Occupational Safety - What You Should Know About OSHA

By Roger S. Hill, MA Certified Hazard Control Manager
As an employer, you have a duty to protect your employees from injury at work. A safe work environment just makes good business sense. Accidents and injuries are more expensive than many realize and costs could mount up quickly. Substantial savings in worker’s compensation expense and lost productivity are possible when workplace injuries decline. The Occupational Safety and Health Administration (OSHA) is a Federal Agency responsible for ensuring a safe workplace. Safety programs are not just about avoiding OSHA fines, but keeping your employees at work rather than at home recovering from an injury.

Top management support is a necessary element in a safety program for your lab. The safety program should be specific to the hazards in your lab. Every employee has safety responsibilities to contribute to the success of the safety program. Even office workers have to know about fire evacuation and office safety concerns such as safe lifting techniques.

One of the primary causes of OSHA inspections occurs when management is unresponsive to the safety and health concerns of employees. Employees have no choice but to call OSHA for help. Employees should be encouraged to report all unsafe conditions. Supervisors must enforce the safety rules to protect employees from injuries and the company from fines. All employee reports of unsafe conditions should be promptly investigated and appropriate documented action taken to correct the hazard.

There are five elements that every effective safety program should have:

1. Management leadership

2. Employee involvement

3. Workplace safety analysis

4. Protect employees from workplace hazards

5. Safety and health training and education.

Management leadership includes having a written safety policy letter signed by the CEO and communicated to employees. This letter should be posted on your company safety bulletin board. This letter establishes management support for the company safety program. This letter, as well as the OSHA poster and other safety information such as the fire evacuation plan, should be posted on the company safety bulletin board.

Employees should be involved in the safety program and have input regarding the rules. One of the best ways to involve employees is to have a Lab Safety Committee. The Committee should maintain minutes and have a senior lab supervisor as the chairperson. Employees should be encouraged to provide suggestions to improve the safety program. At each meeting, the status of the recommendations from the previous meeting should be discussed. The committee minutes should be sent to the senior lab manager for review and to provide resources to make safety program improvements. The safety program should be reviewed at least annually and the status of the correction of safety program deficiencies tracked.

Your employees must be trained on your lab safety program and how to work safely while performing their job. New employees should always be given a training or orientation session before they actually begin their work. During the orientation session, you should review and explain your lab’s safety policies and safe work rules to perform their job safely. The fire evacuation plan, emergency phones number and the company safety program should also be discussed.

A worksite safety analysis should be done to analyze all worksite conditions to identify and eliminate existing or potential hazards. These safety inspections should be done on a regular basis and the safety audit results provided to the appropriate supervisor for correction of the hazard. There should be a current hazard analysis for all jobs and processes. The safety requirements of each job should be included in the work instructions and standard operating procedures of lab operations. Hazards such as eye hazard must have a warning sign in the area to communicate the hazard to the employees performing the task. It is the lab’s responsibility to provide personnel protective equipment such as safety eyewear to employees. Safety problems such as broken electrical conduit (figure 1) and frayed wiring must be repaired.

Hazard Communication Program

One of top OSHA violations is lack of an effective Hazard Communication Program. Employees have the right and need to know the hazards of the chemicals that they come in contact with at work. Employees must be informed of the chemical hazards and how to protect themselves when working with the chemicals. An example of a common hazard in labs is lens polish. Since most polish is acidic, the use of safety eyewear to protect from splashes and the use of gloves is recommended for many polishes. This safety information is included in the Material Safety Data Sheet, which must be available to employees. The MSDS would have a statement such as “May cause eye/skin irritation. Avoid contact with the skin and the eyes.”

A common example of a hazard found in many labs is alloy reclaim operations. This operation requires the use of safety eyewear and a face shield when pouring the liquid alloy into the blocking unit, heat resistant gloves and an apron. Low Melting Point alloy also contains high levels of lead and employees must not eat or drink in the work area if they have the potential to come in contract with the alloy. Employees must be trained regarding the hazards of this material and how to protect themselves.

A written Hazard Communication Plan that describes how the program will be implemented in the lab must be prepared. The written program must reflect what employees are doing in a particular workplace. For example, the written plan must list the chemicals present at the site, indicate who is responsible for the various aspects of the program in that facility, and where written materials will be made available to employees. The written program must describe how the requirements for labels and other forms of warning, material safety data sheets, and employee information and training are going to be met in the facility. The written program should provide enough details about the employer's plans in this area to assess whether or not a good faith effort is being made to train employees.

Steps for Hazard Communication Compliance

1. Assigning A Hazard Communication Coordinator Hazard communication will be a continuing program for your lab. Compliance is not a "one shot deal." In order to have a successful program, you must assign responsibility for both the initial and ongoing activities to keep the program current.

2. Conducting a Laboratory Chemical Inventory To comply with the Hazard Communication Standard, an inventory of chemicals used in your lab must be identified. The standard requires a list of hazardous chemicals in the workplace as part of the written Hazard Communication Program. The list will eventually serve as an inventory of everything for which you must maintain an MSDS. At this point, however, preparing the list will help you complete the rest of the program, since it will give you some ideas of the scope of the program required for compliance in your lab. The best way to prepare a comprehensive list is to survey the workplace for chemicals.

3. Labels and Other Forms of Warning

Containers of chemicals must be labeled, tagged, or marked with the identity of the material and appropriate hazard warnings. If the employer subsequently transfers the material from a labeled container to another container, the employer will have to label that container unless it is for their immediate use.

4. Material Safety Data Sheets

Material Safety Data Sheets (MSDS) must be available to employees when they are in their work areas during their work shifts. A common practice is to keep the MSDSs in a binder in a central location. The information may also be maintained on a computer, if the employee can access the information. It is a good idea to keep a paper copy as a backup in a central location.

5. Employee Hazard Communication Training

Each employee who may be "exposed" to hazardous chemicals when working, must be provided information and be trained prior to their initial assignment to work with a hazardous chemical, and whenever the hazard changes. Where there are a large number of chemicals, or the chemicals change frequently, you will probably want to train based on the hazard categories (e.g., flammable liquids, corrosive materials, carcinogens).

OSHA has a free consultation service to help labs as well as other businesses find out about potential hazards and how to improve their safety program. A visit from OSHA and a consultation is always at the employer’s request. The service offers workplace safety and health training and technical assistance. Consultation is a free service largely funded by OSHA and operated by state government agencies using a well-trained safety and health staff. This service is completely separate from OSHA’s inspection effort; no citations are issued or penalties proposed.

The OSHA consultation inspection is also confidential. Your name, your firm's name, and any information you provide about your workplace, plus any unsafe or unhealthful working conditions that the consultant uncovers, will not be reported routinely to the OSHA inspection staff. This should be considered once your program has been started.

There are many resources that are free to help you develop a safety program for your lab. The OSHA Web site www.osha.gov, your state Department of Labor, and free information on the Internet makes this process much easier. The Optical Laboratories Association has a free manual for member labs on “Chemical Management for the Optical Laboratory” which is a great resource. A safety program requires a constant emphasis, enforcement and employee participation to make it a success.

Roger Hill is the Safety and Environmental Manager for the Naval Ophthalmic Support and Training Activity in Yorktown, VA. He is a Certified Hazard Control Manager, Virginia licensed optician, and OLA consultant. He is the author of the OLA Manual for Chemical Management for Optical Laboratories.

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Labtalk November/December 2018