Wednesday, May 28, 2014

Appendix A to § 1926.50 -- First aid Kits (Non-Mandatory)

First aid supplies are required to be easily accessible under paragraph Sec. 1926.50(d)(1). An example of the minimal contents of a generic first aid kit is described in American National Standard (ANSI) Z308.1-1978 "Minimum Requirements for Industrial Unit-Type First-aid Kits". The contents of the kit listed in the ANSI standard should be adequate for small work sites. When larger operations or multiple operations are being conducted at the same location, employers should determine the need for additional first aid kits at the worksite, additional types of first aid equipment and supplies and additional quantities and types of supplies and equipment in the first aid kits.

In a similar fashion, employers who have unique or changing first-aid needs in their workplace may need to enhance their first-aid kits. The employer can use the OSHA 300 log, OSHA 301 log, or other reports to identify these unique problems. Consultation from the local fire/rescue department, appropriate medical professional, or local emergency room may be helpful to employers in these circumstances. By assessing the specific needs of their workplace, employers can ensure that reasonably anticipated supplies are available. Employers should assess the specific needs of their worksite periodically and augment the first aid kit appropriately.

If it is reasonably anticipated employees will be exposed to blood or other potentially infectious materials while using first-aid supplies, employers should provide personal protective equipment (PPE). Appropriate PPE includes gloves, gowns, face shields, masks and eye protection (see "Occupational Exposure to Blood borne Pathogens", 29 CFR 1910.1030(d)(3)) (56 FR 64175).

Wednesday, May 21, 2014

Appendix A to § 1926.50 -- First aid Kits (Non-Mandatory)

First aid supplies are required to be easily accessible under paragraph Sec. 1926.50(d)(1). An example of the minimal contents of a generic first aid kit is described in American National Standard (ANSI) Z308.1-1978 "Minimum Requirements for Industrial Unit-Type First-aid Kits". The contents of the kit listed in the ANSI standard should be adequate for small work sites. When larger operations or multiple operations are being conducted at the same location, employers should determine the need for additional first aid kits at the worksite, additional types of first aid equipment and supplies and additional quantities and types of supplies and equipment in the first aid kits.

In a similar fashion, employers who have unique or changing first-aid needs in their workplace may need to enhance their first-aid kits. The employer can use the OSHA 300 log, OSHA 301 log, or other reports to identify these unique problems. Consultation from the local fire/rescue department, appropriate medical professional, or local emergency room may be helpful to employers in these circumstances. By assessing the specific needs of their workplace, employers can ensure that reasonably anticipated supplies are available. Employers should assess the specific needs of their worksite periodically and augment the first aid kit appropriately.

If it is reasonably anticipated employees will be exposed to blood or other potentially infectious materials while using first-aid supplies, employers should provide personal protective equipment (PPE). Appropriate PPE includes gloves, gowns, face shields, masks and eye protection (see "Occupational Exposure to Blood borne Pathogens", 29 CFR 1910.1030(d)(3)) (56 FR 64175).

Thursday, May 15, 2014

Eyewash & Shower Facilities OSHA Interpretation

29 CFR 1910.151(C) Where the eyes or body of any person may be exposed to injurious corrosive materials, suitable facilities for quick drenching or flushing of the eyes and body shall be provided within the work area for immediate emergency use.

Dear Mr. B***,

Thank you for your April 21, 2009 letter to the Occupational Safety and Health Administration (OSHA). Your letter was transferred to OSHA's Directorate of Enforcement Programs (DEP) for a response. This letter constitutes OSHA's interpretation of only the requirements discussed and may not be applicable to any questions not delineated within your original correspondence. You had specific questions regarding eyewash and shower facilities required by 29 CFR 1910.151(c). Your paraphrased scenarios, questions, and our responses are below.

Scenario: You state that your company manufactures and sells many commercial cleaning products which are classified as moderate or severe eye irritants. Your company's policy is to specify on the material safety data sheets (MSDS) to use chemical splash goggles as eye protection and to flush for at least 15 minutes as first aid.
Question 1: Is there a requirement for an emergency eyewash in the immediate work area for anything other than injurious corrosive chemicals (including chemicals which the MSDS clearly indicates that the product is a severe irritant, but not corrosive to eyes or skin) under 1910.151(c)? Are there any other Federal OSHA regulations that would require provision of eye flushing facilities for use of chemicals other than corrosives?

Reply 1: No. OSHA's current policy regarding the requirements for providing an emergency eyewash and/or safety shower is explained in its letter of interpretation to Mr. Tom Heslin, May 5, 2004 (attached) as follows:
The OSHA requirements for emergency eyewashes and showers, found at 29 CFR 1910.151(c), specify that "where the eyes or body of any person may be exposed to injurious corrosive materials, suitable facilities for quick drenching or flushing of the eyes and body shall be provided within the work area for immediate emergency use. As the standard states, an eyewash and/or safety shower would be required where an employee's eyes or body could be exposed to injurious corrosive materials. If none of the materials used in this work area is an injurious corrosive [chemical] (as indicated by the Material Safety Data Sheet (MSDS) for each product), then an emergency eyewash or shower would not be required pursuant to 1910.151(c).

While not having the force of a regulation under the OSH Act, the current ANSI standard addressing emergency eyewash and shower equipment (ANSI [Z]358.1-2004) provides for eyewash and shower equipment in appropriate situations when employees are exposed to hazardous materials. ANSI's definition of "hazardous material" would include caustics, as well as additional substances and compounds that have the capability of producing adverse effects on the health and safety of humans. ANSI's standard also provides detail with respect to the location, installation, nature, and maintenance of eyewash and shower equipment. You also may wish to consult additional recognized references such as W. Morton Grant's Toxicology of the Eye (Charles C Thomas Pub. Ltd., 4th edition, August 1993) when considering potential chemical exposures to the eye and the appropriateness of installing eyewash facilities to protect employees against hazards associated with particular chemicals and substances.
Scenario: You state that your company produces concentrated products that are packaged in sealed dispensing containers that are connected to a water source by the user to automatically generate the recommended use dilution. In some cases, the concentrated product, as sold, is corrosive to the eyes or skin, but the use dilution that is generated is no more than an irritant.

Question 2: Is an eyewash and/or shower facilities required in areas where sealed dispensing products are handled since there is no exposure to the corrosive material under anticipated conditions of handling and use?

Reply 2: Yes. In dealing with corrosive products that are packaged in sealed dispensing containers, OSHA's current policy is explained in its letter of interpretation to Mr. Douglas A. Page, April 14, 2008 (attached) as follows:
... the employer must determine if employees can or will be exposed during the course of their duties to hazardous materials in such a way that the protections of an eyewash or emergency shower would be necessary. If hazardous materials are present at a worksite in such a way that exposure could not occur (for example, in sealed containers that will not be opened, or caustic materials in building piping), then an eyewash or emergency shower would not be necessary. However, if the building piping containing caustic materials has, at certain locations, a spigot or tap from which the contents are to be sampled or withdrawn and employees are expected to perform such tasks, then, certainly, an eyewash and/or emergency shower would be needed where this task is to occur.

Friday, May 9, 2014

First Aid List for Part 1904.7(b)(5)(ii)

First Aid List

1904.7 (b)(5)(ii) What is "first aid"?
For the purposes of Part 1904, "first aid" means the following:
(A) Using a nonprescription medication at nonprescription strength (for medications
available in both prescription and non-prescription form, a recommendation by a
physician or other licensed health care professional to use a non-prescription medication
at prescription strength is considered medical treatment for recordkeeping purposes);
(B) Administering tetanus immunizations (other immunizations, such as Hepatitis B vaccine
or rabies vaccine, are considered medical treatment);
(C) Cleaning, flushing or soaking wounds on the surface of the skin;
(D) Using wound coverings such as bandages, Band-Aids™, gauze pads, etc.; or using
butterfly bandages or Steri-Strips™ (other wound closing devices such as sutures,
staples, etc. are considered medical treatment);
(E) Using hot or cold therapy;
(F) Using any non-rigid means of support, such as elastic bandages, wraps, non-rigid back
belts, etc. (devices with rigid stays or other systems designed to immobilize parts of the
body are considered medical treatment for recordkeeping purposes);
(G) Using temporary immobilization devices while transporting an accident victim (e.g.,
splints, slings, neck collars, back boards, etc.).
(H) Drilling of a fingernail or toenail to relieve pressure, or draining fluid from a blister;
(I) Using eye patches;
(J) Removing foreign bodies from the eye using only irrigation or a cotton swab;
(K) Removing splinters or foreign material from areas other than the eye by irrigation,
tweezers, cotton swabs or other simple means;
(L) Using finger guards;
(M) Using massages (physical therapy or chiropractic treatment are considered medical
treatment for recordkeeping purposes); or
(N) Drinking fluids for relief of heat stress.
(iii) Are any other procedures included in first aid?
No, this is a complete list of all treatments considered first aid for Part 1904 purposes.