Hazard Assessment and Employee Training §1910.132 (d), (e), (f)

In April of 1994 OSHA issued a rule updating the PPE standard to reflect current technology and improvements in personal protective equipment and to add provisions requiring employers to assess their workplaces for hazards and train their employees in the use of the protective equipment. OSHA estimates that the new standard will provide improved protection in 1.1 million work establishments covering 11.7 million employees. Upgrades in eye, face, head, foot and new hand requirements became effective July 5, 1994 and hazard assessment and training requirements on October 5, 1994. Guidance in conducting a hazard assessment of the workplace and selecting personal protective equipment is also provided.

The workplace must be assessed to determine if hazards are present which necessitate the use of PPE. The employer must verify that the assessment has been completed through a written certification which identifies the workplace, the person certifying that the evaluation has been performed, the date of the assessment, and a statement which identifies the document as certification of hazard assessment. If it is determined that such hazards are present, the employer must select protective equipment for the employees and communicate the selection decisions to them.

Hazard Assessment

PPE devices alone should not be relied on to provide protection against hazards, but should be used in conjunction with guards, engineering controls, and sound manufacturing practices.

It is necessary to consider certain general guidelines for assessing the foot, head, eye and face, and hand hazard 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 appropriate expertise to accomplish these tasks.

Assessment Guidelines

The employer must conduct a walk-through survey of the areas in question to identify sources of hazards to workers. These hazardous situations may include sources of motion; sources of high temperatures; types of chemical exposures; sources of harmful dust or light radiation; sources of falling objects or potential for dropping objects; sources of sharp objects which might pierce the feet or cut the hands and rolling or pinching objects which could crush the feet; the layout of workplace and location of co-workers; and any electrical hazards.

Following the walk-through survey, it is necessary to organize the data to prepare an analysis of the hazards to enable proper selection of protective equipment. The employer should analyze the data on the workplace and estimate the potential for injuries. Each of the basic hazards should be 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.

Selection Guidelines

After completion of the hazard assessment, the general procedure for selection of protective equipment is to:

1. Become familiar with the potential hazards and the type of protective equipment that is available, and what it can do;
2. Compare the hazards associated with the environment;
3. Select the protective equipment which ensures a level of protection greater than the minimum required to protect employees from the hazards;
4. Fit the user with the protective device and give instructions on care and use of the PPE. It is very important that the users be made aware of all warning labels for and limitations of their PPE.

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 and protective devices are generally available in a variety of sizes.

Adjustments should be made on an individual basis for a comfortable fit that will maintain the protective device in the proper position. Particular care should be taken in fitting devices for eye protection against dust and chemical splashes. In addition, proper fitting of helmets is important to ensure that it will not fall off during work operations.

It is the responsibility of the employer or safety officer to reassess the workplace hazard situation as necessary, to identify and evaluate new equipment and processes, to review accident records, and reevaluate the suitability of previously selected PPE.

Employee Training

Employers must provide training for each employee who is required to use personal protective equipment. Training should include when PPE is necessary; what PPE is necessary; how to wear PPE; its limitations; the proper care, maintenance, useful life, and disposal of the PPE. Employees must demonstrate an understanding of the training and the ability to use the PPE properly before being allowed to perform work requiring the use of the equipment.

If an employer has reason to believe an employee does not have the understanding or skill required, the employer must retrain. Circumstances where retraining may be required include changes in the workplace or changes in the types of PPE to be used which would render previous training obsolete. Also, inadequacies in an affected employee's knowledge or use of the assigned PPE which indicates that the employee has not retained the necessary understanding or skills. Employers must certify in writing that the employee has received and understands the training.

Cleaning and Maintenance

It is important that all PPE be kept clean and properly maintained. Cleaning is particularly important for eye and face protection where dirty or fogged lenses could impair vision. 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 contaminated PPE which cannot be decontaminated is disposed of in a manner that protects employees from exposure to hazards.

Uncontrolled Hazardous Energy Case Studies

Workers may be exposed to hazardous energy in several forms and combinations during installation, maintenance, service, or repair work. A comprehensive hazardous energy control program should address all forms of hazardous energy:

• Kinetic (mechanical) energy in the moving parts of mechanical systems.
• Potential energy stored in pressure vessels, gas tanks, hydraulic or pneumatic systems, and springs (potential energy can be released as hazardous kinetic energy).
• Electrical energy from generated electrical power, static sources, or electrical storage devices (such as batteries or capacitors).
• Thermal energy (high or low temperature) resulting from mechanical work, radiation, chemical reaction, or electrical resistance.

Case Studies

Between 1982 and 1997, The National Institute for Occupational Safety and Health (NIOSH) investigated 152 fatal incidents in which workers contacted uncontrolled hazardous energy. The following case reports summarize five of these investigations.

1. Uncontrolled Kinetic Energy

A 25-year-old male worker at a concrete pipe manufacturing facility died from injuries he received while cleaning a ribbon-type concrete mixer. The victim's daily tasks included cleaning out the concrete mixer at the end of the shift. The clean-out procedure was to shut off the power at the breaker panel (approximately 35 feet from the mixer), push the toggle switch by the mixer to make sure that the power was off, and then enter the mixer to clean it.

No one witnessed the event, but investigators concluded that the mixer operator had shut off the main breaker and then made a telephone call instead of following the normal procedure for checking the mixer before anyone entered it. The victim did not know that the operator had de-energized the mixer at the breaker. Thinking he was turning the mixer off, he activated the breaker switch and energized the mixer. The victim then entered the mixer and began cleaning without first pushing the toggle switch to make sure that the equipment was deenergized. The mixer operator returned from making his telephone call and pushed the toggle switch to check that the mixer was deenergized. The mixer started, and the operator heard the victim scream. He went immediately to the main breaker panel and shut off the mixer.

Within 30 minutes, the emergency medical service (EMS) transported the victim to a local hospital and then to a local trauma center. He died approximately 4 hours later [NIOSH 1995].

2. Uncontrolled Electrical Energy

A 53-year-old journeyman wireman was electrocuted when he contacted two energized, 6.9-kilovolt buss terminals. The victim and two coworkers (all contract employees) were installing electrical components of a sulfur dioxide emission control system in a 14-compartment switch house.

The circuit breaker protecting the internal buss (a conducting bar, rod, or tube that carries heavy currents to supply several electric circuits) within the switch house had been tripped out and marked with a tag — but it had not been secured by locking. This procedure was consistent with the hazardous energy control procedures of the power plant.

The victim and his coworkers were wiping down the individual compartments before a pre-startup inspection by power plant personnel. Without the knowledge of the victim and his coworkers, power plant personnel had energized the internal buss in the switch house. When the victim began to wipe down one of the compartments at the south end of the switch house, he contacted the A-phase buss terminal with his right hand and the C-phase buss terminal with his left hand. This act completed a path between phases, and the victim was electrocuted.

A coworker walking past the victim during the incident was blown backward by the arcing and received first-degree flash burns on his face and neck. A second coworker at the north end of the switch house heard the explosion and came to help. He notified the contractor's safety coordinator by radio and requested EMS. The EMS responded in about 15 minutes and transported the victim to a local hospital emergency room where he was pronounced dead [NIOSH 1994].

3. Uncontrolled Kinetic Energy

A 38-year-old worker at a county sanitary landfill died after falling into a large trash compactor used to bale cardboard for recycling. The cardboard was lifted 20 feet by a belt conveyor and fed through a 20- by 44-inch opening into a hopper. The hopper had automatic controls that activated the baler when enough material collected in the baling chamber. When the baler was activated, material in the chamber was compressed by a ram that entered the chamber from the side. Excess material above the chamber was trimmed by a shearer.

On the day of the incident, cardboard jammed at the conveyor discharge opening. Without stopping, deenergizing, or locking out the equipment, the victim rode the conveyor up to the discharge opening to clear the jam. He fell into the hopper and the baling cycle was automatically activated, amputating his legs. The victim bled to death before he could be removed from the machine [Colorado Department of Public Health and Environment 1994].

4. Uncontrolled Potential Energy

The 32-year-old owner of a heavy equipment maintenance business died after a wheel and tire assembly exploded during repair work. The victim was removing the assembly from a test roller when it exploded and struck him with the flying split rim of the wheel.

The test roller was a large, two-wheeled cart that carried about 60,000 pounds of concrete weights. The roller was used in highway construction to test road surfaces for proper compaction.

The victim had been working as a subcontractor to repair the wheel and tire assembly, which had been smoking earlier in the day and was believed to be rubbing against the concrete weights. The assembly consisted of a two-piece outside rim and an inside ring retainer that was held together and mounted on the axle by 20 wheel bolts and nuts. Normal air pressure for the mounted tire was 70 psi.

The victim raised and blocked the roller. Without discharging the air from the tire and using no personal protective equipment, he began to remove the wheel nuts using a pneumatic impact wrench. He had no training or experience with this type of work or in the servicing of this type of wheel. He did not realize that only some of the bolts held the wheel tire assembly to the axle. The remainder held the outer half of the rim to the inside half, securing the tire to the wheel. As the victim removed the nineteenth wheel nut, the pressurized air in the tire discharged explosively, causing the split rim to fly off the wheel and strike him. He died from cerebral contusions and lacerations [Minnesota Department of Health 1992].

5. Uncontrolled Kinetic and Thermal Energy

A 33-year-old janitorial worker died after he was trapped inside a linen dryer at a hospital laundry while cleaning plastic debris from the inside of the dryer drum. The cleaning task (which usually took 15 minutes to an hour) involved propping open the door to the dryer with a piece of wood and entering the 4- by 8-foot dryer drum. The melted debris was removed by scraping and chiseling it with screwdrivers and chisels. The dryer was part of an automated system that delivered wet laundry from the washer through an overhead conveyor to the dryer, where it was dried during a 6-minute cycle with air temperatures of 217° to 230° F. The system control panel was equipped with an error light that was activated if the dryer door was open, indicating that the dryer was out of service.

On the night of the incident, the victim propped the door open and entered the dryer drum without deenergizing or locking out the dryer. He began to clean the inside of the drum. Although the error light had been activated when the door was propped open, the signal was misinterpreted by a coworker, who restarted the system. When the system was restarted, the overhead conveyor delivered a 200-pound load of wet laundryto the dryer — knocking out the wooden door prop, trapping the victim inside, and automatically starting the drying cycle. The victim remained trapped inside until the cycle was completed and was discovered when the load was discharged from the dryer. He died thirty minutes later of severe burns and blunt head trauma [Massachusetts Department of Public Health 1992].

Conclusions

Review of the NIOSH data indicates that three related factors contribute to injuries and deaths that occur when workers perform installation, maintenance, service, or repair work near hazardous energy sources:

• Failure to completely deenergize, isolate, block, and/or dissipate the hazardous energy source.
• Failure to lockout and tagout energy control devices and isolation points after the hazardous energy source has been deenergized.
• Failure to verify that the hazardous energy source was deenergized before beginning work.

These fatalities could have been prevented if comprehensive hazardous energy control procedures had been implemented and followed.

NIOSH recommends that employers implement the following steps to prevent injuries and deaths of workers who must work with hazardous energy in their jobs:

1. Comply with OSHA regulations.
2. Develop and implement a hazardous energy control program.
3. Identify and label all hazardous energy sources.
4. Deenergize, isolate, block, and/or dissipate all forms of hazardous energy before work begins.
5. Establish lockout/tagout programs that:
   • Require workers to secure energy control devices with their own individually assigned locks and keys — only one key for each lock the worker controls (Use of master keys should be reserved for unusual circumstances when the worker is absent from the workplace. However, if master keys are necessary, keep them under supervisory control. List the proper procedures for using them in the written program for controlling hazardous energy.);
   • Require that each lock used to secure an energy control device be clearly labeled with durable tags to identify the worker assigned to the lock;
   • Make sure that the worker who installs a lock is the one who removes it after all work has been completed; and
   • If work is not completed when the shift changes, workers arriving on shift should apply their locks before departing workers remove their locks.
6. Verify by test and/or observation that all energy sources are deenergized before work begins.
7. Inspect repair work before reactivating the equipment.
8. Make sure that all workers are clear of danger points before reenergizing the system.
9. Train all workers in the basic concepts of hazardous energy control.
10. Include a hazardous energy control program with any confined space entry program.
11. Encourage manufacturers to design machines and systems that make it easy to control hazardous energy.

Preparing a Written Hazard Communication Program

All workplaces where employees are exposed to hazardous chemicals are required to have a written plan describing how hazard communication will be carried out in that facility. Plan preparation is not just a paper exercise — all of the elements must be implemented in order to be in compliance with the rule. This is one of the most important aspects of your compliance program. It is also one of the first items that an OSHA compliance officer will examine to determine if your hazard communication program is adequate.

The irony is that the area that OSHA checks first is the one that the employer most frequently leaves for last. If your written program is not done, at least you are not alone. In a survey of New York State manufacturers, 75 percent did not have a written hazard communication program. A large percentage of the OSHA citations have been issued due to the lack of, or an inadequate, written program. In fact, deficiencies to the written hazard communication program requirement has topped the list of federal OSHA violations as the most cited standard for many years.

The plan does not have to be lengthy or complicated. It is intended to be a blueprint for implementation of your program — an assurance that all aspects of the requirements have been addressed. It serves to communicate to your employees and to OSHA exactly what you have done to comply with the HCS. In general, the written program must describe how the requirements for labels and other forms of warning, material safety data sheets, employee information, and training are going to be met in your facility.

Remember that the written program needs to reflect what you are doing in your workplace. If you use a generic program, it must be adapted to address the facility it covers. For example, the written plan must list the chemicals present at the site, indicate who is to be responsible for the various aspects of the program in your facility, and indicate where written materials will be made available to employees. Your written program must cover the following topics.

Hazard evaluation procedures

If you are a manufacturer responsible for developing MSDSs, you need to document how you made your hazard determination.

1.  Did you use the OSHA-designated lists?

2.  Did you examine the studies involving your chemical?

3.  Did you do any testing?

4.  Are you relying on the data on the MSDSs?

You will probably have used a combination of these four categories. Clearly indicate which chemicals you used which method on. Cite what studies were used for each chemical. The documentation here could be as simple as one sentence stating that you relied on the upstream information from chemical manufacturers that you purchased from. Indicate who is responsible for evaluating the chemicals and who developed the MSDSs.

Hazardous chemical inventory list

This is the inventory of chemicals for which you must have MSDSs. The list may be compiled for the workplace as a whole or for individual work areas. Remember to include any consumer products that you have determined are covered by the standard as well as any substances you may inadvertently produce, such as carbon monoxide. This list must be made available to employees, upon request.

You need only list the chemical name, but OSHA suggests that for your own use, you include all information that will assist in clearly identifying the substance in question, such as chemical name, common or trade name, manufacturer’s product name, and CAS number.

Labels and other forms of warning

Your written program should address the following points regarding labeling:

1.  Designate the person responsible for ensuring all in-plant containers are labeled;

2.  Designate the person responsible for ensuring all shipped containers are labeled;

3.  Describe any labeling system used, either on shipped containers or in-plant (include samples of labels used);

4.  Describe written alternatives to labeling of in-plant containers, if used (for example, putting the label information on batch tickets for stationary process tanks, using posters for air emissions);

5.  Procedures to review and update label information when necessary and to ensure that labels that fall off or become unreadable are immediately replaced;

6.  A copy of posters and other written materials used to inform employees about the HCS, or where the information is located.

Material safety data sheets (MSDS)

In addition to copies of the MSDSs, you should have complete documentation covering the following points:

1.  Designate the person responsible for obtaining/maintaining the MSDSs;

2.  Where the data sheets are kept in your facility and how employees can obtain access to them;

3.  The procedure to follow when an MSDS is not received at time of first shipment;

4.  A list of chemicals received without MSDSs and copies of request letters you have sent to manufacturer or supplier;

5.  If you generate MSDSs, the procedure for updating the MSDS when new and significant health information is found;

6.  A description of alternatives to actual data sheets used in the workplace, if any; and

7.  A copy of the MSDS format used (if your company had to generate any MSDSs).

Employee training

Be sure the following points are covered in your training program:

1.  Designate the person responsible for conducting training;

2.  List the criteria used to determine which employees will receive training (if you are training all employees, state this);

3.  Discuss the format of the program that is used (audiovisual, classroom instruction, etc.);

4.  Procedure to train new employees at the time of their initial assignment;

5.  Procedure to retrain employees when a new hazard is introduced (for example, will personnel track the training and retraining, or will area supervisors?);

6.  Include certificates signed by employees on completion of their training, if you used such a system.

Hazards of non-routine tasks

To cover all situations of employee exposure, be sure to include the following non-routine procedures in your hazard communication program:

1.  Describe the methods you will use to inform employees of the hazards of non-routine tasks (for example, the cleaning of reactor vessels). What procedures do you have to ensure that those jobs that are not part of the weekly or monthly functioning of your facility fall under your employee training system?

2.  Describe how will you inform employees of the hazards of chemicals contained in unlabeled pipes in their work areas.

Hazard Communication an Employee’s Right to Know

About one in every four workers routinely comes in contact with hazardous chemicals while performing his or her job. In many cases, the chemicals may be no more dangerous than those used at home. But in the workplace, exposure is likely to be greater, concentrations higher, and exposure time longer. Reactions to chemical exposures range from slight skin, eye, or respiratory irritation to life-threatening cancers, blood diseases, and debilitating lung damage.

OSHA developed the Hazard Communication Standard (HCS) to protect workers from these dangerous exposures. The standard is based on a simple concept — that employees have both a need and a right to know about the hazards and identities of the chemicals they are exposed to when working. They also need to know what they can do to protect themselves. Additionally, when employers have information about the chemicals being used, they can take steps to reduce exposures, substitute less hazardous materials, and establish safe work practices to prevent illnesses and injuries caused by these substances.

The HCS establishes uniform requirements to make sure that the hazards of all chemicals imported into, produced, or used in U.S. workplaces are evaluated and that this hazard information is forwarded to employers and exposed employees. Basically, the rule incorporates a downstream flow of information. This means that chemical manufacturers have the primary responsibility for generating and disseminating information and chemical users must obtain the information and transmit it to their exposed employees.

Evaluating chemical hazards involves technical concepts and is a process that requires the professional judgement of experienced experts. That’s why the HCS is designed so that employers who simply use chemicals, rather than produce or import them, are not required to evaluate the hazards of those substances.

Hazard determination is the responsibility of the producers and importers of the materials, who must then pass that information to the purchasers and end-users of the products. Employers that don’t produce or import chemicals need only focus on those parts of the rule that deal with establishing a workplace program and communicating information to their workers.

Communication of Hazard to Employees | Bloodborne Pathogens

Q. When are labels required?

A. A warning label that includes the universal biohazard symbol, followed by the term “biohazard,” must be included on bags/containers of contaminated laundry, on bags/containers of regulated waste, on refrigerators and freezers that are used to store blood or OPIM, and on bags/containers used to store, dispose of, transport, or ship blood or OPIM (e.g., specimen containers). In addition, contaminated equipment which is to be serviced or shipped must have a readily observable label attached which contains the biohazard symbol and the word “biohazard” along with a statement relating which portions of the equipment remain contaminated.

Q. What are the required colors for the labels?

A. The background must be fluorescent orange or orange-red or predominantly so, with symbols and lettering in a contrasting color. The label must be either an integral part of the container or affixed as close as feasible to the container by a string, wire, adhesive, or other method to prevent its loss or unintentional removal.

Q. Can there be substitutes for the labels?

A. Yes. Red bags or red containers may be substituted for the biohazard labels.

Q. What are the exceptions to the labeling requirement?

A. Labeling is not required for:

• Containers of blood, blood components, and blood products bearing an FDA required label that have been released for transfusion or other clinical uses.

• Individual containers of blood or OPIM that are placed in secondary labeled containers during storage, transport, shipment, or disposal.

• Specimen containers, if the facility uses Universal Precautions when handling all specimens, the containers are recognizable as containing specimens, and the containers remain within the facility.

• Laundry bags or containers, containing contaminated laundry, may be marked with an alternative label or color-coded provided the facility uses Universal Precautions for handling all soiled laundry and the alternative marking permits all employees to recognize the containers as requiring compliance with Univeral Precautions. If contaminated laundry is sent off-site for cleaning to a facility which does not use Universal Precautions in the handling of all soiled laundry, it must be placed in a bag or container which is red in color or labeled with the biohazard label described above.

• Regulated waste that has been decontaminated.

Q. Does OSHA accept Department of Transportation’s (DOT) labels for waste and specimens which will be shipped or transported?

A. The labeling requirements do not preempt either the U.S. Postal Service labeling requirements (39 CFR Part III) or the Department of Transportation’s Hazardous Materials Regulations (49 CFR Parts 171-181).

DOT labeling is required on some transport containers (i.e., those containing “known infectious substances”). It is not required on all containers for which 29 CFR 1910.1030 requires the biohazard label. Where there is an overlap between the OSHA-mandated label and the DOT-required label, the DOT label will be considered acceptable on the outside of the transport container provided the OSHA-mandated label appears on any internal containers which may be present. Containers serving as collection receptacles within a facility must bear the OSHA label since these are not covered by the DOT requirements.

Q. Which employees must be trained?

A. All employees with occupational exposure must receive initial and annual training.

Q. Should part-time and temporary employees be trained?

A. Part-time and temporary employees are covered and are also to be trained on company time.

Q. Who has the responsibilty for training workers employed by agencies which provide personnel (e.g., nurses) to other employers?

A. As stated in a similar answer, OSHA considers personnel providers, who send their own employees to work at other facilities, to be employers whose employees may be exposed to hazards. Since personnel providers maintain a continuing relationship with their employees, but another employer (your client) creates and controls the hazard, there is a shared responsibilty for assuring that your employees are protected from workplace hazards. The client employer has the primary responsibility for such protection, but the “lessor employer” likewise has a responsibility under the Occupational Safety and Health Act.

In the context of OSHA’s standard on Bloodborne Pathogens, the personnel provider would be required to provide the general training outlined in the standard. The client employer would be responsible for providing site-specific training.

The contract between the personnel provider and the client should clearly describe the training responsibilities of both parties in order to ensure that all training requirements of the standard are met.

Q. What are the qualifications that a person must possess in order to conduct employee training regarding bloodborne pathogens?

A. The person conducting the training is required to be knowledgeable in the subject matter covered by the elements in the training program and be familiar with how the course topics apply to the workplace that the training will address. The trainer must demonstrate expertise in the area of occupational hazards of bloodborne pathogens.

Q. Who are some examples of persons who could conduct training on the bloodborne standard?

A. Examples of health care professionals include infection control practitioners, nurse practitioners, and registered nurses. Non-health care professionals include industrial hygienists, epidemiologists or professional trainers, provided that they can demonstrate evidence of specialized training in the area of bloodborne pathogens.