DEFCON April 10-12, 2012

 APIC – Association for Professionals in

Infection Control and Epidemiology, Inc.
 CDC – Center for Disease Control and Prevention
 CFR – Code of Federal Regulations
 DOL – Department of Labor
 EO – Executive Order
 FACOSH – Federal Advisory Council on Occupational Safety and
Health
 MSDS – Material Safety Data Sheet
 NFPA – National Fire Protection Association
 NIOSH – National Institute for Occupational Safety and Health
 OSHA – Occupational Safety and Health Administration
 PEL – Permissible Exposure Limit
 SIC – Standard Industrial Classification
 29 CFR Part 1910 – Occupational Safety and Health Standards
 1910.1020 - Access to employee exposure and medical records

 29 CFR Part 1960 – Basic Program Elements for Federal

Employees OSHA
 1960.26 - Conduct of inspections

 1960.27 - Representatives of officials in charge and representatives

of employees
 1960.28 - Employee reports of unsafe or unhealthful working

conditions
 1960.29 - Accident investigation

 1960.30 - Abatement of unsafe or unhealthful working conditions

 1960.31 - Inspection by OSHA

 EO 12196 – Occupational Safety and Health Programs for Federal

Employees
(a) Each employer --

  (1) shall furnish to each of his employees employment and a

place of employment which are free from recognized hazards
that are causing or are likely to cause death or serious physical
harm to his employees;
(2) shall comply with occupational safety and health standards
promulgated under this Act.

(b) Each employee shall comply with occupational safety and

health standards and all rules, regulations, and orders issued
pursuant to this Act which are applicable to his own actions and
conduct.
29 USC 654
• Cooperation on injury prevention
• Stress/Workload
• Equipment/machinery
• Ergonomics
• Housekeeping
• Leased spaces/Confined spaces
• Employee Wellness
• Management acknowledgement
• Lack of training/equipment
• Blame the victim
• Food/drink facilities
• Traffic control
 • Supervisory responsibility
• Retaliation
• Intimidation
• Clothing allowance
• Debris
• Environmental
• Respiratory
• Ventilation
• General awareness
• Applicable standards
(Which one takes precedence when there is a conflict?)
• Chemical (i.e., asbestos)
• Infectious Diseases
The Occupational Safety and Health Administration was established in
1971. Since then, OSHA and our state partners, coupled with the efforts of
employers, safety and health professionals, unions and advocates, have
had a dramatic effect on workplace safety. Fatality and injury rates have
dropped markedly. Although accurate statistics were not kept at the time,
it is estimated that in 1970 around 14,000 workers were killed on the job.
That number fell to approximately 4,340 in 2009. At the same time, U.S.
employment has almost doubled and now includes over 130 million
workers at more than 7.2 million worksites. Since the passage of the OSH
Act, the rate of reported serious workplace injuries and illnesses has
declined from 11 per 100 workers in 1972 to 3.6 per 100 workers in
2009. OSHA safety and health standards, including those for trenching,
machine guarding, asbestos, benzene, lead, and bloodborne pathogens
have prevented countless work-related injuries, illnesses and deaths. This
timeline highlights key milestones in occupational safety and health
history since the creation of OSHA.
http://www.osha.gov/osha40/timeline.html
 Who OSHA covers:
 Private Sector Workers
 Federal Government Workers
 State and Local Government Workers
 Condition: Must have OSHA-approved state program

 Not covered by OSHA:

 Self employed
 Immediate family members of farm employers that do not employ
outside employees
 Workplace Hazards regulated by another Federal agency (for
example, the Mine Safety and Health Administration, the Federal
Aviation Administration, the Coast Guard).

http://www.osha.gov/workers.html
1) Alaska
2) Arizona
3) California
4) Hawaii
5) Indiana
6) Iowa
7) Kentucky
8) Maryland
9) Michigan
10)Minnesota
11)Nevada
12)New Mexico
13)North Carolina
14)Oregon
15)South Carolina
16)Tennessee
17)Utah
18)Vermont
19)Virginia
20)Washington
21)Wyoming
22)Puerto Rico
 Workplace violence
 Infectious Disease with the exception of Blood Borne
Pathogens (BBP)
 Air Quality
 Ergonomics
 Weight Limit
*This is not all inclusive.
Employers have the responsibility to provide a safe
workplace. Employers MUST provide their employees
with a workplace that does not have serious hazards and
follow all relevant OSHA safety and health standards.
Employers must find and correct safety and health problems.
OSHA further requires employers to try to eliminate or
reduce hazards first by making changes in working
conditions rather than just relying on masks, gloves, ear plugs
or other types of personal protective equipment (PPE).
Switching to safer chemicals, enclosing processes to trap
harmful fumes, or using ventilation systems to clean the air
are examples of effective ways to get rid of or minimize risks.
Employers MUST also:
 Inform employees about hazards through training, labels,
alarms, color-coded systems, chemical information sheets
and other methods.
 Keep accurate records of work-related injuries and
illnesses.
 Perform tests in the workplace, such as air sampling
required by some OSHA standards.
 Provide hearing exams or other medical tests required by
OSHA standards.
 Post OSHA citations, injury and illness data, and the OSHA
poster in the workplace where workers will see them.
 Notify OSHA within 8 hours of a workplace incident in
which there is a death or when three or more workers go
to a hospital.
 Not discriminate or retaliate against a worker for
using their rights under the law.
 Designate Agency Safety and Health Official
 Conduct annual inspection

 File OSHA complaint(s) on behalf of employee(s)

 Part of Safety Inspection Team (annual)
Workers' rights under the OSH Act
Workers are entitled to working conditions that do not pose a risk of
serious harm. To help assure a safe and healthful workplace, OSHA
also provides workers with the right to:
 Ask OSHA to inspect their workplace
 Use their rights under the law without retaliation and
discrimination
 Receive information and training about hazards, methods to prevent
harm, and the OSHA standards that apply to their workplace. The
training must be in a language you can understand
 Get copies of test results done to find hazards in the workplace
 Review records of work-related injuries and illnesses
 Get copies of their medical records
http://www.osha.gov/workers.html
• SOPs/Policies/Training
• MSDS
• Labels/Containers
• Injury Reports/OSHA Logs (Form 300)
• Monitoring
• Medical Records
• Hazard Assessment
• Surveys
• Complaints
• Service logs/records for equipment
• Past Practice
• Grievances
• Complaints
Other/Government
• Occupational Safety and Health Administration (OSHA)
• Department of Labor (DOL)
• National Fire Protection Association (NFPA)
• Association for Professionals in
Infection Control and Epidemiology, Inc. (APIC)
• Center for Disease Control and Prevention (CDC)
• National Institute for Occupational Safety and Health
(NIOSH)
If you believe working conditions are unsafe or unhealthful,
we recommend that you bring the conditions to your
employer's attention, if possible.
You may file a complaint with OSHA concerning a hazardous
working condition at any time. However, you should not leave
the worksite merely because you have filed a complaint. If the
condition clearly presents a risk of death or serious physical
harm, there is not sufficient time for OSHA to inspect, and,
where possible, you have brought the condition to the
attention of your employer, you may have a legal right to
refuse to work in a situation in which you would be exposed
to the hazard.
You have these options to file your safety and health complaint:
1. Online -
http://www.osha.gov/pls/osha7/eComplaintForm.html
2. Download and Fax/Mail – Download OSHA complaint form at
http://www.osha.gov/oshforms/osha7.pdf. Complete and fax or
mail to your local OSHA Regional or Area Office which can be
found at http://www.osha.gov/html/RAmap.html. Include your
name, address and telephone number so that an OSHA
representative can contact you to follow up.
3. Telephone - your local OSHA Regional or Area Office. OSHA staff
can discuss your complaint and respond to any questions you
have. If there is an emergency or the hazard is immediately
life-threatening, call your local OSHA Regional or Area
Office or 1-800-321-OSHA.

http://www.osha.gov/as/opa/worker/complain.html
File a discrimination complaint if your employer has
punished you for using any employee rights established
under the OSH Act or for refusing to work when faced with
an imminent danger of death or serious injury and there is
insufficient time for OSHA to inspect. If you have been
punished or discriminated against for using your rights, you
must file a complaint with OSHA within 30 days of the alleged
reprisal for most complaints. No form is required, but you
must call or file a letter with the OSHA Area Office nearest
you within 30 days of the alleged discrimination. In states
with approved state plans, employees may file a complaint
with both the State and Federal OSHA.
Employees or their representatives have a right to request an inspection
of a workplace if they believe there is a violation of a safety or health
standard, or if there is any danger that threatens physical harm, or if an
"imminent danger" exists. Employee representatives, for the purposes of
filing a complaint, are defined as any of the following:
An authorized representative of the employee bargaining unit, such as a certified or
recognized labor organization.
An attorney acting for an employee.

Any other person acting in a bona fide representative capacity, including, but not limited to,

members of the clergy, social workers, family members, government officials, nonprofit
groups and organizations acting upon specific complaints and injuries from individuals who
are employees.
In addition, anyone who knows about a workplace safety or health hazard
may report unsafe conditions to OSHA, and OSHA will investigate the
concerns reported.
 How many employees work at the site and how many are exposed to the
hazard?
 How and when are workers exposed?
 What work is performed in the unsafe or unhealthful area?
 What type of equipment is used? Is it in good condition?
 What materials and/or chemicals are used?
 Have employees been informed or trained regarding hazardous
conditions?
 What process and/or operation is involved?
 What kinds of work are done nearby?
 How often and for how long do employees work at the task that leads to
their exposure?
 How long (to your knowledge) has the condition existed?
 Have any attempts been made to correct the problem?
 On what shifts does the hazard exist?
 Has anyone been injured or made ill as a result of this problem?
 Have there been any "near-miss" incidents?
1. Elimination
2. Substitution
3. Engineering Controls – Encapsulation, Safety Measures,
Ventilation Systems
4. Administrative Controls – Labeling Systems, Training,
Rotating Workers – limit exposure, Work permit system – ONLY
those who are qualified, and After Hours – when there is less traffic
throughout the workplace
5. Personal Protective Equipment
 Problem Root Cause
Solving Analysis
Step 1: Identify/Document Step 1: Define the Problem

Step 2: Remedy Step 2: Collect Data

(Make employee whole)
Step 3: Identify Possible
Step 3: Strategy Causal Factors

Step 4: Identify the Root

Cause(s)

Step 5: Recommend and

Implement Solutions
Step 1: Define the problem
 Who, What, When, Where, Why, and How

Step 2: Collect Data

 Documentation is a MUST!
 What proof do you have that the problem exists?

 How long has the problem existed?

 What is the impact of the problem?

 From experts and front line staff who understands the situation and
are most familiar with the problem.
Tools to help identify causal factors (Steps 3-5):
 Appreciation – Use the facts and ask “So what?” to determine all the
possible consequences of a fact.
 5 Whys – Ask “Why?” until you get to the root of the problem.
 Drill Down – Break down a problem into small, detailed parts to
better understand the big picture.
 Cause and Effect Diagrams – Create a chart of all of the possible
causal factors, to see where the trouble may have begun.

Step 3: Identify Possible Causal Factors

 What sequence of events leads to the problem?
 What conditions allow the problem to occur?
 What other problems surround the occurrence of the central problem?
Step 4: Identify the Root Cause(s)
 Why does the causal factor exist?
 What is the real reason the problem occurred?

Tools to help identify causal factors:

 Appreciation – Use the facts and ask “So what?” to determine all the
possible consequences of a fact.
 5 Whys – Ask “Why?” until you get to the root of the problem.
 Drill Down – Break down a problem into small, detailed parts to
better understand the big picture.
 Cause and Effect Diagrams – Create a chart of all of the possible
causal factors, to see where the trouble may have begun.
Step 5: Recommend and Implement Solutions
 What can you do to prevent the problem from happening again?
 How will the solution be implemented?
 Who will be responsible for it?
 What are the risks of implementing the solution?

Plan ahead / Spot potential failures before they happen:

 Failure Mode and Effects Analysis (FMEA) – This tool builds on the
idea of risk analysis to identify points where a solution could fail.
 Impact Analysis – This helps you explore possible positive and
negative consequences of a change on different parts of a system or
organization.
 Kaizen (aka Continuous Improvement) – This is the idea that continual
small changes create better systems overall. It also emphasizes that
the people closest to a process should identify places for improvement.
• Department of Labor -
http://www.dol.gov/index.htm
• Occupational Safety and Health
Administration - http://www.osha.gov
• Office of Workers’ Compensation
Program - http://www.dol.gov/owcp/
• Association for Professionals in
Infection Control and Epidemiology, Inc. -
http://www.apic.org/
• National Fire Protection Association –
http://www.nfpa.org
• Center for Disease Control and
Prevention - http://www.cdc.gov/