1. Setting standards for record keeping requirements, will help in collecting better information on the incidences and nature of occupational diseases. These information are collected on a national basis. Setting standards for recording keeping will help in effective analysis of this information. It can also improve employee’s awareness and involvement in reporting and recording occupational injuries. Majority of the company records are computerized and are easy to access. Employees can log into his account and report his injury, in the employer’s website. It also creates awareness in the employers, on the type of illness or hazard their employees face at workplace, and helps to initiate steps, in correcting hazardous workplace situations. It can also help to plan and manage safety and health programs, more effectively. When employees are aware of workplace hazards, they become motivated to follow safe workplace practices. (Reese & Eidson, 2006)
These records are an important source of information for OSHA, and are reviewed by the OSHA representatives, during inspection. These records help OSHA identify specific injuries and hazards related to a particular workplace. This information, helps to target intervention in the identified area. It also helps OSHA in reviewing the success, of such intervention. Records help to ensure effective implementation of regulatory interventions and other measures. Records also act as source of information, for the BLS-generated nationwide statistics. In a nationwide annual survey, BLS collects data from employers of all private and public sector industries. These data are then organized and analyzed. The statistical information, so generated is made available for research purposes and public information. BLS has been publishing statistic related to occupational hazard and injury since 1971. The nature and magnitude of injury or illness across states, and across countries is revealed by this statistics. This statistical information is used by federal, state and local governments to make decisions concerning health and safety legislations. (Osha.gov, 2015)
2. NIOSH and OSHA have worked together in the 2010 Deepwater Horizon rig explosion cleanup efforts. NIOSH provided OSHA with technical expertise and exposure monitoring during these efforts. Both these agencies worked together and ensured that the clean-up workers are protected from harmful exposures, such as heat, chemicals and other hazards. These two agencies are separate, and were created under the Occupational and Health Act, 1970. Occupational Safety and Health Review Commission was also established under this act. OSHA was devised as an enforcement agency, while NIOSH was designed as a research arm. OSHA reports its activity to the secretary of labor and NIOSH reports its activity to secretary of health and human services. NIOSH does research and develops solutions that help provide a safe work environment and makes recommendations to OSHA, based on these researches. OSHA uses the recommendations to develop standards, and enforces them as rules to keep the workers safe. OSHA is concerned with handling immediate issues, while NIOSH has a long term perspective. (Safetyandhealthmagazine.com, 2012).
OSHA representatives are authorized to conduct planned or surprised inspection of firms and have the authority to question privately, the employers and the employee. It also has subpoena power and requires the employers to maintain records. If OSHA comes across violations during its annual inspection, citations are issued against the alleged violators. These citations lists the alleged violations and notices of penalty for each violation. The affected employer can challenge against these citations, within 15 days, to the Occupational Safety and Health Review Committee. Occupational Safety and Health Review Commission is concerned with reviewing contested OSHA citations. The challenge is heard by an administrative law judge of OSHA. If the employer is still dissatisfied with the committee’s order, he can appeal with 30 days to the U.S federal court. (Reese & Eidson, 2006)
3. NFPA 101 contains the Life Safety Code of National Fire Protection Association, 2009 and it provides a detailed description of emergency exit requirements. Many of the requirements in NFPA code are similar to those mentioned in OSHA standards. For example, OSHA standard 1910.36 is similar to the NFPA101-2009 chapter 7 (paragraph 7.1.1.4.2) emergency exit requirements. Both these standards require a side hinged door for connecting any room with the exit. The 1910 Subpart E of OSHA standards deals with exit routes and emergency planning. (Klinoff, 2015)
1910.34 code is similar to the NFPA101 Chapter 3 life safety code: It provides rules and standards for design, construction and arrangement of egress of buildings and structures. It establishes regulations affecting structures, processes, premises and safeguards relating to any hazard like fire, explosion, etc. It has three parts: part a) covers all employers, part b) covers exit routes and part c) provides definitions for different terms used in these chapters. (Klinoff, 2015)
1910.35 code is similar to Chapter 7.1.1 of NFPA. It deals with compliance with other exit routes as proposed by NFPA101. As per this code employers are expected to adhere to fire safety standards mention by NFPA. (Law.cornell.edu,2015)
1910.36 the code requires the exit routes be permanently and separated from fire resistant materials. Every workplace must have at least two exit routes. A single exit route is permitted when the number of employees, the size of the building and the arrangements can ensure safe exit. It also provides a description and standards on open spaces, to which the exit leads. The exit door must be unlocked at all times. The width, height and other dimension of the exit is provided by this code. (Law.cornell.edu, 2015). 1910.37 Code aims to minimize danger to the employees. It requires the exit route to be free of any explosives or highly flammable furnishings and for the safe location of exit. (Law.cornell.edu, 2015)
4. A supermarket I know requires the following 6 steps in its emergency action plan. 1. Methods to report fire or emergency. A siren alarm may be enough to do this function. 2. Method to act during an emergency. Example for this is designing an exit route through which employees can escape during a hazard. 3. Identify a secure location where the employees could be evacuated. 4. Form a medical help team that can treat injuries happening on workplace. 5. Assign safety personnel who can coordinate and communicate the evacuation process. These personnel can request help from outside sources, when necessity arises. 6. Procure and maintain a fire detecting and extinguishing system. The employers and the employees must be trained in preventing fire and other explosion at the workplace. They also require to be educated on how to act during a fire or hazard. Fuel sources at workplace has the potential to initiate, as well as, contribute to the spread of fire. (Osha.gov,2015)
Developing an emergency action plan is an effective way of ensuring safety at workplace. Proper employee training and well developed action plan can reduce damage and safeguard the health of employees and reduce loss to the firm, occurring from employee absents. Doing a workplace evaluation can help determine risk and develop a suitable action plan. The plan takes into account specific layout of the workplace and the employee response. Responsible trained individuals, who can coordinate and supervise the action plans are as important as the action plan itself. Lack of action plan can result in confusion and disorganized evacuation during a fire. Sometimes, workplaces may require its employee to fight fire instead of fleeing, all of which will be known from the action plan. (Bepreparedcalifornia.ca.gov, 2015)
Large companies can conduct mock drills that will help the employees act during emergency times. A separate safety department can be created, to support large companies in preventing occupational hazard. (Osha.gov,2015)
5. Energy from electrical, hydraulic, mechanical, chemical, thermal or from other sources in a machine can be hazardous to workers handling it, if they do not follow safety protocols. The basic principles in controlling hazardous energy sources are as follows: 1. Preparing to shut down 2. Shutting down the machine. 3. Isolating the machine or equipment from the energy source 4. Applying lockout or tagout devices to the energy isolating device 5. Safely releasing the stored or residual energy. 6. Verifying that the isolated machine is successfully tagged out prior to the start of servicing or maintenance work. 7. After repair or servicing, ensure that the machine components are working properly. 8. Ensure that all workers are removed from the vicinity of the machine or are safely placed. 9. Remove the tagout or lockout devices. (OSHA FactSheet, 2002)
Practicing proper tagout/lockout (LOTO) procedure help in preventing the release of hazardous energy. According to LOTO standards, employers are responsible for the protection of workers from hazards related to energy sources. These standards also provides an outline of the action procedures that need to be followed while servicing or maintaining machines and structures that are linked to hazardous energy sources. Employers must train their workers in the knowledge related to safe handling of hazardous energy source. Workers must possess the skill required for safe application, usage, and removal of energy control devices. All employees at the worksite must receive instructions on the use of energy control procedures and on the prohibition of attempting to restart or reenergize machines /equipment that are locked out or tagged out. Employees who are involved in the service and maintenance of lock out machines or equipment’s must be trained in the recognition of applicable hazardous energy sources at the workplace and in isolating and controlling the energy. The employees must also be aware about the specific limitations of each tagout procedure. Repeated training of employees at regular interval must be undertaken and they must be updated on specific changes introduced into the procedures. (OSHA FactSheet,2002)
6. Confined spaces are those that are not intended for people to stay, but for workers to enter and perform certain jobs. Example of confined spaces: tanks, silo, vessels, storage bin, hopper, vaults, manholes, tunnels, duct work, pipeline, etc. They have limited opening space for entry and exit. The most common hazards associated with working in confined spaces are poor air quality, chemical exposure due to skin contact or ingestion, residual chemical released from the supply line, noise, injury from structural hazards, or movable parts, slips, falls, radiation, temperature fluctuation, collapse of bulk material, flood or release of free flowing fluid, electric shock, poor visibility, biological hazards, etc. Rescuing a victim from confined spaces is very difficult, due to narrow entrance and exit. Working in confined spaces must be done only when absolutely necessary. (Ccohs.ca, 2015)
The principals of working in confined spaces are as follows: i. Prepare the confined space: This is done by testing the air quality throughout the space. The air should have the appropriate oxygen content and must be free of hazardous gases. Proper functioning of ventilation equipment must be ensured. ii. Wear protective equipment (gloves, respirators, gloves) before entering confined spaces. iii. Entrance to confined spaces can be controlled by administration or by the use of the entry permit system. iv. Maintain air quality in confined spaces using mechanical ventilators. v. Avoid working with flames or combustible materials in and around the confined space. In case of unavoidable circumstances the concentration of combustible or explosives is maintained at less than 10% of lower explosive limits. vi. Lock out or tagout any potential sources of hazardous energy before entering the confined space. vii. Remove liquid or free flowing solid from confined space or prevent it using a barrier. The entry and exit must be sufficient for the entry of a person and his protective instruments. (Ccohs.ca, 2015)
7. Mechanical ventilators provide the necessary air exchange that helps to maintain fumes and smoke generated during welding, within safe limits. Mechanical ventilators are particularly important in confined spaces. Electrical devices like portable fans or fans mounted in the ceiling are examples of mechanical ventilation. Requirement for mechanically ventilation is 2000 cfm/welder. When local exhaust hoods, or airline respirators are made available the cfm can be reduced further. (Law.cornell.edu,2015)
As per OSHA standard, natural ventilation is sufficient to control toxic fumes during mild welding and cutting in open spaces. As per OSHA standards, mechanical ventilators are necessary when working with fluorine compound, zinc, lead, beryllium, cadmium, mercury, cleaning compound, degreasing products and stainless steels. (Ehss.vt.edu, 2015)
Local exhaust ventilation will help in removing the fumes and smokes generated at the welding source. Exhaust are particularly important when metal particles are released into the atmosphere during welding. When it is difficult to provide mechanical ventilators, the workers in the confined spaces must be provided with airline respirators. They also need to maintain continuous contact with people monitoring activity from outside the confinement. (Law.cornell.edu, 2015)
High intensity ultraviolet radiation is produced during shielded metal arc welding. The chlorinated solvent used for such purposes must be placed at least 200 feet, away from the exposed arc. The area must be dry before applying chlorinated solvent. The employees must use protective lens, helmet and headshield. Chlorinated vapor can be converted to more toxic gases in the atmosphere. Compressed gas used for welding and cutting must not be used for ventilation purposes or for cooling or for blowing dust or cleaning. (Law.cornell.edu, 2015). Following OSHA standards will ensure safety.
8. OSHA machine guarding standards are more suitable for traditional machine, but outdated when comes to computer operated or robotic machines. These machines are more complex and a simple lockout procedure may not be sufficient to protect the workers from hazards associated with these machines. Computed or robotic machines work faster and all it is difficult to train all personals working with it about the computer program on which it is operating. Robotic system have various unit and shutting down one unit does not ensure the shutdown of the whole system. These machines use sensors to start off. Thus the worker must make sure whether the unit is in the shut down mode or pause mode. OSHA standards are not adequate for automated equipment. (Plantengineering.com, 2015)
Further, the OSHA regulation provides less detailed instructions on maintaining a safer workplace with automated equipment. These automated equipment requires specific type of guideline, rather than a general machine guideline. This will help to identify machine specific hazard potential and take protection. (Plantengineering.com, 2015)
Machines are constantly evolving, safety regulations need to be on par with these new technologies. Machine builders often find it difficult to design equipment on par with OSHA standards. This is because the type of control system, emergency stops, safeguarding selections are quite different for automated equipment, than the traditional machines. More intelligent safety control system is required. The controls of robotic and computerized equipment are computer operated and a simple on or off may not work on this equipment. Safety related control network system is more suitable for a workplace that is completely or semi-automated or operated by robotic. Sophisticated equipment needs someone who is familiar with the safety circuits, and someone who is capable of controlling the machine. The other problem when using OSHA standards for machine guarding is that it is complex and not easily understood by all. (OSHA. gov, 2015)
9. Inhalation of contaminants at work will result in occupational diseases. Health care workers are particularly at high risk for airborne infection. The example of other airborne contaminant includes dust, sprays, mist, smokes and fumes. The OSHA standard that deals with protection against these contaminant is in section 1910.134. Workers exposed to contaminated environment must be provided with respirators. These respirators are intended for purifying the contaminated air and providing safe air to the user. The standard provides regulations for setting up the respirator and for its proper use. It also wants regular medical checkup of workers using the respirator. Occupational causes are commonly associated with chronic respiratory diseases like asthma, COPD and lung cancer. (Osha.gov, 2015)
Using a respirator will provide adequate protection against respiratory contaminants. Further, regular medical check-up and supervision will help to determine if the worker is sufficiently protected. However, respiratory protectors are costly and can hinder the workers comfort and productivity. It is sometimes difficult to get voluntary cooperation from employees in using a respirator. Further, it needs annual testing and medical evaluation. Selecting the suitable respirator is also important. Establishing a respiratory protection program can help the company to evaluate the success of protection from air contaminants. OSHA can provide expert opinion on the type of respirator and in the development of a suitable respiratory protection program. The employee can then establish and develop a system to keep the program functional. Regular workplace evaluation to check for contaminants and supervision on the use of respirators can help in preventing occupational diseases that occur from contaminants. Thus, OSHA standards are effective in preventing airborne contaminants. (Osha.gov, 2015)
Apart from using respirators the company can resort to other less expensive methods whenever possible. These methods of removing contaminants include: replace the toxic contaminants with less toxic materials; Provide engineering control measures to dilute the contaminant or remove it using exhaust; Reduce the amount of time an employee is exposed to the contaminant. (Yates, 2011)
10. The section on HAZCOM 1910.1200 provides standards to ensure that the employees are educated on the hazards related to the use of chemicals. It provides standards that guide measures that evaluate and help to transmit the information to the employees. It requires that the employer generate a written list of hazardous chemicals, maintained at the facility. These hazardous materials are to be labelled and maintained separately as per OSHO standards. The code also establishes labelling requirement for different chemicals. Detailed protocol for usage and disposal is also provided by the section. Companies are required to adhere to the specified format of the data sheet and labelling. All chemicals are classified into: flammable and combustible liquids, spray finishing and combustible materials. (Osha.gov, 2015)
Lead Standard (1910.1025) applies to occupational exposure to lead, except at agricultural and construction work site. Special protective clothing’s and respirators must be used by workers, who are at risk to lead exposure. Unlike that of other chemical, more frequent medical examination is done on workers who are exposed to lead. If a person is exposed to a lead containing environment for more than 7 hours a day, then the sample is collected from the person to access the level of lead contamination. Lead is a metal and widely used for industrial and agricultural purpose. It has a low melting point, high density, high molecular weight and is easily malleable. The permissible exposure limit for lead after an 8 hours exposure is 50ug/m3. If the level of lead is above the permissible limit, the levels need to me monitored repeatedly at 7 days interval. The employers need to evaluate work practices and provide training in using protective gear so as to be successful in bringing the lead to below permissible limits. Lead standards also provide ventilation requirement and other clothing requirements that help to reduce lead toxicity. Workers accumulate lead by ingestion, inhalation and skin absorption. OSHA training standards will help to reduce hazardous consequences associated with lead. (Osha.gov, 2015)
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