Safety In the Building

Services Industry
Joann Natarajan
OSHA
Austin Area Office
 OSHA Laws that Affect This
Industry
• Aerial Lifts
• Hazard Communication
• Permit Required Confined Space
• Personal Protective Equipment
• Bloodborne Pathogens
• Respirators
 Aerial Lifts
• Must be tied off with a
body harness/lanyard
when in basket
• Required to have both
upper controls and
lower controls
• Worker training
 Aerial Lifts
• Worker’s feet to
remain on floor of
basket
• Lift controls checked
each day before use
 Hazard Communication:
What’s the point?
• Purpose." (a)(1) To ensure that the hazards of all
chemicals produced or imported are evaluated, and that
information concerning their hazards is transmitted to
employers and employees.

Hazard Container Material Safety

Communication Labeling Data Sheet
Program
M.S.D.S.
Program
Label

5
 Hazard Communication
The Basic Requirements Are:
• (a)(2) This occupational safety and health standard
is intended to address comprehensively the issue of
evaluating the potential hazards of chemicals, and
communicating information concerning hazards and
appropriate protective measures to employees
– Developing and maintaining a written hazard
communication program for the workplace
– Lists of hazardous chemicals present;

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 Hazard Communication
The Basic Requirements Are:
– Labeling of containers of chemicals in the
workplace,
– Containers of chemicals being shipped to
other workplaces;
– Preparation and distribution of material
safety data sheets to employees and
downstream employers;
– Development and implementation of
employee training programs
 Hazard Communication.
• (e) "Written hazard communication
program."
Employers shall develop,
implement, and maintain at each
workplace, a written hazard Haz Com Program
communication program which at (f) "Labels and other forms
least describes how the of warning."
(g) "Material safety data
requirements for labels and other sheets."
forms of warning, material safety (h) "Employee information
and training."
data sheets, and employee
information and training will be met.

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 Hazard Communication.
(e) "Written hazard communication program."
(continued)

• A list of the hazardous chemicals known to be present

using an identity that is referenced on the appropriate
material safety data sheet (the list may be compiled for
the workplace as a whole or for individual work areas);
and,
• The methods the employer will use to inform
employees of the hazards of non-routine tasks (for
example, the cleaning of reactor vessels), and the
hazards associated with chemicals contained in
unlabeled pipes in their work areas.
• NOTE: The written program is your policy statement
for how the program will be implemented.

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 Hazard Communication.
(e) "Written hazard communication program."
(continued)
• "Multi-employer
workplaces."
– The methods the
employer will use to
provide the other
employer(s) information
on Haz Com, of any
precautionary measures
that need to be taken, to
inform the other
employer(s) of the
labeling system.
– The employer may rely
on an existing hazard
communication program
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Hazard Communication.
• (e)(4) The employer shall
make the written hazard
communication program
available, upon request
OSHA

• (e)(5) Where employees

must travel between
workplaces during a
workshift, i.e., their work is
carried out at more than one
geographical location, the
written hazard
communication program
may be kept at the primary
workplace facility.
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 Providing MSDS’s
• If you have workers that travel between sites
and use chemicals at those site, the employee
should have an MSDS in his vehicle to provide
to those other employers where he is bringing
the chemical to perform work.
 Hazard Communication.

• (f) "Labels and other forms of warning." The chemical manufacturer,

importer, or distributor shall ensure that each container of hazardous
chemicals leaving the workplace is labeled, tagged or marked with the
following information:
– Identity of the hazardous chemical(s);
– Appropriate hazard warnings; and
– Name and address of the chemical
manufacturer, importer, or other
responsible party.

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•
Hazard Communication.
(f)(5) Ensure that each container of
hazardous chemicals in the
workplace is labeled, tagged or
marked with the following
information:
– Identity of the hazardous
chemical(s)
– contained therein; and,
Appropriate hazard warnings,
or alternatively, words,
pictures symbols, or
combination thereof,

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Unlabeled Containers
 Labeling Systems
• You can use a labeling system, but you
must train workers on the system. It is not
required to use a labeling system.
 Other Items that Must Have
Labels
• Equipment or machinery that contains a
chemical (like tanks) must be labeled to indicate
the name and hazard of the chemical contained.
• Fuel tanks for internal combustion engines do
not have to have labels.
 Hazard Communication.

• (g) "Material safety data

sheets." Chemical
manufacturers and
importers shall obtain or
develop a material safety
data sheet for each
hazardous chemical they
produce or import.
Employers shall have a
material safety data sheet
in the workplace for each
hazardous chemical which
they use.
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 Hazard Communication.
• (h) "Employee information and training."
– Employers shall provide employees with
effective information and training on
hazardous chemicals in their work area at the
time of their initial assignment, and whenever
a new physical or health hazard the
employees have not previously been trained
about is introduced into their work area.

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 What Are We Looking For in
Training?
• Employees need to know how to get and use the information
they need to avoid chemical exposure.
• They should know: Where is the MSDS book?
• What are the hazards of the chemical they are using?
• How do they know what PPE to wear with a particular
chemical?
• If the employee can not answer these questions, then OSHA
would argue training was not EFFECTIVE
• If workers do not speak and read English, training must be
the language they understand, and someone who is bilingual
must be available to translate MSDS’s if they have questions.
 Permit Required Confined Space
• A Confined Space is:
• Big enough to enter
• Has limited means of
access/egress
• Not designed for
continuous
occupancy
 Confined Space
• A permit space is one that is a confined
space plus has a safety hazard (physical,
atmospheric, or mechanical)
 Confined Space
• Typical confined
spaces are AHU’s,
crawl spaces, tanks.
• Spaces must be
evaluated for the
potential to be permit
required confined
spaces
 Confined Space
• Written program
• Designated entrants
• Air monitoring prior to entry
• Entry permit
• Rescue and retrieval
 Personal Protective Equipment
(PPE)
• Evaluate the
workplace, specify
PPE for each job task.
• Train the workers on
when PPE is required,
and how to don and
use PPE
• Workers must sign off
they were trained.
Bloodborne Pathogens
 SCOPE
• Applies to all occupational exposure to
blood or other potentially infectious
materials.
 Exposure Control
• Written exposure control plan to include
the exposure determination, schedule and
methods of implementation of paragraphs
(d) to (h), procedure for the evaluation of
circumstances of exposure incidents.
 Exposure Control
• Copy of written plan accessible to
employees.
• Updated at least annually.
• Employer to determine who has exposure
and list job classifications and tasks and
procedures that involve occupational
exposure.
 Exposure Determination
• Exposure determination to be made
without regard to the use of personal
protective equipment.
 Housekeeping – What the Host
Employer is Supposed to Do
• An appropriate written schedule for
cleaning and decontamination is required.
• All equipment and environmental/working
surfaces shall be cleaned after contact
with blood/OPIM and at the end of the
shift.
Regulated & Non-Regulated Waste
• Regulated waste shall be disposed of in
accordance with applicable state and
county regulations.
• Non-regulated waste can be disposed of in
regular trash, however, it will contain
biohazardous materials. Wear gloves
when disposing of the trash in medical
offices.
 Hepatitis B Vaccination
• All employees with occupational exposure
shall be offered the Hep B series at no
cost within 10 days of employment.
• Post exposure evaluation and follow up
shall be offered to employees
occupationally exposed to blood/OPIM.
 Hep B Vaccination
• Employees can accept or decline the Hep
B vaccination series, if they decline, they
must sign the declination in Appendix A.
• The employer shall not make participation
in a prescreening program a prerequisite
for receiving the Hep B series.
 Post Exposure Evaluation
• A post exposure evaluation and follow up
must be immediately available to the
exposed employee.
• If the source individual can be identified,
the source individual’s blood shall be
tested if consent can be obtained and the
results released to the exposed employee.
 Post Exposure Evaluation
• The employee’s blood shall be collected and
tested after consent is obtained.
• Post exposure prophylaxis, counseling and an
evaluation of reported illness shall be made
available to the exposed employee.
• Documentation of the routes of exposure, and
circumstances surrounding the exposure
incident, as well as the source individual’s
 Post Exposure Evaluation
• and medical records relevant to the
employee’s treatment shall be provided to
the health care professional.
• The health care professional shall provide
the employer with a written opinion, stating
if the employee has received the Hep B
vaccination.
 Communication of Hazards
• Warning labels shall be
affixed to regulated
waste,
refrigerators/freezers
containing blood/OPIM,
and other containers.
• Labels shall be orange,
with the biohazard
symbol.
• Red bags may be used
instead of labels.
 Training
• Employees shall be trained upon
employment, and annually thereafter.
• Training to cover the regulation,
epidemiology and symptoms, exposure
control plan, hazard recognition, PPE, Hep
B vaccine, post exposure and follow up
procedures, labeling, with an opportunity
to ask questions.
 Training
• The person conducting the training shall
be knowledgeable in the subject matter.
• Training must be certified.
 Respirators
• If respirators are given to workers-
• They must be provided with NIOSH
approved equipment
• Worker must fill out the medical
questionnaire which is reviewed by a
physician
• Workers must be trained
Questions?