1. 1 April 11, 2003

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3. 3 VOSHA AND YOUR SCHOOL AN OVERVIEW OF YOUR REGULATORY OBLIGATIONS

4. 4 OUTLINE OVERVIEW OF VOSHA: GENERAL DUTY CLAUSE COMPLIANCE AND CONSULTATION CITATIONS AND PENALTIES REGULATIONS

5. 5 JURISDICTION IN GENERAL, VOSHA REGULATIONS COVER ALL EMPLOYERS WITH EMPLOYEES IN VERMONT INCLUDING K-12 SCHOOLS

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7. 7 EMPLOYERS OBLIGATIONS CFR 29 Section 1910 General Duty Clause – OSH Act, Section 5 (a) Each Employer- (1) Shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees; (2) Shall comply with occupational safety and health standards promulgated under this Act. (b) Each employee shall comply with occupational safety and health standards and rules, regulations and orders issued pursuant to this Act which are applicable to his own actions and conduct. Construction Projects

8. 8 VOSHA’S DUAL ROLES COMPLIANCE (INSPECTORS ARE AUTHORIZED TO ISSUE CITATIONS AND FINES), OVER 100 REGULATIONS CONSULTATION (SAFETY AND HEALTH CONSULTANTS, PROJECT WORK SAFE)

9. 9 VOSHA INSPECTIONS CAN BE PROGRAMMED OR UNPROGRAMMED 1. COMPLAINT 2. REFERRAL 3. PLANNED 4. RELATED COMPREHENSIVE OR PARTIAL THEY CAN INSPECT ALL SCHOOLS IN A DISTRICT

10. 10 CITATIONS AND PENALTIES FAILURE TO FOLLOW REGULATIONS RESULTS IN ADMINISTRATIVE CITATIONS PENALTIES ($$$$.$$) ASSESSED BASED ON THE NATURE OF THE VIOLATION (SERIOUS, WILLFUL, ETC.) AND SIZE OF EMPLOYER

11. 11 CONTESTING CITATIONS & PENALTIES INFORMAL CONFERENCE CONTEST PHASE (FORMAL V. SIMPLIFIED PROCEEDINGS) APPEALS

12. 12 SELF-INSPECTION CHECKLIST SAFETY AND HEALTH PROGRAM PERSONAL PROTECTIVE EQUIPMENT $ COMBUSTIBLE MATERIALS POWER TOOLS LOGOUT/TAG OUT CONFINED SPACE $ ELECTRICAL WALKING/WORKING/SLIP & FALL SURFACES

13. 13 HAZARDOUS COMMUNICATION $ ASBESTOS $ LEAD BLOODBORNE PATHOGENS CHEMICAL HYGIENE PLAN FOR LABORATORIES $ RESPIRATORY PROTECTION $ MACHINE GUARDING GENERAL DUTY CLAUSE $

14. 14 HAZARD COMMUNICATION (HAZCOM) 29 CFR 1910.1200 REQUIRES INFORMATION ABOUT PHYSICAL AND HEALTH HAZARDS BE MADE AVAILABLE TO EMPLOYEES, INCLUDING RECOMMENDATIONS FOR SAFE USE. REQUIRES A WRITTEN HAZCOM PROGRAM -HAZARD EVALUATION -TRAINING -MSDS -LABELING

15. 15 RESPIRATORY PROTECTION CFR 1901.134 SCHOOL MUST DEVELOP AND IMPLEMENT A SITE- SPECIFIC WRITTEN PROGRAM IF RESPIRATORY PROTECTION IS REQUIRED -TRAINING -FIT TESTING -MEDICAL EVALUATIONS -EXPOSURE MONITORING MEDICAL EVALUATIONS ARE REQUIRED RECORD KEEPING EMPLOYEES CAN REQUEST RESPIRATORY PROTECTION

16. 16 BLOODBORNE PATHOGENS 29 CFR 1910.1030 SCHOOL MUST DETERMINE POTENTIAL FOR BLOODBORNE PATHOGEN EXPOSURE IF THE POTENTIAL EXIST, A WRITTEN EXPOSURE CONTROL PLAN MUST BE DEVELOPED -TRAINING -LABELING -HANDLING PROCEDURES

17. 17 CONFINED SPACE 29 CFR 1910.146 SCHOOL MUST CONDUCT A THOROUGH EVALUATION TO IDENTIFY SPACES REQUIRING PERMITS ( 1) Is large enough and so configured that an employee can bodily enter and perform assigned work; and (2) Has limited or restricted means for entry or exit (for example, tanks, vessels, silos, storage bins, hoppers, vaults, and pits are spaces that may have limited means of entry.); and (3) Is not designed for continuous employee occupancy. A WRITTEN PROGRAM IS REQUIRED IF EMPLOYEES WILL ENTER “PERMIT REQUIRED” SPACES -TRAINING, INITIAL AND REFRESHER -EQUIPMENT MAY BE REQUIRED

18. 18 HAZARDOUS ENERGY CONTROL 29 CFR 1910.147 “LOG OUT TAG OUT” This standard covers the servicing and maintenance of machines and equipment in which the unexpected energization or start up of the machines or equipment, or release of stored energy could cause injury to employees. This standard establishes minimum performance requirements for the control of such hazardous energy. WRITTEN PROCEDURES REQUIRED FOR: SHUTTING DOWN, ISOLATING, BLOCKING AND SECURING EQUIPMENT TO CONTROL RELEASES OF HAZARDOUS ENERGY –TRAINING –EQUIPMENT

19. 19 LABORATORY STANDARD 29 CFR 1910.1450 REQUIRES SCHOOL TO DEVELOP A WRITTEN CHEMICAL HYGIENE PLAN COVERS LABORATORIES THAT USE CHEMICALS ASSIGNS A CHEMICAL HYGIENE OFFICER TRAINING ASSIGNED RESPONSIBILITIES

20. 20 EMERGENCY ACTION PLAN & FIRE PROTECTION PLAN 29 CFR 1910.38 SCHOOLS MUST HAVE A WRITTEN PLAN THAT COVERS THE DESIGNATED ACTIONS EMPLOYERS AND EMPLOYEES MUST TAKE TO ENSURE EMPLOYEES SAFETY FROM FIRES AND OTHER EMERGENCIES

21. 21 LEAD 29 CFR 1910.1025 WRITTEN PROGRAM REQUIRED -EXPOSURE MONITORING -TRAINING, INITIAL AND ANNUAL -RESPIRATORY PROTECTION -PROTECTIVE CLOTHING AND EQUIPMENT -MEDICAL SURVEILLANCE -RECORD KEEPING (40 YEARS OR DURATION OF EMPLOYMENT PLUS 20 YEARS)

22. 22 ASBESTOS 29 CFR 1910.100 & 1926.1101 REGULATES ASBESTOS PRACTICES -REQUIRED TO IDENTIFY ASBESTOS -REQUIRES NOTIFICATION OF ASBESTOS TO CONTRACTORS AND EMPLOYEES -REQUIRES ANNUAL TRAINING -RECORD KEEPING

23. 23 PERSONAL PROTECTIVE EQUIPMENT (PPE) 29 CFR 1910.132-.138 REQUIRES SCHOOLS TO CONDUCT A JOB HAZARD ANALYSIS (JHA) MUST IMPLEMENT ENGINEERING CONTROLS WHERE FEASIBLE PROGRAM IN PLACE TO SELECT APPROPRIATE TYPES OF PPE TO PROTECT EMPLOYEES TRAINING MUST REQUIRE EMPLOYEES TO WEAR PPE

24. 24 OTHER VOSHA REGULATIONS GENERAL INDUSTRY COMPRESSED GASES (1910.101) ELECTRICAL SAFETY (1910.301) EMERGENCY RESPONSE (1910.120) WALKING/SURFACES (1910.021) POWERED INDUSTRIAL TRUCKS, TRACTORS, FORKLIFTS (1910.178) MANY, MANY MORE

25. 25 OTHER VOSHA REGULATION CONSTRUCTION FALL PROTECTION (1926.500 - 503) EXCAVATIONS (1926.750 – 753) SCAFFOLDS (1926.450 – 454) WELDING AND CUTTING 1926.350 – 354) FIRE PROTECTION AND PREVENTION (1926.150 – 159) LADDERS (1925.1050 – 1060) MANY, MANY MORE

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27. 27 RECOMMENDATIONS ESTABLISH OR SOLIDIFY YOUR SAFETY COMMITTEE PERFORM JHA DEVELOP KEY PROGRAMS, ESPECIALLY REQUIRED WRITTEN PROGRAMS PERFORM SELF AUDITS REVIEW CONTRACTUAL LANGUAGE ATTEND VSBIT SPONSORED VOSHA PROJECT WORK SAFE PROGRAMS HIGHER A VOSHA CONSULTANT BE PREPARED BE DILIGENT BE WILLING TO PROVIDE A SAFE WORK SITE FOR YOUR EMPLOYEES

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30. 30 OSHA REFERENCE WEB SITES www.osha.gov www.state.vt.us/labind/vosha.htm www.ehs.indiana.edu/resources/policies/ www.ehs.indiana.edu/osha/ www.ed.gov/emergencyplan www.osha-safety-training.net/PUB www.uoregon.edu

31. 31 OSHA CONSULTING FIRMS Paul, Frank & Collins One Church Street P.O. Box 1307 Burlington, VT 05402-1307 802-658-2311 ATC Associates Inc. Browns Trace Building 15 East Main Street P.O. Box 3 Richmond, VT 05477-0003 802-434-2113

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