OSHA Compliance

OSHA’s Interim Enforcement Guidance for the Respirable Crystalline Silica in Construction Standard, 29 CFR 1926.1153

October 19, 2017 MEMORANDUM FOR:REGIONAL ADMINISTRATORS THROUGH:THOMAS GALASS, Acting Deputy Assistant Secretary FROM: PATRICK J. KAPUST, Acting Director, Directorate of Enforcement Programs SUBJECT:nterim Enforcement Guidance for the Respirable Crystalline Silica in Construction Standard, 29 CFR 1926.1153 This memorandum provides interim enforcement guidance to Compliance Safety and Health Officers (CSHOs) for enforcing 29 CFR 1926.1153, Respirable…...

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OSHA’s 2017 Top 10

At this year’s NSC Congress OSHA announced their 2017 Top 10 Violations.  They have not updated their Data Page yet, but here are their preliminary…… Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...

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Sharing bad safety programs is a bad safety practice

In this profession we have a saying when it comes to written safety programs… “steal with pride”. We learn early on in our careers that not much changes in OSHA standards so finding someone who already has a written program, training powerpoint, permits, checklist, etc. that we can just “steal it” rather than “recreating the…...

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OSHA clarifies “forklift modifications” requirements

Sometimes we can find the most concise explanations from OSHA in these Extensions of the Office of Management and Budget’s (OMB) Approval of Information Collection (Paperwork) Requirements.  This week OSHA posted an extension notice regarding the paperwork requirements found in 1910.178 Powered Industrial Trucks Standard.  It is in this posting that OSHA does such a nice…...

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OSHA clarifies recording injuries/illnesses when supervision is shared by a prime contractor and subcontractor at a construction site

This 2017 letter of interpretation clarifies the requirements at Section 1904.31, Covered Employees. Specifically, OSHA clarifies who is responsible for recording injuries and illnesses of workers when a prime contractor and subcontractor share supervision at a construction site…. Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in...

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Are you confident in your Hot Work Program, Permit, and Training?

In the process safety arena, OSHA’s PSM Standard (and EPA’s RMP rule) made it official… doing “hot work” in/on/adjacent to the “covered process(s)” required a WRITTEN PERMIT. Before PSM/RMP, OSHA only “preferred” the permission to perform Hot Work be in written form. OSHA PSM (and RMP)intent was to require employers to control, in a consistent…...

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OSHA’s position on “Swing Gates” and fixed ladders

For years, OSHA had taken a position on when/where “swing gates” were actually required and that position was that it did NOT apply to fixed ladders on the edge of a platform.  Then in 2009 they officially stated their enforcement position in a Regional Memo that DID include ladderway opening on the edge of a…...

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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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