Required written programs and plans
CSP video lesson, 7:19. CSP Domain 2: Program Management
What OSHA requires in writing: emergency action plans, fire prevention plans, hazard communication and respiratory protection programs, including minimum elements, the 10-employee oral exception and who administers.
Included with every pass, and free to watch with captions. Every rule and number is cited on screen to its primary source.
Transcript
0:00 Intro
Required written programs and plans, for the CSP exam. Every rule and number here is cited to its primary source, on screen. In this lesson, you'll learn to: state when a plan may be oral instead of written, list the minimum elements of an emergency action plan and a fire prevention plan, explain what a written hazard communication program must include, and describe the respiratory protection program and its administrator.
0:35 Emergency and fire plans
Each plan is required whenever a Part 1910 standard requires one. The default: in writing, kept in the workplace, available for review. The exception: an employer with 10 or fewer employees may communicate the plan orally.
0:54 1910.38(c)
An emergency action plan must include six elements at a minimum. Reporting, and evacuation with type of evacuation and exit route assignments. Critical plant operations before evacuating, and accounting for all employees afterward. Rescue or medical duties, and the name or job title of every employee who may be contacted.
1:21 EAP support requirements
Three duties support the plan. 165. Designate and train employees to assist in a safe and orderly evacuation. Review with each covered employee at development or initial assignment, when duties change, and when the plan changes. A fire prevention plan has its own minimum contents.
1:47 1910.39(c)-(d)
A list of all major fire hazards, with material handling and storage, ignition sources, and protection equipment. Procedures for flammable and combustible waste, and heat-producing equipment safeguards. Plus names or job titles of those responsible for ignition-source equipment and fuel source hazards. Employees learn their fire hazards on initial assignment, plus plan parts needed for self-protection.
2:24 1910.1200(e)
Employers shall develop, implement and maintain a written hazard communication program at each workplace. It describes how labels, SDSs and training are met, and lists hazardous chemicals known to be present. It also covers how employees learn of hazards from non-routine tasks, such as cleaning reactor vessels, and from chemicals in unlabeled pipes. Where other employers' employees may be exposed to your chemicals, add methods for their SDS access, precautions, and labeling.
2:59 1910.1200(e)(3)-(5)
Three access and flexibility rules are testable. An employer may rely on an existing program, provided it meets the criteria. Available on request to employees, their designated representatives, the Assistant Secretary and the Director.
3:24 1910.134(c)(1)
If employees travel between workplaces in a shift, it may be kept at the primary workplace facility. Where respirators are necessary to protect health, or required by the employer: a written program with worksite-specific procedures. Update it as necessary when workplace conditions affecting respirator use change. Provisions, as applicable: selection, medical evaluations, and fit testing for tight-fitting respirators.
4:02 1910.134(c)(2)-(4)
Also use, maintenance schedules, and breathing air for atmosphere-supplying respirators. Finally, training and regular evaluation of effectiveness. Where use is not required, the employer may provide respirators on request or permit employees' own, if it determines use won't itself create a hazard; then it must provide Appendix D information. Voluntary users must be medically able, with respirators cleaned, stored, maintained.
4:41 Common exam traps
Voluntary dust-mask-only users need not be in the written program. The employer designates an administrator qualified by training or experience commensurate with program complexity. Respirators, training, medical evaluations: no cost. Now, six traps that catch people on exam day. One: not every plan must be written. EAPs and fire plans may be oral for 10 or fewer employees. Two: voluntary dust-mask-only users need not be in the written program, but still get Appendix D information. Three: HazCom describes how labels, SDSs and training are met, plus a chemical list and methods for non-routine task and unlabeled pipe hazards. Four: the EAP names or titles employees who may be contacted, not all employees.
5:40 Recap quiz
Five: for employees traveling between workplaces in a shift, the HazCom program may be kept at the primary workplace facility. Six: respirators, training and medical evaluations are provided at no cost to the employee. Question 1. A small employer has 10 or fewer employees. How may it communicate its required emergency action plan? A: Orally. B: In writing only. C: It need not. D: Consultant only. A. An employer with 10 or fewer employees may communicate the plan orally. Question 2. Which is a minimum element of a fire prevention plan? A: Exit route assignments. B: Names or titles responsible for fuel source hazards. C: Fit testing. D: Chemical list by product identifier. B. Fire plans name those responsible for fuel source hazards. Question 3. A contractor's crew may be exposed to a host's chemicals. What must the host's HazCom program add? A: Nothing. B: SDS access, precautions, labeling methods. C: Fit testing. D: Alarm. B. Multi-employer sites add methods for SDS access, precautions, and labeling. Want to see where you stand on every CSP domain? com.
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