OSHA 2017 Summary for the Colorado Chapter of the National Utility Contractors Association (NUCA)

Transcription

1 OSHA 2017 Summary for the Colorado Chapter of the National Utility Contractors Association (NUCA) Todd Flick Assistant Area Director Denver Area Office

2 Topics Fiscal Year 2017 Summary OSHA Emphasis Programs Regulatory Changes OSHA Initiatives Resources

3 Colorado Year in Review FY Fatalities (14 FY 2016, 24 FY 2015) 1,120 Inspections (1158 FY 2016,1429 FY 2015) 84% Safety and 16% Health 58% Construction 32% In-compliance ~ 63% Inspections with violations ~ 62% Violations - serious

4 Colorado Year in Review FY Violations Issued (1597 FY 2016, 1723 FY2015) $4,543,835 in proposed penalties $3, FY 2016, $4,279,279 FY 2015 $3,737 average initial penalty for serious violation 32% reduction in penalty 4.7% contested

5 Colorado Fatalities FY Oil and Gas General Industry Construction Total

6 Colorado Fatalities Brief Facts FY fatalities Weld - 3 Denver - 3 El Paso - 2 Broomfield -1 Arapahoe - 1 La Plata - 1 Garfield - 1 Summit fatalities struck by objects 6 fatalities in construction 1 fatality in oil and gas 1 electrocution 1 explosion 1 drowning 30% involved being struck by object

7 Top Ten Violations Most frequently cited OSHA standards during FY 2017 inspections 1. Fall Protection General Requirements ( ) 2. Hazard Communication ( ) 3. Scaffolding ( ) 4. Respiratory Protection ( ) 5. Lockout/Tagout ( ) 6. Ladders ( ) 7. Powered Industrial Trucks ( ) 8. Machine Guarding ( ) 9. Fall Protection Training Requirements ( ) 10. Electrical Wiring Methods ( )

8 OSHA Specific Standards Most Frequently Cited Violations in Colorado FY Fall Protection, General (b)(13) 2. General Safety & Health (b)(2) 3. Hazard Communication written program (e) 4. Hazard Communication Training (GHS) (h) 5. Eye and Face Protection (a)(1) 6. Ladder use extend 3 above (b)(1) 7. Machine guarding (a)(1) 8. Respiratory protection medical evaluation (e)(1) 9. Respiratory protection program (c)(1) 10. Respiratory protection evaluate respiratory hazards (d)(1)(i) *Above make up 44% of the penalties

9 Top Ten Violations: FY 2017 (with top 5 sections cited) 1) Fall Protection (b)(13) (4,257 violations) fall protection in residential construction (b)(1) (1,055 violations) unprotected sides and edges (b)(10) (589 violations) roofing work on lowslope roofs (b)(11) (485 violations) steep roofs (b)(4)(i) (143 violations) protection from falling through holes, including skylights

10 Top Ten Violations: FY 2017 (with top 5 sections cited) 2) Hazard Communication (e)(1) (1,520 violations) written hazard communication program (h)(1) (1,233 violations) employee information and training (g)(8) (459 violations) maintaining copies of Safety Data Sheets in the workplace and ensuring that they are readily available to employees (g)(1) (338 violations) having Safety Data Sheets in the workplace for each hazardous chemical (h)(3)(iv) (192 violations) training on details of employer s hazard communication program

11 Top Ten Violations: FY 2017 (with top 5 sections cited) 3) Scaffolding (g)(1) (606 violations) fall protection (e)(1) (483 violations) providing access (b)(1) (374 violations) platform construction (g)(1)(vii) (298 violations) use of personal fall arrest or guardrail systems (c)(2) (181 violations) foundation for supported scaffold poles, legs, posts, frames, and uprights

12 Top Ten Violations: FY 2017 (with top 5 sections cited) 4) Respiratory Protection (e)(1) (605 violations) medical evaluation to determine employee s ability to use a respirator (c)(1) (495 violations) written respiratory protection program (f)(2) (277 violations) fit testing for employees using a tight-fitting face piece respirator: testing frequency (c)(2)(i) (239 violations) providing respirators at request of employees or permitting employees to use their own respirators (d)(1)(iii) (225 violations) respirator selection: evaluation of respiratory hazards in workplace

13 Top Ten Violations: FY 2017 (with top 5 sections cited) 5) Lockout/Tagout (c)(4)(i) (622 violations) developing, documenting, and utilizing energy control procedures (c)(6)(i) (384 violations) periodic inspection of energy control procedure at least annually (c)(1) (373 violations) establishing an energy control program (c)(7)(i) (288 violations) training on the energy control program (d) (178 violations) elements of lockout/tagout procedures

14 Top Ten Violations: FY 2017 (with top 5 sections cited) 6) Ladders (b)(1) (1,454 violations) extending portable ladder side rails at least 3 feet above upper landing surface (b)(4) (333 violations) using ladders only for purpose for which they were designed (b)(13) (219 violations) not using the top or top step of a stepladder as a step (b)(16) (108 violations) marking or tagging portable ladders with structural defects and removing them from service (b)(6) (79 violations) using ladders only on stable and level surfaces unless secured

15 Top Ten Violations: FY 2017 (with top 5 sections cited) 7) Powered Industrial Trucks (l)(1)(i) (455 violations) operator training: ensuring that operators are competent to safely operate a powered industrial vehicle as demonstrated by completion of training and evaluation (l)(4)(iii) (254 violations) refresher training and evaluation: evaluation of operator s performance must be conducted at least once every three years (p)(1) (232 violations) not taking powered industrial trucks out of service when in need of repair, defective, or unsafe (l)(6) (225 violations) certification of operator training and evaluation (q)(7) (171 violations) examining powered industrial trucks daily or after each shift before placing them in service

16 Top Ten Violations: FY 2017 (with top 5 sections cited) 8) Machine Guarding (a)(1) (1,334 violations) providing one or more methods of machine guarding (a)(3)(ii) (499 violations) point of operation guarding (b) (104 violations) anchoring fixed machinery (a)(2) (75 violations) affixing guards to the machine (a)(5) (43 violations) guarding fan blades

17 Top Ten Violations: FY 2017 (with top 5 sections cited) 9) Fall Protection, Training (a)(1) (1,237 violations) training program for each employee who might be exposed to fall hazards (b)(1) (245 violations) written training certification (a)(2) (80 violations) training by a competent person qualified in specified areas (c)(3) (61 violations) retraining required when inadequacies in employee s knowledge or use of fall protection systems or equipment indicate that the employee has not retained the requisite understanding or skill (a)(2)(iii) (35 violations) training by a competent person on fall protection to be used, including guardrail, personal fall arrest, safety net, warning line, and safety monitoring systems, and controlled access zones

18 Top Ten Violations: FY 2017 (with top 5 sections cited) 10) Electrical, Wiring Methods (g)(1)(iv)(A) (277 violations) using flexible cords and cables as a substitute for the fixed wiring of a structure (g)(2)(iii) (252 violations) connecting flexible cords and cables to devices and fittings so that strain relief is provided that will prevent pull from being directly transmitted to joints or terminal screws (b)(1)(ii) (215 violations) closing unused openings in cabinets, boxes, and fittings (b)(2)(i) (198 violations) providing pull boxes, junction boxes, and fittings with covers identified for the purpose (b)(1)(i) (73 violations) protecting conductors entering cutout boxes, cabinets, or fittings from abrasion

19 FY 2018 National Emphasis Programs (NEPs) Amputations in Manufacturing Lead Exposures (GI and Construction) C-Target Construction Hexavalent Chromium Exposures Chemical Processing Safety Combustible Dust Trenching and Excavation Primary Metals Industries (Foundries) Federal Agencies based on injury rates

20 FY 2018 Regional and Local Emphasis (REP/LEPs) Regional Emphasis Programs Fall Hazards in Construction Roadway Work Zone Activities Oil and Gas Industry Grain Handling Facilities Workplace Violence in Residential Intellectual and Developmental Disability Facilities Local Emphasis Programs Hazards in Automotive Services (Englewood) Asbestos Abatement (Englewood) Scrap & Recycling (Englewood) Aircraft Support and Maintenance Facilities (Englewood) Beverage handling (Englewood)

21 New Standards and Policies Confined Spaces in Construction Respirable Silica Walking Working Surfaces Beryllium Injury/Illness Reporting Electronic Recordkeeping

22 OSHA s Respirable Crystalline Silica Rule for Construction

23 Silica Standard (Respirable Crystalline Silica) Current permissible exposure limits (PELs) are hard to understand General industry formula PEL is about equal to 100 µg/m 3 ; construction = 250 µg/m 3 Current PELs do not adequately protect workers Epidemiologic evidence that lung cancer/silicosis occur at exposure levels below 100 µg/m3 New PEL 50ug/m3

24 Exposure and Health Risks Exposure to respirable crystalline silica has been linked to: Silicosis; Lung cancer; Chronic obstructive pulmonary disease; and Kidney disease Healthy Lung Silicotic Lung 24

25 Respirable Silica Construction/GI (a) Scope (b) Definitions (c) Specified exposure control methods (const) OR (d) Alternative exposure control methods (const) PEL Exposure Assessment Methods of Compliance (e) Respiratory protection (f) Housekeeping (g) Written exposure control plan (h) Medical surveillance (i) Communication of silica hazards (j) Recordkeeping (k) Dates (e) Regulated areas (GI) (f) Methods of compliance (GI) (1) Engineering and work practice controls (2) Written exposure control plan 25

26 Equipment / Task Handheld power saws (any blade diameter) Example of Table 1 Entry Engineering and Work Practice Control Methods Use saw equipped with integrated water delivery system that continuously feeds water to the blade. Required Respiratory Protection and Minimum APF 4 hr/shift > 4 hr/shift Operate and maintain tool in accordance with manufacturers instruction to minimize dust - When used outdoors - When used indoors or in an enclosed area 26 None APF 10 APF 10 APF 10

27 Engineering Controls Grinding without engineering controls Grinding using a vacuum dust collector 27

28 Construction Competent Person Construction employers must designate a competent person to implement the written exposure control plan Competent person is an individual capable of identifying existing and foreseeable respirable crystalline silica hazards, who has authorization to take prompt corrective measures Makes frequent and regular inspection of job sites, materials, and equipment 28

29 Written Exposure Control Plan The plan must describe: Tasks involving exposure to respirable crystalline silica Engineering controls, work practices, and respiratory protection for each task Housekeeping measures used to limit exposure 29

30 Communication of Hazards Employers required to comply with hazard communication standard (HCS) (29 CFR ) Address: Cancer, lung effects, immune system effects, and kidney effects as part of HCS Train workers on health hazards, tasks resulting in exposure, workplace protections, and medical surveillance. 30

31 Construction Compliance Dates Employers must comply with all requirements (except methods of sample analysis) by September 23, 2017 Compliance with methods of sample analysis required by June 23,

32 Assistance to Small Businesses 32

33 Many examples of controls on 33

34 Electronic Reporting Injury and Illness Records (OSHA 300s) (a)(1) Establishments with 250 or more employees in industries covered by the recordkeeping rule: Must, on an annual basis, provide data from the: Summary Form 300A Log Form 300 Incident Report 301 Does not include the injured worker s name and address Does not include the physician s name and address

35 Electronic Reporting (a)(2) covered Industries Ag., forestry and fishing (NAICS 11) Utilities (NAICS 22) Construction (NAICS 23) Manufacturing (NAICS 31-33) Wholesale Trade (NAICS 42) Industry groups (4-digit NAICS) with a three year average DART rate of 2.0 or greater in the Retail, Transportation, Information, Finance, Real Estate and Service sectors. Full list: sforelectronicsubmission.pdf

36 Timeline for Reporting OSHA 300 information Final Rule Federal Register Notice May 12, 2016 Employee Rights effective date August 10, 2016 Electronic Reporting effective Date January 1, 2017 Phase-in data submission due dates New date moved from July 1, 2017 to December 1, 2017

37 Injury Tracking Application (ITA) The ITA was successfully launched August 1, 2017 Employers can access the application from the ITA landing page at

38 Injury Tracking Application (ITA) ITA is a secure website with 3 options for data submission: o Manually enter data into a webform o Upload CSV file to process single of multiple establishments at the same time o Users of automated recordkeeping systems can transmit data electronically via an Application Programming Interface (API)

39 Injury Tracking Application (ITA): Get Started

40 Injury Tracking Application (ITA): Submit Data to OSHA

41 Injury Tracking Application (ITA): Add 300A Summary

42 Beryllium Published as final rule January 9, 2017 Effective date of May 20, 2017 Compliance with most provisions required within one year March 12, 2018 Proposed rule on construction and maritime published on June 27, 2017 modifying the new standard Beryllium Final Rule website: Contains the rule, overview, FAQ and links to other info including the archived proposed rule page

43 Beryllium Reasons for the rule: Health dangers have been know for decades Chronic Beryllium Disease (sensitization) Lung Cancer OSHA s current PEL is outdated and ineffective for preventing disease New PEL.2ug/m3 2ug/m3 STEL The technology to meet the new standards is widely available and feasible

44 Walking Working Surfaces 29 CFR 1910 General Industry

45 Walking and Working Surface Rule effective January 17, Scope, Application and Definitions General Requirements Ladders Step bolts and Manhole Steps Stairways Dockboards Scaffolds and Rope Descent Systems Duty to Have Fall Protection Fall Protection Systems Criteria and Practices Training Requirements

46 Severe Injury Reporting RAPID RESPONSE INVESTIGATION (RRI) About 870 reported in Colorado since 1/1/15 37% inspections, 90% hospitalizations Collaborative, problem-solving approach Invites an employer and an OSHA Area Office expert to work together toward shared goal: Find and fix hazards, and improve overall safety

47 Severe Injury Reporting: Reporting leads to productive interactions with OSHA Most employers are eager to cooperate with OSHA to prevent similar or worse worker injuries Many employers went above and beyond OSHA requirements Some employers continued to put workers at risk and conceal hazards

48 We Can Help OSHA s Initiatives Heat Illness Prevention

49 Safe + Sound Campaign Transformational: Improves workplace culture Good for workers and businesses bottom line Targets small and medium-sized businesses OSHA encourages this program for every business National Safe + Sound Week: 2018 TBD

50 Safety and Health Programs Recommended Practices Based on best thinking and experiences of successful employers Will help small and medium-sized employers find and fix hazards before workers are harmed Shows how multiple employers on same worksite can coordinate efforts to ensure all workers are given equal protection

51 Safety and Health Programs Seven Core Elements Management leadership Worker participation Hazard identification and assessment Hazard prevention and control Education and training Program evaluation and improvement Coordination and Communication on Multi-Employer Worksites

52 Fall Prevention Campaign FALLS are the leading cause of deaths in construction 37% of all construction fatalities In 2015, 648 workers were killed at work from falls to lower levels. 54% were in construction Millions of employers and workers participate in annual National Safety Stand-Down to prevent falls events nationwide

53 Stop worker falls Following a dramatic decline, communication towers-related worker deaths have risen again 3 6 Source: U.S. Department of Labor Occupational Safety and Health Administration

54 Protecting Temporary Workers: A joint responsibility Both host employers and staffing agencies have roles in complying with workplace health and safety requirements and they share responsibility for ensuring worker safety and health. Legally, both the host employer and the staffing agency are employers of the temporary worker. Shared control over worker = Shared responsibility for worker

55 Protecting Young Workers Workers <25 years old were twice as likely to end up in the emergency room as those 25 and older osha.gov/youngworkers

56 Whistleblowers.gov

57 Whistleblower Protections Retaliation against workers Bad for workers and bad for business When workers fear retaliation for speaking up, problems in the workplace go unreported and become costlier to fix.

58 Compliance Assistance OSHA helping employers HG new info- 21 million visitors to OSHA s website in FY ,000 responses to OSHA calls for help 21,000 Spanish-speaking callers helped 16,000 requests for assistance answered 5,000 outreach activities by Regional & Area Offices 27,800 small businesses helped through Consultation

59 Cooperative Programs Alliance Program OSHA Strategic Partnership Program Voluntary Protection Programs (VPP) OSHA Challenge On-site Consultation Program & Safety and Health Recognition Program (SHARP)

60 We

61 On-site Consultation with Colorado State University

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65 Thank You for listening and Questions??? participating

66 OSHA (6742)

67 Disclaimer This information has been developed by an OSHA Compliance Assistance Specialist and is intended to assist employers, workers, and others as they strive to improve workplace health and safety. While we attempt to thoroughly address specific topics, it is not possible to include discussion of everything necessary to ensure a healthy and safe working environment in a presentation of this nature. Thus, this information must be understood as a tool for addressing workplace hazards, rather than an exhaustive statement of an employer s legal obligations, which are defined by statute, regulations, and standards. Likewise, to the extent that this information references practices or procedures that may enhance health or safety, but which are not required by a statute, regulation, or standard, it cannot, and does not, create additional legal obligations. Finally, over time, OSHA may modify rules and interpretations in light of new technology, information, or circumstances; to keep apprised of such developments, or to review information on a wide range of occupational safety and health topics, you can visit OSHA s website at