OSHA Compliance Posts

Someone requested OSHA to address the growing field of virtual reality safety and health training. Their letter constitutes OSHA’s interpretation ONLY of the requirements herein, and may not be applicable to any questions not delineated in the original correspondence. Your paraphrased questions and our responses follow. Question: We have been told online, commercially available, training…...

OSHA’s latest position on testing electrical gloves is very enlightening!  For example, even if the gloves are simply electrically tested and then returned to storage, OSHA regards the gloves as being issued for use!  This is a new one on me, but in their latest LOI they discuss the following scenario: gloves got tested on…...

I am sharing this OSHRC decision to demonstrate how a citation can be vacated with PROPER supervision and training on machine hazards, guarding, and LOTO.  In this case, an employee opened a guard, reached into the machine to clean/clear breading and the machine started – grabbed his smock and caused serious injuries to his right…...

Many consumers may have never heard of “nitriding”, but just about every metal component in heavy equipment will go through a “nitriding process” to strengthen the metal.  And it is this nitriding process that many businesses have a HIGHLY CONFIDENTIAL/PROPRIETARY blend for their process.  Seems everyone has a slightly different blend and they hold this…...

It seems that just about every month, even during the COVID Pandemic, we come across a safety professional, 3rd party auditor, and even an OSHA CSHO who will swear on his/her grandmother’s grave that the ONLY acceptable HAZCOM labels in the workplace are those that contain: Product identifier; Signal word; Hazard statement(s); Pictogram(s); Precautionary statement(s);…...

At 7:00 p.m. on December 4, 2019, an employee was working at a machine shop. He was operating a CNC (computer numerical control) lathe to machine material. The machine was equipped with an interlock system.  The interlock system was supposed to prevent the lathe from functioning if its door was open; however, the interlock system…...

I am going to guess that the facility’s inventory was less than 10,000 pounds of Propylene as OSHA issued no PSM citations, only a HAZCOM training citation and a GDC citation for four (4) issues they found with how the flammable gas was managed.  Another incident showing OSHA’s weakness with “flammable gases”; they NEED a…...

It is important to understand that the temporary enforcement guidance memoranda do NOT offer blanket waivers or exemptions for complying with any OSHA standards or provisions of such standards, including the Respiratory Protection standard (e.g., annual fit-testing requirements). Rather, they allow for enforcement discretion by CSHOs during the COVID-19 pandemic period in circumstances where an…...

The United States Coast Guard (USCG) has issued a Safety Alert to emphasize the importance of properly installed and maintained listed or certified safe electrical equipment in hazardous areas in order to reduce the risk of fire or explosion on board vessels. The publication follows an increasing number of instances by the Coast Guard where…...

It’s been 8 years since we have been using the Globally Harmonized System for our Hazardous Communications.  This much-needed update to OSHA’s HAZCOM standard was intended to correct many bad practices and to “harmonize” the USA with the rest of the world.  One of the big drivers for this change was the need to formalize…...