OSHA Compliance Posts

What is an Injury & Illness Prevention Program (I2P2)?  It is a very basic, 8-element, safety management system (SMS).  It is OSHA’s attempt to fundamentally change from the complaince model to an SMS model to manage workplace safety and health.  OSHA has been talking about I2P2 for nearly 20 years and has faced relentless pushback…...

Control banding is a generic technique used to guide the assessment and management of workplace risks for chemicals without an occupational exposure limit (OEL). The majority of chemicals in commercial use do not have an established OEL. OELs include NIOSH Recommended Exposure Limits (RELs) and OSHA Permissible Exposure Limits (PELs). OELs help to assess and…...

WHY OIG CONDUCTED THE AUDIT OSHA is responsible for ensuring safe and healthful working conditions for millions of workers nationwide and does so partly by conducting inquiries and inspections of potential hazards. For Fiscal Year (FY) 2019 and FY 2020, inspections from complaints and referrals were slightly greater than 40 percent of OSHA’s total inspections…....

The Department of Industrial Relations Occupational Safety and Health Appeals Board (OSHAB) has issued a precedential decision regarding the provision of water at outdoor worksites, affirming that it must be as close as practicable to the areas where employees are working to encourage frequent consumption. The case clarified the definition of what “as close as…...

At 1:45 p.m. on July 18, 2022, an employee, 51, was preparing to replace an ice machine at a retail store. The employee searched for the electrical panel to de-energize the ice machine but could not locate it. The employee was employed by a refrigeration equipment company and did not work at the retail store…....

Here is the summary of the Apeals Coourts decision, and this was NOT a red tag program issue.  This was an INSPECTION and CORRECTION issue!!! Here is the summary of the decision from the United States Court of Appeals for the Seventh Circuit. Appellants Fun F/X II, Inc. and Cao Enterprises II, LLC (collectively “Fun…...

Not many folks spend a lot of time reading 1910.1020 Access to employee exposure and medical records and it shows during most of our OSH audits.  The standard is not a safety standard, so most safety pros don’t spend much time on the standard.  But there is a lot of “document control and retention” needs…...

The OSHRC has vacated four (4) heat-related OSHA citations against the United States Post Office.  This decision was based ON LEGAL matters regarding the Feasibility of Abatement of the Hazard.  ALL parties agreed to the fact that HEAT CAN BE A HAZARD, but when OSHA issues a GDC Citation, it must provide feasible abatement measures. …...

Last month I wrote a few posts about how a compliance manual made up of dozens of individual safety programs written for OSHA compliance needs is not a safety management system (SMS).  That post got a lot of friends to encourage me to expand on that position and explain what I meant.  So using one…...

ATVs, commonly called 4-wheelers, have been around for decades.  Most people recognize the risks associated with these machines outside of the workplace.  The accident/injury statistics can be alarming.  But when management claims those accident statistics are not work-related and that somehow the risks these machines pose are less in the workplace may be a very…...

I will never understand why/how a location identifies a hazard, in this case, OSHA identified it, failed to take that learning, and did NOT APPLY it across the business where that hazard is present.  In this case, a federal workplace safety investigation at a cattle processing plant – now cited seven times by inspectors for…...