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6 OSHA Programs
You Can’t Afford
to Neglect
From HazCom to Fire Prevention,
make sure these plans are up-to-date.
Meet Your Moderator:
James Ciccone
All lines will be muted – please communicate via the
questions tab in your webinar panel.
There will be live, interactive polling.
There will be a Q&A session at the end of the
presentation – submit your question(s) anytime
throughout the webinar.
Stick around for an exclusive offer at the end of the
webinar.
Webinar Overview
Meet Your Presenter
Rick FooteEHS Consulting Manager
rfoote@triumvirate.com
617-686-6184
25 plus years experience in
EHS management
Our Key Message
Focus on Six Core OSHA Required
Written Programs
What Will You Learn?
What written programs are required?
What is required in each program?
When do you need to update each program?
“Do I need to have a
written program for all of
the OSHA regulations?”
“Am I ready for OSHA
to visit and inspect
my programs?”
Poll Question
How prepared are you for
your next OSHA
inspection?
AgendaWritten Programs Overview
Bloodborne Pathogens Control Plan
Emergency Action Plan
Fire Prevention Plan
Hazard Communication Plan
Respiratory Protection Plan
Lockout/Tagout Plan
Q&A
OSHA Has Been Busy
• OSHA Conducted 92,000
inspections
• There were over 188,000
violations cited
• There was approximately
$240 million in penalties
Written Programs• Bloodborne Pathogens Safety Program 1910.1030
• Confined Space Entry (Permit-Required) 1910.146
• Electrical Safety Plan 1910.331-335
• Emergency Action Plan 1910.38
• Fire Extinguisher Program 1910.157
Written Programs• Fire Prevention Plan 1910.39
• Fire Protection Equipment Maintenance Plan Subpart L
• Hazard Communication Program 1910.1200
• Hearing Conservation Program 1910.95
• Hot Work (Cutting/Welding) Program 1910.252-255
Written Programs• Laboratory Safety Program 1910.1450
• Lockout/Tagout 1910.147
• Machine Safeguarding Program 1910.212
• Material Handling & Crane Safety 1910.179/184
• Medical Record Access 1910.1020
Written Programs• Mechanical Power Presses 1910.217
• Personal Protective Equipment Program 1910.132
• Powered Industrial Truck Program 1910.178
• Process Safety Management 1910.119
• Respiratory Protection Program 1910.134
Written Programs Overview
Bloodborne Pathogens Control Plan
Emergency Action Plan
Fire Prevention Plan
Hazard Communication Plan
Respiratory Protection Plan
Lockout/Tagout Plan
Q&A
Agenda
Scope and Application
• This rule applies to all occupational exposure to
blood or other potentially infectious materials.
Definitions:
• Occupational Exposure means reasonably
anticipated skin, eye, mucous membrane, or
parenteral contact with blood or other potentially
infectious materials that may result from the
performance of an employee's duties.
Bloodborne
Pathogens Plan
Each employer having an employee(s)
with occupational exposure shall
establish a written Exposure Control Plan
designed to eliminate or minimize
employee exposure.
Bloodborne
Pathogens Content
Bloodborne
Pathogens ContentThe plan must include the following items:
• The exposure determination
• The schedule and method of implementation for:
Methods of Compliance
HIV and HBV Research Laboratories and Production
Facilities
Hepatitis B Vaccination and Post-Exposure Evaluation
and Follow-up
Communication of Hazards to Employees
Recordkeeping
Bloodborne
Pathogens Content
• The procedure for the evaluation of
circumstances surrounding exposure
incidents.
• Each employer shall ensure that a
copy of the Exposure Control Plan is
accessible to employees.
Bloodborne
Pathogens ContentThe Exposure Control Plan shall be
reviewed and updated at least annually
and whenever necessary to reflect new
or modified tasks and procedures which
affect occupational exposure and to
reflect new or revised employee
positions with occupational exposure.
Bloodborne
Pathogens ContentThe review and update of such plans
shall also:
• Reflect changes in technology that eliminate
or reduce exposure to bloodborne pathogens;
and
• Document annually consideration and
implementation of appropriate commercially
available and effective safer medical devices
designed to eliminate or minimize
occupational exposure.
Bloodborne
Pathogens Content• An employer shall solicit input from non-managerial
employees responsible for direct patient care who
are potentially exposed to injuries from
contaminated sharps in the identification, evaluation,
and selection of effective engineering and work
practice controls and shall document the solicitation
in the Exposure Control Plan.
• The Exposure Control Plan shall be made available
to the Assistant Secretary and the Director upon
request for examination and copying.
Exposure
Determination• A list of all job classifications in which all employees
in those job classifications have occupational
exposure;
• A list of job classifications in which some employees
have occupational exposure, and
• A list of all tasks and procedures or groups of closely
related task and procedures in which occupational
exposure occurs and that are performed by
employees in job classifications listed.
• This exposure determination shall be made without
regard to the use of personal protective equipment.
Written Programs Overview
Bloodborne Pathogens Control Plan
Emergency Action Plan
Fire Prevention Plan
Hazard Communication Plan
Respiratory Protection Plan
Lockout/Tagout Plan
Q&A
Agenda
Emergency
Action PlansWritten and oral emergency
action plans:• An emergency action plan must be in
writing, kept in the workplace, and
available to employees for review.
• However, an employer with 10 or fewer
employees may communicate the plan
orally to employees.
Emergency Action
Plans Content• Procedures for reporting a fire or other
emergency;
• Procedures for emergency evacuation,
including type of evacuation and exit route
assignments;
• Procedures to be followed by employees
who remain to operate critical plant
operations before they evacuate;
• Procedures to account for all employees
after evacuation;
Emergency Action
Plans Content• Procedures to be followed by
employees performing rescue or
medical duties; and
• The name or job title of every
employee who may be contacted by
employees who need more
information about the plan or an
explanation of their duties under the
plan.
Training & ReviewTraining
• An employer must designate and train employees to assist in a safe and
orderly evacuation of other employees.
Review of emergency action plan
• An employer must review the emergency action plan with each employee
covered by the plan:
• When the plan is developed or the employee is assigned initially to a job;
• When the employee's responsibilities under the plan change; and
• When the plan is changed.
Written Programs Overview
Bloodborne Pathogens Control Plan
Emergency Action Plan
Fire Prevention Plan
Hazard Communication Plan
Respiratory Protection Plan
Lockout/Tagout Plan
Q&A
Agenda
Fire Prevention Plan
Application
• An employer must have a fire prevention plan when an OSHA standard
in this part requires one.
Written and oral fire prevention plans
• A fire prevention plan must be in writing, be kept in the workplace, and
be made available to employees for review.
• However, an employer with 10 or fewer employees may communicate
the plan orally to employees.
Fire Prevention Plan Content• A list of all major fire hazards, proper handling and storage
procedures for hazardous materials, potential ignition
sources and their control, and the type of fire protection
equipment necessary to control each major hazard;
• Procedures to control accumulations of flammable and
combustible waste materials
• Procedures for regular maintenance of safeguards installed
on heat-producing equipment to prevent the accidental
ignition of combustible materials;
Fire Prevention Plan Content• The name or job title of
employees responsible for
maintaining equipment to prevent
or control sources of ignition or
fires; and
• The name or job title of
employees responsible for the
control of fuel source hazards.
Written Programs Overview
Bloodborne Pathogens Control Plan
Emergency Action Plan
Fire Prevention Plan
Hazard Communication Plan
Respiratory Protection Plan
Lockout/Tagout Plan
Q&A
Agenda
Hazard CommunicationRequires chemical manufacturers or
importers to classify the hazards of chemicals
which they produce or import, and all
employers to provide information to their
employees about the hazardous chemicals to
which they are exposed, by means of a
hazard communication program, labels and
other forms of warning, safety data sheets,
and information and training.
Hazard Communication
Plan ContentEmployers shall develop, implement, and
maintain at each workplace, a written hazard
communication program which at least
describes how the criteria of this section for
labels and other forms of warning, safety data
sheets, and employee information and
training will be met.
Hazard Communication
Plan Content• A list of the hazardous chemicals known to be
present using a product identifier that is referenced
on the appropriate safety data sheet (the list may
be compiled for the workplace as a whole or for
individual work areas); and,
• The methods the employer will use to inform
employees of the hazards of non-routine tasks (for
example, the cleaning of reactor vessels), and the
hazards associated with chemicals contained in
unlabeled pipes in their work areas.
Hazard Communication
Plan ContentMulti-employer workplaces
• Employers who produce, use, or store
hazardous chemicals at a workplace in
such a way that the employees of other
employer(s) may be exposed (for example,
employees of a construction contractor
working on-site) shall additionally ensure
that the hazard communication programs
include the following:
Hazard Communication
Plan ContentMulti-employer workplaces (continued)
• The methods used to provide the other employer(s)
on-site access to safety data sheets for each
hazardous chemical the other employer(s)'
employees may be exposed to while working;
• The methods used to inform the other employer(s) of
any precautionary measures that need to be taken to
protect employees during the workplace's normal
operating conditions and in foreseeable emergencies;
and,
Hazard Communication
Plan ContentMulti-employer workplaces (continued)
• The methods used to inform the other
employer(s) of the labeling system used in
the workplace.
• The employer may rely on an existing
hazard communication program to comply
with these requirements, provided that it
meets the criteria established by this
regulation.
Hazard Communication
Plan Content• The employer shall make the written hazard
communication program available, upon request, to
employees, their designated representatives, the
Assistant Secretary and the Director.
• Where employees must travel between workplaces
during a work shift, i.e. their work is carried out at
more than one geographical location, the written
hazard communication program may be kept at the
primary workplace facility.
Written Programs Overview
Bloodborne Pathogens Control Plan
Emergency Action Plan
Fire Prevention Plan
Hazard Communication Plan
Respiratory Protection Plan
Lockout/Tagout Plan
Q&A
Agenda
Respiratory
Protection Plan• A respirator shall be provided to each employee when such
equipment is necessary to protect the health of such
employee.
• The employer shall provide the respirators which are
applicable and suitable for the purpose intended. The
employer shall be responsible for the establishment and
maintenance of a respiratory protection program.
• The program shall cover each employee required by this
section to use a respirator.
Respiratory
Protection Plan
Content• In any workplace where respirators are necessary to protect
the health of the employee or whenever respirators are
required by the employer, the employer shall establish and
implement a written respiratory protection program with
worksite-specific procedures.
• The program shall be updated as necessary to reflect those
changes in workplace conditions that affect respirator use.
The employer shall include in the program the following:
Respiratory
Protection Plan
Content• Procedures for selecting respirators for use in the workplace;
• Medical evaluations of employees required to use respirators;
• Fit testing procedures for tight-fitting respirators;
• Procedures for proper use of respirators in routine and
reasonably foreseeable emergency situations;
• Procedures and schedules for cleaning, disinfecting, storing,
inspecting, repairing, discarding, and otherwise maintaining
respirators;
Respiratory
Protection Plan
Content• Procedures to ensure adequate air quality, quantity, and flow of
breathing air for atmosphere-supplying respirators;
• Training of employees in the respiratory hazards to which they
are potentially exposed during routine and emergency situations;
• Training of employees in the proper use of respirators, including
putting on and removing them, any limitations on their use, and
their maintenance; and
• Procedures for regularly evaluating the effectiveness of the
program.
Respiratory
Protection Plan
ContentWhere respirator use is not required:• An employer may provide respirators at the request of employees or
permit employees to use their own respirators, if the employer
determines that such respirator use will not in itself create a hazard. If
the employer determines that any voluntary respirator use is
permissible, the employer shall provide the respirator users with the
information contained in Appendix D to this section ("Information for
Employees Using Respirators When Not Required Under the
Standard"); and
Respiratory
Protection Plan
Content• In addition, the employer must establish and implement those
elements of a written respiratory protection program necessary to ensure that any employee using a respirator voluntarily is medically able to use that respirator, and that the respirator is cleaned, stored, and maintained so that its use does not present a health hazard to the user.
• Exception: Employers are not required to include in a written respiratory protection program those employees whose only use of respirators involves the voluntary use of filtering facepieces (dust masks).
Written Programs Overview
Bloodborne Pathogens Control Plan
Emergency Action Plan
Fire Prevention Plan
Hazard Communication Plan
Respiratory Protection Plan
Lockout/Tagout Plan
Q&A
Agenda
Lockout/Tagout Plan
• This standard covers the servicing and
maintenance of machines and equipment
in which the unexpected energization or
start up of the machines or equipment, or
release of stored energy, could harm
employees.
• This standard establishes minimum
performance requirements for the control
of such hazardous energy.
Lockout/Tagout Plan Contents
• Procedures shall be developed, documented and utilized for
the control of potentially hazardous energy when employees
are engaged in the activities covered by this section.
• The procedures shall clearly and specifically outline the
scope, purpose, authorization, rules, and techniques to be
utilized for the control of hazardous energy, and the means
to enforce compliance including, but not limited to, the
following:
Lockout/Tagout Plan Contents• A specific statement of the intended use of the procedure;
• Specific procedural steps for shutting down, isolating, blocking and
securing machines or equipment to control hazardous energy;
• Specific procedural steps for the placement, removal and transfer of
lockout devices or tagout devices and the responsibility for them; and
• Specific requirements for testing a machine or equipment to determine and
verify the effectiveness of lockout devices, tagout devices, and other
energy control measures.
Written Programs Overview
Bloodborne Pathogens Control Plan
Emergency Action Plan
Fire Prevention Plan
Hazard Communication Plan
Respiratory Protection Plan
Lockout/Tagout Plan
Q&A
Agenda
Our Key Message
Focus on Six Core OSHA Required
Written Programs
OSHA Written ProgramsRemember to review and update each plan on a
regular basis.
If you change your plan, you will need to re-train employees on the changes.
Ensure that the plan is implemented and actually reflects the day-to-day operations at your facility.
Thank You For
Attending!Request a Free Program Review:
http://info.triumvirate.com/osha Call Us!1-888-834-9697www.triumvirate.com
Contact Rick Foote:rfoote@triumvirate.com
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