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Osha Update 2017 July 2017

The document provides information about an OSHA 503 course that covers locating and applying revised OSHA general industry safety standards and policies, recommending current requirements, describing new standards, and identifying training resources. The course topics include OSHA inspection policy and procedures updates, safety program management, and training techniques. It also addresses OSHA recordkeeping requirements and contractor training documentation.

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OSHA Update John Newquist johnanewquist@gmail.com 815-354-6853 Draft 7 2 2017
OSHA 503 • Course Benefits • Locate and apply recently adopted or revised OSHA general industry safety and health standards, policies and procedures • Recommend current OSHA general industry requirements and policies • Describe new general industry standards • Identify training material resources • Apply techniques and resources used by other general industry outreach trainers • Provide a general overview of general industry safety practices • Earn 1.8 CEU or 3.01 CM • Course Topics • OSHA inspection policy updates • OSHA procedures and standards updates • Safety and health program management • Training techniques
Drug Overdose Deaths 1990—2016
May 2017 • The contractor shall document that each of its employees has successfully completed the training required by this subsection by maintaining a record identifying: • 1. Each employee who has received training; • 2. The date(s) and subject(s) of training each employee has received; and, • 3. The means used to verify that the employee understood the training received.
May 2017 • A manager of the Overlook at Mile High in Denver has been sentenced to 8 months in federal prison after his company released asbestos dust during a remodeling project while tenants were still living in the buildings. • Senior federal Judge Lewis Babcock also fined John Tom Williams, 58, $100,000 and ordered him to serve a year of conditional release following his prison term.
May 2017
May 2017 • Industrial project locations experienced the highest number of fatalities with 813 deaths (35%) • Commercial 5% • AGC fatality study 2010-2012
DOL Head • Alexander Acosta • Appointed by President George W. Bush to the National Labor Relations Board and later served as Assistant Attorney General for Civil Rights and federal prosecutor for the Southern District • Acosta became the second dean of Florida International University College of Lawn District of Florida in 2009
OSHA • Loren Sweatt • Political Deputy • Senior Policy Advisor for the House Committee on Education • AGC
July 2017 • OSHA budget • Same as 2008-2016 • $552 million • 2018 • $532 milliom
11
12 2015
IL Body parts
Top Safety Results
Sales Impact of Selected Injuries Injury/ Illness Average Direct Cost Indirect Cost Total Cost Sales Needed (5% profit) Sprain $4,245 $6,792 $11,037 $220,740 Laceration $1,101 $4,955 $6,056 $121,120 Foreign Body $317 $1,427 $1,744 $34,880 15
Monthly Audits
Monthly Audits 0 20 40 60 80 100 120 1/7/05 2/18/05 4/1/05 5/13/05 6/24/05 8/5/05 9/16/05 10/28/05 12/9/05 1/20/06 3/3/06 4/14/06 Week Beginning Number of Safety Inspections 90% 95% 100% 1/7/05 2/18/05 4/1/05 5/13/05 6/24/05 8/5/05 9/16/05 10/28/05 12/9/05 1/20/06 3/3/06 4/14/06 Week Beginning Safety Inspection Scores 17
Monthly Training for Managers
Daily Job Briefings
BLS
BLS • A total of 4,836 fatal work injuries were recorded in the United States in 2015, a slight increase from the 4,821 fatal injuries reported in 2014 • The 937 fatal work injuries in the private construction industry in 2015 represented the highest total since 975 cases in 2008. • Several construction occupations recorded their highest fatality total in years, including • construction laborers (highest since 2008); • carpenters (2009); • electricians (2009); and • plumbers, pipefitters, and steamfitters (2003).
Feb 2018 • $5 million dollar payroll in highway construction. • Annual premium. • $428,000 EMR 1.0 • $238,000 EMR 0.8 • $635,000 EMR 1.3 • Indiana 44% lower.
Feb 2017 • Atlantic Drain Services and its owner, Kevin Otto, have each been indicted on two counts of manslaughter after he and the company "gambled with their employees' lives and safety," • A grand jury also returned an indictments against Otto and Atlantic Drain of one count of misleading an investigator under the state's witness intimidation statute and six counts of concealing records under the evidence tampering statute.
Whistleblower 2017 • When a co-worker severed part of his thumb in July 2014, a food processor at a beef jerky manufacturing plant acted quickly, helping him apply pressure to the wound and using her cellphone to call 911. • Before responders could answer, the company's owner ordered her to hang up. • Two days later, she was terminated. Lonestar Beef Jerky is not associated with this man! He was the previous owner and we acquired his recipes and brand name in 2016 with no knowledge of this or his other deplorable behavior!
Data • If you make it easier to use safety, more likely it will be used and get done. • Cones, grease gun, lockout, brooms. • Kevin O’Leary
Sleep • Individuals who sleep fewer than six hours a night on average have a 13 per cent higher mortality risk than people who sleep at least seven hours. • U.S. sustains by far the highest economic losses up to $411 billion a year or 2.26% GDP • U.S. loses an equivalent of around 1.2 million working days due to insufficient sleep. • Individuals could: Set consistent wake-up times; limit the use of electronic items before bedtime; and exercise. • Employers could: Recognize the importance of sleep and the employer’s role in its promotion; design and build brighter workspaces; combat workplace psychosocial risks; and discourage the extended use of electronic devices. Est. Incidence Rate per Chronobiology 2010 Less than 5 hours – 7.89 5-6 hours – 5.21 6-7 hours – 3.62 7-8 hours - 2.27 8-9 hours - 2.50
Region V Most Cited Areas • Machine Guarding 1910.212(a)(1) • GHS 1910.1200(e) • GHS 1910.1200(h) • 5(a)(1) • Machine Guarding 1910.212(a)(3)
Region V Fall Fatalities 2010-2014 • 25 Ladders • 19 Roofs • 18 Same Surface • 16 Other • 14 Aerial Lift • 9 Nonmoving Vehicle
Region V Fatalities • OSHA in Region 5 had 111 in 2016 investigated fatalities. Down from 140 in 2015 8. • 34 construction 27 manufacturer 50 other • Seeing lack of chocks, backing trucks • 2004-2016 Region V • 449 struck by • 426 fall • 393 caught • 126 electrical
July 2016 • Behr sentenced to probation, $350K restitution in South Beloit plant worker's death
Data • 35% of all fatalities occurred in workers age 55 or older, with 1,691 deaths. • This is the highest number of fatalities ever recorded for this group of workers.
Older workers • The preliminary number of workers ages 55 and older who died on the job was "the highest total ever reported" by the bureau's census. • The number jumped from 1,490 in 2013 to 1,621 in 2014, a 9 percent rise. • 18% of the workforce, 35% of fatalities
June 2016 • Columbus WI • The teen was working at the factory on June 27, 2016 when he was pinned in a machine while cleaning scrap from underneath a laser cutter in operation. • He later died of his injuries on July 2, 2016. • The teen had only been working there two weeks when the incident happened. This IS my sister-in-law's nephew !!! Killed at 17 ... all because of company not following safety rules, providing proper training and equipment to ensure lockout/tagout - DA
Effective Dates • Published in Federal Register November 17, 2016 • Effective January 17, 2017 • Most of the rule will become effective 60 days after publication in the Federal Register, but some provisions have delayed effective dates, including: • Ensuring exposed workers are trained on fall hazards (6 months), • Inspecting and certifying permanent anchorages for rope descent systems (1 year), • Installing personal fall arrest or ladder safety systems on new fixed ladders over 24 feet and on replacement ladders/ladder sections, including fixed ladders on outdoor advertising structures (2 years), • Ensuring existing fixed ladders over 24 feet, including those on outdoor advertising structures, are equipped with a cage, well, personal fall arrest system, or ladder safety system (2 years), and • Replacing cages and wells (used as fall protection) with ladder safety or personal fall arrest systems on all fixed ladders over 24 feet (20 years).
Dockboards • The employer must ensure that each dockboard used meets the requirements of this section. The employer must ensure: • (d) Measures, such as wheel chocks or sand shoes, are used to prevent the transport vehicle (e.g. a truck, semi-trailer, trailer, or rail car) on which a dockboard is placed, from moving while employees are on the dockboard; 1910.26
Work on low-slope roofs • When work is performed less than 6 feet (1.6 m) from the roof edge, the employer must ensure each employee is protected from falling by a guardrail system, safety net system, travel restraint system, or personal fall arrest system. 1910.28(b)(13)(i)
Low Sloped Roofs • When work is performed at least 6 feet (1.6 m) but less than 15 feet (4.6 m) from the roof edge, the employer must ensure each employee is protected from falling by using a guardrail system, safety net system, travel restraint system, or personal fall arrest system. 1910.28(b)(13)(ii)
Flat Roofs • When work is performed 15 feet (4.6 m) or more from the roof edge, the employer must: • (A) Protect each employee from falling by a guardrail system, safety net system, travel restraint system, or personal fall arrest system or a designated area. The employer is not required to provide any fall protection, provided the work is both infrequent and temporary; and • (B) Implement and enforce a work rule prohibiting employees from going within 15 feet (4.6 m) of the roof edge without using fall protection in accordance with paragraphs (b)(13)(i) and (ii) of this section. 1910.28(b)(13)(iii)
Ladder Safety Systems • The employer must ensure: • (1) Each ladder safety system allows the employee to climb up and down using both hands and does not require that the employee continuously hold, push, or pull any part of the system while climbing; (2) The connection between the carrier or lifeline and the point of attachment to the body harness or belt does not exceed 9 inches (23 cm); 1910.29(i)
Training • Training must be understandable. The employer must provide information and training to each employee in a manner that the employee understands 1910.30(d)
Fall Protection Systems • D-rings, snaphooks, and carabiners must be proof tested to a minimum tensile load of 3,600 pounds (16 kN) without cracking, breaking, or incurring permanent deformation. The gate strength of snaphooks and carabiners, must be proof tested to 3,600 lbs. (16 kN) in all directions. 1910.140(c)(8)
CTA
Slideshare
Beryllium • The old exposure limit, established in 1949, was based largely on guesswork and dubbed "the taxicab standard" because a government health official and an industry medical consultant came up with the rule in the back of a taxi. • The new standard will be 0.2 micrograms per cubic meter, much stronger than what OSHA sought in the 1970s.
Criminal 2017 • A crane operator faces involuntary manslaughter charges in a 2014 incident in which his son and another construction worker plummeted to their deaths from above a Winters bridge construction site. • Mark Powell operated the crane that lifted the basket carrying son and operator Marcus Zane Powell and pile driver Glenn Allen Hodgson early May 30, 2014, according to a Cal-OSHA citation. • The hoisted basket they rode aboard broke free, plunging the pair eight stories to their deaths.
Criminal Update 2017 • Wilmer Cueva, 51, of Elmwood Park, New Jersey, a foreman for Sky Materials, was convicted of criminally negligent homicide and reckless endangerment in the death of Carlos Moncayo, 22 during excavation at a Restoration Hardware site. • Sentencing 1-3 years.
IL 19 Times = $241,000 • The four willful violations include the absence of an accident-prevention program; lack of eye and face protective equipment with use of nail guns; no personal fall arrests, guardrails or safety net systems for workers at heights; and anchorage points used for the attachment of personal fall arrest systems were not independent of the anchorage points used to suspend platforms. • This isn't a new experience for Barringer. • Since 2006, Barringer's various businesses -- Barringer Brothers Roofing, Barringer Brothers Inc., and Barringer Brothers Construction Inc. -- have been cited and fined 19 times by OSHA for safety hazards.
Recordkeeping • Final rule to keep OSHA 300, 300A, 301 records for five years. • Effective January 18, 2017
Slideshare
OSHA In Region 5 - 2016 • 6200 inspection in 2015 • 68 Sigcases +14 egregious cases • 47% construction • 44% programmed • 2017 – 20% cut
Leadership in Region V • Ken Atha • 20 Years Experience • Regional Administrator • Area Director
Aug 2016 • Tonawanda NY • There no reason to ever joke about a loved one’s loss due to a workplace death. • "Michelle Reese This is my uncle. Thanks everyone for the condolences. For those making jokes you may kindly F off... I'm sure you wouldn't be joking if it was someone you love"
Aug 2016 • Settlement • The Secretary alleged in the Complaint that US Steel’s Immediate Reporting Policy discourages reasonable employees from reporting injuries as soon as they realize they have been injured because they risk violating US Steel’s temporally stringent requirement under the Immediate Reporting Policy.
April 2017 • The decision cited a number of factors, including A.C. Castle’s checking to ensure that workers were tied off, its responsibility for safety on its worksites, its ability to fire or discipline workers, its directions to Provencher concerning the size of the crew, the presence of A.C. Castle signs and the lack of Provencher signage at worksites and A.C. Castle’s representing that it had no subcontractors when applying for building permits. • Judge Calhoun's decision upheld the bulk of the citations and determined that A.C. Castle is responsible for paying $173,500 in penalties.
Jan 2017 • The new civil penalty amounts • Jan 1 2017 • New serious penalty for 2017 is $12,675 • Repeat - Willful is $126,749 • Size for 1-10 employee2 is 70% 11-25 is 60% 26-100 is 30% 101-250 is 10%
May 2016 • Electronic recordkeeping • Under the new rule, all establishments with 250 or more employees in industries covered by the recordkeeping regulation must electronically submit to OSHA injury and illness information from OSHA Forms 300, 300A, and 301. • Establishments with 20-249 employees in certain industries* must electronically submit information from OSHA Form 300A only. • Website to input 300A at end of March operational. • Due July 1 2017 • Employee names will not be collected
57 1904.35(b)(1)(i) • You must establish a reasonable procedure for employees to report work related injuries and illnesses promptly and accurately. • A procedure is not reasonable if it would deter or discourage a reasonable employee from accurately reporting a workplace injury or illness;
Drug Testing • OSHA’s interprets this rule broadly to prohibit mandatory post- accident drug testing, concluding that such tests discriminate against employees on the basis of injury and illness reporting. • OSHA further explains that incentive programs are retaliatory if they offer benefits to employees or workforces who do not report injuries and illnesses • OSHA announced that it was delaying the enforcement date of the new rules to November 1, 2016 Reporting guidance memo allows latency for ergo injury Cannot use drug testing to discourage report injury. Ex in the Fed Register is Carpal tunnel. Only drug testing an injured in a crane incident.
May 2016 • “1700 pages of discovery later and they folded like a cheap suit.” • “The issue is that 2 employees were wearing orange jackets. When the CSHO was taking photos at 915am there was an employee signaling the crane. • When the CSHO came back at 1pm - Foreman was monitoring and also wearing an orange jacket.”
May 2016
2017
Non Permit Alternate Procedures cont. • Continuous forced air ventilation must be used • atmosphere within the space must be continuously monitored • must ensure a safe method of entering and exiting the space. • written certification that contains the date, the location of the space, and the signature of the person providing the certification. 62 1926.1203(e)(2)
Jan 2017 Gunnebo Johnson Swivel eye hookCrosby Shur Loc
Columns • Columns evaluated whether guying and bracing needed 1926.755(a)(4)
March 2016 • Friday at 3pm • 3-inch slump concrete • Boot stuck • Ripped hamstring • 3800 lbs in 2 days • 4000 lbs design Training, mats, different concrete, stretching
OSHA Training September 2016 • Falls • Confined Space • Work Zone • Cranes/Rigging • Silica • Trenching
OSHA
OSHA
OSHA • “We are swamped with AMPUTATIONS” • OSHA October 2016 • Aurora saw about 100-115 amputations in 2016. • Inspection is about 40%. • Many during setup with machine energized. • They inspect those with failure of machine guarding or lockout. • The minor servicing exemption comes into play.
Ladders as a Last Resort • JLG lift pod
General Duty Emergency Stops
OSHA • First Three Years of CSHO Training • #1000 Initial Compliance. • #1050 Introduction to Safety Standards for Safety Officers (safety career path/safety specialists). • #1250 Introduction to Health Standards for Industrial Hygienists (health career path/industrial hygienists). • #2000 Construction Standards (construction career path/ construction specialists). • #1310 Investigative Interviewing Techniques • #1410 Inspection Techniques and Legal Aspects. • #2450 Evaluation of Safety and Health Management Systems. • #1230 Accident Investigation. • #8200 Incident Command System I-200 course,
OSHA
May 2016• Pillsbury Mills plant in Springfield IL • Joseph Chernis IV, a federal indictment for improper asbestos removal and for making false statements • The penalty on each count is up to five years in prison followed by three years of supervised release and a fine of up to $250,000. • Chernis, of Sherman, is accused of hiring an untrained individual to illegally remove more than 1,000 feet of asbestos pipe insulation from four buildings between October 2014 and August 2015. • "The asbestos debris was stuffed into approximately 300 garbage bags and at least two open-topped cardboard boxes, and left inside vacant buildings at the facility," according to the indictment announcement.
April 2016 • Don Blankenship, the longtime chief executive officer of Massey Energy, was convicted on charges that he violated federal mine safety laws at the company’s Upper Big Branch Mine prior to an April 2010 explosion that killed 29 miners. • One year in prison + $250,000 • This is the maximum sentence allowed under the law.
Jan 2016 • Cincinnati OH • Grand jury indicts two managers • Zachary Henzerling was working at Environmental Enterprises on Dec. 28, 2012, when a fire broke out as he was treating hazardous waste. • The Colerain Township man was burned, and later died from his injuries. • Another worker also was badly burned in the incident.
Oct 2015 • OSHA moves to a new enforcement weighting system that assigns greater value to complex inspections that require more time and resources. • Routine inspections count as one unit, while those requiring greater resources — such as those involving musculoskeletal disorders, chemical exposures, workplace violence, and process safety management violations — count as up to nine units.
Oct 2015 • Since the beginning of the year, more than 20 workers with allegedly bogus OSHA cards have been busted at NY city construction sites, sources familiar with the crackdown said.
Oct 2015 • A jury convicted Griffin Campbell of six counts of involuntary manslaughter, rejecting the third-degree murder charges sought by prosecutors who said Campbell ignored warnings of an imminent collapse.
2016 Problems • Trench 5-6 feet deep. • Spoil at edge. • No access. OSHA fines P.T. Ferro, says Joliet contractor put trench workers in danger The agency proposed penalties of $104,756.
2016 Problems • Holes not secured and covered with steel plate and fenced off.
2016 Problems • Rigging is used when damaged
2016 Problems • Not keeping the 10 feet safe clearance from powerlines • 240 volts temp lights may not be ok to encroach on the 10 foot. • Weatherproofing is not insulation.
2016 Problems • Workers have ZERO documented training in the MUCTD so set up cones and flags haphazardly
May 2016
October 2016
October 2016
October 2016
September 2016
Apr 2016
Nov 2015
April 2015 • Lifting a piece of pine about 5 foot long 18 inches across • “the load made it to the ground ok the hook of the biner caught the strap and held till we lowered it down.” 92 1910.184(d) Inspections. Each day before being used, the sling and all fastenings and attachments shall be inspected for damage or defects by a competent person designated by the employer.
May 2014 • Providence RI • 8 hurt in fall • The US Occupational Safety and Health Administration said the rigging used put excessive weight on a carabiner, causing the metal loop to fail, and the acrobats, who were hanging by their hair, to fall 15 to 20 feet • According to OSHA, circus staff violated both industry practice and the manufacturer’s instructions for using the carabiner by attaching it so it was pulled in three directions, rather than two.
Feb 2016 94 A 26-year-old tower climber is expected to be in intensive care for another ten days after he fell from a guyed tower in Rosenberg, Tex. when his personal fall protection equipment failed after he slipped from a brace on a climbing face as he was descending after a day’s work on an LTE project for AT&T.
Key Changes in Z359.1 • Section 3.2.1.4 • Gate face strength requirements have changed from 220 lbs. (1kN) (old Standard) to 3,600 lbs. (16kN) (new Standard). 95
June 2013 • Officials canceled work on the St. Charles County bridge after a 55- gallon drum being lifted by a crane fell on 51-year-old Jerseyville IL man. • He was pronounced dead at the scene.
Drums 2015
July 2015 • Issues? • “Perfect balance for cowboy boots” • Photo Justin Morrison 98
February 2015 • Genie • Allows a user to exit the platform and work comfortably around the outside of the platform with a 6-ft lanyard. It attaches to a 6- or 8-ft platform on all Genie telescopic and articulating boom lifts with lift heights higher than 40 ft., with the exception of the S-125HD model.
JLG 100
July 2015 • San Luis Obispo, CA • The machine's blades "came around and broke his arm and came around again and broke his arm a little further up the next turnaround," said San Luis Obispo Fire Battalion Chief Neal Berryman • Berryman said the man's head or neck would have been hit next. 101
July 2015 • MIDDLEFIELD, Ohio – Shady Knob violated the law when they allowed a 14-year-old boy to operate machinery, which resulted in him losing his hand. • “Workers under age 18 are prohibited from operating power-driven woodworking machinery, such as the wood planer used here,” said Howard Eberts, OSHA’s area director in Cleveland. 102 Unsafe! Safe
March 2015 • Island Lake IL • The machinist was using sandpaper to remove surface rust from a part of a computer-run machine. • His hand was caught and pulled into rotating parts, breaking his bones. • The worker underwent several surgeries and rehabilitation 103
ANSI B Series The user shall designate, provide, and ensure the use of at least one of the following methods of safeguarding that affords protection for the operator, consistent with the requirements of the task: • guard(s) • safeguarding device(s) • awareness barrier(s) or awareness device(s) • safe work procedure(s). 104
Machine Guarding
Verification Citation $53,900
Silica
Silica
Silica
Standard Permit-Required Confined Spaces • 29 CFR 1910.146 • Four revisions since was made law by OSHA • 29 CFR 1926.1200 110 1910.146(c)(2) If the workplace contains permit spaces, the employer shall inform exposed employees, by posting danger signs or by any other equally effective means, of the existence and location of and the danger posed by the permit spaces.
Sign 111
Coolers 112 Confined space?
Coolers • Nashville TN • When the power was restored to the building on June 17, 2012, Luther went to check on the cooler. • After he entered, the door slammed shut, locking him inside. • The latch release didn’t work • Luther pressed a panic button inside the cooler and the security alerted the police. • The lawsuit claims that a dry ice company recommended that the restaurant use 500 pounds of dry ice in the cooler to prevent the food from spoiling. 113
Cooler 2016 • March 2016 • A woman was found dead inside a freezer at a downtown Atlanta hotel Tuesday morning. • Atlanta police said the body of Caroline Robinson, 61, of East Point, was discovered at the Hotel. • The woman’s family, through The Witherspoon Law Group it hired, said even though the Hotel maintains the freezer’s exit device “worked perfectly,” injuries to Robinson’s hands are consistent with those of a person suffering and struggling to escape. 114
Non Permit • 1910.146(c)(7) A space classified by the employer as a permit- required confined space may be reclassified as a non-permit confined space under the following (4) procedures: • 1) 1910.146(c)(7)(i) - If the permit space poses no actual or potential atmospheric hazards and if ALL HAZARDS within the space are eliminated without entry into the space, the permit space may be reclassified as a non-permit confined space for as long as the non-atmospheric hazards remain eliminated. 115
Non Permit • 1910.146(c)(7) A space classified by the employer as a permit-required confined space may be reclassified as a non-permit confined space under the following (4) procedures: • 2) 1910.146(c)(7)(ii) - If it is necessary to enter the permit space to eliminate hazards, such entry shall be performed under paragraphs (d) through (k) of this section. • If testing and inspection during that entry demonstrate that the hazards within the permit space have been eliminated, the permit space may be reclassified as a non- permit confined space for as long as the hazards remain eliminated 116
Non Permit • 1910.146(c)(7) A space classified by the employer as a permit-required confined space may be reclassified as a non-permit confined space under the following (4) procedures: • 3) 1910.146(c)(7)(iii) - The employer shall document the basis for determining that all hazards in a permit space have been eliminated, through a certification that contains the date, the location of the space, and the signature of the person making the determination. • The certification shall be made available to each employee entering the space or to that employee's authorized representative 117 This document certifies that the ___________________________ (location) has been cleared for a change in status from a Permit Confined Space to a Non-Permit Confined Space provided that the below conditions are met. All entrants/attendants involved in any entry have completed the Confined Space Entry training. All hazards other than atmospheric (e.g., lockout/tag out) can be completed without entry. Any conditions making it unsafe have been eliminated. Date: Certification Completed By:
Non Permit • 1910.146(c)(7) A space classified by the employer as a permit-required confined space may be reclassified as a non-permit confined space under the following (4) procedures: • 4) 1910.146(c)(7)(iv) - If hazards arise within a permit space that has been declassified to a non- permit space under paragraph (c)(7) of this section, each employee in the space shall exit the space. • The employer shall then reevaluate the space and determine whether it must be reclassified as a permit space, in accordance with other applicable provisions of this section. 118
Non Permit • From an interpretation in 1996 • Question 2: May mechanical hazards be eliminated by compliance with § 1910.147? • Answer: Yes 119
• Continuous forced air ventilation must be used….. 1926.1203(b)(2)(v)
• The atmosphere within the space must be continuously monitored 1926.1203(b)(2)(vi)
Certification
Questions? 123

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Osha Update 2017 July 2017

  • 1.
  • 2.
    OSHA 503 • CourseBenefits • Locate and apply recently adopted or revised OSHA general industry safety and health standards, policies and procedures • Recommend current OSHA general industry requirements and policies • Describe new general industry standards • Identify training material resources • Apply techniques and resources used by other general industry outreach trainers • Provide a general overview of general industry safety practices • Earn 1.8 CEU or 3.01 CM • Course Topics • OSHA inspection policy updates • OSHA procedures and standards updates • Safety and health program management • Training techniques
  • 3.
  • 4.
    May 2017 • Thecontractor shall document that each of its employees has successfully completed the training required by this subsection by maintaining a record identifying: • 1. Each employee who has received training; • 2. The date(s) and subject(s) of training each employee has received; and, • 3. The means used to verify that the employee understood the training received.
  • 5.
    May 2017 • Amanager of the Overlook at Mile High in Denver has been sentenced to 8 months in federal prison after his company released asbestos dust during a remodeling project while tenants were still living in the buildings. • Senior federal Judge Lewis Babcock also fined John Tom Williams, 58, $100,000 and ordered him to serve a year of conditional release following his prison term.
  • 6.
  • 7.
    May 2017 • Industrialproject locations experienced the highest number of fatalities with 813 deaths (35%) • Commercial 5% • AGC fatality study 2010-2012
  • 8.
    DOL Head • AlexanderAcosta • Appointed by President George W. Bush to the National Labor Relations Board and later served as Assistant Attorney General for Civil Rights and federal prosecutor for the Southern District • Acosta became the second dean of Florida International University College of Lawn District of Florida in 2009
  • 9.
    OSHA • Loren Sweatt •Political Deputy • Senior Policy Advisor for the House Committee on Education • AGC
  • 10.
    July 2017 • OSHAbudget • Same as 2008-2016 • $552 million • 2018 • $532 milliom
  • 11.
  • 12.
  • 13.
  • 14.
  • 15.
    Sales Impact ofSelected Injuries Injury/ Illness Average Direct Cost Indirect Cost Total Cost Sales Needed (5% profit) Sprain $4,245 $6,792 $11,037 $220,740 Laceration $1,101 $4,955 $6,056 $121,120 Foreign Body $317 $1,427 $1,744 $34,880 15
  • 16.
  • 17.
    Monthly Audits 0 20 40 60 80 100 120 1/7/05 2/18/05 4/1/05 5/13/05 6/24/05 8/5/05 9/16/05 10/28/05 12/9/05 1/20/06 3/3/06 4/14/06 Week Beginning Numberof Safety Inspections 90% 95% 100% 1/7/05 2/18/05 4/1/05 5/13/05 6/24/05 8/5/05 9/16/05 10/28/05 12/9/05 1/20/06 3/3/06 4/14/06 Week Beginning Safety Inspection Scores 17
  • 18.
  • 19.
  • 20.
  • 21.
    BLS • A totalof 4,836 fatal work injuries were recorded in the United States in 2015, a slight increase from the 4,821 fatal injuries reported in 2014 • The 937 fatal work injuries in the private construction industry in 2015 represented the highest total since 975 cases in 2008. • Several construction occupations recorded their highest fatality total in years, including • construction laborers (highest since 2008); • carpenters (2009); • electricians (2009); and • plumbers, pipefitters, and steamfitters (2003).
  • 22.
    Feb 2018 • $5million dollar payroll in highway construction. • Annual premium. • $428,000 EMR 1.0 • $238,000 EMR 0.8 • $635,000 EMR 1.3 • Indiana 44% lower.
  • 23.
    Feb 2017 • AtlanticDrain Services and its owner, Kevin Otto, have each been indicted on two counts of manslaughter after he and the company "gambled with their employees' lives and safety," • A grand jury also returned an indictments against Otto and Atlantic Drain of one count of misleading an investigator under the state's witness intimidation statute and six counts of concealing records under the evidence tampering statute.
  • 24.
    Whistleblower 2017 • Whena co-worker severed part of his thumb in July 2014, a food processor at a beef jerky manufacturing plant acted quickly, helping him apply pressure to the wound and using her cellphone to call 911. • Before responders could answer, the company's owner ordered her to hang up. • Two days later, she was terminated. Lonestar Beef Jerky is not associated with this man! He was the previous owner and we acquired his recipes and brand name in 2016 with no knowledge of this or his other deplorable behavior!
  • 25.
    Data • If youmake it easier to use safety, more likely it will be used and get done. • Cones, grease gun, lockout, brooms. • Kevin O’Leary
  • 26.
    Sleep • Individuals whosleep fewer than six hours a night on average have a 13 per cent higher mortality risk than people who sleep at least seven hours. • U.S. sustains by far the highest economic losses up to $411 billion a year or 2.26% GDP • U.S. loses an equivalent of around 1.2 million working days due to insufficient sleep. • Individuals could: Set consistent wake-up times; limit the use of electronic items before bedtime; and exercise. • Employers could: Recognize the importance of sleep and the employer’s role in its promotion; design and build brighter workspaces; combat workplace psychosocial risks; and discourage the extended use of electronic devices. Est. Incidence Rate per Chronobiology 2010 Less than 5 hours – 7.89 5-6 hours – 5.21 6-7 hours – 3.62 7-8 hours - 2.27 8-9 hours - 2.50
  • 27.
    Region V MostCited Areas • Machine Guarding 1910.212(a)(1) • GHS 1910.1200(e) • GHS 1910.1200(h) • 5(a)(1) • Machine Guarding 1910.212(a)(3)
  • 28.
    Region V FallFatalities 2010-2014 • 25 Ladders • 19 Roofs • 18 Same Surface • 16 Other • 14 Aerial Lift • 9 Nonmoving Vehicle
  • 29.
    Region V Fatalities •OSHA in Region 5 had 111 in 2016 investigated fatalities. Down from 140 in 2015 8. • 34 construction 27 manufacturer 50 other • Seeing lack of chocks, backing trucks • 2004-2016 Region V • 449 struck by • 426 fall • 393 caught • 126 electrical
  • 30.
    July 2016 • Behrsentenced to probation, $350K restitution in South Beloit plant worker's death
  • 31.
    Data • 35% ofall fatalities occurred in workers age 55 or older, with 1,691 deaths. • This is the highest number of fatalities ever recorded for this group of workers.
  • 32.
    Older workers • Thepreliminary number of workers ages 55 and older who died on the job was "the highest total ever reported" by the bureau's census. • The number jumped from 1,490 in 2013 to 1,621 in 2014, a 9 percent rise. • 18% of the workforce, 35% of fatalities
  • 33.
    June 2016 • ColumbusWI • The teen was working at the factory on June 27, 2016 when he was pinned in a machine while cleaning scrap from underneath a laser cutter in operation. • He later died of his injuries on July 2, 2016. • The teen had only been working there two weeks when the incident happened. This IS my sister-in-law's nephew !!! Killed at 17 ... all because of company not following safety rules, providing proper training and equipment to ensure lockout/tagout - DA
  • 34.
    Effective Dates • Publishedin Federal Register November 17, 2016 • Effective January 17, 2017 • Most of the rule will become effective 60 days after publication in the Federal Register, but some provisions have delayed effective dates, including: • Ensuring exposed workers are trained on fall hazards (6 months), • Inspecting and certifying permanent anchorages for rope descent systems (1 year), • Installing personal fall arrest or ladder safety systems on new fixed ladders over 24 feet and on replacement ladders/ladder sections, including fixed ladders on outdoor advertising structures (2 years), • Ensuring existing fixed ladders over 24 feet, including those on outdoor advertising structures, are equipped with a cage, well, personal fall arrest system, or ladder safety system (2 years), and • Replacing cages and wells (used as fall protection) with ladder safety or personal fall arrest systems on all fixed ladders over 24 feet (20 years).
  • 35.
    Dockboards • The employermust ensure that each dockboard used meets the requirements of this section. The employer must ensure: • (d) Measures, such as wheel chocks or sand shoes, are used to prevent the transport vehicle (e.g. a truck, semi-trailer, trailer, or rail car) on which a dockboard is placed, from moving while employees are on the dockboard; 1910.26
  • 36.
    Work on low-sloperoofs • When work is performed less than 6 feet (1.6 m) from the roof edge, the employer must ensure each employee is protected from falling by a guardrail system, safety net system, travel restraint system, or personal fall arrest system. 1910.28(b)(13)(i)
  • 37.
    Low Sloped Roofs •When work is performed at least 6 feet (1.6 m) but less than 15 feet (4.6 m) from the roof edge, the employer must ensure each employee is protected from falling by using a guardrail system, safety net system, travel restraint system, or personal fall arrest system. 1910.28(b)(13)(ii)
  • 38.
    Flat Roofs • Whenwork is performed 15 feet (4.6 m) or more from the roof edge, the employer must: • (A) Protect each employee from falling by a guardrail system, safety net system, travel restraint system, or personal fall arrest system or a designated area. The employer is not required to provide any fall protection, provided the work is both infrequent and temporary; and • (B) Implement and enforce a work rule prohibiting employees from going within 15 feet (4.6 m) of the roof edge without using fall protection in accordance with paragraphs (b)(13)(i) and (ii) of this section. 1910.28(b)(13)(iii)
  • 39.
    Ladder Safety Systems •The employer must ensure: • (1) Each ladder safety system allows the employee to climb up and down using both hands and does not require that the employee continuously hold, push, or pull any part of the system while climbing; (2) The connection between the carrier or lifeline and the point of attachment to the body harness or belt does not exceed 9 inches (23 cm); 1910.29(i)
  • 40.
    Training • Training mustbe understandable. The employer must provide information and training to each employee in a manner that the employee understands 1910.30(d)
  • 41.
    Fall Protection Systems •D-rings, snaphooks, and carabiners must be proof tested to a minimum tensile load of 3,600 pounds (16 kN) without cracking, breaking, or incurring permanent deformation. The gate strength of snaphooks and carabiners, must be proof tested to 3,600 lbs. (16 kN) in all directions. 1910.140(c)(8)
  • 42.
  • 43.
  • 44.
    Beryllium • The oldexposure limit, established in 1949, was based largely on guesswork and dubbed "the taxicab standard" because a government health official and an industry medical consultant came up with the rule in the back of a taxi. • The new standard will be 0.2 micrograms per cubic meter, much stronger than what OSHA sought in the 1970s.
  • 45.
    Criminal 2017 • Acrane operator faces involuntary manslaughter charges in a 2014 incident in which his son and another construction worker plummeted to their deaths from above a Winters bridge construction site. • Mark Powell operated the crane that lifted the basket carrying son and operator Marcus Zane Powell and pile driver Glenn Allen Hodgson early May 30, 2014, according to a Cal-OSHA citation. • The hoisted basket they rode aboard broke free, plunging the pair eight stories to their deaths.
  • 46.
    Criminal Update 2017 •Wilmer Cueva, 51, of Elmwood Park, New Jersey, a foreman for Sky Materials, was convicted of criminally negligent homicide and reckless endangerment in the death of Carlos Moncayo, 22 during excavation at a Restoration Hardware site. • Sentencing 1-3 years.
  • 47.
    IL 19 Times= $241,000 • The four willful violations include the absence of an accident-prevention program; lack of eye and face protective equipment with use of nail guns; no personal fall arrests, guardrails or safety net systems for workers at heights; and anchorage points used for the attachment of personal fall arrest systems were not independent of the anchorage points used to suspend platforms. • This isn't a new experience for Barringer. • Since 2006, Barringer's various businesses -- Barringer Brothers Roofing, Barringer Brothers Inc., and Barringer Brothers Construction Inc. -- have been cited and fined 19 times by OSHA for safety hazards.
  • 48.
    Recordkeeping • Final ruleto keep OSHA 300, 300A, 301 records for five years. • Effective January 18, 2017
  • 49.
  • 50.
    OSHA In Region5 - 2016 • 6200 inspection in 2015 • 68 Sigcases +14 egregious cases • 47% construction • 44% programmed • 2017 – 20% cut
  • 51.
    Leadership in RegionV • Ken Atha • 20 Years Experience • Regional Administrator • Area Director
  • 52.
    Aug 2016 • TonawandaNY • There no reason to ever joke about a loved one’s loss due to a workplace death. • "Michelle Reese This is my uncle. Thanks everyone for the condolences. For those making jokes you may kindly F off... I'm sure you wouldn't be joking if it was someone you love"
  • 53.
    Aug 2016 • Settlement •The Secretary alleged in the Complaint that US Steel’s Immediate Reporting Policy discourages reasonable employees from reporting injuries as soon as they realize they have been injured because they risk violating US Steel’s temporally stringent requirement under the Immediate Reporting Policy.
  • 54.
    April 2017 • Thedecision cited a number of factors, including A.C. Castle’s checking to ensure that workers were tied off, its responsibility for safety on its worksites, its ability to fire or discipline workers, its directions to Provencher concerning the size of the crew, the presence of A.C. Castle signs and the lack of Provencher signage at worksites and A.C. Castle’s representing that it had no subcontractors when applying for building permits. • Judge Calhoun's decision upheld the bulk of the citations and determined that A.C. Castle is responsible for paying $173,500 in penalties.
  • 55.
    Jan 2017 • Thenew civil penalty amounts • Jan 1 2017 • New serious penalty for 2017 is $12,675 • Repeat - Willful is $126,749 • Size for 1-10 employee2 is 70% 11-25 is 60% 26-100 is 30% 101-250 is 10%
  • 56.
    May 2016 • Electronicrecordkeeping • Under the new rule, all establishments with 250 or more employees in industries covered by the recordkeeping regulation must electronically submit to OSHA injury and illness information from OSHA Forms 300, 300A, and 301. • Establishments with 20-249 employees in certain industries* must electronically submit information from OSHA Form 300A only. • Website to input 300A at end of March operational. • Due July 1 2017 • Employee names will not be collected
  • 57.
    57 1904.35(b)(1)(i) • You mustestablish a reasonable procedure for employees to report work related injuries and illnesses promptly and accurately. • A procedure is not reasonable if it would deter or discourage a reasonable employee from accurately reporting a workplace injury or illness;
  • 58.
    Drug Testing • OSHA’sinterprets this rule broadly to prohibit mandatory post- accident drug testing, concluding that such tests discriminate against employees on the basis of injury and illness reporting. • OSHA further explains that incentive programs are retaliatory if they offer benefits to employees or workforces who do not report injuries and illnesses • OSHA announced that it was delaying the enforcement date of the new rules to November 1, 2016 Reporting guidance memo allows latency for ergo injury Cannot use drug testing to discourage report injury. Ex in the Fed Register is Carpal tunnel. Only drug testing an injured in a crane incident.
  • 59.
    May 2016 • “1700pages of discovery later and they folded like a cheap suit.” • “The issue is that 2 employees were wearing orange jackets. When the CSHO was taking photos at 915am there was an employee signaling the crane. • When the CSHO came back at 1pm - Foreman was monitoring and also wearing an orange jacket.”
  • 60.
  • 61.
  • 62.
    Non Permit AlternateProcedures cont. • Continuous forced air ventilation must be used • atmosphere within the space must be continuously monitored • must ensure a safe method of entering and exiting the space. • written certification that contains the date, the location of the space, and the signature of the person providing the certification. 62 1926.1203(e)(2)
  • 63.
    Jan 2017 Gunnebo JohnsonSwivel eye hookCrosby Shur Loc
  • 64.
    Columns • Columns evaluated whetherguying and bracing needed 1926.755(a)(4)
  • 65.
    March 2016 • Fridayat 3pm • 3-inch slump concrete • Boot stuck • Ripped hamstring • 3800 lbs in 2 days • 4000 lbs design Training, mats, different concrete, stretching
  • 66.
    OSHA Training September2016 • Falls • Confined Space • Work Zone • Cranes/Rigging • Silica • Trenching
  • 67.
  • 68.
  • 69.
    OSHA • “We areswamped with AMPUTATIONS” • OSHA October 2016 • Aurora saw about 100-115 amputations in 2016. • Inspection is about 40%. • Many during setup with machine energized. • They inspect those with failure of machine guarding or lockout. • The minor servicing exemption comes into play.
  • 70.
    Ladders as aLast Resort • JLG lift pod
  • 71.
  • 72.
    OSHA • First ThreeYears of CSHO Training • #1000 Initial Compliance. • #1050 Introduction to Safety Standards for Safety Officers (safety career path/safety specialists). • #1250 Introduction to Health Standards for Industrial Hygienists (health career path/industrial hygienists). • #2000 Construction Standards (construction career path/ construction specialists). • #1310 Investigative Interviewing Techniques • #1410 Inspection Techniques and Legal Aspects. • #2450 Evaluation of Safety and Health Management Systems. • #1230 Accident Investigation. • #8200 Incident Command System I-200 course,
  • 73.
  • 74.
    May 2016• PillsburyMills plant in Springfield IL • Joseph Chernis IV, a federal indictment for improper asbestos removal and for making false statements • The penalty on each count is up to five years in prison followed by three years of supervised release and a fine of up to $250,000. • Chernis, of Sherman, is accused of hiring an untrained individual to illegally remove more than 1,000 feet of asbestos pipe insulation from four buildings between October 2014 and August 2015. • "The asbestos debris was stuffed into approximately 300 garbage bags and at least two open-topped cardboard boxes, and left inside vacant buildings at the facility," according to the indictment announcement.
  • 75.
    April 2016 • DonBlankenship, the longtime chief executive officer of Massey Energy, was convicted on charges that he violated federal mine safety laws at the company’s Upper Big Branch Mine prior to an April 2010 explosion that killed 29 miners. • One year in prison + $250,000 • This is the maximum sentence allowed under the law.
  • 76.
    Jan 2016 • CincinnatiOH • Grand jury indicts two managers • Zachary Henzerling was working at Environmental Enterprises on Dec. 28, 2012, when a fire broke out as he was treating hazardous waste. • The Colerain Township man was burned, and later died from his injuries. • Another worker also was badly burned in the incident.
  • 77.
    Oct 2015 • OSHAmoves to a new enforcement weighting system that assigns greater value to complex inspections that require more time and resources. • Routine inspections count as one unit, while those requiring greater resources — such as those involving musculoskeletal disorders, chemical exposures, workplace violence, and process safety management violations — count as up to nine units.
  • 78.
    Oct 2015 • Sincethe beginning of the year, more than 20 workers with allegedly bogus OSHA cards have been busted at NY city construction sites, sources familiar with the crackdown said.
  • 79.
    Oct 2015 • Ajury convicted Griffin Campbell of six counts of involuntary manslaughter, rejecting the third-degree murder charges sought by prosecutors who said Campbell ignored warnings of an imminent collapse.
  • 80.
    2016 Problems • Trench5-6 feet deep. • Spoil at edge. • No access. OSHA fines P.T. Ferro, says Joliet contractor put trench workers in danger The agency proposed penalties of $104,756.
  • 81.
    2016 Problems • Holesnot secured and covered with steel plate and fenced off.
  • 82.
    2016 Problems • Riggingis used when damaged
  • 83.
    2016 Problems • Notkeeping the 10 feet safe clearance from powerlines • 240 volts temp lights may not be ok to encroach on the 10 foot. • Weatherproofing is not insulation.
  • 84.
    2016 Problems • Workershave ZERO documented training in the MUCTD so set up cones and flags haphazardly
  • 85.
  • 86.
  • 87.
  • 88.
  • 89.
  • 90.
  • 91.
  • 92.
    April 2015 • Liftinga piece of pine about 5 foot long 18 inches across • “the load made it to the ground ok the hook of the biner caught the strap and held till we lowered it down.” 92 1910.184(d) Inspections. Each day before being used, the sling and all fastenings and attachments shall be inspected for damage or defects by a competent person designated by the employer.
  • 93.
    May 2014 • ProvidenceRI • 8 hurt in fall • The US Occupational Safety and Health Administration said the rigging used put excessive weight on a carabiner, causing the metal loop to fail, and the acrobats, who were hanging by their hair, to fall 15 to 20 feet • According to OSHA, circus staff violated both industry practice and the manufacturer’s instructions for using the carabiner by attaching it so it was pulled in three directions, rather than two.
  • 94.
    Feb 2016 94 A 26-year-oldtower climber is expected to be in intensive care for another ten days after he fell from a guyed tower in Rosenberg, Tex. when his personal fall protection equipment failed after he slipped from a brace on a climbing face as he was descending after a day’s work on an LTE project for AT&T.
  • 95.
    Key Changes inZ359.1 • Section 3.2.1.4 • Gate face strength requirements have changed from 220 lbs. (1kN) (old Standard) to 3,600 lbs. (16kN) (new Standard). 95
  • 96.
    June 2013 • Officialscanceled work on the St. Charles County bridge after a 55- gallon drum being lifted by a crane fell on 51-year-old Jerseyville IL man. • He was pronounced dead at the scene.
  • 97.
  • 98.
    July 2015 • Issues? •“Perfect balance for cowboy boots” • Photo Justin Morrison 98
  • 99.
    February 2015 • Genie •Allows a user to exit the platform and work comfortably around the outside of the platform with a 6-ft lanyard. It attaches to a 6- or 8-ft platform on all Genie telescopic and articulating boom lifts with lift heights higher than 40 ft., with the exception of the S-125HD model.
  • 100.
  • 101.
    July 2015 • SanLuis Obispo, CA • The machine's blades "came around and broke his arm and came around again and broke his arm a little further up the next turnaround," said San Luis Obispo Fire Battalion Chief Neal Berryman • Berryman said the man's head or neck would have been hit next. 101
  • 102.
    July 2015 • MIDDLEFIELD,Ohio – Shady Knob violated the law when they allowed a 14-year-old boy to operate machinery, which resulted in him losing his hand. • “Workers under age 18 are prohibited from operating power-driven woodworking machinery, such as the wood planer used here,” said Howard Eberts, OSHA’s area director in Cleveland. 102 Unsafe! Safe
  • 103.
    March 2015 • IslandLake IL • The machinist was using sandpaper to remove surface rust from a part of a computer-run machine. • His hand was caught and pulled into rotating parts, breaking his bones. • The worker underwent several surgeries and rehabilitation 103
  • 104.
    ANSI B Series Theuser shall designate, provide, and ensure the use of at least one of the following methods of safeguarding that affords protection for the operator, consistent with the requirements of the task: • guard(s) • safeguarding device(s) • awareness barrier(s) or awareness device(s) • safe work procedure(s). 104
  • 105.
  • 106.
  • 107.
  • 108.
  • 109.
  • 110.
    Standard Permit-Required Confined Spaces •29 CFR 1910.146 • Four revisions since was made law by OSHA • 29 CFR 1926.1200 110 1910.146(c)(2) If the workplace contains permit spaces, the employer shall inform exposed employees, by posting danger signs or by any other equally effective means, of the existence and location of and the danger posed by the permit spaces.
  • 111.
  • 112.
  • 113.
    Coolers • Nashville TN •When the power was restored to the building on June 17, 2012, Luther went to check on the cooler. • After he entered, the door slammed shut, locking him inside. • The latch release didn’t work • Luther pressed a panic button inside the cooler and the security alerted the police. • The lawsuit claims that a dry ice company recommended that the restaurant use 500 pounds of dry ice in the cooler to prevent the food from spoiling. 113
  • 114.
    Cooler 2016 • March2016 • A woman was found dead inside a freezer at a downtown Atlanta hotel Tuesday morning. • Atlanta police said the body of Caroline Robinson, 61, of East Point, was discovered at the Hotel. • The woman’s family, through The Witherspoon Law Group it hired, said even though the Hotel maintains the freezer’s exit device “worked perfectly,” injuries to Robinson’s hands are consistent with those of a person suffering and struggling to escape. 114
  • 115.
    Non Permit • 1910.146(c)(7)A space classified by the employer as a permit- required confined space may be reclassified as a non-permit confined space under the following (4) procedures: • 1) 1910.146(c)(7)(i) - If the permit space poses no actual or potential atmospheric hazards and if ALL HAZARDS within the space are eliminated without entry into the space, the permit space may be reclassified as a non-permit confined space for as long as the non-atmospheric hazards remain eliminated. 115
  • 116.
    Non Permit • 1910.146(c)(7)A space classified by the employer as a permit-required confined space may be reclassified as a non-permit confined space under the following (4) procedures: • 2) 1910.146(c)(7)(ii) - If it is necessary to enter the permit space to eliminate hazards, such entry shall be performed under paragraphs (d) through (k) of this section. • If testing and inspection during that entry demonstrate that the hazards within the permit space have been eliminated, the permit space may be reclassified as a non- permit confined space for as long as the hazards remain eliminated 116
  • 117.
    Non Permit • 1910.146(c)(7)A space classified by the employer as a permit-required confined space may be reclassified as a non-permit confined space under the following (4) procedures: • 3) 1910.146(c)(7)(iii) - The employer shall document the basis for determining that all hazards in a permit space have been eliminated, through a certification that contains the date, the location of the space, and the signature of the person making the determination. • The certification shall be made available to each employee entering the space or to that employee's authorized representative 117 This document certifies that the ___________________________ (location) has been cleared for a change in status from a Permit Confined Space to a Non-Permit Confined Space provided that the below conditions are met. All entrants/attendants involved in any entry have completed the Confined Space Entry training. All hazards other than atmospheric (e.g., lockout/tag out) can be completed without entry. Any conditions making it unsafe have been eliminated. Date: Certification Completed By:
  • 118.
    Non Permit • 1910.146(c)(7)A space classified by the employer as a permit-required confined space may be reclassified as a non-permit confined space under the following (4) procedures: • 4) 1910.146(c)(7)(iv) - If hazards arise within a permit space that has been declassified to a non- permit space under paragraph (c)(7) of this section, each employee in the space shall exit the space. • The employer shall then reevaluate the space and determine whether it must be reclassified as a permit space, in accordance with other applicable provisions of this section. 118
  • 119.
    Non Permit • Froman interpretation in 1996 • Question 2: May mechanical hazards be eliminated by compliance with § 1910.147? • Answer: Yes 119
  • 120.
    • Continuous forcedair ventilation must be used….. 1926.1203(b)(2)(v)
  • 121.
    • The atmospherewithin the space must be continuously monitored 1926.1203(b)(2)(vi)
  • 122.
  • 123.