Review procedures for Flammable/Combustible Materials
Review procedures for Materials Handling, Lift Trucks and Powered Industrial Trucks
Review procedures for New Installations, Facilities and/or Processes
Review procedures for System Safety Management
Review procedures for Transportation and Vehicles
Review Walkways, Stairs, Ladders and Mechanical Scaffolding Procedures
Training Programs
Review procedures for Management and Supervisory Training
Review procedures for New and Transferred Employees
Review procedures for Production Employee Training
Work Behavior
Review Work Behavior Procedures
New projects
Silver Bay
EAW by Jan 1
Groundwater Monitoring
Inspect monitoring well
Sample monitoring well
Determine direction of groundwater flow
Conduct statistical test on groundwater monitoring results
Submit groundwater elevation, sample analysis and statistical results to implementing agency
Audit sampling procedures and field techniques
Document well abandonment
Evaluate monitoring data for anomalous data or significant trends
Maintain required documentation
Perform QA/QC review on laboratory procedures
Prepare groundwater monitoring plan
Review and update groundwater monitoring plan
Review and update sampling and analysis plan
Train sampling crew
Verify monitoring wells are installed according to required technical specifications
Hazardous Waste Management for Generators
HW General Requirements
Determine hazardous waste generator status
Determine if waste is hazardous
Maintain required hazardous waste records
Obtain EPA indentification number
HW Manifesting
Verify exception reports are filed when necessary
Verify required manifesting procedures are followed
HW Storage
Control emissions from storage units containing volatile organic compounds (VOC)
Inspect hazardous waste storage areas
Verify compliance with regulatory requirements concerning the use and management of hazardous waste containers
Verify compliance with regulatory requirements for satellite accumulation areas
Prepare contingency plan
Large Quantity Generators (LQG)
Conduct hazardous waste generator training
Inspect and maintain emergency response equipment
Maintain hazardous waste training records
Review and amend contingency plan
Submit contingency plan to required agencies and responders
Submit generator report
Verify arrangements with emergency response organizations
Verify waste is not stored onsite for more than 90 days without a permit
Small Quantity Generators (SQG)
Post emergency information next to telephone
Verify employees are familiar with waste handling and emergency procedures
Verify storage time and quantity limitations are not exceeded
ISO 14001 Gap Analysis Questions
Has an Environmental Manager been appointed to coordinate ISO 14001?
Do you know what to include in your ISO 14001 system?
Have you issued an Environmental Policy statement?
Are you using a procedure to assess your significant environmental risks?
Have you identified and understand relevant environmental laws?
Are you achieving your environmental objectives?
Do operational staff have environmental responsibilities?
Are top management allocating resources to environmental management?
Do your employees understand how their work can affect the environment?
Do you have a system for internal and external communications?
Do you have an Environmental Manual of policies and procedures?
Do you involve suppliers and contractors in environmental management?
Do you have plans to protect the environment in emergencies?
Do you measure your emissions and waste?
Arre you using a procedure to check for compliance with applicable laws and regulations?
Are you using a system for handling nonconformances (corrective actions)?
Do you have a system for keeping and managing environmental records and documents?
Do you have a procedure for auditing your ISO 14001 Environmental Management System (EMS)?
Have you audited all your operations?
Have your senior executives completed a management review?
ISO 14001 Standards
Environmental Management System Requirements
Environmental Policy
Ensure policy is appropriate to the nature, scale and environmental impacts of its activities, products or services
Ensure policy is available to the public
Ensure policy is documented, implemented, maintained and communicated to all employees
Include committment to comply with relevant legislation and regulations
Include committment to continual improvement and prevention of pollution
Provide framework for setting and reviewing environmental objectives and targets
Implementation and Operation
Communication
Consider processes for external communication on significant environmental aspects and record decision
Establish and maintain procedures for internal communication between levels and functions of the organization
Establish and maintain procedures for receiving, documenting and responding commnication from external parties
Document Control
Ensure documents are legible, dated (including revision dates), identifiable, maintained in an orderly fashion and reetained for a specified period
Ensure that current versions of documents are available to all locations that need them to follow the requirements of the environmental management system
Ensure the adequancy of documents is approved by authorized personnel
Establish and maintain procedures for controlling all documents required by the international standard
Establish and maintain procedures for creating and modifiying documents
Identify obsolete documents retained for legal purposes
Periodically review and revise documents as necessary
Remove obsolete documents from all points of use
Emergency Preparedness and Response
Establish and maintain procedures for preventing and mitigating environmental impacts associated with accidents and emergency situations
Establish and maintain procedures to identify and respond to accidents and emergency situations
Periodically test emergency response procedures
Review and revise as necessary emergency prepardness and response procedures
Environmental Management System Documentation
Establish and maintain information, in paper or electronic form, that describes the core elements of the management system and their interaction
Establish and maintain information, in paper or electronic form, that provides direction to related documentation
Operational Control
Communicate relevant procedures and requirements to suppliers and contractors
Establish and maintain procedures to cover situations whose absence could lead to deviations from the stated environmental policy
Establish and maintain procedures to identify significant environmental aspects of goods and services used by the organization
Identify operations and activities (including maintenance) that are assosciated with significant environmental aspects
Stipulate operating criteria for all procedures
Structure and Responsibility
Appoint management representative(s) to ensure the environmental management system has been implemented in accordance with the international standard
Appoint management representative(s) who will report on the performance of the environmental management system
Defines roles, responsibilities and authorities regarding environmental management
Provide necessary resources essential to the implementation and control of the environmental management system
Training, Awareness and Competence
Ensure personnel performing tasks that can cause significant environmental impacts are competent on the basis of education, training or experience
Establish and maintain procedures for training employees about conformance with environmental policy and procedures
Establish and maintain procedures for training employees about significant environmental impacts and the benefits of improved personal performance
Establish and maintain procedures for training employees about the potential consequences of departure from specified operating procedures
Establish and maintain procedures for training employees about their roles and respnsibilities in achieveing conformance with the environmental policy and procedures
Identify training needs for the organization
Train personnel whose work will have a significant impact on the environment
Management Review
Document review of environmental management system
Review environmental management system to ensure its suitability, adequacy and effectiveness
Planning
Environmental Aspects
Ensure aspects related to significant impacts are considered in setting environmental objectives
Establish and maintain procedures to identify environmental aspects of activities, products or services
Keep information relating to environmental aspects up-to-date
Environmental Management Programs
Amend environmental programs when necessary to ensure management applies to new or modified developments or activities
Designate responsibility for achieveing objectives and targets for all relevant functions and levels within the organization
Establish and maintain program to achieve environmental objectives and targets
Identify time-frame for achieveing objectices and targets
Legal and Other Requirements
Establish and maintain procedures to identify legal requirements applicable to environmental aspects of activities, products and services
Objectives and Targets
Consider legal requirements, significant environmental aspects, technological options and financial, operational and business requirements when establishing objectives
Establish and maintain documented environmental objectives and targets for all relevant functions and levels within the organization
Make environmental objectives consistent with the environmental policy
Checking and Corrective Action
Environmental Management System Audit
Determine if environmental management system conforms to requirements of the international standard
Determine if environmental management system has been properly implemented and maintained
Establish and maintain procedures for periodic environmental management system audits
Provide audit results to management
Monitoring and Measurement
Calibrate and maintain monitoring equipment
Establish and maintain documented procedures for periodically evaluating compliance with relevant environmental legislation and regulations
Establish and maintain procedures to monitor and measure key characteristics of operations and activities that have a significant impact on the environment
Record information to track performance, operational controls and conformance with environmental objectives and targets
Retain calibration and maintenance records
Non Conformance and Corrective and Preventive Action
Establish and maintain procedures for defining responsibility and authority for handling and investigating nonconformance, mitigating impacts and initiating and completing corrective actions
Implement and record changes to esablished procedures as a result of corrective and preventative actions
Records
Ensure environmental records are legible, identifiable and traceable to the activity, product or service involved
Ensure environmental records are stored and maintained so they are readily retrieveable and protected against damage
Establish and maintain procedures for the identification, maintenance and disposition of environmental records
Establish and record retention times
PCB Management
Clean up PCB spill
Determine if transformers contain PCBs
Inspect PCBs and PCB items in storage
Label PCB items with appropriate marking containing required information
Maintain annual documentation log
Maintain inspection records and maintenance histories for required period of time
Notify USEPA of PCB spill
Notify USEPA of waste handling procedures when managing PCB storage
Prepare annual documentation log
Register PCB transformers with local fire response organization
Register PCB transformers with USEPA
Remove and dispose of PCB transformer
Remove PCB transformers that pose a risk to food or feed
Repair PCB transformer
Replace PCB transformer
Submit 1-year exception report for storage
Verify annual documentation log contains all required information
Verify cleanup of PCB spills and remediation are conducted according to regulatory requirements
Verify combustible materials are not stored too close to PCB transformers
Verify decontamination of non-porous surfaces and concrete of PCBs meets regulatory requirements
Verify exception reports are filed when necessary
Verify laboratories who store, transport or dispose of PCBs meet specific regulatory requirements
Verify PCB transformers in railroad locamotives or self-propelled cars comply with specific regulatory requirements
Verify PCB transformers near commercial buildings comply with specific regulatory requirements
Verify PCBs and PCB items are stored according to regulatory requirements
Verify PCBs used in air compressors comply with specific regulatory requirements
Verify PCBs used in breakers, reclosers and cable comply with specific regulatory requirements
Verify PCBs used in capacitors comply with specific regulatory requirements
Verify PCBs used in electromagnets, switches and voltage regulators comply with specific regulatory requirements
Verify PCBs used in heat transfer systems comply with specific regulatory requirements
Verify PCBs used in hydraulic systems comply with specific regulatory requirements
Verify PCBs used in natural gas pipeline systems comply with specific regulatory requirements
Verify PCBs used in scientific instruments systems comply with specific regulatory requirements
Verify required manifesting procedures are followed
Verify used oil with PCBs is managed according to specific regulatory requirements
Petroleum Underground Storage Tanks (UST)
Design, Construction, Installation and Notification (New UST Systems)
Notify state implementing agency of bringing UST system into use
Request installer certify UST system installation meets requirements
Verify UST system installation meets performance standards for corrosion protection
Verify UST system installation meets performance standards for spill and overfill protection
Verify UST system installation meets release detection standards for piping
Verify UST system installation meets release detection standards for tanks
Verify UST system is compatible with stored substance
Financial Responsibility
Demonstrate financial responsibility
Submit required financial responsibility forms
General Operating Requirements
Inspect cathodic protection system
Maintain and operate cathodic protection system
Maintain required spill containment and overfill prevention equipment
Maintain up-to-date list of USTs
Release Detection
Release Detection for Piping
Conduct groundwater monitoring
Conduct interstitial monitoring
Conduct tightness test on suction piping
Conduct vapor monitoring
Determine whether suction piping meets required criteria for not conducting release detection
Equip pressurized piping with line leak detector
Release Detection for Tanks
Conduct automatic tank gauging and inventory control
conduct groundwater monitoring
Conduct interstitial monitoring
Conduct vapor monitoring
Release Reporting, Investigation and Confirmation
Contain and clean up spill or overfill
Investigate and confirm suspected release
Report release from spill or overfill
Report suspected release
Release Response and Corrective Action
Comply with special clean up conditions imposed by implementing agency
Initiate corrective actions upon confirming release
Monitor clean up activities
Notify implementing agency of clean up acivities
Remove free product
Submit corrective action plan to implementing agency
Verify corrective action plan properly addresses site remediation
Reporting and Recordkeeping
Maintain required closure records
Maintain required corrosion protection records
Maintain required overfill prevention and spill containment equipment records
Maintain required release detection records
Maintain required repair records
Submit registration fee
UST Closure
Comply with all applicable performance requirements for a temporarily closed UST
Conduct closure assessment of excavation zone
Notify implementing agency before beginning closure change-in-service activities
Permanently close or upgrade UST system temporarily closed for more than 12 months
Submit closure assessment to implementing agency
Upgrading and Repair of Existing UST Systems
Conduct repairs according to a recognized code of practice
Inspect UST repairs
Verify repairs will prevent releases due to structural failure or corrosion
Verify upgraded UST system meets requirements
Pretreatment
General Requirements for Pretreatment
Verify discharges (categorical) are in compliance with minimum standards or more stringent permit or local requirements
Verify discharges (noncategorical) are in compliance with permit limits
Monitoring Requirements for Pretreatment
Pretreatment Permit
Obtain permit
Renew permit
Verify compliance with permit conditions
Recordkeeping Requirements for Pretreatment
Maintain records of all monitoring results
Reporting Requirements for Pretreatment
Notify control authority if an upset, bypass or substantial change occurs that will cause noncompliance with applied standards
Notify control authority if sampling indicates a violation of applied standards
Notify POTW of bypass
Notify POTW of discharges that would be a hazardous waste if otherwised disposed of
Submit baseline report
Submit monitoring data to implementing control authority
Tanks
Monitor tanks
Process Wastewater
General Requiements for Wastewater
Develop program for Best Management Practices (BMP)
Identify all discharge points
Review wastewater discharges to determine if modifications to existing permits are required
Review wastewater discharges to determine if new permits are required
Train treatment plant personnel
Verify discharges are in compliance with permit conditions
Verify that unauthorized materials are not put down sewer or otherwised discharged
Verify treatment plant is operated in compliance with permit conditions
Verify treatment plant operators are certified
Monitoring Requirements for Wastewater
Conduct NPDES monitoring
Observe permitted discharge
NPDES Permit
Renew NPDES permit
Submit NPDES permit application
Verify all permit conditions are being met
Recordkeeping Requirements for Wastewater
Maintain required documentation
Maintain required treatment plant operating logs and records
Reporting Requirements for Wastewater
Report incidence of noncompliance to implementing agency
Submit monitoring results to implementing agency
Risk Management Plan (RMP)
General Requirements (RMP)
Determine if any regulated substances exceed threshold quantities
Determine program status
Maintain records of Offsite Consequence Analysis (OCA)
Maintain required documentation
Review and update Offsite Consequence Analysis (OCA)
Review and update RMP
Submit RMP
Program 1
Evaluate size of affected population and any environmental receptors potentially exposed to an accidential release
Prepare 5-year accident history
Prepare worst-case-release scenario analysis
Program 2
Develop management system
Develop prevention program
Evaluate size of affected population and any environmental receptors potentially exposed to an accidential release
Implement emergency response program
Prepare 5-year accident history
Prepare worst-case-release scenario analysis
Program 3
Collect safety information and conduct Process Hazards Analysis (PHA)
Conduct compliance audit
Conduct incident investigation
Develop and implement written procedures to manage changes and conduct pre-startup reviews
Develop contractor control program
Develop employee participation program
Develop hot work permit program
Develop management system
Develop mechanical integrity program
Develop operating procedures
Develop prevention program
Evaluate size of affected population and any environmental receptors potentially exposed to an accidential release
Implement emergency response program
Prepare 5-year accident history
Prepare worst-case-release scenario analysis
Train all employees who are involved in operating a covered process
Safety - Adminstrative
OSHA Poster
Post OSHA workplace poster in a prominent location where all employees are likely to see it
OSHA Recordkeeping
Complete supplemental record for each recordable injury or illness per OSHA Form 101
Enter recordable injuries and illnesses on log no later than six working days after receiving information
Maintain log and summary of all recordable injuries and illnesses on OSHA Form 200 or equivalent
Post an annual summary of occupational illnesses and injuries during the month of February on OSHA form 200
Report orally to OSHA within eight hours the death of any employee or hospitalization of three or more employees
Retain OSHA forms and supplemental information pertaining to recordable injuries and illnesses for five years following the end of the year to which they relate
Safety - General Industry Standards
Bloodborne Pathogens
Document assigned employees who refuse Hepatitis vaccine have signed declination form
Establish engineering and work practice controls to minimize employee exposure
Identify employees assigned as designated first aid providers
Implement exposure control plan
Provide Hepatitis B vaccination to all employees with occupational exposure
Provide post-exposure follow-up to employees
Review and upddate exposure control plan
Train employees with occupational exposure at time of initial assignment and at least annually thereafter
Verify exposure control plan contains required information and is up-to-date
Verify medical records are being kept for the duration of employment plus 30 years
Verify protective equipment is provided and properly maintained as necessary
Verify training program covers all required topics
Verify training records are kept for three years and contain the necessary information
Verify universal precautions are observed when there is contact with blood or other potentially infectious materials
Verify written opinions are being provided for Hepatitis B vaccination and post-exposure follow-up
Compressed Gases
Conduct safety visual inspection of compressed gas cylinders
Conduct training of employees who handle or use compressed gases
Verify all cylinders bear identification of their contents
Verify compressed air is not used for cleaning execpt where reduced to less than 30 psi (dead-end pressure) with effective chip guarding and PPE
Verify training is documented
Confined Spaces
Determine if contractors whose work involves permit space entry meet regulatory requirements
Determine if effective measures have been implemented to prevent employees from entering permit spaces if that is the policy
Evaluate alternate procedures for entering permit spaces
Evaluate procedures for reclassifying a permit space to a non-permit space
Evaluate workplace to determine if any permit-required confined spaces exist
Implement written permit space program if employees enter permit spaces
Post danger signs identifying the existance and location of permit spaces
Retain cancelled entry permits for at least one year
Review permit space program and amend if necessary
Train employees who enter permit spaces and document training
Cranes, Hoists and Slings
Overhead and Gantry Cranes
Conduct initial inspection of new and altered cranes
Establish preventative maintenance program based on manufacturer's recommendations
Inspect all ropes at least monthly and document completion of inspection
Inspect cranes idled for between 1 to 6 months before placing back into service
Inspect cranes idled for over 6 months
Inspect standby cranes at least semiannually
Perform frequent and periodic inspections on cranes in regular use
Test new and altered cranes prior to initial use
Verify an appointed person performs and documents an inspection on all ropes which have been idle for a month or more before they placed back into service
Verify only designated personnel operate a crane
Slings
Maintain records of the most recent month in which alloy steel chains slings where thoroughly inspected
Prohibit the use of knots, bolts or other devices to shorten slings
Remove from service wire rope slings that are kinked, crushed, bird caged or otherwised damaged
Verify a competent person inspects slings and all fastenings and attachments for damage or defects each day before being used
Electrical Safety
Develop a written de-energization procedure or have a copy of 1910.333(b) available to employees
Inspect portable cord and plug connected equipment before use on any shift
Maintain vehicles or mechanical equipment at least 10 feet from energized overhead power lines
Train employees who face a risk of electrical shock
Verify ladders are made with nonconductive side rails if employees are exposed to energized parts
Verify live parts have been de-energized before employees work near them
Verify locks and tags are placed on each disconnecting means used to de-energize circuits
Verify overhead lines have been de-energized and ground them or provide other protective measures if work is performed near them
Verify required reenergization procedures are followed
Emergency Exits
Maintain means of egress free from obstructions and impediments
Mark accesses to exits not readily visible with signs
Mark exits with readily visible signs
Verify alarms or devices installed to restrict improper use of exits do not imped emergency use
First Aid
Provide means for quick drenching or flushing of the eyes and body in areas where corrosive liquids or materials are handled
Verify at least one employee per shift is qualified to render first-aid if medical or first-aid facilities are not in the proximity of the workplace
Verify first-aid supplies have been approved by a physician
Emergency Eyewash and Shower Stations
Flush emergency eyewash and shower stations for 3 minutes each week
Verify bottled eyewash solutions and containers are properly maintained
Verify emergency eyewash or shower stations are available when the eyes, face or other parts of the body may be exposed to harmful substances
Verify portable eyewash stations are properly maintained
Emergency Management and Fire Prevention
Establish emergency alarm system that complies with 1910.165
Prepare emergency action plan
Train employees covered by emergency action plan
Exposure to Chemical Hazards
Determine if employee's exposure to any substance listed in Tables Z-1, Z-2 or Z-3 exceeds limits given for that substance
Implement administrative or engineering controls to achieve acceptable exposure limits
Issue protective equipment as needed to keep exposure of employees within acceptable limits
Verify competent industrial hygienist or other technically qualified person selects equipment or technical measures used to achieve acceptable exposure limits
Verify required "computation formulae" is used when determining employee exposure
Fire Protection Brigades and Systems
Fire Brigades
Implement an organizational statement establishing the fire brigade
Train all fire brigade members at least annually
Train all fire brigade members who will perform interior structural fire fighting at least quarterly
Verify employees expected to do interior structural firefighting are physically capable of performing duties
Verify required protective clothing is made available to employees who perform interior structural fire fighting
Verify required respiratory equipment is made available to employees who perform interior structural fire fighting
Fixed Fire Suppression Equipment
Automatic Sprinkler Systems
Open inspector's test valve at least every two years
Perform main drain flow test annually
Fixed Extinguishing Systems (Dry Chemical)
Sample dry chemical at least annually to ensure it is free of moisture
Fixed Extinguishing Systems (Gaseous Agent)
Fixed Extinguishing Systems (General)
Inspect fixed fire extinguishing system annually to assure proper maintenance and operation condition
Inspect refillable containers at least semi-annually
Post warning signs when hazardous agents are used
Train employees desiganated to inspect, maintain, operate and repair fixed extinguishing systems
Fixed Extinguishing Systems (Water Spray and Foam)
Other Fire Protection Systems
Employee Alarm Systems
Establish procedures for sounding emergency alarms in the workplace
Test reliability of all supervised employeee alarm systems at least annually
Test reliability of non-supervised employee alarm systems once every two months
Fire Detection Systems
Clean fire detectors at regular periodic intervals
Test and adjust fire detection systems
Standpipe and Hose Systems
Inspect and rerack hemp or linen hose at least annually
Inspect hose systems at least annually and after each use
Flammable and Combustible Liquids
Place fire control devices in areas where flammable liquids are stored or used
Post signs to prohibit smoking in fueling areas or where flammable or combustible liquids are received, dispensed or stored
Protect fuel pumps from damage from collision
Store flammable and combustible liquids in closed containers or tanks
Verify nozzle and container are electrically interconnected(bonded) when transferring class 1 liquids
Verify power shut-off controls for fuel pumps are remotely located, clearly identified and readily accessible
Verify vent pipes from underground storage tanks are higher than the fill pipe opening and not less than 12 feet above the adjacent ground level
Fueling Stations
Post conspicuous "No Smoking" signs
Post fire extinguishers near pumps
Protect fuel dispensing units
Provide flammable or explosion proof electrical wiring around fuel dispensing units
Verify fuel is dispensed only from valves that meet regulatory requirements
Hand and Portable Powered Tools and Other Hand-Held Equipment
General Requirements for Hand and Portable Powered Tools and Equipment
Verify cleaning nozzles emit not more than 30 psi of pressure
Guarding of Portable Powered Tools
Verify all portable power tools are properly grounded
Verify portable grinders are completely and adequately guarded
Verify portable power tools are equipped with appropriate guards
Other Portable Tools and Equipment
Hazard Communication
Develop and maintain list of hazardous chemicals known be present in workplace
Develop material safety data sheets for each hazardous chemical produced or imported
Implement and maintain a written hazard communication program
Label containers of hazardous chemicals with appropriate information
Maintain copies of material safety data sheets for all hazardous chemicals and ensure they are readily accessible during all work shifts
Obtain material safety data sheets for all hazardous chemicals used
Train employees on hazardous chemicals in their work areas
Verify chemical information withheld because of trade secert claims is supported
Verify material safety data sheets are provided with shipments of hazardous chemicals
Verify material safety data sheets contain required information
Hazardous Waste Operations and Emergency Response
Implement an incident command system (ICS) for handling emergency response
Implement emergency response plan
Provide medical surveillance and consultation to designated HAZMAT team members
Provide refresher training at least annually
Provide suitable chemical protective clothing and equipment to HAZMAT team members
Train employees who are involved in emergency response operations
Warn employees about facial conditions that may prevent a good seal
Spray Fininshing
Post "No Smoking" signs conspicuously at all paint spraying areas and paint storage rooms
Store bulk quantities of flammable and combustible liquids in portable containers in a separate building
Verify the quantity of flammable and combustible liquids in the vicinity of spraying operations is kept to a minimum
Ventilation
Verify supply of fresh air is adequate in spray booths and open surface tanks
Verify ventilation system adequately removes toxic dust, vapors and gases from working environment
Verify ventilation systems meet the standards for grinding, polishing and buffing operations
Verify ventilation systems meet the standards for open surface tanks
Verify ventilation systems meet the standards for spray finishing operations
Walking and Working Surfaces
General Requirements for Walking-Working Surfaces
Inspect and maintain ladders on a regular basis
Mark permanent aisles and passageways and keep clear
Post load limit weights in storage areas
Provide guardrails or covers to prevent persons from falling into ditches open pits, vats, tanks, etc.
Verify floor holes in which persons could accidentially walk are properly guarded
Verify floors are clean and dry
Verify hatchway and floor openings are properly guarded
Verify stairs are equipped with required railing(s) or handrails(s)
Safety Requirements for Scaffolding
Provide guardrails and toeboards on all open sides and ends of scaffolds more than 10 feet above the ground or floor
Remove from service bent, excessively rusted, altered or structurally damaged scaffold frames or accessories
Verify scaffold planks extend over end supports not less than six inches nor more than 18 inches
Verify scaffolds are properly braced and are always plumb, square and rigid
Verify scafolds and components are capable of supporting without failure at least four times the maximum intended load
Welding, Cutting and Brazing Operations
General Requirements for Welding, Cutting and Brazing
Clean all drums, barrels, tanks or other containers so flammable materials or flammable or toxic vapors are not present before welding, cutting or other hot work is performed
Provide mechanical ventilation as required
Replace cables when insulation is damaged or conductors are bare
Verify all fire hazards in the vicinity of welding or cutting are removed or guarded
Verify confined spaces are adequately ventilated to prevent buildup of toxic materials or oxygen deficiencies
Verify first aid equipment is available at all times
Verify helpers or attendants are wearing appropriate protective equipment
Verify manufacturer's instructions and rules for welding are followed
Verify welding cables with splices within 10 feet of the holder are not used
Verify workers in adjacent areas are properly protected by shields or screens or wearing goggles
Oxygen-Fuel Gas Welding and Cutting
Legibly mark all compressed gas cylinders to indicate their contents
Store cylinders where they will not be knocked over, damaged or subject to tampering
Verify acetylene cylinder valves open no more than one and one-half turns of the spindle
Verify oxygen cylinders are separated from fuel-gas cylinders or combustible materials by at least 20 feet or an appropriate non-combustible barrier
Verify valve protection caps are in place on cylinders not in use
Verify valves are closed when cylinders are moved, empty or work is finished
Resistance Welding
Periodically inspect resistance welding equipment and document inspections
Ergonomics
Conduct job evaluation to determine if ergonomic standard applies
Implement ergonomic program
Prepare and implement Management Leadership and Employee Participation program element
Prepare and implement Hazard Analysis and Control program element
Prepare and implement Job Hazardous Analysis`and Control program element
Prepare and implement Training program element
Prepare and implement MSD Management program element
Prepare and implement Program Evaluation program element
Implement Quick Fix and eliminate MSD hazards
Evaluate Quick Fix to ensure controls have eliminated MSD hazard
Conduct job hazard analysis
Identify, assess and implement feasible controls
Conduct MSD training
Review and update ergonomics program
Verify compliance with record retention requirements
Storm Water
General Requirements for Storm Water
Conduct Comprehensive Site Compliance Evaluation
Conduct SWPPP training
Implement additional management requirements for Section 313 chemicals
Monitoring Requirements for Storm Water
Conduct storm water monitoring
Storm Water Permit
Renew storm water permit
Submit storm water permit application
Storm Water Pollution Prevention Plan (SWPPP)
Prepare SWPPP
Review and update SWPPP
Verify Best Management Practices (BMP) are properly implemented
Used Oil Management for Generators
Evaluate used oil to determine if it is a hazardous waste
Label storage containers
Review used oil disposal facility for regulatory compliance
Review used oil recycler for regulatory compliance
Review used oil transporter for regulatory compliance
Verify used oil filters are managed according to regulatory requirements
Verify used oil is burned in space heaters meeting regulatory requirements
Verify used oil is stored properly
Verify used oil mixtures are managed according to regulatory requirements
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Aboveground Storage Tanks (AST)
Conduct asbestos training
