Who Is OSHA? Who Is PERRP?

Transcription

1

2 Who Is OSHA? Who Is PERRP? Occupational Safety and Health Administration Public Employment Risk Reduction Program Both agencies are responsible for worker safety and health protection. 2

3 PERRP History o o o o o o 1970 Federal OSHA created (public employees exempted from coverage) 1973 Governor s executive order signed providing safety and health protection for executive branch state employees (OPESH) 1992 Ohio Public Employment Risk Reduction Act passed (House Bill 308); OPESH becomes PERRP extending coverage to most local government employees July 1994 the Act went into full effect July 2005 PERRP became part of the Ohio Bureau of Workers Compensation July 2017 PERRP significant R.C amendments 3

4 PERRP Purpose o Ensure public employees in Ohio have a safe and healthy work environment by: Identifying workplace hazards and reducing those hazards through effective safety and health programs. Developing and enforcing mandatory job safety and health standards. Maintaining a reporting and recordkeeping system to monitor job-related injuries and illnesses. Providing assistance, training and other support programs to help public employers and workers understand their rights and responsibilities. 8

5 Employer and Employee Responsibilities o Each public employer in Ohio must: Provide a place of employment free from recognized hazards. This requirement is known as the, General Duty Clause. o Each public employee in Ohio must: Comply with all safety and health regulations; and Any reasonable safety and health policies developed by their employer. ORC ORC

6 What Is Enforced? Regulatory elements of the PERR Act o The federal OSHA regulations 29 CFR Parts 1910, 1926 and 1928 o Chapters 4167 of the Ohio Administrative Code and Ohio Revised Code General Duty Clause (A)(1) Workplace safety poster Injury and illness recordkeeping Ohio Manual on Uniform Traffic Control Devices 10 CFR 20 (Radiation Protection) ORC

7 PERRP Standards o PERRP is required to adopt OSHA standards with 120 days when OSHA adopts, modifies, or revokes a federal standard. PERRP is not obligated to apply OSHA enforcement policies that are not part of the rulemaking process.

8 The required PERRP poster replaces OSHA posters in Ohio governmental workplaces! PERRP OSHA 8

9 PERRP Recordkeeping Forms o o o o 300P Log of Work-Related Injuries and Illnesses Employer must maintain all forms, including 300P, for each establishment and kept on site for five years. 300AP Summary of Work-Related Injuries and Illnesses Employer must submit the 300AP to PERRP by Feb. 1 of each year. 301P Injury and Illness Incident Report Employer must complete the 301P or equivalent for each recordable incident. The forms clarify the requirements for public employers and reference the appropriate sections in the ORC/OAC. 9

10 Recent Statute Changes HB 27 June 30, 2017 amended Revised Code Chapter 4167

11 Ohio Revised Code 4167 o The Ohio BWC biennium budget included amendments to the following statutes in Revised Code, Chapter 4167: Definitions Director to enforce program Inspection procedures Exemption from program (repealed) o Effective date of the amendments is 09/29/2017.

12 ORC Amendments o Change in the definition of public employee extended PERRP Coverage extended to firefighters, EMTs, EMT-Ps, and local correctional officers. o State correctional officers were previously covered by the Act. Peace officers (e.g., police officers, deputy sheriffs, DNR officers, etc.) are still excluded from PERRP coverage.

13 ORC Amendment o Safety Partnership Agreement program created in to replace All public employers (PES and PEC) will be eligible to participate Program will recognize public employers that have exemplary safety and health programs Program participants will be encouraged to serve as mentors for other PEs Program participants will be excluded from PERRP general schedule inspections.

14 Safety Partnership Agreement o Participation Requirements 1. The public employer has an active workers compensation policy and is current with respect to all payments due the bureau; 2. The public employer has an injury and illness history that is less than the aggregate incidence rate for all Ohio public employment sectors; 3. The public employer must establish and maintain a safety committee; 4. The public employer must not have any open, unresolved, or outstanding enforcement actions; and 5. The public employer must agree to comprehensive employment risk reduction inspections. 14

15 ORC Amendments o Scheduled inspections added to the list of enforcement inspections. General schedule inspections will focus on high-risk employers and high hazard work activities Amendment requires an OAC 4167 rule that will explain the inspection criteria Inspection rule will require inspections to be conducted according to a policy and procedures manual (PERRP Field Operations Manual) o Enforcement inspections to be conducted without delay.

16 PERRP Inspection Priorities Priority 1st 2nd 3rd 4th 5th Category of Inspection Refusal to Work: Reasonable certainty an immediate danger exists Fatality/Multiple Hospitalization: Reported to PERRP within eight hours; inspected ASAP Complaints: Worker or worker representative can file a complaint about a safety or health hazard General Schedule Inspections: Inspection schedule based upon high risk workplaces and work tasks (beginning Spring 2018) Compliance Assistance Inspections: Voluntary inspections encourage a pro-active approach to addressing workplace hazards

17 Compliance The foundation of an effective safety and health program isn t complete until you meet the minimum requirements! Lab safety Noise PRCS HAZWOPER PSM LO/TO PPE HAZCOM BBP EAP 300P LOG 300AP 301P/FROI

18 PERRP High Hazard Focus

19 PERRP High Hazard Focus o Ohio Manual of Uniform Traffic Control o Trenching and Excavation o Hazards of tree felling and trimming operations o Confined Space Entry and Work 19

20 OMUTCD

21 Temporary Traffic Control Plan o Temporary traffic control zone was not an integral part of work operations. Temporary traffic control plan was not developed or an appropriate typical application from the manual was not identified and implemented. 21

22 22

23 Advanced Warning o Advanced warning was not provided to motorists. 23

24 24

25 Flagger position o Flagger was not positioned in advance of work zone or; o Flagger was improperly positioned in the center of the roadway. 25

26 26

27 High Visibility Safety Apparel o Apparel performance class was not selected based upon an assessment of the work. i.e., Class 2 or Class 3 o Workers were not wearing high visibility safety apparel, or; o Apparel was improperly maintained and remained in use beyond its useful service life. 27

28 28

29 Trenching Hazards

30 What s wrong with this picture? Worker outside protective system!

31 What s wrong with this picture? Inadequate Access! No Protective System!

32 What s wrong with this picture? Too Close! Unsafe Access! No Protective System! No PPE!

33 T&E Summary o The greatest risk in an excavation is a cavein. o Employees can be protected through sloping, shielding, and shoring the excavation. o A competent person is responsible to inspect the excavation and protect employees. o Other excavation hazards include water accumulation, oxygen deficiency, toxic vapors or fumes, falls, and mobile equipment.

34 Tree Work Hazards 34

35 Hazards of tree felling and trimming o PERRP and OSHA Region 5 both have an emphasis program to conduct inspections on these hazards. o PERRP focus began in April 2014, OSHA began its program in October

36 Permit Required Confined Spaces: 29 CFR & 1926 Subpart AA Identification, evaluation and safe entry requirements for confined spaces in public employment workplaces PERRP

37 Confined Space means: o The location is large enough, and configured, so that a person can bodily enter and perform assigned work; and o Has limited or restricted means of entry or exit; and o Is not designed for continuous human occupancy. 37

38 Permit Required Confined Space o A space that has one or more of the following characteristics: Contains or has a potential to contain a hazardous atmosphere; Contains a material that has the potential for engulfing an entrant; Has an internal configuration that may cause an entrant to be trapped or asphyxiated by inwardly converging walls or by a floor that slopes downward and tapers to a smaller cross-section; Contains any other recognized serious safety or health hazard. 38

39 Confined Space Hazards PERRP o Atmospheric o Physical Configuration o Mechanical o Electrical o Thermal o Noise o Vibration o Engulfment or Entrapment PERRP 39

40 The STATS According to the National Institute for Occupational Safety and Health (NIOSH), from 1983 to 1993*: Approximately 670 workers died in confined spaces. o 45% due to asphyxiation o 41% due to poisoning o 14% from drowning Asphyxiation Many of the victims were would-be rescuers. Poisoning Drowning *Source: Worker Deaths in Confined Spaces: A Summary of Surveillance Findings and Investigative Case Reports, NIOSH Publication, 4676 Columbia Pkwy., Cincinnati, OH

41 Fatal Fact o Wastewater treatment worker was working alone at a normally unmanned plant. o Employee was using a typical sampling cup to collect clarifier samples. o While collecting samples, the employee fell into the clarifier tank and was pulled under by the tank pump. PERRP PERRP 41

42 Fatal Fact o Crew of three workers were called on a weekend to respond to a flooded wastewater dry well. o Crew used a gasoline powered pump to empty well. o One crew member collapsed and died after entering drained well. o Second worker collapsed and was hospitalized after attempting to rescue first worker. PERRP PERRP 42

43 PRCS Evaluation Elements o As part of the overall written PRCS program, the PRCS evaluation must: Identify and evaluate the hazards of permit spaces before employees enter them; Identify the means, procedures, and practices necessary for safe permit space entry operations; Specify acceptable entry conditions and testing procedures to ensure acceptable conditions; Identify equipment necessary for safe permit space entry operations. 43

44 PRCS Program Elements o Prevent unauthorized entry: These procedures can include any effective actions, as long as they accomplish the desired goal. o Possible actions: Warning signs; Installing locks or covers, etc. o Identify and evaluate the hazards: Must be completed before employees enter a PRCS. 44

45 PERRP Top 10 Violations Common hazards identified during educational facility visits

46 # (a)(2)(i) o A portable cord and plug connected piece of equipment was not visually inspected for evidence of external or internal defects or damage. 46

47 # (a)(2)(i) PERRP PERRP PERRP 47

48 # (e)(2) o Monthly visual inspections were not completed of portable fire extinguishers (or fire hose).

49 # (e)(2) PERRP

50 # (a)(3)(ii) o Attachment plugs or receptacles were connected or altered in a manner which prevented proper continuity of the equipment grounding conductor. 50

51 # (a)(3)(ii) PERRP PERRP PERRP 51

52 # (b)(1)(ii) o Unused openings in electrical equipment were not effectively closed.

53 # (b)(1)(ii) PERRP PERRP PERRP

54 # (a)(4) o Abrasive wheel grinder work rest(s) was missing or it was improperly adjusted or installed.

55 # (a)(4) PERRP PERRP PERRP

56 #5: (f)(2) o Electrical circuits or disconnects were not labeled to indicate their purpose.

57 #5: (f)(2)

58 #4: (a)(3)(ii) o A machine guard was not provided to protect the operator and other employees in the machine area from point of operation hazards (e.g., ingoing nip points, rotating parts, flying chips and sparks.)

59 #4: (a)(3)(ii)

60 #3: (a)(4) o Safeguards designed to protect employees during an emergency were not in proper working order.

61 #3: (a)(4)

62 #2: (g)(1)(iv) o Flexible cords and cables were improperly used.

63 #2: (g)(1)(iv)

64 #1: (b)(2) o Listed or labeled electrical equipment was improperly used or installed.

65 #1: (b)(2)

66 PERRP Compliance Assistance PERRP

67 Compliance Assistance o Requests for assistance demonstrate an employer s Good Faith effort to achieve compliance! o PERRP offers these risk reduction services PERRP Safety surveys PERRP Health surveys PERRP Training

68 Compliance Services o PERRP provides compliance assistance services free of charge. o Submit requests by mail, fax, or on BWC s website: o You can also phone in a request to PERRP by calling the investigator/consultant in your area or by contacting the PERRP central office between 8 a.m. and 5 p.m. at:

69 Sources of information o BWC website: o Ohio Center for Occupational Safety and Health (OCOSH) courses o OSHA website: o National Institute for Occupational Safety and Health (NIOSH) OSHA s sister agency o OSHA Training Institute Education Centers o Ohio Forestry Association: o PERRP Compliance Investigators 69

70 PERRP Contact Information Ohio Bureau of Workers Compensation Public Employment Risk Reduction Program Yarmouth Drive Pickerington, Ohio PERRP s Main Number & Refusal to Work/ Fatality Hotline: BWC s Main Number: OHIOBWC

71 PERRP Compliance Regions