OSHA Compliance Posts

OSHA and NFPA Breathing Air Compressor testing and postings

Those of you that have been reading my materials for the past 20+ years know that I can be rather extreme when it comes to critical safety items such as SCBA’s used in IDLH atmospheres.  I make no apologies for my positions and my directness – heck I think more of you need to be…...

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Regional Emphasis Program for Fertilizer Grade Ammonium Nitrate (FGAN) and Agricultural Anhydrous Ammonia Facilities

The intent of this Regional Emphasis Program is to encourage employers to take steps to address hazards, evaluate facilities to determine if the employer complies with all relevant OSHA requirements, and help employers to correct hazards, thereby reducing potential worker injuries, illnesses, and deaths. Region VII OSHA proposes accomplishment through outreach and enforcement activities. Outreach…...

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Determining whether an injury would apply to the work-related exception personal task and outside the assigned working hours

Scenario: An employee experienced an injury when sharpening a personal pocket-knife while sitting in a company owned-truck parked in the employer’s parking lot. The employee lacerated the palm of his hand and was treated with seven sutures, and the employee returned to work immediately with no restrictions.  You state that because the employee was on his…...

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Determining whether an injury would apply to the work-related exception personal task and outside the assigned working hours Read More »

Flame Resistant Lab coats don’t belong in Process Areas

Way back in 1994 when I was implementing my first FRC program there was a great debate on the options that would be made available to operators, maintenance, engineering, EHS, and QA/QC personnel who perform work within a HAZLOC. This debate was of course driven by costs vs. risks and luckily I was working for…...

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Hazard Assessment and Verification (1910.132(d) & (g))

Sometimes the OSHA “Request for public comments” postings contains some really good insights as to the documentation aspect to OSHA compliance.  This week’s posting does a nice job of explaining all that is required to document our PPE Hazard Assessments: (emphasis by me, but 100% OSHA wording) Paragraph 1910.132(d)(1) and the Personal Fall Protection standard…...

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OSHA clarifies the 6-month testing frequency of Rubber Insulating Electrical Gloves (1910.137)

One of the more common deficiencies that we find in our audits is the lack of electrical gloves testing.  1910.137, Table I-5 establishes the testing frequency for these gloves; however, the confusion comes with the “footnote” which states… If the insulating equipment has been electrically tested but not issued for service, the insulating equipment may not…...

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OSHA clarifies the 6-month testing frequency of Rubber Insulating Electrical Gloves (1910.137) Read More »

Compressed Gas Labels and GHS

Many facilities have been struggling with their in-house labeling to meet OSHA’s Global Harmonized Standard (GHS) labeling.  I have written on this topic too many times to mention since 2015,  but one thing that I am finding and I can not explain is how compressed gas manufacturers have not revised their “shipped container” labels to…...

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Can we agree on the terms completely, fully, and absolutely certain?

It seems we, as a profession, struggle to get a consensus on those three words/phrase. For me, it is crystal clear, but for many others I find they wish to have some “room to work” in how they understand these terms to be used. I am often told I read the OSHA (i.e. barebones MINIMUM…...

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Can we agree on the terms completely, fully, and absolutely certain? Read More »

OSHA’s Spring Regulatory Agenda

Below are the items on OSHA’s regulatory agenda.  I have posted their scope on the standards that play a major role in the facility’s I do work in and links to all of the other items for those of interest to you…. Membership Required You must be a member to access this content.View Membership LevelsAlready...

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Car Wash Chain Conveyor sprocket guarding and employee misconduct

Although this serious injury incident occurred at a car wash, the decision of the OSHRC on guarding the chain conveyor and the workers having to work around it due to a change in work practices is an interesting take on “exposure to a hazard”.  If you have ever gone to a car wash that requires…...

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Fire aboard Cargo Ship Chipolbrok Moon (Hot Work Lessons Learned)

​On May 23, 2018, at 0010 local time, a fire was detected in a cargo hold on board the cargo ship Chipolbrok Moon while moored at the Industrial Terminal West in Greens Bayou in the Port of Houston, Texas. Some of the vessel’s 24 crewmembers had completed hot work in that space about 25 minutes…...

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