At present, the Occupational Safety and Health Administration regulates personal protective equipment (PPE) design by reference to American National Standards
BOB ECKHARDT
At present, the Occupational Safety and Health Administration regulates personal protective equipment (PPE) design by reference to American National Standards Institute criteria. OSHA recently has determined that specifying ANSI standards is not an effective approach for PPE design regulation. Accordingly, the agency is proposing a performance-based approach for the formulation of improved PPE design standards to replace ANSI references. It also establishes additional guidance for the determination of a Îgood designÌ standard.
All OSHA-incorporated ANSI standards are more than a decade old; in some instances, two decades have passed since they were adopted by reference. The relevant ANSI standards have been updated; and, in one instance, the ANSI Z41 standard for protective footwear has been completely replaced with American Society for Testing Materials International (ASTM) criteria. In an ironic turn of events, manufacturers have adapted to newer ANSI standards, while outdated OSHA regulations prescribe inferior product. Consequently, employers and employees have difficulty obtaining PPE manufactured in accordance with incorporated standards. OSHA estimates the average life of such types of equipment to be about two to four years. Regulation in this case would appear to be superfluous at best!
In an effort to catch up with its regulated audience, OSHA will now authorize the use of PPE that meets current versions of the referenced standards, which the agency has determined meet the Îgood designÌ requirement and, therefore, will be listed in nonmandatory appendices of the new regulation. Similarly, the proposal presumes that a future national consensus standard will satisfy Îgood designÌ criteria. Employers may rely on that presumption with a high degree of confidence, as the possibility is remote that a future national consensus standard will not incorporate Îgood designÌ requirements.
Unfortunately, the standard lists Îgood designÌ regulations that are dated, as evidenced by the referenced Appendix C of PPE criteria.
APPENDIX C TO SUBPART I OF PART 1910
PERSONAL PROTECTIVE EQUIPMENT CRITERIA (NONMANDATORY)
This appendix lists equipment design regulations that OSHA has determined are good design standards, as that phrase is used in Sec. 1910.133(b), 1910.135(b), and 1910.136(b).
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Good design standards for protective eye and face devices [1910.133(b)]
- ANSI Z87.1-2003, American National Standard Practice for Occupational and Educational Eye and Face Protection
- ANSI Z87.1-1998, American National Standard Practice for Occupational and Educational Eye and Face Protection
- ANSI Z87.1-1989, American National Standard Practice for Occupational and Educational Eye and Face Protection
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Good design standards for protective helmets [1910.135(b)]
- ANSI Z89.1-2003, American National Standard for Personnel Protection Û Protective Headwear for Industrial Workers-Requirements
- ANSI Z89.1-1997, American National Standard for Personnel Protection Û Protective Headwear for Industrial Workers-Requirements
- ANSI Z89.1-1986, American National Standard for Personnel Protection Û Protective Headwear for Industrial Workers-Requirements
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Good design standards for protective footwear [1910.136(b)]
- ASTM F-2412-2005, Standard Test Methods for Foot Protection,” and ASTM F-2413-2005, Specification for Performance Requirements for Protective Footwear (Together, the two are said to constitute a good design standard.)
- ANSI Z41-1999, American National Standard for Personal Protection–Protective Footwear
- ANSI Z41-1991, American National Standard for Personal Protection–Protective Footwear
This proposal is an example of your government tax dollars at work.
OBSOLETE CONTROLLING EMPLOYERS CITATION
A ruling by the Occupational Safety and Health Review Commission (OSHRC No. 03-1622) stipulates that OSHA will no longer be able to cite general contractors for safety violations on construction sites by their subcontractors. Supporting that change is the rationale that the controlling employer has neither created the safety hazard nor exposed employees to the hazard. OSHA previously had cited employers for subcontractor violations. Detailed information regarding this decision can be obtained at osha.gov by entering the finding number in the website search database.
NEW SAFETY SIGN, COLOR REQUIREMENTS
Primary among OSHA sign regulations are 29 CFR 1910.145 for General Industry Standards and 29 CFR 1926.200 for Construction. Both reference by incorporation American National Standard Institute (ANSI) Z53.1-1967 for Safety Signs and Color Codes, which has since been replaced by ANSI 535. In an effort to catch up with improved safety technology, OSHA now recognizes compliance with new Z535 standards as an acceptable alternative to its old regulations, calling this a de minimis situation. The ruling, in effect, allows employers to comply with OSHA regulations via signage that meets the new standard.
The new ANSI standards are reported to meet international standards known as TAG to ISO/TC 145, since the ANSI regulation incorporates the ISO standard by reference. The ISO standard relies on the use of symbols only (no words), while the ANSI standard describes a divided sign with an ISO-mandated symbol on the left-hand side and a color-coded word description on the right half.
OSHA ONLINE SUPPORT
While obligated to enforce the provisions of its 1970 OSHA act, the agency has used a portion of its budget to provide approximately 100 free publications that offer extensive guidance, ranging from advice to helpful direction in meeting compliance with OSHA standards. These publications can be obtained at www.osha.gov by clicking on Îpublications/postersÌ in the left-hand column of the home page.
On the same site are icons for selecting other OSHA web pages, including Hurricane Safety Resources, Pandemic Flu Guidance, Teen Job Safety Campaign, and other seasonally popular subjects. Additionally, OSHA premiered a new online chemical database encompassing over 800 chemicals commonly found in the workplace.
Devoted specifically to Concrete and Concrete Products Û Manufacturing and Construction is an OSHA webpage located at http://www.osha.gov/dcsp/products/topics/concreteproducts/index.html. Also offered online are Quickcards, free posters, BLS statistics, alliance information, and two Hispanic websites, plus Spanish courses. Grants are available to nonprofit organizations for Spanish-language courses designed to train employers and employees in the recognition and prevention of workplace safety and health hazards. Training videos, fact sheets, newsletters, bulletins, and other publications as well can be obtained through OSHA online.
While many of the support media do not specifically target concrete production, applicable offerings address generic topics, including such standards as Hazard Communication, Lockout-Tagout, Personal Protective Equipment, and others. Specific to concrete are the following items:
Publications Posters and Forms
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Concrete Manufacturing Pocket Guide. OSHA Publication 3221 (2004). Also available as a 253 KB PDF (2004), 15 pages.
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Concrete and Masonry Construction. OSHA Publication 3106 (1998). Also available as a 415 KB PDF (1998), 32 pages.
Alliance Information
- American Concrete Pipe Association
- Concrete Sawing and Drilling Association
- Mason Contractor Association of America
Strategic Partnership Information
- National Ready-Mixed Concrete Association
- Georgia Concrete and Products Association
- Nebraska Concrete Aggregates Association
- Various contractor associations
Chemical Sampling Information
- Portland Cement (Respirable Fraction)
Technical Information
- Safety and Health Topics: Concrete and Concrete Products Û Manufacturing and Construction
- Safety and Health Topics: Concrete and Concrete Products Û Manufacturing and Construction Û Industry Segments and Controlling Hazards
- Safety and Health Topics: Concrete and Concrete Products Û Manufacturing and Construction Û Additional Information
Sampling and Analytical Methods
- Portland Cement (Total Dust) in Workplace Atmospheres Û (Inorganic Method #207)
Bulletins
- Potential asbestos contamination in soft concrete 19981008.
- Hazards Associated with Strand Restraint Devices in Manufacturing Prestressed Concrete Beams
- SHIB: Precast Concrete Panels Û Hazardous Storage
Other OSHA Information
- Concrete and Masonry Construction
- Supporting Statement for the Information Collection Requirements of the Concrete and Masonry Construction Standard [29 CRG Part 1926, Subpart O] OMB Control Number 1218-0095 (August 2004)
Fatal Facts Accident Reports
- Nos. 24, 46, and 49
OSHA Quicktakes
- Safe Storage of Concrete Panels Subject of Safety and Health Bulletin.
- New Safety and Health Topics Page for Concrete Industry