Compliance with Occupational and Safety Health ...



1.IntroductionEmployees at a Household Hazardous Waste (HHW) Facility may be exposed to hazards during their normal job responsibilities. Hazards may include chemical exposure, ergonomic hazards, hearing impairment, and equipment usage hazards.HHW Programs shall comply with Occupational Safety & Health Administration (OSHA) regulations to provide a safe and healthy workplace and to identify, analyze and control hazards. With respect to OSHA regulations, the Minnesota Pollution Control Agency (MPCA) is not responsible for educating staff, providing training or materials, or auditing HHW programs to determine compliance with OSHA regulations. The MPCA may provide input during facility site visits and may organize OSHA related training events for HHW Staff. However, it is solely the responsibility of the employer(s) of staff at an HHW facility to ensure staff compliance with OSHA training requirements and regulations. [[Delete if not applicable and verify wording with your safety officer: If your county contracts with an entity for site staffing, it is the contractor’s responsibility to ensure staff are trained and comply with OSHA regulations. While on site, contracted staff shall comply with the County’s site specific safety plans and SOPs.]]This SOP is for informational purposes only and explains the basic employer requirements under OSHA, while the actual regulatory requirements and plans required by OSHA must be provided by [[your county, name who S&H staff, HR, etc]].The North American Industry Classification System (NAICS) is the standard used by Federal agencies to classify business establishments for various purposes. One of the purposes is to indicate which OSHA regulations apply to a specific business type or NAICS code. The NAICS code for a HHW facility is 562211, Hazardous Waste Treatment and Disposal. The following codes, as well as others, may also apply to HHW programs:562111Solid waste collection 562112Hazardous waste collection 562119Other waste collection562212Solid waste landfill 562213Solid waste combustors and incinerators 562219Other nonhazardous waste treatment and disposal 562910Remediation services and materials recovery facilities2.OSHA Safety Communication ProgramsA.Workplace and Accident and Injury Reduction Program (AWAIR) Employers with certain NAICS codes are required to create and implement a comprehensive written safety and health program called "A Workplace Accident and Injury Reduction" (AWAIR) program. HHW Programs are required to develop and implement an AWAIR Program in consultation with a safety officer, consultant or other entity responsible for implementation of OSHA regulations for countyoperations and facilities. This Program’s designated safety official who is responsible for clearlycommunicating work-related hazards to Program staff and to ensure safety and compliance with OSHA regulations is [list staff person here]. This Program’s AWAIR Program is available here: [[insert how county and contracted staff can find the County’s AWAIR Program].B.Employee Right to Know Employers have a responsibility to provide a safe workplace in accordance with OSHA’s Right to Know (RTK) regulations. See Employer responsibility for more information. This Program’s Employee Right to Know program is located [[here: ]]This is a short summary of key employer responsibilities [[delete the list if you just want to reference your RTK Program]]:Provide a workplace free from serious recognized hazards and comply with standards, rules and regulations issued under the OSH Act.Examine workplace conditions to make sure they conform to applicable OSHA standards.Make sure employees have and use safe tools and equipment and properly maintain this equipment.Use color codes, posters, labels or signs to warn employees of potential hazards. Establish or update operating procedures and communicate them so that employees follow safety and health requirements.Employers must provide safety training in a language and vocabulary workers can understand. Employers with hazardous chemicals in the workplace must develop and implement a written hazard communication program and train employees on the hazards exposed to and proper precautions (and a copy of safety data sheets must be readily available). See the OSHA page on Hazard Communication. Provide medical monitoring and training when required by OSHA Standards. Keep records of work-related injuries and illnesses.Not discriminate against employees who exercise their rights under the Act.C.Health and safety policy Employers involved with processing, treating, storing or disposal of hazardous waste must have implemented a written, site-specific safety and health policy for their employees. This detailed safety information establishes a commitment to protection of health and requires all facility staff to: Receive function-specific trainingReceive safety information to identify and analyze potential hazardsDemonstrate control on new or existing hazards, conditions, and mon OSHA-cited HHW Facility violationsAvoid these common OSHA violations (listed most frequently cited to least), including failure to implement written OSHA Training Requirements for:Hazard CommunicationFall Protection Respiratory Protection PlanPPE UsageBlood-Borne PathogensFire Prevention4.ResourcesMinnesota State Duty Officer - 800-422-0798 – For chemical or radioactive emergency spillsMN Bomb Squad – To safely detonate and manage reactive chemicals or explosive materials, immediately contact the MN Duty Officer or your local law enforcement agency who will then contact the bomb squad; they will immediately assist and are free of charge.MN OSHA- 651-284-5050 or 877-470-6742 - Federal OSHA RegulationsMinnesota Pollution Control Agency: 800 657-3864MPCA HHW Information NIOSH Pocket GuideNational Weather Service Wind Chill ChartOSHA Permissible Exposure LimitsProper Ergonomics and Heat StressSafety Data SheetsTOX NET: Toxicology Data Network ................
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