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Who Is OSHA?
Who Is PERRP?
Occupational Safety and Health Administration
Public Employment Risk Reduction Program
Both agencies are responsible for worker
safety and health protection.
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PERRP History
o 1970 – Federal OSHA created (public employees exempted from
coverage)
o 1973 – Governor’s executive order signed providing safety and health
protection for executive branch state employees (OPESH)
o 1992 – Ohio Public Employment Risk Reduction Act passed (House Bill
308); OPESH becomes PERRP extending coverage to most local
government employees
o July 1994 – the Act went into full effect
o July 2005 – PERRP became part of the Ohio Bureau of Workers’
Compensation
o July 2017 PERRP significant R.C. 4167 amendments
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PERRP Purpose
o Ensure public employees in Ohio have a safe
and healthy work environment by:• Identifying workplace hazards and reducing those
hazards through effective safety and health programs.
• Developing and enforcing mandatory job safety and
health standards.
• Maintaining a reporting and recordkeeping system to
monitor job-related injuries and illnesses.
• Providing assistance, training and other support
programs to help public employers and workers
understand their rights and responsibilities.
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Employer and Employee
Responsibilities
o Each public employer in Ohio must:• Provide a place of employment free from
recognized hazards.
• This requirement is known as the, General DutyClause.
o Each public employee in Ohio must:• Comply with all safety and health regulations; and
• Any reasonable safety and health policies
developed by their employer.
ORC 4167.04
ORC 4167.05
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What Is Enforced?
Regulatory elements of the PERR Act
o The federal OSHA regulations• 29 CFR Parts 1910, 1926 and 1928
o Chapters 4167 of the Ohio Administrative
Code and Ohio Revised Code• General Duty Clause - 4167.04(A)(1)
• Workplace safety poster
• Injury and illness recordkeeping
• Ohio Manual on Uniform Traffic Control Devices
• 10 CFR 20 (Radiation Protection)
ORC 4167.07
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PERRP Standards
o PERRP is required to adopt OSHAstandards with 120 days when OSHAadopts, modifies, or revokes a federal standard.• PERRP is not obligated to apply OSHA
enforcement policies that are not part of the rulemaking process.
The required PERRP poster replaces OSHA
posters in Ohio governmental workplaces!
OSHAPERRP 8
PERRP Recordkeeping Forms
o 300P Log of Work-Related Injuries and Illnesses• Employer must maintain all forms , including 300P, for each
establishment and kept on site for five years.
o 300AP Summary of Work-Related Injuries and Illnesses• Employer must submit the 300AP to PERRP by Feb. 1 of each
year.
o 301P Injury and Illness Incident Report• Employer must complete the 301P or equivalent for each
recordable incident.
o The forms clarify the requirements for public employers
and reference the appropriate sections in the ORC/OAC.
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Recent Statute ChangesHB 27 June 30, 2017 amended Revised Code
Chapter 4167
Ohio Revised Code 4167
o The Ohio BWC biennium budget included
amendments to the following statutes in
Revised Code, Chapter 4167:
• 4167.01 Definitions
• 4167.02 Director to enforce program
• 4167.10 Inspection procedures
• 4167.19 Exemption from program (repealed)
o Effective date of the amendments is
09/29/2017.
ORC 4167.01 Amendments
o Change in the definition of “public employee”
extended PERRP Coverage extended to
firefighters, EMTs, EMT-Ps, and local
correctional officers.
o State correctional officers were previously covered by the
Act.
• Peace officers (e.g., police officers, deputy sheriffs,
DNR officers, etc.) are still excluded from PERRP
coverage.
ORC 4167.02 Amendment
o Safety Partnership Agreement program created in 4167.02 to replace 4167.19
• All public employers (PES and PEC) will be eligible to participate
• Program will recognize public employers that have exemplary safety and health programs
• Program participants will be encouraged to serve as mentors for other PEs
• Program participants will be excluded from PERRP general schedule inspections.
Safety Partnership Agreemento Participation Requirements”
1. The public employer has an active workers’
compensation policy and is current with respect to all
payments due the bureau;
2. The public employer has an injury and illness history that
is less than the aggregate incidence rate for all Ohio
public employment sectors;
3. The public employer must establish and maintain a
safety committee;
4. The public employer must not have any open,
unresolved, or outstanding enforcement actions; and
5. The public employer must agree to comprehensive
employment risk reduction inspections.14
ORC 4167.10 Amendments
o Scheduled inspections added to the list of enforcement inspections.
• General schedule inspections will focus on high-risk employers and high hazard work activities
• Amendment requires an OAC 4167 rule that will explain the inspection criteria
• Inspection rule will require inspections to be conducted according to a policy and procedures manual (PERRP Field Operations Manual)
o Enforcement inspections to be conducted without delay.
Priority Category of Inspection
1stRefusal to Work:
Reasonable certainty an immediate danger exists
2ndFatality/Multiple Hospitalization:
Reported to PERRP within eight hours; inspected ASAP
3rd
Complaints:
Worker or worker representative can file a complaint about
a safety or health hazard
4th
General Schedule Inspections:
Inspection schedule based upon high risk workplaces and
work tasks (beginning Spring 2018)
5th
Compliance Assistance Inspections:
Voluntary inspections encourage a pro-active approach to
addressing workplace hazards
PERRP Inspection Priorities
Compliance…
The foundation of an effective safety and health
program isn’t complete until you meet the
minimum requirements!
HAZCOM
LO/TO
BBP
PRCS
PSM
300P LOG
EAPPPE
HAZWOPER
Noise
301P/FROI300AP
Lab safety
PERRP High Hazard Focus
PERRP High Hazard Focus
o Ohio Manual of Uniform
Traffic Control
o Trenching and Excavation
o Hazards of tree felling and
trimming operations
o Confined Space Entry and
Work
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OMUTCD
Temporary Traffic Control
“Plan”
o Temporary traffic control zone was not an
integral part of work operations.
• Temporary traffic control plan was not developed
or an appropriate “typical application” from the
manual was not identified and implemented.
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Advanced Warningo Advanced warning
was not provided to motorists.
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Flagger position
o Flagger was not positioned in advance of
work zone or;
o Flagger was improperly positioned in the
center of the roadway.
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High Visibility Safety Apparel
o Apparel performance class was not selected
based upon an assessment of the work.• i.e., Class 2 or Class 3
o Workers were not wearing high visibility
safety apparel, or;
o Apparel was improperly maintained and
remained in use beyond its useful service
life.
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Trenching Hazards
What’s wrong with this
picture?
Worker outside protective system!
What’s wrong with this
picture?
Inadequate Access!
No Protective System!
What’s wrong with this
picture?Too Close!
No Protective System!
Unsafe Access!
No PPE!
T&E Summary
o The greatest risk in an excavation is a cave-in.
o Employees can be protected through sloping, shielding, and shoring the excavation.
o A competent person is responsible to inspect the excavation and protect employees.
o Other excavation hazards include water accumulation, oxygen deficiency, toxic vapors or fumes, falls, and mobile equipment.
Tree Work Hazards
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Hazards of tree felling and
trimming
o PERRP and OSHA Region 5 both have an emphasis program to conduct inspections on these hazards.
o PERRP focus began in April 2014, OSHA began its program in October 2013.
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Permit Required Confined
Spaces: 29 CFR 1910.146 &
1926 Subpart AA
Identification,
evaluation and safe
entry requirements for
confined spaces in
public employment
workplaces
PERRP
“Confined Space” means:
o The location is large enough, and
configured, so that a person can bodily enter
and perform assigned work; and
o Has limited or restricted means of entry or
exit; and
o Is not designed for continuous human
occupancy.
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Permit Required Confined
Space
o A space that has one or more of the following
characteristics:• Contains or has a potential to contain a hazardous
atmosphere;
• Contains a material that has the potential for engulfing
an entrant;
• Has an internal configuration that may cause an
entrant to be trapped or asphyxiated by inwardly
converging walls or by a floor that slopes downward
and tapers to a smaller cross-section;
• Contains any other recognized serious safety or
health hazard. 38
Confined Space Hazards
o Atmospheric
o Physical Configuration
o Mechanical
o Electrical
o Thermal
o Noise
o Vibration
o Engulfment or
Entrapment
PERRP
PERRP
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The STATS…
o 45% due to asphyxiation
o 41% due to poisoning
o 14% from drowning
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Asphyxiation
Poisoning
Drowning
Approximately 670 workers died in confined spaces.
*Source: “Worker Deaths in Confined Spaces: A Summary of Surveillance Findings and Investigative Case Reports”,
NIOSH Publication, 4676 Columbia Pkwy., Cincinnati, OH 45226-1998.
Many of the victims were
would-be rescuers.
According to the National Institute for Occupational Safety
and Health (NIOSH), from 1983 to 1993*:
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Fatal Facto Wastewater treatment
worker was working alone at
a normally unmanned plant.
o Employee was using a
typical sampling cup to
collect clarifier samples.
o While collecting samples,
the employee fell into the
clarifier tank and was pulled
under by the tank pump.
PERRP
PERRP
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Fatal Fact
o Crew of three workers were called on a weekend to respond to a flooded wastewater dry well.
o Crew used a gasoline powered pump to empty well.
o One crew member collapsed and died after entering drained well.
o Second worker collapsed and was hospitalized after attempting to rescue first worker.
PERRP
PERRP
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PRCS Evaluation Elements
o As part of the overall written PRCS program,
the PRCS evaluation must:• Identify and evaluate the hazards of permit spaces
before employees enter them;
• Identify the means, procedures, and practices
necessary for safe permit space entry operations;
• Specify acceptable entry conditions and testing
procedures to ensure acceptable conditions;
• Identify equipment necessary for safe permit space
entry operations.
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PRCS Program Elements
o Prevent unauthorized entry: These
procedures can include any effective actions,
as long as they accomplish the desired goal.
o Possible actions:• Warning signs;
• Installing locks or covers, etc.
o Identify and evaluate the hazards: Must be
completed before employees enter a PRCS.
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PERRP
Top 10 ViolationsCommon hazards identified during educational facility visits
#10 1910.334(a)(2)(i)
o A portable cord and plug connected piece of
equipment was not visually inspected for
evidence of external or internal defects or
damage.
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#10 1910.334(a)(2)(i)
PERRP PERRP PERRP
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#9 1910.157(e)(2)
o Monthly visual inspections were not
completed of portable fire extinguishers (or
fire hose).
#9 1910.157(e)(2)
PERRP
#8 1910.334(a)(3)(ii)
o Attachment plugs or receptacles were
connected or altered in a manner which
prevented proper continuity of the equipment
grounding conductor.
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#8 1910.334(a)(3)(ii)
PERRP PERRP PERRP
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#7 1910.303(b)(1)(ii)
o Unused openings in electrical equipment
were not effectively closed.
#7 1910.303(b)(1)(ii)
PERRP PERRP PERRP
#6 1910.215(a)(4)
o Abrasive wheel grinder work rest(s) was
missing or it was improperly adjusted or
installed.
#6 1910.215(a)(4)
PERRP PERRP PERRP
#5: 1910.303(f)(2)
o Electrical circuits or disconnects were not
labeled to indicate their purpose.
#5: 1910.303(f)(2)
#4: 1910.212(a)(3)(ii)
o A machine guard was not provided to protect
the operator and other employees in the
machine area from point of operation
hazards (e.g., ingoing nip points, rotating
parts, flying chips and sparks.)
#4: 1910.212(a)(3)(ii)
#3: 1910.37(a)(4)
o Safeguards designed to protect employees
during an emergency were not in proper
working order.
#3: 1910.37(a)(4)
#2: 1910.305(g)(1)(iv)
o Flexible cords and cables were improperly
used.
#2: 1910.305(g)(1)(iv)
#1: 1910.303(b)(2)
o Listed or labeled electrical equipment was
improperly used or installed.
#1: 1910.303(b)(2)
PERRP
Compliance
Assistance
PERRP
Compliance Assistance
o Requests for assistance demonstrate an
employer’s Good Faith effort to achieve
compliance!
o PERRP offers these risk reduction services
TrainingSafety surveys
Health surveys
PERRP
PERRP
PERRP
Compliance Services
o PERRP provides compliance assistance services free of charge.
o Submit requests by mail, fax, or on BWC’s website: http://www.bwc.ohio.gov
o You can also phone in a request to PERRP by calling the investigator/consultant in your area or by contacting the PERRP central office between 8 a.m. and 5 p.m. at:
1-800-671-6858.
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o BWC website: http://www.bwc.ohio.gov
o Ohio Center for Occupational Safety and Health
(OCOSH) courses
o OSHA website: http://www.osha.gov
o National Institute for Occupational Safety and
Health (NIOSH) – OSHA’s sister agency
o OSHA Training Institute Education Centers
o Ohio Forestry Association: http://ohioforest.org
o PERRP Compliance Investigators
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Sources of information
PERRP Contact Information
Ohio Bureau of Workers’ Compensation
Public Employment Risk Reduction Program
13430 Yarmouth Drive
Pickerington, Ohio 43147
PERRP’s Main Number & Refusal to Work/
Fatality Hotline: 1-800-671-6858
BWC’s Main Number: 1-800-OHIOBWC
PERRP Compliance Regions