OSHA Emphasis Programs in Florida. PRESENTED B: Joan M. Spencer Compliance Assistance Specialist Tampa Area Office

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1 OSHA Emphasis Programs in Florida PRESENTED B: Joan M. Spencer Compliance Assistance Specialist Tampa Area Office

2 On Which Emphasis Programs are Based

3 National Emphasis Programs Crystalline silica Lead Combustible dust Oil refineries Trenching Amputations Shipbreaking operations

4 National Emphasis Programs Primary Metal Chemical plants Hexavalent Chromium Diacetyl Federal Agencies Nursing and Residential Care Facilities

5 Regional Emphasis Programs Lead Silica Noise Sharps Health Hazards in Scrap and Waste Materials Recycling Operations

6 Regional Emphasis Programs Forklifts Overhead Powerlines Falls Landscaping Methylene Chloride Sanitation and Clean-up operations Food and Kindred Products.

Combustible Dust Explosions History January 29, 2003 - West Pharmaceutical Services, Kinston, NC Six deaths, dozens of injuries Facility

7 Combustible Dust Explosions History January 29, West Pharmaceutical Services, Kinston, NC Six deaths, dozens of injuries Facility produced rubber stoppers and other products for medical use Plastic powder accumulated above suspended ceiling ignited Polyethylene dust

8 Imperial Sugar 14 Fatalities Forensic Investigation $5.062 million egregious citations

9 OSHA History November 2006 CSB issued a report on their Combustible Dust hazard Study OSHA Recommendations Issue a standard Revise Hazard Communication Standard Communicate to European Union on GHS for Combustible Dust Provide Training Implement a NEP

10 OSHA History October 2007 OSHA launches its Combustible Dust NEP Focus facilities that generate or handle combustible dust which pose a deflagration/explosion hazard Winter 2008 Imperial Sugar Dust explosion March 2008 OSHA revises combustible dust NEP to better focus on most hazardous industries

11 Top Ten Industries Inspected under NEP Wood Products Food Products Chemical Industries Metal Products Rubber/Plastic Prod Primary Metal Elec/Sanitary Serv. Furniture Transp. Equip Dur. Goods

12 Types of Dust Involved in incidents

13 Types of Industries Involved in Dust Incidents

14 What is Combustible Dust? NFPA 69 (2002), and 499 (2004) Definitions Combustible Dust. Any finely divided solid material 420 microns or less in diameter (i.e., material passing through a U.S. No 40 Standard Sieve) that presents a fire or explosion hazard when dispersed

15 Hazard Mitigation Dust control Ignition source control Damage control

16 Dust Control Design of facility & process equipment Contain combustible dust Clean fugitive dust Regular program Access to hidden areas Safe cleaning methods Maintenance

18 Dust Layer Thickness Guidelines 1/8 in grain standard Rule of thumb in NFPA 654 1/32 over 5% of area Bar joist surface area ~ 5% Max 20,000 SF Idealized Consider point in cleaning cycle

20 Lab Tests and Results Percent through 40 mesh Percent moisture content Percent combustible material Percent combustible dust Metal dusts will include resistivity Minimum explosive concentration (MEC) Minimum ignition energy (MIE) Class II test Sample weight Maximum normalized rate of pressure rise (dp/dt) Kst Test Minimum ignition temperature

21 Ignition Source Control Electrical equipment Static electricity control Mechanical sparks & friction Open flame control Design of heating systems & heated surfaces Use of tools & vehicles Maintenance

23 Damage Control Construction Detachment (outside or other bldg.) Separation (distance with in same room) Segregation (barrier) Pressure resistant construction Pressure relieving construction Pressure Venting Relief valves Maintenance

24 Damage Control Systems Specialized detection systems Specialized suppression systems Explosion prevention systems Maintenance

25 Applicable Standards Existing OSHA Standards housekeeping emergency action plans ventilation process safety management electric power generation grain handling facilities

26 Applicable Standards Existing OSHA Standards (cont) hazardous locations hazard communication Section 5(a)(1) General Dusty Clause Applicable ANSI and NFPA standards

27 Combustible Dust Inspection Data November 1, 2007 March 6, 2009

28 Combustible Dust Related Violations (a)(1) HazCom Fire Extinguishers Electrical (Haz Loc) House Keeping Compressed Air PPE First Aid

29 OSHA Findings Under the NEP Hazardous levels of dust accumulations in workplaces due to poor housekeeping Process equipment such as grinders, ventilation ducts, shakers, baghouses, and bagging equipment not designed or maintained to keep dust out of surrounding areas

30 OSHA Findings Under the NEP Electrical equipment and vacuums not approved for locations handling combustible dust Powered industrial trucks not approved for locations handling combustible dust Hot work performed in dust handling locations without hot work procedures

31 OSHA Findings Under the NEP Heating appliances with open flames used in dust handling or generating areas Lack of preventative maintenance on mechanical equipment creating heat and friction Baghouses located inside buildings without proper explosion protection systems

32 OSHA Findings Under the NEP Dust work lacking in venting or explosion suppression systems Deflagration isolation systems not provided Rooms with no explosion relief systems Horizontal surfaces not minimized

33 OSHA Findings Under the NEP Explosions vents or suppression systems not provided on hoppers, silos, bucket elevators, and dust collectors Baghouses located indoors Explosion venting directed into work areas rather than to the outside

35 How is Cr (VI) Formed? Created during hot work processes such as welding on stainless steel or the melting of chromium metal Chromium metal is ionized into the fume high temperatures and chemical reactions temporarily oxidizes the chromium ion into a hexavalent (+6) state

36 Major Industries Electroplating Welding on stainless steel or Cr(VI) painted surfaces Painting Aerospace Auto body repair Chromate pigment and chemical production Chromium dye and catalyst production Glass manufacturing Plastic colorant production Construction Traffic painting Refractory brick restoration Paint removal from bridges

37 Chrome 6 NEP Goals Significantly reduce the number of employees who are exposed to Cr(VI) and other toxic substances often found in conjunction with Cr(VI) at levels that exceed the applicable permissible exposure limits Control health hazards associated with such exposures

38 Inspection Procedures CSHO will consider and evaluate employee exposure and compliance in regard to : Regular operations Setup and preparation for regular operations Making adjustments during operations Cleaning of the process area Scheduled and unscheduled maintenance Implementation of engineering controls Use of PPE Medical Surveillance programs Employee training and education

39 Inspection Procedures Personal exposure monitoring required in all cases where exposure is present CSHO will take properly calibrated instruments and sampling media on first day of inspection Includes adequate materials to immediately ship Cr(VI) sampling media to lab If no monitoring conducted, explanation MUST be included in case file CSHO should NOT rely solely on employer sampling

41 Chrome 6 Findings FY Inspections Nationwide 854 Citations 43 Inspections Region wide (27%) 259 Citations (30%)

42 Chrome 6 Findings FY citations for Region Some citations Most citations were safety related Walking working surfaces Machine guarding LOTO PPE Electrical PIT and a couple of Hazwoper and PRCS citations

43 Health Hazards in Scrap Metal Recycling Operations REP 56 million tons of scrap iron and steel 1.5 million tons of scrap copper 2.5 million tons of scrap aluminum 1.3 million tons of scrap lead, 300,000 tons of scrap zinc 800,000 tons of scrap stainless steel

Health Hazards in Scrap Metal Recycling Operations REP Private, nonferrous recycling industries in the U.S. employed approximately 16,000 employees in 2001.

44 Health Hazards in Scrap Metal Recycling Operations REP Private, nonferrous recycling industries in the U.S. employed approximately 16,000 employees in In 2001, those nonferrous recycling industries reported approximately 3,000 injuries and illnesses.

45 Health Hazards in Scrap Metal Recycling Operations REP The most common causes of illness were poisoning (e.g., lead or cadmium poisoning), disorders associated with repeated trauma, skin diseases or disorders, and respiratory conditions due to inhalation of, or other contact with, toxic agents.

46 Health Hazards in Scrap Metal Recycling Operations REP Reduce exposures to metal fumes, gases, noise, heat, radiation. Safety hazards from risk of fire, machine guarding, struck-by hazards.

48 Health Hazards in Scrap Metal Recycling Operations REP FY 2011 Region conducted 103 inspections Covered 1,690 employees 400 Citations 635,000 in penalties

49 REP Findings Heath related citations issued under: Lead Noise Hazard communication Respiratory protection

50 Health Hazards in Scrap Metal Recycling Operations REP Safety related citations issued under: Walking working surfaces First-aid Machine guarding LOTO Welding and cutting Electrical PIT and one PRCS

51 Noise REP Ten million people in the U.S. have a noise-related hearing loss. Twenty-two million workers are exposed to potentially damaging noise each year. In 2008, approximately 2 million U.S. workers were exposed to noise levels at work that put them at risk of hearing loss. In 2007, approximately 23,000 cases were reported of occupational hearing loss that was great enough to cause hearing impairment. Reported cases of hearing loss accounted for 14% of occupational illness in In 2007, approximately 82% of the cases involving occupational hearing loss were reported among workers in the manufacturing sector. Source: OSHA Website

52 234% of the daily permissible noise level

53 727% of the daily permissible noise level

54 Noise REP Sawmills Planning Mills Wood Pallets and Skids Manufacturers Concrete Products Manufacturers (except block and brick) Plastic Products Industry. SICs include 2421, 2448, 3272, and 3089.

55 Noise REP Findings: 92 Inspections (mostly GA) Mostly safety violations PIT Machine guarding Electrical LOTO 24 noise violations

56 Lead REP OSHA's five-year strategic plan sets a performance goal of a 15% reduction in the average severity of lead exposure or employee blood lead levels in selected industries and workplaces. Scope includes all Industries which lead exposure is a potential

57 Lead REP All establishments that were cited for lead exposures within the past ten fiscal years shall be scheduled for inspection SICs selected by NEP

58 Inspection Procedures Personal air monitoring Collect wipe samples. Monitoring may not be necessary if the employer provides reliable and recent data showing employees exposures are below the action level and the conditions in the work place are the same

59 Inspection Procedures Evaluation of engineering controls and administrative control for the processes where lead exposures above the permissible exposure limit occur. A detailed evaluation of the employer s personal protective equipment (PPE) and respiratory protection programs will be conducted on every inspection where lead hazards exist.

60 Inspection Procedures The employer s hygiene program will be reviewed to determine if hand-to- mouth contact may be contributing to employee exposure to lead. The housekeeping procedures and evaluation and use of PPE will be assessed and documented.

62 Lead REP Findings FY Inspections Covered 2,971 employees 45 lead citations $10,262 average penalty per inspection SICs selected by NEP

63 Silica REP Goal is to significantly reduce/eliminate employee overexposures to crystalline silica and, therefore, control the health hazards associated with such exposures.

64 Silica REP All industries were silica overexposure has been documented in the Region SICs selected by NEP

65 Inspection Procedures Employee exposure monitoring for respirable dust containing crystalline silica Bulk samples Review any existing employer's silica exposure monitoring records. Citations for results over the PEL regardless of PPE

66 Inspection Procedures Engineering and Work Practice Controls: Location of employee(s) with respect to dust generation source Isolation (e.g., control room, enclosures, or barriers) Local exhaust ventilation (LEV) systems Wet methods for cutting, chipping, drilling, sawing, grinding, etc Use of HEPA-equipped vacuums or wet sweeping for cleaning.

67 Inspection Procedures Compressed air usage Substitution with non-crystalline silica material. Use of tools with dust collecting systems. Controls for abrasive blasting (specific standard)

68 Inspection Procedures Respiratory Protection: Minimum Respiratory Protection: N95 Medical Evaluations for Respirator Use Employees who refuse to be medically evaluated cannot be assigned to work in areas where they are required to wear a respirator.

69 Inspection Procedures Hazard Communication: Carcinogen warnings are required on containers of materials containing more than 0.1 percent crystalline silica by weight or volume Bricks/Tiles/Cement boards not exempt Vehicles hauling shipments of crushed stone shall include hazard warnings concerning the carcinogenicity of crystalline silica on their shipping papers or bills of lading

70 Inspection Procedures Determine whether the employer's housekeeping and hygiene practices may contribute to overexposure. Wet sweeping should be used to clean areas if possible. If vacuuming is used for cleaning, the exhaust air should be properly filtered to prevent release of airborne silica back into the workroom.

71 Inspection Procedures Housekeeping and hygiene practices There should be separate break areas for consuming food, beverages, etc. that are kept free of silica. Clothes contaminated with silica should not be blown or shaken to remove dust. Employee Exposure and Medical Records Abrasive Blasting has other special considerations

75 Silica REP Findings FY Inspections Covered 2,109 employees 4 silica citations $3,705 average penalty per inspection SICs selected by NEP

76 What to Watch Methylene Chloride REP Isocyantes REP New and Proposed Rulemaking

77 If you want a copy of our Regional Newsletter, and to be subscribed for future issues, please give us your business card and we will add your e- mail address to our Regional E-News Distribution List.

78 Questions? OSHA (6742)

OSHA Emphasis Programs for Health Hazards. Ed Marshall Compliance Officer Peoria Area Office

OSHA Emphasis Programs for Health Hazards Ed Marshall Compliance Officer Peoria Area Office National Emphasis Programs Focus efforts to reduce specific risks to workers in various industries Feature a