OSHA Safety and Compliance
Occupational Safety and Health Regulations are administered under the Iowa State Plan. These regulations require compliance from every employer, with few exceptions, in the areas of record keeping, safety, training and specific safety programs.
Agency
Iowa Workforce Development
Division of Labor (IOSHA), 1000 East Grand Ave
Des Moines, IA 50319
Phone: (515) 281-5387
Assistance - State Assistance
Iowa Workforce Development
Iowa OSHA Consultation Bureau, 2016 DMACC Boulevard - Bldg. 17,
P.O. Box 249
Ankeny, IA 50021
Phone: (515) 965-7162
Iowa Waste Reduction Center
1005 Technology Parkway
Cedar Falls, IA 50613
Phone: (319) 273-8905 or (800) 422-3109
Consultant
James B. Meehan, PE, PC
3006 Rownd Street
Cedar Falls, IA 50613
Phone: (319) 277-7030
Information Resources
- Occupational Safety & Health Standards for General Industry (29 CFR Part 1910)
- OSHA Handbook for Small Businesses, OSHA 2209
- Training Requirements in OSHA Standards and Training Guidelines, OSHA 2254
Available from:
Iowa Workforce Development
Iowa OSHA Consultation Bureau, 2016 DMACC Boulevard - Bldg. 17
P.O. Box 249
Ankeny, IA 50021
Phone: (515) 965-7162
Available on the Web at:
http://www.osha.gov
- 875 IAC, Chapter 130 (Community Right to Know)
Available from:
Iowa Workforce Development
Iowa OSHA Consultation Bureau, 2016 DMACC Boulevard - Bldg. 17
P.O. Box 249
Ankeny, IA 50021
Phone: (515) 965-7162
Available on the Web at:
http://www.legis.state.ia.us/Rules/2000/iac/875/875112/
- 567 IAC Chapters 20-31 (Environmental Protection)
Available from:
Iowa Department of Natural Resources
Environmental Protection Division, 900 East Grand
Des Moines, IA 50319
Iowa Waste Reduction Center
1005 Technology Parkway
Cedar Falls, IA 50613
Phone: (319) 273-8905
Available from the Web at:
http://www.iwrc.org
http://www.legis.state.ia.us/Rules/2000/iac/gnac/gnac1826/gna1827.pdf
- 40 CFR Protection of Environment
Available from:
CCH Incorporated
4025 W. Peterson Avenue
Chicago, IL 60646-6085
Phone: (800) 248-3248
http://www.cch.com
Available on the Web at:
http://www.epa.gov/docs/epacfr40/chapt I.info/subch C/
- “Ergonomics Program Management Guidelines for Meatpacking Plants”
Available from:
Iowa Workforce Development
Iowa OSHA Consultation Bureau, 2016 DMACC Boulevard - Bldg. 17
P.O. Box 249
Ankeny, IA 50021
Phone: (515) 965-7162
Required Postings
Employers are required by state and federal laws to display specific posters in the workplace. (Free from Government Sources)
State Government Requirements
- Unemployment Insurance
- Safety & Health Protection on the Job
- Your Rights under Iowa's Minimum Wage
Federal Government Requirements
- Employee Polygraph Protection Act
- Family & Medical Leave Act
- Notice to Employees - Federal Minimum Wage
- Equal Employment Opportunity is the Law
Sources for Required Postings
State Postings Source
Iowa Workforce Development
Labor Services Division, 1000 East Grand Avenue
Des Moines, IA 50319
Phone: (800) 562-4692 or (515) 281-3201
Federal Postings Source
Employment Standards Administration
Wage and Hour Division, 643 Federal Building
210 Walnut Street
Des Moines, IA 50309
Phone: (515) 284-4625
EEOC Publications Center
P.O. Box 12549
Cincinnati, OH 45212
Phone: (800) 669-3362
Required Postings
Employers are required by state and federal laws to display specific posters in the workplace. (Free from Government Sources)
State Government Requirements
- Unemployment Insurance
- Safety & Health Protection on the Job
- Your Rights under Iowa’s Minimum Wage
Federal Government Requirements
- Employee Polygraph Protection Act
- Family & Medical Leave Act
- Notice to Employees - Federal Minimum Wage
- Equal Employment Opportunity is the Law
Sources for Required Postings
State Postings Source
Iowa Workforce Development
Labor Services Division, 1000 East Grand Avenue
Des Moines, IA 50319
Phone: (800) 562-4692 or (515) 281-3201
Federal Postings Source
Employment Standards Administration
Wage and Hour Division, 643 Federal Building, 210 Walnut Street
Des Moines, IA 50309
Phone: (515) 284-4625
EEOC Publications Center
P.O. Box 12549
Cincinnati, OH 45212
Phone: (800) 669-3362
OSHA Requirements in General
OSHA Safety Logs
OSHA (IOSHA) requires all general industry employers to develop, implement and maintain the following safety and health plans/programs/logs:
- Log and Summary of Occupational Injuries and Illnesses (OSHA 200 Log)
- Supplementary Record (OSHA 101) (Workman’s Compensation First Report of Injury)
OSHA Safety Programs/Plans for All Employees
OSHA (IOSHA) requires all general industry employers to develop, implement and maintain the following safety and health plans for all employees:
- Hazard Communication Program (Right to Know)
- Emergency Action Plan
- Personal Protective Equipment
- Control of Hazardous Energy (Lockout/Tagout)
- Electrical Work/Exposure
- Permit Required Confined Space (Survey)
OSHA (IOSHA) requires all general industry employers to develop, implement and maintain safety and health plans/programs or provide specific training if employees are exposed to specific safety and health hazards, which include:
- Fire Prevention Plan
- Hearing Conservation Program
- Powered Industrial Truck Operator Training Program
- Permit-Required Confined Space Program
- Exposure Control Plan (Bloodborne Pathogens)
- Respiratory Protection Program
- Portable Fire Extinguishers
OSHA has developed a special program called, “Ergonomics Program Management Guidelines for Meatpacking Plants,” which is enforced for your facilities.
Detail of the Logs and Records by OSHA for All Employers
Log & Summary of Occupational Injuries & Illnesses (OSHA 200 LOG)
Employers must maintain a log and summary of all recordable occupational injuries and illnesses. (An employer who had no more than 10 employees at any time during the calendar year immediately proceeding the current calendar year may not need to maintain a log unless the employer is part of a statistical survey.)
Supplementary Records (OSHA 101)
Employers must maintain a supplementary record for each recordable occupational injury or illness. The Worker’s Compensation First Report of Injury, also sent to the Industrial Commissioner, can be used instead or the OSHA 101 Form.
Detail of the Required Programs and Criteria - OSHA Prgroams for All Employers and for Specific Hazards
Note: All of the programs require training and/or periodic retraining for all employees who are exposed to the hazards. These programs must be in writing and most require documentation of surveys, training and inspections.
Special Note: Employers with 10 or fewer employees may be exempted from certain record keeping requirements, but all employers are required to establish the OSHA-required safety programs and training for employees.
Hazard Communication Program - 20 CFR PART 1910.1200
Employers are required to establish a written Hazard Communication Program if any employee is exposed to non-exempt hazardous chemicals in the workplace. (A hazardous chemical means any chemical which is a physical hazard or a health hazard.)
A system of labeling chemicals used in the facilities is required.
A hazardous chemical list cross-referenced with the Material Safety Data Sheets (MSDS) is required.
Emergency Action Plan - 29 CFR PART 1910.38(a)
Employers must establish an emergency action plan that covers the action employees must take to ensure employee safety from fire and other emergencies. For employers with 10 or fewer employees, the plan may be communicated orally to employees and the employer need not maintain a written plan.
Fire Prevention Plan - 29 CFR 1910.38(b)
Employers may need to establish a fire prevention plan in order to comply with particular OSHA standards. For employers with 10 or fewer employees in one facility, the plan may be communicated orally to employees and the employer need not maintain a written plan.
Hearing Conservation Program - PART 1910.95
Whenever employee noise exposures equal or exceed an 8-hour time-weighted average (TWA) of 85 dBA, the employer is required to administer a continuing, effective hearing conservation program. Employees will be given audiometric tests on an annual basis as a part of this program.
Personal Protection Plan - 1910.132
Each employer is required to assess the workplace to determine if hazards are present, or likely to be present, which necessitate the use of personal protective equipment (PPE) for eyes, face, head and extremities. If hazards are present, or likely to be present, the employer must take steps to protect employees from the hazards, provide the equipment and train employees in the proper use of the equipment.
Respiratory Protection Plan - 1910.134
If the working environment contains air contaminated with harmful dusts, fogs, fumes, mists, gases, smokes, sprays or vapors which cannot be prevented by feasible engineering controls, the employer is required to establish and maintain a respiratory protection program.
An employer is generally required to perform testing to establish the levels of exposure for employees under conditions which may create the need for respiratory protection.
Permit-Required Confined Space Program - 29 CFR 1910.146
The employer must survey the workplace to determine if any spaces are permit-required confined spaces. If permit-required confined spaces are present, employer must establish practices and procedures to protect employees from the hazards of entry into permit-required confined spaces.
Control of Hazardous Energy (Lockout/Tagout) - 29 CFR 1910.147
If an employee performs any service work or maintenance work on machines or equipment, the employer must establish a program and utilize procedures for affixing appropriate lockout devices or tagout devices to energy isolating devices. Machines or equipment must be disabled to prevent unexpected energization, start up or release of stored energy in order to prevent injury to employees.
A lockout procedure is required for every machine.
Portable Fire Extinguishers - 29 CFR 1910.157
Where the employer has provided portable fire extinguishers for employee use in the workplace, the employer is required to provide an educational program that covers the general principles of fire extinguisher use and the hazards involved with incipient stage fire fighting.
Power Industrial Truck Operator Training - 29 CFR 1910.178
Only trained and authorized operators are allowed to operate a powered industrial truck. The employer must ensure that each powered industrial truck operator is competent to operate a powered industrial truck safely as demonstrated by the successful completion of training and evaluation.
Electrical Work/Exposure - 29 CFR 1910.332
All employees need to receive electrical training pertaining to the electrical equipment, devices and exposure to which they use or are exposed.
There are two electrical safety programs, one for employees who simply use electrical equipment and one for maintenance employees.
Bloodborne Pathogen - 29 CFR 1910.1030
Each employer having an employee or employees with occupational exposure to blood or other potentially infectious materials shall establish a written Exposure Control Plan designed to eliminate or minimize employee exposure.
This plan and the training are mandatory for those employees who are required to administer first aid as a part of their job duties.
Ergonomics - A Proposed Standard
Currently there is a proposed OSHA standard that addresses ergonomics hazards. The General Duty Clause is currently cited as the authority which requires an employer to provide employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to employees (ergonomics hazards).
In 1990, OSHA published guidelines titled, “Ergonomics Program Management Guidelines for Meatpacking Plants.” The guidelines are advisory in nature but are generally enforced within the meatpacking industry.
Air Management Environmental Compliance - Iowa Department of Natural Resources
Construction Permits
Construction permits are required if any process or control equipment emit pollutants to the outside air. Permits must be obtained prior to construction of new emission sources.
Existing unpermitted emission sources must obtain a construction permit “as built.”
No construction permit is required for general room exhaust air so long as the general room exhaust is free of pollutants.
Generally, exhaust from a wash booth does not require a construction permit. Steam or water vapor is not considered a pollutant. Some cleaners and detergents used in the washing operation, which are emitted, may require a construction permit for the wash booth.
112(r) Risk Management Program
If your facility uses a 112(r) regulated substance in excess of the threshold quantity, a Risk Management Plan may have to be developed and implemented.
Title V Operating Permits
A Title V Operating Permit is required if your facility has the “potential” to exceed the emission threshold limit on one (1) or more of the listed 189 hazardous air pollutants (HAPS).
Water Management, Environmental compliance Region VII Environmental Protrection Agency
Agency
Office of the Regional Counsel
Environmental Protection Agency
Region VII
726 Minnesota Avenue
Kansas City KS 66101
Phone: (913) 551-7281
National Pollutant Discharge Elimination System (NPDES)
Any discharge of any pollutant to waters of the U.S. from a point source must be authorized by a NPDES permit. Permission to discharge pollutants into a municipal sanitary sewer system requires the municipal sanitary sewer operator’s permission. The municipal sanitary sewer system operator may be required to obtain a NPDES permit.
Storm Water Discharge
A storm water discharge permit for rainwater runoff may be required if the SIC code of the industry is on the list of SIC codes requiring regulation of storm water discharge. The storm water discharge permit may make up all or part of the company NPDES. SIC Code 2011 covers meat packing plants. This SIC code requires a storm water discharge if there are any materials, products, machines, etc., located outside and not under cover.
Sanitary Septic System
If a sanitary septic system is to be installed, a permit must be obtained from the specific county public health department.
Wastewater Lagoon or Settling Pond
If material from a lagoon or settling pond is discharged into a large municipal publicly owned treatment works (POTW), the POTW will generally regulate the waste stream. Discharge into a small POTW is usually regulated by the Iowa Department of Natural Resources as is any discharge into state waters.
Waste Management, Environmental Compliance Region VII Environmental Protection Agency
Resource Conservation & Recovery Act (RCRA)
Persons who generate, transport, treat, store or dispose of solid wastes must determine if their solid waste is a hazardous waste. If the solid waste is a hazardous waste an EPA identification number must be applied for and received. Rules regarding generation, storage, transporting and record keeping must be followed. The transportation of hazardous waste may have to be documented on a manifest. The hazardous waste generator may have to prepare and submit a Biennial Report.
SARA Title III - The emergency Planning & Community Right-To-Know Act (EPCRA)
Sections 301-303
If specific chemicals are present in amounts exceeding the chemicals threshold planning quantity, emergency planning must be completed.
Section 304
Requires the reporting of a release of any listed chemical in excess of the reportable quantity (RQ).
Sections 311-312
Your facility may be required to report the presence of specific hazardous chemicals if the hazardous chemicals are present in quantities exceeding specified thresholds. A Tier I or Tier II form is used for the reporting requirement.
Section 313
If your facility manufacturers or processes a listed toxic chemical in quantities exceeding 25,000 pounds per year or otherwise uses listed toxic chemicals in quantities over 10,000 pounds per year, a Form R must be completed and submitted annually for each chemical exceeding the limits. Note: Filing a Form R fulfills the requirement to file a Tier I or Tier II form.