OSHA Compliance

MEMORANDUM FOR: REGIONAL ADMINISTRATORS, STATE PLAN DESIGNEES THROUGH: AMANDA EDENS,Acting Deputy Assistant Secretary FROM: PATRICK J. KAPUST, Acting Director,Directorate of Enforcement Programs SUBJECT: Enforcement of 29 CFR 1910.29(f)(1)(ii)(B) and 1910.29(f)(1)(iii)(A): Heights of Handrail and Stair Rail Systems This memorandum replaces the memorandum issued on June 10, 2019, on this subject, and provides guidance to Compliance…...

Question 1: Does the HCS apply to universal waste, which is included within the definition of hazardous waste and subject to 40 CFR 273? Response: No. As noted in the background section, per 29 CFR 1910.1200(b)(6)(i), the HCS does not apply to hazardous wastes regulated by the U.S. Environmental Protection Agency (EPA) under the Resource…...

Those of you that have been reading my materials for the past 20+ years know that I can be rather extreme when it comes to critical safety items such as SCBA’s used in IDLH atmospheres.  I make no apologies for my positions and my directness – heck I think more of you need to be…...

The intent of this Regional Emphasis Program is to encourage employers to take steps to address hazards, evaluate facilities to determine if the employer complies with all relevant OSHA requirements, and help employers to correct hazards, thereby reducing potential worker injuries, illnesses, and deaths. Region VII OSHA proposes accomplishment through outreach and enforcement activities. Outreach…...

Scenario: An employee experienced an injury when sharpening a personal pocket-knife while sitting in a company owned-truck parked in the employer’s parking lot. The employee lacerated the palm of his hand and was treated with seven sutures, and the employee returned to work immediately with no restrictions.  You state that because the employee was on his…...

Way back in 1994 when I was implementing my first FRC program there was a great debate on the options that would be made available to operators, maintenance, engineering, EHS, and QA/QC personnel who perform work within a HAZLOC. This debate was of course driven by costs vs. risks and luckily I was working for…...

Sometimes the OSHA “Request for public comments” postings contains some really good insights as to the documentation aspect to OSHA compliance.  This week’s posting does a nice job of explaining all that is required to document our PPE Hazard Assessments: (emphasis by me, but 100% OSHA wording) Paragraph 1910.132(d)(1) and the Personal Fall Protection standard…...

It seems we, as a profession, struggle to get a consensus on those three words/phrase. For me, it is crystal clear, but for many others I find they wish to have some “room to work” in how they understand these terms to be used. I am often told I read the OSHA (i.e. barebones MINIMUM…...