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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: As a company, are you permitted to have only one employee working in the facility at a time?
    A: It is not an OSHA requirement, but it is highly recommended that someone else be present for supervision or if there was an incident.

    See how your facility would do during an OSHA inspection.

    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.

    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.

    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.

     

  • 8. OSHA Training Topics & Requirements
     

    10 HOUR OSHA TRAINING

    10 AND 30 HOUR OUTREACH CARDS

    Q. Five years ago, one of our employees obtained their 30-Hour outreach card. Do they need to be re-certified?

    A. 10 and 30 Hour Outreach cards never expire, so your employee is covered with the card that he has. We would recommend having periodic refresher training for all employees who have had 10 or 30 hour trainings in the past. If you are even interested in have the training completed online I would recommend having it done at 360Training.com. LSCI can also offer training in person for more than 5 employees at a time.

    REQUIRED OSHA 10 HOUR CONSTRUCTION TRAINING

    Q: What states require OSHA 10 hour construction training?
    A: These states require the training:

    • Connecticut
    • Rhode Island
    • New Hampshire
    • New York
    • Massachusetts
    • Missouri
    • Nevada

     300 LOGS

    HOW SOON AFTER AN INJURY DO I NEED TO UPDATE MY OSHA 300 LOG?

    Q: How soon after an injury do I need to put the injury on the OSHA log? What type of injuries do I need to report on OSHA log and what not? Are there any injuries that I need to call into OSHA to inform them of the injury ?

    A: OSHA classifies the following types of injuries below as a “recordable” injury:
    -Fatality (You also have to report it to OSHA within 8 hours.)
    -Injury that caused days away from work
    -Injury that caused restricted work or had the employee transfer to another job
    -Medical treatment beyond first aid. 1904.7(b)(5)(i)(C)
    -Loss of consciousness

    All fatalities must be reported to OSHA within 8 hours of the incident.
    All work-related inpatient hospitalizations, amputations, and loss of an eye must be reported within 24 hours of the incident.
    All OSHA-recordable injuries/illnesses must be entered on the log within 7 days of the injury or illness.

    AERIAL LIFT

    FORKLIFT AND AERIAL LIFT CERTIFICATIONS

    Q: How often do the men need to be certified to operate rough terrain forklifts and aerial lifts?

    A:  Forklift operators need to be re-certified every 3 years or more frequently if any of the following conditions occur:

    • 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.

    OSHA doesn’t have a specific frequency for aerial lift training.  Training must be completed initially and when/if any of the following conditions occur:

    • An accident occurs during aerial lift use,
    • Workplace hazards involving an aerial lift are discovered, or
    • A different type of aerial lift is use

    Contact us today to get re-certified!

    ANNUAL TRAINING REQUIREMENT

    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.

    AUDIOMETRIC TESTING

    AUDIOMETRIC TESTING

    Q: We have conducted yearly audio testing since we were cited by OSHA in 2007, do we need to continue?

    A: As long as employees are still exposed to noise levels above 85 dBA for an 8-hr time-weighted average then you need to continue the baseline audiograms for new employees and annual audiograms for those employees already in the hearing conservation program.

    CARBON MONOXIDE

    CARBON MONOXIDE EXPOSURE

    Q: What is the maximum amount of carbon monoxide exposure permitted by OSHA in a general industry environment?

    A: According to 29 CFR 1910.1000 TABLE Z-1, the maximum limit for carbon monoxide exposure is 50 ppm (55 mg/m3) over an 8 hour TWA (time weighted average).

    CERTIFICATIONS

    FORKLIFT TRAINING VERIFICATION

    Q: Do our employees need to have their forklift certification cards on them at all times, or could they be in their lockers here at work?

    A:  OSHA requires that you as a company maintain records verifying that your employees were in fact trained on forklifts. It is not necessary for your employees to keep a card on them at all times.  However, you may hand the cards out to employees and make a copy for yourself to keep on record. This way you have two forms of documentation, one being the training logs from the training and the copy of the cards being the other.

    CERTIFIED WELDER FOR CRANES

    Q: Do you have to have a certified welder to weld the cross beams on a crane?

    A: OSHA does not say anything about the need for a certified welder it just says the welder must be qualified.  When welding on a crane though, you need to contact the crane manufacture to get their approval because welding on the crane can affect the load rating of that crane.

    TRUCK CRANES

    Q: Do crane operators for ‘truck cranes’ need to be certified?

    A: If you are using the crane for maintenance purposes the crane would fall under the 1910.180 regulation.  Under this regulation only ‘Designated Personnel’ shall operate the crane and there is no certification required.

    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.

    TRUCK CRANES

    Q: Do operators of truck cranes need to be certified?

    A: Yes, the operators need to be certified, if the crane can hoist/lift more than 2,000 pounds.

    See: 1926.1427(a)(3) Exceptions: Operator qualification or certification under this section is not required for operators of derricks (see § 1926.1436), sideboom cranes (see § 1926.1440), or equipment with a maximum manufacturer-rated hoisting/lifting capacity of 2,000 pounds or less (see § 1926.1441).

    OPERATOR TRAINING FOR SKID STEERS

    Q:  Do you have anything on training for skid steer authorization?

    A:  Since skid steers are considered “earth removal equipment” they do not fall under the scope of OSHA’s powered industrial truck requirement.  However, if the skid steer does have a vertical mast it would fall under the requirements.  Click here for an OSHA standard interpretation on this subject.  Although OSHA doesn’t have any training requirements for this type of equipment it is still highly recommended to train your operators and only allow authorized or certified individuals to operate the equipment.

    FORKLIFT TRAIN-THE-TRAINER CERTIFICATIONS

    Q: Do the train-the-trainer certifications received by two of our employees have an expiration date, or a time frame in which they have to get re-certified?

    A: No, the train-the-trainer certification does not have an expiration date. However, if the certified employees are also operators, then they would need to be re-certified every three years. You can also do a refresher training as time progresses.

    MAN LIFT CERTIFICATION FOR OPERATORS

    Q: Do our operators for the man lift need to be certified? Also, what should the training entail?

    A: OSHA’s standards state that only an authorized/competent person shall operate the man lift or aerial device. Therefore, the federal agency does not require aerial lift/man lift operators to be certified or qualified.

    The competent person is designated by the employer. OSHA defines a “competent person”  as one who is capable of identifying existing and predictable hazards in the surroundings or working conditions, which are unsanitary, hazardous, or dangerous to employees, and who has authorization to take prompt corrective measures to eliminate them. An “authorized person” means a person approved or assigned by the employer to perform a specific type of duty or duties or to be at a specific location or locations at the jobsite.

    We always recommend contacting the manufacturer of the man lift to conduct a formal training. The manufacturer’s training would be able to thoroughly discuss the controls and operation of the specific equipment.

    OSHA requires the training to include:
    • Explanations of electrical, fall and falling object hazards
    • Procedures for dealing with hazards
    • Recognizing and avoiding unsafe conditions in the work settings
    • Instructions for correct operation of the lift (including maximum intended load and load capacity)
    • Demonstrations of skills and knowledge needed to operate the lift before operating it on the job.
    • When and how to perform inspections
    • Manufacturer’s requirement’s

    Workers should be retrained if any of the following conditions occur:
    • An accident occurs during the lift’s use
    • Workplace hazards involving an lift are discovered
    • A different type of lift is being used.
    • Employers are also required to retrain workers who they observe operating a lift improperly.

    OSHA REQUIREMENTS FOR RE-CERTIFICATIONS

    Q: When does OSHA require safety re-certifications for forklifts?

    A: OSHA requires re-certifications for Power Industrial Truck Operator training every three years. There are specific safety programs that OSHA requires employees to have training each year, and LSCI covers each of those topics at the annual training. Although if your employees are involved in a union, their training requirements may exceed those outline by OSHA.

    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.

    MANLIFT CERTIFICATIONS

    Q: What kind of certification if any is needed to operate a manlift? Is there special certification needed?

    A: OSHA does not require a certification for manlift operation but employees are required to be adequately trained on the equipment. This includes equipment specific training, safe operating procedures, and fall protection. It's recommended to contact the manufacturer as they have expert knowledge on the equipment.

    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.

    SCAFFOLD CERTIFICATION

    Q: Do all employees need to be certified as a competent person?

    A: No, OSHA only requires that one employee be qualified as a competent person. All other employees need to be trained by a qualified person on the noted requirements if they perform work while on a scaffold (1926.454(a) or are involved in erecting, disassembling, etc. (1926.454(b).

    CONFINED SPACE

    NEW CONFINED SPACE STANDARD REQUIREMENTS

    Q: I am concerned about this new OSHA confined space standard. Do we need to have our crew leaders trained? Are we going to need H2S monitors? Tri pods, harness and rescue plan for each job? Please get back to me so we know what actions need to be taken.

    A: In response to your questions…

    Training – The new Confined Space Standard requires employers to ensure that their workers are trained so that they may perform their duties safely and understand the hazards in permit spaces.  Training is to be provided to each employee whose work is regulated by the a Confined Space Program.  Training must result in an understanding of the hazards in the permit space and the methods used to isolate, control or in other ways protect employees.  Employees should have the understanding, knowledge and skills necessary to safely work in confined spaces.

    • Monitoring – Continuous atmospheric monitoring of confined spaces is now required in the new 1926 standard.  The air in a confined space must be tested before workers enter for oxygen levels, flammable and toxic substances and stratified substances. If it is anticipated that employees may come in contact with H2S, monitors shall be worn to ensure employee safety.

    • Rescue – If you rely on your own rescue team on site, then yes you will need the proper rescue equipment and plans.  If you are relying on local emergency services, please confirm that they offer confined space rescue and also ensure that employees know how to coordinate with rescue personnel.   If the confined space you are entering is deeper than five feet, retrieval equipment must be utilized such as a fall arrest harness, lanyard and tripod.

    LSCI can provide confined space training for your company, give us a call at 888.403.6026.

    CONFINED SPACE TWO PERSON ENTRY

    Q: If two employees are in a confined space can they be hooked up to the same tripod?

    A: Each employee in the confined space must be connected to a separate retrieval line that is hooked up to its own mechanical retrieval device or fixed point. The space must also be large enough so that both employees can be retrieved in a timely manner in the event of an emergency rescue.

    CONFINED SPACE

    Q: Are you allowed to have employees working in two separate confined spaces at the same time but with only one full set of rescue equipment?

    A: No. Adequate rescue equipment needs to be provided for each confined space during entry. If both spaces needed to be entered at the same time then an additional set of rescue equipment would be required or you could rely on outside sources for rescue.

    WELDING IN A CONFINED SPACE

    Q: We have a weld joint that needs to be “fused” after machining.  The welder reaches into a 16” opening about 18” deep and welds this circumferential weld.  His feet never leave the floor; but his head is in the opening.  Based on OSHA’s definition of “entry” do we need to be concerned about this being considered a confined space?

    A: Per 1910.146(b) "Entry" means the action by which a person passes through an opening into a permit-required confined space. Entry includes ensuing work activities in that space and is considered to have occurred as soon as any part of the entrant's body breaks the plane of an opening into the space.

    CRANE

    HARD HATS, OVERHEAD CRANES, AND FORKLIFT MAN BASKET

    Q: Do I need to have a horn for my overhead crane and should my employees wear hard hats? Do I need a checklist for performing work in the forklift man basket?

    A: Yes your employees should wear hard hats as the crane creates an overhead hazard, which could result in falling objects. The crane does not need a horn and OSHA does not require the documentation of an inspection of the man basket but I recommend that you use one in case of an OSHA inspection.

    CERTIFIED WELDER FOR CRANES

    Q: Do you have to have a certified welder to weld the cross beams on a crane?

    A: OSHA does not say anything about the need for a certified welder it just says the welder must be qualified.  When welding on a crane though, you need to contact the crane manufacture to get their approval because welding on the crane can affect the load rating of that crane.

    INSPECTION REQUIREMENTS FOR CRANES

    Q: Does OSHA have inspection requirements for Cranes?

    A: Yes, before initial use all new and altered cranes shall be inspected, frequent inspection - Daily to monthly intervals, and periodic inspection - 1 to 12-month intervals.

    SLING AND CHAIN REQUIREMENTS

    Q: What is the standard for OSHA standard for sling and chain inspections? Is there anything more we should be doing to satisfy any OSHA requirements?

    A: The standard is 1910.184(d) and explains that each day before being used, the sling and all fastenings and attachments shall be inspected for damage or defects by a competent person designated by the employer. Additional inspections shall be performed during sling use, where service conditions warrant. Damaged or defective slings shall be immediately removed from service.

    If the slings are alloy steel chain slings, it would pertain to section 1910.184(e)(3)(i) of the standard. This section explains that a thorough periodic inspection of alloy steel chain slings in use shall be made on a regular basis to be determined on the basis of frequency of sling use; severity of service conditions; nature of lifts being made; and experience gained on the service life of slings used in similar circumstances. Such inspections shall in no event be at intervals greater than once every 12 months.

    OSHA REQUIREMENTS FOR ELECTRIC CRANE

    Q: What are the OSHA requirements for my electric crane in the warehouse?

    A: Minimum clearance of 3 inches overhead and 2 inches laterally shall be provided and maintained between crane and obstructions. Also:

    • The control circuit voltage shall not exceed 600 volts for a.c. or d.c. current.
    • Where multiple conductor cable is used with a  suspended pushbutton station, the station must be supported in some satisfactory manner what will protect the electrical conductors against strain.
    • Pendant control boxes shall be constructed to prevent electrical shock and shall be clearly marked for identification of functions.
    • Electrical equipment shall be located or enclosed that live parts will not be exposed to accidental contact under normal operating conditions.
    • The hoisting motion of all electric traveling cranes shall be provided with an overtravel limit switch in the hoisting direction.
    • Exposed moving parts such as gears, set screws, projecting keys, chains, chain sprockets, and reciprocating components which might constitute a hazard under normal operating conditions shall be guarded.
    • Do not use a chain container with storage capacity less than the lift length on the hoist.
    OSHA REGS FOR NEWLY INSTALLED CRANE

    Q: What do we need to do comply with OSHA on the operations of this newly installed crane?

    A: In regards to your safety question, see the following regulations below to help you comply with the OSHA standards on your newly installed crane. Always make sure to inspect all rigging material prior to use.

    • Monthly inspections for all equipment;
    • Annual inspections for all equipment;
    • Shift, monthly, and annual inspections for all Wire rope;
    • Post-assembly inspections upon completion of assembly;
    • Inspections of modified or repaired/adjusted equipment;

    1926.1417(c)(1) The procedures applicable to the operation of the equipment, including rated capacities (load charts), recommended operating speeds, special hazard warnings, instructions, and operator's manual, must be readily available in the cab at all times for use by the operator.

    The manufacture should be able to provide you with this information, but it must readily available in the cab for the crane operator.

    1926.1417(e)(1)(iv) Barricades or caution lines, and notices, are erected to prevent all employees from entering the fall zone. No employees are permitted in the fall zone.

    Make sure the barricade or caution lines are constructed around the crane, and all employees must be aware that no tools should be placed within the barricade.

    Ground conditions around the equipment for proper support, including ground settling under and around outriggers/stabilizers and supporting foundations, ground water accumulation, or similar conditions.

    For crane inspections, the crane inspector must be a competent person. In short, a competent person is defined as, "one who is capable of identifying existing and predictable hazards in the surroundings or working conditions which are unsanitary, hazardous, or dangerous to employees, and who has authorization to take prompt corrective measures to eliminate them.”

    A variety of inspections are required to ensure that equipment is in safe operating condition. These include, but are not limited to:

    Shift inspections for all equipment;

    OVERHEAD CRANE

    Q: Who is allowed to operate an overhead crane in a manufacturing facility?

    A: See applicable standards below. NOTE: OSHA has separate standards for construction cranes.

    1910.179(b)(8)

    Designated personnel - Only designated personnel shall be permitted to operate...

    CRANES

    Q: Does the load rating need to be posted on both sides of the crane?

    A: The load rating needs to be posted so that the operator can view it from any angle.

    CRUSHING HAZARD

    TRENCH BOX MODIFICATIONS

    Q: Can I mount plates to the end of our trench boxes to further prevent cave-ins?

    A: That may be acceptable, however you will need to verify and be able to prove that any modifications are properly engineered to withstand the anticipated pressure that will be applied.  This can be accomplished by requesting approval from the manufacture or an accredited engineer, however it may be best to purchase a new box instead.

    DEADLINE

    JUNE 1 GHS DEADLINE

    Q: Are we required by law right now to have SDS instead of MSDS on file?

    A: To answer your question, “are we required by law right now to have SDS instead of MSDS on file,” the answer is yes. OSHA implemented the GHS adoption timelines starting with its first deadline in December 2013 where employers were required to train their employees on SDSs, labels, and the GHS format. Throughout the transition period there were other deadlines for manufacturers, importers, and distributors. However as of June 1, 2016, all employers must be in full compliance with GHS. To be in full compliance with GHS means the following: •Hazard Communication program is updated to reflect the changes •All employees have been trained on new hazards identified during the reclassification process •Workplace labels are appropriately updated •All updated Safety Data Sheets have been obtained and easily accessible to employees

    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

    DRYWALL

    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.

    EXCAVATING

    ADJUSTING TRENCH WITHOUT TRENCH BOX

    Q: I have a trench that is currently 6 feet high on both sides.  I want to adjust it so that a protective system does not have to be used.  If I adjust it to be four feet, will I need a protective system?

    A: For trenching, a protective system is required for a trench 5 feet deep or greater.  Therefore, if you would adjust your trench to make the edges only four feet high, a competent person may determine that a protective system is not required.

    EXCAVATING A BASEMENT

    Q: Is 1 to 1 sloping while we are excavating a basement alright?

    A: Most soil is type C so they would need 1.5 to 1 since they are digging at 12 feet deep trench.

    EXCAVATING BELOW THE TRENCH BOX

    Q: Are you permitted to dig 1-2 feet below the shoring box in a 4x5 trench?
    A: Yes, according to 1926.652(e)(2)(i), you can excavate no more than 2 feet below the bottom of the support system, only if the support system itself can handle and resist the forces calculated for the full depth of the trench and if there are no signs of a loss of soil from below or behind the support system.

    Get all your safety questions answered by our experienced OSH consultants, learn how today at lancastersafety.com

    EXCAVATOR

    Q: The rollover protection on an excavator was damaged by a tree.  Does this need to be repaired by a professional or can we do it in-house?

    A:  You must remove unsafe materials and equipment from service until a registered professional engineer evaluates and approves them for use. OSHA Publication on Excavations

    FILTERS

    DOCUMENTING RESPIRATOR FILTER CHANGES

    Q: Is it required to keep documentation on filter changes for respirators?

    A: It is not required by OSHA, but it would be a recommendation to keep track of the service-time-limit.
    o All filters must be replaced whenever they are damaged, soiled, or causing noticeably increased breathing resistance (e.g., causing discomfort to the wearer). Before each use, the outside of the filter material should be inspected. Always follow the respirator filter manufacturer's recommendations.

    FIT-TESTING

    MEDICAL CLEARANCES FOR FIT TESTS

    Q: Is obtaining medical clearance for employees who wear respirators a voluntary program? and does it need to only be done once?

    A: Medical clearance for employees who wear respirators is mandatory. Additionally, employees need to be reevaluated if one of the following occurs:

    - An employee reports medical signs or symptoms that are related to ability to use a respirator.
    - A PLHCP, supervisor, or the respirator program administrator informs the employer that an employee needs to be reevaluated.
    - Information from the respiratory protection program, including observations made during fit testing and program evaluation, indicates a need for employee reevaluation.
    - A change occurs in workplace conditions (e.g., physical work effort, protective clothing, temperature) that may result in a substantial increase in the physiological burden placed on an employee.

    HAZWOPER TRAINING

    SUPERVISOR/MANAGER 8 HOUR HAZWOPER REFRESHER TRAINING

    Q:  Can you tell me where it states that the Supervisor Training is required to be refreshed annually like the HAZWOPER 8 hour?

     A:  OSHA’s requirement for the refresher training is as follows:

    1910.120(e)(8) Refresher training. Employees specified in paragraph (e)(1) of this section, and managers and supervisors specified in paragraph (e)(4) of this section, shall receive eight hours of refresher training annually on the items specified in paragraph (e)(2) and/or (e)(4) of this section, any critique of incidents that have occurred in the past year that can serve as training examples of related work, and other relevant topics.

    OSHA also points out in some of their interpretations that 8 hours is the minimal time required for the refresher training.  Just like employees, supervisors/managers only need a minimum of 8 hours.  Where they differ is in the content of the training.  Employees and supervisors/managers need to have separate refresher trainings.
    Learn more about OSHA refresher training and all OSHA training courses available from Lancaster Safety.

    HAZARDOUS WASTE TRAINING

    Q:  We are going onto a landfill to do some sampling.  No hazardous waste has, is, or ever will be disposed of in the landfill.  Is Hazwoper training required?  If not, what training is required?
    A:  As long as there is no hazardous waste OSHA’s Hazwoper Regulation doesn’t apply.  OSHA’s Hazard Communication Standard applies instead.

    HEARING PROGRAM

    WHEN IS A HEARING CONSERVATION PROGRAM REQUIRED?

    Q: How many days per year would an employee have to be exposed to an environment with noise levels in excess of 85 decibels on an  8-Hour (TWA) before the employee is required to be in the hearing conservation program?

    A: OSHA requires any employee who is exposed to noise levels above 85 dB on an 8-hour (TWA) to be included in the hearing conservation program even if it's only one day.

    HOIST

    RULES AND REGULARITY OF INSPECTING HOISTS

    Q: How often do I need to inspect our hoist and what are the inspecting rules?

    A: OSHA requires that all hoisting equipment be regularly inspected according to standards set by the individual manufacturer and ANSI.  The following is a breakdown of what to look for on a daily, frequent, and periodic basis.

    Daily inspections: the operator at the start of each shift should perform daily inspections, or at the time the hoist is used for the first time during each shift.  All functional operating mechanisms for maladjustment interfering with proper operation should be inspected daily.  The daily inspection regimen should include, but not be limited to, an examination of the chain for wear, twists, excessive dirt, broken links, and proper lubrication.  Hooks should be inspected for deformations, cracks, damage, and properly operating latches.

    Frequent inspections: Frequent inspections are the next level up from daily inspections.  While the operator should perform daily inspections, a person who is trained, experienced, and qualified to do them should do frequent inspections.
    How often the frequent inspections are done is a function of hoist service and ranges from daily to monthly.  General guidelines are as follows.  If the hoist is seeing normal service, then the frequent inspections should be conducted once a month.  For heavy service, the frequent inspections should be weekly to monthly.  Severe service applications warrant frequent inspections, daily to weekly.
    During frequent inspections, check the hoist more thoroughly than the operator’s daily inspections. ASME B30.16 and the manufacturer's recommendations should determine frequent inspection criteria.

    Periodic inspections: Periodic inspections should be performed by a qualified inspector.   The OSHA standard 1910.179 (j)(1)(i)  defines the time frame for conducting periodic inspections as being from 1- to 12-month intervals.  In general, perform periodic inspections at intervals recommended by the manufacturer and according the severity of the service.  Generally, severe service dictates daily periodic inspections, whereas heavy service is weekly.  Normal service inspection periodicity is monthly.
    Periodic inspections are more thorough than frequent inspections.  According to the severity of the service, the inspector should refer to ASME B30.16 and the manufacturer’s recommendations.  Disassembly is not required for any of these inspections unless the inspection indicates a breakdown is needed.  However, prior to placing the hoist back in service, load testing is required if some disassembly involving load-bearing components has occurred.

    HOISTING PERSONNEL USING AN OVERHEAD CRANE

    Q: Our maintenance department is interested in purchasing a crane man basket to perform work onelevated issues, particularly related to our 25' high wheelabrator. They have requested that the lift also be suited to act as a forklift attachable work platform. When elevated work on the machine must be performed, a ladder is used in an unsafe manner because our current man lift basket is too large to access the tight space.

    A: OSHA’s overhead crane regulations contained in 1910.179 does not address this topic. However, I did find a letter of interpretation where this question was raised. OSHA stated that although there is no corresponding general industry regulation addressing this topic, compliance with the construction regulation, 1926.550(g), in its entirety, at general industry worksites would be considered appropriate protection for employees being hoisted to perform these inspection.

    Now, to complicate things, OSHA revised their construction crane regulations a few years back and the old regulations in 1926.550 are now located in 1926.1400. I called OSHA to confirm that the letter of interpretation is still valid and that the new construction crane regulations can be used. I did receive confirmation that the letter is valid and the new regulations can be used. 1926.1431 is the regulation of concern.

    The first section in the regulation states the following: 1926.1431(a) The use of equipment to hoist employees is prohibited except where the employer demonstrates that the erection, use, and dismantling of conventional means of reaching the work area, such as a personnel hoist, ladder, stairway, aerial lift, elevating work platform, or scaffold, would be more hazardous, or is not possible because of the project's structural design or worksite conditions. This paragraph does not apply to work covered by subpart R (Steel Erection) of this part.

    If there is another, safer, means of accessing the area (using a scissor lift, scaffolding, etc.), OSHA states that you must go that route. If none of these options are feasible you can use the crane. If the crane is used, it will be in your best interest to purchase an approved basket or platform from the actual manufacturer of your cranes or another reputable crane company. OSHA requires personnel platforms to be approved by the manufacturer so you might not be able to find one that can be used for a crane and a forklift. You more than likely will have to get separate platforms.

    MEDICAL EVALUATIONS

    RESPIRATOR MEDICAL EVALUATIONS

    Q: How often are medical evaluations required to be performed?  The health care company said they need to be completed every year.  We thought it was every two years.  Can you clarify?

    A: OSHA doesn’t require the medical evaluations to be performed annually or biannually.  Instead, OSHA’s requirements for additional evaluations are as follows:

    • If the employee reports signs or symptoms that are related to the ability to use a respirator
    • If the physician, supervisor, or program administrator informs the employer that an employee needs to be reevaluated
    • If information from the respiratory protection program, including observations made during fit testing and program evaluation, indicates a need for employee reevaluation; or
    • A change occurs in workplace conditions (e.g., physical work effort, protective clothing, and temperature) that may result in a substantial increase in the physiological burden placed on an employee.

    OSHA does require fit testing to be performed at least annually.  Double check with the health care company to make sure they meant the evaluations and not fit tests.

    RESPIRATOR MEDICAL EVALUATIONS

    Q: Do employees need re-evaluation of medical clearance for respirator use?

    A: Yes, under certain circumstances:

    1910.134(e)(7) Additional medical evaluations. At a minimum, the employer shall provide additional medical evaluations that comply with the requirements of this section if:

    1. 1910.134(e)(7)(i) An employee reports medical signs or symptoms that are related to ability to use a respirator;
    2. 1910.134(e)(7)(ii) A Physician or other licensed health care professional, supervisor, or the respirator program administrator informs the employer that an employee needs to be reevaluated;

    iii. 1910.134(e)(7)(iii) Information from the respiratory protection program, including observations made during fit testing and program evaluation, indicates a need for employee reevaluation; or

    1. 1910.134(e)(7)(iv) A change occurs in workplace conditions (e.g., physical work effort, protective clothing, temperature) that may result in a substantial increase in the physiological burden placed on an employee.
    RESPIRATOR MEDICAL EVALUATIONS

    Q:  Do medical evaluations need to be conducted annually for respirator wearers?

    A:  No, additional medical evaluations need to be conducted if:

    • An employee reports medical signs or symptoms that are related to ability to use a respirator
    • A PLHCP, supervisor, or the respiratory program administrator informs the employer that an employee needs to be reevaluated
    • Information from the respiratory protection program, including observations made during fit testing and program evaluation, indicates a need for employee reevaluation; or
    • A change occurs in workplace conditions (e.g., physical work effort, protective clothing, temperature) that may result in a substantial increase in the physiological burden placed on an employee.

    MIRRORS

    MIRROR REQUIREMENTS ON FORKLIFTS

    Q: Are forklifts and tow motors required to have mirrors to see behind them?

    A: OSHA does not require that forklifts or other powered industrial trucks have mirrors to see behind, however, there are a few factors to note:

    • If the equipment was manufactured with mirrors then it must stay in compliance with the original manufacturer’s design. For example, if the mirrors would fall off, break, or become damaged then they would need to be replaced. The equipment should be taken out of service until it can be repaired. Also, any modifications, additions, or alterations to the equipment must be approved in writing by the manufacturer (see 1910.178(p)(1) and 1910.178(a)(4)).
    • Employees should operate the equipment and look in the direction of the path of travel. If the operator’s vision is obstructed at a crossing or other location they should slow down and sound the horn. Also, if the load they are carrying obstructs their forward view then they must travel with the load trailing (see 1910.178(n)(4) and 1910.178(n)(6)).

    MISSED TRAINING

    NEW HIRE/EMPLOYEE MISSED TRAINING

    Q: What can we do if an employee is ill on the day of the training and misses it?

    A: There are a couple of options for if an employee misses a training or even if an individual is hired shortly after our annual training and you want to assure that they receive and understand the necessary information. The first option would be an online training. This would be a training conducted by one of our qualified trainers through GoToMeeting.com. it would be $250 for the first one and then $150 for any online training after that. You can have an unlimited number of employees attend as long as they have access to a computer with internet and a phone (Please see attachment). The other option would be to have a supervisor or qualified individual review the binders with the individual. In each binder, there is a section in the back titled “New Hire Training Summary” of which explains what shall be reviewed. Whichever option you choose, you must be sure the training is documented.

    OSHA REQUIREMENTS

    MAXIMUM AIR PRESSURE

    Q: We have changed to all safety tips on our blow guns, but is there a maximum air pressure that OSHA says is safe for operator use?

    A: The OSHA standard states that compressed air shall not be used for cleaning purposes except where reduced to less than 30 p.s.i. and then only with effective chip guarding and personal protective equipment.

    HVAC SYSTEM REQUIREMENTS

    Q: What specifications should the closet around the HVAC system meet in the barn?

    A: It is recommended that you take the following into consideration when installing the closet around your HVAC system:

    The ambient temperature in wiring closets should be maintained in the range of 680 to 750 F. 24 hours per day, 7 days per week. Humidity should be maintained at 30% to 50%.

    Wiring closets should be ventilated at the rate of one air change per hour. Make sure to establish a route for HVAC filter change. Air-change rates, temperature and humidity shall be closely monitored and controlled on a  continuous basis. The system shall provide adequate ventilation to remove fumes, odors, air borne contaminants, and to safely operate fume hoods continuously.

    Separate thermostatic control shall be provided for each wiring closet.

    Wiring closets should never be located below ground level unless measures are taken to prevent water intrusion.

    Water or drain piping should not be permitted within the wiring closet.

    Walls surrounding the wiring closets should extend to the structural floor above on all sides, both for reasons of physical security and environmental control.

    Minimum height to structural ceiling should be 8'-6".

    Floor finish should be smooth, dust-free and not susceptible to static electricity build-up.

    Provide 3'-0" wide by 7'-0" high door, opening outward, with storeroom function lock.

    Exposure of wiring closet interiors to direct sunlight should be avoided.

    Ensure that the protective encapsulation on HVAC Conduit is not damaged.

    OSHA requires periodic inspections on the following:

    Daily: Visual inspection of hoods, ductwork, access and clean-out doors, blast gate positions, hood static pressure, pressure drop across air cleaner, and verbal contact with users. ("How is the system performing today?")

    Weekly: Air cleaner capacity, fan housing, pulley belts.

    Monthly: Air cleaner components.

    WORK RESTS & TONGUE GUARD MEASUREMENTS

    Q: What are OSHA’s requirements for work rests and tongue guard measurements?

    A: OSHA’s requirements for work rests (1/8”) and tongue guard (1/4”) measurements.

    1910.215(a)(4)

    Work rests. On offhand grinding machines, work rests shall be used to support the work. They shall be of rigid construction and designed to be adjustable to compensate for wheel wear. Work rests shall be kept adjusted closely to the wheel with a maximum opening of one-eighth inch to prevent the work from being jammed between the wheel and the rest, which may cause wheel breakage. The work rest shall be securely clamped after each adjustment. The adjustment shall not be made with the wheel in motion.

    1910.215(b)(9)

    Exposure adjustment. Safety guards of the types described in Subparagraphs (3) and (4) of this paragraph, where the operator stands in front of the opening, shall be constructed so that the peripheral protecting member can be adjusted to the constantly decreasing diameter of the wheel. The maximum angular exposure above the horizontal plane of the wheel spindle as specified in paragraphs (b)(3) and (4) of this section shall never be exceeded, and the distance between the wheel periphery and the adjustable tongue or the end of the peripheral member at the top shall never exceed one-fourth inch.

    NONIONIZING RADIATION (LASERS)

    Q: Is signage required when using lasers?

    A: Yes, OSHA States in 1926.54(d) Areas in which lasers are used shall be posted with standard laser warning placards.

    MANUAL LIFTING

    Q: What is OSHA's requirement for maximum weight a person may lift?

    A:  OSHA does not have a guideline that limits the maximum weight a person may lift.  Employees are to use safe lifting practices and employers may implement a company specific rule that creates a certain weight maximum requirement.

    FOOD AREA IN A TREATMENT ZONE

    Q: Our Cardiologist would like to partition her suite so that she and her nurse may eat back there. This suite is a place of treatment but none of their patient pose a zoonotic threat. So we were going to purchase panel curtains from IKEA and hang them where the suite "L's" that way she can move her desk back there and they are able to eat per OSHA regulations, would this be alright?

    A: The other question pertaining to the treatment suite also does not have a specific OSHA regulation which addresses the issue. Again, OSHA’s 5(a)(1), general duty clause would most likely be used in this situation. As long as you have completed a hazard/risk assessment for this particular suite, and can prove that there is either no potential for risk, or how the hazard is eliminated through either engineering controls or personal protective equipment. In this case, this would be your panel curtains. We encourage that employees eat in a designated kitchen or break area to assure there is no potential hazards or risks as a safe work practice.

    COMPANION THERAPY LASER

    Q: We have the Companion Therapy Laser and I was hoping you could inform me on the OSHA safety regulations for this class 4 laser?

    A: OSHA does not have any regulations that specifically pertain to this piece of equipment. However, there are a few standards that OSHA could use for citations. 5(a)(1), the general duty clause is used when there is no regulation for a particular item, and states that employers are obligated to provide employees with a safe and healthful workplace. They could also cite the personal protective equipment standard 1910.132, which requires the employer to assess the hazards and identify the proper personal protective equipment needed. 1910.133, requires the employer to provide the proper eye and face protection to employees. The last standard pertains to the guarding of the machine. 1910.212 requires that machine guards are in place wherever possible.

    We recommend that you follow all of the manufacturer guidelines and protective measures, as well as provide training to the employees for this machine. Training should include having the employees review the operators manual for the laser. Please be sure to also document this training.

    PORTABLE PROPANE HEATERS

    Q: What are OSHA’s requirements in regards to using propane heaters in enclosed areas?

    A: Listed below is the requirement when using propane heaters inside a building or structure.

    •1926.153(h)(8) Portable heaters, including salamanders, shall be equipped with an approved automatic device to shut off the flow of gas to the main burner, and pilot if used, in the event of flame failure. Such heaters, having inputs above 50,000 B.t.u. per hour, shall be equipped with either a pilot, which must be lighted and proved before the main burner can be turned on, or an electrical ignition system.

    NOTE: The provisions of this subparagraph do not apply to portable heaters under 7,500 B.t.u. per hour input when used with containers having a maximum water capacity of 2 1/2 pounds

    SANDBLASTING

    Q: Since we are doing our own sandblasting, we are getting our sandblaster an air supplied respirator / blasting helmet. If he is more comfortable in the air supplied full face respirator will that be OSHA compliant or do we need to get him the air supplied blasting hood?

    A: OSHA requires that employees must be protected by an abrasive-blasting respirator approved by NIOSH. These respirators must cover the employee’s head, neck, and shoulders to protect from any rebounding abrasives. This link provides an example of the proper sandblast operator’s protective equipment.

    ELECTRICAL CORD REPAIR

    Q: If the prong is damaged on an extension cord, is it permissible to replace the prong with an approved one, provided the repair is done by a qualified electrician?

    A: Yes, OSHA states “Extension cords used in construction may be repaired, so long as the repair returns the cord to the "approved" state required by 1926.403(a)

    WATER REQUIREMENTS ON A JOBSITE
    Q:  Do employers have to provide water on a jobsite?

    A:  OSHA requires that the employer provides water at a jobsite:  Heat Stress Prevention 

    1910.141(b)(1)(i)  Potable water shall be provided in all places of employment, for drinking, washing of the person, cooking, washing of foods, washing of cooking or eating utensils, washing of food preparation or processing premises, and personal service rooms.

    OVERHEAD HAZARD

    OVERHEAD HAZARD

    Q:  Do we need to barricade off the area underneath an aerial lift?

    A:  OSHA’s regulations do not specifically state that the area beneath an aerial lift needs to be barricaded off.  However, it is best to do so.  Tools or equipment could accidentally fall out of the lift and strike someone on the ground causing serious injury.  A hard hat only provides minimal protection.

    We recommend having one of our qualified safety consultants evaluate your work site in order to determine best practices for your company.

    POWERED INDUSTRIAL TRUCK

    HOW OFTEN DO POWER INDUSTRIAL TRUCK OPERATIONS NEED TO BE RE-TRAINED?

    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.

    RESPIRATOR

    PROPER CLEANING PROCEDURES FOR RESPIRATORS

    Q: What are the proper cleaning procedures for respirators?

    A: OSHA requires employers to follow the cleaning procedures found in Appendix B-2 of 1910.134 or procedures recommended by the respirator manufacturer, provided that such procedures are of equivalent effectiveness.

     DECLINING VOLUNTARY RESPIRATOR USE

    Q: Should employees who decline to use respirators on a voluntary basis sign a declination form?

    A: Yes, although it is not required it would be recommended to reduce future liability.

    RESPIRATORS

    Q: Can employees share negative pressure respirators?

    A: Yes, employees are allowed to share respirators however it is not recommended.  You would have to ensure that the respirators are the same make, model, and size, and that they are sanitized before each different employee uses them.

    RESPIRATORY PROTECTION - VOLUNTARY USE
    1. What are the requirements for voluntary use of respirators?
    2. The following is necessary (1) medical clearance; (2) provide employees with information in Appendix D of the OSHA respiratory standard; (3) ensure that respirators are cleaned, stored, & maintained so that they do not present health hazards to users.

    To learn more about OSHA compliance look to the experienced consultants at Lancaster Safety Consulting, Inc.

    RESPIRATORY PROTECTION

    Q: Do respiratory medical release forms/respiratory fit tests need to be completed yearly?

    A: The Respiratory Medical Release Forms do not need to be completed yearly they just need to be completed once and then again if something changes to their health such as drastic weight gain/loss or a physical change to their face that would affect respirator usage.  The respirator fit tests on the other hand do need to be completed yearly.

    RESPIRATORY PROTECTION FOR FURNACE CLEANING
    Q:  An employee assigned to clean out a furnace insisted that OSHA requires him to wear a respirator while cleaning out the furnace.  Do we have to provide it and what kind of respirator do we need?
    A:  In order to determine if a respirator is needed air monitoring must be conducted to figure out the amount of exposure. If the exposure is over OSHA's Permissable Exposure Limit (PEL) then controls need to be used to reduce the exposure. The type of respiratory protection would be based off of the amount of exposure and the substance.
    VOLUNTARY DUST MASK USE

    Q: Do employees who voluntarily wear dust masks still need to sign Appendix D?

    A: If you have any employee who voluntarily wears a dust mask, then they must review and sign Appendix D.

    Get your safety questions answered today by contacting us at 888.403.6026.

    REQUIREMENTS FOR A RESPIRATOR PROGRAM WITH USE OF DUST MASKS

    Q: If dust mask use is required, do we need to have a Respiratory Protection program in place?

    A: Per OSHA standard 1910.134(c)(1), In any workplace where respirators are necessary to protect the health of the employee or whenever respirators are required by the employer, the employer shall establish and implement a written respiratory protection program with worksite-specific procedures.

    Employers do not need to include employees whose only use of respirators involves the voluntary use of filtering facepieces (dust mask) in a written respiratory program.

    RESPIRATORS

    Q:  When are medical clearances and fit tests required?
    A: Since they are not working with lead the medical clearances are required initially and only if the employee had a major health concern (gained weight, heart attack, etc). They fit tests are required yearly.

    WELDING

    WELDING CURTAIN USE

    Q: If employees are working approximately 25 feet from welding operations, is it required that welding curtains be used?

    A: OSHA does not give a definitive working distance, but states that proper welding shields or curtains shall be used to protect other workers in the area. (1910.152(b)(2)(iii)).

    WELDING

    Q: Employees were welding on Hastelloy (Nickel based) and it’s moving more towards a production level. Do they need to be wearing respirators?

    A: Yes, employees do have the potential for exposure to Hex Chrom, and you should conduct air monitoring. Please click here for more information.

    OXYGEN TANKS ON WELDING CARTS

    Q: If you only have one oxygen cylinder on a welding cart do I have to follow the 1910.253 (b)(4)(iii) storage requirement?

    A: For general industry, as long as the oxygen tank is “in use” or “connected for use” the storage requirements do not apply.

     

  • 9. Personal Protective Equipment (PPE)
     

    ABRASIVE BLASTING

    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.

    DEAF EMPLOYEES

    HEARING PROTECTION FOR DEAF EMPLOYEES

    Q: Does a deaf employee still have to wear hearing protection?

    A: In regards to hearing protection, even employees who have been diagnosed with severe or profound deafness may have some residual hearing that needs to be protected from additional loss. Therefore, OSHA has taken the position that the requirements for using hearing protection in accordance with 29 CFR 1910.95(b)(1) and 1910.95(i)(2) apply to deaf employees. The Agency has stated that "there is no exception (for hearing protection) for employees who have diminished capacity to hear or for employees who have been diagnosed as deaf."
    The employee will still be required to comply with the Hearing Protection Standards by OSHA.

    EYE PROTECTION

    WHICH TYPE OF EYE PROTECTION & FOR WHAT

    Q: What types of eye protection should our employees wear for certain tasks (welding, metal fabrication, painting, maintenance)
    A: Generally, for the tasks that do not have light radiation hazards, you’ll want to select a type that meets ANSI Z-87 requirements. You should be able to see Z87 clearly marked on every pair of the glasses to verify that the pair of glasses has been rated and passed the Z87 standard for 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).

    HARDHATS

    STICKERS ON HARDHATS

    Q: Is there a regulation or standard that states a company may not apply stickers to a hard hat?

    A: No there is no regulation or standard stating that but one thing that you want to ensure is that the sticker being applied will not affect the shell of the hardhat. Some stickers contain adhesives that may break down the outer shell and reduce the original protection rating. It is recommended to keep the stickers to a minimum so you can always see the shell and ensure that it is still in good condition.

    REQUIREMENTS FOR REPLACING EQUIPMENT

    Q: Are there any OSHA specific requirements regarding when a hard hat and the suspension systems need to be replaced?

    A: As far as replacing hard hats and/or the suspension, you will want to refer to the manufacturer’s recommendations on replacement. However, if your crews are wearing and using them on a daily basis, you will want to be conscious of the use and some hard hats or suspensions may show wear more quickly than the manufacturer’s maximum recommended use. Employees should be inspecting hardhats daily for wear and tear. If an employee is ever involved in an incident or takes a hit or blow, the hard hat could be damaged and the integrity of the hard could have diminished. In those instances, the hard hat should be replaced even if visible damage is not noticeable. As far as the suspensions, they are typically offered as replacement parts separately, and should always be replaced when they are noticeably damaged or if excessive wear is noticed.

    WEARING STOCKING CAPS UNDER HARDHATS

    Q: Our forklift operators drive outside to put scrap in the scrap bin and in the winter they need head warmth protection. What are the OSHA standards on stocking caps under the hardhat?

    A: OSHA does not have requirements specifically prohibiting the use of cold weather head garments under hard hats, however, it does reference ANSI recommendations and requirements regarding winter liners.

    The ANSI standard permits the use of cold weather liners so long as they are specifically designed for use with hard hats or tight fitting to the head and are compatible with the protective properties of the helmet. If the use of a garment were to affect the fit and security of the helmets suspension, it may no longer meet the specification requirements in these ANSI standards and would therefore be in violation of 1910.135.

    The ANSI standard requires that winter liners be made of fabric, plastic or other suitable materials which do not contain metal parts. Some liners that would be appropriate for use with a hard hat include:
    • Bandannas
    • Skull Caps
    • Hoods; or
    • Welders Caps

    To ensure that the liner selected is appropriate for your helmet, a visual inspection should be conducted prior to entering an area or performing a task with overhead hazards, checking to see that the liner does not affect the overall fit or protective properties.

    Reference: https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=25336

    PERSONAL PROTECTIVE EQUIPMENT (PPE)

    REQUIREMENTS ON STEEL TOED SHOES

    Q: Are steel toed shoes required for forklift operators, warehouse personnel, or anyone that interfaces with forklift traffic?

    A: In essence, if a work environment or job site potentially contains a "danger of foot injuries" due to falling, rolling or piercing objects, then steel toed shoes should be required, as deemed by the employer. These dangers can include nails, cinder blocks, bags of concrete, vehicles (fork lifts), heavy packages, barrels, etc. In other words, there aren't many scenarios where some or most of these risks aren't present. If any of these apply to your workplace, then steel toed shoes would be a requirement. (Refer to 1910.136 (a)).

    PPE FOR INJECTION MOLDING MACHINE

    Q: Regarding PPE (leather glove or kevlar sleeve) that would be used occasionally while working near a heated area on an injection molding machine such as removing purged material at start-up etc. - Can this be a shared item stored on the machine in a safe manner or does each employee that would need to use this have to his/her own glove or sleeve?

    A: You need to ensure that the gloves/sleeves that are being used properly fit the employee working in that area. All exposed employees must have the proper PPE, therefore if you have multiple employees working in that area, you just need to make sure the PPE fits each individual. Due to the possibility of different sizes, frequency of use, and type of operation/use, it may be best to issue PPE to each employee. Lastly, you'll want to ensure that that the PPE remains in a sanitary, protective manner. Be sure to follow all manufacturer recommendations for storage, use, maintenance, etc. and replace any damaged or worn PPE.

    PPE FOR WORKING UNDER HEAVY EQUIPMENT

    Q: Are employees required to wear hard hats even when they are working with extremely heavy materials above? Should we consider making it an optional PPE instead of required? Any potential issues or liabilities that we should consider?

    A: As far as hard hats being required for use, it is under OSHA’s 1910.135(a)(1) standard that says “The employer shall ensure that each affected employee wears a protective helmet when working in areas where there is a potential for injury to the head from falling objects.” While there is no general weight limit or maximum weight limit, to be compliant with OSHA regulations regarding head protection, employers shall ensure that each employee is wearing a hard hat while working in areas with falling object hazards.

    Though the weight of the materials you work with are very high, it would be deemed unsafe to have workers not wearing head protection in the event of an incident occurring.

    Keeping the use of hard hats as a requirement will help reduce liability or potential OSHA citations in the event there is an OSHA inspection or an incident in the workplace.

    PROPER PERSONAL SHOES NEEDED IN MANUFACTURING

    Q: We manufacture and paint steel windows and doors. The raw materials are heavy and the finished product is very heavy. Should we be requiring our employees to wear steel-toe or composite-toe boots? Our current PPE program just says that employees must wear leather work boots.

    A: According to the OSHA Personal Protective Equipment standard, protective equipment, including personal protective equipment for eyes, face, head, and extremities, protective clothing, respiratory devices, and protective shields and barriers, shall be provided, used, and maintained in a sanitary and reliable condition wherever it is necessary by reason of hazards of processes or environment, chemical hazards, radiological hazards, or mechanical irritants encountered in a manner capable of causing injury or impairment in the function of any part of the body through absorption, inhalation or physical contact.

    So, after conducting a hazard assessment, if it is determined that there are hazards that could injure an employee’s foot by performing the work, then yes, steel toed shoes should be a requirement.

    CERTIFICATION FOR GLOVES

    Q:  We recently purchased gloves are that are rated to 300 degrees.  They are not certified by a 3rdparty.  Does OSHA require gloves to be approved by ANSI?

    A:  OSHA requires eye/face, head, and foot protection to meet certain ANSI standards, but not hand protection.  The certification from the manufacturer stating that the gloves are rated to 300 degrees will be what you need.  We recommend that you request the manufacture includes the type of test they performed to determine this rating on the document they provide to you.

    PPE FOR CHANGING FORKLIFT BATTERY

    Q: Is there any specific PPE that is required for changing/checking a forklift battery?

    A: It is recommended that vinyl-coated, PVC, or gauntlet-type gloves with a rough finish are worn, also chemical splash goggles or face shield, safety shoes and an apron. Though OSHA does not require these items to be worn, they would have you refer to the individual MSDS and commonly the items stated above are the minimal required items.

    STEEL TOED SHOES

    Q: When do employees need to replace their steel toed shoes?

    A:  Whenever the boots themselves would present a hazard; such as the soles falling apart, etc.  They would also need replaced if the steel is damaged in any way because they would not work properly in the time of need.

    SAFETY VEST

    Q:  Should we require employees to wear safety shirts in the manufacturing shop?

    A:  Safety shirts are only required in traffic areas, such as on site in the field.

    FLAME RESISTANT CLOTHING
    Q: Can you wear Tyvek suits over FRCs?
    A: They are not made to be flame resistant.  They do make chemical resistance FRCs, that would be a better choice of PPE.
    FLAME RESISTANT CLOTHING

    Q: If Fire Resistant clothing is required to be used along with other PPE such as gloves a fall arrest harness, etc., does the additional PPE also have to be flame resistant?

    A: This link will take you to a memo that was released by OSHA to clarify OSHA’s policy for issuing citations for flame resistant clothing (FRC).  Since fall arrest harnesses are not specifically mentioned in the memo, OSHA would have a hard time issuing a citation for it.  Even though they are not currently required, flame resistant fall arrest harnesses are available for purchase online.

    PPE NEEDED FOR REFUELING EQUIPMENT

    Q: What PPE does OSHA require when refueling equipment that runs on gasoline, diesel or kerosene?

    A: OSHA relies on the employer to determine the PPE needs based on the hazard that the employees are exposed to. In this case, the Material Safety Data Sheets for the fuels need to be reviewed to determine the needed PPE.

    TINTED GLASSES

    Q:  Are there any current restrictions on eye protection when it comes to tinted/shaded lenses for indoor use?

    A:  OSHA doesn’t have any specific restrictions on tinted/shaded lenses used indoors.  However, OSHA would question whether the glasses would be creating a hazard by wearing them indoors.  For example, if the person wearing them is driving a forklift, the tinted glasses may impair their vision thus creating a hazard for themselves and others in the area.  The same can be said for someone who is on foot.  The glasses could impair their vision as well and they might not be able to recognize moving equipment, parts, material, etc. that might be in close proximity to them.  If you don’t want to totally prohibit their use you could regulate the darkness of the glasses that are being worn.

    WHO BUYS PERSONAL PROTECTIVE EQUIPMENT (PPE) - EMPLOYER OR EMPLOYEE?

    Q:  What PPE is the employer responsible to provide?

    A:  The employer is responsible to purchase and provide the PPE that employees need to wear except for a few special situations. OSHA's requirements on purchasing PPE and the special situations are provided below:

    • 1910.132(h) Payment for protective equipment.

    o   1910.132(h)(1) Except as provided by paragraphs (h)(2) through (h)(6) of this section, the protective equipment, including personal protective equipment (PPE), used to comply with this part, shall be provided by the employer at no cost to employees.

    o   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 eyewear, provided that the employer permits such items to be worn off the job-site.

    o   1910.132(h)(3) When the employer provides metatarsal guards and allows the employee, at his or her request, to use shoes or boots with built-in metatarsal protection, the employer is not required to reimburse the employee for the shoes or boots.

    o   1910.132(h)(4) The employer is not required to pay for:

    -1910.132(h)(4)(i) The logging boots required by 29 CFR 1910.266(d)(1)(v);

    -1910.132(h)(4)(ii) Everyday clothing, such as long-sleeve shirts, long pants, street shoes, and normal work boots; or

    -1910.132(h)(4)(iii) Ordinary clothing, skin creams, or other items, used solely for protection from weather, such as winter coats, jackets, gloves, parkas, rubber boots, hats, raincoats, ordinary sunglasses, and sunscreen.

    o   1910.132(h)(5) The employer must pay for replacement PPE, except when the employee has lost or intentionally damaged the PPE.

    o   1910.132(h)(6) Where an employee provides adequate protective equipment he or she owns pursuant to paragraph (b) of this section, the employer may allow the employee to use it and is not required to reimburse the employee for that equipment. The employer shall not require an employee to provide or pay for his or her own PPE, unless the PPE is excepted by paragraphs (h)(2) through (h)(5) of this section.

    o   1910.132(h)(7) This paragraph (h) shall become effective on February 13, 2008. Employers must implement the PPE payment requirements no later than May 15, 2008.

    Note to § 1910.132(h): When the provisions of another OSHA standard specify whether or not the employer must pay for specific equipment, the payment provisions of that standard shall prevail. [39 FR 23502, June 27, 1974, as amended at 59 FR 16334, April 6, 1994; 59 FR 33910, July 1, 1994; 59 FR 34580, July 6, 1994; 72 FR 64428, Nov. 15, 2007]

    PRESCRIPTION SAFETY GLASSES

    PURCHASING PRESCRIPTION SAFETY GLASSES

    Q: Should we provide prescription safety glasses for our employees?

    A: The employer is required to provide safety glasses and other types of eye protection for employees who are exposed to eye hazards.  However, OSHA does not require the employer to pay for prescription safety glasses (1910.132(h)(2).  Employers often opt to provide specialty items such as these as a best practice.

     

  • 10. Recordkeeping
     

    ACCIDENT INVESTIGATION

    STEPPED ON A NAIL

    Q: If an employee stepped on a nail and had to miss the rest of the day for medical evaluation, is it considered a day away from work and therefore recordable?

    A: No, you begin counting the days away from work on the day after the injury occurred or the illness began.

    Refer to 1904.7(b)(3) and 1904.7(b)(3)(i).

    ACCIDENT INVESTIGATION

    Q: How long should accident investigation documents be retained?

    A: OSHA does not specify how long to retain these documents.  OSHA 300 logs must be retained for a period of 5 years, so it is a good idea to retain the accident investigation documents for the same period of time.

    AMPUTATIONS

    REPORTING AMPUTATION TO OSHA

    Q: A death within 30 days of the incident must be reported within 8 hours. What if an amputation occurs long after the incident, but due to damage at work, is there a time limit when the amputation is considered as related and reportable?

    A: For an amputation, you must only report the event to OSHA if it occurs within 24 hours of the work-related incident. However, it must be recorded on your OSHA injury and illness records. You can refer to 1904.39(b)(6) for more information.

    INJURY REPORTING WITH AMPUTATIONS

    Q: Do we report an accident that may or may not have led to an amputation?

    A: For an amputation, you must only report the event to OSHA if it occurs within 24 hours of the work-related incident. However, it must be recorded on your OSHA injury and illness records. You can refer to 1904.39(b)(6) for more information.

    INCIDENT RATE

    HOW TO CALCULATE INCIDENT RATE OF RECORDABLE CASES AND LOST WORKDAY CASES

    Q: How do you calculate the following:

    1. Incident Rate of Recordable Cases
    2. Incident Rate of Lost Workday Cases

    A: 1. The OSHA Recordable Incident Rate (or Incident Rate) is calculated by multiplying the number of recordable cases by 200,000, and then dividing that number by the number of labor hours at the company.

    Number of OSHA Recordable Cases X 200,000
    IR = -----------------------------------------------------------
    Number of Employee labor hours worked

    2. The Lost Time Case Rate is a similar calculation, only it uses the number of cases that contained lost work days. The calculation is made by multiplying the number of incidents that were lost time cases by 200,000 and then dividing that by the employee labor hours at the company.

    Number of Lost Time Cases x 200,000
    LTC Rate = -----------------------------------------------------
    Number of Employee Labor Hours Worked

    INDUSTRY AVERAGE

    RECORDABLE INCIDENT RATE FOR INDUSTRY AVERAGE

    Q: How do you find the recordable incident rate for your company's industry average?

    A: You can find that information and anything else pertaining to incident rates, recordable incidents, days away from work, etc. on the Bureau of Labor Statistics' website.

    You can search Industry Incident Rate and it will lead you to a document that lists all the averages for all industries. You then use the NAICS code to refine the search to the exact industry in question.

    LIGHT DUTY

    LIGHT DUTY EMPLOYEE RECORDKEEPING QUESTION

    Q: If an employee quits during "light duty" do I have to continue to count the days that he works until released to full duty?

    A: If the employee leaves your company for some reason unrelated to the injury or illness, such as retirement, a plant closing, or to take another job, you may stop counting days away from work or days of restriction/job transfer. If the employee leaves your company because of the injury or illness, you must estimate the total number of days away or days of restriction/job transfer and enter the day count on the 300 Log.  1904.7(b)(3)(viii)

    RECORDKEEPING

    RECORDKEEPING FOR SUBCONTRACTOR INJURY

    Q: Do we need to include recordable injuries of our subcontractors in the field that aren't on our payroll, but are paid through purchase orders?

    A:You must record the recordable injuries and illnesses that occur to employees who are not on your payroll if you supervise these employees on a day-to-day basis. If the subcontractor's employee is under the day-to-day supervision of the subcontractor, the subcontractor is responsible for recording the injury or illness. If you supervise the subcontractor employee's work on a day-to-day basis, you must record the injury or illness.  It would be recommended to have a contract in place with all subcontractors to distinguish who is liable for safety and the overall supervision of the workers. You want to eliminate the possibility of having the injury recorded on two separate companies’ OSHA 300 logs.

    COUNTING DAYS WHEN A WORKER REFUSES TO RETURN TO WORK AFTER BEING RELEASED BY A PHYSICIAN

    Q: We have an employee that has been off work due to an injury & surgery. The doctor signed a release for the employee to return to work. However, the employee let us know that he will not be returning to work at this time. Do we continue to count the days that this employee is not working until the workers' compensation case is resolved even though his doctor released him to come back to work?

    A: Since OSHA Recordkeeping and workers' compensation rules differ, the workers' compensation case does not have any bearing on the OSHA Recordkeeping. In this situation, you may stop counting the days away from work based on the physician's release.

    You can refer to: 1904.7(b)(3)(iii)

    REPORTING MINOR INJURIES TO OSHA

    Q: What is the process to report a minor injury to OSHA?

    A: You only need to report an injury to OSHA in the following circumstances:
    • A work-related fatality – must be reported within 8 hours
    • A work-related in-patient hospitalization – must be reported within 24 hours
    • A work-related amputation – must be reported within 24 hours
    • A work-related loss of an eye – must be reported within 24 hours

    If any of the above have occurred, you can call 1-800-321-6742 and report the injury.

    RECORDKEEPING WITHIN DIFFERENT YEARS

    Q: An employee was diagnosed with carpal tunnel in 2014 and was approved for surgery at this time. However, he postponed the surgery until September in 2015 due to a sickness in his family. Do we record the injury on both the 2014 OSHA 300 log and the 2015 OSHA 300 log?

    A: Regarding the employee's carpal tunnel injury in 2014 and medical treatment in 2015, it is necessary to record the injury when it originally occurred in 2014. The details of the injury, days away/on restriction should be logged only on the 2014 OSHA 300 log as they pertain to the original injury. Any updates to the employee's treatment should also be reflected on the 2014 OSHA 300 log. Make sure you are retaining all OSHA 300 logs for 5 years following the year that they cover and update them during that period as needed.

    Refer to 1904.7(b)(3)(ix) and 1904.33(b)(1).

    RECORDKEEPING FOR KNEE INJURY

    Q: We had an employee twist their knee in the shop. They went to the hospital for a medical evaluation and received a prescription for pain medication. Does that count as a recordable injury?

    A: Yes, since the employee was given a prescription, you would need to record the injury.

    Refer to 1904.7(b)(5)(ii)(A).

    Find out about the 2015 recordkeeping changes here and contact us for any questions!

    HOW SOON AFTER AN INJURY DO I NEED TO UPDATE MY OSHA 300 LOG?

    Q: How soon after an injury do I need to put the injury on the OSHA log? What type of injuries do I need to report on the OSHA log and what not? Are there any injuries that I need to call into OSHA to inform them of the injury ?

    A: OSHA classifies the following types of injuries below as a “recordable” injury:
    -Fatality
    -Injury that caused days away from work
    -Injury that caused restricted work or had the employee transfer to another job
    -Medical treatment beyond first aid 1904.7(b)(5)(i)(C)
    -Loss of consciousness

    All fatalities must be reported to OSHA within 8 hours of the incident.
    All work-related inpatient hospitalizations, amputations, and loss of an eye must be reported within 24 hours of the incident.
    All OSHA-recordable injuries/illnesses must be entered on the log within 7 days of the injury or illness.

    RECORDKEEPING - PRE EXISTING CONDITION

    Q: An employee was working onsite and climbed under a pipe to reach the area of equipment that he was servicing. He felt a sharp pain in his knee and went to the doctor for diagnosis. The employee was given a prescription for pain medication and is waiting for further evaluation. Is this considered a recordable incident if the employee had a pre-existing knee injury?

    A: Yes! If the injury/illness is work-related or if an event or exposure in the work environment significantly aggravates a pre-existing injury or illness then it would be considered a recordable incident.

    Refer to 1904.5(a).

    RECORDKEEPING FOR PHYSICAL THERAPY INCIDENT

    Q: We have an employee who went to the doctor for a sore knee after lifting heavy items at work. An x-ray was taken and showed no injury so they set up the employee for a couple of weeks of physical therapy. Does the physical therapy make this an OSHA recordable incident?  He has no work restrictions.

    A: The doctor's medical recommendation of physical therapy, which is considered to be medical treatment, deems this incident as recordable.

    Refer to 1904.7(b)(5)(ii)(M).

    RECORDKEEPING FOR TETANUS SHOT

    Q: Do I record an injury that required a tetanus shot?

    A: No, administering tetanus immunizations is considered first aid.

    Refer to 1904.7(b)(5)(ii)(B).

    RECORDKEEPING IN DIFFERENT CALENDAR YEARS

    Q: We have an employee who was injured in late 2014 and was on restriction days beginning in 2014 but also overlapping into 2015. Do all of the restricted duty days get recorded in the year that the injury occurred even if they occurred in the following year. If not, how do we record a 2014 injury along with its 2015 restricted days on a 2015 log?

    A: According to OSHA, you only record the injury or illness once. You must enter the number of calendar days away for the injury or illness on the OSHA 300 Log for the year in which the injury or illness occurred. If the employee is still away from work because of the injury or illness when you prepare the annual summary, estimate the total number of calendar days you expect the employee to be away from work, use this number to calculate the total for the annual summary, and then update the initial log entry later when the day count is known or reaches the 180-day cap.

    Refer to 1904.(b)(3)(ix).

     GENERAL CONTRACTOR REPORTS SUB CONTRACTOR INJURY  RECORDABLE?

    Q: Does the general contractor have to record a subcontractor injury on a site that is the general contractor?

    A: It would be best to determine the actual relationship the general contractor has with the subcontractor and determine if the information below applies:

    Here is what OSHA requires in section 1904.31:

    • OSHA requires employers to record the recordable injuries and illnesses of all their employees, whether classified as labor, executive, hourly, salaried, part-time, seasonal, or migrant workers.
    • Employers are also required to record the recordable injuries and illnesses of all employees they supervise on a day-to-day basis, even if these workers are not carried on the employer's payroll.
    • Day-to-day supervision generally exists when the employer "supervises not only the output, product, or result to be accomplished by the person's work, but also the details, means, methods and processes by which the work objective is accomplished."
    • OSHA assigns the responsibility for recording and reporting to the employer with the greatest amount of control over the working conditions that led to the injury or illness.

    Multi-employer worksite OSHA regulations can be confusing, contact us for further verification.

    RECORDING AN INJURY: AWAY FROM WORK 1YR

    Q: We had an employee who was injured last year and their medical treatment status has carried over to the following year. The case is now in litigation with our workers' comp carrier to determine if the employee is still considered 'injured.' We are aware of the 180 day-cap for recordkeeping purposes, but do we have to report the full 180 days as this incident has gone back and forth now for almost a year?

    A: You must enter the number of calendar days away for the injury or illness on the OSHA 300 Log for the year in which the injury or illness occurred. If the employee is still away from work because of the injury or illness when you prepare the annual summary, estimate the total number of calendar days you expect the employee to be away from work, use this number to calculate the total for the annual summary, and then update the initial log entry later when the day count is known or reaches the 180-day cap.

    Also note, if the employee leaves your company for some reason unrelated to the injury or illness, such as retirement, a plant closing, or to take another job, you may stop counting days away from work or days of restriction/job transfer. If the employee leaves your company because of the injury or illness, you must estimate the total number of days away or days of restriction/job transfer and enter the day count on the 300 Log.

    Refer to 1904.7(b)(3)(ix).

    INJURED ONE YEAR, MISSED NEXT YEAR: HOW TO RECORD INJURY?

    Q: I have an employee who was injured in 2013 and has missed work all of 2014. Do I record his missed days in the 2014 OSHA 300 log?

    A: According to OSHA, you are only required to record an injury or illness once. You must enter the total number of calendar days away in the OSHA 300 Log for the year in which the injury occurred. You may “cap” the total number of days away at 180 calendar days. Therefore, in your case entering 180 days in the 2013 OSHA log would be sufficient.

    Refer to 1904.7(b)(3)(ix).

    Don't miss our annual recordkeeping webinars that can really help you out with your recordkeeping questions!

    RECORDING INJURY THAT REQUIRED STITCHES

    Q: An employee cut his finger and received stitches. Does this have to be recorded on our OSHA 300 log?

    A: Yes, any injury that required medical attention beyond first aid must be recorded on the log.

    Refer to 1904.7(b)(5)(ii)(D).

    Don't miss our annual recordkeeping webinars that will guide you on what is or isn't a recordable injury.

    NUMBER OF EMPLOYEES FOR RECORDKEEPING

    Q: Do you have to fill out an OSHA 300 log if you have 9 employees?

    A: No, you are exempt from filling out the OSHA 300 log & 300A Summary if you employ 10 or less employees throughout the entire year.

    Refer to 1904.1(a)(1).

    For more recordkeeping questions, join us every January for our Recordkeeping Webinar.

    WHAT OSHA REPORTING CHANGES START IN JANUARY?

    Q: Is there a recordkeeping update coming up in January?

    A: Yes, OSHA has made the following changes on injury reporting:
    OSHA must be notified within a specified time frame for all of the following types of incidents:

    • All work related fatalities - within 8 hours
    • All work related in-patient hospitalizations - within 24 hours
    • All work related amputations and losses of an eye - within 24 hours

    We are hosting a free webinar on recordkeeping and injury reporting on January 7th and 14th at 3pm EST. Register today by clicking here.

    RECORDABLE ACCIDENT?

    Q: We had an employee cut the tip of his finger off and went to the hospital. The employee was given a prescription. Is this a recordable incident?

    A: Yes, it would be considered a recordable since the employee was prescribed medication and the finger was partially amputated. The amputation would also need to be reported to OSHA within 24 hours.

    Refer to 1904.7(b)(5)(ii)(A), 1904.39(a)(2), and 1904.39(b)(11).

    INJURIES THAT NEED TO BE RECORDED

    Q: What constitutes an injury to be a recordable injury?

    A: All work-related fatalities. All work-related injuries and illnesses that result in days away from work, restricted work or transfer to another job, loss of consciousness or medical treatment beyond first aid.

    All work-related injuries or illnesses diagnoses by a physician or other licensed health care professional, even if it does not result in death, days away from work, restricted work or job transfer, medical treatment beyond first aid, or loss of consciousness.

    Injuries include cases such as, but not limited to, a cut, fracture, sprain, or amputation.

    Illnesses include both acute and chronic illnesses, such as, but not limited to, a skin disease (i.e. contact dermatitis), respiratory disorder (i.e. occupational asthma, pneumoconiosis), or poisoning (i.e. lead poisoning, solvent intoxication).

    OSHA's definition of work-related injuries, illnesses and fatalities are those in which an event or exposure in the work environment either caused or contributed to the condition. In addition, if an event or exposure in the work environment significantly aggravated a pre-existing injury or illness, this is also considered work-related.

    RECORDKEEPING FORMS

    Q: What are the requirements with the OSHA forms?

    A: You must use the OSHA 300, 300A, and 301 forms, or equivalent forms, for recordable injuries and illnesses. The OSHA 300 form is called the Log of Work-Related Injuries and Illnesses, the 300A is the Summary of Work-Related Injuries and Illnesses, and the OSHA 301 form is called the Injury and Illness Incident Report.

    You must enter information about your business at the top of the OSHA 300 Log, enter a one or two line description for each recordable injury or illness, and summarize this information on the OSHA 300A at the end of the year.

    You must complete an OSHA 301 Incident Report form, or an equivalent form, for each recordable injury or illness entered on the OSHA 300 Log.

    Refer to 1904.29(a), 1904.29(b)(1), and 1904.29(b)(2).

    RECORDKEEPING FOR AN EYE INCIDENT

    Q: I'm filling out my OSHA 300 form for an accident from last year. The employee got something in their eye. They didn't feel the need for any treatment but we sent them to the emergency room. The emergency room flushed their eye and released the employee without any other medical attention or follow-up. How do we record this incident?

    A: Due to the fact that the medical professional only flushed the eye with solution to cleanse the employee's eye, did not forceps to remove the irritant, or recommend any time off/restricted work then this incident would not be recordable.

    Refer to 1904.7(b)(5)(ii)(3).

    RECORDKEEPING FOR PRESCRIBED MASSAGES

    Q: If an employees is sent by a Doctor to a physical therapist for several visits to receive massages is that a recordable case?

    A: You must consult the physical therapist and determine if the treatment would be considered massage therapy or physical therapy. If the treatment is considered massage therapy then the injury would not be recordable. If the therapist considers the treatment to be physical therapy then it would be considered recordable.

    Refer to 1904.7(b)(5)(ii)(M). 

    RECORDKEEPING FOR CHIROPRACTOR VISIT

    Q: Is a visit to the chiropractor considered medical treatment?

    A: For recordkeeping purposes, OSHA does not distinguish between first aid and medical treatment cases based on the number of treatments administered. If a chiropractor provides observation, counseling, diagnostic procedures, or first aid procedures for a work-related injury then the case would not be recordable. If the chiropractor provides medical treatement and/or prescribes work restrictions for the employees then this case would be recordable.

    Refer to Preamble Discussion: Section 1904.7 (66 FR 5968-5998, Jan. 19, 2001).

    RECORDKEEPING WHEN ACCIDENT HAPPENED IN A DIFFERENT YEAR FROM THE SURGERY

    Q: We had an injury at the end of 2012 where an employee twisted his knee falling into a trench. He went to a doctor, completed his physical therapy, and it was decided he needed surgery. The surgery took place in January 2013. Do I need to record this as a new incident in 2013?

    A: No, because the injury originally occurred in 2012 you will want to include it on the OSHA forms for that year only. You do want to make sure to update the days away from work and include the days from 2012 and 2013.

    Refer to 1904.7(b)(3)(ix).

    RECORDKEEPING FOR A VEHICLE STRUCK BY ACCIDENT AFTER WORKDAY

    Q: Is this case recordable? An employee was struck by a vehicle while walking to his car after a day of work. He went to the emergency room and received X-rays and was recommended for light duty.

    A: Yes, this case would be recordable because the employee was injured in the company parking lot which is considered to be the work environment.

    Refer to 1904.5(b)(1). 

    ACCIDENT ON THE WAY TO WORK

    Q: If an employee is injured in a car accident on the way to or from a job site and the accident does not occur in the parking lot or access road - is the accident is recordable?

    A: If the employee was on their normal commute to work in a motor vehicle accident then the case would not be recordable. OSHA considers the employee's commute from home to work to end, once he or she arrives at the work environment (i.e. parking lot, office, jobsite, etc.) or when he or she starts traveling "in the interest of the employer." Refer to 1904.5(b)(2)(vii).

    RECORDKEEPING FOR TEMP AGENCIES

    Q: Does the temporary personnel agency or the supervised host employer responsible for recording an injury or illness?

    A: The host employer must record the recordable injuries and illnesses of employees not on its payroll if it supervises them on a day-to-day basis.

    Refer to 1904.31(b)(2) and 1904.31(b)(4).

    RECORDKEEPING IN DIFFERENT CALENDAR YEARS

    Q: If an employee was injured in 2012 and continued to miss days in 2013, do I need to record this on the 2013 log?

    A: No, the incident needs to only be recorded for the year in which the incident actually occurred.

    Refer to 1904.7(b)(3)(ix).

    RECORDKEEPING WHEN OUR COMPANY WAS BOUGHT OUT

    Q: If a company gets bought out midway through the year to new ownership, how does management fill out the recordkeeping forms?

    A: As the employer, you are responsible for filling out the OSHA recordkeeping forms only for the period of the year during which you owned the establishment. For example, if you own a company until June, you would fill out the average number of employees, hours worked, injuries, etc. from January to June. The new owner would then be required to fill out the OSHA forms for July to August.

    Refer to 1904.34.

    RECORDABLE DAYS AWAY FROM WORK

    Q: An employee fell on the snow/ice and hurt his leg and the doctor prescribed several days off of work. Is this recordable?

    A: Yes, this incident is recordable since the injury occurred while the employee was at work and it resulted in days away from work.

    HOW TO RECORD AN INJURY WITH VOLUNTARY DAYS AWAY FROM WORK

    Q: An employee was injured and went to the emergency room for a fractured pinky and received stitches. The ER said to follow-up to have the stitches removed in a week but did not recommend any days away from work. The employee chose to take 3 days off prior to having the stitches removed. Do I need to count that as ‘days away from the worksite?”

    A: No you do not need to could the days away from work as the employee voluntarily took days off from work and it was not a medical recommendation. It would still be considered a recordable incident due to the medical treatment of sutures.

    Refer to 1904.7(b)(3)(iii) and 1904.7(b)(5)(ii)(D).

    RECORDING DAYS AWAY FROM WORK IN DIFFERENT CALENDAR YEARS

    Q: Two employees were injured in 2013 and returned to full duty in 2014. Do I count the days away from work that occurred in 2014 or just 2013’s time? Do I record these cases on the 2014 log as well?
    A: Record both injuries as ‘new cases’ on the 2013 log only. You should count the total number of days away from work for both years and record the number only on the 2013 log. Remember you can cap the number of days if it reaches 180.

    RECORDKEEPING FOR TEMP EMPLOYEES

    Q: We occasionally use agency temporary personnel. I should be including their hours worked in the total hours worked. Do I also include them in the headcount or only a fraction for them as the temps work a few days to a few weeks at a time.
    A: Here’s the equation for calculating the average number of employees:

    • Add the total number of employees your establishment paid in all pay periods during the year, including full-time, part-time, temporary, seasonal, salaried, and hourly.
    • Count the number of pay periods your establishment had during the year. Be sure to include any pay periods when you had no employees.
    • Divide the number of employees by the number of pay periods.
    • Round the answer to the next highest whole number.
    RECORDKEEPING FOR A FINGER CUT

    Q: Does this scenario need to be recorded on the OSHA 300 log? The employee cut his finger and went to the hospital, the hospital did not use stitches or give him a prescription. He did not return to work that day but was there the next day.

    A: No, you do not need to record this event since only first aid treatment was rendered and the employee did not miss any days away from work or was not put on restriction/job transfer.

    RECORDKEEPING FOR RESTRICTED DAYS IN DIFFERENT CALENDAR YEARS

    Q: An employee was injured in 2013 and was on restricted duty for 86 days. In 2014, he will have an estimated 21 days away from work. Do you record both or only the worse of the two?

    A: You will want to count all of the days on your 2013 log. Record the total number of days on restricted duty and estimate the number of days that the employee will be away from work. After the employee returns to full duty, you will need to go back to the 2013 log and update it with the actual numbers.

    RECORDKEEPING FOR TEMP EMPLOYEES

    Q: Do we need to include temporary employees on our OSHA logs?

    A: Yes, if the employees are under direct supervision of your company.

    Refer to 1904.31(b)(2) and 1904.31(b)(3).

    RECORDKEEPING FOR 11 EMPLOYEES

    Q: If we only have 11 employees, are we required to do recordkeeping?

    A: Yes. OSHA requires all companies with 11 or more employees to keep their injury and illness logs up to date.

    Refer to 1904.1(a)(2).

    REPORTING OSHA RECORDABLE INJURIES TO WORKERS COMPENSATION COMPANY

    Q: In the state of Texas; Are you required to turn in all OSHA recordable incidents to your workers compensation insurance?

    A: OSHA does not require you to report a claim to your workers compensation provider.  However, that is only because it must be evaluated separately from the OSHA recordkeeping process.  The state of Texas requires employers who carry workers’ compensation insurance to report all known occupational disease and any work-related injuries that result in more than one day of lost time. Employers that fail to meet these requirements commit an administrative violation and may be subject to administrative penalties.

    Contact us today with your safety questions.

    RECORDKEEPING FOR A SPLINTER

    Q: If a physician removes a splinter, is it recordable?

    A: This case would not be recordable if the physician solely performed first aid to remove the splinter.

    Refer to 1904.7(b)(5)(ii)(K).

    REPORTING INJURIES TO OSHA

    Q: Do I need to report injuries/illnesses to OSHA?

    A: You do not need to report all injuries/illnesses to OSHA. In the event of a work-related fatality you must report it to OSHA within 8 hours of the incident. You must also report the in-patient hospitalization of 1 or more employees, loss of an eye, and amputations to OSHA within 24 hours. You can report incidents to OSHA's toll free number, 1-800-321-6742, or the local area office during normal business hours.

    Refer to 1910.39(a)(1) & (2).

    Update: OSHA's 2015 Reporting Requirements changed this - CLICK HERE TO SEE THE CHANGES

    POSTING PERIOD FOR THE OSHA 300A FORM

    Q: Do I need to keep the OSHA 300A – Summary up to date throughout the year?

    A: No, it is not required to fill out the 300A – Summary form until January of the following year, prior to the posting period of February 1-April 30.

    Refer to 1904.32(a). 

    RECORDING CALENDAR OR WORK DAYS

    Q:  When counting days away from work or light duty/restriction, do I count work days or calendar days?

    A: You want to count all calendar days that the employee is off, up to 180.

    Refer to 1904.7(b)(3)(iv).

    RECORDKEEPING WHEN WORKING 2 WEEKS ON AND THEN 2 WEEKS OFF

    Q: If we are working 2 weeks on and then 2 weeks off, do we need to record the two weeks off for an injured employee?

    A: Yes, the case needs to be recorded for each of the days that he is away from work including the 2 off weeks even though the rest of the company is also not working those days.

    Refer to 1904.7(b)(3)(iv).

    RECORDKEEPING FOR NO INJURIES

    Q: What do I need to do if we didn’t have any recordable injuries in 2012?

    A: Complete the 300 log and the left portion of the 300A with zeros.  Fill the right side (company information) of the 300A completely, have the highest ranking company official sign and date it, and post it in an area where information is usually conveyed to employees.

    SENDING IN RECORDKEEPING FORMS

    Q: Do we have to send our 300 logs to OSHA every year?

    A: No, not unless you receive a letter from OSHA/DOL requesting them.

    Refer to 1904.41(a).

    NEEDLE STICK INJURY

    Q: Do needle sticks need to be recorded on the OSHA 300 log if the source was negative or if the source was positive and the employee did not develop disease?

    A: Yes, all work-related needle stick injuries and cuts from sharp objects that are contaminated with another person’s blood or other potentially infectious material must be recorded as an injury.

    Refer to 1904.8(a).

    RECORDKEEPING FORMS

    Q: Are we required to keep the OSHA 300 and 300A for each year, as well as, the OSHA 301 for each incident?

    A: Yes, you must save the OSHA 300 Log, the privacy case list (if one exists), the annual summary (300A), and the OSHA 301 Incident Report forms for five (5) years following the end of the calendar year that these records cover.

    Refer to 1904.29(a) and 1904.33(a).

    RECORDKEEPING FOR BACK INJURY
    Q:  An employee hurt their back and was given a prescription but they did not miss any work.  Is this recordable?

    A:  Yes, it is recordable because the employee was prescribed medicine.

    Refer to 1904.47(b)(5)(ii)(A).

    RECORDKEEPING WHEN EMPLOYEE DOESN'T SHOW UP TO PHYSICAL THERAPY

    Q:  We had an employee strain his back at work.  The incident occurred in April, 2012. After going to an urgent care facility, he was put on restricted work duty for one week, and physical therapy for three weeks. However, the employee did not show up for any follow up appointments or physical therapy treatments.  What is the minimum amount of restricted work days I have to record?

    A:  You must record the amount of time that the doctor recommended. The employee will need to see the doctor at the end of the recommended time period to see of the employee can return to full duty.  You'll need to suggest to the employee that he goes back to the doctor to confirm he is fit for regular duty, if not, there is a possibility that the workers comp and insurance can deny the employees claim.

    Refer to 1904.74(b)(3)(ii).

    RECORDKEEPING FOR CAR ACCIDENT

    Q:  An employee rolled his truck on his way to a job this morning.  He appears to be OK, but was sent to the hospital for X-rays.  Is this recordable?

    A:  If there is medical attention beyond first aid or lost/restricted work days, it needs to be added to their logs. The X-rays are not considered recordable since they are a diagnostic procedure. OSHA does not consider diagnostic procedures a form of medical treatment.

    RECORDKEEPING: RETURNING TO WORK DATE - PHYSICIAN RECOMMENDATION VS. EMPLOYEE

    Q:  How do I handle a case when a physician or other licensed health care professional recommends that the worker return to work but the employee stays at home anyway?

    A: In this situation, you end the count of 'days away from work' on the date the physician or other licensed health care professional recommends that the employee return to work.

    Refer to 1904.7(b)(3)(iii).

    RECORDKEEPING FOR UNFILLED PRESCRIPTION
    Q:  If the physician issues a prescription, but it is not filled, is this recordable?

    A:  Yes, OSHA considers that medical treatment is provided once a prescription is issued.

    Refer to 1904.7(b)(5)(ii)(A).

    RECORDKEEPING FOR INFECTED BLISTER
    Q: An employee developed a blister on his foot, and after time this blister got infected.  The employee went to the doctors to get the checked out.  The doctor then issued a prescription to the employee.  Is this a recordable incident?

    A: Yes, this is a recordable incident because a prescription is considered more than first aid.

    Refer to 1904.7(b)(5)(ii)(A).

    RECORDKEEPING FOR INJURY & THEN SURGERY
    Q: An employee gets injured in 2011, but does not miss any work and is not put on restricted duty/job transfer.  In 2012, that employee finds out he needs surgery form the injury and misses a month of work in 2012.  How would this be inserted in the OSHA 300 logs?

    A:  All of the information would be inserted in the 2011 OSHA 300 form.  The date of the injury would be the date the injury actually occurred even though the employee did not miss any work or was not put on restricted duty/job transfer because of that injury at the moment.  Then count the days the employee missed because of the surgery and insert that information in the days away for that same injury.

    Refer to 1904.7(b)(3)(ix).

    RECORDKEEPING: WHO SHOULD SIGN THE FORMS

    Q:  Who is supposed to sign the OSHA 300 log and where does the signature go?

    A:  A company executive must certify the log. Company executives are considered to be the owner of the company, officer of the corporation, highest ranking company official, or immediate supervisor of the highest ranking company official. The company executive should sign only the 300A form and the signature should go in the bottom right hand corner. The 300A needs to be signed and be posted starting February 1 through the end of April.

    Refer to 1904.32(b)(4).

    RECORDKEEPING - COUNTING RESTRICTED WORK DAYS
    Q:  How do you count the lost work/restricted days on the OSHA 300 log?

    A:  You'll need to count all the days on restriction starting the day after the employee was injured (even if it’s a weekend, or an employee is not scheduled). When the employee returns for restricted/light duty, count those days until they returned to full duty.

    Refer to 1904.7(b)(3)(v)-(vi) and 1904.7(b)(4).

    RECORDKEEPING FOR INJURED EMPLOYEE OUT FOR > YEAR

    Q:  One of our employees slipped on ice and hurt their neck.  They were off for more than a year.  Is there a limit to days that need to be recorded?

    A:  OSHA states the days away from work are capped at 180. This is noted in the following regulation:

    • 1904.7(b)(3)(vii) Is there a limit to the number of days away from work I must count? Yes, you may "cap" the total days away at 180 calendar days. You are not required to keep track of the number of calendar days away from work if the injury or illness resulted in more than 180 calendar days away from work and/or days of job transfer or restriction. In such a case, entering 180 in the total days away column will be considered adequate.
    RECORDKEEPING IN DIFFERENT CALENDAR YEARS

    Q: When filling out the 300 logs what do you do for an injury that occurred in one year, but that employee is still injured and he still is unable to return to work for the next calendar year?

    A: The answer is found under 1904.7(b)(3)(ix).  You only record the injury or illness once.  You must enter the number of calendar days away for the injury or illness on the OSHA 300 Log for the year in which the injury or illness occurred. If the employee is still away from work because of the injury or illness when you prepare the annual summary, estimate the total number of calendar days you expect the employee to be away from work, use this number to calculate the total for the annual summary, and then update the initial log entry later when the day count is known or reaches the 180-day cap.

    RECORDKEEPING - LIGHT DUTY?
    Q. An employee was instructed to keep a wounded finger “clean and dry.”  Would this be considered light duty?

    A. As long as the employee can perform his normal job duties, this would not be considered light duty.

    Refer to 1904.7(b)(4) - (b)(4)(ii).

    RECORDKEEPING FOR LIGHT DUTY

    Q: An employee was on light duty in 2011.  Do I have to carry this over to my 2012 log?

    A: No, all days should be recorded on the 2011 log.

    Refer to 1904.7(b)(3)(ix).

    RECORDKEEPING FOR 9 PEOPLE

    Q:  Are there any exceptions for us with recordkeeping since we only have 9 employees?

    A:  As long as you have fewer than 10 employees throughout the year you would be exempt.

    Refer to 1904.1(a)(1).

    RECORDKEEPING FOR EMPLOYEE AWAY FROM WORK > 180 DAYS
    Q: An employee was injured in 2011 and will be away from work for >180 days.  Do I have to put this on my 2012 log in addition to 2011?

    A: The injury should only be counted in the year that the injury occurred.  All 180 days should be counted in 2011.

    Refer to 1904.7(b)(3)(vii) and (b)(3)(ix).

    OSHA 300 RECORDABLE INCIDENT FOR EYE ACCIDENT

    Q: An employee got a piece of metal in his eye and he was taken to the emergency room to remove it and was given a one-time use nonprescription eye drops.  He later returned to work the same day.  Is this an recordable injury?

    A: No, this would not be considered a recordable incident because the foreign object in the eye was removed by eye drops, not forceps, and because there is no loss of work day or restriction/job transfer.

    Refer to 1904.7(b)(5)(ii)(J).

    RECORDKEEPING FOR ER INCIDENT
    Q: An employee was struck by a piece of equipment in the face and went to the ER, they were physically observed by a physician and it was determined there was no other injuries besides bruising on their face, they did not miss any work; is this recordable?

    A:  If there was no other treatment besides an observation and basic first aid, then no it is not recordable. 

    Refer to 1904.7(b)(5(i) and 1904.7(b)(5)(ii).

    RECORDKEEPING FORMS

    Q: What is the difference between the 301 and the 300 forms in the recordkeeping packet?

    A: The 301 is the incident report, you use it to record all types of injuries/incidents.  The 300 form is used to record only recordable injuries (medical treatment beyond first aid, death, days away from work, job transfer).

    Refer to 1904.29(b)(1) and 1904.29(b)(2).

    RECORDKEEPING FORMS

    Q: Our insurance carrier is asking for our incident forms, is the 301 the form they are referring to?

    A: Yes.

    Refer to 1904.29(b)(2).

    RECORDKEEPING FOR FINGER INJURIES

    Q:  An employee had recently fractured a finger, received stitches in another, and missed days away from work; is this recordable?

    A: Yes, their treatment would be considered medical treatment and they missed days from work.

    Refer to 1904.7(b)(3) and (b)(5)(ii)(D).

    RECORDKEEPING FOR STITCHES

    Q:  If an employee was injured and needed stitches, does this count as a recordable injury?

    A:  Yes, sutures are considered medical treatment.

    Refer to 1904.7(b)(5)(ii)(D).

    RECORDKEEPING FOR BROKEN ARM

    Q:  If an employee falls on ice in the company parking lot during company time and breaks their arm, is this recordable?

    A:  Yes, the incident would be a recordable injury because the employee was on company premises as a condition of their employment.

    Refer to 1904.5(a).

    WHAT FORM TO POST FOR OSHA RECORDKEEPING
    Q:  Which form has to be posted and for how long?

    A:  The 300A will need to be posted from February 1st through April 30th each year. You can download the form here by clicking here.

    Refer to 1904.32(b)(5).

    RECORDKEEPING FOR SAWDUST INCIDENT

    Q: An employee was running a saw and got sawdust in his eye.  He flushed it with water but did not feel the need to see a doctor.  Is the recordable?

    A: No, removing foreign objects from the eyes using irrigation is considered first aid which is not recordable.

    Refer to 1904.7(b)(5)(ii)(J).

    SMALL COMPANIES DON'T HAVE TO FOLLOW OSHA'S RULES?
    Q: Is it true that OSHA has no say over companies with less than 11 employees?

    A: OSHA regulations are applicable to all employers. The number of employees only pertains to OSHA’s recordkeeping requirements.  Companies with 11 or more employees must fill out the OSHA 300 form, 300A Summary, and the 301 form or a similar version. Companies with fewer do not have to keep the mentioned records.

    Refer to 1904.1(a)(1) - (2).

    OSHA 300

    Q: Does the OSHA 300A form only get posted from Feb 1 - April 30th? Does it matter where I buy the 2017 OSHA poster and is there a specific version that I would need?

    A: The OSHA 300A log is only required to be posted from February 1st to April 30th. As for the OSHA posters, OSHA doesn’t change their poster each year, but I can ship you a poster directly from OSHA to ensure that you do have the most current version. Please use this link to order the state required posters.

    300A Summary Form at Short Term Establishments

    Q: Do we have to post the 300A Summary at one of our construction sites?
    A: No, OSHA logs do not have to be kept at or posted at short term establishments (< 1 year) as they can be kept at the corporate establishment. They must be readily accessible to the short term establishment in the event of an OSHA inspection, or required from employee or representative. As a best practice, we recommend posting the 300A Summary at the construction site.

     

  • 11. SDS & Chemicals
     

    CHEMICAL SAFETY

    Requirements for vendors SDS?

    Q: We find that our paint vendors have been giving us the SDS for the base paint only, not for the whole paint including the colorant ingredients. Is this acceptable for us to wait until a problem arises and then to research the details for colorants?

    A: You would need to obtain the SDS for the whole paint including any additives or colorant. It is not acceptable to OSHA to wait until a problem arises and then look for the details of the paint or colorants. The paint vendors should be providing you with the complete SDS for the paint and I recommend requesting it from them anytime you do order the paint. OSHA would consider the paint a mixture and all ingredients in the mixture are required to be listed on the SDS. Per 1910.1200 Appendix D, the following is required:

    For Substances
    (a) Chemical name;
    (b) Common name and synonyms;
    (c) CAS number and other unique identifiers;
    (d) Impurities and stabilizing additives which are themselves classified and which contribute to the classification of the substance.

    For Mixtures
    In addition to the information required for substances:
    (a) The chemical name and concentration (exact percentage) or concentration ranges of all ingredients which are classified as health hazards in accordance with paragraph (d) of §1910.1200 and
    (1) Are present above their cut-off/concentration limits; or
    (2) Present a health risk below the cut-off/concentration limits.
    (b) The concentration (exact percentage) shall be specified unless a trade secret claim is made in accordance with paragraph (i) of §1910.1200, when there is batch-to-batch variability in the production of a mixture, or for a group of substantially similar mixtures (See A.0.5.1.2) with similar chemical composition. In these cases, concentration ranges may be used.

    SDS REQUIREMENTS AND FIELD MANUALS

    Q: What exactly are the requirements for chemicals stored in our SDS binder and what else should we have available at all times in case OSHA were to come on site?

    A: You're required to keep an SDS for literally any chemical that your employees could be exposed to. This even goes for as something as simple as cleaning products. You also want to make sure that your employees have access to your jobsite safety and health manual. The jobsite safety and health manual is a more condensed version of your full programs. They still provide extremely valuable information to employees who may need a quick answer.

    SDS FOR INK AND TONER?

    Q: Do we need an SDS for printer ink/toner?

    A. Yes, you want to make sure to have an SDS (Safety Data Sheet) for all chemicals which does include printer ink and toner.

    LABELING OF SECONDARY USE CONTAINERS

    Q: Which is the current OSHA standard, the HMIS or NFPA label?

    A: OSHA still recognizes the HMIS and NFPA labeling systems. However, since the adoption of the GHS labeling system, we recommend that you use this system which outlines the following requirements:

    • 1910.1200(f)(6)(ii) Product identifier and words, pictures, symbols, or combination thereof, which provide at least general information regarding the hazards of the chemicals, and which, in conjunction with the other information immediately available to employees under the hazard communication program, will provide employees with the specific information regarding the physical and health hazards of the hazardous chemical.
    • 1910.1200(f)(7) The employer may use signs, placards, process sheets, batch tickets, operating procedures, or other such written materials in lieu of affixing labels to individual stationary process containers, as long as the alternative method identifies the containers to which it is applicable and conveys the information required by paragraph (f)(6) of this section to be on a label. The employer shall ensure the written materials are readily accessible to the employees in their work area throughout each work shift. You can use any of the 3 labeling systems internally as long as it has been thoroughly communicated to employees.
    SHARPS CONTAINERS

    Q: What are the proper procedures for the disposal of sharps containers, how do you dispose of the container, and does anything need documented?

    A: The packaging and disposal of sharp materials contaminated by infectious agents or chemicals will follow a different route than non-contaminated materials. If the blades and sharps that you in particular are disposing are classified under non-contaminated, meaning they have not been in contact with any infectious materials or chemicals, they may be segregated and disposed of as recyclable or non-recyclable materials. These may go into the ordinary garbage that you use regularly. These sharps should be placed in a rigid, secondary container that will prevent penetration.

    If they are sharps that are contaminated by chemicals, they are to be disposed of as a Hazardous Waste with identification on the container outlining “Hazardous Materials.”

    If they are contaminated by infectious agents, they must be placed in in a rigid, puncture-resistant, leak resistant, sealable container specifically designed and manufactured for the disposal of sharps. They will also need to be labeled as sharps and with the international biohazard symbol. These containers can be purchased from safety supply companies or through University Stores. For disposal by Environmental Health & Safety, these containers will need to be placed in a red plastic bag with the international biohazard symbol on it and then placed in a biohazard shipping box.

    SHIPPING CONTAINER WITH OLD LABELS

    Q: Are we permitted to ship containers with the new safety data sheets but old HMIS labels?

    A: Yes, the labels are not required to be updated until December 1, 2015, so as long as the new safety data sheets are shipped with the containers, they would be in compliance.

    GHS COMPLIANCE DATES & DISTRIBUTOR QUALIFICATIONS

    Q: If we are a third-party warehouse that provides chemicals to other distributors and employers are we considered a distributor in terms of GHS and what compliance dates do we need to abide by?

    A: OSHA defines a distributor as “a business, other than a chemical manufacturer or importer, which supplies hazardous chemicals to other distributors or to employers.” Your status as a third-party warehouse would deem you responsible for shipping containers that are properly labeled with GHS labels to other distributors or employers. The chemical manufacturers and importers must also abide by these regulations. Unless you are repackaging the chemicals/materials into other containers, they should be properly labeled when they arrive at your facility. Also listed are the applicable GHS compliance dates.

    FORMALDEHYDE SIGN

    Q: Is there a certain sign we must post for Formaldehyde?

    A: OSHA requires the employer to establish regulated areas where the concentration of airborne formaldehyde exceeds either the TWA or the STEL and post all entrances and access ways with signs bearing the following legend:

    DANGER
    FORMALDEHYDE
    MAY CAUSE CANCER
    CAUSES SKIN, EYE, AND RESPIRATORY IRRITATION
    AUTHORIZED PERSONNEL ONLY

    CHEMICAL STORAGE

    CYLINDER STORAGE

    Q: Can compressed gas (argon 75%,carbon dioxide 25%) and nitrogen non flammable gases be stored with oxygen full or empty in the same place also can they be stored inside?

    A: Only fuel gasses need to be separated from Oxygen.  Argon, carbon dioxide, and nitrogen are not fuel gasses so they don't need to be separated and they can be stored inside.

    OXYGEN STORAGE
    Q: How thick does the partition wall have to been between cylinders?
    A: 1910.253(b)(4) states that oxygen cylinders in storage shall be separated from fuel-gas cylinders or combustible materials by at least 20 feet or by a barrier that is at least 5 feet high that has a fire-resistance rating of at least on half hour.  OSHA doesn’t reference the thickness of the barrier.  Only that it has to have a ½ hour fire-resistance rating.
    COMPRESSED GAS CYLINDERS

    Q: We currently house our compressed gas cylinders in a storage cage and we use an outside vendor for service.  We have no problems but we are interested in putting a lock on the storage cage.  Can we lock the storage cage the compressed gas cylinders are in to prevent the vendor or anyone else to come in and out as they please?  In other words, is there any OSHA regulation that states whether or not we can lock that storage unit?

    A: OSHA does not clearly state whether locks are permitted or not permitted on storage areas.  However, OSHA does state that the storage areas should be well-protected.  This includes being protected from tampering by unauthorized persons.  In the circumstance that you described locking the cage would be permitted and provide an added form of protecting the cylinders from tampering.  Below is the OSHA regulation pertaining to this issue.

    • 1910.253(b)(2)(ii) - Inside of buildings, cylinders shall be stored in a well-protected, well-ventilated, dry location, at least 20 (6.1 m) feet from highly combustible materials such as oil or excelsior. Cylinders should be stored in definitely assigned places away from elevators, stairs, or gangways. Assigned storage spaces shall be located where cylinders will not be knocked over or damaged by passing or falling objects, or subject to tampering by unauthorized persons. Cylinders shall not be kept in unventilated enclosures such as lockers and cupboards.
    FLAMMABLE LIQUID INSIDE STORAGE

    Q: How many drums of our resin, which is a class III flammable substance, are we allowed to store inside?

    A: The quantity of liquid that may be located outside of an inside storage room or storage cabinet in a building or in any one fire area of a building shall not exceed 120 gallons in containers or 660 gallons in a single portable tanks. The direct regulation can be found here, 1910.106(e)(2)(ii)(b).

    STORING OXYGEN CYLINDERS

    Q:  An empty and full oxygen tanks be stored together without fire wall?

    A:  Empty and full cylinders of oxygen can be stored together as long as they are either separated from all fuel-gas cylinders by either 20 feet or a noncombustible barrier (fire wall).

    CHEMICAL STORAGE

    Q:  Can acetylene be stored by propane without the fire wall between them?

    A:  Propane and acetylene are both considered to be a fuel-gas by OSHA and can be stored together.

    CHEMICALS

    STORING OXYGEN AND ACETYLENE

    Q: What are the requirements for storing oxygen and acetylene tanks inside a building?

    A: Inside of buildings, cylinders shall be stored in a well-protected, well-ventilated, dry location, at least 20 (6.1 m) feet from highly combustible materials such as oil or excelsior. Cylinders should be stored in definitely assigned places away from elevators, stairs, or gangways. Assigned storage spaces shall be located where cylinders will not be knocked over or damaged by passing or falling objects, or subject to tampering by unauthorized persons. Cylinders shall not be kept in non-ventilated enclosures such as lockers and cupboards.  (1910.253(b)(2)(ii))

    COMMON CLEANERS

    Q: Do I need an MSDS for common cleaners?

    A: It is a good idea to have them readily available.  However, an MSDS is not required as long as the cleaners are used in the workplace for the purpose intended by the chemical manufacturer or importer of the product, and the use results in a duration and frequency of exposure which is not greater than the range of exposures that could reasonably be experienced by consumers when used for the purpose intended  (1910.1200(b)(6)(ix))

    MSDS

    Q: Do I need a separate MSDS for each type of paint that is in their maintenance office.

    A: Yes, the MSDS for each paint needs to be readily available.

    CHEMICAL LABELS

    Q:  Do we have to label secondary containers?  If so, where can we find the information required on the label?
    A:  Unless the employee transferring the substance is in complete control of the container at all times, it would have to be labeled.  Minimal information required on the container would include the chemical/substance name, hazard categories and applicable ratings and target organs/personal protective equipment.  This information can sometimes be found on the original, manufacturers container or the material safety data sheet.

    KEEPING AN MSDS FOR CHEMICAL NO LONGER IN USE

    Q:  How long does a company need to keep the MSDS for chemical that is no longer used?

    A:  MSDS are considered “Employee Exposure Record” and must be kept on file for 30 years.

    COMPRESSED AIR

    TYPE OF AIR NOZZLE FOR AIR HOSE

    Q: What type of air nozzle do you need for your air hose that will let compressed air escape if the nozzle/gun is obstructed?

    A: Please see the following information:

    • Dead ended means that the airflow is restricted at the outlet.
    • The gun must have a relief device or air port within the system that will drop the pressure to under 30 psi if the air-system becomes dead ended.
    • The static pressure at the point of the blockage can be no more than 30 psi, which means that the downstream pressure of the air at the nozzle or opening of the gun will remain at a pressure level below 30 psi for all static conditions.
    • The use of compressed air for cleaning purposes at pressures greater than 30 psi is permissible, only if the outlet or source is fitted with a relief device that drops the pressure to less than 30 psi if the flow is dead ended.

    One example would be to find a tip designed to relieve pressure when dead ended or an air gun that already incorporates a safety relief tip.

    Always remember to check all hoses and connections before use to make sure components are not damaged or worn, and make sure the connections are secured. Make sure the air is turned off and the pressure is drained before changing tools.

    GAS CANS

    PROPER GAS CANS

    Q: Can we use Military Style ‘Gerry’ Gas Cans on jobsites?

    A: Some model ‘Gerry’ Cans may be acceptable if they have anti-spill and flame arrestor features.  If you are unsure if your gas can has these features, it is recommended that you purchase a new ‘safety can’ from a local supplier.

    GAS CYLINDERS

    COMPRESSED GAS CYLINDERS

    Q: If compressed gas cylinders are in use or set up for use do they require caps?

    A: No, 1910.253(b)(2)(iv) states that valve protection caps, where the cylinder is designed to accept a cap, shall always be in place, hand-tight, except when cylinders are in use or connected for use.

    GHS

    SDS COMPLIANCE

    Q: I am trying to find out what our responsibility is if a vendor/supplier still doesn’t have SDS forms that are GHS compliant. Are we supposed to find some other supplier?

    A: The short answer to your question on the SDS is no, you do not need to look for a new supplier. Manufacturers, distributors, and importers of hazardous chemicals are required to have their MSDSs changed over to the new, 2012 Hazard Communication Standard compliant SDS format by now. If you are maintaining an MSDS for a product received prior to June 1, 2015, you would be considered to be compliant with the Hazard Communication standard if the manufacturer, distributor or importer has not provided the new updated SDS version. You will want to document your attempts to obtain the updated SDS from the manufacturer, distributor or importer to show OSHA that you are doing all you can to obtain the SDS. Employers can also reach out to the local OSHA Area Office for assistance in obtaining the SDS.

    This link will take you to an OSHA Standard Interpretation that deals with this issue. I have also included the excerpt from the interpretation below that specifically explains your situation:

    Employers who are not manufacturers, importers, or distributers must maintain the most recently received version of the MSDS/SDS. An employer who is maintaining an MSDS for a product received prior to June 1, 2015, would be considered to be compliant with the Hazard Communication standard unless the manufacturer, importer or distributor has provided a new, HCS 2012-compliant SDS and the employer did not maintain the new SDS. Employers may contact manufacturers, importers or distributors of products they have previously ordered to request new SDSs, and under 29 CFR 1910.1200(g)(6)(iv), the SDS must be provided. If the manufacturer is located outside the United States, the contact would be made to the distributer or importer. If an employer has made a good faith effort to contact the importer or distributor and has still not received the SDS, the local OSHA Area Office may be contacted to provide assistance.

    IN-HOUSE LABELING OF CONTAINERS

    Q: If we are labeling containers internally, how must they be labeled? Do they need to have the six section GHS labeling?

    A: Under HazCom 2012, workplace labels are still performance based -- meaning OSHA doesn’t tell employers exactly what has to go on secondary container labels, but rather labels compliance by how well it does its job: effectively communicating hazards. OSHA says explicitly in the final rule on HazCom 2012, and elsewhere, that employers can continue to use their current workplace labeling systems as long as they effectively communicate to employees the hazards of the chemicals to which the workers are exposed.

    The standard goes on to say that if employers have their own system for labeling or use HMIS or NFPA systems, it can continue to do so, as long as the system provides workers with all of the health and physical hazards of the chemical. If employers choose to employ GHS elements like pictograms on the workplace label, the pictogram borders may have a black border rather than red as required on the shipped label.

    JUNE 1 GHS DEADLINE

    Q: Are we required by law right now to have SDS instead of MSDS on file?

    A: To answer your question, “are we required by law right now to have SDS instead of MSDS on file,” the answer is yes. OSHA implemented the GHS adoption timelines starting with its first deadline in December 2013 where employers were required to train their employees on SDSs, labels, and the GHS format. Throughout the transition period there were other deadlines for manufacturers, importers, and distributors. However as of June 1, 2016, all employers must be in full compliance with GHS. To be in full compliance with GHS means the following: •Hazard Communication program is updated to reflect the changes •All employees have been trained on new hazards identified during the reclassification process •Workplace labels are appropriately updated •All updated Safety Data Sheets have been obtained and easily accessible to employees

    GHS LABEL OBTAINED OUTSIDE U.S.

    Q: If our company purchases a hazardous chemical from another country who does not adopt the GHS labeling system, do we still have to ensure it is labeled according to GHS?

    A: Yes, even if the item is purchased from a country that has not adopted the globally harmonized system, you want to ensure you are protecting your employees by providing proper labeling.

    Employers may choose to label workplace containers either with the same label that would be on shipped containers for the chemical under the revised rule, or with label alternatives that meet the requirements for the standard. Alternative labeling systems such as the National Fire Protection Association (NFPA) 704 Hazard Rating and the Hazardous Material Information System (HMIS) are permitted for workplace containers; however, the information supplied must be consistent with the revised HCS.

    For example, hazard classifications must be revised as necessary to conform to the final rule, and the other information provided must be revised accordingly to ensure the appropriate message is conveyed. Moreover, since these alternative labels would, at a minimum, only provide the product identifier and "general" information regarding the hazards of the chemicals, the employer must also make "specific" information regarding the physical and health hazards of the chemical immediately available to employees through other means under the hazard communication program.

    HAZARD COMMUNICATION

    PROTECTING EMPLOYEES PERFORMING HOT WORK

    Q: How do you protect your employees who perform hot work on stainless steel?

    A: When your employees are welding on stainless steel, you are exposing your employees to a hexavalent chromium exposure. Initial air monitoring shall be completed. If Cr(VI) is used or generated in the workplace, the employer must monitor employee exposure to Cr(VI) to determine if any employee is being exposed to Cr(VI) in excess of the PEL: 5 µg/m3, as an 8-hour time-weighted average (TWA).

    There are several ways to reduce exposure to Cr(VI). Recommended controls vary from operation to operation. The preferred approach is to use engineering controls such as ventilation or equipment and process modification. If these controls are not sufficient, other controls may be implemented, including the use of respirators, eye protection, showering, and changing into street clothes before leaving the warehouse. It will also depend on how many days of the year your employees are welding on stainless steel and their exposure limit from the air monitoring for the applicable OSHA requirements.

    Training must be provided in accordance with this Hazard Communication Program.  Employees must be informed of any operations in their work area where Cr(VI) is present and be trained on the methods that may be used to detect Cr(VI) in the workplace, the hazards of Cr(VI), and measures employees can take to protect themselves from these hazards. Training must be sufficient to ensure that employees exposed to Cr(VI) can demonstrate knowledge of the requirements of the standards and the medical surveillance program required by the standard, including recognition of the signs and symptoms of adverse health effects that may result from exposure.

    SDS

    Q: Is it required to maintain old safety data sheets after you receive an updated version?

    A: Yes. All SDS’s must be retained for 30 years. An employer may keep record of the chemical used, where it was used and when it was used in the absence of the material safety data sheets.

    Visit our news page for useful OSHA related links and tools.

    JOBSITE

    CONTRACTORS RESPONSIBILITIES

    Q: When we install hard perimeter safety, does our company have the right to deny other trades, architects, and other third party individuals from entering our work area without an escort from our company, or participating in our safety course prior?

    A: You do have the right to escort or have personal go through your safety training prior to them entering the area that you have installed perimeter safety. This is recommended as a best safety practice. Also, if using a ladder to gain access to this area they must also get permission prior to use. We highly recommend documenting the safety training if you choose this method.

    MSDS

    REQUEST FOR MSDS

    Q: A customer wants a copy of our MSDS sheet, but the MSDS sheet doesn’t list our name, can I still send a copy over to them?
    A: Yes, the information on steel slag will be the same.

    OXYGEN AND ACETYLENE

    OXYGEN & PROPANE TANK STORAGE

    Q: Can oxygen tanks be stored near a propane tank?
    A: No, 1926.350(a)(10) reads, "Oxygen cylinders in storage shall be separated from fuel-gas cylinders or combustible materials (especially oil or grease), a minimum distance of 20 feet (6.1 m) or by a noncombustible barrier at least 5 feet (1.5 m) high having a fire-resistance rating of at least one-half hour."

    OXYGEN AND ACETYLENE

    Q: Can oxygen and acetylene tanks sit on the same cart if they are connected for use?

    A: Yes, as long as the tanks are connected for use they may sit on the cart together. It is only when they are being stored that they cannot be together.

    TRANSPORTING ACETYLENE AND OXYGEN

    Q: When transporting acetylene and oxygen tanks in the back of a pickup truck what regulations do I have to follow?  Do they need to be separated?  What about if some are full and some are empty?

    A: OSHA’s requirements for transporting, moving, and storing compressed gas cylinders are below:

    • 1926.350(a) Transporting, moving, and storing compressed gas cylinders.

    o   1926.350(a)(1) Valve protection caps shall be in place and secured.

    o   1926.350(a)(2) When cylinders are hoisted, they shall be secured on a cradle, slingboard, or pallet. They shall not be hoisted or transported by means of magnets or choker slings.

    o   1926.350(a)(3) Cylinders shall be moved by tilting and rolling them on their bottom edges. They shall not be intentionally dropped, struck, or permitted to strike each other violently.

    o   1926.350(a)(4) When cylinders are transported by powered vehicles, they shall be secured in a vertical position.

    o   1926.350(a)(5) Valve protection caps shall not be used for lifting cylinders from one vertical position to another. Bars shall not be used under valves or valve protection caps to pry cylinders loose when frozen. Warm, not boiling, water shall be used to thaw cylinders loose.

    o   1926.350(a)(6) Unless cylinders are firmly secured on a special carrier intended for this purpose, regulators shall be removed and valve protection caps put in place before cylinders are moved.

    o   1926.350(a)(7) A suitable cylinder truck, chain, or other steadying device shall be used to keep cylinders from being knocked over while in use.

    o   1926.350(a)(8) When work is finished, when cylinders are empty, or when cylinders are moved at any time, the cylinder valve shall be closed.

    o   1926.350(a)(9) Compressed gas cylinders shall be secured in an upright position at all times except, if necessary, for short periods of time while cylinders are actually being hoisted or carried.

    o   1926.350(a)(10) Oxygen cylinders in storage shall be separated from fuel-gas cylinders or combustible materials (especially oil or grease), a minimum distance of 20 feet (6.1 m) or by a noncombustible barrier at least 5 feet (1.5 m) high having a fire-resistance rating of at least one-half hour.

    o   1926.350(a)(11) Inside of buildings, cylinders shall be stored in a well-protected, well-ventilated, dry location, at least 20 feet (6.1 m) from highly combustible materials such as oil or excelsior. Cylinders should be stored in definitely assigned places away from elevators, stairs, or gangways. Assigned storage places shall be located where cylinders will not be knocked over or damaged by passing or falling objects, or subject to tampering by unauthorized persons. Cylinders shall not be kept in unventilated enclosures such as lockers and cupboards.

    OSHA doesn’t specifically address the transportation of oxygen and acetylene together.  It’s our recommendation to transport them separately since they are supposed to be stored separately.  Also, OSHA doesn’t consider tanks to be empty since they will usually still contain a small amount of the gas.  You will want to treat the “empty” tanks the same as full tanks.

    Finally, due to OSHA’s limited information on transporting the tanks we recommend also checking with the Department of Transportation.  The DOT’s requirements are out of the realm of our expertise, but the following link has some of the requirements that you might have to follow: click here.

    PAINTING BOOTH

    RETRACTABLE AIR LINE IN PAINTING BOOTH

    Q: If we install a retractable air hose reel inside the paint booth on the wall would this be a possible violation?

    A: I have found that as long as the air compressor pump that is attached to the retractable air hose reel is stored outside of the spray booth, you would not be in violation. OSHA states that all electrical equipment must be stored outside of the paint booth, due to fire hazard.

    • 1910.107(i)(4) - Electrical support equipment. Transformers, powerpacks, control apparatus, and all other electrical portions of the equipment, with the exception of the handgun itself and its connections to the power supply shall be located outside of the spraying area or shall otherwise conform to the requirements of paragraph (c) of this section.
    • 1910.107(j)(4)(ii) - During spray operations, the drying apparatus and electrical connections and wiring thereto shall not be located within spray enclosure nor in any other location where spray residues may be deposited thereon.

    PROPANE

    PROPANE TANK DISTANCE FROM BUILDING

    Q. How far away from a building does a 1000 gallon Propane tank need to be, according to OSHA?

    A. A propane tank with anywhere between 500 gallons up to 2000 gallons needs to be kept at least 25 feet from the building. 1910.110(b)(6)(ii)

     SDS

    SDS LOG ON JOBSITES

    Q: Do I need to keep a master copy of my SDS log on every jobsite?

    A: As long as the SDSs for hazardous chemicals that are being used on that site are available, a master SDS log does not need to be onsite.

    -1910.1200(b)(4)(ii) Employers shall maintain copies of any safety data sheets that are received with incoming shipments of the sealed containers of hazardous chemicals, shall obtain a safety data sheet as soon as possible for sealed containers of hazardous chemicals received without a safety data sheet if an employee requests the safety data sheet, and shall ensure that the safety data sheets are readily accessible during each work shift to employees when they are in their work area(s)

    SDS FOR INK AND TONER?

    Q: Do we need an SDS for printer ink/toner?

    A. Yes, you want to make sure to have an SDS (Safety Data Sheet) for all chemicals which does include printer ink and toner.

    SWITCHING FROM MSDS TO SDS

    Q: When do we have to have all documentation in changed over from MSDS to SDS?

    A: You are required to have all documentation by December 1, 2015.

    Contact us for more information on how to comply.

    UPDATING THE MSDS

    Q:  Should I scan the MSDS and keep a digital copy?  Also, how long must we keep them for?

    A:  You could keep a digital copy.  Old MSDS should be treated like medical records and be maintained for 30 years.

    MSDS

    Q:  Do our jobsites need a copy of the MSDS?  I thought that we as a company needed 1, as long as we produce the binders within 24 hours.

    A:  There is nothing in the Hazard Communication standard that allows an employer 24 hours to produce an MSDS.  I have highlighted the key words: “readily accessible” and “immediately” as indicators that the best safety practice would include having an MSDS for each solid, liquid, and gas chemical readily available at each worksite.  Also notice that it is the employers duty to provide an MSDS to OSHA if requested to do so (see 1910.1200 (g) (11) below.

    1910.1200(g)(8)

    1910.1200(g)(8)  The employer shall maintain in the workplace copies of the required material safety data sheets for each hazardous chemical, and shall ensure that they are readily accessible during each work shift to employees when they are in their work area(s). (Electronic access, microfiche, and other alternatives to maintaining paper copies of the material safety data sheets are permitted as long as no barriers to immediate employee access in each workplace are created by such options.)

    1910.1200(g)(9)  Where employees must travel between workplaces during a work shift, i.e., their work is carried out at more than one geographical location, the material safety data sheets may be kept at the primary workplace facility. In this situation, the employer shall ensure that employees can immediately obtain the required information in an emergency.

    1910.1200(g)(10)  Material safety data sheets may be kept in any form, including operating procedures, and may be designed to cover groups of hazardous chemicals in a work area where it may be more appropriate to address the hazards of a process rather than individual hazardous chemicals. However, the employer shall ensure that in all cases the required information is provided for each hazardous chemical, and is readily accessible during each work shift to employees when they are in in their work area(s).

    1910.1200(g)(11)  Material safety data sheets shall also be made readily available, upon request, to designated representatives and to the Assistant Secretary, in accordance with the requirements of 29 CFR 1910.1020(e). The Director shall also be given access to material safety data sheets in the same manner.