Saturday, August 1, 2015

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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Monday, June 1, 2015

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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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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Wednesday, April 1, 2015

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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Monday, March 2, 2015

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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Monday, February 2, 2015

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.