Environmental, Health & Safety Update

 

At the recent TXAPA Seminar OSHA went over the top 10 violations cited in 2016. For construction, the top 10 did not differ from the past several years. Fall protection, PPE, hazard communication (written program) and Training are again on the list. OSHA is also using the General Duty Clause more and more to cite hazards that don’t have a specific OSHA standard. Take away...make sure your safety programs pay close attention to these areas.

Remember that Electronic Submission of OSHA 300 Data starts this year. Employers with 20 or more employees at a location that already are required to keep the OSHA 300A Log will submit data annually into an OSHA electronic database. Submissions for 2017 are due July 1.

 

OSHA is proposing to add requirements to post jobsite longitude & latitude or other specific descriptions for remote jobsites to aid EMS in case of medical emergency. The possible change also requires employers to ensure that their worksite communications system for contacting an ambulance service can reach emergency responders. Rule or not...This should be a best practice for anyone working in remote regions. When working remotely make sure cellular service is available...if not consider the temporary use of a satellite phone to summon emergency help.

 

EPA isn't wasting any time cracking down on hazardous chemicals as the new year gets underway. Under the newly updated Toxic Substances Control Act (TSCA) the Agency is phasing out some commonly used degreasers such as Trichloroethylene and Perchloroethylene. These chemicals are present in most of the degreasers that are used in most mechanic shops. They work really well but are being phased out due to environmental and health concerns. The bottom line is that if your shops use products containing such chemicals then you should be looking for alternatives. The down side is that the current substitute chemicals do not work as fast and as efficiently as the ones being phased out meaning that degreasing and removing asphaltic substances is going to get more difficult.

 

 

OSHA wants to stop using the term "threshold limit values (TLV)" in 29 C.F.R. 1926.55, a rule covering toxic chemicals used during construction. The correct phrase is "permissible exposure limit (PEL)," OSHA says. For our industry this would apply to chemicals such as silica, solvents such as toluene (used in striping operations), and petroleum distillates. Solvents that are in cleaners used in shops would also be included.

 

Remember Silica? It was issued March 25, 2016; became effective June 23, 2016; and covers General Industry, Construction and Maritime. Compliance effective date for Construction is June 23, 2017; for General Industry it is June 23, 2018. The rule states:

•Permissible Exposure Limit (PEL) is 50 µgm/m3 (micrograms per cubic meter) averaged over an 8 hour day

•Requires employers to use wet methods or ventilation to reduce exposure

•Provide respirators if exposure remains

•Restrict access to exposure areas

•Develop a written exposure control plan

•Offer medical exams to highly exposed workers  

Silica is definitely present in our industry. You should make an assessment to find out if silica is going to be an exposure issue for your employees (if you have not done so already). How much is 50 micrograms per cubic meter? In English measurement terms that amount equals 0.000000003121 pounds per cubic foot. THAT’S NOT MUCH!! This will likely be the next "asbestos" with regard to future litigation. We need to pay attention to this rule.

 

https://www.osha.gov/silica/