can you draft me an overview of what salus does so that I can share it with my field staff?

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# Occupational Safety and Health Administration (cont.) ## Appendix C to $1910.119 - Compliance Guidelines and Recommendations for Process Safety Management (Nonmandatory) (cont.) and pressure heads, compressor horsepower and vessel design pressures and temperatures are shown when necessary for clarity. In addition, major components of control loops are usually shown along with key utilities on process flow diagrams. Piping and instrument diagrams (P&IDs) may be the more appropriate type of diagrams to show some of the above details and to display the information for the piping designer and engineering staff. The P&IDs are to be used to describe the relationships between equipment and instrumentation as well as other relevant information that will enhance clarity. Computer software programs which do P&IDs or other diagrams useful to the information package, may be used to help meet this requirement. - The information pertaining to process equipment design must be documented. In other words, what were the codes and standards relied on to establish good engineering practice. These codes and standards are published by such organizations as the American Society of Mechanical Engineers, American Petroleum Institute, American National Standards Institute, National Fire Protection Association, American Society for Testing and Materials, National Board of Boiler and Pressure Vessel Inspectors, National Association of Corrosion Engineers, American Society of Exchange Manufacturers Association, and model building code groups. - In addition, various engineering societies issue technical reports which impact process design. For example, the American Institute of Chemical Engineers has published technical reports on topics such as two phase flow for venting devices. This type of technically recognized report would constitute good engineering practice. - For existing equipment designed and constructed many years ago in accordance with the codes and standards available at th…

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# Occupational Safety and Health Administration (cont.) ## Appendix C to $1910.119 - Compliance Guidelines and Recommendations for Process Safety Management (Nonmandatory) (cont.) assure that the contractor has the appropriate job skills, knowledge and certifications (such as for pressure vessel welders). Contractor work methods and experiences should be evaluated. For example, does the contractor conducting demolition work swing loads over operating processes or does the contractor avoid such hazards? - Maintaining a site injury and illness log for contractors is another method employers must use to track and maintain current knowledge of work activities involving contract employees working on or adjacent to covered processes. Injury and illness logs of both the employer's employees and contract employees allow an employer to have full knowledge of process injury and illness experience. This log will also contain information which will be of use to those auditing process safety management compliance and those involved in incident investigations. - Contract employees must perform their work safely. Considering that contractors often perform very specialized and potentially hazardous tasks such as confined space entry activities and nonroutine repair activities it is quite important that their activities be controlled while they are working on or near a covered process. A permit system or work authorization system for these activities would also be helpful to all affected employers. The use of a work authorization system keeps an employer informed of contract employee activities, and as a benefit the employer will have better coordination and more management control over the work being performed in the process area. A well run and well maintained process where employee safety is fully recognized will benefit all of those who work in the facility whether they be contract employees or employees of the owner. 8. Pre-Startup Safety. For new processes, the employer w…

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# Occupational Safety and Health Administration (cont.) ## Appendix C to $1910.119 - Compliance Guidelines and Recommendations for Process Safety Management (Nonmandatory) (cont.) to be prepared in a second language understood by the workers. In addition, operating procedures need to be changed when there is a change in the process as a result of the management of change procedures. The consequences of operating procedure changes need to be fully evaluated and the information conveyed to the personnel. For example, mechanical changes to the process made by the maintenance department (like changing a valve from steel to brass or other subtle changes) need to be evaluated to determine if operating procedures and practices also need to be changed. All management of change actions must be coordinated and integrated with current operating procedures and operating personnel must be oriented to the changes in procedures before the change is made. When the process is shut down in order to make a change, then the operating procedures must be updated before startup of the process. - Training in how to handle upset conditions must be accomplished as well as what operating personnel are to do in emergencies such as when a pump seal fails or a pipeline ruptures. Communication between operating personnel and workers performing work within the process area, such as nonroutine tasks, also must be maintained. The hazards of the tasks are to be conveyed to operating personnel in accordance with established procedures and to those performing the actual tasks. When the work is completed, operating personnel should be informed to provide closure on the job. 6. Employee Training. All employees, including maintenance and contractor employees, involved with highly hazardous chemicals need to fully understand the safety and health hazards of the chemicals and processes they work with for the protection of themselves, their fellow employees and the citizens of nearby communities. Trainin…

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U.S. DEPARTMENT OF LABOR # Occupational Safety and Health Administration - Part Number: 1910 - Part Number - Title: Occupational Safety and Health Standards - Subpart: 1910 Subpart H - Subpart Title: Hazardous Materials Standard - Number: 1910.119 AppC - Title: Compliance Guidelines and Recommendations for Process Safety Management (Nonmandatory). - GPO Source: e-CFR ## Appendix C to $1910.119 - Compliance Guidelines and Recommendations for Process Safety Management (Nonmandatory) This appendix serves as a nonmandatory guideline to assist employers and employees in complying with the requirements of this section, as well as provides other helpful recommendations and information. Examples presented in this appendix are not the only means of achieving the performance goals in the standard. This appendix neither adds nor detracts from the requirements of the standard. 1. Introduction to Process Safety Management. The major objective of process safety management of highly hazardous chemicals is to prevent unwanted releases of hazardous chemicals especially into locations which could expose employees and others to serious hazards. An effective process safety management program requires a systematic approach to evaluating the whole process. Using this approach the process design, process technology, operational and maintenance activities and procedures, nonroutine activities and procedures, emergency preparedness plans and procedures, training programs, and other elements which impact the process are all considered in the evaluation. The various lines of defense that have been incorporated into the design and operation of the process to prevent or mitigate the release of hazardous chemicals need to be evaluated and strengthened to assure their effectiveness at each Submit Feedback

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# Occupational Safety and Health Administration (cont.) ## Appendix C to $1910.119 - Compliance Guidelines and Recommendations for Process Safety Management (Nonmandatory) (cont.) If the employer wants specific employees in the release area to control or stop the minor emergency or incidental release, these actions must be planned for in advance and procedures developed and implemented. Preplanning for handling incidental releases for minor emergencies in the process area needs to be done, appropriate equipment for the hazards must be provided, and training conducted for those employees who will perform the emergency work before they respond to handle an actual release. The employer's training program, including the Hazard Communication standard training is to address the training needs for employees who are expected to handle incidental or minor releases. Preplanning for releases that are more serious than incidental releases is another important line of defense to be used by the employer. When a serious release of a highly hazardous chemical occurs, the employer through preplanning will have determined in advance what actions employees are to take. The evacuation of the immediate release area and other areas as necessary would be accomplished under the emergency action plan. If the employer wishes to use plant personnel such as a fire brigade, spill control team, a hazardous materials team, or use employees to render aid to those in the immediate release area and control or mitigate the incident, these actions are covered by $ 1910.120, the Hazardous Waste Operations and Emergency Response (HAZWOPER) standard. If outside assistance is necessary, such as through mutual aid agreements between employers or local government emergency response organizations, these emergency responders are also covered by HAZWOPER. The safety and health protections required for emergency responders are the responsibility of their employers and of the on-scene incident commander. Res…

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# APPENDIX A. REVIEW OF THE RECENT CONSTRUCTION SAFETY MANAGEMENT LITERATURE (cont.) ## OVERVIEW OF THE LITERATURE (cont.) employees in accident prevention programs and providing safety training to all workers on the site are essential to success. The literature recognizes that younger workers and non- unionized workers are particularly vulnerable to injuries and that reaching these groups requires special effort (Eastern Research Group 1991). The literature on construction management practices tends to be anecdotal, and it is primarily concerned with "success stories." For example, one of the better studies of this kind describes the experience of the Pizzagalli Construction Company, a Vermont-based heavy construction firm with approximately 30 worksites in 10 States along the East coast (Bruening 1989). In the three years after Pizzagalli implemented a construction safety man- agement program, recordable injuries were reduced by almost 48 percent, the lost-workday rate fell by 33 percent, and workers' compensation costs were cut by 76 percent. Improved training, including an initial orientation program for new employees and weekly safety talks for all employees, was considered the key to the success of this program. Other important elements, according to Pizzagalli, were a drug and alcohol abuse program, incentive awards for safety performance, and equipment inspections that were both more detailed and more frequent than those required by OSHA. In summary, the recent literature on the construction industry is unanimous in emphasizing the importance of management's role in achieving worksite safety. This focus is even more appropriate in construction than in general industry because of the dynamic nature of construction work: the changes in hazards and work crews associated with the various phases of a construction project make active and continuous management involvement and oversight essential if a safe work environment is to be maintained. For example, a…

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# Injuries Are Not Accidents: Construction Will Be Safe When It's Designed to Be Safe (cont.) ## Need for an occupational safety and health management systems approach (cont.) construction safety and health management systems (see sidebar, A success story). ## Sustaining the Construction Hazard Prevention through Design (CHPTD) movement In 2007, NIOSH established a national initiative called Prevention through Design (PtD).85 In all business deci- sions, the PtD approach emphasizes the importance of designing out, or at least minimizing, occupational haz- ards early in the design stage to prevent occupational in- juries and illnesses. The first step for the PtD launch was the 2007 National Workshop, at which stakeholders from eight sectors including construction-convened to formulate the PtD strategy. 85 Construction Hazard Pre- vention through Design (CHPtD) is a procedure in which construction engineers and architects consider the safety of construction workers as they design a facility.86 CHPTD has been recognized and implemented inter- nationally as a feasible method to reduce occupational hazards in construction-in particular in the United Construction Hazard Prevention through Design (CHP+D) is a procedure in which construction engineers and architects consider the safety of construction workers as they design a facility. Kingdom (UK) and Australia. 87 In 1995, the UK passed a law requiring architects and construction engineers to incorporate CHPtD when designing facilities.86 In contrast, in the United States, many professional organizations were not aware of the NIOSH PtD initiative in 2007. In all countries, there seem to be similar challenges in implementing CHPtD, such as designers' lack of safety expertise and additional costs, 86 but in the United States. ## A success story: One corporation's construction safety and health management system84 s a result of a partnership between AMEC Construction Management, Inc., and OSHA-a partnership A that …

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# WORKER PROTECTION PROGRAMS IN CONSTRUCTION (cont.) ## II. CONSTRUCTION SAFETY MANAGEMENT PRACTICES AND CODES OF PRACTICE (cont.) practices designed to reduce hazards and protect the safety and health of construction workers. Exhibit 1 summarizes these provisions in a format that permits a comparison of requirements across organizational lines; Exhibit 2 sets forth individual requirements in de- tail. The safety codes summarized in this section have been excerpted from: - OSHA (29 CFR Part 1926), Construction Standards; • Corps of Engineers (1992), Safety and Health Requirements Manual; - Bureau of Reclamation (1987), Construction Safety Standards; - Department of Energy (1993), Construction Project Safety and Health Management Order (draft); - American National Standards, Basic Elements of an Employer Program to Provide a Safe and Healthful Work Environment, ANSI A10.38-1991; - American National Standard for Construction and Demolition Operations-- Safety and Health Program Requirements for Multi-Employer Projects, ANSI A10.33-1992; - Association of General Contractors (AGC) (1992), Manual of Accident Prevention in Construction; - International Labour Organisation (ILO) (1992), Safety and Health in Construction: A Code of Practice; and - Council of the European Communities (EC) Directive 92/57/EEC (1992), Implementation of Minimum Safety and Health Requirements at Temporary or Mobile Construction Sites. As Exhibit 1 shows, most of these codes emphasize safety and health program and plan development, hazard prevention and control, worksite inspections, and employee training. The programs, practices, and procedures described in the standards, safety manuals, and publications of these organizations are outlined on the following pages. 5

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# Occupational Safety and Health Administration (cont.) ## Appendix C to $1910.119 - Compliance Guidelines and Recommendations for Process Safety Management (Nonmandatory) (cont.) level. Process safety management is the proactive identification, evaluation and mitigation or prevention of chemical releases that could occur as a result of failures in process, procedures or equipment. The process safety management standard targets highly hazardous chemicals that have the potential to cause a catastrophic incident. This standard as a whole is to aid employers in their efforts to prevent or mitigate episodic chemical releases that could lead to a catastrophe in the workplace and possibly to the surrounding community. To control these types of hazards, employers need to develop the necessary expertise, experiences, judgement and proactive initiative within their workforce to properly implement and maintain an effective process safety management program as envisioned in the OSHA standard. This OSHA standard is required by the Clean Air Act Amendments as is the Environmental Protection Agency's Risk Management Plan. Employers, who merge the two sets of requirements into their process safety management program, will better assure full compliance with each as well as enhancing their relationship with the local community. - While OSHA believes process safety management will have a positive effect on the safety of employees in workplaces and also offers other potential benefits to employers (increased productivity), smaller businesses which may have limited resources available to them at this time, might consider alternative avenues of decreasing the risks associated with highly hazardous chemicals at their workplaces. One method which might be considered is the reduction in the inventory of the highly hazardous chemical. This reduction in inventory will result in a reduction of the risk or potential for a catastrophic incident. Also, employers including small employers may…

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# Occupational Safety and Health Administration (cont.) ## Appendix C to $1910.119 - Compliance Guidelines and Recommendations for Process Safety Management (Nonmandatory) (cont.) need some refresher or additional training in light of the changes. Any incident investigation recommendations, compliance audits or PHA recommendations need to be reviewed as well to see what impacts they may have on the process before beginning the startup. 9. Mechanical Integrity. Employers will need to review their maintenance programs and schedules to see if there are areas where "breakdown" maintenance is used rather than an on-going mechanical integrity program. Equipment used to process, store, or handle highly hazardous chemicals needs to be designed, constructed, installed and maintained to minimize the risk of releases of such chemicals. This requires that a mechanical integrity program be in place to assure the continued integrity of process equipment. Elements of a mechanical integrity program include the identification and categorization of equipment and instrumentation, inspections and tests, testing and inspection frequencies, development of maintenance procedures, training of maintenance personnel, the establishment of criteria for acceptable test results, documentation of test and inspection results, and documentation of manufacturer recommendations as to meantime to failure for equipment and instrumentation. - The first line of defense an employer has available is to operate and maintain the process as designed, and to keep the chemicals contained. This line of defense is backed up by the next line of defense which is the controlled release of chemicals through venting to scrubbers or flares, or to surge or overflow tanks which are designed to receive such chemicals, etc. These lines of defense are the primary lines of defense or means to prevent unwanted releases. The secondary lines of defense would include fixed fire protection systems like sprinklers, water spray…

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# Occupational Safety and Health Administration (cont.) ## Appendix C to $1910.119 - Compliance Guidelines and Recommendations for Process Safety Management (Nonmandatory) (cont.) - network to receive and transmit information by telephone, radio or other means. It is important to have a backup communication network in case of power failure or one communication means fails. The center should also be equipped with the plant layout and community maps, utility drawings including fire water, emergency lighting, appropriate reference materials such as a government agency notification list, company personnel phone list, SARA Title III reports and safety data sheets, emergency plans and procedures manual, a listing with the location of emergency response equipment, mutual aid information, and access to meteorological or weather condition data and any dispersion modeling data. 14. Compliance Audits. Employers need to select a trained individual or assemble a trained team of people to audit the process safety management system and program. A small process or plant may need only one knowledgeable person to conduct an audit. The audit is to include an evaluation of the design and effectiveness of the process safety management system and a field inspection of the safety and health conditions and practices to verify that the employer's systems are effectively implemented. The audit should be conducted or lead by a person knowledgeable in audit techniques and who is impartial towards the facility or area being audited. The essential elements of an audit program include planning, staffing, conduting the audit, evaluation and corrective action, follow-up and documentation. - Planning in advance is essential to the success of the auditing process. Each employer needs to establish the format, staffing, scheduling and verification methods prior to conducting the audit. The format should be designed to provide the lead auditor with a procedure or checklist which details the requirem…

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# EXHIBIT 3. Worker Protection Program Success Stories in Construction (continued) (cont.) # EXHIBIT 3. Worker Protection Program Success Stories in Construction (continued) <table><tr><th>COMPANY NAME</th><th>DESCRIPTION</th><th>SUCCESS MEASURE(S)</th><th>KEY ASPECTS OF PROGRAM</th></tr><tr><td rowspan="3">Pizzagalli Construction Co.</td><td rowspan="3">Heavy construction firm 30 worksites in 10 States</td><td>Annual worker compensation costs reduced 76% from 1986 to 1988</td><td>Training, including mandatory site orientation and weekly safety meetings</td></tr><tr><td>General liability costs dropped 96% from 1986-88</td><td>Awards and incentives, including monthly safe project award, yearly superintendent award and savings bonds for hourly field employees</td></tr><tr><td>Approximately $1 million returned in worker com- pensation premiums in 1988 due to improved safety record</td><td>Drug and alcohol testing when accident occurs Fines for non-compliance by subcontractors Personal safety equipment inspection program Management commitment to safety</td></tr><tr><td>Shamrock Farrell Construction Co.</td><td>General contractor, Houston-based 150 employees CISE* and National Safety Award winner</td><td>Low worker compensation costs; increased productivity</td><td>Free flow of communication between hourly workers, supervisors, and managers, in keeping with modern management principles Management reviews every accident, including first-aid incidents Tool box safety talks daily and whenever workers move to new site Weekly safety training sessions Local safety council used for low-cost consulting and training Gift certificates and small gifts to reward safety excellence</td></tr></table> *Construction Industry Safety Excellence Award, given by the Business Roundtable 42

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# Occupational Safety and Health Administration (cont.) ## Appendix C to $1910.119 - Compliance Guidelines and Recommendations for Process Safety Management (Nonmandatory) (cont.) management of change provisions. In addition, the management of change procedures are used to insure that the equipment and procedures are returned to their original or designed conditions at the end of the temporary change. Proper documentation and review of these changes is invaluable in assuring that the safety and health considerations are being incorporated into the operating procedures and the process. - Employers may wish to develop a form or clearance sheet to facilitate the processing of changes through the management of change procedures. A typical change form may include a description and the purpose of the change, the technical basis for the change, safety and health considerations, documentation of changes for the operating procedures, maintenance procedures, inspection and testing, P&IDs, electrical classification, training and communications, pre-startup inspection, duration if a temporary change, approvals and authorization. Where the impact of the change is minor and well understood, a check list reviewed by an authorized person with proper communication to others who are affected may be sufficient. However, for a more complex or significant design change, a hazard evaluation procedure with approvals by operations, maintenance, and safety departments may be appropriate. Changes in documents such as P&IDs, raw materials, operating procedures, mechanical integrity programs, electrical classifications, etc., need to be noted so that these revisions can be made permanent when the drawings and procedure manuals are updated. Copies of process changes need to be kept in an accessible location to ensure that design changes are available to operating personnel as well as to PHA team members when a PHA is being done or one is being updated. 12. Investigation of Incidents. Incide…

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# PROGRAM DIRECTIVE (cont.) ## ENFORCEMENT ACTIVITY RELATED TO THE PSM STANDARD: (cont.) 2. A referral for a PSM inspection must be considered if major deficiencies are indicated. This determination must be documented in the case file. 3. Where complaints or referrals are made for PSM inspections, follow the procedures outlined in Program Directive A-219 Inspection Criteria: Complaint Policies and Procedures and the Field Inspection Reference Manual (FIRM) in evaluating the complaint/referral for action.. C. Responses to Accidents and Catastrophes: Responses to accidents and catastrophes involving PSM must follow the guidelines in Chapter 2 of the FIRM in addition to the guidelines of this Program Directive. If the employer has a PSM covered process, a referral for a PSM inspection must be considered if major deficiencies are indicated. INSPECTION RESOURCES: Appropriate levels of staff training and preparation are essential for compliance activities relating to the PSM standard. Inspections using this NEP may be conducted by either a single Oregon OSHA employee or a team. At least one member of the team or the Oregon OSHA employee must be trained in PSM. In particular, it is anticipated that PSM inspections can be highly resource-intensive; they will therefore require careful planning and coordination. A. PSM Team Members: Only trained Compliance Safety and Health Officers (CSHOS) with knowledge of PSM will be assigned to lead a PSM inspection under this standard. 1. The lead CSHO must have completed one or more courses such as: - OSHA Training Institute's (OTI) Course 3300, Safety and Health in the Chemical Processing Industries (or equivalent) • Course 3400, Hazard Analysis in the Chemical Processing Industries (or equivalent) - Course 3410, Advanced Process Safety Management (or equivalent) Page 3 A-177

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# EXHIT 2. Safety Management Practices Reflected in the Construction Standards and Guidelines of Major Organizations (continued) (cont.) # EXHT 2. Safety Management Practices Reflected in the Coruction Standards and Guidelines of Major Organizations (continued) <table><tr><th>MANAGEMENT PRACTICE</th><th>OSHA CONSTRUCTION STANDARDS (29 CFR 1926) 1971</th><th>CORPS OF ENGINEERS SAFETY AND HEALTH REQUIREMENTS MANUAL 1992</th><th>BUREAU OF RECLAMATION CONSTRUCTION SAFETY STANDARDS 1987</th><th>DOE CONSTRUCTION PROJECT SAFETY AND HEALTHI MANAGEMENT ORDER 5480.9, 1993</th><th>ANSI A10.38 BASIC ELEMENTS OF CON- STRUCTION PROGRAMS 1991</th><th>ANSI A10.33 PROGRAM REQUIREMENTS FOR MULTI- EMPLOYER PROJECTS 1992</th><th>ASSOCIATED GENERAL CONTRACTORS MANUAL OF ACCIDENT PREVENTION IN CONSTRUCTION 1992</th><th>ILO CODE OF PRACTICE, SAFETY AND HEALTH IN CON- STRUCTION 1992</th><th>EC DIRECTIVE FOR CONSTRUC- TION SITES 1992</th></tr><tr><td>TRAINING/ SAFETY MEETINGS (continued)</td><td></td><td>provisions of Corps manual; • Accident- reporting re- quirements; Facilities and pro- cedures for emer- gency response and medical treat- ment; • Unsafe conditions reporting and cor- recting; and Job-specific haz- ards and control measures. Safety meetings shall be held at least weekly for all work- ers, and meetings must be documented. Employees shall be trained to handle emergency situations. Safety meetings are to be conducted at least once a month for all supervisors; once a week by supervisors or fore- men for all workers.</td><td>Each employee shall receive training in the recognition and avoidance of job- specific hazards prior to initiating job assignment. On-site training will be pro- vided to those hand- ling specific hazard- ous materials or tools; Scheduled monthly safety meetings with the Contracting Offi- cer's Representative are to be held to re- view the effectiveness of the contractor's safety effort, lo resolve safety and health problems, and provide a forum fo…

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# Occupational Safety and Health Administration (cont.) ## Appendix C to $1910.119 - Compliance Guidelines and Recommendations for Process Safety Management (Nonmandatory) (cont.) of a preliminary hazard analysis would assist an employer in determining which process should be of the highest priority and thereby the employer would obtain the greatest improvement in safety at the facility. - Detailed guidance on the content and application of process hazard analysis methodologies is available from the American Institute of Chemical Engineers' Center for Chemical Process Safety (see appendix D). 5. Operating Procedures and Practices. Operating procedures describe tasks to be performed, data to be recorded, operating conditions to be maintained, samples to be collected, and safety and health precautions to be taken. The procedures need to be technically accurate, understandable to employees, and revised periodically to ensure that they reflect current operations. The process safety information package is to be used as a resource to better assure that the operating procedures and practices are consistent with the known hazards of the chemicals in the process and that the operating parameters are accurate. Operating procedures should be reviewed by engineering staff and operating personnel to ensure that they are accurate and provide practical instructions on how to actually carry out job duties safely. - Operating procedures will include specific instructions or details on what steps are to be taken or followed in carrying out the stated procedures. These operating instructions for each procedure should include the applicable safety precautions and should contain appropriate information on safety implications. For example, the operating procedures addressing operating parameters will contain operating instructions about pressure limits, temperature ranges, flow rates, what to do when an upset condition occurs, what alarms and instruments are pertinent if an upset co…

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# WORKER PROTECTION PROGRAMS IN CONSTRUCTION (cont.) ## I. STATEMENT OF THE PROBLEM (cont.) The literature on the effectiveness of worker protection programs in construction is largely anecdotal and pertains primarily to large companies. One of the best-documented studies of this type describes the experience of the Pizzagalli Construction Company, a Vermont-based heavy construction firm with approximately 30 worksites in 10 States along the East coast (Bruening 1989). In the two years after Pizzagalli implemented a proactive safety management program, recordable injuries were reduced by almost 48 percent, and the company's lost-workday case rate fell by 33 percent. Improved training, including an orientation program for new employees and weekly safety talks for all workers, was con- sidered the key to the success of this project. Other important elements were visible management leadership of the program, incentives for safety performance, and equipment inspections that were both more comprehensive and more frequent than those required by OSHA. A common thread running through the recent literature is the importance of manage- ment commitment in guaranteeing worksite safety. Management's role may be even more important in construction than in general industry because of the dynamic nature of construc- tion work: the changes in hazards and work crews associated with the various phases of a construction project make proactive, vigorous, and continuous management involvement essential throughout the life of each project. Annual compliance self-inspections performed by the employer may be adequate for the fixed-site operations typical of most general- industry production facilities, but daily (and sometimes even more frequent) inspections are necessary on most construction sites. The following sections of this report describe the safety management practices en- dorsed by various organizations with interest in or oversight authority for worker protection on constr…

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# Occupational Safety and Health Administration (cont.) ## Appendix C to $1910.119 - Compliance Guidelines and Recommendations for Process Safety Management (Nonmandatory) (cont.) It is important to assure that each deficiency identified is addressed, the corrective action to be taken noted, and the audit person or team responsible be properly documented by the employer. To control the corrective action process, the employer should consider the use of a tracking system. This tracking system might include periodic status reports shared with affected levels of management, specific reports such as completion of an engineering study, and a final implementation report to provide closure for audit findings that have been through management of change, if appropriate, and then shared with affected employees and management. This type of tracking system provides the employer with the status of the corrective action. It also provides the documentation required to verify that appropriate corrective actions were taken on deficiencies identified in the audit. [78 FR 9313, Feb. 8, 2013] Scroll to Top + OSHA Standards Enforcement Topics Media Center Contact Us DIPARTMENT OF LABOR UNITED STATES OF # U.S. DEPARTMENT OF LABOR Submit Feedback Occupational Safety and Health Administration [redacted street address] NW Washington, DC [redacted postal code] 1-800-321-OSHA 1-[redacted phone] www.osha.gov FEDERAL GOVERNMENTE White House - Benefits.gov - Coronavirus Resources OCCUPATIONAL SAFETY & HEALTH+ Frequently Asked Questions A - Z Index Freedom of Information Act - OSHA

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# Overview Toolbox Talks are a good and effective ways to communicate safe work practices for lead generating activities and to reinforce jobsite training. OSHA requires construction employers to have hazard communication and accident prevention programs that include worker training on hazard awareness and controls. The Lead in Construction Standard also requires that workers receive training in the contents of the lead standard and lead hazard awareness training. Toolbox Talks help satisfy these requirements. ## The most successful Toolbox Talks: • Make the topic site specific • Use actual examples form the site to illustrate the topic • Involve workers in a brief discussion about the topic • Reinforce best safety and health practices ## Overview of the Guide 1. Planning Toolbox Talks 2. Conducting Toolbox Talks 3. Toolbox Talks Topics and Worksheets • Health Effects of Lead Exposure • Engineering and Work Practice Controls • Air Purifying Respirators • Blood Lead Monitoring • Monitoring for Lead Exposure - This Guide will elaborate on these tasks - F-2 Toolbox Talks for Lead Hazards