Category: Management

Calculations:

OSHA Recordable Incident Rate (IR)

The OSHA Recordable Incident Rate (or Incident Rate) is calculated by multiplying the number of recordable cases by 200,000, and then dividing that number by the number of labor hours at the company.

Number of OSHA Recordable Cases X 200,000
        IR = ———————————————————–
Number of Employee labor hours worked

Lost Time Case Rate (LTC)

The Lost Time Case Rate is a similar calculation, only it uses the number of cases that contained lost work days. The calculation is made by multiplying the number of incidents that were lost time cases by 200,000 and then dividing that by the employee labor hours at the company.

Number of Lost Time Cases x 200,000
        LTC Rate = —————————————————–
Number of Employee Labor Hours Worked

DART Rate (Days Away/Restricted or Job Transfer Rate)

The DART rate is relatively new to industry. This rate is calculated by adding up the number of incidents that had one or more Lost Days, one or more Restricted Days or that resulted in an employee transferring to a different job within the company, and multiplying that number by 200,000, then dividing that number by the number of employee labor hours at the company.

Total Number of DART incidents x 200,000
DART Rate = —————————————————–
Number of Employee Labor Hours Worked

Severity Rate (SR)

The severity rate is a calculation that gives a company an average of the number of lost days per recordable incident. Please note, that very few companies use the severity rate as a calculation, as it only provides an average. The calculation is made by dividing the total number of lost workdays by the total number of recordable incidents.
Total number lost workdays
SR =   ———————————————
Total number of recordable incidents

The records and statistics covers the recording and treatment of data necessary for the computation of incident and injury rates of employees, and forms a general basis for analysis of the reported incident and injuries. This information will then be utilized to examine the safety and health program, which may assist in the identification of trends and what measures should be undertaken to improve incident prevention.

SAMPLE DATA

Number of Employees:                                                  47

(all hourly and salaried personnel)

Number of hours per week:         111,935 (50 hours/week)

Number of lost time injuries:                                         5

(employee unable to work on next scheduled workday) 

Number of days lost:                                                     81

(scheduled workdays – not counting day of injury)

Number of licensed units:                                            36

(spares, autos, pick-ups and revenue producing)

Number of Vehicle Accidents:                                       25

(any claim or damage involving a licensed unit)

Number of OSHA Recordable Cases:                            18

(total cases on OSHA log)

Number of light duty days                                             10

A.  Lost-Time Injury Frequency Rate  

                       No of Lost-Time Injuries x 200,000 

      Formula: ————————————————                                                                                               

Total Hours Worked

                                5 x 200,000

     Sample Data: ————————                                                                        111,935

      Frequency Rate:     8.93

Based on 5 lost-time injuries for 111,935 hours of exposure, this company would experience 8.93 lost-time injuries by the time they reached 200,000 hours. Note: 200,000 hours represents the equivalent of 100 employees working 1 full year.

B.  Lost-Time Injury Severity Rate                           

                        No of Work Days Lost x 200,000 

       Formula: ——————————————–
Total Hours Worked 

                                    18 x 200,000

      Sample Data: ————————-
111,935

       Severity Rate:           32.16

Based on 81 lost workdays for 111,935 hours of exposure, this company would experience 145 days lost by the time they reached 200,000 hours.

C. OSHA Recordable Frequency rate:

                         No of recordable injuries/illness x 200,000

        Formula: ———————————————————
Total Hours Worked 

                                     81 x 200,000 

       Sample Data:  ————————
111,935

       Frequency Rate:   144.73

Based on 91 lost and light duty workdays for 111,935 hours of exposure, this district would experience 162.59 lost and light duty workdays by the time they reached 200,000 hours.

D.  OSHA Recordable Severity Rate                     

                          ( No of work days lost + light duty days lost) x 200,000

         Formula: ————————————————————————-

Total Hours Worked

                                   (81 + 10) x 200,000

         Sample Data: —————————– 

                                         111,935

        Frequency Rate:     162,59

Based on 18 OSHA recordable cases for 111,935 hours of exposure, this company would experience 32.16 OSHA recordable injuries/illnesses by the time they reached 200,000 hours.

METHODS

The method of calculating FR and SR varies from country to country.  Further, in all those calculations, minor injuries or first-aid incidents involving few human-hours lost are not considered. The objective of this paper is to devise a formula which can be applied universally, taking into account all the human-hours lost and to benchmark it within industrial sectors or on a national level. Further, to benchmark occupational safety and health management between workplaces and even among countries, a universal safety performance factor (SPF) or indicator is required.

Singapore

Singapore’s Ministry of Manpower defines FR as the number of accidents / one million human-hours worked (i.e., FR = number of industrial accidents reported per number of human-hours worked) × 1 000000). SR is the number of industrial human-days lost per one million human-hours worked (i.e., SR = number of reported human-days lost × 1000000/number of human-hours worked).

USA

The U.S. Occupational Safety and Health Administration defines incidence rate as the number of injuries/illnesses × 200000/employee-hours worked, where 200000 represents the equivalent of 100 employees working for 40 hrs per week, 50 weeks per year. SR is the total number of lost workdays per year × 200000 work hrs/number of workers in a job (or a department) × 2000 hrs. Incidence rate is usually expressed as the number of cases per 100 workers per year.

Korea

The Korea Occupational Safety and Health Agency defines accident rate as the number of workers covered by the industrial accident compensation insurance act × 100, fatality rate as the number of workers covered by the industrial accident compensation insurance act × 10000, morbidity rate as the number of workers covered by the industrial accident compensation insurance act × 1000 and SR as (work days lost/annual hours worked) × 1000.

Japan

The Japan Industrial Safety and Health Administration [6] defines an occupational accident as death, injury or disease suffered by a worker due to causes attributable to buildings, equipment, raw materials, gases, vapors, dust and other phenomenon related to work or as a result of a worker’s conduct while he/she is at work. Accidents while commuting to and from work are not included. Further, the Administration defines a serious accident as an accident that results in three or more deaths or injuries. Annual accident rate per 1000 workers is defined as the total number of casualties in one year × 1000/average number of workers in one year. Accident frequency rate is defined as the number of deaths and injuries in occupational accidents × 1000000/aggregate number of human-hours, and accident severity as the number of workdays lost rate × 1000000/aggregate number of human-hours. Further, the number of workdays lost is computed based on 300 work days per year.

UK

The UK’s Health and Safety Executive defines lost time accidents as those that result in more than one day of lost time and FR is based on a 12-month rolling period and is calculated per 100 000 hrs worked.

SPF

After analyzing the traditional method of calculating FR and SR, a new definition for SPF is devised:

total man-hours lost

            SPF = —————————————

                      total number of incidents lost

Calculating SPF—lost time per number of incidents—is a reliable and simple tool, which clearly spells out the company’s safety culture and performance. This formula is easy to calculate and does not depend on the number of employees. However, reporting accidents has to continue. The SPR is only a guide to computing a company’s safety performance and to bench marking it against any industrial sectors or national or international organizations.

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PSM Elements:

Specified minimum elements that the OSHA standard requires employers to do:

1. Develop and maintain written safety information identifying workplace chemical and process hazards, equipment used in the processes, and technology used in the processes;

2. Perform a workplace hazard assessment, including, as appropriate, identification of potential sources of accidental releases, identification of any previous release within the facility that had a potential for catastrophic consequences in the workplace, estimation of workplace effects of a range of releases, and estimation of the health and safety effects of such a range on employees;

3. Consult with employees and their representatives on the development and conduct of hazard assessments and the development of chemical accident prevention plans and provide access to these and other records required under the standard;

4. Establish a system to respond to the workplace hazard assessment findings, which shall address prevention, mitigation, and emergency responses;

5. Review periodically the workplace hazard assessment and response system;

6. Develop and implement written operating procedures for the chemical processes, including procedures for each operating phase, operating limitations, and safety and health considerations;

7. Provide written safety and operating information for employees and employee training in operating procedures, by emphasizing hazards and safe practices that must be developed and made available; 8. Ensure contractors and contract employees are provided with appropriate information and training;

9. Train and educate employees and contractors in emergency response procedures in a manner as comprehensive and effective as that required by the regulation promulgated pursuant to section 126(d) of the Superfund Amendments and Reauthorization Act;

10. Establish a quality assurance program to ensure that initial process-related equipment, maintenance materials, and spare parts are fabricated and installed consistent with design specifications;

11. Establish maintenance systems for critical process-related equipment, including written procedures, employee training, appropriate inspections, and testing of such equipment to ensure ongoing mechanical integrity;

12. Conduct pre-startup safety reviews of all newly installed or modified equipment;

13. Establish and implement written procedures managing change to process chemicals, technology, equipment and facilities, and

14. Investigate every incident that results in or could have resulted in a major accident in the workplace, with any findings to be reviewed by operating personnel and modifications made, if appropriate.

PROCESS SAFETY INFORMATION:

Employers must complete a compilation of written process safety information before conducting any process hazard analysis required by the standard. The compilation of written process safety information, completed under the same schedule required for process hazard analyses, will help the employer and the employees involved in operating the process to identify and understand the hazards posed by those processes involving highly hazardous chemicals. Process safety information must include information on the hazards of the highly hazardous chemicals used or produced by the process, information on the technology of the process, and information on the equipment in the process. Information on the hazards of the highly hazardous chemicals in the process shall consist of at least the following:

• Toxicity,

• Permissible exposure limits,

• Physical data,

• Reactivity data,

• Corrosivity data, and

• Thermal and chemical stability data, and hazardous effects of inadvertent mixing of different materials. Information on the technology of the process must include at least the following:

• A block flow diagram or simplified process flow diagram,

• Process chemistry,

• Maximum intended inventory,

• Safe upper and lower limits for such items as temperatures, pressures, flows or compositions, and • An evaluation of the consequences of deviations, including those affecting the safety and health of employees. Where the original technical information no longer exists, such information may be developed in conjunction with the process hazard analysis in sufficient detail to support the analysis. Information on the equipment in the process must include the following:

• Materials of construction,

• Piping and instrument diagrams (P&lDs),

• Electrical classification,

• Relief system design and design basis,

• Ventilation system design,

• Design codes and standards employed,

• Material and energy balances for processes built after May 26, 1992, and

• Safety systems (e.g., interlocks, detection or suppression systems) .

The employer shall document that equipment complies with recognized and generally accepted good engineering practices. For existing equipment designed and constructed in accordance with codes, standards, or practices that are no longer in general use, the employer shall determine and document that the equipment is designed, maintained, inspected, tested, and operated in a safe manner. The compilation of the above described process safety information provides the basis for identifying and understanding the hazards of a process and is necessary in developing the process hazard analysis and may be necessary for complying with other provisions of PSM such as management of change and incident investigations.

PROCESS HAZARD ANALYSIS:

The process hazard analysis is a thorough, orderly, systematic approach for identifying, evaluating, and controlling the hazards of processes involving highly hazardous chemicals. The employer must perform an initial process hazard analysis (hazard evaluation) on all processes covered by this standard. The process hazard analysis methodology selected must be appropriate to the complexity of the process and must identify, evaluate, and control the hazards involved in the process. First, employers must determine and document the priority order for conducting process hazard analyses based on a rationale that includes such considerations as the extent of the process hazards, the number of potentially affected employees, the age of the process, and the operating history of the process. All process hazard analyses must be updated and revalidated, based on their completion date, at least every 5 years. The employer must use one or more of the following methods, as appropriate, to determine and evaluate the hazards of the process being analyzed:

• What-if,

• Checklist,

• What-lf/checklist,

• Hazard and operability study (HAZOP),

• Failure mode and effects analysis (FMEA),

• Fault tree analysis, or

• An appropriate equivalent methodology. Whichever method(s) are used, the process hazard analysis must address the following:

• The hazards of the process;

• The identification of any previous incident that had a potential for catastrophic consequences in the workplace;

• Engineering and administrative controls applicable to the hazards and their interrelationships, such as appropriate application of detection methodologies to provide early warning of releases. Acceptable detection methods might include process monitoring and control instrumentation with alarms, and detection hardware such as hydrocarbon sensors;

• Consequences of failure of engineering and administrative controls;

• Facility siting;

•Human factors; and

• A qualitative evaluation of a range of the possible safety and health effects on employees in the workplace if there is a failure of controls.

OSHA believes that the process hazard analysis is best performed by a team with expertise in engineering and process operations, and that the team should include at least one employee who has experience with and knowledge of the process being evaluated. Also, one member of the team must be knowledgeable in the specific analysis methods being used.

The employer must establish a system to address promptly the team’s findings and recommendations; ensure that the recommendations are resolved in a timely manner and that the resolutions are documented; document what actions are to be taken; develop a written schedule of when these actions are to be completed; complete actions as soon as possible; and communicate the actions to operating, maintenance, and other employees whose work assignments are in the process and who may be affected by the recommendations or actions.

At least every 5 years after the completion of the initial process hazard analysis, the process hazard analysis must be updated and revalidated by a team meeting the standard’s requirements to ensure that the hazard analysis is consistent with the current process.

Employers must keep on file and make available to OSHA, on request, process hazard analyses and updates or revalidation for each process covered by PSM, as well as the documented resolution of recommendations, for the life of the process.

OPERATING PROCEDURES

The employer must develop and implement written operating procedures, consistent with the process safety information, that provide clear instructions for safely conducting activities involved in each covered process. OSHA believes that tasks and procedures related to the covered process must be appropriate, clear, consistent, and most importantly, well communicated to employees. The procedures must address at least the following elements: Steps for each operating phase:

• Initial startup;

• Normal operations;

• Temporary operations;

• Emergency shutdown, including the conditions under which emergency shutdown is required, and the assignment of shutdown responsibility to qualified operators to ensure that emergency shutdown is executed in a safe and timely manner;

• Emergency operations;

• Normal shutdown; and

• Startup following a turnaround, or after an emergency shutdown. Operating limits:

• Consequences of deviation, and

• Steps required to correct or avoid deviation. Safety and health considerations:

• Properties of, and hazards presented by, the chemicals used in the process;

• Precautions necessary to prevent exposure, including engineering controls, administrative controls, and personal protective equipment;

• Control measures to be taken if physical contact or airborne exposure occurs;

• Quality control for raw materials and control of hazardous chemical inventory levels; and

• Any special or unique hazards.

• Safety systems (e.g., interlocks, detection or suppression systems) and their functions.

To ensure that a ready and up-to-date reference is available, and to form a foundation for needed employee training, operating procedures must be readily accessible to employees who work in or maintain a process. The operating procedures must be reviewed as often as necessary to ensure that they reflect current operating practices, including changes in process chemicals, technology, and equipment, and facilities.

To guard against outdated or inaccurate operating procedures, the employer must certify annually that these operating procedures are current and accurate. The employer must develop and implement safe work practices to provide for the control of hazards during work activities such as lockout/tagout; confined space entry; opening process equipment or piping; and control over entrance into a facility by maintenance, contractor, laboratory, or other support personnel.

These safe work practices must apply both to employees and to contractor employees.

Overview

Lead overexposure is one of the most common over exposures found in industry and is a leading cause of workplace illness. The reduction of lead exposure is a high strategic priority. OSHA 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.

Process, Control & Technical Information:

The following information that describes facility specific information concerning processes and controls are maintained as an addendum to this written program:

a. Description of each operation in which lead is emitted; e.g. machinery used, material processed, controls in place, crew size, employee job responsibilities, operating procedures and maintenance practices.

b. Description of the specific means used to achieve compliance, including engineering plans and studies used to determine methods selected for controlling exposure to lead.

c. Report of the technology considered in meeting the permissible exposure limit;

d. Air monitoring data which documents the source of lead emissions;

e. A detailed schedule for implementation of this program, including documentation such as copies of purchase orders for equipment, construction contracts, etc.

f. Records of Employee Training and Notifications

g. Specific work practice program and controls for each operation involving lead exposure

h. Administrative control schedule

i. All other relevant information

Hazards:

Pure lead (Pb) is a heavy metal at room temperature and pressure and is a basic chemical element. It can combine with various other substances to form numerous lead compounds. The Permissible Exposure Limit (PEL) set by OSHA is 50 micro grams of lead per cubic meter of air (50 ug/m(3)), averaged over an 8-hour workday.Lead can be absorbed by inhalation (breathing) and ingestion (eating). Lead is not absorbed through your skin. When lead is scattered in the air as a dust, fume or mist it can be inhaled and absorbed through the lungs and upper respiratory tract. Lead can also be absorbed through the digestive system if swallowed. Handling food, cigarettes, chewing tobacco, or make-up which have lead contamination or handling them with hands contaminated with lead, will contribute to ingestion.A significant portion of inhaled or ingested lead goes into the blood stream. Once in the blood stream, lead is circulated throughout the body and stored in various organs and body tissues. Some of this lead is quickly filtered out of the body and excreted, but some remains in the blood and other tissues. As exposure to lead continues, the amount stored in the body will increase. Lead stored in body tissues can cause irreversible damage, first to individual cells, then to organs and whole body systems.

Short-term (acute) effects of overexposure to lead:

Lead is a potent, systemic poison. Taken in large enough doses, lead can kill in a matter of days. A condition affecting the brain called acute encephalitic may arise which develops quickly to seizures, coma, and death from cardio respiratory arrest. There is no sharp dividing line between rapidly developing acute effects of lead, and chronic effects which take longer to acquire. Lead adversely affects numerous body systems, and causes forms of health impairment and disease which arise after periods of exposure as short as days or as long as several years.

Long-term (chronic) effective of overexposure to lead:

Chronic overexposure to lead may result in severe damage to blood-forming, nervous, urinary and reproductive systems. Some common symptoms of chronic overexposure include loss of appetite, metallic taste in the mouth, anxiety, constipation, nausea, pallor, excessive tiredness, weakness, insomnia, headache, nervous irritability, muscle and joint pain or soreness, fine tremors, numbness, dizziness, hyperactivity and colic. In lead colic there may be severe abdominal pain.

Monitoring:

Initial determination.

The company has made an initial determination of lead work areas and exposure levels and will conduct subsequent “initial determinations” in the event of changes to hazard control methods or operational processes that affect employee or environmental exposure. Initial determinations are conducted to determine if any employee may be exposed to lead at or above the action level of 30 micro grams per cubic meter of air (30 ug/m(3)) averaged over an 8-hour period.

Where a determination is made that no employee is exposed to airborne concentrations of lead at or above the action level, the company shall maintain a written record. The record shall include quantitative sampling data, date of determination, location within the work site, and the name and social security number of each employee monitored.

Monitoring requirements:

• Monitoring and analysis methods shall have an accuracy (to a confidence level of 95%) of not less than plus or minus 20 percent for airborne concentrations of lead equal to or greater than 30 ug/m(3).

• Where a determination shows the possibility of any employee exposure at or above the action level, the company shall conduct monitoring which is representative of the exposure for each employee in the workplace or process area who is exposed to lead.

• For the purposes of monitoring requirements, employee exposure is that exposure which would occur if the employee were not using a respirator.

• Monitoring and sample collection shall cover full shift (for at least 7 continuous hours) personal samples including at least one sample for each shift for each job classification in each work area.

• Full shift personal samples must be representative of the monitored employee’s regular, daily exposure to lead.

Monitoring Frequency:

At or Above Action Level and Below PEL:

Every 6 months ff the initial determination or subsequent monitoring reveals employee exposure to be at or above the action level but below the permissible exposure limit. This monitoring (6 month frequency) will continue until at least two consecutive measurements, taken at least 7 days apart, are below the action level.

Above PEL:

If the initial monitoring reveals that employee exposure is above the permissible exposure limit the company will repeat monitoring quarterly. Quarterly monitoring will continue until at least two consecutive measurements, taken at least 7 days apart, are below the PEL but at or above the action level.

Additional monitoring:

Whenever there has been a production, process, control or personnel change which may result in new or additional exposure to lead, or whenever any other reason to suspect a change which may result in new or additional exposures to lead, additional monitoring will be conducted.

Employee Notification of Monitoring Results:

Within 5 working days after the receipt of monitoring results, each employee will be notified in writing of the results which represent that employee’s exposure.Whenever the results indicate that the representative employee exposure, without regard to respirators, exceeds the permissible exposure limit, the the written notice will include a statement that the permissible exposure limit was exceeded and a description of the corrective action taken or to be taken to reduce exposure to or below the permissible exposure limit.

Observation of monitoring:

The company provides affected employees or their designated representatives an opportunity to observe any monitoring of employee exposure to lead.

Health Effects

Workers today are still being exposed to lead that result in adverse health effects.  Recent studies have provided evidence that lead can cause health effects at blood lead levels lower than those established by OSHA’s 1978 Lead standard.

Epidemiological and experimental studies indicate that chronic exposure resulting in blood lead levels (BLL) as low as 10 µg/dL in adults are associated with impaired kidney function, high blood pressure, nervous system and behavioral effects, cognitive dysfunction later in life, and subtle cognitive effects attributed to prenatal exposure.  Pregnant women need to be especially concerned with reducing BLL since this can have serious impact on the developing fetus.

Chronic exposures leading to BLLs above 20 µg/dL can cause sub clinical effects on cognitive functions as well as adverse effects on sperm/semen quality and delayed conception.  BLLs between 20 to 40 µg/dL are associated with effects such as cognitive aging as well as deficits in vasomotor dexterity, lower reaction times and attention deficit.  At BBLs above 40 µg/dL, workers begin to experience symptoms such as headache, fatigue, sleep disturbance, joint pain, anorexia, and constipation.

While much less common today, workers can be exposed to high lead levels resulting in BLL over 60 µg/dL.  Health effects at these very high BLLs can range from acute effects such as convulsions, coma, and in some cases, death, to more chronic conditions such as anemia, peripheral neuropathy, interstitial kidney fibrosis, and severe abdominal cramping.

Engineering Controls:

Where any employee is exposed to lead above the permissible exposure limit for more than 30 days per year, the company will implement feasible engineering and work practice controls (including administrative controls) to reduce and maintain employee exposure to lead. Wherever the engineering and work practice controls which can be instituted are not sufficient to reduce employee exposure to or below the permissible exposure limit, the company will still use them to reduce exposures to the lowest feasible level and shall supplement them by the use of respiratory protection. Where any employee is exposed to lead above the permissible exposure limit, but for 30 days or less per year, the company will implement engineering controls to reduce exposures to 200 ug/m(3), but thereafter may implement any combination of engineering, work practice (including administrative controls), and respiratory controls to reduce and maintain employee exposure to lead to or below 50 ug/m(3).

Mechanical ventilation:

When ventilation is used to control exposure, measurements which demonstrate the effectiveness of the system in controlling exposure, such as capture velocity, duct velocity, or static pressure shall be made at least every 3 months. Measurements of the system’s effectiveness in controlling exposure shall be made within 5 days of any change in production, process, or control which might result in a change in employee exposure to lead.

Recirculation of air. If air from exhaust ventilation is recirculated into the workplace, the system must include:

• a high efficiency filter with reliable back-up filter; and

• controls to monitor the concentration of lead in the return air and to bypass the re circulation system automatically if it fails are installed, operating, and maintained.

Administrative Controls:

If administrative controls are used as a means of reducing employees TWA exposure to lead, the company shall establish and implement a job rotation schedule which includes:

• Name or identification number of each affected employee ,

• Duration and exposure levels at each job or work station where each affected employee is located.

• Other information which may be useful in assessing the reliability of administrative controls to reduce exposure to lead Administrative control information and records will be maintained as an addendum to this written program.

Controlling Exposure:

Workers are primarily exposed to lead by breathing in particles containing lead.  Lead compounds can also get on the skin, contaminate clothing or food, and be ingested . The most effective way to prevent exposure to a hazardous material such as lead is through elimination or substitution with viable, less toxic alternatives.  The hierarchy of controls describes the order that should be followed when choosing among exposure-control options for a hazardous substance. Generally, elimination or substitution is the preferred choice (most protective) at the top of the hierarchy, followed byengineering controls, administrative controls, work-practice controls, and, finally, personal protective equipment (PPE). Engineering controls include isolating the exposure source or using other engineering methods, such as local exhaust ventilation, to minimize exposure to lead. Administrative controls usually involve logistic or workforce actions such as limiting the amount of time a worker performs work involving potential exposure to lead. When exposure to lead hazards cannot be engineered completely out of normal operations or maintenance work, and when safe work practices and other forms of administrative controls cannot provide sufficient additional protection, a supplementary method of control is the use of protective clothing or equipment. This is collectively called personal protective equipment, or PPE. PPE may also be appropriate for controlling hazards while engineering and work practice controls are being installed. PPE includes wearing the proper respiratory protection and clothing.  Good housekeeping practices to prevent surface contamination and hygiene facilities and practice to protect workers from ingesting and taking home lead are also necessary to prevent exposure to lead.

Respirators:

When respirators are used to supplement engineering and work practice controls to comply with the PEL and all other requirements have been met, employee exposure, for the purpose of determining compliance with the PEL, may be considered to be at the level provided by the protection factor of the respirator for those periods the respirator is worn. Those periods may be averaged with exposure levels during periods when respirators are not worn to determine the employee’s daily TWA exposure. The respiratory protection program will be conducted in accordance with 29 CFR 1910.134 (b) through (d) (except (d)(1)(iii)), and (f) through (m). The company will provide a powered air-purifying respirator when an employee chooses to use this type of respirator and such a respirator provides adequate protection to the employee.

Respirators must be used during:

• Periods necessary to install or implement engineering or work-practice controls.

• Work operations for which engineering and work-practice controls are not sufficient to reduce employee exposures to or below the permissible exposure limit.

• Periods when an employee requests a respirator

Protective Clothing & Equipment:

If an employee is exposed to lead above the PEL, without regard to the use of respirators or where the possibility of skin or eye irritation exists, the company will provide at no cost to the employee appropriate protective work clothing and equipment such as, but not limited to:

• Coveralls or similar full-body work clothing;

• Gloves, hats, and shoes or disposable shoe coverlets; and

• Face shields, vented goggles, or other appropriate protective equipment.

Housekeeping:

• All surfaces shall be maintained as free as practicable of accumulations of lead.

• Floors and other surfaces where lead accumulates may not be cleaned by the use of compressed air.

• Shoveling, dry or wet sweeping, and brushing may be used only where vacuuming or other equally effective methods have been tried and found not to be effective.

• Where vacuuming methods are used, the vacuums shall be used and emptied in a manner which minimizes the reentry of lead into the workplace.

Hygiene Facilities & Practices:

The following is requirements pertain to all areas where employees are exposed to lead above the PEL, without regard to the use of respirators:

• No storage or consumption of food or beverages.

• No tobacco product storage or use.

• No cosmetics stored or used.

• No personal clothing or articles, except in authorized change areas

Change rooms:

Clean change rooms are provided for employees who work in areas where their airborne exposure to lead is above the PEL. Change rooms are equipped with separate storage facilities for protective work clothing and equipment and for street clothes which prevent cross-contamination. Employees who are required to shower after work shifts are not allowed to leave the workplace wearing any clothing or equipment worn during the work shift.

Showers:

Employees who work in areas where their airborne exposure to lead is above the PEL must shower at the end of the each work shift.

Signs:

Proper signs will be posted at the entrance and exits to all lead hazard areas, No other signs or statements may appear on or near any lead hazard sign which contradicts or detracts from the meaning of the required sign. All lead hazard signs will be kept illuminated and cleaned as necessary so that the legend is readily visible. The signs will contain the following or other appropriate wording/warning:

WARNING

LEAD WORK AREA

POISON

NO SMOKING OR EATING

Employee training will consist of:

• specific OSHA requirements contained in ◦ 1910.1025 – OSHA Lead Standard ◦ 1910.1025 App A – Substance data sheet for occupational exposure to lead ◦ 1910.1025 App B – Employee standard summary.

• specific nature of the operations which could result in exposure to lead above the action level.

• purpose, proper selection, fitting, use, and limitations of respirators;

• purpose and a description of the medical surveillance program, and the medical removal protection program including information concerning the adverse health effects associated with excessive exposure to lead (with particular attention to the adverse reproductive effects on both males and females);

• engineering controls and work practices associated with the employee’s job assignment;

• contents of the company compliance plan.

• instructions that cheating agents should not routinely be used to remove lead from their bodies and should not be used at all except under the direction of a licensed physician.

• materials pertaining to the Occupational Safety and Health Act A copy of the OSHA standard 1910.1025 and its appendices will be readily available to all affected employees.

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