Health and Safety Update - WordPress.com · 2016 CMBEN – May 2016 Agenda Massachusetts Hoisting Regulations Latest and Greatest OSHA Standard – Silica Not so New OSHA Standards

2016 CMBEN – May 2016

Health and Safety Update

2016

Alan Stratton

Project Manager

Tighe & Bond

413.875.1604

[email protected]

2016 CMBEN – May 2016

Agenda

■ Massachusetts Hoisting Regulations

■ Latest and Greatest OSHA Standard

– Silica

■ Not so New OSHA Standards

– GHS

– Accident Reporting

■ Oldie but Goodie OSHA Standards

– Lockout / Tagout

– PPE and PPE Hazard Assessments

■ OSHA’s Top 10

2016 CMBEN – May 2016

Massachusetts Hoisting Licenses

Massachusetts Hoisting

■ Regulatory Basis

– Massachusetts Department of Public Safety

– MGL Chapter 146, Section 53 & 520 CMR 6.00

■ Basic Requirements

– Operator of Hoisting Equipment Must Obtain a DPS License

■ 2013 Provisions (November 8, 2013)

– Formalizing of an In-Service Training Program Exemption

■ 2014 Administrative Ruling (November 14, 2014)

– Interpretive exemption for Class 1D operators (Fork Lifts)

Massachusetts Hoisting

■ Mass DPS “Hoist”

– Lift > 10 feet; or

– Lift > 500 pounds; or

– Bucket capacity > ¼ Yd3

■ Hoist Classes

– Class 1 – Hoisting

– Class 2 – Excavating

– Class 3 – Tower/Electric & Air

– Class 4 – Specialty

■ Most Commonly Used Equipment

– Class 1D – Fork Lifts

– Class 3A – Underhung Hoists

Massachusetts Hoisting

■ Key Regulatory Changes / Actions / Interpretations

– November 8, 2013 - Amended 520 CMR 6.00: Hoisting Machinery

» Compliance Option #1:

– Obtain a DPS License for each operator

» Apply, take and pass an exam (requires medical qualification)

» Maintain license (pay renewal fee and continuing education)

» Compliance Option #2

– Obtain an In-Service Training Program Exemption

» Apply for exemption

» Have at least one license holder on-site at all times

» Train employees and issue company licenses

» Renew approval every 2 years

Massachusetts Hoisting

■ Key Regulatory Changes / Actions / Interpretations

– Administrative Ruling No. 2014-03 – November 2014

» No DPS License is Required for:

– Industrial Lift Truck operations

» IF the facility is subject to OSHA General Industry standards

» IF the hoist operates in areas which are not open to the public

» What is “open to the Public”?

– Separated from customer or visitor areas

» What about Deliveries?

– Not considered public if visitors wear PPE, are trained or escorted

Massachusetts Hoisting

■ Which license option is right for you?

– Option #1 - License each operator with DPS:

» PRO - Minimal site administration / No DPS exemption required

» CON - Medical cards / Passing exam / New Hires / CEUs / Liability?

– Option #2 – License each operator with an In-Service program:

» PRO – No individual DPS license / In-house training / New hire training

» CON – DPS license holder must be on-site / In-service Application

must be approved / Renewal every 2 years

Massachusetts Hoisting

■ How to Apply for an In-Service Training Program Exemption

– Submit an Application form (package)

» List the In-Service Training Program Coordinator

» List the In-Service Training Program Supervisor

» List site training Instructors

» List the machinery covered (Make/model)

» Submit Training program

– Inclusive of Mass DPS specific training material

» Provide a sample of the License you plan to issue

» Wait for approval (2-3-4 months)

Massachusetts Hoisting

■ Certain Requirements

Have Gone Away

■ Others Have Not

2016 CMBEN – May 2016

Latest and Greatest OSHA Standard

■ OSHA’s Crystalline Silica Rule

– An estimated 2.3 million workers

are exposed to respirable crystalline

silica in their workplaces.

» About 2 million are in the

construction industry.

» About 295,000 workers are in

over 75,000 general industry and maritime workplaces.

– Exposure to respirable crystalline silica can cause silicosis, lung

cancer, other respiratory diseases, and kidney disease.

2016 CMBEN – May 2016

Latest and Greatest OSHA Standard

■ OSHA’s Crystalline Silica Rule

– OSHA’s previous permissible exposure limits (PELs) for silica were

outdated, inconsistent and did not adequately protect worker health.

– The previous PELs were based on studies from the 1960s and earlier.

– Previous PELs did not reflect more recent scientific evidence showing that

low-level exposures to silica cause serious health effects.

– OSHA estimates this rule will save more than 600 lives annually and

prevent more than 900 new cases of silicosis each year.

– OSHA estimates the new rule will provide net benefits of about $7.7 billion

per year.

2016 CMBEN – May 2016

Latest and Greatest OSHA Standard

■ OSHA’s Crystalline Silica Rule

– Final Rule promulgated March 24, 2016

» One rule for Construction and one for General Industry/Maritime

» Both standards take effect on June 23, 2016

– Compliance dates are staggered (some exceptions)

» General Industry/Maritime Compliance date is June 23, 2018

» Construction Compliance date is June 23, 2017

2016 CMBEN – May 2016

Latest and Greatest OSHA Standard

■ What’s the Change / What do I need to do?

– Verify exposures are below the action level of 25 μg/m

– Protect workers to a PEL of 50 μg/m3

» Prior PELs were based on formulas that were difficult to understand

» Prior PELs for construction were over twice as high as for general industry

» The new PEL is half the previous limit for general industry

» The new PEL is 5 times lower than the previous limit for construction

– Limit access to areas where workers could be exposed above the PEL

– Use dust controls to protect from PEL exposures

2016 CMBEN – May 2016

Latest and Greatest OSHA Standard

■ What’s the Change / What do I need to do?

– Provide respirators when dust controls cannot limit exposures

» Don’t forget to meet OSHA’s respirator standards

– Restrict housekeeping practices that expose workers to silica

– Establish and implement a written exposure control plan

– Medical exams for workers exposed to the action level for 30 days / yr

– Train workers on work operations and ways to limit exposure

– Keep exposure and medical records

2016 CMBEN – May 2016

Not so New OSHA Standards

■ Hazard Communication

Global Harmonized System (effective March 26, 2012)

– Major Elements / Changes

» New Hazard classification process

» New Labels (incoming containers)

» Material Safety Data Sheets

» New / Updated information and training

– Phase-in still in progress

» Update HazCom Plan and finish training by 6-1-2015

– New OSHA inspection Directive issued July 9, 2015

2016 CMBEN – May 2016

Not so New OSHA Standards

■ OSHA Recordkeeping Rule Changes

(Final September 11, 2014)

– Prior Rule

» Within 8 Hours for a fatality

» Within 8 Hours for in-patient hospitalizations of 3 or more workers

– Current Rule

» Within 8 Hours for a fatality

» Within 24 Hours for one or more in-patient hospitalizations

» Within 24 Hours for amputations

» Within 24 Hours for the loss of an eye

2016 CMBEN – May 2016

Oldie but Goodie OSHA Standards

■ Lockout / Tagout (LoTo) Highlights

– Must have LoTo program in place

– Must provide training (affected and authorized)

– Must have written energy control procedures

» Inspect procedures annually

» Inspection verifies authorized employee follows procedure

– Must follow procedures for servicing and maintenance

» Limited exemptions for “normal production operations”

» Energy control required for each and every worker

2016 CMBEN – May 2016

Oldie but Goodie OSHA Standards

■ PPE and PPE Hazard Assessments

– PPE shall be provided, used, and maintained in a sanitary and reliable

condition when there is a hazards capable of causing injury through

absorption, inhalation or physical contact.

– The employer shall assess the workplace to determine if hazards are

present, or are likely to be present, which necessitate the use of

personal protective equipment (PPE).

– The employer shall verify that the workplace hazard assessment has

been performed through a written certification, which includes:

» The workplace evaluated

» The person certifying that the evaluation has been performed

» The date(s) of the hazard assessment

» An identification that the document is a certification of hazard assessment.

2016 CMBEN – May 2016

OSHA Top 10 Updates

I’m from OSHA.

I’m here to help.

2016 CMBEN – May 2016

OSHA Updates

Top 10 List

Fiscal Year 2015 (Oct. 1, 2014 – September 30, 2015)

1. Fall Protection (1926.501) 6,721

2. Hazard Communication (1910.1200) 5,192

3. Scaffolding (1926.451) 4,295

4. Respiratory Protection (1910.134) 3,305

5. Lockout / Tagout (1910.147) 3,002

6. Powered Industrial Trucks (1910.178) 2,760

7. Ladders (1926.1053) 2,489

8. Electrical – Wiring Methods (1910.305) 2,404

9. Machine Guarding (1910.212) 2,295

10. Electrical – General Requirements (1910.303) 1,973

Number of

Citations Citation & Regulation

#10 Electrical – General Requirements

■ Damaged equipment

■ Unlabeled equipment

■ Blocked equipment

■ Arc Flash (NFPA 70E)

#9 Machine Guarding

■ Improper Guards

■ Fixed machinery anchoring

#8 Electrical – Wiring Methods

■ Temporary

■ Damaged Equipment

■ Open boxes / cabinets

■ Flexible cord protection

#7 Ladders - CONSTRUCTION

■ Improper use

■ Positioning with less than

3 feet above top surface

■ Using damaged ladders

#6 Powered

Industrial Trucks

■ Training & refresher training

■ Unsafe Equipment

■ Unapproved attachments

Don’t Forget Other Hoisting Equipment

#5 Lockout / Tagout

■ Energy control procedures

■ Training

■ Application of Energy Control

■ Annual procedure inspections

#4 Respiratory Protection

■ Written respirator program

■ Dust masks = Respirators

■ Medical evaluations

■ Fit Testing

#3 Scaffolding -

CONSTRUCTION

■ Improper design / construction

■ Fall protection

■ Lack of “competent person”

#2 Hazard

Communication

■ Written HazCom program

■ Employee information and training

■ Maintaining MSDS/SDS

■ Labeling

#1 Fall Protection

CONSTRUCTION

■ Inadequate / No fall protection

■ Training

■ Defective equipment

2016 CMBEN – May 2016

Thank You

Alan Stratton

Project Manager

413.875.1604

[email protected]

Offices throughout New England

www.tighebond.com