Regulatory Reminder

September 2010 Edition

Welcome to the September edition of E&SSG’s Regulatory Reminder!



In this month’s edition:

Monthly regulatory focus to keep your year on track



Overview and Pep-Talk

Can you believe it? After this month you will have marked 30 items off of your compliance list. Now you are probably sleeping better knowing that you have not only drastically decreased your company's exposure, but also made your workplace safer for your most valuable assets… your employees. But there’s still more work to do, so let’s roll up our sleeves and get to work!



This month's survey

3RD Quarter Survey – Safety surveys are an important way to monitor your safety status. Completing regular surveys can help you stay in compliance and the information can be used for accident prevention purposes. It is recommended that you conduct safety surveys at least quarterly and possibly more frequently than that depending on your employee/facility size and the hazards associated with your industry.
Below are some items from the topics covered in this month’s focus that we recommend including in your third quarter’s safety survey.



Electrical

  1. Is electric equipment free from recognized hazards that are likely to cause death or serious physical harm to employees?
  2. Is the safety of equipment determined by the suitability for installation and use in conformity with the provisions of subpart S?
  3. Is listed or labeled equipment installed and used in accordance with any instructions included in the listing or labeling?
  4. Are completed wiring installations free from short circuits and from grounds other than those required or permitted by subpart S?
  5. Does equipment that is intended to interrupt current at fault levels have an interrupting rating sufficient for the nominal circuit voltage and the current that is available at the line terminals of the equipment?
  6. Are conductors or equipment located in damp or wet locations identified for use?
  7. Is all electric equipment installed in a neat and workmanlike manner?
  8. Are all unused openings in boxes, raceways, auxiliary gutters, cabinets, equipment cases, or housings effectively closed to afford protection substantially equivalent to the wall of the equipment?
  9. Do all outlet boxes have a cover, faceplate, or fixture canopy?
  10. Are all pull boxes, junction boxes, and fittings provided with covers identified for the purpose?
  11. Is temporary electrical power and lighting installations used only during and for remodeling, maintenance, similar activities?
  12. Is temporary electrical power and lighting installations used for a period not to exceed 90 days for Christmas decorative lighting, carnivals, and similar purposes?
  13. Is all temporary wiring removed immediately upon completion of the project or purpose for which the wiring was installed?
  14. Are conductors entering cutout boxes, cabinets, or fittings protected from abrasion?
  15. Are openings through which conductors enter effectively closed?
  16. Are unused openings in cabinets, boxes, and fittings effectively closed?
  17. Are flexible cords prohibited from being fastened with staples or otherwise hung in such a fashion as could damage the outer jacket or insulation?
  18. Are portable cord and plug connected equipment and flexible cord sets (extension cords) visually inspected before use on any shift for external defects?
  19. If a defect or evidence of damage identified that might expose an employee to injury, is the defective or damaged item removed from service?
  20. A flexible cord used with grounding type equipment shall contain an equipment grounding conductor.
  21. Attachment plugs and receptacles maintained in a condition that will allow proper continuity of the equipment grounding conductor?
  22. Are three prong to two prong adapters prohibited?
  23. Is it required that employees have dry hands when plugging and unplugging flexible cords and cord and plug equipment?
  24. Are only qualified persons allowed to perform testing work on electric circuits or equipment?
  25. Are employees working in areas where there are potential electrical hazards provided with and do they use appropriate electrical protective equipment?
  26. Is protective equipment maintained in a safe, reliable condition?
  27. Is protective equipment periodically inspected or tested?
  28. Are protective shields, protective barriers, or insulating materials used to protect each employee from shock, burns, or other electrically related injuries while that employee is working near exposed energized parts which might be accidentally contacted or where dangerous electric heating or arcing might occur?
  29. Does each employee use insulated tools or handling equipment if the tools or handling equipment might make contact with energized conductors or parts?
  30. Are safety signs, safety symbols, or accident prevention tags used where necessary to warn employees about electrical hazards which may endanger them?


Bloodborne Pathogens

Bloodborne Pathogens Exposure Control Plan and Training - Bloodborne pathogens are infectious materials in blood that can cause disease in humans, including hepatitis B and C and human immunodeficiency virus, or HIV. Workers exposed to these pathogens risk serious illness or death.
Title 29 of the Code of Federal Regulations 1910.1030, details what employers must do to protect workers whose jobs put them at a reasonable risk of coming into contact with blood and other potentially infectious materials. The standard requires employers to do the following:

  • Establish an exposure control plan - This is a written plan to eliminate or minimize employee exposures. Employers must update the plan annually to reflect technological changes that will help eliminate or reduce exposure to bloodborne pathogens. In the plan, employers must document annually that they have considered and implemented safer medical devices, if feasible, and that they have solicited input from frontline workers in identifying, evaluating, and selecting engineering controls.
  • Use engineering controls - These are devices that isolate or remove the bloodborne pathogen hazard from the workplace. They include sharps disposal containers, self-sheathing needles, and safer medical devices such as sharps with engineered sharps-injury protection and needleless systems.
  • Enforce work practice controls - These are practices that reduce the likelihood of exposure by changing the way a task is performed. They include appropriate procedures for hand washing, sharps disposing, lab specimen packaging, laundry handling, and contaminated material cleaning.
  • Provide personal protective equipment - such as gloves, gowns, and masks. Employers must clean, repair, and replace this equipment as needed.
  • Make available Hepatitis B vaccinations - to all employees with occupational exposure to bloodborne pathogens within 10 days of assignment.
  • Provide post-exposure follow-up - to any worker who experiences an exposure incident, at no cost to the worker. This includes conducting laboratory tests; providing confidential medical evaluation, identifying, and testing the source individual, if feasible; testing the exposed employee’s blood, if the worker consents; performing post-exposure prophylaxis; offering counseling; and evaluating reported illnesses. All diagnoses must remain confidential.
  • Use labels and signs to communicate hazards - The standard requires warning labels affixed to containers of regulated waste, refrigerators and freezers, and other containers used to store or transplant blood or other potentially infectious materials. Facilities may use red bags or containers instead of labels. Employers also must post signs to identify restricted areas.
  • Provide information and training to employees - Employers must ensure that their workers receive regular training that covers the dangers of bloodborne pathogens, preventive practices, and post-exposure procedures. Employers must offer this training on initial assignment, then at least annually. In addition, laboratory and production facility workers must receive specialized initial training.
  • Maintain employee medical and training records
  • Maintain a Sharps Injury Log - The employer also must maintain a Sharps Injury Log unless classified as an exempt industry under OSHA’s standard on Recording and Reporting Occupational Injuries and Illnesses.
Reference:
Osha.gov BBP Fact Sheet
OSHA’s website provides more in-depth information about bloodborne pathogens on the Bloodborne Pathogens webpage at www.osha.gov/SLTC/bloodbornepathogens

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Bloodborne Pathogens Training
Content Sample
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That’s it for this month. Until next time, have a safe and productive month! If you ever need some help, give us a call.

(800) 770-7767



We hope you found it helpful and informative. We welcome all of your comments, suggestions and any corrections that you see we need to make. All are very important to us, so if you have any… please let us know.


Regulatory Reminder Input

Disclaimer: These Regulatory Reminders are not intended to be an exhaustive source for all of your particular facility’s compliance issues. They are designed to address the basics requirements with which most companies are required to comply. Following the Regulatory Reminder’s deadlines and Monthly Focus will not guarantee your compliance as these reminders are simply designed to help in your environmental/safety compliance efforts. You should always refer to the federal and your state’s regulations for all your requirements. Ultimately, your compliance with federal and state regulations is your responsibility. E&SSG assumes no liability for your compliance or the resources provided in these “Reminders”.

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