OSHA Compliance Posts

Employers Seeking Relief Under Temporary Enforcement Guidance (Respiratory Protection)

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…...

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More COVID-19 safety and OSHA inspections (HAZCOM and Flammable Liquids)

This week I received a call from a client who had yet another visit from OSHA regarding COVID-19 complaints, but this time the CSHO was an experienced safety professional who peeled that onion back a few more layers and thus she was recommending a serious violation of HAZCOM related to the COVID-19 safety program.  What…...

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Addressing Hazardous Area Electrical Installations (USCG)

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…...

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How high are your loading docks? (1910.28(b)(1))

This citation is what we call a “gimme” as this can be found at just about every workplace that has loading docks.  We have written this up many times during our S&H audits, only to get some lovely looks and compliments from the facility personnel.  Many seem to think that if the dock is only…...

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The sad state of Hazard Communications in safety

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…...

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Cigarette lighters in pockets during hotwork – Allow or Prohibit?

Does your business allow workers to carry their personal lighters in their pockets?  In my word of Flammable Liquids and Gases (FLAGs) and HAZ MATs we never allowed people to have lighters on them while on our property – some companies do not even allow them in parking lots. In most of my plants, our…...

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Another welding on used container fatality

At 12:00 p.m. on November 5, 2019, Employee #1 was making a small spot weld on a piece of metal. He was performing the weld on a drum that contained windshield washer fluid, a CATEGORY 3 Flammable Liquid. There was an explosion, and the drum hit the employee’s face. Liquid splashed on the employee and…...

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OSHA issues a new CPL for Silca Exposures

This new Instruction establishes OSHA’s field inspection and enforcement procedures designed to ensure uniformity when addressing respirable crystalline silica exposures in the workplace. These two new expanded health standards, general industry/maritime (29 CFR § 1910.1053) and construction (29 CFR § 1926.1153), were published in the Federal Register on March 25, 2016, and became effective June…...

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The internet sensation… face coverings can cause headaches due to lack of Oxygen (Truth or Fiction?)

If you have not seen it yet, just wait and one of your anti-mask friends will be sure to share it with you.  My phone blew up this weekend from e-mails, texts, and FB messengers from friends concerned with what they saw before their very eyes.  I tried to explain what they were seeing, but…...

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OSHA HAZ COM citiations after Nitrogen asphyxiation fatality

I am sharing this citation as Nitrogen (N2) use is becoming more and more popular in businesses that often times may not have the level of safety necessary to store and handle this level of hazardous materials.  I have personally seen N2 being used in personal grooming services and microbrewing and now this was a…...

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OSHA, Hot Work, and our Grandfathers

A few weeks back one of my good friends and a hell of a process safety professional contacted me about OSHA’s Hot Work (HW) referenced RAGAGEP, NFPA 51B.  He wanted to be sure he was not missing something, as OSHA still references the Year 1962 Edition of NFPA 51B.  Just to show how broken OSHA…...

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OSHA Discretion in Enforcement when Considering an Employer’s Good Faith Efforts During the COVID-19 Pandemic

In light of the coronavirus disease 2019 (COVID-19) pandemic, OSHA understands that some employers may face difficulties complying with OSHA standards due to the ongoing health emergency.  Widespread business closures, restrictions on travel, limitations on group sizes, facility visitor prohibitions, and stay-at-home or shelter-in-place requirements may limit the availability of employees, consultants, or contractors who…...

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