osha emphasis programs in florida -...

OSHA Emphasis Programs

in Florida

PRESENTED B: Joan M. Spencer Compliance Assistance Specialist Tampa Area Office 813-626-1177 [email protected]

On Which Emphasis Programs are Based

National Emphasis Programs

•Crystalline silica •Lead •Combustible dust •Oil refineries •Trenching •Amputations •Shipbreaking operations

National Emphasis Programs

•Primary Metal •Chemical plants •Hexavalent Chromium •Diacetyl •Federal Agencies •Nursing and Residential Care Facilities

Regional Emphasis Programs

• Lead • Silica • Noise • Sharps • Health Hazards in Scrap and Waste

Materials Recycling Operations

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 produced rubber

stoppers and other products for medical use

– Plastic powder accumulated above suspended ceiling ignited

– Polyethylene dust

Imperial Sugar

• 14 Fatalities • Forensic

Investigation • $5.062 million

egregious citations

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

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

Top Ten Industries Inspected under NEP

164

123

10386 80

6955

40 34 30

050

100

150

200

Wood

Prod

ucts

Food

Prod

ucts

Chem

ical

Indus

tries

Metal

Prod

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Rubb

er/Pla

stic

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Prim

ary M

etal

Elec/S

anita

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rv.

Furni

ture

Trans

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Dur. G

oods

Types of Dust Involved in incidents

Types of Industries Involved in Dust Incidents

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

Hazard Mitigation

• Dust control • Ignition source control • Damage control

Dust Control

• Design of facility & process equipment

• Contain combustible dust

• Clean fugitive dust • Regular program • Access to hidden areas • Safe cleaning methods

• Maintenance

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

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

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

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

Damage Control Systems

• Specialized detection systems • Specialized suppression systems • Explosion prevention systems • Maintenance

Applicable Standards

• Existing OSHA Standards – 1910.22 – housekeeping – 1910.38 – emergency action plans – 1910.94 – ventilation – 1910.119 – process safety management – 1910.269 – electric power generation – 1910.272 – grain handling facilities

Applicable Standards

• Existing OSHA Standards (cont) – 1910.307 – hazardous locations – 1910.1200 – hazard communication

• Section 5(a)(1) – General Dusty Clause

– Applicable ANSI and NFPA standards

Combustible Dust – Inspection Data

November 1, 2007 – March 6, 2009

Combustible Dust Related Violations

130

167

36

133

206

48

151

35

0

50

100

150

200

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a)(1

)

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Fire

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Hous

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Com

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Air PP

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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


• 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


• 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


• Dust work lacking in venting or explosion suppression systems

• Deflagration isolation systems not provided

• Rooms with no explosion relief systems

• Horizontal surfaces not minimized


• 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

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

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

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

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


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

Chrome 6 Findings

• FY11 – 155 Inspections Nationwide – 854 Citations – 43 Inspections Region wide (27%) – 259 Citations (30%)

Chrome 6 Findings

• FY11 – 29 1910.1026 citations for Region – Some 1910.1025 citations – Most citations were safety related

• Walking working surfaces • Machine guarding • LOTO • PPE • Electrical • PIT • and a couple of Hazwoper and PRCS citations

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


• Private, nonferrous recycling industries in the U.S. employed approximately 16,000 employees in 2001.

• In 2001, those nonferrous recycling industries reported approximately 3,000 injuries and illnesses.


• 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.


• Reduce exposures to metal fumes, gases, noise, heat, radiation.

• Safety hazards from risk of fire, machine guarding, struck-by hazards.


• FY 2011 – Region conducted

103 inspections – Covered 1,690

employees –400 Citations –635,000 in penalties

REP Findings

• Heath related citations issued under: – Lead – Noise – Hazard

communication – Respiratory

protection


• Safety related citations issued under: – Walking working

surfaces – First-aid – Machine guarding – LOTO – Welding and cutting – Electrical – PIT – and one PRCS

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 2007.

• In 2007, approximately 82% of the cases involving occupational hearing loss were reported among workers in the manufacturing sector. Source: OSHA Website

234% of the daily permissible noise level

727% of the daily permissible noise level

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.

Noise REP

• Findings: • 92 Inspections (mostly GA) • Mostly safety violations

– PIT – Machine guarding – Electrical – LOTO

• 24 noise violations

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

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


• 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


• 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.


• 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.

Lead REP Findings

• FY 11 – 74 Inspections – Covered 2,971 employees – 45 lead citations – $10,262 average penalty per inspection


Silica REP

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

Silica REP

• All industries were silica overexposure has been documented in the Region



• 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


• 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.


– Compressed air usage – Substitution with non-crystalline silica

material. – Use of tools with dust collecting systems. – Controls for abrasive blasting (specific

standard)


• 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.


• 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


• 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.


• 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

Silica REP Findings

• FY 11 – 166 Inspections – Covered 2,109 employees – 4 silica citations – $3,705 average penalty per inspection


What to Watch

• Methylene Chloride REP • Isocyantes REP • New and Proposed Rulemaking

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.

Questions? www.osha.gov

1-800-321-OSHA (6742)

http://www.osha.gov/

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