An update on what's up and coming in terms of OSHA regulations and what you can do to pass your next inspection.

1. OSHA Compliance Update

2. Recent OSHA Fines
• OSHA fines Vallourec Star for 22 Serious
Violations ($94,000)
• OSHA: Contractor Exposed Workers to Fall
Hazards ($52,470)
• OSHA Focus on Temporary Workers
($135,200 for Texas vegetable processor)
• United Airlines Cited by OSHA (101,300)
• Nebraska Co-op ($84,000)

3. OSHA Has Been Busy
• OSHA Conducted 92,000 inspections
• There were over 188,000 violations cited
• There was approximately $240 million in
penalties

4. Top 10 Violations
1. Hazard Communication
2. Respiratory Protection
3. Electrical ‐ Wiring and Equipment
4. Powered Industrial Trucks
5. Lockout/Tagout

5. Top 10 Violations
6. General Machine Guarding
7. Electrical Systems Design (General)
8. Personal Protective Equipment
(General)
9. Fall protection (Guarding Floor/Wall
Openings and Holes)
10. Exit routes

6. OSHA EMPHASIS
PROGRAMS

7. Combustible Dust

8. Background
Organic Dust Fires and Explosions:
• Massachusetts (3 killed, 9 injured)
• North Carolina (6 killed, 38 injured)
• Kentucky (7 killed, 37 injured)
• Georgia (14 killed, many injured)
• Metal Dust Fire and Explosion: Indiana
(1 killed,1 injured)
• Related Experience in the Grain
Handling Industry

9. Organic Dust Fire and Explosion:
Massachusetts
Fire in a foundry shell
molding machine:
Caused a primary explosion in
ducts containing heavy deposits
of Phenol formaldehyde resin
dust
Resulted in:
a dust cloud from ledge dust deposits
outside the ducts and
an explosion in the plant area

10. Organic Dust Fire and Explosion:
Massachusetts
Causal Factors
• Housekeeping to
control dust
accumulations
• Ventilation system
design
• Maintenance of
ovens
• Equipment safety
devices

11. US Chemical
Safety Board
• Found a pattern of
catastrophic dust
explosions
• Recommended that
OSHA take action
• MSDS sheets often
fail to provide dust
explosion
information

12. Definitions
• Combustible dust – a combustible particulate solid
that presents a fire or deflagration hazard when
suspended in air or some other oxidizing medium
over a range of concentrations, regardless of
particle size or shape.
• Minimum explosible concentration (MEC) – the
minimum concentration of combustible dust
suspended in air, measured in mass per unit
volume, that will support a deflagration.

13. Dust Explosion Requirements
With
confinement
there is an
explosion
Dust is COMBUSTIBLE
It must be dispersed in air or another
oxidant in a concentration at or above the
minimum explosible concentration (MEC).
There is an ignition source, such as:
– an electrostatic discharge,
– spark,
– glowing ember,
– hot surface,
– friction heat, or
– a flame that can ignite the
dispersed combustible
mixture

14. Dust Explosion in a Work Area
Some event
disturbs the
settled dust
into a cloud
Dust settles on flat
surfaces Dust
Dust cloud is
ignited and
explodes
Adapted from CSB

15. Combustible Dust Explosion Hazard
May Exist in a Variety of Industries
• dyes,
• coal,
• metals (e.g., aluminum,
chromium, iron,
magnesium, and zinc),
and
• fossil fuel power
15
generation.
• food (e.g., candy, starch,
flour, feed),
• plastics,
• wood,
• rubber,
• furniture,
• textiles,
• pesticides,
• pharmaceuticals,

16. Dust Explosion Hazard
“. . .any industrial process that reduces a combustible
material and some normally noncombustible materials
to a finely divided state presents a potential for a
serious fire or explosion.” (NFPA’s Industrial Fire
Hazards Handbook)

17. Particles
Size:
• Pellets > 2mm diameter
• Granules 0.42mm - 2mm
• Dust particles < 0.42mm (420 ųm)
Hazard increases as particle size decreases:
• Larger surface area for combustion
• Fine particles may have a larger role in
dust cloud ignition and explosion
propagation

18. Particle Size of Common Materials
Common Material Size (microns)
Table salt 100
White granulated sugar 450 - 600
Sand 50+
Talcum (baby) powder 10
Mold spores 10 – 30
Human hair 40 - 300
Flour 1 - 100
Source: OSHA and Filtercorp International Ltd.

19. Particles
Dusts may occur in the process stream and
cause a hazard, regardless of starting particle
size of the material
may
break
into
or

20. Facility Hazard
Analysis

21. Facility Hazard Analysis Components
Carefully identify:
• Materials that can be
combustible when finely
divided;
• Processes which use,
consume, or produce
combustible dusts;
• Equipment in which dust may
be concentrated;
• Open areas where
combustible dusts may build
up;
• Hidden areas where
combustible dusts may
accumulate;
• Means by which dust may
be dispersed in the air;
and
• Potential ignition
sources

22. Dust Combustibility
The primary factor in an analysis
of these hazards is whether
the dust is in fact
combustible.
Determine if a dust cloud will:
• Detonate
• Deflagrate
• Present a fire hazard
• Or will Not burn or ignite
Testing may be necessary

23. General Industry Standards
• Housekeeping
• 1910.22
• Means of Egress
• 1910 Subpart E
• Ventilation
• 1910.94
• Process Safety Management
• 1910.119
• Warning Signs
• 1910.145

24. General Industry Standards
• Permit-Required Confined Spaces
• 1910.146
• Portable Fire Extinguishers
• 1910.157
• Handling Materials
• 1910.176
• Powered Industrial Trucks
• 1910.178
• Welding, Cutting and Brazing
• 1910.252

25. General Industry Standards
• Hazardous (Classified) Locations
• 1910.307
• Hazard Communication
• 1910.1200
• General Duty Clause

26. Applicable NFPA Standards

27. Other Hazard Analysis Considerations
• Hazard analysis also includes assessing
electrical classification issues
• Scenarios in which dust can be disbursed
during failure of operating procedures or
equipment must also be considered
27

28. Prevention and Mitigation
After the hazard analysis is completed, one
or more of the following may be applied:
• Damage control
28
• Prevention
• Dust control
• Ignition control
• Mitigation
Training must be carried out for both
Prevention and Mitigation

29. Dust Control
NFPA 654
• Use cleaning methods
that do not generate
dust clouds;
• Only use vacuum
cleaners approved
for dust collection;
HAZ LOC

30. Training
Employees need to know
• The safe work practices applicable to their job tasks
• The overall plant programs for dust control and
ignition source control
• Emergency procedures
Training must be
• Before they start work
• Periodically to refresh their knowledge
• When reassigned
• When hazards or processes change

31. Inspection Preparedness

32. Site Specific Targeting

33. DIRECTIVE NUMBER: 14-01 (CPL 02)
EFFECTIVE DATE: 03/06/2014
• The Occupational Safety and Health Administration has
issued its annual inspection plan under the Site-Specific
Targeting 2014* program to direct enforcement resources
to workplaces where the highest rates of injuries and
illnesses occur.
• The SST program is one of OSHA's main programmed
inspection plans for high-hazard, non-construction
workplaces that have 20 or more workers. The SST plan is
based on data collected from a survey of 80,000
establishments in high-hazard industries.

34. DIRECTIVE NUMBER: 14-01 (CPL 02)
• As part of the SST-14 program, OSHA is
conducting a study to evaluate the
effectiveness of the program based on
1,260 randomly selected establishments.
• Programmed inspections of nursing and
personal care establishments will continue
under OSHA's Nursing and Personal Care
Facilities National Emphasis Program.

35. DIRECTIVE NUMBER: 14-01 (CPL 02)
• In addition to the SST program, OSHA implements
both national and local emphasis inspection
programs, which include programmed inspections,
to target high-risk hazards and industries. OSHA
currently has 13 National Emphasis Programs that
intensify inspections on hazards or industries such
as lead, silica, shipbreaking, trenching/excavations
and process safety management, and approximately
140 Regional and Local Emphasis Programs.

36. What establishments are on the
Primary List ?
• Manufacturing Establishments
• Manufacturing establishments with a DART rate at or above 7.0
or a DAFWII case rate at or above 5.0 (only one of these criteria
must be met).
• Non-manufacturing Establishments
• Non-manufacturing establishments (except for Nursing and
Personal Care Facilities) with a DART rate at or above 15.0 or a
DAFWII rate at or above 14.0 (only one of these criteria must be
met).

37. DART Rate
• DART Rate - includes cases involving days
away from work, restricted work activity, and
transfers to another job. It is calculated
based on (N/EH) x (200,000) where N is the
number of cases involving days away and/or
restricted work activity, and/or job transfers;
EH is the total number of hours worked by all
employees during the calendar year; and
200,000 is the base number of hours worked
for 100 full-time equivalent employees.

38. DAFWII Case Rate
• is the number of cases that involve days away from work
per 100 full-time equivalent employees. Cases that involve
only temporary transfers to another job or restricted work
are not included. It is calculated based on (N/EH) x
(200,000) where N is the number of cases involving days
away from work; EH is the total number of hours worked by
all employees during the calendar year; and 200,000 is the
base number of hours worked for 100 full-time equivalent
employees.
• NOTE: The DART and DAFWII rates are differentiated by
the makeup of N in the calculation formula. For the DAFWII
rate, N is equal to the total of Column H from the OSHA-
300 Log.

39. What Establishments Are on
the Secondary List?
• If an Area Office completes its inspections of
all establishments on its Primary Inspection
List before the expiration of this SST
program, it may obtain additional
establishments from its Secondary
Inspection List.

40. What Establishments Are on
the Secondary List?
• Manufacturing Establishments.
• Establishments reporting DART rates of 5.0 or greater, or a
DAFWII case rate of 4.0 or greater. Only one of these criteria
must be met.
• Non-manufacturing Establishments (not
including Nursing and Personal Care
Facilities).
• Establishments reporting DART rates of 7.0 or greater, or a
DAFWII case rate of 5.0 or greater. Only one of these criteria
must be met.1

41. Are you ready for OSHA to
knock at the door?

42. OSHA Inspections:
Preparation is Key!

43. Form a Committee
• EH&S
• Facilities Dept.
• Maintenance
• Environmental Services
• Clinical Lab
• Researcher Admin.
• Radiology
• Pharmacy
• Plant Operators

44. OSHA Inspections - Tips
• Be Prepared!
• Maintain up-to-date plans and records
• Know where documents are; be able to produce them in a
timely manner
• Have a Preparedness Plan
• Records and Documentation Review
• Assemble materials requested by OSHA
• Identify conference room (do not use offices) for records
review
• Offer only requested documents for specific locations
• Make duplicate copies of records that they copy

45. Organize Internal Resources
• Preparedness Coordinating Committee
• Facility Program Managers/Experts
• Facility Inspector Escorts
• Logistics and Planning
• Roles & Responsibilities
• Communications

46. Inspection Preparedness
Coordinating Committee
• Organizes and facilitates the Opening
Conference
• Works out schedule with the inspectors
• Coordinates inspections with
department/program managers
• Conducts daily debriefings
• Organizes and facilitates the Closing
Conference

47. Facility Inspector Escorts
•Introduces the inspector and convey
seriousness of the interview.
•Intercedes when leading questions are asked
during an interview
•Tactfully restates misunderstood questions to
interviewee.
•Doesn’t allow unqualified people to respond to
questions

48. The Inspection

49. Inspections:
Logistics and Planning
• Internal Notification (“The
British are Coming”)
• Enacting the
Preparedness Plan
• Opening Conference
• Coordinating a schedule
with OSHA
• Debriefings with parties
inspecten

50. Opening Conference
• State that the group has been assembled to help
facilitate the inspectors’ review & provide an open
communication channel w/ key facility officials
• Outline positive working relationship with OSHA
inspectors
• Discuss how important compliance is to your facility
• Who in upper management is involved and how
often your department meets with them
• Obtain an understanding of inspection scope

51. Guidelines: Site Inspection
• Identify nature and scope of inspection
• Accompany each inspector at all times
• Cooperate, but do not offer information not
requested
• Duplicate all records copied
• Take good notes, photographs, split samples
• Monitor employee interviews
• Conduct an exit interview for each area to get an
idea of what they found

52. Facility Escort Guidelines
• Restate unclear answers from the
interviewee to the OSHA inspector.
• Stay by the inspectors side
• Take notes
• During and shortly after the interview
• Of issues that the inspector notes during the
inspection
• Of questions that could not be answered

53. Taking care of business
• Fixing Potential Violations
• As issues are found
• Prior to OSHA entry
• Before OSHA finishes for the day
• Behind the Scenes During the Inspection
• OSHA Location during the day
• Fielding questions

54. Closing Conference
• Consider having VP
level representative
and attorney present
• Present
documentation of
correction actions
taken during the
inspection
• Have answers to
questions that
couldn’t be
answered in the field

55. More Guidelines
• Take notes
• Don’t attempt to deal with hypothetical situations
• “Fix” simple deficiencies along the way
• Make a copy of anything given to the inspectors
• Seek approval for all photos requested by the
inspectors; take duplicate photos
• Likewise, take duplicate samples

56. Guidelines Continued…
• Don’t offer an opinion or agree/disagree with
the inspectors
• Do talk about sports, music, general topics
• Don’t be their “buddy” or confidant
• Don’t sign anything
• Keep them from harm’s way (no confined
space entry or near high hazard areas)

57. Guidelines Continued…
• Don’t offer information unless specifically asked
• Don’t argue with the inspectors
• Don’t complain about the regulations
• Don’t be pushed into giving an answer if you don’t
know…say that you don’t know
• Don’t be evasive. Answer directly and succinctly
• Don’t lie to the inspectors or misrepresent what
really happens in your area
• Don’t engage in speculation

58. Training Requirements

59. OSHA Regulations Requiring Training
• 1910.38 - Emergency Action
Plans
• 1910.39 - Fire Prevention
Plans
• 1910.66 - Powered Platforms
for Building Maintenance
• 1910.95 – Occupational
Noise Exposure
• 1910.106 – Flammable and
Combustible Liquids
• 1910.109 - Explosive and
Blasting Agents
• 1910.110 - Storage and
Handling of Liquefied
Petroleum Gases
• 1910.111 - Storage and
Handling of Anhydrous
Ammonia
• 1910.119 - Process Safety
Management of Highly
Hazardous Chemicals
• 1910.120 - Hazardous Waste
Operations and Emergency
Response

60. OSHA Regulations Requiring Training
• 1910.124 - General
Requirements for Dipping
and Coating Operations
• 1910.132 – Personal
Protective Equipment
• 1910.134 – Respiratory
Protection
• 1910.142 - Temporary Labor
Camps
• 1910.145 - Specifications for
Accident Prevention Signs
and Tags
• 1910.146 – Permit Required
Confined Spaces
• 1910.147 – The Control of
Hazardous Energy (lockout-tagout)
• 1910.151 - Medical Services
and First-Aid
• 1910.155 – 1910.165 – Fire
Protection (includes portable
fire extinguishers)

61. OSHA Regulations Requiring Training
• 1910.177 - Servicing of Multi-
Piece and Single-Piece Rim
Wheels
• 1910.178 – Powered
Industrial Trucks (forklift
operator training)
• 1910.179 – Overhead and
Gantry Cranes
• 1910.180 – Crawler,
Locomotives and Truck
Cranes
• 1910.181 – Derricks (material
handling)
• 1910.183 – Helicopters (for
material handling)
• 1910.184 – Slings (material
handling)
• 1910.217 – Mechanical
Power Presses
• 1910.218 – Forging
Machines
• 1910.252 – 1910.255 –
Welding, Cutting and Brazing

62. OSHA Regulations Requiring Training
• 1910.261 - Pulp, Paper, and
Paperboard Mills
• 1910.262 – Textiles
• 1910.264 - Laundry
Machinery and Operations
• 1910.265 – Sawmills
• 1910.266 – Logging
Operations
• 1910.268 –
Telecommunications
• 1910.269 - Electric Power
Generation, Transmission,
and Distribution
• 1910.272 – Grain Handling
Facilities
• 1910.332 – 1910.333 –
Electrical Safety Related
Work Practices
• 1910.410 – 1910.440 -
Commercial Diving
Operations

63. OSHA Regulations Requiring Training
• 1910.1000 – Toxic and
Hazardous Substances
• 1910.1001 – Asbestos
• 1910.1003 – 1910.1016 –
Thirteen Carcinogens
• 1910.1017 – Vinyl Chloride
• 1910.1018 – Inorganic
Arsenic
• 1910.1020 - Access to
Employee Exposure and
Medical Records
• 1910.1025 – Lead
• 1910.1026 - Chromium (VI)
• 1910.1027 – Cadmium
• 1910.1028 – Benzene
• 1910.1029 - Coke Oven
Emissions
• 1910.1030 – Bloodborne
Pathogens
• 1910.1043 – Cotton Dust

64. OSHA Regulations Requiring Training
• 1910.1044 - 1,2-Dibromo-3-
Chloropropane
• 1910.1045 - Acrylonitrile
(Vinyl Cyanide)
• 1910.1047 - Ethylene Oxide
• 1910.1048 – Formaldehyde
• 1910.1050 –
Methylenedianiline
• 1910.1051 - 1,3-Butadiene
• 1910.1052 - Methylene
Chloride
• 1910.1096 – Ionizing
Radiation
• 1910.1200 – Hazard
Communication
• 1910.1450 - Occupational
Exposure to Hazardous
Chemicals in Laboratories

65. Electrical Standard Changes

66. Proposed Silica
Rule Changes

67. Exposure to Silica
• OSHA's Notice of Proposed Rulemaking (NPRM) for
Occupational Exposure to Respirable Crystalline
Silica was published in the Federal Register on
September 12, 2013
• OSHA currently enforces 40-year-old permissible
exposure limits (PELs) for crystalline silica in
general industry, construction and shipyards that are
outdated, inconsistent between industries, and do
not adequately protect worker health. The proposed
rule brings protections into the 21st century.

68. What is New?
• The proposed standard for general industry
and maritime includes provisions for
employers to:
- Measure the amount of silica that workers
are exposed to if it may be at or above an
action level of 25 μg/m3 (micrograms of
silica per cubic meter of air), averaged over
an 8-hour day;

69. What is New?
• Protect workers from respirable crystalline
silica exposures above the permissible
exposure limit (PEL) of 50 μg/m3,
averaged over an 8-hour day;
• Limit workers’ access to areas where they
could be exposed above the PEL;
• Use dust controls to protect workers from
silica exposures above the PEL;

70. What is New?
• Provide respirators to workers when dust
controls cannot limit exposures to the PEL;
• Remember! This will require a written
program, fit testing, etc….
• Offer medical exams-including chest X-rays
and lung function tests-every three years for
workers exposed above the PEL for 30 or
more days per year;

71. What is New?
• Train workers on work operations that
result in silica exposure and ways to limit
exposure; and
• Keep records of workers’ silica exposure
and medical exams.
• OSHA is out enforcing the old standard!!!

72. Preparedness

73. Be Ready!
• Develop an OSHA compliance calendar
• Ensure all of the required written plans are
up to date
• Develop a training matrix
• Keep records organized and ready for
inspection

74. Be Ready!
• Review the OSHA 300 Log
• Conduct internal inspections
• Involve employees to get their buy-in
• Enforce programs such as personal
protective equipment, safety devices, etc..

75. Thank You!
1-888-TEI-WOWS www.triumvirate.com

76. Locations
Eliot, ME
Lowell, MA
Somerville, MA
Portland, CT
Astoria, NY
Woodstown, NJ
Jeannette, PA
Baltimore, MD
Ashland, VA
Orlando, FL
Davie, FL