Document zQ04NQrerL8ro2VMbovbwL2dR

A Division of The Society of The Hashes Industry, Inc. ** 021990 JCL March 26, 1990 TO: The VI Health, Safety & Environment Committee RE: OSHA: Respirators/Engineering Controls As noted on the attached, OSHA has scheduled a public hearing (May 30th) to receive testimony on the Agency's June 5, 1989 proposal to amend existing regulations by identifying certain circumstances for which engineering controls may not be feasible. MNS/pmb Meredith N. Scheck Assistant Director The Society of the Plastics Industry, Inc. 1275 K Street, N.W., Suite 400 Washington, D.C. 20005 (202) 371-5200 FAX 371-1022 MAR 2 31990 TO: OHEIC Stee ` Committee FROM: Phil Stapleton . assistant Technical Director, Issues Analysis RE: OSHA Informal Public Hearing on Alternative Methods of Compliance DATE: March 20, 1990 On March 7, 1990 (55 FR 8152) OSHA announced that an informal public hearing would be held to discuss circumstances in which respirators may be used in lieu of engineering controls to limit exposure to toxic substances. As you may recall, OSHA proposed to amend its regulations on June 5, 1989 (54 FR 23995) to provide flexibility in circumstances where limiting exposure through implementation of engineering controls was infeasible. The proposed rule identified several situations where engineering controls may not be feasible including, among others: where engineering controls result in only negligible reduction in exposure, during emergencies, repair, shutdowns, and field situations where there is a lack of utilities, and during entry into unknown atmospheres. OSHA requested comments on the consideration of cost-effectiveness in determining acceptable control methods, the appropriateness of using respirators in lieu of engineering controls and other aspects of the proposal. The informal hearing is being conducted by OSHA in order to receive testimony and data relevant to the issues raised by the proposed rule. The hearing is scheduled for May 30, 1990, starting at 9:30 am. The location of the hearing will be the Dept, of Labor Building, 200 Constitution Avenue, Washington, D.C. The Federal Register notice is attached. Please call if you have any questions or comments. PJS/rc Attachment cc: H. P. Toner Richard LaLumondier Betsy Shirley Rich Gottwald BOR 009018 8152 Federal Register / Vol. 55. No. 45 / Wednesday. March I Proposed Rules ^ / existing provisions for the methods of February 26.1979); and (3) does not warrant preparation of a regulatory evaluation as the anticipated impact is so minimal Since this is a routine matter that will only affect air traffic procedures and air navigation, it is DEPART------------ ----------- , Occupational Safety and Health Administration am a, | r 29 CFR Part 1910 ^ N c " -- . controlling exposure to toxic substances addressed in its Air Contaminant Standard (29 CFR 1910.1000le)J and Respiratory Protection Standard (29 CFR / 1910.134(a)(1)). The Agencjfproposed to certified that this rule, when promulgated, will not have a significant economic impact on a substantial number of small entities under the criteria of the Regulatory Flexibility Act. List of Subjects in 14 CFR Parts 71 and 73 Aviation safety. Continental control area. Restricted areas. [Docket No. H-160) /"oMtDov4-*~4 * RIN 1218-AA28 2fHHeeaallttlh Standards; Methods (Cojnrptpliance agency: Occupational Safety a^3 Health AdministrationJtOSHAJytaibor. ACTION: Noti^t h of informal public yihcorporate additional flexibility in its methods of compliance requirements by explicitly setting forth, in regulatory language, the circumstances under which respirators may be used due to the general infeasibility of limiting exposure through iimplementation of engineering controls^Other approaches to providing employers with greater flexibility in choosing exposure control The Proposed Amendments Accordingly, pursuant to the authority delegated to me. the Federal Aviation Administration proposes to amend parts 71 and 73 of the Federal Aviation Regulations (14 CFR parts 71 and 73) as follows: PART 71-DESIGNATION OF FEDERAL AIRWAYS, AREA LOW ROUTES, CONTROLLED AIRSPACE. AND REPORTING POINTS 1. The authority citation for part 71 continues to read as follows: Authority: 49 U.S.C. 1348(a). 1354(a). 1510; '"'Executive Order 10854:49 US.C. 106(g) (Revised Pub. L. 97-449. January 12.1983); 14 CFR 11.69. 71.151 [Amended] 2. Section 71.151 is amended as follows: R-6320 Matagorda. TX [New) PART 73--SPECIAL USE AIRSPACE 3. The authority citation for 73 continues to read as follows: Authority: 49 U.S.C. 134Bfa). 1354(a). 1510. 1522: Executive Order 10854; 49 U.S.C. 106(g) (Revised Pub. L. 97-H9, January 12.1983); 14 CFR 11.69. 73.63 [Amended) 4. Section 73.63 is amended as follows: R-63Z0 Matagorda, TX [New] Boundaries. That airspace within a 3-mile circle centered at lat. 28*4234* N,, long. 95*57 34' W. Designated altitudes. Surface up to and including 15.000 feet M5L- Time of designation. Continuous. Controlling agency. Houston ARTCC Using agency. United States Customs Service. Issued in Washington. DC. on t ebruary 27. 1990. Harold W. Becker, Manager. Airspace~Hules and Aeronautical Information Service. (FR Doc. 90-5148 Filed 3-6-90S 8.45 am) BILLING COOS 1S10-D-N hearing)"____________________________ summary; OSHA (^scheduling an informakcublic hearing on its proposed standard 154 FR 23991, fune 5.1989) (to modify the existing provisions for controllin&employee exposure to toxic substanceyfound in 29 CFR 1910.1000(e) and 29 CFR 1910.134(a)(1). This hearing [will allow interested persons to present '-information and evidence on therissues raised by the proposed standard^ dates: Notices of intention to appear at the informal public hearing must be postmariced by April IB, 1990. - Testimony, comments and all evidence which will be introduced into the hearing record mast benostmarekd by May 7,1990- ThartearingAvili be held infWashingtsn. DC peginning ^ Wednesday\May 30,1990 at 9:30 a.n/ The hearing will continue, if necessary, through Friday. June 1,1990. ADORESSEE: Notices of intention to appear at the hearing and testimony and documentary evidence which will be introduced into the hearing record must be submitted in quadruplicate to Mr. Tom Hall, Occupational Safety and Health Administration, Division of Consumer Affairs. Room N3649. 200 Constitution Avenue NW., Washington. DC 20210; (202) 523-8615. Tne informal public hearing will be held in the auditorium of the Frances Perkins Department of Labor Building, 200 Constitution Avenue NW.. Washington. DC 20210. FOR FURTHER INFORMATION CONTACT; Hearings: Mr. Tom Hall, Occupational Safety and Health Administration. Division of Consumer Affairs. Room N3649. 200 Constitution Avenue NW* Washington. DC 20210: (202) 523-8615 Proposal; Mr. James F. Foster. Office of Public Affairs. U.S. Department of Labor. Occupational Safety and Health Administration. Room N3649. 200 Constitution Avenue NW, Washington. DC 20210; (202) 523-8151. supplementary information; On June 5.1989, OSHA proposed to amend it* methodology were also raised in the preamble to the proposed rule. OSHAs proposed standard is based on data submitted to the record in response to an Advance Notice of Proposed Rulemaking published on February 22.1983 (48 FR 7473). and on its experience from other rulemakings dealing with the issue of compliance methodology. The record identified specific situations where engineering controls generally may not be feasible and where respirators may have to be used. The circumstances that were identified by OSHA from data in the record where engineering controls may generally be infeasible are: 1. During the time necessary to install feasible engineering controls: 2. Where feasible engineering controls result in only a negligible reduction in exposure; 3. During emergencies, life saving, recovery operations, repair, shutdowns, and field situations where there is a lack of utilities for implementing engineering controls; 4. Operations requiring added protection where there is a failure of normal controls: and 5. Entries into unknown) atmospheres. The proposed standard incorporated regulatory language specifically exempting these circumstances from requirement of control by engineering means. OSHA proposed paragraph (f)(5) to deal with circumstances where it was infeasible to protect employees from unknown atmospheres through the use of engineering or administrative controls. The discussion of the proposed provision (54 FR at 23995) included reference to confined spaces as examples of workplaces which would be covered by paragraph (f)(5). OSHA wishes to clarify that discussion by noting that there are. in fact, many confined space work situations where it is feasible to protect employees from any hazards which may be confronted in unknown atmospheres through the use tX 9 t'U'lmi3 ? i \ L> BOR 009019 Federal Register / Vol. 55, No. 45 / Wednesday. March 7, 1990 / Proposed Rules 8153 of engineering controls. Therefore, only those confined spaces where it is infeasible to protect employees using such controls would be covered by proposed paragraph (f)(5). OSHA solicits testimony, with supporting information, on any workplace circumstances, including confined spaces, which would be appropriately regulated under the proposed paragraph. The proposed standard also raised for comment other circumstances and approaches where the use of respirators in lieu of feasible engineering controls discussion of issues related to this proceeding. Public Participation in Hearing Pursuant to section 6(b) (3) of the Act. an opportunity to submit oral testimony concerning the limited issues raised by this notice will be provided at an informal public hearing scheduled to begin at 9:30 a.m. on May 30,1990 in the Auditorium. Frances Perkins Department of Labor Building. 200 Constitution Avenue. NW., Washington, DC 20210. reviewed in light of the amount of time requested in the Notice of Intention to Appear. In those instances where the information contained in the submission does not justify the amount of time requested, a more appropriate amount of time will be allocated and the participant will be notified of that fact. Any parly who has not substantially complied with this requirement may be limited to a 10-minute presentation. Any party who has not filed a notice of intention to appear may be allowed to testify, as time permits, at the discretion have been suggested as being suitable in controlling exposure to toxic substances. Comment was requested on the appropriateness of utilizing respirators to control exposure when performing brief, intermittent tasks, during maintenance activities, and to achieve compliance with short-term exposure limits. Further. OSHA requested comment on: (l) Circumstances in which Notice of Intention to Appear All persons desiring to participate at the hearing must file in quadruplicate a notice of intention to appear, postmarked on or before April 18.1990. addressed to Mr. Tom Hall. OSHA Division of Consumer Affairs, Docket H-160, Room N-3647, U.S. Department of Labor. 200 Constitution Avenue NW., of the Administrative Law Judge. OSHA emphasizes that the hearing is open to the public, and that interested persons are welcome to attend. However, only persons who have filed proper Notices of Intention to Appear at the hearing will be entitled to ask questions and otherwise participate fully in the proceeding. cost effectiveness factors would be a Washington. DC 20210: telephone (202) Conduct and Nature of Hearing legitimate consideration in determining 523-6615. The notice of intention to the acceptability of one control method appear also may be transmitted by over another; (2) the appropriateness of . facsimile to (202) 523-5046 or (for FTS) allowing respirator use in lieu of to 8-523-5046, provided the original and feasible engineering controls in certain 4 copies of the notice are sent to the instances where the employer has above address therafter. submitted a comprehensive written The notices of intention to appear, respirator compliance program to the which will be available for inspection Agency; (3) whether reliable and and copying at the OSHA Technical predictable exposure control can be Data Center Docket Office, Room N- The hearing will commence at 9:30 a.m.. on May 30.1990. At that time, any procedural matters relating to the proceeding will be resolved. The informal nature of the rulemaking hearings to be held is established in the legislative history of section 6 of the Act and is reflected by the OSHA hearing regulations (see 29 CFR 1911.15(a). achieved if employers are allowed to establish a "respirator budget" to 2625. 200 Constitution Avenue NW., Washington, DC 20210, telephone (202) Although the presiding officer is an Administrative Law Judge and allocate a certain number of days per 523-7894. must contain the following questioning by interested persons is year or hours per day for employees to information: allowed on crucial issues, it is clear that wear respirators in lieu of implementing (1) The name, address, and telephone the proceeding shall remain informal feasible engineering controls; and (4) number of each person to appear: and legislative in type. The intent, in whether it would be acceptable to allow (2) The capacity in which the person essence, is to provide an opportunity for employers under any circumstances to will appear effective oral presentation by interested comply with exposure limits by any (3) The approximate amount of time persons which can be carried out method the employer deems advisable. requested for the presentation: expeditiously and in the absence of rigid OSHA is interested in receiving (4) The specific issues that will be procedures which might unduly impede testimony and data on the issues addressed; or protract the rulemaking process. mentioned above and on other issues relevant to the discussions set-forth in the proposal. In response to the proposed rule. OSHA has received 89 written comments from interested parties. These comments are available for inspection end copying in the OSHA Docket Office. Room N-2625. U.S. Department of Labor, 200 Constitution Avenue, NW.. Washington. DC 20210. In addition, OSHA received requests for a public Hearing from the American Iron and (5) A statement of the position that will be taken with respect to each issue addressed: and (6) Whether the party intends to submit documentary evidence, and if so, a brief summary of that evidence. Filing of Testimony and Evidence Before Hearing Any party requesting more than 10 minutes for a presentation at the hearing, or who will submit documentary evidence, must provide in The hearings will be conducted in accordance with 29 CFR part 1911. The hearing will be presided over by an Administrative Law Judge who will have all the powers necessary and appropriate to conduct a full and fair informal hearing as provided in 29 CFR part 1911 including the powers. (1) To regulate the course of the proceedings; (2) To dispose of procedural requests, objections and comparable matters; Steel Institute (Ex. 6-20),SPI quadruplicate the complete text of his (3) To confine the presentation to the Composites Institute (Ex. 6-22), and the testimony, including any documentary matters pertinent to the issues raised; United Steelworkers of America (Ex. 6- evidence to be presented at the hearing, (4) To regulate the conduct of those 73). to the OSHA Division of Consumer present at the hearing by appropriate Persons interested in participating in Affairs. This material must be means: the hearing should refer to the notice of proposed rulemaking on Methods of Compliance (54 FR 23991) for the text of the proposal and a more thorough postmarked by May 7,1990 and will be available for inspection and copying at the Technical Data Center Docket Office. Each such submission will be (5) In the Judge's discretion, to question and permit the questioning of any witness and to limit the time for questioning: and BOR 009020 8154 Federal Register / Vol. 55. No. 45 / Wednesday. March 7. 1990 / Proposed Rules (0) In the Judge's discretion, to keep the record open for a reasonable, stated time to receive written information and additional data, views, and arguments from any person who participated in the oral proceedings. Following the close of the hearing, the vessels give a 12-hour advance notice for passage through the drawbridge during peak traffic hours. The proposed changes to these regulations are, to the extent practical and feasible, intended to provide for regularly scheduled drawbridge openings to help reduce reasons for their comments. The Commander. Fifth Coast Guard District, will evaluate all communications received and determine a final course oT action on this supplemental proposal. This rule may be changed based on comments received. presiding Administrative Law Judge will motor vehicle traffic delays and certify the record of the hearing to the congestion on the roads and highways Drafting Information Assistant Secretary of Labor for linked by this drawbridge. The drafters of this notice are Linda L. Occupational Safety and Health. The OATES: Comments must be received on Ciiliam, project officer, end LT S. M. Administrative Law Judge does not or before April 23.1990. Fitten. project attorney. make or recommend any decisions as to the content of the final standard. The proposed standard will be reviewed m light of all testimony and written submissions received as part of the record and a standard will be issued based on the entire record of the proceeding, including the written comments and data received from the public. ADDRESSES: Comments should be mailed to Commander (ob). Fifth Coast Guard District, 431 Crawford Street. Portsmouth. Virginia 23704-5004. The comments and other materials referenced in ths notice will be available for inspection and copying at the above address, room 507, between 8 a.tn. and 4 p.m., Monday through Friday, except Federal holidays. Comments may Discussion of Proposed Regulations On June 14,19e9. Senator Stanley C. Walker requested.that the regulations for the drawbridge across the Eastern Branch of the Elizabeth River at mile 0 4 in Norfolk. Virginia, be amended to restrict openings during the peak highway traffic hours to help reduce traffic congestion, but remain open on Authority and Signature This document was prepared under the direction of Gerald F. Scannell, Assistant Secretary of Labor for Occupational Safety and Health, U.S. Department of Labor. 200 Constitution Avenue NW., Washington. DC 20210. It is issued under section 6(b) of the Occupational Safety and Health Act of 1970 (29 U.S.C. 655). Secretary of Labor's Order No. S-83 (48 FR 35736) and 29 CFR part 1911. Signed at Washington. DC on this 28th day of February. 1990. Gerard F. Scanosll, Assistant Secretary ofLabor. (FR Doc. 5077 Filed 3-6-90; 8:45 am( be hand-delivered to this address. FOR FURTHER INFORMATION CONTACT! Ann B. Deaton. Bridge Administrator. Fifth Coast Guard District at (604) 3986222. SUPPLEMENTARY INFORMATION: On October 17.1989. the Coast Guard published a proposed rule (54 FR 42517) to evaluate bridge opening restrictions during the morning and evening rush hours for the Berkley Bridge. The Commander, Fifth Coast Guard District also published the proposed rule as a public notice on October 6.1989. interested persons were given until December 1.1989, to comment on the proposed rule that was published in the Federal Register. The comment period signal during the rest of the time. The proposed change would have closed the Berkley Bridge to commercial, recreational, and public vessels Monday through Friday, except Federal holidays, from 5:30 a.m. to 9 a.m,, and from 3:30 p.m. to 6:30 p.m. A provision that allows the draw to open on signal at all times for vessels in distress was made a part of the proposal. This supplemental proposal includes the above with an . additional provision which provides commercial deep draft vessels with drafts of 22 feet or greater access through the bridge anytime provided they give a 12-hour advance notice of their arrival during the morning and evening rush hours. BILLING CODS 4510-W-N for the public notice ended November 9, As a result of the proposed rule that 1989. An amendment to the public notice was published in the Federal Register DEPARTMENT OF TRANSPORTATION was issued November 6,1989. extending (54 FR 42517) and the public notice the comment period to December 1. issued on October6.1989. written Coast Guard 1989, to coincide with the comment comments were received from the period published in the Federal Register. maritime community and the motoring 33 CFR Part 117 ICGD5-90-0031 This supplementary proposed rule exempts commercial vessels with drafts of 22 feet or greater from rush hour public. The comments from motorists were all in favor of the proposed restrictions during peak traffic hours Drawbridge Operation Regulations; Elizabeth River, Eastern Branch, Norfolk, VA restrictions provided Jiey give at least 12 hours advance notice for a bridge lift. Imposition of the 12-hour advance notice requirement will provide motorists with since elemination of draw openings during these hours should help reduce traffic disruption, delays, congestion and minor accidents. The comments from the agency: Coast Guard, DOT. an opportunity to learn about scheduled commercial marine industry were ACTION: Supplemental Notice of Proposed Rulemaking. summary: The Coast Guard is issuing a suplemcntal proposed rule for the operation of the Berkley drawbridge across the Eastern Branch of the Elizabeth River, mile 0.4. in Norfolk. Virginia, to allow commercial vessels with drafts 22 feet or greater passage through the bridge during the morning and evening rush hours. This supplemental proposed rule will include a requirement that these deep draft bridge openings by radio broadcasts and any other means established by the bridge owner. Public comments are requested on the deep draft vessel exemption provision and the 12-hour advance notice to ensure that this proposal is both reasonable and workable. Persons wishing to comment may do so by submitting written comments to the office listed under "addresses" in this preamble. Persons submitting comments should include their names and addresses, identify the bridge and give opposed to restricting the drawbridge based on such generalized factors as safety, economic impact concerns, and deep-draft vessel navigation requirements. The industry stated that restriction of deep draft vessels during the morning and evening rush hours would result in numerous days when vessels with drafts of 22 feet or greater would not be able to navigate through the bridge since these vessels require high tide to go upstream of the bridge due to the channel depth. The original proposal would have generally BOR 009021 A Division of The Society of The Plastics Industry, Inc. APR 0 2 1990 JCL March 26, 1990 TO: The VI Health, Safety & Environment Committee RE: OSHA Survey on Medical Surveillance and Exposure Assessment Program As the attached material from SPI notes, the Occupational Safety and Health Administration intends to initiate (perhaps as early as mid-April), a survey of industrial programs for medical surveil lance, exposure monitoring and integrated process safety management systems. An advance copy of the general survey form is included in this material. Please feel free to pass this information on to the appropriate person in your company. I will keep you apprised of any follow-up planned by SPI related to this issue. Sincerely yours. MNS/pmb cc: P. Stapleton, SPI Meredith N. Scheck Assistant Director Wayne Interchange Plaza II IS5 Route 46 West Wayne, NJ 07470 (201)890-9299 Fax # (201) 890-7029 BOR 009022 The Society of the Plastics industry, Inc. 1275 K Street, N.W., Suite 400 Washington, D.G 20005 (202) 371-5200 FAX 371-1022 MftR TO: FROM: OHEIC Steeling. Committee Phil Stapleton^-'Assistant Technical Director, Issues Analysis RE: DATE: Upcoming OSHA Survey on Medical Surveillance and Exposure Assessment Programs March 21, 1990 As noted in the Federal Register on February 23 (55 FR 6491), OSHA intends to conduct a large-scale survey of industrial programs for medical surveillance, exposure assessment, and integrated process safety management systems. If expedited OMB approval of this survey is granted, OSHA plans to initiate telephone surveys by midApril. As you may recall, OSHA announced in November 1989 that it planned to propose generic standards for medical surveillance. The voluntary survey is intended to collect the data needed to evaluate compliance costs associated with possible generic standards for medical surveillance, exposure assessment and integrated process safety systems. A copy of the survey form is attached. As you can see, the survey requests information on the following topics: types of chemicals used on-site, their annual usage, number of employees exposed, and how many of these employees are covered by medical surveillance programs. medical surveillance programs - frequency and extent of examinations, how the program is implemented, how the information is used, etc. exposure monitoring - extent of coverage, types of substances/hazards covered, how the information is used etc. integrated process safety management systems - use of pre-startup safety reviews, written operating procedures, safety inspections, equipment testing and maintenance, and personal protective equipment. In addition to these topics, the survey also requests information on hazard communication and training programs, and recent injury and illness records. BOR 009023 OHEIC Steering Committee March 21, 1990 Page Two It would appear that OSHA is poised to significantly increase its use of generic standards to supplement more stringent exposure limits for hazardous substances and other safety requirements. We may want to collect information (independent of OSHA' survey) on the use of medical surveillance, exposure assessment and integrated process safety management systems within the plastics industry so that we can accurately estimate the potential costs of implementing such programs. If you have any questions or comments please let me know. PJS/rc Attachment cc: Pat Toner - SPI Lew Freeman - SPI Richard LaLumondier - SPI Maureen Healey - SPI John Dubeck - Keller & Heckman Bor 009024 February 2, 1990 Name Company Address city, state OMB Approval No. xxxx SIC Code xxxx OSHA Contact: Kristine Leininger (202) 523-7177 Dear The Occupational safety and Health Administration (OSHA) is considering the development of generic standards to address medical surveillance and exposure monitoring programs. OSHA is also developing regulations on integrated safety management methods for process-related hazards, including fire and explosion risks, injuries due to ergonomic factors, and other contributors to workplace injuries and illnesses. OSHA believes such regulations could significantly improve workplace safety and health as well as enhance the effectiveness of existing regulations. OSHA is conducting a voluntary telephone survey as part of this regulatory effort to determine the extent to which medical surveillance, exposure monitoring, and process safety management are currently done in industry. Your firm has been selected to participate in this survey, and an interviewer will be calling y u within the next few weeks. A copy of the survey instrument is attached. Information and cooperation from your firm will help OSHA develop the most practical and effective standard possible. To insure confidentiality, the survey information will be stored in a data base that will not permit individual firms or their responses to be identified. The survey covers the following areas: medical surveillance programs, types of processes and operations, chemicals used, exposure assessment procedures including monitoring programs, hazard communication, engineering review of process and equipment safety, maintenance practices, employee training, assessments of ergonomics and other hazards, and recent injury and illness experience. We would appreciate your forwarding this letter to the person or persons in your organization best suited to respond t the survey. BOR 009025 We are required by the office of Management and Budget to inform you that the public reporting burden for this collection of information is estimated to average 60 minutes per respondent, including the time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information. If you have comments regarding this burden estimate or any other aspect of this collection of information, including suggestions for reducing this burden, please send them to both the Office of Information Management, Department of Labor, Room N1301, 200 constitution Ave., N.W., Washington, DC 20210 and the Office of Information and Regulatory Affairs, Office of Management and Budget, Washington, DC 20503. We look forward to talking to your firm about these issues. Sincerely, Gerard F. Scannell Assistant Secretary for OSHA BOR 009026 Medical Surveillanc Survey, OSHA [INTERVIEWER INSTRUCTIONS: RECORD THE FOLLOWING INFORMATION] Interviewer Number Cell category Size Code (1-4) Sequence Number (max. 600) Call Record SIC Number of Employees [Reenter Sequence #] [Reenter SIC] INTRODUCTION Hello. My name is and I'm calling from KCA Research in Alexandria, Virginia, we are conducting a survey on behalf of tne Occupational Safety and Health Administration (OSHA) of the U.S. Department of Labor to assess the current practices in industry in the use of Medical Surveillance, Exposure Assessment, Process Safety Management and Ergonomic programs. A letter was sent to your facility informing you of this survey. As the letter indicated, we are interested in understanding the extent of health and safety programs in industry. We would like to emphasize that all responses will be kept strictly confidential. Respondents will not be identified by name in any reports or data compilations submitted to OSHA. We are interested in collecting information about your firm at address^. Should I direct my questions to you, or is there someone else in the facility with whom you would prefer I speak? 1. Our records show your firm to be in SIC code XXXX, which is . Is this correct? a. yes b. no c. don't know d. refused if "a", go to Q4. How would you describe your line of business? a. .... lrecord verbatim} b. don't know c. refused Do you happen to know what that SIC code is? a. enter SIC b. don't know c. refused OR 009027 Are you a publicly owned company? a. yes b. no c. don't know d. refused If "a", only continue if in an OSHA state-plan state, otherwise, terminate. In total, how many employees work at your establishment? a. (record verbatim) (If zero or refused, terminate) I'd like you to divide the employees at your establishment into four broad groups for me. The first group called administrative employees will be those who perform only administrative, managerial, clerical, sales, or similar functions. The second group called production employees would be those who have at least some responsibility for producing the goods or providing the service of your establishment. Included in this group will be custodial employees. The third group called laboratory employees would be those who work in laboratories, including those that perform quality control, R&D, or various testing activities for your company. The fourth group called maintenance employee would be those that perform non-custodial maintenance and repair activities. Do not include contract workers. How many employees are: (record all that apply) a. administrative employees b. production employees c. laboratory employees d. maintenance employees Record number Record number Record number Record number 7. Are contract workers used in this facility? a. yes b. no c. don't know d. refused If "b, c or d", go to Q9, 8. Which work is performed by contract workers? (record all that apply) a. production b. non-janitorial maintenance c. clean-up maintenance d. laboratory e. pickup/delivery f. other ____________ (record verbatim) g. don't know h. refused Bor 009028 9. I'm going to read a list of chemicals that many firms engaged in your line of business often use. I'd like you to tell me which# if any, of these chemicals are used at your location, how many employees are exposed, how much of each one you use in a year, and whether you perform medical surveillance for the chemicals. The term "medical surveillance" refers to the practice of providing physical examinations and medical tests to employees for the purpose of detecting the presence of injuries or illnesses that might be related to work activities. Do you use? (SIC-specific prompt list of o chemical will be provided. Administrative establishments in manufacturing SIC's will be prompted with a separate list.) CHEMICAL ____________ A B C D NUMBER OF EMPLOYEES EXPOSED ANNUAL USAGE MEDICAL fibs, or aals./year) SURVEILLANCE _________ _____ Limit chemical response to 4 chemicals. Respondent will be prompted with a list of chemicals which are ordered according to toxicity. If no chemicals are used at this facility, go to Q15. 10. Are there any other chemicals used that I did not mention? A B ------------- ------------- C ------------- ------------- D ------------- ------------- Limit chemical response to 4 chemicals. 11. Do you have more than 10,000 pounds (or 1,500 gallons) of any flammables stored in one location at your facility? a. yes b no c. don't know d. refused If "b, c, or d", go to Q15. 12. Does this consist only of hydrocarbons that are used on-site for fuel? a. yes no c. don't know d. refused If "a", go to Q15. BOR 009029 13. Does this includ only flammables stored or transferred on site only (i.e. not processed or sold)? a. yes b. no c. don't know d. refused 14. Are the flammable materials stored below their boiling point without the use of chilling or refrigeration? a. yes b. no c. don't know d. refused OVERALL PLANT QUESTIONS -ADMINISTRATIVE The following questions pertain to administrative actions for potential health and safety hazards. We would like to ask you some questions regarding medical surveillance practices. IS. Please tell me whether your facility has any of the* following exams available to employees. (record as many as apply) a. pre-employment examination b. routine periodic examination for employees exposed to hazardous chemicals c. routine periodic examinations for employees exposed to physical stresses (i.e. heat, repetitive motion) d. examinations for workers required to wear respirators e. routine examinations prior to termination of employment f. formal employee wellness program g. random drugtesting h. other ____________ (record verbatim) i. none j. don't know k. refused if "i, j, or k", go to Q29. BOR 009030 16. Do you perform the following examinations? For which employees? medical surveillanc (1) pre-employment (2) routine periodic a. all employees b. production employees only c. only those employees covered by OSHA requirements for medical surveillance d. other (record verbatim) e. don't know o f. refused 17. Please indicate which of the following tests are performed, the frequency of the tests performed and for whom. (record as many as apply) TYPE OF FREQUENCY EMPLOYEE a. general physical examination b. written medical and work history c. audiometric examination i. varies with age d. pulmonary function ii. every 3-5 years e. complete blood count iii. every 2 years f. serum chemistries iv. every year g- urinalysis V. other ___ (record) tl * chest x-ray Vi. don't know i. cholinesterase activity vii. refused j* musculoskeletal examinations k. other (record verbatim) 1. none m. don't know n. refused Are any of the workers at this facility required to wear respirators? a. yes b. no c. don't know d. refused if "b, c, or d", go to Q20. 19. Which of the following tests does your company give to workers who are required to wear respirators? (record all that apply) a. general physical examinations b. pulmonary function c. chest x-ray d. stress test e. other (record verbatim) f. don't know g. refused BOR 009031 20. Where is your company's medical surveillance- program conducted? a. on site b. off site c. both on and off site d. don't know If d, or e' go to Q22. e. refused 21. Who implements your company's medical surveillance program? a. certified occupational physician b. other licensed physician c. certified occupational nurse d. other registered nurse e. licensed practical nurse f. other (record verbatim) g. don't know h. refused 22. Does your company have a formal arrangement with any of the following outside sources to provide medical surveillance services? a. occupational health clinic b. other clinic, hospital, or HMO c. private physician d. mobile medical van service e. insurance carrier f. other ________ (record verbatim) g. none h. don't know i. refused 23. How long are the medical records retained? a. duration of employment b. duration plus X number of years {record wxw) c. other (record verbatim) d. don't know e. refused 24. Does your company systematically review the medical records each year? a. yes b. no c. don't know d. refused if "b, c, or d", go to Q26. BOR 009032 25. Are employee exposure assessments and monitoring data available to the individual conducting this review? a. yes b. no c. don't know d. refused 26. Do you use the medical surveillance results to implement or to change the following programs? (record all that apply) a. exposure monitoring b. training c. engineering controls d: personal protective equipment e. workstation analysis for ergonomic hazards f. other (record verbatim) g. don't know h. refused 27. Are employees notified of the results of their medical examination? a. yes b. no c. don't know d. refused 28. On average, how many hours is an employee away from work to take a medical examination? a. 1 hour b. 2 hours c. 3 hours d. other e. don't know f. refused (record verbatim) I would now like to ask you some questions concerning monitoring for potentially hazardous substances. 29. Do you have an exposure monitoring program? a. yes b.' no c. don't know d. refused If "b, c or d", go to Q41. BOR 009033 30. For which employee do you perform exposure monitoring? (record all that apply) a. administrative b. production c. laboratory d. maintenance e. other ________ (record verbatim) f. don't know g. refused 31. Which of the following types of potential hazards are covered under your exposure monitoring program? What percentage of your exposure monitoring is related to that hazard? (record all that apply) a. substance specific OSHA regulated substances, which include asbestos, benzene, formaldehyde, ethylene oxide, cotton dust, coke oven emissions, and lead. b. z-table chemicals c. other substances d. biological agents e. noise f. radiation g. other _______ (record verbatim) h. don't know i. refused 32. Who performs the exposure monitoring? a. company staff b. outside consultants c. insurance carriers d. other _______ (record verbatim) e. don't know f. refused 33. Does your facility perform any of the following monitoring techniques for substances that are easily absorbed through the skin? (1) surface wipe sampling (2) skin (gauze) patch sampling (3) biological monitoring (taking blood or urine samples to determine absorption) (4) other (record verbatim) a. yes b. no c. don't know d. refused If "a" for #2, continue. Otherwise go to Q35. BOR 009034 How many dermal (patch) sampl s wer coll cted' at this facility during the past year? For how many exposed workers? (record all that apply) a. number of samples b. number of exposed workers c. don't know d. refused __________ _____ For all types of monitoring do you use the implement or to change the following programs? (record all that apply) results to a. additional monitoring b. training c. engineering controls d. personal protective equipment e. medical surveillance f. other (record vferbatim) g. none h. don't know i. refused Do you compute any of the following statistics from your monitoring data? (record all that apply) a. average b. arithmetic standard deviation c. geometric mean d. geometric standard deviation e. maximum exposure observed f. other ________ (record verbatim) g. none h. don't know i. refused What percent of all monitoring samples result in overexposure? a. ___________ percent b. don't know c. refused If answer "a" is * 0 or b or c, go to Q39. How do you define overexposure? (record all that apply) a. > PEL b. < PEL but > 1/2 PEL c. > TLV d. > ceiling/excursion e. > STEL f. other (record verbatim) g. don11 know h. refused BOR 009035 39 . Does your company notify workers of their monitoring* results? a. yes b. no c. don't know d. refused 40. Are monitoring results communicated to contract employees? a. yes b. no c. don't know d. refused The following questions pertain to a company's procedure for assessing potential exposure to health, safety and stressor hazards. We will refer to this as' an exposure assessment. 41. Do you perform any of the following exposure assessment elements? (record as many as apply) a. workplace inventory of chemical agents b. workplace inventory of physical and biological agents and ergonomic stressors c. grouping of jobs by hazard for control or evaluation d. qualitative ranking of exposure risks. e. documentation of qualitative exposure assessment results f. development of quantitative exposure monitoring strategy or protocol g. exposure monitoring/sampling h. evaluation of monitoring results i. records of exposure assessment program j. reevaluation of exposure assessment based on new regulation, employee complaint or health effects data k. reevaluation of exposure assessment after changes in chemical used or changes in process l. reevaluation of exposure assessment based on seasonal changes m. other (record verbatim) n. none o. don't know p. refused If "n, o, or p", go to Q47. BOR 009036 42. For which employees do you perform an exposure assessment? (record all that apply) a. administrative b. production c. laboratory d. maintenance e. other _______ (record verbatim) f. none g. don't know h. refused 43. What percentage of your facility's workers are included in your exposure assessment program? (record all that apply) a. administration b. production c. laboratory d. maintenance Who performs this exposure assessment? a. company staff b. outside consultants c. insurance carriers d. other (record verbatim) e. don't know f. refused -- 45. Do you maintain records of the results of the exposure assessments that are performed at your facility? a. yes b. no c- don't know d. refused 46. Which of the following activities are initiated as a result of your exposure assessment program? (record all that apply) a. employee exposure monitoring b. medical surveillance c. use of personal protective equipment d. implementation of process change or engineering controls e. development of internal exposure guidelines f. toxicology testing g. other ________ (record verbatim) h. don't know i. refused BOR 009037 47. As a result of conducting a medical surveillance program or an exposure assessment program, including use of monitoring if applicable, has your company noticed any of the following changes? What is the estimated percent change? (record all that apply) a. reduction in illness by _____^ b. reduction in injuries by c. reduction in insurance costs by d. reduction in legal expenses by e. increased productivity by h. other (record verbatim) i. don't know j. refused 48. Do you have a hazard communication program in place for the following employees? (record all that apply) * a. administrative b. production c. laboratory d. maintenance e. other _______ (record verbatim) f. none If "f, g, or h", go to Q50. g. don't know h. refused 49. Which of the following is included as part of your hazard communication program? (record all that apply) a. overview of the standard b. hazards of routine and non-routine jobs c. use and location of MSDS d. explanation of labels e. health hazard evaluation of the chemicals produced or used f. protective equipment requirements g. other __________ (record verbatim) h. don't know i. refused 50. Do you have a formal emergency response plan in place? a. yes b. no c. don't know d. refused BOR 009038 51. Docs your facility have a written safety program? &. yes b. no c. don't know If "b, c or d" go to Q59. d. refused 52. Which of the following is included in the safety program? (record all that apply) a. material hazards information b. lockout/tagout procedures c. hot work procedures d. personal protective equipment use e. remedial action for exposures f. confined space entry procedures g. special procedures for opening process equipment and piping h. other (record verbatim) i. don't know j. refused 53. How are safety rules communicated to employees? (record all that apply) a. written b. oral c. classroom training d. on-the-job training e. informally f. other (record verbatim) g. not communicated h. don't know i. refused 54. Who enforces the safety rules? (record all that apply) a. supervisor b. safety director c. safety committee d. labor agreement e. other ________ (record verbatim) f. no one g. don't know h. refused 55. Is there a safety committee? a. yes b. no c. don't know d. refused If "b, c, or d" go to Q58. BOR 009039 56. Does the safety committee have representatives from: (check all that apply) a. labor b. management c. other ________ (record verbatim) d. don't know e* refused 57. Has your company noticed any of the following changes as a result of implementing a written safety program? What is the estimated percent change? (record all that apply) a. reduction in illness by _______ b. reduction in injuries by c. reduction in insurance costs by d. reduction in legal expenses by e. increased productivity by _ h. other (record verbatim) i. dont know j. refused 58. Do you issue hot work permits at your facility? a. yes b. no c. don't know d. refused If "b, c or d" go to Q60. * * 59. How many permits do you issue annually? a. ________ per month b. don't know c. refused BOR 009040 -ENGINEERING RELATED We would now like to ask you questions concerning engineeringrelated procedures to correct or control safety and health hazards. 60. For the following types of process situations, do you perform a pre-startup safety review? (record all that apply) a. for new processes? b. for modified processes where only procedures or methods of operation have changed c. for modified processes where process equipment has been changed. d. other __________ (record verbatim) e. none f. don't know g. refused If "e, f, or g", go to Q65. 61. Does the pre-startup safety review check that: (record all that apply) construction meets the specifications safety, operating and maintenance procedures are-adequate and in place the prerequisites for startup are completed training of operator is complete other __________ (record verbatim) don't know refused 62. Does your facility have written procedures to address changes made with respect to: (record all that apply) a. the chemicals used in a process b. the technical information about a process c. the design of an existing piece of equipment or system d. other ________ (record verbatim) e. none f. don't know g. refused If "e, f, or g", go to Q65. BOR 009041 63. Which of the following does the written procedure address? (record all that apply) a. the technical basis for the change b. the impact on safety and health c. modifications to operating procedures d. requirements for authorizing the change to be made e. other ________ (record verbatim) f. don't know g. refused 64. How do you inform workers of procedural changes either to the process they perform or the equipment they operate? a. written b. oral c. classroom training d. on-the-job training e. other ______ (record verbatim) f. none g. don*1 know h. refused 65. How often are facility safety inspections conducted? a. daily b. weekly c. monthly d. other ________ (record verbatim) e. never f. don't know g. refused -WORK PRACTICE RELATED 66. Do you have any personnel whose sole or primary duty is to inspect and test equipment? a. yes b. no c. don't know d. refused Bor 009042 67. Do you use maintenance workers to do the following? . (record all that apply) a. routine maintenance b. repair of breakdowns c. inspection and testing d. maintenance support e. specific projects f. turnaround (cleanup, etc.) g. other ________ (record verbatim) h. don't know i. refused 68. Are operators expected to perform routine maintenance on their equipment? a. yes b. no c. don11 know d- refused --PPE 69. Are workers required to use personal protective equipment at your facility? a. yes b. no c. don't know d. refused If "b, c, or d", go to Q72. 70. Is there a written policy addressing the selection, use and limitations, decontamination, maintenance, and storage of the personal protective equipment? a. yes b. no c. don't know d. refused 71. Have all employees who are required to wear personal protective equipment been trained upon initial assignment, biennially, and after a major job or process change? a. yes b. no c. don't know d. refused BOR 009043 TRAINING 72. Is it company policy to train workers in the operating procedures of the process they work with or perform? a. yes b. no c. don't know d. refused If "b, c, or d" go to Q80. 73. What types of workers receive this training? (check all that apply) a. all employees b. all production employees (including supervisors) c. new employees d. production workers assigned to a process unit or work activity where they have not previously worked. e. contract employees f. maintenance employees g. other (record verbatim) h. don't know i. refused 74. Does training for non-contract employees address the following topics? (record all that apply) a. potential hazards of the process b. procedures and safe practices applicable to the process c. emergency response d. proper use of personal protective equipment e. general safety rules of the facility f. changes to the process they work with g. other (record verbatim) h. don't know i. refused 75. Do contract, employees receive a briefing (or short training session) which addresses the following topics? (only ask if answered "e" in Q73.) (record all that apply) a. potential hazards of the process b. procedures and safe practices applicable to the process c. emergency response d. general safety rules of the facility e. other (record f. don't know verbatim) g. refused BOR 009044 76. HOW often are training sessions scheduled? a. monthly b. as needed If "a" go to Q78. c. new hires d. other (record verbatim) e. don't know f. refused 77. How many training sessions are given each year? a. number of sessions b. don't know c. refused 78. Typically, how many people attend a training session? 9l * number of workers b. number of trainers c. don't know d. refused 79. How long does each training session last? a. hours (or fraction thereof) b. don't know c. refused - PROCESS ORIENTED 80. OSHA has constructed a breakdown of processes that might b analyzed separately during a hazard analysis. I'm going to read a list of processes that many firms engaged in your type of business often have. I'd like you to tell me which, if any, of these processes are present at your facility. Also, if your company groups these processes for hazard analysis purposes, please give me your list. Do you have a ? (SIC-specific prompt list of processes will be provided).1 2 3 (1) process a (2) process b (3) process c (etc.) 81. Are there any other processes present that I did not mention? (1) process a (2) process b (3) process c (etc.) BOR 009045 Now I am going to ask questions about elements related to the processes you mentioned. (Certain processes will prompt certain questions or parts of a question.) 82. Do you have a set procedure for compiling technical information on individual processes? a. yes b. no c. don't know d. refused If "b, c, or d", go to Q90. 83. Have you compiled any of the following types of information for individu-1 processes? (record all that apply) a. process flow diagram b. process chemistry c. maximum intended inventory of hazardous chemicals d. safe upper and lower limits for operating procedures e. safety and health results of operating outside these limits f. equipment design information g. written operating procedures h. other (record verbatim) i. none j. don11 know k. refused 84. Which of the following are addressed inyour procedures for individual processes? operating a. temporary operations b. emergency operations including emergencyshutdown c. start-up following downtime d. safety equipment available for use with this process e. the function of that safety equipment f. measures to be taken if physical contact or airborne exposure occurs g. other special or unique hazards associated with this process h. other (record verbatim) i. don11 know j. refused BOR 009046 85. Does someone review the operating procedures for agreement with the following? (1) hazardous chemical information for this process (2) technical design information for this process (3) equipment design information for this process a. yes b. no c. don't know d. refused 86. Have the employees working with a process unit received training in operating procedures specific to the process unit? a. yes b. no c. don't know d. refused 87. How much time is spent in initially training each employee in operating procedures? a. _____________ (record verbatim) b. don ' t know c. refused 88. Are formal inspections and tests of critical equipment in each process conducted periodically? a. yes b. no c. don't know d. refused If "b, c or d", go to Q90. 89. How many days of work (man-days) are spent on inspecting and testing critical equipment each month? a. ___________ (record verbatim) b. don't know c. refused 90. When changes are made in the technology of an operation, is the compiled information updated to reflect the change? a. yes b* no c. don't know d. refused if "b, c or d", go to Q92. BOH 009047 91. Are employees informed of such changes? a. yes b. no c. don't know d. refused PROCESS LOOP Now, I would like to ask you questions for each of the processes you mentioned earlier. 92. How many workers at this locution participate in "process a"? a. _____________ workers (record verbatim) b. don't know c. refused 93. How many processes of this type do you have? a. _____________ (record verbatim) b. don't know c. refused 94. Does this process have any of the following engineering controls? (record all that apply) a. general ventilation b. local exhaust ventilation c. laboratory exhaust ventilation d. noise reduction control e. enclosure f. other _________ (record verbatim) g. none h. don't know i. refused 95. Have you performed any of the following hazard analyses of this process? If yes, for which employees? (record all that apply) (1) ergonomic analysis (2) exposure analysis a. administrative b. production (3) fire, explosion prevention (4) spills prevention (5) other (record verbatim) (6) none c. laboratory d. maintenance (7) don't know (8) refused If did not answer "(1)", go to Q99 If answered "(6) , (7), or (8)", go to Q104 BOR 009048 96. Which of the following elements is included in your ergonomic analysis? (record all that apply) a* analyzing injury and illness records for evidence of cumulative trauma disorders b. cataloging work content c. analyzing work content with respect to potential biomechanical risk factors for cumulative trauma disorders d. measuring and documenting time required to perform each work task e. analyzing production records f. video taping jobs g. developing check-lists to identify undesirable worksite conditions or worker activities that contribute to cumulative trauma disorders h. developing study of the work environment i. other (record' verbatim) j. dont know k. refused 97. What actions have you taken resulting from the information generated by the ergonomic analysis? a. redesign work methods b. redesign workstation c. substitution of tools d. other (record verbatim) e. don't know f. refused 98. Have you noticed any reduction in absenteeism, turnover or insurance claims as a result of these ergonomic changes? a. yes b. no c. don't know d. refused 99. Who performs the hazard analysis (ergonomics, exposure, fire or explosion, or spills)? a. in-house staff b. outside consultants c. combination of both d. other (record verbatim) e. don't know f. refused BOH 009049 100. Are writt n reports prepared for each hazard analysis that is performed? a. yes b. no c. -don't know d. refused 101. Which of the following does this analysis include? (record all that apply) a. a description of the results b. a list of recommendations c. the actions taken as a result of the hazard analysis d. other (record verbatim) e. don't know f. refused 102. How many days of work (man-days) are required to perform the hazard analysis, including providing a written report? a. _____________ (record verbatim) b. don't know c. refused 103. Are hazard analyses performed on process units before they ar started or restarted? a. yes b. no c. don't know d. refused 104. What type and number of air samples were collected during the calendar year for how many exposed workers? Personal a. full shift b. short-term c. peak # of samples * of exposed workers General area d. full shift e. short-term f. peak END OF LOOP BOR 009050 105. Did your establishment have any lost time occupational injuries or illnesses recordable on OSHA Form 200 during 1988 and 1989? a. yes b. no c. don't know d. refused If "a", request copies of the OSHA 200 log and any supplemental forms they may have. Give address* bor 009051