OSHA Compliance

OSHA may allow “alternating tread stairs”, but your building code may NOT

We are all working with OSHA’s new Walking and Working Surfaces standards and trying to figure out how all the new design standards will apply to our workplaces and activities.  And in doing so, many of us have seen that OSHA has now “officially” endorsed the use of alternating tread stairs in 1910.25(f).  But there may…...

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OSHRC rules on Arc Flash Injury Case (Arc Flash and PPE matters)

An electrical contractor was under contract to update the energy monitoring and control system of a Hospital. An employee of the contractor who was “troubleshooting” (quotations added by me) the system was burned when an arc flash occurred as he worked near energized electrical parts. The contractor reported the employee injury to OSHA which initiated…...

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Working example of a Noise Attenuation Evaluation (1910.95(j)

Following up on a 2012 post about complying with 1910.95(j), I wanted to share a working example of how I document my “hearing protector attenuation” evaluation.  I think the example speaks for it’s self, but if you need a reference as to what this exercise is meant to accomplish please refer to my 2012 post Hearing…...

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Timing of HBV shots is UPHELD by OSHRC as critical to BBP Control Plan effectiveness

If you have a First-Aid team that “renders aid” as part of their job duties (even though their participation on the team is voluntary – but rendering care once on the team is NOT) this is a case you should understand.  The business was cited for NOT having the employees vaccinated at the time-frames stated…...

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Why our Pressure Safety Valves must meet the phase they will see in an overpressure event

Is there such a thing as a “dual phase” pressure safety valve (PSV)? Not that I have ever encountered; yet that does not stop some from trying to “educate me” on their dual-phase PSVs. So why does this topic matter? Our PSV’s are our LAST LINE of defense in an overpressure event, and if they…...

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A review of OSHA’s “Shaming Campaign”

NOTE: a reduction in penalty can come about many different ways, so a reduction in penalty does not imply that the hazardous condition did not exist at the time of the inspection.  Many reductions in penalties occur due to negotiations requiring abatement of the hazard and extra’s like training supervisors in OSHA 10-hr course.   …...

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OSHA announces a DELAY in the July 1, 2017 Electronic Submission of OSHA Log Data

OSHA has finally announced that the agency is not accepting electronic submissions of injury and illness logs at this time, and intends to propose extending the July 1, 2017 date, by which certain employers are required to submit the information from their completed 2016 Form 300A electronically. Updates will be posted to this webpage when they…...

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Why Does OSHA Require Retention of Placards? (1910.1201)

At 3:40 a.m. on November 29, 1988, the Kansas City, MO Fire Department received an alarm indicating there was a fire at a highway construction project. The dispatcher directed Pumper 41 to respond to the truck fire. He added: “Pumper 41, use caution on your call. There’s information there may be explosives. It’s in a…...

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Does OSHA’s new GHS for Hazardous Communications require my fixed storage tanks to have Pictograms?

  I have to admit that this transition from the old HAZCOM to this Globally Harmonized Hazcom Standard has been a bumpy ride over the past 4-5 years. I have had to correct postings a couple of times with some help from my friends at OSHA and NFPA. But there is one thing that I…...

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OSHRC upholds citation for employee(s) reaching under interlocked doors/guards

This is a very good case on machine guarding (1910.212) application.  Employees routinely reached under a set of doors that were interlocked to clear a jam.  One day and employee reached too far and lost his finger tip.  OSHA cited 1910.212(a)(3)(ii) and the commission upheld it.  The reason why this case is so solid for…...

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