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…...
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…...
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…...
Here is a listing of OSHA’s “Wish List” they hope to accomplish in the coming months/years…. Membership Required You must be a member to access this content.View Membership LevelsAlready a member? Log in here...
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…...
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…...
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…...
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…...
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…...
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…...
This week (November 2015) I have been working with a small employer who is not staffed with a full time EHS professional Great folks, but like many small employers we have a ways to go to get where we need to be. So we started with what I believe to be a bedrock of any…...
MIOSHA issued citations for alleged violations of worker safety provisions totaling $357,000 in penalties. MIOSHA conducted a fatality inspection at a Warehouse from June 16, 2015 to August 19, 2015. During the inspection, six alleged violations were identified. As a result of inspection #1071586, a total of one serious and four willful serious citations were…...
