DPW Safety, at the Garage and in the Field, are you keeping up?

April 2, 2014

Dave Horowitz

2014 NBM ANNUAL SPRING TECHNICAL SESSION

Safety Takeaways

■ We understand!

– Municipal perspective in OSHA

■ Safety Issues Exist– We’ll provide some examples

■ Safety Issues Aren’t Always Obvious– Those hidden gems can be

painful

O.S.H.A.? Who cares?

OSHA standards apply even if you work in the public sector (a municipality)

Public Sector = Department of Public Safety (DPS)Everyone Else = O.S.H.A

Department of Public Safety:

“In lieu of a specific standard you must treat the OSHA standard as the minimum.”

http://www.mass.gov/lwd/labor-standards/massachusetts-workplace-safety-and-health-program/public-sector-employee-health-and-safety

O.S.H.A.? Who cares?

OSHA Top 10

I’m from OSHA. I’m here to help.

(We know – you’re not OSHA regulated)

I’m from OSHA. I’m here to help.

(We know – you’re not OSHA regulated)

OSHA Top 10

1. Hazard Communication

2. Respiratory Protection

3. Powered Industrial Vehicles

4. Electrical Safety

5. Lock Out/Tag Out

6. Machine Guarding

7. Personal Protective Equipment

8. Blood Borne Pathogens

9. Abrasive Wheel Machinery

10.Fall Protection/Prevention

#10 Fall Prevention / Protection

“… Occupational Safety and Health (Conn-OSHA) fined the city $9,000 for a willful violation of the state’s Occupational Safety and Health Act. Specifically, the citation was issued for not having railings or guardrails protecting people from a fall of more than 4 feet in the trash compactor area ….”

GUARDING FLOOR AND WALL OPENINGS

■ 29 CFR 1910.23■ Stairway Floor Openings

– Railing on All Exposed Sides■ Ladderway Floor Opening

– Railing on All Exposed Sides– Swing Gate or Offset for Opening

■ Hatchways– Railing on Exposed Sides– Cover or Protected When Not in Use

#9 Abrasive Wheel Machinery

“… Two repeat safety violations involve hazards related to abrasive wheel machinery used at the base. Tongue guards were missing and work rests were improperly adjusted, exposing employees to the hazard of shrapnel from shattered wheels. A repeat violation exists when an employer previously has been cited for the same or a similar violation of a standard, regulation, rule or order at any other facility in federal enforcement states within the last five years. The Army had been notified by OSHA's area office in Frankfort, Ky., about these same violations at a Kentucky installation ….”

#8 Bloodborne Pathogens

■ When PPE is necessary

■ What type of PPE is necessary

■ How to properly put on, take off, adjust, and wear

■ Limitations of the PPE

■ Proper care, maintenance, useful life and disposal

#7 Personal Protective Equipment

■ Assess the workplace for hazards

■ Eliminate or reduce hazards before using PPE

■ Select and provide appropriate PPE

■ Inform why PPE is necessary

■ Train employees how to use and care for their PPE

■ Require employees to wear selected PPE

#6 Machine Guarding

■ Reaching in to “clear” equipment

■ Not using Lockout/Tagout■ Unauthorized persons

doing maintenance or using the machines

■ Missing or loose machine guards

#5 Lockout / Tagout

#4 Electrical Installation (General)

#3 Powered Industrial Trucks

#2 Respiratory Protection

#1 Hazard Communication

Tier II Reportin

g

Spill Planning

Air Permitting,

Spill Planning

Air Permitting,

Spill Planning

UST Operations

& Inspections

Tight Tank

Spill Planning

ASTs

STI Inspection Results

Compliance Issues

Normal Venting

Emergency Venting

Spill Containers

Overfill Prevention

Interstice

Ultra-Sonic Thickness Testing

Double Wall AST

Remote Spill Box/FillFuel Dispenser

Fuel Pump

Interstitial Leak Detection

Spill Kit

Normal Vent

Labels

Double Wall AST

Dispenser Hose Bollards

Secondary Tank Emergency Vent

Primary Tank Emergency Vent

Mechanical Gauge

Preventive Limiting Barrier

Concrete Pad

1.5-inchesNut

Dike Tank

Integral Containment

Rain Shield

Ideal Installation – Generator Tank

State Authority Having Jurisdiction

■ Massachusetts– 10,000 gallons and under (single tank)

» Local Fire Department – Over 10,000 gallons (single tank)

» Local Fire Department» Town BOS or City Council» State Fire Marshal

■ Connecticut– Local Fire Marshal

Observation Results

■ 200+ Tanks observed for tank integrity■ One* with >75% wall thickness losses

– Compared to existing standards■ Most with regulatory, code compliance, operational

issues– Vent heights & vent configuration/operation– No overfill protection/Level detection devices– Not UL 142 standard construction– No spill prevention devices– Improper protection from vehicular impact

■ Some with evident corrosion– Interior of double wall– External

Florida Leak Study

■ Florida has ~50,000 registered, active tanks at ~20,000 sites

■ 82% of the ASTs have secondary containment

■ 188 discharges from shop-fabricated ASTs (the type of tank that hospitals typically have)

Florida Leak Study

■ Top causes of failures from these ASTs (Accounting for 65% of the failures) were:– Overfills– Spills– Physical damage– Loose components

Safety Takeaways

■ We understand!

– Municipal perspective in OSHA

■ Safety Issues Exist– We’ll provide some examples

■ Safety Issues Aren’t Always Obvious– Those hidden gems can be

painful

Questions