Information,Training & Communicating Hazards to Employees | ASBESTOS

Communicating Hazards to Employees

Employers and building owners are required to treat installed thermal system insulation (TSI) and sprayed on and troweled-on surfacing materials as asbestos containing material (ACM). Treat asphalt and vinyl flooring material installed no later than 1980 as asbestos-containing.

Employers and building and facility owners must exercise due diligence in complying with requirements to inform employers and employees about the presence and location of ACM and presumed asbestos containing material (PACM).

Building Owner Responsibilities

Building and facility owners have to maintain records of all information required concerning the presence, location and quantity of ACM and PACM in the building/facility. Such records need to be kept for the duration of ownership and must be transferred to successive owners.

Building and facility owners have to inform employers of employees with potential exposure risks. Those employers must inform their employees who will perform housekeeping activities in areas which contain ACM and/or PACM of the presence and location of ACM and PACM in these areas. Identification of ACM and PACM should be made by industrial hygienists, or by persons whose skill and experience in identifying asbestos hazards is the equivalent to that of industrial hygienists.

Information and Training

All employees who are exposed to airborne concentrations of asbestos at or above the action level must be properly trained about asbestos hazards. Training has to be provided prior to or at the time of initial assignment, and at least yearly thereafter.

Training Program Elements

An effective training program must provide employees with information about the health hazards of asbestos exposures and include the following elements:

• Relationship between asbestos and smoking in producing lung cancer;
• Operations which could result in asbestos exposure;
• Engineering controls and appropriate work practices associated with the employee's job assignment;
• Purpose, proper use, and limitations of respirators and protective clothing;
• Medical surveillance program;
• Emergency and clean-up procedures;
• Names, addresses, and phone numbers of public health organizations which provide information, materials, and/or conduct programs concerning smoking cessation; and
• A review of the procedures contained in OSHA's asbestos standard at §1910.1001.

All training materials must be available to the employee without cost and, upon request, to OSHA and NIOSH representatives.

Control the Hazards | Ergonomics

Risk factors can be controlled either during the development stages of a product or process or after work has begun. In the development stages, very effective controls can be achieved (proactively) for a small investment. Once production has begun, changes can still be implemented (retrofit changes) but usually require modifications to existing equipment. Retrofit changes also require workers to change work patterns. Implementing a change after habits have been formed requires that the need, the objective, the time frame, and the consequences of the change be communicated. One way to ensure this communication is through employee involvement.

After risk factors and their causes have been identified, either in development or after implementation, the next step is to identify control measures that reduce or eliminate the presence of these factors. Traditional classification of control measures distinguishes between engineering controls and administrative controls. Opportunities for both types of controls differ depending on whether the job or process is new or existing.

A three-tier hierarchy of controls is widely accepted as an intervention strategy for controlling workplace hazards, including ergonomic hazards. These procedures should be evaluated when determining how to correct or control your ergonomic hazards:

• Engineering controls to reduce or eliminate potentially hazardous conditions (e.g., work station, tool, and equipment design or redesign).

• Administrative controls, usually changes in work practices and management policies (e.g., worker rotation, reduced production demand, and increased rest breaks).

• Personal protective equipment

The Inspection Process | OSHA Inspection

After the opening conference, the compliance officer and accompanying representatives proceed through the establishment to inspect work areas for safety or health hazards.

The route and duration of the inspection are determined by the compliance officer. During the inspection, the officer will:

• Observe safety and health conditions and practices,

• Consult with employees,

• Take photos and instrument readings,

• Examine records,

• Collect air samples,

• Measure noise levels,

• Survey existing engineering controls, and

• Monitor employee exposure to toxic fumes, gases and dusts.

Trade Secrets

Trade secrets observed by the compliance officer will be kept confidential. An inspector who releases confidential information without authorization is subject to a $1,000 fine and/or one year in jail. The employer may require that the employee representative have confidential clearance for any area in question.

Consulting with Employees

Employees are consulted during the inspection tour. The compliance officer may stop and question workers, in private, about safety and health conditions and practices in their workplaces. While talking with employees, the compliance officer makes every effort to minimize any work interruptions. Each employee is protected, under the OSH Act, from discrimination for exercising his or her safety and health rights.

Recordkeeping

OSHA places special importance on posting and recordkeeping. The compliance officer will inspect records of deaths, injuries, and illnesses which the employer is required to keep. The officer will check to see that a copy of the totals from the last page of OSHA 200 Log or the OSHA 300A Summary have been posted and that the OSHA 2203 or OSHA 3165 workplace poster is prominently displayed. Where records of employee exposure to toxic substances and harmful physical agents have been required, they are also examined for compliance with the recordkeeping requirements.

The compliance officer also explains that while the following items are not required for all OSHA standards they should be recorded to accurately monitor and assess occupational hazards.

Initial and periodic monitoring for operations involving exposure, including:

• Date of measurement;

• Sampling and analytical methods used and evidence of their accuracy;

• Number, duration, and results of samples taken;

• Type of respiratory protective devices worn; and

• Name, social security number, and the results of all employee exposure measurements.

This record should be kept for 30 years.

Employee physical/medical examinations, including:

• Name and social security number of the employee;

• Physician's written opinions;

• Any employee medical complaints related to exposure to toxic substances; and

• Information provided to the examining physician.

These records should be maintained for the duration of employment plus 30 years.

Employee training records should be kept for one year beyond the last date of employment of that employee.

Communicating Hazards

The compliance officer also explains the requirements of the Hazard Communication Standard which requires employers to establish a written, comprehensive hazard communication program covering provisions for container labeling, material safety data sheets, and an employee training program. The program must contain a list of the hazardous chemicals in each work area and the means the employer will use to inform employees of the hazards of non-routine tasks.

Unsafe Workplace Conditions

During the course of the inspection, the compliance officer will point out to the employer any unsafe or unhealthful working conditions observed. At the same time, the compliance officer will discuss possible corrective action if the employer so desires.

Some apparent violations detected by the compliance officer can be corrected immediately. When they are corrected on the spot, the compliance officer records such corrections to help in judging the employer's good faith in compliance. Even though corrected, however, the apparent violations may still serve as the basis for a citation and, if appropriate, a notice of proposed penalty.

An inspection tour may cover part or all of an establishment, even if the inspection resulted from a specific complaint, fatality or catastrophe