EHS Regulatory Compliance in 2018 and the Changes That Lie Ahead

EHS Regulatory Compliance
in 2018 and the Changes That
Lie Ahead
Mark Liffers, Practice Director – EHS Consulting
Triumvirate Environmental

Meet Your Moderator
2
Nita Vaidya

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During this Webinar
✓ All lines will be muted.
✓ Communicate via the questions tab in your webinar panel.
✓ Unanswered questions will be responded to personally after the
webinar.
✓ Webinar recording and slides will be emailed to you tomorrow.

Mark Liffers
Practice Director – EHS Consulting
Triumvirate Environmental
4
Meet Your Presenter

What Can You Expect?
5
Overview of Current OSHA
“Top 10”
Insight on Most Common
Violations
Recommendations for
Avoiding Citations

Poll Question
How prepared are you for
your next OSHA
inspection?
6

Agenda
7
Regulatory Update
OSHA’s Top 10
Strategies for Improving Your OSHA Programs
Summary
Q&A

2018 Regulatory Update
• August 9, 2018 – Enforcement of The January 2017 Health Standard for
Beryllium
▪ Extension for some provisions in 2019 (change rooms and showers)
• June 23, 2018 – Provisions of the Health Standard for respirable crystalline silica
became enforceable
• July 27, 2018 – Proposed rule to better protect personally identifiable information
by electronically submitting only OSHA Form 300A.
• October 17, 2018 – Electronically submitted injury/illness data used to target high
accident rate businesses
• November 7, 2018 – Final rule on certification of crane operators issued
• December 10, 2018 – Proposal to revise Beryllium Standard issued
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Regulatory Rulemaking – Pre Rule
Stage
• Communication tower safety
• Emergency response and preparedness
• Mechanical power presses update
• Powered industrial trucks
• Lock-Out/Tag-Out update
• Tree care standard
• Prevention of workplace violence in health care and social assistance
• Blood lead level for medical removal
• Occupational exposure to crystalline silica
▪ Revisions to table 1 in the standard for construction
9

Regulatory Rulemaking – Proposed
Rules
• Occupational exposure to beryllium
• Amendments to the cranes and derricks in construction standard
• Update to the hazard communication standard
• Crane operator qualification in construction
• Cranes and derricks in construction
▪ Exemption expansions for railroad roadway work
• Puerto Rico state plan
• Tracking of workplace injuries and illnesses
10

Regulatory Rulemaking – Final Rule
Stage
• Standards improvement project IV
• Quantitative fit testing protocol
▪ Amendment to the final rule on respiratory protection
• Rules of agency practice and procedure concerning OSHA access to
employee medical records
• Technical corrections to 36 OSHA standards and regulations
11

Regulatory Rulemaking – Long Term
Actions
• Occupational injury and illness recording and reporting requirements
▪ Musculoskeletal disorders (MSD) column
• Infectious diseases
• Process safety management and prevention of major chemical accidents
• Shipyard fall protection
▪ Scaffolds
▪ Ladders
▪ Other working surfaces
12

OSHA Penalties
13
Type of Violation Penalty
Serious Other-Than-Serious
Posting Requirements
$12,934 per violation
Failure to Abate $12,934 per day beyond
the abatement date
Willful or Repeated $129,336 per violation
On January 2, 2018, OSHA fines increased for the
third straight year. OSHA penalties went up by about
2% overall in order to compensate for inflation.
https://www.osha.gov/penalties/

OSHA Enforcement
14
• OSHA conducted 32,408 total inspections in 2017
• 21,244 inspections were the result of a phone/fax
complaint
• OSHA issued 58,702 total violations in 2016
https://www.osha.gov/dep/2017_enforcement_summary.html

Agenda
15
Regulatory Update
OSHA’s Top 10
Strategies for Improving Your OSHA programs
Summary
Q&A

OSHA’s Top 10 for 2018
1. Fall Protection: General Requirements
2. Hazard Communication
3. Scaffolding
4. Respiratory Protection
5. Lockout/Tagout
6. Ladders
7. Powered Industrial Trucks
8. Fall Protection – Training Requirements
9. Machine Guarding
10. Personal Protective Equipment
16

Fall Protection – General
Requirements
(1926.501)
7,216 violations
17

Requirements
OSHA requires that fall protection be
provided at elevations of four feet in
general industry workplaces, six feet
in the construction industry.
18

Requirements
• ANSI Z359 fall protection series of
standards
• ANSI Z359.1 Safety requirements for
personal fall arrest systems,
subsystems and components
• ANSI Z359.2 Minimum requirements
for a comprehensive managed fall
protection program
positioning and travel restraint systems
assisted-rescue and self-rescue
systems, subsystems and components
19

3. Scaffolding
5. Lockout/Tagout
6. Ladders
9. Machine Guarding
20

Hazard
Communication
21
(1910.1200)
4,537 violations

Hazard
Communication
22
Required chemical manufacturers or
importers to classify the hazards of
chemicals which they produce or
import, and all employers to provide
information to their employees about
the hazardous chemicals to which
they are exposed, by means of a
hazard communication program,
labels and other forms of warning,
safety data sheets, and information
and training.

Hazard
Communication
23
Employers shall develop, implement,
and maintain at each workplace, a
written hazard communication
program which at least describes how
the criteria of this section for labels
and other forms or warning, safety
data sheets, and employee
information and training will be met.

Hazard
Communication
24
• A list of the hazardous chemicals
known to be present using a product
identifier that is referenced on the
appropriate safety data sheet (that list
may be complied for the workplace as a
whole or for individual work areas); and
• The methods the employer will use to
inform employees of the hazardous of
non-routine tasks (for example, the
cleaning of reactor vessels), and the
hazards associated with chemicals
contained in unlabeled pipes in their
work areas

Hazard
Communication
25
• The employer shall make the written
hazard communication program
available, upon request, to employees,
their designated representatives, the
Assistant Secretary and the Director
• Where employees must travel between
workplaces during a work shift, i.e. their
work is carried out at more that one
geographical location, the written
hazard communication program may be
kept at the primary workplace facility

3. Scaffolding
5. Lockout/Tagout
6. Ladders
9. Machine Guarding
26

Scaffolding
27
(1926.451)
3,319 violations

Scaffolding
28
Suspended Scaffolds

Scaffolding
29
Supported Scaffolds

3. Scaffolding
5. Lockout/Tagout
6. Ladders
9. Machine Guarding
31

Respiratory
Protection
(1910.134)
3,112 violations
32

Respiratory
Protection
• A respirator shall be provided to each
employee when such equipment is
necessary to protect the health of such
employee
• The employer shall provide the
respirators which are applicable and
suitable for the purpose intended. The
employer shall be responsible for the
establishment and maintenance of a
respiratory protector program
• The program shall cover each employee
required by this section to use a
respirator
33

3. Scaffolding
5. Lockout/Tagout
6. Ladders
9. Machine Guarding
34

Lockout/Tagout
(1910.147)
2,923 violations
35

Lockout/Tagout
• This standard covers the
servicing and maintenance of
machines and equipment in
which the unexpected
energization or start up of the
machines or equipment, or
release of stored energy, could
harm employees
• This standard established
minimum performance
requirements for the control of
such hazardous energy
36

Lockout/Tagout
• Procedures shall be developed,
documented and utilized for the
control of potentially hazardous energy
when employees are engaged in the
activities covered by this section
• The procedures shall clearly and
specifically outline the scope, purpose,
authorization, rules, and techniques to
be utilized for the control of hazardous
energy, and the means to enforce
compliance including, but not limited
to, the following:
37

Lockout/Tagout
• A specific statement of the intended
use of the procedure
• Specific procedural steps for shutting
down, isolating, blocking and securing
machines or equipment to control
hazardous energy
• Specific procedural steps for
placement, removal and transfer of
lockout devices and the responsibility
for them, and
• Specific requirements for testing a
machine or equipment to determine
and verify the effectiveness of lockout
devices, tagout devices, and other
energy control measures
38

3. Scaffolding
5. Lockout/Tagout
6. Ladders
9. Machine Guarding
39

Ladders
(1926.1053)
2,780 violations
40

Ladders
Falls from portable ladders (step,
straight, combination, and
extension) are one of the leading
causes of occupational fatalities
and injuries
41

Ladders
• 29 CFR 1910.23
• In late 2016, OSHA published an
update to its walking-working
surface rules for general industry
• As part of the update, OSHA
combined its previously separate
regulations for portable wood
ladders, portable metal ladders,
and fixed ladders under one
comprehensive ladder standard
42

3. Scaffolding
5. Lockout/Tagout
6. Ladders
9. Machine Guarding
43

Powered Industrial
Trucks
(1910.178)
2,281 violations
44

Powered Industrial
Trucks
45
OSHA defines a powered
industrial truck as a mobile,
power-propelled truck used to
carry, push, pull, stack or tier
materials

Powered
Industrial Trucks
46
• Training program based on the general
principles for safe truck operation, the
types of vehicle(s) being used and the
hazards they create
• Trained operators must know how to do
the job properly and safely, as
demonstrated by workplace evaluations
• Formal (classroom, lecture) training
• Practical (demonstration and practical
exercises) training
• Employers must also certify that each
operator has received the training and
evaluate each operator’s performance at
least one every three years

3. Scaffolding
5. Lockout/Tagout
6. Ladders
9. Machine Guarding
47

Fall Protection –
Training Requirements
(1926.503)
1,978 violations
48

Fall Protection –
Training Requirements
49
• Performance-based
• Use methods that are more
effective
• Classroom, audio-visual,
demonstrations, field training, web-
based, computer-based or other
forms of training
• Training must be performed by a
qualified person and if web, video or
computer-based methods are used,
a qualified person must be available
to answer questions

3. Scaffolding
5. Lockout/Tagout
6. Ladders
9. Machine Guarding
50

Machine
Guarding
(1910.178)
2,281 violations
51

Machine
Guarding
52
Amputations are among the
most severe and disabling
workplace injuries that often
result in permanent disability.
They are widespread and
involve various activities and
equipment.

Machine
Guarding
53
ANSI B11 series of American
National Standards and
Technical Reports consists of
nearly three dozen different
documents that deal with
machine / machinery /
machine tool safety, and they
specify requirements for both
the manufacturers (suppliers)
and users of the machines.

3. Scaffolding
5. Lockout/Tagout
6. Ladders
9. Machine Guarding
54

Personal Protective
Equipment
(1926.102)
1,528 violations
55

Agenda
56
Regulatory Update
OSHA’s Top 10
Summary
Q&A

Improving OSHA Programs
Safety 101!
• Management sets safety policies and
procedures
• After employees are hired, they’re trained
on safe work practices and behaviors
• Supervisors watch workers or have them
watch each other to prevent unsafe
actions
• Inspections find safety problems which are
then corrected
57

Agenda
58
Regulatory Update
OSHA’s Top 10
Summary
Q&A

Summary
59
Regulatory rulemaking
Top 10 is consistent
Have a clear strategy!

Agenda
60
Regulatory Update
OSHA’s Top 10
Summary
Q&A

THANK YOU!
Request a Free OSHA
Consultation:
https://www.triumvirate.com/webinar-offer-regulatory-compliance-review
Mark Liffers: mliffers@triumvirate.com

EHS Regulatory Compliance in 2018 and the Changes That Lie Ahead

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