OSHA Compliance Posts

OSHA reiterates the 15-minute flow requirement for eyewash stations

In a 2024 LOI, OSHA reiterated its position that an Eyewash (EW) station must be capable of delivering 15 minutes of water flow. This means these EW bottles are NOT an “approved” EW station. Even the double barrel wall mount with two (2) squirt bottles does not meet the minimum flow rates. However, OSHA has…...

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OSHA reiterates the 15-minute flow requirement for eyewash stations Read More »

Does OSHA accept fiberglass reinforced plastic (FRP) as a material for guard construction for belts and shafts?

OSHA will not issue citations to an employer that properly uses a non-metal guard so long as the guard is constructed of a substantial and suitable material. OSHA standard, 29 CFR § 1910.219(m)(1)(i) states: Standard conditions shall be secured by the use of the following materials. Expanded metal, perforated or solid sheet metal, wire mesh…...

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Does OSHA accept fiberglass reinforced plastic (FRP) as a material for guard construction for belts and shafts? Read More »

Are “reflective vests” a piece of PPE covered by 1910.132?

To be clear, I can’t entirely agree with Alaska OSHRC’s decision to dismiss the OSHA citation.  But I am also tired of the blanketing workplaces with hi-vis gear that is NO LONGER “highly visible” or “reflective.”  These vests and other HI-VIS gear are used WAY beyond their intended life cycle, making safety a highly visible…...

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Are “reflective vests” a piece of PPE covered by 1910.132? Read More »

Inspection Guidance for Animal Slaughtering and Processing Establishments

October 15, 2024 MEMORANDUM FOR: REGIONAL ADMINISTRATORS STATE DESIGNEES THROUGH: AMANDA L. EDENS, Deputy Assistant Secretary FROM: SCOTT C. KETCHAM, Director Directorate of Enforcement Programs SUBJECT: Inspection Guidance for Animal Slaughtering and Processing Establishments This memorandum establishes guidance for inspections conducted in all animal slaughtering and processing establishments, North American Industry Classification System (NAICS) 3116,…...

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Inspection Guidance for Animal Slaughtering and Processing Establishments Read More »

OSHA proposed Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings

A Proposed Rule by the Occupational Safety and Health Administration on 08/30/2024 OSHA is proposing to issue a new standard, titled “Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings”.  The standard would apply to all employers conducting outdoor and indoor work in all general industry, construction, maritime, and agriculture sectors where OSHA…...

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OSHA proposed Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings Read More »

Do you have long-term authorized Hot Work areas?

One of the quandaries I find with the “Safe HW Area” approach is those areas that are actually set up as weld shops with all the bells and whistles we want in welding shops, such as ventilation to control exposures resulting from welding, cutting, and grinding.  For example… 1910.252(a)(2)(viii) Ducts, requires that any ducts and/or…...

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Do you have long-term authorized Hot Work areas? Read More »

OSHA’s newest Quick Card on HAZCOM labeling is WRONG

Sometimes, this government wears me out. A friend and I had this discussion last week about Chemical Container Labeling. The standard is VERY CLEAR (for those who take the time to read it). It comes down to the following: 1910.1200(f)(1) Labels on shipped containers vs 1910.1200(f)(6) Workplace labeling So the first sentence in OSHA’s newest…...

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OSHA’s newest Quick Card on HAZCOM labeling is WRONG Read More »

OSHA will allow the use of the NHANES age-correction data for the creation and use of age-correction tables other than the ones in Appendix F under certain conditions

OSHA’s current age-correction table, Appendix F, discontinues at age 60. More people are working into their sixties instead of retiring, and there is no adequate way to assess presbycusis (age-related hearing loss) in these workers using the current OSHA table. OSHA’s age-correction tables were based on a small sample size and research from the 1970’s…....

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OSHA will allow the use of the NHANES age-correction data for the creation and use of age-correction tables other than the ones in Appendix F under certain conditions Read More »

Do OSHA’s sanitation requirements apply to railroad track employees and roadway maintenance groups that are working along the tracks?

Today, OSHA posted its latest LOI.  This one was regarding railroad track employees and roadway maintenance groups and the need to provide sanitation facilities for these workers. Question: Do OSHA’s sanitation requirements apply to railroad track employees and roadway maintenance groups that are working along the tracks? Answer: Yes. Under section 4(b)(1) of the Occupational…...

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Do OSHA’s sanitation requirements apply to railroad track employees and roadway maintenance groups that are working along the tracks? Read More »

Non-Compliant Exit Signs

A few weeks back, I mentioned that some “safety vendors” sell non-compliant EXIT signs. I received several inquiries about what I was talking about, as if “surely it’s not so.”  I am not going to call out these irresponsible safety vendors, but there are many!  I have even seen EXIT signs that the entire sticker/sign…...

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OSHA’s HIPP Proposed Standard (With my commentary and questions)

OSHA has released a proposed Heat Illness Protection Plan (HIPP) to protect millions of workers from the significant health risks of extreme heat. If finalized, the proposed rule would help protect approximately 36 million workers in indoor and outdoor work settings and substantially reduce heat injuries, illnesses, and deaths in the workplace. The proposed rule…...

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OSHA’s HIPP Proposed Standard (With my commentary and questions) Read More »

Slings Standard (29 CFR 1910.184) paperwork requirements

The Slings Standard (29 CFR 1910.184) specifies several paperwork requirements, depending on the type of sling (paragraph (e) of the Standard covers alloy steel chain slings; paragraph (f) covers wire rope slings; paragraph (g) covers metal mesh slings; paragraph (h) covers natural and synthetic fiber-rope slings; and paragraph (i) covers synthetic web slings)…. Membership Required...

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