OSHA Compliance

Learning MOC mistakes from others

The Management of Change (MOC) section of the PSM standard requires the employer to implement written procedures for managing changes (except for replacements in kind) to processes involving chemicals, technology, equipment, procedures, and changes to facilities that affect a covered process. The MOC procedure requires descriptions of the technical basis for the change, impact on…...

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Learning MI mistakes from others

OSHA has identified the following mistakes found at PSM facilities nationwide. These mistakes were identified at refineries; however, almost all can be found within any PSM-covered process. I have revised OSHA’s wording so that we can ALL learn from these mistakes. PLEASE do not fall for the old trap of “Bryan, we are not a…...

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Safety Pays Individual Injury Estimator

Employers can use the Safety Pays Individual Injury Estimator to assess the impact of occupational injuries and illnesses on their profitability. This program uses a company’s profit margin, the average costs of an injury or illness, and an indirect cost multiplier to project the amount of sales a company would need to generate to cover…...

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Standards Referenced in OSHA Proposed Rule 29 CFR 1910.156 (Emergency Response)

The following NFPA and ANSI standards, in whole or in part, are to be incorporated by reference into proposed rule 1910.156, per 29 CFR 1910.6. See 29 CFR 1910.6(a)(1). Provisions in the proposed standard are drawn from, or consistent with, the following NFPA standards, but these standards are not proposed to be incorporated by reference:…...

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The saga of the bypassed safety interlock

This unfortunate event is the result of the same failure seen in nearly every industrial facility on the planet… a guarding interlock gets bypassed, and a worker pays an unimaginable price for the failure. Sometimes it’s the worker(s) who bypass the interlock, and other times they are the unknowing victim of the bypass. Here is…...

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Application of paraffin wax is usually considered First Aid (OSHA)

The question was asked of OSHA… Whether the use of paraffin wax as a form of topical heat application is considered medical treatment beyond first aid for OSHA recordkeeping purposes?… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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Access to Low Sloped Roofs and Fall Protection (OSHA LOI)

An HVAC technician uses a portable ladder to access a low slope roof 12 feet high. The ladder is secured to the building and is placed at a 4/1 angle. The side rails of the ladder extend three feet above the roof landing. The HVAC unit to be worked on is 25 feet from the…...

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How should the standard stair width be measured to comply with §1910.25(c)(4)

OSHA standard at 29 CFR 1910.25(c)(4) applies to places of employment and requires standard stairs to have a minimum width of 22 inches (56 cm) between vertical barriers. OSHA does not consider a handrail to be a vertical barrier or obstruction to that required minimum width…. Membership Required You must be a member to access...

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OSHA answers the common questions regarding LOTO Feasibility and Alternative Methods

Background: You stated that your client must perform service and maintenance tasks that will require power in certain circumstances. Some of the tasks qualify for the minor servicing exception to 29 CFR §1910.147 standard. However, there are other tasks that are considered service and maintenance, but still require power. An example is setting up a machine…...

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OSHA extends its National Emphasis Program – Outdoor and Indoor Heat-Related Hazards to 2026

The NEP was set to expire on April 8, 2025. The extension allows OSHA to continue identifying and addressing heat-related injuries and illnesses in workplaces. The NEP enforcement initiative includes policies and procedures for implementing a National Emphasis Program (NEP) to ensure that employees in high-hazard industries are protected from heat-related hazards, both indoors and…...

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OSHA issues LOI regarding Recordkeeping Software

Question: Would OSHA accept the documents generated by our software as a substitute for the OSHA Form 300 and Form 300A to meet the requirements of OSHA’s recordkeeping regulation at 29 CFR Part 1904? Response: If the forms generated by your company’s software meet the requirements for equivalent forms at 29 CFR 1904.29 and 1904.32,…...

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Origin and Development of NFPA 660 – Standard for Combustible Dusts and Particulate Solids

This edition of NFPA 660 was approved as an American National Standard on December 6, 2024. NFPA 660 was written by consolidating the requirements of NFPA 652, Standard on the Fundamentals of Combustible Dust; NFPA 61, Standard for the Prevention of Fires and Dust Explosions in Agricultural and Food Processing Facilities; NFPA 484, Standard for…...

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