OSHAA REGULATORY OVER

VIEW FOR HEALTHCARE

New England Healthcare Engineer’s Society

2012 Annual Fall ConferenceSteven Jalowiec, PE, CHFM

Nov. 9, 2011 press release, Dr. Michaels, Assistant Secretary of Labor for OSHA, issued the following statement:

“It is unacceptable that the workers who have dedicated their lives to caring for our loved ones when they are sick are the very same workers who face the highest risk of work-related injury and illness. These injuries can end up destroying a family’s emotional and financial security. While workplace injuries, illnesses and fatalities take an enormous toll on this nation’s economy – the toll on injured workers and their families is intolerable. “

“The rates of injuries and illnesses among hospital and health care workers underscore OSHA’s concern about the safety and health of these workers. OSHA is responding by launching, in the next few months, a National Emphasis Program on Nursing Home and Residential Care Facilities. Through this initiative, we will increase our inspections of these facilities, focusing on back injuries from resident handling or lifting patients; exposure to bloodborne pathogens and other infectious diseases; workplace violence; and slips, trips and falls.”

OSHA INSPECTION TRIGGERS

High-hazard industrieso industries deemed to be of a high-hazard natureo healthcare or construction, will be subject to

more frequent routine inspection.• Employee complaints/referrals

o result of a whistleblower incidento referral from another observing government

agency• High DART Rate

o days away from work, days of restricted work activity or job transfer

o Higher than peer industries locally or nationally

OSHA INSPECTION TRIGGERS Imminent danger

o violation out in the open and highly visibleo seen by concerned individuals or compliance

officer. Fatalities/catastrophic accidents

o incident resulting in a fatality or hospitalization of three or more persons must be reported to OSHA within 8 hours.

o serious events will necessarily prompt an investigation.

Special emphasis programs (SEP)o OSHA’s regulatory agenda always includes areas

of particular concern, such as exposure to lead and combustible dust.

Top 10 Most Frequently Cited StandardsOct. 1, 2010 to Sept. 30, 2011

ALL INDUSTRIES

29 CFR - Code of Federal Regulations1926.451 – Scaffolding 1926.501 – Fall Protection 1910.1200 – Hazard Communication 1910.134 – Respiratory Protection 1910.147 – Control of Hazardous Energy

• Lockout/Tagout 1910.305 – Electrical, Wiring Methods 1910.178 – Powered Industrial Trucks 1926.1053 – Ladders 1910.303 – Electrical, General Requirements 1910.212 – Machine Guarding

Top Ten - SIC Code 8062 - Hospitals October 2010 through September 2011

Standard

# Cited

# Insp Penalty Description

440 83$353,79

2 TOTAL ALL CITATIONS 

19101030

97 29$124,06

4 Bloodborne pathogens.

19101200

26 15 $16,350 Hazard Communication.

19100305

21 13 $6,400Wiring methods,

components, and equipment for general use.

19100303

20 13 $11,985 General requirements.

19040029

19 9 $8,480 Forms.

19100134

19 9 $5,390 Respiratory Protection.

19100147

16 9 $10,850The control of hazardous energy (lockout/tagout).

19040007

14 5 $6,330 General recording criteria.

19100037

14 11 $3,500Maintenance, safeguards,

and operational features for exit routes.

19261101

13 6 $22,100 Asbestos

PART 1910 -- OCCUPATIONAL SAFETY AND HEALTH STANDARDS

Subpart A -- General Subpart B -- Adoption and Extension of Established Federal StandardsSubpart C -- [Removed and Reserved] Subpart D -- Walking - Working Surfaces Subpart E -- Exit Routes and Emergency Planning

Appendix to Subpart E of Part 1910 -- Exit Routes, Emergency Action Plans, and Fire Prevention PlansSubpart F -- Powered Platforms, Manlifts, and Vehicle-Mounted Work Platforms Subpart G -- Occupational Health and Environmental Control Subpart H -- Hazardous Materials Subpart I -- Personal Protective Equipment Subpart J -- General Environmental Controls Subpart K -- Medical and First Aid Subpart L -- Fire Protection Subpart M -- Compressed Gas and Compressed Air Equipment Subpart N -- Materials Handling and Storage Subpart O -- Machinery and Machine Guarding Subpart P -- Hand and Portable Powered Tools and Other Hand-Held Equipment. Subpart Q -- Welding, Cutting, and Brazing.Subpart R -- Special Industries Subpart S – ElectricalSubpart T -- Commercial Diving OperationsSubparts U -- Y [Reserved]Subpart Z -- Toxic and Hazardous Substances

FACILITY ISSUES

• Arc Flash - 1910.333 (NFPA 70E )• Control of Hazardous Energy

o LOTO 1910.147

• Personal Protective Equipment o PPE -1910.132

• Electrical Safety 1910.301-399 o (301-308, 333-335, 399)

FACILITY ISSUES - continued

• Fall Protection 1910.23-28• Shop Tools 1910 Subpart P• Machine /Equipment Guards • 1910 Subpart O

• Hazard Communication Program• 1910 Subpart Z 1910.1200

• Confined Space 1910.146

OSHA TRAINING REQUIREMENTS

Training is required for everything.• best practice regular training • maintain records• tip for compliance

o weekly job box meetings

ARC FLASH POLICY OUTLINE

ARC FLASH POLICY OUTLINE

ARC FLASH POLICY OUTLINE

NOTE: Additional Procedures for each source:ElectricalWaterSteamNatural GasOilBlow Down

Typical LOTO PROCEDURE

Typical LOTO PROCEDURE

PPE PERSONAL PROTECTIVE

EQUIPMENT• Assessment

o assess the hazardo engineering controlo select the necessary PPE

• Universal Precautions• Hearing Conservation 1910.95• Eye & Face Protection 1910.133 • Respiratory Protection 1910.134• Fall Protection

PPE -HEARING CONSERVATION

1910.95(d)(1) When information indicates that any employee's exposure may equal or exceed an 8-hour time-weighted average of 85 decibels, the employer shall develop and implement a monitoring program.

PPE - EYE AND FACE PROTECTION

1910.133(a)(1) The employer shall ensure that each affected employee uses appropriate eye or face protection when exposed to eye or face hazards from flying particles, molten metal, liquid chemicals, acids or caustic liquids, chemical gases or vapors, or potentially injurious light radiation.

PPE –RESPIRATORY PROTECTION

1910.134(a)(1) In the control of those occupational diseases caused by breathing air contaminated with harmful dusts, fogs, fumes, mists, gases, smokes, sprays, or vapors, the primary objective shall be to prevent atmospheric contamination. This shall be accomplished as far as feasible by accepted engineering control measures (for example, enclosure or confinement of the operation, general and local ventilation, and substitution of less toxic materials). When effective engineering controls are not feasible, or while they are being instituted, appropriate respirators shall be used pursuant to this section.

PPE –RESPIRATORY PROTECTION• Engineering Controls

o fume hoods o equipment specific exhaust systemso testing for effectiveness

• 1920.134(c) Respiratory Protection ProgramThis paragraph requires the employer to develop and implement a written respiratory protection program with required worksite-specific procedures and elements for required respirator use.

• Fit testing and medical clearance required for some types of respirators

ELECTRICAL SAFETYTypical OSHA questions:• Is there a description of the circuit or equipment at the job location?• Is there a detailed job description of planned work?• Were the workers performing the tasks qualified to do so?• Can you justify why equipment cannot be de-energized or the job deferred until the next scheduled outage?

• The message is clear: never work on live circuits unless it is absolutely necessary. OSHA allows work on live circuits in some cases, but the reason cannot be simply that turning off the power is inconvenient or will interrupt production.• What about patient care? Could the patient be moved?

FALL PROTECTION• Guarding floor and wall openings and holes, 1910.23

o Skylights• Portable wood ladders, 1910.25• Portable metal ladders, 1910.26• Fixed ladders, 1910.27• Safety requirements for scaffolding, 1910.28• HVAC/Rooftop Equipment

FALL PROTECTION•OSHA Regulation 29 CFR 1910.23 • Guarding Floor and Wall Openings and Holes.• (a) (4) Every skylight, floor opening,

and hole shall be guarded by a standard skylight screen or fixed standard railing on all exposed sides.

•OSHA Regulation 29 CFR 1926.501 Duty to Have Fall Protection• (a) (2) The employer shall determine if the walking/working

surfaces on which the employees are to work have the strength and structural integrity to support employees safely. Employees shall be allowed to work on those surfaces only when the surfaces have the requisite strength and structural integrity.

(b) (4) Holes (i) Each employee on walking/working surface shall be protected from falling through holes (including skylights) more than 6 feet above lower levels by personal fall arrest systems, covers, or guardrail systems erected around such holes. (ii) Each employee on walking/working surface shall be protected from tripping or stepping in the holes (including skylights) by covers.

Two Skylight Tragedies End in Jail Sentences,Apr 28, 2009

FALL PROTECTION

FALL PROTECTION

OSHA requires installation of safety guard rails for the edge of any rooftop within 15 feet of rooftop HVAC equipment.

Horizontal Lifeline System

FALL PROTECTIONLADDER SAFETY

SHOP TOOL SAFETY• Grinders• Table Saws• Shop Air, regulated to < 30 psig• Welding• Fastner guns, Nail Guns• Don’t forget hand tools• Enforce wearing of appropriate PPE

o gloves, safety glasses, dust masks, hearing protection, etc

• Enforce the use and maintenance of equipment guards• Training

SHOP TOOL SAFETY

Also see SawStop

MACHINE/EQUIPMENT GUARDS

YES

NO

HAZARD COMMUNICATION• Written Program• Inventory• MSDS• Right to Know• Spill Response• PPE• Training

CONFINED SPACE"Permit-required confined space (permit space)" means a confined space that has one or more of the following characteristics: (1) Contains or has a potential to contain a hazardous atmosphere; (2) Contains a material that has the potential for engulfing an entrant;(3) Has an internal configuration such that an entrant could be trapped or asphyxiated by inwardly converging walls or by a floor which slopes downward and tapers to a smaller cross-section; or (4) Contains any other recognized serious safety or health hazard.

SPOT THE PROBLEMEXCERCISE

SIGN:FIRE PUMP

RESOURCESOSHA

http://www.osha.gov/

The National Institute for Occupational Safety and Health

(NIOSH)http://www.cdc.gov/niosh/

State OSHA Departments

QUESTIONS

THANK YOUSpecial thanks to Fred Leffingwell,

Assistant Director, Plant Engineering Waterbury Hospital and

Peter Leszczak, PSL Engineering for their contributions to this presentation.

Steven Jalowiec, PE, CHFMstevej06418@yaoo.com

203-228-3480