OSHA’s On-Site Consultation Program
Pictured: Lincoln Home National Historical Site in Springfield, Illinois.
This blog post is based on a presentation given by Nathan Augustine, Nancy Nash, Jenny Houlroyd, and Kathryn Makos at AIHce EXP 2022. An expanded version was published in AIHA's 2022 ebook, The Essentials of OEHS Communication.
As explained in the April 13 blog post, many workers employed in the museum and cultural heritage industry are not familiar with occupational health and safety practices and available resources, and collaborations between museum staff and OEHS professionals present mutually beneficial opportunities. This post covers the second AIHce EXP session on health and safety in museums, "A Behind-the-Scenes Look at Worker Safety Through Industry Practices and OSHA On-Site Consultation Outreach." It discusses how OSHA on-site consultants made contact and built trust with employees of museums and cultural sites who weren't familiar with the program.
Kathryn Makos, MPH, CIH, moderated this session and gave a brief introduction. "To set the stage," she began, "I want to impress upon you that museums and art galleries and historic sites are often many high-hazard industries under one roof." Museum staff members may work in analytical laboratories, do field work in remote locations, treat and prepare specimens, work in facilities management, fabricate exhibits, manage hands-on learning experiences, and more. Museums also address a range of subjects—such as natural history, world history and culture, art, and science and technology. Collections take a variety of forms—botanical gardens, zoos, and aquaria can be thought of as museums with living collections—and are found in a variety of places, including historic buildings, universities, wildlife centers, and businesses. Most government agencies and military service branches have museums or, at least, items on display.
Collection care issues tend to fall below the radar for many OEHS professionals. Fortunately, OSHA's On-Site Consultation Program is offering its services to help small, poorly resourced museums, collections, and historic sites manage their occupational risks.
A Wide Range of Hazards
Nathan Augustine's presentation on his work as art and equipment curator for Deere and Co., also known as John Deere, shed light on hazards encountered by employees managing collections owned by businesses. Established in 1937, the company has collected a number of objects over the years, including a large collection of equipment. Augustine explained that John Deere sees the equipment as "tangible examples of the company's success."
"We want to show people that we've been innovating and changing the world through our products," Augustine continued.
He manages four separately cataloged collections, each with their own hazards. The art collection includes sculptures and paintings, such as the 1931 landscape Fall Plowing by the American artist Grant Wood, which depicts a John Deere plow in the fields of Iowa. Hazards for this collection include pigments containing heavy metals, solvents, pesticides, and fungicides.
The archives include paper, photographs, and film. Historic film collections may contain film made of highly flammable cellulose nitrate and its safer alternative cellulose acetate. While less dangerous, cellulose acetate film produces acetic acid as it degrades. Other hazards in this collection include volatile organic compounds and mold.
The artifacts collection includes historical objects, clothing, memorabilia, and a small but unpleasant sample of fertilizer from the 1950s. Other hazards include pesticides and fungicides, mold, dust, solvents and chemicals, flammable and combustible materials, and talc.
Finally, John Deere's equipment collection includes historic tractors and machines and features the most hazards. Some equipment is so large and heavy that it can only be moved by people with specialized experience and expertise. Other equipment is less dangerous and can be moved by Augustine himself. However, he has found that practically any piece of equipment will leak fuel and other liquids if moved. Catch basins, drip pans, or absorbent pads must be placed under any equipment being stored or displayed, and Augustine deposits the waste in a toxic materials collection point inside his warehouse, to be disposed of by the company.
Augustine, who has a background in fine art, is not an OEHS professional. John Deere's industrial hygiene department provides him with training and personal protective equipment. But this isn't true for all curators.
"I have a lot of resources to help me because I work for a big, worldwide company," Augustine said. He urged audience members to consider how collections might be managed in their own companies. "Even if you don't have a museum, just about every company that's been around for any length of time has things that they're preserving to tell the story of the company," he explained. "And those are museum collections, and they often have hazards associated with them."
OSHA's On-Site Consultation Program
OSHA's On-Site Consultation Program is a no-cost service that operates in all U.S. states, targeting small businesses. Nancy Nash, who previously worked with the program in Illinois, explained that OEHS consultants visit work sites at employers' requests to identify hazards, help develop and maintain effective health and safety programs, and provide training. Consultants are independent of OSHA enforcement activities and will not report hazards or issue citations.
Many museums and cultural heritage sites are eligible for on-site consultations but aren't aware of the program or their responsibilities to meet OSHA regulations. Therefore, OSHA partnered with AIHA's Museum and Cultural Heritage Industry Working Group for a project aimed at establishing a relationship between the industry and the On-Site Consultation Program in seven pilot states: Connecticut, New Hampshire, Massachusetts, Georgia, Illinois, Ohio, and Texas. The working group has provided each state's consultation program with hazard information specific to the museum and cultural heritage industry and helped create promotional materials, which were distributed in the pilot states by the American Institute for Conservation and other organizations for museum professionals. In this initial phase, the project aims to advertise the consultation service, create standardized checklists, and conduct consultations when requested by employers.
The On-Site Consultation Program's goal is to provide museum employers with consultation visits before they're inspected by OSHA. According to Nash, employers have reported that consultants are professional, knowledgeable, and helpful; make facilities safer within one visit; ensure employers understand their obligations to meet safety standards; and are able to address questions and concerns. "When I was a consultant, employers would often say, 'I wish I knew about this service sooner,'" said Nash.
Outreach in Georgia
Following Nash's introduction, Jenny Houlroyd, CIH, MSPH, provided additional details on the On-Site Consultation Program's outreach in Georgia. Houlroyd helps small businesses throughout the state make sure their workers are protected and sites are as free from hazards as possible through her position as a certified industrial hygienist with the Georgia Tech Safety and Health Consultation Program. To her, the program not only provides museum and cultural heritage professionals with education in occupational health and safety but also helps her grow as an OEHS professional. "I’ve worked in the program for over 17 years now," she said. "I know a lot about industrial plants and construction, but I don’t know much about museums."
First, the project needed to find a message that would resonate. When Houlroyd first began contacting museums and cultural sites, employees tended not to believe they needed the consultation program’s services. AIHA’s Georgia Local Section started the conversation by holding a local section meeting at a museum, giving OEHS professionals a chance to meet the people who worked at the site. The local section also attended a conference for museum professionals, which allowed them to listen to the concerns of people within the field.
Houlroyd said she found that most people on museum and collections staff, in addition to lacking backgrounds in health and safety, weren’t very interested in talk of compliance and regulations. "They're artists," said Houlroyd. “They're creatives. They don’t want to hear some sort of rule." What they were interested in was a discussion. She recommended asking museum staff about their work experience. Had they ever been injured on the job? What did they think they might be interacting with on a daily basis that caused them low-level harm? What were their concerns about health and safety?
Communicating With Museum Staff
In fact, the project team found it helpful to develop a list of questions for consultants to ask when visiting a site. This approach helped the consultants learn about the wide range of hazards encountered by museums and heritage sites in different parts of the state and framed the activity as dialogue, not enforcement. "We still have a lot to learn about how to address things like electrical safety and slip, trip, and fall hazards in historical buildings that may have very specific restrictions on how they can be adjusted and modified," Houlroyd explained.
- Is there a research laboratory associated with this facility? Learning about the research facility and how it's managed helps consultants begin conversations about chemical hygiene plans.
- Do employees conduct field collection, preparation, or processing? Workers removing fossils or artifacts from rock or soil may be exposed to silica dust and other chemicals and therefore require the protection of OSHA's silica or hazard communication standards.
- Do employees perform conservation tasks such as preserving or treating objects? Conservation tasks may involve the use of solvents, strong acids or bases, resins, powders, paints, adhesives and other chemicals, or examination and treatment methods using X-ray, ultraviolet, or infrared radiation and lasers.
- How do employees care for and store items? It's important to reconcile the need for safe storage with museum staff members' desire for objects and artifacts to be stored in ways that meet the facility's aesthetic standards.
- How are exhibits fabricated and displays produced? Some materials used in construction, such as the silica product gunite, are also used to fabricate museum displays.
- Are there any live demonstrations that may pose hazards to employees or visitors? Often, the facility has no machine guarding for demonstrations, and staff hasn't thoroughly considered whether demonstrations are safe for employees to operate and guests to observe.
- What has been done at this facility to address fire safety management, fire prevention, and life safety? It's important to know how people can get out of the facility in an emergency.
- Describe general maintenance of the facilities, structures, and grounds. How is construction safely managed? The financial costs of addressing safety issues related to facility maintenance can be overwhelming, so it's important that museum staff know the consultation can be limited to issues they're financially prepared to address.
- What planning has the facility done to prepare for emergency response? Facilities need to prepare for emergencies such as tornadoes, hurricanes, flooding, natural disasters, and workplace violence. Mold is another frequent concern, especially with older buildings and materials.
The Georgia consultation program also uses an activity called "hazard mapping" to help museum and cultural site staff members think about hazards and controls in their workplaces. In this activity, staff members draw their site's floor plan on paper, marking various kinds of hazards using different colors of crayons or markers.
Frequently, the desires of people in charge of preserving history and those in charge of protecting their safety may conflict. Houlroyd related a story about archeologists who unearthed a Civil War-era Parrott artillery shell in one of Georgia's national parks and, accordingly, called the police. However, the police bomb squad wanted to safely detonate the shell so that it was no longer a hazard, while the archeologists wanted to preserve it. Although this was an extreme situation, OEHS professionals assisting museums and heritage sites may need to navigate similar dilemmas.
AIHA: "Museum and Cultural Heritage Industry Working Group."
Makos, Kathryn; Augustine, Nathan; Nash, Nancy; and Houlroyd, Jenny. "Museums, Part 2 – A Behind-the-Scenes Look at Worker Safety Through Industry Practices and OSHA On-Site Consultation Outreach." AIHce EXP, AIHA, May 23, 2022, virtual. Conference Presentation.
Massachusetts Department of Labor Standards: Museum and Cultural Heritage Site Hazards: On Display and Unseen (PDF).
OSHA: "On-Site Consultation."
Texas Department of Insurance: Museum and Cultural Heritage Industry Workplace Program (PDF).
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