OSHA Compliance

Interim Enforcement Procedures for New Recordkeeping Requirements Under 29 CFR 1904.35 (OSHA)

November 10, 2016 MEMORANDUM FOR:    REGIONAL ADMINISTRATORS                                         STATE DESIGNEES THROUGH:                      DOROTHY DOUGHERTY                           …...

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OSHA Clarifies the Employer’s Continuing Obligation To Make and Maintain an Accurate Record of Each Recordable Injury and Illness

On December 19, 2016, OSHA issued a final rule titled, “Clarification of Employer’s Continuing Obligation to Make and Maintain an Accurate Record of Each Recordable Injury and Illness.” See 81 FR 91792. The final rule, which became effective on January 18, 2017, resulted in various amendments to OSHA’s recordkeeping regulations clarifying that the duty to make…...

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An accident involving fall protection on low slope roofs and 6′ distance assumptions (OSHRC)

I normally do not follow or write about Construction related safety matters as it is not an area I have a lot of experience, but this decision caught my attention because next month (May 2017) OSHA’s new General Industry Fall Protection standards take hold and some of the issues in this case will be dealt…...

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HOT WORK Statistics (NFPA Research)

U.S. fire departments responded to an average of 4,440 structure fires involving hot work per year.  These fires caused an average of 12 civilian deaths, 208 civilian injuries and $287 million in direct property damage per year.  From 2001-2015, five firefighters were fatally injured in four unintentional fires started by torches.  Forty-two percent of the fires…...

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OSHA renews it REP for Safety Hazards in Auto Parts Industry – NAICS 3363XX (Motor Vehicle Parts Manufacturing)

The purpose of this instruction is to continue a Regional Emphasis Program to reduce workplace exposures to safety hazards associated in the Auto Parts Supplier Industry. The Notice applies to Atlanta East, Atlanta West, Birmingham, Jackson, and Mobile Area Offices.  During FY-16, Region IV conducted 46 inspections coded under the REP. One hundred and forty-three…...

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Severe Injury Reports from 1/1/2015 through 9/30/2016 (OSHA)

Here is an EXCEL spreadsheet with the “Severe Injuries” reported to OSHA from 1/1/2015 through 9/30/2016.  These reports make great content for safety discussions and awareness efforts.  You can sort by Hospitalized, Amputation, Injury Nature, Part of Body, Source, Secondary Source.  You can also download the full data sheet from OSHA.  CLICK HERE (.xls) to download my revised spreadsheet…. Membership Required You...

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Am I required to have a Fire Prevention Plan (FPP)? (1910.39)

Much like the Emergency Action Plan (EAP) requirements, a WRITTEN FPP is ONLY required when your business/facility falls under some other OSHA standard.  And in the case of FPPs, there are ONLY three (3) OSHA standards requiring a FPP: Ethylene Oxide, 1910.1047 Methylenedianiline – 1910.1050 1,3-Butadiene – 1910.1051 Here is a nice flowchart from OSHA…...

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Enforcement of minimum approach distance requirements in 29 CFR 1910.269 and 29 CFR Part 1926, Subpart V

On April 11, 2014, OSHA promulgated a final rule revising the general industry and construction standards for work on electric power generation, transmission and distribution installations. On February 13, 2015, OSHA entered into a settlement agreement with the Edison Electric Institute, the Utility Line Clearance Coalition, and the Tree Care Industry Association resolving legal challenges…...

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1/4″ openings are NOT universally permissible on machinery (OSHRC Machine Guarding decision)

This case is yet another example of how “legal” and “safety” can be so far apart from each other.  This case was won by the company because OSHA did a horrible job in defending their citation; and yet, it will become ammo for companies to use in future cases.  Let’s not fool ourselves into believing…...

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Welding Carts and Separating your Flammable gases and Oxidizers (IFC 2015)

Over my career in safety I have seen the use of “welding carts” spin out of control as if they are all the “almighty” in fire prevention.  These carts can now be purchased with a 30-minute “fire wall” between the fuel gas (e.g. acetylene, propane, etc.) and the oxidizer (e.g. oxygen) and in fact do…...

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Clarifications to CPL 02-02-079, Inspection Procedures for the Hazard Communication Standard (HCS 2012)

This memorandum provides information on issues raised since the publication of the Inspection Procedures for the Hazard Communication Standard (HCS 2012) compliance directive, CPL 02-02-079. This memo serves primarily to assist the field staff in clarifying the requirements of HCS 2012.  OSHA clarifies the following questions: Question 1: Has OSHA changed the meaning of the…...

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