| SAFETY |
| Q. |
I understandt that fall protection is required when an employee is working on a walking/working surface that is 6 feet or more above a lower lever. At what height is fall protection required when working on a scaffold? |
| A. |
According to 1926.451(g), “Each employee on a scaffold more than 10 feet above a lower level shall be protected from falling to that lower level”. |
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| Q. |
My company is using a scissor lift. The lift operates vertically only and is provided with a basket that has guardrails. Do authorized personnel have to tie off when in the basket? |
| A. |
The scissor lift is considered an Aerial Lift and falls under the 1926, Subpart L-Scaffolds regulations. According to 1926.453(b)(2)(v), “A body belt shall be worn and a lanyard attached to the boom or basket when working from an aerial lift”. Note that as of January 1, 1998 body belts are not acceptable for personal fall arrest, but only as a tethering device. Since employers have generally discontinued the use of body belts for reasons of safety and practicality, it would be prudent for employees to be required to wear a full body harness when working from the scissor lift basket. |
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| Q. |
Does OSHA require my employees to obtain a medical examination annually under the 1910.134 Respiratory Protection standard? |
| A. |
No, but at least a medical evaluation is required. According to 1910.134(e)(1), “The employer shall provide a medical evaluation…before the employee is fit tested or required to use the respirator in the workplace”. Under 1910.134(e)(2), “The employer shall identify a physician or PLHCP to perform medical evaluations using a medical questionnaire or an initial medical examination that obtains the same information as the medical questionnaire”. The medical questionnaire is found in Appendix C of 1910.134.
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| Q. |
Do I need training if I fill out a waste manifest or transport hazardous materials? |
| A. |
Yes, you need a training class to be in compliance with HM-126F. The training you need is an 8-hour DOT Hazmat employee class. The purpose of the training is to ensure safe work practices in loading, unloading, handling, storing, transporting, and emergency preparedness to accidents. |
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| ASBESTOS |
| Q. |
How do I tell if a building material could be asbestos? |
| A. |
You must presume that any thermal system insulation, sprayed on fireproofing and/or plaster in a building constructed no later than 1980, and vinyl and asphalt flooring installed no later than 1980 is asbestos. An inspection must be conducted by an EPA -accredited Inspector to identify asbestos in a facility.
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| Q. |
How much asbestos can be removed by a maintenance worker who has received 16-Hour OSHA Class III training? |
| A. |
State regulations vary. Under Federal Regulations, the amount that can be removed by an OSHA Class III trained person cannot exceed that which can be contained in a standard glove-bag or waste bag (60”x 60”) in order to access a building component. This means that the OSHA Class III worker can only remove the asbestos in order to perform a maintenance function (i.e. valve replacement).
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| Q. |
If I have a project that is more than 25 linear feet of asbestos pipe insulation, do I need a decontamination unit for workers? |
| A. |
Yes. OSHA’s Asbestos in Construction Standard, 29 CFR1926.1101 states that for all Class I work over 25 linear feet, 10 square feet, a 3-stage decontamination unit is needed. This consists of an equipment room, shower room and clean room in series.
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| Q. |
If I want to do Operations & Maintenance in Maryland, do I need a company asbestos license? |
| A. |
Yes. All asbestos activities in Maryland are regulated. Therefore your company needs a Maryland Asbestos License.
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| Q. |
When is a Project Monitor needed in Virginia? |
| A. |
A licensed project monitor is needed in VA on projects where a building will be occupied or intended to be occupied at the completion of the response action and when ever the building owner deems necessary.
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| Q. |
When does a project need to be designed by a Project Designer? |
| A. |
A Project Designer is needed for a project that is over 3 square feet or 3 linear feet. EPA AHERA regulations state that any project greater than a small scale, short duration project needs to be designed by a project designer. It also states that for a Major Fiber release episode (unintentional disturbance of 3 square feet, 3 linear feet, or more) must be designed by an accredited project designer and cleaned up by persons accredited to conduct response actions (4 day trained worker and a 5 day supervisor). |
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| LEAD |
| Q. |
What regulation applies to all lead jobs regardless of what type of building or facility is being worked on? |
| A. |
The OSHA Lead in Construction Standard (29CFR 1926.62) applies to all jobs where an employee may be exposed to lead. This includes lead abatement projects, interim control work, alteration, repair, or renovation of structures that contain lead. |
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| Q. |
After I complete an initial Lead Inspector/Risk Assessor course, will I have to take both refresher classes? |
| A. |
No, Risk Assessors do not need to take a Lead Inspector refresher class. |
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| Q. |
Are there any other requirements that must be fulfilled after taking an initial lead training course? |
| A. |
Yes, after successfully completing the initial training course, you must apply for a license from the state that you plan to work in and take a third party exam. This requirement does not apply to lead abatement workers or lead project designers working in Maryland. |
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| Q. |
What are my options for disposal of LBP debris? |
| A. |
Generally, debris from residential abatement projects, and waste from interim control work can be disposed of as household waste. Contact the state in which you will be working for their interpretation. LBP debris form all other projects must be tested to characterize the waste as hazardous or non-hazardous waste. |
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| Q. |
Does OSHA require the competent person on a Lead-in-Construction project to be a 32-hour EPA certified supervisor? |
| A. |
No, but sufficient training must be given to allow this individual to identify and control lead hazards on the jobsite. |
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| Q. |
What is the difference between a Lead Abatement project and a Lead-in-Construction project? |
| A. |
An Abatement project is one in which the intent of the job is to permanently eliminate lead-based paint hazards in target housing or child-occupied facilities. If the intent of the project is to renovate, remodel, restore or repair, then it is a construction project. |
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| Q. |
On what type of projects are trained and certified Lead Abatement Workers and Supervisors required? |
| A. |
If the project is considered an abatement project, then all workers and supervisors on the project must be trained by an approved training provider. Additionally, each state has individual licensing or accreditation requirements for workers and supervisors. Maryland also requires accredited workers and supervisors to perform lead hazard reduction treatments in residential rental properties that were constructed prior to 1950. |
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