1. OSHA Compliance for Temp Agencies and Host Employers
Compliance with osha health standards: Overview Georgia Tech’s Safety and Health Consultation Program
OSHA Compliance for Temp Agencies and Host Employers

2. Basic Scope of IH Compliance
Hazard Communication (Chemical)
Hearing Conservation
Air Contaminants
Permit-Required Confined Spaces
Respiratory Protection
Personal Protective Equipment
First Aid & Bloodborne Pathogens

3. Hazard Communication Standard
Compliance with OSHA Health Standards

4. “CHEMICAL” Hazard Communication Standard
HCP
“CHEMICAL” Hazard Communication Standard
MSDS
LABEL

5. Purpose
To insure that the hazards of all chemical produced in or imported into the U.S. are evaluated
Hazards transmitted to
employers
employees

6. Basic Program Elements
Chemical Hazard Inventory
MSDS’s
Labeling
Employee Training
Contractor Training
Written Program
Hazard Communication Program

7. Temp Workers and HazCom: Shared Responsibility
Staffing Agency
Generic Policies
Host Company
Specific Chemicals

8. Global Harmonization System (GHS)
Final Standard: March 2012
Implementation Period: December 2013 through June 2016
Hazard Communication Changes
Labels, Pictograms
Safety Data Sheets
Employee Training

9. Four Major Changes in GHS
Hazard Classification (changed from hazard determination)
Labels
Safety Data Sheets (changed from MSDS)
Information and Training
Will affect nearly 40 million workers and 5 million workplaces.

10. Principles Of Harmonization
Consistent Classification (both intra- and inter- nationally)
Harmonized across agencies:
OSHA, Consumer Protection Agency, EPA, DOT
Both code Words and Pictograms
Warnings are based on intrinsic hazards of chemicals
Identify the Severity of exposure

11. Compliance with OSHA Health Standards
Hearing Conservation
Compliance with OSHA Health Standards

12. Monitoring Requirements (Dosimetry)
Initial Monitoring
required if employer has indications of full-shift exposure at or above 85 dBA (Action Level)
Rule of Thumb for estimating 85 dBA
Host and Staffing Agency Duties
Who will conduct noise monitoring?
Default assumption of 85 dBA
What are high range exposures?

13. Hearing Conservation Program: Who Implements Basic Elements?
Provide hearing protection
Train workers on noise effects (annual)
Provide baseline and annual audiometric testing
Retain exposure and audiometric measurements

14. Hearing Conservation Documentation
Copy of Written Guidelines and Policies (Recommended)
Noise Measurement Data and Annual Audiograms
Standard Threshold Shifts Documentation and Notification Letters
OSHA 300 Hearing Loss Records
Which employer records an incident?

15. Compliance with OSHA Health Standards
Air Contaminants
Compliance with OSHA Health Standards

16. Evaluating Host Companies for Air Contaminants
GASES: low density molecules, rapid diffusion
VAPORS: liquids with high vapor pressure
DUSTS: solid particles
FUMES: recondensation of vaporized solids
MISTS: liquid droplets, (aerosols)
SMOKE: complex combustion products
FIBERS: 3 to 1 length to width ratio

17. Chemical Mixtures

18. Anticipate Potential Air Hazards
Review plant layout and chemical flow
Observe air flow patterns
Identify existing controls
Temp Workers and high hazard work
Restrictions on job assignments?

19. Understanding Exposure Limits
PEL
TLV
REL
WEEL
EU Standards
MRG
All of these acronyms will be defined in this section, so just explain that one may see one or more of these limits used on an MSDS/SDS or other documentation.

20. OSHA PEL (Regulatory in US)
Permissible Exposure Limit—PEL
(Or)
“Impermissible” Exposure Limit

21. Categories of OSHA PEL’s
1. The PEL Lists (~400 chemicals)
Current PEL’s are based on 1968 ACGIH-TLV’s
2. The “Substance Specific” Standard
E.g., lead, asbestos, cadmium, methylene chloride, etc.
Relatively few substance specific chemicals regulated

22. Occupational Exposure Limits (OELs) (Non-Regulatory)
American Conference of Governmental Industrial Hygienists—Threshold Limit Value (ACGIH –TLV)
National Institute for Occupational Safety and Health —Recommended Exposure Limit (NIOSH REL)
American Industrial Hygiene Association—Workplace Environmental Exposure Limit (AIHA WEEL)
European Union standards
Manufacturer’s Recommended Guidelines
Some of the acronyms from the earlier slide are defined here.

23. Time-Weighted Average (TWA) Exposure
Example: Acetone, PEL = 1000 PPM, TWA
800
700
600
500
PPM
400
TWA = 200 ppm
300
200
100
200
400
TIME (min)

24. Evaluating Exposures Pre-screening Passive sampling Active IH sampling
STEL Measurements (Short Term)
TWA Measurements (Full Shift)
Acute Exposures (Confined Space)

25. Initial Screening of Exposure

26. Passive Samplers
Organic Vapor Sampler Inorganic Mercury Sampler

27. Full Shift Breathing Zone Exposures

28. Air Contaminants in Permit-Required Confined Spaces (Evaluate Acute Air Hazards)

29. Host and Staffing Agency
Who conducts evaluations?
Who keeps records?
Who has access to records?
Medical surveillance (lead, cadmium, asbestos, methylene chloride, etc)
Who conducts biological monitoring?

30. Respiratory Protection
Compliance with OSHA Health Standards

31. Organize the Program

32. Respirator Program Elements
Selection of respirators
Define use and application
Medical evaluation
Fit testing
Training
Maintenance and care
Breathing air quality and use
Program evaluation
(c)(1)(i)

33. Host and Staffing Agency
Will Temp Workers be assigned to use respirators?
Who will manage the Respirator Program?
Medical evaluation for use
Fit Testing
Training
Recordkeeping

34. Personal Protective Equipment
Compliance with OSHA Health Standards

36. Personal Protective Equipment
PPE HAZARD ASSESSMENT SURVEY 
Job/Task Evaluated:________________________
Date(s): _____________________
Conducted By:_________________________________
(Name and Title)

37. PPE Hazard Assessment

38. PPE Hazard Assessment

39. PPE: Host and Staffing Agency
Review the job hazards
Review the PPE requirements
Review work conditions for PPE use
When
Where
What processes
Paying for PPE

40. Compliance with OSHA Health Standards
Bloodborne Pathogens
Compliance with OSHA Health Standards

41. Applications General Industry/Manufacturing
Designated First Aid responders
BBP standard does not cover “Good Samaritan” acts in which an employee voluntarily provides first aid to a fellow employee
Medical and Human Services Offices
Any employee whose job involves contact with blood or other potentially infectious materials (OPIM)

42. Universal Precautions
All human blood/OPIM are treated as if known to be infectious for bloodborne pathogens, regardless of the perceived “low risk” status of a patient or patient population

43. Exposure Control Plan (Gradient of Complexity)
General Industry/Manufacturing
Relatively simple (First Aid): written policy, PPE, training
Medical Providers/Human Services
Relatively complex (Medical interventions): many program elements to manage; treatment procedures; cleaning schedules; compliance with changing guidance on Sharps; awareness and compliance with CDC infection control practices.

44. Host and Staffing Agency
Review Exposure Control Plan (ECP)
Identify job positions included in ECP
Provide training for Bloodborne Pathogens
Restrict access to specific areas of facility
Identify special PPE requirements
Specify required vaccinations

45. Summary (Host and Staffing Agency shared duties)
Hazard Communication (Chemical)
Hearing Conservation
Air Contaminants
Permit-Required Confined Spaces
Respiratory Protection
Personal Protective Equipment
First Aid & Bloodborne Pathogens