The utility sector mirrors what happens with the general
industry and construction sectors throughout America. The field personnel
conduct trenching, excavations, even erecting structures on a regular basis.
Plant personnel are exposed to chemical, biological hazards, and many other
hazards that can cause injury or illnesses. OSHA, the Occupational Safety and
Health Administration, is the regulatory body that has jurisdiction to guide
the employers in ways to protect the employees.
However, only states that have their own approved OSHA
program can regulate public water and wastewater utilities. Each state plan
must be as strict as or more stringent than the federal OSHA as a term of their
program approval. In addition, the state programs must adopt the federal OSHA
regulations within six months for the final ruling in the Federal Register.
This article will highlight four key regulatory changes or pending changes in
2015.
According to OSHA’s Unified Agenda, there are three stages for rules to
become law:
Pre-Rule
Emergency Response and Preparedness
Communication Towers
Proposed Rule
Cranes and Derricks in Construction: Operator
Certification
Occupational Exposure to Crystalline Silica
Final Rule
Improve Tracking of Workplace Injuries and Illnesses
Confined Spaces in Construction
Recordkeeping requires the employer to denote workplace
injuries, illnesses, catastrophes, or fatalities within a certain timeframe.
After January 1, 2015, a catastrophe will be one hospitalization instead of
three, which has been modified. Once the worker is admitted to the hospital,
OSHA has to be notified within 24 hours of the hospitalization. In addition, any
amputation or loss of an eye must be reported to the OSHA office within 24
hours. A workplace fatality must be reported no later than eight hours of
notification.
The utility can report to OSHA by:
1. 1-800-321-OSHA
(6742)
2. Calling
the closest OSHA Area Office
3. Use
the upcoming online form
OSHA has been making a push to get companies to switch
from highly hazardous chemicals to safer alternatives. This switch will help
reduce the exposure to chemical hazards to the workers and the community.
Liquid utilities have to disinfect with chemicals in a large quantity,
therefore, several are under the Process Safety Management program or the EPA
Risk Management Program. There is a guidance
electronic tool (e-tool) provided by OSHA that gives seven steps transition
to safer chemicals. These steps are:
1. Develop
a team to outline a plan with achievable goal and milestones to the transition.
2. Include
engineering, service workers, maintenance, operators, laboratory personnel, and
any applicable stakeholder.
3. Develop
a work plan (OSHA sample work plan model used below).
1. Evaluate
your current chemical use.
2. Prioritize
what chemical is the greatest concern for the utility.
3. Do
an inventory to date to ascertain how much product must be replaced and in what
timeframe.
1. Look
for all possible chemical alternative that will be as effective as or more
effective than the target chemical.
2. Make
sure to check with NPDES permit issuers for regulatory guidance on
alternatives.
1. Be
aware of the hazards associated with the alternative chemical.
2. Know
how to protect the workers from the new hazards, if any, in accordance to
regulatory requirements.
1. Continue
to assess the pros and cons of each alternative, but select one after the
analysis.
2. The
EPA
has a design for alternative assessments for chemicals to help the utility
in this quest.
1. Do
a small and large-scale test to make sure the anticipated result matches the
actual performance.
2. Consider
a job
hazard analysis for the handling and use of the new chemical to identify
and select protection for each stage of the tasks.
1. Did
the alternative chemical work as well as you wanted?
2. Keep
tracking performance to verify effectiveness.
3. Share
your results with fellow utilities.
Fall Protection for General Industry
Falls in constructions is a known hazard that is
addressed in OSHA’s Focus 4 (the four leading causes of death) initiative. The
construction standard, 29 CFR 1926, even has Subpart M, which is expressly for
Fall Protection. However, the General Industry standard 29 CFR 1910, there are
sporadic mentions of fall protection. Falls to lower levels can end tragically,
but there are not standards to cite when a general industry worker is
maintaining a building at an elevated height. A simple task of changing a
windsock on a steep pitched roof would not violate a specific standard except
the General Duty Clause in 5A1 of the OSH Act of 1970 that states in part that
an employer must furnish a place of employment free from any known or suspected
hazards.
In the Unified Agenda, OSHA has a final rule on the
revision of the Walking Working Surfaces and Personal Fall Protection System
(Slips, Trips, and Fall Prevention). However, this final rule for this 29 CFR 1910 revision to Subpart D (Walking Working Surface) and
Subpart I (Personal Protective Equipment) has been pending since May 2010.
If 2015 were the year that the fall protection for general industry passes,
then the utilities would have an additional regulation to be aware of and
comply. Training on compliance requirements and additional PPE will be needed
by the utility.
Confined Space is defined:
·
as any space that a worker can get into and
perform assigned work; and
·
it is not meant for continuous human occupation;
and
·
has limited access and egress
When a confined space has a hazard present such as
electrical, atmospheric, configuration, etc., then it becomes a permit-required
confined space. The permitting process is in-house, but it takes account of the
situation, entrants responsibilities, attendee responsibility, and how to
protect the worker from the hazard that is present.
In construction, excavations meet the definition of a
confined space; therefore, the workers must be protected in the same manner as
general industry. OSHA has made the final rule for this change, so now the
utility must adjust and train workers as to how to protect themselves.
Although, this article only highlighted four occupational
safety concerns and future and/or current regulations, the utility must remain
vigilant to protect the workers from injury and illnesses. As always,
protecting the workers is a high priority with each public sector throughout
the U.S.
Source: Water
Online
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