What does the Occupational Health and Safety Administration OSHA require employers to do?

14.4 Accidents and Loss Prevention Measures

All accidents and near misses, which are unplanned events that do not result in injury, should be reported. Statistical analyses based on the reported accident data improve regulations and procedures to save lives and property by reducing and eliminating accidents in industry. The benchmarking indicators for accident reporting (Ball, 1991) are: lost time accident (LTA) rate, recordable accident rate, LTA severity rate and days lost per LTA.

Accident frequency rates are calculated on the basis of number of accidents per 100,000 working hours. The typical LTA rate is 0.3. An LTA value of 0.3 means 0.3 injuries per 100,000 h. The average time at work in refineries is 2000 h per year (50 work weeks/year × 40 h/week). For example, if a refinery has 1000 employees, the working hours will be 2 million (1000 employee × 2000 h), and with a LTA rate of 0.3, this gives 6 accidents per year in this refinery based on OSHA's LTA.

OSHA's incidence rate (2004) is based on the number of incidents per 100 workers years (2000 h/year). Therefore, OSHA incidence rate is based on 200,000 h of all workers exposed to hazards, either based on injuries (equation 14.1) or based on lost workdays (equation 14.2):

(14.1)OSHA incidence ratebased on injuries=number of injuries×200000total hours worked by all employees

(14.2)OSHA incidence rate based on lost workdays=number of lost workdays×200000total hours worked by all employees

The OSHA incidence rate provides information on all types of work related accidents.

Example E14.1

A refinery has 1500 full-time employees. In a particular year, this plant had 28 reportable lost-time injuries that resulted in 175 lost workdays. Compute the OSHA incidence rate based on injuries and lost workdays.

Solution:

Since total working hours for all employees is 1500 × 2000,

OSHA incidence ratebased on injuries=28×2000001500×2000=1.87

OSHA incidence ratebased lost workdays=175×2000001500×2000=11.67

Information Available Electronically

OSHA has a variety of materials and tools available on its website at www.osha.gov. These include e-tools such as Expert Advisors, Electronic Compliance Assistance Tools (e-cats), Technical Links; regulations, directives, and publications; and videos and other information for employers and employees. OSHA's software programs and compliance assistance tools walk you through challenging safety and health issues and common problems to find the best solutions for your workplace. A wide variety of OSHA materials, including standards, interpretations, directives, and more, can be obtained from the OSHA website.

Does OSHA Provide Any Information Electronically?

OSHA has a variety of materials and tools available on its web site at www.osha.gov. These include eTools such as Expert Advisors, Electronic Compliance Assistance Tools (e-CATs), technical links, regulations, directives, publications, videos, and other information for employers and employees.

OSHA's software programs and compliance assistance tools walk you through challenging safety and health issues and common problems to find the best solutions for the workplace.

The Occupational Safety and Health Administration's online help includes standards, interpretations, directives, and more—see www.osha.gov/dts/osta/oshasoft/asbestos/index.html. For publications, contact the U.S. Government Printing Office, Superintendent of Documents, P.O. Box 371954, Pittsburgh, PA 15250-7954; telephone: 202-512-1800.

5.4.1 Occupational Exposure Levels

OSHA and the ACGIH have established workplace exposure standards and guidelines, respectively, to protect the health and safety of workers from overexposure to many of the individual constituents of crude oil. In addition, the National Institute for Occupational Safety and Health (NIOSH) has derived Recommended Exposure Limits (RELs) for the same purpose. These values are expressed as 8-hour (OSHA PELs and ACGIH TLVs) or 10-hour (NIOSH RELs) Time-Weighted Averages (TWA) and are intended to address daily worker exposures occurring over a working lifetime. Others may be expressed as Short-Term Exposure Limits (STEL; 15-minute average exposures) or Ceilings (maximum values allowed during a work period). The STEL and Ceiling values are applicable to exposures of shorter duration that can occur during chemical release emergencies. The 8-hour TWA values may also be relevant to emergency settings if intended to protect against short-term health effects such as irritation, central nervous system depression, etc. Together, the worker exposure guidelines and standards provide useful information for the development of action levels and in the interpretation of the results of air monitoring and sampling performed during crude oil releases. Table 5.4 summarizes the OSHA worker exposure standards and the NIOSH and ACGIH guidelines for target analytes associated with crude oil.

Table 5.4. Occupational Exposure Standards and Guidelines

(ACGIH, 2014a), NE, Not Established; (C), Ceiling.

8.1 OSHA and fatigue risk

The Occupational Safety and Health Administration (OSHA) is an agency of the US Department of Labor. It was founded in 1970 by an act of Congress. OSHA’s mission is to assure safe working conditions in the United States by enforcing numerous safety regulations. There are some exceptions such as those for the self-employed or family farms, but most private sector employers are bound by OSHA regulations. OSHA has jurisdiction unless preempted by another federal agency such as the Department of Transportation or Federal Aviation Administration, but these agencies can only preempt OSHA in a specified activity or task. OSHA has the ultimate responsibility for the safety and health of American employees.

OSHA does not have standards currently that address fatigue risk management. It has taken a position on extended work shifts which includes the definition of an extended shift as:

A normal work shift is generally considered to be a work period of no more than eight consecutive hours during the day, five days a week with at least an eight-hour rest. Any shift that incorporates more continuous hours, requires more consecutive days of work, or requires work during the evening should be considered extended or unusual. Extended shifts may be used to maximize scarce resources. Long or unusual shifts are often required during response and recovery phases of emergency situations such as terrorist threats, which generally come without warning, require continuous monitoring, and may overwhelm local responders both technically and tactically. These schedules ensure that the appropriate scarce resources are in place and accessible while full mobilization is being developed.

OSHA website [1]

OSHA does not have specific regulations about extended shift work. The agency’s website does provide information on fatigue risk management as a guide. There is potential that OSHA could adopt standards in this area. They issued a statement in 2010 (see Fig. 8.1) supporting the report of US Chemical Safety and Hazard Investigation Board (CSB) on the BP Texas City accident. The statement clearly shows OSHA’s belief that long work hours can be hazardous. Over the years the agency has written citations of safety infractions that are not specifically covered by regulations using the general duty clause which states “Each employer 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.” It is plausible that in the future when OSHA is investigating a serious accident that excessive work hours could be cited as causing an unsafe workplace and the agency could levy fines for this.

3.1.1 Occupational Safety and Health Administration

OSHA Process Safety Management (PSM) regulation, 29 CFR 1910.119, requires a comprehensive set of plans, policies, procedures, practices, administrative, engineering, and operating controls designed to ensure that barriers to major incidents are in place, in use, and are effective. Its emphasis is on the prevention of major incidents rather than specific worker health and safety issues. PSM focuses its safety activities on chemical-related systems, such as chemical manufacturing plants, wherein there are large piping systems, storage, blending, and distributing activities.

Occupational Safety and Health Administration

The OSHA is responsible for establishing and enforcing workplace safety rules. In an era of increased focus on patient safety, it is important to remember that OSHA deals with employee safety only. OSHA safety regulations do not deal with facility safety per se. Rather, OSHA regulations specify safety practices that are to be enforced while maintaining the facility. These regulations are typically identified for a specific hazard, such as respiratory protection when using aerosolized paint. OSHA does have a “general duty clause,” which is a catch-all regulation requiring employers to provide employee safety programs for hazards that the employer should have been aware exist, even if no specific safety program is identified.

Safety programs under OSHA particularly relevant to clinical engineering include those for employee protection from blood-borne pathogens, rules related to worker protection from energized equipment, ladder safety, and hearing and eye protection when using tools such as grinders and drills.

Rules on blood-borne pathogens include those applicable to all hospital personnel with potential exposure to blood and body fluids from direct patient contact. They also include requirements for clinical engineering departments to develop and enforce rules for the decontamination of patient equipment prior to repair. Rules for blood-borne pathogens can be found in 29 CFR 1910.

OSHA requires that worker protection be provided when repairs being made to “energized” devoices. These can be powered from an electrical, pneumatic, or other power source. The rules are classified as “lockout/tagout” rules. A typical example of the application of the lockout/tagout rule is the repair of any permanently wired electrical equipment such as x-ray systems. The rule does not apply to those devices that can be disconnected from their power source prior to repair. In the case of permanently wired equipment, department policy must be clear that such devices cannot be repaired while connected to their power source unless specifically approved on a case-by-case basis.

3.2 US Regulatory Agencies

The OSHA was created by the Occupational Safety and Health Act of 1970 and has responsibility for enforcing that Act. OSHA comes under the Secretary of Labor and is headed by an Assistant Secretary of Labor. Its activities include the adoption of standards and making of rules, the inspection of workplaces and the investigation of accidents.

The EPA, created by the National Environmental Policy Act (NEPA) 1969, is responsible for environmental legislation, including that on air pollution, water pollution and hazardous wastes. The areas of responsibility between the OSHA and the EPA are not clearcut. Although the OSHA is concerned with the workplace and the EPA with the environment, there are some areas where both agencies are involved. One of these is accidental releases and another is toxic substances, as described below. The relation between the two agencies is discussed by Spiegelman (1987) and Burk (1990).

Mining and mineral processing (such as Alumina refineries and lime processing) are the responsibility of the Mine Safety and Health Administration (MSHA).

Offshore production safety is the responsibility of the Mineral Management Service (MMS), which took over from the original US Coast Guard duties in the mid-1980s. However, the Coast Guard now has responsibility for deep water facilities, in addition to its traditional role of marine safety.

Pharmaceutical safety comes under the watchful eye of the Food and Drug Administration (FDA).

Pipeline safety, rail transport safety, and motor carrier safety issues are the responsibility of the Department of Transportation.

Respiratory Protection

Occupational Safety and Health Administration publication 3079 defines a respirator as a device designed to protect the wearer from inhaling harmful dusts, fumes, vapors, or gases (OSHA 2002). Respirators have been developed by the military and private industry and therefore come in a wide range of types and sizes. They can be loose or tight fitting. Tight fitting respirators adhere closely to the skin and can cover just the mouth and nose or the entire face from the hairline to below the chin. Loose fitting respirators are typically hoods and helmets that cover the head completely and are often worn as a complement to a full body protection device. Respirators can be categorized as either air purifying or air supplied (OSHA 2002):

Air purifying respirators use filters to remove harmful contaminants from inhaled air, and they range from simple dust masks to complex masks that filter a wide variety of harmful chemical contaminants. These respirators do not provide supplemental oxygen, and they are not recommended for use in oxygen deficient atmospheres or other atmospheres that are immediately dangerous to life or health. Examples of air purifying respirators are gas masks, chemical canister masks, and chemical cartridge masks.

Air supplied respirators use an alternate source of breathable air to supplant the contaminated air. These range from supplied air respirators, that is, masks connected to flexible hoses that provide positive pressure breathable air, to self contained breathing apparatuses, that is, masks connected to a portable storage tank that provides positive pressure breathable air.

The selection of a respirator depends heavily on the environment in which the respirator is to be used, and the length of time for which the respirator is to be needed. Like all other forms of personal protective equipment, respirators often have targeted environments, where they operate most effectively. Particulate size, particulate concentration, and specific chemical compounds and vapors are just a few of the environmental characteristics that dictate the choice of respirator. Usage time also dictates respirator selection. For example, supplied air respirators with their bigger breathable gas sources can provide relatively long periods of breathable air, while self contained breathing apparatuses and cartridge respirators provide shorter periods of respiratory protection, because they are limited by breathable air source capacity and cartridge life, respectively (OSHA 2002). Table 7.14 provides a simplified version of the characteristics and factors used to select a respirator.

Table 7.14. Respirator Selection Criteria