PDC 107 The Good, The Bad, and The Ugly - EHS at The Worst Plant

AIHce
EXP2019
Advancing Worker Health & Safety
PDC 107:
The Good, the Bad, and
MAY the Ugly – EHS at the

Worst Plant
20-22
MINNEAPOLIS
MN
PDCs: MAY 18, 19, and 23
The premier conference and
exposition for occupational
and environmental health
www.AIHce2019.org and safety professionals
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PDC 107
The Good, the Bad, and the Ugly – EHS at

the Worst Plant
Intermediate | Competent
Saturday, May 18 | 8:00 AM – 5:00 PM
Credits: 7 CM Credit Hours
Topics
Regulation & Legislation, Risk Assessment and Management, Safety Management
Description
The Worst Plant - A Virtual H&S Audit was one of the most successful seminars presented at conferences since its
inception in 2015. The Good, the Bad, and the Ugly takes attendees through a photographic tour of IH, safety, and
environmental issues at the worst plant in the world. Numerous forms of visual media are used to discuss the regulatory
compliance issues noted and possible audit findings. A full slate of EHS topics is covered (e.g., abrasive wheel, subpart Z,
air pollution, underground storage tanks, etc.).
Prerequisites
Participants should have fundamental knowledge of IH, safety, and environmental issues and regulations. A laptop or
similar device to conduct regulatory research is required.
Value Added
Participants will receive information on EHS regulations, supplemental materials, various resources (e.g., directives,
letters of interpretation, etc.), and a PDF of this presentation.
Outline
 Introductions of Instructors and Attendees

 Course Approach and Learning Objectives
 Health Topics Review (Hazard Communication, PPE, RP, Ventilation, Noise, etc.)
 Environmental Topics Review (Air Pollution, Waste, Water, RMP, etc.)
 Safety Topics Review (Fall Protection, LOTO, Electrical, Confined Spaces, etc.
 Loss Prevention and Emergency (Fire, Egress, Process Safety, etc.)
 Course Summary
 Final Q&A
 Closing
Learning Outcomes
Upon completion, participants will be able to:
 Leverage their recognition skills for EHS compliance issues.

 Communicate with their team and others on various topics.
 Decipher OSHA and EPA standards, compliance directives, and letters of interpretations.
 Apply OSHA and EPA regulations as they pertain to the topics presented.
 Describe the non-compliance issues noted in the photographic tour.
 Suggest types of corrective action(s) that might apply to a given scenario.
Transfer of Knowledge
Instructors will evaluate participants’ understanding of the materials presented based on:
 Group activities
 Interactive games
 Practice exercises
 Workshops
Instructors
Corey Briggs, CIH, CET, FAIHA, Colden Corporation, Quincy, MA.

Michael Holton, CIH, CSP, Ramboll, Princeton, NJ.
Tom Martin, CIH, CSP, Ramboll, Ann Arbor, MI.
Clint Smith, MS, CIH, CSP, Colden Corporation, East. Syracuse, NY.
© American Industrial Hygiene Association

3141 Fairview Park Drive, Suite 777, Falls Church, VA 22042 ● phone +1 703-849-8888 ● fax +1 703-207-3561
AIHce EXP 2019 PDC 107
WELCOME TO MINNEAPOLIS
PDC 107
“The Good the Bad and the Ugly: EHS at
the Worst Plant”
May 18, 2019
As you are getting settled please meet
your teammates for the day!
Your Facilitation Team
Colden Corporation
Corey Briggs, CIH, CET, FAIHA,
AIHA Distinguished Lecturer
Boston, MA
Clint Smith, CIH, CSP
Syracuse, NY
Ramboll
Tom Martin, CIH, CSP
Ann Arbor, MI
Michael Holton, CIH, CSP
Princeton, NJ
2
AIHA ® Page 1
Introductions
• Corey: Co-
Creator,
Lead
Facilitator,
and
Moderator
Introductions
• Clint
• Tom
• Mike
AIHA ® Page 2
Introductions
You…….there are too
many of you so
you're off the hook,
but we'll be meeting
and working with
you during the
session
Meet
your
team! 5
Rules of the Road
AIHA ® Page 3
• Logistics
– Signing in
– Badges
– Teams
– Breaks/Lunch
– Course Reviews
– Restrooms
– Etc. Etc. Etc.
Introductions and Rules of the Road

• Lots of experience in the room…let’s share it!
• Town hall meeting BUT…one person talking at a
time please.
• Mixed presentation methods for this session:
“Show and Tell”, Case studies, Problem sets,
H&S/IH Bar Trivia
• Group participation, teamwork, and discussion are
key!
• We are all here to learn.
• Corey will serve as the overall moderator.
AIHA ® Page 4

We agree to disagree on some
items….maybe…and possibly be politically
incorrect (but not on purpose!) and may
have a good laugh at someone’s
expense….but remembering the overall goal
of our profession
…encouraging doing whatever we can to
help assist with managing and
implementing health and safety in the
workplace

What is an audit vs. inspection?
What do you do (Policies, procedures, practices)?
1. Show me (I’m from Missouri!)
2. Physical Inspection
Letter of the law (Finding) vs. Best practice (BMP)

approaches
10
AIHA ® Page 5
Learning Objectives/Outcomes
• As the majority of you have IH as your primary
education and training, learn more about workplace,
employee, facility, and process safety
• Improve your recognition skills for various EH&S
hazards, risks and compliance issues that can occur in
the workplace
• Get tips on auditing techniques for various EH&S topics
• Navigate various OSHA and environmental standards,
compliance directives and letters of interpretation
• Apply OSHA and environmental regulations as they
pertain to the topics presented
• Interpret various regulatory issues
11
Agenda (Just a list...we mix it up)

• PPE
• Machine Guarding
• Walking/Working
Surfaces
• Air Contaminants/IH
• Materials Handling,
Storage and the
PIT Hall of Shame
• Fire Protection,
Prevention
and Planning
12
AIHA ® Page 6
Agenda
• LOTO
• HazCom
• Electrical Safety
• Confined Space
• Welding, Cutting, Brazing, Hot Work
• Laboratory Safety
• Emergency Planning
• First Aid/Bloodborne Pathogens
13
Agenda
• Respiratory Protection
• Combustible Dust
• Cranes, Hoists and Slings
• Contractor Safety Management
• Process Safety Management
• Key “E” topics will be sprinkled in……
• Lightning Rounds
• EHS Bar Trivia
• Closing - All
14
AIHA ® Page 7
A Multi-Dimensiona l Company
-Mission Statement
“We Do it Al l ”
Location: Somewherein, Minnesota
15

Let's meet the Owner, Plant Manager the
EHS Representative
Mr. Fred Dontcare
16
AIHA ® Page 8
17
Personal Protective Equipment - CB
18
AIHA ® Page 9
Personal Protective Equipment - PPE
19
• Pressure dump valve inside

PPE the A suit was not inspected
(in backwards)
• Incomplete inspection of
equipment prior to donning
Subpart I (PPE) and 1910.120
Corrective Action:
• Setup a formal equipment
inspection process and train
employees.
20
AIHA ® Page 10
PPE
21
PPE
22
AIHA ® Page 11
PPE
• Improper storage and poor hygienic condition
1910.132
Corrective Actions:
• Dispose of old, damaged PPE
• Establish a better storage system
• Retrain personnel
• Inspect areas periodically
23
PPE
Case
Study:
The
“After”
Picture
24
AIHA ® Page 12
PPE
• What PPE do you think was worn previously?
• Do you think a certified PPE Hazard
Assessment was done?
– Yes or No?
25
PPE
Suggested Improvements
• Evaluate the task/job...not necessarily the work
area
• Include with Job Safety Assessment (JSAs)
• Make sure to get with employees: get their input!
• Ongoing review, review, review and review
• Be aware of new job tasks
• Others?
26
AIHA ® Page 13
PPE – Any Guesses?
27
Machine Guarding - TM
Hierarchy of controls
– Where does
machine guarding fit
in?
Is a sign a substitute
for machine
guarding?
(Why/Why Not?)
Legal – What would

this sign do for Fred’s
OSHA citation
defense, if a worker
were to be hurt on
this machine?
Any other (non-

guarding) hazards you
see? Dust, electrical wiring, others?
28
AIHA ® Page 14
Machine Guarding
• 1910.219(c)(3)
...vertical and
inclined
shafting seven
feet or less
from floor
shall be
enclosed with
a stationary
casing...
29
Machine Guarding
What does OSHA and ANSI say? What about OSHRC?
• ANSI B65/NAPIM 177.2-2006 …minimally,

guards shall extend from the top of the
exposed shaft to below the side height of the
in-place mixing vessel... examples include shaft
guards such as flexible “bellows-type”,
telescopic, vessel lids with integrated or
attached shaft guards, or fixed shaft guards
that extend to the impeller…
30
AIHA ® Page 15
Machine Guarding
What does OSHA and ANSI say? What about OSHRC?
• OSHA Review Commission (OSHRC) - “OSHA must prove that a

hazard within the meaning of the standard exists in the
employer’s workplace” (ConAgra Flour Milling Co. 1993-95,
and South Dakota Beverly Enters. – 2005). “OSHA must show
that the employees are in fact exposed to a hazard as a result
of the manner in which the machine functions and is operated”
(Jefferson Smurfit Corp – 1991). “The mere fact that it is not
impossible for an employee to come into contact with the
moving parts of a particular machine does not, by itself, prove
that the employee is exposed to a hazard” (Armour Foods –
1986).
31
Cotton
carding
machine –
operators
clean several
times per
day.
Does this
need to be
guarded?
What parts?
How would
you guard
it?
32
AIHA ® Page 16
Pump
motors –
what about
the gap
here?
Exposed
shaft – you
could get
your fingers
inside the
guard.
Is this OK
with OSHA?
33
Is this
“properly”
guarded? –
Why/Why Not?
What about
the top side?
What “height”
does Fred need
to guard to, per
OSHA?
What about
“risk” vs.
“OSHA
compliance”?
34
AIHA ® Page 17
Machine Guarding – It’s interlocked,

but . . .
35
Machine Guarding
Are these guarded properly? – What to look for . . .(Risk Assessment)

Are guards interlocked? Are the interlocks “control reliable”? Can someone be in the enclosure with the
gate closed, and another operator start the equipment without seeing the person inside the enclosure?
Does the equipment stop quickly enough to prevent injury if the gate/door is opened during operation?
Does anyone access the equipment to clear minor jams that occur during production?
(See “Exception to LOTO”)
36
AIHA ® Page 18
Machine Guarding 101
•OVER
•UNDER
•AROUND
•THROUGH
37
Walking and Working Surfaces - MH
HOW
HIGH
CAN
HE
GET…
…
38
AIHA ® Page 19
39
Walking and Working Surfaces

Issues:
• Aisle blocked; tripping hazard
Issues:
• 1910.22(a)(1)All places of
employment, passageways,
storerooms, service rooms, and
walking-working surfaces are kept
in a clean, orderly, and sanitary
condition.
• 1910.176(c) - Storage areas shall be
kept free from accumulation of
materials that constitute hazards
from tripping
Corrective Action:
• Remove materials from aisle and
store properly; train personnel,
ongoing inspection
40
AIHA ® Page 20
This is a
Foot
41
42
AIHA ® Page 21
EHS BAR TRIVIA TIME – SLIPS
Name the band!
43

Case Study
• PROBLEM: We had a problem with coffee
constantly being spilled on one particular stairwell
and a couple of employees had slipped (no injuries
yet ....).
• Citation: 1910.22(a)(2) The floor of every workroom

shall be maintained in a clean and, so far as possible,
a dry condition. Where wet processes are used,
drainage shall be maintained, and false
floors, platforms, mats, or other dry standing places
should be provided where practicable.
44
AIHA ® Page 22

• Corrective Action #1:
– Check the stair treads to
see if they were unusually
slippery when wet. – (The
treads were fine.)
– We asked the janitorial staff to check that stairwell more
frequently –
– No improvement. Someone could spill coffee right after they
cleaned it.)
45

– We installed paper towel
dispensers (yes, we put
combustibles in an exit stair),
installed pop-up tents (see
photo), and installed signs
asking employees to clean up
their spills or at least mark
them with tents.
– No improvement.
46
AIHA ® Page 23

– We finally got smart and realized
that the coffee vending machine
filled the cups all the way to the
top and we had not provided
lids.
– We fixed both those issues and
still had coffee on the stairs.
– No improvement.
47

– We finally got wise and realized that the
coffee vending machine was next to the
cafeteria on the 2nd floor.
– The vast majority of people worked on the
first floor. We moved the coffee machine to
the 1st floor - No more coffee on the stairs!
We felt stupid that it took so long to get to the
root of the problem!
• Immediate cause(s)
• Contributing factors
48
AIHA ® Page 24

and Egress?
49
Air Contaminants/Regulated
Substances (E and H&S) – CS
50
AIHA ® Page 25
Air Contaminants
• OSHA Regulated Substances…
– Do you have them at your plant or facility?
– Are you sure?
51
1. 1,2 –dibromo-3-chloropropane
Regulated 2.
3.
1,3 Butadiene
2-Acetylaminofluorene,
4. 3,3'-Dichlorobenzidine (and its salts)
Substances 5.
6.
4-Aminodiphenyl
4-Dimethylaminoazo-benezene
7. 4-Nitrobiphenyl
8. Acrylonitrile
9. alpha-Naphthylamine
10. Arsenic – Inorganic
11. Asbestos
12. Benzene
13. Benzidine
14. Beryllium
15. beta-Naphthylamine,
16. beta-Propiolactone
17. bis-Chloromethyl ether
18. Beryllium
19. Cadmium
20. Coal Tar Pitch Volatiles
21. Cotton Dust
22. Crystalline Silica
23. Ethylene Oxide
24. Ethyleneimine
25. Formaldehyde
26. Hexavalent Chromium
27. Lead –Inorganic
28. Methyl chloromethyl ether
29. Methylene Chloride
30. N-Nitrosodimethylamine
31. Vinyl chloride
32. Cotton Dust
33. Coke Oven Emissions
52
AIHA ® Page 26
Air Contaminants – Case Study
53
Air Contaminants – Case Study
#203
54
AIHA ® Page 27
Air Contaminants
55
Air Contaminants
• Lack of formal exposure
assessment and
improper respirator use
- several
1910.1000 and
1910.134
• Exposure assessment,
determine the best
method of control, if
respirators - correct
ones and full program
56
AIHA ® Page 28
Air Contaminants
The case of the cyclones that would not calibrate ..........................
57
Air Contaminants
Inspection, inspection, inspection….and bring spares!
58
AIHA ® Page 29
59
Lightning Round #1
• 8 Images
• 10 Seconds per image
• Shown 3 times
• What can you see or what
questions would you have?
60
AIHA ® Page 30
61
62
AIHA ® Page 31
63
64
AIHA ® Page 32
65
66
AIHA ® Page 33
67
68
AIHA ® Page 34
69
70
AIHA ® Page 35
71
72
AIHA ® Page 36
73
74
AIHA ® Page 37
75
76
AIHA ® Page 38
77
78
AIHA ® Page 39
79
80
AIHA ® Page 40
81
82
AIHA ® Page 41
83
84
AIHA ® Page 42
Lightning Round #1
Let’s Review
85
86
AIHA ® Page 43
87
88
AIHA ® Page 44
89
90
AIHA ® Page 45
91
92
AIHA ® Page 46
93
Control of Hazardous Energy/LOTO - TM
How do I
Is this a attach my
LOTO lock to
lock? this?
Any other
issues
here?
94
AIHA ® Page 47
What are the

OSHA rules on
LOTO tags?
(29 CFR
1910.147)
Next slide . . .
95
LOTO
• Tag but no lock. Tag can't support 50
pounds, and istied on, easily removed.
• 1910.147(c)(S)(ii)(C)(2)
• Tagout devices - including their means
of attachment, shall be substantial
enough to prevent inadvertent or
accidental removal.
Corrective Actions
• Ensure use of a tagout system is
equivalent to the control provided by a
lockout / tagout process; including
unlocking strength of no less than 50
pounds
96
AIHA ® Page 48
This is an “E-
stop”
What are the

rules about
using e-stops
for LOTO
purposes?
(next slide . . . )
97
LOTO
• An E-stop is not (usually) an " Energy Control Device" [a.k.a.,
energy isolating device [EID)] and not a suitable place for
LOTO. ( W h y ? )
• Ever seen a LOTO hasp on an E-stop or control button?
Sometimes they come that way from the manufacturer.
Explain that to Fred (or anyone else)!
• 1910.147( b) - Definitions - Energy isolating device. Mechanical

device that physically prevents the transmission or release of
energy…a manually operated electrical circuit breaker; a disconnect
switch; a manually operated switch by which the conductors of a
circuit can be disconnected Push buttons, selector switches and
other control circuitry type devices are NOT energy isolating
devices. Discuss non-US equipment – what to look for; a very
different philosophy about this subject.
98
AIHA ® Page 49
“The Exception to LOTO”

Scenario: You find Fred’s
operating personnel
clearing a jam from the
inside of this machine.
Jams are common events

during production runs.
They happen routinely and
repetitively during
production.
This machine has modern,

control-reliable interlocks
and safety systems.
Do I need to LOTO
the machine to clear
jams?
99

Interlocks are not energy isolation devices, and is not generally
suitable for servicing and repair work. If you want to apply the
“Exception to LOTO” - 29 CFR 1910.147(a)(2)(ii) . . .
• Determine the applicability of the (a)(2)(ii) exception. Read the

OSHA Enforcement Policy and Inspection Procedures (CPL 02-00-
147) first!
• Retrain employees/management. Install suitable/lockable EIDs
for each hazardous energy source (if none exist); write and
implement an energy control procedure (ECP) and train
authorized personnel…or develop, document and implement
alternative effective measures.
• Exception to paragraph (a)(2)(ii): SEE NEXT PAGE
100
AIHA ® Page 50

Minor tool changes, adjustments, minor servicing activities (during
normal production operations) are not covered by the LOTO
standard if they are routine, repetitive, and integral to the use of
the equipment for production, if…using alternative measures which
provide effective protection – see Subpart O.
1. Effectively safeguarded with a control-reliable safety

system
2. Minor tool changes, minor adjustments, minor servicing is
OK. . . but not tool changes for new/changed production
runs, sanitizing, other repair/maintenance – these require
LOTO.
3. Routine, repetitive, and integral to production . . . likely
does not mean what you think it does.
All three of the above elements are required for the exception to
apply.
101
LOTO
Scenario: You find a
LOTO lock and tag
dated 11/30/1999.
Today's date is
5/20/2019. No one has
worked on this
equipment for a very
long time (many
months/years).
Any problems here for

Fred to address?
(“But we’re still waiting on a repair part

to be shipped . . . “
102
AIHA ® Page 51
LOTO
Corrective action:
• Use "Out of Service" tags that are

visually distinct from the LOTO
tags for this purpose. Or use a
completely different style/color
lock.
• Ensure this process is in your Back
w ritten LOTO program and
personnel are trained on the
purpose.
1910.147(c)(5)(ii)
Lockout/tagout devices ". . . shall not
be used for other purposes; . . ."
See OSHA Letter of Interpretation on
this subject dated October 11, 2006.
103
Materials Storage - MH
104
AIHA ® Page 52
105
Materials Storage
Materials stored in an
unsecured fashion.
1910.176(b) - Storage of material

shall not create a hazard. Bags,
containers, bundles, etc., stored in
tiers shall be stacked, blocked,
interlocked and limited in height so
that they are stable and secure
against sliding or collapse.
Corrective Action:
Remove materials from aisle
and store properly; train
personnel, ongoing inspection
106
AIHA ® Page 53
107
108
AIHA ® Page 54
Materials Storage
Quick Question – What
is the section/citation
number of the OSHA
General Industry
regulation for metal
racking safety?
Answer – There is no
metal racking
regulation.
Does this mean Fred

can’t be cited for this?
109
Materials Storage
Damaged racking
• OSHA General Duty Clause
• 5(a)(1) - …free from recognized
hazards…
• RAGAGEP is ANSI MH16.1-2012
Corrective Action:
• Develop a maintenance and
inspection program for storage
racks ensuring racks are
properly aligned, plum, and level,
per manufacturer’s instructions,
as well as encouraging
employees to promptly report
any damage to racks.
110
AIHA ® Page 55
111
• Materials too close to ceiling with

automatic sprinkler coverage.
• 1910.159(c)(10) - The minimum vertical
clearance between sprinklers and
material below shall be 18 inches (45.7
cm).
• Also, storage on non-rated structure.
• 1910.22(d)(2) - It shall be unlawful to
place, or cause, or permit to be placed,
on any floor or roof of a building or other
structure a load greater than that for
which such floor or roof is approved by
the building official.
Corrective Action:
• Develop a maintenance and inspection
program for storage racks ensuring
materials are not stored closer than 18”
to automatic sprinklers or in / on non-
rated spaces or structures.
112
AIHA ® Page 56
Hazardous Waste - CB
• Three levels of generator status – VSQG, SQG, and LQG.
– VSQG: generates less than 100 kg per calendar month of non-acutely hazardous waste
and accumulates no more than 1,000 kg at any time.
– SQG: generates between 100 kg and 1,000 kg per calendar month of non-acutely
hazardous waste and accumulates no more than 6,000 kg for not more than 180 days.
– LQG: generates greater than 1,000 kg per calendar month of non-acutely hazardous
waste and accumulates for not more than 90 days.
• Different statuses have increasingly complex requirements; however, in
general:
– Must characterize why the waste is hazardous.
– Must dispose at properly permitted TSDFs.
– Containers must be in good condition and compatible with contents.
– Containers must be closed.
– Containers must have a containment system.
– Label “hazardous waste” and dated at start of accumulation.
113
114
AIHA ® Page 57
115
116
AIHA ® Page 58
Universal Waste Management - CB

• Typically covers batteries, lamps, pesticides and mercury-containing
equipment, but states may define others.
• Packaging must be closed, structurally sound and compatible (40 CFR
273.13).
• Must label containers “universal waste XXX,” “waste XXX,” or “used XXX”
(40 CFR 273.14).
• May only accumulate for one year and be able to demonstrate that one
year is not exceeded (40 CFR 273.15).
• Must train employees on proper handling/management procedures (40
CFR 273.16).
117
Used Oil - CB
- Used oil containers must be in good condition
(no severe rusting, apparent structural
defects or deterioration) and not leaking. 40
CFR 279.22(b)
- The containers must clearly be labeled “used
oil.” 40 CFR 279.22(c).
- In the event of a release, you must stop the
release, contain the used oil, clean up and
repair/replace leaking containers. 40 CFR
279.22(d) 118
AIHA ® Page 59
119
120
AIHA ® Page 60
Laboratory Safety - CS
121
Laboratory Safety
Question?
Is my lab covered by the OSHA
Laboratory Standard
(1910.1450)?
Straightforward answer…right?
GROUP ACTIVITY
What are the conditions that need to be
met to meet the definition of a lab?
122
AIHA ® Page 61
123
Laboratory Safety
Problem
• Likely incompatible
chemical storage
Citation
• 1910.1450
Corrective Action
• Proper chemical
segregation and
storage
• Training
124
AIHA ® Page 62
Laboratory Safety
125
Laboratory Safety
Problems?
• Possibly working alone
• Hood sash height
• Others?
Citation
• General duty 1910.1450/CA
ventilation
Corrective Actions
• Buddy system
• Need to evaluate proper sash
height
126
AIHA ® Page 63
Laboratory Safety - Bottle

Crusher
This glass crusher is
routinely used to
compact glass sample
containers containing
water that must be
disposed of.
What H&S issues can

occur when this glass
crusher is used to crush
vials containing
toluene?
127
Laboratory Safety - Bottle

Crusher
Problem
• Toluene PEL and Ceiling
Limit – 29 CFR 1910.1000,
Table Z-2
Citation
• Fire and Explosion Hazard
– Electric motor not
intrinsically safe – 29
CFR 1910.307
– No fire extinguisher
present – 29 CFR
1910.157
Corrective Action
• Stop the operation!
128
AIHA ® Page 64
Hazard Communication (Hazcom) - MH
129
Per HazCom, does waste

need to be labelled?
This section does not
apply to any hazardous
waste as such term is
defined by the Solid
Waste Disposal Act, as
amended by the Resource
Conservation and
Recovery Act of 1976, as
amended (42 U.S.C. 6901
et seq.), when subject to
regulations issued under
that Act by the
Environmental Protection
Agency.
1910.1200(b)(6)(i)
130
AIHA ® Page 65
131
Hazard Communication (Hazcom)

• No identifying labels
• Improper secondary
container labelling
• 1910.1200
• Corrective Action
– Label properly, noting
exemptions for
consumer products
132
AIHA ® Page 66
Secondary
Containers
VS
https://www.osha.gov/Publications/OSHA3636
.pdf
133
Hazard Communication
• What about piping
systems?
• Are unlabeled
hazardous chemical
piping systems an audit
finding?
134
AIHA ® Page 67
• Pipes are not required
to be labeled with HCS
labels because they are
not considered
“containers” under the
HCS. Note: It is
required along with
direction of flow in
Canada!
• However……
135
• Train employees on the hazards associated with the
chemicals in their work area. Must include:
• Information on the pipe coding system and any other labeling
requirements established by other standards that address pipes and
piping systems
• Hazards of the chemicals in those pipes
• Methods used to detect a leak from those pipes
• Methods the should follow in the event the pipes leak or rupture.
• Workers who are assigned to work on such pipes should also be trained on
how to protect themselves from the hazards of the chemicals in the pipes.
https://www.osha.gov/dsg/hazcom/hazcom-faq.html
136
AIHA ® Page 68

Effective Completion Date Requirement(s) Who
December 1, 2013 Train employees on the new label Employers

elements and safety data sheet (SDS)
format.
June 1, 2015*December 1, 2015 Compliance with all modified Chemical manufacturers, importers,
provisions of this final rule, distributors and employers
except: The Distributor shall not ship
containers labeled by the chemical
manufacturer or importer unless it is
a an HCS Compliant label
Update alternative workplace Employers
June 1, labeling and hazard communication
program as necessary, and provide
2016…yup additional employee training for

newly identified physical or health
hazards.
that’s coming
up on 3 years
ago!
Transition Period to the effective May comply with either 29 CFR Chemical manufacturers, importers,
completion dates noted above 1910.1200 (the final standard), or the distributors, and employers
current standard, or both
137

Group Exercise:
You ask the plant manager for
MSDS/SDS and are directed to the
plant intranet which is on a desk
top computer near the time clock
What audit findings may you

encounter?
138
AIHA ® Page 69

• SDS outdated SDS missing
• SDS only for raw materials
• Employees don't know how to accessing the
event of an emergency
• SDS are not accessible at all hours
• No one knows how to access SDS from intranet
• Old SDS have been thrown away and not archived
• Intranet not available – can’t log in/no wifi
outside of facility
• Has subscription service been paid????
• Audit your online service!
139
Electrical Safety - TM
Who likes spaghetti?
Who likes exposed,

energized electrical
conductors, stuffed
in an electrical box
that’s too small, was
designed to be
attached to a
wall/column, has no
cover, and has open
“knockouts” into the
box?
Welcome to OSHA
Subpart S!
140
AIHA ® Page 70
What should we look for in a circuit

breaker (CB) panel?
Is every CB properly labeled at to its

purpose, i.e., the circuit/thing it
powers?
Is every opening into the inside of the

CB panel appropriately covered? (Is
electric tape an appropriate covering?)
Green tape on the CB panel door –

what do you think that’s for? (My
guess – to cover a CB instead of proper
application of a lock/tag)
Question for Fred – Who is allowed to

access the CB panel, and what
directions have employees been given
about resetting CBs that have tripped?
141
What do
you see?
What
question(s)
do you have
for Fred?
142
AIHA ® Page 71
143
Questions for Fred:
1. Is this energized? How do you know this?
2. If energized - why is the cover off and no barrier and/or

attendant?
29 CFR 1910.333(a)(1) - "Deenergized parts." Live parts to which an

employee may be exposed shall be deenergized before the
employee works on or near them, unless the employer can
demonstrate that deenergizing introduces additional or increased
hazards or is infeasible due to equipment design or operational
limitations. Live parts that operate at less than 50 volts to ground
need not be deenergized if there will be no increased exposure to
electrical burns or to explosion due to electric arcs.
(Best reference source – NFPA 70E-2018)

144
AIHA ® Page 72
What do you see?
145
Electrical Safety
• You've probably seen
this one….a classic!
The contractor was hired by
his buddy (Fred’s purchasing
rep) to install a disco ball
above the company indoor
pool/swim-up bar. Yes……..he
was the low bidder!
(but OK – what’s wrong here? – See

next slide)
146
AIHA ® Page 73
Electrical Safety
• 120 v. corded drill motor . . . In a
swimming pool . . .
• On a aluminum ladder . . . In bare feet
. .. .
• He's wet from the waist down . ..
• But he does have on goggles! and the
cord and connection are not in the
water.
Questions:
• If the drill motor was plugged
into a "GFCI" - would this be OK?
• What about an 18 v. battery powered

drill motor?
• What do you think?
147
Work: Note:
Determine Big/Fat
if the power Wires =
is off using
and aka
electrical BFW
test meter.
148
AIHA ® Page 74
Electrical Safety
• He is metering t o verify
th e power is off.
• How do you know th e

power is off until you
test?
• W here is his arc

f l ash/sh ock PPE?
149
Electrical Safety
Corrective action:
Perform an ARC flash

assessment and label
equipment with
NFPA 70E labels,
train personnel, and
obtain task-
appropriate arc
flash/electric shock
PPE. 150
AIHA ® Page 75
Electrical Safety
Is an arc flash study required by OSHA?
Not mentioned directly in a standard by OSHA . . . but
if you have qualified persons working/testing
potentially energized equipment, how will you know if
the arc flash PPE is the right incident energy rating if
you have not done the study? (Then you could be
cited under the PPE standard). Note that there are
some tables in NFPA 70E-2018 that could be
referenced in the absence of study data – with great
care and SME support)
151
This is an “adapter”
to make a single 120
V outlet into four
outlets.
Located in the
cafeteria, behind the
vending machines.
Any issues here?
What about NRTL?

(What’s a NRTL
anyway?)
152
AIHA ® Page 76
EHS BAR TRIVIA TIME - ELECTRICAL
480VOLTS…50,000
WEATTS = HOW
MANY AMPS
153
Lightning Round #2 – MH & TM

• 5 images
• 10 seconds per image
• 3 times through
154
AIHA ® Page 77
155
156
AIHA ® Page 78
157
158
AIHA ® Page 79
159
160
AIHA ® Page 80
161
162
AIHA ® Page 81
163
164
AIHA ® Page 82
165
166
AIHA ® Page 83
167
168
AIHA ® Page 84
169
Lightning Round #2 – Let’s

Review
170
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171
172
AIHA ® Page 86
173
174
AIHA ® Page 87
175
Fire Prevention/Protection and Planning - CB
176
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177
178
AIHA ® Page 89
179
Fire Prevent ion/Protection

and Planning
Does Fred’s facility need one or
not?
180
AIHA ® Page 90

and Planning
Class Exercise
- W h ich of the OSHA standards specif i cally require a
Fire Prevent ion Plan [FPP]?
- What are the m inim um requirements of an FPP?
- Other than OSHA, who else m ight require the

facilit y to have an FPP?
181
Fire Prevention/Protection and

Planning - Hint
OSHA Compliance
Directive CPL 2-1.037
182
AIHA ® Page 91

and Planning
Class Exercise
- W h ich of the OSHA standards specifically
require a Fire Prevent ion Plan [FPP]?
- What are the m inim um requirements

of an FPP?
- Other than OSHA, who else m ight

require the facility to have an FPP? 183

and Planning
Quick Case Study:
The Value of the Insurance Company

Loss Prevent i on and Risk M anagement
Reports
184
AIHA ® Page 92
Fire Prevention/Protection and

Planning
The same loss prevention and risk management
representative visits the facility each year to 16
months. He's buddies with the plant
ma nager.
For several years, the insurance company's annual
reports indicated in
writing that "the facility is grossly under protected in
many areas of the plant" for fire and that significant
losses would occur.
There is no doc umentation responding to the

insurance company's findings noted in the report.
Auditors found out that various entities in corporate

were not aware of this after it was raised in the closeout
185
meeting and in the report.
FPP: Inspection Processes
186
AIHA ® Page 93
187
188
AIHA ® Page 94
FPP
189
190
AIHA ® Page 95
191
EHS BAR TRIVIA TIME
192
AIHA ® Page 96
Fall Protection/Prevention - CS
Is there an OSHA
legal issue here?
No. So long as she

is not someone’s
employee; i.e. she
is self-employed.
(Note that the law

of gravity does
apply in this
situation,
however.)
193
Any issues
here?
What is the
requirement
for personal
fall arrest
anchoring
equipment and
anchors?
29 CFR
1910.140(c)(4)
and (c)(13)(i).
5,000 lbs.
194
AIHA ® Page 97
Very
common
audit
finding .
.....
195
Fall Protection/Prevention
• Unprotected ladder
way (chain or gate
needed)
• Other issues –
clearance from
ladder rungs, can’t
really tell if a
handrail is missing on
the right side, can’t
tell the height of the
ladder.
196
AIHA ® Page 98
1910.23(a)(2)
• Every ladderway floor
opening or platform shall be
guarded by a standard railing
with standard toe board on
all exposed sides {except at
entrance to opening),with
the passage through the
railing either provided with a
swinging gate or so offset
that a person cannot walk
directly into the opening.
197
Fall Protection/Prevention – GOOD!
But somebody
explain what
we’re looking at
here . . .
198
AIHA ® Page 99
What is it
and what
is this for?
199
• No
documentation of
platform design
and minimum
live-load rating
200
AIHA ® Page 100

1910.66(f )( l)
• General requirements. The
following requirements apply
to equipment which are part
of a powered platform
installation, such as platforms,
stabilizing components,
carriages, outriggers, davits,
hoisting machines, wire ropes
and electrical components.
Equipment installations shall
be designed by or under the
direction of a registered
professional engineer
experienced in such design;
• The design shall provide for a

minimum live load of 250
pounds {113.6 kg) for each
occupant of a suspended or
supported platform
201
Corrective Actions:
Ensure working platforms
• are designed by a
professional engineer;
• have sufficient load
ratings,
• are appropriately
inspected/maintained
• chained to the forklift
mast when occupied
• always attended by a
licensed forklift
operator
202
AIHA ® Page 101

203
1910.23(e)(S)
• Skylight screens shall be of such construction and mounting that
they are capable of withstanding a load of at least 200 pounds
applied perpendicularly at any one area on the screen. They shall
also be of such construction and mounting that under ordinary
loads or impacts, they will not deflect downward sufficiently to
break the glass below them. The construction shall be of grillwork
with openings not more than 4 inches long or of slatwork with
openings not more than 2 inches wide with length unrestricted.
204
AIHA ® Page 102

Corrective Action:
• Replace guarding with compliant structure
205
EHS BAR TRIVIA TIME - FALLS
Name the singer
206
AIHA ® Page 103

First Aid/Bloodborne Pathogens - MH
207
First Aid/CPR
• The finding:
– Company offers First Aid
training to employees.
– No procedure for first
aid emergencies,
instructions
• Do you NEED to offer
First Aid?
208
AIHA ® Page 104

First Aid/CPR
• Do you need to offer First Aid training?
– “In the absence of an infirmary, clinic, or hospital in near proximity to
the workplace which is used for the treatment of all injured
employees, a person or persons shall be adequately trained to render
first aid. “ *
– “OSHA has long interpreted the term "near proximity" to mean that
emergency care must be available within no more than 3-4 minutes
from the workplace”
• Who are you offering it to?

– An established team – names and numbers?
– For information only?
• *https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_
table=INTERPRETATIONS&p_id=25627
209
FA Supplies
210
AIHA ® Page 105

FA Supplies
• Locked First Aid
cabinet-
– Audit finding?
https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=25621
211
CPR
• Some OSHA Standards require CPR
– Example: 1910.146 – Permit-Required Confined
Spaces
• Guide for written FA/CPR programs

– https://www.osha.gov/Publications/OSHA3317firs
t-aid.pdf
212
AIHA ® Page 106

BBP
Audit Finding: No BBP Program at this facility

• Is BBP Program needed?
• Why?
• What if participation is strictly voluntary. No “TEAM”.
→ “If an employee is trained in first aid and identified by the employer as responsible for
rendering medical assistance as part of his/her job duties, that employee is covered by the
bloodborne pathogens standard.” *
→ Corrective Action:
→ Establish BBP Program
*https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=25627
213
BBP Program
• Exposure Control Plan
• THAT is the program
• Non-applicable parts?
• HIV/HBV research laboratories, etc.…
• Needlestick Safety and Prevention Act 2000
Some of the new and clarified provisions in the standard apply only
to healthcare settings, but other provisions, particularly the
requirements to update the Exposure Control Plan and to keep a
sharps injury log, apply to non-healthcare as well as healthcare
settings.
214
AIHA ® Page 107

BBP
• Training
– Who is conducting the training?

– Are they covering the required elements?
– How is it documented?
https://www.osha.gov/SLTC/bloodbornepathogens/otherresources.html
215
BBP
• Cleanup/Decontamination????
– Who does the cleanup?
– Disposal of the infectious waste be in accordance
with federal, state, or local regulations
216
AIHA ® Page 108

Confined Spaces - CB
Walking through
Fred’s facility we
notice this vessel
with a fan
positioned at an
opening…????
217
Confined Spaces
218
AIHA ® Page 109

Confined Spaces
Corrective action
• Entry should not occur if readings indicate a
hazardous atmosphere is present.
• Ventilation should be provided and maintained until
an acceptable atmosphere is present .
• Ongoing monitoring
219
Confined Spaces – Your Turn

• CNC machine.
• Workers occasionally
have to enter this
machine to clear jams,
debris, and find/fix
hydraulic leaks
• The entrance is above
floor level and the
workers basically have
to physically climb into
the machine.
220
AIHA ® Page 110


• Is this a confined
space?
• Is it a permit-
required space?
• How can we solve
this issue?
221

• It is a permit-required
space, but may be able
to be re-classified.
• Can they utilize LO/TO
(C)(7) to reclassify the
space?
• Or maybe add access
panels and use tools to
reduce/eliminate the
need for entry.
222
AIHA ® Page 111

• Is th is a permit-requ ired confined space?

• Are th ere t w o conf i ned spaces here? Signage?
• Have th ese spaces been evaluated (i.e. documented )?
223
Confined Spaces
Corrective action:
Ask a bo ut t he spa ce(s), w hat tasks are conducted in t he pit, is th e

tank entered, w hat chem icals a re present, w hat evaluations have
been performed, etc.
224
AIHA ® Page 112

225
226
AIHA ® Page 113

227
Combustible Dust - TM
Hopefully,
not Dontcare
Industries!
228
AIHA ® Page 114

229
Several things
from this photo:
1. Yes, there is a
lot of both
settled and
airborne dust.
2. When you use

your flash to
take pictures in
a dusty area, it
looks like a
snow storm.
Is this a hazard?
How do we
determine if this is
a hazard?
230
AIHA ® Page 115

First – Is this a
combustible dust?
(It’s polyethylene
dust)
Likely it is
combustible, but it
should be tested to
verify this. “Fred –
have you had this dust
tested?” Show me the
SDS. Show me the lab
data.
Document your
observations – dust
thickness, airborne
observations,
housekeeping
practices, engineering
controls.
231
232
AIHA ® Page 116

If lab test data

showed this was a
combustible dust, is
this compliant with
OSHA?
There is not a specific

OSHA combustible
dust standard . . . But
there are other
standard that cover
combustible dust
hazards, including the
General Duty Clause
[Section 5(a)(1)].
See:
https://www.osha.go
v/dsg/combustibledu
st/standards.html
233
If this is a
combustible dust, do
you think that this
condition is a
problem?
Why/why not?
234
AIHA ® Page 117

Respiratory Protection - CS
235
236
AIHA ® Page 118

237
238
AIHA ® Page 119

Respiratory Protection
• 1910.134(h)(4)(i} Repairs or adjustments to
respirators are to be made only by persons
appropriately trained to perform such operations and
shall use only the respirator manufacturer's NIOSH
approved parts designed for the respirator.
• 1910.134(h)(4)(ii} Repairs shall be made according to
the manufacturer's recommendations and
specifications for the type and extent of repairs to be
performed.
• 1910.134(1} Program evaluation. This section
requires the employer to conduct evaluations of the
workplace to ensure that the written respiratory
protection program is being properly implemented,
and to consult employees to ensure that they are
using the respirators properly.
239
Corrective Action
• Replace respirator with
fully functional respirator.
Ask:
• How are users trained?
• How is program
evaluation done?
• How could the program
capture and correct this
deficiency?
240
AIHA ® Page 120

241
Escape capsule (5-15 minute)
• Not included in respirator program or SOPs, not

maintained at full pressure, not clean, not
inspected every 30 days, not hydrostatically
tested, personnel not trained to use.
242
AIHA ® Page 121

Corrective Action:
• Ensure all devices are
fully incorporated into
the facility respiratory
protection program
243
Respiratory Protection Group Activity
244
AIHA ® Page 122

Respiratory Protection Group Activity

• Improper respirator storage
• 1910.134(h)(2), Storage
• The employer shall ensure that
respirators are stored as follows:
All respirators shall be stored to
protect them from damage,
contamination, dust, sunlight,
extreme temperatures, excessive
moisture, and damaging
chemicals, and they shall be
packed or stored to prevent
deformation of the face piece and
exhalation valve.
245
Lightning Round #3
246
AIHA ® Page 123

Group Hazards Compliance Breakout
In the next picture, you and

your group have 10 minutes to
identify as many “OSHA issues
and standards” as possible. You
are entering a large portable
paint spray booth…………………
247
248
AIHA ® Page 124

249
Lightning Round #3
Let’s Review
250
AIHA ® Page 125

251
252
AIHA ® Page 126

Hot Work
Is this Hot Work?
29 CFR 1910.252 – Welding, Cutting and Brazing
Refers to: Standard for Fire Prevention in Use of Cutting and Welding
Processes, NFPA Standard 51B, Welding, Cutting and Other Hot Work
Programs may expand on OSHA’s General Industry definition

Welding, brazing, cutting, soldering, thawing pipes, using heat guns, torch
applied roofing and chipping operations, or the use of spark-producing
power tools, such as drilling or grinding.
Insurance Company Requirements?? 253
Hot Work
• It’s not over even when it’s over.
– When the hot work ends, the fire watch must
continue for at least another 30 minutes.*
– OSHA 1910.252 (a) (III) (4) (8).
254
AIHA ® Page 127

WCB and Hot work
Group Exercise
• You have received a large pile of hot work permits from the
maintenance manager?
• How will you review them?
• What could be some audit findings that you could discover
during your review?
255
WCB and Hot work
• M issing dates and t i mes

• M issing signatures of the person auth orizing and
doing the work
• Pertinent boxes of precaut ions improperly checked
• No fi re watch
• No indication th at air monitoring for flammables
was done
• Talking to welders to fi nd out what they do
• No system to check permits and address corrective
action
256
AIHA ® Page 128

COMMONWEALTH OF
MASSACHUSETTS
•STATE-WIDE HOT
WORKS REG
• Massachusetts Comprehensive Fire Safety Code, 527 CMR 1.00.
Visit www.mass. gov/dfs and search for 527 CMR 1.
• These requirements are found in Chapter 41. This section adopts
NFPA 51B – Standard for Fire Prevention During Welding,
Cutting, and Other Hot Work (2014 Edition), which also includes
Massachusetts amendments
257
The PIT Hall of Shame - CS
258
AIHA ® Page 129

259
260
AIHA ® Page 130

PIT ACCIDENT AND SOME

RACKING ISSUES
https://youtu.be/EjOvI0TOx98
261
Contractor Safety -
TM
262
AIHA ® Page 131

Contractor Safety
Background Questions -
•What is a "Contractor" vs. a "Contract

Employees (a.k.a. “Temp Labor”)?
• What is the difference, and why is this

important?
• OSHA's " Multi-Employer Worksite Policy"
Special Emphasis Program – covers
responsibilities of multiple employers on a
worksite.
• Employment Test – “Day-to-day supervision”

and “Specifies not only outcomes, but the
means and methods to achieve the
outcomes”
263
Contractor Safety
For Contractors
• Four employers may be responsible. Let’s use a floor hole as an example:
"Creating Employer" - The employer who created the hole even if his
employees are not exposed to the hazard.
"Exposing Employer" - The employer whose employees worked near
the hole without fall protection, even though they didn't create the hole.
“Correcting Employer” A contractor that is responsible for correcting
hazards contractually, even hazards the contractor may not have created.
"Controlling Employer" – Usually the owner or GC, as they had the
implied or contractual obligation to provide safety oversight to the job
site.
• Multi-Employer Citation Policy (not a regulation) - CPL 02-00-124
• Some states and provinces have more descriptive policies or
regulations concerning the responsibilities of employers on multi-
employer worksites.
• Contract language and worksite practices are important.
264
AIHA ® Page 132

Contract Employee Safety

Contract Employees
• Are generally considered to be the controlling employer’s employees for

purposes of safety/health responsibility. Some aspects may be shared with an
agency, such as safety training.
• Employment test – Who supervises on a day-to-day basis? Does the
supervision specify the means and methods to achieve outcomes?
Fred has “Temps” – but he says that they have their own (agency employee)
supervisors.
What should we tell Fred?
265
EAP/ERP
266
AIHA ® Page 133

267
268
AIHA ® Page 134

Emergency Planning
Group Exercise:
Is every spill of a hazardous substance

classif ied as an emergency response per OSHA?
T or F
Break into you r teams t o discuss this for

about 5 m inutes and make not of key
issues. We w i ll then discuss as a group.
269
Emergency Planning
1910.38 - Notification and “Bug Out "
1910.120 (definit ions and section q) -

Incidental Release, Defensive, and Offensive
Approaches
OSHA Compliance Directive ''CPL 02-02-

073'' specif ically Appendix A
270
AIHA ® Page 135

Emergency Planning
An emergency response includes, but is not lim ited to, the
followi ng situations:
1.The response comes from outside the immediate release area.
2. The release requires evacuation of employees in the area.
3.The release poses, or has the potential to pose, conditions that are
immediately dangerous to life or health (IDLH).
4.The release poses a serious threat of fire or explosion (exceeds or has
the potential to exceed the lower explosive lim it or lower flammable lim it).
5. The release requires immediate attention because of imminent danger.
6. The release may cause h igh levels of exposure to toxic substances.
7.There is uncertainty about whether the employees in the work area can
handle the severity of the hazard w ith the PPE and equipment that has
been provided and the exposure lim it could easily be exceeded.
8. The s ituation is unclear, or data are lacking on important factors.
271
272
AIHA ® Page 136

Citation: Related to 19 10 .38

Corrective Action: Think about who may be onsite and how best t o evacuate in
the event of an emergency (t h ink of disabled persons, very
pregnant, etc.) 273
Crane and Hoist Safety : “OSHA- Approved”

System for Hedge Trimming - TM
274
AIHA ® Page 137

What’s going on here?
275
Crane and Hoist Safety

3000 LBS
2.5T
10K LBS
276
AIHA ® Page 138


3000 LBS
2.5T
10K LBS
• Load rating on travel beam is 3,000 lbs. the load is 5,000 lbs.
• Load is suspended over worker’s heads.
• Crane operator is not paying attention to his lift
277

3000 LBS
2.5
T
10K LBS
1926.1417(0)(1)
• The equipment must not be operated in excess of its rated capacity.
1926.1425(e)(2)
• Only employees essential to the operation are permitted in the fall zone (but not
directly under the load).
1926.1417(d)
• The operator must not engage in any practice or activity that diverts his/her
attention while actually engaged in operating the equipment, such as the use of
cellular phones (other than when used for signal communications).
278
AIHA ® Page 139


3000 LBS
2.5
T
10K LBS
Corrective Actions
• Determine if the operator is trained, and if the site has
communicated work rules concerning the use of cranes.
• Develop/implement crane safety training and assess site

management systems for enforcement of crane safety.
279

• What is the
issue/problem(s)?
• What is the
citation(s)?
• What about
corrective action(s)?
280
AIHA ® Page 140


• Using an excavator
to hoist a load
• Load shift could

crush workers in
excavation.
• Is an excavator a
crane?
281

29 USC 654, Section
S(A)(l) - General Duties of
Employers
Each employer
• (l)shall furnish to each of his
employees employment and a
place of employment which are
free from recognized hazards
that are causing or are like y to
cause death or serious physical
harm to his employees.
• Excavators are exempted from
the construction crane
standards in 1926.1400.
282
AIHA ® Page 141

Corrective Actions:
• Assess the job, and
determine best methods
for positioning tank in the
hole that does not involve
men being in the hole
when the tank is moved.
283

Construction
or General
Industry?
Both General Industry and Construction standards require pre-
use and regular inspections.
The m in imum requirements for crane inspections are found in

the standards applicable to GI/construction and to the
" service use" of the crane/hoist.
284
AIHA ® Page 142


No inspections -
General Industry - 1910.179
Construction - 1926.550, or other

specific to the type of crane.
From OSHA - "The owner must, however, maintain a record of inspections.

OSHA regulations only require that such equipment be inspected during initial
use and annually thereafter by a "competent person", or by a government or
private agency recognized by the DOL. The owner must, also, maintain a record
of these inspections."
There is wide latitude in the regulations as to the definition of a "competent

person." A competent person can be the equipment owner's maintenance
personnel or any other person the owner chooses, as long as that person is
deemed "competent."
285
Process Safety Management, EPA Risk

Management and OSHA Hazardous Materials -
CB
286
AIHA ® Page 143

PSM
• Does it apply to facility/plant operations?
• Came out in early 1990s
• Need to be in tune with operational changes, new
areas, new products
• Some parts of the standard are vaguely written;
courts even told OSHA this.
• Still running into businesses that think they are
exempt
• OSHA Special Emphasis Program
• Due Diligence Experience
• OSHA is looking to revise language (especially the
vessel maintained at atmospheric pressure
exemption)
• Be aware of State-specific requirements
(Massachusetts) and EPA RMP
287
EPA RMP RULE OF CAA

• The Risk Management Plan (RMP) Rule implements Section 112(r) of the 1990 Clean Air Act amendments.
• RMP requires facilities that use extremely hazardous substances to develop a Risk Management Plan.
– https://www.epa.gov/rmp/list-regulated-substances-under-risk-management-plan-rmp-program
• These plans must be revised and resubmitted to EPA every five years.
– Hazard assessment that details the potential effects of an accidental release, an accident history of
the last five years, and an evaluation of worst-case and alternative accidental releases scenarios;
– Prevention program that includes safety precautions and maintenance, monitoring, and employee
training measures; and
– Emergency response program that spells out emergency health care, employee training measures
and procedures for informing the public and response agencies (e.g., the fire department) should an
accident occur.
• Owners and operators of a facility (stationary source) that manufactures, uses, stores, or otherwise
handles more than a threshold quantity of a listed regulated substance in a process, must implement a risk
management program and submit a single RMP for all covered processes at the facility.
288
AIHA ® Page 144

Process Safety Management and OSHA

Hazardous Materials
• Ammonia
• “Ultra-Bad
Nasties”
• Flammables
289
Process Safety Management and OSHA Hazardous Materials
Fred’s Place…after he got our report
https://www.youtube.com/watch?v=NMofeKl4
hpY
290
AIHA ® Page 145

Process Safety Management and OSHA Hazardous

Materials – PEPCON, Nevada – mid 1980s
• Pre- PSM…………….
• 9 Million pounds of ammonium perchlorate in various storage containers
consumed…PSM Threshold Quantity is 7500 lbs.
• Plant and neighboring marshmallow manufacturing plant destroyed
• 2 fatalities 300 injured
• Last explosion registered 3.5 on the Richter scale….600 miles away in
Colorado!
• Crater left in the storage area was 15 feet deep and 200 feet wide
• Blast damage equivalent to 250 tons of TNT
• Damage estimate $74 million…$171 million settlement reached before
going to trial; approximately 17,000 claimants.
THE CAUSES?????
291
EHS BAR TRIVIA TIME - ELECTRICAL
PART OF THE NAME

OF THIS BAND
INCLUDES A TYPE OF
AEROSOL…WHAT IS
THE AEROSOL
292
AIHA ® Page 146

The Last Finding
293
Last Finding
Explosion proof
Intrinsically safe blender!
294
AIHA ® Page 147

Last Finding
Happy Hour!!!!
Have a great rest of the conference!
295
Closing Comments
• Thank you for coming

• We thank you for your participation.
• We learned a lot and hope you did do.
• We hope you enjoyed this "atypical"
PDC.
• If you have suggestions to make
this even better, please see any of us.
296
AIHA ® Page 148

Your Presenters’ Contact Information

Colden Corporation - www.colden.com
Corey Briggs, CIH, CET, FAIHA, AIHA Distinguished Lecturer
briggs@colden.com
Clint Smith, MS, CIH, CSP
smith@colden.com
Ramboll – www.ramboll.com
Tom Martin, CIH, CSP
tmartin@ramboll.com
Michael Holton, CIH, CSP
mholton@ramboll.com
297
AIHA ® Page 149

AIHA is bringing our professional development
courses (PDCs) to Chicago, IL!
This the ﬁrst of many regional AIHA University

Pop-Ups intended to provide additional
education opportunities for IH/OH professionals
nationwide.
Learn more at bit.ly/AIHAuniversity

MAY 31 - JUNE 3
ATLANTA, GA
www.AIHce2020.org

PDC 107 The Good, The Bad, and The Ugly - EHS at The Worst Plant

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Erin Breece, Program Director, Education, ebreece@aiha.org, 703-846-0749.

The Good, the Bad, and the Ugly – EHS at

Regulation & Legislation, Risk Assessment and Management, Safety Management

 Introductions of Instructors and Attendees

Upon completion, participants will be able to:

 Leverage their recognition skills for EHS compliance issues.

Corey Briggs, CIH, CET, FAIHA, Colden Corporation, Quincy, MA.

© American Industrial Hygiene Association

Your Facilitation Team

Rules of the Road

Introductions and Rules of the Road

Introductions and Rules of the Road

Introductions and Rules of the Road

1. Show me (I’m from Missouri!)

Letter of the law (Finding) vs. Best practice (BMP)

Agenda (Just a list...we mix it up)

Introductions and Rules of the Road

Mr. Fred Dontcare

Personal Protective Equipment - CB

Personal Protective Equipment - PPE

• Pressure dump valve inside

Subpart I (PPE) and 1910.120

PPE – Any Guesses?

Legal – What would

Any other (non-

• ANSI B65/NAPIM 177.2-2006 …minimally,

• OSHA Review Commission (OSHRC) - “OSHA must prove that a

Machine Guarding – It’s interlocked,

Are these guarded properly? – What to look for . . .(Risk Assessment)

Machine Guarding 101

Walking and Working Surfaces - MH

Walking and Working Surfaces

EHS BAR TRIVIA TIME – SLIPS

Name the band!

Walking and Working Surfaces

• Citation: 1910.22(a)(2) The floor of every workroom

Walking and Working Surfaces

Walking and Working Surfaces

Walking and Working Surfaces

Walking and Working Surfaces

Walking and Working Surfaces

Air Contaminants – Case Study

Air Contaminants – Case Study

The case of the cyclones that would not calibrate ..........................

Inspection, inspection, inspection….and bring spares!

Control of Hazardous Energy/LOTO - TM

What are the

What are the

• 1910.147( b) - Definitions - Energy isolating device. Mechanical

“The Exception to LOTO”

Jams are common events

This machine has modern,

“The Exception to LOTO”