OSHA Laws That Affect Council Offices and Camps
The following is provided as general guidance and does not cover all potential safety and health hazards workers may be exposed to in the council office or at camp. If further guidance is needed, the council office or camp should consult OSHA's website at www.osha.gov or contact the closest OSHA area or state plan office.
OSHA Workplace Poster
- The OSHA workplace poster, publication No. 3165, or appropriate state plan OSHA workplace poster must be displayed in a conspicuous place or a place where notices to workers are customarily posted. Commercially available five-in-one posters are acceptable.
Occupational Injury and Illness Recordkeeping and Reporting (29 CFR 1904)
- A council office or camp (NAICS 813410/SIC 8641) is not required to keep injury or illness records unless requested in writing to do so by OSHA, the Bureau of Labor Statistics (BLS), or a state agency under the authority of OSHA or the BLS.
- A council or camp is required to report to OSHA (1-800-321-OSHA) or the nearest area/state plan office any worker fatality or hospitalization of three or more workers. This includes seasonal staff at council camps during the summer or at other times.
Programs/Plans and Training
See OSHA Safety and Health Topics
A program/plan is needed for the following:
Note: The BSA has provided the following model written plans on the Scouting Safely Web page:
Training is required for the following:
Emergency Action Plans and Fire Prevention Plans (29 CFR 1910.38/29 CFR 1910.39) (when required by a specific OSHA standard)
- A written emergency action plan addressing as appropriate fires, floods, earthquakes, tornadoes, hurricanes, etc., must be in effect. Coordinate the development of the plan with local emergency management.
- A fire prevention plan must include at a minimum a list of all major fire hazards, proper handling and storage procedures for hazardous materials, potential ignition sources and their control, and the type of fire protection equipment necessary to control each major hazard.
- Portable fire extinguishers must be mounted, located, and identified so they are readily accessible for use.
- All fire extinguishers must be certified annually. Fire extinguishers must also be visually inspected monthly, with the inspector initialing and dating the tag.
- Emergency evacuation floor plans that indicate exits, location of fire extinguishers, and the assembly area must be posted in appropriate areas, e.g., headquarters building, commissary, dining hall, health lodge, etc.
Walking/Working Surfaces (Subpart D) (see also Ladders)
- All stairs with four or more risers must have a standard handrail.
- Work areas must have at least two exit routes.
- Every opening, floor, or platform 4 feet or more above ground level must have a standard rail 42 inches high, a 21-inch midrail, and toe boards.
- Temporary openings must have standard railings as above or be constantly attended.
- Construction areas where floor openings, open sides, and hatchways are 6 feet above the working/walking surface must have standard railing (42-inch top rail and 21-inch middle rail), fall protection (full body harness and lifeline), or a safety net. This is covered in OSHA Standard 29 CFR 1926.501. Although this is a construction industry standard, all people who perform this type of construction work must comply. This includes ranger activity.
- Floors must be free of protruding nails, splinters, holes, and loose floorboards.
- Only tools in good condition may be used. Tools with cracked or broken handles or mushroom or broken heads must not be used.
- When welding or cutting, proper personal protective equipment such as face shields with proper welding lenses, protective gloves, and leather apron must be used. Adequate ventilation must also be used where appropriate. Proper grounding to prevent flash must be ensured.
Ladders (29 CFR 1910.25–1910.27)
- Portable stepladders must be maintained in good condition. Portable rung ladders must have safety feet securely bolted or fastened.
- Metal ladders must be equipped with nonslip rungs.
- Nonconductive ladders must be used in the area of electric lines and equipment.
- Ladders must be inspected frequently, and those that have developed defects must be withdrawn from service for repair or destruction and tagged or marked "Dangerous, Do Not Use."
- Self-supporting (foldout) and non-self-supporting (leaning) portable ladders must be able to support at least four times the maximum intended load, except extra-heavyduty metal or plastic ladders, which must be able to sustain 3.3 times the maximum intended load.
- Non-self-supporting ladders, which must lean against a wall or other support, are to be positioned at such an angle that the horizontal distance from the top support to the foot of the ladder is about one-fourth the working length of the ladder. In the case of job-made wooden ladders, that angle should equal about one-eighth the working length. This minimizes the strain of the load on ladder joints that may not be as strong as on commercially manufactured ladders.
- Ladder rungs, cleats, or steps must be parallel, level, and uniformly spaced when the ladder is in position for use. Rungs must be spaced between 10 and 14 inches apart. For extension trestle ladders, the spacing must be 8–18 inches for the base, and 6–12 inches on the extension section. Rungs must be shaped so that a person's foot cannot slide off and must be skid-resistant.
- Ladders are to be kept free of oil, grease, wet paint, and other slipping hazards. Wooden ladders must not be coated with any opaque covering, except identification or warning labels on one face only of a side rail.
- When information indicates that any employee's exposure may equal or exceed an eight-hour time-weighted average of 85 decibels, the employer shall develop and implement a monitoring program.
- A hearing conservation program must be established for all employees exposed at or above 85 decibels.
- Hearing protection in the form of earplugs or earmuffs must be provided (at no cost to employees) at locations with designated hearing protection areas (e.g., rifle/shotgun range).
Personal Protective Equipment (PPE) (29 CFR 1910.132)
- A hazard assessment must be made of each work area to determine what, if any, personal protective equipment (PPE) must be used by employees to protect their head, eyes, ears, face, hands, and feet.
- Employees must be trained in the proper selection and use of the PPE they are required to use, as well as in the potential for injury to these areas of the body.
- Respiratory protection (29 CFR 1910.134) must be worn whenever such equipment is necessary to protect the health of the employee. Where respirators are used, a written respiratory protection program is required that includes worksite-specific procedures and elements for required respirator use. The program must be administered by a suitably trained program administrator.
- Bump caps should be worn at all times by maintenance employees while on the job. Hard hats must be worn in construction zones and when there is an overhead hazard.
- Toilet facilities must be adequate for the number of employees.
- Toilet room doors must have self-closing devices.
- Individual towels or drying equipment must be provided in employee washrooms.
- Potable water must be provided in all places of employment.
- Toilet facilities must be occupied by no more than one person at a time, be lockable from the inside, and contain at least one water closet. Separate toilet rooms for each sex need not be provided.
- All employee food service facilities must be maintained and operated in accordance with sound hygiene principles.
- Food must be processed, prepared, handled, and stored in such a manner as to be protected against contamination.
- Passageways, storerooms, service rooms, and work areas must be clean and have clear aisles; all floors must be clean and dry.
- Covered receptacles must be provided in eating areas and emptied not less than once daily.
- Where disposable drinking cups are provided, a container must be provided for disposal of used cups.
Accident Prevention Signs and Tags (29 CFR 1910.145)
- Permanent passageways and aisles must be appropriately marked.
- Exits must be marked by a readily visible sign and must be illuminated by a reliable illumination source.
- Doors or openings that are not a means of exit and that are not otherwise identified must be marked with a sign that reads, "Not an Exit." Where exits are not clearly visible from work areas, signs pointing to exits must be posted.
- Circuit-breaker switches must identify the circuits
- No Smoking signs must be posted in areas where conditions require them.
- Load limits must be marked where storage is on a second floor, balcony, or other overhead area and on storage shelves.
- All hazardous substances, i.e., those in containers labeled with the signal words "poison," "danger," "caution," or "warning," must be properly labeled when transferred to secondary containers.
- Signs indicating personal protective equipment required by work areas must be posted.
- Signs indicating a potential lead area must be posted at the firing range.
- Fan blades must be guarded with a screen or a similar material having openings no larger than 1⁄2 inch when the blade is less than 7 feet from the floor.
- Work rests on bench grinders must be maintained 1⁄8 inch or less from the grinding wheel. Tongue guards must be adjusted to within 1⁄4 inch from the grinding wheel. Eye protection must be worn in grinding areas.
- The spindle end, nut, and flange projections must be guarded.
- All portable power-driven circular saws must be equipped with guards above and below the base plate or shoe.
- Woodworking machinery such as table saws, band saws, and radial saws must be properly guarded, except that portion of the blade that does the actual cutting.
- All belts, pulleys, sprockets, and roller chains must be properly guarded.
Electrical (Subpart S)
- Drop cords, trouble lights, and extension cords must be of the "three-wire grounded" type, properly insulated, and free of cuts, frays, splices, and exposed wires.
- Unused or abandoned electric receptacles must be plate-covered.
- A de-energization (lockout) program must be provided to render inoperable those machines operated by electric motors or pneumatic or hydraulic power while repairs are being made.
- All metal electrical equipment (refrigerators, coffee makers, vending machines, etc.) must be grounded using a three-wire cord and three-prong plug.
- All hand power tools must be double-insulated or havea three-prong plug and three-wire cord. Double-insulated power tools must not be used in wet or damp areas.
- Ground-fault circuit interrupters must be used in wet locations (e.g., bathrooms, kitchens, basements, and outside locations).
- Receptacles should be checked periodically to affirm that polarity is correct.
- Access to electrical panels must be unobstructed.
These points apply to potential lead exposure (e.g., shooting sports firing ranges—rifle, shotgun). Camps must provide proper personal protective equipment and require hygiene practices for staff exposed to lead-based ammunition. This also applies to cleaning of the firearms. Ammunition can contain as much as 70 percent lead.
- A written lead program is required where employees are exposed to lead.
- Hand-washing facilities must be available and required to be used by range staff. Soap and water at a minimum must be used to wash hands.
- When handling lead-based ammunition, proper PPE (e.g., disposable gloves) at a minimum must be used. All lead-contaminated PPE must be disposed of in a properly covered container.
- Employees must be properly trained in the hazards of lead (see Hazard Communication).
- Cleaning of firing ranges must not be done by volunteers or staff. Decontamination and remediation of firing ranges must be conducted by a licensed lead abatement contractor.
- These points apply to any chemical known to be present in the workplace that employees may be exposed to under normal conditions of use or in a foreseeable emergency.
- A written hazard communication plan is required where employees are using hazardous chemicals.
- Containers received from a manufacturer or distributor must be properly labeled with the identity of the hazardous chemical(s); appropriate hazard warnings, including target organs; and the name and address of the manufacturer or distributor.
- Secondary containers must contain the identity of the hazardous chemical(s) and appropriate hazard warnings.
- Safety Data Sheets (SDSs; also known as Material Safety Data Sheets or MSDSs) must be maintained and readily accessible to employees.
- Employees must be properly trained in the hazards of the chemicals they use or are exposed to.
- These points apply to all employees who could reasonably be anticipated to have occupational exposure to blood or other potentially infectious material (OPIM) (e.g., camp medical staff, camp lifeguards, and designated first-aiders). Employees must be provided training in the methods of compliance, hazards of BBP, hepatitis B vaccinations, and postexposure evaluation and follow-up.
- Nondesignated first aiders (Good Samaritans) are not covered.
- A written exposure control plan must be developed in accordance with 29 CFR 1910.1030.
- Minimal personal protective equipment includes disposable nonlatex, nitrile, or vinyl gloves and disposable mouth shields for CPR.
- Hepatitis B vaccinations must be made available at no cost to all occupationally exposed employees (e.g., camp lifeguards).
General Health and Safety
- A physician-approved first-aid kit must be available.
- Approved self-closing metal containers must be available for handling flammable liquids, e.g., gasoline and paint thinners.
- Approved flammable-liquid storage cabinets must be provided where flammable liquids are routinely stored. The cabinets must be properly grounded.
- Closed containers must be provided for disposal of oily rags.
- Lighting in work areas must be adequate for the work being performed.
- Seat belts where available are required to be worn and must be used in all off-highway vehicles (e.g., tractors, dump trucks)
- Permissible noise-exposure levels must have been checked in necessary areas, and personal protective equipment must be provided as needed, e.g., on rifle ranges.
- Storage of material must not create a hazard. Bags, containers, etc., must be stacked, blocked, interlocked, and limited in height so that they are stable and secure against sliding or collapsing.
- All hand and power tools and similar equipment must be maintained in a safe condition.
- Compressed air must not be used for cleaning purposes except where reduced to less than 30 psi, and then only with effective chip guarding and PPE.
- When welding or cutting, proper grounding to prevent flash must be ensured.
Although not required by OSHA, the National Health and Safety Support Committee highly recommends that each council and camp have an active enterprise risk management committee.
An enterprise risk management committee or health and safety committee or a qualified person should be appointed to conduct periodic inspections. Copies of the inspections should be maintained on file. Safe camps and offices result from good planning.
Additional OSHA information, guidance, e-tools, and publications can be obtained by visiting OSHA's website at www.osha.gov or by calling the nearest area/state plan office.
Note: The OSHA standards cited in this guidance document are only general industry standards, 29 CFR 1910. For construction standards, 29 CFR 1926, council offices and camps should consult OSHA's website at www.osha.gov.