OSHA Compliance Posts

REMINDER… OSHA 300-A Posting by February 1st

Where does the time go?  As most practicing safety professionals in the USA know, the time has come to do our annual summary of our OSHA 300 Log.  But for many these logs can be very confusing.  So here is a reminder and what is required for us to comply…… Membership Required You must be...

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OSHA issues another Hazard Alert Letter regarding EMT’s providing medical care

Last week OSHA sent another “Hazard Alert” letter to an employer regarding their practice of using on-site EMT’s to provide care to employees.  In this case, OSHA is again asserting that the EMT’s are performing duties outside their certifications and the purpose of the EMT’s is to avoid recording injuries.   Medical care must be…...

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EMT’s, MusculoSkeletal Disorders (MSDs), and OSHA Recordkeeping

Over the holidays I came across this “letter” from OSHA to an employer regarding how the facility was “managing” their “1st Aid cases” using on-site EMTs who were not actually state certified EMT’s, nor had they been trained to identify and assess musculoskeletal disorders (MSDs).  In reading the letter, OSHA was clearly implying that these 1st…...

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2015 OSHA PRCS activity by Industry Sectors

UPDATED on 1/10/2016 Here is a look at OSHA’s PRCS activity in 2015 (October 2014 – September 2015). As you can see, OSHA did 206 PRCS inspections and issued 545 citations for a total of $1,435,301 in fines. This is the SETTLED amount and NOT the initial citations. Here is a quick breakdown of activity:…...

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2015 OSHA LOTO activity by Industry Sectors

Here is a look at OSHA’s Lockout/Tagout (LOTO) activity in 2015 (October 2014 – September 2015).  As you can see, OSHA did 1,796 LOTO inspections and issued 3,139 citations for a total of $9,013,808 in fines.  This is the SETTLED amount and NOT the initial citations.  Here is a quick breakdown of activity: NAICS Code:…...

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2015 OSHA PSM activity by Industry Sectors

Here is a look at OSHA’s PSM activity in 2015 (October 2014 – September 2015).  As you can see, OSHA did 109 PSM inspections and issued 477 citations for a total of $2,344,741 in fines.  This is the SETTLED amount and NOT the initial citations.  Here is a quick breakdown of activity: NAICS Code: 311…...

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Pitfalls of Contractors and LOTO (1910.147(f)(2)

OSHA’s Control of Hazardous Energy (lockout/tagout) standard has a paragraph called “Outside personnel (contractors, etc.)” and although it indicates that a contractor CAN use their own LOTO program within our facilities, I will attempt to convince you that it is MORE challenging than many may have considered.  Here is what 1910.147 states about “Outside personnel…...

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Administrative court sets precedent, allowing request for enterprise-wide hazard abatement by employer to proceed to trial

An Administrative Law judge has decided that the Occupational Safety and Health Review Commission may have authority under the Occupational Safety and Health Act to order abatement measures sought by the U.S. Department of Labor’s Occupational Safety and Health Administration beyond the specific violations OSHA identified in its the citations.  OSHA cited Central Transport LLC in November 2014 for 14 violations of workplace…...

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Administrative court sets precedent, allowing request for enterprise-wide hazard abatement by employer to proceed to trial Read More »

OSHRC decision on “minor servicing” and “safety blocks” in lieu of LOTO

This only one part of a case, but it is about the “minor servicing” exception and how it can be applied. It is also critical in that the case revolves doing servicing and maintenance on presses using only the “safety blocks” in lieu of LOTO. Item 1, Alleged Violation of Section 1910.147(c)(4)(i) of the LOTO…...

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OSHA grants VARIANCE to Lockout (1910.147(d)(4)(i)

This variance provides us with some detailed insight in what OSHA accepts as an “alternative” to LOTO.  Facilities do not have to request a variance for their “minor servicing” exception; however, this variance does provide us with some valuable insights into what OSHA believes is an “acceptable alternative” to LOTO when using these alternate methods…...

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OSHA grants VARIANCE to Lockout (1910.147(d)(4)(i) Read More »

CHALLENGE: Protecting the Safety and Health of Workers (OSHA/MSHA OIG Report 2015)

The Department of Labor (DOL) administers the Occupational Safety and Health Act of 1970 (OSH Act) and the Federal Mine Safety and Health Act of 1977 (Mine Act), as amended by the Mine Improvement and New Emergency Response Act of 2006 (MINER Act). DOL’s effective enforcement of these laws is critical to protecting workers from…...

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