New Reporting Requirements Confined Space Rescue

PRESENTED BY: Andrew Palhof Compliance Assistance Specialist

Concord OSHA Area Office J.C. Cleveland Federal Building 53 Pleasant Street, Room 3901 Concord, NH 03301 603-225-1629 603-225-1580 (fax) Weekend / After Hour # 800-321-OSHA

What is OSHA’s Mission? Working Together to Make a Difference To prevent work-related injuries, illnesses, and deaths.

Each day, 15 U.S. workers die as a result of a traumatic injury on the job.

Coverage of the Act • Extends to all employers / employees in all 50 states, District of Columbia, Puerto Rico and other territories • Applies to every employer with 1 or more employees (federal, state, and local government employees excluded) • Note: Some state plan jurisdictions

OSHA has no control over many workplace fatalities: • Motor Vehicle / Transportation (43%) • Violence / Crime / Suicide (14%) • Heart Attack / Stroke (DEPENDS!) • Self-employed. DBA’s • Public Sector Workers • Mines / Quarries / Gravel Pits (MSHA)

OSHA Enforcement Staff• 2,200 inspectors (Including State Partners). • Translates to about one compliance officer for every 59,000 workers. • OSHA Investigations conducted allow the identification of factors that contribute to fatal injuries. • Concord Area office Staffing– 5 Safety Compliance Officers – 2 Industrial Hygienist

Focus Four Hazards All Others 21%

Struck By 24%

Electrical 11%

Caught in Between 10%

Fall 34% Source: Bureau of Labor Statistics

Fall Hazards #1

Struck-By Hazards #2

High Visibility Clothing

Caught in Between Hazards #3

Trench / Excavation

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Electrical Hazards #4

Overhead Lines

MINIMUM 10' Distance

INSPECTION PRIORITIES • Imminent Danger • Fatalities and Catastrophes (Employer have 8 hours to call OSHA!)

• Complaints – –

Formal Non-formal

• Referrals- Medical Examiners, Police & Fire, Media. • Programmed • Follow Up

Nathan Davis, DBA American Tree Service • •

Received Media Referral on 1/25/12 and traveled to the site. OSHA issued $8400 in citations for multiple violations.

www.osha.gov

Updates to OSHA’s Reporting Rule: What events must be reported to OSHA and which employers have to keep records

How does OSHA define “Amputation”? An amputation is the traumatic loss of a limb or other external body part. Amputations include a part, such as a limb or appendage, that has been severed, cut off, amputated (either completely or partially); fingertip amputations with or without bone loss; medical amputations resulting from irreparable damage; amputations of body parts that have since been reattached. Amputations do not include avulsions, enucleations, deglovings, scalpings, severed ears, or broken or chipped teeth.

Expanded reporting requirements The rule expands the list of severe work-related injuries and illnesses that all covered employers must report to OSHA. Starting January 1, 2015 employers must report the following to OSHA:

• All work-related fatalities within 8 hours (same as current requirement) • All work-related in-patient hospitalizations of one or more employees within 24 hours • All work-related amputations within 24 hours • All work-related losses of an eye within 24 hours

www.osha.gov

How can employers report to OSHA? • By telephone to the nearest OSHA office during normal business hours. • By telephone to the 24-hour OSHA hotline (1-800-321OSHA or 1-800-321-6742). • Online: OSHA is developing a new means of reporting events electronically, which will be available soon at www.osha.gov/report_online

Metal recycling compactor fatal

No written LOTO procedures Employee routinely clear jams behind pusher block . 147 ( c) (4)

(i) No LOTO training Employees not trained on need to lockout

What information do I need to give to OSHA about the in-patient hospitalization, amputation, or loss of an eye? You must give OSHA the following information for each fatality, in-patient hospitalization, amputation, or loss of an eye: (i) The establishment name; (ii) The location of the work-related incident; (iii) The time of the work-related incident; (iv) The type of reportable event (i.e., fatality, in-patient hospitalization, amputation, or loss of an eye); (v) The number of employees who suffered a fatality, in-patient hospitalization, amputation, or loss of an eye; (vi) The names of the employees who suffered a fatality, in-patient hospitalization, amputation, or loss of an eye; (vii) Your contact person and his or her phone number; and (viii) A brief description of the work-related incident.

Confined Space Rescue

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Selecting a Rescue Team Two Components- Initial Evaluation vs Performance Evaluation

• Initial Evaluation •

The employer should meet with the prospective rescue service to facilitate the evaluations.

•

If an off-site rescue service is being considered, the employer must contact the service to plan and coordinate the evaluations required by the standard.

•

Merely posting the service's number or planning to rely on the 911 emergency phone number to obtain these services at the time of a permit space emergency would not comply with paragraph (k)(1) of the standard.

Performance Evaluation Rescue services are to practice rescues at least once every 12 months, provided that the team or service has not successfully performed a permit space rescue within that time. As part of each practice session, the service should perform a critique of the practice rescue, or have another qualified party perform the critique, so that deficiencies in procedures, equipment, training, or number of personnel can be identified and corrected.

Basics • What is a confined space? – Big enough to enter – Not for regular occupancy – Difficult to exit

• Examples include: Sewers, pits, crawl spaces, attics, boilers, tanks, etc. • Hazards include: Low oxygen, toxic atmospheres, flammables/explosives, animals and insects, etc., and hazards caused by the work being done!

What is a Non Permit-Required Confined Space • A confined space that does not contain or, with respect to atmospheric hazards, have the potential to contain any hazard capable of causing death of serious physical harm.

What is a Permit-Required Confined Space • A PermitRequired Confined Space is confined space that has one or more of the following characteristics:

• Contains or has the potential to contain a hazardous atmosphere; • Contains a material that has the potential for engulfing an entrant; • Has an internal configuration such that an entrant could become trapped or asphyxiated; or • Contains any other serious safety or health hazard.

What’s Different • Relying on 911 or local emergency responders for entry rescue

The construction rule explicitly states that the emergency responders must agree to notify the employer in the event that the rescue service becomes unavailable. • A competent person must conduct worksite evaluation.

Emergency Rescue 

Emergency rescue teams must be available while authorized entrants are in the confined space.

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Let’s Take a Look at Response Time

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Rescue Techniques There are 3 types of rescue techniques: 1. Non-entry 2. Entry by others 3. Entry by Trained employees from the company

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Rescue Techniques 2. Entry by others continued – in this case the Fire Department would need: • To be familiar with the types of confined spaces located in the facility, • the hazards they may encounter, • the entry means into the confined spaces, • the types of rescue equipment to effect a rescue and 33 • the types of PPE required for any potential rescue.

Concord OSHA Area Office J.C. Cleveland Federal Building 53 Pleasant Street, Room 3901 Concord, NH 03301

603-225-1629 603-225-1580 (fax)

Weekend / After Hour # 800-321-OSHA