OSHA Compliance

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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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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