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.
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a. Dilution Ventilation – reducing airborne contamination concentration
by mixing with copious amount of clean air
b.
Local Ventilation - capturing and removing contaminants within 12
inches of point of generation
c.
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:
a. Wearing closed-toe shoes and ankle-length pants when
performing laboratory or maintenance work
b. Insuring maintenance workers wear one-piece work clothes
(coveralls) or shirts tucked in at the pant waist.
c. 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.
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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
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(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.
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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
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face protection to protect against hazards associated with the listed
hazard "source" operations.
EYE AND FACE HAZARD PROTECTION SELECTION CHART
Source of Hazard
Impact:
Chipping, grinding
machining, masonry, work,
woodworking, sawing,
drilling, chiseling, powered
fastening, riveting, and
sanding.
Potential Hazard
Flying fragments,
objects, large chips,
particles, sand, dirt,
etc.
Furnace operations, pouring,
casting, hot dipping, and
welding
Hot sparks
Face shields, goggles,
and spectacles with
side protection. For
severe exposures use
face shield. See notes
(1), (2), (3).
Splash
Environmental Health
and Safety, Utilities,
Central Energy Plant,
Warehouse
Irritating Mists
Grounds Maintenance,
Police Department,
Warehouse, Utilities
Goggles, eyecup and
cover types. For
severe exposure, use
face shield. See notes
(3), (11)
Special-purpose
goggles.
Nuisance dust
Dental School
Workrooms,
High Temperature
exposure
Dust:
Woodworking, buffing,
Recommended PPE
Spectacles with side
protection, goggles,
face shields. See notes
(1), (3), (5), (6), (10).
For severe exposure,
use face shield
Laboratory Animal
Resources (LAR),
Welding Shop, Fleet
Maintenance,
Anatomy,
Instrumentation
Services, Utilities
Welding Shop, Electric
Shop, Instrumentation
Services
Instrumentation
Services, Welding
Shop, Research
Laboratories, Fleet
Maintenance, Grounds
Maintenance, Utilities
Splash from molten
metals
Chemicals:
Acid and handling chemicals
handling, degreasing, plating
Hazard Potential
Work Areas
Grounds Maintenance,
Cabinet Shop,
Utilities, Central
Energy Plant (CEP),
Welding Shop,
Orthopedic
Laboratory, Elevator
Maintenance, Utilities,
Dental School
Workshops
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Face shield over
goggles. See notes (1),
(2), (3).
Screen face shields,
reflective face shields.
See notes (1), (2), (3).
Goggles, eyecup and
cover types. See note
general dusty conditions
Housekeeping,
Utilities, Cabinet
Shop, Instrument
Services, General
Stores, Warehouse
Dental School,
Welding Shop,
Instrumentation
Services
Welding Shop,
Instrumentation
Services, Electric Shop
(8)
Light and/or Radiation
Welding: Electric Arc.
Optical Radiation
Welding helmets or
welding shields.
Typical shades: 10-14.
See notes (9), (12)
Welding goggle or
welding face shield.
Typical shades: gas
welding 4-8, cutting 36, brazing 3-4. See
note (9)
Welding: Gas
Optical Radiation
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.
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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
Employees should make immediate verbal or written report of unsafe condition(s).
Similarly, supervisors must promptly investigate reports and initiate appropriate action to
eliminate the hazard.
3.4
Hearing Protection
Exposure to hazardous noise levels greater than or equal to 85 decibels “A” weighed (>85
dBA) for more than eight hour will cause hearing loss. The chart below gives OSHA
UNPROTECTED exposure times at a 3dB exchange rate for a healthy person with
normal hearing.
Hazardous
Noise
Level in
dBA
85
88
91
94
97
100
103
106
109
Unprotected
Exposure
Time Limit
in Hours
8
4
2
1
0.5
0.25
0.125
0.06
0.03
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Unprotected
Exposure Time
Limit in
Minute
480
240
120
60
30
15
7
3
1
Supervisors of departments where employees have the potential or are actually exposed
to hazardous noise must develop a Hazardous Noise Exposure and Control Plan
(HNECP). The plan must include:
A Hearing Conservation Plan which outlines:
1. Posting the area with “Hazardous Noise Area” warning signs
2. Noise generating equipment used by personnel
3. Available Personnel Protective Equipment (PPE)
4. Baseline audiometric examination requirements
5. Routine audiometric examination requirements
6. Significant Threshold Shift (STS) management
7. Education and Training
Shop Supervisors and Leaders must make every effort to coordinate development of their
local HCP with EH&S to insure congruency between their HCP and the UTHSCSA
HNECP. Areas where employees might be routinely exposed to hazardous noise include:
1. Facilities Management
a. Central Energy Plant
b. Cabinet Shop
c. Fleet Management
d. Utilities
e. Grounds Management
f. Housekeeping
2. Print Shop
3. Dental School
3.5
Respiratory Protection
Respiratory hazards include exposure to harmful dusts, fogs, fumes, mists, gases, smoke,
sprays, and vapors. The best means of protecting personnel is through the use of
engineering controls, e.g., local exhaust ventilation. When this is unfeasible or
impractical and workers are exposed to measurable, unsafe, airborne hazardous material
concentrations, respiratory protective equipment will be used to reduce their exposure to
below the American Conference of Industrial Hygienists (ACGIH) Documented
Occupational Exposure Level (OEL).
EH&S is responsible for the UTHSCSA Respiratory Protection Program addressed in 29
CFR 1910.134. Before employees are outfitted with respirators, they must:
1. With the exception of a moustache, remove all facial hair
2. Undergo medical examination to verify good health and capacity to wear a
respirator without it adversely affecting their health or well-being.
3. Attend and successful complete an EH&S sponsored Respirator Use,
Maintenance, and Fit Test training class
5. Be successfully trained and qualitatively fit tested by a certified trainer.
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6. Workers requiring the use of tight fitting respirators must first obtain medical
approval from UT Employee Health Services to wear a respirator before a
respirator can be issued. The written respiratory protection program is
maintained by Physical Safety in separate document and can be obtained by
contacting Physical Safety.
Leaders and Supervisors of employee who are exposed to measurable airborne
concentrations of harmful compounds must develop a local Respiratory Protection Plan
(RPP) tailored to suit their workers and specific operations. The UTHSCSA, EH&S,
Respiratory Protection Program, 2004 outlines RPP fundamentals necessary for
development of work specific respiratory protection programs.
4.0
General Contractor Safety Requirements
Contractor or Contractor Personnel working on UTHSCSA Campuses or holdings
must:
1. Have current, General Liability Insurance or Insurance Plan
2. Current, Workers Compensation Insurance or Insurance Plan
3. Written company Safety Plan covering:
a. The scope of work to be performed on UTHSCSA property
or holdings.
b. Appropriate Personal Protective Equipment for the duration
of the project and for the scope of work to be performed.
c. Certify all lifting, powered industrial, cranes, earth moving
and other heavy equipment are certified safe for operation
in accordance with applicable regulatory standards and/or
Manufacturer Use Guidelines.
d. Obtain written approval from the Director, Facilities
Management, 72 hours prior to beginning ANY digging or
trenching on UTHSCSA property or holdings.
4. Erect appropriate barricades, shielding, postings, and covers to protect
UTHSCSA faculty, staff, and students from ANY hazards created during
the scope of work to be performed on UTHSCSA property or holdings.
5. Provide written notification to UTHSCSA Facilities Management and
Environmental Health and Safety of any impairment of Fire and Life
Safety Systems including Fire Alarm Control Panels (FACP), Fire Alarm
Initiating or Signaling Device, Smoke Detector, Fire Hydrant, Sprinkler
System [in part or whole], Fire Pump, or Control Valve [of ANY type].
Non-UTHSCSA employees are not authorized to impair any Fire & Life
Safety System [in part or whole] without direct supervision and prior
approval from UTHSCSA Facilities Management or Environmental
Health & Safety.
6. Obtain a Hot Work Permit from Environmental Health and Safety prior
to initiating ANY work that could generate sparks or require use of open
flame [torches].
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7. Remove all hazardous or potentially hazardous materials and hazardous
wastes generated during the course of work from UTHSCSA premises or
its holdings immediately or upon substantial completion of the scope of
work.
8. Minimize, contain, or control noise, particulates [dust], or gaseous
emissions while executing the Scope of the Work of the Contract. Develop
and coordinate plans to prevent or avoid entrainment into UTHSCSA
outside air intakes.
9. Immediately notify UTHSCSA Police at (210) 567-2800 of any
emergency condition affecting Health Science Center property, facilities,
or personnel.
UTHSCSA Environmental Health and Safety reserves the right to immediately
seek dissolution of any Contract and Terms of Agreement between UTHSCSA
and Contractor(s) for failure to follow requisite State, Local, or Federal
Regulatory Standards or the above Safety requirements. Under these
circumstances, all Contractor personnel will be immediately ejected from
UTHSCSA property and holdings by campus police.
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