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FREQUENTLY ASKED QUESTIONS
MEDICAL
Q: Am I required
to train my employees in CPR and First Aid? A: Probably one of the most misunderstood regulations
is the requirement to provide trained personnel to perform CPR and First
Aid. The reason for the confusion is very obvious as OSHA does not clearly
give the answer to this in the regulation. What it does state is that
"the employer shall ensure the ready availability of medical personnel
for advice and consultation . . . and in the absence of an infirmary,
clinic or hospital, a person or persons shall be adequately trained to
render first aid." 8 CCR, Section 3400 (A) and (B). Is it required to be trained on how to use an AED (Automated External Defibrillator)? A: In the state of California, legally speaking, YES!
Wihin Title 22, section 100038, it clearly states all of the training
requirements that need to be met by non-emergency personnel. Title 22
also defines the training requirements for emergency response personnel. I need to buy some disposable paper air filters for my employees to
protect them against airborne dust. When I began looking a disposable dust
masks I found N95’s, R99’s, P100’s and a bunch of other combinations of
these letters and numbers. What do all of the letters and numbers mean?
A: On July 10, 1995 a new federal regulation took effect: 42 CFR 84.
It is within this regulation (referred to as Part 84) that 9 new particulate
air filter designations were created. Particulate air filters will now be
marked with a combination of letter designations (N, R and P) and numeral
designations (95, 99 and 100). The 100’s are actually 99.97.
How small does dust have to be in order for me to inhale it? A: It is commonly believed that respirable dust is less than 10 micrometers (also known as microns). So how small is that? Consider this, a human hair is approximately 60 microns thick. If the dust is smaller than 5 microns it can get into the deepest regions of the lungs, the air sacs. If the dust is larger than 10 microns it has a greater likelihood of being capture in the upper regions of the lungs. Do I have to fit test my employees that use disposable dust masks A: It depends. If the employee is wearing the dust mask because the amount of dust exceeds the OSHA Permissible Exposure Limit (PEL), then a fit test is required since the dust mask is a respirator. If the employee is wearing the dust mask to protect against dust levels below the PEL, than the answer could be “no.” It should be noted here, whenever respiratory protection is to be used, the substance to be protected against and it’s airborne concentration should be known. Also, this exception only applies to dust masks, not other types of respirators which are also worn voluntarily. OSHA actually has requirements for those who wear respirators in a voluntary basis. If I give my employee a dust mask to wear in dusty areas of our
operation, why do I have to know the airborne concentration of the dust?
A: OSHA has established a Permissible Exposure Limit (PEL) for nuisance dusts, the kind that we most often encounter. If the amount of dust that an employee is exposed to exceeds the PEL, the use of a NIOSH-approved respirator is required, which would then mean the implementation of a Respiratory Protection Program. If the measured concentration is below the PEL, then respiratory protection is not required, therefore, neither is a Respiratory Protection Program. Additionally, different kinds of dusts have different PELs and different sizes of particles, so knowing what kind of dust is in the air is required in order to know which type of respirator is required. Q: I hear a lot about lead poisoning at work. Where can lead be found in the workplace? A: Today, the workplace is much safer than it used to be concerning levels of lead. This is due to two factors. First, lead has been phased out of many products that used to contain the material. Second, for many years a lot of work has been done to remove lead that was placed there in the first place. However, lead is insidious. That means that it is hard to get rid of. This is true both in the workplace and in your body and that makes it dangerous. Lead can still be found in old paint, lead pipes, solder, and in lead contaminated soil. The good news is that if you take a few basic steps to determine the presence of lead and wear protective equipment when required, you can significantly reduce the chance of lead poisoning on the job. Q: I have been told that lead poisoning can be fatal. Is this true? A: Like many chemicals, the health effects caused by lead depend on the dose. That is, how much you are exposed to and for how long. Another factor is how the material gets into your body. Lead is an inhalation hazard and an ingestion hazard. Lead on your skin poses little threat. If lead does get in your body, symptoms of lead poisoning can range from loss of appetite, a metallic taste in your mouth, to numbness, dizziness and even impotence and sterility. It takes a very large amount to be fatal, but a lesser amount to cause some of the other symptoms. To determine how bad is bad, the Occupational Safety and Health Administration (OSHA) has established a Permissible Exposure Limit (PEL) of 50 micrograms per cubic meter. If you stay below this level, it is expected that no adverse effect should occur and protective equipment is recommended but not required. GENERAL
REGULATORY
Obviously, we do not/can not
train people in all of the functions that could occur in the shipment
of hazardous materials. For example, the proper loading of rail cars,
tank vehicles, etc. cannot be done online as this is a skills training
issue which requires that they demonstrate competency in a manipulative
manner. Most organizations generally already provide this training to
their employees in the course of their in house training programs. If
this is well documented, it would supplement the certification that we
provide and likely satisfy the DOT requirements. Once federal OSHA issues new rules, the rules go into
effect on the effective date of the regulation. For those state-plan-states,
the rules may be modified to be more restrictive. Generally, a state
has up to 180 days to adopt their version of the new federal regulation.
In
many cases, they adopt the federal regulations verbatim and do not modify
it. In some states, such as California, the state OSHA often makes rules
more restrictive than the federal counterpart.
A: Like most other regulatory agencies, OSHA at either the state or federal levels does not have the necessary staff to visit all organizations on a regular basis. For this reason, they selectively enforce the regulations and visit sites under some relatively standard conditions. These include:
Q: What does OSHA have to do with other federal and state agencies? A: OSHA is just one of a whole range of governmental regulators who have an impact on your organization. Like the IRS who regulates taxes, OSHA also has specific areas of responsibility. Here is the long and the short of it when it comes to regulators.
Q: What does it mean to be certified and who actually does the certification? A: As a general rule OSHA does not certify employees, trainers, or training programs. OSHA sets the rules and technically it is the employer who has the responsibility to "certify" that their staff has complied with the applicable OSHA regulations. A certificate is issued by an employer or by a training firm used by that employer to attest to the fact that certain things have been accomplished. Anyone can "certify" someone since OSHA does not. Ultimately, it is the employer who must ensure that the regulations have been met and it is the employer who issues the certificate to document this. The certificate may be nothing more than a piece of paper which documents that training or compliance with a regulation has occurred. Q: What does OSHA say about the various ways to obtain training? For example, can we use video tapes or computer-based training in lieu of traditional training programs?
So once you know what training is required, how do
you know how to accomplish the training? Again, OSHA does not provide
specificity here and relies on the employer to ensure that the training
is done. For the employer, there are a number of options available.
There
are video tapes, computer discs, and even Internet-based courses available.
These along with the traditional types of training programs leave the
options wide open. Unfortunately, not all training programs are created
equal and OSHA expects that we know how best to accomplish the required
training.
Q: I took a General Site Worker Hazwoper course in May 2002. I was unable to take a refresher course in 2003. Do I have to retake the full 40 hour course? A: According to the regulations, after you take a Hazwoper course, you have 365 days, or one year to take a refresher course. The bad news is that after the 365th day, you are no longer certified to work as a General Site Worker. The good news is that OSHA realizes that you probably did not forget everything you had learned during your original course. You have an additional 365 days before you have to retake the full course, and until May of 2002, you can still take the 8 hour refresher course. Q: Our company is looking into the purchase of an electronic, computer-based MSDS system. Will that satisfy the regulations? A: While the regulations stipulate that your material safety data sheets (MSDSs) be easily accessible to employees, they do not say how they must be filed. Electronic data systems are acceptable as long as there is a back-up system in case of power failures, and they can be accessed by all shifts. Of course, training would have to be provided to the employees on how to access and read the MSDS. Q: I have a small landscaping business with 12 employees. Do I need an Injury and Illness Prevention Program? And if I do need one, how often do they need to be updated? A: Actually, the answer to whether or not you are required
to have a written Injury and Illness Prevention Program (IIPP) depends
on where you live. In California, every employer with more than 10 employees
must
develop and implement a
written IIPP. This document must be maintained current and not just sit on the
shelf. Other states have similar requirements and federal OSHA
is looking at implementing something as well. Q: I need to provide Hazard Communication training to my employees. Do generic Hazard Communication programs meet OSHA requirements? A: Though generic or packaged courses can supplement other courses they won't fully satisfy OSHA's requirements. As an employer you are obligated to provide this training specific to your hazards and the best way to do this would be a course specifically designed to address the topic. This could be an expanded version of a Hazard Communication course (Right to Know), reviewing the specific MSDS and the hazards noted. Terms and definitions related to the materials would also be covered in this. Q: Why do you need various types of Hazwoper refresher courses? A:The reason we have more than one refresher is that OSHA essentially requires that all training received by employees be job specific. We can see that in the HAZWOPER regulations CFR 1910.120 (e) (2), there is a list of all materials to be covered in a HAZWOPER waste worker course. Three of the items listed are as follows:
As you can see by these requirements, OSHA requires that hazardous waste employees receive training on hazards that are presented by their specific job function and that they be trained on ways to minimize those hazards. With the wide array of job functions and hazards presented by these job functions in the industrial field, it would be virtually impossible to cover all known chemical hazards in one course. Even so, if such a course were possible, would a worker at a sulfuric acid regeneration plant need to know the hazards that a worker at a wastewater treatment facility would encounter? No. They only need to know about the hazards that are presented at their site and by their work practices. This necessitates a variety of courses to meet the variety of needs encountered in today's industrial world. Q: Does OSHA require that I mount a fire extinguisher in my building? A: Yes, numerous codes and regulations including OSHA, the Fire Code and NFPA standards dictate the types and locations of fire extinguishers that should be found in most workplaces. The types and locations of these vary. For more information on fire extinguishers go to: http://www.hanford.gov/fire/safety/extingrs.htm. Q: I just completed the initial HAZWOPER site worker course and was wondering if I need to take an additional DOT course in order to sign hazardous waste manifests for shipment. A: Yes, you will have to take the additional DOT course in order to comply with 49 CFR 172.704 subpart H. Sometimes multiple agencies have jurisdiction on the activities we do in our business and they may all require specific training for the function they regulate, even if some of the training is redundant. The good news is that you will have an easier time in the DOT class now that you have the background of the HAZWOPER course, as some of the required topics are the same for both courses. Q: I'm looking in to taking your 40 hour HAZWOPER course. Would that qualify me to be an emergency responder to hazmat spills? A: No. This is an area of confusion and for good reason. After all, the acronym HAZWOPER means hazardous waste operations and emergency response. Most people assume if they take the popular 40 hour HAZWOPER course they are qualified in the emergency response portion.
To each type of personnel, different sections of the regulation are assigned: to the General Hazardous Waste Site Worker’s sections (a) through (o) are applicable; to the TSDF workers only section (p) is applicable; and to the hazmat emergency responders, section (q) is applicable. Each of the three personnel have their own regulations regarding operations and training, which makes sense since the knowledge that one would need to work at a hazardous waste cleanup site would be different than a hazmat team would need in responding to an emergency. Q: I was told by a local regulator that I need a Hazardous Materials Business Plan (HMBP). What is this and what are the requirements? A: Certain states use the HMBP to fulfill the community Right to Know requirements. This is a document that lists your chemicals and how they are stored along with the programs that you have in place to protect yourself and the community. While the requirements may vary, you will generally need an HMBP if you possess any one hazardous material or hazardous waste in an amount equal to or greater than 55 gallons for liquids, 500 lbs. for solids, or 200 cubic feet at Standard Temperature and Pressure for gases. Q: I think I need a Spill Prevention Control and Countermeasure (SPCC) plan. What are the requirements? A: You will need an SPCC if you store greater than 1,320 gallons of oil product above ground. Q: Do I need a Spill Prevention Control and Countermeasure (SPCC) plan if my tank is underground? A: Not as of July 17, 2002. The EPA revised the SPCC requirements on this date. Underground Storage Tanks (UST’s) will be covered by the various underground tank regulations only. Q: What is considered to be "oil-product" as it relates to Spill Prevention Control and Countermeasure (SPCC) plans? A: Oil product is defined as, "oil of any kind or in any form, including but not limited to petroleum, fuel oil, sludge, oil refuse and oil mixed with wastes other then dredged spoil and oily mixtures." This also includes, but is not limited to, non-petroleum oils, synthetic, mineral, animal, and vegetable oils. Q: What postings are required to be displayed at my worksite? A: There are several postings you are required to display. A list of them can be found at the California Department Of Industrial Relations-Workplace Settings. Q: I supervise an accounting department where we spend many hours a day at computer workstations performing data entry. Someone mentioned they had some pain in their wrists and forearms. How can I help this person and the rest of the staff from incurring on-the-job injuries? A: Working all day on a computer seems like a job with few safety hazards. Unfortunately, statistics show that there are some inherent hazards in the repetitive motions as simple as typing or frequently scrolling and moving a mouse. The good news is that there are some things you can do to limit the possibilities of ergonomic related injuries. Here are a few suggestions:
Q: Why is there a difference between international and domestic hazard classes for shipping hazardous materials? For example, internationally ammonia is listed as a 2.3, toxic gas, hazard class while the DOT regulation lists ammonia as 2.2, non-flammable gas. A: Whenever we deal with regulatory bodies that are government based we have to realize that they can be swayed by public interest groups and lobbyists. Ammonia is a good example of this. Anhydrous ammonia is highly toxic, has twice the flammable range as gasoline, and is extremely corrosive. Even still DOT lists it as a 2.2 non-flammable gas for all domestic shipments because ammonia is a very common chemical, used in many industries such as farming and household cleaners. This is a good lesson to learn: safety based on compliance only to regulations is not always the safest method! Q: What is UN specification packaging? For example, on a steel drum is the UN symbol (circle with UN in it) and then “1A2/X114/S”. What does it all mean? A: Actually, the UN specification packaging is part of an international system of ensuring the quality of packaging materials for transport. It is helpful when determining proper packaging needs for specific materials. Let's look at your example:
The UN specifications can have other symbols as well to indicate such things as faulty packaging, which country it was made in, etc. Most times we should refer to manufacturer specifications if we have questions about whether the package we're using is good for the materials we need to ship. Q: What does the abbreviation “n.o.s.” in a DOT hazardous material proper shipping name mean? And what about “n.o.i.” and “n.o.i.b.n.”? A:
If you look in the DOT regulations under the definitions section, 49 CFR 171.8,
you will find that the definition of n.o.s.
is "not otherwise specified". This abbreviation is used for chemicals that are either mixtures of hazardous materials or
possibly new hazardous materials that have not been give their own proper shipping name. What they put instead is a description
of the hazards of the material (e.g. Corrosive, acidic, inorganic n.o.s.). For new materials the use of n.o.s. is only temporary
until an official number has been assigned.
Q: Who is IATA and what is their relation to hazmat shipping? A: The International Air Transport Organization, or IATA,
is a group of air carriers and shippers that formed an organization in order
to promote safer practices for air transportation, much like the National
Fire Protection Association does in the area of fire and building code standards
development. Also, like the NFPA, IATA publishes standards for their safe
practices, in particular for the transportation of hazardous materials (called
dangerous goods) internationally, in its Dangerous Goods Regulations, or
DGR. The DGR is not enforceable by law by itself, but the DGR is in compliance
with another organizations regulations, the Technical Instructions for the
Shipment of Dangerous Goods, put out by the International Civil Aviation
Organization, or ICAO. ICAO is a United Nations organization and thus has
an international rule of law to back it up. So if you are shipping in compliance
with IATA regulations you are essentially in compliance with ICAO regulations.
Q: I work for a plumbing company and on the way to jobs we carry materials that would be considered hazardous. Someone told us that before transporting any hazardous materials we need to have DOT training. Is this true? A: The good news is that no, it is not true in this case. The Department of Transportation has identified some materials as Materials of Trades, or MOTs, which are any materials transported in small quantities as part of a business that fall under any one of the three following definitions:
Any materials that fall under these definitions and under certain packaging and quantity limitations can be shipped without a lot of the restrictions that a normal hazardous material would get, including training requirements for shippers. Q: I received an email warning about static electricity and cell phones starting fires at gas stations. Is it true? A: The Petroleum Equipment Institute (PEI) investigates
incidents of fires at gas stations, most of which are a result of someone
smoking a cigarette, a car engine being left on, or a lack of electrical
continuity between the nozzle and the gasoline dispenser. However, in
recent years there has been an upsurge in the number
of gas station fires that are believed to be caused by static electricity.
There is not much to worry about though. Of the 16 to 18 billions of
times people go to the pumps every year less than 100 possible cases
of fires due
to static electricity
have occurred. The PEI suggests that in order to avoid getting static
electricity buildup that you not get back in your car while re-fueling.
Getting in your car can create static buildup which can create an ignition
source
for any leaked gasoline
vapors. If you need to go back into your car during re-fueling touch
the metal part of your car that is not near the fuel tank area. This
will dissipate any static charge that you may have built up. Q: I've heard some talk about a new class of fires, other than the traditional A, B, C, and D. What can you tell me about that? A: The NFPA has recently classified a new type of fire
and fire extinguisher. Most people are aware of the class A, ordinary
combustibles, class B, flammable liquids, class C, electrical fires, and
class D, combustible metals, but the new classification of fire is class
K, which involve “fires in cooking appliances that involve combustible
cooking media (vegetable or animal oils and fats)”-(NFPA 10-4). Q: I am starting a job that will require me to clean up crime scenes, such as old meth labs, and scenes of violent crimes, after the police have collected evidence. What kind of training do I need? A: The answer
to this question will vary from area to area. Most states consider old
drug labs to be hazardous waste sites, and for good reason because of
the chemicals that could be on site. If this is the case then your work
would fall under the
HAZWOPER (hazardous waste operations and emergency response) regulation,
which would require a couple of different trainings. You should
check with your local law enforcement agency to determine if this is
the case. Q: I am a working towards becoming a fire fighter. Are there any courses you can offer me that could help me to get an edge against the competition? A: Getting
your foot in the door of the fire service can be difficult at times and
any extra training or qualities that you can have beforehand could give
you a head above the rest of the applicants. For courses we offer you
should consider taking one of our hazardous materials emergency response
courses, specifically the First Responder Operations, or FRO, level under
29 CFR 1910.120(q). This is the level of response most fire fighters
are
trained to for hazmat response and it will give you a head start in this
area. All of our courses satisfy the OSHA regulations so you’re
in good hands with us. You may also consider one of the other levels
of response,
possibly even an Incident Commander course, to give you an even further
edge above the competition. We have a number of emergency response courses
online inlcuding Incident Commander. Q: What can you tell me about that gas that was used during the hostage situation in Russia? A: The gas that was used was a derivative of the substance
fentanyl. Fentanyl is an opiate-based narcotic 100 times more powerful
than morphine that is used for pain relief in surgeries. In the United
States it is
the most common narcotic used for anesthesia. Fentanyl can cause extreme
drowsiness but in America it is mostly used to stop breathing during
surgery when breathing is mechanically supported. For this reason, high
doses of fentanyl alone
can be fatal, according to the Center for Disease Control. |
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A:
This is a difficult question to answer in a general way since the topic
is a bit confusing even to OSHA. On both the state and federal levels,
OSHA establishes a range of regulations covering a variety of industries
and operations. They generally include such lists as the General Industry
Safety Orders which are used by almost everyone, Construction Industry
Safety Orders which apply when major construction activity takes place,
Electrical Safety Orders for activities involving electrical work, and
more. This can be very confusing for many people
but the basic application of the rules is generally spelled out in the
first
section
of each group of rules. If you have questions, email us and we can help
you with this.
A:
OSHA does not endorse nor specify any particular training
program. OSHA generally does not specify a particular
number of hours that would be required to be certified to do a particular
thing. When you read most OSHA regulations, the regulation will
not necessarily specify an amount of training, only that training is
required.