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Environmental Health and Safety Committee 4-30 Health & SAFETY Update. Lee Wilmot TTM Technologies February 2007. Health & SAFETY Update. 2005 BLS Injury Rate Data Review OSHA Citations for PWB Industry Latest Inspections Regulatory Agenda Actions. Health & SAFETY Update BLS Injury Data.
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Environmental Health and Safety Committee4-30Health & SAFETY Update Lee Wilmot TTM Technologies February 2007
Health & SAFETY Update • 2005 BLS Injury Rate Data Review • OSHA Citations for PWB Industry • Latest Inspections • Regulatory Agenda Actions
Health & SAFETY UpdateBLS Injury Data While injury rates are prime focus, the BLS database contains average employment data by industry
Health & SAFETY UpdateBLS Injury Data In addition to average injury rates by NAICS code, the BLS database shows injury rates by facility size
Health & SAFETY UpdateOSHA Citations • OSHA citations SIC 3672 (Oct’05-Sept’06) • 12 inspections (down from 13 & 18 in prior years) • 65 citations (compares to 63 and 88 in prior yrs) • $21,625 in penalties (v $14519 and $26,464) • Top standards cited (# cites/ # inspects/ penalty) • Haz Com (1200) still #1 • 9 / 5 / $2400 v 11 / 6 / $2671 • Lockout Tagout (147) #2 - 8 / 3 / $3300 • Resp Protect (134) still #3 • 5 / 2 / $425 v 7 / 4 / $1350 • Lead (1025) #5 (was #2) • 5 / 3 / $1750 v 8 / 4 / $438
Health & SAFETY UpdateOSHA Inspections OSHA inspections and citations of PWB industry up from 2005 levels • 1/1/6-12/31/6 period shows 48 inspections (46 in 05) with 144 (up from 97) violations at 39 locations (up from 25) • 26 complaints, 17 planned, 3 referrals, 2 other • Only 1 No Inspection/Out of Business (was 7) • Many companies not recognized >> IPC members? • Altek Electronics, Empire Electronics, International Electronics, Micron Laser Technology, Minco Products, Newonics Inc, Simhof Manufacturing, Titan PCB West
Health & SAFETY UpdateOSHA Semiannual Regulatory Agenda Agenda Published 12/11/2006 • Completed Rules • Assigned Protection Factors for Respirators • Updates to Electrical Standards • New Poster Requirement • Final Rule Stage • Employer Payment for PPE • Proposed Rule Stage • Updates to National Consensus Standards • Walking Working Surfaces & Fall Protection • Prerule Stage • Hazard Communication • Ionizing Radiation • Emergency Response & Prepardness
Health & SAFETY UpdateOSHA Regulatory Completed Rules • Assigned protection factors (APFs) and maximum use concentrations (MUCs) for respiratory protection standard (134) • Final rule published Aug. 24, 2006 (71 FR 50122) Effective 11/22/2006 • APFs from ANSI Z88.2-1992 adopted • PWB industry impacts • Revised Table 1 1910.134(d)(3)(i) • Lead std. 1910.1025(f)(3)(i) • Formaldehyde std 1048(g)(2) & (3)
Health & SAFETY UpdateOSHA Regulatory Completed Rules • Revise & Update subpart S Electrical Stds • Final Rule published February 14, 2007 72 FR 7135 Effective August 13, 2007 • Based on 2000 edition of NFPA 70E & 2002 edition of National Electric Code • Rule focuses on SAFETY in design and installation of electrical equipment • Reference to 1971 NEC in powered platform standard changed
Health & SAFETY UpdateOSHA Semiannual Regulatory Agenda • Final Rule Stage • Employer Payment for PPE • In 1999 OSHA proposed employers pay for required PPE, with few exceptions • Reopened comment period in 2004 to get input on PPE considered as “tool of the trade” • Comment period ended 08/23/04 • Final action projected in May 2007
Health & SAFETY UpdateOSHA Semiannual Regulatory Agenda Proposed Rule Stage Standards Update to National Consensus Standards • Current standards adopted in 1970-72 • OSHA stds reference consensus stds that are outdated or out of print • Multi-year project started 24 Nov. 2004 • 1st Final Rule published 13 Sept 2005 and Was Effective 14 Nov. 2005 (flam & combust liquids, arc welding & cutting, etc)
Health & SAFETY UpdateOSHA Semiannual Regulatory Agenda • Proposed Rule Stage • Update of Walking Working Surfaces and Fall Protection Standards • Current standards do not include available technologies & procedures to protect EEs from slip, trip and fall hazards • NPRM and hearing in 1990. Re-opened record in 2003. Comment period ended 7/31/2003. • New NPRM projected in October 2007
Health & SAFETY UpdateOSHA Semiannual Regulatory Agenda • Pre-Rule Stage • Ionizing Radiation (1910.196) • Request for Information Extended 11/28/05. • Stakeholder meetings projected April 2007. • Emergency Response & Preparedness • Request for Information Projected May 2007. • Hazard Communication • Remember Globally Harmonization System (GHS) to match 2003 UN proposal by 2008 (Reg Plan Seq No. 83)
Health & SAFETY Update Keep in Touch with EHS Issues • Visit the Website at www.ipc.org under “Legislative and Regulatory Affairs” • Subscribe to the EHS Update • Join Compliance Net email forum Contact: Fern Abrams, IPC Director of Environmental Policy (202) 962-0460, fabrams@ipc.org Bret Bruhn, EHS Committee Chairman (503) 992-4689, bret.bruhn@merix.com Lee Wilmot, EHS Committee Vice Chairman (860) 684-8000 x 4702, lee.wilmot@ttmtech.com