Monday, December 1, 2014

Goodbye 2014

Every couple of years, I take time away from blogging about a particular OSHA topic during the month of December so I can rest and recharge. Instead of doing my "real" work, I try and spend a little more time with my family, travel somewhere fun, and take lots of naps. This is one of those Decembers.

I do plan on coming back strong next year, and it sounds like OSHA will give us plenty of things to discuss. Things will get started fast with the release of the new OSHA injury reporting rules, as well as planned releases of their new confined space standard for construction (only been 30 years in the making) and walking/working surfaces standard.

My thanks to all our great readers for supporting the OSHA Training Blog. Happy Holidays, and a prosperous 2015! - Curtis

Saturday, November 1, 2014

Commonly Asked Questions About Portable Fire Extinguishers

November 1, 2014 - It’s been a little over a year since I posted a blog explaining Federal OSHA’s requirements to provide education and training on portable fire extinguishers to workers when there are extinguishers available for their use. Since that time, some readers have emailed me with other questions about extinguishers; the same questions that come up quite often when I conduct mock-OSHA inspections.  While I could probably ramble on trying to answer fifteen or twenty recurring questions today, I decided to post answers to five commonly-asked questions about portable fire extinguishers in my blog.
  • How high above the floor does OSHA require portable fire extinguishers to be mounted?   Federal OSHA standard 1910.157(c)(1) simply states that the employer “shall mount” portable fire extinguishers so they are accessible to employees; there is no height requirement listed. However, in OSHA’s . . . 
 
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Wednesday, October 1, 2014

OSHA Regulations on Use of Cell Phones at Work

I got my first cell phone way back in the 1980’s, when they were a very unusual (and expensive) novelty. Now it seems that a smart phone is a “must have” for every person over the age of 10. But I am still shocked every time I see somebody either talking on their cellphone or using it to send or read text messages and emails while at work.
 
I’m not talking about those people who are sitting at a desk or standing behind a sales counter (although it aggravates me to no end to be ignored by a sales rep who is busy with their phone); my concern is for those workers I have witnessed during safety audits who are chatting away or typing a text message into their cell phone while performing relatively complex tasks such as . . .
 
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Monday, September 1, 2014

Are You TRULY Done With Aerial Lift Operator Training?

Let’s address one of those topics that a lot of people never think about until it is too late. And that is training for operators of aerial lifts of all types (boom-lifts and scissor-lifts) required per applicable OSHA and/or ANSI standards. I find that most employers do provide training for their lift operators on the function of the equipment’s controls. But I’m not talking about training just for the operator running the controls in the basket or work platform, I’m talking about ALL operators. Before I explain the specific problem I run across too often, it might help if I first recap the two different sets of controls available on most types of aerial lifts.

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Friday, August 1, 2014

Common Questions About Personal Protective Equipment

Last month’s post focused on appropriate (and inappropriate) personal protective equipment (PPE) for head protection. That brought up a couple of commonly-asked questions about other types of PPE that I thought I would go ahead and address.

Question # 1 – Are safety glasses required to be worn beneath face shields?

OSHA requirements for eye protection can be found in either 1910.133 for general industry workplaces, 1926.102  for construction sites, or 1915.153 for shipyard employment.  It seems we sometimes forget that each of these sections of the OSHA regulations cover eye AND face protection, or even worse, we forget to differentiate between the two types of safety gear.
 
Standard safety glasses are designed to protect against injuries associated with regular eye hazards such as flying or falling objects and particles, as well as some chemical and/or radiation hazards. However, in some work operations . . .
 
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Tuesday, July 1, 2014

Workers Using Inappropriate PPE? Perhaps Not

Have you ever experienced this? You're in a training class and the instructor brings up a certain topic, then all of the sudden the room becomes electrified! All of the trainees are sitting on the edge of their seats because they have a lot of pent-up questions and/or uncertainties about that topic. And now that the floodgates are opened, they can’t wait to ask their question or voice their concern. It really is something special to experience.
 
This happened to me recently while conducting an OSHA 10-hour construction class for a group of professionals in the cellular communications industry. The group consisted mostly of project managers, engineers, and construction managers associated with one of the major wireless networks, who as part of their duties would always set aside some time when they visited their cell tower sites to evaluate the safety performance of workers. The topic I had just brought up was head protection, no sooner had I put up my PowerPoint slide showing a hard hat when almost every hand in the room shot up and people started shouting out their questions. This topic had obviously struck a nerve with this particular group.
 
It seems that some of the sub-contract workers who climb their cell towers were not wearing traditional hard hats. One trainee said he recently saw some of those workers wearing  .  .  .  .  .
 
  

Monday, June 2, 2014

Leading Workplace Hazard? Government Bureaucracy!

An organization here in the United States became aware many years ago that there was a serious safety hazard injuring and even killing workers; a lot of workers! They estimated there had been more than 950 workers seriously injured every year due to this particular hazard, and it also resulted in six or more fatalities occurring every year. This organization has come up with a solution to prevent the vast majority of these injuries and fatalities, yet they have still not implemented this solution after several years. So the hazard goes unabated while a high number of workers continue to suffer and even die.
  
You would expect OSHA to step in and force the organization to implement as fast as humanly possible the solution needed to prevent these horrible injuries and fatalities. And it wouldn’t surprise you if OSHA issued one of their “press releases” to try and shame the organization into making the changes needed to stop this carnage. Unfortunately, OSHA is not the solution in this scenario; they (as part of a broken rule-making process) are actually a part of the problem.

The particular hazard I am speaking of . . .

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Friday, May 2, 2014

Would You Tell OSHA to Go Get a Warrant to Inspect Your Site?

Would you consent to a search of your entire household by a police officer who got a complaint about your barking dog but decided he wanted to poke his nose in all your closets and drawers to determine if you were breaking any other laws? I bet most of you would not consent to the search because you are aware of your constitutional protection against unreasonable search and seizure without probable cause. Well, that same protection applies to the workplace too.
  
Many people do not realize that a company has the right to tell OSHA to get a warrant before being allowed to conduct an inspection on their site. In fact, the Supreme Court ruled in the case of Marshall v. Barlow's, Inc. in 1978 that OSHA may not conduct warrantless inspections without an employer's consent. OSHA may however, inspect the site after acquiring a judicially authorized search warrant based upon administrative probable cause (like the random selection of a company covered under one of the national emphasis programs) or upon evidence of a violation (such as a valid employee complaint).
 
So why would a company tell OSHA they must get a warrant to inspect?  The “benefits” of doing so could include . . . . .     
    
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Tuesday, April 1, 2014

Clarification of OSHA Requirement to Conduct Periodic Inspections of the Lockout Tagout Procedure


One side benefit of conducting numerous OSHA training classes and mock-OSHA inspections every year is that I get an opportunity to pick up on trends where employers and employees seem to be struggling to comply with certain OSHA standards. So in this month’s post, I want to discuss one specific part of OSHA’s standard for The Control of Hazardous Energy (also known as the Lockout/Tagout standard) where, more times than not, the requirements of the standard are not being met.
The specific section of the Lockout/Tagout (LOTO) standard I am referring to in this post is paragraph 1910.147(c)(6)(i), which requires employers to “conduct a periodic inspection of .  .  . 
 
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Sunday, March 2, 2014

OSHA Fall Protection Requirements - Construction

This month I provide a non-exhaustive overview of the different thresholds for fall protection found throughout the Federal OSHA 1926 construction standards. This is in contrast to last month’s discussion of the 1910 general industry standards, which required some form of fall protection for employees working at heights ranging from ground level all the way up to 24 feet. As you will soon see, the construction regulations are even more varied.
  
Most people are quite aware that Subpart M of the Federal OSHA 1926 Construction standards mandates the utilization of some form of fall protection device or practice to protect workers from falls of greater than six (6) feet. In fact, you will find fifteen distinct ways that a worker can fall covered in section 1926.501, titled “Duty to have fall protection”. And the allowable methods specified for fall protection devices and practices listed in this Subpart go well beyond merely installing a standard guardrail; other allowable methods include installation of a safety net system, as well as using a personal fall arrest system, body positioning devices, covers, fences, barricades, warning lines, controlled access zones, and a safety monitor system, and even a written fall protection plan. However, be warned that many of these fall protection methods are only allowed in certain situations . . .
    

Saturday, February 1, 2014

OSHA Fall Protection Requirements - General Industry

 
When I conduct OSHA 10 and 30-hour training classes, most students seem to know that Federal OSHA requires some form of fall protection for employees working at heights greater than four (4) feet in General Industry (1910), and at heights over six (6) feet in Construction (1926). However, many of them are unaware that there are numerous other OSHA standards requiring fall protection at other heights; some are lower, some are higher, and some only apply (or do not apply) in certain situations.
 
So in this month's blog I decided to provide an overview of the most prevalent Federal OSHA 1910 General Industry standards requiring some form of fall protection when employees are working at various heights (next month I'll list the 1926 Construction standards) so that, should you come across one of these scenarios, you'll be up to speed on the actual OSHA requirements.
 

Thursday, January 2, 2014

OSHA Annual Refresher Training Requirements


Can you believe that 2014 is here already? It seems like only yesterday we were all worried about a Y2K-triggered meltdown of our computer systems. And while that non-event passed us by many years ago without so much as a fizzle, there is one other issue that does require your full attention each and every year; identifying OSHA standards that require mandatory annual refresher training for employees.
  
Most everyone who has visited our website knows that we have place links to excerpts of all Federal OSHA references to OSHA training in General Industry and Construction standards; we even referenced indirect phrases such as “the employer shall inform employees” or “competent person” which can imply some level of mandatory training or information. These pages get hundreds of views every day, and are a great resource to help identify your overall OSHA training requirements.
  
But since we are here at the beginning of a brand new year, I thought it might also be helpful to our readers if I went back through all of those standards and pulled out the ones that specifically require employers to provide their workers with mandatory refresher training and information annually and make a table that lists them in this month’s blog post. 
  
So here is my list of Federal OSHA standards that specifically mandate annual OSHA refresher training:
 
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