Contractor responsibilities

The contractor shares an obligation with the employer to ensure workplace safety. Contractors must communicate planned work activities, associated tasks, and contracted versus host facility assignments. Contractors must also provide the tools, equipment, and training for contract employees.

In cases where there are prime contractors and subcontractors, OSHA requires each to make their own arrangements with respect to workplace obligations, which might be more appropriately treated on a jobsite basis, rather than individually. For example, the prime contractor and subcontractors may wish to make an express agreement that the prime contractor will provide all required first-aid or toilet facilities, thus relieving the subcontractor from the actual, but not any legal, responsibility.

Whether prime or sub, any contractor agreeing to perform any part of the contract, also assumes responsibility for complying with regulatory standards related to each part. So, the prime contractor assumes the entire responsibility under the contract and the subcontractor assumes responsibility with respect to their portion of the work. For subcontracted work, the prime contractor and any subcontractor(s) have joint responsibility according to OSHA. And where joint responsibility exists, both are considered subject to the enforcement provisions of the OSH Act.

Employer responsibilities

Both the employer and the contractor have a responsibility to comply with safety regulations. Employer responsibilities when working with contractors is to still provide a safe and healthful workplace. However, it becomes even more vital to establish clear expectations, communicate openly, provide necessary training, and monitor activities when contractors are involved.

Host employers have the responsibility to ensure contractors understand expectations and responsibilities for assigned tasks before, during, and after work is performed. Employers should carefully review contractor safety programs to ensure they align with company requirements and develop a written plan or contract addressing individual responsibilities.

Ultimately, the employer is responsible for hazardous conditions specific to their workplace. The contractor is responsible for hazards they may bring onto or create on site, as well as ensuring their employees understand how to perform their jobs safely.

Training

With so many risks associated with contractors who work in unfamiliar workplaces and the potential hazards they may encounter, training is a essential for an effective safety program.

The contractor must:

• Train all workers on all safety and health hazards and provisions applicable to the type of work being done, and provide documentation of such training to you or your designated representative; and
• Train its employees on where to obtain first-aid and medical services.

The employer must:

• Ensure that affected company employees receive training on all hazards to which they will be introduced by a contractor; and
• Emphasize to the contractor that it is the contractor’s responsibility to convey to its employees any safety information provided by the company to the contractor.

Policies and reporting

Your company may already have a written safety policy covering contractor relationships. If this is the case, follow its guidelines whenever you work with a contractor. A written contractor safety policy usually has guidelines to provide a safe working environment; govern host facility relationships with outside contractors; and ensure that contractor employees and host employees are trained to protect them from all potential and existing hazards. Even if you don’t have a formal policy, you should have uniform requirements for contractor safety orientation, coordination, and safety administrative practices.

The host employer must make sure that contractors perform their work safely by:

• Informing the contractor of known potential fire, explosion, or toxic release hazards related to the contractor’s work;
• Explaining the applicable provisions of the emergency action plan to the contractor, and requiring that the contractor disperse that information to all workers who will work at that site;
• Developing and implementing safe work procedures to control contract employee entry into hazardous work areas;
• Maintaining a contract employee injury and illness log;
• Periodically evaluating the contract employer’s fulfillment of responsibilities under this policy; and
• Using only contractors who meet your company’s standards in safety and health.

For reporting, the host employer must designate a representative to coordinate and communicate all safety and health issues with the contractor. The designated representative must have a copy of the contract, be thoroughly familiar with its contents, and with the safety and health aspects of the work, or know who to call to obtain this information.

The host’s designated representative should ensure that all company responsibilities listed below are carried out by:

• Providing a copy of the facility’s written safety policies and procedures to the contractor;
• Informing the contractor of any emergency signals and procedures, including the telephone numbers of the nearest hospital, ambulance service, and fire department;
• Conducting an inspection of the proposed worksite area before the pre-start up meeting so any known information about onsite hazards, particularly non-obvious hazards, are documented and thoroughly communicated to the contractor;
• Working directly with the contractor’s designated representative, with whom all contacts should be made;
• Conducting a pre-start up meeting (walk through) with the contractor’s designated representative and a supervisor from each area of the plant that will be involved in the contractor’s work;
• Reviewing all contract requirements related to safety and health with the contractor’s designated representative, including, but not limited to, rules and procedures, personal protective equipment, and special work permits or work procedures;
• Advising the contractor that the facility safety and health policies must be followed. A copy of the host facility’s safety plans must be furnished to the contractor;
• Informing the contractor’s designated representative of the required response to employee alarms and furnishing the contractor with a demonstration or explanation of the alarms;
• Communicating any safety and health hazards (particularly non-obvious hazards and hazard communication issues). It is the contractor’s responsibility to convey this information to its employees;
• Reviewing worksite preparation procedures before the contractor begins initial work;
• Identifying connect-points for all services, such as steam, gas, water, and electricity. Define any limitations for the use of such services; and
• Ensuring that all affected host employees receive training on all hazards to which they may be exposed during the contractor’s work.

Concrete/Masonry construction key definitions

• Key definitions for concrete/masonry construction are found in this section.

Bull float: A tool used to spread out and smooth concrete.

Formwork: The total system of support for freshly placed or partially cured concrete, including the mold or sheeting (form) that is in contact with the concrete as well as all supporting members including shores, reshores, hardware, braces, and related hardware.

Jacking operation: The task of lifting a slab (or group of slabs) vertically from one location to another (e.g., from the casting location to a temporary (parked) location, or from a temporary location to another temporary location, or to its final location in the structure), during the construction of a building/structure where the lift-slab process is being used.

Lift slab: A method of concrete construction in which floor and roof slabs are cast on or at ground level and, using jacks, lifted into position.

Limited access zone: An area alongside a masonry wall that is under construction, and that is clearly demarcated to limit access by employees.

Precast concrete: Concrete members (such as walls, panels, slabs, columns, and beams) that have been formed, cast, and cured prior to final placement in a structure.

Reshoring: The construction operation in which shoring equipment (also called reshores or reshoring equipment) is placed as the original forms and shores are removed, in order to support partially cured concrete and construction loads.

Shore: A supporting member that resists a compressive force imposed by a load.

Vertical slip forms: Forms that are jacked vertically during the placement of concrete.

Steel erection key definitions

• Key definitions for the steel erection industry are found in this section.

Column: A load-carrying vertical member that is part of the primary skeletal framing system. Columns do not include posts.

Competent person: One who is capable of identifying existing and predictable hazards in the surroundings or working conditions that are unsanitary, hazardous, or dangerous to employees, and who has authorization to take prompt corrective measures to eliminate them.

Controlling contractor: A prime contractor, general contractor, construction manager or any other legal entity which has the overall responsibility for the construction of the project — its planning, quality and completion.

Multiple lift rigging: A rigging assembly manufactured by wire rope rigging suppliers that facilitates the attachment of up to five independent loads to the hoist rigging of a crane.

Opening: A gap or void 12 inches (30.5 cm) or more in its least dimension in a floor, roof or other walking/working surface. For the purposes of this subpart, skylights and smoke domes that do not meet the strength requirements of 1926.754(e)(3) shall be regarded as openings.

Multiple lift rigging: A rigging assembly manufactured by wire rope rigging suppliers that facilitates the attachment of up to five independent loads to the hoist rigging of a crane.

Qualified person: One who, by possession of a recognized degree, certificate, or professional standing, or who by extensive knowledge, training, and experience, has successfully demonstrated the ability to solve or resolve problems relating to the subject matter, the work, or the project.

Environmental concerns in health care

• Environmental concerns in health care settings can include the handling of wastewater, hazardous waste management, air emission control, toxic substance control, and more.

The health care industry is affected by multiple federal environmental statutes. In addition, the industry is subject to numerous laws and regulations from state, tribal, and local governments. A high-level overview is provided below.

Wastewater sources include sinks, drains, showers, toilets, and tubs; photographic development drains from radiology (X-rays), other imaging, and dentistry; and stormwater. The health care industry is subject to various provisions of the Clean Water Act, including:

• Wastewater discharges;
• Stormwater permits (municipal separate storm sewer systems such as those from hospitals and construction activities are subject to stormwater permitting requirements); and
• Oil pollution prevention requirements (for hospitals that have a total aboveground oil storage capacity exceeding 1,320 gallons or an underground storage capacity exceeding 42,000 gallons).

Safe Drinking Water Act (SDWA) regulations protect drinking water. A hospital would be considered a public water system if it regularly serves at least 25 of the same persons six months per year from its own water source. The hospital would be required to comply with SDWA monitoring and reporting requirements. Health care facilities that have their own drinking water treatment could generate hazardous or radioactive waste.

Under federal hazardous waste laws, most health care facilities are hazardous waste generators. The Environmental Protection Agency (EPA) regulates facilities that generate, transport, treat, store, or dispose of hazardous waste.

Community right-to-know laws establish reporting obligations (such as Tier I and Tier II forms) for facilities that store or manage specified chemicals, including many chemicals commonly found at health care facilities.

Air emissions may come from air conditioning and refrigeration, boilers, medical waste incinerators (if on site), asbestos, paint booths, ethylene oxide sterilization units, emergency generators, anesthesia, laboratory chemicals, and laboratory fume hoods. Under the Clean Air Act, states develop plans to identify sources of air pollution and to determine what reductions are required to meet federal air quality standards.

Health care facilities may be subject to the Toxic Substance Control Act through:

• Lead hazard reduction regulations;
• Hexavalent chromium regulations;
• Polychlorinated Biphenyls (PCB) hazard reduction regulations; and
• Asbestos hazard reduction regulations.

In health care settings, EPA regulates disinfectants that are used on environmental surfaces (housekeeping and clinical contact surfaces). Disinfectants intended for use on clinical contact surfaces (e.g., light handles, radiographic-ray heads, or drawer knobs) or housekeeping surfaces (e.g., floors, walls, or sinks) are regulated under the Federal Insecticide, Fungicide, and Rodenticide Act.

Formaldehyde in health care

• Formaldehyde can be used in health care settings as a disinfectant or a sterilant.
• Exposure to formaldehyde can cause acute eye, nose and throat irritation, and respiratory problems over time. It is also a cancer hazard.

The Occupational Safety and Health Administration (OSHA) has a standard on formaldehyde at 1910.1048. The standard and equivalent regulations in states with OSHA-approved state plans applies to all occupational exposures to formaldehyde from formaldehyde gas, its solutions, and materials that release formaldehyde.

In health care settings, formaldehyde can be used as a disinfectant or a sterilant. It is often found mixed in water and referred to as formalin. Formaldehyde can be used to prepare viral vaccines; as an embalming agent; as a tissue fixative; and in the sterilization of medical equipment. Paraformaldehyde (a solid polymer of formaldehyde) can be heat vaporized for the gaseous decontamination of laminar flow biologic safety cabinets.

Formaldehyde is a sensitizing agent that can cause an immune system response upon initial exposure. It is also a cancer hazard. Acute exposure is highly irritating to the eyes, nose, and throat and can make anyone exposed cough and wheeze. Subsequent exposure may cause severe allergic reactions of the skin, eyes, and respiratory tract. Ingestion of formaldehyde can be fatal, and long-term exposure to low levels in the air or on the skin can cause asthma-like respiratory problems and skin irritation such as dermatitis and itching. Concentrations of 100 parts per million (ppm) are immediately dangerous to life and health (IDLH).

In general, OSHA requires covered employers to:

• Identify all workers who may be exposed to formaldehyde at or above the action level or short-term exposure limit (STEL) through initial monitoring and determine their exposure. The permissible exposure limit (PEL) for formaldehyde is 0.75 parts formaldehyde per million parts of air (0.75 ppm) measured as an eight-hour time-weighted average (TWA). The standard includes a short-term exposure limit (STEL) of 2 ppm which is the maximum exposure allowed during a 15-minute period. The action level (which is the standard’s trigger for increased industrial hygiene monitoring and initiation of worker medical surveillance) is 0.5 ppm when calculated as an eight-hour TWA.
• Reassign workers who suffer significant adverse effects from formaldehyde exposure to jobs with significantly less or no exposure until their condition improves. Reassignment may continue for up to six months until the worker is determined to be able to return to the original job or to be unable to return to work, whichever comes first.
• Implement feasible engineering and work practice controls to reduce and maintain worker exposure at or below the eight-hour TWA and the STEL. If these controls cannot reduce exposure to or below the PELs, employers must provide workers with respirators.
• Label all mixtures or solutions composed of greater than 0.1 percent formaldehyde and materials capable of releasing formaldehyde into the air at concentrations reaching or exceeding 0.1 ppm. For all materials capable of releasing formaldehyde at levels above 0.5 ppm during normal use, the label must contain the words “potential cancer hazard.”
• Train all workers exposed to formaldehyde concentrations of 0.1 ppm or greater at the time of initial job assignment and whenever a new exposure to formaldehyde is introduced into the work area. Repeat training annually.
• Select, provide and maintain appropriate personal protective equipment (PPE). Ensure that workers use PPE such as impervious clothing, gloves, aprons, and chemical splash goggles to prevent skin and eye contact with formaldehyde.
• Provide showers and eyewash stations if splashing is likely.
• Provide medical surveillance for all workers exposed to formaldehyde at concentrations at or above the action level or exceeding the STEL, for those who develop signs and symptoms of overexposure, and for all workers exposed to formaldehyde in emergencies.
• Keep adequate records. Retain exposure records for 30 years. Retain medical records for 30 years after employment ends. Allow access to medical and exposure records to current and former workers or their designated representatives upon request. Note: Health care employers may also be subject to requirements, standards, and guidance from other agencies and organizations, such as The Joint Commission, the Centers for Disease Control and Prevention, and the Public Health Administration.

Grain handling key definitions

• Key definitions for the grain handling industry are found in this section.

Key definitions regarding grain handling include the following:

• Fugitive grain dust: Combustible dust particles, emitted from the stock handling system, of such size as will pass through a U.S. Standard 40 mesh sieve (425 microns or less).
• Grain elevator: A facility engaged in the receipt, handling, storage and shipment of bulk raw agricultural commodities such as corn, wheat, oats, barley, sunflower seeds, and soybeans.
• Hot work: Work involving electric or gas welding, cutting, brazing or similar flame-producing operations.
• Inside bucket elevator: A bucket elevator that has the boot and more than 20 percent of the total leg height (above grade or ground level) inside the grain elevator structure. Not considered “inside bucket elevators” are bucket elevators with leg casings that are inside (and pass through the roofs) of rail or truck dump sheds with the remainder of the leg outside of the grain elevator structure.
• Lagging: A covering on drive pulleys used to increase the coefficient of friction between the pulley and the belt.
• Permit: The written certification by the employer authorizing employees to perform identified work operations subject to specified precautions.

Logging key definitions

• Key definitions for the logging operations industry are found in this section.

Key definitions related to logging operations include the following:

• Cable yarding: The movement of felled trees or logs from the area where they are felled to the landing on a system composed of a cable suspended from spars and/or towers. The trees or logs may be either dragged across the ground on the cable or carried while suspended from the cable.
• Danger tree: A standing tree that presents a hazard to employees due to conditions such as, but not limited to, deterioration or physical damage to the root system, trunk, stem or limbs, and the direction and lean of the tree.
• Designated person: An employee who has the requisite knowledge, training and experience to perform specific duties.
• Guarded: Covered, shielded, fenced, enclosed, or otherwise protected by means of suitable enclosures, covers, casings, shields, troughs, railings, screens, mats, or platforms, or by location, to prevent injury.
• Logging operations: Operations associated with felling and moving trees and logs from the stump to the point of delivery, such as, but not limited to, marking danger trees and trees/logs to be cut to length, felling, limbing, bucking, debarking, chipping, yarding, loading, unloading, storing, and transporting machines, equipment and personnel to, from and between logging sites.
• Skidding: The yarding of trees or logs by pulling or towing them across the ground.
• Yarding: The movement of logs from the place they are felled to a landing.

Food safety environmental concerns

• The food processing industry is subject to regulation around wastewater, air quality, toxic substance control, pesticides, and more.

The food processing sector is affected by a number of major environmental statutes and regulations.

Water

The discharge of wastewater is usually covered by the federal Clean Water Act (CWA). Federal regulations target three types of industrial discharges. Industrial wastewater discharges from food processing facilities probably fall into one of these categories:

• Direct discharges include any wastewater (e.g., untreated, unpolluted wastewater, or treated process wastewater) that is discharged straight to surface waters (e.g., ponds, lakes, oceans, streams, and wetlands). Storm water discharges also are considered a type of direct discharge.
• Indirect discharges include any wastewater that is discharged to a publicly owned treatment works (POTW), which subsequently discharges to a surface water.
• Land application discharges include any wastewater that is discharged to land to either condition the soil or to fertilize crops or other vegetation grown in the soil.

Facilities that store petroleum and nonpetroleum oils (e.g., vegetable oils and animal fats) must follow Oil Pollution Prevention Regulations, also known as the Spill Prevention, Control and Countermeasures (SPCC) Regulation.

Water used in food processing operations must meet the Environmental Protection Agency’s (EPA’s) safe drinking water requirements.

Air

Although total air emissions by the food processing industry typically are less than other manufacturing industries, some sources may emit sufficient air pollution to be regulated under Clean Air Act (CAA).

National Ambient Air Quality Standards (NAAQS) for Criteria Pollutants may affect food processing industries in the following ways:

Sulfur dioxide, nitrogen dioxide, and particulate matter result from the combustion of fossil fuels (e.g., industrial boilers). Some significant sources of particulate emissions result mainly from solids handling, solid size reduction, cleaning, roasting, drying, and cooking (e.g., PM10 results from flour, sugar, and other dry ingredients). Some of the particulates are dusts, but others are produced by the condensation of vapors ranging in the low-micrometer or sub-micrometer particle size.

Volatile organic compound (VOC) emissions may result from fryers (e.g., doughnuts, french fries), direct use of ethanol, by-products of yeast fermentation (ethanol), and from lubricating oils for machinery.

A food processing facility may emit air pollutants from both process and ancillary operations, such as refrigeration and steam generation.

Food processors may be subject to risk management planning requirements if they have one or more of the identified substances onsite above the threshold quantity. If a facility has more than a threshold quantity of any of the regulated substances in a single process, it is required to comply with the regulation (68). In terms of this regulation, process means “manufacturing, storing, distributing, handling, or using” a regulated substance in any other way. Ammonia, chlorine, and propane are some of the regulated substances commonly used by food processing facilities.

A food processing facility may be subject to requirements of the Stratospheric Ozone Protection Program if it has motor vehicle air conditioners, certain appliances (air conditioners, refrigerators, and freezers), and industrial process refrigeration units that use chlorofluorocarbons (CFCs) and other Class I and Class II substances.

Toxic substance control

Drugs, cosmetics, foods, food additives, pesticides, and nuclear materials are exempt from the Toxic Substances Control Act (TSCA) and are subject to control under other federal statutes (e.g., foods and food additives are under the purview of the Federal Food, Drug and Cosmetics Act (FFDCA) administered by the FDA). In order for a food or food additive to be exempt, however, it must meet the definition contained in the FFDCA (21 USC 321 et seq.), or related statutes such as the Poultry Products Inspection Act and the Federal Meat Inspection Act. If the food or food additive does not meet the definition, the substance may then be regulated under TSCA and is subject to all the requirements of TSCA including testing, premanufacture notice, reporting and recordkeeping, export notification, and import certification.

Additional TSCA requirements may apply to facilities that manage substances such as asbestos, CFCs, and polychlorinated biphenyls (PCBs).

Pesticides

The Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) primarily regulates the manufacture and registration of pesticides (Part 152 and 156), but important requirements also exist for pesticide users. Food processors must comply with all FIFRA requirements relating to these activities.

Under this program, the term “pesticides” includes herbicides, insecticides, and rodenticides.

Emergency planning and community right to know

If a food processing facility, no matter how small, has any of the extremely hazardous substances (EHSs) in amounts equal to or in excess of certain minimum amounts (called threshold planning quantities or TPQs), it must participate in emergency planning activities. EHSs typically found at food processing facilities include ammonia (for refrigeration), chlorine (for disinfection), and nitric and sulfuric acids (for cleaning).

Hazardous chemical inventory and reporting provisions require employers to inventory the hazardous chemicals present onsite at each facility in amounts equal to or in excess of TPQs.

Form R reporting requirements often apply to food facilities. Some multi-establishment food processing facilities overlook the fact that they may have to submit Form R or Form A reports for chemicals used in agricultural operations.

Hazardous waste

A food processor may produce wastes that could be hazardous. For example, food processors will most likely generate spent solvent wastes, which are F-listed wastes. Other wastes commonly generated at food facilities include the following:

• Spent or unusable chemical preservatives,
• Vehicle maintenance waste,
• Solvents,
• Liquid flux for soldering,
• Waste ink,
• Solvent-laden rags,
• Used fountain solution, and
• Used oil.

If a facility has an underground storage tank (UST) system, it is subject to requirements for USTs containing petroleum products or hazardous substances.

Spraying/Spray finishing key definitions

Key definitions for the spray finishing industry are found in this section.

Some key definitions related to spray finishing include the following:

• Approved: Approved and listed by a nationally recognized testing laboratory.
• Electrostatic fluidized bed: A container holding powder coating material which is aerated from below so as to form an air-supported expanded cloud of such material which is electrically charged with a charge opposite to the charge of the object to be coated; such object is transported through the container immediately above the charged and aerated materials in order to be coated.
• Fluidized bed: A container holding powder coating material which is aerated from below so as to form an air-supported expanded cloud of such material through which the preheated object to be coated is immersed and transported.
• Spray booth: A power-ventilated structure provided to enclose or accommodate a spraying operation to confine and limit the escape of spray, vapor, and residue, and to safely conduct or direct them to an exhaust system.
• Spraying area: Any area in which dangerous quantities of flammable vapors or mists, or combustible residues, dusts, or deposits are present due to the operation of spraying processes.

Safety requirements

• Due to the risk of fire hazard, spray areas must be kept free from accumulation of combustible residues, and care must be taken with other combustibles like flammable liquids and contaminated employee clothing.
• The spraying area must display the appropriate warning signage, including no smoking warnings, ventilation warnings, and signs calling for proper grounding of electrical equipment.

All spraying areas must be kept as free from the accumulation of deposits of combustible residues as practical, with cleaning conducted daily if necessary. Scrapers, spuds, or other such tools used for cleaning purposes must be of non-sparking material. The use of solvents for cleaning operations must be restricted to those having flashpoints not less than 100°F. However, for cleaning spray nozzles and auxiliary equipment, solvents having flash points not less than those normally used in spray operations may be used. Such cleaning must be conducted inside spray booths and ventilating equipment operated during cleaning.

Spray finishing employees’ clothing must not be left on the premises overnight unless kept in metal lockers.

The storage of flammable liquids or liquids with a flashpoint greater than 199.4°F (93°C) in connection with spraying operations must conform to the requirements of 1910.106, where applicable. See also 1910.107(e).

Spray booths must not be alternately used for different types of coating materials, where the combination of the materials may be conducive to spontaneous ignition, unless all deposits of the first used material are removed from the booth and exhaust ducts prior to spraying with the second used material.

Fire hazards

In sprinklered buildings, the automatic sprinkler system in rooms containing spray finishing operations must conform to the requirements of 1910.159. In unsprinklered buildings where sprinklers are installed only to protect spraying areas, the installation must conform to such standards insofar as they are applicable. Sprinkler heads must be located so as to provide water distribution throughout the entire booth, and must be kept as free from deposits as practical by cleaning daily if necessary. An adequate supply of suitable, portable fire extinguishers must be installed near all spraying areas.

Residue scrapings and debris contaminated with residue must be immediately removed from the premises and properly disposed of. Approved metal waste cans must be provided wherever rags or waste are impregnated with finishing material and all such rags or waste deposited therein immediately after use. The contents of waste cans must be properly disposed of at least once daily or at the end of each shift.

Labeling

The spraying and powder coating equipment must carry a prominent permanently installed warning regarding the necessity for a grounding feature on all electrically conductive objects in the spraying area or within the charging influence of the electrodes. The drying apparatus must contain a prominently located, permanently attached warning sign indicating that ventilation should be maintained during the drying period and that spraying should not be conducted in the vicinity that spray will deposit on apparatus.

Posting

Smoking must be prohibited and “No smoking” signs in large letters on contrasting color background must be conspicuously posted at all spraying areas, paint storage rooms, powder coating areas and powder storage rooms.

Only nonsparking tools may be used in any area where organic peroxides are stored, mixed or applied. A safe distance must be maintained between goods being painted and electrodes or electrostatic atomizing heads or conductors of at least twice the sparking distance. A suitable sign indicating safe distance must be conspicuously posted near the assembly. The spraying and powder coating equipment must carry a prominent permanently installed warning regarding the necessity for a grounding feature on all electrically conductive objects in the spraying area or within the charging influence of the electrodes.

The drying apparatus must contain a prominently located, permanently attached warning sign indicating that ventilation should be maintained during the drying period and that spraying should not be conducted in the vicinity that spray will deposit on apparatus.

Spraying/Spray finishing equipment requirements

• Spray booth equipment must meet several safety standards including construction materials, ventilation and exhaust requirements, electrical requirements, and more.

Spray booths must be substantially constructed of steel, securely and rigidly supported, or of concrete or masonry except that aluminum or other substantial noncombustible material may be used for intermittent or low volume spraying. Spray booths must be designed to sweep air currents toward the exhaust outlet. See 1910.107(b).

Ventilating and exhaust systems must be in accordance with the Standard for Blower and Exhaust Systems for Vapor Removal, National Fire Protection Association (NFPA) No. 91-1961, which is incorporated by reference as specified in 1910.6, and where applicable and must also conform to the provisions of 1910.107(d).

Drying, curing, or fusion apparatus must conform to the Standard for Ovens and Furnaces, NFPA 86A-1969.

• Spray booths, rooms, or other enclosures used for spraying operations must not alternately be used for the purpose of drying by any arrangement which will cause a material increase in the surface temperature of the spray booth, room, or enclosure.
• Drying, curing, or fusion units utilizing a heating system having open flames or which may produce sparks must not be installed in a spraying area, but may be installed adjacent thereto when equipped with an interlocked ventilating system. See 1910.107(j)(3).
• Automobile refinishing spray booths or enclosures, otherwise installed and maintained in full conformity with 1910.107, may alternately be used for drying with portable electrical infrared drying apparatus when conforming with the requirements in 1910.107(j)(4).

All electrical equipment, open flames and other sources of ignition must conform to the requirements of 1910.107(c), with some exceptions.

Electrostatic hand spraying equipment must be of approved types.

• Transformers, power-packs, control apparatus, and all other electrical portions of the equipment, with the exception of the handgun itself and its connections to the power supply, must be located outside of the spraying area.
• The handle of the spraying gun must be electrically connected to ground by a metallic connection and be constructed so the operator in normal operating position is in intimate electrical contact with the grounded handle.
• All electrically conductive objects in the spraying area must be adequately grounded.
• Objects being painted or coated must be maintained in metallic contact with the conveyor or other grounded support.
• The electrical equipment must be interlocked with the ventilation of the spraying area so the equipment cannot be operated unless the ventilation fans are in operation.
• The spraying operation must take place within a spray area which is adequately ventilated to remove solvent vapors released from the operation.

Fixed electrostatic apparatus must be of approved types, and must be equipped with automatic controls which will operate without time delay to disconnect the power supply to the high-voltage transformer and to signal the operator. See 1910.107(h)(9).

• Transformers, power packs, control apparatus, and all other electrical portions of the equipment, with the exception of high-voltage grids, electrodes, and electrostatic atomizing heads and their connections, must be located outside of the spraying area.
• Electrodes and electrostatic atomizing heads must be adequately supported in permanent locations and must be effectively insulated from the ground.
• High-voltage leads to electrodes must be properly insulated and protected from mechanical injury or exposure to destructive chemicals. Electrostatic atomizing heads must be effectively and permanently supported on suitable insulators and must be effectively guarded against accidental contact or grounding. An automatic means must be provided for grounding the electrode system when it is electrically de-energized for any reason. All insulators must be kept clean and dry.
• A safe distance must be maintained between goods being painted and electrodes or electrostatic atomizing heads or conductors of at least twice the sparking distance. A suitable sign indicating this safe distance must be conspicuously posted near the assembly.
• Goods being painted using this process are to be supported on conveyors. The conveyors must be so arranged as to maintain safe distances between the goods and the electrodes for electrostatic atomizing heads at all times.
• Adequate booths, fencing, railings, or guards must be so placed about the equipment that they, either by their location or character or both, assure that a safe isolation of the process is maintained from plant storage or personnel. Such railings, fencing, and guards must be of conducting material, adequately grounded.
• Where electrostatic atomization is used, the spraying area must be so ventilated as to insure safe conditions from a fire and health standpoint.
• All areas used for spraying, including the interior of the booth, must be protected by automatic sprinklers where this protection is available. Where this protection is not available, other approved automatic extinguishing equipment must be provided.

Electrical equipment and other sources of ignition must conform to the requirements of 1910.107(c)(1)(i)-(iv), (8), and (9)(i), and Subpart S of 1910.

• Exhaust ventilation must be sufficient to maintain the atmosphere below the lowest explosive limits for the materials being applied. All nondeposited air-suspended powders must be safely removed via exhaust ducts to the powder recovery cyclone or receptacle.
• Powders must not be released to the outside atmosphere.
• All areas must be kept free of the accumulation of powder coating dusts, particularly such horizontal surfaces as ledges, beams, pipes, hoods, booths, and floors.
• Transformers, powerpacks, control apparatus, and all other electrical portions of the equipment, with the exception of the charging electrodes and their connections to the power supply must be located outside of the powder coating area.
• All electrically conductive objects within the charging influence of the electrodes must be adequately grounded.
• Objects being coated must be maintained in contact with the conveyor or other support in order to insure proper grounding. Hangers must be regularly cleaned to ensure effective contact and areas of contact must be sharp points or knife edges where possible.
• The electrical equipment must be so interlocked with the ventilation system that the equipment cannot be operated unless the ventilation fans are in operation.

Laundry operations physical hazards: Noise, heat, and ergonomics

• Laundry operations expose workers to hazards from noise, heat and ergonomic concerns.

Laundry operations involve a number of hazards including noise, heat, and ergonomic concerns.

Noise hazards

Industrial machines can generate considerable noise, particularly if several machines are running at the same time. If normal conversation is difficult because of machinery noise, workers may be at risk of hearing loss. Prolonged exposure to loud machinery can also lead to conditions like hypertension, high blood pressure, stress, or other health hazards.

Employers must take steps to protect the hearing of workers exposed to noise levels of 85 decibels (dB) or more, averaged over eight hours. Most industrial washers and dryers are less than 80 dB, but multiple machines could increase the noise levels. Many workers won’t be around the machines for 8 hours per day, however, and that reduces the total noise exposure.

If the noise exposure levels are less than 85 dB over eight hours, the employer does not need to create a hearing conservation program or provide hearing protection. Even so, employers may want to take steps to reduce exposure to loud noises. Examples include installing sound baffles, or rotating workers through noisy areas to reduce the exposure time.

Heat hazards

Dryers produce a lot of heat that can make the laundry room uncomfortably warm. High humidity can make a warm location feel even hotter, and a laundry room could be a hot, humid area.

At high temperatures, the body circulates more blood to the skin to eliminate heat through perspiration. As a result, less blood gets circulated to vital organs, including the brain. Exposure to excessive heat can result in conditions such as heat exhaustion and heat stroke.

Employers should train employees and supervisors to detect early signs of heat-related illness. Employers should also evaluate engineering and work practice controls such as:

• General ventilation and local exhaust ventilation at points of high heat production.
• Spot cooling fans or air conditioning.
• Encourage employees to wear light, loose-fitting, breathable clothing (like cotton).
• Alternate work and rest periods with frequent short breaks in cool areas to allow cooling down.

Ergonomic hazards

Excessive reaching, pushing, and lifting wet heavy laundry can cause injuries such as strains and sprains to the back or shoulder area.

Employers should assess the laundry area to identify hazards, and inform workers of how to decrease the risk of injury. Examples of options include the following:

• Use proper lifting techniques.
• Avoid lifting bulky or awkwardly weighted objects.
• Avoid lifting, reaching, or working above shoulder height.
• Avoid awkward postures, such as twisting while lifting.
• Hold items close to the body while lifting or carrying.
• Limit the weight of the item to be lifted, and divide heavy loads into two or more smaller loads.
• Use well maintained carts with wheels that can roll easily over flooring as well as gaps between elevators and hallways.
• Use mechanical aids to reduce the lifting, such as spring-loaded platforms to help lift wet heavy laundry, and to keep laundry at a comfortable work height.
• Provide washers that automatically dump loads into baskets so workers don’t have to reach in and pull out wet heavy laundry.

Hazardous chemicals

Laundry workers are exposed to a variety of chemicals including bleach, soap, and detergents that can cause injury to the skin and eyes.

Handling laundry at work often involves working with chemicals such as bleach. Although employees might use similar chemicals at home, their potential exposure at work is much higher due to the volume and frequency of use.

Soaps and detergents may cause allergic reactions and dermatitis (skin rash). Further, the broken skin from soap or detergent irritation may create potential for infection or injury if the workers are exposed to other chemicals or biological hazards.

Employers should provide training on working with detergents and similar chemicals, and show employees where to find a Safety Data Sheet (SDS) for each product. The SDS:

• Provides information about the hazards of the chemical,
• Describes how to protect against exposure (such as using personal protective equipment), and
• Explains what to do in case of exposure, such as a chemical splashing in the eyes.

Where chemicals might splash on a worker’s body or in the eyes, the work area should include a quick drenching or eyewash station for flushing chemicals from the eyes.

Laundry operations and bloodborne pathogens

• Laundry workers may be exposed to blood and other body fluids, especially from towels and bedding. Such workers must be trained in how to protect themselves from bloodborne pathogens such as HIV and hepatitis.

Laundry workers have the potential for exposure to blood or other body fluids, particularly from towels or bedding. Workers handling laundry may be exposed if the laundry is contaminated with blood or certain other body fluids.

According to the Occupational Safety and Health Administration (OSHA), workers with “occupational exposure” to blood or certain body fluids require training on how to protect themselves from bloodborne pathogens such as hepatitis or HIV. The term “occupational exposure” means the employee is reasonably anticipated to have contact with blood or certain body fluids as a result of job duties.

While OSHA does not generally consider housekeeping staff in non-health care facilities to have occupational exposure, the employer must determine if certain jobs or tasks could involve reasonably anticipated contact with blood. In the hotel/motel industry, for example, employers must determine if any employees could come into contact with blood during normal cleaning of rooms, stripping of beds, and handling of laundry. Employees who handle linens that are visibly soiled with blood would be occupationally exposed.

If any workers have occupational exposure, they must be given training on how bloodborne pathogens can spread and how to protect themselves. An employer may designate specific individuals to handle contaminated laundry or other situations where exposure to blood may occur. If workers have not been trained to handle these situations, they should be told which employees have been properly trained, and informed of how to contact them.

For bloodborne pathogens:

• Laundry which has been soiled with blood or other potentially infectious materials or may contain sharps is considered contaminated and must be handled as little as possible with a minimum of agitation.
• Contaminated laundry must be bagged or containerized at the location where it was used and must not be sorted or rinsed in the location of use.
• Contaminated laundry must be placed and transported in bags or containers labeled or color-coded in accordance with 1910.1030(g)(1)(i). When a facility uses Universal Precautions in the handling of all soiled laundry, alternative labeling or color-coding is sufficient if it permits all employees to recognize the containers as requiring compliance with Universal Precautions.
• Whenever contaminated laundry is wet and presents a reasonable likelihood of soak-through of or leakage from the bag or container, the laundry must be placed and transported in bags or containers which prevent soak-through and/or leakage of fluids to the exterior.
• The employer must ensure that employees who have contact with contaminated laundry wear protective gloves and other appropriate personal protective equipment.
• When a facility ships contaminated laundry off-site to a second facility which does not use Universal Precautions in the handling of all laundry, the facility generating the contaminated laundry must place such laundry in bags or containers which are labeled or color-coded.

Dry cleaning

• Dry cleaning may expose workers to several hazards, the most serious of which is exposure to solvents and other chemicals. The most commonly used solvent, perchloroethylene, may be cancer causing.
• Dry cleaning operations are subject to regulation to reduce harm to the environment from chemical releases into the surrounding air, water, and land.

Many industries provide personal and laundry services to individuals, households, and businesses. Laundry and dry cleaning workers clean cloth garments, linens, draperies, blankets, and other articles. They also may clean leather, suede, furs, and rugs.

Laundries and dry cleaning establishments are often hot and noisy. Employees also may be exposed to harsh solvents, but newer environmentally friendly and less toxic cleaning solvents are available.

Dry cleaning process hazards include chemical, fire, and ergonomics.

Exposure to hazardous chemicals commonly used in dry cleaning shops may occur through skin absorption, eye contact, or inhalation of the vapors. Perchloroethylene (PERC), a potential human carcinogen, is the most commonly used dry cleaning solvent. Symptoms associated with exposure include depression of the central nervous system; damage to the liver and kidneys; impaired memory; confusion; dizziness; headache; drowsiness; and eye, nose, and throat irritation. Repeated dermal exposure may result in dermatitis.

Environmental concerns

Depending on the materials and activities at a facility, dry cleaning operations may adversely affect air, water, and land in several ways:

• Air releases of perchloroethylene and petroleum solvents are the primary environmental release. Chemicals involved in dry cleaning volatilize, which contributes to air emissions from the facility and to smog formation.
• Spills, inadequate storage, and drain disposal of solvents have led to groundwater contamination.
• Hazardous wastes, including fluorescent lamps and batteries, impact the environment and public health. In addition, (improper) disposal of solvent laden material, such as filters, as nonhazardous solid waste is of concern.
• Use or storage of oil can trigger spill prevention, control, and countermeasure requirements, as well as used oil disposal issues.
• Use and storage of chemicals may trigger reporting under emergency planning and community right-to-know regulations, and chemical accident prevention provisions.

The dry cleaning industry is becoming increasingly regulated at the federal, state, and local levels. Some of the regulations are directed specifically at dry cleaners such as the National Emission Standard for Hazardous Air Pollutants (NESHAP) for Perchloroethylene Dry Cleaning. Other regulations are more general but also likely affect a significant part of the industry, such as standards on underground tank storage.

Dry cleaners or their landlords may be held joint and severally liable for perchloroethylene (PCE) contamination of the site under the Comprehensive Environmental Response, Compensation and Liability Act (Superfund). The contamination may occur by having PCE-containing waste water leak through sewer pipes or by leaks of PCE during normal operation.

Dry cleaners who generate 220 pounds or more of perchloroethylene solid wastes (hazardous waste code D039) such as still bottoms, cartridge filters, and filter muck each month are regulated under hazardous waste rules and must dispose of their wastes at a licensed hazardous waste facility. The slightly contaminated waste water generated by dry cleaners from various sources is considered hazardous waste because it was derived from an F002 waste. The toxicity characteristic leaching procedure (TC) cutoff for perchloroethylene is 0.7 ppm. Typical separator water contains about 150 ppm and is therefore considered hazardous because it exceeds the TC level.

Dry cleaning facilities that store either petroleum or perchloroethylene in an underground storage tank are subject to underground storage tank regulations which require that the tank must be protected from corrosion, be equipped with devices that prevent spills and overfills, and must have a leak detection method that provides monitoring for leaks at least every 30 days (265.190-196).

Discharges to a publicly owned treatment works (POTW)

Facilities discharging wastewater to a sewer are often subject to restrictions required under the Clean Water Act. These restrictions are established by the local sewerage authority to prevent significant interference with the treatment facility or pass-through of pollutants not removed by treatment (Part 125). The specific requirements include notifying the POTW of discharges that could cause problems at the POTW, monitoring and record keeping as established by the POTW, and a one-time notice of the discharge of hazardous waste.

Telecommunication key definitions

• Key definitions for the telecommunications industry are found in this section.

Alive or live (energized): Electrically connected to a source of potential difference, or electrically charged so as to have a potential significantly different from that of the earth in the vicinity. The term “live” is sometimes used in the place of the term “current-carrying,” where the intent is clear, to avoid repetition of the longer term.

Barricade: A physical obstruction such as tapes, cones, or “A” frame type wood and/or metal structure intended to warn and limit access to a work area.

Cable: A conductor with insulation, or a stranded conductor with or without insulation and other coverings (single-conductor cable), or a combination of conductors insulated from one another (multiple-conductor cable).

Circuit: A conductor or system of conductors through which an electric current is intended to flow.

Conductor: A material, usually in the form of a wire, cable, or bus bar, suitable for carrying an electric current.

Equipment: A general term which includes materials, fittings, devices, appliances, fixtures, apparatus, and similar items used as part of, or in connection with, a supply or communications installation.

Ground tent: A small tent usually constructed of vinyl coated canvas supported by a metal or plastic frame. Its purpose is to protect employees from inclement weather while working at buried cable pedestal sites or similar locations.

Grounded conductor: A system or circuit conductor which is intentionally grounded.

Grounding electrode conductor (grounding conductor): A conductor used to connect equipment or the grounded circuit of a wiring system to a grounding electrode.

Qualified employee: Any worker who by reason of training and experience has demonstrated the ability to safely perform assigned duties.

Telecommunications center: An installation of communication equipment under the exclusive control of an organization providing telecommunications service, that is located outdoors or in a vault, chamber, or a building space used primarily for such installations. Note: Telecommunication centers are facilities established, equipped and arranged in accordance with engineered plans for the purpose of providing telecommunications service. They may be located on premises owned or leased by the organization providing telecommunication service, or on the premises owned or leased by others. This definition includes switch rooms (whether electromechanical, electronic, or computer controlled), terminal rooms, power rooms, repeater rooms, transmitter and receiver rooms, switchboard operating rooms, cable vaults, and miscellaneous communications equipment rooms. Simulation rooms of telecommunication centers for training or developmental purposes are also included.

Telecommunication service: The furnishing of a capability to signal or communicate at a distance by means such as telephone, telegraph, police and fire alarm, community antenna television, or similar system, using wire, conventional cable, coaxial cable, wave guides, microwave transmission, or other similar means.

Vault: An enclosure above or below ground which personnel may enter, and which is used for the purpose of installing, operating, and/or maintaining equipment and/or cable which need not be of submersible design.

Telecommunications general safety requirements

• In addition to energized equipment, telecommunications workers face hazards from the use of battery acid, radiation, falls, and exposure to inclement weather during climbing work.

In addition to coming into contact with energized equipment or lines, telecommunication workers may face many other hazards.

Batteries

Telecommunication workers need to know and understand how to handle storage batteries, how to properly handle and store battery acid, what to do in an emergency, and what personal protective equipment (PPE) to wear. This includes the correct tools and equipment, general safety precautions, and confined spaces (for underground lines).

When handling batteries:

• Wear eye protection, protective clothing, and gloves when checking the specific gravity of the battery.
• Follow emergency procedures.
• Add acid to water, never water to acid.
• Cover the open end of hydrometer with an acid-resistant material when moving it from cell to cell.
• First-aid supplies should be readily available and inspected monthly.

Power line work

For power line work, maintain safe approach distances to exposed energized overheard power lines and parts depending on the voltage of the lines or parts.

When working in traffic areas, use warning signs, flags, and other traffic control devices. For night work, use warning lights and protective barricades.

Climbing

Personal climbing equipment must be used when working more than 4 feet above the ground on poles and towers. Pole climber gaffs must be 1-1/4 inches long. Cover gaffs with safety caps when they are not being used.

Radiation

Telecommunications workers may be exposed to nonionizing radiation. This includes radiation originating from radio stations, radar equipment, and possible sources of radiation used for communication, radio navigation, and industrial and scientific purposes. The presence of dangerous levels of radioactivity can only be detected with special monitors. Its effect on the human body may not be evident for days, weeks, or even years after exposure occurs. The effects of nonionizing radiation are generally limited to the skin and eyes, including immediate changes in skin color, which may appear as sunburn or suntan, and irreversible damage to ocular structures within the eyes. The degree of injury a person may receive from radiation exposure depends on several factors. These include the amount of the radiation dose, the duration of the dose, the rate at which the dose was received, the type of radiation received, and the body parts receiving the dose.

Tower work

Employees climb towers throughout the year, including during inclement weather conditions. Some of the more frequently encountered hazards include:

• Falls from great heights,
• Electrical hazards,
• Hazards associated with hoisting personnel and equipment with base-mounted drum hoists,
• Inclement weather,
• Falling object hazards,
• Equipment failure, and
• Structural collapse of towers.

Other hazards

Other safe practices include:

• Avoiding flame-type heaters for tent heaters.
• Using torches in a tent only when the tent material is fire resistant.
• Following the appropriate grounding procedures for all equipment used.
• Using wiping cloths or gloves, and eye protection when performing lead work.
• Using a drip pan to catch hot lead drippings.

Pulp, paper, and paperboard mills environmental concerns

• Pulp, paper, and paperboard mills are regulated by environmental and safety programs aimed at maintaining clean air and water, controlling hazardous waste, and requiring emergency planning.

Several regulatory programs affect operations at pulp, paper, and paperboard mills.

Air

At pulp and paper mills, air emissions from both process and combustion units are regulated under the National Ambient Air Quality Standards (NAAQS) and the State Implementation Plans (SIP) that enforce the standards. States may implement controls to limit emissions of particulate matter (PM), nitrogen oxides (NOx), volatile organic compounds (VOC), and sulfur dioxide (SO2).

Air toxics regulations apply to several parts of the pulp and paper milling process. National Emission Standards for Hazardous Air Pollutants (NESHAP) have been developed expressly for two processes of the pulp and paper industry:

• Part 63, Subpart S Controlling HAP emissions from the pulp and paper production areas of mills using the kraft, sulfite, semi-chemical, and soda pulping processes (MACT I), and controlling HAP emissions from pulp and paper production areas of mills using mechanical, secondary fiber, and non-wood pulping, and papermaking systems at all mills; and
• Part 63 Subpart MM Controlling HAP emissions from chemical recovery processes that involve the combustion of spent pulping liquor at kraft, soda, sulfite, and stand-alone semichemical pulp mills.

Most pulp and paper mills are subject to explicit risk management requirements.

Many pulp and paper mills are required to have a Title V permit, and may be required to submit information about emissions, control devices, and the general process at the facility in the permit application.

Many pulp and paper facilities operate industrial process refrigeration units, such as chillers for chlorine dioxide plants. For those units that utilize ozone-depleting chemicals, such as chlorofluorocarbons (CFCs), facilities are required to follow leak repair requirements.

Water

There are two industry-specific components of the Clean Water Act (CWA) requirements: National Pollution Discharge Elimination System (NPDES) permitting and pretreatment programs. Other general CWA requirements, such as those for wetlands and stormwater, may also apply to the pulp and paper mills.

Emergency planning and community right to know (EPCRA)

Three of the components of EPCRA are directly relevant to the pulp and paper industry:

• Emergency Planning - Businesses that produce, use or store “hazardous substances” must: 1) submit material safety data sheets or the equivalent, and 2) Tier I/Tier II annual inventory report forms to the appropriate local emergency planning commission. Those handling “extremely hazardous substances” also are required to submit a one-time notice to the state emergency response commission.
• Emergency Notification of Extremely Hazardous Substance Release - A business that unintentionally releases a reportable quantity of an extremely hazardous substance must report that release to the state emergency planning commission and the local emergency planning commission.
• Release Reporting - Manufacturing businesses with 10 or more employees that manufactured, processed, or otherwise used a listed toxic chemical in excess of the “established threshold” must file annually a Toxic Chemical Release form with EPA and the state.

Hazardous waste

The pulp and paper industry generates hazardous wastes, but most are associated with wastewater, which is rendered non-hazardous in wastewater treatment or neutralization units within manufacturing facilities, and therefore is not subject to Resource Conservation and Recovery Act (RCRA) requirements. Also, black liquor is exempt as a solid waste if it is reclaimed in a recovery furnace and reused in the pulping process. Therefore, most of the industry’s RCRA requirements are those described in the general regulations for hazardous waste.

Electric utilities key definitions

• Key definitions for the electric utilities industry are found in this section.

The following definitions apply to work performed under 1910.269.

• Contract employer: An employer, other than a host employer, that performs work covered by this section under contract.
• Energized (alive, live): Electrically connected to a source of potential difference, or electrically charged so as to have a potential significantly different from that of earth in the vicinity.
• Host employer: An employer that operates, or that controls the operating procedures for, an electric power generation, transmission, or distribution installation on which a contract employer is performing work covered by this section. Note to the definition of “host employer”: The Occupational Safety and Health Administration (OSHA) will treat the electric utility or the owner of the installation as the host employer if it operates or controls operating procedures for the installation. If the electric utility or installation owner neither operates nor controls operating procedures for the installation, OSHA will treat the employer that the utility or owner has contracted with to operate or control the operating procedures for the installation as the host employer. In no case will there be more than one host employer.
• Line-clearance tree trimmer: An employee who, through related training or on-the-job experience or both, is familiar with the special techniques and hazards involved in line-clearance tree trimming. Note 1 to the definition of “line-clearance tree trimmer”: An employee who is regularly assigned to a line-clearance tree-trimming crew and who is undergoing on-the-job training and who, in the course of such training, has demonstrated an ability to perform duties safely at that level of training and who is under the direct supervision of a line-clearance tree trimmer is considered to be a line-clearance tree trimmer for the performance of those duties. Note 2 to the definition of “line-clearance tree trimmer”: A line-clearance tree trimmer is not considered to be a “qualified employee” under this section unless that employee has the training required for a qualified employee under paragraph (a)(2)(ii) of this section. However, under the electrical safety related work practices standard in Subpart S of this part, a line-clearance tree trimmer is considered to be a “qualified employee.” Tree trimming performed by such “qualified employees” is not subject to the electrical safety-related work practice requirements contained in 1910.331 through 1910.335 when it is directly associated with electric power generation, transmission, or distribution lines or equipment. See 1910.331 for requirements on the applicability of the electrical safety-related work practice requirements contained in 1910.331 through 1910.335 to line clearance tree trimming performed by such “qualified employees,” and see the note following 1910.332(b)(3) for information regarding the training an employee must have to be considered a qualified employee under 1910.331 through 1910.335.
• Line-clearance tree trimming: The pruning, trimming, repairing, maintaining, removing, or clearing of trees, or the cutting of brush, that is within the following distance of electric supply lines and equipment: (1) For voltages to ground of 50 kilovolts or less: 3.05 meters (10 feet); (2) For voltages to ground of more than 50 kilovolts: 3.05 meters (10 feet) plus 0.10 meters (4 inches) for every 10 kilovolts over 50 kilovolts. Note to the definition of “line-clearance tree trimming”: This section applies only to line-clearance tree trimming performed for the purpose of clearing space around electric power generation, transmission, or distribution lines or equipment and on behalf of an organization that operates, or that controls the operating procedures for, those lines or equipment. See paragraph (a)(1) of this section. Tree trimming performed on behalf of a homeowner or commercial entity other than an organization that operates, or that controls the operating procedures for, electric power generation, transmission, or distribution lines or equipment is not directly associated with an electric power generation, transmission, or distribution installation and is outside the scope of this section. In addition, tree trimming that is not for the purpose of clearing space around electric power generation, transmission, or distribution lines or equipment is not directly associated with an electric power generation, transmission, or distribution installation and is outside the scope of this section. Such tree trimming may be covered by other applicable standards. See, for example, 1910.268 and 1910.331through 1910.335.
• Lines. (1) Communication lines: The conductors and their supporting or containing structures which are used for public or private signal or communication service, and which operate at potentials not exceeding 400 volts to ground or 750 volts between any two points of the circuit, and the transmitted power of which does not exceed 150 watts. If the lines are operating at less than 150 volts, no limit is placed on the transmitted power of the system. Under certain conditions, communication cables may include communication circuits exceeding these limitations where such circuits are also used to supply power solely to communication equipment. Note to the definition of “communication lines”: Telephone, telegraph, railroad signal, data, clock, fire, police alarm, cable television, and other systems conforming to this definition are included. Lines used for signaling purposes, but not included under this definition, are considered as electric supply lines of the same voltage. (2) Electric supply lines: Conductors used to transmit electric energy and their necessary supporting or containing structures. Signal lines of more than 400 volts are always supply lines within this section, and those of less than 400 volts are considered as supply lines, if so run and operated throughout.
• Qualified employee (qualified person): An employee (person) knowledgeable in the construction and operation of the electric power generation, transmission, and distribution equipment involved, along with the associated hazards. Note 1 to the definition of “qualified employee (qualified person)”: An employee must have the training required by (a)(2)(ii) of this section to be a qualified employee. Note 2 to the definition of “qualified employee (qualified person)”: Except under (g)(2)(iv)(C)(2) and (g)(2)(iv)(C)(3) of this section, an employee who is undergoing on-the-job training and who has demonstrated, in the course of such training, an ability to perform duties safely at that level of training and who is under the direct supervision of a qualified person is a qualified person for the performance of those duties.
• System operator: A qualified person designated to operate the system or its parts.

Electric utilities hazards and training

• Serious hazards associated with the electric power industry include electrocution, falls, confined spaces, fires and explosions, and more.
• Qualified workers must have the proper training to recognize and control or avoid electrical hazards present at the worksite.

Many of the specific hazards associated with the electrical industry are similar to those found in other large industries. Some of the more serious and common hazards associated with the electric power industry are:

• Electrocution;
• Falls;
• Confined spaces;
• Fires and explosions;
• Sprains, strains, and fractures; and
• Environment stress (e.g., weather).

The 1910.269 standard includes requirements relating to:

• Enclosed spaces;
• Hazardous energy control;
• Working near energized parts;
• Grounding for employee protection;
• Work on underground and overhead installations;
• Line-clearance tree trimming;
• Work in substations and generating plants; and
• Other special conditions and equipment unique to the generation, transmission, and distribution of electric energy.

The 1910.269 standard primarily addresses electrical safety-related work practices for “qualified” employees only. The standard contains very few equipment design and installation requirements. Electric power generation, transmission, and distribution installations typically are designed to conform to the National Electrical Safety Code (ANSI/IEEE C-2) and/or National Electrical Code (ANSI/NFPA 70).

Work activities by “unqualified” employees on, near, or with electric power generation, transmission, or distribution lines or equipment are covered by 1910 Subpart S, Safety-related Work Practices. An employee who is undergoing on-the-job training, but is not under the direct supervision of a qualified person, is considered an unqualified employee for the performance of those duties.

Additionally, regarding line clearance tree-trimming, the electrical safety-related work practices in Subpart S apply if the work does not meet the line clearance tree trimming definition in 1910.269(x) or if the line clearance tree trimming work is performed by an employee other than a qualified employee or line-clearance tree trimmer.

Training

The degree of training must be determined by risk to the worker for the hazard involved.

Qualified workers must have training to recognize and control or avoid electrical hazards present at the worksite.

Line-clearance tree trimmers must have training to distinguish exposed live parts and to determine the voltage on those parts, and they must have training in minimum approach distances and how to maintain them.

It is no longer necessary for employers to certify that workers are proficient in safe work practices.

Minimum approach-distance

The standards require the employer to establish minimum approach distances that employees must maintain from exposed energized parts. The employer must base those distances on formulas set by the standard or follow default minimum approach-distance tables contained in the standard.

Appendix B to the standard provides tables listing minimum approach distances for conditions common in electric power transmission and distribution work. Employers may use these tables to establish minimum approach distances under the exposure conditions covered by the tables. In addition, Appendix B provides guidance on:

• How to comply with the minimum approach-distance requirements in the standard,
• How to use portable protective gaps to limit maximum transient overvoltages at the worksite and thereby reduce minimum approach distances, and
• How to calculate minimum approach distance when employers use portable protective gaps.

Fall protection

Qualified workers must use fall protection when climbing or changing location on poles, towers, or similar structures unless climbing or changing location with fall protection is infeasible or creates a greater hazard than climbing or changing location without it.

Personal fall arrest equipment must be used in accordance with 1910 Subpart I. Personal fall arrest equipment must be capable of passing a drop test after exposure to an electric arc with a heat energy of 40± cal/cm2 if the workers using the fall protection are exposed to flames or electric arc hazards.

Work-positioning equipment must be rigged so that workers can free fall no more than 0.6 meters (2 feet).

Electric utilities construction work

• Employees who are working on construction of electric power systems are covered under the OSHA standard 1926 (not 1910, General Industry). However, if employees are only working on maintenance of these systems, those activities are covered under 1910.

Employees engaged in the construction of electric power transmission or distribution systems are protected by the provisions of Subpart V of the Construction Standards (Part 1926) rather than 1910.

Construction vs. maintenance

A general definition of “construction” is given at 1910.12(b) as follows: “For purposes of this section, Construction work means work for construction, alteration, and/or repair, including painting and decorating.”

Following are some situations common to electric utilities work, along with the Occupational Safety and Health Administration (OSHA)’s stance on whether the work is construction or maintenance (general industry) work.

• The repair of specific limited portions of electrical systems with “replacement in kind” parts to keep them in operation is maintenance and covered by the general industry standards.
• Generally speaking, reconfiguration of space or installation of new equipment (such as equipment capable of carrying higher voltages) is construction; refurbishing (replacement “in kind”) equipment and space is maintenance and covered under the general industry standards.
• The building of new power lines and towers, generation plants, underground distribution facilities and power stations is construction. Additions to or extensions of existing equipment or lines is also construction.
• Moving an existing power line and supporting poles, even without alteration or replacement of parts, a few feet to the side to allow for the widening of a roadway is construction and covered under Part 1926, Subpart V, because this is a layout alteration. If there were violations, the company moving the power lines, in this scenario the contractor working on the roadway, would be cited under Part 1926. If further down the road, longer power lines (with longer power line spans) or different sized poles (e.g., 35-foot to 40-foot pole replacement) had to be installed to cross the widened span of the roadway, then this operation would also be covered under the construction standards due to the design specification changes involved.
• Scheduled touch-up and spot painting that is done to maintain equipment or structures is not construction. Therefore, maintenance painting for power generating, transmission, and distribution equipment is covered by 1910.269. Painting to complete newly built structures and buildings is construction covered by 1926. Additionally, a complete repainting job in one room or on a major portion of a structure or building is construction and removal of lead-based paint is also construction. (Note: Painting is not covered by Part 1926 Subpart V.)

In cases in which it is not readily obvious whether the general industry or construction standards apply, citations of the appropriate standards from both general industry and construction may be issued, in the alternative, to address each identified hazard.

Before contract work

Before contract work begins, the contractor must:

• Provide documentation of any necessary safety training, such as electrical safety training or lockout/tagout;
• Name a representative to coordinate all safety and health issues and communicate with you;
• Sign a confidentiality statement to protect your company’s proprietary data;
• Provide information on the safety and health hazards that may arise during the course of the contractor’s work at this company, and the means necessary to avoid danger from those hazards;
• Get your safety rules and regulations;
• Be informed of emergency signals and procedures where its employees are working;
• Have the telephone numbers of the nearest hospital, ambulance service, and fire department;
• Know who to call and what to do in emergencies, including where first-aid and medical services are located, and how to train employees;
• Advise and train its employees on hazards associated with the work to be performed, including any Hazard Communication or other hazard information provided the contractor by you, or your designated representative; and
• Keep you or your representative fully informed of any work that may affect your employees or property. This includes complying with the state and federal Hazard Communication requirements and providing the designated representative appropriate safety data sheets (SDSs) or other required information about chemicals the contractor will bring onto the site.

During contract work

During contract work, the contractor will:

• Ensure that all subcontractors also abide by your requirements;
• Perform its work while the plant is operating, if necessary, and establish necessary safe practices to permit work under operating conditions without endangering your company’s associates and property. This includes but is not limited to barricading, sign-posting, and fire watches;
• Make sure that any equipment, chemicals, or procedures used by the contractor to perform contracted work meet all OSHA requirements;
• Have a designated site safety coordinator present and attentive to the work being carried out at all times that the contractors and/or subcontractors are working at the facility site;
• Be responsible and accountable for any losses or damages suffered by your company and/or its employees as a result of contractor negligence;
• Provide its employees with medical care and first aid treatment. Plant first aid facilities may be used only in case of emergencies;
• Use only the plant or building entrance designated, and follow the facility access control practice. The contractor also will ensure that each contractor employee is issued and wears some form of easily seen identification;
• Provide supervisors and employees who are competent and adequately trained, including training in all health and safety aspects of the work involved in the contract; provide all tools and equipment for the work, including personal protective equipment (PPE), and ensure the equipment is in proper working order, and that employees are instructed in its proper use;
• Maintain good housekeeping;
• Follow your specific instructions in emergencies;
• Notify you or your designated representative immediately of any OSHA recordable injury or illness to contractor employees or subcontractor employees occurring on your site;
• Provide a copy of each accident report to the designated representative;
• Receive and use a copy of the facility’s written safety policies and procedures; and
• Be responsible for cleaning all work areas, and disposing of any discarded materials in a proper and legal manner.

Before contract work

Before contract work begins, the employer must:

• Review preparation of worksite before contractor begins initial work;
• Ensure that the designated representative has a copy of the contract, is thoroughly familiar with its contents, and with the safety and health aspects of the work, or knows who to call to obtain this information. The designated representative is responsible for ensuring that all company responsibilities are carried out;
• Provide a copy of your facility’s written safety policies and procedures to the contractor;
• Designate a representative to coordinate and communicate all safety and health issues and communicate with the contractor;
• Conduct an inspection of the proposed worksite area before the pre-start up meeting so that any known information about on-site hazards, particularly non-obvious hazards, are documented and thoroughly communicated to the contractor;
• Work directly with the contractor’s designated representative, with whom all contacts should be made;
• Conduct a pre-start up meeting (walk through) with the contractor’s designated representative and a supervisor from each of the areas of the plant involved in the contractor’s work;
• Review all contract requirements related to safety and health with the contractor’s designated representative, including, but not limited to, rules and procedures, personal protective equipment (PPE), and special work permits or specialized work procedures;
• Advise the contractor that the facility safety and health policies must be followed. A copy of the facility’s safety plans must be furnished to the contractor;
• Inform contractor’s designated representative of the required response to employee alarms, and furnish the contractor with a demonstration or explanation of the alarms;
• Communicate thoroughly with the contractor’s designated representative any safety and health hazards (particularly non-obvious hazards and hazard communication issues). It is the contractor’s responsibility to convey this information to its employees;
• Identify connect-points for all services, such as steam, gas, water, electricity, etc. Define any limitations of use of such services; and
• Ensure that all affected employees at your company receive training on all hazards to which a contractor will introduce them.

During contract work

During contract work, the employer must:

• Limit, as necessary, the entry of company employees into contractor work areas;
• Monitor the contractor’s compliance with the contract throughout the duration of the work;
• Document all discussions, including place, time, and names of contractor employees in attendance;
• Approve the contractor beginning work each day, unless it is routine service or maintenance work or periodic outdoor service or maintenance work;
• For work for which your company has developed specific and generally applicable procedures, make sure contractors and their subcontractors follow the same procedures;
• If an unsafe act or a condition is noted that creates an imminent danger of serious injury, take immediate steps to stop the unsafe act or condition. Report the situation to the contractor’s designated representative, or in their absence, the contractor’s employees. Do not allow work that is in violation of a regulation to continue.
• Do not allow loaning of tools and equipment to outside contractors and their subcontractors. The contractor is required to provide the necessary tools and equipment;
• Contact the nearest medical facilities, when available, in emergency situations where severity of the injury dictates immediate attention;
• Get a copy of each OSHA recordable injury report from the contractor and subcontractor;
• Investigate and report to the facility manager all personal injuries to contractor and subcontractor employees;
• Investigate and report any property losses;
• Maintain a contractor accident report file; and
• After conclusion of the contract work, complete a post-project assessment of the contractor’s safety performance for the facility manager to be used for future reference, with a recommendation on whether or not to re-hire the contractor.