OSHA Compliance Posts

A robot, a conveyor, two different maintenance crews, and an amputation with no LOTO (OSHRC)

On July 31, 2016, a contract employee at an automobile manufacturing facility was replacing a motor on a robot on the first floor of the facility. While he did so, three maintenance technicians were performing a preventive maintenance inspection on a conveyor on the upper level of the facility. When the contract employee completed his…...

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A robot, a conveyor, two different maintenance crews, and an amputation with no LOTO (OSHRC) Read More »

Does color coding on your NFPA 704 Diamond matter?

In the past several years the use of NFPA’s 704 “Diamond” as a means for secondary labeling has seen much scrutiny; however, even OSHA has stated that this label can be used as an in-house secondary label under the GHS labeling requirements. (SAFTENG members can see my earlier articles on this topic in the OSHA…...

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Settling the Fit Test debate on when a QLFT vs. QNFT is required

This should not be new to many of you who have been reading my materials for years, but we continue to see Emergency Responders who are by default “entering IDLH atmospheres” who have been fit tested using a Qualitative Method.  In order to set the record straight, this is not a Haywood thing or a…...

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Settling the Fit Test debate on when a QLFT vs. QNFT is required Read More »

Going above OSHA minimums on Fit Factor(s)

As many of you know, I love to use other codes and standards that take my programs above and beyond OSHA minimums.  That even includes using standards and codes from other countries.  One area of safety that we can easily achieve a level above OSHA minimums is our “fit factors.”  We know that OSHA has…...

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Going above OSHA minimums on Fit Factor(s) Read More »

OSHA machine guarding citations to steel fabrication facility and its staffing company (multi-employer citation OSHRC)

The staffing company contests a two-item Citation and Notification of Penalty (Citation) issued March 20, 2017, by the Secretary. The Secretary issued the Citation following an inspection by OSHA on November 21, 2016, of a steel fabrication facility, in response to a report of a serious employee injury.  The injured employee was one of several…...

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OSHA machine guarding citations to steel fabrication facility and its staffing company (multi-employer citation OSHRC) Read More »

Can employee’s be fit-tested with “stubble beard growth”?

This is without a doubt one of the top ten questions we get each year… Can employee’s be fit-tested with facial hair stubble?  And not to be a smart a_s about it, the answer is still the same… NO.  OSHA has been consistent over the years and my dozen or so articles on the matter…...

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Can employee’s be fit-tested with “stubble beard growth”? Read More »

Can OSHA require abatement when no citation has been issued? (OSHRC and enterprise-wide abatement)

As some of you may recall the Post Office got hammered by OSHA some years ago, and from those inspections, OSHA asked for abatement across all post office locations.  One of those items was related to heat stress, and I might add that already this summer we have seen another heat stroke fatality within the…...

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Can OSHA require abatement when no citation has been issued? (OSHRC and enterprise-wide abatement) Read More »

Are your LOTO “machine specific” procedure actually “specific” and the OSHRC settles the debate about isolating a PRCS

This 2018 decision is a MUST read for all safety professionals who wish to question the requirement for “machine specific” isolation procedures for “complex processes” AND for those who want to understand the isolation expectation for entry into a PRCS.  This business made two mistakes that run rampant in businesses when it comes to the…...

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Are your LOTO “machine specific” procedure actually “specific” and the OSHRC settles the debate about isolating a PRCS Read More »

MIOSHA revises their Eyewash/Shower Equipment requirements

As you know, I love using some of the State OSHA Plan standards as they can be more protective and offer some explanations as to their requirements.  The state of Michigan just renewed its 1910.151 standard as it relates to Eyewash/Shower Equipment and in doing so has offered some excellent insight into their revisions.  Whereas…...

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MIOSHA revises their Eyewash/Shower Equipment requirements Read More »

Another worker dies when he hooked his SAR into a Nitrogen Supply

At 5:15 p.m. on May 16, 2017, an employee was preparing to paint a car. The employee hooked up his airline respirator to a nitrogen hose instead of to the compressed air hose, resulting in the employee suffering asphyxiation…. Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log...

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Another worker dies when he hooked his SAR into a Nitrogen Supply Read More »

OSHRC establishes “stable and secure against sliding or collapse” (1910.176)

Citation 1, Item 1 is classified as “Serious” and alleges that Respondent violated 29 C.F.R. § 1910.176(b), stating that “employees are exposed to struck-by hazards from unstable material storage.”  A penalty of $10,864.00 is proposed for this item.  For the reasons that follow, the Citation is AFFIRMED, and the proposed penalty is assessed. The Accident…...

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