One of the quandaries I find with the “Safe HW Area” approach is those areas that are actually set up as weld shops with all the bells and whistles we want in welding shops, such as ventilation to control exposures resulting from welding, cutting, and grinding. For example… 1910.252(a)(2)(viii) Ducts, requires that any ducts and/or…...
Do you have long-term authorized Hot Work areas? Read More »
Sometimes, this government wears me out. A friend and I had this discussion last week about Chemical Container Labeling. The standard is VERY CLEAR (for those who take the time to read it). It comes down to the following: 1910.1200(f)(1) Labels on shipped containers vs 1910.1200(f)(6) Workplace labeling So the first sentence in OSHA’s newest…...
OSHA’s newest Quick Card on HAZCOM labeling is WRONG Read More »
OSHA’s current age-correction table, Appendix F, discontinues at age 60. More people are working into their sixties instead of retiring, and there is no adequate way to assess presbycusis (age-related hearing loss) in these workers using the current OSHA table. OSHA’s age-correction tables were based on a small sample size and research from the 1970’s…....
Today, OSHA posted its latest LOI. This one was regarding railroad track employees and roadway maintenance groups and the need to provide sanitation facilities for these workers. Question: Do OSHA’s sanitation requirements apply to railroad track employees and roadway maintenance groups that are working along the tracks? Answer: Yes. Under section 4(b)(1) of the Occupational…...
A few weeks back, I mentioned that some “safety vendors” sell non-compliant EXIT signs. I received several inquiries about what I was talking about, as if “surely it’s not so.” I am not going to call out these irresponsible safety vendors, but there are many! I have even seen EXIT signs that the entire sticker/sign…...
Non-Compliant Exit Signs Read More »
OSHA has released a proposed Heat Illness Protection Plan (HIPP) to protect millions of workers from the significant health risks of extreme heat. If finalized, the proposed rule would help protect approximately 36 million workers in indoor and outdoor work settings and substantially reduce heat injuries, illnesses, and deaths in the workplace. The proposed rule…...
OSHA’s HIPP Proposed Standard (With my commentary and questions) Read More »
The Slings Standard (29 CFR 1910.184) specifies several paperwork requirements, depending on the type of sling (paragraph (e) of the Standard covers alloy steel chain slings; paragraph (f) covers wire rope slings; paragraph (g) covers metal mesh slings; paragraph (h) covers natural and synthetic fiber-rope slings; and paragraph (i) covers synthetic web slings)…. Membership Required...
Slings Standard (29 CFR 1910.184) paperwork requirements Read More »
Throughout my career, I have been called “crazy,” “certifiable,” “unreasonable,” etc. I have worn those insults as a badge of honor, as in my professional opinion, there is nothing too crazy to protect the men and women doing the dirty and dangerous work! So buckle up, as this thought process may push you over the…...
Li Battery Storage ideas (compartmentalizing our risks) Read More »
Scenario: In your letter, you state that an employee who does not have a fixed work site left his home and traveled approximately 300 miles to a customer site. After the employee arrived at the customer site, he checked into a hotel and conducted work activities for several days. Once the work activities at the…...
Recently, a client had two (2) heat-related incidents within one (1) week. This after, we forced a download of the OSHA/NIOSH Heat App to all company phones. I have used this technique to ensure front-line supervisors and managers have a TOOL to help them manage the Heat Prevention Plan requirements. I have used this forced…...
Which establishments are covered by the update to the HCS? The scope and framework of the HCS have not changed with this rulemaking. Chemical manufacturers and importers are still responsible for providing information about the hazards of chemicals they produce or import. All employers with hazardous chemicals in their workplaces continue to be required to…...
Questions & Answers for OSHA’s Update to the HCS Final Rule Read More »
#1 If an employee presents a work status that indicates they are able to perform restricted work or light duty work yet we do not have work available that meets the restrictions, should we enter the number of days under “On Job Transfer or Restriction” or “Away from Work?”… Membership Required You must be a...
OSHA Recordkeeping Updates Read More »
