OSHA Compliance Posts

OSHA’s Application of Instance-by-Instance Penalty Adjustments

The current Instance-by-Instance (IBI) policy, published in 1990, applies only to willful citations. OSHA believes that a more expansive application of IBI will incentivize employers to proactively prevent workplace fatalities and injuries and provide OSHA with another tool to use on its mission to ensure safe and healthful working conditions for America’s workforce.  The scope…...

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Fires in Structures under Construction (NFPA)

We were debating this in the SAFTENG social media groups… are these fires happening more frequently or is social media making it easier to learn about these events?  Well the NFPA has studied the fires involving structures under construction from 2016-2020 to answer a lot of questions.  The one piece of data that got my…...

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The 2021 IMC catches up to the large-diameter ceiling fans

Most of us have seen these “Big _ss” fans before.  They move a lot of air and work well. (This is not an endorsement of the brand).  Now, the 2021 International Mechanical Code (IMC) has caught up with these types of large-diameter ceiling fans. These fans are DEFINED and QUANTIFIED as: A ceiling fan that…...

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OSHA issues LOTO, PRCS, and RP citations @ malthouse ($174K)

A Wisconsin company that supplies malt barley to major craft breweries, home breweries, and other spirit and food production in the Midwest has again been found exposing employees to dangerous workplace hazards by federal safety inspectors.  OSHA has proposed penalties of $174,351 after inspectors identified two repeated and 14 serious safety and health violations after…...

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OSHA and Temporary Heating Devices

It is that time of year again… these heaters can become a serious hazard in the workplace.  And each year I get emails asking for help in controlling their use.  And as you know, I love to use safety standards that may not be legally applicable but provide excellent guidance to improve safety.  For those…...

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Ever wondered where fire extinguishers may be required above and beyond the typical locations?

Another reason I like using the IFC over OSHA standards is that they take a lot of guesswork out of the safety equation!  Take, for example, the following list of 42 specific locations where a fire extinguisher is required based on the hazard…… Membership Required You must be a member to access this content.View Membership...

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OSHA’s position on Flammable Gases and GHS Rev. 7 Adoption

As we have discussed at length, OSHA is in the process of updating the HAZCOM Standard (1910.1200) to reflect GHS Rev. 7.  The most significant change in this adoption will be how Flammable Gases are categorized in 1910.1200 Appendix B, and this will also impact the PSM standard (1910.119) application.  Here is OSHA’s official justification…...

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OSHA Respiratory Protection Activity in 2022

In OSHA’s fiscal year (October 2021 through September 2022), the agency conducted 151 Respiratory Protection inspections and issued 325 citations, with penalties totaling $1,388,505.  62311 / Nursing Care Facilities (Skilled Nursing Facilities) was #1 in Citations with 325 62311 / Nursing Care Facilities (Skilled Nursing Facilities) was #1 in Inspections with 151 62211 / General…...

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Cathodic Protection and the Utilization of Metallic Bonding to Control Hazardous Energy

Background: CP rectifiers protect pipes against corrosion. Their use is mandated on liquid and gas pipelines by the Department of Transportation’s (DOT), 49 CFR § 195.573 (liquid pipelines) and § 192.465 (gas pipelines). While 29 CFR 1910.147 standard may control the hazards associated with the operation of CP rectifiers, it does not eliminate the other…...

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OSHA EXIT signs and ISO’s international emergency exit symbol as defined in ISO 7010 (OSHA LOI)

Does § 1910.37(b)(7) permit the display of the ISO’s international emergency exit symbol as defined in ISO 7010 beside the mandatory EXIT text on an existing exit sign?… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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OSHA HAZWOPER Activity in 2022

In OSHA’s fiscal year (October 2021 through September 2022), the agency conducted 18 HAZWOPER inspections and issued 29 citations, with penalties totaling $124,086.  42469 / Other Chemical and Allied Products Merchant Wholesalers was #1 in Citations with 5 42469 / Other Chemical and Allied Products Merchant Wholesalers, 32521 / Resin and Synthetic Rubber Manufacturing, and 33231…...

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