3.0 General Health and Safety

3.1 Preventing and Controlling Workplace Hazards

In our commitment to providing safe, healthful facilities, it is essential that UTHSCSA faculty and staff comply with all applicable general health and safety standards, guidelines, or Best Management Practices (BMPs). Environmental Health and Safety

(EH & S) will employ every effort to abate or eliminate physical and life safety health hazards as quickly as is reasonably achievable. Physical and life safety hazards will be prioritized for abatement management purposes. The preferred method of hazard abatement is elimination. Process adjustment to reduce hazard(s) to the greatest extent possible without affecting efficiency is the next method of choice.

3.1.1. Principles of Hazard Control

1. Elimination. Removing the hazard or its potential is best. This can be achieved by modifying the process in question to reduce hazard potential, as close as reasonably possible, to zero. If the hazard results from unnecessary processes or procedures, it can be easily abated through elimination of that process or procedure if efficiency and production remain constant.

2. Reduction. Replacing hazardous processes, materials, or equipment with, low toxicity or non-hazardous items will reduce the risk of injury or illness. However, extreme care must be taken when exercising this option. Engineer, manufacturer, EH & S, or other competent authority’s advice concerning planned substitution must be sought prior to implementing process change(s). It is always prudent to exercise extreme caution when substitution is employed as a hazard control method. Extreme care to insure substitute materials are technically acceptable and incapable of exposing workers to new hazards must be taken.

3. Isolation. Hazards are controlled through isolation by erecting impermeable barriers or berms between the hazard source and potentially exposed workers. Effective barriers can be physical enclosures, separation (of worker from task for a set period time to allow for biological recovery), or distance (keeping workers away from hazard generating task in an area where airborne contaminant is lower than established Occupational Exposure Level - OEL). Isolation devices include, but are not limited to; machine guards, curtains as used in welding shops, electrical insulation, glove boxes, acoustical or anechoic material, and remote controlled equipment.

4.  Engineering. Local ventilation is the primary engineering control used today. Controlling potentially hazardous, airborne substances with ventilation can be accomplished in three ways – Dilution, General, and Local.

  1. Dilution Ventilation – reducing airborne contamination concentration by mixing with copious amount of clean air
  1. Local Ventilation - capturing and removing contaminants within 12 inches of point of generation
  1. General Ventilation – commonly referred to as Heating Air Conditioning and Ventilation (HVAC) systems which are use to control indoor air quality.

Local exhaust ventilation is generally the preferred and more economical method of hazard control. However, dilution ventilation can be very effective in removing large volumes of air to keep concentrations of nuisance, airborne contaminants low.

5. Administrative. This method of hazard control depends on effective Standard Operating Practices or Procedures (SOPs) that prevent, control, or reduces employee exposure to chemical and physical hazards. SOP practices take the form of:

A.  Limiting access to high hazard areas to authorized Personnel ONLY

B.  Routine Preventative Maintenance Programs (PMPs) to reduce potential for equipment failure, personal injury, or overexposure resulting from hazardous substances leakage or faulty equipment operation

C.  Adjusting work schedules to limit employee exposure to hazardous material

D.  Insuring students and employees wear appropriate clothing while on UTHSCSA Campuses, remote sites, and miscellaneous holdings. Specifically:

  1. Wearing closed-toe shoes and ankle-length pants when performing laboratory or maintenance work
  2. Insuring maintenance workers wear one-piece work clothes (coveralls) or shirts tucked in at the pant waist.
  3. Insuring maintenance workers remove loose hanging articles, wedding bands, and jewelry during business hours.

6. Personal Protective Equipment. This method of hazard control is least preferred. Personal protective devices can reduce workers’ productivity, while affording less effective protection than other methods of hazardous exposure control. Nonetheless, situations where adequate levels of risk protection or reduction cannot be effectively achieved through any of the previously described methods will arise. In these instances, a combination of control methods previously outlined together with personal protective devices must be employed.

3.2. EH&S Industrial Workplace Evaluation Process

3.2.1 This evaluation is performed in accordance with Subpart I Appendix A (App A), 29 Code of Federal Regulations (29CFR), 1915. This Occupational Safety and Health Administration (OSHA) document gives useful Hazard Assessment guidelines for evaluating, Personal Protective Equipment (PPE) Selection, and PPE Training Programs.

3.2.2. This Appendix is intended to provide compliance assistance for hazard assessment, selection of personal protective equipment (PPE) and PPE training. It neither adds to nor detracts from the employer's responsibility to comply with the provisions of this subpart.

1.  Controlling hazards. Employers and employees should not rely exclusively on PPE for protection from hazards. PPE should be used, where appropriate, in conjunction with engineering controls, guards, and safe work practices and procedures.

2.  Assessment and selection. Employers need to consider certain general guidelines for assessing the hazardous situations that are likely to arise under foreseeable work activity conditions and to match employee PPE to the identified hazards. The employer should designate a safety officer or some other qualified person to exercise common sense and appropriate expertise to assess work activity hazards and select PPE.

3.  Assessment guidelines. In order to assess the need for PPE the following steps should be taken:

a. Survey. Conduct a walk-through survey of the area in question to identify sources of hazards.

Categories for Consideration:

(1) Impact

(2) Penetration

(3) Compression (roll-over)

(4) Chemical

(5) Heat

(6) Harmful dust

(7) Light (optical) radiation

(8) Drowning

(9) Falling

b. Sources. During the walk-through survey the safety officer should observe:

(1) Sources of motion; for example, machinery or processes where any movement of tools, machine elements or particles could exist, or movement of personnel that could result in collision with stationary objects

(2) Sources of high temperatures that could result in burns, eye injury or ignition of protective equipment

(3) Types of chemical exposures

(4) Sources of harmful dust

(5) Sources of light radiation, for instance, welding, brazing, cutting, heat treating, furnaces, and high intensity lights

(6) Sources of falling objects or potential for dropping objects

(7) Sources of sharp objects which might pierce or cut the hands

(8) Sources of rolling or pinching objects which could crush the feet

(9) Layout of work place and location of co-workers.

(10) Any electrical hazards

(11) Review injury/accident data to help identify problem

areas

c. Organize data. Following the walk-through survey, it is necessary to organize the data and other information obtained. That material provides the basis for hazard assessment that enables the employer to select the appropriate PPE.

d. Analyze data. Having gathered and organized data regarding a particular occupation, employers need to estimate the potential for injuries. Each hazard should be reviewed and classified as to its type, level of risk, and seriousness of any potential injury. Where it is foreseeable that an employee could be exposed to several hazards simultaneously, the consequences of such exposure should be considered.

4. Selection guidelines. After completing the procedures in paragraph 3:

(a) Become familiar with the potential hazards and the types of protective equipment that are available, and what they can do; for example, splash protection, and impact protection;

(b) Compare the hazards associated with the environment; for instance, impact velocities, masses, projectile shapes, radiation intensities, with the capabilities of the available protective equipment;

(c) Select the protective equipment which ensures a level of protection greater than the minimum required to protect employees from the hazards; and

(d) Fit the user with the protective device according to manufacturer’s instructions on care and use of the PPE. It is very important that users be made aware of all warning labels and limitations of their PPE.

5. Fitting the device.

Careful consideration must be given to comfort and fit. The employee will be most likely to wear the protective device if it fits comfortably. PPE that does not fit properly may not provide the necessary protection, and may create other problems for wearers. Generally, protective devices are available in a variety of sizes and choices. Therefore employers should be careful to select the appropriate sized PPE.

6. Devices with adjustable features.

(a) Adjustments should be made on an individual basis so the wearer will have a comfortable fit that maintains the protective device in the proper position. Particular care should be taken in fitting devices for eye protection against dust and chemical splash to ensure that the seal is appropriate for the face.

(b) In addition, proper fitting of hard hats is important to ensure that the hard hat will not fall off during work operations. In some cases a chinstrap may be necessary to keep the hard hat on an employee's head. (Chinstraps should break at a reasonably low force to prevent a strangulation hazard). Where manufacturer's instructions are available, they should be followed carefully.

7. Reassessment of hazards.

Compliance with the hazard assessment requirements of Sec. 1915.152(b) will involve the reassessment of work activities where changing circumstances make it necessary. a. The employer should have a safety officer or other qualified person reassess the hazards of the work activity area as necessary. This reassessment should take into account changes in the workplace or work practices, such as those associated with the installation of new equipment, and the lessons learned from reviewing accident records, and a reevaluation performed to determine the suitability of PPE selected for use.

8. Selection chart guidelines for eye and face protection.

Examples of occupations for which eye protection should be routinely considered are carpenters, engineers, coppersmiths, instrument technicians, insulators, electricians, machinists, mobile equipment mechanics and repairers, plumbers and ship fitters, sheet metal workers and tinsmiths, grinding equipment operators, machine operators, welders, boiler workers, painters, laborers, grit blasters, ship fitters and burners. This is not a complete list of occupations that require the use of eye protection. The following chart provides general guidance for the proper selection of eye and face protection to protect against hazards associated with the listed hazard "source" operations.

EYE AND FACE HAZARD PROTECTION SELECTION CHART

Source of Hazard / Potential Hazard / Hazard Potential Work Areas / Recommended PPE
Impact:
Chipping, grinding machining, masonry, work, woodworking, sawing, drilling, chiseling, powered fastening, riveting, and sanding. / Flying fragments, objects, large chips, particles, sand, dirt, etc. / Grounds Maintenance, Cabinet Shop, Utilities, Central Energy Plant (CEP), Welding Shop, Orthopedic Laboratory, Elevator Maintenance, Utilities, Dental School Workshops / Spectacles with side protection, goggles, face shields. See notes (1), (3), (5), (6), (10). For severe exposure, use face shield
Furnace operations, pouring, casting, hot dipping, and welding / Hot sparks / Laboratory Animal Resources (LAR), Welding Shop, Fleet Maintenance, Anatomy, Instrumentation Services, Utilities / Face shields, goggles, and spectacles with side protection. For severe exposures use face shield. See notes (1), (2), (3).
Splash from molten metals / Welding Shop, Electric Shop, Instrumentation Services / Face shield over goggles. See notes (1), (2), (3).
High Temperature exposure / Instrumentation Services, Welding Shop, Research Laboratories, Fleet Maintenance, Grounds Maintenance, Utilities / Screen face shields, reflective face shields. See notes (1), (2), (3).
Chemicals:
Acid and handling chemicals handling, degreasing, plating / Splash / Environmental Health and Safety, Utilities, Central Energy Plant, Warehouse / Goggles, eyecup and cover types. For severe exposure, use face shield. See notes (3), (11)
Irritating Mists / Grounds Maintenance, Police Department, Warehouse, Utilities / Special-purpose goggles.
Dust:
Woodworking, buffing, general dusty conditions / Nuisance dust / Dental School Workrooms, Housekeeping, Utilities, Cabinet Shop, Instrument Services, General Stores, Warehouse / Goggles, eyecup and cover types. See note (8)
Light and/or Radiation Welding: Electric Arc. / Optical Radiation / Dental School, Welding Shop, Instrumentation Services / Welding helmets or welding shields. Typical shades: 10-14. See notes (9), (12)
Welding: Gas / Optical Radiation / Welding Shop, Instrumentation Services, Electric Shop / Welding goggle or welding face shield. Typical shades: gas welding 4-8, cutting 3-6, brazing 3-4. See note (9)
Cutting, Torch Brazing, Torch Soldering. / Optical Radiation / Welding Shop, Fleet Maintenance, Computer Maintenance, Computer Resources, Instrumentation / Spectacles or welding face-shield. Typical shades,
1.5 – 3. See notes (3), (9).
Glare / Poor vision / Administrative offices, Welding Shop, Grounds Maintenance, Electric Shop, / Spectacles with shaded or special-purpose lenses, as suitable. See notes (9), (10).
3.1.2. Application of Hazard Control Principles

EH&S identifies and eliminates potential life safety occupational hazards by reviewing new construction and modification plans, operating procedures, and equipment use or replacement.

Design Reviews. Life Safety and occupational health controls shall be considered, designed, and engineered into all new UTHSCSA facilities during the programming phase. EH&S shall the review design plans and construction specifications for projects whose total cost is equal to or greater than $50,000.00.

Operating Procedures. Standard Operating Procedures (SOPs) or similar directives shall include appropriate life safety information. Leaders and Supervisor must develop SOPs on working with or handling radioactive, chemical, carcinogenic, mutagenic, or flammable material in areas where they are used. SOPs must be reviewed and approved by EH&S before implementation.

Purchasing Procedures. UTHSCSA organizations responsible for developing equipment, service, or procedural specifications must insure these documents include appropriate occupational life safety requirements and standards of protection.

3.3 Hazard Reporting

Reporting potentially unsafe or unhealthful conditions is everyone’s responsibility. Health or safety hazard report should be made in the following order to management or supervisory personnel:

1.  Work area Supervisor or Leader

or…

2.  Department Chair

or…

3.  Environmental Health and Safety, Physical Safety Manager

or

4.  The Director of Environmental Health and Safety