H. Cole, M. Garrahan, R. Biersner, U.S. DOL/OSHA, Washington, DC.
The OSHA Variance Program offers employers an opportunity to develop innovative methods or use updated technologies to protect workers from safety and health hazards in the workplace that diverge from the specific requirements of existing OSHA standards. The program also has provisions whereby employers can apply for extra time to come into compliance with a new OSHA standard. Special variances are available for employers when compliance with an existing OSHA standard would seriously impair the national defense. The Variance Program provides OSHA with a mechanism to consider worker-protection methods and technologies that are creative and unique or that represent the latest developments in safety and health technology. Variances from OSHA standards are authorized under sections 6 and 16 of the Occupational Safety and Health Act of 1970 (OSH Act), and the implementing rules contained in 29 CFR 1905. A variance may be requested by an employer or by a class of employers for specific workplaces. Generally, a variance is an alternative to complying with an existing OSHA safety and health requirement; in addition, the employer believes that the alternative will provide employees with a level of protection that is at least as effective as the protection afforded by the existing OSHA requirement. There are four types of variances available to employers: permanent, temporary, experimental, and defense. This paper will discuss the different types of variances, the pitfalls to avoid when submitting a variance application to OSHA, and examples of successful variance requests. These examples will include imaginative alternatives to existing OSHA safety and health requirements. Also discussed will be new efforts to simplify the variance application process (e.g., adding a variance application to the OSHA website).
A. Miguel, University of Minho, Guimaraes, Portugal; N. Sousa, Sun Chemical Portugal, Porto, Portugal.
The European Union (EU) Directive 1999/92/CE, commonly referred as ATEX137, is a social directive on “minimum requirements for improving the safety and health protection of workers potentially at risk from explosive atmospheres.” This directive is concerned with the risks arising from materials that have the potential to create explosive atmospheres. ATEX137 applies, with a few exceptions, wherever workers are potentially at risk resulting from those atmospheres. This legislation lays down the requirements that employers are obliged to follow, which can be synthesized in two main categories: (1) technical risk assessment and classification of hazardous areas; and (2) management arrangements to maintain safe systems of work, procedures (namely emergency ones), and training. ATEX137 has been implemented over recent years across the EU. Although the key requirements of the directive apply throughout all member states, leaving very little to modify by local legislation, minor variations exist among them. The main purpose of this study is to present the local singularities, as well as the different approaches, observed in Portugal, Spain, and UK in the implementation of ATEX137. To reach this target, local legislation in each of the three countries was analyzed. Six case studies in the cited countries were also considered in order to have a global perspective of the referred implementation.
M. Axelrod, Boeing, Beverly Hills, CA.
A large aerospace company utilizes safety metrics to measure the effectives of its safety management systems as well as to communicate and influence performance. This presentation evaluates those metrics as an effective tool to communicate and facilitate improved employee safety. The results of the analysis show that, contrary to intuitive expectations, the metric itself maybe a barrier to improved performance, reinforcing a culture that is already risk-taking through “acceptance communication.” Recorded accidents become an accepted norm based on history and a shared social construct regarding acceptable employee accident rates. This analysis uses communications tools informed by High Reliability Organization and Normal Accident Theory to illustrate the opportunity for improvement. Other concepts, such as “trial and error learning,” and “normalization of deviance,” are presented, along with company metric artifacts, cartoons, and other citations from the literature. The proposed solution is a “leading indicator” safety metric. A proposal currently being evaluated for implementation is presented for consideration.
D. Guerra, L. Ricciardi, J. Laborde, IRSN, Gif sur Yvette, France.
Currently, the prediction of the space-time evolution of an airborne pollutant released during an accidental leak remains hard to assess. However, this prediction is essential in hazardous activities, such as chemical processes or nuclear plants. Indeed, it is essential to know the concentration of an airborne pollutant concentration that can be inhaled by an operator or detected by a monitoring system for operators protection. The study presents a model that describes space-time evolution of an airborne pollutant dispersion in the near-field of an emission source, around a workplace. The case that is considered is a gas leak, following a containment rupture. Iin this situation, the pollutant dispersion is mainly controlled by the initial leak velocity (gas leak from a breach on a pressurized enclosure or a duct, failure of the glove box containment, etc.). Thus, the leak flow is similar to the continuous or transient jet flow from a slot or a round opening. The whole work is based on experiments of gas tracing into a full-scale ventilated room, and on multidimensional simulations using computational fluids dynamics tools. The final model is written as equations that are a function of various parameters, such as leak geometry, initial gas velocity, and emission duration. Moreover, the influence of room ventilation (deflected leak into cross-flows), the influence of room walls (impinging leaks). and buoyancy effects (for high-concentrated gaseous pollutant) have also been numerically studied in the case of continuous leaks.
The proposed equations are a user-friendly application tool developed to quickly calculate the pollutant concentration evolution in both cases of continuous and transient leaks.
I. Wainless, U. S. DOL/OSHA, Washington, DC.
Aluminum dust explosions have been ignored both by industry and the public. The public and some industries see aluminum as a large inert sheet of material, not as reactive dust, and do not know that it can burn and explode. Aluminum dust, like many metal dusts, represents an explosion hazard and under certain circumstances presents a fire hazard. Aluminum is very reactive, burning rapidly in air when vigorously heated. Finely divided aluminum powder or dusts forms highly explosive mixtures in air. Ignition may be the result of heat, shock, or abrasion; it may also be spontaneous due to humidity or moisture. In a finely divided form, aluminum will react violently with boiling water to form hydrogen and aluminum hydroxide; the reaction is slow in cold water. Under ordinary circumstances, aluminum’s chemical activity is reduced by the formation of a layer of aluminum oxide. If this protecting layer is breached, reactions consistent with its strong electropositive character may occur. In handling fires where aluminum dust is present, one is warned not to use water. Any powder handling or processing operation should be the subject of a hazard assessment that includes study of the risk of explosion. Such an assessment must begin with the identification of the hazards in the operation and the collection of flammability data on the materials being handled. This will then allow risk assessment to be performed on those identified hazards that takes into account both the likelihood of explosion and also the consequence of such an event. The flammability properties determined in the laboratory will have a major influence on the outcome of the hazard assessment, giving valuable information on how likely an explosion is to occur, how severe the consequences can be and how explosion protection measures should be designed to protect people and plant.
E. Pechter, P. Hunt, Massachusetts Department of Public Health, Boston, MA.
Two 35-year-old Vietnamese floor sanders died, and two others were injured in an explosion and fire in a Massachusetts apartment building in September 2004. In July 2005, a 43-year-old Vietnamese man died in a fire during floor refinishing in a single-family home. Fires associated with floor refinishing are not uncommon; Boston had more than 25 fires over 10 years directly attributed to hardwood floor installation and finishing, with resulting property loss >$1.5 million. In the two fires that led to loss of life highly flammable lacquer floor sealants were used, (one with a flash point of 9°F). Both fires were likely ignited by pilot lights. Many factors contribute to the risk of fire in floor refinishing. These include the predominance of small businesses, fierce competition to reduce costs; marketing of highly flammable sealants; lack of union penetration in the industry; lack of government oversight; and the absence of accurate, usable information about the hazards for consumers, contractors, and workers. The hardwood floor refinishing industry is dominated by Vietnamese small contractors in Boston, accounting for 127 of 144 registered businesses. Many other contractors may be unregistered. Vietnamese contractors dominate the industry in other cities as well. In the Boston area, a response has been mounted to prevent similar tragedies in the future. Community-based organizations, advocacy groups, community-based health centers, legislators, and government agencies have worked together on prevention steps. Legislation has been filed calling for licensure of floor refinishers. The Massachusetts Department of Public Health is collaborating with the Fire Marshall’s office and nongovernmental organizations to promote the use of safer and healthier floor finishing products, ensure the development and distribution of information in Vietnamese for the contractors and their employees, and provide information for home owners about product selection.
S. Mallinger, Congressional Office of Compliance, Washington, DC.
The Congressional Office of Compliance is obligated to conduct a biennial safety and health inspection of all Legislative Branch facilities once every ongressional session. A major portion of this space consists of offices for members of congress. Since no new office space has been constructed on Capitol Hill since the opening of the Hart Senate Office Building in 1987, members of congress must cram new employees into existing space when they increase the size of their staffs. As a result, individual work space gets smaller and (1) employees resort to using extension cords and daisy chaining power strips, (2) fire safety egress issues surface as walkways are made too narrow and exit corridors were not designed for the occupant load, (3) storage space is at a minimum and combustible materials are stacked above sprinkler heads, )4) indoor air complaints increase as carbon dioxide levels increase, (5) lack of swing space results in construction activity occurring in office work areas where lead and asbestos abatement activities are ongoing, and (6) training requirements in emergency response are elevated due to high employment turnover. In order to combat these problems careful planning, coordinating, communicating, and monitoring must occur.
C. Pan, S. Pratt, NIOSH, Morgantown, WV; A. Hoskin, M. Lin, National Safety Council, Itasca, IL.
The objective of this study was to determine risk factors for injuries to package delivery drivers. The courier industry is the fourth largest of the 10 segments of the transportation sector of the national economy. The rate of occupational injury and illness in the courier industry (12.8 per 100 FTE workers in 2003) was the highest of any segment of the transportation sector and 2.6 times the private sector rate. The days-away-from-work case incidence rate (5.8) was tied with air transportation as the highest in the sector and was 3.9 times the private sector rate. Detailed data analyses were conducted to determine priority injury problems and related factors. The Bureau of Labor Statistics’ Census of Fatal Occupational Injuries (CFOI) and Survey of Occupational Injuries and Illnesses (SOII) provided descriptive case and demographic data on fatal and nonfatal work-related injuries in the courier industry for 2003. The National Highway Traffic Safety Administration’s Fatality Analysis Reporting System (FARS) and General Estimates System (GES) provided detailed data for 2003 on the circumstances of fatal and nonfatal highway crashes involving step vans and walk-in vans. The leading causes of the estimated 22,410 injuries involving days away from work in the courier industry were overexertion (35.5%) and contacts with objects (19.2%) (SOII). On the other hand, almost 90% of 17 fatal injuries in 2003 resulted from highway crashes (CFOI). In 63.2% of the 4,175 nonfatal highway crashes, the van was the striking vehicle (GES). Of the 98 fatal crashes, 71.4% were collisions with another vehicle in transport, 10.2% were fixed-object collisions, and 10.2% were pedestrian collisions (FARS). Outcomes of this study will be combined with focus group studies to develop focused research hypotheses on the most significant variables contributing to manual materials handling and motor vehicle incidents.
Posted May 30, 2006