OSHA Website Focuses On Green Job Hazards

Wind Farm in California

The Occupational Safety and Health Adminisitration (OSHA) standards cover many of the hazards in green industries and employers must use the necessary controls to protect workers.  The green industry is being defined broadly as an industry that helps to improve the environment.  The jobs created by this green industry (typically called green jobs) also create opportunities to help revitalize the economy and get people back to work.  Examples of the different green industries include:

• Wind Energy
• Solar Energy
• Geo-thermal
• Biofuels
• Recycling
• Green Roofs
• Hydrogen Fuels
• Weather Insulating/Sealing

Green jobs do not necessarily mean that they are safe jobs. Workers in the green industries may face hazards that are commonly known in workplaces -- such as falls, confined spaces, electrical, fire, and other similar hazards.  These hazards may be new to many workers who are moving into the fast-growing green industries.  Additionally, workers may be exposed to new hazards which may not have been previously identified.  An example of this are workers in the solar energy industry may be exposed to Cadmium Telluride, a known carcinogen, if adequate controls are not implemented.  The Occupational Safety and Health Act (OSH Act) requires employers to comply with safety and health regulations promulgated by OSHA.  In addition, the OSH Act’s General Duty Clause, Section 5(a)(1), requires employers to provide their employees with a workplace free from recognized hazards likely to cause death or serious physical harm.  In the absence of an OSHA standard, OSHA can enforce the General Duty Clause. 

One of the key concept for all industries, but especially those that are just beginning to grow, is "Prevention through Design (PtD)" – designing the process/equipment in a way that eliminates hazards to the workers who use them.  The National Institute of Occupational Safety and Health (NIOSH) has a web page discussing this concept, visit it at: http://www.cdc.gov/niosh/topics/PTD/.  The basic premise of this is to address occupational safety and health needs in the design process (having occupational safety and health professionals working with design engineers) to prevent or minimize the work-related hazards and risks associated with the construction, manufacture, use, maintenance, and disposal of facilities, materials, and equipment.  If the design eliminates the hazard before what is being designed is built, then the hazards may never be created.  Visit OSHA's website at http://www.osha.gov/dep/greenjobs/index.html to better understand the job hazards in each of the different green industries.

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• OSHA Log Form 300A Posting Due February 1, 2011. (futureenv.blogspot.com)

OSHA Log Form 300A Posting Due February 1, 2011.

Section 1904 of the Occupational Safety and Health Administration (OSHA) regulations require certain employers to comply with the OSHA recordkeeping guidelines (this includes most employers, see http://www.osha.gov/recordkeeping/ppt1/RK1exempttable.html for a list of partially exempt industries).  This regulation requires OSHA form 301 to be completed for each work related injury/illness.  The information  from the 301 form is logged onto the OSHA 300 form.  At the end of calendar year 2010, the totals from OSHA 300 form is entered onto the OSHA 300A form.  The 300A form is the total number of cases (injuries/illnesses), total number of work days lost (due to injuries/illnesses), and total number of injury/illness types from the calendar year 2010 for each facility/work site/employer.  The OSHA 300A form must be posted from February 1, 2011 thru April 30, 2011.  The 300A form should be posted in a conspicuous place where you normally post employee information. Failure to post can result in citations and penalties.  You are required to maintain the OSHA 300 and 300A forms for 5 years following the year they pertain and make them available to employees upon request.  To get the forms mentioned above and instructions on how to complete then visit OSHA's website at http://www.osha.gov/recordkeeping/new-osha300form1-1-04.pdf.  For more information on recordkeeping requirements visit OSHA's website on recordkeeping at http://www.osha.gov/recordkeeping/index.html.  If you need assistance or training on completing these forms you can also contact us at angelo3@futureenv.com. 

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OSHA Reminds Employers Of The Hazards Associated With Ice And Snow Cleanup

Image via WikipediaThe Occupational Safety and Health Administration (OSHA) in Region 4 (Georgia) is warning employers of the hazards associated with ice and snow removal.  However, with the Northeast being hit by more snow just this week it is important to remember these hazards ourselves.

Common hazards can include:

• Electric shock from contact with downed power lines or the use of ungrounded electrical equipment.
• Falls from clearing ice jams in gutters, snow removal on roofs or while working in aerial lifts or on ladders.
• Being struck or crushed by trees, branches or structures that collapse under the weight of accumulated ice.
• Carbon monoxide poisoning from gasoline-powered generators in inadequately ventilated areas or idling vehicles.
• Lacerations or amputations from unguarded or improperly operated chain saws and power tools, and improperly attempting to clear jams in snow blowers.
• Slips or falls on icy or snow-covered walking surfaces.
• Being struck by motor vehicles while working in roadways.
• Hypothermia or frostbite from exposure to cold temperatures.

Means of addressing these hazards can include:

• Assuming all power lines are energized, keeping a distance and coordinating with utility companies.
• Making certain that all electrically powered equipment is grounded.
• Providing and ensuring the use of effective fall protection.
• Properly using and maintaining ladders.
• Using caution around surfaces weighed down by large amounts of ice.
• Making certain all powered equipment is properly guarded and disconnected from power sources before cleaning or performing maintenance.
• Using and wearing eye, face and body protection.
• Clearing walking surfaces of snow and ice, and using salt or its equivalent where appropriate.
• Establishing and clearly marking work zones.
• Wearing reflective clothing.
• Using engineering controls, personal protective equipment and safe work practices to reduce the length and severity of exposure to the cold.

Information on hazards and safeguards associated with cleanup and recovery activities after a storm or other major weather events is available online in English and Spanish at http://www.osha.gov/OshDoc/hurricaneRecovery.html.

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EPA Removes Saccharin As A Hazardous Waste

Saccharin 2-D Formula

In December, 2010 the Environmental Protection Agency (EPA) amended its regulations regarding saccharin as a hazardous waste.  Saccharin, an artificial sweetener in the form of a white crystalline powder, is 300 times sweeter than sucrose or sugar.  It is typically an ingredient in diet soft drinks, juices, sweets, and chewing gum.  Saccharin can also be found in cosmetics and pharmaceuticals.

EPA amended its regulations under the Resource Conservation and Recovery Act (RCRA) to remove saccharin and its salts from the lists of hazardous constituents and commercial chemical products which are hazardous wastes when discarded or intended to be discarded.  In addition, EPA amended the regulations under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) to remove saccharin and its salts from the list of hazardous substances.  EPA responded to a petition submitted by the Calorie Control Council (CCC) to remove saccharin and its salts from RCRA and CERCLA, EPA will no longer list these substances as hazardous on the above mentioned lists.  EPA granted CCC’s petition based on a review of the evaluations conducted by key public health agencies concerning the carcinogenic and other potential toxicological effects of saccharin and its salts.  In addition, EPA assessed the waste generation and management information for saccharin and its salts, concluding that the wastes do not meet the criteria for hazardous waste regulations.

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OSHA Acts To Protect Residential Roofing Workers

Fall Protection established for this roof project.

On December 22, 2010, the Occupational Safety and Health Administration (OSHA) announced a new directive withdrawing a former one that allowed residential builders to bypass fall protection requirements.  The directive being replaced, issued in 1995, initially was intended as a temporary policy and was the result of concerns about the feasibility of fall protection in residential building construction.  However, there continues to be a high number of fall-related deaths in construction, and industry experts now feel that feasibility is no longer an issue or concern.
"Fatalities from falls are the number one cause of workplace deaths in construction.  We cannot tolerate workers getting killed in residential construction when effective means are readily available to prevent those deaths," said Assistant Secretary of Labor for Occupational Safety and Health Dr. David Michaels.  "Almost every week, we see a worker killed from falling off a residential roof.  We can stop these fatalities, and we must."
The National Association of Home Builders recommended rescinding the 1995 directive, as did OSHA's labor-management Advisory Committee for Construction Safety and Health; the AFL-CIO; and the Occupational Safety and Health State Plan Association, which represents the 27 states and territories that run their own occupational safety and health programs.
According to data from the department's Bureau of Labor Statistics, an average of 40 workers are killed each year as a result of falls from residential roofs.  One-third of those deaths represent Latino workers, who often lack sufficient access to safety information and protections.  Latino workers comprise more than one-third of all construction employees.
OSHA's action rescinds the Interim Fall Protection Compliance Guidelines for Residential Construction, Standard 03-00-001.  Prior to the issuance of this new directive, Standard 03-00-001 allowed employers engaged in certain residential construction activities to use specified alternative methods of fall protection rather than the conventional fall protection required by the residential construction fall protection standard. With the issuance of today's new directive, all residential construction employers must comply with 29 Code of Federal Regulations 1926.501(b)(13).  Where residential builders find that traditional fall protection is not feasible in residential environments, 29 CFR 1926.501(b)(13) still allows for alternative means of providing protection.
Construction and roofing companies will have up to six months to comply with the new directive.  OSHA has developed training and compliance assistance materials for small employers and will host a webinar for parties interested in learning more about complying with the standard. To view the directive and for more information, visit http://www.osha.gov/doc/residential_fall_protection.html.

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EPA Revises Lead Ambient Air Monitoring Requirements



Air Quality Testing for several parameters.

On December 14, 2010, the Environmental Protection Agency (EPA) published the final lead (Pb) ambient air monitoring requirements.  The purpose of this revision was to expand the nation’s lead monitoring network to better assess compliance with the revised National Ambient Air Quality Standards (NAAQS) for lead issued in 2008.  In 2008, EPA substantially strengthened the lead NAAQS by revising the level of the primary (health-based) standard from 1.5 micrograms per cubic meter (μg/m3) to 0.15 μg/m3, measured as total suspended particles (TSP).  The agency revised the secondary (welfare-based) standard to be identical to the primary standard.  EPA in this final rule (Dec. 2010) also changed the emission threshold that state monitoring agencies (such as New York State Department of Environmental Conservation [NYS DEC]) must use to determine if an air quality monitor should be placed near an industrial facility that emits lead. The new emission threshold is 0.5 tons per year (tpy), reduced from the previous threshold of 1.0 tpy. Any new monitors located near an emissions source must be operational no later than one year after this rule is published in the Federal Register.  EPA maintained a 1.0 tpy lead emission threshold for airports.  However, EPA is requiring a 1-year monitoring study of 15 additional airports (beyond those currently required to monitor at the existing 1.0 tpy emission threshold) for the New York area this includes Brookhaven and Republic airports. The study will help EPA determine whether airports that emit less than 1.0 tpy have the potential to cause the surrounding areas to exceed the lead NAAQS of 0.15 micrograms per cubic meter (μg/m3).  The monitors participating in the study must be operational no later than one year after this rule is published in the Federal Register.
EPA is also requiring lead monitoring in large urban areas (Core Based Statistical Areas, or CBSAs, with a population of 500,000 people or more).  Monitors will be located along with multi-pollutant ambient monitoring sites (known as the “NCore network”).  Lead monitoring at these sites will begin January 1, 2012.

• The NCore network will consist of approximately 80 monitoring sites, of which 63 will be in large urban areas.  The requirement to add these monitors replaces an existing requirement to place lead monitors in each CBSA with a population of 500,000 or more people.

The above revisions were made based on comments received on EPA’s proposed revisions.

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Asbestos Controversy in Troy New York.

Demolition of the Old Troy City Hall in Troy, New York has caused controversy regarding the asbestos discovered in the building.  It seems based on the news report it seems like they got caught doing demolition before removal.  The City Engineer says he is doing exploratory demolition and New York State Department of Labor approved it.  Is he looking for more asbestos?  When was this building built?  Have they sampled all 46 of the presumed and suspect asbestos materials that is on the New York State Industrial Code Rule 56 list?  These are just some of the questions I have regarding this demolition.  Additional reports have mentioned a limited asbestos survey.  Why is it limited?  What hasn't been sampled?

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