Safety Questions

Safety Questions2018-08-24T16:24:54+00:00
  • SAFETY TOPICS BY CATEGORY
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  • 1. Arc Flash & Electrical
     

    ARC FLASH

    PROPER LABELING OF ELECTRICAL PANELS FOR ARC FLASH

    Q: Which electrical panels are required to be labeled as arch flash warning and what should we look for?

    A: OSHA requires employers to mark electrical equipment with descriptive markings, including the equipment’s voltage, current, wattage, or other ratings as necessary.

    In 1910.335(b), OSHA requires employers to use alerting techniques (safety signs and tags, barricades, and attendants)  to warn and protect employees from hazards which could cause injury due to electric shock, burns or failure of electric equipment parts. Although these Subpart S electrical provisions do not specifically require that electric equipment be marked to warn qualified persons of arc-flash hazards,  the NFPA has specific requirements regarding potential arc flash hazards.

    According to NFPA 70E, all equipment operating 50 volts or higher,  must be assessed for electrical shock (establishing protection boundaries,  PPE, and potential arc-flash hazards. In addition to OSHA and NFPA requirements, Article 110.16 of the National Electrical code requires all equipment that may be worked on while energized to be identified and marked with an Arc-Flash warning label.

    Keep in mind if you always deenergize equipment before working on it, an arc flash hazard assessment should be performed to determine the type of PPE to use when verifying that power is off. The new NFPA 70E Article 130.3(C) requires arc flash warning labels to include, at a minimum, the arc flash incident energy or required level of PPE.

    Section 400.11 of NFPA 70E-2004 states: Switchboards, panelboards, industrial control panels, and motor control centers that are in other than dwelling occupancies and are likely to require examination, adjustment, servicing, or maintenance while energized shall be field marked to warn qualified persons of potential electric arc flash hazards. The marking shall be located so as to be clearly visible to qualified persons before examination, adjustment, servicing, or maintenance of the equipment.

    LABELING OF ELECTRICAL PANELS FOR ARC FLASH WARNINGS

    Q: Which electrical panels are required to be labeled as an arc flash warning and what should we look for?

    A: OSHA requires employers to mark electrical equipment with descriptive markings, including the equipment’s voltage, current, wattage, or other ratings as necessary.

    In 1910.335(b), OSHA requires employers to use alerting techniques (safety signs and tags, barricades, and attendants)  to warn and protect employees from hazards which could cause injury due to electric shock, burns or failure of electric equipment parts. Although these Subpart S electrical provisions do not specifically require that electric equipment be marked to warn qualified persons of arc-flash hazards,  the NFPA has specific requirements regarding potential arc flash hazards.

    According to NFPA 70E, all equipment operating 50 volts or higher,  must be assessed for electrical shock (establishing protection boundaries,  PPE, and potential arc-flash hazards. In addition to OSHA and NFPA requirements, Article 110.16 of the National Electrical code requires all equipment that may be worked on while energized to be identified and marked with an Arc-Flash warning label.

    Keep in mind if you always deenergize equipment before working on it, an arc flash hazard assessment should be performed to determine the type of PPE to use when verifying that power is off. The new NFPA 70E Article 130.3(C) requires arc flash warning labels to include, at a minimum, the arc flash incident energy or required level of PPE.

    Section 400.11 of NFPA 70E-2004 states: Switchboards, panelboards, industrial control panels, and motor control centers that are in other than dwelling occupancies and are likely to require examination, adjustment, servicing, or maintenance while energized shall be field marked to warn qualified persons of potential electric arc flash hazards. The marking shall be located so as to be clearly visible to qualified persons before examination, adjustment, servicing, or maintenance of the equipment.

    ARC FLASH & OPENING ELECTRICAL PANEL

    Q: What are the requirements specifically for opening up an electrical panel if we were to outfit our men?

    A: According to the NFPA 70E (Electrical Safety in the Workplace), there are a few requirements pertaining to this process.

    First, make sure all unqualified persons maintain a distance from the exposed energized conductors or circuit parts and no one should cross the arc flash boundary unless they are wearing the appropriate personal protective clothing.

    Since that the employees will be removing the covers, possibly resetting the panels, and performing maintenance for panels or other equipment rated > 240V and up to 600V, this would put them at a higher risk. Please remember that arc-rated apparel shall fit properly such that it does not interfere with the work task.

    • Here are the PPE requirements for your employees:
      Arc-Rated Clothing, Minimum Arc Rating of 8 cal/cm2
      Arc-rated long sleeve shirt and pants or arc-rated coverall
      Arc-rated flash suit hood or arc-related face shield and arc0rated balaclava
      Arc-rated jacket, parka, rainwear, or hard hat liner.
      Hardhat
      Safety glasses or safety goggles
      Hearing protection
      Heavy-duty leather gloves (Heavy-duty leather gloves are made entirely of leather with minimum thickness of .03 in. are unlined or lined with nonflammable, non-melting fabrics. )
      Leather work shoes
    NFPA COMPLIANCE DEADLINE

    Q: What's the deadline to be NFPA compliant?

    A: There is no actual set date. Since you should already be in compliance, we recommend to get compliant as soon as possible.

    Training 

    As indicated in 130.2(D)(3) an employer is required to provide additional training when:
    (1) supervision or the annual inspection indicates that an employee is not following the
    required electrical safety-related work practices; or (2) when new technology or new
    equipment or changes in work procedures requires the use of electrical safety-related
    work practices that are different from those which the employee would normally use, or
    (3) when an employee is required to use electrical safety-related work practices that are
    new to them.

    As stated in 110.2(D) employees are to be given additional (retaining in) electrical
    safety-related work practices every three years. It should be noted the NFPA 70E,
    Standard for Electrical Safety in the Workplace is revised on a three year cycle.

    For more frequently asked questions, click here.

    PPE FOR ARC FLASH

    Q: Is it acceptable to use alternative personal protective protection when applying ‘the table method’ to protect employees from arc flash hazards?

    A: Unless you can prove through arc flash analysis data that the PPE will provide sufficient protection, it is not recommended.

    ARC FLASH MATERIALS

    Q: Where can I find reference material for arc flash?

    A: The two best sources are the NFPA 70E (available for a fee at www.NFPA.org) and OSHA 1910 Subpart S standard (available for no cost at www.osha.gov).

    ELECTRICAL

    SHOVELING AROUND BAD ELECTRIC LINES

    Q: We have come upon a concern in our industry. The concern is a shock hazard if we are using a shovel to locate a water service with a potential “bad” electric line nearby. Can you aid me in finding if OSHA has a regulation on the following questions?
    • Does OSHA consider or recognize a wood shovel handle as non-conductive?
    • Is a fiberglass non-conductive handle required by OSHA in this instance?

    A: Per OSHA, a wood shovel would be considered conductive and they do not recommend using a fiberglass non-conductive handle. As far as the “bad” electric lines, please see 1926.651(b)(4). Also, you would want to conduct a one call to identify the lines and also ensure that all lines are de-energized to avoid any potential shock hazard.

    ELECTRICAL CONTROL STANDARDS

    Q: What are the electrical control standards according to OSHA?

    A: 1926.417(a) Controls. Controls that are to be deactivated during the course of work on energized or deenergized equipment or circuits shall be tagged.

    1926.417(b) Equipment and circuits. Equipment or circuits that are deenergized shall be rendered inoperative and shall have tags attached at all points where such equipment or circuits can be energized.

    1926.417(c) Tags. Tags shall be placed to identify plainly the equipment or circuits being worked on.

    PPE FOR ELECTRICAL EQUIPMENT

    Q: My employees are working with a 480 volts panel what PPE do they need?

    A: The PPE requirement for working with electrical equipment various for each situation. The National Fire Protection Agency (NFPA) classifies electrical work in categories from 0 to 4. The higher the category number the more personal protective equipment is required. You stated employees are working with 480 volts, that is part of the information needed. The other information needed is what parts of the electrical box they are working on. With the box being rated at 480 volts, this falls under categories 0-2. A 0 rating would require the employees to be wearing non-insulated clothes, safety glasses, etc. while a 2 rating would require them to be wearing fire resistant clothing with an ARC flash rating of a 8. Fire resistant clothing is special clothing outside of the normal work wear, some shirts will list their ARC rating on the tags. The employees should always be working with non conductive tools, preferably rubber or hard plastic along with wearing safety glasses or a face shield when working with electrical hazards.

    WORKING NEAR POWER LINES

    Q: How close can you get equipment for drilling to a live power line?

    A: Under OSHA 1910.333 standard for voltages to ground 50kV or below you can get within 10 feet.  For voltages to ground over 50kV you would need to be 10 feet away plus 4 inches for every 10kV over 50kV.

    DAMAGED CORD

    Q: Is it acceptable to cut the end off of a damaged cord and replace it with a new plug?

    A: OSHA will allow this type of repair as long as the plug is replaced with an “approved” plug (i.e., by a testing laboratory such as factory mutual, underwriters laboratories, etc.).

    GFCI

    GFCI WITH POWERED HAND TOOLS

    Q: If I use a powered tool, such as a 110v drill, in their shop, do I need to use a GFCI in the circuit?

    A: GFCIs are not required to be used in all outlets in general industry. However, they must be used in damp or wet locations.

    POWER LINES

    SECONDARY POWER LINES

    Q: When using scaffolding, what safety measures need to be taken to stay safe when working by secondary electric lines running to homes or businesses?

    A: You have several options that you can use to keep yours employees safe, as well as being in compliance with OSHA:

    • You can disconnect the power
    • Work at least 10 feet from the lines
    • Reroute the lines
    • Have the power company cover the lines.
    Lockout Devices on Air Hoses

    Q: Are lockout devices needed for the end of the air hose when it is detached from the machine? If so, what type should be purchased?

    A: You are required to lock out the system so that it cannot be reconnected. If this means you need to lock out the air hose, then you could look online at Grainger and see what options they have for you to purchase. You may just be able to lock out the area of the machine where it plugs in or lock out the air system at the ball valve, if equipped.

     

  • 2. Company Policy & Requirements
     

    DRUG TESTING

    OSHA STANDARDS FOR DRUG SCREENING

    Q: What are the OSHA standards pertaining to drug screening?

    A: OSHA does not have any specific criteria on drug screening, however, they do have regulations in place for accessing the drug test results.

    OSHA's access to employee exposure and medical records standard is triggered if an employee is exposed to a toxic substance or harmful physical agent in his or her workplace. The standard requires that exposure and medical records of "exposed" employees must be preserved and retained. These records must also be made available to employees and their designated representatives. Therefore if an employer must maintain employee medical and exposure records under the standard, then the employee has access to his or her entire medical record and relevant exposure records. This would include drug test results and any other non-occupational medical records that the employer chooses to maintain as part of the employee's medical record. If, however, an employee has not been exposed to a toxic substance or harmful physical agent in the workplace and records are not subsequently required to be maintained then the access requirements of paragraph do not apply.

    The majority of employers across the United States are NOT required to drug test and many state and local governments have statutes that limit or prohibit workplace testing, unless required by state or Federal regulations for certain jobs. Also, drug testing is NOT required under the Drug-Free Workplace Act of 1988. On the other hand, most private employers have the right to test for a wide variety of substances.

    DRUG TESTING & DOT REQUIREMENTS

    Q: We are looking to switch our drug testing. We are using DISA and will continue to use them. But we are currently requiring hair test, urine, and BA for post accident and during randoms. Is there any reason that we couldn't switch to only doing BA and urine from a legal DOT perspective?

    A: The hair test is a level above a urine test, which tracks a longer level of drug and alcohol use. DOT only requires the breath alcohol and urine test for post-accident and random drug tests. You can also refer to Part 382.303 of the Federal Motor Carrier Safety Administration’s Controlled Substances and Alcohol Use and Testing Regulation for more detailed information.

    DRUG TESTING

    Q: We have suspicion that one of our subcontractor's employees is using drugs while working on our jobsite. What can we do about this?

    A: If the employee is a subcontractor working on your site you can require drug testing such as pre-employment, random, post-accident, etc.

    DRUG TESTING

    Q: Does OSHA require or regulate employee drug testing programs?

    A: No, although many states and insurance companies will require a testing program for certain tasks such as operating commercial vehicles.  For safety and health, it is always a good idea to make sure employees are drug and alcohol free while at work.  Workers compensation carriers should be able to provide more information that will specifically apply to your business.

    EMPLOYEE RIGHTS

    REQUIRED EMPLOYEE BREAKS

    Q: Does OSHA have a regulation requiring the employer to provide breaks for employees? What are the requirements for Ohio?

    A: OSHA does not have a regulation stating that a lunch break or any short break is required to be provided by the employer, however, the employer must provide suitable restroom facilities and permit restroom breaks within a reasonable manner. Ohio law does not require a lunch break or a short break, but if the employer does permit a break of less than 15 minutes, they must pay the employee during that period.

    EMPLOYER RIGHTS

    PRESCRIPTION EYE GLASSES PPE

    Q: What are our options for employees who wear prescription eye glasses in the workplace?

    A: 1910.132(h)(2):The employer is not required to pay for non-specialty safety-toe protective footwear (including steel-toe shoes or steel-toe boots) and non-specialty prescription safety eye wear, provided that the employer permits such items to be worn off the job-site.

    Please remember that regular eye glasses are not considered eye protection. All prescription safety glasses should have the ANSI Z87 rating to be adequate for the work area.

    As for the tasks with radiant light hazards (welding), you’ll want to use a type of safety glasses which also have an adequate filter lens or properly tinted face shields.  OSHA outlines the minimum protective shade requirements for these operations in 1910.133(a)(5).

    • Provide an allowance towards prescription safety glasses if possible financially
    • Provide goggles that can fit comfortably over corrective eyeglasses without disturbing the alignment of the eyeglasses
    • Provide goggles that incorporate corrective lenses mounted behind protective lenses

    Since the employer is not required to provide prescription safety eyewear, here are a few options for you to ensure the safety of your employees:

    WHO PAYS FOR PPE?

    Q: If we buy our subcontractors safety equipment, can we charge them for it?

    A: OSHA requires that safety equipment is provided at no cost to employees.  However, if the equipment is for another contractor, you are free to invoice them as long as your contractor agreements do not prevent the transaction.  Note: some states require that you charge sales tax for reselling equipment.  It is recommended that you consult an attorney and/or an accountant.

    For more safety questions, contact Lancaster Safety.

    JEWELRY AT WORK

    WEARING JEWELRY AT WORK

    Q: What are the hazards associated with wearing neckwear encircling the neck or jewelry near machines having rotating shafts or spindles?

    A: In the Hand and Power Tools publication, paragraph (f) section (12) it states: “Wear proper apparel for the task. Loose clothing, ties, or jewelry can become caught in moving parts.” In the Basics of Machine Guarding publication, the last paragraph of chapter one states: “Jewelry such as bracelets and rings, can catch on machine parts or stock and lead to serious injury by pulling a hand into the danger area.” OSHA’s general industry regulations on machine guarding and/or hand and power tools do not specifically prohibit employees from wearing jewelry. However, if the employer has recognized that wearing loose jewelry is a hazard likely to cause serious physical harm, the employer would have an obligation to address the hazard under the General Duty Clause.

    LABOR LAW POSTER

    OSHA & LABOR LAW POSTERS

    Q: Do I need to post a new OSHA poster and Labor Law poster each year?

    A: The OSHA poster does not need to be updated annually.  The labor law posters do need to be updated annually.

    MULTI-EMPLOYER WORKSITE

    REQUIREMENTS FOR SUBCONTRACTORS

    Q: What are OSHA's requirements for subcontractors on our property? Do they need to sign in?

    A: In terms of maintaining compliance while subcontractors are working on your property, OSHA will reference the multi-employer citation policy. This policy is mainly used on construction sites but is implemented in general industry as well.  During an OSHA inspection, your company could be issued citations for any hazards that they create or even hazards that the subcontractors create.  It is recommended to include language in your contracts illustrating that subcontractor will abide by all Federal, State, and Local laws.  If possible, also include that the contract can be terminated if the subcontractor is in violations of these laws.

    TRAINING OF SUBCONTRACTORS ON A JOBSITE

    Q: Is the main contractor required to provide training for their subcontractors on a jobsite? Also, would training at any time 2014 be sufficient for all of 2015?

    A: For your question regarding the dates of the training, it depends on the OSHA annual requirements. For example, Fire Safety, Confined Space, and Hearing Conservation all have an annual training requirement pending the employees exposure to the hazards in the workplace. This is why we recommend for all employees to attend training annually to satisfy the requirements and as a refresher.

    As a main contractor, you may request for subcontractors to provide and/or implement their own documentation for required health and safety training, but you are not required to provide it. However, it would be beneficial to you have them attend the training if they are a subcontractor that you typically use frequently. The decision is ultimately up to you has a company. OSHA does not require that you as a company are  to train your subcontractors, but it is required that they must be adequate for the job. However, if they are not properly trained, it could lead to hazardous conditions on the jobsites.

    Please refer to the “OSHA-Multi Employer Worksite Policy.” This  policy specifically means that if your subcontractor violates an OSHA standard, the main contractor can be held accountable for allowing all workers present to be exposed to the hazard, not controlling the environment, and allowing unsafe practices to occur.

    RECORDKEEPING ON MULTI-EMPLOYER WORKSITE

    Q: If a subcontractor's employee has a work-related injury should it be recorded on the OSHA 300 log of the General Contractor or the subcontractor's?

    A: The injury only needs to be recorded once. If the general contractor is responsible for that employee's day-to-day supervision, it would need to be recorded their OSHA log. If the subcontractor is responsible for the employee's day-to-day supervision, they would record it on their OSHA log.

    OSHA’S MULTI-EMPLOYER CITATION POLICY

    Q: If an outside contractor is working in the plant, is it their responsibility to be in compliance or do we need to make sure they are in compliance?

    A: It would be to your benefit to make sure the contracted company is in compliance.  OSHA’s Multi-Employer Citation Policy states the following:

    • Multi-employer Worksites. On multi-employer worksites (in all industry sectors), more than one employer may be citable for a hazardous condition that violates an OSHA standard. A two-step process must be followed in determining whether more than one employer is to be cited.

    o   Step One. The first step is to determine whether the employer is a creating, exposing, correcting, or controlling employer. The definitions in paragraphs (B) - (E) below explain and give examples of each. Remember that an employer may have multiple roles (see paragraph H). Once you determine the role of the employer, go to Step Two to determine if a citation is appropriate (NOTE: only exposing employers can be cited for General Duty Clause violations).

    o   Step Two. If the employer falls into one of these categories, it has obligations with respect to OSHA requirements. Step Two is to determine if the employer's actions were sufficient to meet those obligations. The extent of the actions required of employers varies based on which category applies. Note that the extent of the measures that a controlling employer must take to satisfy its duty to exercise reasonable care to prevent and detect violations is less than what is required of an employer with respect to protecting its own employees.

    OSHA would consider the contracted company to be the exposing employer and your company as the controlling employer.  Please visit our websitefor more information.

    OSHA’S MULTI-EMPLOYER CITATION POLICY
    1. We are working on a roofing project and wanted to know who is responsible to make sure the contractor is in compliance?
    2. They are both responsible!  Click here for more information 

    If you are looking for help with your company's safety program, please visit our website:  lancastersafety.com

    OSHA POSTER

    OSHA POSTER REQUIREMENTS

    Q: Does the OSHA poster need to be posted on EVERY jobsite or can it be posted in the central meeting place where all of our other postings are housed?

    A: Here is OSHA’s interpretation of the regulation that requires the posting of the “OSHA Job Safety and Health – It’s the Law!” poster. It states, “We recommend posting the OSHA poster in the central office. When employees do not work at or report to a single establishment, 1903.2 states posters shall be posted at the location from which the employees operate to carry out their activities.”

    Download the OSHA poster here.

    OVER THE COUNTER DRUGS

    PURCHASING OVER THE COUNTER DRUGS

    Q: Are employers allowed to purchase any form of over-the-counter drugs for employees?

    A:  ANSI regulation allows employers to provide over-the-counter medication if the following guidelines are met:
    Make available only individually packaged tablets. Packages must be clearly marked with all FDA and manufacturer required indications and warnings. Tablet packaging should conform to the specifications in the Appendix to the ANSI Standard Z308.1-1998.

    Employers should make tablets available at no cost to the employee and receive no benefits from supplying the products.

    Employers are not liable in the event products are tampered with, unless the employer knew about the tampering and did nothing to protect employees.

    Employers are not liable when the employee makes an informed selection of tablets on their own, and when employer makes available only products supplied by a responsible vendor offering properly packaged and labeled products.

    Employers who allow sharing of open bottles of over-the-counter medication or provide nonprescription drugs, which are not individually packaged and properly labeled may be liable if an employee suffers and adverse reaction.

    PROGRAMS

    WRITTEN PROGRAM STORAGE

    Q:  Where do we need to keep our written programs - plant or office?

    A:  OSHA requires that the manuals are “accessible” to all employees.  So either in the plant or the office would work as long as the employees have access to them.  You may not want to keep them in the office if the office is ever locked while employees are working.  OSHA wouldn't consider them to be accessible in this case.

    EMPLOYEE ACCESS TO WRITTEN PROGRAMS

    Q:  What is the OSHA standard on accessibility to written programs?

    A:  OSHA has a number of standards that require the written programs to be accessible to all employees on site.  A few examples of these are  29 CFR 1910.1030(c)(1)(i) and 1910.1030(c)(1)(iii) (bloodborne pathogens) and 29 CFR 1910.1200(e)(1) and 1910.1200(e)(4) (hazard communication).  Where the standard requires that the written program must be made available to employees, the employer must ensure that employees know how to access the document and that there are no barriers to employee access.

    RESTROOMS FOR EMPLOYEES

    RESTROOM REQUIREMENTS

    Q:  As an employer, what obligations do I have pertaining to providing restrooms for the employees?

    A:  1910.141(c) Toilet facilities.1910.141(c)(1)   General.  1910.141(c)(1)(i)   Except as otherwise indicated in this paragraph (c)(1)(i), toilet facilities, in toilet rooms separate for each sex, shall be provided in all places of employment in accordance with table J-1 of this section. The number of facilities to be provided for each sex shall be based on the number of employees of that sex for whom the facilities are furnished. Where toilet rooms will be occupied by no more than one person at a time, can be locked from the inside, and contain at least one water closet, separate toilet rooms for each sex need not be provided. Where such single-occupancy rooms have more than one toilet facility, only one such facility in each toilet room shall be counted for the purpose of table J-1.

    Number of employees Minimum number of water closets1
    1 to 15 1
    16 to 35 2
    36 to 55 3
    56 to 80 4
    81 to 110 5
    111 to 150 6
    Over 150 2

    1Where toilet facilities will not be used by women, urinals may be provided instead of water closets, except that the number of water closets in such cases shall not be reduced to less than 2/3 of the minimum specified.

    SAFETY MEETINGS

    TOOLBOX TALKS

    Q: If we have a 2-day construction project, do we need to do a toolbox talk each day?
    A: OSHA does not require toolbox talks, although they do encourage them.  Safety meetings are always a good way to keep your employees thinking about safety, which is always helpful.  On a two day job it would probably be ok to just hold one meeting, unless the work you are doing is completely different on the second day.

    SLIPS

    SLICKER BOOTS

    Q: Can the employees wear slicker boots, is there a tripping hazard associated with them?

    A: Yes the employee can wear slicker boots to prevent the water from soaking the employees, there are no OSHA items stating that they are a potential tripping hazard.

    SPANISH

    OSHA POSTER IN SPANISH

    Q: Does OSHA require us to hang the OSHA required poster in Spanish?

    A: OSHA regulations do not specify or require employers to display the OSHA poster in a foreign language. However, OSHA encourages employers with Spanish-speaking workers to also display the Spanish version of the poster.

    Find out what OSHA requires at your company.

    STEP LADDERS

    STEP LADDER REQUIREMENTS

    Q: We need to purchase new step stools for some very tight spaces. We saw some stools for sale from Home Depot that are shown as “Type 1A rated” with a 300 pound capacity. Are these adequate and does the Type 1A refer to an ANSI ladder approval? Do you have information regarding what the Type 1A rating ensures?

    A: According to ANSI Standard A14.5 Portable Reinforced Plastic - Safety Requirements:

    Ladder Types included are:
    Duty Rating Ladder Type Working Load (pounds)
    Special Duty IAA 375
    Extra Heavy-Duty IA 300
    Heavy-Duty I 250
    Medium-Duty II 225
    Light-Duty III 200

    Note: Ladder type step stools are covered by A14.5. It is recognized that a step stool standard is under development. When the step stool standard is approved, A14.5 will no longer cover ladder type step stools.

    In summary, yes the Type 1A rating is referring to the ANSI standard and as long as a 300lb working load will be adequate for use.

    TEMPORARY-EMPLOYEES

    TRAINING FOR TEMPORARY WORKERS

    Q: What type of training do I need to provide to temporary employees?

    A: OSHA views temporary workers as if they were existing, permanent employees. Temporary staffing agencies and host employers share control over the employee and are therefore jointly responsible for temp employee’s safety and health. It is essential that both employers comply with the relevant OSHA requirements.   OSHA recommends that the temporary staffing agency and the host employer set out their respective responsibilities for compliance with applicable OSHA standards in their contract. Including such terms in a contract will ensure that each employer complies with all relevant regulatory requirements, thereby avoiding confusion as to the employer's obligations.

    Both host employers and staffing agencies have roles in complying with workplace health and safety requirements and they share responsibility for ensuring worker safety and health. A key concept is that each employer should consider the hazards as they are in a position to prevent, correct, and comply with OSHA standards. For example: staffing agencies might provide general safety and health training, and host employers provide specific training tailored to the particular workplace equipment/hazards.
    -The key is communication between the agency and the host to ensure that the necessary protections are provided.
    -Staffing agencies have a duty to inquire into the conditions of their workers' assigned workplaces. They must ensure that they are sending workers to a safe workplace.
    -Ignorance of hazards is not an excuse.
    -Staffing agencies need not become experts on specific workplace hazards, but they should determine what conditions exist at their client (host) agencies, what hazards may be encountered, and how best to ensure protection for the temporary workers.
    -The staffing agency has the duty to inquire and verify that the host has fulfilled its responsibilities for a safe workplace.
    -And, just as important: Host employers must treat temporary workers like any other workers in terms of training and safety and health protections.

    It would be essential to go over the processes and the hazards associated with each process for the temporary workers. They should be aware of the evacuation routes, SDS location, first aid kits, etc. within your specific facility. It is crucial that they undergo safety and health training prior to starting work.

    CAN TEMP AGENCIES COVER SAFETY INFORMATION WITH EMPLOYEES?

    Q: "Can I have the Temp Agencies go over safety information with the temporary employees before they actually come here and work? If so what would they need to go over?"

    A: OSHA views temporary workers as if they were exiting normal employees. Temporary staffing agencies and host employers share control over the employee, and are therefore jointly responsible for temp employee’s safety and health. It is essential that both employers comply with the relevant OSHA requirements.   OSHA recommends that the temporary staffing agency and the host employer set out their respective responsibilities for compliance with applicable OSHA standards in their contract. Including such terms in a contract will ensure that each employer complies with all relevant regulatory requirements, thereby avoiding confusion as to the employer's obligations.

    Both host employers and staffing agencies have roles in complying with workplace health and safety requirements and they share responsibility for ensuring worker safety and health. A key concept is that each employer should consider the hazards it is in a position to prevent and correct, and in a position to comply with OSHA standards. For example: staffing agencies might provide general safety and health training, and host employers provide specific training tailored to the particular workplace equipment/hazards.

    -The key is communication between the agency and the host to ensure that the necessary protections are provided.
    -Staffing agencies have a duty to inquire into the conditions of their workers' assigned workplaces. They must ensure that they are sending workers to a safe workplace.
    -Ignorance of hazards is not an excuse.
    -Staffing agencies need not become experts on specific workplace hazards, but they should determine what conditions exist at their client (host) agencies, what hazards may be encountered, and how best to ensure protection for the temporary workers.
    -The staffing agency has the duty to inquire and verify that the host has fulfilled its responsibilities for a safe workplace.
    -And, just as important: Host employers must treat temporary workers like any other workers in terms of training and safety and health protections.

    It would be essential to go over the processes and the hazards associated with each process for the temporary workers. They should be aware of the evacuation routes, MSDS location, first aid kits, etc. within your specific facility. It would be essential to make sure that they have had safety and health training prior to work.

    VEHICLES

    INSPECTION REQUIREMENTS FOR VEHICLES

    Q: Does OSHA have inspection requirements for Vehicles?

    A: At the beginning of each shift, all vehicles that will be used must be inspected to assure that they are in safe operating condition and free of apparent damage that could lead to an accident. All defects must be corrected before the vehicle is placed in service.

    WINTER DRIVING

    WINTER DRIVING

    Q: What are OSHA’s requirements regarding winter driving?

    A: OSHA does not have any specific winter driving training requirements. However, here is a link to OSHA’s webpage that will help give you some pointers:

    https://www.osha.gov/Publications/SafeDriving.pdf

    WORKING UNSUPERVISED

    WORKING UNSUPERVISED

    Q: Are we breaking any OSHA Regulations if we have a production employee come in over the weekend and work by themselves while no one else is in the facility?

    A: At this time, OSHA only has specific “Working Alone” regulations for shipyard requirements and maintenance work on electric power generation, transmission and distribution lines and equipment. However, there are certain factors you should consider to ensure you maintain compliance with OSHA requirements. Employees are responsible to ensure their workers have a safe and health environment. Therefore, certain Standard Operating Procedures shall be in place such as:
    • The Lone Worker should understand their responsibilities and be trained on any safety & health hazards they may encounter.
    o Set limits for what is permissible during lone work. For example, you wouldn’t want a lone worker entering a confined space or operating equipment that they have not been trained on.
    o Make sure that they are following proper safety policies and wearing required PPE for any hazardous process.
    • A clear action plan shall be in place in the event of an emergency.
    o Make sure emergency contacts are listed and the employee carries their cell phone when working alone.
    o Would it be possible to have a supervisor required to check-in with the lone worker during the shift? It would be recommended for the lone worker to check in with a supervisor at the beginner of their shift, during a break, and when they are completed.

    Although OSHA does not have clear requirements for lone workers in your industry, a citation can be issued under the General Duty Clause. The General Duty Clause is OSHA’s “catch-all” standard to require employers to provide their employees with a place of employment that is free from recognized hazards that are causing or likely to cause death or serious harm. This can most likely be prevented if there is a clear standard operating procedure for all lone workers and that they are trained on all applicable hazards as well as have action plan in the event of an emergency.

    WRITTEN PROGRAMS

    MAINTAINING HARD COPIES OF WRITTEN PROGRAMS

    Q: Do I need to maintain hard copies of each written program?

    A: Electronic versions of programs may be maintained as long as they are made available to employees and the employer has ensured that employees know how to access the document and that there are no barriers to employee access.

    https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=27325

     

  • 3. Emergency Planning & Response
     
    Keeping Track of Visitors in Case of an emergency

    Q: We do not have a system in place to account for all employees, delivery people, or visitors that may be here in the event of a fire. We have discussed different options but nothing suits us, everything we thought of will require a lot of time. In the event of a fire we don’t want to be wasting time and we just want something in place that is quick and easy for everyone involved. Can you give us some ideas of the best way to account for everyone and the less time consuming for someone to take care of?

    A: I would recommend the system we use here at our company which is a sign in sheet for all visitors. We have all visitors sign in and include the time they get here and we have them sign out when they leave. You could grab the sign in sheet and use that to account for visitors or delivery people when doing head counts for your fire drills. I hope this was helpful, if you need anything else please let me know!

    ABRASIVE BLASTING

    Q: What are the exit requirements regarding fire and blasting booths?

    A: 1910.94(a)(3)(i)(e)(1) Doors shall be flanged and tight when closed.

    1910.94(a)(3)(i)(e)(2) Doors on blast-cleaning rooms shall be operable from both inside and outside, except that where there is a small operator access door, the large work access door may be closed or opened from the outside only.

    1910.94(c)(3)(ii) Unobstructed walkways shall not be less than 6 1/2 feet high and shall be maintained clear of obstruction from any work location in the booth to a booth exit or open booth front. In booths where the open front is the only exit, such exits shall be not less than 3 feet wide. In booths having multiple exits, such exits shall not be less than 2 feet wide, provided that the maximum distance from the work location to the exit is 25 feet or less. Where booth exits are provided with doors, such doors shall open outward from the booth.

    To help paraphrase, you must ensure your doors are flanged and tight when closed.  The doors must open outward from the booth.  These doors need to be installed one every 25 feet or less.  If you have multiple doors the doors only need to be 2 feet wide, but if you only have one door that door needs to be at least three feet wide.

    ALARM PULL STATIONS

    IS AN AUDIBLE ALARM SYSTEM REQUIRED?

    Q. We have an audible alarm system in the plant with pull stations at all exits.  Are we required to have an audible alarm in every building / room?  We are specifically wondering about storage rooms or closets.

    A. OSHA requires that any employee alarm if capable of being perceived above and noise or light levels by all employees in the affected portions of the workplace. If there is an alarm outside of a storage room and it is able to be heard over all work being performed then that is acceptable.

    Also, OSHA allows for employers with 10 or fewer employees in a particular workplace, direct voice communication is allowed for a sounding alarm provided that all employees can hear.

    ALARM PULL STATIONS

    Q. Are alarm pull stations required to be located at every door?

    A. The location & number of pull stations were not specifically covered by OSHA, but by building/fire codes administered by each state’s Department of Labor & Industry. Location & number of pull stations would be determined by sprinkler coverage & building class. See OSHA’s alarm standard (29 CFR 1910.165).

    EGRESS

    OSHA REQUIREMENTS FOR OFFICE EXIT SIGNS

    Q: What are the regulations for exit signs for my office?

    A: For the exit route door, OSHA requires the following:

    • The exit route door must be free of decorations or signs that obscure the visibility of the exit route door.
      Each exit must be clearly visible and marked by a sign reading "Exit” in plainly legible letters.
      o The actual letters shall not be less than six inches high, and not less than three-fourths of an inch wide.
      If the direction of travel to the exit or exit discharge is not immediately apparent, signs must be posted along the exit access indicating the direction of travel to the nearest exit and exit discharge. Additionally, the line-of-sight to an exit sign must clearly be visible at all times.
      Each exit sign must be illuminated to a surface value of at least five foot-candles (54 lux)  by a reliable light source.

    For your other doorways in your office, OSHA requires each doorway or passage along an exit access that could be mistaken for an exit must be marked, “Not an Exit” or similar designation, or be identified by a sign indicating its actual use such as “closet” according to 1910.37(b)(5).

    EXIT SIGNS

    Q: What are OSHAs requirements on Exit Signs? Do they have to be a certain size, lit up?

    A: OSHA requires that each exit sign must be illuminated to a surface value of at least five foot-candles (54 lux) by a reliable light source and be distinctive in color. Self-luminous or electroluminescent signs that have a minimum luminance surface value of at least .06 footlamberts (0.21 cd/m2) are permitted. Each exit sign must have the word "Exit" in plainly legible letters not less than six inches (15.2 cm) high, with the principal strokes of the letters in the word "Exit" not less than three-fourths of an inch (1.9 cm) wide.

    EMERGENCY ACTION PLAN

    OIL AND FUEL SPILL PROTOCOL

    Q: What is the protocol for an oil and fuel spill?

    A: If an employee should discover a spill or leak, they should leave the area immediately and notify the managers. The Safety Data Sheet (SDS) for the spilled or leaking material should be consulted to identify potential hazards, protective equipment required, and correct procedures for clean-up. Shut off ignition sources, flames, spark producing or heat producing equipment, and provide adequate ventilation. If the spill or leak is too big to handle with available equipment, an emergency response team should be notified.

    Extended Answer: If you have a fuel or chemical release you should take the necessary precautions listed in your Emergency Action Plan. It reads as follow:

    Fuel or Chemical Release - Chemicals whether liquid, solid, or gas can spill or leak and be harmful to both personnel and the environment. If an employee should discover a spill or leak, they should leave the area immediately and notify the managers. The Material Safety Data Sheet (MSDS) for the spilled or leaking material should be consulted to identify potential hazards, protective equipment required, and correct procedures for clean-up. Shut off ignition sources, flames, spark producing or heat producing equipment, and provide adequate ventilation. If the spill or leak is too big to handle with available equipment, an emergency response team should be notified.

    Liquid Spills – If a container is leaking, a reasonable effort should be made to stop the leak and/or contain the spill, without compromising personal risk. Maneuver containers so that the hole is above the liquid level or try to plug the hole. If possible, confine a spill so that its contents do not enter a drain, ditch or seep into the ground.

    Gas Leaks – Alert all employees, check the wind direction, and begin assessing the extent of the release.
    • Evacuate and assemble upwind of the leak.
    • Direct non-essential personnel and visitors to evacuate the immediate area. Ensure that the selected assembly area is upwind of the gas leak. If not, evacuate all personnel to the alternate safe area outside of the facility using routes and exits that will avoid the hazard area.
    • Perform a headcount.
    • WARNING! RESCUE OF ANY DOWNED PERSONNEL SHOULD BE PERFORMED ONLY BY A TRAINED, QUALIFIED PERSON WEARING SCBA WITH AN APPROPRIATE BACKUP/WATCHER. Without this capacity, do not attempt a rescue; contact the EMS and/or fire department.
    • Stop or contain the leak, if possible. NOTE: Careful assessment is essential before you proceed.

    DEADBOLT ON AN EMERGENCY DOOR PERMITTED?

    Q: Is a dead bolt lock on an emergency door permitted?

    A: An exit door must be unlocked. Employees must be able to open an exit route door from the inside at all times without keys, tools, or special knowledge. A device such as a panic bar that locks only from the outside is permitted on exit discharge doors. Exit route doors must be free of any device or alarm that could restrict emergency use of the exit route if the device or alarm fails. The outdoor exit route must be reasonably straight and have smooth, solid, substantially level walkways; and the outdoor exit route must not have a dead-end that is longer than 20 feet (6.2 m).

    We always recommend having a safety consultant come in to evaluate your workplace for possible hazards like this. Please contact us today if you would like help.

    LOCKED EXIT DOORS

    Q: Is is acceptable to keep an exit door in our shop locked to prevent people from walking in from the street?

    A: Employees must be able to open an exit route door from the inside at all times without keys, tools, or special knowledge. A device such as a panic bar that locks only from the outside is permitted on exit discharge doors.

    Reference: 1910.36(d)(1) https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_id=9724&p_table=STANDARDS

    EMERGENCY ACTION PLAN FOR EMPLOYEE-FREE LOCATION

    Q: If we typically do not have any employees at a location, but there is a possibility that more than 10 employees will be there at once, do we still need an emergency action plan?

    A: Yes. If more than 10 employees congregate at this facility, a written plan is needed. The written requirement for employee emergency or fire prevention plan is based on the number of employees that are physically in a facility at any time of the working day and not on the number of employees that are employed by the employer. Click Here For Reference.

    OSHA 1910 FIRST AID STANDARD

    Q:  What is the definition of “near proximity” used in the OSHA first aid standard 1910.151(b)?

    A: The term "near proximity" that is contained in the first aid standard, means the facility or jobsite must be 4 minutes away from a first responder or medical facility to treat the injured employee. If the facility or jobsite isn’t within a 3-4 minute time frame of a first responder, or drive time, than you are required to have an employee on-site that is capable of performing first aid duties (must be certified).

    If you need to have your employees trained in first aid/CPR/AED, please contact LSCI by clicking this link.

    REQUIREMENTS FOR TESTING EMERGENCY LIGHTING

    Q: What are OSHA's requirements for testing emergency lighting?

    A: OSHA does not have any requirement to test emergency lighting as it would fall under NFPA. OSHA’s requirements simply state that you have to provide adequate emergency lighting.

    The NFPA requirements state that there are three different categories of emergency lights: traditional, self-testing/self-diagnostic and computer based self-testing/self-diagnostic. It essentially requires both a monthly activation test, where the lights remain illuminated for a minimum of 30-seconds, and an annual test where the lights are activated for 1.5-hours to simulate a long term emergency event. Written records of the monthly and annual tests must be maintained for inspection. Computer based emergency lighting systems must be capable of generating a self-report of testing at all times.

    EMERGENCY EVACUATION PLAN

    Q: Does OSHA require posting emergency evacuation maps every so many feet throughout the plant?

    A: There is nothing that specific in the standard but they should be in common areas such as offices and break rooms, doorways, etc.  The maps should be visible to anyone walking by.  They should have a primary and secondary route color coded and the mustering point marked.

    EMERGENCY EVACUATION PLAN

    Q:  What should I put on the emergency evacuation plans?

    A:  There needs to be a primary and secondary route, where they are currently located in the building ("you are here"), where the meeting point is outside, and where the fire extinguishers are throughout the facility.  Click here for more information.

    EMERGENCY ACTION PLAN

    Q: Will it violate any OSHA standards if I put materials or a barricade in front of a garage door?

    A: A garage door is not permitted to be considered a route of egress; as long as the materials or barricade do not block an exit route.

    EMERGENCY SHOWERS

    EMERGENCY SHOWERS

    Q: How far away does an emergency shower have to be from the lab?

    A: The emergency shower must be within 10 seconds of the exposure site or 55 feet.

    EMERGENCY SHOWERS

    Q:  Are there any OSHA requirements that apply to the placement of where we put our safety showers?

    A:  OSHA’s regulation regarding emergency showers and eyewash facilities states the following:  1910.151(c) Where the eyes or body of any person may be exposed to injurious corrosive materials, suitable facilities for quick drenching or flushing of the eyes and body shall be provided within the work area for immediate emergency use.

    Even though OSHA currently doesn't have specific requirements for the location of the facilities, OSHA does recognize the guidelines set by sources such as the American Standards Institute (ANSI).  ANSI requires that emergency eyewash facilities to take no longer than 10 seconds to reach.  They also state that where a strong acid or caustic is used, the unit should be immediately adjacent to the hazard.  The MSDS for the chemical will also provide guidelines on how corrosive the chemical is and information on drenching facilities.

    If you have specific questions about safety issues at your facility, contact us today!

    REQUIREMENTS FOR EYE WASH AND EMERGENCY SHOWER SIGNAGE
    Q. What color do our eye wash and emergency shower signs have to be?
    A. OSHA does not require a specific color or set up of an eye wash station. Most signs available are green with white lettering.

    EMERGENCY STOPS

    OSHA REQUIREMENTS FOR EMERGENCY STOPS ON MACHINERY

    Q: Does OSHA have a regulation concerning emergency stops for machinery?  Do they specify the frequency of testing for these emergency stops?

    A: OSHA’s standpoint concerning emergency stops states they are designed to be used in reaction to an incident or hazardous situation, but are not considered machine safe guarding, and are more of a complementary protective measure.

    OSHA’s general requirements for emergency stops for all types of machinery include:

    • All emergency stop bars, stop buttons, and electrical switches used for emergency stopping of hazardous machines shall be red.
    • Stop the hazardous process as quickly as possible, without creating additional risks by a single human action when the normal stopping function is inadequate
    • Where necessary, trigger or permit the triggering of certain safeguard movements.
    • OSHA requires emergency stop devices to be easily accessible to the operator, clearly visible, and unobstructed.
      o   This recognized safety feature provides employees with the means to shut off the equipment in the event of a hazardous situation.
    • Frequency of infrequency of use
    • Operating conditions
    • Operating environment

    Although OSHA does not regulate the frequency of testing, as it states, they state it should be “regularly” tested.  The NFPA standard states you should consider the need for periodic testing based on the components of the emergency stop such as:

    These three factors would determine the frequency of testing the emergency stops. It would be recommended to review the manufacturer’s manual to determine if there is any manufacturer recommendations in regards to the emergency stops.

    EVACATION PLAN

    POSTING EVACUATION PLAN

    Q: Where do I need to post my evacuation plan and what should be included?

    A: The evacuation route should include locations of exits, assembly points, and equipment (such as fire extinguishers, first aid kits, spill kits) that may be needed in an emergency. Although there is not an OSHA requirement directly stating where to post the evacuation plan, OSHA does state that it must be posted prominently for all employees to see. A recommendation would be to make sure it is posted in each building and reviewed with all employees so they know that the evacuation plan is easily accessible.

    It would be beneficial to designate both a primary and secondary evacuation route and exits. Color coding will also aid employees in determining their route assignments. This way, if the primary route is  not accessible during an emergency, employees will also be aware of the secondary evacuation route. It is important to ensure that the evacuation routes and emergency exits meet the following conditions:
    • Clearly marked and well lit;
    • Wide enough to accommodate the number of evacuating personnel;
    • Unobstructed and clear of debris at all times; and
    • Unlikely to expose evacuating personnel to additional hazards.

    EVACUATION DRAWINGS

    EVACUATION DRAWINGS

    Q: Where should we hang our evacuation maps?

    A: By all the main exits and fire extinguishers.

    Be prepared in the event of an emergency, find out how.

    EXIT SIGN

     LACK OF LIGHTING FOR EXIT SIGN

    Q: Can fluorescent lighting be used in place of an exit sign since we do not have outlets near all exits?

    A: Yes, OSHA requires each exit route to be adequately lighted so that an employee with normal vision can see, the exit is clearly marked by a sign reading "EXIT", and the routes are free of decorations or signage that blocks the visibility of the exit light. See 1910.37(b).

    FIRE

    FIRE EXTINGUISHER TRAINING REQUIREMENTS

    Q: What is the requirement for hand-on fire extinguisher training regarding the number of employees that must be trained? Can we train our own employees?

    A: Per OSHA’s Portable fire extinguishers standard, 1910.157, you must train employees who are designated to operate a fire extinguisher upon initial assignment and at least annually thereafter. If you do not have any employees designated to use a fire extinguisher, meaning they are required to evacuate and not fight a fire, then the hands-on training is not required. You can perform the training yourselves as long as the employees are actually putting out a fire with the fire extinguishers. We recommend contacting your local fire department for the training though. Also, OSHA has no requirement on the number of employees that need to be designated to use the fire extinguishers.

    FIRE ALARM, SPRINKLER SYSTEM, AND FIRE EXTINGUISHER INSPECTIONS

    Q: How often do fire alarms, sprinkler systems, and fire extinguishers need inspected?

    A: Fire alarms must be inspected every two months if unsupervised, and one a year for supervised systems. A supervised alarm means it has the ability to monitor its own integrity. Sprinklers must assure that a main drain flow tests is performed annually and the inspector’s test valve shall be opened at least every two years.   Portable extinguishers or hose visually inspected monthly with an annual maintenance check.

    Below are the OSHA requirements for inspecting fire alarms, sprinkler systems, and fire extinguisher requirements to better assist you:

    Fire Alarms
    1910.164(c)(2)The employer shall assure that fire detectors and fire detection systems are tested and adjusted as often as needed to maintain proper reliability and operating condition except that factory calibrated detectors need not be adjusted after installation.
    1910.165(d)(1)The employer shall assure that all employee alarm systems are maintained in operating condition except when undergoing repairs or maintenance.

    1910.165(d)(2) The employer shall assure that a test of the reliability and adequacy of non-supervised employee alarm systems is made every two months. A different actuation device shall be used in each test of a multi-actuation device system so that no individual device is used for two consecutive tests.

    1910.165(d)(4) The employer shall assure that employee alarm circuitry installed after January 1, 1981, which is capable of being supervised is supervised and that it will provide positive notification to assigned personnel whenever a deficiency exists in the system. The employer shall assure that all supervised employee alarm systems are tested at least annually for reliability and adequacy.

    Sprinkler systems
    1910.159(c)(2)The employer shall properly maintain an automatic sprinkler system installed to comply with this section. The employer shall assure that a main drain flow test is performed on each system annually. The inspector's test valve shall be opened at least every two years to assure that the sprinkler system operates properly.

    Fire extinguishers:
    1910.157(e)(3) The employer shall assure that portable fire extinguishers are subjected to an annual maintenance check. Stored pressure extinguishers do not require an internal examination. The employer shall record the annual maintenance date and retain this record for one year after the last entry or the life of the shell, whichever is less. The record shall be available to the Assistant Secretary upon request.

    1910.157(e)(2)Portable extinguishers or hose used in lieu thereof under paragraph (d)(3) of this section shall be visually inspected monthly.

    FIRE EXTINGUISHER LOCATIONS

    Q: Where do fire extinguishers need to be located throughout the facility?

    A: Fire extinguishers need to be place 75 feet from class A fire and 50 feet from class B fire which is flammable chemicals.

    FIRE EXTINGUISHER’S ON FORKLIFTS

    Q: What would be your recommendation for fire extinguishers on forklift trucks; is this mandatory by OSHA?

    A: If the forklift comes from the manufacturer with a fire extinguisher then it must be properly maintained and inspected. If it does not come with one then it falls under OSHA’s fire extinguisher regulation. Whether it is fueled by propane, gas/diesel, or battery then it would be considered a Class B fire hazard and is required to be within 50 feet of a fire extinguisher at all times. If the forklift is operated outside of the 50 foot travel distance then it is recommended that one be mounted on the forklift. Lastly, all modifications and additions to forklifts need to be approved by the manufacturer.

    To see if your facility is OSHA compliant, contact LSCI to set up a mock OSHA inspection.

    FIRE EXTINGUISHER

    FIRE EXTINGUISHERS ON CONSTRUCTION EQUIPMENT

    Q: What are the minimum requirements for fire extinguishers on large construction equipment?

    A: The fire protection and prevention standard (29 CFR 1926.150) does not state any specific weight or size requirements for fire extinguishers on construction equipment.  However, a fire extinguisher, rated not less than 10B, shall be provided within 50 feet of wherever more than 5 gallons of flammable or combustible liquids or 5 pounds of flammable gas are being used on the jobsite. There are times where heavy equipment has factory mounts for extinguishers. In this case, they should be maintained.

    FIRE EXTINGUISHERS NECESSARY IN FACILITIES WITH SPRINKLER SYSTEMS

    Q: Are fire extinguishers required for my facility that contains a sprinkler system?

    A: 1910.157(d)(3) The employer may use uniformly spaced standpipe systems or hose stations connected to a sprinkler system installed for emergency use by employees instead of Class A portable fire extinguishers, provided that such systems meet the respective requirements of 1910.158 or 1910.159, that they provide total coverage of the area to be protected, and that employees are trained at least annually in their use..

    If your employees are trained annually on the use of the sprinkler systems, the sprinkler system meet the requirements of 1910.158 or 1910.159, the sprinkler system provides total coverage of the area protected, you may use a sprinkler system instead of a Class A portable fire extinguisher. To better understand the Class A fire, water is the best extinguishing agent and it contains normal combustibles such as wood, paper, cardboard, cloth etc.

    FIRE EXTINGUISHERS ON COMPANY VEHICLES

    Q. Can you provide any specifics on the required fire extinguishers for our company trucks?

    A. OSHA does not have any requirements for fire extinguishers being on company vehicles. However, portable fire extinguisher equipment is required to be on all worksites within 100 feet travel distance. So when employees are out on their own then there should be a fire extinguisher rated note less than 2A with them on the trucks.

    FIRE EXTINGUISHERS IN COMPANY CARS

    Q: Are fire extinguishers required for employee company cars?

    A: Although recommended to be available along with proper training, fire extinguishers are not required for company cars unless the vehicle falls under 1926.601 construction requirements.

    MOUNTING FIRE EXTINGUISHERS

    Q: When mounting 2 different types of fire extinguishers, is it required to use the exact type of bracket listed on the side of the fire extinguisher or a universal wall hook for a 10 lb ABC extinguisher?

    A: Although it is recommended to use the manufacturer’s product, as it is made for that exact fire extinguisher, it is not required.

    FIRE EXTINGUISHER

    Q: How high off of the floor does a fire extinguisher need to be mounted?

    A: Fire extinguishers need to be mounted and identified so that they are readily accessible to employees without subjecting them to possible injury. Generally, the carrying handle should be placed 3-5 feet above the floor.

    FIRE EXTINGUISHERS INSPECTION REQUIREMENTS

    Q: What are the monthly requirements when inspecting fire extinguishers?

    A:  Fire extinguisher need to be inspected monthly.  This inspection should be completed by an employee working for the company.  This employee needs to document the inspection and assure all extinguishers are maintained fully charged and in operable condition.  The fire extinguishers must also be located in their designated areas at all times so employees know where they are located.

     

  • 4. Fall Protection
     

    AERIAL LIFT

    AERIAL LIFTS

    Q: Is it acceptable to tie off inside a basket (lift) using a retractable safety cable and harness?

    A: It is a requirement to tie off when using an aerial lift in any form other than a properly guarded scissors lift.  OSHA requirements when using the personal fall arrest system state, when stopping a fall:
    (iii) be rigged such that an employee can neither free fall more than 6 feet (1.8 m), nor contact any lower level.  [1926.502(d)(16)(iii)]

    FALL PROTECTION

    PROTECTING WORKERS ON A FLAT ROOF

    Q: What is the proper and OSHA approved method of protecting my workers on a flat roof with multiple curb mounted skylights on the roof? We have a perimeter warning line in place all around the roof as required, but are not sure about each individual skylight. Can we use a warning line around them one at a time while working close to each or do they all have to be covered individually on the whole roof section while we are working on that section of roof? If so, what is required to cover those with?

    A: You would want to treat the skylights essentially like the edge of a roof or another leading edge. You should either use guardrails around each skylight or a cover for each skylight to block access. It is recommended to use the guardrail system to completely avoid the area, but if you do decide to use covers, per 1926.502(i)(2), they shall be capable of supporting, without failure, at least twice the weight of employees, equipment, and materials that may be imposed on the cover at any one time. This Letter of Interpretation explains the requirements for covers in more detail. Also, you can review 1926.501(b)(4)(i) through (b)(4)(iii) for the fall protection requirements when working around skylights.

    FALL ARREST HARNESSES

    Q:Attached is an inspection report for the fall arrest harnesses.  I was looking through the fall protection program but I was not able to find how often this report needs to be done - monthly, annually?

    A:In regards to your question about how frequent fall arrest harnesses should be inspected, they should be visually inspected for mildew, wear & tear, damage, deterioration, or other defect before each use by whoever will be wearing the harness. We recommend documenting the inspections using the checklist  on a monthly basis or before each use if the harnesses are not used frequently.

    LADDER TIE OFF REQUIREMENTS

    Q: What are the safety requirements for hanging wood fascia while working off of a ladder? Do the employees need to be tied off?

    A: You are required to maintain three points of contact at all times and are not permitted to work off of the top step of the ladder. as long as you meet those requirements, you would not have to be tied off.

    FALL ARREST HARNESS INSPECTIONS

    Q: We have harnesses and fall arrest lanyards.  Someone told me that the harnesses need to be inspected periodically. Is this just a visual inspection that the employees can do themselves or does someone outside of our company have to do this?

    A: Your employees can perform a visual inspection, just be sure to document that the equipment was inspected. Also, if you do an inspection of the equipment and it appears to be damaged or unusable, be sure to dispose of it and replace it.

    WORKING OVER WATER AND LADDER SAFETY

    Q: What are the requirements for fall protection over the water? Is a USCG approved life vest acceptable at all height levels? At what height would fall protection be required, if at all?

    A: When working above water, employers must provide fall protection if the distance from the walking/working surfaces to the water’s is 6 feet (1.8 m) or more. Each employee on a walking/working surface (horizontal or vertical) with an unprotected side or edge which is 6 feet (1.8 m) or more above a lower level shall be protected from falling by the use of guardrails systems, safety net systems, or personal fall arrest systems.

    The use of USCG approved life vests are what is required by OSHA regulations. So that is great that you already have that prepared. However, if you use a continuous fall protection system (without exception) to prevent employees from falling into the water, the use of USCG approved life vests is not required.

    However, the use of ring buoys and skiff are required. This device addresses the hazards that may occur in the event of a failure of operation of fall protection devices, or the lapse of their use.

    FALL PROTECTION REQUIREMENTS FOR LADDERS

    Q: What are the requirements for ladders in regards to fall protection?
    a. I cannot locate any information on height requirements, types of ladders, cages, etc.

    A: There is no requirement that states which type of ladder is to be used (fixed or portable), however it is recommended that if the primary use of that specific ladder is for the transportation of employees into and out of work areas, a fixed ladder is used.

    For Fixed Ladders:

    • Fixed ladders shall be provided with cages, wells, ladder safety devices, or self-retracting lifelines where the length of the climb is less than 24 feet (7.3 m) above lower levels.
    • Where the length of a climb exceeds 24 feet (7.3 m), fixed ladders shall be equipped with one of the following:
      - Ladder safety device;
      - Self-retracting lifelines, and rest platforms at intervals not to exceed 150 feet (45.7 m); or
      - A cage or well, and multiple ladder sections, with each ladder section not exceeding 50 feet (15.2 m) in length. Ladder sections shall be offset from adjacent sections, and landing platforms shall be provided at maximum intervals of 50 feet (15.2m).

    Portable Ladders:

    • Neither the ladder standard (29 CFR 1926, subpart x) nor the fall protection standard (29 CFR 1926, subpart M) requires fall protection for workers while working on portable ladders.
    • However, if you are working for a General Contractor, they may require that subcontractors implement a personal fall arrest system when working on ladders 6 feet or higher.
    WORKING 10 FEET IN THE AIR

    Q: We have a machine that is about 8-10 feet in the air and the employees work on top of it. Do they need to be tied off?

    A: If an employee is exposed to a drop greater than 4 feet, fall protection must be provided. In this instance, there could be a restraint attached to the machine that they could tie off to. Guard rails could also be used if feasible as well as a rolling ladder or scaffolding.

    DIFFERENCE BETWEEN A FALL ARREST AND A FALL RESTRAINT SYSTEMS

    Q: What is the difference between a fall arrest and a fall restraint system? When do you know which one to choose?

    A: In regard to the technical differences between fall arrest and fall restraint according to the ANSI Standard Z 359.3  Subsection 3.2.2., the expanded definition of fall restraint is a working surface from zero degrees up to 18.4 degrees of slope. The 18.4 degree slope is used because it is a common 3/12 pitch on a roof. At slope angles greater than 18.4 degrees, the work environment demands a fall arrest system because a worker can no longer be restrained from an edge. The slope itself becomes the fall hazard.

    Fall restraint systems are generally suitable if the person needs to work near the edge of a hazard. It prevents the person from reaching the fall risk. For example, where there is a need to maintain gutters along the edge of a roof, or if there are other potential fall hazards such as roof lights or air vents.  A few examples include guardrails or work-positioning systems such as a full body harness that attaches you to an anchor and leave both hands free or a travel-restriction systems which is personal fall protection equipment used to prevent you from traveling to the  actual edge.  The anchor must have a load capacity of 800 lbs or four times the weight of the worker connected to the system. In a fall restraint system, a line is attached to an anchor and to your harness in such a way that you cannot fall.

    A fall arrest system provides maximum freedom of movement for workers to conduct their duties. In doing so it allows them to reach the point where the fall could occur such as the actual edge or a roof. However, in the event of a fall, the fall will be arrested so allow the person to either effect a self-rescue or be rescued. Fall arrest systems protect you after you fall by stopping the fall before you hit the surface below. Examples would include safety nets or full body harnesses connected by lanyards or lifelines to secure anchors as Mike. The harness must be attached to an anchor that is able to withstand 5000 lb. or two times the maximum arrest force.

    FALL PROTECTION ON 18' WIDE FLAT ROOF

    Q: We are working on an 18' wide, flat roof. Is requiring employees to be 100% tied off adequate fall protection?
    A: Yes.

    Reference: 1926.501(b)(1)"Unprotected sides and edges." Each employee on a walking/working surface (horizontal and vertical surface) with an unprotected side or edge which is 6 feet (1.8 m) or more above a lower level shall be protected from falling by the use of guardrail systems, safety net systems, or personal fall arrest systems.

    CERTIFICATION FOR INSPECTING FALL ARREST HARNESSES

    Q. Do employees need to be certified to inspect fall arrest harnesses and what should we look for?

    A. Employees need to be competent and qualified, not certified. You want to look for any signs of damage (rust, cracks, rips). See Attached File.

    PPE NEEDED TO PROTECT AGAINST A FALL

    Q: Will our employees be safe if they are wearing a 6 foot lanyard with an 18 foot fall?
    A: When calculating a fall clearance distance using a shock-absorbing lanyard and D-Ring Anchorage Connector, there are a few lengths to be considered.

    • First add the length of the shock absorbing lanyard (6 ft.) to the maximum elongation of the shock absorber during deceleration (3-1/2 ft.) to the average height of a worker (6ft.)
    • Then, add a safety factor of 3 ft. to allow for the possibility of an improperly fit harness, a taller than average worker, and/or miscalculation of distance.

    The total 18-1/2 ft. is the suggested safe clearance distance for a 6 foot lanyard. Therefore, the employees should be wearing a 3-4 ft. lanyard for a 18 foot fall.

    HVAC ON A LOW SLOPED ROOF

    Q: Can you use a 15 foot warning line on when preforming HVAC work on a low sloped roof?
    A: Here is a interpretation from OSHA that reviews this warning line regulation. As you can see they do state the use of the 15 foot warning line but it is still referred as a De Minimis Violation.  A De Minimis Violation can still result in a citation even though you are not directly putting your employees health and safety at risk.

    Q: What requirements do you need to follow working on an elevated roof?
    A: Employees that are conducting work within 6 feet of the roofs edge will need to have on fall protection. For work in the middle of the flat roof you can erect a warning line six feet from the roofs edge. No employees or tools can be in-between the warning line and edge of the roofs surface.

    FALL PROTECTION

    Q: Is it acceptable to use a choker as a beam wrap to attach a fall protection lifeline?
    A: In short the two things you need in order to use the choker as a beam wrap is that it needs to be made of synthetic fibers and from the picture it is.  Secondly it needs to be capable of supporting at least 5,000 pounds per employee attached.  Please ensure the label states this and you will be good to go.

    •1926.502(d)(14) Ropes and straps (webbing) used in lanyards, lifelines, and strength components of body belts and body harnesses shall be made from synthetic fibers.

    •1926.502(d)(15) Anchorages used for attachment of personal fall arrest equipment shall be independent of any anchorage being used to support or suspend platforms and capable of supporting at least 5,000 pounds (22.2 kN) per employee attached, or shall be designed, installed, and used as follows:

    1926.502(d)(15)(i) as part of a complete personal fall arrest system which maintains a safety factor of at least two; and

    1926.502(d)(15)(ii)under the supervision of a qualified person.

    1926.502(d)(16) Personal fall arrest systems, when stopping a fall, shall:

    1926.502(d)(16)(i) limit maximum arresting force on an employee to 900 pounds (4 kN) when used with a body belt;

    1926.502(d)(16)(ii) limit maximum arresting force on an employee to 1,800 pounds (8 kN) when used with a body harness

    FALL PROTECTION & SKYLIGHTS

    Q: Do skylights need to be protected?

    A: In short you will need to take safety precautions to protect yourself from the skylight; either by personal fall arrest systems, covers, or guardrail systems erected around such holes.

    • 1926.501(b)(4)(i) Each employee on walking/working surfaces shall be protected from falling through holes (including skylights) more than 6 feet (1.8 m) above lower levels, by personal fall arrest systems, covers, or guardrail systems erected around such holes.

    • 1926.501(b)(4)(ii) Each employee on a walking/working surface shall be protected from tripping in or stepping into or through holes (including skylights) by covers.

    • 1926.501(b)(4)(iii) Each employee on a walking/working surface shall be protected from objects falling through holes (including skylights) by covers.

    LADDERS & SCAFFOLDING

    Q: Do employees have to use the ladder to access scaffolding on the jobsite.

    A: Yes the employees should use the ladders to access scaffolding. OSHA standard on ladder access to scaffolding is :

    1926.451(e)(1)

    When scaffold platforms are more than 2 feet (0.6 m) above or below a point of access, portable ladders, hook-on ladders, attachable ladders, stair towers (scaffold stairways/towers), stairway-type ladders (such as ladder stands), ramps, walkways, integral prefabricated scaffold access, or direct access from another scaffold, structure, personnel hoist, or similar surface shall be used. Cross braces shall not be used as a means of access.

    FALL PROTECTION

    Q: Is safety ribbon sufficient to warn employees of a fall hazard, if that fall hazard is a minimum of 6 feet?
    A: Safety ribbon is not sufficient as a guard rail because the guardrail system must be capable of withstanding a force of at least 200 pounds. The guard rail must also have top rail height of 42 inches plus or minus 3 inches.

    RAMP SLOPE

    Q: What does OSHA allow for a pitch of a ramp and does it need hand rails?

    A: OSHA does not want a ramp greater than 30 degrees from horizontal and it must have a handrail if it is 20 degrees or more.

    FALL ARREST HARNESS FOR SCISSOR LIFT

    Q: Does an employee have to wear a fall arrest harness when working in a scissor lift, also can we move the scissor lift?

    A: The employee does not have to wear a fall arrest harness if the scissor lift has adequate fall protection. (standard railing) Also the scissor lift can't be moved with a person in it while the lift is elevated. The employee must lower the lift, reposition then raise lift to continue the work.

    FALL PROTECTION

    Q: When accessing a roof with a 12 by 12 pitch what are the fall protection requirements?

    A: When climbing the ladder the employee must have 3 points of contact. Upon reaching the sloped roof the employee shall attach a safety lanyard to the D-ring on their fall arrest harness. Depending on the work, ideally the lanyard would be best severed attached to a horizontal life line supported by anchor points. Guardrails shall be erected whenever employee are not attached to a safety line.

    REPLACING A RAILING WITH NYLON ROPE

    Q: Can we replace a standard railing with a nylon rope?
    A: In OSHA letters of interpretation it states that there is no required material for a railing, but it must meet the 200 lbs top rail and 150 lbs midrail for support with a deflection of 3 inches or less.

    LADDER REQUIREMENTS FOR ACCESSING A BILLBOARD

    Q: What is the safety requirements for a 32’ climb to get to a LAMAR sign? They are using a ladder.

    A: If the sign has a fixed ladder the manufacturer should have installed the ladder to meet the following requirement: 1926.1053(a)(18) Fixed ladders shall be provided with cages, wells, ladder safety devices, or self-retracting lifelines where the length of climb is less than 24 feet (7.3 m) but the top of the ladder is at a distance greater than 24 feet (7.3 m) above lower levels.

    If the ladder has a vertical lifeline, or similar apparatus, the employees need to attach their fall arrest harness to it while climbing. A double ended lanyard is recommended so the employees can attach to the anchor point on the platform prior to disconnecting from the vertical lifeline. This way they will be maintaining 100% attachment at all times.

    If the employees will be using an extension, ladder OSHA doesn’t require a fall arrest harness to climb it, but they will need to attach to an anchor point on the platform of the sign before the step onto it. They will also want to make sure the ladder is secure, it’s extended at least 3’ above the platform and the proper angle is met.

    LADDERS

    Q: When using a ladder what do you do when you cannot have the ladder properly tied off?

    A: In this case the employees are working on a residential roof with a 6-12 pitch. It was instructed to insert a screw into the edge of the roof at a good position so they are able to tie the ladder off securely. When they are working on the finishing touches they are to leave the section that the ladder is tied off to for last. They will document the fact the ladder has been tied off and inspected. When it comes time to finish the last section the screw shall be removed and an employee from the ground level will hold the ladder in place until all work is completed and the ladder is removed.

    IS YOUR LADDER TALL ENOUGH?

    Q: If we have a ladder that is not long enough to extend 3 feet above a landing, does OSHA permit the use of a platform or base to boost the ladder 3 feet?

    A: OSHA does not permit the use of a platform or base. You would need to purchase a longer ladder.

    FALL PROTECTION

    Q: We were told today that the 42” height for perimeter safety can include the vertical AND HORIZONTAL measurements of a parapet wall. Is this true?

    A: OSHA’s height guideline on guardrails is as follows:

    • 1926.502(b)(1) Top edge height of top rails, or equivalent guardrail system members, shall be 42 inches (1.1 m) plus or minus 3 inches (8 cm) above the walking/working level.

    The depth of the wall does not affect OSHA’s height requirement of the guard rail.

    ENTERING A DUMPSTER

    Q: We sometimes have an employee enter the dumpster on the jobsite to rearrange it. What would be the proper protection for this employee?

    A: Proper PPE would need to be worn while performing this task. Cut/puncture resistant gloves, safety glasses, steel toes, etc. would need to be worn. Also, since there could be boards that have nails sticking out of them footwear with puncture resistance/steel reinforced soles would need to be worn. If the dumpster is 6 feet or higher and the worker needs to access it when it’s full proper fall protection would be required as well. To eliminate the need for fall protection, a company policy should be put in place that prohibits the worker from accessing the dumpster if the material is less than 42 inches from the top of the dumpster. Ladders can also be used outside of the dumpster if possible.

    FALL PROTECTION

    Q: Is it acceptable to use a scissors lift from an elevated platform that has perimeter openings of 40 inches around the outside of the floor?

    A:  Since the wall openings are 40 inches, it is required for workers working from the floor level to have fall protection.  In this case the horizontal lifeline and fall arrest harnesses are acceptable, as long as they are used in the proper form.

    Any employee using the scissors lift will be required to have their fall arrest harness secured and attached until entering the lift because of the 40 inch openings.  When in the lift, the wall structures and the curtain walls must act as a curbing system; that will not allow the lift to reach the edge of the floor, exposing the employees to the risk of driving the lift off the edge.

    This process must be made as safe as possible to ensure that the lift is incapable of driving over the curtain walls that are acting as the curbing system.  If there are any potential hazards that may occur, they must be addressed.  OSHA may be unclear with the use of equipment use from an elevated platform, but OSHA does state under the General Duty Clause that the employer must ensure a safe workplace for the employees.

    Safety challenges can come up at any time, trust the OSH consultants at LSCI to help with your company's safety.

    FORKLIFT MAN BASKETS

    Q: Are man baskets allowed by OSHA?

    A: Forklift man baskets are allowed by OSHA as long as you use them the correct way the manufacture designed them to be used.  When employees are inside the man basket they need to have a fall arrest harness on and tied off with a lanyard to ensure they cannot be ejected.

    STILTS

    Q: Does OSHA permit the use of stilts when doing drywall and taping?

    A: Stilts are permitted, but make sure the working area is clean and free of tripping hazards. Also, if you are working in an area that has guardrails you will need to add extra protection to ensure the employees on stilts cannot fall over the top of the guardrail.

    LEADING EDGE WORK

    Q:  When installing plywood decking on a suspended concrete slab that is 13 feet high; is fall protection required?

    A: Yes fall protection is required unless you can prove that fall protection is infeasible or creates a greater hazard than the fall protection systems.  Listed below is the OSHA standard that explains this.

    • 1926.501(b)(2)(i) Each employee who is constructing a leading edge 6 feet (1.8 m) or more above lower levels shall be protected from falling by guardrail systems, safety net systems, or personal fall arrest systems. Exception: When the employer can demonstrate that it is infeasible or creates a greater hazard to use these systems, the employer shall develop and implement a fall protection plan which meets the requirements of paragraph (k) of 1926.502.

    Note: There is a presumption that it is feasible and will not create a greater hazard to implement at least one of the above-listed fall protection systems. Accordingly, the employer has the burden of establishing that it is appropriate to implement a fall protection plan which complies with 1926.502(k) for a particular workplace situation, in lieu of implementing any of those systems.

    We recommend using temporary anchorage points!  These are simple to use and can be installed into concrete or wood.  The use of these anchorage points with either a retractable lifeline with a personal fall arrest harness or a horizontal life line and personal fall arrest harness will ensure you’re in compliance with OSHA!

    STAIR RAILINGS

    Q:  Does OSHA require stair railings to be installed when the stairs have 4 risers or 4 steps?

    A:  OSHA requires stairs with 4 or more risers to be equipped with a stair railing or handrail.

    LANYARD SPECIFICATIONS

    Q:  What is the fully open length of a 6' lanyard after its activated?  We are quoting a job with 10'6" floor to floor, they are saying we cannot tie to the beams, because the lanyard + activation added length + the body length is more than 10'6".  Do they make a 4' or 5' lanyard ?

    A:  You usually add on an additional 3 feet to the length of a lanyard when it is activated.  OSHA and the fall protection manufacturers take 4 different lengths into consideration when they determine the safe fall distance:  the height of the wearer, the length of the lanyard, the 3 feet activation length, and a safety factor of 3 ½ feet. A 6’ tall person wearing a 6’ lanyard would need to be able to attach the lanyard at least 18 ½’ above the lower level.

    MECHANICAL EQUIPMENT ON A LOW SLOPED ROOF

    Q:  Are there restrictions or requirements regarding the use of gas powered 4 wheel carts on a roof?  The carts would be driven.  The brakes are normally cable drum brakes.  The specific job we are referring to would have 2’ high parapet walls.  Please advise to the perimeter safety requirements.

    A:  Since the parapet wall is only 24” high OSHA wouldn’t consider this adequate fall protection.  In order for the parapet wall to meet OSHA’s guardrail requirement of 42” (plus or minus 3”) it would need to be 39-45” high.  If you extend the height of the parapet wall to meet OSHA’s guardrail requirements, you can operate the cart freely on the roof.  That’s assuming the parapet wall fully encompasses the roof and your employees wouldn’t be exposed to an area where the guardrail height wouldn’t be below 39”.

    If it’s not feasible to extend the height of the parapet wall, you are allowed to use the cart without fall protection if you are using a warning line and the following provisions are met:
    ·         1926.502(f)(1)(ii): When mechanical equipment is being used, the warning line shall be erected not less than 6 feet (1.8 m) from the roof edge which is parallel to the direction of mechanical equipment operation, and not less than 10 feet (3.1 m) from the roof edge which is perpendicular to the direction of mechanical equipment operation.
    ·         1926.502(f)(4): Mechanical equipment on roofs shall be used or stored only in areas where employees are protected by a warning line system, guardrail system, or personal fall arrest system.
    ·         1926.502(h)(2): Mechanical equipment shall not be used or stored in areas where safety monitoring systems are being used to monitor employees engaged in roofing operations on low sloped roofs.

    See the OSHA standard interpretation that explains the use mechanical equipment.
    If your company would like experienced OSH consultants answering your safety questions, please contact us today for more information.

    MOBILE LADDER PLATFORM

    Q:  Does a mobile ladder platform need to have fall protection?

    A:  Yes, OSHA considers these types of ladders working surfaces and they need to have fall protection if they are 4’ or taller.

    FALL PROTECTION

    Q: When using a fall arrest harness what are the load requirements dealing with the anchorage point?

    A: The anchorage point must have a safety factor of at least two, i.e., capable of supporting at least twice the weight expected to be imposed upon or able to withstand 5,000 pounds.

    FALL PROTECTION

    Q: When working on a low-slope roof that is less than 50 feet wide is a safety monitoring system alone permitted without any other means of fall protection or warning line system?

    A: Technically under OSHA’s regulations and interpretations it could be.  However, you need to ensure that your safety monitor is not preforming any other job tasks or even talking on the cell phone.  It is also important that there is no other means of fall protection that can be used.  If it is possible use a guardrail system, safety net, or personal fall arrest system.  Please see OSHA’s regulation and interpretation for more information.

    1926.501(b)(10)"Roofing work on Low-slope roofs." Except as otherwise provided in paragraph (b) of this section, each employee engaged in roofing activities on low-slope roofs, with unprotected sides and edges 6 feet (1.8 m) or more above lower levels shall be protected from falling by guardrail systems, safety net systems, personal fall arrest systems, or a combination of warning line system and guardrail system, warning line system and safety net system, or warning line system and personal fall arrest system, or warning line system and safety monitoring system. Or, on roofs 50-feet (15.25 m) or less in width (see Appendix A to subpart M of this part), the use of a safety monitoring system alone [i.e. without the warning line system] is permitted.

    HORIZONTAL LIFE LINE
    Q: Is it acceptable to fasten two D-Rings into the roof or structure, and string aircraft cable between them in order to create a mobile retractable tie off point?
    A: Horizontal lifelines shall be designed, installed, and used under the supervision of a qualified person, maintaining a safety factor of at least two. Also, Dee-Rings must have a minimum tensile strength of 5,000 pounds.  The lifeline should also be able to support 5,000 pounds of force for each employee attached.
    FALL ARREST HARNESS

    Q: When do fall arrest harnesses need to be replaced?

    A: 29 CFR 1910.66 App C(e) (v) (7) Personal fall arrest systems or components subjected to impact loading shall be immediately removed from service and shall not be used again for employee protection unless inspected and determined by a competent person to be undamaged and suitable for reuse.

    ANSI A10.32-2004 states the service life of fall protection equipment manufactured of synthetic fiber shall be 5 years unless otherwise specified by the manufacturer.

    GUARDS FOR SKYLIGHTS

    Q:  Do skylights need to be covered or guarded on the roof if the workers are tied off to a fall arrest harness?

    A:  No, as long as the workers are properly tied off the skylights do not need to be covered.

    PORTABLE LADDERS

    Q: When employees are climbing ladders to do job tasks such as changing a light bulb do they need to be tied off?

    A: No, fall protection is not required for employees climbing or working on portable ladders.

    SCISSOR LIFTS TIED OFF

    Q: Are employees required to be tied-off when working on a guardrail-equipped scissor lifts?

    A: No, OSHA does not require employees to be tied-off when working from scissor lifts that have properly maintained guardrails.

    FALL PROTECTION AT LOADING DOCKS

    Q:  We would like to know if you have the OSHA requirements necessary for our loading dock area for a rail or barrier. We are in the midst of having our chains replaced with a more secure barrier. Our loading dock is about 5’ off the ground. Any information would be great.

    A:  You’ll want to make sure the new barriers that you install meet the following criteria:

    • Top rail at 42 inches in height and capable of withstanding 200 lbs of outward and downward force.
    • Midrail at 21 inches in height.

    I’ve seen some facilities use 2x4 boards for these barriers.  They install brackets on the inside of the door that hold the boards.  They are then able to lift the boards out of brackets with ease in order to use the dock.  This seems to be a sturdy solution for a removable barrier at the dock.  This is just a suggestion as I’m not sure if this would work for your application.

    SCISSOR LIFTS

    Q: Do you need to wear a fall arrest harness when working in a scissor lift that that has a guardrail system around it?

    A: No, you do not need to wear a fall arrest harness when working in a scissor lift if it has a proper guardrail system around it.  However, if the guardrail system is less than adequate, or the worker leaves the safety of the work platform, an additional fall protection device would be required.

    WALKING WORKING SURFACES

    Q:  We have built a few small “platforms” to stand on to do some of our work.  When I say platform, I mean a small single step.  These “platforms” range from about 7-9 inches tall with a rectangular flat service of 18X18 inches on the small end, and 30X36 inches on the larger end. Is there an OSHA requirement that a surface area must be so large for a certain height?

    A:  Yes, OSHA does have requirements for steps.  The platforms you are talking about will be covered by those requirements for steps.  The regulations that will want to follow for the structure and surface area are as follows:

    • 1910.24(c) "Stair strength." Fixed stairways shall be designed and constructed to carry a load of five times the normal live load anticipated but never of less strength than to carry safely a moving concentrated load of 1,000 pounds.
    • 1910.24(d) "Stair width." Fixed stairways shall have a minimum width of 22 inches.

    Regarding your question about the need for handrails, the only need for a handrail is if the platform is 4 feet or more above an adjacent floor or ground.  In your case the two steps that total 16 inches would not need a handrail:  click here to refer to 1910.23(c)(1) - 1910.23(c)(1)(iii).

    FALL PROTECTION FOR WALKWAY

    Q: What would the aisle width requirements be for a walkway that is 10 feet off the ground?

    A:  1910.22(b) "Aisles and passageways."

    1910.22(b)(1) Where mechanical handling equipment is used, sufficient safe clearances shall be allowed for aisles, at loading docks, through doorways and wherever turns or passage must be made. Aisles and passageways shall be kept clear and in good repairs, with no obstruction across or in aisles that could create a hazard.

    1910.23(c) "Protection of open-sided floors, platforms, and runways."

    1910.23(c)(1) Every open-sided floor or platform 4 feet or more above adjacent floor or ground level shall be guarded by a standard railing (or the equivalent as specified in paragraph (e)(3) of this section) on all open sides except where there is entrance to a ramp, stairway, or fixed ladder. The railing shall be provided with a toeboard wherever, beneath the open sides,

    1910.23(c)(1)(i) Persons can pass,

    1910.23(c)(1)(ii) There is moving machinery, or

    1910.23(c)(1)(iii) There is equipment with which falling materials could create a hazard.

    1910.23(c)(2) Every runway shall be guarded by a standard railing (or the equivalent as specified in paragraph (e)(3) of this section) on all open sides 4 feet or more above floor or ground level. Wherever tools, machine parts, or materials are likely to be used on the runway, a toeboard shall also be provided on each exposed side.

    If the walkway is part of an exit, it would have to meet these requirements:

    1910.36(g)(2) An exit access must be at least 28 inches (71.1 cm) wide at all points. Where there is only one exit access leading to an exit or exit discharge, the width of the exit and exit discharge must be at least equal to the width of the exit access.

    FALL PROTECTION

    Q: How long can a person be suspended in a fall arrest harness?
    A: The following is the regulation dealing with the rescue time for someone who has fallen and is being suspended by a fall arrest harness:

    1926.502(d)(20) The employer shall provide for prompt rescue of employees in the event of a fall or shall assure that employees are able to rescue themselves.

    The word “prompt” requires rescue be performed quickly, in time to prevent serious injury to the worker. OSHA does not have a set time in which an employee would need rescued, but recent studies indicate that a person may become unconscious within 5 minutes.

    FALL PROTECTION - ROOF CART

    Q: In construction, is it acceptable to tie off to roof carts that weigh about 500 lbs.?

    A: No. The anchor point should not be mobile and should follow the guidelines of 29 CFR 1926 Subpart M:

    1926.502(d)(15) - Anchorages used for attachment of personal fall arrest equipment shall be independent of any anchorage being used to support or suspend platforms and capable of supporting at least 5,000 pounds (22.2 kN) per employee attached, or shall be designed, installed, and used as follows:

    1926.502(d)(15)(i) - as part of a complete personal fall arrest system which maintains a safety factor of at least two; and

    1926.502(d)(15)(ii) - under the supervision of a qualified person.

    REQUIREMENTS FOR HOLE COVERS

    Q: During construction, when covering openings in a roof such as skylights and fan rough-ins, how strong does the material have to be?

    A: 1926.502(i)(2) All other covers shall be capable of supporting, without failure, at least twice the weight of employees, equipment, and materials that may be imposed on the cover at any one time.

    FALL PROTECTION ON PORTABLE LADDER
    Q.  Do you have to have fall protection on while working from a portable ladder?
    CAGED LADDER?
    1. I have a ladder 103" platform to platform. Does OSHA require this ladder to be caged?  What is the required distance between the platform and the bottom of a ladder cage?
    2. The answer to your first question is - OSHA’s standard 29 CFR 1910.27(d)(1)(ii) states that cages or wells (except as provided in subparagraph (5) of this paragraph) conforming to the dimensions shown in figures D-7, D-8, and D-9 shall be provided on ladders of more than 20 feet to a maximum unbroken length of 30 feet.  If you click on this link it will take you to an interpretation that deals with this requirement: click here

    The answer to your second question is - 29 CFR 1910.27(d)(1)(iv) states that cages shall extend down the ladder to a point not less than 7 feet nor more than 8 feet above the base of the ladder, with bottom flared not less than 4 inches, or portion of cage opposite ladder shall be carried to the base.

    FALL PROTECTION QUESTION

    A piece of siding has been damaged and is hanging off the building. They can fix it by accessing a low roof they can walk on but they would need fall protection to work from the roof's edge to repair it. The problem is there is no anchorage/tie off point.

    Q:  Could we use another employee as a tie off point?

    A:  No.  You would need an anchorage point, a ladder, or lift.

    GUARDRAIL

    AUTHORIZED PERSONNEL

    Q: I have a silo with a wraparound fixed staircase.  The staircase has proper railings.  The question is, if I have a locking gate on the entrance to the staircase and signage posted so only authorized personnel can enter, is this compliant?

    A: OSHA does not have a specific standard on this.  This is more of a liability issue, but with the locking gate and signage it shows you are taking the proper measures to keep unauthorized people out.

    LADDERS

    LADDERS

    Q: Does it matter if you use a fiberglass ladder or an aluminum ladder when doing framing on a house when there is no electrical work being done?

    A: No, it does not matter as long as each ladder has the proper warning labels on them.

    FIXED LADDERS

    Q: If you have a fixed ladder with a cage or well around it would you also need to have a safe access hatch?

    A: This would actually fall under the 1910.23 (Guarding floor and wall openings and holes standard) instead of the 1910.27 (Fixed ladder standard).  If there is a potential that the employee can free fall 4 or more feet the fixed ladder will need a safe access hatch.

    STEP LADDERS

    Q: Do you need to use a fall protection system when climbing a step ladder that is greater than six feet high?

    A: No, you do not need to use fall protection when climbing the step ladder.  You only need to use fall protection if you are climbing a fixed ladder.

    LADDERS

    Q: We have a “V-type” free standing step ladder, can we fold it and lean it against a wall? Some extension ladders are too tall.

    A: No, because that is not how the ladder is designed, that will affect the stability of the step ladder.

    LADDER LABELS

    Q: Some of the decals on the ladders are worn off or illegible. Do we have to go back to the manufacturer of the ladder to get replacement decals or can we get them from somewhere else?

    A: Any applicable information specific to the ladder type, warnings or ratings shall be legible to the user.  The type of label would be specific to each manufacturer since products may differ.  Manufacturers may offer replacement labels.  However, due to liability concerns, it is doubtful that a ladder manufacturer will distribute ladder warning labels when they have no idea what their customer is putting them on.  This is why ladders should be kept clean, free of damage, stored properly and inspected prior to use.  Having a proper ladder inspection/safety program in place will prevent the labels from getting damaged.

    CLASS OF LADDERS

    Q: Is there a minimum class that the ladders have to be rated? Can the ladders be wooden, aluminum and/or steel?

    A: This all depends on the type of ladder, where the ladder will be used, and the type of forces exerted on the ladder.  Typically ladders have several different ratings. Consider factors such as proximity of electrical lines or systems, contaminants such as chemicals and how they will have an effect on the ladder material, weight of the average individual who will be using the ladder, the weight of the objects which may be handled while on the ladder.  Examples of a ladder classification system are as follows:

    • Type III, light duty ladder is rated for 200lbs, red in color
    • Type II, medium duty ladder is rated for 225lbs, green in color
    • Type I, heavy duty industrial ladder is rated for 250lbs, blue in color
    • Type IA, extra heavy duty industrial ladder is rated for 300lbs, orange in color
    • Type IAA, special duty ladder is rated for 375lbs, yellow in color
    FALL PROTECTION ON PORTABLE LADDER
    Q.  Do you have to have fall protection on while working from a portable ladder?
    CAGED LADDER?
    1. I have a ladder 103" platform to platform. Does OSHA require this ladder to be caged?  What is the required distance between the platform and the bottom of a ladder cage?
    2. The answer to your first question is - OSHA’s standard 29 CFR 1910.27(d)(1)(ii) states that cages or wells (except as provided in subparagraph (5) of this paragraph) conforming to the dimensions shown in figures D-7, D-8, and D-9 shall be provided on ladders of more than 20 feet to a maximum unbroken length of 30 feet.  If you click on this link it will take you to an interpretation that deals with this requirement: click here

    The answer to your second question is - 29 CFR 1910.27(d)(1)(iv) states that cages shall extend down the ladder to a point not less than 7 feet nor more than 8 feet above the base of the ladder, with bottom flared not less than 4 inches, or portion of cage opposite ladder shall be carried to the base.

    LEADING EDGE WORK

    LEADING EDGE WORK

    Q:  When installing plywood decking on a suspended concrete slab that is 13 feet high; is fall protection required?

    A: Yes fall protection is required unless you can prove that fall protection is infeasible or creates a greater hazard than the fall protection systems.  Listed below is the OSHA standard that explains this.

    • 1926.501(b)(2)(i) Each employee who is constructing a leading edge 6 feet (1.8 m) or more above lower levels shall be protected from falling by guardrail systems, safety net systems, or personal fall arrest systems. Exception: When the employer can demonstrate that it is infeasible or creates a greater hazard to use these systems, the employer shall develop and implement a fall protection plan which meets the requirements of paragraph (k) of 1926.502.

    Note: There is a presumption that it is feasible and will not create a greater hazard to implement at least one of the above-listed fall protection systems. Accordingly, the employer has the burden of establishing that it is appropriate to implement a fall protection plan which complies with 1926.502(k) for a particular workplace situation, in lieu of implementing any of those systems.

    We recommend using temporary anchorage points!  These are simple to use and can be installed into concrete or wood.  The use of these anchorage points with either a retractable lifeline with a personal fall arrest harness or a horizontal life line and personal fall arrest harness will ensure you’re in compliance with OSHA!

    ROOFING

    WORKING ON A ROOF IN HIGH WINDS

    Q:  Does OSHA have a defined wind speed where roof work should be stopped.

    A:  Unfortunately, OSHA does not have a defined wind speed.  OSHA only mentions “high winds” in the regulations.  The responsibility to remove workers from the roof is given to the employer.  Ultimately it comes down to the supervisor on the job to stop the work once it is determined the wind is creating a dangerous situation for the workers.

    SCAFFOLDING

    SCAFFOLD ACCESS

    Q: If you lower a Perry scaffolding to the lowest point, which is 26 inches off the ground, do you need an access ladder?

    A: OSHA’s scaffolding requirement is anything over 2 feet or 24 inches you need a means of safe access. This does not mean it has to be a ladder an approved stool would be sufficient.

    SCISSOR LIFT

    SCISSOR LIFT TRAINING
    Q:  Does OSHA have specific training requirements for scissor lifts?
    A:  Since scissor lifts are covered under OSHA’s scaffolding trainings there are no specific training requirements.  However, under the general duty clause it would be the employer’s responsibility to ensure all operators are competent and authorized to operate the lift.
  • 5. First Aid & CPR
     

    BANDAGES

    FIRST AID KIT LOCATION

    Q: We currently are keeping our first aid (Bandages, etc ) along with over the counter medicines in a cabinet in the foreman’s office.  If an employee gets a minor cut, they can obtain a bandage from the foreman. Is this permissible, or do we need to move these supplies out into the open?

    A: OSHA does not define “readily available” in the standard. The person who has been trained to render first aid must be able to quickly access the first aid supplies in order to effectively provide injured or ill employees with first aid attention. The first aid supplies should be located in an easily accessible area, and the first aid provider generally should not have to travel through several doorways, hallways, and/or stairways to access first aid supplies.

    If the foremen are always nearby to provide the supplies, this would be an appropriate method. However, if those deemed capable of providing first aid must travel through the facility to locate a foreman, this would hinder response time defeating the concept of “readily accessible”, and therefore could be considered a violation of the OSHA standard.

    CPR

    DOES OSHA REQUIRE FIRST AID/CPR

    Q: Does OSHA have any requirements on having employees First Aid/CPR trained or is it just a good practice to have certified employees in the field?

    A: According to 1910.151(b), if your jobsites are located within 4 minutes of a first responder you are not required to train your employees in First aid/CPR. However, in the absence of an infirmary, clinic, or hospital within 4 minutes of the workplace, OSHA requires that you do have a person adequately trained to render first aid.  In further explanation, OSHA’s 4 minute response time is based off of the time the call is made to 911 and the responders actually showing up.

    FIRST AID KIT REQUIREMENTS

    Q: What are the requirements for a first aid kit, and are there any specific items needed specially for our trucking department?

    A: ANSI Z308.1-1998 – Minimum requirements for workplace first aid kits
    Basic kit – minimum contents:

    • 1 Absorbent compress, 32 sq. in. (81.3 sq. cm.) with no side smaller than 4 in. (10 cm)
    • 16 Adhesive bandages, 1 in. x 3 in. (2.5 cm x 7.5 cm)
    • 1 Adhesive tape, 5 yd. (457.2 cm)
    • 10 Antiseptic, 0.5g (0.14 fl oz.) applications
    • 6 Burn treatment, 0.5 g (0.14 fl. oz.) applications
    • 2 Medical exam gloves pair
    • 4 Sterile pads, 3 in. x 3 in. (7.5 x 7.5 cm)
    • 1 Triangular bandage, 40 in. x 40 in. x 56 in. (101 cmx 101 cm x 142 cm)

    For DOT, on top of the standardized first aid kits, employers must have a fire extinguisher, spare electrical fuses (unless equipped with circuit breakers), and warning devices for parked vehicles. Your cargo should not make it hard to access the emergency equipment.

    REQUIREMENTS IN A FIRST AID CABINET

    Q: Are there specific requirements we need to have in our first aid cabinet?
    A: OSHA does not have mandatory requirements but they do refer to ANSI standards:

    ANSI Z308.1-1998 – Minimum requirements for workplace first aid kits

    Basic kit – minimum contents:

    • 1 Absorbent compress, 32 sq. in. (81.3 sq. cm.) with no side smaller than 4 in. (10 cm)
    • 16 Adhesive bandages, 1 in. x 3 in. (2.5 cm x 7.5 cm)
    • 1 Adhesive tape, 5 yd. (457.2 cm)
    • 10 Antiseptic, 0.5g (0.14 fl oz.) applications
    • 6 Burn treatment, 0.5 g (0.14 fl. oz.) applications
    • 2 Medical exam gloves pair
    • 4 Sterile pads, 3 in. x 3 in. (7.5 x 7.5 cm)
    • 1 Triangular bandage, 40 in. x 40 in. x 56 in. (101 cmx 101 cm x 142 cm)

    Remember that accidents are NEVER planned. Look into getting your staff trained today!

    EYE WASH STATION

    HEIGHT FOR EYEWASH STATION

    Q. Is there a height that the eyewash station needs to be?

    A. There is no OSHA standard that gives a height but it does need to be readily accessible. They would be able to cite through the general duty clause based off ANSI Z358.1. The ANSI standard states the Eyewash station should be between 33 inches and 53 inches.

    EYE WASH TEMPERATURES

    Q: Is there an OSHA rule about eye wash stations - and whether it MUST be a cold water station or whether the water can be tempered?

    A: OSHA has a rule about eye wash stations that states the need for eye washes in areas where hazards are present but it does not state specific requirement as to the water temperature. OSHA relies on the ANSI Standard Z358.1 for specifics requirements pertaining to eye washes. ANSI specifies that the water must be tempered between 60 and 100 degrees F. In the event of an OSHA inspection, they would refer to the ANSI standard if necessary.

    EYEWASH

    OSHA REQUIREMENTS FOR EYEWASH STATIONS

    Q: What are the OSHA requirements for eyewash stations?

    A: OSHA requires the following:  1910.151(c). Where the eyes or body of any person may be exposed to injurious corrosive materials, suitable facilities for quick drenching or flushing of the eyes and body shall be provided within the work area for immediate emergency use.

    ANSI is the organization that has a standard regarding eyewash stations. ANSI requires the following: the emergency equipment should be installed within 10 seconds walking time from the location of a hazard (approximately 55 feet). The equipment must be installed on the same level as the hazard (i.e. accessing the equipment should not require going up or down stairs or ramps). The path of travel from the hazard to the equipment should be free of obstructions and as straight as possible.

    EYEWASH DISTANCES

    Q: We don’t handle any corrosive chemicals and only have an eyewash station as an emergency precaution when grinding and other tool use. What is the required distance?

    A: OSHA only requires the eyewash station to be immediately adjacent when working with corrosive chemicals. In any other case it is recommended to have the eyewash station as close as possible.

    EYE WASH STATION

    Q: Can a portable eye wash station have the solution off to the side to preserve shelf life?

    A: It is recommended that in any portable eye wash station that must be filled manually with solution to have it filled with the solution. This is so that if an employee does have something in the eyes they don’t have to first fill the station before using it.

    BATTERY CHARGING PPE

    Q: We have forklifts and power floor sweepers that operate off of batteries.  We have an eyewash station in the charging/changing area, but what types of PPE should we require?
    A: Goggles, face shields, aprons, and rubber gloves need to be worn while handling the batteries.  Refer to the MSDS of the battery acid to determine the type of rubber gloves/aprons that need to be worn.

    EYE WASH REQUIREMENTS

    Q:  What is the recommended eye wash solution and amount?  I read somewhere that for eye wash bottles in the field there should be 30 seconds worth of eye wash.

    A:  OSHA doesn’t have specific guidelines or requirements when it comes to emergency eyewash, however, 29 CFR 1910.151(c), specifies that "where the eyes or body of any person may be exposed to injurious corrosive materials, suitable facilities for quick drenching or flushing of the eyes and body shall be provided within the work area for immediate emergency use."  OSHA may reference the ANSI Z358.1-2009 eyewash standard which outlines equipment location/access which is an unobstructed 10 seconds travel, a suitable water temperature which is 60-100 degrees Fahrenheit and the fact that the eyewash device must provide a minimum flow of .4 GPM at 30psi for a 15 minute period.  Portable eyewash bottles are considered supplemental equipment only.

    REQUIREMENTS FOR EYE WASH AND EMERGENCY SHOWER SIGNAGE
    Q. What color do our eye wash and emergency shower signs have to be?
    A. OSHA does not require a specific color or set up of an eye wash station. Most signs available are green with white lettering.

    FIRST AID

    RESTRICTED ACCESS TO FIRST AID KIT

    Q: Would we be violating any OSHA standard by having the first aid supplies in the foreman’s office where the employee has to ask the foreman to get them the first aid supplies?

    A: The person who has been trained to render first aid must be able to quickly access the first aid supplies in order to effectively provide injured or ill employees with first aid attention. The first aid supplies should be located in an easily accessible area, and the first aid provider generally should not have to travel through several doorways, hallways, and/or stairways to access first aid supplies.

    If the foremen are always nearby to provide the supplies, this would be an appropriate method. However, if those deemed capable of providing first aid must travel through the facility to locate a foreman, this would hinder response time defeating the concept of “readily accessible”, and therefore could be considered a violation of the OSHA standard.

    IS GETTING STITCHES A RECORDABLE INJURY?

    Q: An employee cut their thumb on Monday and reported it to a supervisor. The cut didn't look to severe so it was wrapped with a bandage. On Tuesday, the employees went to Med Express and they put in 10 stitches. Is this recordable incident?

    A: Yes, because the cut required stitches, which are considered medical treatment beyond first aid measures, then it would be considered a recordable incident. Refer to 1904.7(b)(5)(ii) for more information on what OSHA outlines as 'first aid' treatment.

    FIRST AID KIT STOCKING

    Q: We are stocking 10 packets of antiseptic and also a 2 fl.oz. bottle of antiseptic in our first aid kit.  We are also stocking 6 applications of burn treatment and also a 2 fl.oz. bottle of burn treatment. Can you tell me if it is necessary to stock the bottle and the wipes for both items?

    A: The ANSI standard requires both items in fluid ounces, which would require them to be kept in bottles:

    Antiseptic, 0.5g (0.14 fl oz.) applications                                                                 10

    Burn treatment, 0.5 g (0.14 fl. oz.) applications                                                        6

    The wipes would just be additional supplies you could provide for your employees to us.

    FIRST AID/ CPR

    OSHA 1910 FIRST AID STANDARD

    Q:  What is the definition of “near proximity” used in the OSHA first aid standard 1910.151(b)?

    A: The term "near proximity" that is contained in the first aid standard, means the facility or jobsite must be 4 minutes away from a first responder or medical facility to treat the injured employee. If the facility or jobsite isn’t within a 3-4 minute time frame of a first responder, or drive time, than you are required to have an employee on-site that is capable of performing first aid duties (must be certified).

    If you need to have your employees trained in first aid/CPR/AED, please contact LSCI by clicking this link.

    ONLINE FIRST AID/CPR TRAINING

    Q:  Is online First Aid and CPR training accepted by OSHA?

    A:  Generally, online CPR and/or First Aid training is not recommended. However, as long as the students are able to demonstrate that they understand the training and know how to properly perform CPR and First Aid, it should be considered acceptable.

    FIRST AID KITS

    Q:  Does a first aid kit need to be OSHA approved?

    A:  OSHA doesn’t approve or disapprove of any products out there.  When a company uses the marketing “OSHA Approved”, it usually means that their product meets OSHA’s standards.  When it comes to first aid kits, OSHA refers to ANSI’s regulations on the minimal contents that the kits must contain.

    FIRST AID KIT

    Q:  What are your recommendations on the size of  kit, contents required, and maintenance of the first aid kits on monthly or quarterly basis?

    A:  OSHA’s regulation states that in the absence of an infirmary, clinic, or hospital near the workplace, a person or persons must be adequately trained to render first aid.  Adequate first aid supplies must be readily available.  Appendix A to 1910.151 (first aid requirement) is a non-mandatory guide for the contents of first aid kits.   OSHA uses ANSI’s Minimal Requirements for Workplace First Aid Kits as an example of the minimum contents for a generic kit.

    OSHA does specify that this is only the minimal requirement, and employers who have unique or changing first-aid needs in their workplace may need to enhance their first aid kits.  Also, if it is reasonably anticipated that employees will be exposed to blood or other potentially infectious materials while using first aid supplies, employers are required to provide appropriate PPE.  Purchasing a bloodborne pathogens kit or emergency first responder kit to go along with your first aid kit is also recommended.

     

  • 6. Forklifts
     
    SERVICING OUR OWN FORKLIFT

    Q: Can we service our own forklifts?

    A: OSHA requires any power-operated industrial truck that is in need of repairs to be done by an authorized person that is trained to do so. If you have employees in house who meet that requirement, then you should be fine to do your own repairs. You will want to make sure you are conducting pre-use inspections of all power industrial trucks and documenting any issues and taking the forklift out of service until the issue has been repaired.

    REMOVING KEYS FROM FORKLIFT

    Q: Do we need to remove the keys from forklifts when not in use to prevent unauthorized use?

    A: It is not an OSHA requirement to remove the keys; it is a recommendation. If you do have good policies in place where non-trained or non-certified personnel cannot operate the forklifts, it shouldn’t be an issue. If your operators do want to keep the key in the forklift so it is easier for them to use, make your disciplinary policy stricter for unauthorized personnel to deter them from attempting to operate the equipment. However, we do know how the human factor does come in to play and there still could be instances where unauthorized individuals feel the urge to operate the forklifts, so you might have to go the route of removing the key when not in use. Hopefully a stricter disciplinary policy will do the trick.

    HOW OFTEN DO POWER INDUSTRIAL TRUCK OPERATIONS NEED TO BE RETRAINED?

    Q: How often do our power industrial truck operators need to be re-evaluated? Also, is there a different between a lift truck certification and tow motor?

    A: For your question regarding Power Industrial Truck training, an evaluation of the operator’s performance is required to be conducted at least once every three years.  The training is to consist of a combination of formal instruction (e.g., lecture, discussion, interactive computer learning, video tape, written material), practical training (demonstrations performed by the trainer and practical exercises performed by the trainee), and evaluation of the operator's performance in the workplace.

    However, refresher training must be provided to the operator when the following occurs:
    • The operator has been observed to operate the vehicle in an unsafe manner;
    • The operator has been involved in an accident or near-miss incident;
    • The operator has received an evaluation that reveals that the operator is not operating the truck safely;
    • The operator is assigned to drive a different type of truck; or
    • A condition in the workplace changes in a manner that could affect safe operation of the truck.
    The term “power industrial truck” is a mobile, power, propelled truck used to carry, push, pull lift, stack or tier material. Vehicles that are used for earth moving and over-the-road hauling are excluded. Each of the different types of powered industrial trucks has its own unique characteristics and some inherent hazards. To be most effective, training must address the unique characteristics of the type of vehicle(s) the employee is being trained to operate.

    WHEN TO PERFORM FORKLIFT TESTING

    Q. We have several employees that are in need of re-certification for forklift operation.  Can you tell me if they have to go through the complete training or if there is a refresher course we can offer. We do all training in house so I am wondering if the trainer can do a simple walk through instead of the entire training.

    A. Employees who are up for re-certification do not need to go through the exact training that they went over initially. The training can include a hands on proficiency test and a written test that can evaluate the effectiveness of the training.

    1910.178(l)(4)(iii) An evaluation of each powered industrial truck operator's performance shall be conducted at least once every three years.

    SPEED LIMIT ON FORKLIFTS

    Q: What is the speed limit OSHA requires when operating forklifts?

    A: OSHA require for forklifts to travel at a speed that will permit it to be brought to a stop in a safe manner. All traffic regulations shall be observed, including authorized plant limits. A safe distance shall be maintained approximately three truck lengths from the truck ahead.

    FORKLIFT TRAINING REQUIREMENTS

    Q: What are the requirements of forklift training?

    A: Training shall consist of a combination of formal instruction (e.g., lecture, discussion, interactive computer learning, video tape, written material), practical training (demonstrations performed by the trainer and practical exercises performed by the trainee), and evaluation of the operator's performance in the workplace.

    All operator training and evaluation shall be conducted by persons who have the knowledge, training, and experience to train powered industrial truck operators and evaluate their competence.

    FORKLIFT

    Q:  Are both a showering facility and eye wash station needed for charging forklift batteries?

    A: A showering facility is not needed as long as you have an eye wash station.  Here is OSHA’s regulation explaining this.
    • 1910.178(g)(2) Facilities shall be provided for flushing and neutralizing spilled electrolyte, for fire protection, for protecting charging apparatus from damage by trucks, and for adequate ventilation for dispersal of fumes from gassing batteries.

    However, OSHA also states if you are exposed to corrosive materials you would need a facilities for quick drenching of the eyes and body.
    • 1910.151(c) Where the eyes or body of any person may be exposed to injurious corrosive materials, suitable facilities for quick drenching or flushing of the eyes and body shall be provided within the work area for immediate emergency use.

    Depending on where you are accessing the charging port you can see it may go either way!

    FORKLIFT LOAD BACKRESTS

    Q: We typically use our forklifts for moving boxes of parts. The level of the parts in the box do not pass the top edge. Is it okay to remove the backrest to facilitate use of the top shelf of our racks? The backrest is in interference with duct piping and the ceiling when in place.

    A: Yes, the load backrest is considered a removable device on the forklift and therefore wouldn’t be considered a modification (modifications to the equipment need to be approved by the manufacturer). It is only required to be used if the load you are moving presents a hazard and has the potential for falling rearward. You can remove it for instances such as this as long as the box or object that you’re moving is properly loaded and doesn’t create a greater hazard during transition [See 1910.178 (e)(2) and (m)(10)].

    PHYSICAL EVALUATIONS FOR FORKLIFT OPERATORS

    Q: Do forklift operators need to have an annual physical evaluation that includes hearing and vision?

    A: OSHA doesn't have provisions for checking vision, hearing, or general medical status of employees operating powered industrial trucks. (See Question #18 on OSHA’s Frequently Asked Questions about Powered Industrial Truck Operator Training page.)  29 CFR 1910.178(l) requires you to “ensure that each powered industrial truck operator is competent to operate a powered industrial truck safely, as demonstrated by the successful completion of the training and evaluation specified in this paragraph.”  Here is also letter of interpretation regarding the topic.

    FORKLIFT TRAINER

    Q: How long is my fork lift trainer card good for?

    A: The forklift trainer card doesn't expire as long as your company feels the trainer is still competent in performing the task training.

    FORKLIFT MAN BASKET

    Q:  Can we attach a man basket to the forklift? Also, can it be moved while an employee is in it?

    A:  OSHA permits the use of personnel platforms on forklifts as long as the manufacture approves it.  You would need to contact the manufacturer of the forklift to see if they permit it’s use.  The manufacturer would also be able to provide you with the new forklift specifications (center of gravity, weight limit, etc.) when using the platform.  Riding on a forklift is not permitted due to the tipping hazard so the employee would need to exit the platform before it is moved.

    FORKLIFT LICENSE

    Q: Does an employee need a valid drivers license to operate a forklift?

    A:  The employee is required to be trained and certified to operate the forklift in the workplace.  Training and certification shall be documented.  An operators performance shall be evaluated every 3 years.

    AGE OF FORKLIFT DRIVER

    Q: How old do you have to be to operate a forklift?

    A: The operator must be 18 years of age or older.

    The forklift operator must also be trained and certified. If you need forklift training please contact us at 888.403.6026.

    FORKLIFT TRAIN THE TRAINER

    Q:  Does the forklift trainer need to be recertified to train the operators?
    A:  No, OSHA does not have any requirements for recertifying the forklift trainer.  However, if the trainer also operates any forklifts then the trainer would need to be recertified to do so every 3 years.

    ATTACHING MAN BASKET TO FORKLIFT

    Q: Can you attach a man basket on a forklift that is manufactured by a different company?

    A: You must have the manufactures approval when using any attachment on the forklift.  It will vary forklift to forklift, so you will need to contact the forklift manufacture for an answer.

    FORKLIFTS

    Q: Do the fork extensions have to reach to the other side of the load?

    A: OSHA states in “1910.178(o)(5) A load engaging means shall be placed under the load AS FAR AS POSSIBLE; the mast shall be carefully tilted backward to stabilize the load.”

    Also keep in mind that you do not exceed the forklifts manufactures load capacity.

    FORKLIFT CERTIFICATION

    Q: How long are forklift 'train the trainer' certifications good for?

    A: Indefinitely as long as the employee has training, authorization from the company, and demonstrates competency as a trainer.

    FORKLIFT SEAT BELTS

    Q: If a forklift was not originally manufactured with a seat belt, does the employer have to install a seat belt?

    A: OHSA's enforcement policy relative to the use of seat belts on powered industrial trucks is that employers are obligated to require operators of powered industrial trucks which are equipped with operator restraint devices or seat belts to use the devices. OSHA may also issue citations if the employer has not taken advantage of a manufacturer operator restraint system or seat belt retrofit program.

    FORKLIFT

    Q: Can a forklift engine be left running if the driver steps off the vehicle for a few moments?

    A: Yes, but only if the following conditions apply:

    1910.178(m)(5)(i) When a powered industrial truck is left unattended, load engaging means shall be fully lowered, controls shall be neutralized, power shall be shut off, and brakes set. Wheels shall be blocked if the truck is parked on an incline.

    1910.178(m)(5)(ii) A powered industrial truck is unattended when the operator is 25 ft. or more away from the vehicle which remains in his view, or whenever the operator leaves the vehicle and it is not in his view.

    1910.178(m)(5)(iii) When the operator of an industrial truck is dismounted and within 25 ft. of the truck still in his view, the load engaging means shall be fully lowered, controls neutralized, and the brakes set to prevent movement.

    FORKLIFT AISLES

    Q: How wide do the aisles for the forklift traffic have to be?

    A: The aisle must be at least 3 feet wider than your widest piece of equipment.

    COVERING FORKLIFT

    Q: What is the OSHA regulation for covering the top of a forklift to stay dry when it rains?  Is there an OSHA approved add-on for this purpose?

    A: In OSHA’s Forklift Regulation there is nothing that is specific about adding modifications to the forklift to protect the employee from rain.  What the regulation does state is that prior to adding any modification you need the manufacturer’s written approval, but this is only if these modifications are going to affect the capacity and safe operation of the forklift.  See the regulation below.  I would recommend calling the company that manufactures your forklift and ask them if they have any additions that add rain protection and to check with them to ensure it will not affect the load capacity.

    • 29 CFR 1910.178(a)(4) Modifications and additions which affect capacity and safe operation shall not be performed by the customer or user without manufacturers prior written approval. Capacity, operation, and maintenance instruction plates, tags, or decals shall be changed accordingly.
    FALL PROTECTION

    Q:  What is required by OSHA for man lifts as far as fall protection?

    A:  If you’re using scissor lifts a personal fall arrest harness is not needed if all four sides of the lift are protected by guardrails since they fall under OSHA’s scaffolding regulation.  If you’re using an extendable boom aerial lift then personal fall protection is required.  It’s OSHA’s policy that an employer will be in compliance with OSHA’s fall protection requirements for aerial lifts if one of these three means of fall protection are used:

    • Use of a body belt with a tether anchored to the boom or basket (fall restraint system),
    • Use of a body harness with a tether (fall restraint system), or
    • Use of a body harness with a lanyard (fall arrest system).

    If using a fall arrest system you need to be aware of the distance it takes to actually arrest the employees fall.  For example, if a 6’ person is using a 6’ lanyard the distance that would be needed to arrest the fall safely without hitting the ground would be around 18 feet.  This length is taking into consideration the distance that the lanyard could stretch and a 3’ safety factor that OSHA requires to be added into the total distance.

    USE OF HEADPHONES

    Q:  Does OSHA prohibit the use of headphones while operating the forklift?

    A:  OSHA does not address this specifically but the employee would need to be able to hear the back up alarms, horns, or other emergency alarm systems.

    FORKLIFT GUARDRAILS

    Q: Are there any requirements on how strong guardrails need to be when there is forklift traffic near the area?

    A:  The only requirement for the strength of a guardrail is 200 pounds.  There is no regulation for guardrail strength for forklift traffic because it would have to be “extremely heavy duty.”  However, 29 CFR 1910.178(m)(6) states : “A safe distance shall be maintained from the edge of ramps or platforms while on any elevated dock, or platform or freight car.”  The best thing to do is effectively communicate and enforce safe driving practices while on the dock and ramp.  He mentioned that some companies have installed rumble strips near edges to warn drivers that they are getting close.

    FORKLIFT MOUNTED MAN BASKET

    Q: Is there an actual OSHA requirement relating to a forklift mounted man basket?  If not, what other “rules” apply to this type of equipment?

    A: There is not an actual general industry standard concerning mounted man baskets on forklifts.  However companies must abide by The American National Standards Institute (ANSI).  ANSI’s standard regarding mounted man baskets on forklifts is B56.6.  In this standard it covers the design, training, and machine requirements.  Listed below are a few examples as to what it covers.

    • Requires both the forklift operator and the employee in the man basket to be properly trained on the use of the work platform.
    • Requires the employees to be trained on the use of seat belts, lanyards, and the use of hard hats.
    • Requires the forklift operator to have training on inspecting the man basket, attaching the man basket, as well as how to properly operate the man basket when employees are inside.
    • Requires that both sides of the man basket lock into place on the forklift so the basket will not slide.
    • The use of the man basket is to be the last option.
    • Requires safety belt attachment points.
    • Ladders are not allowed inside of the man basket to reach high.
    • A first aid kit and fire extinguisher must be inside the man basket.
    • The forklift operator can only move the platform up and down when employees are inside of the basket.
    • The basket is required to have the following – two boards, handrails, a gate locked in place, and a load capacity.

     

  • 7. Oil & Gas
     

    DRILLING

    GERONIMO LINE ON A DRILLING RIG

    Q: Where is the proper location to place a Geronimo Line on a drilling rig?

    A: The location varies rig to rig where the line must be located. But there are a few helpful guidelines for the proper set up of a Geronimo line that come from the American Petroleum Institute (API) RP-54 Standard:

    The escape line should be kept clear of obstructions.

    • The escape line needs to be a wire rope of a minimum diameter of 7/16” in good condition.
    • Tension on the line should be periodically checked and adjusted to enhance safe landing of the user.
    • Tension should be set up with 6 to 12 feet of sag in the middle, depending upon the length of the cable.
    • It is recommended that the ground anchor point of the escape line should be located a minimum lateral distance from the derrick or mast equal to two times the height of the work platform.

    OIL & GAS

     ENTRANCE SIGN REQUIREMENTS FOR LEASE ROAD

    Q: What are the exact requirements regarding the entrance sign to the lease road?

    A: According to The Division of Oil and Gas Resources Management, safety must be maintained from the time of the initial entranceway is built until the well is abandoned at the end of its life. In urban areas, a copy of the Ohio Drilling Permit and Special Permit Conditions are part of the posted safety signage, and appropriate signage should be placed at the beginning of each lease road. The identification shall be on a metal or wooden sign with the sign maintained to remain legible at all times.

    Each identification sign in an urbanized area, posted by the owner or their authorized representative shall include, at a minimum, the following information in 2 inch or larger letters:

    • Well owners name, address, and telephone number.
    • County, Township, name of Village - City - Town (where applicable).
    • Property street address (or nearest address to the access road entrance. If "nearest" is used, it should be reflected on sign).
    • State Permit Number, Lease Name, and Well Number.
    • Local emergency response phone number and company emergency phone number.
    • Where a gate exists on the access road, the identification sign shall be placed on the gate.
    • Keys or the combination to the lock shall be provided to the state inspector or local emergency response officials on request.

    A permanent locked entranceway gate may be required by the State or requested by the landowner when a lease/access road to the wellhead and/or tank battery extends a significant distance from the ingress access point. A locked gate made of tubular steel or material similar in strength shall be placed near the entrance to the access road restricting access to the well site.

    For more oil & gas questions, contact our consultants today at LancasterSafety.com.