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April 11, 2003

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VOSHA AND YOUR SCHOOL

AN OVERVIEW OF YOUR REGULATORY OBLIGATIONS

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JURISDICTION

• IN GENERAL, VOSHA REGULATIONS COVER ALL EMPLOYERS WITH EMPLOYEES IN VERMONT INCLUDING K-12 SCHOOLS

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EMPLOYERS OBLIGATIONS• CFR 29 Section 1910• General Duty Clause – OSH Act, Section 5

(a) Each Employer-(1) Shall furnish to each of his employees employment and

a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees;

(2) Shall comply with occupational safety and health standards promulgated under this Act.(b) Each employee shall comply with occupational safety and health standards and rules, regulations and orders issued pursuant to this Act which are applicable to his own actions and conduct.

• Construction Projects

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VOSHA’S DUAL ROLES

• COMPLIANCE(INSPECTORS ARE AUTHORIZED TO ISSUE CITATIONS AND FINES), OVER 100 REGULATIONS

• CONSULTATION(SAFETY AND HEALTH CONSULTANTS, PROJECT WORK SAFE)

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VOSHA INSPECTIONS

• CAN BE PROGRAMMED OR UNPROGRAMMED1. COMPLAINT2. REFERRAL3. PLANNED4. RELATED

• COMPREHENSIVE OR PARTIAL

• THEY CAN INSPECT ALL SCHOOLS IN A DISTRICT

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CITATIONS AND PENALTIES

• FAILURE TO FOLLOW REGULATIONS RESULTS IN ADMINISTRATIVE CITATIONS

• PENALTIES ($$$$.$$) ASSESSED BASED ON THE NATURE OF THE VIOLATION (SERIOUS, WILLFUL, ETC.) AND SIZE OF EMPLOYER

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CONTESTING CITATIONS & PENALTIES

• INFORMAL CONFERENCE

• CONTEST PHASE

(FORMAL V. SIMPLIFIED PROCEEDINGS)

• APPEALS

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SELF-INSPECTION CHECKLIST

• SAFETY AND HEALTH PROGRAM

• PERSONAL PROTECTIVE EQUIPMENT $

• COMBUSTIBLE MATERIALS

• POWER TOOLS

• LOGOUT/TAG OUT

• CONFINED SPACE $

• ELECTRICAL

• WALKING/WORKING/SLIP & FALL SURFACES

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• HAZARDOUS COMMUNICATION $

• ASBESTOS $

• LEAD

• BLOODBORNE PATHOGENS

• CHEMICAL HYGIENE PLAN FOR LABORATORIES $

• RESPIRATORY PROTECTION $

• MACHINE GUARDING

• GENERAL DUTY CLAUSE $

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HAZARD COMMUNICATION (HAZCOM) 29 CFR 1910.1200

• REQUIRES INFORMATION ABOUT PHYSICAL AND HEALTH HAZARDS BE MADE AVAILABLE TO EMPLOYEES, INCLUDING RECOMMENDATIONS FOR SAFE USE.

• REQUIRES A WRITTEN HAZCOM PROGRAM-HAZARD EVALUATION-TRAINING-MSDS-LABELING

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RESPIRATORY PROTECTIONCFR 1901.134

• SCHOOL MUST DEVELOP AND IMPLEMENT A SITE-SPECIFIC WRITTEN PROGRAM IF RESPIRATORY PROTECTION IS REQUIRED-TRAINING-FIT TESTING-MEDICAL EVALUATIONS-EXPOSURE MONITORING

• MEDICAL EVALUATIONS ARE REQUIRED• RECORD KEEPING• EMPLOYEES CAN REQUEST RESPIRATORY

PROTECTION

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BLOODBORNE PATHOGENS 29 CFR 1910.1030

• SCHOOL MUST DETERMINE POTENTIAL FOR BLOODBORNE PATHOGEN EXPOSURE

• IF THE POTENTIAL EXIST, A WRITTEN EXPOSURE CONTROL PLAN MUST BE DEVELOPED-TRAINING-LABELING-HANDLING PROCEDURES

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CONFINED SPACE 29 CFR 1910.146

• SCHOOL MUST CONDUCT A THOROUGH EVALUATION TO IDENTIFY SPACES REQUIRING PERMITS(1) Is large enough and so configured that an employee can bodily enter and perform assigned work; and

(2) Has limited or restricted means for entry or exit (for example, tanks, vessels, silos, storage bins, hoppers, vaults, and pits are spaces that may have limited means of entry.); and

(3) Is not designed for continuous employee occupancy.

• A WRITTEN PROGRAM IS REQUIRED IF EMPLOYEES WILL ENTER “PERMIT REQUIRED” SPACES

-TRAINING, INITIAL AND REFRESHER

-EQUIPMENT MAY BE REQUIRED

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HAZARDOUS ENERGY CONTROL 29 CFR 1910.147

• “LOG OUT TAG OUT”This standard covers the servicing and maintenance of machines and equipment in which the unexpected energization or start up of the machines or equipment, or release of stored energy could cause injury to employees. This standard establishes minimum performance requirements for the control of such hazardous energy.

• WRITTEN PROCEDURES REQUIRED FOR: SHUTTING DOWN, ISOLATING, BLOCKING AND SECURING EQUIPMENT TO CONTROL RELEASES OF HAZARDOUS ENERGY– TRAINING– EQUIPMENT

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LABORATORY STANDARD 29 CFR 1910.1450

• REQUIRES SCHOOL TO DEVELOP A WRITTEN CHEMICAL HYGIENE PLAN

• COVERS LABORATORIES THAT USE CHEMICALS

• ASSIGNS A CHEMICAL HYGIENE OFFICER

• TRAINING

• ASSIGNED RESPONSIBILITIES

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EMERGENCY ACTION PLAN & FIRE PROTECTION PLAN

29 CFR 1910.38

• SCHOOLS MUST HAVE A WRITTEN PLAN THAT COVERS THE DESIGNATED ACTIONS EMPLOYERS AND EMPLOYEES MUST TAKE TO ENSURE EMPLOYEES SAFETY FROM FIRES AND OTHER EMERGENCIES

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LEAD 29 CFR 1910.1025

• WRITTEN PROGRAM REQUIRED-EXPOSURE MONITORING-TRAINING, INITIAL AND ANNUAL-RESPIRATORY PROTECTION-PROTECTIVE CLOTHING AND EQUIPMENT-MEDICAL SURVEILLANCE-RECORD KEEPING (40 YEARS OR DURATION OF EMPLOYMENT PLUS 20 YEARS)

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ASBESTOS29 CFR 1910.100 & 1926.1101

• REGULATES ASBESTOS PRACTICES

-REQUIRED TO IDENTIFY ASBESTOS

-REQUIRES NOTIFICATION OF ASBESTOS TO CONTRACTORS AND EMPLOYEES

-REQUIRES ANNUAL TRAINING

-RECORD KEEPING

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PERSONAL PROTECTIVE EQUIPMENT (PPE)29 CFR 1910.132-.138

• REQUIRES SCHOOLS TO CONDUCT A JOB HAZARD ANALYSIS (JHA)

• MUST IMPLEMENT ENGINEERING CONTROLS WHERE FEASIBLE

• PROGRAM IN PLACE TO SELECT APPROPRIATE TYPES OF PPE TO PROTECT EMPLOYEES

• TRAINING• MUST REQUIRE

EMPLOYEES TO WEAR PPE

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OTHER VOSHA REGULATIONS GENERAL INDUSTRY

• COMPRESSED GASES (1910.101)• ELECTRICAL SAFETY (1910.301)• EMERGENCY RESPONSE (1910.120)• WALKING/SURFACES (1910.021)• POWERED INDUSTRIAL TRUCKS,

TRACTORS, FORKLIFTS (1910.178)• MANY, MANY MORE

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OTHER VOSHA REGULATIONCONSTRUCTION

• FALL PROTECTION (1926.500 - 503)• EXCAVATIONS (1926.750 – 753)• SCAFFOLDS (1926.450 – 454)• WELDING AND CUTTING 1926.350 – 354)• FIRE PROTECTION AND PREVENTION

(1926.150 – 159)• LADDERS (1925.1050 – 1060)• MANY, MANY MORE

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RECOMMENDATIONS

• ESTABLISH OR SOLIDIFY YOUR SAFETY COMMITTEE

• PERFORM JHA• DEVELOP KEY PROGRAMS, ESPECIALLY

REQUIRED WRITTEN PROGRAMS• PERFORM SELF AUDITS• REVIEW CONTRACTUAL LANGUAGE• ATTEND VSBIT SPONSORED VOSHA PROJECT

WORK SAFE PROGRAMS• HIGHER A VOSHA CONSULTANT• BE PREPARED BE DILIGENT BE WILLING TO

PROVIDE A SAFE WORK SITE FOR YOUR EMPLOYEES

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OSHAREFERENCE WEB SITES

• www.osha.gov

• www.state.vt.us/labind/vosha.htm

• www.ehs.indiana.edu/resources/policies/

• www.ehs.indiana.edu/osha/

• www.ed.gov/emergencyplan

• www.osha-safety-training.net/PUB

• www.uoregon.edu

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