Topic: Upcoming Safety Issues in the High Tech Industry
Most Frequently Cited Cal/OSHA Standards
Jay highlighted the Cal/OSHA standards for which violations are most frequently cited, including:
New and Impending Regulations
New Cal/OSHA standards for blood-borne pathogens became effective in July '99, requiring use of sharps devices with "engineered sharps injury protection" (esip) and maintenance of a sharps injury log. The first citation under these regulations was recently issued to a hospital for failure to use esip. Check out the Cal/OSHA Fact Sheet (Cal-OSHA Reporter 66-203, 7/30/99) and link to a list of devices with esip at www.ohb.org/sharps.htm.
Since the Ergonomics standard (5110) was adopted, there have been many legal challenges. A recent court decision establishes it as a performance standard: If you develop and implement your ergonomic protection program in good faith, they you are in compliance. Another court decision removed the small employer exemption: Now all employers, no matter how many employees they have, are covered by the ergonomics standard. You still have to have a doctor make the determination that an injury is a "repetitive motion injury" (rmi), and the requirement for having a written ergonomic protection program is still triggered if you have two or more rmi/year.
As of May '99, there are many new requirements for respiratory protection programs. The written program must specify a change-out schedule for cartridge-type respirators. The program must identify a Respiratory Protection Program Administrator, with specific training requirements. There are new annual training requirements, substantially more stringent requirements for qualitative fit-testing, and many other changes.
The federal standards for confined space rescue have changed, so that now they are more stringent than the Cal/OSHA requirements. Under the new federal standards, if you are relying on outside responders (e.g. fire department, public emergency medical service) then you must evaluate the capacity and proficiency of the responder, inform prospective responders of the potential hazards at your facility, and offer site visits for the responder to become familiar with your facility.
Beginning July 2000, Cal/OSHA standards for forklift training will require operator competence evaluation every three years, and annual training only under certain conditions (an accident has occurred, unsafe driving is observed, new equipment, or other change in conditions).
The Workers Safety Reform Act (AB1127, effective January 1, 2000), allows Title 8 regulations to be entered as evidence in civil suits, and greatly expands the scope of employees who can initiate a formal Cal/OSHA complaint to include an employee's attorney, an environmental health and safety professional, a government official, union representative, or contractor. This legislation is expected to increase litigation and inspections: Cal/OSHA is required to inspect within 14 days of any serious violation and 10% of non-serious violations. Cal/OSHA has received increased funding, and will be hiring more inspectors to respond to the changes brought by this legislation. The new law also increases fines and jail terms for Cal/OSHA violations, and removes protection of government agencies from fines and penalties.
Other developments to watch for in 2000: Upcoming legislation will protect users of defibrillator units under a "good Samaritan" provision, and their use in the work-place will become much more common. There will be new equipment certification standards for SEMI S2. The ANSI laser standard will be modified.
Thanks, Jay, for an information-packed meeting! Those of you looking for more information can contact Jay at JayJam@environsafetech.com.
Topic: Overview of Bioaerosols and Their Role in Indoor Air Quality
At the July Dinner Meeting, Phil Bumala, Industrial Hygienist with The Denali Group, gave us an overview of bioaerosols and their role in indoor air quality problems. Mr. Bumala has a long professional history of examining indoor air quality problems, looking at sources ranging from bat guano to Legionella. He began his career working on air emissions from large industrial sources, and eventually focused his expertise as an industrial hygienist in looking at the effects of specific air contaminants on people. Indoor air quality is an age-old problem. In fact, the Bible (Leviticus Chapter. 14: Versus 33-57) provides procedures for remediation of fungi in a building, presumably the first industrial hygiene specification. In modern times, indoor air quality issues have typically been associated with VOCs, particulates, and ventilation problems. Recently, more attention is aimed at biological agents, such as fungi and bacteria, as important sources of indoor air quality problems. Fungi have two life-cycles with different forms that present different potential air quality impacts: a filamentous form that reproduces asexually, and spores which are widely dispersed by air. Spores can be released in large quantities: One species releases up to 30 billion spores/day, which can present serious respiratory problems indoors where the concentration of spores is not diluted by ambient air. One such fungus can secrete a microtoxin that is a suspected carcinogen. Fungi that propagate through passive dispersion can persist in the environment, remaining dormant while dry until they are reactivated by moisture. Bioaerosols in indoor air can cause both acute and chronic health effects. Allergies and other long-lasting, severe respiratory problems related to bioaerosols have been found in silo and mill workers, and users of old garage shops and other unattended structures without routine maintenance. Recommended mitigation measures include: · Stop moisture intrusion. · Identify and eliminate dispersal routes (e.g. HVAC system). · Remove contaminated materials. · Desiccate contaminated material. Commonly attempted mitigation measures that are NOT recommended include: · Heating - heat stimulates growth of biological agents. · Spraying Clorox or other non-specific disinfectants - it's a temporary cosmetic fix. There are disinfectants that are specifically formulated for remediating biological contamination. · Removing contaminated building materials without proper personal protective equipment and/or engineering controls - this can result in significant exposures to workers and occupants. · Sealing contamination without completely drying contaminated materials. Building materials can get wet from outside or inside through rain, groundwater, or vapor penetration. Moisture migrates from warm areas to cold areas, therefore the sources of moisture and routes of migration vary in different climates. One of the best ways to prevent bioaerosol contamination is in design and selection of buildings to control movement of moist air. "Portables" used as school classrooms can often suffer bioaerosol-related air quality problems because they are usually constructed quickly and cheaply, using lots of high organic content materials such as press-board and bulletin boards.
Speaker: Paul Blais, DTSC Deputy Director
Meeting Synopsis developed by Carol Bach, CHMM, 1999 Secretary NCC-ACHMM
Paul Blais, DTSC's Deputy Director for the State's Superfund program spoke to attendees at the April dinner meeting. Since the State's Superfund law sunseted in 1998, DTSC has continued to oversee current State Superfund projects under the authority of the hazardous waste statute. Senator Byron Sher has authored SB47, an emergency statute that would reinstate the State's Superfund law, applicable retroactively to January 1, 1999. Governor Gray Davis is expected to sign this legislation in May.
Speaker: George Carson, Risk Management Plan Program Manager for Santa Clara County Department of Environmental Health,
Summary by Carol Bach, CHMM, Secretary NCC-ACHMM
Mr. Carson provided an overview of California's Accidental Release Program.
The CalARP program replaces the State's Risk Management and Prevention Program, and is implemented by local agencies. Use or storage of federally listed toxics or flammables, or state listed toxics above the threshold planning quantity triggers applicability of the CalARP requirements. The CalARP program includes three tiers of requirements depending upon the nature of the facility.
Speaker: Heather Shepard, Wine Industry Consultant
Meeting Summary by John Wondolleck, CHMM. Our December 1998 Dinner Meeting coincided with our annual Wine Tasting event. The Wine Tasting was again hosted by Ivan Wong who provided an array of local wines. He also opened a bottle from his personal collection (an aged wine worth money to wine collectors). NCC-ACHMM again thanks Ivan for his efforts and support this year.
October 22, 1998 Dinner Meeting (Joint Meeting ACHMM Board/NCC-ACHMM October Meeting)
Speaker: James L. Meeder,
Our October 1998 was a joint meeting with the National Academy of Certified Hazardous Materials Managers. The quarterly meeting of the national Board was being held in San Francisco on October 23. Cindy Savage, ACHMM President, spoke first. Cindy summarized ACHMM activities including the reduced rates Comania (sp?) Insurance is offering to CHMMs. ACHMM is working on a reference book that will be available the first quarter of 1999.
Harry Kemp, ACHMM Treasurer, also said a few words. ACHMM is in the black. ACHMM is not spending funding on budgeted activities due to a lack of CHMM leaders to take on tasks. ACHMM is also looking for leadership to establish new chapters
Speaker: Dr. Bart Simmons, California Department of Toxic Substances Control
Speaker: Dr. Shanna Swan of the California Department of Health Services
Speaker: Mr. Mike Lozeau, Executive Director, Baykeeper
Speaker: Mr. Tom Adkisson of PRC/TetraTech
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Last Update March 27, 2000