Controlling Job Hazards

Information obtained from a job hazard analysis is useless, unless hazard control measures recommended in the analysis are incorporated into the tasks. You should recognize that not all hazard controls are equal. Some are more effective than others at reducing the risk.

After reviewing your list of hazards with the employee, consider what control methods will eliminate or reduce them, such as combining steps or changing the sequence, or whether safety equipment and precautions are needed to reduce the hazards.

The most effective controls are engineering controls that physically change a machine or work environment to prevent employee exposure to the hazard. Consider redesigning the process or equipment, changing tools, adding machine guards, personal protective equipment or ventilation to eliminate or reduce hazardous conditions. The more reliable or less likely a hazard control can be circumvented, the better.

If this is not feasible, administrative controls may be appropriate. This may involve changing how employees do their jobs. Discuss your recommendations with all employees who perform the job and consider their responses carefully. If you plan to introduce new or modified job procedures, be sure they understand what they are required to do and the reasons for the changes. The following information provides the recommended order of precedence and effectiveness for job hazard control.

Engineering Controls

Engineering controls include:

• Hazard elimination/minimization by designing the facility, equipment, or process to remove the hazard, or substituting processes, equipment, materials, or other factors to lessen the hazard;
• Enclosing the hazard using enclosed cabs, enclosures for noisy equipment, or other means;
• Isolating the hazard with interlocks, machine guards, blast shields, welding curtains, or other means; and
• Removing or redirecting the hazard such as with local and exhaust ventilation.

Administrative Controls

Administrative controls include:

• Written operating procedures, work permits, and safe work practices;
• Exposure time limitations (used most commonly to control temperature extremes and ergonomic hazards);
• Monitoring the use of highly hazardous materials;
• Alarms, signs, and warnings;
• Job rotation;
• Buddy system; and
• Training.

Personal Protective Equipment

Personal protective equipment, such as respirators, hearing protection, protective clothing, safety glasses, and hardhats, is acceptable as a control method in the following circumstances:

• When engineering controls are not feasible or do not totally eliminate the hazard;
• While engineering controls are being developed;
• When safe work practices do not provide sufficient additional protection; and
• During emergencies when engineering controls may not be feasible.

Use of one hazard control method over another higher in the control precedence scale may be appropriate for providing interim protection until the hazard is abated permanently. In reality, if the hazard cannot be eliminated entirely, the adopted control measures will likely be a combination of all three items instituted simultaneously.

Careful Documentation is Essential

If safer and better job steps can be used, list each new step, such as describing a new method for disposing of material. List exactly what the worker needs to know in order to perform the job using a new method. Do not make general statements about the procedure, such as "Be careful." Be as specific as you can in your recommendations.

Go over the recommendations with all employees performing the job. Their ideas about the hazards and proposed recommendations may be valuable. Be sure that they understand what they are required to do and the reasons for the changes in the job procedure.

Identifying Workplace Hazards

A job hazard analysis is an exercise in detective work. Your goal is to discover the following:

• What can go wrong?
• What are the consequences?
• How could it arise?
• What are other contributing factors?
• How likely is it that the hazard will occur?

To make your job hazard analysis useful, document the answers to these questions in a consistent manner. Describing a hazard in this way helps to ensure that your efforts to eliminate it and implement controls help target the most important contributors to the hazard.

Good hazard scenarios describe:

• Where it is happening (environment),
• Who or what it is happening to (exposure),
• What precipitates the hazard (trigger),
• The outcome that would occur should it happen (consequence), and
• Any other contributing factors.

Rarely is a hazard a simple case of one singular cause resulting in one singular effect. More frequently, many contributing factors tend to line up in a certain way to create the hazard. Here is an example of a hazard scenario:

• In the metal shop (environment), while clearing a snag (trigger), a worker's hand (exposure) comes into contact with a rotating pulley. It pulls his hand into the machine and severs his fingers (consequences) quickly.

To perform a job hazard analysis, you should ask the following questions.

• What can go wrong?
• The worker's hand could come into contact with a rotating object that "catches" it and pulls it into the machine.
• What are the consequences?
• The worker could receive a severe injury and lose fingers and hands.
• How could it happen?
• The accident could happen as a result of the worker trying to clear a snag during operations or as part of a maintenance activity while the pulley is operating. Obviously, this hazard scenario could not occur if the pulley is not rotating.
• What are other contributing factors?
• This hazard occurs very quickly. It does not give the worker much opportunity to recover or prevent it once his hand comes into contact with the pulley. This is an important factor, because it helps you determine the severity and likelihood of an accident when selecting appropriate hazard controls. Unfortunately, experience has shown that training is not very effective in hazard control when triggering events happen quickly because humans can react only so quickly.
• How likely is it that the hazard will occur?
• This determination requires some judgment. If there have been "near-misses" or actual cases, then the likelihood of a recurrence would be considered high. If the pulley is exposed and easily accessible, that also is a consideration.
• In the example, the likelihood that the hazard will occur is high because there is no guard preventing contact, and the operation is performed while the machine is running.

Building Owner Responsibilities | Asbestos

Q.	Does a building owner have any responsibility under the standard even though the employees at risk may not be the owner's direct employees?
A.	Yes. The building and/or facility owner must notify contractors and tenants of the presence of ACM/PACM, even though the employees at risk are not the owner's direct employees. OSHA has the authority to require building owners who are "statutory employers" to take necessary action such as notifying other employers, and to protect employees other than their own. They also have the responsibility to identify and label ACM/PACM when required. Homeowners are not considered "building owners" when they have work done in their private homes.
Q.	When shipyard vessels undergoing repair are foreign-owned, who is considered the "building owner?"
A.	When a foreign-owned vessel is repaired in an American shipyard, the employer is either the shipyard or an outside primary contractor. They must either treat materials defined as PACM as asbestos-containing or sample the suspect material and analyze it to determine whether or not it contains asbestos.
Q.	Does a long term lessee of a building have the same responsibilities as a "building owner"?
A.	"Building owner" has been defined to include lessees who control the management and recordkeeping functions of a building/facility/vessel. It is not OSHA's intention to exempt the owner from notification requirements by allowing a lessee to comply. Rather, when the owner has transferred the management of the building to a long-term lessee, that lessee is the more appropriate party to receive, transmit, and retain information about in-place asbestos. When the lease is terminated, the records are to be transferred to the building owner.
Q.	Can building owners use building records to rebut the presumption of asbestos containing materials (PACM)?
A.	Generally, building records must be relied upon to rebut the presumption of asbestos containing material (PACM). If an employer had an AHERA asbestos survey, such a survey would be accepted. However, for non-PACM materials, building owners and employers may use all sources of information including building records to show that the materials do not contain asbestos.
Q.	What materials must be presumed to contain asbestos?
A.	Thermal System Insulation (TSI) and sprayed on and troweled on surfacing materials installed no later than 1980. (Note: In addition, resilient flooring material installed no later than 1980 shall be identified as asbestos-containing). Other building/facility areas and material would not be exempt from the standard's control requirements; however, they would not be presumptively considered to contain asbestos.
Q.	Do the standards require any particular qualifications of the person who designates materials as PACM?
A.	The person who designates materials as PACM is not required to have any technical training. The evaluation is not to determine if the material is or is not asbestos, rather it is to identify thermal system insulation and surfacing materials. The process does not require technical training. Thermal system insulation, and sprayed on or troweled on surfacing material are easily recognized and identified.
Q.	Are the sign and label requirements the same in the General Industry standard as they are in the Construction and Shipyard standards?
A.	Yes, the three standards contain the same provisions.

Q:	If construction of a building began before 1981 but was not completed until several years later, is the owner responsible for presuming asbestos exists in the entire building?
A:	The CSHO will need to evaluate this on a case-by-case basis. Generally speaking, the focus would be on areas that contain suspect materials in those areas built before 1981.
Q.	How has the definition of repair and maintenance changed?
A.	Repair and maintenance is now considered Class III work if it involves less than one glovebag of material, regardless of the time it takes to do the job. If the job involves more than one glovebag of TSI or surfacing material then it is a Class I job. If the job involves more than one bag of other ACM then it is a Class II job.
Q.	What are some examples of activities that may be classified as Class III?
A.	These activities may include: maintenance/repair of boilers, air handling units, heat exchangers, and tanks; repair/replacement of pipe insulation including cutting away of small amounts of ACM (that which fits into a standard glovebag or disposal bag); valve or gasket replacement, or activities above suspended ceilings such as connections and/or extensions for telecommunication/computer networks; adjustment/repair of HVAC systems and; testing/cleaning/replacing smoke or heat detectors when connected to ceilings containing ACM. Class III work involves a "disturbance."

Flooring Operations | Asbestos

Q.	When must an employer presume that flooring material contains asbestos?
A.	A 1988 EPA survey reported that 42 percent of public and commercial buildings within the U.S. contain asbestos-containing flooring material. The standard requires that employers presume that floor tile and resilient flooring found in buildings constructed no later than 1980 contains asbestos and take the specific precautions required unless the employer demonstrates that the flooring materials do not contain asbestos, by using recognized analytical techniques.
Q.	What work practices are prohibited or restricted in floor maintenance?
A.	(1) Sanding of asbestos-containing flooring material is prohibited; (2) stripping of finishes must be conducted using low abrasion pads at speeds lower than 300 rpm and wet methods; and (3) burnishing or dry buffing may be performed only on asbestos-containing flooring which has sufficient finish so that the pad cannot contact the asbestos-containing material.
Q.	What work practices must be used when removing floor tile?
A.	The floor must first be HEPA-vacuumed. The floor tiles then must be carefully pried up individually after being wetted. Misting is sufficient if the tiles are removed intact. After removal, each tile must be placed in an impermeable trash bag or other impermeable waste container.

Q.	If the wetting agent contains a hazardous substance, what other precautions must the employer take?
A.	The employer may be responsible for compliance with other standards such as the Hazard Communication standard. The employer shall obtain a material safety data sheet for the substance and follow the recommendations for the use of personal protective equipment and provide training.
Q.	If floor tiles are broken during removal, are they no longer "intact?"
A.	Not necessarily. Some incidental breakage of floor tiles is to be expected. Under the standard, material is not intact only if it has crumbled, been pulverized, or has otherwise deteriorated so that the asbestos fibers are no longer likely to be bound with their matrix. Therefore, the incidental breakage of tiles does not by itself mean that the material is not intact.
Q.	How are tiles to be removed when they cannot be removed by careful prying?
A.	The tiles may be heated to soften the adhesive holding them to the substrate. When tiles are removed intact using heat, wetting may be omitted.
Q.	How are tiles to be removed when they cannot be removed by either careful prying or heating?
A.	Aggressive techniques such as mechanical chipping can be used if a competent person evaluates the worksite and determines that additional precautions required by the standard are properly installed and operated. This may include negative pressure enclosures.
Q.	How must residual adhesive be removed?
A.	The standard does not require removal of residual adhesive, but it is often necessary to remove or smooth residual adhesive to prepare the surface for installation of a new floor. Wet methods must be used when removing residual adhesive. The adhesive must either be wet-scraped manually or removed using a low speed floor machine and wetted sand or a removal solution. The adhesive residues must be placed in an impermeable trash bag or other impermeable container while still wet. Remaining water or dirt in the area must then be HEPA vacuumed.
Q.	What work practices must be used when removing resilient sheet flooring?
A.	The material must not be ripped up. The floor shall first be HEPA vacuumed. The sheet flooring shall then be removed in strips four to eight inches wide. As a strip is removed, the point of separation must be constantly misted to minimize fiber release. A strip must be rolled up as it is removed and the roll placed in an impermeable trash bag or other impermeable container. Residual felt and adhesive is then removed by wet scraping, and the floor is HEPA vacuumed.
Q.	When must flooring removal jobs be monitored for asbestos levels?
A.	Most jobs will not require monitoring. Monitoring is only required if compliant work practices are not followed, if the material is not removed intact, or if the employees are not properly trained in accordance with the standard.
Q.	What level of training is required for competent persons for flooring removal operations?
A.	When flooring removal jobs are conducted using compliant work practices and the material is removed intact, the competent person must have completed at least 12 hours of training. If the material is not removed intact, the competent person must have completed a training course that meets the requirement for a Class II competent person.
Q.	Must respirators be worn when floor tiles are removed using heat?
A.	The standard generally requires that respirators be worn when Class II work, including floor tile removal, is not performed using wet methods. However, the standard allows wetting to be omitted when floor tiles are removed intact using heat. Since the use of heat to remove floor tiles provides the same level of protection against fiber release as the use of wetting, the omission of wetting does not require respirators to be worn when heat is used and the tiles are removed intact. Respirators would only be needed if their use is required under another provision of the standard.

Brake and Clutch | Asbestos

Q.	Are the appendices on brake and clutch repair (Appendix F for General Industry and Appendix L for Shipyard employment) mandatory?
A.	Yes.
Q.	What are the two "preferred" methods for brake and clutch repair?
A.	The two "preferred" methods are the low pressure/wet-cleaning method and the negative pressure enclosure/HEPA vacuum system.
Q.	Is the solvent spray method prohibited?
A.	No. The solvent spray method is an "equivalent" method that may be used when proper work practices are followed.
Q.	What are the work practices that must be used when an employer chooses the spray/solvent can method?
A.	An employer who uses an "equivalent" method must follow detailed written procedures. At a minimum, the solvent spray method should include the following procedures: (1) the solvent shall be used to first wet the brake and clutch parts; (2) the brake and clutch parts shall be wiped clean with a cloth; (3) the contaminated cloth shall be placed in an impermeable container, and then either disposed of properly or laundered in a way that prevents the release of asbestos fibers in excess of 0.1 fiber per cubic centimeter of air; (4) any spilled solvent or dispersed asbestos shall be cleaned up immediately and not allowed to dry, either with a cloth or a HEPA vacuum. Dry brushing during solvent spray operations is prohibited.
Q.	What other precautions are required when solvents are used?
A.	The solvents typically used in brake and clutch work are hazardous chemicals, and the employer must therefore comply with the Hazard Communication standard. If the solvents used are flammable, appropriate precautions against fire and explosion must be taken.
Q.	If the employer chooses to use one of the two "preferred" methods or an "equivalent" method, does the employer have to conduct exposure monitoring?
A.	No.
Q.	Does Appendix F that covers brake and clutch work practices also cover brake and clutch work done on large stationary equipment like printing presses?
A.	No, the Appendix is only intended for automotive work. For other asbestos jobs as described above, the employer must use work methods that reduce the exposures to below the PELs.
Q.	What type of "aqueous" solution is allowed when the low pressure/wet cleaning method is used?
A.	The intent of the standard was to ensure that the asbestos is sufficiently wet so that exposures are kept well below the PELs. The solution can consist only of water, or water mixed with an organic solvent, or a detergent. It is important to note the potential danger of solvent use in these operations. The use of solvents, which are often flammable and may also present a health hazard, must be undertaken with great care. The employer must also be in compliance with the Hazard Communication standard.

Q.	Are other methods allowed for employers who do brake and clutch work infrequently?
A.	Yes, for those shops in which brake work is infrequent, OSHA has determined to allow the use of a wet control method as a "preferred" method. Therefore, in facilities in which five (5) or fewer brake "jobs" (five brake "jobs" is equivalent to five vehicles) or 5 clutches, or some combination totaling 5, are repaired each week, the mechanic/technician may control potential asbestos exposure through the use of a pump sprayer (bottle) containing water or amended water to wet down the drum or clutch housing before it is removed and to control fiber release during subsequent activities. The mechanic may use other implements to deliver the water such as a garden hose; however, the resulting wastewater generated must be captured and properly disposed of without allowing it to dry on any surfaces. The spray should be controlled through the use of low pressure to the extent feasible. OSHA anticipates that the use of a spray bottle will be adequate to control the dust without generating a large volume of wastewater. However, any waste water generated must be disposed of properly.
Q.	What provisions are required to perform a brake inspection?
A.	The extent to which an "inspection" is different from the other brake servicing depends on whether and how the drum is removed. Most inspections of brake shoes involve removing the drum which may contain a substantial number of asbestos fibers. Precautions must be taken against the release of those fibers into the workplace. If the drum is carefully pulled back just far enough to observe the brake shoe and brake components, it is sufficient to thoroughly wet the exterior and around the seam between the brake drum and backing plate. Any dislodged material must be immediately cleaned up in accordance with 1910.1001(k). Blows to the drum with a hammer or similar implement to dislodge a rusted-in-place or frozen drum may cause asbestos fibers to be released. For such cases, in shops performing 6 or more brake jobs per week, an enclosure must be installed around the drum to capture the dust or the drum interior and contents must be thoroughly wetted prior to striking or forcibly removing the brake drum. As with other brake servicing, this must be done using a preferred or equivalent method. When using the equivalent spray can method, first wet the interior and contents of the drum before striking it. Then, carefully pull the drum back just enough to allow another application of solvent and thoroughly wet the interior before removal of the drum. There should be no visible dust created during drum loosening and removal.

Definitions | Workplace Hazards

Q.	How has the definition of "asbestos" changed in the asbestos standards?
A.	The non-asbestiform varieties of the minerals actinolite, tremolite and anthophyllite are no longer included in the definition of asbestos.
Q.	Briefly, what are the four classes of activities covered in the Construction standard?
A.	"Class I" work is defined as activities involving the removal of thermal system insulation (TSI) and sprayed-on or troweled-on or otherwise applied surfacing asbestos-containing material or presumed asbestos-containing material. "Class II" asbestos work is defined as removal of ACM or PACM which is not TSI or surfacing ACM or PACM. Certain "incidental" roofing materials such as mastic, flashing and cements when they are still intact are excluded. "Class III" asbestos work is defined as repair and maintenance operations which are likely to disturb ACM or PACM. "Disturbance" means activities that disrupt the matrix of ACM or PACM, crumble or pulverize ACM or PACM, or generate visible debris from ACM or PACM. Operations may include drilling, abrading, cutting a hole, cable pulling, crawling through tunnels, or attics and spaces above the ceiling where asbestos is actively disturbed or asbestos-containing debris is actively disturbed. "Class IV" asbestos work means maintenance and custodial activities during which employees contact, but do not disturb ACM or PACM, and activities to clean up dust, waste, and debris resulting from Class I, II, and III activities. This may include dusting surfaces where ACM waste and debris and accompanying dust exists, and cleaning up loose ACM or PACM debris from thermal system insulation or surfacing ACM/PACM, following construction activity.
Q.	Do the new standards set a minimum level of asbestos content for asbestos-containing materials?
A.	Asbestos-containing material means any material containing more than 1% asbestos.
Q.	What is "presumed asbestos containing material" (PACM)?
A.	The definition of PACM is limited to thermal system insulation and sprayed on and/or troweled or otherwise applied surfacing material in buildings constructed no later than 1980. The material is "presumed" to contain asbestos unless it is demonstrated in accordance with the standard that PACM does not contain asbestos.

Q.	Does OSHA still use the term "small-scale, short-term"?
A.	No. OSHA has dropped the term "small-scale, short-term" work from the regulatory text. The term "small-scale, short-term" was too limiting, has been shown to be confusing, and could not be defined with sufficient precision to serve the purpose of distinguishing high risk asbestos-disturbing activity from activity of reduced risk.
Q.	Are "wrap and cut" operations included in the definition of "removal"?
A.	Yes, a wrap and cut operation is a type of asbestos removal. It consists of two distinct operations. The wrap portion requires the removal of small amounts of asbestos from either side of the pipe to be cut. This will be a Class I or III operation depending on the amount of asbestos removed. Once the asbestos is removed and wrapped, the pipe is then cut. The cutting portion of the job is unclassified, as it does not involve asbestos removal.

Questions and Answers on the Asbestos Standard | Workplace Hazards

Scope

Q.	Are marine terminals and longshoring covered by the General Industry standard?
A.	Marine terminals and longshoring are covered by the General Industry standard if asbestos is being loaded, unloaded or stored.
Q.	What work activity is most affected by the General Industry asbestos standard?
A.	Brake and clutch repair in the General Industry standard is the activity engaged in by the largest group of asbestos exposed workers, although most of them are exposed sporadically and at low levels. The next largest group consists of custodial workers who do not perform their duties as part of construction activities, but clean surfaces, sweep, buff and vacuum floors and wash walls and windows in manufacturing plants and a wide variety of public and commercial buildings.
Q.	Is housekeeping work covered under the General Industry standard or the Construction standard?
A.	Housekeeping work which is not related to a construction activity, is regulated under the General Industry standard. Housekeeping work which is related to construction activities at a construction site is covered by the Construction standard.
Q.	What other industries are covered by the General Industry standard?
A.	Primary and secondary manufacture of asbestos-containing products.
Q.	What activities does the Construction standard (29 CFR 1926.1101) cover?
A.	The construction standard explicitly states that it covers, but is not limited to, the following activities involving asbestos: demolition, removal, alteration, repair, maintenance, installation, clean-up, transportation, disposal, and storage. It has been redesignated 29 CFR 1926.1101.

Q.	If construction activities are performed in a facility normally covered by the General Industry standard, which standard applies?
A.	Asbestos work which involves removal, repair, maintenance or demolition is explicitly regulated by the Construction standard even if such work is performed within a facility otherwise regulated under the General Industry standard.
Q.	Does the standard apply during earthmoving projects, drilling, blasting or sawing where natural deposits of asbestos occur?
A.	The record indicates that certain construction sites in mostly well-defined areas contain deposits of naturally occurring asbestos. In such cases, wetting of the excavation site, often required by local authorities, should be sufficient to suppress measurable airborne asbestos concentrations. No other actions are required by the standard.
Q.	In the above case is the employer required to take any action if there is no information readily available indicating asbestos contamination of the soil?
A.	In the absence of actual knowledge or information showing asbestos contamination of soil in the immediate vicinity of a construction site, the employer is not required to take any action under this standard.