OSHA Compliance Posts

OSHA’s GHS Labeling made easy!!!!

I want to try an clarify a couple of misconceptions that I and others may have implied over the past year.  Each time I do a HAZCOM session I get asked the same questions, not from the workers, but from the EHS/Management personnel overseeing the facility’s HAZCOM program.  In this post I try and answer…...

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Should OSHA get out of the pre-accident inspection business? (Editorial)

We have all heard the complaints about the evil OSHA inspectors and how much power their reign over USA businesses.  We also hear statistics that there are only enough OSHA Compliance Safety and Health Officers (CSHO) to visit each US business every 99 years.  So I had to ask the question… should OSHA just get…...

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OSHA’s Semiannual Agenda of Regulations (1/2014)

This Federal Register Notice contains the regulatory flexibility agenda. In addition, the Department’s Regulatory Plan, a subset of the Department’s regulatory agenda, is being published in the Federal Register. The Regulatory Plan contains a statement of the Department’s regulatory priorities and the regulatory actions the Department wants to highlight as its most important and significant…....

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LOTO Accident – REAL Accident that cost a life!

From the accident files @ MSHA… This incident involves a failure to LOTO equipment during servicing and maintenance, with a contributing factor involving the mis-programming of the Programmable Logic Controller (PLC) which permitted equipment to be inadvertently energized without warning. A mechanic/repairman, age 37, was fatally injured about 12:30 p.m. on January 8, 1997 when the…...

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OSHA extends comment period on proposed rule to improve tracking of workplace injuries and illnesses

OSHA has announced that it will extend the comment period to March 8, 2014 on the proposed rule to improve workplace safety and health through improved tracking of workplace injuries and illnesses. The proposed rule would amend recordkeeping regulations to add requirements for the electronic submission of injury and illness information that employers are already…...

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OSHRC rules on LOTO case

This is a great example of how businesses make the mistake of viewing LOTO as a “maintenance function” and therefore ONLY maintenance personnel need to be trained in LOTO.  This case covers Training, Machine Specific procedures, and application of LOTO devices.  It also shows how operations personnel can actually do “maintenance and servicing” activities (as…...

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Cal/OSHA Issues Notice, Schedules Public Hearing on Process Safety Management (PSM) Program Assessment

CAL-OSHA has issued a Notice of Rulemaking (pdf) after Emergency Adoption to make permanent the recently adopted Process Safety Management Program Assessment regulations.  A public hearing has been scheduled for 10 a.m., February 3, 2014 in the auditorium of the Elihu Harris Building, 1515 Clay Street, Oakland, CA 94612. Members of the public may also submit…...

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Classification of Combustible Dusts under the Revised Hazard Communication Standard (OSHA Memo)

FYI OSHA issued this memo on 12/27/13 to Regional AD’s to close the gap on how Combustible Dust will be handled under the new HAZCOM std.  Until OSHA addresses these issues through rulemaking, CSHOs will use this memo to determine if manufacturers and importers (from now on “classifier”) are in compliance with the obligations of…...

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OSHA seeks public comment on agency standards to improve chemical safety

OSHA has announced a request for information seeking public comment on potential revisions to its Process Safety Management standard and related standards, as well as other policy options to prevent major chemical incidents.  The RFI is in response to executive order 13650, which seeks to improve chemical facility safety and security, issued in the wake…...

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Record Requirements in the Mechanical Power Presses Standard

OSHA is making two (2) main revisions to its Mechanical Power Presses Standard. First, OSHA is revising a provision that requires employers to develop and maintain certification records of periodic inspections performed on the presses by adding a requirement that they develop and maintain certification records of any maintenance and repairs they perform on the…...

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Engineering Controls and Economic Feasibility

Most safety professionals practice the hierarchy of controls:  Elimination/Substitution, Engineering Controls, Administrative Controls, and LASTLY Personal Protective Equipment (PPE).  But there is always this thing called “feasibility” when it came to asking for capital to install “engineering controls”.  Earlier this year OSHA issued a memo discussing how they would enforce 1910.95(b)(1), which requires employers to…...

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