Friday, May 1, 2015

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

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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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32 comments:

  1. I appreciate your blogs! I'll be sharing this with my clients. NOTE to other readers: Even though California has CalOSHA, changes in the Federal regulations that are more stringent will prevail until CalOSHA updates theirs. That's the same with any other State OSHA. Curtis - YOU ROCK!

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  2. Curtis, Thanks for the information. I am in safety but will make sure my MOSH IH counterparts know of the confined space information.

    Thanks for the information about the OSHA Posters.

    Richard Heiser
    MOSH Consultation Services

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  3. Love your posts Curtis! Informative and intelligently written with a touch of humor...evidence of hard to find skill sets in a safety professional!-) Please continue to share.

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  4. I am another who appreciates reading what you've taken the time to research and present. Keep up the good work! (Please!!!)

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  5. Don't stop writing! I am ashamed to admit this is the first time I have written in the comments section and I should have thanked you many times in the past. I also may have been inadvertently circumventing your sharing data because I always just copy and email the link instead of using the page tools or social media buttons.

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  6. Yes, please the blog going. I'm a big fan of your comments and writing style. I haven't been consistently receiving email notifications and if others have experienced the same, that might be the reason for the drop in responses. Keep it up, Curtis

    Ken W.

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  7. Curtis, even thought we don't comment, we read and share your posts. Sometimes long after they are posted. Keep up the good work.

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  8. Your blogs are very helpful and always an informative read. Please keep it up! I have shared your posts in the past and this one will be shared as well. Thanks!

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  9. Your comments and updates are very much appreciated. I use them in keeping my clients up to date.

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  10. I enjoy your blog. Just barely have enought time to read the blog and digest and Usually no time to actually respond. It is helpful. Thanks. Deb

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  11. Keep on sending the updates Curtis. I will also say that I am not one to comment but that does not mean I am not reading your posts. Keep it up and thanks a million for your time on these issues.

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  12. Great blogs, please don't stop the posts!!

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  13. I read your updates all the time, but I don't usually comment. THANK YOU for putting these together as they really do help me understand OSHA changes even better. I am always excited to get your monthly email to find out what I can learn to make myself a better EHS Professional. Thanks again - please keep it going!

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  14. Your monthly blog helps me to keep up with OSHA guidance and compliance. Keep up the information dissemination to help the EHS world.

    Thanks. Joe M.

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  15. Curtis, keep up the good informative work that you do for all of us!

    Kind Regards,

    Chris

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  16. Keep up the good work Curtis!
    Dennis E. Parnell, MESH
    MJ Price Construction Co., Inc.

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  17. Thanks Curtis, keep up the good work!

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  18. You work is well received even though I have never commented before.

    Thanks

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  19. Keep writing these blogs, don't stop. I always use your information to pass along to my colleagues globally.

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  20. Thanks for the updates.

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  21. Curtis,
    I was aware that significant changes were being implemented, and had done some internet research in an effort to see if anyone had done comparison of the new and old standards. I was glad to see your post. Is this the only change from the old standard or is there more?
    R. Saizan

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    1. Rick.

      According to the OSHA FAQ page for this new standard, there are 5 key differences from the construction rule, and several areas where OSHA has clarified existing requirements. The five new requirements include:

      1.More detailed provisions requiring coordinated activities when there are multiple employers at the worksite (for more detail, see question below). This will ensure hazards are not introduced into a confined space by workers performing tasks outside the space. An example would be a generator running near the entrance of a confined space causing a buildup of carbon monoxide within the space.

      2.Requiring a competent person to evaluate the work site and identify confined spaces, including permit spaces.

      3.Requiring continuous atmospheric monitoring whenever possible.

      4.Requiring continuous monitoring of engulfment hazards. For example, when workers are performing work in a storm sewer, a storm upstream from the workers could cause flash flooding. An electronic sensor or observer posted upstream from the work site could alert workers in the space at the first sign of the hazard, giving the workers time to evacuate the space safely.

      5.Allowing for the suspension of a permit, instead of cancellation, in the event of changes from the entry conditions list on the permit or an unexpected event requiring evacuation of the space. The space must be returned to the entry conditions listed on the permit before re-entry.

      In addition, OSHA has added provisions to the new rule that clarifies existing requirements in the General Industry standard. These include:

      1.Requiring that employers who direct workers to enter a space without using a complete permit system prevent workers’ exposure to physical hazards through elimination of the hazard or isolation methods such as lockout/tagout.

      2.Requiring that employers who are relying on local emergency services for emergency services arrange for responders to give the employer advance notice if they will be unable to respond for a period of time (because they are responding to another emergency, attending department-wide training, etc.).

      3.Requiring employers to provide training in a language and vocabulary that the worker understands.

      Finally, several terms have been added to the definitions for the construction rule, such as "entry employer" to describe the employer who directs workers to enter a space, and "entry rescue", added to clarify the differences in the types of rescue employers can use.

      Hope this helps. CC

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    2. Ditto the above comments - I read the stuff you send out, but typically do not post comments. Thanks for all you do. ~Angela

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  22. Curtis, unfortunately I really enjoy your posts. So please don't stop. You present the information in a clear and concise manner that I enjoy. Thanks for working hard to help make us better!

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  23. I find some of your posts helpful, please continue. We have ordered our new OSHA posters. You should also make your comments button larger. It took me a little while to find it. Others may be having the same problem and as a result are not submitting comments.

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  24. Yes, I read every one. Many of them contain insights I had not thought of. Really - good job. Keep it up.

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  25. Curtis, please keep writing, your posts are particularly more valuable and insightful than many other communications. Chin up, fingers marching. Thanks for what you do..

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  26. Curtis, I read and generally learn something from your blog or I wouldn't subscribe. I also share them with others. Keep the damn things coming.
    Nick

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  27. I read and share the information you provide. Thanks for providing this and keep 'em coming.

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  28. Thank you for posting the variety of informative topics that you do. I feel that I am able to stay more current with the information you bring out. Thanks! Please do keep them coming! We are reading them and sharing them with our folks in the field.

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  29. Judging from previous comments I know I'm not alone in appreciation of your OSHA Training blog. There aren't many places in this world where you can get valuable and accurate analysis at a great price-no charge! Thank you Curtis for truly caring about the health and safety of American workers!

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  30. Read and share them on a regular basis! Keep em coming!!

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