Submit Your Ideas and Suggestions, Please!

When I started writing this OSHA Training Blog a few years ago, my mind was full of ideas for things to write about; that was 60 posts ago.  Now I am starting to run out of good ideas for things to write about (tells you a little something about the capacity of my brain, huh?).

Do you have an idea or suggestion for a topic to cover in this blog?  Obviously, it needs to be OSHA related. Also, the topic should not be too specific in scope - like Nevada OSHA rules for using left-handed monkey wrenches in underground tunnels . . .  Just submit your suggestion (and any comments you want) in the "COMMENTS" section below.

While we are at it, I am also soliciting suggestions for future OSHA training toolbox talks that we post free every month. The last one for 2015 finishes up our series on Lockout/Tagout, and I will need a new topic to focus on for the next 6 to 12 talks starting January 1, 2016.  So please, add you suggestions for toolbox talks in the COMMENTS section below, too.

Let me close by saying "Thank You" to everyone who reads the blog, and especially those who send emails and post comments. You make me feel creating these resources is worth the effort.

HAPPY HOLIDAYS!!!

Curtis Chambers

OSHA Penalty Caps are Increasing - Significantly!

With the stroke of a pen, President Barack Obama will sign into law on Monday (11/02/15) the Bipartisan Budget Act of 2015. This means no more squabbling for the next two years about shutting down the government by threatening to withhold passage of the federal budget. Additionally, the White House claims this bill, which increases government spending and debt limits, will stimulate the nation’s economy. But nothing comes for free; passage of this Act also means your OSHA penalties will be going up – significantly!

 

Many people mistakenly believe that employers pay monetary penalties attached to federal OSHA citations directly to OSHA, making them a self-funded agency. But that is not true. The monies actually go . . .

  

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Significant (and Overlooked) Facts About OSHA's New Confined Spaces in Construction Standard

When OSHA issued their new “Confined Spaces in Construction” standard (29 CFR 1926, Subpart AA) earlier this year, they announced that there were a “few” key differences in this new rule as compared to their 1910 general industry standard for permit-required confined spaces. And as always when OSHA issues a new standard, I tear it apart and analyze it frontwards and backwards to find the “hidden” things that employers cannot afford to overlook. And there are some doozies hidden within this new confined space in construction regulation! So I thought I’d address one of the most significant (and overlooked) revelations about this new standard . . .

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Does OSHA's HazCom Standard Prohibit NFPA / HMIS Labeling Systems?

It seems like once every week or two I get a call or email from someone asking me if I’d help clarify for them OSHA’s requirements on labeling of in-house containers and secondary containers per the revised Hazard Communication standard. Apparently many people think that OSHA now requires all in-house containers be labeled with the pictograms and other information adopted from the Global Harmonized System of Classification and Labeling of Chemicals (GHS), and that OSHA no longer allows the use (some even say they “outlaw” the use) of other hazard labeling systems such as those created by the National Fire Protection Association (NFPA) and the Hazardous Materials Identification System (HMIS).
 

In actuality, it is only those containers shipped by manufacturers, importers, and distributors that are required by OSHA’s updated Hazard Communication standard to be labeled with all the GHS-related information (specifically, a product identifier, signal word, hazard statement(s), pictogram(s), precautionary statements, and the name, address, and telephone number of the chemical manufacturer, importer, or other responsible party). But when it comes to labeling of in-house containers . . .

 

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Does OSHA Require Daily Toolbox Talks?

Every once in a while I am retained by one of the parties to a lawsuit to be an “expert witness”. This involves reviewing evidence and offering my opinions in the case. As part of a recent case where I was retained by the defendant, the attorney for the Plaintiff who was conducting my deposition asked me to show him the “OSHA-required documented proof that the defendant conducted mandatory daily toolbox talks”.  It was obvious he did not like my answer.

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OSHA Lockout/Tagout Standard and Motor Vehicles

One area where the OSHA lockout/tagout standard is commonly thought not to apply is when we work on our cars, trucks, and other vehicles powered by internal combustion engines. But to overlook these types of equipment would be wrong, as it could lead to an injury, or even death!

Employees performing service or maintenance on vehicles powered by internal combustion engines are exposed to . . .

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Do Employees REALLY Have "Occupational Exposure"?

It happens more times than I care to admit.  I’m teaching an OSHA 30 hour class or conducting a mock-OSHA inspection and we are covering the topic of OSHA’s Bloodborne Pathogens (BBP) standard. Someone participating in the audit or attending the class says “Everybody at our facility is covered by the OSHA Bloodborne Pathogens standard”. Or, conversely, someone will say “Not a single person at our facility is covered by this standard”.  More times than not, neither statement is true.

 

Inclusion in an OSHA-compliant BBP program is based on one thing; an employee has “occupation exposure” to blood or some other potentially infectious material. The key is to understand the . . .

 

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Two Recent OSHA Changes; Do They Require Action On Your Part?

When OSHA makes a change, that usually means the employer must do something in response, be that write a new program, train workers, or post notifications. But one recent OSHA changes does not require the employer to take action even though you may think it does, and another requires you to take action even though you were previously told you don’t have to do anything! Confused? Read on . . .
 
New Workplace Notification . . . . .  

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OSHA’s Newest Inspection Strategies – Will They Back-fire?

As is the case with most other government agencies, people like to complain about the Occupational Safety and Health Administration (OSHA). Employers grumble about new or revised OSHA standards that are not clear and concise, “sneaky” inspectors, and undeserved citations. Workers sometimes gripe about having to follow strict safety procedures required by OSHA that they feel slows them down or makes their jobs more difficult. And safety professionals often protest when OSHA “changes the rules” by issuing a directive or letter of interpretation that seems to change (or greatly expand) their previous position on a topic.

 

But lately what I hear complaints about most often are OSHA’s efforts to implement new and unconventional approaches to getting into the door of businesses and organizations to inspect . . .

 

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Four Little Words Too Many Employers Overlook

“Objective information or data”.  At first glance, these four little words plucked from a passage in the middle of OSHA’s respiratory protection standard are easy to overlook or misinterpret. But any employer who fails to carefully read and understand what is required to comply with 1910.134(d)(3)(iii)(B)(2) will not only be setting themselves up for an OSHA citation with a hefty penalty, they might also be putting the health and safety of their workers at risk!
 
This section of the Federal OSHA respiratory protection standard applies when there is . . .

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Tips To Better Engage Students During OSHA Training

After conducting so many OSHA training sessions over 30 years, one tends to figure out what keeps the students’ attention, as well as what puts them to sleep.  So I thought I would share two simple training tactics that I have found consistently keeps students strongly engaged during classroom training sessions.

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Respiratory Protection Program - Annual Reviews

It’s often said that the devil is in the details, and that could not be truer than when it comes to the requirements of some of OSHA’s comprehensive health and safety standards. In fact, there are several OSHA standards that actually require affected employers to conduct annual program reviews, including the OSHA respiratory protection standard (see requirement at 1910.134(l)(1) and (2). Therefore, I am going to start off this New Year by outlining the problems most commonly identified when I assist employers with their annual respiratory protection program reviews.

Facial Hair – OSHA standard 1910.134(g)(1)(i)(A) states that employers “shall not permit respirators with tight-fitting face-pieces to be worn by employees who have facial hair that comes between the sealing surface of the face-piece and the face . . .”.  Unfortunately, this language is very subjective, and employers often . . .
  

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