OSHA Compliance Posts

The effect of wearer stubble on the protection given by Filtering Facepieces Class 3 (FFP3) and Half Masks (UK’s HSE RR1052)

Ever wonder about that 5 o’clock shadow and the impact it may have on a respirator face-to-mask seal?  How about 2-3 days growth… what is that impact on respiratory protection safety?  Well now we have a much better idea!  The UK’s Health and Safety Executive (HSE) did a small study to find out just how…...

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The effect of wearer stubble on the protection given by Filtering Facepieces Class 3 (FFP3) and Half Masks (UK’s HSE RR1052) Read More »

OSHA issues “Inspection Procedures for the Hazard Communication Standard (HCS 2012)”

The Hazard Communication standard (HCS) has been revised to align with the United Nations Globally Harmonized System of Classification and Labelling of Chemicals (GHS Revision 3, 2009). This includes updates to the requirements for labeling and for safety data sheets (SDSs). This instruction outlines the revisions to the HCS, such as the revised hazard classification…...

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OSHA issues “Inspection Procedures for the Hazard Communication Standard (HCS 2012)” Read More »

Whats OSHA been up to for the past month? (6/10/15 to 7/10/15)

Back by popular request… Coverage: National Period: 30 days, 6/10/15 to 7/10/15 New Inspections: Opened in the last 30 days = 4,553 Closed Inspections: Closed in the last 30 days = 4,319 Ongoing Inspections: Opened prior to 30 day reporting period and still not closed = 118,209 Inspections with Violations = 150 Inspections with no…...

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OSHA’s General Industry Fall Protection Standard under OMB Review

DOL/OSHA RIN: 1218-AB80 Publication ID: Spring 2015  Title: Walking Working Surfaces and Personal Fall Protection Systems (Slips, Trips, and Fall Prevention)  Abstract: In 1990, OSHA published a proposed rule (55 FR 13360) addressing slip, trip, and fall hazards and establishing requirements for personal fall protection systems. Slips, trips, and falls are among the leading causes…...

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Documentation requirements of the PPE Standard (1910.132)

Subpart I specifies several paperwork requirements. The following describes the information collection requirements in subpart I and addresses who will use the information: Hazard Assessment and Verification (§ 1910.132(d) Paragraph (d)(1) requires employers to perform a hazard assessment of the workplace to determine if hazards are present, or likely to be present, that make the…...

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Documentation requirements of the Noise Standard (1910.95)

The information collection requirements specified in the Noise Standard protect employees from suffering material hearing impairment. The information collection requirements of the Noise Standard include: Conducting noise monitoring; Notifying employees when they are exposed at or above an 8-hour time-weighted average of 85 decibels; Providing employees with initial and annual audiograms; Notifying employees of a…...

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So here’s a trick question for you IH professionals… When I get my new SDSs, do I have to retain my old MSDS for 30 years?

One standard that OSHA failed to update when they revised 1910.1200 was 1910.1020 – Access to employee exposure and medical records.  This standard still uses the term MSDS and does not address my question about the changing of MSDS for the new SDS.  Granted, a lot of the exposure info on the new SDS(s) has…...

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So here’s a trick question for you IH professionals… When I get my new SDSs, do I have to retain my old MSDS for 30 years? Read More »

Are you maintaining your heat sampling data per 1910.1020(d)(1)(ii)

As summer heat intensifies, OSHA’s focus on preventing heat related illness intensifies.  With this intensity, many employers are going hi-tech to collect “heat exposure data” to establish work practices based on exposures.  I have seen a recent increase in advertising for devices that can measure wet-bulb temperatures in workplaces and they are tying these reading…...

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Are you maintaining your heat sampling data per 1910.1020(d)(1)(ii) Read More »

Interim Enforcement Guidance for Hazard Communication 2012 (HCS 2012) June 1, 2015 Effective Date (OSHA)

 May 29, 2015 MEMORANDUM FOR: REGIONAL ADMINISTRATORS THROUGH: DOROTHY DOUGHERTYDeputy Assistant Secretary FROM: THOMAS GALASSI, DirectorDirectorate of Enforcement Programs (DEP) SUBJECT: Interim Enforcement Guidance for Hazard Communication 2012 (HCS 2012) June 1, 2015 Effective Date This memorandum is to provide additional, interim guidance on the Hazard Communication 2012 June 1, 2015 effective date.  OSHA provided…...

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Does the “voluntary use” of a “filtering facepieces” (dust masks) require the use Appendix D?

Are you providing a copy of 1910.134 Appednix D to each employee who wears a filtering facepieces (dust masks) on a “voluntary basis”? Are you controlling these filtering facepieces (dust masks) so that ONLY employees who have been provided with a copy of Appendix D have access to these filtering facepieces (dust masks)?  For the…...

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Does the “voluntary use” of a “filtering facepieces” (dust masks) require the use Appendix D? Read More »

OSHRC on “Universal PPE Hazard Assessments” at distribution centers

This is a very interesting AND disappointing decision by the commission.  They accepted a PPE Hazard Assessment done at a distribution center in AR for a facility in TX.  The business argued that the 100+ distribution centers around the country are identical with identical job functions.  The commission, although they state otherwise, appears to be…...

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OSHA’s Process Safety Management Standard is NOT the only standard that requires “verification of knowledge” after training

In the PSM/RMP world, the battle rages on with regards to “verification of knowledge” for those receiving training related to their work in, on and adjacent to a PSM/RMP covered process.  Yet for those safety professionals not working at a PSM/RMP facility, you too have a standard, that will just about cover ALL workplaces, that…...

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