Safety and Health Program - RBC, Robinson Brothers Construction

Transcription

health and safety
policy
Robinson Brothers Construction, Inc.
Safety and Health Program
Table of Contents
Recordable Injury Statistics
Workers Compensation Rates and Modifier
Health and Safety Policy
1. Introduction – Company Policy – Objective Statement
2. Employee Orientation
3. Responsibility and Accountability
4. Disciplinary
5. Safe Work Rules
6. Good Housekeeping
7. Personal Protective Equipment
8. Machinery and Equipment
9. Hand and Portable Electric Tools
10. Lock Out/Tag Out
11. Fall Protection
12. Ladders
13. Scaffolding
14. Fire and Flammable Materials/Storage
15. Emergency Action Plan
16. Heat Stress
17. Traffic Control and Safety Procedures/Working Zones
Hazard Communications
1. HAZ COM Program
2. Material Safety Data Sheet
Job Hazard Assessment
Drug and Alcohol Policy
CPR – First Aid
Work Zone Safety
Trench, Excavation and Shoring
Working Alone Guidelines
Fleet Auto Policy
Respiratory Protection
Hearing Conservation
Safety Training Matrix
Number
RBC-03-2009
Effective Date
Reference
1910.1200
Revision Number
September 1 , 2009
Number of Pages
4
0
Review Date
September 1 , 2010
HAZARD COMMUNICATION (HAZCOM)
A.
To ensure that workers are protected from chemical hazards within the workplace.
B.
1.
Container Labeling:
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2.
No container of hazardous chemicals will be released/accepted for use until
the following information is verified: Containers are clearly labeled as to the
contents; Appropriate hazard warnings are noted, (flammable, oxidizer,
toxic, corrosive, etc.); the name and address of the manufacture is listed.
The employee using the hazardous material is responsible for ensuring all
incoming hazardous material containers have adequate labels.
The RBC Employee will ensure that when hazardous materials are
transferred to secondary containers (example: pumping gasoline from a
storage tank to a portable gas can) the secondary container is labeled with
the contents and the hazard warning statement. If the secondary container
is used immediately by the employee that performs the transfer of the
hazardous material, then labeling of the secondary container is not needed.
Blank labels for marking containers should be available at the MSDS
stations or company vehicles when in the field.
Stationary Process Container:
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Stationary Process Containers are usually a large un-removable tank or
vessel designed to store hazardous materials.
They should be marked with the name of the chemical contents, the
appropriate hazard warning (oxidizer, flammable, corrosive, etc.) and
should be equipped with a NFPA placard.
3. Material Safety Data Sheets (MSDS):

Material Safety Data Sheets (MSDS) are those information sheets provided
by the chemical manufacturer for each of the hazardous products that they
make. MSDS’s list the hazardous ingredients; manufacturer’s name and
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4.
Hazardous Material Inventory:
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5.
A hazardous material inventory will be performed annually by a Robinson
Brothers Construction, Inc. representative and reviewed to determine any
new risk to workers.
A copy of the inventory should be placed with the MSDS binder.
For those chemical materials that are missing a MSDS, this should be noted
on the inventory sheet. The date and time of the request (and follow up
requests) for a replacement or new MSDS for the product should be noted
on the inventory sheet.
Contractors:
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6.
phone number as well any other valuable information about the chemical
product.
Copies of all MSDS for all hazardous material used by workers at a work site
will be kept at those areas accessible to workers: maintenance yard break
room; common areas of office areas; mobile office on a construction site.
Workers shall be informed of the location of MSDS’s.
MSDS’s should be made readily available for review by: employees; past
employees; employee representatives; OR-OSHA; contractors.
If a MSDS is missing, the work center supervisor or other designated
representative should be notifies and a copy of the MSDS should be ordered
from the chemical supplier or manufacturer.
Contractors should make available MSDS’s for those chemicals materials
used within Robinson Brothers Construction, Inc. spaces.
This could include: paints; fumigation agents; carpet cleaning chemicals;
janitorial supplies.
Chemicals in Pipes:
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
All chemicals transferred by pipe in Robinson Brothers Construction, Inc.
facilities will be properly labeled with the product contents and any hazard
warning statement.
The direction of flow of material in the pipe should also be noted on the pipe.
7. Hazardous Non-Routine Tasks
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Periodically, employees must perform hazardous non-routine tasks.
Before starting work on such projects, each affected employee should be
given information by their supervisor about hazardous chemicals to which
they may be exposed during such activity.
Information provided should include: specific chemical hazards; protective
safety measures employees can take; measures Robinson Brothers
Construction, Inc. has taken to reduce the hazard.
C. ROLES & RESPONSIBLITES
Contractors
1. All contractors are required to submit a list of chemicals to be used on Robinson
Brothers Construction, Inc. contracts, or on Robinson Brothers Construction, Inc.
facilities, to their Project Coordinator prior to their being used.
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No chemicals are to be left on open, unprotected ground.
Have a spill protection while performing work for Robinson Brothers
Construction, Inc.
Have a written Hazard Communication Program.

Have an MSDS for each chemical brought onto Robinson Brothers
Construction, Inc. projects/property.
Employee
1. Employees will ensure that hazardous materials are used in accordance with
the manufacturer’s guidelines.
2. Employees will ensure that they seek advice or guidance on those chemical
materials they are unfamiliar with.
3. Employees will inform supervisors or other designated persons if an MSDS is
missing, or chemicals lack proper labeling, or if controls or work practices are
insufficient.
Managers
4. Supervisors and Managers are responsible for ensuring that workers are
trained on the site specific chemicals that they use and that such training is
documented and available for review.
5. Supervisors and Managers are responsible for conducting Hazard Assessments
to ensure that the correct personal protective equipment is available and used.
6. Schedule and deliver required training to affected employees.
7. Maintain a system for ensuring that only approved chemicals are allowed on
site/for use, that all approved chemicals are properly labeled, that all approved
chemicals have a MSDS on file and employees are informed and trained to use
them.
8. Supervisors and Managers shall review each Contractor to ensure that their
Hazard Communication Program is at least equivalent to Robinson Brothers
Construction, Inc.
D. TRAINING REQUIREMENTS
1.
All Employees: HAZCOM Training:
Those employees using hazardous materials (any item that has a Material Safety
Data Sheet assigned to it) within Robinson Brothers Construction, Inc. workspaces
will complete the course “HAZCOM”.
 This course is designed for personnel that work with hazardous materials on
a daily or weekly basis or have potential risks related to the exposure of
these materials.
 HAZCOM will consist of: overview of OR-OSHA standard; location of the
written program and the material safety data sheets; how to detect a spill
or leak; physical effects of the materials used at the facility; how to prevent
exposure; how to read a MSDS; identification of key personnel within this
program.
 This course will consist of classroom training of 1-2 hours in length.
 Completion of this course will be documented in Robinson Brothers
Construction, Inc. records management process.
 If an employee is deficient in demonstration the requirements of this
program, then the supervisor is encouraged to send the employee through
this course again.
2.
All Employees: Ongoing Site Specific Training:

All employees should know where: MSDS’s are located; location of Robinson
Brothers Construction, Inc. Written Hazard Communication Program;
location of hazardous materials stored or used in the work center; location
of labels to be used.
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Before performing activities with a hazardous material in the work center,
the new employee is to review the MSDS’s on file for that crew, pay
attention to proper usage of the material and personal protective equipment
required, and have supervisor or designee provide guidance in the proper
use of the material.
Anytime a new hazardous material is introduced to the workplace or used
by the crew, training on the proper handling, PPE, and hazards must take
place. A review of the MSDS’s is the best way to accomplish this.
Employees should document site specific HAZCOM training in the same book
where MSDS’s are stored. An example of proper documentation is provided
as Attachment A.
3. New Employees:
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New employees should be shown where: MSDS’s are located; location of
Robinson Brothers Construction, Inc. Written Hazard Communication
Program; location of hazardous materials stored or used in the work center;
location of labels to be used.
Will attend, Intro to HAZCOM training, prior to starting work.
This orientation of new employees could consist of an appropriate video and
discussion of Robinson Brothers Construction, Inc. program (35-45 min. in
length)
New employees will be provided with: developing safety attitudes to make
employees more aware of hazardous chemicals; motivate employees to
protect themselves by preventing exposure to hazardous chemicals; learn
how to read and understand labels and MSDS’s; make employees aware of
the hazard communication rules.
Completion of this course will be documented Robinson Brothers
Construction, Inc. records.
It is very important that all questions regarding hazardous chemicals used
within Robinson Brothers Construction, Inc. workspaces are answered.
Workers should feel free to contact the manufacturer of the chemical or the
Robinson Brothers Construction, Inc. Management.
E. TRACKING REQUIREMENTS
1.
Material Safety Data Sheets need to be maintained on site during the use of the
product.
2. Material Safety Data Sheets for those products no longer used need to be
maintained on file for approximately 30 years.

Material safety data sheets for those materials that contain carcinogens,
lead, asbestos of benzene should be transferred to state archives for
retention. You should include your crew #, region and job activity with the
MSDS submitted to archives.
3. List of hazardous chemicals.
4. A written Program is required for this OSHA Standard.
F. INSPECTION AND REVIEW
This program is to be reviewed by Management annually.
Number
Effective Date
Reference
29CFR1910.132
Revision Number
September 1 , 2009
Number of Pages
2
0
Review Date
September 1 , 2010
JOB HAZARD ASSESSMENT (JHA)
A. PURPOSE
To ensure that employees are trained to complete job hazard assessments and learn
how to develop remedies for those hazards.
B. GUIDELINES
DEFINITION:
1. Job Hazard Assessment (JHA) is a procedure used to review job methods and
uncover hazards. The focus of a JHA is on identifying safety and health
hazards and developing remedies to address those hazards.
2. Managers and Supervisors shall ensure employees are trained in the purpose,
use, and the development of JHA’s for their work.
3. The Company Manager shall sign and date a document signifying that a
hazard assessment has been completed to determine the necessary PPE. This
shall be maintained on file for review.
4. JHA shall be used to train new employees, pre-job instructions on irregular
jobs, review of job procedures after accidents occur, and improvements of job
methods.
5. A JHA requires:
 Breaking down selected jobs or tasks;
 Identifying potential hazards;
 Developing procedures to eliminate hazards;
 Repeat until all hazards identified.
6. Identifying hazards includes, but not limited to:
 Is there a danger of the employee striking against, being struck by, or
making contact with an object?
 Can the employee be caught in, by, or between objects?
 Is there a potential for slip or trip?
 Can employees fall on the same level or to a lower level?
 Can the employee strain themselves by pushing, pulling, lifting,
bending, or twisting?
 Is the environment hazardous to safety or health with respect to
chemical exposure, toxic gas, mist, fume, vapor, heat, noise, or
radiation?
7. Recommendations to evaluate eliminate hazards identified in JHA include:
 Find a new method of doing the job.
 Change or modify physical conditions that create hazards. Eliminate
physical or environmental hazards still present by changing procedures.
 Reduce the necessity of doing a job or the frequency it must be
performed, which limit the exposure, would however, not eliminate it.
 All employee recommendations shall be reviewed by the Robinson
Brothers Construction, Inc. Management team. Every effort shall be
made to eliminate hazards.
8. Any time new processes or tasks are assigned a new JHA will be completed by
employees and reviewed by a manager or supervisor.
C. ROLES & RESPONSIBLILITES
EMPLOYEES
1. Employees shall participate in development of JHA’s and are responsible for
safe work practices.
2. Employees shall inform supervisor or manager of unsafe conditions or
practices.
3. Employees shall complete required training on JHA.
MANAGERS
1. The Robinson Brothers Construction, Inc. Manager shall sign, date and
maintain on file, a document indicating that all hazard assessments have
been completed to determine the necessary PPE to be used in areas under
their responsibility.
2. Managers or Supervisors shall provide the necessary directions, support and
resource such as: funding, employee involvement, and schedule required
training.
3. Managers or Supervisors shall develop with employees a JHA for all major
tasks and all new or redesigned work tasks.
4. Managers or Supervisors shall keep all JHA’s on file and use in all new
employees training.
D. TRAINING REQUIREMENTS
1. No mandatory OSHA training requirement for this standard.
2. Ensure employees have adequate training to comply with standard.
Written document signed by Management signifying that all hazard assessments
have been completed identifying where personal protective equipment is required to
be used.
This standard may be inspected during the quarterly safety committee inspections or
reviewed by the company owner or representative.
drug & alcohol
policy
Number
RBC-00-2009
Effective Date
Reference
ORS 437-02-151
Revision Number
September 1 , 2009
Number of Pages
3
0
Review Date
September 1 , 2010
CPR and First Aid
A. Purpose
To ensure that employees who sustain an on the job illness or injury, receive prompt
medical attention.
B. Guidelines
1. Emergency Response plans shall be maintained at each work site. A site
health and safety plan will be established for field work. Plans must identify
telephone numbers of local police, ambulance, and fire departments in case of
emergency. The plan must also identify employees trained in First Aid/CPR
on site.
2. First aid is the immediate, temporary care given to the injured or suddenly ill
person.
3. Facilities or work locations located within a reasonable response time to
emergency personnel, such as police, fire department or ambulance, are not
required to train all employees at that location. Training may be provided to
all employees, however is not required.
4. Facilities and field crews that are not within a reasonable response time to
emergency medical services must have at least one employee on site that is
trained and in possession of a current First Aid/CPR Card. That person must
be able to demonstrate an acceptable proficiency level in Medic First Aid and
CPR.
5. All employees will have ready access to first aid supplies. Each location shall
be equipped with a 24 unit first aid kit. Minimum kit content includes:
 2-4x4 Bandage Compress
 3x4 Gauze Pads (4 per box)
 2- Triangular bandages (44 “ Tyvek)
 4 inches by 5 yards Gauze Bandage
 ½ inch x 2.5 yards Adhesive Tape (2 per box)
 Sting Kill Swabs (10 per box)
 2 boxes of 1” Adhesive Bandages (2 per box)
 Sterile Buffered Isotonic Eyewash Kit (1 oz) with 2 eye pads, 2
adhesive strips
 Instant Cold Pack
 Triple Antibiotic Ointment (1-32 oz pkg. 10 per box)
 CPR micro shield Rescue Breather
 Disposable gloves (2 per box)
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Disposable clear plastic face mask
Rescue Blanket, silver/silver
Burn Spray (2 cans per kit)
Alcohol Wipes (910 per box)
Ammonia inhalants (910 per box)
Scissors
C. Roles and Responsibilities
Employees
1. Employees shall comply with all applicable guidelines contained in this safety
standard.
2. All employees are responsible for reporting unsafe acts or conditions
immediately to their supervisor.
3. First Aid trained employees will administer first aid as conditions and
circumstances dictate. First Aid is provided only to the level of training
received. They are also responsible for ensuring that first aid supplies are
replenished when used.
4. Daily vehicle pre-trip inspections, for all fleet vehicles requiring daily
inspection, shall include inspection of vehicle First Aid/CPR supplies.
Managers
5. Managers and Supervisors must ensure adequate funds are available for first
aid supplies, training of appropriate personnel, and are responsible for
ensuring that current written emergency response plans are readily available
and employees are trained on emergency medical response procedures.
6. Managers and Supervisors will assist first aid trained personnel as needed.
7. Local facility Manager or Supervisor is responsible for maintaining an
inventory of first aid supplies.
D. Training Requirements
1. When the work site or location is not within reasonable response time, at
least one employee on site must be trained and current in Medic First Aid and
CPR.
2. Required training for Medic First Aid is every 2 years.
3. CPR Training is required on an annual basis.
4. Practical hands-on demonstration is a required element of the training.
5. At a minimum, training shall cover:
 Site specific reporting protocols
 Injury and acute illness
 Working with local emergency response system and teams
 Principles of triage
 Legal aspects of providing First Aid/CPR and AED
 Methods of surveying an incident scene and assessment
 Performing primary survey and victim care including airway, breathing
and circulation
 Getting a victims health history at the scene
 CPR
 Bandaging
 Splinting
 Rescue and transport of victims
 PPE (Personal Protective Equipment)
 Proper disposal of contaminated or sharp material
 Tagging
E. Tracking Requirements
1. Supervisors are responsible for ensuring the emergency response plan
accurately reflects the appropriate emergency response agencies
telephone numbers and employees who are trained to provide First Aid if
needed.
2. Robinson Brothers Construction, Inc. records of all injuries and illness are
required to be documented on the OSHA Form 300 log.
3. Supervisors are required to keep training records at the primary office
location and make information readily retrievable if needed.
4. On the job injuries and illnesses which are rerecorded onto the OSHA 300
log shall have an accident investigation-Incident Analysis completed. The
completed investigation will become a permanent part of the employee
injury file.
5. For serious injuries, multiple injuries, 3rd party injuries, fatalities or
hospitalization, it is recommended that Robinson Brothers Construction,
Inc. contract with Evergreen Safety Council to provide investigation and
analysis.
6. Records for an employee who received first aid on a one time basis do not
need to be kept specifically for OSHA purposes unless:
 The individual is involved in a work related accident involving a fatality
or the hospitalization of 2 or more employees; and
 There is an “Employee Exposure Record” Maintained for certain toxic
or hazardous substances.
 There is an on site Health and Safety Plan in place.
NOTE: If there is an on the job injury or illness and the employee is hospitalized
(in-patient status or if there is a fatality at the work site for any reason, OSHA must
be notified within 8 hours.
F. Inspection and Review
1. Safety Committee quarterly inspections will include review of compliance with
this guideline.
2. Quarterly inspection by Company Owner, facility manager, or Supervisor for
compliance with this guideline.
Number
Effective Date
Reference
OR810.200(a); MUTCD
Revision Number
September 1 , 2009
Number of Pages
3
0
Review Date
September 1 , 2010
WORKZONE SAFETY
A. PURPOSE
To ensure employees are trained in proper work zone traffic control procedures and
work zone safety.
B. GUIDLINES
APPLICATION
1.
This program applies to all Robinson Brothers Construction, Inc. employees
involved in designing traffic control plans when establishing a work zone on
or near the highway. This includes:
 The application of traffic control principles;
 Proper placement of traffic control devices;
 Flagger safety and certification; and
 Understanding how to minimize legal liability associated with a work
zones.
2.
Evaluation of a work zone must include the type of work to be done, location
of the work, expected length of the project when establishing a highway work
zone.
3.
The work zone must provide adequate protected work space by:
 Allowing space for safe movement of crews and equipment;
 Use of traffic control devices, such as signs, cones, flaggers, etc.;
 Minimize distance and exposure by limiting short term projects not to
exceed one mile in length; and
 The use of vehicles for protection of workers, when feasible.
4.
Adequate warning time for motorist and appropriate reaction time to make
adjustments to traffic pattern must be considered. Guidance to drivers must
be clear and visible for the motorist’s perspective. Do not move motorist
unnecessarily out of their normal driving pattern.
5.
Supervisor or lead person is required to drive through the work zone,
immediately following set-up, to review signs, traffic flow and pattern, and
consistency in message to drivers. Signs must be clear to the work being
done, consistently applied, are clean and in good repair. When signs are not
in use, turn, cover, or remove signs as soon as possible.
6.
Supervisor or lead person is required to inspect all work zones. Initial review
after set-up, mid-shift review, and end of shift review. Inspections must be
documented, hazards identified and corrected, verify repairs and
improvements made, assess correct personnel and inventory for the project
and document all close calls, incidents, or complaints by motorist or flaggers.
7.
Documentation of incidents or accidents in a work zone must be immediate
and include: time work began, type of work, traffic control devices used and
application, names of personnel on the job, type of equipment used, and
changes in permanent or temporary regulatory devices during project, such
as: signs.
FUNDAMENTAL PRINCIPLES
1.
Traffic safety in temporary traffic control areas should be an integral and high
priority element of every project.
2. A traffic control plan, in detail and appropriate to the complexity of the work
shall be prepared and understood by all workers before the work begins.
3. Traffic movement should be inhibited as little as practicable.
4. Adequate warning should be provided to assure the motorist of positive
guidance in advanced of and through the work area.
5. Traffic control in work and incident sites should be designed on the
assumption motorist will only reduce their speed if they clearly perceive a
need to do so.
6. Motorist should be guided in a clear and positive manner. Frequent or abrupt
changes in geometric, such as lane narrowing, dropped lanes, or main
roadway transitions which require rapid maneuvers should be avoided.
7. Provisions should be made for the safe operation of equipment and
emergency vehicles.
8. Construction and maintenance time should be minimized to reduce exposure.
9. Routine inspection of traffic control elements will be performed.
10. Only individuals who are trained in the principles of safe traffic control shall
be responsible for safety at work sites.
11. Modifications in traffic control may be required in order to expedite safe
traffic movement and promote worker safety. Changes or modification to
Robinson Brothers Construction, Inc. standards must be approved by
Robinson Brothers Construction, Inc. Management.
12. All traffic control devices shall be removed immediately when no longer
needed.
C. ROLES & RESPONSIBILITIES
EMPLOYEES
1.
2.
3.
4.
Only employees who have been trained in work zone traffic control will be
assigned the duties of setting up a work zone.
Flaggers must have completed a work zone traffic control Flagger course.
Employees shall ensure safe work practices and procedures are followed and
applied. All unsafe acts and conditions will be promptly reported to
immediate manager, supervisor, or lead person.
All employees are responsible for observing the flow of traffic, pedestrians,
and bicyclists to help in assessing any changes that allow for smoother
movement through the work zone.
MANAGERS
1.
2.
3.
4.
Managers and Supervisors are responsible for the proper training and use of
equipment by their employees.
Managers and Supervisors are responsible for the traffic control practices that
are in accordance with RBC standards.
Managers and Supervisors shall ensure the work zone provides adequate
visibility, warning time, and reaction time for motorists.
Managers and Supervisors shall require employees to assist their work and
traffic flow for minimizing exposure to traffic.
D. TRAINING REQUIREMENT
1. Personnel who are flagging shall be current in Flagger training through an
approved training provider.
2. Training must include: a) establishing a work zone; b) work zone parts and
devices; c) tapers and cone spacing; d) principles and roles of the Flagger; e)
documentation and legal liabilities; f) basic traffic flow management, and g)
highway work zones from the driver’s perspective.
1.
2.
No OSHA tracking requirement.
Managers and Supervisors are responsible for ensuring appropriate
employees receive initial training in WZTC. Retraining is required every three
years.
1.
2.
The application of this standard may be inspected during the quarterly safety
committee inspections or reviewed by Robinson Brothers Construction, Inc.
Management.
In addition, employees are responsible for inspection of each work zone
before work begins, during, and at the end of the day.
excavation safety
Number
RBC-13-09
Effective Date
Reference
Internal
Revision Number
September 1 , 2009
Number of Pages
2
0
Review Date
September 1 , 2010
WORKING ALONE GUIDELINES
A.
PURPOSE
To ensure the safety of employees who are required to work alone for extended
periods of time. This shall be accomplished by establishing communication systems
via radio, telephone, or personal contact.
B.
GUIDELINES
1. A Hazard Assessment shall be completed in each work section to determine
the assignments where employees are required to work alone and the
associated risks with the tasks being performed.
2. Based on the associated risks of the task, a communication plan shall be
developed that outlines the means of communication, employees involved,
intervals for contact, and emergency procedures.
3. The intervals of contact shall be determined by the hazard assessment but
shall not exceed two hours between contacts.
4. If radios or cellular phones are used as the primary means of communications,
the device shall be capable of reaching the designated point of contact or the
employee shall not work alone.
5. If radios or cellular phones are used, they must be available to the
employee(s) at all times.
6. If the task being performed requires leaving a radio or telephone equipped
vehicle, a proper communication device must be provided to the employee.
7. Regular intervals of contact shall be maintained until the employee returns to
their assigned work section.
C. ROLES & RESPONSIBILITY
Employees
1. Shall follow the established communication guidelines as defined in this
written standard and developed within your assigned work sections.
Managers
1. Managers and Supervisors shall ensure this safety standard is implemented
and followed in their areas of responsibility.
2. Identify and ensure adequate training for all employees that are affected by
this standard.
3. Shall perform a Hazard Assessment to determine the assignments where
employees are required to work along and the associated risks with the tasks
being performed.
D.
TRAINING REQUIREMENTS
1. No mandatory OSHA training requirement for this standard.
2. Ensure employees have adequate training to comply with this
standard.
E.
TRACKING REQUIREMENTS
1. No Tracking Requirements
F.
INSPECTION AND REVIEW
This guideline may be inspected during the quarterly safety committee inspection or
reviewed by Robinson Brothers Construction, Inc. Management or safety
representative.
Number
RBC-00-2009
Effective Date
Reference
ORS 437-02-151
Revision Number
September 1 , 2009
Number of Pages
3
0
Review Date
September 1 , 2010
Fleet Auto Policy
Robinson Brothers Construction, Inc. (RBC) is committed to the safe and efficient
operation of all company vehicles. We accept this responsibility and will make every
effort to provide an environment that encourages this objective.
By accepting this responsibility, we will endeavor to comply with all federal, state, and
local rules and regulations regarding vehicle operation, maintenance and use. Every
employee is an integral part of this process and is expected to meet this commitment.
RBC Safety Director has overall responsibility for the vehicle safety program. Drivers
are responsible for the care and operation of vehicles assigned to them.
Driver and Vehicle Maintenance Responsibility
•
•
There will be no driving company vehicles while under the influence of drugs
or alcohol. Exception with a written prescription from your physician that
does not interfere with your work or driving.
Maintenance identification needs of vehicles are the responsibility of the
assigned driver. Maintenance personnel are to be notified of mechanical
concerns other than regularly scheduled preventative maintenance service
work. Vehicles are to be maintained in a clean and acceptable condition to
reflect favorably on the company’s business image.
Company Vehicle Personal Use Policy
•
•
Intended use of company vehicles is for conduct of company business. No
personal use of company vehicles is allowed other than to commute to and
from the job site.
No other person is allowed to operate a company vehicle except assigned
driver or other authorized company employee.
Personal Vehicle Use Policy
Employees who drive their personal vehicles while conducting organization business are
subject to the requirements of this Fleet Safety Program and Policy.
Employees must:
•
•
•
•
Maintain auto liability insurance which meets or exceeds the state’s minimum
requirements, such as, but not limited to liability, bodily injury, property
damage, and Personal Injury Protection.
Keep their vehicles compliant with all organization and state vehicle
inspection requirements.
Perform a pre-trip safety check, maintain their vehicles in safe-operating
condition, and do not drive a vehicle which has a safety related issue.
Documentation of the vehicle maintenance is to be retained and available for
review.
Meet all driver qualification requirements.
MVRs (Motor Vehicle Reports)
•
•
•
Only employees with a valid driver’s license are allowed to drive company
vehicles on state and county roads. Employees may be authorized to briefly
drive on the jobsite.
MVRs are ordered and reviewed for all new drivers, to confirm the person
has an acceptable driving record before they are allowed to operate a
company vehicle. MVR’s are ordered and reviewed on an annual basis to
confirm the driver maintains an acceptable driving record.
At anytime during employment should a driver receive a violation or citation
on their driving record, whether in company or personal vehicle, they are to
report it to RBC management immediately.
Accidents
•
•
•
•
Report all accidents / incidents immediately to supervisor.
Make no statements about accepting responsibility for the accident. Give
official information only. Company name, name of insurance company, policy
#, drivers name, drivers license number, etc
Get name of other driver, driver license number, vehicle license number,
other driver’s insurance company and policy number.
Accidents will be investigated to determine root cause, and if it was
preventable by the driver.
Driver performance criteria
Drivers must have an acceptable driving record at the time of hire or when their job
duties require them to drive and are expected to maintain an acceptable driving record
on an ongoing basis. Driving privileges may be revoked for:
1. Conviction of driving under the influence of alcohol (drunk driving or any
other mind altering substance).
2. Refusal to take a breath analyzer test.
3. Two or more preventable accidents in a twelve (12) month period.
4. Fleeing the scene of an accident.
5. Homicide, assault, or criminal negligence resulting from the operation of a
vehicle.
6. Driving while license is suspended or revoked
7. Reckless driving.
8. Frequent and/or severe traffic violations such as:
a) Three (3) violations in three years.
b) Two (2) violations in three years, if speeding 15 or more m.p.h. of
posted limit; or
c) Two (2) violations in two years.
Employees who, during the annual MVR check, are discovered to have more than three
(3) moving violations and/or accidents in the previous 36 months are subject to
disciplinary action. Such disciplinary action may include (but is not limited to)
suspension from driving company vehicles, demotion to a non-driving classification
(possibly including a corresponding wage reduction), or discharge. RBC must consider
past driving records when determining penalties for excessive moving violations and/or
accidents.
Cell Phone Policy
While RBC recognizes the inevitability that some business communications must be
undertaken by employees while outside the office, it is our policy that safe driving is
always your first responsibility.
RBC does not support, encourage, or condone the use of cell phones or other electronic
communications devices by any of its employees while driving if doing so will cause any
distraction or compromise safety. Good judgment should be exercised at all times when
using a cell phone, and care must be taken to ensure that cell phone use does not
distract in any way from the paramount duty to operate a vehicle safely and in
compliance with all local and state rules of the road.
Unnecessary phone calls should be avoided. If it is necessary to use a cell phone while
driving, the following common sense safety guidelines should be followed:
•
A "hands free" device should be used for any phone calls initiated or received
while driving, so your hands remain on the steering wheel, and your eyes
remain on the road without interruption.
•
Unavoidable phone calls should be brief. Alert the person with whom you are
speaking at the outset of the conversation that you are on a cell phone and may
have to abruptly interrupt or postpone the call depending on traffic or other
conditions.
•
Never take notes of your phone call, look up phone numbers, or attempt to read
any materials during your phone conversation while driving.
•
Avoid using a phone in heavy traffic, adverse weather, or other hazardous road
conditions.
•
Consider deferring any cell phone calls you receive until you are no longer
driving, or routing the caller to voicemail so that you can retrieve and respond to
the phone call when not driving.
•
Initiate phone calls, if possible, when traffic is not moving or before you enter
traffic.
•
Employees sign & date below showing they have read this policy.
____________________________________
(Employee Printed Name)
_____________________________________
(Employee Signature)
_____________________________________
Date
_____________________________________
Company Representative
Number
RBC-13-09
Effective Date
Reference
Internal
Revision Number
September 1 , 2009
Number of Pages
19
0
Review Date
September 1 , 2010
Purpose:
 To protect those employees for which exposures can not be controlled by use
of conventional engineering controls or administrative controls.
July 2009
Evergreen Safety Council
Training and Fit Testing:

required on an annual basis including limitations
Tracking Requirements:
Robinson Brothers Construction (RBC) Management will maintain a list of employees
who are authorized to wear respiratory protection and the type of protection which
they are approved to use.
Inspection and Review:
RBC Management will review this program on an annual basis to ensure it is in
accordance with OSHA requirements.
Medical Evaluations:

All employees using respirators, including dust masks, will receive a
respiratory physical prior to using a respirator for the first time.
1910.134
Table of Contents
I.
Objective
II. Assignment of Responsibility
A. Employer
B. Program Administrator
C. Supervisors
D. Employees
III. Applicability
IV. Program
A. Hazard Assessment and Respirator Selection
B. Updating the Hazard Assessment
C. Training
D. NIOSH Certification
E. Voluntary Respirator Use
F. Medical Evaluation
G. Fit Testing
H. General Respirator Use Procedures
I. Air Quality
J. Change Schedules
K. Cleaning
L. Maintenance
M. Storage
N. Respirator Malfunctions and Defects
O. Emergency Procedures
P. Program Evaluation
Q. Documentation and Recordkeeping
V. Attachments
A. Sample Hazard Assessment Log
B. Sample Record of Respirator Use
C. Sample Hazard Evaluation
D. Sample Record of Respirator Issuance
E. Respirator Inspection Checklist
F. Sample Emergency Potential Log
G. Sample IDLH Assessment
Respiratory Protection Program
I.
OBJECTIVE
The Robinson Brothers Construction Respiratory Protection Program is designed
to protect employees by establishing accepted practices for respirator use, providing
guidelines for training and respirator selection, and explaining proper storage, use
and care of respirators. This program also serves to help the company and its
employees comply with Occupational Safety and Health Administration (OSHA)
respiratory protection requirements as found in 29 CFR 1910.134. From this point
forward in this document, Robinson Brothers Construction will be identified as
RBC.
II.
ASSIGNMENT OF RESPONSIBILITY
A. Employer
RBC is responsible for providing respirators to employees when they are
necessary for health protection and will provide respirators that are applicable
and suitable for the intended purpose at no charge to affected employees.
Any expense associated with training, medical evaluations and respiratory
protection equipment will be borne by the company.
B. Program Administrator
The Program Administrator for RBC is ________________. The Program
Administrator is responsible for administering the respiratory protection
program. Duties of the program administrator include:
1. Identifying work areas, process or tasks that require workers to
wear respirators.
2. Evaluating hazards.
3. Selecting respiratory protection options.
4. Monitoring respirator use to ensure that respirators are used in
accordance with their specifications.
5. Arranging for and/or conducting training.
6. Ensuring proper storage and maintenance of respiratory
protection equipment.
7. Conducting qualitative fit testing with Bitrex or smoke tube
8. Administering the medical surveillance program.
9. Maintaining records required by the program.
10. Evaluating the program.
11. Updating written program, as needed.
C. Supervisors
Supervisors at RBC are responsible for ensuring that the respiratory
protection program is implemented in their particular areas. In addition to
being knowledgeable about the program requirements for their own
protection, supervisors must also ensure that the program is understood and
followed by the employees under their charge. Duties of the supervisor
include:
1. Ensuring that employees under their supervision (including new
hires) receive appropriate training, fit testing, and annual medical
evaluation.
2. Ensuring the availability of appropriate respirators and
accessories.
3. Being aware of tasks requiring the use of respiratory protection.
4. Enforcing the proper use of respiratory protection when
necessary.
5. Ensuring that respirators are properly cleaned, maintained, and
stored according to this program.
6. Ensuring that respirators fit well and do not cause discomfort.
7. Continually monitoring work areas and operations to identify
respiratory hazards.
8. Coordinating with the Program Administrator on how to address
respiratory hazards or other concerns regarding this program.
D. Employees
Each employee is responsible for wearing his or her respirator when and
where required and in the manner in which they are trained. Employees must
also:
1. Care for and maintain their respirators as instructed, guard them
against damage, and store them in a clean, sanitary location.
2. Inform their supervisor if their respirator no longer fits well, and
request a new one that fits properly.
3. Inform their supervisor or the Program Administrator of any
respiratory hazards that they feel are not adequately addressed
in the workplace and of any other concerns that they have
regarding this program.
4. Use the respiratory protection in accordance with the
manufacturer’s instructions and the training received.
III.
APPLICABILITY
This program applies to all employees who are required to wear respirators during
normal work operations, as well as during some non-routine or emergency
operations, such as a spill of a hazardous substance.
In addition, any employee who voluntarily wears a respirator when one is not
required (i.e., in certain maintenance and coating operations) is subject to the
medical evaluation, cleaning, maintenance, and storage elements of this program,
and will be provided with necessary training. Employees who voluntarily wear
filtering face pieces (dust masks) are not subject to the medical evaluation, cleaning,
storage, and maintenance provisions of this program.
All RBC employees and processes that fall under the provisions of this program are
listed in Attachment D.
IV.
PROGRAM
A. Hazard Assessment and Respirator Selection
The Program Administrator will select respirators to be used on site, based on
the hazards to which workers are exposed and in accordance with the OSHA
Respiratory Protection Standard. The Program Administrator will conduct a
hazard evaluation for each operation, process, or work area where airborne
contaminants may be present in routine operations or during an emergency.
A log of identified hazards will be maintained by the Program Administrator
(See Sample Hazard Evaluation, Attachment C). The hazard evaluations shall
include:
1. Identification and development of a list of hazardous substances
used in the workplace by department or work process.
2. Review of work processes to determine where potential
exposures to hazardous substances may occur. This review shall
be conducted by surveying the workplace, reviewing the process
records, and talking with employees and supervisors.
3. Exposure monitoring to quantify potential hazardous exposures.
The proper type of respirator for the specific hazard involved will be selected
in accordance with the manufacturer’s instructions. A list of employees and
appropriate respiratory protection will be maintained by the Program
Administrator (see Attachment D).
B. Updating the Hazard Assessment
The Program Administrator must revise and update the hazard assessment as
needed (i.e., any time work process changes may potentially affect
exposure). If an employee feels that respiratory protection is needed during
a particular activity, he/she is to contact his/her supervisor or the Program
Administrator. The Program Administrator will evaluate the potential hazard,
and arrange for outside assistance as necessary. The Program Administrator
will then communicate the results of that assessment to the employees. If it
is determined that respiratory protection is necessary, all other elements of
the respiratory protection program will be in effect for those tasks, and the
respiratory program will be updated accordingly.
C. Training
The Program Administrator will ensure training is provided to respirator users
and their supervisors on the contents of the Robinson Brothers
Construction Respiratory Protection Program and their responsibilities
under it, and on the OSHA Respiratory Protection Standard. All affected
employees and their supervisors will be trained prior to using a respirator in
the workplace. Supervisors will also be trained prior to supervising employees
that must wear respirators.
The training course will cover the following topics:
1. RBC Respiratory Protection Program;
2. The OSHA Respiratory Protection Standard (29 CFR 1910.134);
3. Respiratory hazards encountered at RBC and their health affects;
4. Proper selection and use of respirators;
5. Limitations of respirators;
6. Respirator donning and user seal (fit) checks;
7. Fit testing;
8. Emergency use procedures;
9. Maintenance and storage; and
10. Medical signs and symptoms limiting the effective use of
respirators.
Employees will be retrained annually or as needed (e.g., if they change
departments or work processes and need to use a different respirator).
Employees must demonstrate their understanding of the topics covered in the
training through hands-on exercises and a written test. Respirator training will
be documented by the Program Administrator and the documentation will
include the type, model, and size of respirator for which each employee has
been trained and fit tested.
D. NIOSH Certification
All respirators must be certified by the National Institute for Occupational
Safety and Health (NIOSH) and shall be used in accordance with the terms of
that certification. Also, all filters, cartridges, and canisters must be labeled
with the appropriate NIOSH approval label. The label must not be removed or
defaced while the respirator is in use.
E. Voluntary Respirator Use
The Program Administrator shall authorize voluntary use of respiratory
protective equipment as requested by all other workers on a case-by-case
basis, depending on specific workplace conditions and the results of medical
evaluations.
The Program Administrator will provide all employees who voluntarily choose
to wear the above respirators with a copy of Appendix D of the OSHA
Respiratory Protection Standard. (Appendix D details the requirements for
voluntary use of respirators by employees.) Employees who choose to wear
a half face piece APR must comply with the procedures for Medical Evaluation,
Respirator Use, Cleaning, Maintenance and Storage portions of this program.
F. Medical Evaluation
Employees who are either required to wear respirators, or who choose to
wear a half face piece APR voluntarily, must pass a medical exam provided by
RBC before being permitted to wear a respirator on the job. Employees are
not permitted to wear respirators until a physician has determined that they
are medically able to do so. Any employee refusing the medical evaluation will
not be allowed to work in an area requiring respirator use.
A licensed physician at (to be determined) where all company medical
services are provided, will provide the medical evaluations. Medical
evaluation procedures are as follows:
1. The medical evaluation will be conducted using the questionnaire
provided in Appendix C of the OSHA Respiratory Protection
Standard. The Program Administrator will provide a copy of this
questionnaire to all employees requiring medical evaluations.
2. To the extent feasible, the company will provide assistance to
employees who are unable to read the questionnaire. When this
is not possible, the employee will be sent directly to the physician
for medical evaluation.
3. All affected employees will be given a copy of the medical
questionnaire to complete, along with a stamped and addressed
envelope for mailing the questionnaire to the company physician.
Employees will be permitted to complete the questionnaire on
company time.
4. Follow-up medical exams will be granted to employees as
required by the Standard, and/or as deemed necessary by the
evaluating physician.
5. All employees will be granted the opportunity to speak with the
physician about their medical evaluation, if they so request.
6. The Program Administrator shall provide the evaluating physician
with a copy of this Program, a copy of the OSHA Respiratory
Protection Standard, the list of hazardous substances by work
area, and the following information about each employee
requiring evaluation:
a. his or her work area or job title;
b. proposed respirator type and weight;
c. length of time required to wear respirator;
d. expected physical work load (light, moderate or heavy);
e. potential temperature and humidity extremes; and
f. Any additional protective clothing required.
7. Positive pressure air purifying respirators will be provided to
employees as required by medical necessity.
8. After an employee has received clearance to wear his or her
respirator, additional medical evaluations will be provided under
the following circumstances:
a. The employee reports signs and/or symptoms related to
their ability to use the respirator, such as shortness of
breath, dizziness, chest pains or wheezing.
b. The evaluating physician or supervisor informs the Program
Administrator that the employee needs to be reevaluated.
c. Information found during the implementation of this
program, including observations made during the fit testing
and program evaluation, indicates a need for reevaluation.
d. A change occurs in workplace conditions that may result in
an increased physiological burden on the employee.
A list of RBC employees currently included in medical surveillance is provided
in Attachment D of this program.
All examinations and questionnaires are to remain confidential between the
employee and the physician. The Program Administrator will only retain the
physician’s written recommendations regarding each employee’s ability to
wear a respirator.
G. Fit Testing
Employees who are required to or who voluntarily wear half-face piece APRs
will be fit tested:
1. prior to being allowed to wear any respirator with a tight-fitting
face piece;
2. annually; or
3. when there are changes in the employee’s physical condition that
could affect respiratory fit (e.g., obvious change in body weight,
facial scarring, etc.).
Employees will be fit tested with the make, model, and size of respirator that
they will actually wear. Employees will be provided with several models and
sizes of respirators so that they may find an optimal fit. Fit testing of
powered air purifying respirators will be conducted in the negative pressure
mode.
The Program Administrator or authorized representative will conduct fit tests
in accordance with the OSHA Respiratory Protection Standard.
H. General Respirator Use Procedures
1. Employees will use their respirators under conditions specified in
this program, and in accordance with the training they receive on
the use of each particular model. In addition, the respirator shall
not be used in a manner for which it is not certified by NIOSH or
by its manufacturer.
2. All employees shall conduct user seal checks each time they wear
their respirators. Employees shall use either the positive or
negative pressure check (depending on which test works best for
them) as specified in the OSHA Respiratory Protection Standard.
a. Positive Pressure Test: This test is performed by closing off
the exhalation valve with your hand. Breathe air into the
mask. The face fit is satisfactory if some pressure can be
built up inside the mask without any air leaking out between
the mask and the face of the wearer.
b. Negative Pressure Test: This test is performed by closing of
the inlet openings of the cartridge with the palm of you
hand. Some masks may require that the filter holder be
removed to seal off the intake valve. Inhale gently so that
a vacuum occurs within the face piece. Hold your breath for
ten (10) seconds. If the vacuum remains, and no inward
leakage is detected, the respirator is fit properly.
3. All employees shall be permitted to leave the work area to
maintain their respirator for the following reasons:
a. to clean their respirator if it is impeding their ability to
work;
b. to change filters or cartridges;
c. to replace parts; or
d. To inspect respirator if it stops functioning as intended.
Employees should notify their supervisor before leaving the area.
4. Employees are not permitted to wear tight-fitting respirators if
they have any condition, such as facial scars, facial hair, or
missing dentures, which would prevent a proper seal. Employees
are not permitted to wear headphones, jewelry, or other items
that may interfere with the seal between the face and the face
piece.
5. Before and after each use of a respirator, an employee or
immediate supervisor must make an inspection of tightness or
connections and the condition of the face piece, headbands,
valves, filter holders and filters. Questionable items must be
addressed immediately by the supervisor and/or Program
Administrator.
I. Air Quality
For supplied-air respirators, only Grade D breathing air shall be used in the
cylinders. The Program Administrator will coordinate deliveries of compressed
air with the company's vendor and will require the vendor to certify that the
air in the cylinders meets the specifications of Grade D breathing air.
The Program Administrator will maintain a minimum air supply of one fully
charged replacement cylinder for each SAR unit. In addition, cylinders may be
recharged as necessary from the breathing air cascade system located near
the respirator storage area.
J. Change Schedules
Respirator cartridges shall be replaced as determined by the Program
Administrator, supervisor(s), and manufacturers’ recommendations.
K. Cleaning
Respirators are to be regularly cleaned and disinfected at the designated
respirator cleaning station. Respirators issued for the exclusive use of an
employee shall be cleaned as often as necessary. Atmosphere-supplying and
emergency use respirators are to be cleaned and disinfected after each use.
The following procedure is to be used when cleaning and disinfecting reusable
respirators:
1. Disassemble respirator, removing any filters, canisters, or
cartridges.
2. Wash the face piece and all associated parts (except cartridges
and elastic headbands) in an approved cleaner-disinfectant
solution in warm water (about 120 degrees Fahrenheit). Do not
use organic solvents. Use a hand brush to remove dirt.
3. Rinse completely in clean, warm water.
4. Disinfect all facial contact areas by spraying the respirator with
an approved disinfectant.
5. Air dries in a clean area.
6. Reassemble the respirator and replace any defective parts.
Insert new filters or cartridges and make sure the seal is tight.
7. Place respirator in a clean, dry plastic bag or other airtight
container.
The Program Administrator will ensure an adequate supply of appropriate
cleaning and disinfection materials at the cleaning station. If supplies are
low, employees should notify their supervisor, who will inform the Program
Administrator.
L. Maintenance
Respirators are to be properly maintained at all times in order to ensure that
they function properly and protect employees adequately. Maintenance
involves a thorough visual inspection for cleanliness and defects. Worn or
deteriorated parts will be replaced prior to use. No components will be
replaced or repairs made beyond those recommended by the manufacturer.
Repairs to regulators or alarms of atmosphere-supplying respirators will be
conducted by the manufacturer.
1. All respirators shall be inspected routinely before and after each
use.
2. Respirators kept for emergency use shall be inspected after each
use, and at least monthly by the Program Administrator to assure
that they are in satisfactory working order
3. The Respirator Inspection Checklist (Attachment E) will be used
when inspecting respirators.
4. A record shall be kept of inspection dates and findings for
respirators maintained for emergency use.
5. Employees are permitted to leave their work area to perform
limited maintenance on their respirator in a designated area that
is free of respiratory hazards. Situations when this is permitted
include:
a. washing face and respirator face piece to prevent any eye
or skin irritation;
b. replacing the filter, cartridge or canister;
c. detection of vapor or gas breakthrough or leakage in the
face piece; or
d. Detection of any other damage to the respirator or its
components.
M. Storage
After inspection, cleaning, and necessary repairs, respirators shall be stored
appropriately to protect against dust, sunlight, heat, extreme cold, excessive
moisture, or damaging chemicals.
1. Respirators must be stored in a clean, dry area, and in
accordance with the manufacturer’s recommendations. Each
employee will clean and inspect their own air-purifying respirator
in accordance with the provisions of this program, and will store
their respirator in a plastic bag in the designated area. Each
employee will have his/her name on the bag and that bag will
only be used to store that employee’s respirator.
2. Respirators shall be packed or stored so that the face piece and
exhalation valve will rest in a near normal position.
3. Respirators shall not be placed in places such as lockers or
toolboxes unless they are in carrying cartons.
4. Respirators maintained at stations and work areas for emergency
use shall be stored in compartments built specifically for that
purpose, be quickly accessible at all times, and be clearly
marked.
5. The Program Administrator will store RBC supply of respirators
and respirator components in their original manufacturer’s
packaging when possible. The Administrator will provide
resources such as clean plastic boxes etc. to store and maintain
respirators when not in use.
N. Respirator Malfunctions and Defects
1. For any malfunction of an ASR (atmosphere-supplying
respirator), such as breakthrough, face piece leakage, or
improperly working valve, the respirator wearer should inform
his/her supervisor that the respirator no longer functions as
intended, and go to the designated safe area to maintain the
respirator. The supervisor must ensure that the employee either
receives the needed parts to repair the respirator or is provided
with a new respirator.
All workers wearing atmosphere-supplying respirators will work
with a buddy. The Program Administrator shall develop and
inform employees of the procedures to be used when a buddy is
required to assist a coworker who experiences an ASR
malfunction.
2. Respirators that are defective or have defective parts shall be
taken out of service immediately. If, during an inspection, an
employee discovers a defect in a respirator, he/she is to bring the
defect to the attention of his/her supervisor. Supervisors will
give all defective respirators to the Program Administrator. The
Program Administrator will decide whether to:
a. Temporarily take the respirator out of service until it can be
repaired;
b. Perform a simple fix on the spot, such as replacing a head
strap; or
c. Dispose of the respirator due to an irreparable problem or
defect.
When a respirator is taken out of service for an extended period of time, the
respirator will be tagged out of service, and the employee will be given a
replacement of a similar make, model, and size. All tagged out respirators will be
kept in a receptacle or box clearly labeled OOS- do not use.
O. Emergency Procedures
In emergency situations where an atmosphere exists in which the wearer of
the respirator could be overcome by a toxic or oxygen-deficient atmosphere,
the following procedure should be followed. The locations in Robinson
Brothers Construction (RBC) where the potential for dangerous
atmosphere exists are listed in Attachment F of this procedure. Locations of
emergency respirators are also listed in Attachment F.
1. When the alarm sounds, employees in the affected area must
immediately don their emergency escape respirator, shut down
their process equipment, and exit the work area.
2. All other employees must immediately evacuate the building.
RBC Emergency Action Plan describes these procedures
(including proper evacuation routes and rally points) in greater
detail.
3. Employees who must remain in a dangerous atmosphere must
take the following precautions:
a. Employees must never enter a dangerous atmosphere
without first obtaining the proper protective equipment and
permission to enter from the Program Administrator or
supervisor.
b. Employees must never enter a dangerous atmosphere
without at least one additional person present. The
additional person must remain in the safe atmosphere.
c. Communications (voice, visual or signal line) must be
maintained between both individuals and all present.
d. Respiratory protection in these instances is for escape
purposes only. RBC employees are not trained as
emergency responders, and are not authorized to act in
such a manner.
P. Program Evaluation
The Program Administrator will conduct periodic evaluations of the workplace
to ensure that the provisions of this program are being implemented. The
evaluations will include regular consultations with employees who use
respirators and their supervisors, site inspections, air monitoring and a review
of records. Items to be considered will include:
1.
2.
3.
4.
5.
6.
comfort;
ability to breathe without objectionable effort;
adequate visibility under all conditions
provisions for wearing prescription glasses;
ability to perform all tasks without undue interference; and
confidence in the face piece fit.
Identified problems will be noted in an inspection log and addressed by the
Program Administrator. These findings will be reported to RBC Management,
and the report will list plans to correct deficiencies in the respirator program
and target dates for the implementation of those corrections.
Q. Documentation and Recordkeeping
1. A written copy of this program and the OSHA Respiratory
Protection Standard shall be kept in the Program Administrator’s
office and made available to all employees who wish to review it.
2. Copies of training and fit test records shall be maintained by the
Program Administrator. These records will be updated as new
employees are trained, as existing employees receive refresher
training, and as new fit tests are conducted
3. For employees covered under the Respiratory Protection
Program, the Program Administrator shall maintain copies of the
physician’s written recommendation regarding each employee’s
ability to wear a respirator. The completed medical
questionnaires and evaluating physician’s documented findings
will remain confidential in the employee’s medical records at the
location of the evaluating physician’s practice.
ATTACHMENT A
Robinson Brothers Construction
Assessment Log
Hazard Assessment Log
DATE
Department
*
**
Contaminant
Exposure
Level
(8 hr TWA*)
PEL**
Controls
Summarized from Industrial Hygiene report provided by:
___________________________. (Name and title)
These values were obtained from a survey on average exposures as published
in the American Journal of Industrial Hygiene.
ATTACHMENT B
RBC Sample Record of Respirator Use
Required & Voluntary Respirator Use at Robinson Brothers Construction
Type of Respirator
Department/Process
Filtering face piece (dust mask)
Voluntary use for warehouse workers
Half-face piece APR or PAPR with P100 filter
Prep and Assembly
Voluntary use for maintenance workers
when cleaning spray booth walls or
changing spray booth filter
SAR, pressure demand, with auxiliary SCBA
Maintenance - dip coat tank cleaning
Continuous flow SAR with hood
Spray booth operations
Prep (cleaning)*
Half-face piece APR with organic vapor
cartridge
Voluntary use for Dip Coat Tenders, Spray
Booth Operators (gun cleaning), and
maintenance workers (loading coating
agents into supply systems)
Escape SCBA
Dip Coat, Coatings Storage Area, Spray
Booth Cleaning Area
* Until ventilation is installed.
ATTACHMENT C
Sample Hazard Evaluation
Process Hazard Evaluation for Robinson Brothers Construction
DATE
Process
Noted Hazards
Prep-sanding
Ventilation controls on some sanders are in place, but
employees continue to be exposed to respirable wood dust at
2.5 - 7.0 mg/m3 (8 hour time-weighted-average, or TWA).
Half-face piece APRs with P100 filters and goggles are required
for employees sanding wood pieces. PAPRs will be available for
employees who are unable to wear an APR.
Prep-cleaning
Average methylene chloride exposures measured at 70 ppm
based on 8-hour TWA exposure results for workers cleaning
and stripping furniture pieces. Ventilation controls are
planned, but will not be implemented until designs are
completed and a contract has been let for installation of the
controls. In the meantime, employees must wear supplied air
hoods with continuous airflow, as required by the Methylene
Chloride Standard 1910.1052.
Assembly
Ventilation controls on sanders are in place, but employees
continue to be exposed to respirable wood dust at 2.5 - 6.0
mg/m3 (8 hour TWA); half-face piece APRs with P100 filters
and goggles are required for employees sanding wood pieces in
the assembly department. PAPRs will be available for
employees who are unable to wear an APR. The substitution
for aqueous-based glues will eliminate exposures to
formaldehyde, methylene chloride, and epoxy resins.
Maintenance
Because of potential IDLH conditions, employees cleaning dip
coat tanks must wear a pressure demand SAR during the
performance of this task.
Cleaning Spray Booth
Walls
Employees may voluntarily wear half-face piece APRs with
P100 cartridges. Although exposure monitoring has shown
that exposures are kept within PELs during this procedure,
RBC will provide respirators to workers who are concerned
about potential exposures
Loading Coating Agents
into Supply Systems
organic vapor cartridges. Although exposure monitoring has
shown that exposures are kept within PELs during this
procedure, RBC will provide respirators to workers who are
concerned about potential exposures
Changing Booth Filters
P100 cartridges. Although exposure monitoring has shown
that exposures are kept within PELs during this procedure,
RBC will provide respirators to workers who are concerned
about potential exposures
(Include documentation of the sampling data that hazard evaluation is based on.)
ATTACHMENT D
Sample Record of Respirator Issuance
Personnel in Respiratory Protection Program
Date
Respiratory protection is required for and has been issued to the following personnel:
Name
Department
Job Description/
Work Procedure
Type of
Respirator
Operator
Half mask APR
P100 filter when
sanding/ AR
continuous flow
hood for
cleaning
Spray Booth
SAR, continuous
Date
Issued
ATTACHMENT E
RBC Respirator Inspection Checklist
Type of Respirator:
Location:
Respirator Issued to:
Type of Hazard:
Face piece
_________ Cracks, tears, or holes
_________ Face mask distortion
_________ Cracked/loose lenses/face
shield
Head straps
_________ Breaks or tears
_________ Broken buckles
Valves:
_________ Residue or dirt
_________ Cracks or tears in valve
material
Filters/Cartridges:
_________
_________
_________
_________
Approval designation
Gaskets
Cracks or dents in housing
Proper cartridge for hazard
Air Supply Systems
_________
_________
_________
_________
valves
Breathing air quality/grade
Condition of supply hoses
Hose connections
Settings on regulators and
Rubber/Elastomer Parts
_________ Pliability
_________ Deterioration
Inspected by:
Action Taken:
Date:
ATTACHMENT F
Sample Emergency Potential Log
The following work areas at Robinson Brothers Construction have been identified
as having foreseeable emergencies:
Area
Type of Emergency
__________________________________
Program Administrator
Location of
Emergency
Respirator(s)
____________________
Date
ATTACHMENT G
Sample Immediately Dangerous to Life and Health (IDLH) Assessment Log
The Program Administrator has identified the following area as presenting the
potential for IDLH conditions:
Process
IDLH Condition
Any Permit Required
Confined Space
________________________________
Program Administrator
Procedure
Workers will follow the permit
required confined space entry
procedures specified in the
Confined Space Program. As
specified in these procedures, the
Program Administrator has
determined that workers entering
this area shall wear a pressure
demand SAR. In addition, an
appropriately trained and equipped
standby person shall remain outside
the dip tank and maintain constant
voice and visual communication with
the worker. In the event of an
emergency requiring the standby
person to enter the IDLH
environment, the standby person
shall immediately notify the Program
Administrator and will proceed with
rescue operations in accordance with
rescue procedures outlined in the
Confined Space Program.
________________________
Date
Number
RBC-13-09
Effective Date
Reference
Internal
Revision Number
September 1 , 2009
Number of Pages
7
0
Review Date
September 1 , 2010
Hearing Conservation Program
Occupational Safety and Health Consultation Program
1910.95
The following hearing conservation program is provided only as a guide to assist
employers and employees in complying with the requirements of OSHA’s Hearing
Conservation Standard, 29 CFR 1910.95, as well as to provide other helpful
information. It is not intended to supersede the requirements of the standard. An
employer should review the standard for particular requirements which are
applicable to their individual situation and make adjustments to this program that
are specific to their company. An employer will need to add information relevant to
their particular facility in order to develop an effective, comprehensive program.
1910.95
Table of Contents
I.
Objective
II.
Assignment of Responsibility
A. Management
B. Employees
III.
Procedures
A. Noise Monitoring
B. Employee Training
C. Hearing Protection
D. Audiograms/Hearing Tests
IV.
Attachments
A. Hearing Conservation Training Log
B. Record of Hearing Protection Needs
I.
OBJECTIVE
The objective of the Robinson Brothers Construction Hearing Conservation
Program is to minimize occupational hearing loss by providing hearing protection,
training, and annual hearing tests to all persons working in areas or with equipment
that have noise levels equal to or exceeding an eight-hour time-weighted average
(TWA) sound limit of 85 dBA (decibels measured on the A scale of a sound level
meter). A copy of this program will be maintained by all affected departments. A
copy of OSHA’s Hearing Conservation Standard, 29 CFR 1910.95, can be obtained
from ____________________, RBC Hearing Conservation Program Administrator.
A copy of the standard will also be posted in areas with affected employees. Within
this document, Robinson Brothers Construction Company will be referred to as RBC.
II.
ASSIGNMENT OF RESPONSIBILITY
A. Management
1. Use engineering and administrative controls to limit employee
exposure.
2. Provide adequate hearing protection for employees.
3. Post signs and warnings in all high noise areas.
4. Conduct noise surveys annually or when new equipment is
needed.
5. Conduct annual hearing test for all employees.
6. Conduct hearing conservation training for all new employees.
7. Conduct annual hearing conservation training for all employees.
B. Employees
1. Use company-issue approved hearing protection in designated
high noise areas.
2. Request new hearing protection when needed.
3. Exercise proper care of issued hearing protection.
III.
PROCEDURES
A. Noise Monitoring
1. Monitoring for noise exposure levels will be conducted by Gene
Rushing, Evergreen Safety Council. . It is the responsibility of the
individual departments to notify ______________________ (safety
director) when there is a possible need for monitoring. Monitoring will
be performed with the use of sound level meters and personal
dosimeters at the discretion of Evergreen Safety Council; i.e. Gene
Rushing.
2. Monitoring will also be conducted whenever there is a change in
equipment, process or controls that affect the noise levels. This
includes the addition or removal of machinery, alteration in building
structure, or substitution of new equipment in place of that previously
used. The responsible supervisor must inform RBC Management when
these types of changes are instituted.
B. Employee Training
1. Affected employees will be required to attend training concerning
the proper usage and wearing of hearing protection. The training will
be conducted by Evergreen Safety Council, or a designated
representative, within a month of hire and annually thereafter.
2. Training shall consist of the following components:
a.
b.
c.
d.
e.
f.
How noise affects hearing and hearing loss;
Review of the OSHA hearing protection standard;
Explanation of audiometric testing;
Rules and procedures;
Locations within company property where hearing
protection is required; and
How to use and care for hearing protectors.
3. Training records will be maintained by ______________________
(safety director) (see Attachment A).
C. Hearing Protection
Management, supervisors, and employees shall properly wear the prescribed
hearing protection while working or traveling through any area that is
designated as a high noise area.
1. Hearing protection will be provided at no cost to employees who
perform tasks designated as having a high noise exposure and
replaced as necessary. It is the supervisor’s responsibility to require
employees to wear hearing protection when noise levels reach or
exceed 85 dBA. Those employees will have the opportunity to choose
from at least two different types of hearing protection.
2. Personal stereo headsets, or “Walkman,” or MP3 players or IPods
are not approved for hearing protection and are not permitted in any
operating area of company property.
3. Signage is required in areas that necessitate hearing protection. It
is the responsibility of RBC Management to provide signage to the
appropriate areas.
4. Pre fitted earplugs and earmuffs should be washed periodically and
stored in a clean area. Foam inserts should be discarded after each
use. Hands should be washed before handling preformed earplugs and
foam inserts to prevent contaminants from being placed in the ear.
5. RBC Safety Director will keep a log of the areas or job tasks
designated as requiring hearing protection, as well as the personnel
affected by this Hearing Conservation Program (see Attachment B).
D. Audiograms/Hearing Tests
1. Employees subject to the Hearing Conservation Program who have
time-weighted average (TWA) noise exposures of 85 dBA or greater
for an eight (8) hour work shift will be required to have both a baseline
and annual audiogram. The audiograms will be provided by the RBC
and conducted by (Contractor TBD) with no cost to the employee.
2. The baseline audiogram (if warranted by prior measurement will be
given to an employee within one (1) month of employment with RBC
and before any exposure to high noise levels. Annual audiograms will
be performed within one year from the date of the previous
audiogram. It is the responsibility of the individual and the RBC Safety
Director to schedule the annual audiogram.
3. If an annual audiogram shows that an employee has suffered a
standard threshold shift, the employee will be retested within thirty
(30) days of the annual audiogram. If the retest confirms the
occurrence of a standard threshold shift, the employee will be notified
in writing within twenty-one (21) days of the confirmation. Employees
who do experience a standard threshold shift will be refitted with
hearing protection and provided more training on the effects of noise.
Attachment A
Hearing Conservation Training Log
Training Date:__________________________________
Topic:_________________________________________
Training Conducted by:__________________________
Employee Name
(printed)
Employee Signature
Job Title
Attachment B
Record of Hearing Protection Needs
Personnel in Hearing Conservation Program
July 2009
Hearing protection is required for and has been issued to the following personnel:
Employee
Name
Department
Job
Description/
Equipment
Being Used
Type of
Hearing
Protection
Issued
Date Issued
Safety Training Matrix
Number
RBC-11-09
Reference
Internal
Effective Date
Revision Number
September 1 , 2009
0
Number of Pages
1
Review Date
September 1 , 2010
New Hires
Safety Orientation
Hazard Communication
DOT Training
All Employees
Foremen
Field Supervisors
4 Hrs upon
hire
2 Hrs upon
hire
2 Hrs upon
hire
Lockout/Tagout
10 Hrs. annually
First Aid & Heat Stress
10 Hrs. annually
CPR
10 Hrs. annually
Excavation/Competent Person
Confined Space
Traffic Control & Flagging
Safety
Probable Cause/Drug and
Alcohol
Forklift
Aerial Lifts/Scissor Lifts
Crane Operation
* As needed for specific task or position
10 Hrs.
annually
10 Hrs.
annually
10 Hrs.
annually
10 Hrs.
annually
10 Hrs.
annually
10 Hrs.
annually
8-16 Hrs. annually
8-16 Hrs. annually
8-16 Hrs. annually
8-16 Hrs. annually
8-16 Hrs. annually
8-16 Hrs. annually
8-16 Hrs. annually
4 Hrs. as
needed*
4 Hrs. as
needed*
24 Hrs. as
needed*

Safety and Health Program - RBC, Robinson Brothers Construction

Transcription

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