As this year comes to a close, I was reminded by a FaceBook post of a common misconception regarding 1910.119(f)(3), which is actually two (2) separate requirements/actions stated in a single paragraph of the standard. The standard states:
1910.119(f)(3) The operating procedures shall be reviewed as often as necessary to assure that they reflect current operating practice, including changes that result from changes in process chemicals, technology, and equipment, and changes to facilities. The employer shall certify annually that these operating procedures are current and accurate.
As we can see there are two (2) distinct actions stated above and it is the fact that these actions are DISTINCTLY DIFFERENT that I want to discuss.