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OSHA 30: 1926 Subpart D Health and Environmental Controls


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In a previous article that was posted on December 14, 2016, we gave an overview of OSHA’s 30-hour training course. You can read that article here: hvac-blog.acca.org/osha-30-need-know/

The OSHA 30-hour Construction Industry Training course covers several specific topics. However, there are certain topics that OSHA may require contractors to complete extra training on based on the industry that the person participating is associated with.

Contact your local OSHA office to determine whether you are required to participate in extra training as part of the OSHA 30-hour Construction Industry Training course. More information can be found at www.osha.gov.

If you are required to participate in a training program focusing on Subpart D Health and Environmental Controls, you can expect to cover a wide range of topics including first aid, lighting, exposure to chemical and exposure to radiation.

Be aware that several of the standards focused on in Subpart D are also referenced in other parts of the 1926 standards*. For instance, the standard for eye washing facilities found at 1926.51(g) applies to all phases of construction such as site work, concrete placement and demolition. This standard may be reiterated in a paragraph such as, Formaldehyde (1926.1148 (h)(3)) “If there is any possibility that an employee’s eyes may be splashed with solutions containing 0.1 percent or greater formaldehyde, the employer shall provide acceptable eyewash facilities with the immediate work area for emergency use.” Or this standard may be used with Hazard Communication (1926.59(g)(x)) when the Material Safety Data Sheet requires 15 minutes of flushing of the eye.

Also, there are several items mentioned in Subpart D that are covered by their own focused set of standards. These include Lead (1926.62) and Personal Exposure Limits (PEL’s) (1926.55); lighting in Illumination (1926.56); breathing zone air quality in Ventilation (1926.57) and Criteria for Design and Construction for Spray Booths (1926.66); abrasive blasting/grinding in Ventilation (1926.57) and lasers in Nonionizing Radiation (1926.54).

1926 Subpart D training covers the requirements that an employer must adhere when developing a safety and health program.

General requirements are as follows:

Chemical Emergency, in section 65;
Hazardous waste operations and emergency response to chemicals and hazardous substances (see paragraph q) are in this section.

Chemical Information, in section 59;
This is the Hazard Communication standard that has provisions for a written program that includes training, labeling and availability and use of Material Safety Data Sheets.

Chemicals: gases, vapors, fumes, dusts and mists, the personal exposure limits (PEL’s), in section 55;
Exposure by inhaling, ingestion, skin or other contact must be controlled by engineering, administrative or personal protective equipment.

Drinking Water and Cups, in section 51;
An adequate supply of drinking quality water must be available.

Lighting, in section 56;
General construction lighting must be at least 5 foot-candles.

Medical Services and First Aid, in section 50;
Arrangements are to be made prior to the start of the project for prompt medical attention.

Noise and the hearing conservation program in section 52;
Engineering, administrative or hearing protection must be provided.

Shipping Labels, in section 61;
Packages, freight containers, freight cars, etc., with the Department of Transportation’s hazardous materials labels or making must be visibly placarded until the packaging is removed of potential hazards.

Rodents and other pests, in section 51;
A program for extermination must be in place for enclosed sites.

Toilets, in section 51;
At least one toilet must be available.

Specific requirements are:

Abrasive Blasting, in section 57;

Composition and toxicity of the dust must be evaluated and the amount in the breathing must be below the PEL’s.

Personal protective equipment such as aprons, gloves, and shoes is covered in paragraph (5).

Silica, respirator and dust-filter mask use are described in paragraph (5).

Open Surface Tanks, mechanical and vapor degreasing operations, in section 57;

The hazard potential must be determined and ventilation/exhaust or other control means must be used.

Rescue procedures must include at least one standby employee.

Grinding and Polishing, in section 57;

The types of wheels, discs and belts and the exhaust systems are listed in paragraph (g).

Lasers, microwaves and other non-ionizing radiation, in section 54;

Qualified, trained operators may use laser equipment. Where the equipment is in use signs must be posted. Laser beams shall not be directed at anyone.

Lead, in section 62;

Before the start of each project, a written plan following the standard must be developed.

Exposure assessment is the level of lead to which an employee would have been exposed had he/she not been wearing a respirator. This assessment must be done initially and when there is a change in the working conditions. Employees must be informed on writing, of the results within 5 day.

Eight-hour average exposure must not exceed 50 micrograms per cubic meter.

Medical surveillance is in paragraph (j) and applies to employees exposed at or above the action level for more than 30 days in any 12 consecutive months.

No exposures at or above the action level must be documented in writing.

Personal protective equipment, change areas, showers, eating places and handwashing are covered in paragraphs (g) and (i).

Respirator selection is in paragraph (f).

Employee training is outlined in paragraph (i) and communication with other contractors is in paragraph (e).

Methylenedianiline (MDA) in section 60;

Exposures, medical attention/surveillance/removal, monitoring, personal protective equipment, records, sanitation, sharing of information with other contractors, training, written emergency plan, etc. are in this section.

Process Safety Management of highly hazardous chemicals, in section 64;

This standard covers the prevention of catastrophic releases of certain quantities of listed chemicals such as ammonia, hydrogen sulfide and phosgene.

An initial process hazard analysis must be done by May 26, 1997, with updates at least every 5 years.

Employee training is outlined in paragraph (g) and communication with other contractors is in paragraph (f)(4) and (h).

Radiation, in section 53;

Exposure/dose limits, monitoring and precautions are in this section.

Spray Booths, in section 66;

Design, cleaning, electrical, ventilation, exhaust and fire protection requirements are in this section.

Drying and curing apparatus are in this section.

Hand held electrostatic applications are in this section.

Spray Finishing, in section 57;

Spray booth and spray area design, cleaning, electrical, ventilation, make-up air exhaust, fire protection and velocity requirements are in section (h).

Ventilation, in section 57;

When used as an engineering control the system requirements for dusts, fumes, mists, vapors, gases are in this section.

*For a complete listing of Part 1926 – Safety and Health Regulations for Construction see: http://tinyurl.com/osha-1926-list

Ruben Porras

Posted In: Safety

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