OSHA Compliance Posts

Interpretation of 1904.35(b)(1)(i) and (iv)

OCT 19 2016 MEMORANDUM FOR:       REGIONAL ADMINISTRATORS FROM:                                DOROTHY DOUGHERTY, Deputy Assistant Secretary SUBJECT:                          Interpretation of 1904.35(b)(1)(i) and (iv) On May 12, 2016, OSHA published…...

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OSHA’s new Walking-Working Surfaces and Personal Protective Equipment (Fall Protection Systems) and “hoist areas”

With OSHA’s new Walking-Working Surfaces and Personal Protective Equipment (Fall Protection Systems) standard comes some new requirements for protecting workers in “hoist areas”.  Paragraph (b)(2) establishes fall protection requirements for workers who work in “hoist areas” that are four (4) feet or more above a lower level. The final rule defines a “hoist area” as an elevated…...

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OSHA’s new Walking and Working Surface standard and “fixed industrial stairs”

With OSHA’s new Walking-Working Surfaces and Personal Protective Equipment (Fall Protection Systems) standard comes some clarification as to when “stairs” must be provided vs. using a ladder.  In the new standard, paragraphs (b)(7) through (9) specify when and where employers MUST provide standard stairs, and under what conditions employers may use spiral, ship, or alternating tread-type stairs…....

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OSHA’s NEW fall protection requirements for low-sloped roofs in General Industry

OSHA’s new Fall Protection standard for General Industry has a lot of MAJOR changes (for the better!) that we will be dealing with over the next several years (up to 20 years for some).  One that caught my eye was the new requirements for our maintenance personnel who may be doing work on low-sloped roofs…...

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OSHA’s Walking-Working Surfaces and Personal Protective Equipment (Fall Protection Systems) standard has arrived

Tomorrow OSHA will publish their new standard Walking-Working Surfaces and Personal Protective Equipment (Fall Protection Systems) in the Federal Register.  This means that 60 days later (January 17, 2017), the standard will be EFFECTIVE, with some provisions having delayed enforcement dates.  This rule, in the making since the 1990’s, will essentially change the way FALL PROTECTION in…...

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OSHA clarifies Injury Rate Formula (OSHA LOI)

Incidence rates can be used to show the relative level of injuries and illnesses among different industries, firms, or operations within a single firm. Because a common base and a specific period of time are involved, these rates can help determine both problem areas and progress in preventing work-related injuries and illnesses. An incidence rate…...

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Is there any justification to not record an STS shift on employee exposure after de-rating falls below 85 dBA? (OSHA LOI 2016)

OSHA recently posted one of the most interesting LOI’s I have seen in quite a while.  Somone asked:  If an employee exposure after de-rating falls below 85 dBA, would that be a justification to not record an STS shift on the OSHA 300 Log?  Of course OSHA said NO, but it was a nice try.  Here…...

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OSHA’s 2016 Top 10 Cited Standards

As usual, OSHA released their annual news at the National Safety Council’s Congress and Expo… OSHA’s Top 10 Standards Cited.  The Top 10 for FY 2016* are: # Topic OSHA Std # of Citations 1 Fall Protection 1926.501 6,929 2 Hazard Communication 1910.1200 5,677 3 Scaffolds 1926.451 3,906 4 Respiratory Protection 1910.134 3,585 5 Lockout/Tagout…...

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OSHA posts two (2) new Letters of Interpretation for the new GHS (HazCom)

Although the dates of these letters are eariler this year, they were just posted… Responsible party’s address and phone number on SDSs and labels [1910.1200(c)] Requirements for labeling of products shipped for export to domestic and international destinations, under the revised Hazard Communication Standard (HCS 2012) [1910.1200(f)(1)(i)]  … Membership Required You must be a member to...

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OSHA UPDATE on Post Accident Drug Testing and Walking-Working Surfaces for GI

These past two weeks we have seen some interesting developments on two OSHA actions: 1) anti-retaliation provisions in the new record-keeping rule and 2) Walking-Working Surfaces and Personal Protective Equipment (Fall Protection Systems) in General Industry (Subpart D and Subpart I) .  It seems a judge has delayed OSHA’s enforcement of its anti-retaliation provisions in the new record-keeping…...

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OSHA’s Standards Improvement Project, Proposed Revisions (October 2016)

As part of an ongoing effort to revise provisions in its standards that may be confusing, outdated or unnecessary, the Occupational Safety and Health Administration is proposing 18 changes to the agency’s recordkeeping, general industry, maritime and construction standards.  The proposed revisions would save employers an estimated $3.2 million per year. They are based on…...

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OSHA issues citations for not protecting Propane Tank and Cylinder area

Recently OSHA issued citations to a business that has its own LPG storage tank and fills its own forklift LPG cylinders.  We have seen far too many of these types of set-ups that are FAR OUTSIDE any resemblance of OSHA/NFPA/Fire Code compliance.  These two (2) citations drive home the point about PROTECTING our storage tanks from…...

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