Well, I don't post often but when I do my posts are damn intersting and I figured my title would grab some interest.
Tommorrow night I have an OSHA inspector who will be joining me for a night of hood cleaning. The only thing I have to say is if any of you read the previous sentance and you get a tingle in your spine then you should think HARD about what you are doing.
Quick story: Had an employee I fired several months ago for lying and stealing from me. He wants revenge so he calls OSHA and says I am not a "safe" company to work for. Nothing happened to the employee I fired, just your usual disgruntled x-employee (I guess, this is a first for me)trying to get back at me. OSHA shows up for a surprise visit at my office unannounced. He spends seven hours combing through my files making sure my polices, procedures, and forms are correct.
In his intro he came down hard and it was as scary as you should expect should you ever have a visit. As he got to know me and realized my paperwork was in order he lightened up and the visit became a little more pleasant. (if thats possible)
After all is said and done there is one issue: Soduim Hydroxide, or ANY corrosive for that matter. Without going through every issue and detail of what you need to make sure you are doing if you are using any kind of corrosive here are the basics:
-Have en eye wash station on your vehicles, capable of 15 minutes of flushing. Eye wash bottles WILL NOT cut it, you will be fined- oops!
-MSDS which is common sense, but don't be caught without one- I wasn't.
-Secondary containers and proper labeling. Must be very specific- refer to OSHA for proper labeling.
_Safety procedures, Safety manuals, safety orientations, and safety _____________ (add your own word here) for anything and everything that has to do with what you do.
-Safety gear, refer to Niosh and OSHA for what your using and what you need to have
This barely scratches the surface of what we went through. No I didn't have EVERYTHING exactly as it should be and it is going to cost me a few dollars in fines, but he was impressed with what I did have and my HONESTY.
So back to the Sodium Hydroxide.
I could have told him ":NO, we don't use NAOH or any corrosive for that matter," and saved myself a whole lot of headache, but the fact of the matter is we do. We use it safely and pretty much ANYBODY who cleans hoods uses NAOH in some form but he got a whole lot more interested in the "kitchen exhaust cleaning" industry when I told him that!
So heres where we stand: He is going out with one of my employees tommorrow night to ensure that he has been trained properly and to collect a sample of sodium hydroxide mist. The cieling limit in NAOH per niosh is 2m/m3 per eight hours. My guys all wear full protective gear and RESPIRATORS but you can't go just buy one and think your OSHA compliant.
Your employee has to:
Go to a doctor and doctor must say yes he can wear a respirator
A environmental hygenist has to do a fit test of an approved respirator
A certification of said fit test is provided and must be carried
A maintanance test must be performed using a bitrex test once a month
and so on and so on..
My crews have done this when they were hired so it is not a problem for me but there was a time when my guys just put on their gear and went to work. Make sure you have done the OSHA required stuff!
My reason for posting this is for a reason that I have posted before. You fly by nighters out there. Who cares if you come and go, (A hundred of you have in the 15 years I have been doing this) who cares if you don't have insurance, who cares if you are a lowballer of the worst kind: just care about the safety issues and OSHA! If your in business right now and your not compliant, you are dancing on a mine field!
I thought I was fully compliant and I wasn't, so you must do your homework. This inspector is VERY interested in the pressure washing/hood cleaning industry because it is so unregulated and enforcement is unheard of, so he says it as a chance for him to make his mark and "make a difference." And believe me this guy LOVES what he does. Ambitious would be an understatement.
For any of the quality companies out there who are doing it right, if you have any questions on all this stuff, I now consider myself an expert. However my nerves will be a little high until after tommorrow night!
Tommorrow night I have an OSHA inspector who will be joining me for a night of hood cleaning. The only thing I have to say is if any of you read the previous sentance and you get a tingle in your spine then you should think HARD about what you are doing.
Quick story: Had an employee I fired several months ago for lying and stealing from me. He wants revenge so he calls OSHA and says I am not a "safe" company to work for. Nothing happened to the employee I fired, just your usual disgruntled x-employee (I guess, this is a first for me)trying to get back at me. OSHA shows up for a surprise visit at my office unannounced. He spends seven hours combing through my files making sure my polices, procedures, and forms are correct.
In his intro he came down hard and it was as scary as you should expect should you ever have a visit. As he got to know me and realized my paperwork was in order he lightened up and the visit became a little more pleasant. (if thats possible)
After all is said and done there is one issue: Soduim Hydroxide, or ANY corrosive for that matter. Without going through every issue and detail of what you need to make sure you are doing if you are using any kind of corrosive here are the basics:
-Have en eye wash station on your vehicles, capable of 15 minutes of flushing. Eye wash bottles WILL NOT cut it, you will be fined- oops!
-MSDS which is common sense, but don't be caught without one- I wasn't.
-Secondary containers and proper labeling. Must be very specific- refer to OSHA for proper labeling.
_Safety procedures, Safety manuals, safety orientations, and safety _____________ (add your own word here) for anything and everything that has to do with what you do.
-Safety gear, refer to Niosh and OSHA for what your using and what you need to have
This barely scratches the surface of what we went through. No I didn't have EVERYTHING exactly as it should be and it is going to cost me a few dollars in fines, but he was impressed with what I did have and my HONESTY.
So back to the Sodium Hydroxide.
I could have told him ":NO, we don't use NAOH or any corrosive for that matter," and saved myself a whole lot of headache, but the fact of the matter is we do. We use it safely and pretty much ANYBODY who cleans hoods uses NAOH in some form but he got a whole lot more interested in the "kitchen exhaust cleaning" industry when I told him that!
So heres where we stand: He is going out with one of my employees tommorrow night to ensure that he has been trained properly and to collect a sample of sodium hydroxide mist. The cieling limit in NAOH per niosh is 2m/m3 per eight hours. My guys all wear full protective gear and RESPIRATORS but you can't go just buy one and think your OSHA compliant.
Your employee has to:
Go to a doctor and doctor must say yes he can wear a respirator
A environmental hygenist has to do a fit test of an approved respirator
A certification of said fit test is provided and must be carried
A maintanance test must be performed using a bitrex test once a month
and so on and so on..
My crews have done this when they were hired so it is not a problem for me but there was a time when my guys just put on their gear and went to work. Make sure you have done the OSHA required stuff!
My reason for posting this is for a reason that I have posted before. You fly by nighters out there. Who cares if you come and go, (A hundred of you have in the 15 years I have been doing this) who cares if you don't have insurance, who cares if you are a lowballer of the worst kind: just care about the safety issues and OSHA! If your in business right now and your not compliant, you are dancing on a mine field!
I thought I was fully compliant and I wasn't, so you must do your homework. This inspector is VERY interested in the pressure washing/hood cleaning industry because it is so unregulated and enforcement is unheard of, so he says it as a chance for him to make his mark and "make a difference." And believe me this guy LOVES what he does. Ambitious would be an understatement.
For any of the quality companies out there who are doing it right, if you have any questions on all this stuff, I now consider myself an expert. However my nerves will be a little high until after tommorrow night!
