OSHA Compliance Posts

Sharing bad safety programs is a bad safety practice

In this profession we have a saying when it comes to written safety programs… “steal with pride”. We learn early on in our careers that not much changes in OSHA standards so finding someone who already has a written program, training powerpoint, permits, checklist, etc. that we can just “steal it” rather than “recreating the…...

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OSHA clarifies “forklift modifications” requirements

Sometimes we can find the most concise explanations from OSHA in these Extensions of the Office of Management and Budget’s (OMB) Approval of Information Collection (Paperwork) Requirements.  This week OSHA posted an extension notice regarding the paperwork requirements found in 1910.178 Powered Industrial Trucks Standard.  It is in this posting that OSHA does such a nice…...

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OSHA clarifies recording injuries/illnesses when supervision is shared by a prime contractor and subcontractor at a construction site

This 2017 letter of interpretation clarifies the requirements at Section 1904.31, Covered Employees. Specifically, OSHA clarifies who is responsible for recording injuries and illnesses of workers when a prime contractor and subcontractor share supervision at a construction site…. Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in...

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Are you confident in your Hot Work Program, Permit, and Training?

In the process safety arena, OSHA’s PSM Standard (and EPA’s RMP rule) made it official… doing “hot work” in/on/adjacent to the “covered process(s)” required a WRITTEN PERMIT. Before PSM/RMP, OSHA only “preferred” the permission to perform Hot Work be in written form. OSHA PSM (and RMP)intent was to require employers to control, in a consistent…...

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Are you confident in your Hot Work Program, Permit, and Training? Read More »

OSHA’s position on “Swing Gates” and fixed ladders

For years, OSHA had taken a position on when/where “swing gates” were actually required and that position was that it did NOT apply to fixed ladders on the edge of a platform.  Then in 2009 they officially stated their enforcement position in a Regional Memo that DID include ladderway opening on the edge of a…...

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OSHA may allow “alternating tread stairs”, but your building code may NOT

We are all working with OSHA’s new Walking and Working Surfaces standards and trying to figure out how all the new design standards will apply to our workplaces and activities.  And in doing so, many of us have seen that OSHA has now “officially” endorsed the use of alternating tread stairs in 1910.25(f).  But there may…...

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OSHA may allow “alternating tread stairs”, but your building code may NOT Read More »

OSHRC rules on Arc Flash Injury Case (Arc Flash and PPE matters)

An electrical contractor was under contract to update the energy monitoring and control system of a Hospital. An employee of the contractor who was “troubleshooting” (quotations added by me) the system was burned when an arc flash occurred as he worked near energized electrical parts. The contractor reported the employee injury to OSHA which initiated…...

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Working example of a Noise Attenuation Evaluation (1910.95(j)

Following up on a 2012 post about complying with 1910.95(j), I wanted to share a working example of how I document my “hearing protector attenuation” evaluation.  I think the example speaks for it’s self, but if you need a reference as to what this exercise is meant to accomplish please refer to my 2012 post Hearing…...

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Timing of HBV shots is UPHELD by OSHRC as critical to BBP Control Plan effectiveness

If you have a First-Aid team that “renders aid” as part of their job duties (even though their participation on the team is voluntary – but rendering care once on the team is NOT) this is a case you should understand.  The business was cited for NOT having the employees vaccinated at the time-frames stated…...

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Timing of HBV shots is UPHELD by OSHRC as critical to BBP Control Plan effectiveness Read More »

A review of OSHA’s “Shaming Campaign”

NOTE: a reduction in penalty can come about many different ways, so a reduction in penalty does not imply that the hazardous condition did not exist at the time of the inspection.  Many reductions in penalties occur due to negotiations requiring abatement of the hazard and extra’s like training supervisors in OSHA 10-hr course.   …...

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