Other Required Written Programs

Process safety management of highly hazardous chemicals Bloodhorne pathogens/exposure control plan Emergency action plan Fire prevention plan Respirator program 

Lockout/tagout/energy control program Hazard communications program 

Hazardous waste and emergency response/site-specific safety and health program, training program, and personal protective equipment program Fall protection plan Confined space permit entry plan 

The specific requirements for the content of written programs vary with the regulation. The respirator regulation requires that the following exist  

Written standard operating procedures Program evaluation procedures Respirator selection procedures Training program 

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Companies have their own processes for patient enrollment that typically require the completion of an application and a reporting of the patient s health insurance coverage, assets, income, and liabilities. A prescription for the medication is usually required. Many programs allow enrollment over the phone, while others require written correspondence. In order to determine eligibility, many companies require verification of a patient s financial status by documents such as income tax returns, W-2 forms, social security and other benefit... 

Most of the OSHA-required written programs are referenced in other portions of this text. As a review or summary, most are pre-... 

Other compliance areas do not require written programs but do require specific documentation. Developing formal written procedures for addressing these other issues is beneficial to ensure consistent compliance and implementation. One example of this is in personal protective equipment (PPE) where no written program is required but, under 29 CFR 1910.132 (2004), there must be a written and "certified" assessment of the workplace hazards. 

A written respiratory protection program is required when necessary to protect the health of the employee from workplace contaminants or when the employer requires the use of respirators. A limited written program is also required when respirators (other than dust masks) are being voluntarily worn by employees. This latest document states It is the intent of the standard that the employer would not be required to incur any costs associated with voluntary use of filtering facepieces other... 

Compliance with the written program can be verified during the walkaround by personal observation and employee interviews. If respirators are required to be worn in the workplace or respirators other than dust masks are worn by voluntary users, a written program is required. An overexposure is not required to cite. Discrepancies between the written program and implemented work practices at the worksite should be cited. Use of a elastomeric or supplied-air respirator, even when voluntary on the part of the employee, will require the employer to include all elements in a written program that will make sure that there is proper use of these respirators so that they do not create a hazard. 

The employer is required to address in its written program the type of regular surveillance of the workplace necessary to evaluate the effectiveness of the respirator program. Other items discussed in the standard include ... 

Such a system would include a program similar to that of Storer and Comish-Bowden to do equilibrium calculations. A communication-control subprogram would be Hiked to an expert model by using the EXPERT knowledge-base shall (or system-builder) which is advantageous here because it can interact with procedures such as those written in FORTRAN for numerical computation. Additional programs and a small data base, which EXPERT can handle, would keep track of which chemical was what array element, and other requirements mentioned above. 

With the addition of electives and other required courses, a total of 12 classes are required. Students take five cumulative exams throughout the program, which are written by influential leaders in green chemistry from outside the program, such as Paul Anastas and Berkeley ( Buzz ) Cue. An additional requirement in this program is that all students... 

Significant deficiencies in the security and control of samples have been well documented. " " In fact, it has been estimated that just over half of samples actually reach patients. Samples may be used by prescribers and staff, or they may be diverted. Personal use of drug samples by physicians and other healthcare providers raises ethical concerns and is not without risk." Limaye and Paauw described three medical residents who self-prescribed antimicrobials and were subsequently diagnosed with Clostridium difficile infection." Tong and Lien reported self-medication with samples and distribution of samples to nonphysicians by almost 60% of pharmaceutical representatives surveyed at a Canadian family practice office. A contributing factor to some of these issues is that institutional or facility sample policy and procedures are often absent, or compliance is poor. One institution found only 10% compliance when the inventory of samples was compared with the required written documentation. Even after an educational program in which the policy was explained to the house staff, a second audit found only 26% compliance. " Poor compliance with policy and procedure may jeopardize patient safety, as well as put the institution at risk for JCAHO recommendations or Board of Pharmacy penalties. 

Does the written program provide employees (including contractor employees) and their representatives access to PHAs and all other information developed as required by the PSM standard . 119(c)(3) ... 

Keep in mind that this Toolbox Talk covers the voluntary use of dust masks only. It does not cover the voluntary use of other respirators, such as elastomeric air-purifying respirators or powered air-purifying respirators. In those cases, there are further provisions for you to follow at 1910.134, such as for medical evaluation, scheduling, and certain elements of a written program. Also, this Toolbox Talk does not cover surgical masks, which are not considered respirators nor dust masks. Finally, if dust masks are required to be used by the employer, even when not required by OSHA, they cannot be considered Voluntary use. ... 

Organizations requiring contracted services in locations of their facility where hazardous materials are used or stored must inform those contracted employees of all hazards present. This must be part of the written program. This program should include methods and procedures the employer will use to provide all contractors with MSDSs, information on labeling and other forms of warning, and... 

The plan does not have to be lengthy or complicated. It is intended to be a blueprint for implementation of your program—an assurance that all aspects of the requirements have been addressed. It serves to communicate to your employees and to OSHA exactly what you have done to comply with the HCS. In general, the written program must describe how the requirements for labels and other forms of warning, safety data sheets, employee information, and training are going to be met in your facility. 

An employer would not have any other written program or training requirements. 

The first thing discussed in this chapter is a written program for hazard communication that is going to be important in staying in compliance with the requirements set forth by the OSHA standard. The specific methods described are used as a sample written program, and are for illustrative purposes and not intended to make up your entire program. Other effective methods can be substituted into this sample to satisfy the needs of the company for which you are working. 

This perceived need for written programs must be tempered with a view to their practical development and implementation. A very small employer who employs one to four employees and no supervisors in all likelihood needs only a very basic written plan, along with any other written programs that are required as part of an Occupational Safety and Health Administration (OSHA) regulation. However, as the size of the company and the number of employees increase, the employer becomes more removed from the hands-on aspects of what now may be multiple facilities or worksites. 

The written program must reflect what employees are doing in a particular workplace. For example, the written plan must list the chemicals present at the site, indicate who is responsible for the various aspects of the program in that facility, and where written materials will be made available to anployees. The written program must describe how the requirements for labels and other forms of warning, MSDSs, and anployee information and training will be met in the facility. 

A written program is required to achieve compliance with the requirements of the standard. The specific methods described in this written program are for illustrative purposes, and other effective methods may be substituted to satisfy local needs or practices. 

The programs DRFLA for vapor-liquid and DRELI for liquid-liquid calculations are written in FORTRAN IV source language for the CDC 6400 of the Computer Center, University of California, Berkeley. Minor modifications, mostly with regard to input and output, will be required for implementation on most other computer systems. 

Since dependency analysis is not needed, we can go on to the BUILD program. Go to FTAPSUIT and select 5 "Run Build." It asks you for the input file name including extender. Type "pv.pch," It asks you for name and extender of the input file for IMPORTANCE. Type, for examle, "pv.ii . It next asks for the input option. Type "5" for ba.sic event failure probabilities. This means that any failure rates must be multiplied by their mission times as shown in Table 7.4-1. (FTAPlus was written only for option 5 which uses probabilities and error factors. Other options will require hand editing of the pvn.ii file. The switch 1 is for failure rate and repair time, switch 2 is failure rate, 0 repair time, switch 3 is proportional hazard rate and 0 repair time, and switch 4 is mean time to failure and repair time.)... 

FieldNotes user verification can be conducted by following the SOP written by Astrix, which can be downloaded from the Astrix Web site. The SOP contains a script that is typed into the computer system. If the printout matches the SOP script, then verification is complete. A record of this must be placed in the facility archive. This verification process takes 1 h or less. For FieldNotes, calculations are not verified at the field site since the manufacturer feels that the software developer and the sponsors have performed adequate validation of these calculations previously. This may, therefore, require a visit to the sponsor or to the manufacturer to confirm that this important step of the validation process has been completed and is adequately documented. By following the Astrix SOP, the user is simply ensuring that the program operates on their system(s). The SOP script must be typed in exactly as written in order to confirm the printout accuracy. QA must ensure that the verification documentation is properly archived. Just as with any other SOP, this SOP must be approved in writing by field site management to comply with GLP. 

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