Does 1910.146 allow (c)(5) AND (c)(7) to be used on the same PRCS at the same time? (Part 2)
A couple of weeks I posed this question, and I figured there is NOT a consensus among the safety community (including OSHA) as to whether (c)(5) AND (c)(7) can be used on the same PRCS at the same time. My position is NO, they can not be; but I am only one voice in the debate, and many excellent safety professionals have spoken up and said YES. I know it is not clear if we read all the OSHA materials (LOIs, CPL, and Preamble), and in fact, some of the written statements by OSHA do make it appear that both (c)(5) AND (c)(7) can be used on the same PRCS at the same time. But since I do not believe OSHA intended this, I am going to attempt to make the argument that (c)(5) AND (c)(7) are NOT to be used on the same PRCS at the same time. |
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