Introduction
The OSH Act of 1970 involved the federal government in workplace safety to an unprecedented degree. This act of Congress created the Office of Safety and Health Administration (OSHA). OSHA proceeded to develop a substantial body of safety regulations, known collectively as the General Industry Standards.
These standards are published as a portion of the Code of Federal Regulations, under the heading 29 CFR 1910. Subchapters of 1910 are the various subject areas covered within each standard. These standards are voluminous in size and scope, but a few of the standards have continuing application to Postal Service work. This paper will briefly introduce and explain some of these safety standards.
Life Safety
Life safety standards are published under 29 CFR 1910.36 Means of Egress. These OSHA regulations state generally that all buildings, new and old, must permit the prompt escape of occupants in case of fire or other emergency. Employers must provide sufficient, clearly identified, infallibly illuminated, and always unobstructed egress from the building or structure, when occupied. Any building sufficiently large that fire or smoke may prevent a safe egress for a reasonably large number of persons must have at least two means of egress, remote from each other. In buildings sufficiently large that a fire itself may not provide adequate warning, such a building must provide fire alarm facilities. Even during periods of construction, no building shall be occupied whole or in part until all exit facilities for the occupied portion are usable.
Electrical Wiring
OSHA has published extensive code on electricity, but most routine violations are of its published basic standard, 29 CFR 1910.303 General requirements. This standard is based on the premise that electrical equipment shall be free from recognized hazards that are likely to result in death or serious physical harm to employees. Standard 1910.303 requires use of only approved equipment, use of proper splices, enclosure of arcing parts, use of properly-marked equipment, and identification of means of disconnection.
Illumination Contstruction Standards
A related OSHA standard, 29 CFR 1926.56 Illumination defines minimum illumination in construction in terms of foot-candle levels for safe working in various environments. Some of the ratings that could apply to our situations include a 5 foot basic foot-candle requirement for indoor halls and exitways, a 10 foot-candle requirement for active store rooms, mess halls, and toilets, and a 30 foot-candle requirement for first aid station, infirmaries, and offices.
Sanitation
OSHA has well-defined standards for lavatory facilities and basic cleanliness, written under 29 CFR 1910.141 Sanitation. Sanitation violations in the Post Office are frequent where older post offices have not been retrofitted for the change from our former, male-dominated work force to our present, much more gender equitable population. Since supervisors frequently have their own lavatories, the cleanliness and adequacy of facilities for craft employees will often be ignored.
Lavatory facilities must be provided in all places of employment. Except where locking facilities can be provided, toilet rooms shall be separate for each sex. The number of facilities needed is based on the number of employees of that sex.
In men's restrooms, urinals may be provided instead of toilets, so long as the maximum number of water closets shall not be reduced to less than two-thirds of the minimum number specified
Nonpotable water shall not be used for cleaning any portion of the person, nor any food utensils or eating area. Hot and cold (or tepid) water shall be provided, and hand soap shall be furnished.
Waste disposal containers shall be furnished, made of easily cleanable or disposable materials. They shall be emptied not less than each working day, unless unused. This issue is often overlooked in women’s rest rooms.
Material Hazards
Workers are at risk of exposure to many types of hazardous materials in the performance of duties. OSHA has published an extensive standard regulating such exposures, under the title 29 CFR 1910.1200 Hazard communication.
The scope of management responsibility for hazard communication goes beyond manufacture of hazardous products to cover downstream use of hazardous content in further manufacture or product use. In the Postal Service, maintenance employees have the highest ongoing exposures to hazardous materials, but all employees are exposed to stamp inks, floor compounds, paints, and other cleaning compounds.
The Material Safety Data Sheet (MSDS) is a critical tool in policing material hazards and protecting exposed employees who become ill. Employers are required to assess the hazards of any chemicals they produce or import and inform employees through labeling of containers and through use of material safety data sheets, which must be available to employees upon request. An MSDS will describe the chemical, identify hazardous aspects including long-term exposure risks, and will discuss first-aid measures in the event of exposure-induced illness.
A hard copy MSDS is a vital documentation tool in grievance presentations where harmful exposures are alleged. Material safety data sheets are increasingly available by computerized retrieval, FAX, and microfiche, each of which is an acceptable means of furnishing MSDS information if the employees are trained in using these means and have reasonable access.
OSHA Standards by Computer
For those who have an on-line service on their personal computers, such as Prodigy or America on Line, OSHA standards can be reviewed or printed practically for free. A wealth of other Federal regulations and timely information can also be reviewed and saved or printed immediately at practically no cost at all as part of the subscribed service. The Department of Labor maintains several sites on the Internet, including their Salt Lake City, Utah location, where all their regulations can be accessed. An advantage in downloading information is that it usually is the most current version available, and comes out of the printer neatly titled and ready for use.
The MSALC would be happy to attempt to locate a particular standard if you can request it by number or at least accurately describe the safety problem at issue.
Hard copy OSHA standards make for compelling safety discussions and are
invaluable if one must enter the grievance process in the fight to win a safer workplace. And we must all be soldiers in the fight for safer working conditions.
Disclaimer: The material in this article is not presumed or intended to reflect an official position of the
National Association of Letter Carriers or the Michigan State Association of Letter Carriers. This article contains opinion statements of the writer offered for basic informational purposes only. There is no substitute for consultation with or representation by a trained advocate. The writer cannot assume responsibility of any type for the use of this material by others.
