OSHA Inspections & Violations in Brief

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Loreen Blake
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1 OSHA Inspections & Violations in Brief

2 The listed violations constitute OSHA s Top Ten List across ALL industries. NCA s experience with an OSHA visit to a drycleaning facility, whether it is the result of a complaint or simply a random sweep inspection, is that the inspection will be comprehensive. That means the inspector will verify employee training, necessary Haz-Com paperwork, Employee Accident and Illness Reports, the OSHA wall poster and if you are a perc user, solvent vapor PEL You can expect the inspector to look at all of the following and issue violation as he finds them. A B C D E F G H I J K Hazard Communication Program Walking Working Surfaces Machines Portable Fire Extinguishers Electrical Sanitation Flammable Liquids Means of Egress Personal Protective Equipment Employee Recordkeeping re: Accidents and Illnesses Miscellaneous Poster Display, Blood Borne Pathogens, Ladders, etc. With these possible areas of violation in mind, but not limited to this list, NCA suggests that every drycleaner make a self-evaluation to be sure that he has a safe and healthful plant. It pays in two ways: you will not be subject to a violation and a fine, and you reduce the possibility of an accident, and it could be you. The list that follows is an overview, and such is not exhaustive. A Hazard Communication Program (Contact NCA re: a complete HAZCOM training program) Y/N Have completed, full hazard communication program? (Training, instructions, records, etc.) Y/N Have current SDS for all chemicals? (NCA has a pretty complete SDS library on the members website) Y/N Have evacuation plan? Y/N Have lockout/tagout plan (employee repairs?) Y/N Have fully trained all employees? Do you train as new chemicals are introduced? Y/N Have labeling system in use?

3 B Walking Working Surfaces Y/N Are floors swept daily and is the facility free of debris? Y/N Are water overflows, grease and oil cleaned up immediately when they occur? Y/N Are aisles and passageways clear, in good repair with no obstruction and no holes in the floor? Y/N Do trap doors have handrails and guards? Y/N Are low hanging objects flagged? Y/N Are rugs and mats slip resistant? Y/N Are there hand rails on stairs? C- Machinery Y/N Do you have a lockout/tagout program for ALL machinery (cleaning machines, shirt units, boilers, etc) under repair by employees? Y/N Is the drycleaning machine area provided with effective ventilation? Y/N Are button traps cleaned to eliminate solvent overflow? Y/N Are buckets or pails covered? Are dip tanks covered when not in use? Y/N Is the drycleaning machine or any solvent at least 25 feet from an open flame? Y/N Are the belts, gears or any moving parts of any piece of machinery completely enclosed on all exposed sides to prevent physical contact? Are all belt or blade guards in place? Y/N Are all fans less than 7 feet above the floor enclosed with fine wire mesh? Y/N Are all steam pipes less than 7 feet above the floor covered/insulated to prevent burns? Y/N Are all safety features and interlocks on presses, shirt units and other equipment operative and used? No safety interlocks overridden? D- Portable Fire Extinguishers and Fire Exits Y/N In s space 25 x 100, are there two portable five-pound dry chemicals placed about 50 feet apart, hung visibly on a wall in a readily accessible position? Are fire extinguishers red, or is the wall painted red behind the fire extinguisher? Y/N have the fire extinguishers been inspected within one year, and is there a rag on the fire extinguisher certifying the date and person who inspected it? Y/N Have your employees been trained in the use of fire extinguishers? Y/N Do you have an SDS for the fire extinguisher? E Electrical Y/N Are all motors grounded? Y/N Is all wiring over 6 feet of a permanent type? No extension cords. Y/N Are all boxes with electrical connections covered and secure?

4 Y/N Are extractors, washers and drycleaning, shirt finishing, pressing and other machines equipped with a working safety interlock device? Y/N Are electrical-powered machines equipped with a power cutoff switch to use while repairs or adjustments are made? Y/N Are the grounding prongs of 3 prong plug intact? F Sanitation and First Aid Y/N Do you have 15 minutes eye wash station that is properly maintained and always accessible (not located in a bathroom)? Y/N Are your waste containers liquid tight? Are they emptied frequently? Y/N Is drinking water readily available? Are there disposable cups? Y/N If only one toilet is available on the premises, is it one person at a time only? Y/N Are there washing facilities with running hot or cold water? Is there a supply of liquid soap and paper towels or an air dryer? Y/N Is there a first aid kit readily available? Does the kit contain burn ointment? Are supplies adequate for the number of employees you have? Y/N Is your lunch area away from the toxic areas? G Flammable Liquids Y/N Are your flammable liquids (less than 5 gallons) stored and dispensed in a safety can? Y/N Are approved type metal storage cabinets provided for the storage of flammable liquids. Are such cabinets conspicuously labeled FLAMMABLE-KEEP FIRE AWAY. Y/N Are there NO SMOKING signs in the area flammable chemicals? H Means of Egress Y/N Are there two exits from the premises (if possible?) Y/N Is there an illuminated exit sign over each exit with letters 6 inches high and ¾ inches wide which can be seen from any work station? Are there direction exit signs visible from workstation? Y/N Are doors which are not exits, marked NOT EXIT or BOILER ROOM, etc? Y/N Are fire exit doors unlocked or open for exit at all times? Y/N Are egress areas and aisles clear at all times? Y/N Are fire drills held periodically? Y/N Are egress are well lit? Y/N Have an evacuation plan?

5 I Personal Protective Equipment Y/N Is proper eye protection furnished to the employees who require it? Y/N Is eye protection fitted to the employee and for the employees personal use? Y/N Are proper respirators available for every effected employee? Y/N Do you have written operating procedures for the use of respirators? Y/N Do employees wear respirators while cleaning perc stills, removing filter powder and transferring sludge? Do they wear respirators while cleaning up minor perc solvent spills? Y/N Have employees who wear respirators (a) been given a medical fitness test, (b) had a snug fitness test (are they clean shaven) and (c) do they have their OWN personal respirator (no sharing)? Y/N Are respirators stored in a vapor tight bag to ensure no passive contamination? Y/N Do employees know what to do in the event of a major solvent spills? Y/N Do you have solvent resistant gloves for employees to use when handling materials saturated with hazardous chemicals? Y/N Do you have adequate ventilation? J Employee Records Y/N Are Forms 300, 300A and 301 completed regarding illness and accidents reports? Y/N If you have more than 20 employees is Form 300A submitted to OSHA each year in a timely fashion? (July 1 in 2017 and 2018 and March 2 in 2019 and beyond). K Miscellaneous Y/N Is the OSHA poster on display in a prominent place where it can be viewed by all employees? Is it in a language understood by all employees? Download at: Y/N Do you have a blood borne pathogen program in place? Have employees been offered a Hepatitis vaccine? If they declined vaccination, do you have a written declination? Y/N Are any ladders on premises NIOSH approved? Y/N Is their height adequate to provide safety in the tasks its use is intended for? Y/N Are employees trained in proper use? Y/N If a forklift is in use have employees undergone OSHA approved training? Y/N Are hand trucks available to move heavy materials? Are employees trained? OBSERVE & TALK & QUESTION Observe employees using equipment to make sure all safety protocols and recommendations by manufacturers are being followed. Talk to them about any problems they may be having with a machine s operation. Ask them if any repairs are needed. OSHA regulations/documents for various areas of concern follow.

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7 Blood Borne Pathogen Hepatitis B Vaccine Declination Part Number: 1910 Part Title: Occupational Safety and Health Standards Subpart: Z Subpart Title: Toxic and Hazardous Substances Standard Number: App A Title: Hepatitis B Vaccine Declination (Mandatory) GPO Source: e-cfr I understand that due to my occupational exposure to blood or other potentially infectious materials I may be at risk of acquiring hepatitis B virus (HBV) infection. I have been given the opportunity to be vaccinated with hepatitis B vaccine, at no charge to myself. However, I decline hepatitis B vaccination at this time. I understand that by declining this vaccine, I continue to be at risk of acquiring hepatitis B, a serious disease. If in the future I continue to have occupational exposure to blood or other potentially infectious materials and I want to be vaccinated with hepatitis B vaccine, I can receive the vaccination series at no charge to me. Print Name Signature Date Witness [56 FR 64004, Dec. 06, 1991, as amended at 57 FR 12717, April 13, 1992; 57 FR 29206, July 1, 1992; 61 FR 5507, Feb. 13, 1996]

8 OSHA Record Keeping Rules for Employers Dry-cleaning and laundry services. Dry cleaning and Laundry is listed in Appendix A of this regulation and therefore you must keep records and depending on the number of employees you have you may have to electronically submit those records to OSHA once a year. Part Number: 1904 Part Title: Recording and Reporting Occupational Injuries and Illness Subpart: E Subpart Title: Reporting Fatality, Injury and Illness Information to the Government Standard Number: Title: Electronic submission of injury and illness records to OSHA. Applicable 01/01/2017 Standards: Appendix: A GPO Source: e-cfr (a) Basic requirements (a)(1) Annual electronic submission of part 1904 records by establishments with 250 or more employees. If your establishment had 250 or more employees at any time during the previous calendar year, and this part requires your establishment to keep records, then you must electronically submit information from the three recordkeeping forms that you keep under this part (OSHA Form 300A Summary of Work-Related Injuries and Illnesses, OSHA Form 300 Log of Work-Related Injuries and Illnesses, and OSHA Form 301 Injury and Illness Incident Report) to OSHA or OSHA's designee. You must submit the information once a year, no later than the date listed in paragraph (c) of this section of the year after the calendar year covered by the forms (a)(2) Annual electronic submission of OSHA Form 300A Summary of Work-Related Injuries and Illnesses by establishments with 20 or more employees but fewer than 250 employees in designated industries. If your establishment had 20 or more employees but fewer than 250 employees at any time during the previous calendar year, and your establishment is classified in an industry listed in appendix A to subpart E of this part, then you must electronically submit information from OSHA Form 300A Summary of Work- Related Injuries and Illnesses to OSHA or OSHA's designee. You must submit the information once a

9 year, no later than the date listed in paragraph (c) of this section of the year after the calendar year covered by the form (a)(3) Electronic submission of part 1904 records upon notification. Upon notification, you must electronically submit the requested information from your part 1904 records to OSHA or OSHA's designee (b) Implementation (b)(1) Does every drycleaner or laundry have to routinely submit information from the injury and illness records to OSHA? No, dry cleaners with less than 20 employees do not have to submit. Only two categories of employers must routinely submit information from their injury and illness records. First, if your establishment had 250 or more employees at any time during the previous calendar year, then you must submit the required Form 300A, 300, and 301 information to OSHA once a year. Second, if your establishment had 20 or more employees but fewer than 250 employees at any time during the previous calendar year, then you must submit the required Form 300A information to OSHA once a year. Employers in these two categories must submit the required information by July 1 st in 2017 and 2018 and March 2 in If you have fewer than 20 employees, then you must submit information from the injury and illness records to OSHA only if OSHA notifies you to do so for an individual data collection. However, everyone must keep ALL the records (b)(2) If I have to submit information under paragraph (a)(1) of this section, do I have to submit all of the information from the recordkeeping form? No, you are required to submit all of the information from the form except the following: (b)(2)(i) Log of Work-Related Injuries and Illnesses (OSHA Form 300): Employee name (column B) (b)(2)(ii) Injury and Illness Incident Report (OSHA Form 301): Employee name (field 1), employee address (field 2), name of physician or other health care professional (field 6), facility name and address if treatment was given away from the worksite (field 7) (b)(3) Do part-time, seasonal, or temporary workers count as employees in the criteria for number of employees in paragraph (a) of this section? Yes, each individual employed in the establishment at any time during the calendar year counts as one employee, including full-time, part-time, seasonal, and temporary workers (b)(3) Do part-time, seasonal, or temporary workers count as employees in the criteria for number of employees in paragraph (a) of this section? Yes, each individual employed in the establishment at any time during the calendar year counts as one employee, including full-time, part-time, seasonal, and temporary workers (b)(4) How will OSHA notify me that I must submit information from the injury and illness records as part of an individual data collection under paragraph (a)(3) of this section? OSHA will notify you by mail if you will have to submit information as part of an individual data collection under paragraph (a)(3). OSHA will also announce individual data collections through publication in the Federal Register and the OSHA newsletter, and announcements on the OSHA Web site. If you are an employer who must routinely submit the information, then OSHA will not notify you about your routine submittal (b)(5)

10 How often do I have to submit the information from the injury and illness records? If you have more than 20 employees you must submit the information once a year, by the date listed in paragraph (c) of this section of the year after the calendar year covered by the form or forms. If you are submitting information because OSHA notified you to submit information as part of an individual data collection under paragraph (a)(3) of this section, then you must submit the information as often as specified in the notification (b)(6) How do I submit the information? You must submit the information electronically. OSHA will provide a secure Web site for the electronic submission of information. For individual data collections under paragraph (a)(3) of this section, OSHA will include the Web site's location in the notification for the data collection (b)(7) Do I have to submit information if my establishment is partially exempt from keeping OSHA injury and illness records? If you are partially exempt from keeping injury and illness records under and/or , then you do not have to routinely submit part 1904 information under paragraphs (a)(1) and (2) of this section. You will have to submit information under paragraph (a)(3) of this section if OSHA informs you in writing that it will collect injury and illness information from you. If you receive such a notification, then you must keep the injury and illness records required by this part and submit information as directed (b)(8) Do I have to submit information if I am located in a State Plan State? Yes, the requirements apply to employers located in State Plan States (b)(9) May an enterprise or corporate office electronically submit part 1904 records for its establishment(s)? Yes, if your enterprise or corporate office had ownership of or control over one or more establishments required to submit information under paragraph (a)(1) or (2) of this section, then the enterprise or corporate office may collect and electronically submit the information for the establishment(s) (c) Reporting dates (c)(1) In 2017 and 2018, establishments required to submit under paragraph (a)(1) or (2) of this section must submit the required information according to the table in this paragraph (c)(1): Submission Submission Year Deadline Drycleaners / Laundries with more than 250 employees Drycleaners/ Laundries with employees 2017 Form 300A Form 300A July 1, Forms 300A, 300, 301 Form 300A July 1, Forms 300A, 300, 301 Form 300A March 2, (c)(2) Note:Beginning in 2019, establishments that are required to submit will have to submit all of the required information by March 2 of the year after the calendar year covered by the form or forms (for example, by March 2, 2019, for the forms covering 2018). [66 FR 6134, Jan. 19, 2001; 81 FR May 12, 2016] Regulations (Standards - 29 CFR) Note Dry cleaners with less than 250 employees need only be concerned with submitting Form 300A. You must complete and keep all FORMS 300, 300A, 301.

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