OSHA Compliance

2015 OSHA LOTO activity by Industry Sectors

Here is a look at OSHA’s Lockout/Tagout (LOTO) activity in 2015 (October 2014 – September 2015).  As you can see, OSHA did 1,796 LOTO inspections and issued 3,139 citations for a total of $9,013,808 in fines.  This is the SETTLED amount and NOT the initial citations.  Here is a quick breakdown of activity: NAICS Code:…...

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2015 OSHA PSM activity by Industry Sectors

Here is a look at OSHA’s PSM activity in 2015 (October 2014 – September 2015).  As you can see, OSHA did 109 PSM inspections and issued 477 citations for a total of $2,344,741 in fines.  This is the SETTLED amount and NOT the initial citations.  Here is a quick breakdown of activity: NAICS Code: 311…...

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Pitfalls of Contractors and LOTO (1910.147(f)(2)

OSHA’s Control of Hazardous Energy (lockout/tagout) standard has a paragraph called “Outside personnel (contractors, etc.)” and although it indicates that a contractor CAN use their own LOTO program within our facilities, I will attempt to convince you that it is MORE challenging than many may have considered.  Here is what 1910.147 states about “Outside personnel…...

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Administrative court sets precedent, allowing request for enterprise-wide hazard abatement by employer to proceed to trial

An Administrative Law judge has decided that the Occupational Safety and Health Review Commission may have authority under the Occupational Safety and Health Act to order abatement measures sought by the U.S. Department of Labor’s Occupational Safety and Health Administration beyond the specific violations OSHA identified in its the citations.  OSHA cited Central Transport LLC in November 2014 for 14 violations of workplace…...

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OSHRC decision on “minor servicing” and “safety blocks” in lieu of LOTO

This only one part of a case, but it is about the “minor servicing” exception and how it can be applied. It is also critical in that the case revolves doing servicing and maintenance on presses using only the “safety blocks” in lieu of LOTO. Item 1, Alleged Violation of Section 1910.147(c)(4)(i) of the LOTO…...

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OSHA grants VARIANCE to Lockout (1910.147(d)(4)(i)

This variance provides us with some detailed insight in what OSHA accepts as an “alternative” to LOTO.  Facilities do not have to request a variance for their “minor servicing” exception; however, this variance does provide us with some valuable insights into what OSHA believes is an “acceptable alternative” to LOTO when using these alternate methods…...

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CHALLENGE: Protecting the Safety and Health of Workers (OSHA/MSHA OIG Report 2015)

The Department of Labor (DOL) administers the Occupational Safety and Health Act of 1970 (OSH Act) and the Federal Mine Safety and Health Act of 1977 (Mine Act), as amended by the Mine Improvement and New Emergency Response Act of 2006 (MINER Act). DOL’s effective enforcement of these laws is critical to protecting workers from…...

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OSHA screening methods for Process Safety Management during a NON-PSM inspection

During an opening conference, CSHOs can (FOM states “SHALL”) request a list of the chemicals on-site and their respective maximum intended inventories. CSHOs shall review the list of chemicals and quantities, and determine if there are highly hazardous chemicals (HHCs) listed in §1910.119, Appendix A or flammable liquids or gases at or above the specified threshold quantity. CSHOs may…...

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COST OF NOT COVERING YOUR VALVE STEMS (WY-OSHA)

I came across this SAFETY ALERT from WY-OSHA.  I never knew they would cite exposed valve stems and there example is for stems extending into egress paths.  Most surprisingly is that this OSHA Alert actually “endorses” a private product, which I thought OSHA refused to do.  Of course this is a “State Plan” and NOT…...

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OSHA says fainting at the sight of blood is RECORDABLE

Scenario: An employee scratched his index finger on a vinyl saw clamp at work. He immediately began walking to the onsite first aid station to obtain a Band-Aid. On the way, the injured employee met a co-worker who told him that he had a Band-Aid in his pocket. As the co-worker began to apply the…...

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OSHA restates Injury/Illness Recordkeeping requirements for temp/contract workers

For many years OSHA has taken the position that the company who “supervises the daily activities” of the worker is the company who has to record their injuries on their 300 Log.  I am guessing that with all the recent emphasis on “temporary workers”, the recordabiity question was asked once again and ONCE AGAIN OSHA…...

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