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New York State Department of Labor
Public Employee Safety and Health (PESH
PESH/ OSHA Standards
Questions and Answers for Fire & EMS Services
Hazardous Materials Emergency Response 1910.120
Q – 1. What level of training does the Hazardous Materials Emergency Response Standard require fire fighters to receive?
A – Most PESH and OSHA standards require training based on the job duties members are required to perform. PESH interpretation of 1910.120(q) requires first responders to receive initial and annual refresher training based on the role their employer has assigned to them within the employer’s written plan. For example fire police are expected to respond to a potential HAZMAT incident and help secure the scene by directing traffic and or pedestrians. The standard requires fire police to receive and maintain their Awareness Level certification at least annually. Active fire fighters are expected to respond to a potential HAZMAT incident defensively by establishing safe distances, ensuring site security and by performing other duties. The standard requires all active fire fighters to receive and maintain their Operations Level certification at least annually. 1910.120(q)(8)(i) states “Those employees who are trained in accordance with paragraph (q)(6) of this section shall receive annual refresher training of sufficient content and duration to maintain their competencies, or shall demonstrate competency in those areas at least yearly. The standard does not indicate a minimum number of hours of refresher training. Depending on other duties, including responding offensively or as the Incident Commander the standard requires additional training.
Q – 2. Does the standard require certifications or a specific educational background to train fire fighters on their initial and annual refresher requirements?
A- 1910.120(q)(7 requires that instructors providing training in any of the topics listed in paragraph (q) of 1910.120 shall have successfully completed an instructor training program for the subject matter they are expected to teach, such as training offered by the NYS Office of Fire Prevention and Control or the National Fire Academy, or “shall have the training and./or academic credentials and instructional experience necessary to demonstrate competent instructional skills and a good command of the subject matter of the courses they are too teach.
Q – 3. Does the standard describe who is to be in charge of an emergency response?
A - 1910.120(q)(3) specifies: “The senior emergency response official responding to an emergency shall become the individual in charge of a site-specific Incident Command System (ICS). All emergency responders and their communications shall be coordinated and controlled through the individual in charge of the ICS assisted by the senior official present for each employer”.
Additionally, paragraph (q)(3)(vii) requires the incident commander to designate a safety officer knowledgeable in the operations being conducted to be specifically responsible to identify and evaluate hazards, provide direction with respect to the safety of those operations and suspend or terminate activities when an imminent danger situation may be present.
1910.120(q)(6)(v) requires that an on scene incident commander responsible for operations beyond the awareness level shall have training to the Hazardous Materials First Responder Operations level and competency in areas including the following: implementation of the incident command system and their hazardous materials emergency response plan, knowledge of the hazards and risks associated with personnel operating in chemical protective clothing, and knowledge of the importance of decontamination procedures.
RESPIRATORY PROTECTION 1910.134
Q – 1. Why is a written respiratory protection plan required by the standard?
A – A respirator program helps to ensure that respirators are used and maintained within the limits of their design and intended application. A respirator will only protect if it is correctly used and maintained. The standard also requires a number of written elements within all respirator programs.
Q – 2. Who is in charge of the respirator program?
A - The program must be administered by a trained program administrator who is qualified and knowledgeable in respiratory protection to run all aspects of the program.
Q – 3. When does the standard require respirators to be worn?
A. Whenever it is necessary to protect the health of the employee from contaminated or oxygen deficient air. This includes situations where respirators are necessary to protect employees in an emergency and in unclassified or unknown atmospheres.
Q – 4. Why is a formal respirator program needed?
A: The employer must establish and implement a written respiratory protection program with specific worksite procedures and elements for required respirator use. The provisions of the program include procedures for selection, medical evaluation, fit testing, training, use and care of respirators. Employees who are required to wear a respirator must be trained and competent within these provisions of the program.
Q – 5. When is respirator fit testing required?
A: Fit testing is required prior to initial use, whenever a different respirator face piece is used, and at least annually thereafter. An additional fit test is required whenever there are changes in the user’s physical condition that could affect respirator fit (e.g., facial scarring, dental changes, cosmetic surgery, or an obvious change in body weight). The employer must be fit tested with the same make, model, style, and size of respirator that will be used.
Q – 6. Must employees see a doctor before they use a respirator?
A – 1910.134(e) requires the employer to provide a medical evaluation to determine the employee’s ability to use a respirator (at no cost to the employee). Before any employee is fit tested or required to use the respirator in the workplace the employee must be evaluated by a physician or licensed health care professional (PLHCP). In New York, the licensed health care professional can be a physician assistant (PA) or a nurse practitioner (NP).
1910.134(e)(2)(i) states “The employer shall identify a physician or other licensed health care professional (PLHCP) to perform the medical evaluations using a medical questionnaire or an initial medical examination that obtains the same information as the medical questionnaire.” The standard provides a copy of the medical questionnaire in Appendix C of 29 CFR 1910.134; the PLHCP can use either method to make the determination.
Q – 7. Are fire districts or departments required to provide and pay for lens inserts and prescriptive lenses for SCBA face-pieces?
A - Prescription eyewear inserts/lenses for full face respirators are considered specialty eyewear when used to comply with an OSHA standard.
Table V-2 “Examples of PPE for Which Employer Payment is Required” has Prescriptive eyewear inserts and lenses for full face respirators listed as an example of personal protective equipment required to be paid for by the employer. The link below is to the Federal Register dated November 15, 2007 that clarifies “Employer Payment for Personal Protective Equipment”
Q – 8. Can a fire fighter refuse to be fit tested and still conduct his duties as an active fire fighter?
A - The Respiratory Protection Standard 1910.134(f)(2) refers to the fit test being a requirement prior to performing the job duties where respirator use is required by the employer, this part also requires the fit testing to be performed at least annually. Prior to any employee donning a respirator for training, fit testing or other purposes they must successfully complete a medical evaluation by a physician or licensed health care professional PLHCP. If a fire fighter refuses to take an annual fit test, they will be unable to perform any operations that may require respirator use.
Q – 9. Can a fire department utilize a compressed air cylinder from a different manufacturer during SCBA use?
A - Two of OSHA's standards [1910.156(f)(1)(iv) and 1910.120(q)(3)(x)] do permit the use of other manufacturer's cylinders on self-contained breathing apparatuses (SCBA's), when deemed necessary to meet the tasks at hand. The standards state that “Approved self-contained compressed air breathing apparatus may be used with approved cylinders from other approved self-contained compressed air breathing apparatus provided that such cylinders are of the same capacity and pressure rating. All compressed air cylinders used with self-contained breathing apparatus shall meet DOT and NIOSH criteria.” Although this temporarily voids NIOSH approval, PESH believes that the interchangeability of air cylinders is important enough to the life safety of fire brigade members to permit it.
In non-emergency situations, PESH strongly encourages SCBA's to be maintained and used in their approved condition. SCBA’s using other manufacturer’s cylinders meeting the above criteria would be considered a “De Minimis” violation. A condition is considered to be “De Minimis” when it has no direct or immediate relationship to employee safety and health or when it is apparent that the employer is complying with the clear intent of the standard but deviates in a minor, technical, or trivial way. A written notice of violation would not be issued by PESH for a “De Minimis” violation.
Q – 10. Can a fire fighter use the results from their work medical evaluation for the fire service or EMS?
A - The PESH/ OSHA standards do not address how the results of the medical determination can be shared with other employers. There may be some reluctance for an employer to accept a medical determination when the specifics regarding their employees job duties, PPE use and respirators were not considered by the physician or licensed health care professional (PLHCP). Prior to the employee's physical, the employer is required to provide the background information addressed by 1910.134(e)(5)-Supplemental information for the PLHCP. This information helps to provide the PLHCP with a better understanding of the environmental stresses the employee experiences when performing their job duties.
• The information required to help the PLHCP make the medical determination:
• The type and respirator to be used by the employee
• The duration and frequency of respirator use (including use for rescue and escape)
• The expected physical work effort
• Additional protective clothing and equipment to be worn
• Temperature and humidity extremes that may be encountered
• A copy of the written Respiratory Protection Plan
• A copy of 1910.134(e)
The employer is ultimately responsible for ensuring that employees are properly trained, use the correct PPE and are physically capable of performing the task prior to job assignment. An employer would be making the right decision by not accepting a medical determination when they did not provide the information required by 1910.134(e)(5).
Q – 11. Does the standard cover biological hazards?
A - The standard applies to most biological hazards such as Histoplasma capsulatum spores (bird droppings) and Blood borne pathogens) with the exception of Mycobacterium tuberculosis (TB). PESH will continue to enforce respirator use for TB under the previous respirator standard that has been redesigned 29 CFR 1910.139.
Q – 12. When is the employer required to provide engineering controls?
A - This standard does not make any changes to the longstanding hierarchy of controls which requires employers to use engineering and work practice controls where feasible. Only if such controls are not feasible or while they are being implemented may an employer rely on a respirator to protect employees. For example after an interior fire has been extinguished, firefighters will generally open up the walls and ceilings to prevent re ignition. Studies have proven that partially burnt materials inside the structure continue to off gas and the interior’s environment can contain a hazardous atmosphere above the PESH permissible exposure limit. Prior to allowing fighters to remove their SCBA’s while inside the structure, atmospheric monitoring must conditions are safe. Engineering controls such as smoke exhaust fans may help clear contaminants and maintain acceptable levels during continuous monitoring.
Q – 13. Will PESH require respirators to be worn for chemicals that do not have Permissible Exposure Limits (PEL)?
A - PESH requires respirators to be worn whenever such equipment is necessary to protect the health of employees. If an exposure to an airborne contaminant, that does not have a permissible exposure limit (PEL), could result in serious illness or injury, the general duty clause could be cited in accordance with the provisions in the PESH FOM Field Operations Manual, which can be viewed at:
The PESH PEL’s can be viewed at the following website:
Q – 14. Can a fit test for a respirator be performed before the initial medical evaluation has been completed?
A – No 1910.134e(1) states the initial medical evaluation must be conducted prior to fit testing to identify individuals whose health may be harmed by the limited amount of respirator use associated with fit testing.
Q – 15. Are employees who use filtering face piece respirators (dust masks) voluntarily (e.g., for employee comfort) also required to have medical evaluations?
A - No. If the employer has determined that there is no hazard, and dust mask use is
voluntary, then no medical evaluation is required. If employers allow voluntary use of this type of respirator, then they must provide the employee the information contained in Appendix D of the standard, and ensure that such respirator use will not itself create a hazard.
Q – 16. Does the employer have to medically reevaluate the employee’s ability to wear a respirator on an annual basis?
A - No. There is no annual or periodic requirement for medical reevaluation. The standard lists four conditions that trigger medical reevaluation: an employee reports signs or symptoms related to the ability to wear a respirator; the PLHCP, administrator or supervisor determine it is necessary; information from the respiratory protection program indicates a need for reevaluation; or a change in workplace conditions substantially increases the physiological burden placed on the employee. The PLHCP is a licensed professional; as long as the PLHCP receives the supplemental information required by the standard they are free to use their judgment regarding a follow up physical.
Q – 17. Which respirator use requires fit testing?
A - Fit testing is required when PESH or the employer requires employees to wear tightfitting respirators. The employee must pass a fit test prior to the initial use of the
respirator. Additional fit tests are required annually and whenever the employee reports, or the employer, PLHCP, Supervisor or Program Administrator observes changes in the employee’s physical condition that could affect respirator fit. If the employee changes to a different fitting facepiece a new fit test is required. An annual fit test is required after the initial fit test.
Q – 18. Our fire department receives calls that require SCBA use very infrequently. Is there a frequency of use below which fit testing would not be required for SCBA’s?
A - The standard’s requirement of annual fit testing applies to emergency response
personnel who wear respirators to protect against hazardous atmospheres. Proper fit is especially necessary for emergency personnel. These people may only wear the equipment infrequently, but when they do use the equipment, they often use it in very dangerous atmospheres.
Q – 19. Can an employee wear a tight-fitting respirator with a beard or other facial hair?
A – No 1910.134(g(1)(i)(A) states when respirators are required, an employer is prohibited from allowing respirators with tight-fitting facepieces to be worn by employees who have "facial hair that comes between the sealing surface of the facepiece and the face or that interferes with valve function.”
Q – 20. Can corrective glasses, goggles, or other personal protective equipment be used with tight-fitting respirators?
A -The standard is written in performance terms so that any particular piece of equipment may be used as long as it does not interfere with the facepiece seal. Corrective glasses or goggles or other personal protective equipment can be used with tight-fitting respirators, but employers must ensure that they are worn in a manner that does not interfere with the seal of the facepiece to the face of the user. Eyeglass inserts or spectacle kits are acceptable if the devices: (1) do not interfere with the facepiece seal; (2) do not cause any distortion of vision; and (3) do not cause any physical harm to the wearer during use.
Q – 21. May employees wear contact lenses with respirators?
A - Contact lenses may be used with respirators. Employers who have employees who wear corrective eyewear must be sure that the respirator does not interfere with the eyewear, make it uncomfortable, or force the employee to remove the eyewear. Employers should use the respirator selection process to make accommodations to ensure that their respirator-wearing employees can see properly when wearing these devices.
Q – 22. Who must comply with “two-in, two-out”?
A - The PESH adopted Respiratory Protection Standard applies directly to all public volunteer and paid fire brigades engaged in firefighting. This interpretation does not however prevent a fire fighter from performing lifesaving duties without the required number of properly equipped personnel
Q – 23. What is the difference between incipient stage firefighting and interior structural firefighting? How can one tell when the” two-in, two-out” requirement takes effect?
A - OSHA standard 29 CFR 1910.155(c)(26) defines “incipient stage” as: “a fire which is in the initial or beginning stage and which can be controlled or extinguished by portable fire extinguishers, Class II standpipe or small hose systems without the need for protective clothing or breathing apparatus.”
Interior structural firefighting is firefighting to control or extinguish a fire in an advanced stage of burning inside a building. The “two-in, two-out” requirement does not take effect until firefighters begin to perform interior structural firefighting. Because the fire is producing large amounts of smoke, heat and toxic products of combustion, exposure of firefighters is extremely hazardous and is considered an “immediately dangerous to life or health” (IDLH) environment.
Q – 24. If firefighters utilize respiratory protection, does that mean that an Immediately Dangerous to Life or Health (IDLH) atmosphere exists, and that “two-in, two-out” applies?
A - Not necessarily. Respiratory protection and “two-in, two-out” are required in all
interior structural firefighting situations. Interior structural fires are considered to
be IDLH atmospheres. However, the use of respiratory protection does not, by itself,
invoke the requirements associated with an IDLH atmosphere. The use of a self-contained breathing apparatus could be unrelated to exposure to an IDLH atmosphere associated with an interior structural fire. For example, during overhaul there may be an opportunity for an overexposure to a PESH PEL but not necessarily an IDLH atmosphere were two-in, two-out would apply. Only when firefighters are engaged in interior structural firefighting that the use of respirators is mandatory and the “two-in, two-out” requirement applies.
Q – 25. What would constitute an "appropriately trained" person who is responsible for performing repairs or adjustments to respirators?
A -The use of the term ‘appropriately trained’ refers to an individual who has received
training from the manufacturer or otherwise has demonstrated that he/she has the skills to return the respirator to its original state of effectiveness.
Q – 26. What are the minimum specifications for Grade D breathing air?
A - The ANSI/CGA G.7-1 - 1989 specifies the contents of Grade D breathing air as: oxygen (volume/volume) of 19.5 to 23.5 %; hydrocarbon (condensed) of 5 mg/m³ of air or less; carbon monoxide of 10 parts per million (ppm) or less; carbon dioxide of 1,000 ppm or less; and a lack of a noticeable odor.
Q – 27. What regulations apply to the handling, testing, and storage of cylinders used to supply breathing air to respirators?
A - Cylinders must be constructed, tested and maintained in accordance with the Shipping Container Specification Regulations of the Department of Transportation (DOT) 49 CFR Parts 173 and 178. These regulations are also required for NIOSH certification. The implant handling and storage of compressed gas cylinders must be in accordance with 29 CFR 1910.101(b) which incorporates by reference CGA Pamphlet P-1-1965.
Fire Brigade Standard 1910.156
Q – 1. Why do volunteer fire fighter’s need to comply with 1910.156 the Fire Brigade Standard and what gives the state the authority to enforce this regulation?
A – New York State Department of Labor became a State Plan State by adopting and enforcing the OSHA regulations to public employees.
Section 1910.156(a)(2) states that the Fire Brigades standard applies to “fire brigades, industrial fire departments and private or contractual type fire brigades.” New York State has interpreted that volunteer and in some cases municipal paid fire fighters are public employees. Members of a Fire District, Fire Protection District and municipal departments fall within the jurisdiction of PESH when the workers compensation policy has been directly or indirectly paid for by tax payers’ dollars.
Q – 2. What written plans are required by the Fire Brigade Standard?
A – 1910.156 requires the employer do develop and maintain an Organizational Statement that describes “ the basic organizational structure of the brigade, the type amount and frequency of training to be provided to fire brigade members; the expected number of members in the fire brigade; and the functions that the fire brigade is to perform.”
Additional plans and programs – such as a written respiratory protection program – may be required by other PESH standards based on the specific tasks being performed.
Q – 3. Are all fire fighters required to receive the same basic fire ground training?
A - The training requirements for fire brigade members would be based on the job duties that the member is expected to perform. If the member is an active member of a fire brigade the 15 hr initial training is required and a 8 hr annual refresher training is required thereafter. All active fire fighters are expected to administer first aid and may have opportunity for exposure to blood or other potentially infectious body fluids, annual training under 29 CRF 1910.1030 would apply as well. If the member is on the truck responding to a potential HAZMAT incident they must be trained to the Operations Level as described in 29 CFR 1910.120(q)(6)(ii). Copies of these standards can be viewed online at:
Q – 4. Is the employer (fire department) responsible for ensuring their employees are physically capable of performing the work task assigned to them?
A - 1910.156(b)(2) specifically states that the employer shall not allow members with known heart disease, epilepsy, or emphysema, to participate in any fire brigade emergency activities unless a physician provides a certificate stating the specific duties the member is physically capable of performing.
Q –5. What are the New York State training requirements for volunteer fire fighters?
The annual training requirement for fire fighters is addressed under 29 CFR 1910.156 (c)(1) through 156(c)(4). This describes who will be trained, when they will be trained and how they will be trained. The interpretation of these standards and how they would apply to fire brigades covered by the PESH jurisdiction was completed on August 14, 1985 in a meeting with former Assistant Director of Safety and Health, Stuart Schrank and various representatives from the fire fighter association within New York State. In a letter dated September 14, 1985, written by Assistant Director Schrank, the training requirements for fire brigades are described in detail. To summarize the number of hours required for fire brigade training is 8 hours annually under the refresher requirement and a minimum of 15 hours for new members of the fire brigade.
The letter provides guidelines for general training topics and possible length of time or subjects within the topics. Depending on the types of work tasks described within the Organizational Statement, tasks assigned to members and the environment in which they will be performed, the Chief should decide the appropriate time and topics for his membership. Suggested topics discussed with the letter include:
• General Hazard Recognition
• Fire Station Safety
• Response Safety
• Fire or Emergency Scene Safety
• Protective Clothing
• SCBA
• Tools and Equipment Safety
• Recent Developments in Fire Safety
Please note that other PESH standards will have additional training requirements beyond the requirements of the Fire Brigade standard, for example: Blood Bourne Pathogens, Hazard Communication and Right to Know, Workplace Violence Prevention, Respiratory Protection, hazardous Materials Emergency Response, etc.
Q – 6. Does 1910.156 Fire brigades, specifically require Company Captains and Fire Chiefs to be trained to a higher level than the training that the general membership receives?
A - Company Captains and Fire Chiefs do need to be trained to a higher level than the general membership, as stated in 1910.156(c)(1).
1910.156(c)(3) addresses “quality of training” where New York State Office of Fire Protection and Control’s training program is specifically referenced. With NYS OFPC the classes that would help trainers reach this higher level of competency would include Fire Officer 1 and 2 and Fire Chief’s training.
A copy of the Fire Brigade Standard can be found at:
Viewing 1910.156(c)(3) on line by using the web link above, will provide you with the hyperlink to a OSHA Letter of Interpretation that discussed the training level for fire brigade instructors as being “minimal and generalized”, the standard does not have different levels of instructor certification as stated in National Fire Protection Agency (NFPA) 1401.
Q – 7. Who is responsible for purchase cost and ensuring fire fighters protective equipment is properly maintained?
A – 1910.156(e) applies to turn out gear for interior structural fire fighters. The standard requires the employer to cover all cost of purchasing and maintaining a full set of turn out gear. The member who is assigned interior structural firefighting duties shall be provided a full set of turn out gear that complies with the requirements of this section. The equipment must fit properly and be maintained as per the manufacturers written recommendations. Prior to assigning a work tasks, the employer shall assess that the member has the required protective equipment to safely perform the task, prior to the start of work.
Bloodborne Pathogens 1910.1030
Q – 1. Who is covered by the standard?
A - The standard applies to all public employees who have occupational exposure to blood or other potentially infectious materials (OPIM).
Occupational exposure is defined as reasonably anticipated skin, eye, mucous membrane, or parenteral contact with blood or other potentially infectious materials that may result from the performance of an employee's duties.
Blood is defined as human blood, human blood components, and products made from human blood.
Other potentially infectious materials is defined as the following: saliva in dental procedures; semen; vaginal secretions; cerebrospinal, synovial, pleural, pericardial, peritoneal, and amniotic fluids; body fluids visibly contaminated with blood; along with all body fluids in situations where it is difficult or impossible to differentiate between body fluids; unfixed human tissues or organs (other than intact skin); HIV-containing cell or tissue cultures, organ cultures, and HIV- or HBV-containing culture media or other solutions; and blood, organs, or other tissues from experimental animals infected with HIV or HBV.
Exposure determinations are made without regard to the use of personal protective equipment, this is discussed in section 1910.1030(c)(2)(ii).
Q – 2. Are firefighters and EMS technicians covered by the standard?
A - Yes. Due to their expected job duties (rescue and administering first aid) fire fighters and EMS are considered to have occupational exposure and are covered by the protections of the standard.
Q – 3. Are employees such as housekeepers, maintenance workers and janitors covered by the standard?
A - The employer is responsible for making a exposure determination based on the duties in which the employee is expected to perform. Housekeeping workers in nursing homes, healthcare facilities, prisons and schools may have occupational exposure, as defined by the standard. Individuals who perform housekeeping duties, particularly in patient care and laboratory areas, may perform tasks, such as cleaning blood spills and handling regulated wastes, which cause occupational exposure.
Q – 4. What is an Exposure Control Plan?
A -The exposure control plan is the employer's written program that outlines the protective measures an employer will take to eliminate or minimize employee exposure to blood and other potentially infectious body fluids (OPIM).
The standard defines the minimum content the written exposure control plan must contain, at a minimum:
The exposure determination identifies all job classifications with occupational exposure and the work tasks or procedures where there is occupational exposure.
The procedures for evaluating the circumstances surrounding exposure incidents;
A schedule of how other provisions of the standard are implemented, including methods of compliance, HIV and HBV research laboratories and production facilities requirements, hepatitis B vaccination and post-exposure evaluation and follow-up, communication of hazards to employees, and recordkeeping;
• Methods of compliance include:
• Universal Precautions
• Engineering and work practice controls, e.g., safer medical devices, sharps disposal containers, hand hygiene;
• Personal protective equipment;
• Housekeeping, including decontamination procedures and removal of regulated waste.
Documentation of:
• The annual consideration and implementation of appropriate commercially available and effective safer medical devices designed to eliminate or minimize occupational exposure, and
• the solicitation of non-managerial healthcare workers (who are responsible for direct patient care and are potentially exposed to injuries from contaminated sharps) in the identification, evaluation, and selection of effective engineering and work practice controls.
Q – 5. In the exposure control plan, are employers required to list specific tasks that place the employee at risk for all job classifications?
A - No. If all the employees within a specific job classification perform duties where occupational exposure occurs, then a list of specific tasks and procedures is not required for that job classification. However, the job classification (e.g., "nurse") must be listed in the plan's exposure determination, and all employees within the job classification must be included under the requirements of the standard.
Q – 6. How often must the exposure control plan be reviewed?
A - The standard requires an annual review of the exposure control plan. In addition, whenever changes in tasks, procedures, or employee positions affect, or create new occupational exposure, the existing plan must be reviewed and updated accordingly.
Q – 7. Must the exposure control plan be accessible to employees?
A -Yes, the exposure control plan must be accessible to employees, as well as to PESH representatives. The location of the plan may be adapted to the circumstances of a particular workplace, provided that employees can access a copy at the workplace during the work shift. If the plan is maintained solely on computer, employees must be trained to operate the computer.
A hard copy of the exposure control plan must be provided within 15 working days of the employee's request in accord with 29 CFR 1910.1020(e).
Q – 8. What should be included in the evaluation of an exposure incident?
• A - Following an exposure incident, employers are required to document, at a minimum, the route(s) of exposure, and the circumstances under which the exposure incident occurred. To be useful, the documentation must contain sufficient detail about the incident. There should be information about the following:
• The source individual, unless the employer can establish that identification is infeasible or prohibited by state or local law.
• The engineering controls in use at the time and work practices followed;
• Description of the device in use;
• The protective equipment or clothing used at the time of the exposure incident;
• Location of the incident and procedures being performed when the incident occurred; and
• Employee’s training.
• The employer should then evaluate the policies and "failures of controls" at the time of the exposure incident to determine actions that could prevent future incidents.
Q – 9. What is meant by the term Universal Precautions?
A - Universal Precautions is the required method of control to protect employees from exposure to all human blood and other potentially infectious body fluids (OPIM). The term, "Universal Precautions," refers to a concept of bloodborne disease control which requires that all human blood and certain human body fluids be treated as if known to be infectious for HIV, HBV or other bloodborne pathogens.
Q – 10. Can Body Substance Isolation (BSI) be adopted in place of Universal Precautions?
A - Yes. Body Substance Isolation is a control method that defines all body fluids and substances as infectious. BSI incorporates not only the fluids and materials covered by the standard but expands coverage to include all body substances. BSI is an acceptable alternative to Universal Precautions, provided facilities utilizing BSI adhere to all other provisions of the standard.
Q – 11. What are engineering controls?
A - The term, "engineering controls," refers to controls (e.g., sharps disposal containers, self-sheathing needles, safer medical devices, such as sharps with engineered sharps injury protections and needleless systems) that isolate or remove the bloodborne pathogens hazard from the workplace.
Q – 12. What are some examples of safer devices or alternatives that could be used in lieu of exposed needles?
A - Some examples of such devices or alternatives include needleless systems, needle-protected systems, and "self-sheathing" needles.
Q – 13. Are employers required to provide these safer devices?
A - The standard requires that engineering and work practice controls be used to eliminate or minimize employee exposure. The Exposure Control Plan must document annual consideration and implementation of appropriate, commercially-available and effective engineering controls designed to eliminate or minimize exposure. The employer must solicit and document for this process input from non-managerial employees responsible for direct patient care who are potentially exposed to injuries from contaminated sharps.
Q – 14. Can employees of an ambulance medical rescue service eat or drink inside the cab of the unit?
A - Employees are allowed to eat and drink in an ambulance cab only if the employer has implemented procedures to permit employees to wash up and change contaminated clothing before entering the ambulance cab. To prevent a possible ingestion exposure, EMT’s should prevent any contaminated material from entering the cab, if there is any chance that blood or other potentially infectious body fluids (OPIM) is within the cab, eating and drinking would not be allowed. The standard prohibits the consumption, handling, storage, and transport of food and drink in the rear of the vehicle, and has procedures to ensure that patients and contaminated materials remain behind the separating partition.
Q – 15. What alternatives are acceptable if soap and running water are not available for hand washing?
A - Antiseptic hand cleansers in conjunction with clean cloth/paper towels or antiseptic towelettes are examples of acceptable alternatives to running water. However, when these types of alternatives are used, employees must wash their hands with soap and running water as soon as feasible. These alternatives are only acceptable at worksites where it infeasible to provide soap and running water.
Q – 16. Who is responsible for providing PPE?
A - The responsibility for providing, laundering, cleaning, repairing, replacing, and disposing of PPE at no cost to employees rests with the employer. Employers are not obligated under the standard to provide general work clothes to employees, but they are responsible for providing PPE. If laboratory jackets or uniforms are intended to protect the employee's body or clothing from contamination, they are to be provided at no cost by the employer.
Q – 17. Does protective clothing need to be removed before leaving the work area?
A - Yes. PESH requires that personal protective equipment be removed before leaving the work area. While "work area" must be determined on a case-by-case basis, a work area is generally considered to be an area where work involving occupational exposure occurs or where the contamination of surfaces may occur.
Q – 18. What type of eye protection do I need to wear when working with blood or other potentially infectious body fluids (OPIM)?
A - The use of eye protection would be based on the reasonable anticipation of facial exposure. Masks in combination with eye protection devices, such as glasses with solid side shields, goggles, or chin-length face shields, shall be worn whenever splashes, spray, spatter, or droplets of blood or other potentially infectious body fluids (OPIM) may be generated and eye, nose, or mouth contamination can be reasonably anticipated.
Q – 19. When should gloves be changed?
A - Disposable gloves shall be replaced as soon as practical after they have become contaminated, or as soon as feasible if they are torn, punctured, or their ability to function as a barrier is compromised. Hands must be washed after the removal of gloves used as PPE, whether or not the gloves are visibly contaminated.
Q – 20. Are gloves required when giving an injection?
A - Gloves are not required to be worn when giving an injection as long as hand contact with blood or other potentially infectious materials is not reasonably anticipated.
Q – 21. What does the standard mean by the term "regulated waste"?
A - The Bloodborne Pathogens standard uses the term, "regulated waste," to refer to the following categories of waste which require special handling: (1) liquid or semi-liquid blood or other potentially infectious body fluids (OPIM); (2) items contaminated with blood or OPIM and which would release these substances in a liquid or semi-liquid state if compressed; (3) items that are caked with dried blood or OPIM and are capable of releasing these materials during handling; (4) contaminated sharps; and (5) pathological and microbiological wastes containing blood or OPIM.
Q – 22. Are feminine hygiene products considered regulated waste?
A - These products generally are not considered medical waste when discarded into waste containers which are properly lined with plastic or wax paper bags. Such bags should protect the employees from physical contact with the contents.
At the same time, it is the employer's responsibility to determine the existence of regulated waste. This determination is not based on actual volume of blood, but rather on the potential to release blood (e.g., when compacted in a waste container).
Q – 23. How should sharps containers be handled?
A - Sharps containers shall be maintained upright throughout use, replaced routinely and not be allowed to overfill. When removing sharps containers from the area of use, the containers shall be:
• Closed immediately before removal or replacement to prevent spillage or protrusion of contents during handling, storage, transport, or shipping;
• Placed in a secondary container if leakage is possible. The second container shall be:
• Closable;
• Constructed to contain all contents and prevent leakage during handling, storage, transport, or shipping; and
Labeled or color-coded according to paragraph (g)(1)(i) of the standard, . Communication of Hazards to employees
o (i) Labels :
[A] Warning labels shall be affixed to containers of regulated waste, refrigerators and freezers containing blood or other potentially infectious material; and other containers used to store, transport or ship blood or other potentially infectious materials, except as provided in paragraph (g)(1)(i)(E), (F) and (G).
[B] Labels required by this section shall include the following legend:
[pic]
[C] These labels shall be fluorescent orange or orange-red or predominantly so, with lettering and symbols in a contrasting color.
[D] Labels shall be affixed as close as feasible to the container by string, wire, adhesive, or other method that prevents their loss or unintentional removal.
[E] Red bags or red containers may be substituted for labels.
[F] Containers of blood, blood components, or blood products that are labeled as to their contents and have been released for transfusion or other clinical use are exempted from the labeling requirements of paragraph (g).
[G] Individual containers of blood or other potentially infectious materials that are placed in a labeled container during storage, transport, shipment or disposal are exempted from the labeling requirement.
[H] Labels required for contaminated equipment shall be in accordance with this paragraph and shall also state which portions of the equipment remain contaminated.
[I] Regulated waste that has been decontaminated need not be labeled or color-coded.
o Signs 1910.1030(g)(1)(ii)
[A]The employer shall post signs at the entrance to work areas specified in paragraph (e), HIV and HBV Research Laboratory and Production Facilities, which shall bear the following legend:
[pic]
(Name of the Infectious Agent)
(Special requirements for entering the area)
(Name, telephone number of the laboratory director or other responsible person.)
[B] These signs shall be fluorescent orange-red or predominantly so, with lettering and symbols in a contrasting color.
Q – 24. How do I dispose of regulated waste?
A - Regulated waste shall be placed in containers which are:
• Closable;
• Constructed to contain all contents and prevent leakage of fluids during handling, storage, transport or shipping;
• Labeled or color-coded in accordance with paragraph (g)(1)(i) of the standard; and (see question 23 above); and
• Closed before removal to prevent spillage or protrusion of contents during handling, storage, transport, or shipping.
• If outside contamination of the regulated waste container occurs, it shall be placed in a second container. The second container shall be:
Disposal of all regulated waste shall be in accordance with applicable regulations of the New York State, and political subdivisions of the State and Territories.
Q – 25. What does the standard mean by the term "contaminated laundry"?
A - Contaminated laundry means laundry which has been soiled with blood or other potentially infectious materials or may contain sharps.
Q – 26. How should contaminated laundry be handled?
A - Contaminated laundry shall be handled as little as possible with a minimum of agitation. Contaminated laundry shall be bagged or containerized at the location where it was used and shall not be sorted or rinsed in the location of use, (g)(1)(i) (see question 24 above) of the standard describes other requirements.
• Contaminated laundry shall be placed and transported in bags or containers labeled or color-coded in accordance with paragraph (g)(1)(i) (see question 24 above) of the standard. When a facility utilizes Universal Precautions in the handling of all soiled laundry, alternative labeling or color-coding is sufficient if it permits all employees to recognize the containers as requiring compliance with Universal Precautions.
• Whenever contaminated laundry is wet and presents a reasonable likelihood of soak-through or leakage from the bag or container, the laundry shall be placed and transported in bags or containers which prevent soak-through and/or leakage of fluids to the exterior.
• The employer shall ensure that employees who have contact with contaminated laundry wear protective gloves and other appropriate personal protective equipment.
• When a facility ships contaminated laundry off-site to a second facility which does not utilize Universal Precautions in the handling of all laundry, the facility generating the contaminated laundry must place such laundry in bags or containers which are labeled or color-coded in accordance with paragraph (g)(1)(i) of the standard (see question 24 above).
Q – 27. Are employees allowed to take their protective equipment home and launder it?
A - Employees are not permitted to take their protective equipment home and launder it. It is the responsibility of the employer to provide, launder, clean, repair, replace, and dispose of personal protective equipment.
Q – 28. Do employers have to buy a washer and dryer to clean employees' personal protective equipment?
A - There standard does not require the employer to purchase a washer and dryer to launder protective clothing. The employer may contract out the laundering of protective clothing or possibly use disposable personal protective clothing and equipment.
Q – 29. Are there guidelines to be followed when laundering personal protective equipment? What water temperature and detergent types are acceptable?
A - The decontamination and laundering of protective clothing are governed by the laundry provisions of the standard in paragraph (d)(4)(iv) below:
(iv) Laundry.
[A] Contaminated laundry shall be handled as little as possible with a minimum of agitation.
[1] Contaminated laundry shall be bagged or containerized at the location where it was used and shall not be sorted or rinsed in the location of use.
[2] Contaminated laundry shall be placed and transported in bags or containers labeled or color-coded in accordance with paragraph (g)(1)(i) of this standard. When a facility utilizes Universal Precautions in the handling of all soiled laundry, alternative labeling or color-coding is sufficient if it permits all employees to recognize the containers as requiring compliance with Universal Precautions.
[3] Whenever contaminated laundry is wet and presents a reasonable likelihood of soak-through of or leakage from the bag or container, the laundry shall be placed and transported in bags or containers which prevent soak-through and/or leakage of fluids to the exterior.
[B] The employer shall ensure that employees who have contact with contaminated laundry wear protective gloves and other appropriate personal protective equipment.
[C] When a facility ships contaminated laundry off-site to a second facility which does not utilize Universal Precautions in the handling of all laundry, the facility generating the contaminated laundry must place such laundry in bags or containers which are labeled or color-coded in accordance with paragraph (g)(1)(i).
Washing and drying the garments should be done according to the clothing manufacturer's instructions.
Q – 30. Who must be offered the hepatitis B vaccination?
A - The hepatitis B vaccination series must be made available to all employees who have occupational exposure, except as provided. The employer does not have to make the hepatitis B vaccination available to employees who have previously received the vaccination series, who are already immune as their antibody tests reveal, or for whom receiving the vaccine is contraindicated for medical reasons.
Q – 31. When must the hepatitis B vaccination be offered to employees?
A - The hepatitis B vaccination must be made available within 10 working days of initial assignment, after appropriate training has been completed. Thus, arranging for the administration of the first dose of the series must be done at a time which will enable this schedule to be met.
Q – 32. Can employees refuse the vaccination?
A - Employees have the right to refuse the hepatitis B vaccine and/or any post-exposure evaluation and follow-up. Note, however, that the employee needs to be properly informed of the benefits of the vaccination and post-exposure evaluation through training. The employee also has the right to decide to take the vaccination at a later date if he or she so chooses. The employer must make the vaccination available at that time.
Q – 33. Whose responsibility is it to pay for the hepatitis B vaccine?
A - The responsibility lies with the employer to make the hepatitis B vaccine and vaccination, including post-exposure evaluation and follow-up, available at no cost to the employees.
Q – 34. What information must the employer provide to the healthcare professional following an exposure incident?
A - The healthcare professional must be provided with a copy of the standard as well as the following information:
• A description of the employee's duties as they relate to the exposure incident;
• Documentation of the route(s) and circumstances of the exposure;
• The results of the source individual's blood testing, if available; and
• All medical records relevant to the appropriate treatment of the employee, including vaccination status, which are the employer's responsibility to maintain.
Q – 35. What information does the healthcare professional provide to the employer following an exposure incident?
A - The employer must obtain and provide to the employee a copy of the evaluating healthcare professional's written opinion within 15 days of completion of the evaluation. The healthcare professional's written opinion for hepatitis B is limited to whether hepatitis B vaccination is indicated and if the employee received the vaccination. The written opinion for post-exposure evaluation must include information that the employee has been informed of the results of the evaluation and told about any medical conditions resulting from exposure that may require further evaluation and treatment. All other findings or diagnoses must be kept confidential and not included in the written report.
Q – 36. What type of counseling is required following exposure incidents?
A - The standard requires that post-exposure counseling be given to employees following an exposure incident. Counseling concerning infection status, including results and interpretation of all tests, will assist the employee in understanding the potential risk of infection and in making decisions regarding the protection of personal contacts. For example, counseling should include the United States Public Health Service (USPHS) recommendations about the transmission and prevention of HIV. Counseling based on the USPHS recommendations must also be provided for HBV and HCV and other bloodborne pathogens, as appropriate. In addition, counseling must be made available regardless of the employee's decision to accept serological testing.
Q – 37. What recordkeeping does PESH require for exposure incidents?
A - Any public employer who is required to maintain a log of occupational injuries and illnesses under the PESH Recordkeeping regulation Part 801
is also required to establish and maintain a sharps injury log for the recording of percutaneous injuries from contaminated sharps. Employers must also record all work-related needle stick injuries and cuts from sharp objects that are contaminated with another person's blood or other potentially infectious material (as defined by 29 CFR 1910.1030) on the SH 900 Log. Employers may use the SH 900 Log to meet the requirements of the sharps injury log provided they enter the same information required for the sharps injury log on the PESH 900 Log and maintain the records in a way that segregates sharps injuries from other types of work-related injuries and illnesses, or allows sharps injuries to be easily separated. Employers must enter sharps injury cases on the PESH 900 Log and the sharps injury log without entering the employee’s name. [See the requirements for privacy cases in paragraph 801.29]
If an employee is splashed or exposed to blood or OPIM without being cut or punctured, the incident must be recorded on the SH 900 Log if it results in the diagnosis of a bloodborne illness or if it meets one or more of the recording criteria in 900.7
Q – 38. Which employees must be trained?
A - All public employees with occupational exposure must receive initial and annual training. In addition, training must be provided when changes (e.g., modified/new tasks or procedures) affect a worker’s occupational exposure.
Q – 39. Must part-time and temporary employees be trained?
A - Part-time and temporary employees are covered and are also to be trained on company time.
Q – 40. What is contained in the medical record?
A - The medical record includes the name and social security number of the employee; a copy of the employee's hepatitis B vaccination status including the dates of all the hepatitis B vaccinations and any medical records relative to the employee's ability to receive the vaccination; copies of all results of examinations, medical testing and follow-up procedures; copies of the healthcare professional's written opinion; and copies of the information provided to the healthcare professional.
Q – 41. Who keeps the medical records?
A - The employer is responsible for the establishment and maintenance of medical records. However, these records may be kept off-site at the location of the healthcare provider. The employer must ensure that the medical records are kept confidential and are not reported or disclosed without the express written consent of the worker, except as required by the standard or as may be required by law.
Q – 42. How long must the medical records be kept?
A - Medical records must be kept for the duration of employment plus 30 years.
Q – 43. What is included in the training record?
A - The training record contains the dates of the training, the contents or a summary of the training sessions, the names and job titles of all persons attending the training, and the names and qualifications of the persons conducting the training.
Q – 44. How long must training records be kept?
A - Training records must be retained for 3 years from the training date.
Q – 45. Where can I obtain additional information on the Bloodborne Pathogens standard?
A - Employees and Employers can call a PESH consultant with questions regarding any of the PESH standards or program elements. The PESH Bureau also provides a free consultative service upon request from the employer; employers can invite a consultant to visit their work place to provide assistance with program development, training or any of the other services listed within the PESH Consultative Services Pamphlet
Hazard Communication and Global Harmonization 1910.1200
Q – 1. What changes were recently made to the Hazard Communication Standard 29 CRF 1910.1200?
A - On March 26, 2012 OSHA published the final rule to integrate the United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals (GHS) into OSHA’s Hazard Communication (HazCom) standard. The amended HazCom standard requires employers to classify chemicals according to their health and physical hazards, and to adopt new, consistent formats for labels and safety data sheets (SDS)1 for all chemicals manufactured or imported in the United States.
Q – 2. How was the old standard changed?
A - The new harmonized HazCom standard amends the existing HazCom standard by integrating GHS. The “harmonized” standard ensures that employees will continue to have access to labels and SDS, but that information should now be easier to find and more understandable because of standardized formats and information, including the use of common signal words, pictograms, hazard statements and precautionary statements
Q – 3. What is a Hazard Classification?
A - Hazard classification has been broken down in “Health Hazards” and “Physical Hazards” as well as classification of mixes. The specific criteria will help ensure that evaluations of hazard effects are consistent and that labels and safety data sheets are more universal and accurate as well.
Q – 4. How has Hazard Classification changed in the revised HCS?
A - The new standard has specific criteria for classifying health and physical hazards along with detailed instructions for hazard evaluation and determinations as to whether mixtures or substances are covered. The standard uses both hazard class and hazard category, for most of the effects; the classes are divided into categories that reflect the relative severity of the effect. The current HCS does not include categories for most of the health hazards covered, so this new approach provides additional information that can be related to the appropriate response to address the hazard. The hazard category is the degree of severity within each hazard class (flammable liquid includes four hazard categories)
Q – 5. What changes were made to the labeling requirements?
A - Chemical manufacturers and importers will now be required to provide labels that include a global harmonized signal word, pictogram, and hazard statement for each hazard class and category also precautionary statements must be provided.
Q – 6. What Hazard Communication Standard provisions are unchanged in the revised HCS?
A - The revised Hazard Communication Standard (HCS) is a modification to the existing standard. The parts of the standard that did not relate to the GHS (such as the basic framework, scope, and exemptions) remained largely unchanged. There have been some modifications to terminology in order to align the revised HCS with language used in the GHS. For example, the term "hazard determination" has been changed to "hazard classification" and "material safety data sheet" was changed to "safety data sheet." OSHA stakeholders commented on this approach and found it to be appropriate.
Q – 7. What is the stepped compliance schedule within the revised HCS?
A - During this transition period employers may comply with the existing standard, the revised standard, or both.
• December 1, 2013- Train employees on the new labeling requirements and safety data sheet (SDS).
• June 1, 2013 – Compliance with all modified provisions of the final rule, except:
• December 1, 2015 – Distributors shall not ship containers of hazardous materials labeled by the chemical manufacturer or importer unless it carries the appropriate HCS label.
• June 1, 2016 – Update alternative workplace labeling and hazard communication program as necessary, and provide additional employee training for newly identified physical or health hazards.
Record Keeping 12 NYCRR Part 820
Q – 1. Is my fire department required to retain a record of my exposures during all my years of service? If so, for how long? Can you provide me with the specific OSHA regulation that requires that these records be kept?
A - According to the New York State Labor Law 12 NYCRR Part 820 Section 879 Records, the employer is responsible for maintaining a list of all toxic chemicals you were exposed to during your employment; the employer must maintain this list for 40 years. Section 880 Employee’s rights, describes the employee’s rights to receive a copy of exposure records from the employer. A copy of 12 NYCRR Part 820 can be obtained at:
A listing of the Subpart Z chemicals referred to above can be found at:
There may be other regulations outside of the jurisdiction of the Department of Labor as well.
Safety and Health Programs
Q – 1. What is a Safety and Health Accident Prevention Program?
A - A Safety and Health Accident Prevention Program is a means for employers to use systematic policies, procedures and practices for the recognition and control of workplace hazards. It is recognized that there is a direct correlation between effective safety and health management, and the reduced number and severity of workplace injuries and illnesses. The safety and health elements listed here are performance oriented and not required by a specific standard.
• Management commitment
• Assignment of safety and health responsibilities
• Employee involvement
• System for assuring compliance with established safe work practices
• System for workplace hazard assessments/evaluations
• Accident investigations
• Procedures for correcting unsafe/unhealthy conditions
• Ongoing safety and health training
• System for recordkeeping
Workplace Violence Prevention Programs 12 NYCRR Part 800.6
Q – 1. What is the New York State Workplace Violence Prevention Law?
A - On April 29, 2009 12 NYCRR Part 800.6 was promulgated and published in the State Register as a final rule. This Part requires public employers (other than schools covered under the school safety plan requirements of the education law) to perform a workplace evaluation or risk evaluation at each worksite and to develop and implement programs to prevent and minimize workplace violence caused by assaults and homicides. The Law is designed to ensure that the risk of workplace assaults and homicides are regularly evaluated by public employers and that workplace violence protection programs are implemented to prevent and minimize the hazard to public employees.
Q – 2. What is the effective date of the Law?
A - At the time of publishing the rule included a stepped compliance period. As of August 27, 2009 employers are required to be in compliance with the entire Part.
Q – 3. What public employers are covered by this Law?
A - According to the law, the term public employer includes the state, a political subdivision of the state, a public authority, a public benefit corporation and any other governmental agency or instrumentality. Employers defined in Section 2801-A of New York State Education Law are exempt from the provisions of the Workplace Violence Prevention Law since there is existing law requiring them to develop and maintain “school safety plans”.
Q – 4. What is Workplace Violence?
A - Any physical assault or acts of aggressive behavior occurring where a public employee performs any work-related duty in the course of his or her employment including but not limited to:
(i) An attempt or threat, whether verbal or physical, to inflict physical injury upon an employee;
(ii) Any intentional display of force which would give an employee reason to fear or expect bodily harm;
(iii) Intentional and wrongful physical contact with a person without his or her consent that entails some injury;
(iv) Stalking an employee with the intent of causing fear of material harm to the physical safety and health of such employee when such stalking has arisen through and in the course of employment.
Workplace violence presents serious occupational safety hazards for workers and unique challenges for employers who must prevent violence from occurring. During the last decade homicide was the third leading cause of death for all workers and the leading cause of occupational death for female workers. A large number of these reported homicides were related to robberies and police and public security functions. The majority of violent type incidents affecting workplaces are cases of assaults, threats, domestic violence, forms of harassment and physical and/or emotional abuse.
An employer conducted risk evaluation will help determine the possible dangers that employees may face from workplace violence risks and assist the employer in the development of a suitable workplace violence prevention program.
While workplace violence can occur in any workplace setting, typical examples of employment situations that may pose higher risks include:
Duties that involve the exchange of money
Delivery of passengers, goods, or services
Duties that involve mobile workplace assignments
Working with unstable or volatile persons in health care, social service or criminal justice settings
Working alone or in small numbers
Working late at night or during early morning hours
Working in high-crime areas
Duties that involve the guarding valuable property or possessions
Working in community-based settings
Q – 5. What are public employers required to do to comply with this Law?
A - The law requires every public employer to perform a risk evaluation of their workplace to determine the presence of factors or situations that might place employees at risk from occupational assaults and homicides.
Develop and implement a written policy statement, prepare a workplace violence prevention program and inform and train employees on the requirements of the Law and the workplace risk factors that were identified. Additionally, public employers with a combined total of 20 or more full-time permanent employees shall develop and implement a written workplace violence prevention program and provide employee training on workplace violence prevention measures and other information contained within the employers written program. Such employers shall also inform employees of the location and availability of the written workplace violence prevention program. Employee workplace violence training must be provided at the time of job assignment and annually thereafter. The written workplace violence prevention program should be pro-active, capable of assessing potential threats before they occur, and capable of responding to actual incidents immediately.
Q – 6. What is a Workplace Violence Prevention “Risk Evaluation”?
A - A risk evaluation is an employer’s inspection or examination of their workplace to determine if existing or potential hazards exist that might place employees at risk of occupational assaults or homicides. The Law requires all public employers to perform a risk evaluation of their workplace. Risk evaluation techniques should include, for example:
• An examination of the history of past incidents to identify patterns or trends which occurred in your workplace;
• A review of your occupational injury and illness logs (SH 900) and incident reports to identify injuries that my have resulted from workplace violence incidents;
• Surveying employees regarding details associated with the occurrence of workplace violence incidents;
• Conducting physical workplace security building surveys.
Q – 7. How can employees protect themselves from workplace violence?
A - The employee’s best protection is knowledge and an understanding of the warning signs of potentially violent individuals or situations. Employer training and education programs, as well as the implementation of clear zero tolerance workplace violence policies, are effective methods of reducing the possibility that violence will affect your workplace. Also, immediate reporting of any workplace violence incident to supervision or management and the police will help ensure that prompt action is taken.
Q – 8. What should be included in the Workplace Violence Prevention Training Program?
A - After completing the workplace violence prevention program, every employer shall provide each employee with information and training on the risks of workplace violence in their workplace or workplaces at the time of the employee’s initial assignment and at least annually thereafter. While workplace violence prevention training for employees may be specific to the type of facility and duties performed, there are certain essential topics that employers should address when conducting such training. These may include:
• The requirements of Part 800.6
• The specific Risk Factors found during the risk evaluation and determination
• What is Workplace Violence and what employees can do to protect themselves
• Specific procedures that the employer has implemented to protect the employees
• If 20 or more employees, the location of the written workplace violence program and how employees can obtain a copy
• How to report a Workplace Violence incident
• How and when incidents will be investigated by the employer
• Where employees can go for assistance
Q – 9. What are the recordkeeping and reporting requirements for workplace violence incidents?
A - Employers are required to establish and implement a reporting system for workplace violence incidents.
Reporting systems that meet the requirements of other federal, state or local regulations are acceptable if they address the information required by Part 800.6. An additional or separate reporting system is not required.
When there is a pattern of workplace violence incidents within your facility the employer will attempt to develop a protocol with the District Attorney or Police to insure that violent crimes committed against employees in the workplace are promptly investigated and appropriately prosecuted.
The employer shall utilize a Workplace Violence Incident Report that minimally contains the following information:
(a) Workplace location where incident occurred;
(b) Time of day/ shift when incident occurred;
(c) A detailed description of the incident, including events leading up to the incident and how the incident ended;
(d) Names and job titles of involved employees;
(e) Name or other identifier of other individual(s) involved;
(f) Nature and extent of injuries arising from the incident; and
(g) Names of witnesses.
The employer with the cooperation of the Authorized Employee Representative shall conduct a review of the Workplace Violence Incident Reports at least annually to identify trends in the types of incidents in the workplace and a review of the effectiveness of the mitigating actions taken.
How will the Department of Labor respond to complaints of workplace violence hazards?
Employees must provide a written notice to a supervisor and then allow a reasonable period of time for correction if they wish to file a complaint with the Commissioner of Labor. The condition that the employee brings to the supervisors attention must be a serious violation of the program (failure to develop and implement a Workplace Violence Prevention Program) or a situation that could result in serious physical harm. If after a reasonable period in time, the employee or the Authorized Employee Representative believes that serious violation of a workplace violence prevention program remains or that an imminent danger exists, such employee may request an inspection by notifying the Commissioner of Labor of the alleged violation. Written notice to an employer is not required where imminent danger exists to the safety of a specific employee or to the general health of a specific patient and the employee reasonably believes in good faith that reporting to a supervisor would not result in corrective action.
Valid complaints may result in a worksite inspection to determine if the employer has implemented the requirements of the Workplace Violence Prevention.
OUTDOOR WORKER SAFETY
Q – 1. How can public employers protect state employees from climate hazards?
A - Climate hazards from heat, cold and UV light from the sun can pose a serious threat to health. Once you recognize the hazards, take simple steps to minimize or avoid them. We will help employers assess workplace risks to see if climate hazards exist
and put workers at unreasonable risk. Employers should take precautions and offer workers protective measures to ensure their safety.
Q – 2. What is your risk from exposure to Ultraviolet Radiation (UV) from the Sun?
A - Employees who work in the sun risk skin exposures that cause blemishes, sun freckles and wrinkles. With continued exposure, sun-damaged skin can turn cancerous. Three skin cancers are linked to sun overexposure. Basal cell cancer (the most common) and squamous cell cancer are usually treatable and totally cured, if caught in time. Malignant melanoma is rarer, but more likely to be fatal if treatment is delayed. Most of the 10,000 Americans who die from skin cancer each year are victims of malignant melanoma. Skin cancer risk increases in proportion to unprotected timein the sun and the intensity of the sun’s rays during exposure. Intensity is greater in the summer, from 10 am to 2 pm, at higher altitudes. Work surfaces, such as metal roofing, concrete, etc, can also reflect up to 50 percent of the sun’s radiation, which intensifies exposure.
Q – 3. How can you reduce your risk from UV exposure?
A - The easiest way is to reduce your direct exposure to the sun. Wear protective clothing, such as a wide-brimmed hat, long pants and a long-sleeved shirt. Protective sunscreens help. Use a sunscreen with an SPF (skin protection factor) of at least 15, which is water-resistant to withstand humidity and sweat. Avoid baby oil, cocoa butter or skin oils that do not protect against sunburn. In addition, examine your skin regularly. Check for danger signs, including any wound, sore or patch of skin that won’t heal or constantly scales or any growing lump, particularly if it is brown or bluish in color. Also check for moles that grow, or change shape or color. If anything looks suspicious get a medical opinion sooner rather than later. Also advise your employer of any sun-related condition or medical diagnosis.
Q – 4. What is the risk of working in cold conditions?
A - Cold stress or hypothermia can affect employees who are not sufficiently protected against low temperatures. The cold may result naturally from weather conditions or be created artificially, as in refrigerated environments. Cold is a physical hazard in many outdoor workplaces. When the body is unable to warm itself, serious cold-related illnesses and injuries may occur that could lead to permanent tissue damage or worse. Workplaces that are prone to cold, wet and/or windy conditions include: roofs; open or unheated cabs; bridges or other projects near large bodies of water; large steel structures that retain cold or are exposed to cold; high buildings open to the wind; and refrigerated rooms, vessels, and containers. Your body tries to maintain an internal (core) temperature of approximately 98.6ºF (37ºC) by reducing heat loss and increasing heat production. Under cold conditions, blood vessels in skin, arms and legs constrict, decreasing blood flow to extremities. This minimizes cooling of the blood and keeps critical internal organs warm. At very low temperatures, however, reducing blood flow to the extremities can result in a lower skin temperature and a higher risk of frost bite.
Q – 5. What other risk factors are associated with cold injury?
A - Various medical conditions such as heart disease, asthma/ bronchitis, diabetes and vibration/white finger disease can increase the risk of cold injury. Check with your health practitioner to learn whether medications you take could also have adverse effects in a cold environment.
Q – 6. How do you protect against cold-related risks?
A - Be aware and be prepared. Workers should recognize the signs and symptoms of overexposure to cold in both themselves and co-workers. Pain in the extremities may be the first warning sign. Any worker shivering severely should come in out of the cold.
Q –7. How should fire fighters use protective measures in cold weather?
• Inform workers about wind-chill factors, especially those working on bridges or out in the open on high buildings.
• Ensure that workers are medically fit to work in excessive cold, especially those subject to the risk factors highlighted above.
• Stress the importance of high-caloric foods when working in cold environments. Warm sweet drinks and soups will maintain caloric intake and fluid volume.
• Coffee should be discouraged in cold conditions because it increases water loss and blood flow to extremities.
• Personnel working in isolated cold environments, whether indoors or outdoors, should have backup or monitors. Also, employees at risk should use shelters or other protected areas at regular intervals.
• Warm drinks and regular breaks are beneficial under extremely cold working conditions.
Q – 8. How should fire fighters select protective clothing to suit the cold, the job, and the level of physical activity.
• Wear several layers of clothing rather than one thick layer. Air captured between layers acts as an insulator.
• Wear synthetic fabrics such as polypropylene next to the skin because these wick away sweat. Clothing should not restrict flexibility.
• If conditions are wet, as well as cold, ensure that the outer clothing layer is waterproof or at least water-repellent. Some conditions require wind-resistant fabrics.
• At air temperatures of 2ºC (35.6ºF) or less, workers whose clothing gets wet for any reason will need an immediate change of clothing and may need treatment for hypothermia.
• Encourage the use of hats and hoods to prevent heat loss from the head and to protect ears. Balaclavas or other face covers may also be necessary under certain conditions.
• Tight-fitting footwear restricts blood flow. Footwear should be large enough to allow wearing either one thick or two thin pairs of socks. Wearing too many socks can tighten fit and harm rather than help.
• Workers who get hot while working should open their jackets but keep hats and gloves on.
Additional assistance is available regarding written plan development, training, programs, fit testing and maintenance of the PPE chosen and utilized. PESH Consultants are available to assist public employers with fire service questions, fit testing and other department strategies.
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