INTRODUCTION TO OSHA STANDARDS The purpose of this discussion is to provide you with the information you will need in order to apply the OSHA standards to hazards in the workplace. Origin of OSHA Standards Before we proceed, let us take a brief look at the origin of the OSHA standards. Initially, the OSHA standards were taken from three sources: consensus standards, proprietary standards, and federal laws in effect when the Occupational Safety and Health Act became law. Consensus standards are developed by industry-wide standarddeveloping organizations and are discussed and substantially agreed upon through consensus by industry. OSHA has incorporated the standards of the two primary standards groups, the American National Standards Institute (ANSI) and the National Fire Protection Association (NFPA), into its set of standards. An example, ANSI Standard B56.1-1969, Standard for Powered Industrial Trucks, covers the safety requirements relating to the elements of design, operation and maintenance of powered industrial trucks. Another consensus standard source was the NFP A standards. NFP A No. 30-1969, Flammable and Combustible Liquids Code was the source standard for Part 1910, Section 106. It covers the storage and use of flammable and combustible liquids with flash points below 200 F. Proprietary standards are prepared by professional experts within specific industries, professional societies, and associations. The proprietary standards are determined by a straight membership vote, not by consensus. An example of these would be the "Compressed Gas Association, Pamphlet P-1, Safe Handling of Compressed Gases." This proprietary standard covers requirements for safe handling, storage and use of compressed gas cylinders. Some preexisting federal laws are enforced by OSHA, including the Federal Supply Contracts Act (Walsh-Healey); the Federal Service Contracts Act (McNamara-O'Hara); the Contract Work Hours and Safety Standards Act (Construction Safety Act) and the National Foundation on the Arts and Humanities Act. Standards issued Introduction to OSHA Standards Page 1
under these Acts are now enforced in all industries where they apply. Horizontal and Vertical Standards Standards are sometimes referred to as being either "horizontal or "vertical" in their application. Most standards are horizontal or "general," which means they apply to any employer in any industry. Standards relating to fire protection, working surfaces and first aid are examples of horizontal standards. Some standards, though, are relevant only to a particular industry, and are called vertical, or "particular" standards. Examples are standards applying to the longshoring industry or the construction industry and to the special industries covered in Subpart R of 1910. Code of Federal Regulations Probably one of the most common complaints from people having to use the Part 1910 Labor standards is "how do you wade through hundreds of pages of standards and make sense out of them?" From time to time you may have experienced this frustration and been tempted to throw the standards in the round file. One of our many goals at the OSHA Training Institute is not only to teach hazard recognition but to develop an understanding by the student of the Code of Federal Regulations system, the format to which the standards are written, and a simplified color coding method for using the code. These aids take a lot of the "fog" out of the standards and make them much easier to comprehend and use. The Code of Federal Regulations is a codification of the general and permanent rules published in the Federal Register by the Executive departments and agencies of the Federal Government. The Code is divided into 50 titles that represent broad areas subject to Federal regulation. Each title is divided into chapters that usually bear the name of the issuing agency. Each chapter is further subdivided into parts covering specific regulatory areas. Based on this breakdown, the Occupational Safety and Health Administration is designated Title 29-Labor, Chapter XVII. Introduction to OSHA Standards Page 2
Each volume of the Code is revised at least once each calendar year and issued on a quarterly basis approximately as follows: Tit1e16 Title17throughTitle27 Title28 through Title 41 Title 42 through Title 50 as of 01 January as of 01April as of 01 July as of 01 October OSHA's regulations (Title 29) are therefore issued as of July 1. The approximate revision date is printed on the cover of each volume. The Code of Federal Regulations is kept update by the individual issues of the Federal Register. These two publications (the CFR and the Federal Register) must be used together to determine the latest version of any given rule. To determine whether there have been any amendments since the revision date of the Code volume in which the user is interested, the following two list must be consulted: the "Cumulative List of CFR Sections Affected " issued monthly and the Cumulative List of Parts Affected" which appears daily in the Federal Register. These two lists will refer you to the Federal Register page where you may find the latest amendment of any given rule. The pages in the Federal Register are numbered sequentially from January 1 to January 1 of the next year. We have discussed the fact that under Title 29, Chapter XVII is setaside for the Occupational Safety and Health Administration. Under Chapter XVII the regulations are broken down into Parts. Part 1910 for example, is the standard you are all familiar with, Occupational Safety and Health Standards," commonly known as the "General Industry Standards." Under each part, such as Part 1910, major blocks of information are broken down into Subparts. The major Subparts in the 1910 standards include: Subpart D- Walking-Working Surfaces Subpart E -Means of Egress Subpart F -Powered Platforms, Manlifts, and Vehicle- Mounted Work Platforms Subpart G- Occupational Health and Environmental Control Introduction to OSHA Standards Page 3
Subpart H -Hazardous Materials Subpart I -Personal Protective Equipment Subpart J -General Environmental Controls Subpart K -Medical and First Aid Subpart L -Fire Protection Subpart M -Compressed Gas and Compressed Air Equipment Subpart N -Materials Handling and Storage Subpart O -Machinery and Machine Guarding Subpart P -Hand and Portable Powered Tools and Other Hand- Held Equipment Subpart Q -Welding, Cutting and Brazing Subpart R -Special Industries Subpart S -Electrical Subpart Z -Toxic and Hazardous Substances Each Subpart is further broken down into sections. Let's look at one subpart in detail: Subpart D -Walking-Working Surfaces. The index of Subpart D is shown below. Subpart D Walking and Working Surfaces 1910.21 Definitions 1910.22 General requirements 1910.23 Guarding floor and wall openings and holes. 1910.24 Fixed industrial stairs 1910.25 Portable wood ladders 1910.26 Portable 1910.27 Fixed ladders 1910.28 Safety requirements for scaffolding 1910.29 Manually propelled mobile ladder stands and scaffolds (towers) 1910.30 Other working surfaces Introduction to OSHA Standards Page 4
.1910.31 Sources of standards 1910.32 Standards organizations You will note that Subpart D is broken down into sections. Section 21 (1910.21) entitled "Definitions," provides the user with definitions of terms used in each of the Subpart D sections. Next we have general requirements (Section 22) which includes housekeeping, aisle marking, open pit protection, and floor loading designation. Sections 23 through 30 give specific requirements for such things as floor openings, ladders, scaffolding, mobile ladder stands and dock boards. Section 31 and 32 provide the user with basic information on the source standard used to prepare each section and the standard organizations referenced in the subpart. Each subsequent subpart repeats these last two items (i.e., source of standard and standards organization). Subparts E and L go together. All of the requirements for access to an exit, exit, and exit discharge are contained in Subpart E. Employee emergency plans and fire prevention plans are also included in this subpart. Subpart L, Fire protection, contains requirements for fire brigades whenever they are established by an employer, and provides standards relating to different types of fire extinguishing systems. These include portable and fixed fire suppression equipment, as well as other fire protection systems, including fire detection andemployee alarm systems. Subpart F, "Powered Platforms, Manlifts, and Vehicle Mounted Work Platforms," provides standards for devices used to lift personnel to elevated work positions. Subparts G and Z go together, as they are health related. Subpart G contains ventilation requirements and limitations for noise and radiation exposures. Subpart Z contains limitations for air contaminants as well as specific standards for certain toxic health hazards, e.g., asbestos, lead, inorganic arsenic, and acylonitrile. OSHA' s "right-to-know" rule titled "Hazard Communication" is also contained in Subpart Z. Subpart H is titled "Hazardous Materials." This subpart has many sections common to all industry. Introduction to OSHA Standards Page 5
One of these sections is 101 and contains general requirements relating to handling, storage, and use of compressed gases. Section 106 is very widely used since it gives requirements for storage of flammable liquids in portable tanks or other portable containers. Section 106 also addresses the design of flammable liquid storage cabinets, the interior design of flammable liquid storage rooms, and also provides safety standards for industrial operations and service station operations. Another commonly used section is 107 where we find basic requirements for design, construction, electrical wiring, ventilation, illumination, operations and maintenance of paint spray booths. Section 110 is applicable to any operation you have where liquefied petroleum gas (LPG) used to fuel forklifts or used for other industrial purposes. If a company is using anhydrous ammonia for any of its operations, it should be aware of the requirements in section 111. Standards for Hazardous Waste Operations and Emergency Response (HAZWOPER) are contained in Section 120. Subpart H is a very important and lengthy standard. Later we will learn how color-code the standard book. This will make using the standards, especially, Subpart H, much easier. Subpart I contains requirements for the use of Personal Protective Equipment (PPE). Requirements are set forth for protection of all parts of the body including eye, face, head and extremities. Section 132 also mentions use of protective clothing, shields and barriers. Section 134 contains requirements for the use of respiratory protection. Subpart J, General Environmental Controls, contains requirements for sanitation, temporary labor camps and "non-water carriage disposal systems." Section 144 contains safety color coding requirements for marking physical hazards, such as portable containers of flammable liquids. So in Section 106 where the standard states we shall use approved cans, the color of that approved can is described in Section 144. Colors and specifications for signs, aisle marking, tags, machine controls and other items are in Section 144 and 145. Section 147 covers the control of hazardous energy (lockout/ tagout) during the servicing and maintenance of machines and equipment. Subpart K contains requirements for first aid and consists of only three paragraphs. The first paragraph requires the ready availability of medical consultation on worker health. The second paragraph Introduction to OSHA Standards Page 6
requires first aid trained personnel when the company is not geographically close to a hospital. The third paragraph requires eye washes and deluge showers to be in the work area where employees might be exposed to injurious corrosive materials. Subpart M, "Compressed Gas and Compressed Air Equipment" sets forth the basic requirements for air receivers in Section 169. These include such things as an indicating gauge, a safety valve, and a drainpipe and valve. Subpart N is titled "Materials Handling and Storage." Section 176 discusses general storage requirements. Section 178 covers powered industrial trucks used to transport, load, unload and stack these materials. Other materials handling devices such as overhead cranes, derricks and helicopters are also covered in sections 179 through 183. Sling standards are delineated in Section 184. Subparts O and P go together. Basically, Subpart O contains the guarding requirements for larger pieces of machinery. Subpart P then contains guarding requirements for hand-held portable power tools. If you wanted to know the guarding requirements for a mechanical power press, you would use Subpart O Section 217. If you wanted to know the requirements for a hand-held circular saw, you would use Subpart P, Section 242. Subpart Q is a specific standard on welding, cutting and brazing. Any welding operation should meet these standards. Specific types of operations covered by this standard include oxygen-fuel gas, arc, and resistance welding. Subpart R contains specific industry standards or "vertical" standards as we discussed earlier. For example, if a company's main business were in pulpwood logging, any hazards noted in those operations should be referenced to the vertical standard. If there were not standard coverage in Subpart R, you could use the general standards in the subparts we have just discussed. Subpart S is the electrical standard. These are among the most frequently cited general industry standards. This would indicate that a common need for all of us to zero in on electrical hazards in the workplace. Paragraph Numbering System We have now become familiar with some of the basic organization of the general industry standards. Let's review some of the Introduction to OSHA Standards Page 7
terminology we have discussed and relate it to the paragraph numbering system in the Federal Register. We'll use an example from Section 110 of the 1910 standards. 29 CFR 1910.110(b)(13)(ii) (b)(7)(iii) Portable containers shall not be taken into buildings except as provided in paragraph (b)(6)(i) of this section. Title Code of Fed. Reg Part Section 29 CFR 1910.110 As you can see from this example, the first number 29 stands for the title. Next we have CFR which of course stands for Code of Federal Regulations. Next we have 1910 which is Part 1910. Next you see a period. Following that is an Arabic number which will always be the section number, in this case Section 110 for storage and handling of liquefied petroleum gases. If the number were 95, you would always relate it to the noise standard. Section 106 relates to flammable and combustible liquids. 29 CFR 1910.110(b)(13)(ii) (b)(7)(iii) Portable containers shall not be taken into buildings except as provided in paragraph (b)(6)(i) of this section. Title Code of Fed. Reg Part Section 29 CFR 1910.110 (b) Lower Case Alphabetical Introduction to OSHA Standards Page 8
Now, let's go to the next breakdown of paragraphs and study the numbering system. As you can see, the first tier of paragraphs beneath the section level ill be numbered in parentheses (a), (b), (c), (d), etc. as will all further designations, so that if you only had three major paragraphs of information under a section, they would be numbered 110(a), 110(b), 110(c). 29 CFR 1910.110(b)(13)(ii) (b)(7)(iii) Portable containers shall not be taken into buildings except as provided in paragraph (b)(6)(i) of this section. Title Code of Fed. Reg Part Section 29 CFR 1910.110 (b) (13) Lower Case Alphabetical Arabic Number The next level of numbering involves the use of Arabic number. As an illustration, if there were three paragraphs of information between subheadings (a) and (b), they would be numbered (a)(1), (a)(2), and (a)(3). Introduction to OSHA Standards Page 9
29 CFR 1910.110(b)(13)(ii) (b)(7)(iii) Portable containers shall not be taken into buildings except as provided in paragraph (b)(6)(i) of this section. Title Code of Fed. Reg Part Section 29 CFR 1910.110 (b) (13) (ii) Lower Case Alphabetical Arabic Number Lowercase Roman The next level uses the lowercase roman numeral. An example would be between paragraphs (2) and (3). If there were five paragraphs of information pertaining to Arabic (2) they would be numbered (2)(I), (2)(ii), (2)(iii), (2)(iv), and (2)(v). Fortunately, the system complexity ends because e will take the first three paragraph numbering sequences that you have noted and merely repeat them, only we will italicize them. This means that all you have to really know is the basic sequence from the section level; that is, the first digit will always be a lower case alpha, the second digit will always be an Arabic number, and the third digit will always be a lower case roman numeral It should be mentioned that standards promulgated after 1979 may be identified as follows: 1910.304(f)(5)(iv)((F)(1). A capital letter is used instead of an italicized one in the fourth set of parenthesis. Color Coding To simplify the use of the standards it is suggested to color-code your standards book. There are many ways to do this and you need to select one that works for you. Your instructor will lead you through an exercise to provide an example of this technique. Introduction to OSHA Standards Page 10
In summation, you are now prepared to color code those particular sections of the standards that you use frequently. It should also be pointed out that there is a subject index in the back of the standards book. This index can be very helpful to locate specific standards when you pick out a key word from any given hazard description. The following activity will assist you in using the index. Hazard/Violation Search Description of Hazard Standard 1. Some locations in warehouse where directions of travel to exit are not apparent. 2. No energy control (lockout/ tagout) procedure. 3. Carbon dioxide extinguishing system not being inspected annually. 4. Exit door blocked from outside. 5. Ten inch vertical clearance between sprinklers and material below.. 6. Fire extinguishers obstructed. 7. No eyewash facility in battery charging area - battery acid being used. 8. Employer did not assess the workplace to determine the need for PPE. 9. Respirators required -no training program for users. 10. Tennis shoes being worn by employees loading concrete blocks on pallets. 11. Acid dip tank operation -with quick drench or flushing capability for body or eyes. 12. No eye protection being worn by employees in metal plating area, exposing them to splashing chemicals. Introduction to OSHA Standards Page 11
Description of Hazard Standard 13. Unapproved containers being used for storage of flammable liquids. 14. Paint spray booth with electric motor and fan located inside exhaust duct. 15. End attachments on a wire rope sling are cracked and deformed. 16. Welding operation being done inside paint spray booth. 17. 150 gallons of Class I liquid stored in a flammable liquid storage cabinet. 18. Forklift operator giving a ride to two personnel on a standard pallet mounted on forks. 19. The face velocity on a dry-filter spray booth was less than 50 linear feet per minute. 20. Containers used to transfer flammable liquids were not bonded to the dispensing drum. 21. Employee was exposed to 300 ppm-twa of 22. Stairway has six risers and no handrail. 23. Open sided floor -six foot drop -no guardrails. 24. Fixed ladder -30 feet high with no cage guard. 25. Open-sided work platform (less than 4 ft. high) adjacent to dangerous equipment, not guarded with standard railing and toeboard. 26. Portable dockboard without any securing device to prevent slipping. Introduction to OSHA Standards Page 12
Description of Hazard Standard 27. Compressed gas cylinders in storage with no valve protection caps. 28. Oxygen and fuel gas stored together. 29. The entire length of two parallel oxygen and acetylene hoses is wrapped with tape. 30. Welding electrode cable lead damaged and frayed, exposing bare wire. 31. A loose conduit is feeding into a box. 32. Hazardous chemicals leaving the workplace not properly labeled. 33. Hand-held portable electric grinder with no guard. 34. Hand-held electric circular saw equipped with. 35. Hand-held circular saw being used with no lower blade guard. 36. Material safety data sheets for each hazardous chemical not readily accessible to employees 37. Radial arm saw has lower portion of blade unguarded. 38. Bench mounted grinder has 1h inch space between wheel and work rest. 39. No guarding provided to protect employees from flying chips of a metal turning lathe. 40. Distance between wheel periphery and adjustable tongue on bench mounted grinder was 3 / 8 inch. Introduction to OSHA Standards Page 13