OSHA Compliance Posts

OSHA compliance update 2022

In OSHA’s fiscal year (October 2021 through September 2022), the agency conducted 17,353 inspections; issued 46,662 citations, totaling $192,778,680. The industry with the most inspections: 23816 / Roofing Contractors (3,182) The industry with the most citations: 23816 / Roofing Contractors (7,820)  The industry with the most $ in penalties: 23816 / Roofing Contractors ($33,003,232) #Cited…...

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How can improperly maintained eyewash stations cause infections?

Water found in improperly maintained eyewash stations is more likely to contain organisms (e.g., Acanthamoeba, Pseudomonas, Legionella) that thrive in stagnant or untreated water and are known to cause infections. When a worker uses an eyewash station that is not maintained, organisms in the water may come into contact with the eye, or skin, or…...

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Emergency egress and Security Turnstiles

Many facilities have security requirements due to their handling, storage, and/or processing of certain hazardous materials.  These facilities will use perimeter security barriers such as fencing and personnel turnstiles.  And one of the top egress questions we get during audits is regarding the security turnstiles that are also part of the emergency egress path.  OSHA’s…...

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Improving the means of egress illumination

If the means of egress bothers you, look no further than your state’s fire code for a beefed-up standard on egress.  OSHA standards are outdated and only intended to establish a “floor” that every employer has to work above.  Even OSHA will tell you that complying with their standards will NOT help a business achieve…...

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Buyer Beware – OSHA 10-Hour General Industry course does NOT make a facility compliant

In the past 4-5 months, I have received numerous phone calls and e-mails from friends/clients regarding their desire to hold an OSHA 10-hour course for their employees.  Most of this is driven by the idea that they believed, as they were told by some less than scrupulous consultants, that OSHA would accept their 10-hr card…...

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CALOSHA’s revises its Controls for Hazardous Energies Guide

Last month CAL-OSHA issued a revised guide on Controls for Hazardous Energies.  This is a MUST-HAVE for all safety professionals responsible for their Lockout/Tagout (LOTO) Program.  Never mind that it is a State OSHA program publication – this is a solid document that explains the in’s and out’s of LOTO.  My favorite section… Interlocks Are…...

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Covid-19: OSHA’s enforcement activities did not sufficiently protect workers from pandemic health hazards

WHY OIG CONDUCTED THE AUDIT The Occupational Safety and Health Administration (OSHA) is responsible for ensuring safe and healthful working conditions for 130 million workers employed at more than 8 million worksites. It does so by setting and enforcing standards and by providing training, outreach, education, and assistance to employers and employees. The COVID-19 pandemic…...

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“Distance” as a passive mitigation measure

Last week I wrote about how either distance or a barrier is necessary to CONTROL hazards.  OSHA’s made a great case in 2020, explaining how the separation distances in 1910.110 is a PASSIVE MITIGATION measure.  (emphasis by me) OSHA concludes that NFPA 58 (2017), Sections 6.28.2 and 6.28.3, do not provide an equivalent level of…...

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Flashback arrestors are PROTECTION devices, not prevention devices

In a recent discussion regarding an accident with a Fuel-Oxy Torch system, I had some discussions about the layers of protection and the Prevent-Protect-Mitigate safety model using the Hierarchy of Controls (Elimination, Substitution, Engineering Controls, Administrative Controls, and PPE).  The event did NOT involve a flash-back, but I used the flash-back requirements to demonstrate the…...

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CT-OSHA also pushing ANSI Z358.1-2014

In this month’s CT-OSHA Safety Newsletter, the agency is pushing the ANSI Z358.1–2014 standard as their baseline EW/SS enforcement standard.  The entire newsletter, which you should sign-up for, is dedicated to EW/SS’s and is full of great info.  I am not a lawyer, but I do not think they can enforce a consensus standard that…...

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NV-OSHA adopts ANSI Z358.1-2014

Nevada OSHA adopted regulation R069-20, which includes the adoption by reference of ANSI Z358.1-2014 for Emergency Eyewash and Shower Equipment.  By adopting ANSI Z358.1-2014, Nevada OSHA has identified the minimum design and installation criteria necessary to meet the definition of suitable facilities, which is otherwise undefined in federal statute. Additionally, training requirements have been introduced…...

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