This blog series focuses on best practices for the asset management of real property including buildings, grounds, furnishings, and equipment.

by John zumBrunnen, CEO and Founder, zumBrunnen, Inc.

Occupational Safety and Health Administration (OSHA)

“Safety first” may be a common cliché, but it is fundamental in the management of your assets, whether it be real property or the safety of employees and residents. Vital concerns involve safe practices in daily operations, equipment maintenance, and storage and handling of hazardous materials including infectious wastes. The federal government has entrusted the oversight of workplace hazards to the Department of Labor’s Occupational Safety and Health Administration, more commonly known as OSHA. OSHA inspectors can visit your community and review safety procedures and issue fines and citations if you are found to be in violation of OSHA regulations, which could also apply to incomplete or inaccurate recordkeeping and documentation or postings. OSHA is mandated to be self-funded, funded by the fines it imposes.

OSHA responds to complaints by persons reporting unsafe practices, hazardous materials, odors, and so forth. Every employer must have programs in place to comply with OSHA standards. Some key points to remember in these standards are the presence of eyewash stations, easily accessible material safety data sheets (MSDS’s), lock-out/tag-out procedures, personal protective equipment, handling hazardous and infectious waste and disposal, and incident reporting and recordkeeping. Each standard has the following main components: written program, education and training programs, material and equipment safety data logs, and inventory and record keeping. All the standards discussed below in part can be viewed in detail on the www.osha.gov website.

OSHA Hazard Communication Standard (HCS):

Protection under HCS includes all workers exposed to hazardous chemicals in all sectors; Fact Sheet No. OSHA 93-26. This standard is based on a simple concept: employees have both a need and a right to know the hazards and identities of the chemicals they are exposed to, and what protective measures are available to prevent adverse effects from occurring. The HCS covers both physical hazards (such as flammability or the potential for explosions) and health hazards (both acute and chronic effects). By identifying hazards and providing precautions for safe use, the illnesses and injuries caused by chemicals are reduced. Employees are better able to effectively participate in these programs when they understand the hazards and know the steps to take to protect themselves. Detailed records require a notebook of all Hazardous Material Data Sheets provided by manufacturers and lists of all known chemicals in use.

OSHA Standards for Lock-Out/Tag-Out Procedures:  

The OSHA standard for the Control of Hazardous Energy (Lock-out/Tag-out), Title 29, CFR, Part 1910.147 addresses practices and procedures necessary to disable machinery or equipment, thereby preventing the release of hazardous energy while employees perform service and maintenance activities. These energy sources include electrical, mechanical, hydraulic, pneumatic, chemical, and thermal sources. A lock-out/tag-out standard establishes the employer’s responsibility to protect employees from these dangers. This program is required to be tailored to your community and to suit the particular needs of the types of equipment and machines being maintained and serviced.

OSHA Standards for Bloodborne Pathogens:

In 1991, OSHA issued the Occupational Exposure to Bloodborne Pathogens Standard Title 29, CFR, Part 1910.1030, designed to protect approximately 5 to 6 million workers in healthcare and related occupations from the risk of exposure to bloodborne pathogens, such as the Human Immunodeficiency Virus (HIV) and the Hepatitis B Virus (HBV). This standard has numerous requirements, including the development of an Exposure Control Plan. It includes rules specific to certain types of wastes generated at healthcare facilities, termed “regulated waste.” Regulated waste includes blood and items contaminated with blood or other potentially infectious materials (OPIM). This standard covers the management of contaminated sharps, regulated waste, communication of hazards to employees, and training. It is important that you be aware of the employer responsibilities mandated in this standard.

OSHA Standard for Indoor Air Quality/Sick Building Syndrome:

OSHA has no indoor air quality (IAQ) standards, but it does provide guidelines addressing the most common workplace complaints about IAQ. Complaints are typically related to temperature, humidity, lack of outside air ventilation, or smoking. However, when IAQ complaints move beyond matters of comfort to potential hazardous conditions leading to serious physical harm or death, OSHA standards become applicable. Such standards may include those for specific air quality contaminants, ventilation systems, or the General Duty Clause of the OSHA Act. IAQ concerns increased during the 1970s when energy conservation measures were instituted in office buildings. These measures minimized the introduction of outside air and contributed to the buildup of indoor air contaminants. Other terms related to IAQ include indoor environmental quality (IEQ) and “sick building syndrome” (SBS).

OSHA Guidelines for Nursing Homes:

Relatively new are the Guidelines for Nursing Homes – Ergonomics for Prevention of Musculoskeletal Disorders, OSHA 3182-3R (2009), issued as recommendations designed specifically for nursing homes. The guidelines are advisory in nature and are not legal standards enforceable by OSHA. The standard primarily deals with proper techniques for positioning, re-positioning, and lifting of patients to help reduce the number and severity of musculoskeletal disorders including back pain and injuries, sciatica, rotator cuff injuries, and carpal tunnel syndrome. However, the standard does include good recommendations for other tasks such as are involved in housekeeping, cleaning, and handling of heavy items such as laundry and supplies.

OSHA has various publications, technical assistance, and compliance tools to help you and offers extensive assistance through its many safety and health programs: workplace protection programs, grants, strategic partnerships, state plans, training, and education. Guidance such as OSHA’s Safety and Health Management Program Guidelines identifies elements that are critical to the development of a successful safety and health management system. This and other information are available on OSHA’s website www.osha.gov; regional offices located in major cities can be contacted directly.

About the Author:

John zumBrunnen is Founder and CEO of zumBrunnen, Inc., an independent construction and building consulting firm founded in 1989. zumBrunnen has a BS in mechanical engineering from the University of North Dakota, completed the US Army Corps of Engineers Training Program in 1972, and is a member of LeadingAge and Community Associations Institute on national and state levels. zumBrunnen has 40+ years of experience in construction, property assessment, development, and reserve budgeting. He is the inventor of the FacilityForecast® software system and a respected author and speaker in the industry.

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