the use of any negative or
positive TIGHT FITTING face piece
respirator
No Fit Testing Required
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Hoods, helmets and loose-fitting
facepieces
Escape-only respirators
Voluntary use respirators
Hood
Helmet
Loose-fitting
User Seal Check
Non-Air Contaminate/Expanded Std.
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1910.1020: Access to Med & Exp
Records
1010.1030: Bloodborne Pathogens
1910.1096: Ionizing Radiation
1910.1200: Hazard Communication
1910.1450: Chemicals in
Laboratories
Access to Medical and Exposure Records
1910.1020
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Formerly 1910.20 –
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WRONG in OSHA Standards to this day!
Where it says to keep MSDS for 30 years!
Sampling Data
Medical: Audiograms
Medical Access Order is Related: 1913.10
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http://www.osha.gov/SLTC/medicalaccessorder/index.html
http://www.osha.gov/pls/oshaweb/owadisp.sh
ow_document?p_table=STANDARDS&p_id=10
207
Availability of Med & Exp Records
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1913.10(b)(3) This section does not apply to OSHA
access to, or the use of, aggregate employee medical
information or medical records on individual employees
which is not in a personally identifiable form. This section
does not apply to records required by 29 CFR Part 1904,
to death certificates, or to employee exposure records,
including biological monitoring records treated by 29 CFR
1910.1020(c)(5) or by specific occupational safety and
health standards as exposure records.
1913.10(b)(4) This section does not apply where OSHA
compliance personnel conduct an examination of
employee medical records solely to verify employer
compliance with the medical surveillance recordkeeping
requirements of an occupational safety and health
standard, or with 29 CFR 1910.1020. An examination of
this nature shall be conducted on-site and, if requested,
shall be conducted under the observation of the
recordholder. The OSHA compliance personnel shall not
record and take off-site any information from medical
records other than documentation of the fact of
compliance or non-compliance.
Access to Medical and Exposure Records
1910.1020
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Inform Upon Initial Hire and
Annually There after….NOT TRAINED
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Posting
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Wisconsin Council of Safety Example
Producing the Record after
Requested
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What is a request
Who can request
15 days
Access To Exposure & Medical Records:
1910.1020
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Exposure Record
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Medical Records
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MSDS
Industrial Hygiene Monitoring
Medical Surveillance Results
Written Medical Opinions
WCS Website w/ sample program:
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http://www.doa.state.wi.us/docs_view2.asp?docid=2510
Access To Exposure & Medical Records:
1910.1020
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Retention Time:
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Unless specified in a “vertical” standard
"Employee medical records." The medical record for
each employee shall be preserved and maintained
for at least the duration of employment plus thirty
(30) years, except that the following types of
records need not be retained for any specified
period:
The medical records of employees who have worked
for less than (1) year for the employer need not be
retained beyond the term of employment if they are
provided to the employee upon the termination of
employment.
"Employee exposure records." Each employee
exposure record shall be preserved and maintained
for at least thirty (30) years, except that:
BLOODBORNE PATHOGENS
1910.1030
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Written Exposure Control Plan
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Training
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Reviewed at least annually
Date(s)
Content or Summary
Names and Qualifications of Trainer
Names and Titles of Attendees
Retained for 3 Years
Training Materials
Sharps Log
Coverage
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Standard applies to all occupational
exposure to blood or other
potentially infectious materials
If you answer NO

Develop a policy stating that there
are no first aid responders or
cleanup and that the company will
rely on 911 for any type of response
to injuries
If you answer YES

Develop and implement all elements
of a written bloodborne pathogens
program
•Exposure Control Plan must provide:
•Engineering controls (where applicable)
•Hygiene (hand washing)
•PPE (e.g., gloves, CPR masks)
•Housekeeping
•Disposal of regulated waste
•Hepatitis B vaccine
•Post-exposure evaluation & follow-up
•Training
Exposure Control Plan
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Requires employers to:
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identify potentially exposed workers
those who need training
PPE
Vaccination
Engineering Controls (Safer Needle
Devices)
Required to be reviewed and updated
annually with Employee Input
Bloodborne Pathogens
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Are your employees going to be
exposed or have the potential to be
exposed to Bloodborne Pathogens
or other potentially infectious
materials?
Who performs cleanup of blood or
fluids?
Are you going to appoint designated
first aid responders?
Bloodborne Pathogens
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1990’s
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Effective Date: March 6, 1992
1993 FAQ – One of the First
Latex Allergies Surfaced and Addressed
Collateral Duty Clause:
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Directive to Use any / all standards + 5a1
First Aid as additional responsibility
All Other Provisions in Place
After Opportunity to Perform 1st Aid
 Offer Hep B Vaccination
Region V Policy for BBP
Sharps Log /Safer Needle Devices: 2001
Revisions to 1910.1030 as a result of the
Needlestick Safety and Prevention Act:
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Paragraph 1910.1030(d)(2)(i) requires the use of
engineering and work practice controls to eliminate or
minimize employee exposure to bloodborne pathogens.
Employers must keep a Sharps Injury Log for the
recording of percutaneous injuries from contaminated
sharps [1910.1030(h)(5)(i)].
The Exposure Control Plan (1910.1030(c)(1)(i)) shall:
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Reflect changes in technology that eliminate or reduce
exposure to bloodborne pathogens
[1910.1030(c)(1)(iv)(A)].
Document annually consideration and implementation of
appropriate commercially available and effective safer
medical devices designed to eliminate or minimize
occupational exposure [1910.1030(c)(1)(iv)(B)].
Solicit input from non-managerial employees responsible
for direct patient care, who are potentially exposed to
injuries from contaminated sharps, in the identification,
evaluation, and selection of effective engineering and
work practice controls and shall document the solicitation
in the Exposure Control Plan [1910.1030(c)(1)(v)].
Methods of Compliance
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Universal Precautions
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Engineering Controls
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Personal Protective Equipment
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Housekeeping
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Handling of regulated waste
Training Employees
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All employees (including part-time
and temporary) must receive initial
and annual training
Must be conducted in the language the
employee understands
Must be “interactive”
14 Points
Qualified Trainer
1910.1200
Hazard Communication / “Right to Know”
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“Right to Know”
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MN Terminology: St. Croix Valley Companies
Previously: State of WI
The Four Stages of the Program
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Material Safety Data Sheets (MSDSs)
Labeling and Marking Systems
Employee Training
Written Plan
Hazard Communication
1910.1200
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Written Program
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Program
MSDS
Labeling
Training
MSDS: Material Safety Data Sheets
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30 years after you stop using it
Hot Topics:
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Article
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Brick / Block = Article
Silica = Chemical Exposure if Sawn
Electronic Access – Readily Available
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Devices must be readily accessible in workplace
Workers must be trained in their use
Must be back-up system to address emergencies
Labeling
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Target Organ
Compromises: Additional Training
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Placarding Allowed
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HMIS: Paint Industry
NFPA
Welding Areas
Color Coded Bottles
Secondary Containers Primary
Problem
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If not used w/in the shift
Labeling and Marking Systems
HMIS Labels
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Blue = Health
Red = Flammability
Yellow = Instability
White = Personal
Protective Equipment
or special protection
information
Numerical Rating of 04
Labeling and Marking Systems
NFPA Diamonds
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4= Deadly Hazard
3= Severe Hazard
2= Moderate Hazard
1= Slight Hazard
0= No Hazard
Color coded,
numerical rating
system
Will be located near
main entrances, fire
alarm panels, or on
outside entrance
doors
Provide at-a-glance
hazard information
What Documents Should I NOT
Possess?
What Documents Should I NOT
Possess?
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Specific findings or diagnoses unrelated to
occupational exposure - Do NOT Possess:
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Instead - Possess “Written Opinions” from:
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Pass/Fail or Satisfactory/Unsatisfactory on Medical Tests
Medications, Blood Pressure, History, etc.
Ee Completed Appendix C: Respirator Medical Evaluation
Respirator Medical Evaluations
Emergency Response Medical Evaluations
Bloodborne Pathogen Test Results, etc.
HIPAA: http://www.hhs.gov/ocr/hipaa/


Provisions for Confidentiality if Medical Records are Kept.
Plant Nurse or Health Department
Written Opinion vs.
Medical Test Results

Written Opinion: No Specific Results
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Can Perform Duties
Can Not Perform Duties
Can Perform Duties w/ Following Limitations
Medical Tests: ER Needs to Know Results
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Audiograms to Determine STS
Worker Comp and OSHA Log Info - Diagnosis
Biological Indicators for Chemicals

Blood Lead Test Results and other Metal Test
Results
More Common Standards

List is NOT Complete:
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1903: Abatement Verification
1904: Injury & Illness Log
1910.38 & .39: Emergency Action & Fire Plan
1910.95: Hearing Conservation / Noise
1910.119: Process Safety Management (PSM)
1910.120: Emergency Response -HAZWOPPER
1910.132: Personal Protective Equipment- PPE
1910.134: Respiratory Protection Program
1910.146: Permit-Required Confined Spaces
Most Common Standards
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1910.147:
1910.157:
1910.178:
1910.179:
1910.180:
1910.184:
1910.217:
1910.266:
1910.268:
1910.269:
1910.401:
Lockout - Tagout
Portable Fire Extinguishers
Powered Industrial Trucks
Overhead and Gantry Cranes
Crawler Locomotive & Truck Cranes
Slings
Mechanical Power Presses
Logging
Telecommunications
Power Gen, Trans, & Distribution
Commercial Diving
Most Common Standards

1910.1001-1910.1052
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
1910.1020: Formerly 1910.20




Expanded Health Standards
Access to Exposure and Medical Records
1910.1030: Bloodborne Pathogens
1910.1200: Hazard Communication
1910.1450: Chemical Hygiene Plan Labs
Maintain in What Form?

Readily Accessible




On or Off Site
24/7/365
How to access
Withstand Changing Technology



Electronic Forms Constantly Changing
Need 30 Plus Years
Software Changes
What about your Contractors?




Do your outside contractors have
the required documentation of their
safety and HEALTH program?
Do you ask?
Do you receive copies?
What programs would you ask for?
Eau
Claire
Madison
Appleton
Milwaukee
For More Help

Kelly Bubolz,

Madison Area Office
4802 E. Broadway
Madison, WI 53716
608-441-5388
Appleton Area Office
1648 Tri Park Way
Appleton, WI 54914
920-734-4521

Mary Bauer,
Eau Claire Area Office
1310 West Clairemont
Eau Claire, WI 54701
715-832-9019
Leslie Ptak,

Pat Ostrenga, Jim Lutz
Milwaukee Area Office
310 W. Wisconsin Ave. Rm 1180
Milwaukee, WI 53203
414-297-3315
QUESTIONS
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 or hazards, 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 employer’s 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 OSHA’s website at www.osha.gov.