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Training Requirements In OSHA Standards Why do we even have OSHA? 4,383 workers were killed on the job in 2012 – 3.2 per 100,000 full time workers.

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Presentation on theme: "Training Requirements In OSHA Standards Why do we even have OSHA? 4,383 workers were killed on the job in 2012 – 3.2 per 100,000 full time workers."— Presentation transcript:

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2 Training Requirements In OSHA Standards

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4 Why do we even have OSHA? 4,383 workers were killed on the job in 2012 – 3.2 per 100,000 full time workers – 84 per week – 12 deaths every day 40,961 Total Federal Inspections 51,133 Total State inspections Since 1970, workplace fatalities have been reduced by more than 65%

5 Top 10 Most Cited OSHA Standards Violations in FY13 1. Fall protection, construction (29 CFR ) [related OSHA Safety and Health Topics page]29 CFR related OSHA Safety and Health Topics page 2. Hazard communication standard, general industry (29 CFR ) [related OSHA Safety and Health Topics page]29 CFR related OSHA Safety and Health Topics page 3. Scaffolding, general requirements, construction (29 CFR ) [related OSHA Safety and Health Topics page]29 CFR related OSHA Safety and Health Topics page 4. Respiratory protection, general industry (29 CFR ) [related OSHA Safety and Health Topics page]29 CFR related OSHA Safety and Health Topics page 5. Electrical, wiring methods, components and equipment, general industry (29 CFR ) [related OSHA Safety and Health Topics page]29 CFR related OSHA Safety and Health Topics page 6. Powered industrial trucks, general industry (29 CFR ) [related OSHA Safety and Health Topics page]29 CFR related OSHA Safety and Health Topics page 7. Ladders, construction (29 CFR ) [related OSHA Safety and Health Topics page]29 CFR related OSHA Safety and Health Topics page 8. Control of hazardous energy (lockout/Tagout), general industry (29 CFR ) [related OSHA Safety and Health Topics page]29 CFR related OSHA Safety and Health Topics page 9. Electrical systems design, general requirements, general industry (29 CFR ) [related OSHA Safety and Health Topics page]29 CFR related OSHA Safety and Health Topics page 10.Machinery and Machine Guarding, general requirements (29 CFR ) [related OSHA Safety and Health Topics page29 CFR related OSHA Safety and Health Topics page

6 The 10 most common documents an OSHA inspector might ask to see…… 1. OSHA 300 Log 2. Lockout/Tagout Program 3. Process Safety Management 4. Emergency Action Plan 5. Respirator Program 6. Confined Space 7. Portable Fire Extinguishers 8. Hazard Communication 9.Hazard Assessment 10. Hearing Conservation

7 How many of you think that there are certain mandatory training requirements each year? How many think that there are not any mandatory training requirements but do conduct some kind of required training?

8 Different OSHA Standards 1903 Inspections, Citations AND Proposed Penalties 1904 Recording and Reporting Occupational Injuries and illness 1910 General Industrial 1926 Construction

9 Horizontal and Vertical Standards Some standards are horizontal meaning “general”, or “across the board” Horizontal standards could apply to any employer in any industry Examples of horizontal standard: – Hazard Communication Standard – Walking and Working Surfaces

10 Horizontal and Vertical Standards Vertical standards are specific only to a particular industry: – Pulp, paper, and paperboard mills ( ) – Textiles ( ) – Sawmills ( ) – Logging operations ( ) No Federal vertical standard for oil and gas well drilling or servicing

11 Voluntary Training Guidelines The Occupational Safety and Health Act of 1970: – “ does not address specifically the responsibility of the employers to provide health and safety information to employees”

12 ;although Section 5(a)(2) does require that each employer”……shall comply with occupational safety and health standards promulgated under this Act”

13 General Industry Training Requirements – Derricks (material handling)Derricks (material handling) – Helicopters (for material handling)Helicopters (for material handling) – Slings (material handling)Slings (material handling) – Mechanical Power PressesMechanical Power Presses – Forging MachinesForging Machines – – Welding, Cutting and BrazingWelding, Cutting and Brazing Pulp, Paper, and Paperboard MillsPulp, Paper, and Paperboard Mills – TextilesTextiles Laundry Machinery and OperationsLaundry Machinery and Operations – SawmillsSawmills Emergency Action PlansEmergency Action Plans Fire Prevention PlansFire Prevention Plans Powered Platforms for Building MaintenancePowered Platforms for Building Maintenance – Occupational Noise ExposureOccupational Noise Exposure – Flammable and Combustible LiquidsFlammable and Combustible Liquids Explosive and Blasting AgentsExplosive and Blasting Agents General Requirements for Dipping and Coating OperationsGeneral Requirements for Dipping and Coating Operations – Personal Protective EquipmentPersonal Protective Equipment – Respiratory ProtectionRespiratory Protection Temporary Labor CampsTemporary Labor Camps Specifications for Accident Prevention Signs and TagsSpecifications for Accident Prevention Signs and Tags – Permit Required Confined SpacesPermit Required Confined Spaces – The Control of Hazardous Energy (lockout-Tagout)The Control of Hazardous Energy (lockout-Tagout) Medical Services and First-AidMedical Services and First-Aid – – Fire Protection (includes portable fire extinguishers) Fire Protection (includes portable fire extinguishers) Servicing of Multi-Piece and Single- Piece Rim WheelsServicing of Multi-Piece and Single- Piece Rim Wheels – Powered Industrial Trucks (forklift operator training) Powered Industrial Trucks (forklift operator training) – Overhead and Gantry CranesOverhead and Gantry Cranes – Crawler, Locomotives and Truck CranesCrawler, Locomotives and Truck Cranes

14 General Industry Training Requirements, cont……… – Logging OperationsLogging Operations – TelecommunicationsTelecommunications Electric Power Generation, Transmission, and DistributionElectric Power Generation, Transmission, and Distribution – Grain Handling FacilitiesGrain Handling Facilities – – Electrical Safety Related Work PracticesElectrical Safety Related Work Practices – Commercial Diving OperationsCommercial Diving Operations – Toxic and Hazardous SubstancesToxic and Hazardous Substances – AsbestosAsbestos – – Thirteen CarcinogensThirteen Carcinogens – Vinyl ChlorideVinyl Chloride – Inorganic ArsenicInorganic Arsenic Access to Employee Exposure and Medical RecordsAccess to Employee Exposure and Medical Records – LeadLead Chromium (VI)Chromium (VI) – CadmiumCadmium – BenzeneBenzene Coke Oven EmissionsCoke Oven Emissions – Bloodborne PathogensBloodborne Pathogens – Cotton DustCotton Dust ,2-Dibromo-3-Chloropropane1,2-Dibromo-3-Chloropropane Acrylonitrile (Vinyl Cyanide)Acrylonitrile (Vinyl Cyanide) Ethylene OxideEthylene Oxide – FormaldehydeFormaldehyde – MethylenedianilineMethylenedianiline ,3-Butadiene1,3-Butadiene Methylene ChlorideMethylene Chloride – Ionizing RadiationIonizing Radiation – Hazard CommunicationHazard Communication Occupational Exposure to Hazardous Chemicals in LaboratoriesOccupational Exposure to Hazardous Chemicals in Laboratories ADMINISTRATIVE REQUIREMENTS Posting of Notice; Availability of the Act, Regulations and Applicable Standards Posting of Notice; Availability of the Act, Regulations and Applicable Standards Injury and Illness Recordkeeping Requirements - Employee InvolvementInjury and Illness Recordkeeping Requirements - Employee Involvement

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16 OSHA Guidelines A. Determining if Training is Needed B. Identifying Training Needs C. Identifying Goals and Objectives D. Developing Learning Activities E. Conducting the Training F. Evaluating Program Effectiveness G. Improving the Program

17 Is Training the Solution? Some experts believe that training should only be provided after all other performance issues have been addressed. As you evaluate the potential hazards during your worksite analysis, try to determine if any other issues could be contributing to the performance problem before choosing training as the solution.

18 Identifying If Training is Needed: Your worksite analysis, may help you discover additional areas where training will be beneficial. Accident investigation of a hand injury may show that the employee had not been properly trained in lockout / Tagout procedures. Self-inspection may show that employees were working in confined spaces without having received any training in this area. A JHA may show that employees are improperly lifting boxes because they have not been trained in proper lifting techniques.

19 Job Hazard Analysis “JHA” Not required by Federal OSHA – But, employers are required to take necessary steps to ensure safety (d) (2): The employer shall verify that the required workplace hazard assessment has been performed through a written certification that identifies the workplace evaluated; the person certifying that the evaluation has been performed; the date(s) of the hazard assessment; and, which identifies the document as a certification of hazard assessment. – Some state may require/accept it as part of an I2P2, IIPP or similar “safety program” requirement

20 Breaking Down the Term “JHA” Job = tasks (changing a light bulb, chocking a trailer, grinding a part) Hazard = caught-in, struck-by, chemical, ergonomic … anything that can cause harm Analysis = Talking with operators, watching job being performed, breaking down into steps, identifying hazards, implementing controls

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22 Risk Management is Managing Risk What is the tolerance for risk ? – Accept low risk Cost of risk low Consequences of risk low Duration of the risk – Can not accept risk Frequency is high Consequences high Costs are high

23 Direct Costs of Injuries and Illnesses Direct costs of the most disabling workplace injuries in the U.S. averaged $47.6 billion per year between 1998 and 2008

24 Consequences LikelihoodSevere (1) Major (2) Medium (3) Minor (4) Negligible (5) Almost certain (A) EHHMM Likely (B) HHMML Possible (C) HMMLL Unlikely (D) MMLLT Rare (E) MLLTT

25 Extreme Risk – Immediate action required; this level of risk need detailed research and planning by senior management. High Risk – Action plan is required as soon as practicable by senior management Moderate risk – Action plan is required by Area/Department Manager Low risk – Managed by routine procedures and employees under supervision Trivial risk – Unlikely to need specific application of resources

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28 Some Industries Horizontal Standards Requirements for Every Business Basic Safety Training Personal Protective Equipment Emergency Action Plan Fire Prevention Hazard Communication Exit Routes Walking/Working Surfaces Medical and First Aid Injury/Illness Reporting Bloodborne Pathogens Additional Requirements for High Risk, Construction, and Manufacturing Machine Guarding Lockout/Tagout Electrical Hazards Respirators Noise Protection Confined Spaces

29 IF TRAINING IS DONE………… Initial training is required before you start your job. Annual training is training that occurs every year for certain occupations including medical and environmental occupations. Special incremental training is training that occurs every other year or every three years, and potential hazard training is required when companies identify new hazards.

30 IF TRAINING IS DONE………… It must use both a language and vocabulary that the employee can understand. Requirements related to employee comprehension

31 Identifying Training Requirements Some standards might require different levels of training, depending on the worker's level of exposure to the hazard. Employees who actually perform the work would need extensive training; other employees may just need to know that the hazard exists Multiple levels of training may be explicitly stated.

32 Training Requirements? OSHA explicitly require the employer to train employees in the safety and health aspects of their jobs. Others limit certain job assignments to employees who are “certified”, “competent” or “qualified”

33 Terminology Certified Certified A “Certified” person is authoritatively or officially attested or confirmed as being genuine or true as represented, or as complying or meeting specified requirements or standards. It may or may not mean as being accompanied by a certificate. Competent The term “competent person” is used in many Occupational Safety and Health Administration (OSHA) standards and documents. An OSHA “competent person” is defined as “one who is capable of identifying existing and predictable hazards in the surroundings or working conditions which are unsanitary, hazardous, or dangerous to employees, and who has authorization to take prompt corrective measures to eliminate them”. Qualified Qualified A qualified person is one who, by possession of a recognized degree, certificate, or professional standing, or who by extensive knowledge, training and experience, has successfully demonstrated his ability to solve or resolve problems relating to the subject matter, the work, or the project.

34 Designated Person The term “designated” personnel means employees selected or assigned by the employer or the employer’s representative as being qualified to perform specific duties. Terminology Continued…… The Lockout/Tagout standard distinguishes between "authorized employee training", "affected employee training" and "all other employee training". Authorized employee training is for workers who perform maintenance on equipment. Affected employee training is for workers whose job may require regular use of the equipment but not involve maintenance or repair on it. All other employee training is for workers whose work operations are or may be in an area where lockout/Tagout is utilized

35 Is Training the Solution? Training is an appropriate solution to performance problems when there is a deficiency of knowledge or skills. Suppose your company experiences safety performance problems such as employees working with guards removed from machinery or not wearing the proper personal protective equipment (PPE). Company pressure to work too quickly or improper sizing of PPE may be the underlying causes of these behaviors, not lack of knowledge.

36 Document, Document, Document… Document all training for proof of training. – Although not required by standard, must prove that the worker understands the training Records need to be kept for at least one year to show current training. OSHA Logs Form 300 must be kept for five years following the year to which they pertain.

37 Can You Name the For Basic Areas That OSHA requires Witten Documentation? 1. Safety Program 2. Documenting of Hazard Assessment 3. Maintaining of Training Records 4. Certification of Training Given to Employees

38 Conditions must be met for OSHA to issue: – The hazard was recognized – The employer failed to keep the workplace free of hazard to which his or her employees were exposed – A feasible and useful method was available to correct the hazard – The hazard was causing or likely to cause death or serious injury. GENERAL DUTY CLAUSE

39 Summary Training is voluntary and OSHA does not intend to make the guidelines mandatory – OSHA encourages a personalized approach to the informational and instructional programs at individual worksites, thereby enabling employers to provide the training that is most needed and applicable to local worksites Must Determine if training is needed and Identifying what training pertains to them

40 Summary Cont…………… The adequacy of employee training may also become an issue in contested cases where the affirmative defense of unpreventable employee misconduct is raised. Documentation is key to proof of training and its effectiveness If not a defined OSHA hazard it can still fall under the General Duty Clause Not the end….but the beginning of SAFETY

41 Questions?

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