OSH Plan for Textile Industry: Compliance with OSH Act 1994

This report presents an OSH plan tailored for a new textile manufacturing company in Nilai, Malaysia, addressing critical health and safety issues. The plan meticulously examines noise exposure, including permissible exposure limits (PELs), risk assessment methodologies, and various compliance strategies such as engineering and administrative controls, personal protective equipment (PPE), and audiometric testing programs. It delves into the USECHH regulations, covering the identification of hazardous chemicals, PELs, risk assessments, and exposure control measures. The report also emphasizes the importance of labeling, training, exposure monitoring, health surveillance, and record-keeping. The plan's core objective is to ensure the company's compliance with the Occupational Safety and Health Act 1994, thereby safeguarding worker health and safety in the textile manufacturing environment, while also discussing the role of NIOSH and OSHA regulations.

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Name of the student
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Executive summary
This study reassesses and confirms the National Institute of Occupational Safety and Health
(NIOSH) and Use and Standard of Exposure Chemical Hazardous to Health (USECHH)
suggested exposure cap for noise pollution and hazardous chemical exposure. This paper makes
suggestions that go beyond the efforts to maintain listening by relying on occupational Noise
induced hearing loss (NIHL) avoidance and USECHH provides a legal structure to monitor
chemical exposure to safety at work.

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Table of Contents
Introduction......................................................................................................................................3
Discussions......................................................................................................................................4
Task 1 - Noise Exposure Regulation...........................................................................................4
Permissible Exposure Limit (PEL) criteria..............................................................................4
Noise risk assessment..............................................................................................................5
Method of compliance.............................................................................................................5
Hearing Protection Devices.....................................................................................................6
Audiometric Testing Program.................................................................................................7
Record Keeping.......................................................................................................................8
Task 2 – USECHH Regulations..................................................................................................9
Identification of chemicals hazardous to health......................................................................9
Permissible Exposure Limit (PEL)........................................................................................10
Assessment of risk to health..................................................................................................10
Action to control exposure.....................................................................................................11
Labelling and Relabeling.......................................................................................................12
Information, training and instruction.....................................................................................12
Monitoring of exposure.........................................................................................................13
Health surveillance................................................................................................................14
Medical Removal Protection.................................................................................................14
Warning sign..........................................................................................................................15
Record Keeping.....................................................................................................................15

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Introduction
The textile and clothing manufacturing sector has been a significant and vibrant element
of newly industrialized countries and other status-aspiring nations ' financial development
attained in latest years. Malaysia is one such outlet, and a review of the latest developments in
the textile and clothing industries in Malaysia shows resourceful and continuous involvement in
this commerce. Textile factories comprise of a variety of activities including fibre synthesis,
spinning, manufacturing, dyeing and finishing. The method of manufacturing fibre textiles and
clothing includes a range of procedures, but the textile industry has significant safety and
hygiene problems. This report is about the different health and safety problems related to the
textile industry such as noise and chemical exposure and discusses on the plan to comply with
occupational safety and health act 1994 on noise issues. One of the earliest sectors has been
widely researched in textile activities and there are many norms in the workforce. Compared to
such significant Asian manufacturers as China, Hong Kong, Japan, Korea, Taiwan, the
Malaysian business is low. Yet as a growth industry, textiles have been specifically directed, and
forecasts call for steady growth and acceptance as a major manufacturing community. In
particular, the Malaysian Industrial Master Plan calls for enhanced quality products, maintaining
decent price levels and expanding export-oriented marketing. Since most development has been
attributable to export production, Malaysian companies and representatives are well conscious of
the financial consequences of international trade strategies and bilateral trade agreements.

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Discussions
The textile industry is a highest increasing area that contributes significantly to
Malaysia's economic development. In Malaysia, after both the electronic and palm oil sectors,
this sector is the third significant foreign exchange participant. However, there are certain major
safety and health problems in the textile industry that can be classified as exposure to chemicals
and noise.
Task 1 - Noise Exposure Regulation
Malaysia is taking major measures towards becoming an industrialized country by 2020,
which will involve strong and widespread use of chemical compounds. The 1997 OSH
Regulations (Classification, Packaging and Labeling) and the Chemical Health Risk Assessment
2000 Manual help workers evaluate either substantial substances are exposed to the employee
and further clinical supervision is required. The OSH Regulations 2000 (Use and Exposure
Standards for Chemicals Hazardous to Health) is another effort to improve the sustainable use of
chemical compounds. Congress proclaimed its objective to ensure secure and healthy operating
environments for every worker as far as feasible and to maintain our human capital. The National
Institute for Occupational Safety and Health (NIOSH) is responsible for recommending
occupational safety and health norms and identifying pollution levels that are secure for different
phases of work and also the concentration should be restricted to a certain level at which the
workers will have functional capacity, greater life expectancy and will not suffer any diminished
health. (Steege, Boiano & Sweeney, 2014)
Permissible Exposure Limit (PEL) criteria
The NIOSH recommended exposure limit (REL) for occupational noise uptake [ 85 dBA
as an 8-hour time-weighted average (TWA) ] was assessed using modern risk management
methods and integrating the audiometric range of 4000 Hz in the concept of hearing problem.
The revised risk analysis reconfirms 85-dBA REL assistance. With a 40 years continuous
experience of 85-dBA REL, the surplus danger of creating occupational NIHL is 8%
significantly smaller than the surplus danger of 25% at the 90-dBA permissible exposure limit
(PEL) presently imposed by the Occupational Safety and Health Administration (OSHA). The
Walsh-Healey exposure threshold of 90 dBA was initially enacted by OSHA as an 8-hour TWA

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with an exchange rate of 5 dB as its acceptable usage threshold for general industry. In 1974,
OSHA suggested a modified sound norm in response to the NIOSH requirement report but
leaving the PEL intact. The United States in 1969 under the influence of the Walsh-Healey
Public Contracts Act, the Department of labour issued a noise level. The norm encompassed a
constant noise PEL of 90 dBA. (Kostoff, 2018)
Noise risk assessment
The choice of an exposure limit relies on two parameter definitions: the optimum
tolerable loss of occupational hearing and the amount of the occupational noise-exposed labour
force for which the highest possible acceptable loss of occupational hearing is tolerated. In 1972
NIOSH evaluated the surplus threat of physical hearing loss as a feature of occupational decibel
exposure levels for a particular time frame (e.g., 40 years of working life). The excess risk of
hearing loss was reported to be 3%, 16%, or 29%, respectively, for a 40-year worker lifetime
commitment to standard regular noise frequencies of 80, 85, or 90 dBA. NIOSH suggested an 8-
hour TWA usage threshold of 85 dBA based on this risk assessment. A different category of
surplus threat was assessed using ONHS information with the ' 1997-NIOSH project ', which
varied from the 1972-NIOSH model. The two designs differed, considering the likelihood of
nonlinear noise impacts in the 1997-NIOSH model, whereas the 1972- NIOSH system was
focused exclusively on a linear hypothesis of noise impacts. Nonlinear models were discovered
to suit the data well and linear models close to the 1972-NIOSH model just did not match. In
unfavourable or abrupt listening environments, the 4000-Hz audiometric frequency is accepted
as both noises delicate and essential for understanding and hearing words. (Ahmed Khan,
Tabassum & Mustaq, 2014)
Method of compliance
Using various types of engineering devices can help in the decrease in noise intensity to
the extent significantly of reducing the danger of listening. Engineering and administrative
controls are essential to an effective hearing loss prevention program.
1. Engineering controls - Include modification or change in machinery or associated
physical modifications at the origin of noise or along the transmission route to decrease
the noise level at the ear of the worker.

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2. Administrative controls - A job or timetable change that reduces or eliminates employee
noise sensitivity.
3. Personal protective equipment - Control the sensitivity of the employee to the risk.
Noise barriers should minimize or eliminate pollution cause; stop noise from
transmitting, amplifying, and resonating; and keep employees from unnecessary noise intrusion.
For most forms of sound, they are technologically viable, but their financial development needs
to be determined individually. In some cases, applying a fairly humble sound abatement
resolution decreases the risk to the degree that other system components, such as audiometric
analysis and the use of auditory safety equipment, are no longer needed. The noise reduction
technique can be more complicated in most other instances and must be achieved over a time
frame in phases. Even so, the risk of deafness is decreased for each reduction of a few decibels,
interaction is enhanced and irritation related to noise is diminished.
Identifying the noise components and their comparative significance is the first stage in
noise control. In an industrial area with many origins of sound, this can be hard. This can be
accomplished using different techniques - Obtain a frequency spectrum from an octave band
analyzer, switch on and off multiple segments in the facility, or use provisional mufflers or
enclosures to remove origins of noise, and test regions near to sound level meter facilities to
identify predominant regions of sound. These steps will help to determine the noise elements that
most influence labourers and should be given priority when carrying out noise monitoring. Once
the triggers of sound have been recognized, an engineering control, administrative support or a
type of personal protective equipment can be selected to decrease noise, if noise consumption is
too big.
Protective listening systems
Workers are needed to carry auditory protectors as an 8-hour TWA when involved in
a job that exposes them to sound equivalent to or exceeding 85 dBA. The listed noise reduction
rating (NRR) of the company (which are presently used by OSHA to determine PEL
compatibility when engineering measures are being applied or are not viable) generally do not
represent real events. Auditory protectors shall adequately modulate noise to maintain the
noise affecting the worker (i.e., noise stress at the worker's ear when auditory protectors are

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carried) below 85 dBA as an 8-hour TWA. (Bockstael, Bruyne, Vinck & Botteldooren, 2013)
Workers with TWA exposures above 100 dBA for 8 hours should be provided with dual ear
cover (example - equip earplugs and earmuffs simultaneously). The designated sound restriction
levels (NRRs) shall be derived as represented to account for recognized variations between test-
derived amplification scores and the safety acquired by an employee in the actual globe:
1. Earmuffs — deduct 25% from the NRR specified by the producers
2. Slow recovery of formable earplugs — drop 50%
3. Other noise cancelling headphones — remove 70% of the NRR marked by the producers
Audiometric Evaluation
The workplace shall provide audiometry for all employees whose exposures as an 8-hour
TWA are equivalent to or greater than 85 dBA. Audiometric test results shall be conducted by a
doctor, an audiologist or an occupational hearing conservationist licensed by the Occupational
Hearing Conservation Accreditation Council (CAOHC), operating under instruction of an
audiologist or medical professional. The relevant specialist chart (e.g. licensing, accreditation, or
CAOHC license code) is registered on the audiogram of each worker. Audiometric screening
shall comprise of no less than 500, 1000, 2000, 3000, 4000, and 6000 hertz (Hz) air-conduction,
plain-tone, listening cap measurements. Right, and left ears are screened separately. As an
alternative and also as a helpful source of data about the aetiology of deafness, the 8000-Hz
baseline should also be assessed. Audiometric trials shall be performed with audiometers that
fulfill the requirements of the American National Standard Specifications for Audiometers and
are retained and used. Audiometers shall be given a regular functional check, an acoustic
configuration check whenever the functional check shows a baseline disparity of more than 10
dB of either earphone at any frequency, and an extensive yearly calculation check or until an
acoustic configuration indicates the need. The last yearly calibration deadline will be registered
on the audiogram of each worker. Audiometric trials shall be carried out in a space where
atmospheric sound volumes comply with all demands of the American National Standard for
Audiometric Test Rooms. Tools used for ambient noise measurement shall comply with the
American National Sound Level Meter Specification Type 1 and the American National
Standard Specification for Octave-Band and Fractional-Octave-Band Analog and Digital Filters.
Ambient noise concentrations must be inspected at least yearly for continuous on-site monitoring

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equipment. Ambient noise concentrations shall be checked regularly for portable monitoring
equipment, or whenever the plant is relocated, whichever is more frequent. Readings of
background noise shall be collected under circumstances that reflect the typical acoustic
environment probable to be available when audiometric screening is carried out. Background
noise concentrations are to be registered on each audiogram or otherwise rendered available to
the audiogram specialist editor. For all labourers who have to be enrolled in the HLPP, a baseline
audiogram shall be acquired before work or within 30 days of work. Workers shall not be
subjected to noise concentrations above or below 85dBA for at least 12 hours prior to obtaining
an audiometric test. Instead of the appropriate quiet duration, hearing protectors shall not be
used. (Yuen, 2014)
Record Keeping
Creating and retaining files on every part of the Hearing loss prevention programs
(HLPP) includes record holding. It is more than just a paperwork or machine data entry practice.
Record keeping presents the only convincing proof of correct, consistent and careful
performance of the HLPP parts. System documents are often required many years after
collection. The documents are ineffective if they cannot be determined to be true. It is clearly one
of the most key elements of HLPP to view paperwork. The individual shall keep an accurate
count of all required exposure readings of the noise exposure assessment. These documents shall
provide, at a minimum, the name of the employee being monitored; the identification number;
the roles performed and the areas of work ; the times and dates of measurement ; the type, brand,
model and size of hearing safety equipment used ; the thresholds of exposure assessed ; and the
identity of the person taking the readings. Copies of the exposure report of a worker arising from
this necessity are to be included in the medical chart of the worker along with the audiograms of
the worker.

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Task 2 – USECHH Regulations
Occupational Safety and Health (Use and Standard of Exposure Chemical Hazardous to
Health) Regulations 2000 (USECHH Regulations) were established to include a legislative
mechanism for controlling the contact of chemicals dangerous to occupational health. This
regulation is aimed at creating a limit for the individual in the industry to be exposed to
chemicals harmful to wellness. (Idris, 2019)
Identify health-dangerous chemicals
Health-dangerous database of chemicals.
1. An employee shall recognize and document all chemicals used in the workplace that are
dangerous to safety in a register.
2. The documents should maintained to be in a working and usable condition and that
should be revised regularly. The documents should consist of the following data:
 A list of all the chemical compounds that are danger to health
 Latest Chemical Safety Data Sheet for all dangerous chemicals apart from
pesticides
 The estimated amount used, manufactured or deposited for each of the chemicals
that are dangerous to safety by month or year
 The procedure and place of job in which dangerous chemicals are used
 All the harmful chemicals supplier’s name and address
3. The record is available to all personnel at the workplace who may be subjected to or
expected to be subjected to chemicals that are harmful to safety.
4. The rules in sub-regulation [1] and [2] shall not occur if the company has agreed with the
criteria of Regulation 9 (Waste generator shall keep an inventory of scheduled wastes)
and Regulation 11 (Scheduled wastes transported outside waste generator’s premises to be

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accompanied by information) of the 1989 Regulation on Environmental Quality (Scheduled
Wastes) (Osha.gov, 2000)
Permissible Exposure Limit (PEL)
 Ceiling Limit –
A worker’s role is to ensure and remember that no individual should be exposed to any
kind of hazardous chemicals that have been referred in the list in schedule 1 and at no
point of time should exceed the exposure of the chemical’s ceiling limit specified for that
chemical.
 8 Hour TWA –
1. An individual needs to ensure that, in an eight-hour work week shift, any
individual's exposure to any chemical harmful to safety mentioned in Schedule I
does not reach the eight-hour weighted average airborne concentration specified
in that schedule for that chemical.
2. Unresisting sub-regulation (1), any individual exposed to any chemical dangerous
to safety mentioned in Schedule I during the work shift shall not cross that
chemical's permitted exposure cap.
 Cooperation with the sensitivity cap permitted by the respirator –
1. The degree of security provided by the inhalator or the respirator during the
phases during which the inhalator is carried should be brought into consideration
for the intent of understanding whether the employee has met the permissible
exposure requirement.
2. During the interval when respirators are not carried to determine the regular time-
weighted median effect of the employee, the duration referred to in sub-regulation
(1) shall be compared with the exposure rate of the atmospheric volume.
3. For the purposes of this compliance, the degree of protection indicates the
proportion of pollutant outside the respirator's air volume to pollutant volume
within the respirator's face piece.

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Evaluation of wellness risks
An individual shall not do any job that is probably to attract or send any worker to any
chemical dangerous to safety unless the worker has produced a detailed analysis of the hazards
that the chemical causes to the employee's safety. According to the analysis the sub-regulation
(1) should contain the following:
 Potential dangers to an individual from exposure to harmful chemicals
 Methods and protocols embraced regarding the use of harmful chemicals for safety
 The complexity of the health hazard
 The level of exposure to such harmful chemicals
 The safety hazard arising from the use and disposal of chemicals from job operations
 Initiatives and processes for preventing an employee's vulnerability to dangerous
chemicals
 Measures, techniques and tools required to monitor any unexpected release of a chemical
dangerous to life due to discharge, spillage or failure of the system or machinery
 The need for an exposure surveillance program for employees
 The need for an initiative for health supervision
 The practice and retraining obligation for workers as needed by Regulation 22
(dosh.gov.my,2019)
If the work has already been started before the coming into effect of such Regulations
that may involve or is probable to introduce any worker to chemicals dangerous to safety, the
company shall perform the evaluation within one year from the date of commencement into
the practice of these Regulations. (Osha.gov, 2000)
Action to control exposure
An evaluation study suggests that intervention is needed to eliminate or decrease an
employee's sensitivity to dangerous chemicals for safety, such intervention may be taken by an
individual, including modifications to job processes, practices, procedures, factories or industrial
management machinery, within one month of acquiring the evaluation document from the
investigator. The company shall use the necessary monitoring steps to regulate chemicals
harmful to wellness: