OSHA


Every year since 1996 the Occupational Safety and Health Administration (OSHA) has collected work-related injury and illness data from more than 80,000 employers. For the first time, the agency has made the data from 1996 to 2007 available in a searchable online database, allowing the public to look at establishment or industry-specific injury and illness data. The workplace injury and illness data is available at http://www.osha.gov/pls/odi/establishment_search.htmlas well as Data.gov.

OSHA uses the data to calculate injury and illness incidence rates to guide its strategic management plan and to focus its Site Specific Targeting (SST) Program, which the agency uses to target its inspections.

“Making injury and illness information available to the public is part of OSHA’s response to the administration’s commitment to make government more transparent to the American people,” said David Michaels, Assistant Secretary of Labor for OSHA. “This effort will improve the public’s accessibility to workplace safety and health data and ensure the Agency can function more effectively for American workers.”

Information available at the data.gov and www.osha.gov Web sites includes an establishment’s name, address, industry, associated Total Case Rate (TCR), Days Away, Restricted, Transfer (DART) case rate, and the Days Away From Work (DAFWII) case rate. The data is specific to the establishments that provided OSHA with valid data through the 2008 data collection (collection of CY 2007 data). This database does not contain rates calculated by OSHA for establishments that submitted suspect or unreliable data.

Data.gov provides expanded public access to valuable workforce-related data generated by the Executive Branch of the federal government. Although the initial launch of Data.gov provides a limited portion of the rich variety of Federal datasets presently available, the public is invited to participate in shaping the future of Data.gov by suggesting additional datasets and site enhancements to provide seamless public access and use of federal data.

More information about the Department of Labor’s Open Government Web site is available at http://www.dol.gov/open/where there are links to the latest data sets, ways to connect with Department staff, and information about providing public input that will make the Department’s site and its work more useful and engaging.

A new “Warehouse Safety Hazards and Solutions Guide” is now available free from Graphic Products, Inc. It lists common warehouse safety hazards, presents safety solutions and provides “Think Safety” checklists for avoiding certain hazards.

“Safety hazards in a warehouse like forklifts, electrical wiring, docks and use of poor ergonomics contribute to a myriad of injuries and deaths each year,” said Daniel Evans, assistant marketing manager at Graphic Products. “It’s so crucial not only to recognize warehouse safety hazards but to understand effective solutions for preventing them in the first place, and that’s where this new guide steps in.”

By listing up front 10 OSHA standards for which warehousing establishments are most frequently cited, the “Warehouse Safety Hazards and Solutions Guide” immediately speaks to the reality of working in such a potentially dangerous environment.

It then lists specific hazards presented to warehouse workers, including unsafe use of forklifts, improper stacking of products, failure to use personal protective equipment, failure to follow proper lockout/tagout procedures and repetitive motion injuries.

Safety solutions are presented in an orderly manner within the guide for each of the following hazards:

- Forklifts
- Docks
- Conveyors
- Materials Storage
- Manual Lifting/Handling
- Charging Stations
- Poor Ergonomics
- General Hazards
- Materials Handling

An excerpt from the guide introduces some of the solutions to fire and explosion hazards related to charging stations:

- Prohibit smoking and open flames in and around charging stations (mark these areas with signs)
- Provide adequate ventilation to disperse fumes from gassing batteries
- Ensure that fire extinguishers are available and fully charged (identify fire extinguisher locations with highly visible signs)

Another excerpt from the guide allows a peak into part of a “Think Safety” checklist for hazard communication safety:

- All hazardous materials containers are properly labeled, indicating the chemicals’ identity, the manufacturer’s name and address, and appropriate hazard warnings.
- The facility has written a program that covers hazard determination, including Material Safety Data Sheets (MSDSs), labeling and training
- Employees use proper personal protective equipment when handling chemicals

“What we’ve done is compiled pertinent information as a means to offer valuable safety insights to anyone working in warehouse operations,” said Evans.

The seven-page “Warehouse Safety Hazards and Solutions Guide” is available, free of charge, from Graphic Products. It may be requested by visiting http://www.duralabel.com/free-warehouse-safety-guide.php or by calling Graphic Products at 1-888-326-9244.

OSHA recently solidified leadership for the agency and has provided a clearer picture of the regulatory horizon.

First of all, David Michaels, PhD, MPH, assumed his position as head of OSHA when the Senate confirmed his nomination as assistant secretary of Labor for occupational safety and health. Nominated by President Barack Obama on June 28, the Senate acted on the nomination December 3.

Michaels, an epidemiologist, has been a professor at the George Washington University School of Public Health and Health Services in Washington, DC, and is also the author of Doubt is Their Product: How Industry’s Assault on Science Threatens Your Health.

Agency watchers assumed that any work on new, and perhaps controversial, standards, would await the establishment of a permanent director.

While Michaels as settling in, Secretary of Labor Hilda L. Solis held an online Q&A session Dec. 7 to discuss regulations at the Department of Labor.

Solis announced that OSHA is considering airborne infectious disease protection for healthcare workers and will publish a request for information in the Federal Register in March.

A standard would require healthcare employers to protect workers from tuberculosis, severe acute respiratory syndrome (SARS), and influenza, such as H1N1, on which OSHA recently issued an enforcement directive.

When asked if an airborne infectious disease standard would be modeled after the California version, which took years to achieve consensus among employers, labor and other stakeholders, Solis said the California standard “would certainly be one important piece of information that OSHA will consider in deciding whether to propose or issue a standard.” She would not predict how long it would take to issue a final standard.

Also, Solis confirmed that although OSHA has conducted several inspections, it has not yet issued any citations based on the H1N1 enforcement directive.

In an OSHA-specific session later that day, HealthLeaders Media asked OSHA interim director Jordan Barab, if the absence of airborne infectious disease standard has hampered the agency with regard to its H1N1 educational preparedness and enforcement activities?

“No, it has not hampered us,” said Barab. “While a standard on airborne transmissible diseases would have been preferable, we believe that we are responding to the issues effectively using existing standards and the General Duty Clause.”

On the matter of issuing an industry-wide ergonomics standard, both Solis and Barab reiterated—word-for-word in fact—”At this time, OSHA has no plans for regulatory activity.” Both said that a proposal to reinstate the work-related musculoskeletal disorders column on the OSHA 300 Injury Log was not a prelude to issuing such a standard.

Concerning an industry-specific ergonomic standard, such as one for safe patient handling standard, Barab said,” There are many options that OSHA might consider if the agency decides to pursue rulemaking in this area. Industry specific standards is one option that would be considered.”


David LaHoda, the managing editor of Medical Environment Update and OSHA Watch, has produced healthcare training videos and consulted for medical practices and ambulatory healthcare facilities.

NIOSH Update: Aging Workers at Higher Risk of Death, Severe Injury, Conference Report Suggests Ways to Keep Workers Healthy and Productive

Policy Shifts on Work Environment, Health Promotion, Continued Research Needed to Maintain Healthy U.S. Workforce

A report of conference presentations and discussions among participants from the National Academies of Science, universities and research institutions, and representatives of professional associations, industry and labor, recommends attention to workplace environments to maintain “work ability” as workers age, along with legislative fixes and research to fill in knowledge gaps for keeping workers healthy and productive.

According to researchers using U.S. Bureau of Labor Statistics (BLS) data, older workers are more severely injured and die with greater frequency from work-related injuries than younger workers. Older workers also have longer recovery periods than younger workers. These findings raise health care delivery and economic issues for the nation, as more workers are choosing to delay retirement due to collapsed 401(k) plans and savings. BLS uses workers age 55 and older in its calculations, although the rates rise sharply for those workers over age 65. Other agencies and organizations define the term as age 50 or 55 and up. The Department of Labor uses age 40 as a starting point for “older worker.”

“The issue of healthy aging is critically important as the U.S. economy is revitalized. As we go forward in time, the demand for workers will grow but fewer workers will be entering the workforce and a larger proportion of the workforce will be older. This is a simple reality of demographics,” said National Institute for Occupational Safety and Health (NIOSH) Director John Howard, M.D. “Having a healthy, productive workforce will help sustain economic growth in the decades ahead. We must take steps now to help all workers stay safe and healthy at work as they age. We must also take steps to address the special needs of older workers who, more and more, will be staying on the job past traditional retirement age.”

The conference, held Feb. 17-18, 2009, at the National Labor College in Silver Spring, Md., paid particular attention to workers in physically demanding jobs, such as construction and health care. Health care cost-containment has meant longer work hours and increased stress among health care workers, which has led to a shortage of nurses. Thirty-nine percent of RNs were 45 years or older in 2002.

Construction workers already suffer the highest number of fatalities in any U.S. industry.  But the death rate among construction workers 55 years and older was nearly 80% higher than that of construction workers under 35 in 2007. And like the rest of the workforce, the average age of a construction worker is rising; it was 40.4 in 2008, which is 4.4 years older than in 1985. The average retirement age among construction workers is 61.

“Our nation loses an average of four construction workers every workday to a job-related incident – and that’s been consistent for more than a decade,” said Pete Stafford, executive director of CPWR – The Center for Construction Research and Training, one of the conference’s co-sponsors. “As we start to rebuild our nation’s crumbling infrastructure and venture into green jobs, we want to make sure jobsites do not become a source of pain and death for older workers who have so much to contribute, especially in mentoring younger workers.”

Howard believes the conference confirms and expands on a 2004 report from the National Academies of Science that recognized the deteriorating conditions facing an aging workforce, to the detriment of workers, their families, and businesses. “Health and Safety Needs of Older Workers” made clear recommendations to increase research efforts toward preventing work-related injury, illness and fatality among aging workers.   These recommendations have yet to be adopted.

“The discussions and recommendations from the conference point to steps that can be taken to address needs identified in the 2004 report  that were never acted upon,” said Jordan Barab, acting Assistant Secretary of Labor for  the Occupational Safety and Health Administration (OSHA). “As those discussions make clear, a sustainable workforce will be a critical component of a secure and prosperous 21st century economy. The work we do now is an investment in a stronger workforce for tomorrow.”

The Healthy Aging for Workers conference was funded through grants from NIOSH and CPWR. The Association of Occupational and Environmental Clinics and the Society for Occupational and Environmental Health were conference sponsors. Additional co-sponsors were AARP, OSHA, the American Public Health Association, the Veterans Administration, and the University of Maryland Work and Health Research Center.

The full conference report and presentations from national and international researchers on occupational health and safety issues can be found on the Society for Occupational and Environmental Health’s Web site.

First aid in the era of biohazards

by Lisa J. Burns, Q.S.S.P.

10 best practices to keep responders safe

Everyone sees the need for trained responders, first-aid kits and automated external defibrillators at the workplace. But what about the simple cut that bleeds enough to require a gauze bandage? Does the responder — or just a nearby helpful employee — see the need to wear disposable gloves? Bloodborne pathogens and other biohazards command little attention from most people, yet can cause critical illnesses and sometimes eventual death.

Defining the danger
Bloodborne pathogens are microorganisms (bacteria or viruses) carried in the blood that can be transmitted and cause disease in other people. Hepatitis B Virus (HBV) and Human Immunodeficiency Virus (HIV) are two examples that are addressed by the OSHA Bloodborne Pathogen standard 29 CFR 1910.1030. Malaria and syphilis also are caused by bloodborne pathogens. Other body fluids also may transmit these and other diseases.

Infectious disease such as the H1N1 flu virus is a workplace concern that employers must address.

Transmission
Unbroken skin generally acts as a barrier to bloodborne pathogens. However, microorganisms can enter through any damaged or broken skin such as acne, sunburn, blisters, open sores, cuts or abrasions. They also may be transmitted through mucous membranes, including those of the eyes, nose or mouth.

Infectious diseases such as the H1N1 flu virus are primarily transmitted through airborne body fluids emitted with coughs and sneezes, and breathed in by others in the immediate vicinity. They also are transmitted when a hand used to cover the mouth then touches faucets, doorknobs and other surfaces from which it is later picked up by others.

OSHA first-aid regulations
Emergency medical services and first aid that general industry employers must provide are described in OSHA standard 29 CFR 1910.151. The standard recommends kits and supplies that are compliant with the minimum guidelines established by the American National Standards Institute (ANSI) in Z308.1-2009. It also incorporates other standards and measures by reference, such as 29 CFR 1910.1030, which deals with bloodborne pathogens.

OSHA’s 29 CFR 1910.1030 standard requires limiting employee exposure to blood and other potentially infectious materials. It specifies that training and personal protective equipment must be provided for employees who can be “reasonably anticipated” to face possible contact with blood or other potentially infectious materials on the job.

The standard, issued in 1991, was updated in 2001 in response to the Needlestick Safety and Prevention Act, and can be found at http://www.osha.gov, along with FAQs and various letters of interpretation issued over the years since then.

Best practices
Following the best PPE practices recommended below will help keep first responders safe from bloodborne pathogens and other infectious material.

1. “Universal precautions.” Treat every situation as potentially dangerous. OSHA’s universal precautions require that all human blood or other potentially infectious materials be considered hazardous.

2. Hand protection. Before donning gloves, cover any cuts or sores on your own hands with a bandage. Inspect the gloves and if the material is thin, doubleglove to provide another layer of protection. Do not use torn or punctured gloves, no matter how miniscule the damage might be. When removing used gloves, pull them off from the cuff, turning them inside out so the outside of the gloves do not touch your bare skin. Dispose of them in a designated biohazard bag. Immediately scrub your hands thoroughly, including under nails — and any other potentially contaminated skin — with nonabrasive soap and running water at hand-washing facilities that employers must provide in readily accessible areas.

3. Eye and face protection. While providing first aid or other medical assistance as well as working in labs or while cleaning up a spill, there may be a risk of splashing or vaporization of contaminated fluids. Use goggles to protect against transmission of pathogens through your eye membranes. Use a face shield in addition to goggles to protect against splashes to your nose and mouth.

4. Body protection. In some cases, you may need to wear aprons or body shields to protect your clothing and keep blood or other contaminated fluids from soaking through to your skin. Wear shoe covers to avoid contamination of your footwear.

5. Clean up. For clean-up of blood or other body fluids from sick or injured employees, use gloves and, depending on the situation, some or all of the above-mentioned PPE. In addition, you should have available a small shovel and scraper, appropriate absorbent materials, biohazard bags, ties, germicidal towelettes — and for large areas, a mop or sponge and bucket with a solution of 1/4 cup bleach to 1 gallon of water. Some manufacturers supply complete biohazard clean-up kits that contain all the necessary supplies, including special absorbent materials that deodorize as well as bind the hazardous body substances together.

6. Deposit waste. Once clean-up is complete, deposit the waste material first in a labeled, red biohazard bag and tie it tightly. Use germicidal towelettes or bleach solution to clean the contaminated area. Then put the first bag into a second biohazard bag, and add the used towelettes or sponges, your shoe covers, gown, face mask with eye shield and, lastly gloves in the same bag, and seal it with a tie. Discard the red bag in an appropriate container for infected solid waste as required by local regulations.

7. Sharps. For any broken glass or other sharp material, use a broom with shovel or dustpan, and deposit them in appropriate boxes. Never touch them with your gloved or ungloved hands and do not put them in a biohazard bag.

8. Decontamination. Finally, wipe your hands with antiseptic hand wipes that provide rapid bactericidal action and allow them to air dry. Next, go to the nearest handwashing area and wash your hands and all potentially exposed skin thoroughly with non-abrasive soap and running water.

9. Equipment decontamination. A person trained in the appropriate procedures must decontaminate and sterilize all non-disposable equipment and tools used, such as mops, buckets and re-usable gloves, as soon as possible.

No complacency
Factory or construction site, chemical, plastics or food and beverage processing plant — no matter what the workplace — there should be no toleration of complacency when there is potential for exposure to bloodborne pathogens and other infectious disease. The effects of exposure may not be immediate, but there is a definite potential for serious illness and eventual death.

Lisa J. Burns, Q.S.S.P. Lisa is associate product manager-personal protection- Americas at North by Honeywell. She is a member of the International Safety Equipment Association and a Qualified Safety Sales Professional. Lisa can be reached at (401) 275-2608 or by e-mail at Lisa.J.Burns@Honeywell.com.

In general, health care management emphasizes the prevention of impairment and disability through early detection, prompt treatment, and timely recovery. Medical management responsibilities fall on employers, employees, and health care professionals (HCPs). A medical management program can help to either eliminate or substantially reduce the risk of development of ergonomics-related problems and symptoms through early identification and treatment.

Identifying and addressing signs and symptoms at an early stage helps to slow or halt the progression of the disorder. When MSDs are caught early, they are more likely to be reversible, to resolve quickly, and not to result in disability or permanent damage. Early intervention plays a big part in reducing the need for surgery.

Employer Responsibilities

An employer’s basic obligation is to make MSD management available promptly to employees with work-related MSDs. In other words, MSD management means that you have established a process for assuring that employees receive timely attention for it, including, if appropriate, work restrictions or job accommodation and follow-up.

Where there is no onsite HCP, an individual should be designated to receive and respond promptly to reports of MSD signs, symptoms, and hazards. Where there is an onsite HCP, he or she would be the likely person to have responsibility for MSD management, including referral as appropriate.

An effective MSD management program has:

  1. A method for identifying available appropriate work restrictions and promptly providing them when necessary;

  2. A method for ensuring that an injured employee has received appropriate evaluation, management, and follow-up in the workplace;

  3. A process for input from persons contributing to the successful resolution of an employee’s covered MSD; and

  4. A method for providing relevant information and communicating with the safety and health professionals and HCPs involved in the process.

Employee Responsibilities

Employees should participate in the health care management process by:

  • Following applicable workplace safety and health rules,

  • Following work practice procedures related to their jobs, and

  • Reporting early signs and symptoms of MSDs.

Employees may be faced with conflicting job demands or requirements. Safe work practices or rules may conflict with pressures or incentives to be more productive.

Health Care Professional Responsibilities

Health care professionals who evaluate employees, determine employees’ functional capabilities, and prepare opinions regarding work relatedness should be familiar with employee jobs and job tasks. With specific knowledge of the physical demands involved in various jobs and the physical capabilities or limitations of employees, the HCP can match the employees’ capabilities with appropriate jobs. Being familiar with employee jobs not only assists the HCP in making informed case management decisions but also assists with the identification of ergonomic hazards and alternative job tasks.

The health care professional should:

  • Acquire experience and training in the evaluation and treatment of MSDs.

  • Seek information and review materials regarding employee job activities.

  • Ensure employee privacy and confidentiality to the fullest extent permitted by law.

  • Evaluate symptomatic employees including:

    • Medical histories with a complete description of symptoms,

    • Descriptions of work activities as reported by the employees,

    • Physical examinations appropriate to the presenting symptoms and histories,

    • Initial assessments or diagnoses,

    • Opinions as to whether occupational risk factors caused, contributed to, or exacerbated the conditions, and

    • Examinations to follow-up symptomatic employees and document symptom improvements or resolutions.

OSHA said its Site-Specific Targeting 2009 program will focus enforcement efforts on nearly 4,000 high-hazard worksites on the agency’s list for comprehensive safety inspections. The agency said the SST program helps it direct enforcement resources to workplaces such as manufacturing and nursing homes where the highest rate of injuries and illnesses occur.

Changes to this year’s program include dividing the primary list of establishments slated for inspection into three sectors–manufacturing, non-manufacturing, and nursing homes. Rather than using one rate for all establishments, OSHA established minimum injury and illness rates for each group, allowing the agency to inspect even more establishments that exceed the minimum rates specific to that sector. Additionally, some facilities that did not answer an OSHA Data Initiative survey will be added to the inspection list. The agency said its intent is to deter employers from not responding to avoid inspection.

“These inspections examine all aspects of a workplace’s operations and the effectiveness of its safety and health efforts,” said acting Assistant Secretary of Labor for OSHA Jordan Barab. “The SST program emphasizes to employers the importance of ensuring safe working conditions for workers.”

The SST-09 inspection program is based on injury and illness data from the agency’s 2008 Data Initiative survey of 80,000 employers, with 40 or more workers, in industries with historically high occupational injury and illness rates. The primary and secondary lists show case rates calculated from the number of days away from work, restricted work activity or job transfer (DART), or a “days away from work injury and illness” (DAFWII) rate.

The primary list includes 3,100 manufacturing establishments with a DART rate of 8 or more, or a DAFWII rate of 6 or more. The 500 non-manufacturing establishments have a DART rate of 15 or more or a DAFWII rate of 13 or more. The remaining 300 establishments are nursing homes and personal care facilities with DART or DAFWII rates of 17 or more or 14 or more, respectively.

The secondary list shows establishments in manufacturing with a DART rate between 6 and 8, or a DAFWII rate between 4 and 13; non-manufacturing with a DART rate between 6 and 15, or a DAFWII rate between 4 and 13; and nursing homes and personal care facilities with DART or DAFWII rates between 15 and 17 or between 11 and 14, respectively.

The Hazardous Waste Operations and Emergency Response Standard (HAZWOPER) applies to five distinct groups of employers and their employees. These include any employees who are exposed or potentially exposed to hazardous substances — including hazardous waste — and who are engaged in one of the following operations:

clean-up operations — required by a governmental body, whether federal, state, local, or other involving hazardous substances — that are conducted at uncontrolled hazardous waste sites;

corrective actions involving clean-up operations at sites covered by the Resource Conservation and Recovery Act of 1976 (RCRA) as amended (42 U.S.C. 6901 et seq.);

voluntary clean-up operations at sites recognized by federal, state, local, or other governmental body as uncontrolled hazardous waste sites;

operations involving hazardous wastes that are conducted at treatment, storage, and disposal facilities regulated by Title 40 Code of Federal Regulations Parts 264 and 265 pursuant to RCRA, or by agencies under agreement with U.S. Environmental Protection Agency to implement RCRA regulations; and

emergency response operations for releases of, or substantial threats of releases of, hazardous substances regardless of the location of the hazard.

(More information can be found in osha documents as specified by 1910.120 and 1926.65)

OSHA has authorized several specific HAZMAT training courses know has the hazwoper training courses.These courses are comprised of the 40 hour hazwoper, 24 hour hazwoper and the 8 hour hazwoper refresher course.

Many OSHA authorized sites like OSHAu.co offer hazwoper training courses online.These courses can be administered in self-paced, downloadable modules which allow the student to complete the required training at their leisure.Online training also provides employers with the benefit of allowing their employees to take the required training from any internet-based computer eliminating travel costs and while maintaining productivity. The benefits of online training are realized through increased safety and health of employees and an increased protection of our environment and it’s resources.

 

AIHA Asks OSHA to Lower Noise Exposure PEL

EHS Today, reported by Laura Walter 

 

In an April 28 letter to OSHA Acting Assistant Secretary Jordan Barab, American Industrial Hygiene Association (AIHA) President Lindsay E. Booher asked OSHA to take immediate action to lower the Permissible Exposure Limit (PEL) for occupational noise exposure.

AIHA requested the PEL to be lowered to 85 dBA (as an 8-hour time-weight average) and to adopt the 3 dB exchange rate, changes AIHA “strongly believes” are appropriate for both general industry and construction standards.

“One of the greatest challenges and concerns we now face in the United States is the hearing loss that is occurring in our work force,” Booher wrote. “Over 30 million workers are exposed to hazardous levels of noise, and noise-induced hearing loss is one of the most common occupational diseases. Such hearing loss significantly affects the ability to communicate and negatively impacts a worker’s quality of life.”

According to the letter, even a compliant hearing conservation program – where workers are exposed up to 90 dBA TWA with no hearing protection – “will yield up to 26 percent excess risk of material hearing impairment over the course of a working lifetime.” Lowering the PEL to 85 dBA, however, could reduce the number of workers at risk by at least one half.

“The vast majority of the nations of the world regulate workers’ noise exposures at lower levels than the U.S. In fact, the U.S. is one of only two nations that still uses the 90 dBA PEL and is one of only three nations that uses the 5 dB exchange rate,” Booher wrote. “As a result, American workers are allowed exposure to noise levels that would result in more hearing loss than the rest of the world.”

The letter also pointed out that many agencies and organization in the United States use or recommend the lower exposure limit, including the National Institute for Occupational Safety and Health (NIOSH) and the American Conference of Governmental Industrial Hygienists (ACGIH). Furthermore, lowering the PEL could help streamline hearing conservation program management by adopting a single threshold for all engineering controls, training, hearing protection and hearing conservation programs.

“AIHA urges OSHA to take immediate action on this issue to ensure that American workers are afforded the same level of protection from hazardous noise that the majority of the world’s nation provide their workers,” Booher wrote.

A Confined Space Safety Policy can be divided into 9 sections.
This article briefly describes the nine parts of a comprehensive yet efficient confined space safety program.

1 - Purpose - The confined space safety policy states the requirements for the identification and safe entry into both permit required and non-permit required confined spaces.  The policy applies to areas of the workplace not designed for continuous occupancy and containing recognized serious safety or health hazards.
2 - Reference - OSHA 29 CFR 1910.146
3 - Scope - Applicable to all of the business’s employees, visitors and contractors.
4 - Administration - Variable, but generally administration of the confined space policy is by safety coordinators, supervisors, engineers and other trained managerial staff.
5 - Definitions - Can be standard, see: OSHA, Occupational Safety and Health Act
6 - Descriptions -

Confined Space is an area/space where an employee: - has limited openings for entry and egress; - can bodily enter and which is large enough to perform assigned work; - could be engulfed by bulk materials; - is not intended to continuously occupy.
Non-Permit Required Confined Space is a confined space neither containing nor having the potential to contain any hazard.
Permit Required Confined Space is a confined space with: - a hazardous atmosphere or potential for it; - material that could engulf an entrant; - converging/tapering walls/floors that could entrap or asphyxiate; - a recognized hazard.
Procedures Followed For All Permit Required Confined Space Entry
- - Permit
- - Issuance - By the supervisor, mandatory for the employee, one shift in duration.
- - Cancellation - At shift end or on job completion.
- - Retention - Must be reviewed and kept. -
- - Alternate Entry/Space Reclassification - Specific ref: OSHA 29 CFR 1910.146 (c)(5)/(c)(7)
- - Pre-Entry Briefing - By permit issuing entry supervisor.
- - Contractor Notification - Outside contractor adheres to procedures - compliance must be assured.
- - Lighting Requirements - Natural, auxiliary, emergency.
- - Special Tools and Equipment - Intrinsically safe in flammable or combustible atmosphere.
- - Preparation and Hazard Control - Preventing engulfment, burns. Lockout/tagout procedures.
- - Assuring adequate ventilation.
- - Pre-Entry Atmospheric Testing - Includes employee training with testing equipment.
- - Monitor Calibration and Testing
- - Field and Manufacturer Testing.
- - Attendant Duties - Mandatory for permit required confined space entry, no other duties.
- - Entry Supervisor Duties - Trained and authorized entry supervisor.
- - Safety Equipment - PPE, non-entry rescue, rescue, general.
- - Equipment Inspection - Per manufacturer’s recommendation.
- - Handling Problems
- - Rescue and Emergency Services - Documented, available, trained, equipped.
- - Summoning Rescue Services Procedure

7 - Responsibilities - Employees and Entry Supervisor - Safety Coordinators - Supervisors - Contractors
8 - Training - Initial - Refresher - Annual
9 - Revision - Annually by Safety Coordinators

These are the nine parts of a Confined Space Safety Policy.
Fleshed out details of just such a policy can be read at Confined Space Safety Policy

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