Document ZBpVVDMEEgrB5pj6vn1bBQ70O

KELLER'S Industrial Safety REPORT AUGUST 1994____________________ VOLUME .4_____ NUMBER 8 FEATURED THIS MONTH OSHA REVISES CONFINED SPACE RULE - Revisions to the confined space rule add information regarding air contaminant sensor instruments. Page 1 OSHA INCREASES WILLFUL VIOLATION PENALTIES - OSHA has increased the minimum proposed penalty for willful violation of workplace safety rules to $25,000. Page 2 RESPIRATORY PROTECTIVE DEVICES RESPONSIBILITY TRANSFERS TO NIOSH - Proposals would transfer sole responsibility for administration of respirator equipment to National Institute for Occupational Safety and Health. Page 3 PPE RULE IS EFFECTIVE JULY 5 - Guidelines to walk you through a workplace assessment and help you choose appropriate personal protective equipment. Page 6 CONTENTS ^ OSHA Activity OSHA revises confined space rule...................................1 Willful violation penalties increase five-fold................2 OSHA extends comment period on indoor air quality........................................................................2 Proposals transfer sole responsibility for respiratory protective devices to NIOSH...................................... 3 NIOSH proposal reclassifies respirator particulate filters................................................................................. 4 Modules to upgrade respirator requirements................................................................... 4 OSHA selects four new training centers.......................5 Top 1992/1993 violations................................................... 5 OSHA delivers record breaking lead penalty...............6 Proposal targets fall hazards in longshoring...............6 Guidelines to help you meet the new PPE requirements................................................................... 6 PPE impacts on general industry..................................11 Safety Matters Danger from above - hard hats protect workers...... 13 EPA Activity Freon Release Brings Citation from EPA.................. 14 Proposal Removes Pigment Blue 15:1 from Toxic Chemical List................................................................ 14 EPA compiles radon maps for Upper Midwest............................................................ 15 "Safe & Secure", Television Show Highlights Keller's Official OSHA Safety Handbook..............15 RCRA updates inspection manual................................ 15 Seminars and Workshops...........................................16 OSHA Activity OSHA Revises Confined Space Rule OSHA recently published a technical amend ment revising the Atmospheric Monitoring sec tion of Appendix E to the confined space rule (29 CFR 1910.146). The amendment adds infor mation regarding air contaminant sensor instruments which must be used before entry into sewer systems. In June 1993 OSHA published a correction doc ument to the confined space rule. In that docu ment, OSHA removed all references to "broad range sensor instruments" from the Atmo spheric Monitoring section of non-mandatory Appendix E. At that time, the Agency felt it was inappropriate to suggest a particular type of sensor instrument for all sewer entries. By removing the reference to broad range sen sors, OSHA inadvertently created the impres sion that it favored using substance-specific sensors over broad range sensors for the moni toring of hazardous air in sewer systems. That was not the intent of the Agency. jrj: KELLER & ASSOCIATES, INC. CTL023210 ^AUGUST,1994- "(yM'i!,. ^VOLUME 4! fc^n^Tirwf"\I\ NUMBER 8 OSHA expects employers to choose sensors or other monitoring equipment which will best identify the atmospheric hazards present or potentially present in a sewer. If the employer has already identified those hazards, substance-specific sensors are preferable because they accurately indicate the concentrations of the identified air contaminants. However, if the employer has not been able to identify the specific atmospheric hazards present, broad range sensors are preferred because they indi cate that the hazardous threshold of a contam inant in the sewer has been exceeded. Therefore, OSHA is revising the information in 1910.146, Appendix E by restoring the ref erence to broad range sensors and clearly stat ing the advantages and limitations of both the oxygen sensor/broad range sensor instrument and the substance-specific device. OSHA expresses no preference for either type of meter. Instrument selection is left up to the employer, who is in a position to decide what type of testing instrument is appropriate for a particular sewer entry. In this technical amendment, OSHA has also added a metric equivalent (1.52 meters) of 5 feet to 1910.146(k)(3)(ii). This section OSHA Extends Comment Period on Indoor Air Qualiity Due to exceptionally heavy interest in the proposed indoor air quality standards, OSHA is adding six weeks to the comment period and rescheduling the start of hear ings. The proposal, which was issued on March 24, covers general indoor air quality and environmental tobacco smoke in all indoor non-industrial work environments. OSHA is extending the comment period from June 29 to August 13, and the public hear ings on the proposal will begin September 20 rather than July 12. According to Joseph Dear, Assistant Secretary of Labor, the indoor air proposal has generated more than 5,000 comments. Notice of the extension was published in the June 14, 1994 Federal Register. For more information, contact Frank Kane, OSHA, (202) 219-8151. requires that a mechanical device be used to retrieve personnel from vertical type permit spaces more than 5 feet deep. In the original rule, this metric equivalent was omitted. The rule became effective May 19, 1994. For more information, contact James Foster, OSHA, (202) 219-8181. Willful Violation Penalties Increase Five-Fold OSHA has increased minimum penalties for willful violation of workplace safety rules to $25,000, according to a recent announcement by Secretary of Labor, Robert Reich. "The increase in minumum proposed penalties for the more serious willful violations will make it that much more difficult for those few bad actors to regard penalties as simply a cost of doing business," Reich said. The increased penalties are in line with OSHA's directive to implement a four-pronged enforcement policy of targeting the worst offenders and offenses; protecting vulnerable populations; deterring violations with significant penalties, including criminal penalties; and getting results swiftly and efficiently. Raising penalties for willful violations is one of several enforcement strategies being looked at by OSHA to enhance the agency's effective ness. According to OSHA's Administrator, Joseph Dear, "Willful violations are but a small percentage of all cited violations, but they result from employer conduct which, deliberately or through plain indifference, endangers the safety and health of workers." Proposed penalties for willful violations will be set on "gravity-based" factors (i.e. high, medium or low) with adjusted reductions up to 30 percent for the employer's size. The firm's job safety and health history could reduce penalties up to an additional 10 percent. There will be no adjustment on proposed penalties for willful violations based on a cited firm's good faith efforts. The penalty revision became effective June 16, 1994 and state-plan-states had 30 additional days to notify OSHA of their intent to enforce the new federal penalty levels. Minimum penalties for willful violations deemed otherthan-serious remain at $5,000. -ii. CTL023211 k AUGUST 1994 ________ VOLUME 4 NUMBER 8 Gravity-Based Proposed Penalties The chart below lists maximum gravity-based proposed penalties for willful violations which otherwise would have been deemed "serious" with percentage reductions based on size and job safety and health history. The main factor will be the size of a company with up to a 30 percent reduction possible, and an additional 10 percent based on the company's history. Penalty amounts thus could be reduced from 0 to 40 percent based on size and history. Gravi ty is based on the severity of the violation (i.e. the probability of serious injury or death) determined by facts noted during an inspec tion. Proposed penalties for regulatory viola tions (i.e. recordkeeping, reporting or posting requirements) that are considered willful will be multiplied by 10 but in no case will the pro posed penalty be less than $5,000 after adjust ment for size. Penalties to be Proposed (Rounded to the closest $500) Percentage Reduction for size and/or history 0% 10% 20% High Gravity $70,000 $63,000 $56,000 Medium Gravity $55,000 $49,500 $44,000 Low Gravity $40,000 $36,000 $32,000 30% $49,000 $38,500 $28,000 Percentage of Reduction Based on Size Number of Employees Percentage of Reduction 1-25 30 26-100 20 101-250 10 251 or more 0 40% $42,000 $33,000 $25,000 Proposals Transfer Sole Responsibility for Respiratory Protective Devices to NIOSH In proposed rulemakings issued May 23, 1994, the existing rules requiring joint approval of respiratory protective equipment by the National Institute for Occupational Safety and Health (NIOSH) and the Mine Safety and Health Administration (MSHA) would be removed. The rules would be replaced by revised approval procedures and technical requirements for respirators which would be administered solely by NIOSH under CFR Title 42, Part 84. Joint agency certification and approval would be retained regarding only those respirators which are unique to the min ing industry. While MSHA currently reviews applications for respirator approvals and has conducted some product evaluations and laboratory testing for certain respirators, the responsibility for the administering of quality control provisions involving testing and certification activities is primarily NIOSH's. The May proposals would remove the MSHA respiratory protection Part 11 from Title 30. This would, however, be con tingent on publication of the NIOSH proposal as a final rule. Existing MSHA respirator use provisions in Part 11 would be retained and recodified in CFR Title 30, Parts 70 and 71. Under the NIOSH proposal, MSHA and NIOSH would continue to review and approve respirators jointly for mine emergencies and mine rescue, and their associated service-life plans and users' manuals. Among the types of devices which would continue to be subject to joint approval are self-contained, self-rescue devices. In addition, MSHA would continue to test electrical compo nents of certain respirators to be used in mines and issue a separate MSHA approval under 30 CFR part 18 for such respirators. v. *-'**'-' KELLER ^ASSOCIATES, INC. CTL023212 f&AUGUST 1994 ^wgfggisgf^r1* -wajfi. >NUMBER 8;^ Both NIOSH and MSHA rulemaking activities will be coordinated to ensure that the level of respiratory protection afforded to all affected workers will be maintained during the transi tion period. The National Institute for Occupa tional Safety and Health and Mine Safety and Health Administration proposals were pub lished in the May 24, 1994 Federal Register. For more information, contact Patricia Silvey, MSHA (703) 235-1910. NIOSH Proposal Reclassifies Respirator Particulate Filters In conjunction with the proposed transfer of respirator responsibilities from the Mine Safe ty and Health Administration, NIOSH has included a proposal to upgrade current testing requirements for particulate filters. The new requirements would significantly improve the current approach to evaluating the effective ness of an air-purifying respirator's filter to remove toxic particulates from the air. The new filter provisions would provide a par ticulate efficiency determination and classifi cation system consistent with advances in res piratory protection technology. Tests would enable classification of the filters based on their ability to inhibit the penetration of par ticulates. This will result in the formation of a three-tiered classification system which will eliminate the need to test and classify the fil ter respirator according to composition of con taminant (e.g. dust, fume, mist and asbestos). The penetration rate for particulates in the atmosphere, regardless of composition, will not exceed that of the test particulate. Provisions in this proposal also address per formance requirements for certifying air-puri fying respirators against biological agents. This addresses the current risk of tuberculosis (TB) transmission in health care and other facilities. The only certified air-purifying res pirator class that meets biological protection criteria is a respirator with a high efficiency (HEPA) filter. However, all six classes of airpurifying particulate respirators to be certified under provisions of the new tests (filter pene tration) would meet or exceed performance recommendations of the Centers for Disease Control (CDC). Because immediate implemen tation of respirator modifications in this pro posal should promote a substantial increase in respiratory protection to all workers potential ly exposed to TB, NIOSH is moving forward with a schedule to publish a final rule pertain ing to particulate filters in late 1994. NIOSH estimates that these changes to the particulate filter requirements will affect approximately 80 percent of all respirators currently marketed. This proposal was pub lished in the May 24, 1994 Federal Register. For more information, contact Richard Metzler, NIOSH, (304) 284-5713. Modules to Upgrade Respirator Requirements The upgrading of current testing requirements for particulate filters is just the first step in NIOSH's proposal for respiratory protective devices. The Institute is planning a series of module actions which will, over the next sever al years, upgrade current respirator require ments. This modular approach will allow improvements to be implemented on a priority basis as well as facilitate adaptation to new requirements by the manufacturers and users of respirators. The anticipated subjects and sequence of the NIOSH modular rulemaking approach are: Subject Area Particulate Filter Tests Assigned Protection Factors Administrative Program (application submittal and processing, fee structure, etc.) Quality Assurance Requirements Gas and Vapor Requirements Positive Pressure SCBA Requirements Simulated Workplace Protection Factor Test Anticipated timetable for proposed rule May 1994 Late 1994 Early 1995 Early 1995 Mid 1995 Early 1996 Early 1997 CTL023213 WT AUGUST 1994 VOLUME'4'' **C NUMBER 8 This proposal was published in the May 24, 1994 Federal Register. For more informa tion, contact Richard Metzler, NIOSH (304) 284-5713. ifci OSHA Selects Four New Training Centers OSHA recently announced the selection of four new job safety and health education centers. Officially called OSHA Training Insitiute (OTI) Education Centers, these additions dou ble the number of such training facilities and reflect the growing public desire for improving workplace safety and health. OTI Education Centers were established to expand training opportunities for members of the private sector and other federal agencies. The Centers receive no federal funds and their costs are covered by tuition. Courses to be offered for general industry include machinery and machine guarding standards; guides to voluntary compliance in safety and health; and voluntary compliance in the industrial hygiene area. A collateral duty course for other federal agencies and a course for instructors on OSHA's construction standards will also be available. The four Centers initially established under a pilot program are located at: 1. Georgia Tech Research Institute in Atlanta, GA; 2. Maple Woods Community College in Kansas City, MO; 3. Red Rocks Community College in Lakewood, CO; and 4. University of California in San Diego. The four newly selected Centers are located at: 1. Keene State College in Keene, NH; 2. Niagara County Community College in Sanborn, NY; 3. National Resource Center for Construc tion Safety and Health, AFL-CIO Build ing and Construction Trades Depart ment in Washington, DC in conjunction with West Virginia University in Mor gantown, WV; and 4. Texas Engineering Extension Service in College Station in conjunction with the Texas Safety Association in Austin, TX. For more information, contact Deborah Page Crawford, OSHA, (202) 219-8151. OSHA's Top 1992/1993 Violations Standard 1910.1200 Description Hazard Communication No. of Violations 17,979 1910.147 Lockout/Tagout 7,134 1910.305 1910.219 Wiring Methods, Components, & Equipment Mechanical Power Transmission Apparatus 4,864 4,644 1910.451 Scaffolding 4,507 1904.2 Log Summary of Occupational Injuries & Illness 4,281 1910.1030 Bloodbome Pathogens 4,094 1910.134 Respiratory Protection 3,954 1910.212 General Requirements for Machines (Guarding) - 3,828 CTL023214 ^ AUGUST ,1994 NUMBER 8 OSHA Delivers Record Breaking Lead Penalty Labor Secretary Robert Reich recently issued a $5,088,500 penalty, the largest single employer construction penalty to date, against a Pennsylvania painting company. The penalty is for allegedly subjecting employees to lead exposures that were in some cases hundreds of times greater than the level permitted by regulations. OSHA's inspections found that employees removing lead-based paint were exposed to lev els of airborne lead nearly 700 times the per missible exposure limit (PEL) for construction workers. The violations involve 90 employees performing abrasive blasting, repainting and general work on a bridge which had previously been painted with lead-bearing paint. In its inspection, OSHA found that 20 of the 90 employees were overexposed to lead and that the employer failed to provide appropriate engi neering controls and respiratory protection. The company also failed to adequately train employees in the hazards of working with lead and how they should protect themselves. OSHA's new interim final rule on lead in con struction, mandated by Congress, became effective June 3, 1993 with various provisions phased in over time. It reduces the permissi ble exposure limit for lead in construction to the same level that applies in general indus try, a level one-fourth the earlier PEL for lead in construction. Proposal Targets Fall Hazards in Longshoring OSHA's recent proposal is targeting worker protection from fall hazards in the longshoring industry. The industry has changed dramati cally since the OSHA standards were adopted in 1971 and methods of cargo handling and equipment technology have undergone signifi cant modifications. A major issue brought about by intermodalism (containerization) is container-top fall protec tion. Longshore workers often are required to work on top of containers on ship decks where the fall distance is typically 50 feet. As a result of improvements in container securing devices, OSHA believes that many work oper ations which expose workers to fall hazards now can be eliminated. The use of semi-auto matic twistlocks which secure one container to another eliminates the need for workers to go aloft in 90 percent of the cases. These devices represent an initial investment cost, but also result in significant productivity increases. Other hazards addressed by the proposal include those associated with cargo lifting gear, vehicular cargo transfers, manual cargo handling, and hazardous atmospheres and materials. Marine terminal standards which were adopted in 1983 and parallel those of longshoring would also be updated under this proposal. The proposal is what is known as a "vertical" standard, to apply specifically to the industry. Vertical standards can encourage voluntary compliance because they are directed to the particular problems of the industry, and because they only contain provisions that are appropriate to the industry. OSHA expects that the rule will prevent three deaths and 1,300 injuries, and save the industry more than $18 million annually. Hearings will be held on the proposal later this year in Charleston, SC, Seattle, WA, and New Orleans, LA. This proposed rulemaking was published in the June 2, 1994 Federal Register. For more information, contact James Foster, OSHA, (202) 219-8148. r----------------- Guidelines to Help You Meet the New PPE Requirements V_______ J OSHA's revised safety standards for personal protective equipment (PPE) became effective on July 5, 1994. The new rule requires employers to assess the workplace to deter mine if hazards are present which necessitate the use of personal protective equipment. The employer is required to verify the hazard assessment in writing. If hazards are present, the employer must select, and have each affected employee use, the types of PPE that 4 AUGUST 1994 v^r V0LUME4 NUMBER 8 will protect against the identified hazard. PPE must properly fit each employee. The employer must also provide training for each employee required to use PPE. Training should include when PPE is necessary, what PPE is necessary, how to wear PPE, the proper care, maintenance, useful life, and disposal of the PPE. Employers must certify in writing that the employee has received and under stands the training. To assist employers and employees in imple menting the requirements of the rule, OSHA has developed non-mandatory guidelines for performing hazard assessments in the work place and selecting appropriate personal protec tive equipment. These guidelines should help you meet the new requirements and create a safer work environment for your employees. Appendix B to Subpart I--Non-mandatory Compliance Guidelines for Hazard Assessment and Personal Protective Equipment Selection 1. Controlling hazards. PPE devices alone should not be relied on to provide protection against hazards, but should be used in con junction with guards, engineering controls, and sound manufacturing practices. 2. Assessment and selection. It is necessary to consider certain general guidelines for assess ing the foot, head, eye and face, and hand haz ard situations that exist in an occupational or educational operation or process, and to match the protective devices to the particular hazard. It should be the responsibility of the safety officer to exercise common sense and appropri ate expertise to accomplish these tasks. 3. Assessment guidelines. In order to assess the need for PPE the following steps should be taken: a. Survey. Conduct a walk-through survey of the areas in question. The purpose of the sur vey is to identify sources of hazards to workers and co-workers. Consideration should be given to the basic hazard categories; (a) Impact (b) Penetration (c) Compression (roll-over) (d) Chemical (e) Heat (f) Harmful dust (g) Light (optical) radiation b. Sources. During the walk-through survey the safety officer should observe: (a) Sources of motion; i.e., machinery or pro cesses where any movement of tools, machine elements or particles could exist, or movement of personnel that could result in collision with stationary objects; (b) Sources of high temperatures that could result in burns, eye injury or ignition of pro tective equipment, etc.; (c) Types of chemical exposures; (d) Sources of harmful dust; (e) Sources of light radiation, i.e., welding, brazing, cutting, furnaces, heat treating, high intensity lights, etc.; (f) Sources of falling objects or potential for dropping objects; (g) Sources of sharp objects which might pierce the feet or cut the hands; (h) Sources of rolling or pinching objects which could crush the feet; (i) Layout of workplace and location of co workers; and (j) Any electrical hazards. In addition, injury/accident data should be reviewed to help identify problem areas. c. Organize data. Following the walk-through survey, it is necessary to organize the data and information for use in the assessment of haz ards. The objective is to prepare for an analysis of the hazards in the environment to enable proper selection of protective equipment. d. Analyze data. Having gathered and orga nized data on a workplace, an estimate of the potential for injuries should be made. Each of the basic hazards (paragraph 3.a.) should be R| oym CTL023216 AUGUST1994 VOLUME* *-- `j - - ^ ^ NUMBER^ ' j reviewed and a determination made as to the type, level of risk, and seriousness of potential injury from each of the hazards found in the area. The possibility of exposure to several hazards simultaneously should be considered. 4. Selection guidelines. After completion of the procedures in paragraph 3, the general proce dure for selection of protective equipment is to: a) Become familiar with the potential hazards and the type of protective equipment that is available, and what it can do; i.e., splash pro tection, impact protection, etc.; b) Compare the hazards associated with the environment; i.e., impact velocities, masses, projectile shape, radiation intensities, with the capabilities of the available protective equipment; c) Select the protective equipment which ensures a level of protection greater than the minimum required to protect employees from the hazards; and d) Fit the user with the protective device and give instructions on care and use of the PPE. It is very important that end users be made aware of all warning labels for and limitations of their PPE. 5. Fitting the device. Careful consideration must be given to comfort and fit. PPE that fits poorly will not afford the necessary protection. Continued wearing of the device is more likely if it fits the wearer comfortably. Protective Eye and Face Protection Selection Chart Source Assessment of Hazard Protection IMPACT--Chipping, grinding machining, masonry work. woodworking, sawing, dnlling, chiseling, powered tastening, riveting, and sanding.. HEAT--Furnace operations, pouring, casting, hot dip ping, and welding. CHEMICALS--Acid and chemicals handling, degreasing plating.. DUST-- Woodworking, buffing, general dusty conditions. LIGHT and/or RADIATION--. Welding: Electric arc Welding: Gas Cutting, Torch brazing. Torch soldering Glare Flying fragments, objects, targe chips, particles sand, dirt, etc.. Hot sparks ..................................... Splash from molten metals............ High temperature exposure........... Splash ____________ __ ________ Irritating mists ....... ................. ....... Nuisance dust.... ........... ............. Optical radiation............................. Optical radiation............................. Optical radiation............................. Poor vision..................................... Spectacles with side protection, goggles, (ace shields. See notes (1), (3), (5), (6), (10). For severe exposure, use faceshiek). Faceshields, goggles, spectacles with side pro tection. For severe exposure use faceshield See notes (1), (2), (3). Faceshields worn over goggles. See notes (1). (2). (3). Screen face shields, reflective lace shields. See notes (1). (2), (3). Goggles, eyecup and cover types. For severe exposure, use face shield. See notes (3). (11). Special-purpose goggles. Goggles, eyecup and cover types. See note (8). Welding helmets or welding shields. Typical shades: 10-14. See notes (9), (12) Welding goggles or welding face shield. Typical shades: gas welding 4-3, cutting 3-6, brazing 3-4. See note (S) Spectacles or welding face-shield. Typical shades, 1.5-3. See notes (3), (9) Spectacles with shaded or special-purpose lenses, as suitable. See notes (9), (10). Notes to Eye and Face Protection Selection Chart: (1) Care should be taken to recognize the possibility of multiple and simultaneous exposure to a vanety of hazards. Adequate protection against the highest level of each of the hazards should be provided. Protective devices do not provide unlimited protection. (2) Operations involving heat may also involve light radiation. As required by the standard, protection from both hazards must be provided. (3) Faceshields should only be worn over primary eye protection (spectacles or goggles). (4) As required by the standard, filter lenses must meet the requirements for shade designations in 1910.133(a)(5). Tinted and shaded lenses are not filter lenses unless they are marked or identified as such. (5) As required by the standard, persons whose vision requires the use of prescription (Rx) lenses must wear either protective devices fitted with prescnption (Rx) lenses or protective devices designed to be worn ever regular prescription (Rx) eyewear. (6) Wearers of contact lenses must also wear appropriate eye and face protection devices in a hazardous environment. It should be recog nized that dusty and/or chemical environments may represent an additional hazard to contact lens wearers. (7) Caution should be exercised in the use of metal frame protective devices in electrical hazard areas. (8) Atmosphenc conditions and the restricted ventilation of the protector can cause lenses to fog. Frequent cleansing may be necessary. (9) Welding helmets or faceshields should be used only over pnmary eye protection (spectacles or goggles). (10) Non-sideshield spectacles are available for frontal protection only, but are not acceptable eye protection for the sources and operations listed for "impact." (11) Ventilation should be adequate, but well protected from splash entry. Eye and face protection should be designed and used so that it pro vides both adequate ventilation and protects the wearer from splash entry. (12) Protection from light radiation is directly related to filter lens density. See note (4) . Select the darkest shade that allows task performance. CTL023217 AUGUST 1994 VOLUME4 NUMBER 8 devices are generally available in a variety of sizes. Care should be taken to ensure that the right size is selected. 6. Devices with adjustable features. Adjust ments should be made on an individual basis for a comfortable fit that will maintain the protective device in the proper position. Par ticular care should be taken in fitting devices for eye protection against dust and chemical splash to ensure that the devices are sealed to the face. In addition, proper fitting of helmets is important to ensure that is will not fall off during work operations. In some cases a chin strap may be necessary to keep the helmet on an employee's head. (Chin straps should break at a reasonable low force, however, so as to prevent a strangulation hazard). Where manu facturer's instructions are available, they should be followed carefully. 7. Reassessment of hazards. It is the responsi bility of the safety officer to reassess the work place hazard situation as necessary, by identi fying and evaluating new equipment and processes, reviewing accident records, and reevaluating the suitability of previously selected PPE. 8. Selection chart guidelines for eye and face protection. Some occupations (not a complete list) for which eye protection should be routine ly considered are: carpen ters, electricians, machin ists, mechanics and repairers, millwrights, plumbers and pipe fit ters, sheet metal workers and tinsmiths, assemblers, sanders, grinding machine opera tors, lathe and milling machine operators, sawyers, welders, laborers, chemical process operators and handlers, and timber cutting and logging workers. The selection chart pro vides general guidance for the proper selection of eye and face protection to protect against hazards associated with the listed hazard "source" operations. (See Chart on page 8). 9. Selection guidelines for head protection. All head protection (helmets) is designed to pro vide protection from impact and penetration hazards caused by falling objects. Head protec tion is also available which provides protection from electric shock and burn. When selecting head protection, knowledge of potential elec trical hazards is important. Class A helmets, in addition to impact and penetration resis tance, provide electrical protection from lowvoltage conductors (they are proof tested to 2,200 volts). Class B helmets, in addition to impact and penetration resistance, provide electrical protection from high-voltage conduc tors (they are proof tested to 20,000 volts). Class C helmets provide impact and penetra tion resistance (they are usually made of alu minum which conducts electricity), and should not be used around electrical hazards. Where falling object hazards are present, hel mets must be worn. Some examples include: working below other workers who are using tools and materials which could fall; working around or under conveyor belts which are car rying parts or materials; working below machinery or processes which might cause material or objects to fall; and working on exposed energized conductors. Some examples of occupations for which head protection should be routinely considered are: carpenters, electricians, linemen, mechanics and repairers, plumbers and pipe fitters, assemblers, packers, wrappers, sawyers, welders, laborers, freight handlers, timber cut ting and logging, stock handlers, and ware house laborers. 10. Selection guidelines for foot protection. Safety shoes and boots which meet the ANSI Z41-1991 Standard pro vide both impact and com pression protection. Where necessary, safety shoes can be obtained which provide punc ture protection. In some work situations, metatarsal protection should be provided, and in other special situations electrical conductive or insulating safety shoes would be appropriate. Safety shoes or boots with impact protection would be required for carrying or handling materials such as packages, objects, parts or heavy tools, which could be dropped; and, for other activities where objects might fall onto the feet. Safety shoes or boots with compres sion protection would be required for work CTL023218 4 AUGUST 1994 JV-O- --L--U- ME -4--- - ^ - ^NUMBER 8 activities involving skid trucks (manual mate rial handling carts) around bulk rolls (such as paper rolls) and around heavy pipes, all of which could potentially roll over an employee's feet. Safety shoes or boots with puncture pro tection would be required where sharp objects such as nails, wire, tacks, screws, large sta ples, scrap metal etc., could be stepped on by employees causing a foot injury. Some occupations (not a complete list) for which foot protection should be routinely con sidered are: shipping and receiving clerks, stock clerks, carpenters, electricians, machin ists, mechanics and repairers, plumbers and pipe fitters, structural metal workers, assem blers, drywall installers and lathers, packers, wrappers, craters, punch and stamping press operators, sawyers, welders, laborers, freight handlers, gardeners and grounds-keepers, timber cutting and logging workers, stock han dlers and warehouse laborers. 11. Selection guidelines for hand protection. Gloves are often relied upon to prevent cuts, abrasions, burns, and skin contact with chemicals that are capable of causing local or systemic effects fol lowing dermal exposure. OSHA is unaware of any gloves that provide protection against all potential hand hazards, and commonly available glove materials pro vide only limited protection against many chemicals. Therefore, it is important to select the most appropriate glove for a particular application and to determine how long it can be worn, and whether it can be reused. It is also important to know the performance characteristics of gloves relative to the specific hazard anticipated; e.g., chemical hazards, cut hazards, flame hazards, etc. These perfor mance characteristics should be assessed by using standard test procedures. Before pur chasing gloves, the employer should request documentation from the manufacturer that the gloves meet the appropriate test stan dard^) for the hazard(s) anticipated. Other factors to be considered for glove selec tion in general include: (A) As long as the performance characteris tics are acceptable, in certain circumstances, it may be more cost effective to regularly change cheaper gloves than to reuse more expensive types; and, (B) The work activities of the employee should be studied to determine the degree of dexterity required, the duration, frequency, and degree of exposure of the hazard, and the physical stresses that will be applied. With respect to selection of gloves for protec tion against chemical hazards: (A) The toxic properties of the chemical(s) must be determined; in particular, the ability of the chemical to cause local effects on the skin and/or to pass through the skin and cause systemic effects; (B) Generally, any "chemical resistant" glove can be used for dry powders; (C) For mixtures and formulated products (unless specific test data are available), a glove should be selected on the basis of the chemical component with the shortest break through time, since it is possible for solvents to carry active ingredients through polymeric materials; and, (D) Employee's must be able to remove the gloves in such a manner as to prevent skin contamination. 12. Cleaning and maintenance. It is important that all PPE be kept clean and properly main tained. Cleaning is particularly important for eye and face protection where dirty or fogged lenses could impair vision. For the purposes of compliance with 1910.132(a) and (b), PPE should be inspected, cleaned, and maintained at regular intervals so that the PPE provides the requisite protection. It is also important to ensure that contaminat ed PPE which cannot be decontaminated is disposed of in a manner that protects employ ees from exposure to hazards. 'AUGUST 1994 --/T.-gry- VOLUME 4 _L NUMBER 8 HhC TABLE 2--Number ol Employees and Parts of the Body Requiring Personal Protective Equipment Among the Population at Risk OIGS 1/kJuSU rtiS Production Employees Total Exposed . Population Head Body Part Exposed- Eye Face Hand 20,21 22 20,31 24 25 26 27 28 29 30 32 33 34 35 36 37 38,39 41,42 48 49 501,55, 75 50,51,52 7692 13 078,08 Food & Tobacco ............ Textiles ........................... Apparel & Leather ......... Lumber & Wood Prod ucts. Furniture & Fixtures....... Paper & Allied Products . Printing & Publishing ..... Chemicals ....................... Petroleum Refining........ Rubber & Plastics.......... Stone, Glass, Concrete .. Primary Metals ............... Fabricated Metals........... Machinery & Computers . Electric & Electronics .... Transportation Equip ment. Misc. Manufacturing ...... Transportation ................ Communications............. Utilities ............................ Automotive Trade & Services. Wholesale & Retail Trade Welding Repair............... Oil & Gas Extraction...... Horticulture & Forestry ... 1,196,818 596,846 964,677 597.764 412,323 479,730 680,370 497,054 44,169 565.705 400,987 549,603 921,660 1,018,420 1,204,266 1,113,656 599,624 1,258,897 788,800 334,492 1,373.718 963,641 24.622 117,579 173,863 782,205 255,815 558,884 405,054 306,280 387,578 462,259 402,925 33,805 393,468 282,065 476,145 638,577 788,598 810,492 894,417 410,532 688,183 642,609 266,440 803,309 822,312 20,317 92,602 106,782 112,574 36,685 16,527 65,597 26,231 35,146 0 116,763 14,562 47,984 64,462 95,001 33,157 59,583 66,001 53,777 35,815 70,798 461,102 126,995 55,791 255,319 797 49,872 22,050 91,806 104.918 72,682 29,483 41.767 132,898 242,298 158,344 11.918 57,839 38,156 95,727 85,767 146,365 334,211 129,841 124,151 79,546 133,783 106,879 297,398 154,863 11,108 51,451 39,546 0 3,877 0 104,352 26,130 4,576 0 3,098 476 20,048 19,234 120,272 12,101 2,246 611 4,575 9,092 588 15,162 24,321 0 4,842 172 0 5,146 220,059 134,669 462,683 103,547 127,295 156,569 257,095 155,596 16,136 124,766 81,620 214,995 144,447 329.603 469,622 315.617 203,543 67,043 341,999 96,394 407,995 134,153 10,492 51,804 83,217 TOTAL 16,879,284 11,731,653 1,922,589 2,772,745 380,919 4,710,979 * "Exposed body part" total exceeds total exposed population because some employees are exposed to multiple hazards. Source: U.S. Department of Labor, OSHA, Office of Regulatory Analysis._________________________ Foot 652.884 129,498 133,101 388,436 234,696 326,256 333,121 322,095 15,948 313,688 243,835 394,255 570.595 631,485 455,479 759,262 284,091 665,473 182,129 246,691 595,690 742,635 15,278 76,391 44,856 8,757,868 PPE Impacts on General Industry The hazards addressed by the new personal protective equipment standards are present in varying degrees in virtually all workplaces cov ered by OSHA's General Industry standards. Impact varies by industry, depending on the hazards, the types of occupational activity, and current practices regarding PPE use. PPE has been in widespread use for many years. However, until recently very little statis tical data existed to determine the number of employees who are using PPE or who should be using PPE by virtue of the hazards to which they are exposed. OSHA inspection documents indicate that approximately 3.5 percent of all planned safety inspections result in citations under PPE standards. Statistics published by the Bureau of Labor Statistics (BLS) provide evidence that many injured workers are not wearing adequate per sonal protective equipment. Based on BLS data, relatively few firms with serious record able injury cases have performed a formal assessment of the potential hazards in their workplace. In addition, these firms offered minimal training to workers regarding the importance of using protective equipment. To obtain information on the need for personal protective equipment and the extent to which that need is being met, OSHA conducted a national survey in 1989. The survey sampled 5,361 establishments from 61 SIC groups. It identified hazards related to industrial pro cesses and types of PPE required when work ing in or near these processes. Answers to sur vey questions were used to evaluate the appropriateness of PPE use, training, and haz ard assessment. The survey identified over 11 million workers who should be wearing some form of PPE. Occupational categories include craft, operat ing, maintenance and material handling employees. These categories encompass most production employees and are most likely to be affected by this standard. However, OSHA has previously estimated over a million other work ers may also be exposed to hazards requiring PPE use in the rest of general industry. ^'AUGUST 1994 ' j*-,' rij^.-qcy- - ^Lsii, "gig-,PS1---' r.ww.;n,.i ^3?MSNUMBER 8 ^ TABLE 4--Injuries Prevented Through Compliance With New PPE Requirements SIC Industry Lost Workday Lost Workdays Non-lost-workday Cases Prevented Prevented Cases Prevented 20.21 22 23,31 24 25 26 27 28 29 30 32 33 34 35 36 37 38,39 41.42 48 49 501,55,75 50.51,52 7692 13 078.08 Food & Tobacco....................................................................... Textiles.......................................... .......................................... Apparel & Leather.................................................................... . Lumber & Wood Products........................................................ Furniture & Fixtures .................................................................. Paper & Allied Products............................ ............................. . Printing & Publishing................................................................ Chemicals....... .................................................._..................... . Petroleum Refining................................................................... Rubber & Plastics .................................................................... Stone, Glass, Concrete............................................................ Primary Metals......................................................................... Fabricated Metals....................................... .............................. Machinery & Computers ......................................................... Electric & Electronics................................................................ Transportation Equipment....................................................... . Misc. Manufactumg... .................................. ............................ TCroamnmspuonrictaattiioonn.s............................................................................................................................................................... Utilities...................................................................................... Automotive Trade & Services .................................................. Wholesale & Retail Trade........................................................ Welding Repair......................................................................... . Oil & Gas Extraction ................................................................. Horticulture & Forestry................................... ......................... 3,178 710 607 1,850 1,216 978 755 783 120 1,873 989 1,829 3,506 3,372 1,343 1,966 1,044 2,127 255 740 1,423 6,243 90 389 537 57.195 12,780 11,531 35,151 20,680 21,512 14,340 14,870 2,529 31,837 19,782 36,587 63,114 57,324 24,173 37,359 19,374 54,710 4.846 13,318 26,005 109,743 1,424 11,680 10,358 3,945 1,405 1,482 2,375 1,818 1,718 1,361 1,082 125 2,625 1,578 2,821 6,097 6,744 2,578 5,829 1,610 2,355 357 867 7,942 7,005 91 404 316 37.924 Source: U.S. Department ol Labor, Bureau ol Labor Statistics and OSHA, Office of Regulatory Analysis 712,223 64,530 Table 2 (page 11) shows that almost 8.8 mil lion workers are exposed to foot injury, while the potential for hand injury exists for 4.7 million workers. Other anatomical parts cov ered by this rule are eyes (2.8 million work ers), head (1.9 million workers) and face (381,000 workers). OSHA expects that employers will be able to comply with the new and revised require ments without difficulty, because the means of compliance are readily available and because the final rule "grandfathers" equipment that complies.with the existing standards. Costs of Compliance OSHA estimated compliance costs using data on current practices and exposed population from the PPE survey. Annual compliance costs under the new provisions will approximate $52.4 million. OSHA's survey identified 433,149 establish ments which need to take steps to come into compliance with the new provisions for hazard assessment. Approximately 47 percent already have a hazard assessment program in place. The cost to conduct hazard assessments for all establishments was estimated to be $15.9 mil lion per year, assuming a reassessment is con ducted once every five years. The new provision for PPE training will affect approximately 10.8 million employees in need of training, at an annual cost of $36.5 million. Assessment of Hazards and Benefits OSHA believes that the risk of fatality and injury to workers is unacceptably high among sectors affected by the revised personal protec tive equipment standard. The revised stan dard is designed to enhance compliance with existing requirements and ensure future com pliance related to a heightened level of hazard awareness and training. These changes to the standard should help to eliminate or reduce accidents within industries subject to the rule. The standard has performance-oriented provi sions addressing eye, face, hand, head and foot hazards that allow employers to adopt the most up-to-date PPE for use in their establish ments. The flexibility to substitute new mate rials and technologies should produce more comfortable and protective PPE, increasing worker acceptance. OSHA's expectation is that increased use of better equipment will prevent or lessen the severity of many accidents. * |p AUGUST rssew: -rr" r3VOLUME4' i rt inr-- ' ^ ~v 'V'*- w-, 'M *' *muiij.iu -i ^.NUMBER 'i>!7.h ir .in 8^ ^ Injuries According to BLS statistics in Occupational Injuries and Illnesses in the United States by Industry, 1989, there were a total of 1.6 mil lion lost-workday cases and 1.8 million nonlost-workday cases during the survey year. Estimated injuries which could be prevented by the new standards are shown in Table 4 (page 12). Cost of scheduling and funding overtime necessitated by the accident. Cost to find and train a replacement worker. Extra wage cost to rehabilitate the returning worker at a reduced capacity. Cost to clean up, repair, or replace dam age from the accident. OSHA estimates that employers will save 712,000 lost workdays and 65,000 non-lost workday cases from compliance with require ments for employee training and workplace hazard assessment. These benefits will be gained through selection of more appropriate PPE, increased awareness of hazards and improved consistency in use. Accident data indicates that 125 fatal head injuries occur annually. While most fatal head injuries are the result of crushing injuries, falls, explosions and other traumatic events beyond the scope of this standard, some are preventable with the use of head protection. OSHA believes that four head injury fatalities could be prevented each year through compli ance with the new provisions of the standard. Cost Savings to Employers Based upon the estimated reduction in injuries, OSHA estimates that society will reap substantial economic benefits from pre vented injuries. Lost work time injuries are particularly expensive. Cost for safety and clerical personnel to record and investigate the accident. However, the cost of workplace injuries is typi cally borne primarily by employees them selves. Applying this figure to OSHA's esti mate of 37,924 lost workday injuries prevented annually, revisions to the rule should save employees, employers and third parties over $1 billion annually. These figures of economic benefits may be con servative, since the benefits analysis focuses on injuries prevented, not reduced severity of injuries. In sum, OSHA estimates the rule will save society over $1 billion annually, dwarfing the initial $52 million investment. Employers themselves should save over $150 million through full compliance with revisions to the PPE standard, approximately three times the estimated cost of compliance. t--.. ^ # While employers typically bear only a fraction of the costs related to injuries, these costs can be substantial. Employers specifically will ben efit from reduced lost production time, adminis trative time spent preparing insurance claims and accident reports, and replacing injured workers. The average lost worktime injury costs employers at least $4000 and the new rule could save firms over $150 million annually. Costs involved include: Safety Matters Rt . Danger From Above - Hard Hats Protect Workers Administrative cost of handling insur ance company claims. Wages paid to other workers for the time not worked (work interrupted). In two recent incidents, workers were struck and injured by falling objects that were dis lodged from loads hoisted overhead. In both cases, hard hats worn by the workers prevent ed more serious injuries from occurring. ElSilHilii J . - AUGUST 1994 ^2^YPLUME4: NUMBER 8 The first incident occurred when work ers were preparing to lower two convey or belt rollers down a shaft. The rollers were secured in a sling. When a worker pulled the tag line to adjust the load, the line slid along the roller and dislodged a 10-pound bearing on the end. The bear ing fell 200 feet down the shaft, rico cheted off the lower shaft wall, and hit a worker standing 10 feet inside the shaft. The bearing struck the worker's hard hat, which he was wearing backwards, and hit him on the forehead, knocking him to the ground. The second incident occurred while a flag pole was being raised. An iron worker steadying the base of the pole was struck on the head and shoulder by a piece of wood that came loose when the crane operator inadvertently released tension on the choker. The worker initially declined medical attention but received treatment for cervical injury the next day. He underwent neck surgery about two months after the incident. These incidents suggest a shared lesson regarding the use of hard hats. Wear your hard hat, and wear it properly. Hard hats are vital pieces of personal pro tective equipment. They should be worn near hoisted loads and in all other situa tions for which they are required. Work ers who wear their equipment improperly do not receive the maximum benefit of its protection. Whenever loads are hoisted overhead, there is always a danger that something will fall. To mitigate this danger, the following precautions should be taken: Stay clear of hoisted loads. Workers should take all reasonable precautions to avoid placing themselves beneath a hoisted load. Always pay attention to your surround ings. In the second incident, the crane operator's momentary distraction allowed the choker to become slack. All loads must be thoroughly checked before they are moved. Loose items must be properly secured or removed and hoisted separately. Rigging should be appropriate for the lift. EPA Activity Freon Release Brings Citation from EPA The owner/manager of a Missouri car-repair shop pleaded guilty for knowingly releasing freon (which contains chlorofluorocarbons or CFCs) while servicing automobile air condition ers at his business. Approximately 60 automo biles were serviced at the shop between Jan uary 1992 and July 1993, the period covered by this citation. The owner could face up to five years in prison and/or a $250,000 fine. This was the first case filed involving Clean Air Act (CAA) requirements that repair shops use freon recycling equipment. The require ments also mandate that employees be trained and certified in the use of this equipment before servicing motor vehicle air conditioners (MVACs). Mechanics using proper equipment can capture freon in the machine, filter it, and resell it to the next customer. EPA estimates that prior to implementation of the 1992 CAA requirements, 30 percent of all CFCs released into the atmosphere came from mobile air conditioners with most of the releas es occurring during A/C service and repair. For more information: Contact Linda Algar, EPA Region 7, (913) 551-7060. EPA Considers Removing Pigment Blue 15:1 from Toxic Chemical List The Environmental Protection Agency has issued a proposal to remove Pigment Blue 15:1 (copper monochlorophthalocyanine) from the "copper compounds" category of the toxic chemicals list. EPA has concluded that copper CTL023223 1 AUGUST 1994 111 "" [rC~ VOLUME 4 ^V*!S--jr~ ^ t,iiyw g# number's monochlorophthalocyanine is not known to cause acute or chronic toxicity in humans or to have adverse effects in the environment and therefore, does not meet the criteria of EPCRA section 313(d)(2). The toxic chemicals list is comprised of over 300 chemicals subject to reporting under sec tion 313 of the Emergency Planning and Com munity Right-to-Know Act. For more informa tion, contact Maria Doa, EPA, (202) 260-9592 or the EPCRA Hotline (800) 535-0202. EPA Compiles Radon Maps for Upper Midwest Region 5 of the Environmental Protection Agency (EPA) recently released maps identify ing radon risks for each county in the six upper Midwest states. Radon is a radioactive gas which rises naturally from the soil and can accumulate in buildings. Annually, an estimat ed 14,000 deaths in the U.S. are attributed to radon contamination. The maps will help government and other orga nizations target high-risk areas and popula tions. They can determine whether counties fall into high, moderate, or low radon zones and where special building codes may be necessary. EPA compiled the maps using data on indoor radon measurements, foundation types, the amount of uranium in underground rocks, geology, and soil permeability. The Environ mental Protection Agency strongly recom mends radon testing. For more information on the maps or on radon issues, contact EPA's Region 5 at (312) 886-6042. "Safe & Secure", Television Show Highlights Keller's Official OSHA Safety Handbook Tune your TV sets to CNBC on July 30 at 4:00 p.m. (EST) to watch a full-featured seg ment on Keller's latest innovation in safety training. This 200-page, full-color, illustrated handbook features all 17 of OSHA's most focused-on topics including lockout tagout, confined spaces and forklift safety. The employee receipt page used for training docu mentation and the low cost make this publi cation an ideal training tool for all your employees. For a free sample please call us toll-free at 1-800-531-8899. RCRA Updates Inspection Manual The Environmental Protection Agency (EPA) recently announced the availability of The 1993 RCRA Inspection Manual. This updated guide for final inspections replaces the 1988 RCRA Inspection Manual. This manual is primarily intended for use by RCRA field inspectors to assist them in compliance evaluation inspections of RCRA generators, transporters, and treatment, storage, and disposal (TSDs) facilities. However, EPA has made it available to the public. Copies of the new manual are available for viewing at all EPA libraries. It can be pur chased from the National Technical Infor mation Service (NTIS), U.S. Department of Commerce, Springfield, VA 22161 (703) 4874600. Request The 1993 RCRA Inspection Manual (NTIS #PB94-963-605). CTL023224 SEMINARS AND WORKSHOPS J.J. Keller & Associates, Inc., will be holding the following seminars and workshops in September and October of this year. Call (800) 642-2067 for more information. SEPTEMBER OSHA SEMINAR 20 Albany, NY 21 East Syracuse, NY 22 Buffalo, NY OSHA WORKSHOP 13 Ontario, CA 15 San Diego, CA HM-181 TECHNICAL TRAINING COURSE 14-16 Natick, MA HAZARDOUS WASTE MANAGEMENT SEMINAR 27 Knoxville, TN 28 Nashville, TN 29 Memphis, TN OCTOBER ALCOHOL & DRUG COMPLIANCE SEMINAR 20-21 Houston, TX 22-23 Dallas, TX 27-28 Nashville, TN 29-30 Memphis, TN WORKER'S COMPENSATION SEMINAR 1 Philadelphia, PA 13 Des Moines, LA 14 Kansas City, MO 15 St. Louis, MO 20 Natick, MA 21 Saddlebrook, NJ 22 East Elmhurst, NY HM-181 SEMINAR 20 Fort Wayne, IN 21 Indianapolis, IN 22 New Albany, IN HM-181 WORKSHOP 13-14 Tulsa, OK 15-16 Oklahoma City, OK OSHA MANAGEMENT - BEYOND COMPLIANCE 19-21 King of Prussia, PA ALCOHOL & DRUG COMPLIANCE SEMINAR 11-12 Minneapolis, MN 13-14 Milwaukee, WI 18-19 Coraopolis, PA 20-21 Harrisburg, PA WORKER'S COMPENSATION SEMINAR 4 Cincinnati, OH 5 Columbus, OH 6 Cleveland, OH 11 Memphis, TN 12 Birmingham, AL 13 Atlanta, GA 25 Portage, IN 26 LaGrange, IL 27 Arlington Heights, IL HM-181 TECHNICAL TRAINING COURSE 26-28 Long Beach, CA 1994 J. J. Keller & Associates, Inc., Neenah, WI 54957-0368, U.S.A. All rights are reserved. Neither the Bulletin nor any part thereof may be reproduced in any manner without the written permission of the publisher. Due to the constantly changing nature of government regulations, it is impossible to guarantee absolute accuracy of the material contained herein. The Publisher and Editors, therefore, cannot assume any responsibility for omissions, errors, misprinting, or ambiguity contained within this publication and shall not be held liable in any degree for any loss or injury caused by such omission, error, misprinting or ambigu ity presented in this publication. This publication is designed to provide reasonably accurate and authoritative information in regard to the subject matter covered. It is sold with the understanding that the Publisher is not engaged in rendering legal, accounting, or other professional service. If legal advice or other expert assistance is required, the services of a competent professional person should be sought. EDITOR: Julie A. Nussbaum EDITORIAL MANAGER: Webb A. Shaw CONTRIBUTING EDITORS: Linda S. Wereley, Timothy J. Solinger, Mary Gavin Schreiber, Gerald L. Woodson, Patrick B. Olsen ISSN 1053-3826 Canadian Goods and Services Tax (GST) Number - R123-317687 Printed In USA IKEUIfi SSOGfATESUNC CTL023225 I t* Highlight on Publications -- Compliance Audits Training & Recordkeeping Essential Checklists for OSHA, EPA & Other Key Agencies OSHA/EPA/DOT Crossreference Manual Compliance Need Compliance Need The complexity of complying with OSHA and EPA regula tions requires constant auditing. This unique manual makes the auditing process easier and more comprehensive. Product Information When dealing with multiple regulatory agencies such as OSHA, EPA, and DOT, there is an overriding need for coor dinating the massive recordkeeping and training requirements while eliminating overlapping efforts. Records should also be easily accessible. Organized by work-area or typical work situation, this manual has three sections: 1. A "pull-out/carry-along" section for the in-plant audit, con sisting of multi-part forms: An original for the auditor file, copy for maintenance/repair, and a copy to verify repair. 2. An "office-based" audit section to verify compliance with planning and recordkeeping requirements. 3. A reference section with explanatory material. The record keeping section covers emergency response plans. Hazard communication plans, training and similar items. Product Information This "one-stop" reference helps save time by consolidating compliance requirements for OSHA/EPA/DOT training and recordkeeping. It clearly explains requirements and how to handle them to avoid duplicating compliance efforts. It also provides a unified, comprehensive approach to recordkeeping to help assure successful compliance as well as proper docu mentation in the event of a lawsuit or agency enforcement action. Samples of forms, logs and other support documenta tion are included. Specifications 17 area-specific 4-part forms and 1 generic form in front pocket of binder. (Includes pad holder). EPA and OSHA checklists for work areas, including: Warehouse, Welding Area, Compressed Gas Storage Area, Spray Paint Area, Plant Maintenance Area, etc. Hazard Communication written program; Process Safety Management of Highly Hazardous Chemicals; Emergency Action Plan; employee training records and much more. Loose-leaf 3-ring binder, tab divided, 192 pages. T Update Service available separately. Special Subscriber Offer: Purchase a 3 or 5 year ,, subscription and receive this manual FREE! Specifications T Addresses training, as required under OSHA, EPA and DOT: Lists of required training; forms and certificates to be used; compliance tips; checklists; and recordkeeping. Loose-leaf 3-ring binder, tab-divided. Approximately 450 pages. T Update Service available separately. Special Subscriber Offer: Purchase a 3 ot 5 year subscription and receive this manual FREE! Manual alone. Only $125 Manual alone. Only $125 (800) 327-6868 (TS-48-M) (800) 327-6868 J. J. KELLER & ASSOCIATES, INC. Action Code 9032 CTL023226 L________ Highlight on Training -- Lockout/Tagout Safety Training A Video Training Kit Compliance Need 29 CFR 1910.147 requires that employees involved in certain processes must be provided with a specific training program, on lockout/tagout. Product Information A full-color video shows employees practicing proper lock out/tagout procedures in an actual manufacturing plant. It includes employee handbooks filled with the exact training information called for in 29CFR, Part 1910.147. the kit focuses on energy sources - how to identify them, what pro cedures are required to avoid life threatening situations, how to ensure a "Zero Energy State", when to use tags, what rules to follow for using multiple locks, and other informa tion. It includes the proper paperwork for meeting documen tation requirements. Each kit contains enough material to train up to 10 employees. Additional materials can be ordered separately. Specifications T 1 VHS, full-color, 13-minute Video T 1 Instructors Guide (20 pages) 10 Employee Handbooks (20 pages each; pre- and post training quizzes included) T 1 Training Log 10 Wallet Cards Safe Forklift Operations A Video Training Kit Compliance Need 1910.178(1) states that anyone who operates a powered industrial truck (forklift) must be trained. Product Information This ready-to-use program covers everything the forklift operator needs to know based on OSHA's Part 1910.178 training requirements. The full-color training video shows professional forklift drivers in different warehouse situations. Topics covered include: inspecting the forklift, picking up and traveling with loads, stacking and dropping loads, work ing with smaller lift devices, and proper procedures for using hand trucks and other equipment. The kit comes in an attrac tive clamshell binder for convenient storage of components. Each kit contains enough material to train up to 10 employ ees. Additional materials can be ordered separately. Specifications 1 VHS, full-color 18-minute Video T 1 Instructor's Guide (8 pages) T 10 Employee Handbooks (20 pages each; pre- and post- training quizzes included) 1 Training Log T 10 Wallet Cards Special;;. . Subscriber/Sf/T Offer: - Receive this entire pmj: gram in an attractive }:^;' clamshell binder for.. . 4V' -vt '`A'-Jr- ; . A. i-VntWi. Only $125 Safi'tv Training: (TS-28-K) (800) 327-6868 Special , Subscriber/ Receive this entire program in an attractive - ' v/* clamshell binder for... - (TS-27-K) (800) 327-6868 J. J. KELLER & ASSOCIATES, INC. Action Code 9032 CTL023227 U252 'l