Guess what? - OSHA is looking at theatre shop operations

Below is an article published on the Department of Labor's OSHA.gov web site:

Region 3 News Release: 13-1492-NEW (osha 13-72)
July 25, 2013
Contact: Leni Fortson      Joanna Hawkins
Phone: 215-861-5102      215-861-5101
Email: uddyback-fortson.lenore@dol.gov      hawkins.joanna@dol.gov

Jersey City, NJ, theatrical equipment company cited by US Department of
    Labor's OSHA for exposing workers to workplace safety and health hazards

JERSEY CITY, N.J. – The U.S. Department of Labor's Occupational Safety and Health Administration has cited Acadia Scenic Inc., which builds scenery for the entertainment industry, with 22 safety and health violations, including two willful. The citations followed an April inspection, prompted by the agency's Health-High-Hazard Top 50 Local Emphasis Program and its Amputations and Combustible Dust Emphasis Program. Proposed penalties total $49,600.

The willful violations, with $28,000 in penalties, were cited for a lack of guarding on hand-fed circular ripsaws and crosscut table saws. A willful violation is one committed with intentional, knowing or voluntary disregard for the law's requirements, or with plain indifference to worker safety and health.

The 19 serious violations, with $21,200 in penalties, include the company's failure to keep the workplace clean and orderly; prevent accumulations of explosive dust; provide railings on stairs; establish or implement a written respiratory protection program for workers required to wear respirators; have fire extinguishers mounted and readily accessible for use; and provide an educational program on the general principles of fire extinguisher use and hazards involved for workers expected to fight incipient stage fires. The company was also cited for failing to provide machine guarding for a miter saw; provide spreaders and nonkickback devices on two hand-fed circular ripsaws; properly adjust a work rest on grinding machinery; determine each employee's exposure to methylene chloride; provide appropriate gloves and eyewash facilities for workers using methylene chloride-containing adhesives; and develop and implement a written hazard communication program that includes training for workers exposed to hazardous chemicals. A serious violation occurs when there is a substantial probability that death or serious physical harm could result from a hazard about which the employer knew or should have known.

"Each of these hazards threaten the company's ability to provide employees with a safe and healthful work environment, and should be corrected immediately," said Kris Hoffman, director of OSHA's Parsippany Office. "OSHA will continue to hold employers responsible when they fail to protect their workers."

Inspectors also cited the company for one other-than-serious violation, which carries a $400 penalty, for not recording a workplace injury on the employer's OSHA Form 300 Log of Work-Related Injuries and Illnesses. An other-than-serious violation is one that has a direct relationship to job safety and health, but probably would not cause death or serious physical harm.

Acadia Scenic Inc. has 15 business days from receipt of the citations to comply, ask for an informal conference with OSHA's area director in Parsippany or contest the citations and proposed penalties before the independent Occupational Safety and Health Review Commission.

To ask questions, obtain compliance assistance, file a complaint, or report workplace hospitalizations, fatalities or situations posing imminent danger to workers, the public should call OSHA's toll-free hotline at 800-321-OSHA (6742) or the agency's area offices.

Under the Occupational Safety and Health Act of 1970, employers are responsible for providing safe and healthful workplaces for their employees. OSHA's role is to ensure these conditions for America's working men and women by setting and enforcing standards, and providing training, education and assistance. For more information, visit http://www.osha.gov.

Keeping it all together

GRC (Not the Nutrition Guys) is a term commonly used to abbreviate Governance, Risk Management, and Compliance in the safety industry.  It is supposed to be an organizational cohesion that coordinates the efforts of everyone in a business so that guidance (Governance) is uniformly applied to all the sub-groups, and the subgroups share information and resources openly.

School Districts and Universities typically show significant separations between Risk Management (aka insurance claims management), Facility Safety (building and equipment maintenance), Public Safety (security), and personnel safety (actually training staff and students).

Interdepartmental separations occur, too.  Why is it the automotive shop student is given protective eye wear, while the theatre shop student has to provide his own?  The disparities are numerous and sometimes frustrating.  It affects the supply of safety information, safety goods, safety training, and maintenance.  When properly implemented, it answers the question of "Who's going to pay for this?"

For the governing administrators to do their jobs effectively, it is critical that they understand the wide variety of environments under their care.  In the theatre, this means that we have to pull-back the curtain and expose ourselves to the scrutiny of other non-theatre people.  This is hard.  We spend our entire careers trying to create magic and not let anyone outside of the theatre process know how it really works.  This is the exception.  When it comes to safety - everyone has to know and understand.

Don't stand there and tell everybody that your theatre is safe.  It's not.  This blogger sees brand new theatres that are constructed unsafely all of the time, and few new facilities come with any significant amount of operational safety training - everybody just brings their old bad habits with them and go on with little or no thought as to how they might make cultural changes to their work process.

In the 70's, the phone company ran a series of advertisements that said: "To communicate is the beginning of understanding."  The theatre plant is a perfect example of how important this is.  Maintenance workers need to access equipment and understand what is 'special' theatre equipment and know when they can work on it, and what is 'off limits' so that only specially qualified personnel are brought in to service it.  Good examples might be:

• Dimmer Racks:  The air filters need to be cleaned regularly.  This may require that the power to the dimmer rack be disconnected because there may be live electrical parts within.  Chasing-off the cleaning crew and then not having the filters serviced may cause the dimmers to overheat and malfunction, or even catch fire.  At a minimum, it will shorten the life of the equipment.  This applies to the air filters for the workspaces around the theatre, too.  I've seen clogged air filters and air grilles in follow spotlight rooms, on stages, in dimmer rooms, and on dimmer racks - all preventable if the theatre staff would engage with the maintenance staff.
• Stage Rigging:  Equipment must be inspected regularly by qualified personnel.  Most janitors and building maintenance crews are NOT trained or experienced enough to perform this task.  The maintenance of the stage rigging falls into this category.  The oil field rigging, construction rigging, or ship rigging backgrounds that some maintenance workers might have may be of some use, but without a knowledge of theatrical systems and how they are used, the resulting 'fixes' may be dangerous, incompatible with the theatrical operational needs, or aesthetically undesirable.
• Fire Curtain, Smoke Vent, and Fire Doors:  Inspections and maintenance present challenges similar to the Stage Rigging.  Corrections that are not compatible with Fire Codes, Theatre Operations, and the Audience's enjoyment of the presentations must be prevented through the use of knowledgeable people.  Hire a consultant of you need one - this is where your Risk Management Department and or your Safety Office may be able to assist in securing the necessary funding.

Finding a balance with safety equipment provision policies, cost deferrals, and training budgets can only be achieved if the various participants can speak openly about the needs of their buildings and operations.  It also requires that the administrators truly understand and acknowledge just how dangerous a theatre plant is.  They care about bad brakes on buses, broken playground equipment, football helmets, and toxic fumes in the chemistry lab - why should your performing arts venue be any different?

Blogger Norman Marks on the Sustainable Business Forum site has a series of articles that help to explain GRC:  http://sustainablebusinessforum.com/node/59561

EPA Seeks Comments on Environmental Health in Schools

The U.S. Environmental Protection Agency (EPA) has released for public comment the K-12 School Environmental Health Program Guidelines for States, Tribes and Territories.

In December 2007, Congress enacted the Energy Independence and Security Act (EISA). Subtitle E, Section 504 of EISA requires the EPA, in consultation with the Department of Education, the Department of Health and Human Services and other relevant federal agencies, to develop voluntary guidelines to assist states in establishing and implementing environmental health programs in K-12 schools.

Exposure to environmental hazards in schools can negatively impact the health of students and school staff. Unhealthy school environments can affect attendance, concentration and performance. In carrying out this statutory mandate, EPA, with assistance from its federal partners and feedback from stakeholders, developed these draft voluntary State K-12 School Environmental Health Program Guidelines. The guidelines are primarily intended to be used as a resource for the establishment of a state, tribal, or territorial K-12 school environmental health program.

Your feedback will help in the development of useful guidelines to states, tribes, and territories that will better support healthy school environments for our nation's children. We encourage you to review the draft guidelines and provide comments by April 13, 2012. Please visit the EPA's Office of Children's Health Protection School's website at www.epa.gov/schools to post your comments.

The EPA is also happy to announce the release of a Request for Applications (RFA) which will provide funding for implementation of the draft voluntary guidelines. Eligibility for funding under this competitive solicitation is limited to states, tribes and territories. Total funding available is expected to be $750,000 and applications for up to $150,000 will be accepted. The closing date for receipt of applications is April 10, 2012. For more information, including a copy of the RFA, go to: www.epa.gov/schools.

Commentary:  Scene Shops, Costume Shops, and Paint / Chemical Storage Areas are not the only hazardous spaces in the theatre plants.  Hazards can be physical, electrical, and thermal, too, and may be affected by these guidelines.  Most importantly, the key directive in this document focus on Indoor Air Quality (IAQ) which is directly related to asbestos (think: Fire Curtains), (saw) dust, mold, mildew, poor ventilation (think: rotting drapes and carpets), and sanitation.  Old florescent lights may have ballasts with PCB's in them, too, so this may be an opportunity to get them upgraded to energy-efficient, color-correct LED lights.  Shops, clean-up areas, restrooms, orchestra pits, trap rooms / basements, and storage rooms all are susceptible to poor IAQ conditions, so making sure that your performing arts venues are included in environmental studies and corrective planning can help you to get your facilities up-to-date and keep your students healthy.

ANSI Approves PLASA Dust Effect Standard

Luke, I'm Your Father

The PLASA Standards group has announce that on Friday, 2 December 2011, the ANSI Board of Standards Review approved the adoption of ANSI E1.40- 2011, Recommendations for the Planning of Theatrical Dust Effects, as an American National Standard.  The new dust effect standard is written as a recommendation, a document that gives a mixture of guidance "should" statements and mandatory "shall" statements.

A great variety of materials might be suitable for dust effects, either as dust lying on props and scenery or as aerosol clouds, so it does not specify exactly what dust must be addressed.  However, the standard will help people to avoid inappropriate materials, to select those that are least likely to cause health or safety problems, and to use them with care.  Publication is expected in a few weeks.

Cough, Cough, Wheeze - Dust Mask, Please!

Specialty Tools and Fasteners Distributors Association (www.STAFDA.org) is a not-for-profit educational trade association comprised of distributors, manufacturers, and rep agents of light construction, industrial, and related products. STAFDA membership also includes publishers of industry trade press (affiliates). STAFDA has more than 2,500 members from the U.S., Canada, and overseas.

Their recent annual convention showed a strong interest in dust collection and containment accessories that would be helpful around the Scene Shop.  There is a good summary of this aspect of the show at The Powertool Authority Blog: www.coptool.com/blog/2011/11/dust_collection_a_strong_focus.html

Check it out and maybe you can find a way to just need dust masks in lieu of respirators!

Breath deep (if you can)

Professional Propmaster, Eric Hart, writes a handy blog called "Eric Hart's PROP Agenda".  His latest post about the need for fresh air in the shop and in particular, your lungs, is a good read.  Check it out!

www.props.eric-hart.com/safety/breathe-nothing-but-air/

ISO Standard Signage for Mandatory Dust Protection

Other good resources include:

Dust Masks vs. Respirators:  www.osha-answers.com/lore/article.php?id=044

Wood Dust:   www.osha.gov/SLTC/wooddust/index.html

PPE Selection:   www.osha.gov/SLTC/etools/respiratory/index.html

Dust Mask Training:  www.slideshare.net/Hvacmach/dust-mask-safety-training