Safety Issues Common in the Remanufacturing Industry

1. Safety Issues Common in the Remanufacturing Industry

2. Regulations that are applicable • NFPA – National Fire Protection Association • ANSI – American National Standards Institute • ASTM – American Society for Testing & Materials • ASME – American Society of Mechanical Engineers

3. Regulations - continued • CGA – Compressed Gas Association • ACGIH – American Conference of Governmental Industrial Hygienists • NIOSH – National Institute of Occupational Safety & Health • State & Local Ordinances • Fire Marshall (Boiler / Pressure Vessel) • A.E.D. Deployment Notification

4. The Regulatory Agency • OSHA – Occupational Safety & Health Administration • 29 CFR 1910.6 Incorporation by reference • Over 275 additional standards are included

5. Why should I comply?

6. Fatality Incident

7. Why should I comply? • Protection of your employees. • Avoid costly OSHA Fines.

8. Violations / Penalties • Other than Serious • Up to $7,000 / violation • May be adjusted down by up to 95% • Serious • From $1,500 to $7,000 / violation • Willful • Up to $70,000 / violation • Minimum is $5,000 / violation

9. Administrative Enhancements to OSHA’s Penalty Policies • Memo dated April 22, 2010 • From David Michaels, PhD, MPH • “Last year, the Occupational Safety and Health Administration assembled a work group to evaluate the Agency’s penalty policies. The general consensus of the group was that the Agency’s penalties are too low to have an adequate deterrent effect.”

10. OSHA activity in the past year • The following are some of the citations that were issued for NAICS 336340 / 336350 • 1910.106 Flammable & Combustible Liquids • Initial Penalty $1250.00 • 1910.134 Respiratory Protection • Initial Penalty $1250.00 • 1910.212 Machine Guarding • Initial Penalty $1250.00 • 1910.147 Lockout / Tag out • Initial Penalty $1500.00 • 1910.304 Wiring Design & Protection • Initial Penalty $1250.00

11. The Top 5 in SIC 3714(Oct 08 – Oct 09) • 1910.1200 Hazard Communication $15,350.00 • 1910.147 Lockout / Tag out $54,310.00 • 1910.1025 Lead Exposure $5,425.00 • 1910.212 Machine Guarding $8,485.00 • 1910.178 Powered Industrial Truck $44,550.00

12. Hazard Communication • Secondary Container Labeling • MSDS • Training

13. Lockout / Tag out • Written LOTO Procedure • Training • LOTO Equipment

14. Lead Exposure • Respiratory Protection • Medical Surveillance • Training

15. Machine Guarding • No point – of – operation guarding on the machine • Physical guarding insufficient

16. Powered Industrial Truck • Operator Training • Inspection / Maintenance • Seatbelts

17. Most recent activity / focus • 29 CFR 1910.305 (g)(1)(iv)(A) Temporary wiring – “a flexible cord or cable was used as a substitute for the fixed wiring of a structure”.

18. Most recent activity / focus • 29 CFR 1910.305 (g)(1)(iii)(B) Temporary wiring – “flexible cords and / or cables were run through holes in walls, ceilings, or floors”.

19. Most recent activity / focus • NFPA 70E Arc Flash / Arc Blast Protection • Labeling of panels • Personal Protective Equipment for Qualified Personnel

20. Special emphasis • Industrial Hygiene • Lead Exposure • Spraying Operations • Respiratory Protection • Physicals • Fit Testing • Combustible Dust

22. Environmental Compliance • Clean Air Act • Hazardous Waste (RCRA) • Clean Water Act • Emergency Planning and Community Right to Know • Oil Spill Prevention and Control

23. State Level vs. Federal • Each State has their own set of environmental regulations • Most States will mirror the Federal requirements • Each State may have their own requirements that go above and beyond Federal

24. Clean Air Act • Permitting required for the construction of new air pollution sources • New paint booths • New bake off ovens • Shot blasters • Boilers • Building heat and mobile sources may have exemptions Applies to plant expansions and new facilities

25. Hazardous Waste • Requirements are found in the Resource Conservation and Recovery Act (RCRA) -businesses have responsibility to determine if waste is hazardous (testing is required) -paint waste -blasting dust -paint booth filters -fluorescent light tubes -batteries -bottoms from distillation units

26. This is not acceptable testing

27. Hazardous Waste • Exemptions • Wastes that go to public treatment facilities • Sewage

28. Clean Water Act • Stormwater Discharge • Most facilities need a permit • May require periodic testing or a written plan to keep runoff free from contamination

29. Emergency Planning and Community Right to Know • Tier II Report • If hazardous materials are stored in quantities of 10,000 lbs or more • Extremely hazardous substances have small thresholds Form R • If you use 25,000 lbs or more of certain chemicals • If you process 10,000 lbs or more of certain chemicals.

30. Oil Spill Control • Applies to facilities that have storage capacities at or above 1320 gallons of all petroleum products in containers greater than 55 gallons. • Bulk oil -Gasoline -Diesel • Transmission fluid -Used oil

31. Oil Spill Control • Requires a written plan to be developed on how to handle spills, tank failures, etc. • Employee training • Tank integrity inspections • Spill/Leak prevention

33. References • OSHA 29 CFR 1910 General Industry Regulations www.osha.gov • U.S. Department of Labor – Bureau of Labor Statistics • NFPA 70E • U.S. Environmental Protection Agency

34. Questions