IH Update Industrial Hygiene as defined by the American Industrial Hygiene Association:

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Ronald Holmes
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1 IH Update Industrial Hygiene as defined by the American Industrial Hygiene Association: A "science and art devoted to the recognition, evaluation and control of those environmental factors or stresses arising in or from the workplace that may cause sickness, impaired health and well being, or significant discomfort and inefficiency among workers or among the citizens of the community.

2 Top 10 most frequently cited OSHA standards violated in FY 2011 (Federal OSHA data) Scaffolding, general requirements, construction (29 CFR ) Fall protection, construction (29 CFR ) Hazard communication standard, general industry (29 CFR ) Respiratory protection, general industry (29 CFR ) Control of hazardous energy (lockout/tagout), general industry (29 CFR ) Electrical, wiring methods, components and equipment, general industry (29 CFR ) Powered industrial trucks, general industry (29 CFR ) Ladders, construction (29 CFR ) Electrical systems design, general requirements, general industry (29 CFR ) Machines, general requirements, general industry (machine guarding) (29 CFR )

3 Top 10 Most Accessed General Industry Standards Bloodborne Pathogens Hazard Communication Respiratory Protection Occupational Noise Exposure Powered Industrial Trucks Permit-required Confined Spaces Lockout/Tagout Hazardous Waste Operations and Emergency Response Guarding Floor and Wall Openings and Holes Personal Protective Equipment

4 Hot Topics Addressing of PELs in regulatory agenda Formaldehyde in Hair Straightening Noise in Construction Globally Harmonized System of classifying and labeling chemicals (GHS) Coal Slag Abrasives & Beryllium Exposure Methylene Chloride in bathtub refinishing

5 Chemical Safety & PELs OSHA is moving ahead on a fundamental challenge. Staff members are working hard to find a new way to address our seriously outdated Permissible Exposure Limits. In the first years of OSHA in the 1970s, we adopted these standards based on science from the 1950s and 1960s. Science has moved on, and today we know that significant danger exists at lower exposure levels than were thought almost a half-century ago. We are looking to update these standards and to find a way to more quickly establish worker protections against new chemicals as we learn about them. In June 2010, OSHA assembled a group of stakeholders to discuss options for updating the PELs. These stakeholders, from industry, labor and academia, provided OSHA with several innovative potential solutions. Then, we held a Web forum to encourage the public to nominate chemicals they believe are most hazardous for workers. We received more than 130 nominations, and these are posted on our Web site. Using those nominations, input from the OSHA field offices and other preliminary information, we have developed a draft list of 16 chemicals. To refine this list, we are working closely with NIOSH, the National Institute for Occupational Safety and Health, to refine our target list of chemicals that pose the greatest danger to America's workforce - and this list of chemical is where we will next concentrate our attention.

6 Chemical Safety and PELs OSHA's Fall 2011 semi-annual regulatory agenda, which the agency released in early 2012, includes a "Review/Lookback of OSHA Chemical Standards" to begin to address the agency's permissible exposure limits (PELs), which most safety stakeholders consider woefully out of date. A request for information, targeted for August 2012, will seek input from the public to identify additional options for addressing the outdated limits.

7 Formaldehyde Exposures in hair straightening treatments The Occupational Safety and Health Administration (OSHA) and several State OSHA programs are investigating questions and complaints from hair salon owners and workers about possible formaldehyde exposure from hair smoothing products. Some of these products have been labeled as "formaldehyde-free."

Formaldehyde Exposures in hair During Federal OSHA investigations, air tests showed formaldehyde at levels above OSHA's limits in salons using Brazilian

8 Formaldehyde Exposures in hair During Federal OSHA investigations, air tests showed formaldehyde at levels above OSHA's limits in salons using Brazilian Blowout Acai Professional Smoothing Solution, labeled "formaldehyde free," and Brasil Cacau Cadiveu, resulting in violations and citations. straightening treatments

9 Formaldehyde Exposures in hair straightening treatments OSHA continues to respond to complaints and referrals of formaldehyde exposure in salons, beauty schools and manufacturing facilities. In calendar year 2011, federal OSHA issued citations to 23 salon owners and beauty schools in Connecticut, Massachusetts, Pennsylvania, Florida, Illinois, New York, New Jersey and Ohio, with fines ranging up to $17,500 for failing to protect workers from overexposure and potential exposure to formaldehyde.

10 Noise In Construction Equipment and daily activities at construction job sites can expose workers to high levels of noise. To effective reduce exposures below 90dBA OSHA currently allows an employer to rely on any combination of Hearing protective devices w/conservation program Engineering controls Admin controls

11 GHS Proposal to modify the HCS to align with the GHS: OSHA is proposing to modify the current Hazard Communication Standard (HCS) to align with the provisions of the Globally Harmonized System of Classification and Labeling of Chemicals (GHS).

12 GHS Major proposed changes to the HCS: Hazard classification: Provides specific criteria for classification of health and physical hazards, as well as classification of mixtures. Labels: Chemical manufacturers and importers will be required to provide a label that includes a harmonized signal word, pictogram, and hazard statement for each hazard class and category. Precautionary statements must also be provided. Safety Data Sheets: Will now have a specified 16-section format. Information and training: The GHS does not address training. However, the proposed HCS will require that workers are trained within two years of the publication of the final rule to facilitate recognition and understanding of the new labels and safety data sheets

13 GHS The primary benefit is to increase the quality and consistency of information provided to workers, employers and chemical users by adopting a standardized approach to hazard classification, labels and safety data. Provides a single set of harmonized criteria for classifying chemicals according to their health and physical hazards and specifies hazard communication elements for labeling and safety data sheets. Under the GHS, labels would include signal words, pictograms, and hazard and precautionary statements and safety data sheets would have standardized format.

14 Coal Slag Greater scrutiny of coal slag abrasive manufacturers. Initiated after a complaint listing 8 abrasive manfuacturer s did not disclose beryllium in their products. Studies showing workers exposed to beryllium as high as 9.5micrograms per cubic meter. OSHA PEL is 2 micrograms per cubic meter.

15 Methylene Chloride in bathtub refinishing A review of the Integrated Management Information System (IMIS), a database for federal and state OSHA investigations, identified 12 methylene chloride related deaths associated with professional bathtub refinishing operations during Methylene chloride based stripping products usually are applied with a paint brush or aerosol can. The products cause the bathtub coating to pucker, allowing it to be easily scraped away so that a new finish can be applied. The standard mandates that air monitoring, medical surveillance, hazard communication, and personal protective equipment be in place where methylene chloride is used.

16 Rulemaking Currently open for public comments Asbestos in Construction Standard; Extension of the Office of Management and Budget s (OMB) Approval of Information Collection (Paperwork) Requirements. ACTION: Request for public comments. Docket ID: OSHA While OSHA continues to with them, it has listed rulemakings on combustible dust and diacetyl as long-term actions.

17 Rulemaking Infectious Diseases OSHA held a stakeholder meeting in July 2011 to consider the need for and shape of a potential rule A small business review of the agency's infectious diseases rulemaking is targeted for March. According to abstract, it could cover health care, emergency response, correctional facilities, homeless shelters, drug treatment programs, and other occupational settings where employees are at increased risk of exposure to infections.

18 LEPs & NEPs Primary Metal Industries Hexavalent Chromium Crystalline Silica

19 Primary Metals OSHA inspection history has shown that individuals employed in the Primary Metal Industries are exposed to serious safety and health hazards on a daily basis. Previous inspections of primary metal establishments have resulted in citations for overexposures to a wide variety of health hazards including chemical exposures in foundry operations as well as physical stressors such as noise and heat. This Instruction describes policies and procedures for implementing a National Emphasis Program (NEP) to identify and reduce or eliminate worker exposures in facilities under the Primary Metal Industries, Major Group 33 in the Standard Industrial Classification (SIC) Manual. This NEP will also heighten health and safety awareness within the affected industries of the potential for worker exposure to harmful chemical and physical hazards so that employers may voluntarily take steps to correct hazards and comply with current safety and health regulations and practices.

20 National Emphasis Program Goals. To minimize and/or eliminate worker exposure to the hazards, both physical and chemical, which are known to be present in the primary metal industries. Reduction and/or elimination of chemical exposures will help to reduce and prevent the occurrence of skin and eye injuries as well as occupational lung injury and other illnesses. Reduction of worker exposures to physical hazards will help prevent adverse effects such as hearing loss. To significantly reduce/eliminate worker overexposures to both chemical and physical stressors and, therefore, control the health hazards associated with such exposures. This goal will be accomplished by a combined effort of inspection targeting, outreach to employers, and compliance assistance. Inspections will be directed to those facilities known to manufacture primary metals and metal products.

21 Primary Metals Lead overexposure is one of the most common overexposures found in industry and is a leading cause of workplace illness. Therefore, OSHA has established the reduction of lead exposure to be a high strategic priority. OSHA's five year strategic plan sets a performance goal of a 15% reduction in the average severity of lead exposure or employee blood lead levels in selected industries and workplaces.

22 Primary Metals An inspection conducted under this LEP will focus on the hazards of working in Primary Metal Industries. The inspections will address at a minimum the following safety and health issues: Material handling and storage, including, but not limited to, the use of cranes, forklifts, conveyors and rail yards; Control of hazardous energy (such as lockout/tagout); Machine guarding; Pouring, molding, smelting, drawing and rolling operations; Operations involving equipment, such as furnaces, ovens, kettles and ladles; Fall hazards; Hazard assessments, including the selection and use of personal protective equipment (PPE), how the employer is addressing potential fire and/or explosion hazards associated with molten metal operations, and emergency action plans; Air contaminants (list of contaminants included as Appendix A); Hazards created by excessive noise; Review of all safety and health programs; and Ergonomic hazards.

23 Hexavalent Chromium Workers in many different occupations are exposed to hexavalent chromium (Cr(VI)). Occupational exposures occur mainly among workers who handle pigments containing dry chromate, spray paints and coatings containing chromate, operate chrome plating baths, and weld or cut metals containing chromium, such as stainless steel.

Hexavalent Chromium This Instruction establishes a National Emphasis Program (NEP) that focuses on the health hazards presented to workers by occupational exposure to hexavalent chromium and a number

24 Hexavalent Chromium This Instruction establishes a National Emphasis Program (NEP) that focuses on the health hazards presented to workers by occupational exposure to hexavalent chromium and a number of other toxic substances often found in conjunction with hexavalent chromium. This Instruction contains directions for identifying and inspecting workplaces where workers are likely to be exposed to hexavalent chromium and the other toxic substances, as well as relevant procedures and plans for compliance assistance.

25 HexChrome NEP Goals The purpose of this NEP is to significantly reduce the number of workers who are exposed to hexavalent chromium and the toxic substances listed in Appendix C at levels that exceed applicable OSHA permissible exposure limits (PELs) and to control the health hazards associated with such exposures. This goal will be accomplished by a combined effort of inspection targeting, outreach, and compliance assistance. Inspections will target industries and facilities that are likely to have workers exposed to the health hazards covered by this NEP. Each Region must conduct at least five (5) inspections under this NEP each year, although Regions are free to conduct more inspections, if warranted.

26 Hexavalent Chromium The OSHA workplace standard requires employers to: limit eight-hour time-weighted average CrVI exposure in the workplace to 5 micrograms or less per cubic meter of air. perform periodic monitoring at least every 6 months if initial monitoring shows employee exposure at or above the action level provide appropriate PPE when there is likely to be a hazard present from skin or eye contact. implement good personal hygiene and housekeeping practices to prevent exposure. prohibit employee rotation as a method to achieve compliance with the PEL. provide respiratory protection as specified in the standard. make available medical examinations to employees

27 CrVI and Portland Cement Portland cement is a generic term used to describe a variety of building materials valued for their strong adhesive properties when mixed with water. Employees who work with portland cement are at risk of developing skin problems, ranging from mild and brief to severe and chronic. Wet portland cement can damage the skin because it is caustic, abrasive, and absorbs moisture. Portland cement also contains trace amounts of hexavalent chromium [Cr(VI)], a toxin harmful to the skin. OSHA has established a permissible exposure limit to address the inhalation hazards of working with dry portland cement. Employers must limit airborne exposure to portland cement to 15 milligrams per cubic meter (mg/m3) of air for total dust and 5 mg/m3 for respirable dust. Because the Cr(VI) content in portland cement is so low, it is anticipated that by meeting the permissible exposure limit (PEL) of 15 mg/m3 for portland cement, employers will also meet the Cr(VI) PEL and action level of 5 and 2.5 micrograms per cubic meter (μg/m3) respectively (see ).

28 Crystalline Silica Purpose. This instruction describes policies and procedures for implementing a National Emphasis Program (NEP) to identify and reduce or eliminate the health hazards associated with occupational exposure to crystalline silica.

29 Crystalline Silica EMPHASIS PROGRAM GOALS The purpose of this NEP is to significantly reduce/eliminate employee overexposures to crystalline silica and, therefore, control the health hazards associated with such exposures. This goal will be accomplished by a combined effort of inspection targeting, outreach to employers, and compliance assistance. Inspections should be targeted to work sites that likely create high silica exposures. In each Region, at least 2 percent of inspections every year must be silica-related inspections. Additionally, the silica-related inspections should be conducted at a range of facilities reasonably representing the distribution of general industry and construction work sites in that region.

30 Crystalline Silica Two million workers are exposed to potentially hazardous levels of silica dust, mostly in the construction and sandblasting industries. Inhaling the dust causes lung cancer and silicosis, a debilitating lung disease. One year ago, the Occupational Safety and Health Administration (OSHA) submitted a proposal to the White House that would update the standard that protects workers from exposure to crystalline silica dust.

32 Heat Illness Smartphone App for Android, Blackberry and iphone.

33 Asbestos

Hazard Communication and the Globally Harmonized System (GHS) John Frowd, CAS USDOL-OSHA Manhattan Area Office

Hazard Communication and the Globally Harmonized System (GHS) John Frowd, CAS USDOL-OSHA Manhattan Area Office Frowd.john@dol.gov Brief Overview/GHS Learning Objectives Why Adopt the GHS Description of