 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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 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  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:
Employee training shall include at least:
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  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  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   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  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.  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 OSHA Standard: 1926.21 Occurrence: Initial assignment Frequency: As jobsite conditions or roles change Training Style: Varies, but could include classroom training, toolbox talks, and hands-on training. Employer Responsibilities: 1) The employer should create training programs and have them available for OSHA and employees to review. 2) The employer shall instruct each employee in the recognition and avoidance of unsafe conditions and the regulations applicable to his work environment to control or eliminate any hazards or other exposure to illness or injury. 3) Employees required to handle or use poisons, caustics, and other harmful substances shall be instructed regarding the safe handling and use, and be made aware of the potential hazards, personal hygiene, and personal protective measures required. 4) In job site areas where harmful plants or animals are present, employees who may be exposed shall be instructed regarding the potential hazards, and how to avoid injury, and the first aid procedures to be used in the event of injury. 5) Employees required to handle or use flammable liquids, gases, or toxic materials shall be instructed in the safe handling and use of these materials and made aware of the specific requirements. 6) All employees required to enter into confined or enclosed spaces shall be instructed as to the nature of the hazards involved, the necessary precautions to be taken, and in the use of protective and emergency equipment required. The employer shall comply with any specific regulations that apply to work in dangerous or potentially dangerous areas Employee Responsibilities: Employees are to ensure they have been trained in their assigned roles. If roles change, they must ensure that they are trained and competent in the new roles. And, they must request information if they are unsure of the hazard or what protective system they need to employ. Summary: This is a pretty short and sweet standard but has wide reaching effects. It is the employers responsibility to perform a hazard analysis of each task and of the jobsite and determine what training and controls are necessary. So, do you have a program in place for working with caustic and flammable liquids? And do you have a policy for working around harmful plants and animals? And how do you track employee competency of the task? Contact STAC for assistance if you have any questions! cbengel@staccard.com   OSHA Standard: 1926.20 – Accident Prevention Responsibilities
Occurrence/Frequency: FREQUENT and REGULAR inspections of the job site, materials, and equipment to be made by COMPETENT person. Style of Program: Written program that is initiated and maintained. Location: N/A Employer Responsibilities: This standard has several employer requirements for job site inspections:
Employee Responsibilities:
Summary: This is the standard that is regularly cited under OSHA, mainly for failure to perform frequent and regular jobsite inspections. The core principle of this standard is training hazard identification, authorization, and qualification. This standard also brings up the topic of equipment training. Unlike the power industrial truck, earth moving equipment does not have a direct standard. However, this is the standard that OSHA uses to cite companies that do not properly train their employees. One way to verify if you employees have been trained is to use to STAC system to run reports on what current training your employees have. |
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