OSHA Compliance

OSHA has a long and consistent history of interpreting its standards and other requirements to require employers to present information in a manner that their employees can understand. See, e.g., CPL 2-2.38(D)(1998) (“[i]f the employees receive job instructions in a language other than English, then training and information to be conveyed under the [hazard communication…...

Paragraph (c) of 29 CFR 1910.151 requires that suitable facilities for quick drenching or flushing be provided within the work area for immediate use if an employee’s eyes or body may be exposed to corrosive materials. The OSHA standard does not set specifications for emergency eyewash and shower equipment, but we agree that equipment that…...

The NIOSH Hearing Loss Simulator is a software training and communication tool for promoting hearing loss prevention. It allows a user or trainer to demonstrate the effects of noise exposure on hearing without experiencing an actual noise-induced hearing loss. Estimates of the effects of different levels of noise exposure are based on the American National…...

Although this decision was really about when OSHA can cite an employer for exposure to a hazard.  The company claimed there was none or very little exposure to these unguarded lathe chucks because only one worker used these lathes only once or twice a year; however, OSHA cited for the unguarded equipment based on this…...

A few months back I posted an article regarding OR-OSHA’s revisions to their “STATIONARY COMPACTORS, SELF-CONTAINED COMPACTORS AND BALERS” standard and offered up the idea that we could/should be using this state plan standard as our own guidance in how we manage safety around our equipment, even though we are not in the state of…...

A few months back I posted an article regarding OR-OSHA’s revisions to their “STATIONARY COMPACTORS, SELF-CONTAINED COMPACTORS AND BALERS” standard and offered up the idea that we could/should be using this state plan standard as our own guidance in how we manage safety around our equipment, even though we are not in the state of…...

When we do our many third-party S&H audits around the country, there are a few findings we could just leave on our spreadsheet as they are so common from business to business. One of these common findings is the lack of annual training for employees on their rights to access, view, copy, etc., their own…...

Have you ever seen a fire extinguisher with a HAZCOM label (e.g., NFPA 704 or HMIS) and thought to yourself…that is overkill? Well, actually, it is not overkill, and it may be a requirement for the facility under the HAZCOM standard when the extinguisher contains a hazardous chemical. OSHA defines compressed gas as a physical…...

1910.303(g)(1): “Space about electric equipment. Sufficient access and working space shall be provided and maintained about all electric equipment to permit ready and safe operation and maintenance of such equipment.” 1910.303(g)(1)(i): “Working space for equipment likely to require examination, adjustment, servicing, or maintenance while energized shall comply with the following dimensions, except as required or…...

OSHA does have an exception to “consumer products” in regard to what has to be in the HAZCOM program. For example, Windex would be excluded if the quantities used on site are that of what a consumer would use. So, if you have a few bottles of Windex in janitorial closets, you do not need…...

Each year, HAZCOM is OSHA’s most often cited standard, and many of us would agree that a HAZCOM program is like the “A” of the ABCs of safety. However, we often see programs that are not up to 100% compliant. Here are the OSHA requirements for our written program. Does your program meet these? In…...