New Year's Resolution

New Year’s Resolution

Review policies and programs for compliance

Fred WorkleyBy Fred Workley

February 2001

Check company policies on required programs
Many of us are involved in safety-sensitive activities. We fall under the requirements for Alcohol and Drug Testing Program. The Federal Aviation Administration has published the testing rates for 2001 based on the number of positive tests. For aviation industry employees, a 10 percent minimum annual percentage rate continues for random alcohol testing. A 25 percent minimum annual percentage rate continues for random drug testing. Overall, the positive rates for both alcohol and drugs are very low, but these testing levels are the lowest permitted under the law. The types of operators required to have an Anti-drug Plan/Alcohol Prevention Program approved by the Drug Abatement Division of the FAA are: Part 121; Part 135;
Part 135.1(c) sightseeing only; and Part 145 Repair Stations or contractors.
Remember that contractors to Part 121, 135, and 135.1(c) certificate holders will ensure that any contract company’s employees performing covered functions are included in a FAA-approved anti-drug plan and an alcohol misuse prevention program.

Ergonomic final rule published
On November 14, 2000, the Occupational Safety and Health Administration (OSHA) published in the Federal Register, a new final rule covering ergonomics. These rules are effective January 16, 2001, and cover ailments caused by repetitive motions.
Employers must provide free medical care to workers with musculoskeletal disorders (MSD). MSD, according to the rule, is a disorder of blood vessels, muscles, tendons, nerves, joints, ligaments, cartilage and spinal discs. If any of these ailments are reported, the employer has to determine if this is an MSD incident as defined by the standard in the rule. The MSD must be categorized as causing any of the following: medical treatment other than first aid, restrictions in work performed, results in loss of days of work, or signs and symptoms that last for seven days or longer.

Documentation of programs required
The rule provides for up to 90 days of employer-paid sick leave from the job. Employers must prepare, implement, and evaluate comprehensive ergonomics programs. These programs must teach workers about the symptoms and the risks of cumulative trauma disorders. The following are the elements of the program: hazard information and reporting, management leadership, employee participation, job hazard analysis and control, management of MSD, an evaluation of the program. Employees who cannot continue to do the repetitive tasks must be moved to other jobs.
Other ergonomic risks identified by OSHA are the use of tools with high vibration levels for more than 30 minutes a day, squatting for more than two hours a day, pulling or pushing with an initial force of more than 20 pounds, and lifting more than 75 pounds at any one time.
This rule is far reaching because it affects the hand, wrist, elbow forearm, shoulder, neck, foot, ankle, knee, back and abdomen. It is not clear at this time how this new federal rule will affect the state worker compensation programs.

Did you hear that?
It may be a good time to determine if your shop has to have a Hearing Conservation Program (HCP). Inquire about both state OSHA and Worker’s Compensation Insurance standards. Servicing operations are exempt.
The elements of the HCP are as follows: noise exposure monitoring, audiometric testing, hearing protection, a training program, and record keeping. Many state programs require that the employer shall institute a training program for all employees who are exposed to noise at or above an 8-hour time-weighted average of 85 dBA and ensure each employee participates. The training program shall be repeated annually for each employee included in the hearing conservation program. The employer shall ensure that each employee is informed of the following:
1) The effects of noise on hearing; 2) The purpose of hearing protectors, the advantages, disadvantages, and attenuation of various types, and instructions on selecting, fitting and care; and 3) Access to Information and Training Materials.
The employer shall make available to affected employees or their representatives copies of the General Industry Safety Orders for Occupational Noise, usually Article 105 is state regulations, Control of Noise Exposure. A copy of this information shall also be posted in the workplace. Also, the employer shall provide to affected employees any materials pertaining to the standard that are supplied to the employer by the U.S. Department of Labor, Occupational Safety and Health Administration.

Breathe easier with a respirator program
Have you written program operating procedures that cover the specific type of respiratory protective equipment that is used in you work area? Are there provisions for medical screening of each employee assigned to wear respiratory equipment to determine if he or she is physically or psychologically able to wear a respirator? Do you assign respiratory protective equipment to employees for their exclusive use? Do you test for proper fit of the equipment? Is the equipment cleaned and sanitized regularly? Have you made provisions for proper storage? Are there provisions for periodic inspection and repair? Is there a periodic review and evaluation by the administrator of the respirator program to assure continued functioning and the effectiveness of the program? Have you documented the employee-training program in which the employee becomes familiar with the respiratory protective equipment and is trained in its proper use and limitations?

Hazmat hazards
Hazardous Materials Inspection Programs should include periodic inspections of your facilities. You should use a Hazardous Materials-Waste Aboveground Storage Area Inspection Form. Things that should be checked are as follows: storage for hazardous materials area free of spills and leaks, containers and storage area properly marked, containers within a secondary containment, fire extinguishers serviced and tagged, hazardous waste labels complete and visible, eye wash, safety showers, emergency response equipment functional, containers sealed with tight-fitting lids/bungs, incompatibles segregated, waste not stored over allowable time.
By now, you’re beginning to get the idea. You probably do most of these things in your work place already, but how would you ever prove it without records from an established, written program? While writing this article, I thought of several programs that you might review for your work place. For more programs, please see sidebar below.
Developing, implementing, maintaining, reviewing and revising policies and programs will ensure best practices and Keep ’em flying.

Get With The Program
Other safety programs to consider....

Back Injury Prevention
Compressed Air Receivers and Compressed Gas Cylinders
Electrical hazards and Electro Static Discharge
Emergency Action Plan
Fire Protection
Foreign Object Damage/Debris
Forklift and Manlift Inspection and Safety
Handling of Life Limited Parts
Inspection of transformers for PCBs and leakage
Lockout Block-out procedures for equipment capable of movement during cleaning, servicing and set up
Medical services and first aid
Receiving and Shipping Inspection
"SUPS Program" (Suspected Unapproved Parts)
Ventilation for indoor air quality

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