The OSHA standards
related to their workplace poster are contained in section 1903.2 of the regulations. And right off the
bat you will see paragraph 1903.2(a), which requires the Federal OSHA poster be displayed at each establishment “in a conspicuous
place or places where notices to employees are customarily posted.” That
usually can be achieved by placing it on the wall in the break room or on the
employee bulletin board next to the time clock.
But what are you
supposed to do if you have employees that do not actually work at your facility,
but instead report directly to some other location such as a construction site?
According to paragraph 1903(b)(2), where employers are engaged in activities which
are physically dispersed, such as agriculture, construction, transportation,
communications, and electric, gas and sanitary services, the OSHA poster must be
displayed at the location to which those employees report each day. That is why
you often see OSHA posters displayed at office trailers at construction sites. The
standard goes on to say that where employees do not usually work at, or report
to, a single establishment, such as some traveling salesmen, technicians,
engineers, etc., the OSHA poster must be displayed at the location from which
the employees operate to carry out their activities. So make certain you have
the OSHA poster displayed at each location required by the standard.
One other requirement
that many people have never read is the last sentence of paragraph 1903(a), the
one saying you must take steps to insure that your OSHA posters are not “altered,
defaced, or covered by other material”. That means no more company memos about
important upcoming events like the company picnic stapled over the top of the
OSHA poster! You should occasionally
conduct inspections to make sure your OSHA posters are clearly visible,
unencumbered, and free from damage, and replace them if and when necessary. A
good idea I see implemented at several workplaces is to place the postings in a
display case or bulletin board behind a clear Plexiglas cover.
During some site
inspections, I have seen where the employer printed a copy of the OSHA poster
off the OSHA website onto a standard piece of copy paper (8.5” by 11”) for
display at their worksite. However, doing so would be a violation of 1903.2(a)(3),
which mandates the poster be printed on paper measuring at least 8.5” by 14”;
that standard also addresses details such as minimum font sizes . . .
And what about you
employers located in those states operating their own State OSHA program?
Paragraph 1903(a)(2) requires you to display the State version of the OSHA
poster in those workplaces covered by a state-run OSHA program. But pay careful
attention, because there are many workplaces located within states that have implemented
a State OSHA program which still fall under the jurisdiction of Federal OSHA; in
those cases, the Federal OSHA poster would still need to be displayed. If you
are uncertain about which OSHA program (state or federal) has jurisdiction over a
particular workplace, re-visit our earlier post to this blog addressing that
topic (click here).
Last but not least,
what are you required to do if you have employees who do not read or speak
English? According to an OSHA letter of interpretation addressing that very
question (click here to see the letter),
the standard requires employers to post the OSHA poster which is available in
English, but does not specify or require that the notice be posted in a foreign
language. However, that letter goes on to explain that OSHA encourages
employers that have Spanish-speaking workers to post an additional poster in
Spanish, which is available on the OSHA website or through private vendors (click here).
In fact, OSHA recently added a version of their poster printed in Polish (click here) and Portuguese (click here) to their website. And some of the state-OSHA websites have versions of their
posters available in many other exotic languages (click here) on their
websites.
As you can see, there is
more to compliance with the OSHA workplace notification standards that just
sticking a poster up on a bulletin board and forgetting about it. You must make
sure you have the correct version of the poster displayed (federal or state
OSHA), make certain posters are displayed at all sites where off-site workers
report, ensure the poster meet minimum size requirements specified by OSHA, and
maintain your posters so they are legible and visible at all times. And where
feasible, you are also encouraged to display OSHA posters in languages familiar
to your workforce.
If you need a resource
offering comprehensive Labor Law Posters that include up-to-date versions of the
OSHA notices for federal and state OSHA programs available in English and
Spanish, visit our sister website (click here).
And if you’d like to
share with our readers your stories or
experiences related to your OSHA posters, please provide that information in
the “comments” section below. And last but not least, please pass a link to this blog post along to
others in your network who you think may benefit by this information.
Great Stuff - I have several people working from home though, did you happen to find any guidance on what I need to do for them?
ReplyDelete-Eric
Eric. Good question. I've not seen any official word on that exact topic. OSHA issued a memorandum in 2000 saying they would not inspect the homes of workers who operate independently out of their homes. My recomendation in the past has always been to 1) make sure you posted a copy of the poster in the office their boss works out of, and 2) present a copy to worker at orientation for their records. Letr me know if you are aware of any other strategies.
ReplyDeleteThank you for these great strategies. Meeting all the requirements can be a bit stressful. By that how any training should be. OHSA is slowly killing my ambition.
ReplyDeleteMaybe post on company intranet site?
ReplyDeleteWhat if you have 3 office trailers at the same site one for safety one for admin and one for a sister company that is union and meets there at the union office? Do I need 3 postings?
ReplyDeleteChad, you must post it at a place where employee postings are customarily placed. So even if the union has its own trailer, the posting at the employer trailer may be okay as long as that is a place the workers are accustomed to finding such postings. If not, then posting at all the sites may be needed.
DeleteGood info, but we do not have construction trailers. Our employees drive from their home directly to the construction site, or multiple sites during the day. They do not report to the office or the shop. We do have foreman on most of the jobs, but not always. Where do you suggest we post?
ReplyDelete