Module14 OSHA Safety Compliance

The SOCMA Chemical Process Operator Training Course
SECTION 14: OSHA SAFETY COMPLIANCE
Of the many different types of workplace environments, the chemical manufacturing facility can be one of the more dangerous. There are all the hazards normally associated with any manufacturing environment, such as hazards from machinery, hot surfaces, slippery surfaces, welding and noise, plus the hazards associated with the handling of hazardous chemicals. The added risks to the employees become added risks to the employer as well, since injured workers can translate into lost production, potential problems with OSHA, costly medical and insurance expenses and decreased morale. Complying with OSHA Safety Regulations is crucial to the successful operation of a chemical manufacturing facility. These safety regulations cover nearly every aspect of the workplace. OSHA safety regulations for general industry are found in 29 CFR 1910, which contains nearly 700 pages of regulatory text pertaining to general workplace safety and over 350 pages of regulations concerning hazardous chemicals. Dedicated and coordinated efforts are required to achieve safety compliance in any workplace environment, but especially in a chemical manufacturing facility. OSHA safety compliance cannot be fully achieved by a "Safety Manager" or by management alone. It demands the informed and willing cooperation of every employee. Achieving health and safety compliance is not a one time action but an ongoing process which requires attention and continuous effort. The compliance process can be broken down into 7 steps: Determining the applicable regulations Identifying the requirements of the applicable regulations Evaluating the operations in light of regulatory requirements Developing a well thought out, prioritized action plan Creating written programs, procedures and plans. Taking predetermined and definite actions Monitoring for compliance
Determining the applicable regulations - This is usually done by someone knowledgeable of OSHA regulations to ensure that all aspects are considered. It may require an informal interview and a walkthrough inspection of the facility or a formalized audit. Identifying the specific requirements - The requirements of each regulation should be listed separately at first. Later, common elements will be identified to avoid unnecessary efforts. This may also require the assistance of someone who is knowledgeable about OSHA regulations. Evaluating facility operations - The compliance status of the facility must be determined by regulation. It is important to be thorough, critical and honest in the evaluation so that a true picture of the facility compliance status is obtained. Obtain input from all areas of the facility. As part of the evaluation, be sure to also consider situations that have the potential to result in non-compliance. This may save you headaches later. Developing a prioritized action plan - Actions must be prioritized and scheduled within reasonable time limits in order to effectively use available resources. Situations where employees are put at unreasonable risk would require immediate action. Developing procedures or training employees are examples of actions which can be scheduled at later times. Determine where the greatest risks to employee safety are and also where there is the greatest liability. Some actions which require minimal effort and expense (purchase of safety equipment, installing guard rails, putting up signs) can be done immediately. Other
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actions such as training and developing procedures may require months to accomplish. The action plan should take these considerations into account. Responsibilities must be defined and realistic goals should be set. Creation of written programs and procedures - These describe how compliance will be achieved and maintained, and by whom. They will serve as a reference point and will provide for the communication of the requirements of the facilitys safety program in detail. The written procedures will also form the basis for compliance with OSHAs record keeping and documentation requirements. Taking predetermined and definite actions - This could involve training, addition or revision of equipment, new systems and/or documentation of activities. Careful follow-through and diligence are necessary in order to achieve full compliance. Be sure that each item on the action list is completed and approved before checking it off the list. It is vital that what is written down on the action plan be carried out accurately and completely. Monitoring for compliance - Self-audits and inspections should be conducted to assess progress and determine if further actions are needed. Getting into compliance is only the first step; staying in compliance is the ultimate goal. This will require regular and consistent attention. Completing this 7 step process can take anywhere from weeks to several years depending on the size of the facility, the number of employees, the number of and complexity of the applicable regulations and the existing compliance status of the facility. The most important thing is to get the process started. Eventually, this process must become part of normal operations, just like any other part of the business. When this is the case, things will be well on the way toward the successful operation of the chemical processing facility. Although there are many regulations affecting the chemical process industries, there are a few key regulations which are of primary concern. It is important to have at least a basic understanding of their requirements. Once these requirements are understood, the operator can be better prepared to fulfill his/her role in the companys OSHA compliance programs. The key OSHA regulations which apply to chemical plant process operators can be categorized by breaking these regulations into three groups: CHEMICAL - those regulations that relate to the handling, storage and use of hazardous chemicals. PLANT PROCESS - those regulations which are related to working in or around plant processes. OPERATOR - those regulations that are not directly related to the plant processes and which are related to the safety of and the responsibilities of the operator.
Listed below are some of the applicable OSHA regulations identified by these three categories:
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OSHA Safety Compliance Revised: March, 2009
Table 14-1 Chemical
Applicable OSHA Regulations by Category Plant Process

Confined Space Entry Electrical Safety/Lockout-Tagout Forklift/Materials Handling Machine Guarding Hotwork/Cutting and Brazing Fall Protection
Operator
Emergency Action Plans Fire Extinguisher Safety Safety Committees Hearing Conservation Hazwoper Ergonomics
Subpart Z Hazardous/Toxic Materials Hazard Communication Personal Protective Equipment Respiratory Protective Equipment The Chemical Hygiene Plan
PROCESS
SAFETY
MANAGEMENT
The Process Safety Management regulation cuts across all the categories and is in itself an extensive regulation. In this section we will concentrate on the other OSHA regulations, since process safety management is covered in another section of this course.
14.1 CHEMICAL REGULATIONS

14.1.1 Subpart Z - Toxic and Hazardous Substances 29 CFR 1910 Subpart Z (1910.1000 to End) Toxic and Hazardous Substances, addresses employee exposure to listed hazardous air contaminants. 29 CFR 1910.1000 Tables Z-1-A, Z-2, and Z-3 identify these air contaminants and establish their Permissible Exposure Limits (PEL). Permissible exposure limits are expressed as a Time Weighted Average (TWA), Short Term Exposure Limit (STEL) and/or a Ceiling or Excursion Limit (Ceiling). A TWA is the employee's average airborne exposure in any 8-hour work shift of a 40-hour work week which is not to be exceeded. A STEL is the employee's 15-minute time weighted average exposure which shall not be exceeded at any time during a work day unless another time limit is specified, in which case the TWA over that time period shall not be exceeded during the working day. A Ceiling Limit is the employee's exposure which shall not be exceeded during any part of the work day.
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Table 14-2
Subpart Z Regulated Chemicals Chemical name

Air Contaminants Asbestos 4-Nitrobiphenyl alpha-Naphthylamine Methyl Chloromethyl Ether 3,3'-Dichlorobenzidine bis-Chloromethyl Ether beta-Naphthylamine Benzidine 4-Aminodiphenyl Ethyleneimine beta-Propiolactone 2-Acetylaminofluorene 4-Dimethylaminoazobenzene N-Nitrosodimethylamine Vinyl Chloride Inorganic Arsenic Lead Cadmium Benzene Coke Oven Emissions Blood Borne Pathogens Cotton Dust DBCP Acrylonitrile Ethylene Oxide Formaldehyde 4,4'-Methylenedianiline Methylene Chloride
Requirement Section
(29 CFR 1910.1000) (29 CFR 1910.1001) (29 CFR 1910.1003) (29 CFR 1910.1004) (29 CFR 1910.1006) (29 CFR 1910.1007) (29 CFR 1910.1008) (29 CFR 1910.1009) (29 CFR 1910.1010) (29 CFR 1910.1011) (29 CFR 1910.1012) (29 CFR 1910.1013) (29 CFR 1910.1014) (29 CFR 1910.1015) (29 CFR 1910.1016) (29 CFR 1910.1017) (29 CFR 1910.1018) (29 CFR 1910.1025) (29 CFR 1910.1027) (29 CFR 1910.1028) (29 CFR 1910.1029) (29 CFR 1910.1030) (29 CFR 1910.1043) (29 CFR 1910.1044) (29 CFR 1910.1045) (29 CFR 1910.1047) (29 CFR 1910.1048) (29 CFR 1910.1050) (29 CFR 1910.1052)
Table Z-1-A (1910.1000) lists several hundred air contaminants, from acetaldehyde to zirconium compounds, and their PELs and STELs. Subpart Z also regulates toxic and hazardous substances for which specific regulations apply (1910.1001 to end). To achieve compliance and limit employee exposure, an employer that uses any of the listed chemical substances must perform initial air monitoring in the workplace to determine the level of employee exposure. If monitoring indicates employee exposure levels above the established limits, administrative or engineering controls must be determined and implemented. When such controls are not feasible, or are unable to reduce exposure to below the limit, personal protective equipment must be used to reduce exposure to below the established limit.
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Subpart Z initial monitoring determines if employee exposure is above the action level. The action level refers to a level of exposure which initiates certain required activities, including medical surveillance and periodic monitoring. The action level is one half the PEL. Table 14-3 Subpart Z Chemicals with Monitoring Requirements Chemical name
Asbestos Vinyl Chloride Inorganic Arsenic Lead Cadmium Benzene Coke Oven Emissions DBCP Cotton Dust Acrylonitrile Ethylene Oxide Formaldehyde 4,4-Methylenedianiline Methylene Chloride
Requirement Section
(29 CFR 1910.1001) (29 CFR 1910.1017) (29 CFR 1910.1018) (29 CFR 1910.1025) (29 CFR 1910.1027) (29 CFR 1910.1028) (29 CFR 1910.1029) (29 CFR 1910.1044) (29 CFR 1910.1043) (29 CFR 1910.1045) (29 CFR 1910.1047) (29 CFR 1910.1048) (29 CFR 1910.1050) (29 CFR 1910.1052)
Initial results will indicate what level of response is necessary. Three basic scenarios may occur. 1) Identified chemical is not detected or is below the action level. 2) Identified chemical is above action level but below PEL. 3) Identified chemical is above PEL. Those chemicals that are above the action level or PEL may require action steps in the following areas: Periodic monitoring. If employee exposures are above the action level, a program for determining exposures must be established. The initial level of exposure will determine how often to repeat the monitoring. For example, if vinyl chloride concentrations exceed the PEL, monitoring will be repeated monthly, and if vinyl chloride concentrations exceed the action level, monitoring will be quarterly. Establishment of regulated areas. A regulated area means any area where airborne concentrations exceed or can reasonably be expected to exceed, the PEL. Access to regulated areas must be limited to authorized personnel. Compliance programs. A written program must be established and implemented that reduces employee exposure to or below the PEL. Respiratory and personal protection programs. These can include requirements to provide respirators or other PPE, as well as requirements for respirator fit testing and training. Medical Surveillance. The employer may be required to have regular medical examinations including chest x-rays, bloodwork, or other testing to monitor employee health.
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Hazard communication and training. Requires a program to keep employees aware of hazardous materials. Record keeping. Certain records must be kept for a designated period of time. Employee notification. responsibilities. Ensures that employees are aware of their rights and
A complete Subpart Z program must be implemented that integrates components of each applicable regulation (determined by the results of the initial monitoring program). Most of the time this will mean reexamining a program that is already in place, with adjustments being made where needed. If on-going monitoring is required, an in-house air monitoring program should be developed. This program must be documented, and all affected employees must be informed of the program and its contents. Table 14-4 Permissible Exposure Limits for Subpart Z Chemicals TWA
0.1 f/cc 1 ppm 10 ug/m3 50 ug/m3 5 ug/m3 1 ppm 150 ug/m3 200 ug/m3 1 ppb 2 ppm 1 ppm 0.75 ppm 10 ppb 25 ppm 10 ppm 5 ppm 1 ppm 0.5 ppm 0.5 ppm 5 ppb 12.5 ppm Varies
Chemical Name
Asbestos (29 CFR 1910.1001) Vinyl Chloride (29 CFR 1910.1017) Inorganic Arsenic (29 CFR 1910.1018) Lead (29 CFR 1910.1025) Cadmium (29 CFR 1910.1027) Benzene (29 CFR 1910.1028) Coke Oven Emissions (29 CFR 1910.1029) Cotton Dust (29 CFR 1910.1043) DBCP (29 CFR 1910.1044) Acrylonitrile (29 CFR 1910.1045) Ethylene Oxide (29 CFR 1910.1047) Formaldehyde (29 CFR 1910.1048) 4,4'-Methylenedianiline (29 CFR 1910.1050) Methylene Chloride (29 CFR 1910.1052)
Ceiling
1 f/cc
Action Level
0.05 f/cc 0.5 ppm 5 ug/m3 30 ug/m3 2.5 ug/m3 0.5 ppm
14.1.2 The Hazard Communication Standard The hazard communication standard is OSHAs regulation pertaining to an employees "Right-toKnow" of the chemical related hazards faced in the workplace. This regulation provides the foundation for all other chemical related safety regulations, and is one of the most important for a chemical operator to understand. The hazard communication standard, found in 29 CFR 1910.1200, is the most frequently violated OSHA regulation, and is often the most misunderstood. The requirements upon the employer are extensive, with one of the greatest challenges being the effective communication of the nature, extent and characteristics of the hazards of the chemicals in use at their facility.
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Table14-5 lists the most frequently cited violations of the OSHA standards. violations in 2007 involved the Hazard Communication Standard. Table 14-5 Subject
Hazard communication - Written program Machine guarding - Types of guarding Hazard communication - Employer must provide hazard information and training Guarding floor openings, platforms, and runways Machine guarding - Point of operation guarding First aid - Eye wash/emergency shower facilities not in near proximity to employees Lockout/tagout - Written energy control procedures Abrasive wheel machinery - Exposure adjustment/safety guards Electric - Wiring methods, components and equipmentCabinets, boxes/Conductors Lockout/tagout - Establish an energy control program Hazard communication - MSDS available for each hazardous chemical Respiratory protection - Provide medical evaluation prior to fit test and respirator use Respiratory protection - Establish a written program Powered industrial trucks - Operator training Electrical-Equipment must be installed according to instructions Lockout/tagout - Annual procedure inspection Mechanical power transmission - Pulley guarding Personal protective equipment - Written certification of hazard assessment Electric-Wiring methods, components and equipment Cabinets, boxes/Covers Abrasive wheel machinery - Work rests
Three of the top 25
Top 25 Most Cited Violations of OSHA 1910 -- 2007 Standard

1910.1200(e)(1) 1910.212(a)(1) 1910.1200(h)(1) 1910.23(c)(1) 1910.212(a)(3)(ii) 1910.151(c) 1910.147(c)(4)(i) 1910.215(b)(9) 1910.305(b)(1) 1910.147(c)(1) 1910.1200(g)(1) 1910.134(e)(1) 1910.134(c)(1) 1910.178(l)(1)(i) 1910.303(b)(2) 1910.147(c)(6)(i) 1910.219(d)(1) 1910.132(d)(2) 1910.305(b)(2) 1910.215(a)(4)
Total violations
2,272 1,576 1,141 841 786 757 752 723 695 681 675 654 636 632 601 526 520 508 497 494 491 491 489 481 480
Personal protective equipment - Must conduct a hazard 1910.132(d)(1) assessment Lockout/tagout - Training and communication Eye and face protection - Use of appropriate eye and face protection Compressed air - Reduce to less than 30 p.s.i. Personal protective equipment - Provide, use, maintain equipment in a sanitary and reliable condition 1910.147(c)(7)(i) 1910.133(a)(1) 1910.242(b) 1910.132(a)
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This regulation establishes requirements for employers to: Evaluate all chemicals present on the site to determine which are hazardous, and to evaluate the nature, extent and characteristics of the hazards in relation to potential risks to employees. Inform employees about the presence and location of all hazardous chemicals. Develop a written hazard communication program which includes a list of all the hazardous chemicals and their locations, along with explanations of the steps the company will take to comply with the requirements of the standard. Generate or obtain, and make available MSDS for all hazardous chemicals. Develop a labeling program which ensures that containers of hazardous chemicals are clearly identified and that proper hazard warnings are displayed. Train affected employees concerning all the elements of the program. This includes training employees to understand how to read an MSDS, how to understand hazard warnings on labels, and all the details of the companys written hazard communication program. Inform contractors of their requirements under the standard.
This regulation also establishes some employee rights: The "right-to-know" about the hazardous chemicals an employee is required to work with or around and about related health and safety information. The right of access to any MSDS for such hazardous chemicals. The right to see, review and have a copy of the site written hazard communication program.
Communication is the key concept underlying the requirements of this standard. This communication takes place through Material Safety Data Sheets (MSDS), labels, training and written procedures. In order to be sure that employees understand the information contained in MSDS, labels etc., employers must educate the employees about the contents of an MSDS and the meaning of systems used to communicate hazards, such as the NFPA diamond and the Hazardous Materials Identification System (HMIS) labels. Employees must be able to recognize and locate any hazardous material in their workplace and understand how to protect themselves from the hazards of the material. Employees shall be informed of the requirements of the regulation, any operations in their work area where hazardous materials are present and the location and availability of the employers' written hazard communication program. Employees must be trained to recognize and detect the presence of a release. They must also be trained to know the physical and health hazards of any hazardous chemicals on the site and the measures taken by the employer to protect employees from these hazards. Training must be conducted at the beginning of the employee's assignment and periodically whenever there are changes to the program or if new hazardous chemicals are in use. Many employers conduct annual refresher training. Containers of hazardous chemicals in a facility are to be labeled with the hazardous chemical identity, and an appropriate hazard warning. Container labels prepared by the chemical manufacturer, importer, or distributor should never be removed or defaced. Incoming hazardous chemicals must be checked to verify that the appropriate identification and hazard warnings are
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present and in English. Included in this check will be confirmation that the following information is present on the label: 1) Chemical identity; 2) Appropriate hazard warnings, such as HMIS, NFPA or written warnings; and 3) Name and address of the chemical manufacturer. Portable containers (that is, containers into which hazardous chemicals are transferred from labeled containers) are not required to be labeled if the container will only be used by the employee who transferred the hazardous chemical into it, and the container will be empty by the end of the shift of that employee. Otherwise it is the responsibility of the individual using the portable container to obtain and apply a label that indicates the chemical identity and hazard warning information. Stationary process units, including storage tanks and reaction vessels, containing hazardous chemicals will be labeled with the identity of the hazardous chemical(s) contained in the process unit, with appropriate hazard warnings.
14.1.2.1 Labeling Systems There are several different hazardous labeling systems. These labeling systems have been developed by organizations in order to help standardize the information presented on labels. Three of the most common systems presently in use include the:
1. National Fire Protection Association (NFPA) 704 Standard; 2. American National Standards Institute (ANSI) Standard Z129.1; and 3. National Paints and Coatings Association Hazardous Materials Information System (HMIS). The NFPA system uses hazard ranking and pictographs within a distinctive three color diamond to convey health, reactivity and flammability hazard information. The NFPA's hazard ranking and identification system rates hazards by severity on a 0 to 4 scale (4 being the most hazardous). Since this system does not include chemical identity information, it cannot be used alone for compliance with the Hazard Communication Standard. The ANSI standard recommends the use of signal words such as caution, warning and danger to convey the degree of hazard. Standard language is also used to convey chemical hazards, precautions for chemical storage and use, and first aid procedures. The Hazardous Materials Information System is similar to the NFPA system in that the health, flammability and reactivity hazards are rated by severity on a 0 to 4 scale with the same color scheme. However the HMIS label is rectangular rather than diamond shaped and contains the identity of the hazardous material as listed on the material safety data sheet. At the bottom of a HMIS label is a pictograph which indicates what personal protective equipment should be worn with the hazardous material. This information is very useful for reminding employees what personal protective equipment is needed to handle a hazardous chemical.
14.1.2.2 Material Safety Data Sheets The Material Safety Data Sheet (MSDS) is the backbone of chemical safety management and is the key resource for obtaining health and safety information about hazardous chemicals. Far too often, the MSDS is underutilized or misunderstood.
Material safety data sheets must be obtained for all hazardous chemicals within the facility. MSDS for hazardous chemicals are made available by the manufacturer, distributor or importer upon initial shipment of each hazardous chemical and with the first shipment after an update is made to the information on the MSDS. If possible, MSDS should be obtained prior

to the initial shipment, enabling the hazards to be assessed, permitting the review of safe handling and disposal procedures, and allowing facility employees to have hazard information before the chemical arrives and is stored or used. Material safety data sheets must be available to employees in the workplace during the employee's work shift. Material safety data sheets can have many different formats and may be kept in any form. Regardless of which format is selected, the required information must be provided for each hazardous chemical entering the facility. MSDSs are required to be in English and contain at least the following information: Manufacturer Information, Exposure Limits, Identity Information, Carcinogenicity, Physical and Chemical Characteristics, Precautions for Safe Handling and Use, Physical Hazards, Control Measures, Health Hazards, Emergency and First Aid Procedures, Primary Routes of Entry, and Preparation Date.
14.1.2.3 Contractor Safety Contractors must be informed of the hazards of any chemicals that they may handle or be occupationally exposed to during their work at the facility. Procedures must be developed and followed any time a contractor or subcontractor is hired to work at the facility in an area where hazardous chemicals may be used or are present.
Contractors are not to bring onto the grounds of the facility any substance that may be considered hazardous without prior consent. Contractors should not dispose of, in any manner, substances that may be considered hazardous within the facility without prior consent. The following factors will be considered in the determination to allow the use of any hazardous substance by contractors at the facility: Relative hazards of its use, Disposal of the substances, The potential for employee exposure, and Availability of substitutes.
Any equipment used by the contractor in areas where flammable materials are stored or processed must be explosion proof. Questions concerning chemicals or equipment that may be hazardous should be thoroughly investigated. Contractor errors and mistakes have contributed to a substantial number of serious accidents. It is the responsibility of the employer to insure that a program is in place to address these contractor issues.
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Contractor and contractor personnel should be provided with appropriate hazard information and training. Information and training are to include the following: Potential chemical and physical hazards for the area in which contract operations are being conducted; Location and availability of Material Safety Data Sheets; Detection of the presence of hazardous chemicals; Facility precautions and safety procedures; Emergency information concerning evacuation procedures and signals, location of the emergency/first aid station, alarms, deluge showers, eyewash stations, and other emergency equipment; Hazardous chemical labeling system; and Directions to and appropriate locations for eating, drinking, smoking, and sanitation facilities.
Contractor personnel shall sign a Contractor Certification Statement verifying that they have received and understand the information presented.
14.1.2.4 Visitors or Other Non-employee Personnel Visitors will be made aware of the potential hazards in areas where they will visit on site. They will also be made aware of policies designed to avoid hazards and protect their health and safety. The objective of the following procedures is to transmit information to visitors to ensure their safety as well as the safety of facility employees.
The following procedures should apply to visitors: Visitors should not be allowed to proceed anywhere within the facility without supervision. Areas to be excluded will be pointed out. Visitors must observe safety procedures and warning signs. Depending on the areas to be visited, personal protective equipment will be provided. Visitors will be briefed on emergency information concerning evacuation procedures, locations, and signals. Visitors will be made aware of the emergency/first aid equipment, emergency alarms, and other emergency equipment available in the areas to be visited. Visitors will be briefed on the location and availability of material safety data sheets and the chemical labeling system used. Visitors will be informed of appropriate locations for eating, drinking, smoking, and sanitation facilities.
14.1.3 Personal Protective Equipment OSHAs regulations related to Personal Protective Equipment (PPE) are found in 29 CFR 1910 Subpart I (1910.132 to 1910.140). Employers are required to evaluate the workplace to determine where the use of PPE will be required. This is called the Hazards Assessment, and it forms the foundation of the employers PPE Program. It is important to note that the PPE program is only a part of the employers overall health and safety program, and that the correct use of PPE does not negate the employers responsibility to provide workers with a workplace free from recognized health and safety hazards. OSHAs real emphasis is on the elimination of hazards through engineering or administrative controls. The use of PPE is appropriate only after
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such controls have been investigated, and the employer is in the process of implementing these controls, or the implementation of such controls is not feasible. Once PPE has been selected and identified for use for a particular job or work area based upon the information gathered in the hazards assessment, employers must provide this PPE to employees free of charge in most cases. Employees are then required to wear and use the PPE properly. Employers must train employees concerning the proper use, care, maintenance, inspection and disposal of each type of PPE used. Employees must know when PPE is necessary and what PPE is necessary. Employees must also be informed of the limitations of the particular PPE to be used and be instructed in how to obtain a proper fit. Additionally, employees should learn how to recognize when PPE needs to be replaced and how to properly store and clean different types of PPE. An employer must certify in writing that the workplace has been evaluated, and also certify that employees have been trained as mentioned above. An employee who demonstrates that they do not know how to properly utilize their assigned PPE will be selected for retraining, and then must again be certified by the employer. The employer is also required to document the work areas where PPE is required and must identify, in writing, the particular PPE to be used by employees in each work area. This can be in the form of a chart, table, or standard operating procedure. The goal of OSHA regulations is worker protection. PPE regulations identify requirements for assessing the workplace for hazards, selecting appropriate PPE, and training in the proper use and care of PPE.
14.1.3.1 Types of Personal Protective Equipment The main function of Personal Protective Equipment (PPE) is to form a barrier between the hazard and the worker. The correct use of PPE does not eliminate the hazard, it only prevents the hazard from reaching the worker. The types of PPE are based upon the types of hazards which are faced in the workplace. There are hazards from heat, light, sound, abrasive or sharp surfaces, electricity, chemicals, pinching, crushing, puncturing and flying objects. Based on the types of hazards, employees may use one or a combination of the following types of PPE:
Table 14-6 Gloves
Leather gloves Rubber gloves Vinyl or PVC gloves Latex gloves
Types of Personal Protection Equipment (PPE) Eye protection

Safety glasses Safety goggles Splash shields
Head protection
Class A. B. or C hardhats Type I or Type II bump caps
Foot protection
Steel toed shoes Steel toed boots Rubber boots Shoes with metatarsal guards
Hearing protection
Ear plugs Ear muffs
Other
Aprons Chaps Leggings Rubber matting Torso protection
Chain-knit gloves Asbestos or heat resistant gloves
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There are many variations in design, materials of construction, size and application. During the selection process, carefully read the manufacturers recommendations and consult with other users to determine the right PPE for any particular situation. 14.1.4 Respiratory Protective Equipment Because of the nature of respiratory hazards and the potential for occupational diseases from inhalation of dusts, fogs, fumes, mists, gases, vapors and sprays, respiratory protective equipment (RPE) can be the most important type of PPE. Persons required to utilize RPE often do so because of the presence of toxic and potentially lethal gases or vapors in the workplace air. Failure to properly select, use and maintain RPE can have serious implications. The OSHA standard for respiratory protective equipment is found in 29 CFR 1910.134. Employers have to develop a written RPE program which identifies what they will do to comply with the requirements found in this section. As with the general requirements for PPE, a hazards assessment must be conducted to evaluate the workplace for actual or potential respiratory hazards. After the assessment, appropriate respirators must be selected for the nature, extent and characteristics of the hazard(s).
14.1.4.1 Selection of Respirators The selection of RPE involves the following basic steps:
Identification of the hazard; Evaluation of the hazard; and Selection of appropriate RPE based on the first two considerations.
The following are types of respirators that can be selected for use: A half face negative pressure air purifying respirator with appropriate cartridges; A full face negative pressure air purifying respirator with appropriate cartridges; A positive pressure powered air purifying respirator with appropriate cartridges; An atmosphere supplying respirator. This type of respirator may be either an air line respirator with positive pressure, or a self contained breathing apparatus (SCBA), with the pressure demand regulator set for positive pressure.
All respirators selected must be tested and certified by the National Institute for Occupational Safety and Health (NIOSH) as being effective against the contaminant for which it is designed. Respirators are certified as specific units by the manufacturer. Interchanging parts from different respirator manufacturers is strictly prohibited. Note that air purifying respirator cartridges must be selected on the basis of the chemical hazard which is, or may be, present. An air purifying respirator cannot be worn when working with materials which cannot be perceived by odor or which may react with the cartridge material. If a chemical odor is perceived, work must be stopped immediately. In a clean area, the respirator cartridges must be discarded and replaced with a new set. 14.1.4.1.1 Half Face Negative Pressure Respirator The half face negative pressure respirator is an air purifying device that covers the nose, mouth, and chin. It is equipped to handle various types of cartridges that capture gases, vapors, dust particles, mists, and fumes. Since it provides no eye protection, safety glasses or goggles are required when wearing this type of respirator. The half face respirator may be worn when exposure levels are expected to be minimal.
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CAUTION: The half face respirator does not protect against oxygen deficiency, temperature extremes, or hazards not listed on the cartridge label. 14.1.4.1.2 Full Face Negative Pressure Respirator The full face negative pressure respirator is an air purifying device that covers the nose, mouth, and chin, with the addition of a face piece to protect the eyes and face. It should fit snugly around the face and eyes. A full face respirator should be worn when chemical hazards are present to the eyes. If the hazard is present in the form of splashing liquid, additional personal protective equipment may be required. CAUTION: The full face respirator does not protect against oxygen deficiency, temperature extremes, or hazards not listed on the cartridge label. 14.1.4.1.3 Positive Pressure Powered Air Purifying Respirators The Powered Air Purifying Respirator (PAPR) is a modified air purifying respirator. An electric motor attached to the wearers belt pulls air through 2 air purifying cartridges, blowing this purified air into a headpiece which fits loosely around the face and chin. A positive air pressure is maintained to keep contaminants out. This type of respirator is not designed for use around particularly toxic contaminants or with heavy exertion by the wearer. 14.1.4.1.4 Atmosphere Supplying Respirators Atmosphere supplying respirators, either air line or self contained, must be used in environments where the contaminants are unknown and/or the rate of evolution is rapid. This respirator must be used if the possibility of an oxygen deficient or "Immediately Dangerous to Life or Health" (IDLH) atmosphere exists. Air line respirators supply clean air through a hose attached to an ambient air breathing pump or compressor, or from a tank of compressed air. The SCBA allows greater mobility since you carry clean air in a tank on your back. The clean air is supplied from the tank through a regulator to the mask.
14.1.4.2 Respirator Use A tight respirator to face seal is required when conditions mandate respirator usage. Under no circumstances must an employee be allowed to work if facial hair prevents a tight seal when using RPE. This means no beards. Any mustache and all hair must be kept trimmed so as not to interfere with the sealing of RPE. If a respirator does not seal, it is useless.
The respirator to face seal is the most critical factor in the proper use of any negative pressure respirator. There are specific protocols to be followed when fit testing a respirator for use. Properly trained individuals should be consulted to ensure that proper fit testing is conducted.
14.1.4.3 Corrective eye lenses If the temple bars of eyeglasses extend through the sealing edge of the respirator, a proper seal cannot be made. Glasses with either short or no temple bars may be taped to the wearers head. A specially designed pair of prescription safety glasses which fit inside the respirator can be obtained for those employees needing them, provided that the individual presents a current eye prescription.
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Respirator Training Every new employee that will be working in a position which may require them to wear RPE at any time during their employment should be given formal instructions in the use and care of respirators. The training must include at a minimum the following: How and when to wear a respirator; Proper fit test procedures; Respiratory hazards; Proper cleaning, maintenance, and storage; Inspection procedures; and Donning and doffing procedures.
Each employee will also receive a pulmonary function test in order to certify his ability to wear RPE. This testing will be done during their physical, which is done prior to the first day of employment.
14.1.4.4 Cleaning and Storage Respirators should be cleaned after each use regardless of the duration; however, it is suggested that they be cleaned and disinfected monthly. RPE should be inspected during cleaning. Before leaving a work area, gross contamination shall be removed from the respirator, and used cartridges should be discarded. Respirator cleaning may involve disassembly of the respirator and washing in warm water and mild detergent. Once clean, the respirator should be thoroughly rinsed and allowed to air dry.
Respirators must be protected from dust, sunlight, temperature extremes, excessive moisture, and damaging chemicals. Respirators should be kept in carrying cases or cartons and stored in a cool dry place. Plastic ziplock bags are ideal for protecting the respirator against contamination. Respirators should be packed and stored so that the facepiece and exhalation valve will rest in a normal position and function will not be impaired by the elastomer setting in an abnormal position. Respirators placed at stations and work areas for emergency use should be quickly accessible at all times.
14.1.4.5 Inspections Respiratory protective equipment must be regularly inspected. Respirators used routinely should be inspected before each use and after each cleaning. Non-routine respirators kept for emergency use or backup shall be inspected after each use and at least monthly. SCBAs should be inspected monthly to ensure air and oxygen cylinders are fully charged, and that the regulator and warning devices are working properly.
The respirator inspection should consist of checking the following items: Face shield for cracks and wear; Facepiece for warping, pliability, cracks, and wear; Valves, gaskets, and filter elements for pliability, wear, warping, and proper seating; and Headbands for elasticity and wear.
Defects must be reported, and action should be taken to ensure that each employee who needs a respirator has one that is in good working condition. Defective or broken parts
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should be replaced by qualified personnel, or the entire respirator must be replaced if necessary.
14.1.4.6 Medical Evaluation When conditions require the use of respirators, employees are required to be evaluated by a physician to determine if they are physically able to perform and use the equipment. As a part of this examination, a pulmonary function test should be conducted to measure their forced vital capacity and forced expiratory volume to demonstrate their lung capacity and identify any obstructions of restrictive airways. A written conformation from the examining physician certifying their ability to work while using RPE should be placed into the employee files.
14.1.5 Chemical Hygiene Plan The Chemical Hygiene Plan (CHP) is the OSHA Hazard Communication Program for laboratories. The regulation, which is found in 29 CFR 1910.1450 (Occupational exposure to hazardous chemicals in laboratories) is also called the Laboratory Right-to-Know Standard. It applies to employers engaged in the laboratory use of hazardous chemicals, except for procedures that may be or may simulate parts of a production process. The CHP must be written, and must set forth procedures, equipment, PPE and work practices which are capable of protecting employees from health hazards of hazardous chemicals used in the laboratory. Implementing a CHP involves air monitoring to determine employee exposure to hazardous chemicals; development of specific procedures and control measures to minimize chemical exposures (such as the proper use and maintenance of laboratory fume hoods); employee training; medical consultation and surveillance; use of PPE and RPE; and record keeping of all monitoring and measurements taken, and the results of medical surveillance tests. The laboratory should have its own PPE and RPE program, as well as its own Hazardous Chemical Inventory and MSDS program. Finally, the employer has to designate a qualified person to be the company Chemical Hygiene Officer (CHO). The CHO will be responsible for the implementation of all aspects of the CHP and will provide technical guidance and support.
14.2 PLANT PROCESS REGULATIONS

14.2.1 Confined Space Entry Confined spaces can be deadly. OSHAs confined spaces standard (29 CFR 1910.146) defines what a confined space is and identifies requirements for employers to: Identify and mark confined spaces in the workplace, Establish a permit system for any work to be done in certain confined spaces, Set up rescue procedures and obtain equipment where necessary, Identify individuals at the worksite who are responsible for implementing confined space procedures and define their duties in writing, and Develop and carry out a training program for all employees.
Each employer must determine if there are confined spaces on their site. If there are, they must be marked and identified and employees must be advised of their presence and location. The confined spaces must be evaluated to determine if they are "permit required confined spaces" which will require a formal permitting procedure to be implemented before anyone can be allowed to work in the space. This permitting program ensures that any work to be done in the space can
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be done safely and that all safety precautions are taken to guarantee the safety of the workers. Under this program, the positions and duties of the persons responsible for its implementation must be identified. Employers will be required to obtain or utilize equipment, at no cost to employees, to test the atmosphere of the confined spaces for oxygen level and for the presence of toxic and/or flammable gases. Where applicable, employers will have to obtain rescue equipment and train workers concerning proper rescue procedures. Procedures must be in place to prevent unauthorized entries and to provide for sign-off of all activities. Confined space permits and all related records must be kept.
14.2.1.1 Confined Space Safety Programs Before any work may begin, the workplace shall be evaluated to decide if any spaces are permit required confined spaces. Permit required confined spaces have the potential for chemical and physical hazards that make entry immediately dangerous to life and health. The atmosphere may be oxygen deficient, toxic, flammable, or explosive. The confined space also may contain hazards such as slippery or uneven floors. Entry can only be authorized when acceptable entry conditions are obtained. The Entry Permit is mandatory for any operation that requires an employee to enter or work inside a confined space. 14.2.1.2 Responsibility and duties A permit required confined space entry requires the approval of an Entry Supervisor. The Entry Supervisor is responsible for determining if acceptable entry conditions are present, for authorizing and overseeing entry operations, and for terminating the entry. The duties of the Entry Supervisor include the following:
Knows the hazards that may be faced during entry, including information on the mode, signs or symptoms, and consequences of chemical exposure; Before endorsing the permit and allowing entry to begin, verifies that all tests specified by the permit are conducted and that all procedures and equipment specified by the permit are in place; Verifies that rescue services are available and that the means for summoning them is operable; Removes unauthorized individuals who enter or who attempt to enter the permit space during entry operations; Determines that entry operations remain consistent with terms of the entry permit and that acceptable entry conditions are maintained; and Terminates the entry and cancels the permit as warranted.
Attendants, stationed outside the permit space, monitor the Authorized Entrants and are responsible for their safety. Attendant duties include the following: Know the hazards that may be faced during entry, including information on the mode, signs or symptoms, and consequences of the exposure; Be aware of possible behavioral effects of hazard exposure in Authorized Entrants; Continuously maintain an accurate count of Authorized Entrants in the permit space and ensure that the means used to identify entrants accurately identifies who is in the permit space; Remain outside the permit space during entry operations until relieved by another Attendant;
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Communicate with Authorized Entrants as necessary to monitor entrant status and to alert entrants to evacuate the space; Monitor activities inside and outside the space to assess safety for the entrants to remain in the space; Summon rescue and other emergency service when determined that the Authorized Entrants may need assistance to escape from permit space hazards; Prevent unauthorized entry into confined space; Perform non-entry rescues; and Perform no duties that might interfere with the Attendant's primary duty to monitor and protect the Authorized Entrant.
Authorized Entrants, those employees authorized to enter a permit space, duties include the following: Know the hazards that may be faced during entry, including information on the mode, signs or symptoms, and consequences of the exposure; Properly use any needed equipment; Communicate with the Attendant as necessary to enable the Attendant to monitor entrant status and to enable the Attendant to alert entrants of the need to evacuate; Alert the Attendant whenever the entrant recognizes any warning sign or symptom of exposure to a dangerous situation or the entrant detects a prohibited condition; and Exit from the permit space as quickly as possible whenever an evacuation order is given, or whenever the entrant recognizes any warning sign or symptom of exposure to a dangerous situation or when the entrant detects a prohibited condition.
Rescue Personnel, those employees designated to perform rescue operations from permit spaces, duties include: Know the configuration and potential hazards of each permit space; Develop appropriate rescue plans; Participate in simulated rescue operations; and Know Authorized Entrant duties and responsibilities.
14.2.1.3 The Confined Space Permit Before entry is authorized, a Confined Space Entry Permit must be completed, documenting the spaces safety and completion of safety measures. The completed permit will be made available at the time of entry to all Authorized Entrants by posting it at the entry portal or by other equally effective means. This will confirm to the entrants that pre-entry preparation has been completed, and will remain posted as long as the permit is valid. The duration of the permit may not exceed 8 hours or the assigned task or job identified on the permit.
The Confined Entry Permit, completed by the Entry Supervisor, includes the following information: Permit space identification; Entry Purpose; Date and duration of permit;
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Names of Authorized Entrants; Names of current Attendants; Name and signature of original and current Entry Supervisor; Hazard(s) in the permit space; Isolation measures and means of eliminating or controlling hazards; Acceptable entry conditions; Test results, including initials of person performing the tests; Rescue and emergency services and means to summon them; Communications procedures for Attendants and Authorized Entrants; Required equipment; and Any additional information and permits.
The Entry Supervisor will terminate entry and cancel the permit when the entry operations covered by the permit are completed or when a condition that is not allowed under the permit arises in or near the permit space. Canceled entry permits shall be retained for a period of at least one year for the purpose of reviewing the program depending on facility retention policy. Problems encountered during an entry operation will be noted on the pertinent permit so that appropriate program revisions can be made.
14.2.1.4 Pre-entry Preparation The specific design or nature of a confined space will determine what practical and common sense precautions shall be taken. Adequate safety measures to protect the worker from possible dangers will be evaluated based on current conditions and circumstances.
Danger signs, posted near permit required confined spaces, notify employees of the location of permit spaces and state that unauthorized entry is prohibited. The confined space must be sufficiently barricaded to protect entrants from external hazards. This may be accomplished by roping off the area, using saw horse barricades, or other applicable methods. The confined space must be cleaned, flushed, or purged to the maximum extent possible prior to entry. Atmospheric hazards will be eliminated by purging, inerting, flushing, or venting. The confined space will be isolated by the following means: Following Lockout/Tagout procedures, all electrically operated equipment or electrical lines connected to the confined space must be taken out of service before entry; All process lines connected to the confined space must have their valves chained and locked in the closed position or blanked with a solid flange, and identified with a "Danger" Tag; and Instrument leads, blow back lines, purge connections, drains and possible sources of contaminating material must be physically disconnected, blanked, or chained and locked in the closed position.
After cleaning and isolation, the permit space conditions must be evaluated. The internal atmosphere will be tested with a calibrated direct-reading instrument to determine if acceptable entry conditions exist. Entry conditions shall be continuously monitored in the areas where Authorized Entrants are working to determine if acceptable conditions are being maintained during the course of operations. The atmosphere will be tested for oxygen
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content, flammable gases or vapors, and potential toxic air contaminants. authorized when the following conditions are met: Entry will be
Atmospheric concentrations of oxygen are above 19.5% and below 23.5%; Flammable gas, vapors, or mist is below 10% of its Lower Explosive Limit (LEL); Atmospheric concentrations of substances for which a Permissible Exposure Limit (PEL) is published in 29 CFR Subpart G or Z have been feasibly reduced by engineering controls; and Other atmospheric conditions that are immediately dangerous to life and health have been eliminated.
All equipment must be adequately prepared and maintained to protect the workers involved. Before entry, Authorized Entrants and Attendants will be provided with the necessary equipment and training to do the job safely. The following equipment may be used during an entry: Atmospheric testing and monitoring equipment; Ventilation equipment, as needed, to obtain acceptable entry conditions; Communications equipment that enables the Attendant to monitor entrant status and to enable the Attendant to alert entrants of the need to evacuate the space; Personal protective equipment if feasible engineering and work practice controls do not adequately protect employees; Lighting equipment needed to enable employees to see well enough to work safely and exit the space quickly in an emergency; Barriers and shields as necessary to protect entrants from external hazards; Equipment, such as ladders, needed for safe ingress and egress by Authorized Entrants; Rescue and emergency equipment; and Any other equipment necessary for safe entry into and rescue from permit spaces.
For the duration of entry operations, at least one Attendant shall be stationed outside the permit space into which entry is authorized. Attendants may be stationed at any location outside the permit space to be monitored as long as their duties can be effectively performed for each monitored permit space. When entry operations have been completed or a condition that is not allowed under the entry permit arises in or near the permit space, the Entry Supervisor shall close the permit space and cancel the permit. Canceled permits shall be retained for a period of at least one year. Entry operations will be reviewed if there is reason to believe that the measures taken under the confined space permit program may not have protected the employee. The program will be revised to correct any deficiencies before subsequent entries are authorized. The Permit Required Confined Space Program will be reviewed annually, covering all entries performed during a 12 month period. The program will be revised as necessary to ensure that employees participating in entry operations are protected from permit space hazards.
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14.2.1.5 Rescue and Emergency Services If the Attendant determines that activities inside or outside the confined space make it unsafe for entrants to remain in the space, evacuation orders will be given immediately. The Attendant shall summon help by using the emergency communications and will provide immediate assistance to the entrant(s), without entering the confined space or jeopardizing their own life. 14.2.1.6 Confined Space Rescue Rescue personnel must receive specialized and extensive training in order to be qualified to perform rescue operations. Rescue operations involving confined spaces can be dangerous and risky, especially if the rescue requires entry into the confined space. Non-entry rescue procedures are often preferred. This involves the use of harnesses and extraction lines by the entrants, enabling personnel outside of the confined space to extract or rescue the entrant without entering the confined space. Communication is critical in performing this kind of operation so that the attendant maintains contact with the entrant at all times, either verbal, visual or by some other effective means. The attendant is not authorized to enter the confined space unless he is relieved by another attendant. The role of the attendant is to "attend" to the entrant, and to be sure he/she is safe.
Whenever non-entry rescue procedures are utilized, the roles of all personnel involved must be clearly defined and understood. All procedures and responsibilities are to be documented. If at any time during entry operations there is a questionable action or non-movement by the Authorized Entrant inside, a verbal check shall be made. If there is no response, the worker will be removed immediately. If the entrant is disabled because of falling or impact, the entrant will not be removed unless there is immediate danger to life and health. The on-site rescue service shall be notified immediately and will implement emergency procedures to fit the situation. The Attendant may enter the confined space in case of an emergency (wearing appropriate personal protective equipment) only after being relieved by another attendant. A safety belt or harness with attached lifeline shall be used by all workers entering the space with the free end of the line secured outside the entry opening. The Attendant shall attempt to remove disabled entrant via his lifeline before entering the space. When entry must be through a top opening, the safety belt shall be of the harness type that suspends a person upright and a hoisting device or similar apparatus shall be available for lifting entrants out of the space. In any situation where their use may endanger the entrant, use of a hoisting device or safety belt and attached lifeline may be discontinued.
14.2.1.7 Training Training must be provided to all employees involved in confined entry operations. The training provides employees with the understanding, knowledge, and skills necessary for the safe performance of their duties. Training is provided to each affected employee:
Upon initial assignment; Whenever there is a change in assigned duties; Whenever there is a change in permit space operations that presents a hazard about which an employee has not been previously been trained; and Whenever there are deviations from the permit program or that there are inadequacies in the employee's knowledge of use of the program.
Rescue service personnel also need to practice and be trained in the following:
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Proper use of rescue and personal protective equipment necessary for making rescues; Assigned rescue duties; Authorized Entrant duties and responsibilities; Basic first aid and CPR; and Simulated rescue operations.
14.2.1.8 Contractors When contractors are employed to perform work that involves permit space entry, they will be informed and apprised of the following:
The presence of permit spaces and that entry is allowed only through compliance with the Permit Required Confined Space Entry Program; Available information regarding the elements, including the hazards identified, and experience with the permit space; and Precautions and procedures that have been implemented for the protection of employees in or near the permit space where contractor personnel will be working.
Entry operations will be coordinated when both the host and contractor personnel will be working in or near the permit space. The contractor will be debriefed at the conclusion of entry operations regarding the permit space program and any hazards confronted or created during entry operations. 14.2.2 Lockout / Tagout - The Control of Hazardous Energy The Control of Hazardous Energy Standard is also referred to as the Lock Out/Tag Out standard, because it involves the actions of locking out and/or tagging out energized equipment. Every year, hundreds of accidents occur as a result of failure to properly lock out equipment before attempting to service or work on it. The purpose of this standard is to protect workers from the hazards of energized equipment in the workplace. The standard, found in 29 CFR 1910.147, applies to those who must work on energized equipment. The employer must evaluate the workplace to identify the location and type of energy source (electrical, steam, pneumatic) for all workplace equipment and then identify all the energy isolating devices which are part of each machine. An energy isolating device is a device which physically prevents the transmission or release of energy (circuit breakers, disconnect switches, valves, etc.). When work must be conducted on equipment the energy source must be "locked out"; in other words, a lock must be placed on the energy isolating device so that the equipment cannot be energized. In addition, the same device is tagged out; a tag is placed on the device which clearly and noticeably states "Do not energize this equipment!" If an energy isolating device is not capable of being locked out, the employers energy control program shall utilize a tagout system. To ensure safety, there is a definite step by step procedure to follow, and each employee who is authorized to work on equipment will have his own locks and keys. Employers are responsible to provide training about the regulation and its requirements. The employer must also educate employees about the dangers of servicing energized equipment and concerning the specific responsibilities of employees related to this standard. Employees who are authorized to service equipment will be identified and all other affected employees will be informed.
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14.2.2.1 The Lock Out/Tag Out or Energy Control Program The Energy Control Program contains practices and procedures that will protect employees from the hazards associated with the servicing and maintenance of machines and equipment, and complies with 29 CFR 1910.147. The program applies to the control of energy only during maintenance and/or servicing of machines and equipment in which the unexpected energization or start-up of the machines or equipment, or release of stored energy, could cause injury. Normal production operations are not covered unless:
An employee must remove or bypass a guard or other safety device; or An employee must place any part of his/her body into an area on a machine or piece of equipment where work is performed such as the point of operation, or any zone where the machine or equipment may present a hazard if unexpectedly energized.
14.2.2.2 Definitions Authorized Employees - Those employees who the facility authorizes to perform the lock out/tag out before service or maintenance.
Affected Employees - Those employees who use or work near machines or equipment that is locked or tagged out during service or maintenance. This also includes employees who will conduct the service or maintenance. Other Employees - Those employees who may be in the area.
14.2.2.3 The Lockout Permit The Lockout Permit is a document that must be completed prior to any equipment service or maintenance. The signature of an Authorized Employee is required. The following information must be on the Lockout Permit:
Signatures of Affected Employees; Permit expiration date; and Signatures of Authorized Employees.
The Lockout Permit expires when the job is complete or there is a change in work crews. A new Lockout Permit is required at each change of work crew. When the original Authorized Employee is relived, but the Affected Employees are the same, the oncoming Authorized Employee must countersign the permit within thirty (30) minutes of assuming responsibility for the job. The expired Lockout Permit will be retained based on facility retention policy.
14.2.2.4 Responsibilities It shall be the responsibility of the department that operates the equipment to initiate the Lockout Permit. The Authorized Employee is responsible for shutting down equipment and making it safe to work on. The Authorized Employee is the first to tag and lock out the equipment.
The Affected Employee is responsible for satisfying himself that the conditions under which he is working and the conduct of his work is safe for himself and his fellow workers. He must sign the tag and apply his lock to the equipment immediately after the Authorized Employee.
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14.2.2.5 Procedures A double responsibility procedure will be used to ensure maximum protection. work is performed on equipment, the tag and locks shall be applied by the Employee. No person will be allowed to work on power driven equipment or accessories unless the equipment or machine can be locked and tagged. The Employee initiates the lockout in the following manner:
Whenever Authorized connected Authorized
Before an employee performs any servicing or maintenance on a machine or equipment, the machine must be isolated and rendered inoperative. Switch off the equipment according to the manufacturer's instructions. This must be done without creating new hazards. Turn the equipment power off at all energy isolating devices needed to control the equipment or machine. Sometimes energy is stored in parts like springs, rotating flywheels, or water pressure systems. If so, that energy must be dissipated or restrained with such techniques as blocking and bleeding. The Authorized Employee must attach a "DANGER--DO NOT OPERATE" tag on the power control unit switch in the "off" position. The Authorized Employee who placed the "DANGER" tag must completely fill out the tag, including the date and their signature. The Authorized Employee will then attach a multiple lockout adapter to the switch and put the first lock on the adapter. Methods of attaching the adapter to the switch will vary according to the type of switch to be locked out. Each Affected Employee who is to work on or in the equipment must verify that the equipment is clear and inoperable by placing his signature on the tag, and lock on the lockout adapter. This must be done in the presence of the Authorized Employee who is responsible for tagging operations on that shift. The starter button must be tried to insure that the correct switch has been used and to determine that the equipment or machine is inoperable and fully de-energized. Conditions may arise that make it impossible for a repairer to remove his lock. The Authorized Employee may authorize lock removal. The lock may be removed by the person placing it on or by his authorized relief, after ensuring that all work is complete and after all other locks are removed. When work is interrupted, the lock and the "DANGER" tag shall be left on the switch gear. In instances where frequent and repetitive starting and stopping of motor driven equipment may be required as part of the servicing or maintenance, or where it would be impractical for a supervisor or designate to attend the repetitive locking and unlocking sequences the following precautions shall be taken: o o All tools and materials must be removed from the area. Affected and other employees also must leave the area. When frequent starting/stopping becomes necessary, the Authorized Employee may remove his lock, leaving the "DANGER--DO NOT OPERATE" tag and repair locks on the switch. Affected Employees will remove their locks only when it is necessary to jog or move the equipment, reattaching the locks when such moving is complete and before recommencing work on such equipment. Specific cleaning or inspection routines, performed frequently, may require exceptions to this procedure. Always, authorization shall be obtained in writing.
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14.2.2.6 Release of Lock Out/Tag Out Before lock out or tag out devices are removed and energy is restored to the machine or equipment, the Authorized Employee must ensure the following:
The work area must be inspected to ensure that all nonessential items have been removed and the machine or equipment is operationally intact. All Affected Employees must be notified that the lock out/tag out devices have been removed. Each lock out/tag out device must be removed from each energy isolating device by the Affected and Authorized Employee(s) who applied the devices. The equipment must be tested to ensure that it is safe to operate prior to beginning production. Once the equipment passes the test, it may be placed back into full production.
14.2.2.7 Training Employees will be trained to ensure that the purpose and function of the Energy Control Program are understood and that the knowledge and skills required for the safe application, usage, and removal of the energy control are acquired. Training includes the following:
Authorized Employees receive training in the recognition of hazardous energy sources, the types and magnitude of the energy available in the workplace, and the methods and means necessary for energy isolation and control. Affected employees are instructed in the purpose and use of the energy control procedures. All other employees whose work operations are or may be in an area where energy control procedures may be utilized, will be instructed about the procedure, and about the prohibition relating to attempts to restart or re-energize machines or equipment which are locked or tagged out.
When tag out systems are used, employees are trained in the following limitations of tags: Tags are essentially warning devices affixed to energy isolating devices, and do not provide restraint on those devices that is provided by a lock. When a tag is attached to an energy isolating means, it is not to be removed without authorization of the Authorized Employee responsible for it, and it is never to be bypassed, ignored, or otherwise defeated. Tags must be legible and understandable by all Authorized Employees, Affected Employees, and all other employees whose work operations are or may be in the area, in order to be effective. Tags and their means of attachment must be made of materials which will withstand the environmental conditions encountered in the workplace. Tags may evoke a false sense of security, and their meaning needs to be understood as part of the overall Energy Control Program. Tags must be securely attached to energy isolating devices so that they cannot be inadvertently or accidentally detached during use.
Retraining will be provided for Authorized and Affected Employees whenever there is a change in their job assignments, a change in machines, equipment or processes that present a new hazard, or when there is a change in the energy control procedures.

14.2.3 Forklift Safety Forklifts, or powered industrial trucks, are widely used throughout general industry. There are a variety of models, styles, sizes and functions and without them business productivity would suffer greatly. At the same time, forklifts pose a serious health and safety hazard to those employees working with or around them. Accidents and injuries involving forklifts are often serious, and there have been many fatalities as a result of accidents. Forklift safety regulations are needed to ensure that employers develop procedures and programs to train employees concerning safe operation. OSHAs Powered Industrial Trucks regulation (29 CFR 1910.178) requires that "...only trained and authorized operators...be permitted to operate a powered industrial truck." Employers must have a formal program of training and instruction for forklift operators. This training must instruct employees concerning the safe operation of forklifts and enable forklift operators to understand the potential safety hazards. An effective forklift operator training program should contain safety training and procedures related to the following elements: General Operating Instructions, Pre-Startup Daily Inspections, Traveling and Cornering, Transporting a Load, Loading and Unloading of Vehicles, and Fueling, Charging and Maintenance.
An operator must fully understand and be able to safely use all the functions of the forklift he or she must operate. It is recommended that the Owners Operating Manual be reviewed as part of the training. A forklift must be in safe operating condition before it can be safely operated. Daily or pre-startup inspections will ensure that forklifts which are not in safe operating condition are not operated. Records must be kept of these inspections. Operators must know how to safely navigate a forklift in any circumstance encountered in the workplace, such as loading, unloading, cornering, traveling, etc. The employers forklift safety program must identify those to be trained. It should also indicate how and when they will be trained. The content of the training should be customized to each workplace.
14.3 OPERATOR REGULATIONS

14.3.1 Emergency Action Plans Emergencies can occur at any time and anywhere. In order to ensure that employers provide for employee safety during workplace emergencies such as fires, explosions, and weather related emergencies, OSHA requires certain employers to prepare an Emergency Action Plan. The Emergency Action Plan (EAP) will identify what the employer and employees will do in an emergency. The employees will evacuate the workplace according to the instructions given in the EAP. This usually involves knowing the means by which the employer will notify the employees of an emergency, such as a fire alarm, intercom announcements, or flashing lights. Additionally, employees will need to know the location of all exits, including the location of the exit closest to each work area. The employer will assign certain employees to account for everyone to ensure that everyone has evacuated safely after an alarm.
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Phone numbers of emergency services will be identified and instruction will be given as to who will contact those services and when they are needed. Employees will receive training to review the details of the EAP for their particular facility. The requirements for emergency action plans are found in 29 CFR 1910.32. In some cases, a facility is already required to have an Emergency Response Plan because of other OSHA regulations such as Process Safety Management or the HAZWOPER standard, or because of EPA requirements. A separate EAP will not be required or necessary in these cases. 14.3.2 Fire Extinguisher Safety Fire extinguishers, when properly used, become a vital part of a companys fire prevention program. It is much easier to deal with a fire when it is in its beginning stages and is small enough to be extinguished with a portable fire extinguisher. However, there are inherent dangers associated with any fire and even with the use of fire extinguishers. Using a fire extinguisher safely and effectively is critical and requires training and education. OSHA standard 29 CFR 1910.157 details requirements for employers. Whenever an employer plans to have and use fire extinguishers, OSHA requires that the fire extinguishers be properly distributed so that 1) there are enough fire extinguishers for use, and 2) the fire extinguishers are spaced so that they can be easily reached from any point in the workplace. In addition, all fire extinguishers must be inspected regularly and be properly maintained and tested. The employer must keep a list of all site fire extinguishers. The employer also must train employees expected to use fire extinguishers concerning the proper and safe use of fire extinguishers along with the hazards of dealing with small fires in the workplace. 14.3.3 Hearing Conservation OSHAs standard on occupational noise exposure, 29 CFR 1910.95, requires employers to provide protection against the effects of noise exposure in the workplace. Where noise exposure is detected, an employer must write an effective hearing conservation program, with requirements for monitoring, audiometric testing and evaluation, training, provision of hearing protection devices and record keeping. The action level at which the standard becomes effective is an eight hour TWA (time weighted average) of 85 decibels on the A scale, or 85 dBA. If the 8 hour TWA is at or above 90 dBA, feasible administrative or engineering controls must be implemented to reduce noise levels. If these controls do not reduce the TWA below 90 dBA, or where use of such controls is economically or mechanically infeasible, then personal protective equipment (hearing protection devices) must be provided by the employer and used by the employee to reduce their exposure to less than the 90 dBA 8 hour TWA. 29 CFR 1910.95 requires that a hearing conservation program be implemented for employees exposed to noise levels above the 85 dBA TWA. This program requires: Baseline and annual audiometric exams, Provision of a variety of hearing protection devices for employee selection and use, Periodic monitoring of the work areas, Training covering proper use of hearing protection devices and the nature of sound induced hearing loss, Record keeping, and Establishment of a written program explaining the hearing conservation activities as listed above.
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Areas with noise levels near 85 dBA should be periodically monitored using a dosimeter to measure the 8 hour TWA for affected employees. 14.3.4 The HAZWOPER Standard "Hazwoper" is an acronym which stands for the Hazardous Waste Operations and Emergency Response Standard drafted by OSHA, effective since 1991. The standard can be found in 29 CFR 1910.120. It consists of 2 parts: Hazardous Waste Operations and Emergency Response. It was developed by a joint effort of both OSHA and EPA and was intended to address those persons involved in cleaning up hazardous wastes or responding to emergencies. Regulations were already in place for industrial settings, but the particular circumstances involved with cleanups and emergency response was not adequately addressed. Hence, Hazwoper came into being. The section of the standard on "hazardous waste operations" applies mainly to Permitted TSD (Treatment, Storage and Disposal) facilities and to operations involving the cleanup of hazardous wastes as a result of RCRA corrective actions or actions under CERCLA. The Emergency Response section, however, is much broader in scope and applies to the majority of general industry. In particular, if you have hazardous substances on your site (including any hazardous waste) and your employees work in an area where the substances are present and therefore may witness a release or spill of those substances and must take any actions, the standard will apply. The exception would be where the employer does not allow any employee to take any action to clean up any spill or release of any hazardous substance, and the employer has implemented an Emergency Action Plan as required in 29 CFR 1910.38. Applying this exemption may be a desirable option for some employers, mainly because of the fact that they are exempted from the requirements of the standard. These employers could also argue that they are preventing possible employee exposures to hazardous substances. On the other hand, many employers prefer the advantages of being able to take certain basic, defensive actions during an emergency spill or release in order to minimize the severity of a spill and its impact on other workers and the environment. Decisive actions can often prevent a spill or release from escaping the site and potentially exposing neighbors or the surrounding community to hazardous substances. An appropriate first response to an emergency situation can often be the difference between a major catastrophe and a relatively minor incident. Under section (q) of the standard, there are substantial requirements which include training, development and/or implementation of emergency response or emergency action plans, record keeping, and medical surveillance. There is also some overlap with other OSHA standards and also with DOT and RCRA standards pertaining to the handling of hazardous materials. The requirements for general industry are mainly related to the emergency response portion of the standard for employee training. Varying levels of training are required based on an employees potential level of involvement in an emergency. An employee who is expected to recognize when a particular release constitutes an emergency would get a minimum of what OSHA calls "awareness level" training. An employee taking defensive actions to prevent the spread of a release would be required to have a minimum of "operations level" training (8 hour training). Those employees who must take offensive actions to approach the point of release require a minimum of 24 hours of training at the "hazardous material technician" level. Hazwoper training requirements are also performance based. This means that the employees must obtain the required hours of training and master the competencies referred to in the standard. Employees must be retrained annually to maintain competency levels.
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14.3.5 Emergency Response Staff
14.3.5.1

First Responder (Awareness Level)
Will witness or discover a release of hazardous materials, and has the following training: Knows what a hazardous material is and understands the risks associated with them in an incident. Understands the potential outcome associated with a hazardous material incident. Can recognize the presence of hazardous material in an emergency. Can identify the hazardous material, if possible. Understands the contingency plan and its implementation. Able to notify the proper authorities.
14.3.5.2
First Responder (Operations Level)
Responds to releases of hazardous material in a defensive manner. Does not try to stop the release. Has the following training: All first responder awareness level requirements. Knowledge of basic hazard and risk assessment techniques. Can select and use proper PPE. Understands basic hazardous material terminology. Can perform basic control, containment, and/or confinement operations. Can implement basic decontamination procedures. Understands relevant standard operating procedures.
14.3.5.3 HAZMAT Technician Responds aggressively to stop the release of hazardous materials. training:
All first responder operations level requirements. Knows how to implement contingency plans.
Has the following
Can classify, identify, and verify known and unknown materials through the use of monitors and survey equipment. Able to function within an assigned role in the incident command system. Can select and use specialized PPE. Understands hazard and risk assessment techniques. Able to perform advanced control, containment, and/or confinement operations. Understands and can implement decontamination techniques. Understands basic chemical and toxicological terminology and behavior.
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14.3.5.4 HAZMAT Specialist Responds with and in support to HAZMAT technicians, but also has specific knowledge of various hazardous substances. Training at this level includes:
All requirements of HAZMAT Technician level. Knows how to implement the local emergency response plan. Can classify, identify, and verify known and unknown materials through the use of advanced monitors and survey equipment. Knows of the state emergency response plan. Can select and use specialized PPE. Able to perform specialized control, containment, and/or confinement operations. Understands and can implement decontamination procedures. Can develop a site safety and control plan. Understands chemical, radiological, and toxicological terminology and behavior.
14.3.5.5 On Scene Incident Commander Assumes control of the incident scene beyond the first responder awareness level. Training at this level includes:
All requirements of first responder operations level. Can implement incident command system. Understands the hazards and risks associated with employees working in PPE. Can implement the local emergency response plan. Knows of the state emergency response plan and of the federal regional response team. Understands the importance of decontamination procedures.
14.4 SUMMARY
Depending on your workplace, you may need to comply with various other OSHA regulations. More information can be found from your employer and from 29 CFR 1910.
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The SOCMA Chemical Process Operator Training Course

SECTION 14: OSHA SAFETY COMPLIANCE

The SOCMA Chemical Process Operator Training Course

OSHA Safety Compliance Revised: March, 2009

The SOCMA Chemical Process Operator Training Course

Table 14-1 Chemical

Applicable OSHA Regulations by Category Plant Process

14.1 CHEMICAL REGULATIONS

OSHA Safety Compliance Revised: March, 2009

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Subpart Z Regulated Chemicals Chemical name

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Three of the top 25

Top 25 Most Cited Violations of OSHA 1910 -- 2007 Standard

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The SOCMA Chemical Process Operator Training Course

The SOCMA Chemical Process Operator Training Course

The SOCMA Chemical Process Operator Training Course

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The SOCMA Chemical Process Operator Training Course

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Types of Personal Protection Equipment (PPE) Eye protection

Chain-knit gloves Asbestos or heat resistant gloves

OSHA Safety Compliance Revised: March, 2009

The SOCMA Chemical Process Operator Training Course

OSHA Safety Compliance Revised: March, 2009

The SOCMA Chemical Process Operator Training Course

OSHA Safety Compliance Revised: March, 2009

The SOCMA Chemical Process Operator Training Course

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14.2 PLANT PROCESS REGULATIONS

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The SOCMA Chemical Process Operator Training Course

OSHA Safety Compliance Revised: March, 2009

The SOCMA Chemical Process Operator Training Course

OSHA Safety Compliance Revised: March, 2009

The SOCMA Chemical Process Operator Training Course

OSHA Safety Compliance Revised: March, 2009

The SOCMA Chemical Process Operator Training Course

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The SOCMA Chemical Process Operator Training Course

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The SOCMA Chemical Process Operator Training Course

OSHA Safety Compliance Revised: March, 2009

The SOCMA Chemical Process Operator Training Course

Whenever Authorized connected Authorized

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The SOCMA Chemical Process Operator Training Course

14.3 OPERATOR REGULATIONS

OSHA Safety Compliance Revised: March, 2009

The SOCMA Chemical Process Operator Training Course

OSHA Safety Compliance Revised: March, 2009

The SOCMA Chemical Process Operator Training Course

OSHA Safety Compliance Revised: March, 2009

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