OSHA Compliance Posts

The International Fire Code is an EXCELLENT resource

Are you tired of playing the OSHA Compliance game that requires us to “comply” with standards that are 50 years old?  The International Fire Code (IFC) is an excellent resource for taking your hazardous materials handling systems/processes to the next level.  The IFC is used or adopted in 42 states, including the District of Columbia,…...

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Limitations of EH Rated Safety Footwear

This article aligns with my previous article, “When are High-Vis garments no longer considered High-Vis?”  It is in the same spirit of managing the PPE that so many workers rely on daily.  And anyone who has been in safety for six months or longer can tell us horror stories of what they have seen with…...

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Here’s your sign… 1910.145

We visit 25-30 facilities each year, with about 15% of those being first-time and last-time visits!  And man-o-man, we see some crazy things.  I may have unreasonable expectations of safety, but complying with OSHA standards that have been on the books for 50+ years should not be a battle we are still fighting today.  Take…...

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Line Break gone bad (Stored energy)

On March 1, 2024, a miner died after a metal slurry pipe struck him. The miner was removing the last bolt connecting two metal slurry pipes when the pipe broke free and swung in his direction. Best Practices • Prevent miners from positioning themselves in a manner that will expose them to hazards while performing…...

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Does OSHA have any specific requirements regarding dimensions of gaps between the moving parts (belt or shaft) and the guards? (LOI)

Yes. OSHA’s standards at 29 CFR § 1910.212 and 29 CFR § 1910.219 apply to the safeguarding of machines and mechanical power-transmission equipment and require guarding to protect the operator and other employees in the area from hazards such as those created by ingoing nip points, rotating parts, flying chips, and sparks. In regard to…...

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Does OSHA have any specific requirements regarding dimensions of gaps between the moving parts (belt or shaft) and the guards? (LOI) Read More »

When are High-Vis garments no longer considered High-Vis?

NOTE: I have never managed a facility/workforce where we required Hi-Vis garments, except for Fire Watches and PRCS Entry Attendants, but those requirements were not for the user’s safety, so we did not get into all the ANSI requirements for these vests. However, I do equate this Hi-Vis effectiveness concern to what I dealt with…...

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When are High-Vis garments no longer considered High-Vis? Read More »

How good is your HAZCOM program management?

I will use one of the last tests when a facility has hit home runs in managing its Hazardous Communications program.  They are great with their container labeling, pipe labeling, training, etc.  They even could provide an SDS for all their significant chemicals; however, only a tiny percentage of these facilities can do this…… Membership...

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Employer failed to address 3rd party OSH audit findings ($348K)

This is an interesting “press release” from OSHA.  Although OSHA has a “policy” not to use audits and inspections performed within the facility to issue citations against, when the employer does NOT address the hazards identified in the inspections and audits, OSHA can take issue with this failure to abate.  This is what seems to…...

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OSHA addresses Compressed Gas cylinders on carts (OSHA LOI)

Your letter discusses concerns with the safety of compressed gas cylinders on some types of portable carts configured for “in use” or “connected for use.” Specifically, you mention that cylinders, which are top heavy and therefore can be unstable (unbalanced), are commonly found poorly secured to the cart and leave the cylinders susceptible to toppling…...

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Does 1910.178 apply to personnel and other equipment moving equipment?

OSHA answers the following questions as they relate to 1910.178 Powered Industrial Trucks Does OSHA standard 29 CFR 1910.178 apply to the following equipment: A vehicle designed to convey both personnel and equipment, such as welding equipment (Pack Mule Industrial Electric Vehicle: Models covered: SC-775, SCT-7750); Motorized shopping cart trolley/collector (Dane Technologies, QuicKART: Models covered:…...

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Does 1910.178 apply to personnel and other equipment moving equipment? Read More »

HCS applicability to an industrial marker containing liquid paint or ink

OSHA has posted a Letter of Interpretation (LOI) regarding  “industrial markers containing liquid paint or ink. ” Here are the four (4) questions OSHA answers: Question 1: Can an industrial isopropyl alcohol (IPA) or ethyl acetate (EA) based marker containing 10 milliliters (ml) of liquid paint or ink be considered an article per paragraph 1910.1200(c)…...

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