OSHA Compliance

OSHA Due Dates for some fixed ladders is November 19, 2018

As November is just around the corner, we are reminded of a couple of OSHA Due Dates regarding the revised Walking and Working Surface Standards.  Coming up next month we have:… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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The difference between and “inspector” and “examiner” (ASME B31.3)

Under ASME B31.3 (Process Piping), the roels and requirements for an Examiner are distinctly different from those for an [Owner’s] Inspector. While the Inspector represents the owner and audits the work, the Examiner represents the manufacturer, fabricator, or erector and is the person actually performing the quality control examinations—including visual inspection. Because ASME B31.3 classifies…...

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OSHA and weather reporters

In the recent Supreme Court hearings, the nominee was asked about his position on the Sea World Fatality with the killer whale.  He disagreed with OSHA’s authority to cite Sea World and a member of Congress asked him about his decision.  He stated “precedent” as to why he ruled that way and since then there…...

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A robot, a conveyor, two different maintenance crews, and an amputation with no LOTO (OSHRC)

On July 31, 2016, a contract employee at an automobile manufacturing facility was replacing a motor on a robot on the first floor of the facility. While he did so, three maintenance technicians were performing a preventive maintenance inspection on a conveyor on the upper level of the facility. When the contract employee completed his…...

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Does color coding on your NFPA 704 Diamond matter?

In the past several years the use of NFPA’s 704 “Diamond” as a means for secondary labeling has seen much scrutiny; however, even OSHA has stated that this label can be used as an in-house secondary label under the GHS labeling requirements. (SAFTENG members can see my earlier articles on this topic in the OSHA…...

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Settling the Fit Test debate on when a QLFT vs. QNFT is required

This should not be new to many of you who have been reading my materials for years, but we continue to see Emergency Responders who are by default “entering IDLH atmospheres” who have been fit tested using a Qualitative Method.  In order to set the record straight, this is not a Haywood thing or a…...

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Going above OSHA minimums on Fit Factor(s)

As many of you know, I love to use other codes and standards that take my programs above and beyond OSHA minimums.  That even includes using standards and codes from other countries.  One area of safety that we can easily achieve a level above OSHA minimums is our “fit factors.”  We know that OSHA has…...

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OSHA machine guarding citations to steel fabrication facility and its staffing company (multi-employer citation OSHRC)

The staffing company contests a two-item Citation and Notification of Penalty (Citation) issued March 20, 2017, by the Secretary. The Secretary issued the Citation following an inspection by OSHA on November 21, 2016, of a steel fabrication facility, in response to a report of a serious employee injury.  The injured employee was one of several…...

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Can employee’s be fit-tested with “stubble beard growth”?

This is without a doubt one of the top ten questions we get each year… Can employee’s be fit-tested with facial hair stubble?  And not to be a smart a_s about it, the answer is still the same… NO.  OSHA has been consistent over the years and my dozen or so articles on the matter…...

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Can OSHA require abatement when no citation has been issued? (OSHRC and enterprise-wide abatement)

As some of you may recall the Post Office got hammered by OSHA some years ago, and from those inspections, OSHA asked for abatement across all post office locations.  One of those items was related to heat stress, and I might add that already this summer we have seen another heat stroke fatality within the…...

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