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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 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? How do I know if I need one? Required Documentation Maintenance/Retention of Records Exposure and Medical Records Tips on Record Maintenance “Paperwork Reduction Act” 1942, 1980 & 1995 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 Require a “program” Don’t Require it written 1910.95: Hearing Conservation Program Newer Standards Requires a Written Program Bloodborne Pathogens Respirator Written Program Periodic Review Industrial Hygiene from an OSHA Perspective 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 Skin Contact - Dermal Hearing Loss Ringing in the Ear Bloodborne Irritant Burns Noise 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 1910.1001-1910.1052 Expanded Health Standards Expanded Standards: 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 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 1910.1020: Formerly 1910.20 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 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: 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 1926.60: Methylenedianiline 1926.62: Lead 1926.64: Process Safety Management 1926.65: Haz Waste Operation & Emer Response 1926.66: Spray Booths Subpart Z: 1926.1101-.1152: Expanded Standards Related Standards PPE 1910.132: General 1910.133: Eye & Face 1910.138: Hand Ventilation: 1910.94 Flammable: 1910.106 LEL/UEL vs. PEL Emergency Response: 1910.120 PSM: 1910.119 Medical Services and First Aid: 1910.151 Expanded Standards: Common Paragraphs Scope and Application Definitions AL / PEL / STEL / Action Level Monitoring Initial & Subsequent Ees Access Regulated Areas Method of Compliance Respiratory Protection Expanded Standard: Common Paragraphs 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? MSDS Observation: Smell, Taste, See, Feel Screening – Next Session Direct Reading Instruments Short Term Sampling- Next Session TWA Sampling – Next Session Bulk Sampling Interviews: Mgmt – Ees Hazard Review Chemical or Hazard: What’s used? How Much? How Often? Previous Sampling? Controls? Existing? Determined Effective? Changes in Process since Determined Maintained? Measured? (Manometer) Sampling: Only way to really know! Qualified Person 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 Engineering Administrative Personal Protective Equipment Training Controls or Abatement Methods Classic Hierarchy: Product Substitution / Elimination Methylene Chloride: Have Avoided at all costs! Asbestos – Limited to No Mfg or Product Containing Engineering Control Ventilation Barrier / Distance / Automation Administrative Controls: Rotation Prohibited for Some Contaminates (Pb) PPE Respirator Hearing Protection Noise: 1910.95(m) Exposure Measurements Sound Level or Dosimeter Readings Retain for 2 Years * HOWEVER, Need to Show Monitoring Results * Audiograms: Employee Info Testing Equipment Information Duration of Affected Employee’s Employment Includes Specific Information Occupational Noise Exposure Assess your workplace! Monitor areas of concern Sample worker’s full-shift noise exposure Engineering Controls or Hearing Protection??? Hearing Conservation Requirements Monitoring Employee Notification Audiometric Testing Hearing Protectors Training Access To Records Recordkeeping Noise Sampling – Some Tools Industrial Hygienists Use: Sound level meter: Spot Checks Noise dosimeters: Exposure Determination Occupational Noise Exposure If full-shift noise exposure averages above the OSHA PEL of 90 dBA (decibels A-weighted) Hearing protection must be provided & used If full-shift noise exposure averages above OSHA Action Level of 85 dBA A hearing conservation program must be implemented Hearing Conservation Program (HCP) Purpose: prevent or reduce progression of noise-induced hearing loss HCP must include: Noise monitoring Hearing protection Hearing testing (audiograms) Training Recordkeeping NRR: EPA Rating Audiometric Testing New Hires Annual Standard Threshold Shifts Testing Equipment Notification to Employee Revised Baselines or Retesting VAN EXEMPTION Respiratory Protection 1910.134 Written Copy of Respiratory Program 1910.134( c)(1)(i)-(ix) Written PLHCP Opinion Fit Testing Certification / Inspection Emergency Use Respiratory Protection When must you provide your workers with respiratory protection? 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 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” 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? Written program Respirator selection Medical Evaluations Fit testing Proper use of respirators Continued effectiveness 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 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 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 Qualitative Quantitative Next Session PortaCount Rep & Equipment Fit Testing Before the use of any negative or positive TIGHT FITTING face piece respirator No Fit Testing Required Hoods, helmets and loose-fitting facepieces Escape-only respirators Voluntary use respirators Hood Helmet Loose-fitting User Seal Check Non-Air Contaminate/Expanded Std. 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 Formerly 1910.20 – 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 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 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 Inform Upon Initial Hire and Annually There after….NOT TRAINED Posting Wisconsin Council of Safety Example Producing the Record after Requested What is a request Who can request 15 days Access To Exposure & Medical Records: 1910.1020 Exposure Record Medical Records MSDS Industrial Hygiene Monitoring Medical Surveillance Results Written Medical Opinions WCS Website w/ sample program: http://www.doa.state.wi.us/docs_view2.asp?docid=2510 Access To Exposure & Medical Records: 1910.1020 Retention Time: 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 Written Exposure Control Plan Training 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 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 Requires employers to: 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 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 1990’s Effective Date: March 6, 1992 1993 FAQ – One of the First Latex Allergies Surfaced and Addressed Collateral Duty Clause: 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: 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: 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 Universal Precautions Engineering Controls Personal Protective Equipment Housekeeping Handling of regulated waste Training Employees 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” “Right to Know” MN Terminology: St. Croix Valley Companies Previously: State of WI The Four Stages of the Program Material Safety Data Sheets (MSDSs) Labeling and Marking Systems Employee Training Written Plan Hazard Communication 1910.1200 Written Program Program MSDS Labeling Training MSDS: Material Safety Data Sheets 30 years after you stop using it Hot Topics: Article Brick / Block = Article Silica = Chemical Exposure if Sawn Electronic Access – Readily Available Devices must be readily accessible in workplace Workers must be trained in their use Must be back-up system to address emergencies Labeling Target Organ Compromises: Additional Training Placarding Allowed HMIS: Paint Industry NFPA Welding Areas Color Coded Bottles Secondary Containers Primary Problem If not used w/in the shift Labeling and Marking Systems HMIS Labels Blue = Health Red = Flammability Yellow = Instability White = Personal Protective Equipment or special protection information Numerical Rating of 04 Labeling and Marking Systems NFPA Diamonds 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? Specific findings or diagnoses unrelated to occupational exposure - Do NOT Possess: Instead - Possess “Written Opinions” from: 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 Can Perform Duties Can Not Perform Duties Can Perform Duties w/ Following Limitations Medical Tests: ER Needs to Know Results 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: 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 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 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.