OSHA Compliance Posts

OSHA screening methods for Process Safety Management during a NON-PSM inspection

During an opening conference, CSHOs can (FOM states “SHALL”) request a list of the chemicals on-site and their respective maximum intended inventories. CSHOs shall review the list of chemicals and quantities, and determine if there are highly hazardous chemicals (HHCs) listed in §1910.119, Appendix A or flammable liquids or gases at or above the specified threshold quantity. CSHOs may…...

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COST OF NOT COVERING YOUR VALVE STEMS (WY-OSHA)

I came across this SAFETY ALERT from WY-OSHA.  I never knew they would cite exposed valve stems and there example is for stems extending into egress paths.  Most surprisingly is that this OSHA Alert actually “endorses” a private product, which I thought OSHA refused to do.  Of course this is a “State Plan” and NOT…...

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OSHA says fainting at the sight of blood is RECORDABLE

Scenario: An employee scratched his index finger on a vinyl saw clamp at work. He immediately began walking to the onsite first aid station to obtain a Band-Aid. On the way, the injured employee met a co-worker who told him that he had a Band-Aid in his pocket. As the co-worker began to apply the…...

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OSHA restates Injury/Illness Recordkeeping requirements for temp/contract workers

For many years OSHA has taken the position that the company who “supervises the daily activities” of the worker is the company who has to record their injuries on their 300 Log.  I am guessing that with all the recent emphasis on “temporary workers”, the recordabiity question was asked once again and ONCE AGAIN OSHA…...

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Are your Safety Data Sheets compliant?

This week (November 2015) I have been working with a small employer who is not staffed with a full time EHS professional  Great folks, but like many small employers we have a ways to go to get where we need to be.  So we started with what I believe to be a bedrock of any…...

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MIOSHA citations @ Warehouse (Electrical Fatality; $357,000)

MIOSHA issued citations for alleged violations of worker safety provisions totaling $357,000 in penalties. MIOSHA conducted a fatality inspection at a Warehouse from June 16, 2015 to August 19, 2015. During the inspection, six alleged violations were identified.  As a result of inspection #1071586, a total of one serious and four willful serious citations were…...

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OSHA looses Fatal Lathe Guarding case

I am posting this to merely share the news, BUT PLEASE remember a worker DIED in this accident, so from a SAFETY PERSPECTIVE we really should not give a rats ass as to what a court found and reversed the OSHA citation.  This posting is NOT intended for “ammo” to show we do not have…...

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OSHA citations for Flame-Retardant Clothing (FRC) in a non-PSM facility

This week OSHA issued a PPE citations to a glass manufacturing company after a worker suffered third-degree burns on his legs and hands when molten glass bottles fell on the production floor and ignited oil residue that had leaked from the machines.  The proposed fine for ONLY the PPE citations involving FRC concerns was $85,000…....

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Breaking down OSHA’s General Hotwork Requirements (1910.252(a)

For those of you at PSM/RMP covered facilities, this OSHA standard is a baseline requirement; however, this OSHA standard does NOT require a Hotwork permit.  It merely “prefers” the authorization be “in the form of a written permit”.  It was not until OSHA’s Process Safety Standard (and EPA’s RMP) that OSHA/EPA actually REQUIRE a hotwork…...

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OSHA’s REVISED Field Operations Manual (FOM ) incorporates “employer safety incentive” programs directly into the inspection process

So many of us can recall the 2012 “Letter to Regional Admins” titled Employer Safety Incentive and Disincentive Policies and Practices where OSHA called out “safety incentive” programs that encourage under reporting of accidents.  Then it was merely a “letter” to regional admin(s).  Now the Field Operations Manual (FOM) has been revised in a manner that…...

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OSHA’s Top 10 Citations for FY 2015

This list was released at last week’s National Safety Council‘s 2015 Congress & Expo.  OSHA’s Top 10 for FY 2015 (10/1/2014 through 9/8/2015) are: Fall Protection (1926.501) – 6,721 violations Hazard Communication (1910.1200) – 5,192 Scaffolding (1926.451) – 4,295 Respiratory Protection (1910.134) – 3,305 Lockout/Tagout (1910.147) – 3,002 Powered Industrial Trucks (1910.178) – 2,760 Ladders…...

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OSHA is REVISING electrical safety-related work practices standard for general industry and the electric power generation, transmission, and distribution standards for general industry and construction

OSHA is REVISING the electrical safety-related work practices standard for general industry and the electric power generation, transmission, and distribution standards for general industry and construction to provide additional clarification regarding the applicability of the standards to certain operations, including some tree trimming work that is performed near (but that is not on or directly…...

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OSHA is REVISING electrical safety-related work practices standard for general industry and the electric power generation, transmission, and distribution standards for general industry and construction Read More »

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