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Training Series - PPE: Respiratory Protection

12/16/2018

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OSHA Standard: 1910.134

Training Frequency: Upon initial assignment (before mask is worn), and annually.

Training Style: Hands-on

When is Respiratory Protection Required? - In any workplace where respirators are necessary to protect the health of the employee or whenever respirators are required by the employer

Background: Respiratory Protection Program:
Respiratory protection program requires the employer to develop and implement a written respiratory protection program with required worksite-specific procedures and elements for required respirator use. The program must be administered by a suitably trained program administrator. In addition, certain program elements may be required for voluntary use to prevent potential hazards associated with the use of the respirator.
The program shall be updated as necessary to reflect those changes in workplace conditions that affect respirator use. The employer shall include in the program the following provisions:
  • Training of employees in the respiratory hazards to which they are potentially exposed during routine and emergency situations;
  • Training of employees in the proper use of respirators, including putting on and removing them, any limitations on their use, and their maintenance;
A program administrator must be established. This individual must be qualified by appropriate training or experience that is commensurate with the complexity of the program to administer or oversee the respiratory protection program and conduct the required evaluations of program effectiveness.

The employer shall provide respirators, training, and medical evaluations at no cost to the employee.

​Training Information:
The training must be comprehensive, understandable, and recur annually, and more often if necessary. The employer shall ensure that each employee can demonstrate knowledge of at least the following:
  • Why the respirator is necessary and how improper fit, usage, or maintenance can compromise the protective effect of the respirator;
  • What the limitations and capabilities of the respirator are;
  • How to use the respirator effectively in emergency situations, including situations in which the respirator malfunctions;
  • How to inspect, put on and remove, use, and check the seals of the respirator;
  • What the procedures are for maintenance and storage of the respirator;
  • How to recognize medical signs and symptoms that may limit or prevent the effective use of respirators;

Retraining:
Retraining shall be administered annually, and when the following situations occur:
  • Changes in the workplace or the type of respirator render previous training obsolete;
  • Inadequacies in the employee’s knowledge or use of the respirator indicate that the employee has not retained the requisite understanding or skill; or
  • Any other situation arises in which retraining appears necessary to ensure safe respirator use. 
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Training Series - PPE: Eye & Face Protection

12/12/2018

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OSHA Standard: 1926.102
Training: Initially Upon assignment and as conditions or equipment changes
 
The employer shall train each affected employee:
  • Uses appropriate eye or face protection when exposed to eye or face hazards from flying particles, molten metal, liquid chemicals, acids or caustic liquids, chemical gases or vapors, or potentially injurious light radiation.
  • Uses eye protection that provides side protection when there is a hazard from flying objects. Detachable side protectors (e.g. clip-on or slide-on side shields) meeting the pertinent requirements of this section are acceptable.
  • Who wears prescription lenses while engaged in operations that involve eye hazards wears eye protection that incorporates the prescription in its design, or wears eye protection that can be worn over the prescription lenses without disturbing the proper position of the prescription lenses or the protective lenses.

Protectors shall meet the following minimum requirements:
  • Eye and face PPE shall be distinctly marked to facilitate identification of the manufacturer.
  • They shall provide adequate protection against the particular hazards for which they are designed.
  • They shall be reasonably comfortable when worn under the designated conditions.
  • They shall fit snugly and shall not unduly interfere with the movements of the wearer.
  • They shall be durable.
  • They shall be capable of being disinfected.
  • They shall be easily cleanable.

Eye and face protection equipment required by this Part shall meet the requirements specified in American National Standards Institute, Z87.1-1968, Practice for Occupational and Educational Eye and Face Protection.

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Process Safety Management of Highly Hazardous Chemicals

11/27/2018

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OSHA Standard: 1926.64

Training Requirement: Initial training is required for each employee involved in operating a process of highly hazardous chemicals BEFORE being involved in that operation. Refresher training shall be provided at least every three years, and more often if necessary.

Training Documentation: The employer shall prepare a record which contains the identity of the employee, the date of training, and the means used to verify that the employee understood the training.

Training: All employees, including maintenance and contractor employees, involved with highly hazardous chemicals need to fully understand the safety and health hazards of the chemicals and processes they work with for the protection of themselves and others. The operating procedures are often viewed as the standard operating practices (SOPs) for operations. Control room personnel and operating staff, in general, need to have a full understanding of operating procedures.

Training in subjects such as operating procedures and safety work practices, emergency evacuation and response, safety procedures, routine and nonroutine work authorization activities, and other areas pertinent to process safety and health will need to be covered by an employer’s training program. Because of this this, hands-on-training is strongly encouraged to be used.

Training evaluations are strongly encouraged. If, after the evaluation, it appears that the trained employees are not at the level of knowledge and skill that was expected, the employer will need to revise the training program, provide retraining, or provide more frequent refresher training sessions until the deficiency is resolved.

Audits: Employers need to select a trained individual or assemble a trained team of people to audit the process safety management system and program. The audit is to include an evaluation of the design and effectiveness of the process safety management system and a field inspection of the safety and health conditions and practices to verify that the employer’s systems are effectively implemented.

Evaluate: Employers need to periodically evaluate their training programs to see if the necessary skills, knowledge, and routines are being properly understood and implemented by their trained employees.
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Training Series Part XI: Methylenedianiline (MDA)

7/24/2018

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Subpart: D – Occupational Health and Environmental Controls

OSHA Standard: 1926.60

Occurrence: Upon initial assignment

Frequency: ANNUALLY or as conditions or roles change

Training Style: Hands on training (PPE), toolbox talk, classroom instruction.

Background:
MDA, a suspected human carcinogen, is a white to tan solid (amine odor) liquid. Uses for MDA include enhancement of thermal stability in polyamides, fatigue resistance and dye ability in fibers, and the preparation of impact resistant resins, polyimides with superior wire coating properties, benzimidazolethiols (antioxidants), hydraulic fluids, urethane foams, fungicide stabilizers, and sensitizers for explosives. Route of exposure: Inhalation; skin absorption; ingestion. MDA can be inhaled, absorbed through the skin, or ingested. Exposure can lead to dermatitis, abdominal pain, fever, chills, liver damage, and bladder cancer.

Permissible Exposure: 10 parts per billion (ppb) over an 8-hour time weighted average. Eye and skin contact are not permitted

Employer Responsibilities:
In addition to the information required under 29 CFR 1910.1200 (HAZCOM standard), the employer shall: Discuss PEL and where the possible exposure could occur, signs and symptoms of exposure, appearance health hazard associated with MDA, hazard controls implemented (engineering, administrative, and PPE), proper handling and storage, and treatment.

Employers are required to perform measurements that are representative of your exposure to MDA and you or your designated representative are entitled to observe the monitoring procedure.
​
Access to training materials: The employer shall make readily available to all affected employees, without cost, all written materials relating to the employee training program, including a copy of this regulation.  The employer shall provide to the Assistant Secretary and the Director, upon request, all information and training materials relating to the employee information and training program. Training records shall be maintained for one (1) year beyond the last date of employment for all employees.
 
Employee Responsibilities:
Employees have the responsibility to ensure stay within their roles. If assigned to work with MDA to ensure they are properly trained and follow identified work practices to limit exposure. Workers are entitled to observe the steps taken in the measurement procedure and to record the results obtained. Employees or their representative are entitled to see the records of measurements of your exposure to MDA upon written request to your employer. Employee medical examination records can be furnished to your physician or designated representative upon request by you to your employer.
 
Contact STAC for assistance if you have any questions!
cbengel@staccard.com

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Training Series Part X: Hazard Communication

6/26/2018

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Subpart: D – Occupational Health and Environmental Controls

OSHA Standard: 1926.59/1910.1200

Occurrence: Initially upon assignment.

Frequency: As chemicals, conditions or roles change.

Training Style: Hands on training, toolbox talk, classroom instruction.

Background:
The purpose of this section is to ensure that the hazards of all chemicals produced or imported are classified, and that information concerning the classified hazards is transmitted to employers and employees. This standard is to be consistent with the provisions of the United Nations Globally Harmonized System of Classification and Labelling of Chemicals (GHS), Revision 3. The transmittal of information is to be accomplished by means of comprehensive hazard communication programs, which are to include container labeling and other forms of warning, safety data sheets and employee training.

Employer Responsibilities:
Employers are required to 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 chemical hazard the employees have not previously been trained about is introduced into their work area.
Employees shall be informed of:
  1. The HAZCOM OSHA standards;
  2. Any operations in their work area where hazardous chemicals are present and the nature/category of that hazard; and,
  3. The location and availability of the written hazard communication program, including the required list(s) of hazardous chemicals, and safety data sheets.

Employee training shall include at least:
  1. Methods and observations that may be used to detect the presence or release of a hazardous chemical in the work area (such as monitoring conducted by the employer, continuous monitoring devices, visual appearance or odor of hazardous chemicals when being released, etc.);
  2. The physical, health, simple asphyxiation, combustible dust, and pyrophoric gas hazards, as well as hazards not otherwise classified, of the chemicals in the work area;
  3. The measures employees can take to protect themselves from these hazards, including specific procedures the employer has implemented to protect employees from exposure to hazardous chemicals, such as appropriate work practices, emergency procedures, and personal protective equipment to be used; and,
  4. The details of the hazard communication program developed by the employer, including an explanation of the labels received on shipped containers and the workplace labeling system used by their employer and the material safety data sheet, including the order of information and how employees can obtain and use the appropriate hazard information.

​Employee Responsibilities:

Employees are expected to take an active role with the training and ask questions as they arise. They are also expected to ensure that they do not perform task that they have not been trained or is outside there scope of work.
Contact STAC for assistance if you have any questions!
cbengel@staccard.com

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Training Series Part VIII: Gases, Vapors, Fumes, Dusts, and Mists

5/30/2018

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Subpart: D – Occupational Health and Environmental Controls

OSHA Standard: 1926.55

Occurrence: Upon initial assignment.

Frequency: As equipment, conditions, or roles change.

Training Style: Classroom, or hands-on, or toolbox talk.

Background:
Exposure of employees to inhalation, ingestion, skin absorption, or contact with any material or substance at a concentration above those specified in the Threshold Limit Values (TLV) of Airborne Contaminants for 1970 of the American Conference of Governmental Industrial Hygienists, shall be avoided. See Appendix A of 1926.55 for TLV values for each substance. Substances not covered in this standard (as they are covered in other standards) include airborne asbestos, tremolite, anthophyllite, or actinolite dust, and formaldehyde.
​
Employer Responsibilities:
Ensure employees stay under the TLV through administrative or engineering control first whenever feasible. When such controls are not feasible to achieve full compliance, protective equipment or other protective measures shall be used to keep the exposure of employees to air contaminants within the limits prescribed in Appendix A. Any equipment and technical measures used for this purpose must first be approved for each use by a competent industrial hygienist or other technically qualified person. Whenever respirators are used, their use shall comply with applicable OSHA standards.

Employee Responsibilities:
Ensure you are trained and understand the controls for the substance that you are working with. That includes understanding the engineering and administrative controls as well as the proper selection and maintenance of any assigned PPE.
 
Contact STAC for assistance if you have any questions!
cbengel@staccard.com

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Training Series Part VII: Non-ionizing Radiation (NIR)

5/21/2018

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Subpart: D – Occupational Health and Environmental Controls

OSHA Standard: 1926.54

Occurrence: Initially upon assignment.

Frequency: As equipment, conditions, or roles change.

Training Style: Hands on training, toolbox talk, classroom instruction.

Background:
Non-ionizing radiation is described as a series of energy waves composed of oscillating electric and magnetic fields traveling at the speed of light. Non-ionizing radiation includes the spectrum of ultraviolet (UV), visible light, infrared (IR), microwave (MW), radio frequency (RF), and extremely low frequency (ELF). Lasers commonly operate in the UV, visible, and IR frequencies. Non-ionizing radiation is found in a wide range of occupational settings and can pose a considerable health risk to potentially exposed workers if not properly controlled. Level 1 type lasers are included with this standard, that includes survey equipment. Construction limits worker exposure to 10 mW/sq.cm.

Employer Responsibilities:
The employer shall provide for the instruction of each laser equipment operator and instructor in accordance with the applicable manufacturer's recommendations. The instruction process shall inform the operator of various hazards associated with the use of the equipment and the necessary or recommended control measures for the elimination of hazards to personnel. Areas in which lasers are used shall be posted with standard laser warning placards. In addition to information from the manufacturer, the American National Standard ANSI Z136.1-1986 could be reviewed for training information.

Employee Responsibilities:
Take part in training is assigned any type of NIR equipment. Ensure that the laser beam is not directed at employees. When it is raining or snowing, or when there is dust or fog in the air, the operation of laser systems shall be prohibited where practicable; in any event, employees shall be kept out of range of the area of source and target during such weather conditions.

Summary:
NIR is a series of energy waves composed of oscillating electric and magnetic fields at the speed of light. The most common example of NIR on the jobsite is survey equipment. Only qualified and trained employees shall be assigned to install, adjust, and operate laser equipment. Proof of qualification of the laser equipment operator shall be available and in possession of the operator at all times.
 
Contact STAC for assistance if you have any questions!
cbengel@staccard.com

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Training Series Part VI: Ionizing Radiation

5/14/2018

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Subpart: D – Occupational Health & Environmental Controls

OSHA Standard: 1926.53

Occurrence: When using radioactive or x-rays in the workplace.

Frequency: Initial assignment and as conditions or roles change.

Training Style: If under the Nuclear Regulatory Commission (NRC): Competent and Licensed. If not under the NRC: competent person training.

Background:
Ionizing radiation is one of the two categories of radiation. Ionizing radiation can be found anywhere in the natural environment. It comes from space, from the sun, and from naturally occurring radioactive elements in the earth (radon is one example). One example of radioactive elements in the earth is Radon. Radon can accumulate in poorly ventilated areas such as crawlspaces, basements, mines, and tunnels. Ionizing radiation can also come from manmade sources such as nuclear power plants and x-ray machines. The main sources of ionizing radiation are x-rays, gamma rays, alpha particles, beta particles, and neutrons.

Employer Responsibilities:
Any activity which involves the use of radioactive materials or X-rays, whether or not under license from the NRC, shall be performed by competent persons specially trained in the proper and safe operation of such equipment. In the case of materials used under Commission license, only persons actually licensed, or competent persons under direction and supervision of the licensee, shall perform such work.  
​
Employee Responsibilities:
Ensure that they are complying with the competent training if working with ionizing radiation. Ensure they have the equipment in proper repair if doing background sampling.
 
Contact STAC for assistance if you have any questions!
cbengel@staccard.com

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Training Series Part V: Occupational Noise Exposure

5/2/2018

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Subpart: D/G – Occupational Health & Environmental Control

OSHA Standard: 1926.52/1910.95

Occurrence: Initially when hazard exist - noise level exceeds decibels (dBA) over an 8-hour time weighted average (TWA).

Frequency: Annually for each employee included in the hearing conservation program

Training Style: Classroom, hands-on, tool box talk (refresher).

Employer Responsibilities:
The employer shall provide training in the use and care of all hearing protectors provided to employees. The Training program is made up of three components:
(1) The employer shall institute a training program for all employees who are exposed to noise at or above an 8-hour time weighted average of 85 decibels, and shall ensure employee participation in such program.
(2) The training program shall be repeated annually for each employee included in the hearing conservation program. Information provided in the training program shall be updated to be consistent with changes in protective equipment and work processes.
(3) The employer shall ensure that each employee is informed of the following:
(i) The effects of noise on hearing;
(ii) The purpose of hearing protectors, the advantages, disadvantages, and attenuation of various types, and instructions on selection, fitting, use, and care; and
(iii) The purpose of audiometric testing, and an explanation of the test procedures.
The next piece of this standard relates to access to information and training materials:
(1) The employer shall make available to affected employees or their representatives copies of this standard and shall also post a copy in the workplace.
(2) The employer shall provide to affected employees any informational materials pertaining to the standard that are supplied to the employer by the Assistant Secretary.
(3) The employer shall provide, upon request, all materials related to the employer’s training and education program pertaining to this standard to the Assistant Secretary and the Director.

Employee Responsibilities:
Take an active role in the training for occupational noise exposure. Follow the company guidelines for training and proper selection of PPE based upon the hazard.
​
Summary:
This standard raises the question, when is the last time that you reviewed your occupational noise exposure policy, or have done testing? Do you hold refresher training annually? And how do you track that training? This is one of the few standards that does require refresher training annually. Another question that comes up is the use of headphones in the workplace. In a 1987 letter of interpretation that dealt with the use of walkman radio, tape or CD players and their effect when hearing protection is in use. Special ear muffs equipped with volume-limited music for use in monotonous high noise jobs to protect employee hearing but at the same time allowing them to enjoy background music is in compliance as long as their average music output is less than 90 dBA. However, use of any listening device over required ear protection is a violation.

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Training Series Part IV: Medical Services & First Aid

4/26/2018

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Subpart: D – Occupational Health & Environmental Controls

OSHA Standard: 1926.50

Occurrence: In the absence of accessible medical facility, medical & first aid training is required.

Frequency: Every 2 years – First Aid/CPR. Annually for Bloodborne Pathogens (BBP)

Training Style: Classroom & Hands On. Tool box talk - BBP

Employer Responsibilities:
In the absence of an infirmary, clinic, hospital, or physician, that is reasonably accessible in terms of time and distance to the worksite. OSHA has determined that emergency care must be available within no more than 3-4 minutes from the workplace.  The employer must ensure that adequate first aid is available in the critical minutes between the occurrence of an injury and the availability of physician or hospital care for the injured employee. Therefore, if medical facility is more than 3-4 minutes from a jobsite, at least one person must have a valid certificate in first-aid training from the U.S. Bureau of Mines, the American Red Cross, or equivalent training that can be verified by documentary evidence, shall be available at the worksite to render first aid. First aid supplies shall be easily accessible and the contents of the first aid kit shall be placed in a weatherproof container with individual sealed packages for each type of item and shall be checked by the employer before being sent out on each job and at least weekly on each job to ensure that the expended items are replaced. Note, there are no OSHA construction standards that specifically require an employer to provide an AED at a construction site currently.
The bloodborne pathogens standard at 29 CFR 1910.1030(g)(2) requires employers to provide training to any employees who have occupational exposure to blood or other potentially infectious materials, such as employees assigned medical or first aid duties by their employers. The standard at 29 CFR 1910.1030(b) defines "occupational exposure" as "reasonably anticipated skin, eye, mucous membrane, or parenteral contact with blood or other potentially infectious materials that may result from the performance of an employee's duties." 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.

Employee Responsibilities:
Take seriously First Aid/CPR training as they could be responsible to provide crucial life saving measures in the event of an injury.

Summary:
Basically, at least one person on every work site needs to have First-Aid/CPR training, at is it required to be available within 3-4 minutes. This training needs to be done every 2 years. Bloodborne pathogens training needs to be performed annually. This could be accomplished through a toolbox talk.

Contact STAC for assistance if you have any questions!
cbengel@staccard.com

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