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CONN-OSHA Quarterly

Volume No. 47
Fall 2006

Public Schools: Requirements for Written Programs
By: Lisa Costanzo~Occupational Hygienist 

While conducting inspections in educational facilities, a number of public school administrators have expressed that they were not aware of the many requirements covered by CONN-OSHA standards, particularly with regard to those standards requiring written programs.  In some instances, they were aware of the written program requirements, but not of all the elements that need to be included or the requirements for reviewing/updating the program.  This article will provide a summary of three CONN-OSHA standards requiring a written program that are most commonly cited in public schools. 

One of the most frequently cited CONN-OSHA standards in public schools is 29 CFR 19Published by the Connecticut Department of Labor, Project Management Office.1200, Hazard Communication.  The purpose of the Hazard Communication standard is to ensure that the hazards of all chemicals are evaluated and that information concerning their hazards is transmitted to employers and employees.  The major elements of the Hazard Communication standard that typically apply to public schools and will be discussed in this article are:  the written hazard communication program and list of hazardous chemicals, labels and other forms of warning, material safety data sheets, and employee information and training. 

The Hazard Communication standard requires employers who use hazardous chemicals at their workplace to develop, implement, and maintain a written hazard communication program.  The written hazard communication program, like other written programs required by CONN-OSHA standards, provides a roadmap describing how the employer is going to comply with the required elements of the standard.  In addition, the written program must include a list of hazardous chemicals known to be present in the workplace.  When compiling this list, employers should be sure to check all areas of the school including, but not limited to, custodial closets, cafeterias, art rooms, woodworking rooms, and automotive shops. 

The Hazard Communication standard also requires the employer to ensure that each container of hazardous chemicals in the workplace is labeled with the identity of the hazardous chemical and appropriate hazard warnings.  The employer must also have a material safety data sheet (MSDS) in the workplace for each hazardous chemical they use and MSDS’s must be readily accessible to employees during each work shift.  Employees should not have to ask for an MSDS, as this could be perceived by employees as a barrier to access.  In addition, the employer must provide employees with effective information and training on hazardous chemicals at the time of initial assignment and whenever a new physical or health hazard that the employee has not previously been trained about is introduced into the work area.  The type of information and training to be provided is outlined in 19Published by the Connecticut Department of Labor, Project Management Office.1200 (h)(2) and (h)(3). 

Another CONN-OSHA standard frequently cited in public schools is 29 CFR 19Published by the Connecticut Department of Labor, Project Management Office.1450, Occupational Exposure to Hazardous Chemicals in Laboratories, also referred to as “The Lab Standard.”  This standard, often confused with the Hazard Communication standard, applies specifically to the laboratory use of hazardous chemicals, which is further defined in paragraph (b) of the standard. 

Similar to the identification requirements set forth in the Hazard Communication standard, the Lab Standard requires the employer to ensure that labels on incoming containers of hazardous chemicals are not removed or defaced, maintain any MSDS’s that are received with incoming hazardous chemicals, and ensure that MSDS’s are readily accessible to laboratory employees.  The employer also must provide employees with information and training as outlined in 19Published by the Connecticut Department of Labor, Project Management Office.1450 (f)(3) and (f)(4) prior to initial assignment to a work area where hazardous chemicals are present and prior to assignments involving new exposure situations.  The frequency and duration of refresher training shall be determined by the employer.  

This standard also requires that employers who fall within the scope of the standard develop and carry out the provisions of a written Chemical Hygiene Plan.  The written plan must include the following elements:  standard operating procedures to be followed when laboratory work involves the use of hazardous chemicals; criteria the employer will use to determine and implement control measures to reduce employee exposure to hazardous chemicals; specific measures to be taken to ensure proper and adequate performance of fume hoods and other protective equipment, such as eye wash stations and showers; provisions for employee information and training; the circumstances under which a particular laboratory procedure or activity requires prior approval from the employer; and provisions for medical consultation and medical examinations, when applicable.   

The plan also must designate personnel responsible for implementing the Chemical Hygiene Plan, including a Chemical Hygiene Officer, who through training or experience, is qualified to provide technical guidance in the development and implementation of the provisions of the plan.  In addition, the effectiveness of the Chemical Hygiene Plan must be reviewed and evaluated at least annually and be updated as necessary.  Appendix A to 19Published by the Connecticut Department of Labor, Project Management Office.1450, “National Research Council Recommendations Concerning Chemical Hygiene in Laboratories,” is a valuable resource which provides recommendations to assist employers in developing their own Chemical Hygiene Plans. 

The third of the most frequently cited standards requiring a written program is 29 CFR 19Published by the Connecticut Department of Labor, Project Management Office.Published by the Connecticut Department of Labor, Project Management Office30, Bloodborne Pathogens.  This standard is designed to eliminate or minimize occupational exposure to bloodborne pathogens including, but not limited to, Hepatitis B and Human Immunodeficiency Virus (HIV). 

Under 19Published by the Connecticut Department of Labor, Project Management Office.Published by the Connecticut Department of Labor, Project Management Office30, public school employers who have employees with occupational exposure (as defined by paragraph (b) of the standard) must establish an Exposure Control Plan which describes how the following elements of the standard, at a minimum, will be implemented:  methods of compliance, including engineering and work practice controls, personal protective equipment, and housekeeping; Hepatitis B Vaccination and Post-Exposure Evaluation and Follow-up; Communication of Hazards to Employees; and Recordkeeping, including medical records, training records, and Sharps Injury Logs.

The Exposure Control Plan also must include an exposure determination which lists all job classifications in which all employees in those job classifications have occupational exposure, all job classifications in which some employees have occupational exposure, and those tasks and procedures in which occupational exposure occurs and are performed by those employees determined to be occupationally exposed.  Any employee who has been determined to be occupationally exposed, as defined by the standard, must be offered the Hepatitis B vaccination within Published by the Connecticut Department of Labor, Project Management Office working days of initial assignment, but after the employee has received the initial training required by this standard. 

The Exposure Control Plan must be reviewed at least annually and updated whenever necessary to reflect new or modified tasks and procedures which affect occupational exposure and also to reflect new or revised employee positions with occupational exposure.  Although documentation of the review is not required, it is recommended that the employer do so to ensure that the review is being conducted at least on an annual basis and that each affected employee has access to the most current Plan. 

In addition to the annual review of the Exposure Control Plan, the employer must provide information and training as outlined in paragraph (g)(2)(vii) to employees with occupational exposure at the time of initial assignment to tasks where occupational exposure may take place, at least annually thereafter (which means within one year of their previous training), and whenever changes (i.e. to tasks or procedures) take place that affect the employee’s occupational exposure.  Training must be documented in accordance with paragraph (h)(2)(i) of the standard. 

It is important to note that all written programs must be site specific.  Very often employers obtain “canned” sample programs, but fail to modify them to their own site, work practices, and personnel.  When using template programs, be sure that all information contained in the program is specific to and meets the needs of your workplace. 

This article is intended to provide only a brief overview of three of the more commonly cited CONN-OSHA standards in public schools.  For more detailed information about the requirements of these standards that apply to a given workplace, employers should refer to the actual standards.  In addition to these standards, employers must comply with all CONN-OSHA standards applicable to their workplace.  For assistance in determining which standards or elements of a particular standard may apply to your workplace, contact CONN-OSHA’s free consultation program at (860) 263-6900.
 


Working Together for a Positive Change: The Connecticut Department of Environmental Protection and The Connecticut Department of Labor
By: Kenneth Neumann, Health and Safety Administrator, Connecticut Department of Environmental Protection
 

In October of 2005, the Connecticut Department of Environmental Protection (DEP) and The Connecticut Department of Labor, Division of Occupational Safety and Health (CONN-OSHA) entered into an alliance formalizing a history of over seven years of cooperative effort to reduce accidents and improve safety programs and performance at DEP. The DEP has approximately 900 full-time and 600 seasonal employees working at hundreds of locations across the state.  They perform a wide variety of occupational activities including: maintenance and operation of parks, forests, fish hatcheries, wildlife management areas, boats, vehicles, dams; buildings and air monitoring sites, law enforcement, environmental regulatory enforcement; oil and chemical spill response and much more. 

DEP began using CONN-OSHA’s services over seven years ago to provide needed training and assistance.  These services helped DEP meet regulatory needs, increase safety awareness and knowledge and eliminate unsafe practices, thereby helping to reduce accidents and injuries.  By 2003, OSHA recordable injuries had dropped almost in half and the incident rate had dropped by about one third of what they were in 1999.  From 2002 to 2005, injuries had dropped 58% and the rate dropped 67%. (See chart

This improvement was achieved by gradually changing the Department’s culture from “we’ve always done it this way” to  “ let’s do it right and safe.”  Progress was slow at the start, but a series of occurrences provided a catalyst that began to motivate change.  A CONN-OSHA enforcement inspection, a vehicular fatality and several serious injuries convinced DEP managers that they needed to change the safety related performance of their units.  Working with the DEP Health & Safety Office, CONN-OSHA helped provide training for trenching and excavation, ladders, scaffolds, respirators, hazard recognition, electrical safety, accident investigation and the Published by the Connecticut Department of Labor, Project Management Office hour OSHA Outreach course for both general industry and construction.  Employees and managers have learned that there are better ways to get jobs done safely and employees are less willing to engage in risky behavior or tolerate unsafe conditions.  DEP has utilized the CONN-OSHA consultation program to perform industrial hygiene monitoring, provide site safety audits, ergonomic assessments, and reviews of plans and policies.  In return, DEP has provided training to CONN-OSHA employees, such as HAZWOPER (Hazardous Waste Operations and Emergency Response) refreshers, and others. 

DEP and its employees have benefited significantly from the relationship and alliance with CONN-OSHA and look forward to the future progress in safety performance that this alliance will help bring about. 

DEP Injury Summary 2002 thru 2005

 

2002

2003

2004

2005

OSHA Recordable Injuries

78

44

39

33

OSHA Incident Rate

7.25

3.9

3.4

2.4

 

Alliance News... 

A new alliance was recently signed by CONN-OSHA, the OSHA Hartford area office, and the UCONN Health Center’s Occupational and Environmental Health Center.  The goal of the alliance is to provide small to medium sized employers and employees with a new technique of identifying workplace hazards that may require chemical exposure controls. 

For a more complete understanding of the technique, a Control Banding workshop will be held on Thursday, November 16, 2006 at the Rensselaer Hartford Campus.  To view the workshop agenda and for a registration form go to  http://www.oehc.uchc.edu/news/control_banding.htm .  For further information contact Anne Bracker at bracker@nso.uchc.edu or call (860) 679-2369. 


Hazard Corner  

Equipment Operator Seriously Injured In Asphalt Paver Rollover 

Background

In July of 2003, a local highway department was involved in an asphalt paving operation.  There were approximately ten highway department employees involved: two paver operators, two rakers/laborers, one asphalt roller operator and approximately five dump truck drivers. 

At approximately 3:00 p.m., the asphalt roller operator was seriously injured when the ten ton asphalt compactor he was operating went off the pavement, down an embankment and overturned, trapping him beneath.  Coworkers immediately ran over to aid the operator while another employee called for help.  While waiting for emergency medical services to arrive at the site, coworkers removed the employee from underneath the compactor.  EMS crews arrived at the site and transported the employee by Lifestar to an area hospital.  The employee spent several days in the hospital.  As of this writing, due to the injuries he sustained in the accident, he has lost his sight and has not returned to work. 

The Bureau of Labor Statistics identified 282 deaths associated with road grading and surface machinery during 1992 – 2001.  At least 70 of these deaths involved roller/compactors.  Review of this data suggests two common causes of injury: machine rollovers and being struck by the moving compactor. 

Recommendations 

  • Use machinery equipped with rollover protective structures (ROPS) and seatbelts

  • Wear the seatbelt on machines equipped with ROPS

  • Train the operator on safety procedures and proper use of equipment

  • Develop site-specific safety plans for all aspects and stages of the job

  • Minimize the presence of workers on foot near machinery

  • Use barriers to separate workers from moving equipment

  • Ensure that machines are not operated on grades steeper than those recommended by the manufacturer

Summary

Injuries and deaths can be prevented through the wider use of rollover protective structures, seat belts, employee training, establishing and adhering to safety plans, safe work practices, and using appropriate personal protective equipment.


CONN-OSHA ~ Training Update ... 

Breakfast Roundtable    This discussion Group meets the third Tuesday of every month.  These free 90-minute workshops discuss safety and health issues in a supportive and informal environment.  The roundtable meetings are held from 8:15 am to 9:45 am.  The location and topics vary, be sure to call concerning the discussion subject and the location.  Pre-registration is required.  For additional information or to be placed on the e-mail distribution list, call John Able at (860) 263-6902 or send an email to able.john@dol.gov

OSHA 300 Recordkeeping    Friday September 15, 2006  Develop skills to accurately report occupational injuries and illnesses on the OSHA 300 Log.  Reference materials will be provided. 

Classes are free and held at 200 Folly Brook Boulevard, Wethersfield, CT in Conference Room A from 9 am - 12 noon unless noted.  To register, contact  John Able at (860) 263-6902 or able.john@dol.govPre-registration is required.

Fatality & Casualty Reporting 

State & Town: CONN-OSHA (860) 263-6946 (local) or 1-866-241-4060 (toll-free)
Private Employers: Report to Federal OSHA at 1-800-321-OSHA(6742))

OSHA-Quarterly Index

Last Updated: March 01, 2017


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