OSHA Example

Threshold limit values (TLV) (safety) The maximum amount of a chemical that a worker can be exposed to continuously or as a time-weighted average (TWA), as defined by the OSHA. Examples Trichloroethylene - 270mg/m Arsine - 0.05 mg/m Chlorine - 1 mg/m. ... 

Color Coding. New machinery and equipment must conform to OSHA standards and OEM specifications for color coding. Color coding can also help to speed up maintenance procedures. Examples include lubrication information, orientation, timing marks, torque requirements, etc. 

Inhalation of certain fine dusts may constitute a health hazard. Eor example, exposure to siUca, asbestos, and beryllium oxide dusts over a period of time results ki the potential risk of lung disease. OSHA regulations specify the allowable levels of exposure to kigestible and respkable materials. Material Safety Data Sheets, OSHA form 20, available from manufacturers, provide information about hazards, precautions, and storage pertinent to specific refractory products. 

Stringent OSHA composition limits exist for appHcations of brazing filler metals and solders. For example, only no-lead solders are permitted for joining parts that may come in contact with potable water. 

This knowledge is also important in order to determine if air tests conducted by OSHA compliance officers are valid. For example, if threshold limit value in the health standard is an 8-hour time-weighted average, the air sample should be obtained by sampling over the entire shift in the employee s breathing zone. It cannot be measured by a few short term samples, even if spaced over the full shift unless the worker is in a relatively fixed location with no variation in his work procedure or in the process. Such an event is generally the exception rather than the rule. 

CAS Number - Chemical Abstracts Service Registry Number A CAS (Chemical Abstracts Service) Registry Number is a unique identifier that tells you, for example, that aeetone and dimethyl ketone are actually the same substance. The Chemical Abstracts Service is a division of the American Chemical Society. OSHA only requires certain items on an MSDS and a CAS number is not one of them. However, authors of MSDS s are allowed to add additional information, such as the CAS number, if they desire. The numbers you see on trucks on the highway are not CAS Numbers, butU.S. Department of Transportation (DOT) codes, which are not necessarily specific to each chemical. Their aim is to assist emergency responders. 

Sensitizer A sensitizer is defined by OSHA as "a chemical that causes a substantial proportion of exposed people or animals to develop an allergic reaction in normal tissue after repeated exposure to the chemical." The condition of being sensitized to a chemical is also called chemical hypersensitivity. Certain chemicals have no immediate health effect. But if you are exposed to them several times, they can make you allergic or sensitive to other chemicals. A classic example is formaldehyde (HCHO). Typical reactions to sensitizers can include skin disorders such as eczema. When working with sensitizers, always use proper protective equipment such as gloves, respirators, etc. Once you are sensitized to a particular chemical, even minute amounts will cause symptoms. Sensitization is usually a lifelong effect. 

The required notification must be provided at ieast annually In writing. Acceptable forms of notice are, for example, a letter, product labeling, and product literature distributed to customers. If you are required to prepare and distribute a Material Safety Data Sheet (MSDS) for the mixture under the Occupational Safety and Health Act (OSHA) Hazard Communication Standard, your section 313 notification may be attached to the MSDS or the MSDS may be modified to include the required information. (A sample letter and recommended text for inclusion in an MSDS appear on pages E-4 and E-5 of this appendix.)... 

Eor example, the federal Oeeupational Safety and Health Administration (OSHA) regulates asbestos, lead, and other hazardous substanees. It would be very diffieult to provide the reader with every regulatory ageney that may have jurisdietion over hazardous materials. It is not our intent to provide the reader with every detail. However, the information offered in this book ean aid the reader in general eompli-anee issues and assist in planning for safety. This, in the long run, will help to improve on-site safety performanee. 

In Chapter 4 we will diseuss the regulatory framework and analyti-eal tools to eonduet these assessments, sueh as JHA (job hazard analysis), job safety analysis (JSA), safety analysis reports, proeess hazard analysis (PHA), and job, task, and hazard analysis. The reader needs to understand that OSHAs view on physieal and ehemieal hazards is far reaehing, as stated in the HAZWOPER standard. Note the following examples. 

OSHA provides guidanee on interpretation, ineluding numerous examples, in its publieation HAZWOPER Interpretive Quips (IQs.) The IQs are poliey statements abstraeted from offieial OSHA letters of inter-... 

Safety hazards are treated in the same manner. For example, workers who work in trenches in clean areas of the site would be covered by the OSHA Excavation and Trenching Standard, Subpart P, 29 CFR 1926. Workers who work in trenches in contaminated areas would fall under both Subpart P and HAZWOPER. Workers who do not work in trenches fall under HAZWOPER only when working in contaminated areas and would not be covered by either standard when working solely in clean areas, provided they are not exposed to safety hazards resulting from hazardous waste operations. 

For example, in considering workers in contaminated areas of the site who work on scaffolds, the OSHA Scaffolding Standards are more protective for safety hazards resulting from working on scaffolds. HAZWOPER is more protective for health hazards resulting from the contamination. The applicable provisions of both standards would apply to the work. 

If the PPE is personal in nature and can be used by the employee off the job, the payment issue may be left up to labor and management. Examples cited in the memorandum include safety shoes, nonspecialty safety glasses, and cold-weather gear. OSHA makes it clear that, If shoes and cold-weather gear is subject to contamination of hazardous substances and cannot be safely worn off-site it should be paid for by the employer. ... 

Contractors at Sites E, H, and J had documented confined space programs but had not fully implemented these programs. The Site H contractor had established a permit-required confined space entry program consistent with HAZWOPER requirements however, onsite procedures were not completely consistent with the written program or OSHA requirements. For example, the confined space permit form used at Site H was not the form included in the written program. The audit team also found evidence that employee training was insufficient for safe... 

Other sites provided general provisions for acceptable training programs but lacked the site-specific detail necessary to implement a successful program. Eor example, the contractor s plan at Site E contained a requirement that all project field personnel receive training in accordance with applicable OSHA standards, including a minimum of 40 hours of hazardous waste operations training. The plan did not contain,... 

For example, initial implementation may be confined to those chemicals and processes covered by the OSHA process safety rule, which is limited to a specific list of chemicals and excludes processes that meet specific criteria. However, the OSHA regulation does not cover all materials and processes that may represent process risks. 

Table 64.2 provides examples of hazardous chemicals that require investigation when a catastrophic release occurs or when one could have happened. These OSHA guidelines should be used in conjunction with site-specific procedures. For a complete listing of the reportable chemical used in your plant, refer to the site Hazardous Materials Policy and Procedure Manual. 

Regulatory Compliance Issues in the US Table 64.2 Examples of OSHA-listed chemicals... 

After a prioritized list of processes is developed, a plan for PrHAs can be established. This plan must follow the minimum schedule in the PSM Rule, listed in Section 2.2.1, with no less than one-fourth of the PrHAs completed by May 26, 1994 and one-fourth completed each succeeding year. All PrHAs must be completed by May 26, 1997. However, the PSM Rule also states that PrHAs are to be done "as soon as possible, but no later than [the following schedule...]." This point is stated explicitly in the OSHA inspector s compliance guidelines, so it must be demonstrated that scheduled PrHAs were completed before the annual deadlines and that no intentional delays were incorporated into the PrHA schedule. For example, a large site might have mostly office and laboratory facilities, and only two processes covered by the PSM Rule. If manpower is available to conduct two PrHAs in parallel within the first year, then the PrHA schedule should not be extended over a 3-year period. 

Recognizing that the chemical industry is safe, why is there so much concern about chemical plant safety The concern has to do with the industry s potential for many deaths, as, for example, in the Bhopal, India, tragedy. Accident statistics do not include information on the total number of deaths from a single incident. Accident statistics can be somewhat misleading in this respect. For example, consider two separate chemical plants. Both plants have a probability of explosion and complete devastation once every 1000 years. The first plant employs a single operator. When the plant explodes, the operator is the sole fatality. The second plant employs 10 operators. When this plant explodes all 10 operators succumb. In both cases the FAR and OSHA incidence rate are the same the second accident kills more people, but there are a correspondingly larger number of exposed hours. In both cases the risk taken by an individual operator is the same.4... 

After the law is official, how is it put into practice Laws often do not include the details for compliance. For example, the USC requires the appropriate respirator protection, but it does not specify the detailed types or limitations of respirators. To make the laws work on a day-to-day level, Congress authorizes governmental organizations, including the EPA and OSHA, to create regulations and/or standards. 

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