Work Place Safety

Is there an OSHA regulation that an eyewash station must be within a specific distance from the chemical storage?

Code requires that "Eyewash stations shall be in accessible locations that remain free of obstructions to their use and require no more than 10 seconds [or a distance of no more than 100 feet] for the injured person to reach [CCR Title 8, Section 5162 (c)]."

To clarify that statement, we suggest that the 10 second or 100 foot distance should apply to the location where the chemicals are used and or mixed, not necessarily the storage location. This is because the activity of mixing the chemical is what creates the hazard of a splash to the eyes. Also, the injured person should have to pass through no more than one door to reach the eyewash.

In the case of pesticides, the eyewash should be located near the area where the pesticides are mixed - the distance from the storage cabinet to the eyewash could be greater than 100 feet. Please see EH&S Safety Note #34 for additional information on the subject of eyewash stations.

Are fire extinguishers required to be installed on forklifts, tractors, or other non-road vehicles?

There is no direct requirement by Cal OSHA that requires a fire extinguisher on a forklift, tractors, or other non-road vehicles. However, Cal OSHA does state that all ignition sources need to be kept clear of anything that is flammable.

Best practices suggest the following:

IF you are operating your forklift or other non-road vehicle in an area that has fire extinguisher readily available, like a shop or barn, then one is not required on the vehicle.

IF you are operating a tractor or other non-road vehicle in the field and the probability of the vehicle igniting a fire is very low, then one is not required on the vehicle.

IF you are operating a tractor or other non-road vehicle in the field and there is a possibility of a fire to be caused by the vehicle then one should be on the vehicle.

If there is a fire extinguisher on the vehicle it does need to be maintained and inspected just like the other fire extinguishers and the employees need to be trained if we want them to use it.

An issue of liability has come up and we would like to know if we should continue to supply over the counter medications (i.e. Tylenol, aspirin, etc.) in our First Aid kits?

It was intentional that we left Tylenol or aspirin off the list of items that should be in a First Aid kit (Please see EH&S Safety Note #147)

Potential liability, should someone have an adverse reaction, is one reason. Another reason is that providing medication (even over-the-counter) could be construed as “diagnosis and treatment,” which can only be performed by a licensed medical professional. I know this sounds extreme, but it was the opinion of a physician advising Cal/OHSA on the subject of first aid kits. So, it was our conclusion not to recommend aspirin or other pain relievers be part of a UC-provided first aid kit. Antiseptics or antibiotic ointments are not considered “medication” and are therefore appropriate.

Employees may choose bring over-the-counter pain relievers for personal use, and may share with their co-workers, but this is not part of the employer-provided first aid kit.

I have heard that CPR (Cardio Pulmonary Resuscitation) classes will only be teaching chest compressions procedures, instead of mouth-to-mouth rescue breathing. Is this correct?

It appears that the information in the media about this topic has been somewhat confusing. It is our understanding that the Red Cross and American Heart Association still teach standard CPR with chest compressions and rescue breathing. In October 2010, the American Heart Association revised their guidelines for CPR to place the chest compressions first, before the rescue breathing. The American Red Cross is reviewing these changes but has not determined whether they will revise their training program. If you have been trained in CPR, follow your training.

You may have also heard about "Hands-Free" CPR. This is based on research that has shown that for the untrained bystander, chest compressions only were as effective as chest compressions in combination with rescue breathing.

For further information, visit the following web link: Medline Plus - Chest Compressions

For more information, see these links from the American Heart Association (AHA) and American Red Cross (ARC):

With proper training and practice, full CPR is still the recommended action, however in certain situations, chest compressions only can help.

We are planning to purchase a portable eyewash, can you recommend a model?

Grainger Industrial Supply offers preferred pricing through UCD Buy: http://ucdbuy.ucdavis.edu/mm/catalog.cfm

Models we recommend:

Mounted Units:

http://www.grainger.com/Grainger/items/2LVL4?Pid=search

http://www.grainger.com/Grainger/BRADLEY-Self-Contained-Emergency-Gravity-4YF98?Pid=search

Freestanding Units:

http://www.grainger.com/Grainger/SPERIAN-Eye-Wash-Station-6JD87?Pid=search

http://www.google.com/products/catalog?q=portable+eyewash+station&hl=en&rls=com.microsoft:en-us:IE-SearchBox&prmd=ivns&biw=1133&bih=666&bav=on.2,or.r_gc.r_pw.&wrapid=tlif130272785192910&um=1&ie=UTF-8&cid=1751991590742468772&sa=X&ei=sQymTfbrCIWasAOetZX5DA&ved=0CIwBEPMCMAc#

When do employees who work with pesticides need medical monitoring (blood testing for cholinesterase levels)?

The trigger for this blood test requirement is working with a “pesticide with the signal word “DANGER” or “WARNING” that contains an organophosphate or carbamate…” This comes from California Code of Regulations, Title 3, Section 6728 a.

The procedures that the RECs use (and I would recommend for a CE office as well) for this testing are contained in the REC Policy and Procedure: AGRICULTURAL WORKER PROTECTION STANDARD, Section E (starting on page 10).

Another relevant reference is ANR Administrative Handbook Section 281: POLICY ON PESTICIDES AND RELATED CHEMICALS: USE AND EXPERIMENTATION. Section IV.D.1.e. Medical Supervision.

A vendor has requested a copy of my Research Authorization form to order experimental pesticides for field trials that I am conducting. Where can I get this?

California Code of Regulations, Title 3, Section 6268 provides an exemption for UC employees conducting research from needing to obtain the written authorization, as long as there is policy covering the experimental use. ANR Administrative Handbook Section 281: POLICY ON PESTICIDES AND RELATED CHEMICALS: USE AND EXPERIMENTATION is written to comply with this regulation.

Providing the vendor with a copy of the policy should satisfy their request to see a Research Authorization. Please make sure you follow all the safety, posting, crop destruct, record-keeping and reporting requirements in Section III of the policy. The regulatory exemption only applies to obtaining the written Research Authorization, but the other regulatory requirements concerning the use of pesticides still apply.

Is the purchase of work boots or other protective clothing considered an allowable UC expense if the job requires it?

In some cases, work boots are required for protection from injury and should be provided by the employer (University). In the case that brought up the question, a Farm Advisor and his research assistants spend time walking in, and along irrigation ditches, and carrying heavy equipment. Due to the hazard of wet conditions and danger of dropping items on the foot, EH&S agreed that foot protection is required and should be paid for by the University. Be Smart About Safety funding cannot be used for this type of purchase because according to Be Smart guidance, funds “are not intended for replacement of general operating supplies or personal protective & safety equipment which is required by law.”

It is always best to refer specific questions like this to EH&S for review. We will consider the request and the work requirements and make a determination of whether the equipment is required and the purchase should be approved. In some cases the Business Operations Center will forward this type of request to EH&S for review and determination if the expense is a safety requirement.

For future reference, here is some relevant Code and Policy: General Industry Safety Orders

Title 8, Section 3381 - Head Protection – requires head protection when there is a risk of injury from falling or flying objects. Employer shall ensure that approved helmets are selected and used.

Title 8 Section - 3382 Eye and Face Protection – requires employees working in locations where there is a risk of receiving eye injuries such as punctures, abrasions, contusions, or burns… shall be safeguarded by means of face or eye protection. The employer shall provide and ensure that employees use protection suitable for the exposure.

Title 8, Sections 3383, 3384, and 3385 require protection of the body, hands, and feet, when the work duties expose employees to potential injury. This section does not require that the employer provide the protection, just that it be used.

Title 3, Pesticides and Pest Control Operations, Section 6738 – Personal Protective Equipment – The employer shall provide all required personal protective equipment.

UCD Policy & Procedure Manual 290-50 states “It is the policy of the University to provide employees with certain protective work clothing and personal protective equipment. Employees may be required to provide their own cold weather clothing.” It defines personal protective equipment and protective work clothing as follows:

Personal protective equipment-- equipment or devices worn or used by employees, students, or visitors to control exposure to hazardous substances to prevent occupational illnesses, accidental injuries, or serious harm to employees working in hazardous or potentially hazardous environments. Personal protective equipment specifically designed to protect the individual includes, but is not limited to, respiratory protection equipment, safety head covers, safety hats, helmets, hard hats, hearing protectors, gloves, face shields, goggles, safety glasses, safety shoes, specialized body protection equipment, ergonomic equipment, and specialized law enforcement and firefighting equipment.
Protective work clothing--attire worn over or in place of regular clothing to protect the employee's clothing from damage, exposure, or abnormal soiling or to maintain essential sanitary conditions in areas such as hospital food services, surgical rooms, animal quarantine areas, laboratory animal colonies, and "clean rooms." Protective work clothing includes surgical gowns, scrub suits, laboratory coats or smocks, coveralls, aprons, and hair nets. Certain personal protective equipment can also be considered as specialized work clothes used to protect the body from exposure or potential exposure to a hazardous environment.