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 combination of enforcement and educational outreach for employers whose workers face certain hazards.

• NEPs are National in scope.

National Emphasis Programs • COMBUSTIBLE DUST

• FEDERAL AGENCIES

• HAZARDOUS MACHINERY

• HEXAVALENT CHROMIUM

• ISOCYANATES

• LEAD

• NURSING AND RESIDENTIAL CARE FACILITIES

• PRIMARY METAL INDUSTRIES

• PROCESS SAFETY MANAGEMENT

• SHIPBREAKING

• SILICA

• TRENCHING & EXCAVATION

LOCAL EMPHASIS PROGRAMS

• Enforcement strategies designed and implemented at the regional office and/or area office levels.

• Intended to address hazards or industries that pose a particular risk to workers in the office's jurisdiction.

• May be implemented by a single area office, or at the regional level (Regional Emphasis Programs), and applied to all of the area offices within the region.

Region V (IL, IN, MI, MN, OH, WI) LEPs

• LEP for Building Renovation/Rehabilitation and Demolition • LEP for Powered Industrial Vehicles • LEP for Fall Hazards in Construction and General Industry • LEP for High Rise Building Construction Inspections in Chicago • Local Emphasis Program for Grain Handling Facilities • Local Emphasis Program for Carbon Monoxide Hazards in Const. • Local Emphasis Program for Federal Agencies • Local Emphasis Program for Tree Trimming Operations • LEP for the Wood Pallet Manufacturing Industry • LEP for Maritime Industries • Local Emphasis Program for Lead • Local Emphasis Program for Silica

NEP for Hexavalent Chromium

• Identify and reduce or eliminate the health hazards associated with occupational exposure to hexavalent chromium and other toxic substances commonly found in conjunction with hexavalent chromium.

• Inspections under this NEP will generally focus on industries where overexposures to hexavalent chromium are known to occur.

• Establishments with fewer than 10 workers shall be included in this NEP.

NEP for Hexavalent Chromium

• Work Activities in General Industry and Maritime Likely to Result in Elevated Exposures to Hexavalent Chromium. – Electroplating Operations – Welding – Painting – Maritime/shipyard – Foundry, Steel Mill, and Other Molten Metal

Handling Operations.

NEP for Hexavalent Chromium

• Work Activities in Construction Likely to Result in Elevated Exposures to Hexavalent Chromium. – Painting and Surface Preparation (Abrasive

Blasting)

– Welding and Thermal Cutting

– Miscellaneous Construction Activities with Limited Potential for Cr(VI) Exposures

• CCA lumber/woodworking

NEP for Isocyanates

To identify and reduce or eliminate the incidence of adverse health effects associated with occupational exposure to isocyanates. Jobs that may involve exposure to isocyanates include: • Painting • foam-blowing • manufacture of many Polyurethane products, such as

chemicals, polyurethane foam, insulation materials, surface coatings, car seats, furniture, foam mattresses, under-carpet padding, packaging materials, shoes, laminated fabrics, polyurethane rubber, and adhesives, and during the thermal degradation of polyurethane products.

NEP for Isocyanates

• Occupational exposure to isocyanates is a recognized cause of immune sensitization and asthma.

• Scientific research indicates that dermal exposure to isocyanates is at least as likely as inhalation exposure to induce isocyanate-related asthma.

• Inspections conducted under this instruction shall include an evaluation of the employer’s controls (engineering controls, administrative and work practice controls, and personal protective equipment

NEP/LEP for Lead

• The activities covered under this NEP include inspections and inquiries conducted in any industry or at any work site where the Agency determines that there is potential employee exposure to lead.

• Employee exposure to airborne lead will be sampled, whenever possible, during both the initial and follow-up inspection. Medical surveillance records will be reviewed, whenever available, by CSHOs during NEP lead inspections.

NEP/LEP for Lead

• To reduce occupational exposures to lead in General Industry and Construction.

• OSHA estimates that approximately 804,000 workers in general industry and an additional 838,000 workers in construction are potentially exposed to lead.

• Region V had 345 inspections coded for lead between 4/1/11 – 1/17/14 that found more than 800 serious hazards.

• Includes firing ranges and any landscaping services or cleaning contractors who perform work at firing ranges.

NEP for Nursing & Residential Care Facilities

Sets forth policy and procedures for targeting and conducting programmed inspections in this industry.

The specific hazards being addressed include ergonomic stressors in patient lifting, bloodborne pathogens, tuberculosis, workplace violence, and slips, trips and falls.

NEP for Nursing & Residential Care Facilities

• Inspections conducted under this NEP will focus on establishments classified in the following sectors within the selected NAICS codes 623110, 623210 and 623311.

• Also includes provisions to review – Tuberculosis

– Workplace Violence

– MRSA and other bio hazards.

NEP for Primary Metals

• Identify and reduce or eliminate worker exposures to harmful chemical and physical health hazards in facilities in the Primary Metal Industries.

• Previous inspections of primary metal establishments have resulted in citations for overexposures to a wide variety of health hazards including chemical exposures in foundry operations as well as physical stressors such as noise and heat.

NEP for Primary Metals

• Inspections conducted under this NEP shall focus on facilities with workers in Major Group 33 of the SIC Manual – The Primary Metal Industries (PMI) are a group of

establishments engaged in the smelting andrefining of both ferrous and nonferrous metals. These metals are refined from ore, pig, and scrap, during rolling, drawing, casting, and alloying metal operations.

NEP/LEP for Silica

NEP Instruction Appendix H of NEP • Addresses targeting of

worksites with elevated exposure to crystalline silica, as well as silica-related inspection procedures and compliance assistance

• Each office that does not already have a Local Emphasis Program (LEP) for crystalline silica, will develop and implement a LEP for crystalline silica.

NEP/LEP for Silica

• To reduce occupational exposures to silica in General Industry & Construction

• The National Emphasis Program (NEP) for crystalline silica required each regional office to develop an LEP.

• Silica as used in this program refers specifically to crystalline silica.

LEP for Building Renovation/Rehab and Demolition

• For safety & health inspections of those construction projects which involve extensive reconstruction, renovation, and rehabilitation on the interior of an existing building and add demolition activities that raze the exterior of a structure in any way.

LEP for Building Renovation/Rehab and Demolition

• Health Factors Evaluated – Lead

– Cadmium

– Noise -

– Silica

– Nuisance Dust

– Asbestos

Recent Industry Alerts/Letters

• Methylene Chloride in bathtub refinishing

• Diesel Exhaust from vehicles

• Silica in “fracking”

• 1-Bromopropane

• Poultry Processors

Enforcement Exemptions and Limitations under the Appropriations

Act. • OSHA Instruction CPL 02-00-051 states that LOW HAZARD

employers with 10 or fewer employees and with lost workday case rates below the national private sector rate are exempt from programmed safety inspections. CSHOs are permitted to take any action authorized by the Act with respect to health hazards.

• Health inspections are to be scheduled, observed health hazards cited, and penalties assessed for all classification of violations in accordance with current procedures. Safety violations noted during the inspection shall not be cited unless the violation constitutes imminent danger.