Question About a Dead End in an Outdoor Exit Route

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QUESTION:  OSHA 1910 Subpart E, 1910.36 (h)(4), which says "The outdoor exit route must not have a dead-end that is longer than 20 feet", does not make sense to me. How should I interpret that statement? - Glen K. – Indiana

ANSWER:  Hello Glen.  Yours is a very good question, and it actually comes up occasionally in our OSHA 30 hour general industry training classes. Fortunately I did some research on this particular OSHA standard years many ago when I ran into this exact problem at a building where I was serving as safety manager. I am going refer you to a crude drawing I whipped up (see below – birds eye view, not to scale) to try and help you visualize one basic example of this situation as I try and answer your question.

The fire alarm goes off in the building pictured below, and everyone needs to head towards their designated assembly area, which is located outside to the right-hand side of the building pictured below . . .  

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Do Your Machinery Start Buttons Meet OSHA Requirements?

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Avoid Use of PVC Pipe and Water Hose Clamps With Compressed Air

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Five Most Prevalent Myths About OSHA's Excavation Standard

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Do Not Overlook This One Last Deadline for GHS / Haz-Com

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When OSHA updated their Hazard Communication (aka Haz-Com) standard back in 2012, many employers jumped into action so they could meet the mandatory deadline for training their employees about the new GHS criteria for labeling containers and Safety Data Sheets (SDS). And most employers have been assembling the new SDS’s that are issued by product manufacturers and distributors.  And hopefully everyone has updated their in-house container labeling systems to reflect the requirements in the updated Haz-Com standard. But there is one more deadline that employers have hanging over their heads, and it’s coming up VERY soon.
  
OSHA has given employers a deadline of June 1, 2016 to . . .

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Are Trenches Regulated as Confined Spaces?

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Two Common Violations of a Vague OSHA Electrical Standard

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Are There OSHA Requirements to Secure Pallet Racks?

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OSHA Penalty Caps are Increasing - Significantly!

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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

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

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Does OSHA Require Daily Toolbox Talks?

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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

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Do Employees REALLY Have "Occupational Exposure"?

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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?

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

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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

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“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

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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

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Commonly Asked Questions About Portable Fire Extinguishers

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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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