General Safety FAQ's

Design Safety Standards and Electrical Systems

(The following are Technical Interpretations provided by the Florida Department of Labor and Employment Security)

Q: Do circuit breakers in panel boxes have to be labeled? If so, do labels need to be next to breakers or can they be on the outer door of the panel box?
A: Yes, labeling is required. Each circuit breaker or disconnect switch must be clearly marked to indicate its purpose. Labels cannot be on the outer door of the panel box unless there is only one circuit breaker in the panel box. A labeling system must be located on the inside of the panel box door or next to each circuit breaker. {29 CFR 1910, Subpart S, Electrical; Subsection 303 (f)}
   
Q: How would the ground to path requirement covered under 1910.304 (f) (4) apply to buildings having a 2-wire system?
A: Older wiring systems with outlets designed for 2-prong receptacles may be found in buildings built before March 1972. These receptacles accept 2-prong plugs without a grounding pin. Current wiring codes, however, require outlets to be designed for 3-prong receptacles. The path to ground requirement for electrical systems with either 2 or 3-prong receptacles must be permanent and continuous. If the outlet is designed to be part of the permanent wiring of the building, then the wiring is permanent. Converting a 2-prong receptacle to accept a 3-prong plug by using a plug-in adapter with or without a grounding wire is not acceptable because it is not part of the permanent wiring of the building. {29 CFR 1910.302 and 1910.304; NFPA 70E}
 


Personal Protective Equipment

(The following are Technical Interpretations provided by the Florida Department of Labor and Employment Security)


Q: Is there a standard, either OSHA or ANSI, that covers/requires employees with long hair to put it in a hair net while they are working on or near powered machinery?
A: There is no specific OSHA standard in either 1910 Subpart I (personal protective equipment) or 1910 Subpart O (machinery and machine guarding) regarding hair nets and usage. However, if a machine guard does not provide adequate protection and long hair could become entangled in moving parts of machinery, the employer should require that the employee's hair be covered or confined. (OSHA publication 2095, p. 14) Caps and hair nets should be used to confine hair to prevent the worker's hair from being caught in machinery. (OSHA publication 3067, p. 10) Generally, employers should cover this area in a safety policy that prohibits such items as unconfined neckties, dangling jewelry, as well as unconfined long hair from being situated near operating machinery where injury could result. Certain workplaces have standards on sanitation that may further influence the workplace in this regard. {29 CFR 1910.132 (a)}
   
Q: A manufacturer's MSDS recommends the use of gloves. Is the employer required to provide gloves for the employees use?
A: Yes, if required on the MSDS. Whenever it is necessary by reason of hazards of processes or environment, CHEMICAL HAZARDS, radiological hazards, or mechanical irritants encountered in a manner capable of causing injury or impairment in the function of any part of the body through absorption, inhalation or physical contact, personal protective equipment for the extremities must be provided, used, and maintained. {29 CFR 1910.132 (a)}
   
Q: Are there any personal protection requirements for employees using household bleach in the workplace?
A: Yes. Employers are required to provide protective gloves, chemical goggles, and a face shield for employees who are exposed to corrosive liquids. Household bleach (i.e., Clorox), also known as sodium hypochlorite (CAS No. 7681-52-9), is a strong eye, skin, and mucous membrane irritant that is commercially available in 5% and 12 % concentrations. The extent of irritation depends on the concentration of sodium hypochlorite and the duration of exposure. {29 CFR 1910.132 & .133}
   
Q: What are the medical requirements for wearing a respirator?
A: There are no specific medical requirements for wearing a respirator. A local physician must determine what health and physical condition is pertinent for the employee to use the equipment and perform the work. This medical determination may or may not consist of a full or partial physical examination of the employee. If, in the judgement of the local physician, no physical examination is deemed necessary, then a statement from the physician indicating that the employee may use the respirator at work is acceptable. {29 CFR 1910.134 (b) (10)}
   
Q: Respirators are used in a facility. Are physical examinations required on an annual basis?
A: No. The standard on respiratory protection provides that persons should not be assigned to tasks requiring the use of respirators unless it has been determined that they are physically able to perform the work and use the equipment. The local physician shall determine what health and physical conditions are pertinent.

There is no examination requirement for an annual physical examination. However, this section recommends, but does not mandate, that the respirator user's medical status be reviewed periodically.

   
Q: What is meant by medical evaluation and fit testing for respirators?
A: 29 CFR 1910.134 (a) (2) does require that an employer provide respirators when such equipment is necessary to protect the health of the employee. This standard further requires that an employer providing respirators shall be responsible for the establishment and maintenance of a respiratory protective program. The requirements of such a respiratory protective program are listed under 29 CFR 1910.134 (b).

Medical examinations are not required by 29 CFR 1910.134 (b) (10). However, other specific standards, for example: 29 CFR 1910.1025 (j) (3), "Lead," and 29 CFR 1910.1001 (l) (1) - (3), "Asbestos," do require medical examinations for certain users of respiratory protection devices.

29 CFR 1910.134 (b) (10) describes one of the required elements of a respiratory protective program. The program must address the instruction that persons who are not physically able to use respirators should not be assigned to tasks requiring respirator use. The standard does not specify how the employer shall address this issue. It does provide, however, that any determination of whether or not a particular condition of a specific employee precludes him or her from respirator use shall be made by a local physician.

29 CFR 1910.134 (b ) (10) does not require, but recommends, periodic review of the medical status of employees who use respirators. Other specific standards, such as 29 CFR 1910.1011 (g) (1) (ii), "4-Aminodiphenyl," and 29 CFR 1910.1017 (k) (2), "Vinyl Chloride," mandate employers establish and maintain medical surveillance programs providing employees with periodic medical examinations at no cost to the employee. These standards, however, shield specific operations and do not apply to other applications.

Examples of policies that could be included within a respiratory protective program to meet the requirements of (b) (10) are: 1) requiring each employee to bring a note from his or her doctor saying that the employee is physically able to perform the work and use the respirator, 2) providing medical exams for all employees by a physician designated by the employer, or 3) requiring each employee to respond to a questionnaire which asks if the employee has any existing condition or other reason that would make him or her physically unable to perform the work and wear a respirator; any employee responding positively to the questionnaire would not be assigned tasks requiring use of respirator, unless a physician determines that he or she is able to use a respirator.

Fit-testing for all users of respirators is required by 29 CFR 1910.134 (e) (5). The American National Standards Practices for Respiratory Protection Z88.2-1969, incorporated by reference in 29 CFR 1910.134c, defines a respirator as: "A device designed to protect the wearer from the inhalation of harmful atmospheres." The procedures specified in 29 CFR 1910.134 (e) (5) apply whenever respirators are used. This means that whenever respirators are required or permitted by the employer, any employee who is a user of the respiratory protective device must be fitted and fit-tested. Fitting may be accomplished in accordance with the manufacturer's facepiece fitting instructions. The actual fitting and fit-test are part of the employer's respirator training program.


Hearing Protection & Noise

(The following are Technical Interpretations provided by the Florida Department of Labor and Employment Security)

Q: What does a permissible exposure limit of 115 dB(A) for 15 minutes or less mean?
A: Noise exposures above 115 dB(A) are not permissible for any length of time. This assumes that exposures are continuous or intermittent in nature and not impact or impulse noise. Impact or impulse noise exposure must not exceed 140 dB(A) peak sound pressure level. {29 CFR 1910.95 (b)}
   
Q: If an employer has posted a notice to employees that says "hearing protection required". does the employer have to provide hearing protectors?
A: Yes. Posting of this warning sign means the employer has information indicating that employees may be exposed to noise levels that equal or exceed an 8-hour TWA of 85 dB(A). Unless a noise monitoring program indicates otherwise, the employer must provide hearing protectors as part of a hearing conservation program to any employee authorized or permitted to enter the posted exposure area. {29 CFR 1910.95 (b)}
   
Q: When are hearing protectors required in the workplace?
A: Hearing protectors are required when engineering or administrative controls fail to reduce noise level below the allowable limit. The allowable limit for noise levels over an 8-hour time weighted average is 90 decibels measured on the A-scale. When the sound level exceeds an average of 85 decibels, a continuing, effective hearing conservation program must be administered in accordance with 29 CFR 1910.95 (c) through (o). {29 CFR 1910.95}
   
Q: If employees are provided with hearing protectors by their employer, is the employer required to have a hearing conservation program?
A: No. Insert-type hearing protectors are often provided to employees such as welders and oil derrick workers to keep dust, aerosols and other airborne particulates out of the ear canal. Unless noise monitoring indicates otherwise, simply providing hearing protectors to employees does not require an employer to have a hearing conservation program. {29 CFR 1910.95 (c)}
   
Q: Is there a requirement for an employer to have a written hearing conservation program?
A: No. There is no expressed requirement for an employer to have a "written" hearing conservation program. However, a hearing conservation program does require recordkeeping by the employer to document monitoring, audiometric testing, and employee training. {29 CFR 1910.95 (c)}
   
Q: When is an employer required to have a hearing conservation program?
A: A hearing conservation program is required whenever noise exposure in a full 8-hour shift does not go above 115dB (A) at any time, or equals or exceeds an 8-hour TWA of 85 dB(A). {29 CFR 1910.95 (c)}
   
Q: If employer monitoring indicates employee sound levels for an 8-hour TWA of 82dB(A) and the employer elects to provide hearing protectors to employees, is the employer required to have a hearing conservation program?
A: No. If the employer has developed and implemented a noise monitoring program and the noise levels measure did not equal or exceed an 8-hour TWA of 85 dB(A), the employer is not required to have a hearing conservation program. Even though hearing protectors were provided in this case, program requirements to perform audiometric testing and employee training do not apply.{29 CFR 1910.95 (d)}

Hazard Communication & Employee Right-to-Know

(The following are Technical Interpretations provided by the Florida Department of Labor and Employment Security)

Q: What are the training requirements under the OSHA Hazard Communication Standard (HCS)?
A: Under 29 CFR 1910.1200 (h) (1) & (2), Hazard Communication (1988), employers are required to provide initial training at the time of assignment and when a new chemical is introduced to all employees that are required to work with or may otherwise be exposed to these chemical substances. Required subject areas for employee training include a list of chemicals present and their location, location of the required written HCS program, knowledge of protective measures required, procedures to determine the presence of hazardous chemicals, and ability to interpret labels and information on the MSDS sheet.{29 CFR 1910.1200 (h) (1) & (2)}
   
Q: Are Secondary School, College, Crime, and Forensic Laboratories, and their stockrooms, covered under the provisions of this standard?
A: Yes. All laboratories that meet the specific conditions mentioned in the standard fall under the provisions of the standard. Stockrooms that are ancillary to the laboratories generally do fall under the guidelines of the standard since they are an integral part of the laboratory, i.e. chemicals are often transferred from larger to smaller containers via gravity fed tubes, spigots, scoops, and funnels. However, if the laboratory stockrooms are not captured in the standard they, as are the laboratories not covered under this standard, are regulated by Subpart Z.

The laboratory operations governed under this standard include all employers whose business activities involve working with hazardous chemicals and having procedures that include:

  • working with substances used for effecting reactions and transfers,
  • the necessary and customary handling of substances that are packaged or transferred in containers designed to be easily and safely manipulated by one person,
  • the use of multiple chemicals or chemical procedures when the procedures accomplished in the activity are not a part of, or supplemental to, a production process, or
  • in those circumstances where employees have demonstrated a need for protective equipment and laboratory procedures that are generally accepted as standard in the industry for minimizing the potential for exposure to hazardous chemicals.

If a laboratory is governed by this standard, the employer must also provide for the employees a written Chemical Hygiene Plan and a mechanism to monitor the cumulative exposure of employees to hazardous chemicals.

The written Chemical Hygiene Plan shall be:

  • capable of protecting employees from health hazards associated with the laboratory use of hazardous chemicals,
  • capable of keeping employee exposures to hazardous chemicals below permissible exposure limits,
  • readily accessible to employees, representatives of employees, and upon request, to the Assistant Secretary.

{29 CFR 1910.132 & .133}


Machinery and Machine Guarding

(The following are Technical Interpretations provided by the Florida Department of Labor and Employment Security)

Q: What does "exposure to a hazard" mean? If there is an unguarded machine which is not being used, does that constitute exposure?
A: A hazard is the risk of exposure to machines, materials, processes, operating procedures or practices that can produce a harmful effect by causing injury or disease or by endangering the life of an employee. The risk of exposure to a machine that is required to be guarded does not in itself constitute a hazard if it is determined that: (a) the machine is out of service; or (b) the machine is not presently being operated, but when in operation, a guard is provided and used to prevent injury to the operator. {29 CFR 1910.212 (a) (1)}

Medical and First Aid

(The following are Technical Interpretations provided by the Florida Department of Labor and Employment Security)

Q: Are first aid kits required in workplaces? How many and where located?
A: No. However, if the employer opts to provide first aid supplies, those supplies approved by the consulting physician shall be readily available. {29 CFR 1910.151 (b)}