Guest Column | March 8, 2018

Occupational Safety And Utility Compliance: Top 5 Violations For The Water And Wastewater Sectors

Sheldon Primus

By Sheldon Primus

The water and wastewater sectors are mostly regulated by their own organizations, because they are exempt from federal Occupational Safety and Health Administration (OSHA) regulations. Holistically, the management of municipalities have a responsibility to protect the workers from injury and illnesses. There are 22 states or territories that have OSHA-approved State Plans that cover private, state, and local government workers. Five other states and one U.S. territory have OSHA-approved State Plans that cover state and local government workers only. This article will evaluate the most frequent violations as reported by the OSHA State Plan states for water and wastewater facilities (OSHA, 2018).

In a review of the North American Industry Classification System (NAICS) codes for water and wastewater facilities, the top five violations for each type of facility are listed below:

Water Supply and Irrigation Systems (NAICS Code 221310)

  1. Respiratory Protection
  2. Hazard Communication
  3. Powered Industrial Truck
  4. Occupational Noise Exposure
  5. Process Safety Management of Highly Hazardous Chemicals

Sewage Treatment Facilities (221320)

  1. Permit-Required Confined Space
  2. Personal Protective Equipment (PPE) General Requirements
  3. Respiratory Protection
  4. Powered Industrial Trucks
  5. Head Protection

Respiratory Protection

Due to hazards that can enter the body from inhalation of fumes, dusts, mists, and gases, a respiratory protection program is very important. Exposure can lead to occupational health diseases and hazards such as, but not limited to:

  • Silicosis
  • Asbestosis
  • Mesothelioma
  • Simple Asphyxiants
  • Poisons (sampling reagents)

Utility workers must follow all precautions to protect themselves from health hazards. Therefore, using the OSHA guidelines is the minimum acceptable standard for worker safety. The 29 CFR 1910.132 Subpart I PPE standard is very clear that a written respiratory protection program is needed for workers that use respirators. The minimum requirements for a written program are outlined in 29 CFR 1910.134(c)(1).

Hazard Communication

Hazard Communication is used to protect workers that handle or use chemicals to be able to understand the true risk related to working with the chemicals. Often workers who use secondary containers without a proper label are exposed to unknown dangers. The California Poison Control System and Central California Children’s Hospital identified over 1,400 cases of “accidental poisoning caused by storage of non-food substances in soda bottles, unmarked bottles, cups or glasses” between the years of 1998 and 2009.

The employer must protect the worker that uses chemicals with labeling, training, and having a written hazard communication program. OSHA has switched to the Globally Harmonized System of Classification and Labeling of Chemicals (GHS) as a uniformed method of keeping the workers protected from chemical exposures. Each chemical must have a Safety Data Sheet (formerly Material Safety Data Sheet) that is readily available to the workers who are using or working around the chemical.

OSHA has a compliance assistance page for the Hazard Communication Standard on its website. This guideline outlines:

  • Safety Data Sheets
  • Labeling
  • Pictograms
  • Letters of Interpretation
  • Standards

Powered Industrial Trucks

Forklifts are known as powered industrial trucks and are used in a variety of situations for material handling. There are many types of forklifts used in the utility field due to the constant need to move heavy items. Safety concerns for operating a powered industrial truck can range from struck-by incidents to rollover events.

There are several key safety and health components to have an effective powered industrial truck program:

  • Selecting the right machine for the location and application
  • Training operators using a combination of classroom and driving instructions
  • Wearing seatbelts during operations
  • Operating the equipment in a responsible manner
  • Restricting the use of the equipment to only qualified operators.

OSHA has a forklift electronic tool (eTool) that gives an overview of:

  • Types and Fundamentals
  • Operating the Forklift
  • Understanding the Workplace
  • Training Assistance

Process Safety Management (PSM) of Highly Hazardous Chemicals

PSM is a program that affects treatment plants with highly hazardous chemicals such as gas chlorine. This program uniquely intersects with the U.S. EPA’s Risk Management Program (RMP). The PSM is regulated by OSHA to address how these chemicals can affect the workers, while the RMP covers the control of chemicals that affect the community and environment.

Under the PSM/RMP programs, all aspects of handling the chemicals are analyzed for potential risks and outbreaks. Each RMP facility is given a program number that is related to hazard levels. I wrote in a previous article the 7 Tips for Risk Management Program Compliance that outline the programs as listed below:

Program 1:

A Program 1 facility is one that would not affect the public on its very worst day (as noted in worst-case scenario modeling) and did not have an accident within the past five years.

Program 2:

A facility not eligible for Program 1 or subject to Program 2 is put into Program 3 status. These facilities have additional hazard assessment, emergency response, and management requirements (EPA, 2009).

Program 3:

Program 3 status is for facilities that do not meet Program 1 requirements and are not subject to the OSHA PSM standard under state or federal programs or classified in one of 10 specified industry codes from the NAICS. Level 3 programs must follow OSHA PSM standards because the RMP incorporates the PSM into its standard.

Permit-Required Confined Space (PRCS) Program

PRCS program is used to protect workers who are doing activities in a particularly dangerous environment. By definition, a confined space has three characteristics:

  • The space is large enough to fit a body
  • There are limited means of access and egress
  • The space was not meant for continuous human occupancy

When a hazard exists in a confined space, then it becomes a permit-required confined space. Permits are developed in-house for the identification and control of hazards. Some hazards of a PRCS are:

  • Engulfment
  • Drowning
  • Asphyxiation
  • Explosion
  • Heat Stress
  • Electrical
  • Gravity
  • Hazardous Atmosphere

To understand the many facets of the PRCS program, the utility can use the OSHA publication for PRCS.  

Utilities are responsible for more than delivering water and wastewater treatment services. They must provide a workplace that is free from known hazards. Using the NAICS information in this article will direct the utility — and worker — to hazards identification and awareness.