ACC’s 2008 Annual Meeting Informed. In-house. Indispensable.

Monday, October 20 9:00 am-10:30 am

004 Understanding & Surviving OSHA

Jose Chanfrau IV General Counsel Downrite Engineering Corporation

Scott Clearwater Associate General Counsel Hess Corporation

Greg Watchman Associate General Counsel Freddie Mac

This material is protected by copyright. Copyright © 2008 various authors and the Association of Corporate Counsel (ACC). Materials may not be reproduced without the consent of ACC. Reprint permission requests should be directed to ACC’s Legal Resources Department at ACC: 202/293-4103, ext. 338; [email protected] ACC's 2008 Annual Meeting Informed. In-house. Indispensable.

Mr. Watchman presently serves ACC as vice-chair of the employment and labor Faculty Biographies committee. Mr. Watchman has also received ACC’s Jonathan S. Silber Award as Outstanding Committee Member of the Year. Jose Chanfrau IV Mr. Watchman received his JD from Cornell Law School and is a graduate of Williams Jose M. Chanfrau IV is the general counsel for Downrite Engineering Corp. and a College. principal in Legal Group, LLC.

Mr. Chanfrau has years experience providing legal counsel to corporations, business entities, and individuals in negotiating construction services contracts, construction payment and defect litigation, environmental compliance, labor, employment law, health and safety, real estate, administrative law, bankruptcy, and commercial litigation.

Mr. Chanfrau has obtained advanced training on union avoidance, union organizing campaigns, collective bargaining, grievances, discipline and discharge cases, arbitration, and alleged unfair labor practices.

Scott Clearwater

Scott Clearwater is currently associate general counsel, environmental affairs, for Hess Corporation. Mr. Clearwater handles a wide variety of environmental, health, and safety issues for Hess’ global marketing and refining and exploration and production operations. In that role, Mr. Clearwater assists clients on process safety management, OSHA compliance, transactional issues, remediation, and EHS litigation.

Over the past 20 years, Mr. Clearwater worked as in-house counsel and EHS director at Engelhard Corporation, in-house counsel at Mobil Oil Corporation, and as an associate at Winston & Strawn.

Mr. Clearwater has a BS from the University of Rochester and a JD from The College of William and Mary.

Greg Watchman

Gregory R. Watchman is associate general counsel for employment law at Freddie Mac in Tyson’s Corner, Virginia.

Previously, Mr. Watchman served as acting assistant secretary of labor and deputy assistant secretary of labor at the US Department of Labor, Occupational Safety and Health Administration. In addition, he served as labor counsel to the labor committees in the US Senate and House of Representatives, working on a broad range of employment and labor law legislation. Mr. Watchman also has experience counseling employers on employment law issues, with the national firms Paul Hastings and Morgan Lewis.

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UNDERSTANDING & SURVIVING OSHA

TODAY’S AGENDA The General Duty Clause: The Catchall Provision •! Overview of Regulatory Framework According to the Occupational Health & •! OSHA Initiatives Safety Act of 1970 (Act) employers must furnish employment “free from •! Recent Enforcement Actions & Cases recognized that are causing or •! Avoiding the Most Common Mistakes are likely to cause death or serious physical harm to his employees,” and •! How to Avoid an Inspection must comply with OSHA’s standards. •! How to Survive an Inspection

•! How to Appeal a Citation "

Brief Overview of OSHA’s Regulatory Framework Inspection Priorities •! Imminent Danger Four Types of Inspections OSHA Standards •! Fatality/Catastrophe Inspections •! Complaint/ Referrals Inspections • Programmed Horizontal Standards Vertical Standards Performance Standards Specific Standards ! Inspections

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Standards to Establish A Citation (Secretary of Labor v. Atlantic Battery Company, Inc., 1994 WL 682922*6 (O.S.H.R.C.) •! The applicability of the standard. •! The employer’s noncompliance with the standard’s terms. •! Employee access to the violative conditions. •! That the employer had actual or constructive knowledge of the violation.

Federal Inspections - Fiscal Year 2006 38,579 Inspections Percent Reason for Inspection Number 7,376 (19.1%) Complaint/accident related Penalties 21,504 (55.7%) High targeted 9,699 (25.1%) Referrals, follow-ups, etc. •! De minimis Violation- Violations of standard which have no direct or immediate Number Percent Industry Sector relationship to safety or health. 22,891 (59.3%) Construction •! Other Than Serious Violation- These are violations where OSHA cannot predict if the violation will result in serious injury or illness but the hazard, nonetheless, does have a 7,689 (19.9%) Manufacturing direct and immediate relationship to their safety and health. 403 (1%) Maritime •! Serious Violations- To demonstrate a "serious violation" of a safety standard OSHA must 7,596 (19.7%) Other industries prove: (1) that the cited standard applies and that its requirements were not met, (2) that OSHA identified the following violations: employees were exposed to, or had access to, the violative condition, and (3) that the Percent Type Current Penalties employer knew or, through the exercise of reasonable diligence, could have known of this Violations condition; (4) furthermore, there must be a substantial probability that death or serious 479 (0.5%) Willful $16,009,045 physical harm could result from the hazard. 61,337 (73.1%) Serious 54,139,361 •! Wilfull or Repeated Violations- These violations according to OSHA involve evidence that 2,551 (3.0%) Repeat 9,688,804 shows either an intentional violation of the Act or plain indifference to its requirements. 288 (0.3%) Failure to Abate 1,044,925 Repeated issuance of citations addressing the same or similar conditions or lack of communication of the OSHA standards to lower level personnel is enough to constitute a 19,246 (23%) Other 3,098,221 willful violation. If the willful violation results in the death of the employee, it could result in a 12 (0.01%) Unclassified 1,044,925 criminal penalty punishable by up to six months of imprisonment and a fine of $10,000.00. 83,913 TOTAL $84,413,006 29 USC §666(a)

Source: OSHA http://www.osha.gov/as/opa/oshafacts.html visited 6/21/08

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State Consultation Programs Current OSHA Initiatives/Enforcement

According to 29 USC 667 nothing in the Act shall prevent any state agency or court from •! Site-Specific Targeting (SST) asserting jurisdiction under –! Based on injury & illness data reported by employers state law over any occupational –! Covers worksites with 40+ employees and above-average safety or health issue with injury & illness rates respect to which no standard is •! Enhanced Enforcement Program (EEP) in effect under section 6 subject –! Can broaden inspections from one site to other sites of same to the approval of the Secretary employer of Labor. The state plan must at •! National Emphasis Programs (NEPs) least meet the standards of –! Lead, silica, shipbreaking, amputations, refineries, trenching, federal OSHA. chemical plants (PSM), diacetyl •! Local Emphasis Programs (LEPs)

OSHA’S JURISDICTIONAL LIMITS Current OSHA Initiatives/Rulemaking •! Section 4 (b)(1) of the OSH Act restricts OSHA’s jurisdiction to industries in •! Health Standards: Silica, Beryllium, Diacetyl which another federal agency has not •! Safety Standards: Explosives, Vertical Tandem Lifts regulated in the area of worker safety (Longshoring), Confined Spaces/Construction, •! This section limits OSHA’s jurisdiction in Electric Power Transmission, Cranes & Derricks such areas as rail safety (FRA), airline safety (FAA), & trucking safety (DOT) •! Hazard Communications

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Current OSHA Initiatives Recent Enforcement Actions & Cases •! Partnerships •! BP Products, Oregon, Ohio refinery –! OSHA proposed $2.4 Million fine –!Alliances –! Identified a number of violations similar to those found in –!Voluntary Protection Programs BP’s Texas City refinery, which had an explosion killing 15 workers (resulting in OSHA penalty of over $20 Million) –!Informal Partnerships –! Citations included: locating people in vulnerable buildings among process units; failing to correct deficiencies with gas monitors, failing to prevent non-approved electrical equipment in locations with flammable gases, failing to •! Legislation develop shutdown procedures, and failing to resolve –!Increased Penalties recommendations made after a prior safety incident

Recent Enforcement Actions & Cases Recent Enforcement Actions & Cases OSHA Seeks $8.7 Million Fine Against Sugar Company Konie Cups International: $64,250 •! On July 25, 2008, OSHA proposed an $8.7 Million Despite earlier warning by Fire Dept, OSHA penalty against Imperial Sugar for safety violations discovered locked exit door and door key not easily resulting in the death of 13 workers in a sugar dust explosion accessible in case of emergency, resulting in “willful” violation •! OSHA claims senior management was aware of combustible dust hazards and did not take Munro Muffler: $107,000 appropriate action to eliminate them OSHA found locked fire exits, fall exposures, •! Agency found 118 “egregious” violations improper storage. OSHA alleged repeat •! Ventilation and dust collection issues fell under and serious violations because same issues were agency’s “general duty” clause found at other company stores

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Recent Enforcement Actions & Cases The Case of Safeco Corporation North East Linen: $79,250 The company has a safety program. The safety team completed their 2008 internal Two employees, who were cleaning a safety audit of the plant in April, and the team wastewater tank, were discovered at the is now working its way down the list of bottom of the tank, which was - hazards and compliance deficiencies it deficient and contained hazardous identified in the audit report. The safety team chemicals. Serious citations included focuses on hazards created by its own failure to provide hazard communication employees; the company’s contractors are and confined space entry training required by contract to ensure that their own employees follow safety rules.

Avoiding the Most Common Management Mistakes The Case of Safeco Corporation When the team finds hazards, a team The Case of Safeco Corporation member follows up with the responsible employee(s) to make sure they understand Safeco Corporation manufactures toys. The the rules. Repeat offenders are required to plant and corporate offices are located in take additional training. When injuries or Pennsylvania, housing 1,516 employees and another 362 contingent workers employed by illnesses occur, the safety team errs on the contractors. side of caution and records any ambiguous ones as recordable on the OSHA log.

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The Case of Safeco Corporation The Case of Safeco Corporation The company is proud of its safety record, and believes that given its “one big family” Compliance Issue #1: philosophy, workers would report any unsafe conditions to management before going to OSHA. In fact, there have been few “OSHA Doesn’t Inspect White Collar complaints. The company has not had any Offices or Service Businesses” interaction with OSHA since a boiler exploded in 1998, and hopes it stays that way.

The Case of Safeco Corporation White Collar & Service Workplaces •! OSHA does inspect white collar & service You are Safeco’s in-house counsel, and workplaces you are asked to assess any potential •! For example, the agency might do so in compliance risks and provide advice. response to a complaint, a fire, or a safety How would you advise the company? incident •! These workplaces should make sure they are up to speed on the basic compliance rules

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White Collar & Service Workplaces: Basic Compliance Building Blocks OSHA Recordkeeping Requirements 101 •! Who must complete and maintain the •! Fire Safety & Emergency Action Plans OSHA forms? •! Hazard Communication –! Companies with ten (10) or more employees during the last calendar year •! Personal Protective Equipment •! What must be recorded? Injury or illness to •! Training any employee whether permanent, part time, •! Slips, Trips & Falls temporary hourly or salaried. •! Electrical •! When must you contact OSHA? •! Ergonomics –! Any workplace incident that results in a fatality or the hospitalization of three or more employees.

OSHA Recordkeeping Requirements What Forms Must Be Kept? •! OSHA Form 300 Log of Work Related Injuries and Illnesses. •! OSHA Form 300A Summary of Work Related Injuries and Illnesses. •! OSHA Form 301 Injury and Illness Incident Report.

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The Case of Safeco Corporation The Case of Safeco Corporation

Compliance Issue #2: Compliance Issue #3:

“Our Safety Audit Will Demonstrate “If it’s not my employee, it’s not my Good Faith By Showing That We problem.” Regularly Look For Hazards”

“If It’s Not My Employee, It’s Not My Internal Audits May Be Used Against You! Problem.” •! Who is Considered an •! Consider whether audit should be conducted Employee for OSHA under attorney-client privilege Purposes? OSHA looks to the party who controls the •! Use trained inspection team work site. •! Document compliance issues •! Who Controls the Work Environment? Although it •! Ensure open issues are corrected and may seem that determining “Who controls the work tracked to closure environment?” is a straightforward proposition, •! Uncorrected issues may be evidence of a once you add the element of contingent workers and a “willful” violation! multi-employer work site, not only is there not a bright line, to the extent there is any line at all it is definitely very hazy and wavy.

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OSHA’s Multi-Employer Policy The Case of Safeco Corporation

•! More than one employer may be citable for a Compliance Issue #4: “We focus on correcting hazardous condition that hazards, not on disciplining employees.” violates an OSHA standard.

•! OSHA may cite: •! OSHA inspectors will look for evidence that –! “Creating” employer –! “Exposing” employer safety rules are regularly enforced through –! “Controlling” employer employee discipline –! “Correcting” employer •! Can affect scope of inspection, extent and classification of citations, and amount of See: OSHA Instruction CPL 02-00-124 - CPL 2-0.124 - Multi-Employer Citation Policy. proposed penalties

Contingent Workers The Case of Safeco Corporation •! “Contingent Workers” are part- Compliance Issue #5: “I’ll record every time, temporary, and contract workers who do not have a potentially recordable incident, to avoid traditional relationship with a recordkeeping citations.” single work-site employer. •! According to a 2005 Department of Labor study, •! Cautious approach makes sense contingent workers comprise over 9.7 percent of the civilian •! But beware OSHA’s targeted inspection workforce consisting of independent contractors, on call program -- focused on reported injury & workers (workers called to work illness rates only as needed), temporary help agency workers and workers provided by contract firms.

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The Case of Safeco Corporation How To Avoid an Inspection

Compliance Issue #6: “My employees would •! Take steps to minimize possibility of OSHA complaints or incidents that come to me with safety concerns rather than could trigger an OSHA inspection going to OSHA.” –! Make sure your safety program and internal complaint processes are robust –! Address the most significant hazards –! Resolve workplace disputes (if you are undergoing labor problems or other disputes with employees, it is more likely that employees will call OSHA) •! Most employees fear retaliation •! Respond promptly to OSHA “warning letters” and phone/fax •! But most want quick resolution of safety communications issues if trustworthy avenue is available •! Track OSHA’s targeted inspection program •! Review your internal complaint process to –! Is your industry on the “high hazard” list? (manufacturing, landscaping/ make sure it fosters trust (provide multiple horticultural services, oil & gas field services, fruit & vegetable processing, concrete & concrete products, blast furnace & basic steel products, ship, avenues, allow anonymous complaints, boat building & repair, public warehousing & storage) provide responses, involve employees) –! Is your reported injury and illness rate high enough to trigger an inspection?

The Case of Safeco Corporation How to Survive an Inspection Compliance Issue #7: “The less we interact •! When an inspector arrives, document name, with OSHA, the better.” credentials and obtain purpose and scope of inspection •! If likely to have OSHA interaction, don’t wait •! If the inspector arrives with a search warrant, for a complaint or incident ask for copy and contact legal counsel •! Consider informal outreach, partnership with •! Designate one company representative as Area Office (e.g., on a safety conference or OSHA’s point of contact training video), or more formal alliance

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How to Survive an Inspection How to Survive an Inspection •! Opening Conference •! Site Inspection –!Determine scope of investigation –! Make copies of all documents provided to inspector –!Personnel advised of objectives, logistics, –! If documents are confidential, make sure they are scheduling of inspection activities marked as such –!Inspector(s) may be required to attend –! Duplicate any photographs taken by the inspector safety orientation before inspection and ensure no confidential business information appears in the photographs

How to Survive an Inspection How to Survive an Inspection •! Site Inspection •! Closing Conference –! Stay with inspector at all times –! Be deferential, but request copies of all sample/analytical –! Limit inspection to scope determined during reports, interview reports, field notes and inspector’s report opening conference –! Ask inspector for a receipt acknowledging what documents were provided –! Document all issues discussed and name of –! Document problem areas indicated by the inspector, along employees interviewed. Company has right to with applicable standards, abatement procedures and advise employee that she/he can request potential penalties company representative be present –! Use closing conference as an opportunity to demonstrate –! Employees should answer only questions asked good faith efforts -- promote company’s safety programs and and avoid statements that may be construed as commitment to safety and health admissions of non-compliance

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How to Appeal a Citation or Penalty How to Appeal a Citation or Penalty •! Request an Informal Conference •! Notice of Contest –! Meet ASAP With Area Director (must be within 15 –! Must file within 15 days from date of receipt of working days of receipt of citation, before Notice of citation – NO EXCEPTIONS Contest due) –! Attorneys may participate, but it is not necessary •! Mediation –! Company’s union representation should be invited •! Discovery & ALJ Hearing –! Opportunity for possible penalty reduction, •! Appeal to OSH Review Commission and then extension of abatement dates, deletion and/or reclassification of citations and create open federal courts of appeals communication with the Area Director

How to Appeal a Citation or Penalty The Future of OSHA: •! Informal Conference What Does the Next Administration & –!Area Director may propose modified Congress Have in Store? citations or penalty assessment –!If you reach a settlement, make sure to •! Increased penalties, enhanced enforcement authority include a non-admission clause in any •! Rulemaking on S&H Programs, Silica, PELs, & more settlement agreement, indicating employer •! “Leveraged” enforcement programs under “new does not admit to any violations governance” model

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ACC 2008 Annual Meeting Program 004 Subpart L - Fire Protection UNDERSTANDING & SURVIVING OSHA (1910.155 - 165)- FY 2006 Serious Violations

HANDOUT: OSHA BASICS FOR WHITE COLLAR & SERVICE BUSINESSES

Every year OSHA inspects a host of white collar workplaces and service establishments due to worker complaints or safety incidents. The attached slides detail some of the most frequent sources of citations and penalties for these establishments.

Jose Chanfrau, IV

Top Eight Standards Cited for SIC 8700 in 2007: Engineering, Accounting, Research, Management, And Related Services Do you have a fire extinguisher? Source: OSHA http://www.osha.gov/pls/imis/citedstandard.sic?p_sic=87&p_esize=&p_state=FEFederal

•! OSHA requires ALL Standard #Cited #Insp $Penalty Description Total 396 101 212387

businesses to have portable 19100134 32 13 10485 Respiratory Protection. fire extinguishers. 19100305 25 14 5900 Wiring methods, components, and •! All businesses that have a equipment for general use. portable fire extinguisher must have a Emergency 19100132 23 18 10323 General requirements. 19100037 21 14 4925 Maintenance, safeguards, Action Plan (EAP) that and operational features meets certain minimum for exit routes. requirements. 19101200 21 10 3715 Hazard Communication. 19100303 18 10 4725 General requirements.

19261101 17 2 4500 Asbestos

19100157 15 12 1475 Portable fire extinguishers.

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Minimum Requirements For An Emergency Action Plan •! Means of reporting fires and other emergencies. •! Evacuation procedures and emergency escape route assignments. •! Procedures to be followed by employees who remain to operate critical plant operations before they evacuate. •! Procedures to account for all employees after an has been completed. •! Rescue and medical duties for those employees who are to perform them. •! Names or job titles of persons who can be contacted for further information or explanation of duties under the plan. •! Management of safety & health.

Subpart E – Exit Routes, Emergency Action Plans, and Fire OSHA Recordkeeping Requirements Prevention Plans What Forms Must Be Kept? (1910.33 - 39)-FY 2006 Serious Violations

Exit routes free & unobstructed •! OSHA Form 300 Log of Work Related Injuries Exit marking and Illnesses.

Exit route doors unlocked •! OSHA Form 300A Summary of Work Exit access signs Related Injuries and

“Not an Exit” signs Illnesses. •! OSHA Form 301 Injury and Illness Incident Report.

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OSHA Recordkeeping Requirements 101 •! Who must complete and maintain the OSHA forms? –! Companies with ten (10) or more employees during the last calendar year •! What must be recorded? Injury or illness to any employee whether permanent, part time, temporary hourly or salaried. •! When must OSHA be notified? –! Any workplace incident that results in a fatality or the hospitalization of three or more employees.

Recordation of Injuries or Illness Are Not The Illness Log Required If: •! At the time of the injury or The medical record for illness the person was present as a member of the general each employee must be public. preserved and •! The injury or illness involves maintained for at least signs or symptoms that surface the duration of at work but result solely from a employment plus 30 non-work related event or exposure that occurs outside years, unless a specific the work environment. occupational safety and •! The injury or illness results health standard solely from voluntary provides a different participation in a medical,fitness, or recreational period of time. activity such as blood donation, flu shot, sports etc.

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The Top Ten Most Frequently Cited Hazard Communications Standards by OSHA •! The maintenance of Fiscal Year 2007 (October 2006 through September 2007) Source: OSHA material safety data sheets (MSDS) is Scaffolding, general requirements, construction (29 CFR 1926.451) required under OSHA's Fall protection, construction (29 CFR 1926.501) Hazard Communication Hazard communication standard, general industry (29 CFR 1910.1200) Standard, and is the Control of hazardous energy (lockout/tagout), general industry (29 CFR 1910.147) single largest source of Respiratory protection, general industry (29 CFR 1910.134) OSHA violations by Powered industrial trucks, general industry (29 CFR 1910.178) employers. Electrical, wiring methods, components and equipment, general industry (29 CFR 1910.305) Ladders, construction (29 CFR 1926.1053) 29 CFR 1910.1200. Machines, general requirements, general industry (29 CFR 1910.212) Electrical systems design, general requirements, general industry (29 CFR 1910.303)

Subpart Z - Toxic & Hazardous Substances Subpart H - Hazardous Materials (1910.1000 - 1450)-FY 2006 Serious Violations (1910.101 - 126)-FY 2006 Serious Violations

Hazard Communication - Written program Compressed gases - Handling, storage & use Hazard Communication - Information & training Spray booth – Air velocity Hazard Communication - Training initially & for new hazards Class I liquids - Dispensing Hazard Communication - Material Safety Data Sheets Sources of ignition - Precautions Hazard Communication - Label identification Spray areas – Approved wiring & equipment

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Subpart N - Materials Handling & Storage Subpart S - Electrical (1910.176 - 184) (1910.301 - 399)-FY 2006 Serious Violations FY 2006 Serious Violations

Conductors entering cabinets/boxes/fittings protected from abrasion Powered Industrial Trucks – Operator competency

Electrical box covers Powered Industrial Trucks – Safe operating condition

Proper installation & use of equipment Secure storage Live parts Powered Industrial Trucks – Operator certification Grounding path Powered Industrial Trucks – Examination for defects

Subpart I - Personal Protective Equipment Subpart J - General Environmental Controls (1910.132 - 139)-FY 2006 Serious Violations (1910.141 - 147)-FY 2006 Serious Violations

Medical evaluation to determine employee’s ability to use respirator Lockout/Tagout - Program

Written respiratory protection program Lockout/Tagout - Procedures

Lockout/Tagout - Training Personal protective equipment

Lockout/Tagout procedure - Periodic inspection Eye & face protection Lockout/Tagout - Content of energy control procedures PPE hazard assessment

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Typical Occupational Categories of Employees Mandatory Training Programs Facing a Higher Than Normal Risk of Electrical Accident ______Occupation •! There are currently 76 standards that ______1.! Blue collar supervisors(1) require training. 2.! Electrical and electronic engineers(1) 3.! Electrical and electronic equipment assemblers(1) •! Mandatory training programs 4.! Electrical and electronic technicians(1) 5.! Electricians predictably involve issues such as 6.! Industrial machine operators(1) energized equipment/lock out-tag out. 7.! Material handling equipment operators(1) 8.! Mechanics and repairers(1) 9.! Painters(1) •! Others are less obvious such as the first 10.! Riggers and roustabouts(1) aid training standard. 11.! Stationary engineers(1) 12.! Welders ______Footnote (1) Workers in these groups do not need to be trained if their work or the work of those they supervise does not bring them or the employees they supervise close enough to exposed parts of electric circuits operating at 50 volts or more to ground for a hazard to exist. [55 FR 32016, Aug. 6, 1990]

OSHA’s Training Guidelines Electrical Hazard Training Type of Scope of Content of Additional Additional •! Determining if Training is Training Require- Require- Training Training Needed. ments for •! Identifying Training Needs. ments for Unqualified Qualified •! Identifying Goals and Persons Objectives. Persons Classroom or Apply to Employees shall Trained in and 1) Skills and •! Developing Learning techniques necessary Activities. on-the-job type employees who be trained in and familiar with any to distinguish exposed depending on face a risk of familiar with the electrically live parts from other parts of electric •! Conducting the Training. the nature of electric shock safety-related related safety hazard. that is not work practices practices not equipment. •! Evaluating Program reduced to a required by specifically 2) The skills and techniques necessary Effectiveness. safe level by the 1910.331 addressed by to determine the electrical through 1910.331 nominal voltage of •! Improving the Program 1910.335 that through exposed live parts. installation pertain to their 1910.335 but 3) The clearance distances specified in requirements respective job which are 1910.333(c) and the assignments. necessary for corresponding voltages to which the their safety. qualified person will be exposed.

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First-aid and CPR Training (Mandatory). - Patient Assessment and for: 1910.266 App B Minimum Requirements •! The definition of first aid. •! Handling and transporting •! Respiratory arrest. injured persons. •! Cardiac arrest. •! Legal issues of applying first •! Hemorrhage. aid (Good Samaritan ). •! Treatment of bites, stings, or •! Lacerations/abrasions. •! Basic anatomy. contact with poisonous plants •! Amputations. •! CPR. or animals. •! Musculoskeletal injuries. •! Patient assessment and first •! Shock. •! Application of dressings and aid for the following named •! Eye injuries. slings. •! Burns. conditions: (See List) •! Treatment of strains, sprains, •! Loss of consciousness. and fractures. •! Extreme exposure (/) •! Paralysis •! Immobilization of injured •! Poisoning. persons. •! Loss of mental functioning (psychosis/hallucinations, etc.). •! Artificial ventilation. •! Drug overdose.

Subpart K - Medical & First Aid (1910.151 - 152)-FY 2006 Serious Violations

Eye & body flushing facilities

First aid

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