OSHA for Weatherization Contractors and Inspectors Joann Natarajan OSHA Austin Office
Objectives Who OSHA has coverage over Most Frequently Cited for weatherization industry Confined Space in Construction Fall hazards Personal Protective Equipment
What is OSHA? A Federal Agency that enforces safety laws in the United States OSHA covers employees of an employer OSHA has jurisdiction over private sector and Federal civilian employment OSHA does not cover city, county or state workers OSHA does not cover the general public the self employed, sole owners or partners
Top 10 Hazards for Weatherization Contractors 1. Scaffolds General requirements 2. Fall protection 3.Hazard Communication 4. Excavations General requirements 5. Respirators 6. Ladders 7. Excavations Specific methods 8. Aerial Lifts 9. Safety Training 10. Scaffolds specific requirements
1. Scaffolds ANY temporary elevated work platform Working levels fully planked and decked Firm and stable footings 18 wide platform
If a worker can fall more than 4 ft. or 6 ft. the employer must guard against the fall using guard rails, safety nets, or personal fall arrest systems 2. Fall Protection
3. Hazard Communication Written program Safety Data Sheets Worker Training Labeling in house containers New GHS labels and safety data sheets
4. Excavations Supporting utilities/calling 811 Safe Access Keeping vehicles from falling in Hazardous atmospheres Water accumulation Daily inspection Adjacent structures
5. Respirators ASSESS, then select 1 st - Engineering controls Medical questionnaire Fit testing Employee training on use, maintenance, and inspection
6. Ladders Worker training Load rating and good condition Three points of contact Three feet extended for entering/exiting the ladder
7. Excavations Cave in protection is required when deeper than 5 ft. Shields Benching Shoring Sloping
8. Aerial Lifts Worker must wear body harness, lanyard and be tied off to the lift Workers feet must remain in the basket
9. Safety Training Workers must be trained on the hazards that they will encounter on the jobsite such as chemicals, plants, animals and appropriate personal protective equipment
10. Scaffolds Specific requirements for types of scaffolds including: Pump jack Ladder jack
Confined Space in Construction What is a confined space? Big enough to enter Not for regular occupancy Difficult to exit Examples include: Sewers, pits, crawl spaces, attics, boilers, tanks, etc. Hazards include: Low oxygen, toxic atmospheres, flammables/explosives, animals and insects, etc., and hazards caused by the work being done!
What is a Permit Space? Permit-Required Confined Space (Permit Space) A confined space WITH Hazardous or potentially hazardous atmosphere; Engulfment hazard; Physical Hazard; Other serious safety or health hazard
Who Evaluates the Space? The employer must designate a competent person to evaluate confined spaces The competent person is knowledgeable about the actual or potential hazards and has the authority to correct them The competent person would evaluate the attic, crawl space to determine if the space is a permit required confined space
OSHA Memo Dated 5-24-16 https://www.osha.gov/confinedspaces/ls_ ResidentialConstruction_05242016.html Multiple scenarios regarding entry into attics are addressed Entry/exit by pull down ladder could make the space confined if it impedes egress The mere presence of electrical in an attic does not make it a confined space, ther must be exposed live electrical
OSHA Memo Dated 5-24-16 Heat must be so extreme that it could potentially impede an entrant's ability to exit the attic without assistance Performance of duties outside of an attic would only turn a "confined space" into a "permitrequired confined space" if the work outside of the attic could create a hazardous atmosphere or physical hazard in the attic that could impede the ability of an entrant to safely exit the space without assistance
OSHA Memo Dated 5-24-16 Attics with full-sized doors at least two feet in width and six feet, six inches in height would not meet the definition of a confined space HVAC repair is considered maintenance work on the unit such as adjusting existing equipment or replacing component parts in kind.
OSHA Memo Dated 5-24-16 Upgrading the HVAC system or its component parts would be considered construction work. This would also be the case for any other piece of equipment in an attic that is a confined space. Basements are not confined spaces if they have means of access that do not impede the entrant from self rescue
OSHA Memo Dated 5-24-16 Initial entry into attic/basement by competent person is not required to make determination the space is a permit required confined space. Fall hazards through drywall
Site evaluation: Who does what? Any employer whose employee may enter a confined space needs to ensure that the site is evaluated and spaces are posted, but the evaluation and posting may be coordinated through a single employer. Site evaluation involves hazard recognition hazards already in the space, and hazards created as a result of the work being done.
Who does what? Permit issuance: Entry employers (employers who direct workers to enter a permit space) must develop and post permits. Permits list required entry conditions, equipment that must be used, and track who is inside the space.
Proper Prior Planning Awareness of hazards Addressing hazards BEFORE entering Preparation for rescue in the event of an emergency/unanticipated condition. With planning and forethought, many construction employers will be able to avoid the need for a permit space program.
Helpful Information https://www.osha.gov/ Publications/OSHA38 25.pdf https://www.osha.gov/ confinedspaces/index.html
Fall Hazards Falls of more than 4 feet must be guarded against Can use fall protection, guardrails, safety nets
Fall Protection Numerous devices exist for fall protection Listing of devices: http://www.ot.wustl.ed u/fptech/index.htm
Other Work Methods Work from a ladder, scaffold, aerial lift
Personal Protective Equipment Eye protection is required if chemicals or chips can strike the eye For corrosive chemicals, faceshield or chemical goggles are required
Head Protection Where objects can strike the head, heard hats are required Ex: Workers walking on ground adjacent to a scaffold that has workers on it
When handling heavy objects, steel toed footwear may be required Foot Protection
Questions? Natarajan.joann@dol.gov 512-374-0271 x 232