OSHA Compliance

Recent OSHA Initiatives Signal Increased Enforcement (Sponsor Article)

KMCL has noted that OSHA has been very aggressive in its enforcement efforts and in seeking large penalties over the last several months.  As described below, the initiatives the agency has recently announced signal that this intensity will continue to ratchet up over the coming months and likely beyond.  As a result, employers should consider…...

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OSHA Multi-employer citation policy used @ Power Plant with Contractor LOTO issues

This posting is a demonstration as to how OSHA (State of IN OSHA) can/will issue citations against BOTH the host facility and it’s contractor for the same OSHA violations.  In this case, the contractor doing the work, did so using TAGOUT without any additional measures that would make “tagout” equally effective as “lockout” (e.g. Tag…...

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OSHA, PPE Hazard Assessment, Injuries, Feasibility, greater hazard, and Industry Practices (OSHRC Decision)

We see this argument from time to time, hence I am sharing this OSHRC decision from last week as a discussion “starter” at facilities, especially food facilities where safety glasses are not used for whatever reason(s).  This case involved a chicken processing facility that chose to NOT use safety glasses on a “chicken deboning line”.  The…...

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Establishments in the following industries with 20 to 249 employees must submit injury and illness summary (Form 300A) data to OSHA electronically

The new rule, which takes effect Jan. 1, 2017, requires certain employers to electronically submit injury and illness summary (Form 300A) data.  The amount of data submitted will vary depending on the size of company and type of industry.  The new reporting requirements will be phased in over two years.  Establishments in the following industries…...

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Whats OSHA been up to for the past month? (May 2016)

Have you ever wondered just how busy is OSHA? How many inspections does OSHA do in a single month? What are they working on? Who are they visiting? Why are they visiting certain workplaces and not others? Are they “picking on anyone”? etc. Well, have a look into a month of inspection history from 4/20/16 to…...

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What’s OSHA have in store for us? (Spring 2016 Agenda)

Last week OSHA published their “spring agenda” and this gives us a very good idea as to which standards OSHA has on their radar screen.  Here is their agenda…… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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The history and explanation of Anhydrous Ammonia’s dual NFPA 704 Flammability Ratings

The changes in NH3’s flammability ratings in NFPA’s 704 ratings comes down to the difference between ammonia’s inherent chemical properties and specific regulatory overrides designed for enclosed refrigeration systems. Strictly speaking, the base chemical rating for pure anhydrous ammonia is a “1”. However, the International Mechanical Code (IMC) and the International Institute of Ammonia Refrigeration (IIAR)…...

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Combustible Dusts Hazards and OSHA signage

I came across this citation at an Ethanol plant (May 2016) regarding their combustible dusts hazards and the lack of WARNING signs… Citation 2 Item 1 Type of Violation: Other-than-Serious; $0.00 29 CFR 1910.145(c)(2)(i): Caution signs shall be used only to warn against potential hazards or to caution against unsafe practices:… Membership Required You must...

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What’s the condition of your storage racks?

We have all seen the videos and pics of the storage racks collapsing and most of us are amazed at how violent these incidents are; yet how many of us can walk through our storage areas and not find missing anchor bolts, corroded and damaged structural components, no posted load ratings, or out-of-straight support columns?  In a recent OSHA…...

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FATAL Air Receiver Explosion (Paper Mill)

At approximately 11:20 a.m. on May 28, 2012 Employee #1, a 50-year-old male was working in the vicinity of the mill air receiver tank when it exploded. The State Fire Marshal report stated in their report that not enough cool water was reaching the air compressor, which failed to shut down when it overheated.  The…...

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Revised Interim Enforcement Procedures for Reporting Requirements under 29 C.F.R. 1904.39

This memorandum provides updated internal guidance and procedures for the Area Offices to enforce the reporting requirements. Among other things, this memo updates the procedures for the intake of reports from employers, data collection and sorting; and entry of data in the OIS system.  Revised flow charts are provided to help understand the intake process…....

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Year One of OSHA’s Severe Injury Reporting Program: An Impact Evaluation (OSHA)

Under a requirement that took effect Jan. 1, 2015, employers must report to OSHA within 24 hours any work-related amputation, in-patient hospitalization, or loss of eye. (The requirement to report a fatality within 8 hours was unchanged.) Injuries may be reported directly to an OSHA field office, to the OSHA toll-free number, or via an online…...

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