Lancaster Safety Questions Blog

DOT Numbers

2012-02-20T12:34:00.001-05:00

Q: What is a DOT number?

A: Companies that operate commercial vehicles transporting passengers or hauling cargo in interstate commerce must be registered with the FMCSA and must have a USDOT Number. Also, commercial intrastate hazardous materials carriers who haul quantities requiring a safety permit must register for a USDOT Number. The USDOT Number serves as a unique identifier when collecting and monitoring a company's safety information acquired during audits, compliance reviews, crash investigations, and inspections. (Be sure to check your state's policy)

Tinted Glasses

2012-02-17T15:22:00.001-05:00

Q: Are there any current restrictions on eye protection when it comes to tinted/shaded lenses for indoor use?

A: OSHA doesn’t have any specific restrictions on tinted/shaded lenses used indoors. However, OSHA would question whether the glasses would be creating a hazard by wearing them indoors. For example, if the person wearing them is driving a forklift, the tinted glasses may impair their vision thus creating a hazard for themselves and others in the area. The same can be said for someone who is on foot. The glasses could impair their vision as well and they might not be able to recognize moving equipment, parts, material, etc. that might be in close proximity to them. If you don’t want to totally prohibit their use you could regulate the darkness of the glasses that are being worn.

Recordkeeping

2012-02-13T09:22:00.001-05:00

Q: An employee gets injured in 2011, but does not miss any work and is not put on restricted duty/job transfer. In 2012, that employee finds out he needs surgery form the injury and misses a month of work in 2012. How would this be inserted in the OSHA 300 logs?

A: All of the information would be inserted in the 2011 OSHA 300 form. The date of the injury would be the date the injury actually occurred even though the employee did not miss any work or was not put on restricted duty/job transfer because of that injury at the moment. Then count the days the employee missed because of the surgery and insert that information in the days away for that same injury.

Respirator Medical Evaluations

2012-02-10T09:21:00.002-05:00

Q: How often are medical evaluations required to be performed? The health care company said they need to be completed every year. We thought it was every two years. Can you clarify?

A: OSHA doesn’t require the medical evaluations to be performed annually or biannually. Instead, OSHA’s requirements for additional evaluations are as follows:

If the employee reports signs or symptoms that are related to the ability to use a respirator
If the physician, supervisor, or program administrator informs the employer that an employee needs to be reevaluated
If information from the respiratory protection program, including observations made during fit testing and program evaluation, indicates a need for employee reevaluation; or
A change occurs in workplace conditions (e.g., physical work effort, protective clothing, and temperature) that may result in a substantial increase in the physiological burden placed on an employee.

OSHA does require fit testing to be performed at least annually. Double check with the health care company to make sure they meant the evaluations and not fit tests.

Cranes

2012-02-09T14:41:00.002-05:00

Q: Do you have to have a certified welder to weld the cross beams on a crane?

A: OSHA does not say anything about the need for a certified welder it just says the welder must be qualified. When welding on a crane though, you need to contact the crane manufacture to get their approval because welding on the crane can affect the load rating of that crane.

Ladders

2012-02-06T08:56:00.001-05:00

Q: Does it matter if you use a fiberglass ladder or an aluminum ladder when doing framing on a house when there is no electrical work being done?

A: No, it does not matter as long as each ladder has the proper warning labels on them.

Recordkeeping

2012-02-03T08:52:00.000-05:00

Q: Who is supposed to sign the OSHA 300 log and where does the signature go?

A: The highest ranking company official should sign only the 300A form and the signature should go in the bottom right hand corner. The 300A needs to be signed and be posted starting February 1 through the end of April.

Hearing Conservation - Audiometric Testing

2012-02-02T08:53:00.001-05:00

Q: We bring in an audiometric testing mobile to administer the tests once a year. Sometimes they don’t get a good reading or there’s a red flag. The employees who have this happen need to go to their main office to be retested. Does the employer need to pay the employee for the time spent going to take the re-test?

A: The audiometric testing is required to be provided at no cost to the employee. Whether or not the employee is to be paid for the time spent going to take the test needs to be determined between the employee and the employer.

Hearing Conservation - Audiometric Testing

2012-02-01T09:35:00.001-05:00

Q: We have all of our employees undergo audiometric testing each year including me (president/owner of company). Do I still need to go through the testing if I no longer work on the floor?

A: Audiometric testing is no longer needed if the occupational exposure has decreased below the action level of 85 dBA.

Recordkeeping

2012-01-31T09:13:00.001-05:00

Q: How do you count the lost work/restricted days on the OSHA 300 log?

A: You'll need to count all the days away from work starting the day after the employee was injured (even if it’s a weekend, or an employee is not scheduled). When the employee returns for restricted/light duty, count those days until they returned to full duty.

Recordkeeping

2012-01-27T10:32:00.001-05:00

Q: One of our employees slipped on ice and hurt their neck. They were off for more than a year. Is there a limit to days that need to be recorded?

A: OSHA states the days away from work are capped at 180. This is noted in the following regulation:

· 1904.7(b)(3)(vii) Is there a limit to the number of days away from work I must count? Yes, you may "cap" the total days away at 180 calendar days. You are not required to keep track of the number of calendar days away from work if the injury or illness resulted in more than 180 calendar days away from work and/or days of job transfer or restriction. In such a case, entering 180 in the total days away column will be considered adequate.

Recordkeeping

2012-01-26T09:37:00.001-05:00

Q: When filling out the 300 logs what do you do for an injury that occurred in one year, but that employee is still injured and he still is unable to return to work for the next calendar year?

A: The answer is found under 1904.7(b)(3)(ix). You only record the injury or illness once. You must enter the number of calendar days away for the injury or illness on the OSHA 300 Log for the year in which the injury or illness occurred. If the employee is still away from work because of the injury or illness when you prepare the annual summary, estimate the total number of calendar days you expect the employee to be away from work, use this number to calculate the total for the annual summary, and then update the initial log entry later when the day count is known or reaches the 180-day cap.

Recordkeeping

2012-01-25T10:05:00.003-05:00

Q. An employee was instructed to keep a wound finger “clean and dry.” Would this be considered light duty?

A. As long as the employee can perform his normal job duties, this would not be considered light duty.

Recordkeeping

2012-01-24T11:31:00.003-05:00

Q: An employee was on light duty in 2011. Do I have to carry this over to my 2012 log?

A: No, all days should be recorded on the 2011 log.

Drug Testing

2012-01-23T14:22:00.002-05:00

Q: Does OSHA require or regulate employee drug testing programs?

A: No, although many states and insurance companies will require a testing program for certain tasks such as operating commercial vehicles. For safety and health, it is always a good idea to make sure employees are drug and alcohol free while at work. Workers compensation carriers should be able to provide more information that will specifically apply to your business.

Recordkeeping

2012-01-19T12:33:00.001-05:00

Q: Are there any exceptions for us with recordkeeping since we only have 9 employees?

A: As long as you have fewer than 10 employees throughout the year you would be exempt.

http://www.osha.gov/recordkeeping/index.html

Arc Flash

2012-01-18T09:29:00.003-05:00

Q: Is it acceptable to use alternative personal protective protection when applying ‘the table method’ to protect employees from arc flash hazards?

A: Unless you can prove through arc flash analysis data that the PPE will provide sufficient protection, it is not recommended.

Arc Flash

2012-01-17T09:14:00.002-05:00

Q: Where can I find reference material for arc flash?

A: The two best sources are the NFPA 70E (available for a fee at www.NFPA.org) and OSHA 1910 Subpart S standard (available for no cost at www.osha.gov).

Recordkeeping

2012-01-10T14:46:00.001-05:00

Q: An employee was injured in 2011 and will be away from work for >180 days. Do I have to put this on my 2012 log in addition to 2011?

A: The injury should only be counted in the year that the injury occurred. All 180 days should be counted in 2011.

Fall Protection at Loading Docks

2012-01-05T09:03:00.001-05:00

Q: We would like to know if you have the OSHA requirements necessary for our loading dock area for a rail or barrier. We are in the midst of having our chains replaced with a more secure barrier. Our loading dock is about 5’ off the ground. Any information would be great.

A: You’ll want to make sure the new barriers that you install meet the following criteria:

Top rail at 42 inches in height and capable of withstanding 200 lbs of outward and downward force.
Midrail at 21 inches in height.

I’ve seen some facilities use 2x4 boards for these barriers. They install brackets on the inside of the door that hold the boards. They are then able to lift the boards out of brackets with ease in order to use the dock. This seems to be a sturdy solution for a removable barrier at the dock. This is just a suggestion as I’m not sure if this would work for your application.

Battery Charging PPE

2012-01-04T08:33:00.001-05:00

Q: We have forklifts and power floor sweepers that operate off of batteries. We have an eyewash station in the charging/changing area, but what types of PPE should we require?
A: Goggles, face shields, aprons, and rubber gloves need to be worn while handling the batteries. Refer to the MSDS of the battery acid to determine the type of rubber gloves/aprons that need to be worn.

Scissor Lift Training

2012-01-03T15:27:00.001-05:00

Q: Does OSHA have specific training requirements for scissor lifts?

A: Since scissor lifts are covered under OSHA’s scaffolding trainings there are no specific training requirements. However, under the general duty clause it would be the employer’s responsibility to ensure all operators are competent and authorized to operate the lift.

Fixed Ladders

2011-12-21T09:39:00.003-05:00

Q: If you have a fixed ladder with a cage or well around it would you also need to have a safe access hatch?

A: This would actually fall under the 1910.23 (Guarding floor and wall openings and holes standard) instead of the 1910.27 (Fixed ladder standard). If there is a potential that the employee can free fall 4 or more feet the fixed ladder will need a safe access hatch.

First Aid Kit

2011-12-08T10:59:00.001-05:00

Q: What are your recommendations on the size of kit, contents required, and maintenance of the first aid kits on monthly or quarterly basis?

A: OSHA’s regulation states that in the absence of an infirmary, clinic, or hospital near the workplace, a person or persons must be adequately trained to render first aid. Adequate first aid supplies must be readily available. Appendix A to 1910.151 (first aid requirement) is a non-mandatory guide for the contents of first aid kits. OSHA uses ANSI’s Minimal Requirements for Workplace First Aid Kits as an example of the minimum contents for a generic kit.

OSHA does specify that this is only the minimal requirement, and employers who have unique or changing first-aid needs in their workplace may need to enhance their first aid kits. Also, if it is reasonably anticipated that employees will be exposed to blood or other potentially infectious materials while using first aid supplies, employers are required to provide appropriate PPE. Purchasing a bloodborne pathogens kit or emergency first responder kit to go along with your first aid kit is also recommended.

Accident Investigation

2011-12-07T10:08:00.001-05:00

Q: How long should accident investigation documents be retained?

A: OSHA does not specify how long to retain these documents. OSHA 300 logs must be retained for a period of 5 years, so it is a good idea to retain the accident investigation documents for the same period of time.

LOTO Requirements

2011-11-30T14:14:00.003-05:00

Q: We purchased a deluxe lock out/tag out kit. Does this have to be in a place for everyone to see, or can we keep it in the office and advise everyone where it is? Maybe post a signs where to locate it.

A: To answer your question it does not have to be in a place where everyone can see it. However, it does need to be in a place that all of the Authorized Lo/To Personal know where it is, and that they can access it at all times. For example, you don’t want to keep it in an office that could be locked and the Authorized Personal would not be able to access it.

Respiratory Protection

2011-11-29T09:00:00.001-05:00

Q: Do respiratory medical release forms/respiratory fit tests need to be completed yearly?

A: The Respiratory Medical Release Forms do not need to be completed yearly they just need to be completed once and then again if something changes to their health such as drastic weight gain/loss or a physical change to their face that would affect respirator usage. The respirator fit tests on the other hand do need to be completed yearly.

OSHA 300 Recordable Incident

2011-11-28T12:33:00.003-05:00

Q: An employee got a piece of metal in his eye and he was taken to the emergency room to remove it and was given a one-time use nonprescription eye drops. He later returned to work the same day. Is this an recordable injury?

A: Yes it is because removing splinters or foreign material from the eye is not covered under “first aid”, but because he returned to work the same day it is not a loss of work day incident.

Learn more about OSHA recordable incidents through our OSHA safety training classes available from Lancaster Safety.

Employee Access to Written Programs

2011-11-21T08:53:00.001-05:00

Q: What is the OSHA standard on accessibility to written programs?

A: OSHA has a number of standards that require the written programs to be accessible to all employees on site. A few examples of these are 29 CFR 1910.1030(c)(1)(i) and 1910.1030(c)(1)(iii) (bloodborne pathogens) and 29 CFR 1910.1200(e)(1) and 1910.1200(e)(4) (hazard communication). Where the standard requires that the written program must be made available to employees, the employer must ensure that employees know how to access the document and that there are no barriers to employee access.

Supervisor/Manager 8 Hour Hazwoper Refresher Training

2011-11-18T08:55:00.003-05:00

Q: Can you tell me where it states that the Supervisor Training is required to be refreshed annually like the HAZWOPER 8 hour?

A: OSHA’s requirement for the refresher training is as follows:

1910.120(e)(8) Refresher training. Employees specified in paragraph (e)(1) of this section, and managers and supervisors specified in paragraph (e)(4) of this section, shall receive eight hours of refresher training annually on the items specified in paragraph (e)(2) and/or (e)(4) of this section, any critique of incidents that have occurred in the past year that can serve as training examples of related work, and other relevant topics.

OSHA also points out in some of their interpretations that 8 hours is the minimal time required for the refresher training. Just like employees, supervisors/managers only need a minimum of 8 hours. Where they differ is in the content of the training. Employees and supervisors/managers need to have separate refresher trainings.

Learn more about OSHA refresher training and all OSHA training courses available from Lancaster Safety.

Scissor Lifts

2011-11-17T08:55:00.002-05:00

Q: Do you need to wear a fall arrest harness when working in a scissor lift that that has a guardrail system around it?

A: No, you do not need to wear a fall arrest harness when working in a scissor lift if it has a proper guardrail system around it. However, if the guardrail system is less than adequate, or the worker leaves the safety of the work platform, an additional fall protection device would be required.

MSDS

2011-11-16T09:26:00.001-05:00

Q: Do our jobsites need a copy of the MSDS? I thought that we as a company needed 1, as long as we produce the binders within 24 hours.

A: There is nothing in the Hazard Communication standard that allows an employer 24 hours to produce an MSDS. I have highlighted the key words: “readily accessible” and “immediately” as indicators that the best safety practice would include having an MSDS for each solid, liquid, and gas chemical readily available at each worksite. Also notice that it is the employers duty to provide an MSDS to OSHA if requested to do so (see 1910.1200 (g) (11) below.

1910.1200(g)(8)

1910.1200(g)(8) The employer shall maintain in the workplace copies of the required material safety data sheets for each hazardous chemical, and shall ensure that they are readily accessible during each work shift to employees when they are in their work area(s). (Electronic access, microfiche, and other alternatives to maintaining paper copies of the material safety data sheets are permitted as long as no barriers to immediate employee access in each workplace are created by such options.)

1910.1200(g)(9) Where employees must travel between workplaces during a work shift, i.e., their work is carried out at more than one geographical location, the material safety data sheets may be kept at the primary workplace facility. In this situation, the employer shall ensure that employees can immediately obtain the required information in an emergency.

1910.1200(g)(10) Material safety data sheets may be kept in any form, including operating procedures, and may be designed to cover groups of hazardous chemicals in a work area where it may be more appropriate to address the hazards of a process rather than individual hazardous chemicals. However, the employer shall ensure that in all cases the required information is provided for each hazardous chemical, and is readily accessible during each work shift to employees when they are in in their work area(s).

1910.1200(g)(11) Material safety data sheets shall also be made readily available, upon request, to designated representatives and to the Assistant Secretary, in accordance with the requirements of 29 CFR 1910.1020(e). The Director shall also be given access to material safety data sheets in the same manner.

Truck Cranes

2011-11-10T08:47:00.003-05:00

Q: Do crane operators for ‘truck cranes’ need to be certified?

A: If you are using the crane for maintenance purposes the crane would fall under the 1910.180 regulation. Under this regulation only ‘Designated Personnel’ shall operate the crane and there is no certification required.

Forklift

2011-11-09T12:55:00.003-05:00

Q: How long are forklift 'train the trainer' certifications good for?

A: Indefinitely as long as the employee has training, authorization from the company, and demonstrates competency as a trainer.

Learn more about OSHA forklift training and all OSHA training courses available from Lancaster Safety.

Walking Working Surfaces

2011-11-03T15:21:00.008-04:00

Q: We have built a few small “platforms” to stand on to do some of our work. When I say platform, I mean a small single step. These “platforms” range from about 7-9 inches tall with a rectangular flat service of 18X18 inches on the small end, and 30X36 inches on the larger end. Is there an OSHA requirement that a surface area must be so large for a certain height?

A: Yes, OSHA does have requirements for steps. The platforms you are talking about will be covered by those requirements for steps. The regulations that will want to follow for the structure and surface area are as follows:

1910.24(c) "Stair strength." Fixed stairways shall be designed and constructed to carry a load of five times the normal live load anticipated but never of less strength than to carry safely a moving concentrated load of 1,000 pounds.
1910.24(d) "Stair width." Fixed stairways shall have a minimum width of 22 inches.

Regarding your question about the need for handrails, the only need for a handrail is if the platform is 4 feet or more above an adjacent floor or ground. In your case the two steps that total 16 inches would not need a handrail: click here to refer to 1910.23(c)(1) - 1910.23(c)(1)(iii).

Learn more about OSHA requirements, look to the experienced OSHA consultants available from Lancaster Safety.

Step Ladders

2011-11-02T08:51:00.002-04:00

Q: Do you need to use a fall protection system when climbing a step ladder that is greater than six feet high?

A: No, you do not need to use fall protection when climbing the step ladder. You only need to use fall protection if you are climbing a fixed ladder.

Recordkeeping

2011-10-31T11:19:00.001-04:00

Q: An employee was struck by a piece of equipment in the face and went to the ER, they were physically observed by a physician and it was determined there was no other injuries besides bruising on their face, they did not miss any work; is this recordable?

A: If there was no other treatment besides an observation and basic first aid, then no it is not recordable.

Recordkeeping

2011-10-31T11:15:00.001-04:00

Q: What is the difference between the 301 and the 300 forms in the recordkeeping packet?

A: The 301 is the incident report, you use it to record all types of injuries/incidents. The 300 form is used to record only recordable injuries (medical treatment beyond first aid, death, days away from work, job transfer). Here is an easy to use recordkeeping e-tool.

Ladders

2011-10-27T16:19:00.002-04:00

Q: We have a “V-type” free standing step ladder, can we fold it and lean it against a wall? Some extension ladders are too tall.

A: No, because that is not how the ladder is designed, that will affect the stability of the step ladder.

Recordkeeping

2011-10-27T15:09:00.001-04:00

Q: An employee had recently fractured a finger, received stitches in another, and missed days away from work; is this recordable?

A: Yes, their treatment would be considered medical treatment and they missed days from work. Here is an easy to use recordkeeping e-tool.

Recordkeeping

2011-10-27T15:06:00.001-04:00

Q: Our insurance carrier is asking for our incident forms, is the 301 the form they are referring to?

A: Yes.

Fall Protection

2011-10-25T16:39:00.001-04:00

Q: What would the aisle width requirements be for a walkway that is 10 feet off the ground?

A: 1910.22(b) "Aisles and passageways."

1910.22(b)(1) Where mechanical handling equipment is used, sufficient safe clearances shall be allowed for aisles, at loading docks, through doorways and wherever turns or passage must be made. Aisles and passageways shall be kept clear and in good repairs, with no obstruction across or in aisles that could create a hazard.

1910.23(c) "Protection of open-sided floors, platforms, and runways."

1910.23(c)(1) Every open-sided floor or platform 4 feet or more above adjacent floor or ground level shall be guarded by a standard railing (or the equivalent as specified in paragraph (e)(3) of this section) on all open sides except where there is entrance to a ramp, stairway, or fixed ladder. The railing shall be provided with a toeboard wherever, beneath the open sides,

1910.23(c)(1)(i) Persons can pass,

1910.23(c)(1)(ii) There is moving machinery, or

1910.23(c)(1)(iii) There is equipment with which falling materials could create a hazard.

1910.23(c)(2) Every runway shall be guarded by a standard railing (or the equivalent as specified in paragraph (e)(3) of this section) on all open sides 4 feet or more above floor or ground level. Wherever tools, machine parts, or materials are likely to be used on the runway, a toeboard shall also be provided on each exposed side.

If the walkway is part of an exit, it would have to meet these requirements:

1910.36(g)(2) An exit access must be at least 28 inches (71.1 cm) wide at all points. Where there is only one exit access leading to an exit or exit discharge, the width of the exit and exit discharge must be at least equal to the width of the exit access.

Letter of Interpretation

Recordkeeping

2011-10-24T13:33:00.000-04:00

Q: If an employee was injured and needed stitches, does this count as a recordable injury?

A: Yes,here is an easy to use recordkeeping e-tool.

OSHA Requirements

2011-10-21T13:23:00.002-04:00

Q: Who is not covered by OSHA?

A: The following are not cover by OSHA:

• Self-Employed

• Immediate family members of farm employers that do not employ outside employees

• Workplace hazards regulated by another Federal agency (for example, the Mine Safety and Health Administration, the Federal Aviation Administration, the Coast Guard).

Learn more about OSHA requirements, look to the experienced OSHA consultants available from Lancaster Safety.

Truck Cranes

2011-10-21T11:12:00.002-04:00

Q: Do operators of truck cranes need to be certified?

A: Yes, the operators need to be certified, if the crane can hoist/lift more than 2,000 pounds.

See: 1926.1427(a)(3) Exceptions: Operator qualification or certification under this section is not required for operators of derricks (see § 1926.1436), sideboom cranes (see § 1926.1440), or equipment with a maximum manufacturer-rated hoisting/lifting capacity of 2,000 pounds or less (see § 1926.1441).

Recordkeeping

2011-10-20T09:54:00.000-04:00

Q: If an employee falls on ice in the company parking lot and breaks their arm, is this recordable?

A: Yes, the incident would be a recordable injury because the employee was on company premises as a condition of their employment. Here is a link to an OSHA Letter of Interpretation.

Forklift Seat Belts

2011-10-17T12:34:00.001-04:00

Q: If a forklift was not originally manufactured with a seat belt, does the employer have to install a seat belt?

A: OHSA's enforcement policy relative to the use of seat belts on powered industrial trucks is that employers are obligated to require operators of powered industrial trucks which are equipped with operator restraint devices or seat belts to use the devices. OSHA may also issue citations if the employer has not taken advantage of a manufacturer operator restraint system or seat belt retrofit program.

Transporting Acetylene and Oxygen

2011-10-10T14:21:00.001-04:00

Q: When transporting acetylene and oxygen tanks in the back of a pickup truck what regulations do I have to follow? Do they need to be separated? What about if some are full and some are empty?

A: OSHA’s requirements for transporting, moving, and storing compressed gas cylinders are below:

· 1926.350(a) Transporting, moving, and storing compressed gas cylinders.

o 1926.350(a)(1) Valve protection caps shall be in place and secured.

o 1926.350(a)(2) When cylinders are hoisted, they shall be secured on a cradle, slingboard, or pallet. They shall not be hoisted or transported by means of magnets or choker slings.

o 1926.350(a)(3) Cylinders shall be moved by tilting and rolling them on their bottom edges. They shall not be intentionally dropped, struck, or permitted to strike each other violently.

o 1926.350(a)(4) When cylinders are transported by powered vehicles, they shall be secured in a vertical position.

o 1926.350(a)(5) Valve protection caps shall not be used for lifting cylinders from one vertical position to another. Bars shall not be used under valves or valve protection caps to pry cylinders loose when frozen. Warm, not boiling, water shall be used to thaw cylinders loose.

o 1926.350(a)(6) Unless cylinders are firmly secured on a special carrier intended for this purpose, regulators shall be removed and valve protection caps put in place before cylinders are moved.

o 1926.350(a)(7) A suitable cylinder truck, chain, or other steadying device shall be used to keep cylinders from being knocked over while in use.

o 1926.350(a)(8) When work is finished, when cylinders are empty, or when cylinders are moved at any time, the cylinder valve shall be closed.

o 1926.350(a)(9) Compressed gas cylinders shall be secured in an upright position at all times except, if necessary, for short periods of time while cylinders are actually being hoisted or carried.

o 1926.350(a)(10) Oxygen cylinders in storage shall be separated from fuel-gas cylinders or combustible materials (especially oil or grease), a minimum distance of 20 feet (6.1 m) or by a noncombustible barrier at least 5 feet (1.5 m) high having a fire-resistance rating of at least one-half hour.

o 1926.350(a)(11) Inside of buildings, cylinders shall be stored in a well-protected, well-ventilated, dry location, at least 20 feet (6.1 m) from highly combustible materials such as oil or excelsior. Cylinders should be stored in definitely assigned places away from elevators, stairs, or gangways. Assigned storage places shall be located where cylinders will not be knocked over or damaged by passing or falling objects, or subject to tampering by unauthorized persons. Cylinders shall not be kept in unventilated enclosures such as lockers and cupboards.

OSHA doesn’t specifically address the transportation of oxygen and acetylene together. It’s our recommendation to transport them separately since they are supposed to be stored separately. Also, OSHA doesn’t consider tanks to be empty since they will usually still contain a small amount of the gas. You will want to treat the “empty” tanks the same as full tanks.

Finally, due to OSHA’s limited information on transporting the tanks we recommend also checking with the Department of Transportation. The DOT’s requirements are out of the realm of our expertise, but the following link has some of the requirements that you might have to follow: click here.

Oxygen Tanks on Welding Carts

2011-10-10T10:20:00.002-04:00

Q: If you only have one oxygen cylinder on a welding cart do I have to follow the 1910.253 (b)(4)(iii) storage requirement?

A: For general industry, as long as the oxygen tank is “in use” or “connected for use” the storage requirements do not apply.

Sling Tags

2011-10-07T09:27:00.001-04:00

Q: Do load rating tags on nylon slings need to be legible while the slings are in use?

A: Yes, the slings have to be essentially free of damage and a torn, missing or smudged data tag would constitute damage.

Fall Protection

2011-10-06T09:31:00.005-04:00

Q: How long can a person be suspended in a fall arrest harness?
A: The following is the regulation dealing with the rescue time for someone who has fallen and is being suspended by a fall arrest harness:

1926.502(d)(20) The employer shall provide for prompt rescue of employees in the event of a fall or shall assure that employees are able to rescue themselves.

The word “prompt” requires rescue be performed quickly, in time to prevent serious injury to the worker. OSHA does not have a set time in which an employee would need rescued, but recent studies indicate that a person may become unconscious within 5 minutes.

Forklift

2011-10-05T11:11:00.001-04:00

Q: Can a forklift engine be left running if the driver steps off the vehicle for a few moments?

A: Yes, but only if the following conditions apply:

1910.178(m)(5)(i) When a powered industrial truck is left unattended, load engaging means shall be fully lowered, controls shall be neutralized, power shall be shut off, and brakes set. Wheels shall be blocked if the truck is parked on an incline.

1910.178(m)(5)(ii) A powered industrial truck is unattended when the operator is 25 ft. or more away from the vehicle which remains in his view, or whenever the operator leaves the vehicle and it is not in his view.

1910.178(m)(5)(iii) When the operator of an industrial truck is dismounted and within 25 ft. of the truck still in his view, the load engaging means shall be fully lowered, controls neutralized, and the brakes set to prevent movement.

Forklift

2011-09-29T14:46:00.001-04:00

Q: How wide do the aisles for the forklift traffic have to be?

A: The aisle must be at least 3 feet wider than your widest piece of equipment.

Secondary Power Lines

2011-09-26T15:05:00.001-04:00

Q: When using scaffolding, what safety measures need to be taken to stay safe when working by secondary electric lines running to homes or businesses?

A: You have several options that you can use to keep yours employees safe, as well as being in compliance with OSHA:

You can disconnect the power
Work at least 10 feet from the lines
Reroute the lines
Have the power company cover the lines.

Forklift

2011-09-22T12:37:00.003-04:00

Q: What is the OSHA regulation for covering the top of a forklift to stay dry when it rains? Is there an OSHA approved add-on for this purpose?

A: In OSHA’s Forklift Regulation there is nothing that is specific about adding modifications to the forklift to protect the employee from rain. What the regulation does state is that prior to adding any modification you need the manufacturer’s written approval, but this is only if these modifications are going to affect the capacity and safe operation of the forklift. See the regulation below. I would recommend calling the company that manufactures your forklift and ask them if they have any additions that add rain protection and to check with them to ensure it will not affect the load capacity.

•29 CFR 1910.178(a)(4) Modifications and additions which affect capacity and safe operation shall not be performed by the customer or user without manufacturers prior written approval. Capacity, operation, and maintenance instruction plates, tags, or decals shall be changed accordingly.

Respiratory Protection

2011-09-20T16:41:00.000-04:00

Q: How do you know from the MSDS if you need to wear a respirator when working with chemicals that requires a respirator but only at a certain PEL?
A: You cannot tell from just the MSDS. Our recommendation would be to conduct air monitoring to determine what the exposure for the workers would be. If you can’t have air monitoring conducted, you’ll need to assume that the workers are exposed above the permissible exposure limits and follow the MSDS’ recommendation for respiratory protection.

Emergency Evacuation Plan

2011-09-16T11:02:00.001-04:00

Q: Does OSHA require posting emergency evacuation maps every so many feet throughout the plant?

A: There is nothing that specific in the standard but they should be in common areas such as offices and break rooms, doorways, etc. The maps should be visible to anyone walking by. They should have a primary and secondary route color coded and the mustering point marked.

Fall Protection

2011-09-16T10:48:00.001-04:00

Q: What is required by OSHA for man lifts as far as fall protection?

A: If you’re using scissor lifts a personal fall arrest harness is not needed if all four sides of the lift are protected by guardrails since they fall under OSHA’s scaffolding regulation. If you’re using an extendable boom aerial lift then personal fall protection is required. It’s OSHA’s policy that an employer will be in compliance with OSHA’s fall protection requirements for aerial lifts if one of these three means of fall protection are used:

Use of a body belt with a tether anchored to the boom or basket (fall restraint system),
Use of a body harness with a tether (fall restraint system), or
Use of a body harness with a lanyard (fall arrest system).

If using a fall arrest system you need to be aware of the distance it takes to actually arrest the employees fall. For example, if a 6’ person is using a 6’ lanyard the distance that would be needed to arrest the fall safely without hitting the ground would be around 18 feet. This length is taking into consideration the distance that the lanyard could stretch and a 3’ safety factor that OSHA requires to be added into the total distance.

Use of Headphones

2011-09-08T16:13:00.001-04:00

Q: Does OSHA prohibit the use of headphones while operating the forklift?

A: OSHA does not address this specifically but the employee would need to be able to hear the back up alarms, horns, or other emergency alarm systems.

Emergency Evacuation Plan

2011-09-07T11:26:00.002-04:00

Q: What should I put on the emergency evacuation plans?

A: There needs to be a primary and secondary route, where they are currently located in the building ("you are here"), where the meeting point is outside, and where the fire extinguishers are throughout the facility. Click here for more information.

Fall Protection Policies for Residential Construction

2011-09-01T10:02:00.000-04:00

Q: Do you have any videos or material on the new OSHA policies for residential construction that I can show to my new hires?

A: OSHA recently released a video, click here to watch.

LOTO Requirements

2011-08-26T09:08:00.001-04:00

Q: When we have to change a skill saw blade onsite, we obviously would unplug the tool but, do we need to have a lock out tag out box to clamp around the plug end so that no one can plug the item back in while it is being swapped out?

A: Other than unplugging the piece of equipment nothing else needs to be done to change the blade in the saw. OSHA’s 29 CFR 1910.147 standard goes over the requirements that are required for the control of hazardous energy (lockout/tagout). The standard does not apply to a piece of equipment that has only a cord and plug for a source of energy.

· 1910.147(a)(2)(iii) This standard does not apply to the following:

o 1910.147(a)(2)(iii)(A)

Work on cord and plug connected electric equipment for which exposure to the hazards of unexpected energization or start up of the equipment is controlled by the unplugging of the equipment from the energy source and by the plug being under the exclusive control of the employee performing the servicing or maintenance.

Although it is not required, placing a lock and tag on the saw would go beyond OSHA’s requirements and would be a good safe work practice that we recommend.

Emergency Action Plan

2011-08-23T11:38:00.001-04:00

Q: Will it violate any OSHA standards if I put materials or a barricade in front of a garage door?

A: A garage door is not permitted to be considered a route of egress; as long as the materials or barricade do not block an exit route.

Recordkeeping

2011-08-22T09:36:00.002-04:00

Q: An employee was injured at work and failed to report the injury. The employee was terminated for not following company policy (reporting the injury). Does the injury have to still be recorded on the OSHA 300 logs? If so, how many days away from work should be reported?

A: Yes, the injury still needs to be recorded. The number of days away from work should correspond with the doctor’s recommendation.

Forklift

2011-08-19T08:43:00.003-04:00

Q: Are there any requirements on how strong guardrails need to be when there is forklift traffic near the area?

A: The only requirement for the strength of a guardrail is 200 pounds. There is no regulation for guardrail strength for forklift traffic because it would have to be “extremely heavy duty.” However, 29 CFR 1910.178(m)(6) states : “A safe distance shall be maintained from the edge of ramps or platforms while on any elevated dock, or platform or freight car.” The best thing to do is effectively communicate and enforce safe driving practices while on the dock and ramp. He mentioned that some companies have installed rumble strips near edges to warn drivers that they are getting close.

Fire Extinguisher

2011-08-18T11:04:00.002-04:00

Q: How high off of the floor does a fire extinguisher need to be mounted?

A: Fire extinguishers need to be mounted and identified so that they are readily accessible to employees without subjecting them to possible injury. Generally, the carrying handle should be placed 3-5 feet above the floor.

Recordkeeping

2011-08-12T15:23:00.001-04:00

Q: Which form has to be posted and for how long?

A: The 300A will need to be posted from February 1st through April 30th each year.

Recordkeeping

2011-08-11T13:34:00.001-04:00

Q: An employee was running a saw and got sawdust in his eye. He flushed it with water but did not feel the need to see a doctor. Is the recordable?

A: No, first aid is not recordable.

Operator Training for Skid Steers

2011-08-09T16:37:00.001-04:00

Q: Do you have anything on training for skid steer authorization?

A: Since skid steers are considered “earth removal equipment” they do not fall under the scope of OSHA’s powered industrial truck requirement. However, if the skid steer does have a vertical mast it would fall under the requirements. Click here for an OSHA standard interpretation on this subject. Although OSHA doesn’t have any training requirements for this type of equipment it is still highly recommended to train your operators and only allow authorized or certified individuals to operate the equipment.

Eye Wash Requirements

2011-08-09T15:38:00.002-04:00

Q: What is the recommended eye wash solution and amount? I read somewhere that for eye wash bottles in the field there should be 30 seconds worth of eye wash.

A: OSHA doesn’t have specific guidelines or requirements when it comes to emergency eyewash, however, 29 CFR 1910.151(c), specifies that "where the eyes or body of any person may be exposed to injurious corrosive materials, suitable facilities for quick drenching or flushing of the eyes and body shall be provided within the work area for immediate emergency use." OSHA may reference the ANSI Z358.1-2009 eyewash standard which outlines equipment location/access which is an unobstructed 10 seconds travel, a suitable water temperature which is 60-100 degrees Fahrenheit and the fact that the eyewash device must provide a minimum flow of .4 GPM at 30psi for a 15 minute period. Portable eyewash bottles are considered supplemental equipment only.

Restroom Requirements

2011-08-02T12:53:00.004-04:00

Q: As an employer, what obligations do I have pertaining to providing restrooms for the employees?

A: 1910.141(c) Toilet facilities.1910.141(c)(1) General. 1910.141(c)(1)(i) Except as otherwise indicated in this paragraph (c)(1)(i), toilet facilities, in toilet rooms separate for each sex, shall be provided in all places of employment in accordance with table J-1 of this section. The number of facilities to be provided for each sex shall be based on the number of employees of that sex for whom the facilities are furnished. Where toilet rooms will be occupied by no more than one person at a time, can be locked from the inside, and contain at least one water closet, separate toilet rooms for each sex need not be provided. Where such single-occupancy rooms have more than one toilet facility, only one such facility in each toilet room shall be counted for the purpose of table J-1.

Number of employees	Minimum number of water closets¹
1 to 15	1
16 to 35	2
36 to 55	3
56 to 80	4
81 to 110	5
111 to 150	6
Over 150	2

¹Where toilet facilities will not be used by women, urinals may be provided instead of water closets, except that the number of water closets in such cases shall not be reduced to less than 2/3 of the minimum specified.

Hazardous Waste Training

2011-07-28T10:54:00.002-04:00

Q: We are going onto a landfill to do some sampling. No hazardous waste has, is, or ever will be disposed of in the landfill. Is Hazwoper training required? If not, what training is required?
A: As long as there is no hazardous waste OSHA’s Hazwoper Regulation doesn’t apply. OSHA’s Hazard Communication Standard applies instead.

Ladder Labels

2011-07-27T10:56:00.002-04:00

Q: Some of the decals on the ladders are worn off or illegible. Do we have to go back to the manufacturer of the ladder to get replacement decals or can we get them from somewhere else?

A: Any applicable information specific to the ladder type, warnings or ratings shall be legible to the user. The type of label would be specific to each manufacturer since products may differ. Manufacturers may offer replacement labels. However, due to liability concerns, it is doubtful that a ladder manufacturer will distribute ladder warning labels when they have no idea what their customer is putting them on. This is why ladders should be kept clean, free of damage, stored properly and inspected prior to use. Having a proper ladder inspection/safety program in place will prevent the labels from getting damaged.

Class of Ladders

2011-07-27T10:52:00.002-04:00

Q: Is there a minimum class that the ladders have to be rated? Can the ladders be wooden, aluminum and/or steel?

A: This all depends on the type of ladder, where the ladder will be used, and the type of forces exerted on the ladder. Typically ladders have several different ratings. Consider factors such as proximity of electrical lines or systems, contaminants such as chemicals and how they will have an effect on the ladder material, weight of the average individual who will be using the ladder, the weight of the objects which may be handled while on the ladder. Examples of a ladder classification system are as follows:

Type III, light duty ladder is rated for 200lbs, red in color
Type II, medium duty ladder is rated for 225lbs, green in color
Type I, heavy duty industrial ladder is rated for 250lbs, blue in color
Type IA, extra heavy duty industrial ladder is rated for 300lbs, orange in color
Type IAA, special duty ladder is rated for 375lbs, yellow in color

Fall Protection

2011-07-26T14:38:00.002-04:00

Q: In construction, is it acceptable to tie off to roof carts that weigh about 500 lbs.?

A: No. The anchor point should not be mobile and should follow the guidelines of 29 CFR 1926 Subpart M:

1926.502(d)(15) - Anchorages used for attachment of personal fall arrest equipment shall be independent of any anchorage being used to support or suspend platforms and capable of supporting at least 5,000 pounds (22.2 kN) per employee attached, or shall be designed, installed, and used as follows:

1926.502(d)(15)(i) - as part of a complete personal fall arrest system which maintains a safety factor of at least two; and

1926.502(d)(15)(ii) - under the supervision of a qualified person.

Cylinder Storage

2011-07-26T09:05:00.000-04:00

Q: Can compressed gas (argon 75%,carbon dioxide 25%) and nitrogen non flammable gases be stored with oxygen full or empty in the same place also can they be stored inside?

A: Only fuel gasses need to be separated from Oxygen. Argon, carbon dioxide, and nitrogen are not fuel gasses so they don't need to be separated and they can be stored inside.

Oxygen Storage

2011-07-26T09:00:00.002-04:00

Q: How thick does the partition wall have to been between cylinders?

A: 1910.253(b)(4) states that oxygen cylinders in storage shall be separated from fuel-gas cylinders or combustible materials by at least 20 feet or by a barrier that is at least 5 feet high that has a fire-resistance rating of at least on half hour. OSHA doesn’t reference the thickness of the barrier. Only that it has to have a ½ hour fire-resistance rating.

Compressed Gas Cylinders

2011-07-25T16:16:00.001-04:00

Q: If compressed gas cylinders are in use or set up for use do they require caps?

A: No, 1910.253(b)(2)(iv) states that valve protection caps, where the cylinder is designed to accept a cap, shall always be in place, hand-tight, except when cylinders are in use or connected for use.

Respirator Medical Evaluations

2011-07-25T15:02:00.003-04:00

Q: Do employees need re-evaluation of medical clearance for respirator use?

A: Yes, under certain circumstances:

1910.134(e)(7) Additional medical evaluations. At a minimum, the employer shall provide additional medical evaluations that comply with the requirements of this section if:

i. 1910.134(e)(7)(i) An employee reports medical signs or symptoms that are related to ability to use a respirator;

ii. 1910.134(e)(7)(ii) A Physician or other licensed health care professional, supervisor, or the respirator program administrator informs the employer that an employee needs to be reevaluated;

iii. 1910.134(e)(7)(iii) Information from the respiratory protection program, including observations made during fit testing and program evaluation, indicates a need for employee reevaluation; or

iv. 1910.134(e)(7)(iv) A change occurs in workplace conditions (e.g., physical work effort, protective clothing, temperature) that may result in a substantial increase in the physiological burden placed on an employee.

Requirements for Hole Covers

2011-07-25T08:45:00.001-04:00

Q: During construction, when covering openings in a roof such as skylights and fan rough-ins, how strong does the material have to be?

A: 1926.502(i)(2) All other covers shall be capable of supporting, without failure, at least twice the weight of employees, equipment, and materials that may be imposed on the cover at any one time.

OSHA’s Multi-employer Citation Policy

2011-07-22T08:39:00.003-04:00

Q: If an outside contractor is working in the plant, is it their responsibility to be in compliance or do we need to make sure they are in compliance?

A: It would be to your benefit to make sure the contracted company is in compliance. OSHA’s Multi-Employer Citation Policy states the following:

· Multi-employer Worksites. On multi-employer worksites (in all industry sectors), more than one employer may be citable for a hazardous condition that violates an OSHA standard. A two-step process must be followed in determining whether more than one employer is to be cited.

o Step One. The first step is to determine whether the employer is a creating, exposing, correcting, or controlling employer. The definitions in paragraphs (B) - (E) below explain and give examples of each. Remember that an employer may have multiple roles (see paragraph H). Once you determine the role of the employer, go to Step Two to determine if a citation is appropriate (NOTE: only exposing employers can be cited for General Duty Clause violations).

o Step Two. If the employer falls into one of these categories, it has obligations with respect to OSHA requirements. Step Two is to determine if the employer's actions were sufficient to meet those obligations. The extent of the actions required of employers varies based on which category applies. Note that the extent of the measures that a controlling employer must take to satisfy its duty to exercise reasonable care to prevent and detect violations is less than what is required of an employer with respect to protecting its own employees.

OSHA would consider the contracted company to be the exposing employer and your company as the controlling employer. Please visit our website for more information.

Compressed Gas Cylinders

2011-07-21T09:14:00.001-04:00

Q: We currently house our compressed gas cylinders in a storage cage and we use an outside vendor for service. We have no problems but we are interested in putting a lock on the storage cage. Can we lock the storage cage the compressed gas cylinders are in to prevent the vendor or anyone else to come in and out as they please? In other words, is there any OSHA regulation that states whether or not we can lock that storage unit?

A: OSHA does not clearly state whether locks are permitted or not permitted on storage areas. However, OSHA does state that the storage areas should be well-protected. This includes being protected from tampering by unauthorized persons. In the circumstance that you described locking the cage would be permitted and provide an added form of protecting the cylinders from tampering. Below is the OSHA regulation pertaining to this issue.

1910.253(b)(2)(ii) - Inside of buildings, cylinders shall be stored in a well-protected, well-ventilated, dry location, at least 20 (6.1 m) feet from highly combustible materials such as oil or excelsior. Cylinders should be stored in definitely assigned places away from elevators, stairs, or gangways. Assigned storage spaces shall be located where cylinders will not be knocked over or damaged by passing or falling objects, or subject to tampering by unauthorized persons. Cylinders shall not be kept in unventilated enclosures such as lockers and cupboards.

Trench Box Modifications

2011-07-21T09:00:00.002-04:00

Q: Can I mount plates to the end of our trench boxes to further prevent cave-ins?

A: That may be acceptable, however you will need to verify and be able to prove that any modifications are properly engineered to withstand the anticipated pressure that will be applied. This can be accomplished by requesting approval from the manufacture or an accredited engineer, however it may be best to purchase a new box instead.

Proper Gas Cans

2011-07-21T08:59:00.003-04:00

Q: Can we use Military Style ‘Gerry’ Gas Cans on jobsites?

A: Some model ‘Gerry’ Cans may be acceptable if they have anti-spill and flame arrestor features. If you are unsure if your gas can has these features, it is recommended that you purchase a new ‘safety can’ from a local supplier.

Respirator Medical Evaluations

2011-07-20T09:03:00.003-04:00

Q: Do medical evaluations need to be conducted annually for respirator wearers?

A: No, additional medical evaluations need to be conducted if:

An employee reports medical signs or symptoms that are related to ability to use a respirator
A PLHCP, supervisor, or the respiratory program administrator informs the employer that an employee needs to be reevaluated
Information from the respiratory protection program, including observations made during fit testing and program evaluation, indicates a need for employee reevaluation; or
A change occurs in workplace conditions (e.g., physical work effort, protective clothing, temperature) that may result in a substantial increase in the physiological burden placed on an employee.

Chemical Labels

2011-07-19T10:52:00.007-04:00

Q: Do we have to label secondary containers? If so, where can we find the information required on the label?
A: Unless the employee transferring the substance is in complete control of the container at all times, it would have to be labeled. Minimal information required on the container would include the chemical/substance name, hazard categories and applicable ratings and target organs/personal protective equipment. This information can sometimes be found on the original, manufacturers container or the material safety data sheet.

MSDS

2011-07-15T14:55:00.003-04:00

Q: How long does a company need to keep the MSDS for chemical that is no longer used?

A: MSDS are considered “Employee Exposure Record” and must be kept on file for 30 years.

Respiratory Protection

2011-07-14T14:40:00.000-04:00

Q: An employee assigned to clean out a furnace insisted that OSHA requires him to wear a respirator while cleaning out the furnace. Do we have to provide it and what kind of respirator do we need?

A: In order to determine if a respirator is needed air monitoring must be conducted to figure out the amount of exposure. If the exposure is over OSHA's Permissable Exposure Limit (PEL) then controls need to be used to reduce the exposure. The type of respiratory protection would be based off of the amount of exposure and the substance.

OSHA Requirements

2011-07-12T09:44:00.002-04:00

Q: Is it true that OSHA has no say over companies with less than 11 employees?

A: OSHA regulations are applicable to all employers. The number of employees only pertains to OSHA’s recordkeeping requirements. Companies with 11 or more employees must fill out the OSHA 300 form, 300A Summary, and the 301 form or a similar version. Companies with fewer do not have to keep the mentioned records. If your company needs help getting your safety program on track please visit our website.

Personal Protective Equipment (PPE)

2011-07-08T15:40:00.000-04:00

Q: What PPE is the employer responsible to provide?

A: The employer is responsible to purchase and provide the PPE that employees need to wear except for a few special situations. OSHA's requirements on purchasing PPE and the special situations are provided below:

· 1910.132(h) Payment for protective equipment.

o 1910.132(h)(1) Except as provided by paragraphs (h)(2) through (h)(6) of this section, the protective equipment, including personal protective equipment (PPE), used to comply with this part, shall be provided by the employer at no cost to employees.

o 1910.132(h)(2) The employer is not required to pay for non-specialty safety-toe protective footwear (including steel-toe shoes or steel-toe boots) and non-specialty prescription safety eyewear, provided that the employer permits such items to be worn off the job-site.

o 1910.132(h)(3) When the employer provides metatarsal guards and allows the employee, at his or her request, to use shoes or boots with built-in metatarsal protection, the employer is not required to reimburse the employee for the shoes or boots.

o 1910.132(h)(4) The employer is not required to pay for:

-1910.132(h)(4)(i) The logging boots required by 29 CFR 1910.266(d)(1)(v);

-1910.132(h)(4)(ii) Everyday clothing, such as long-sleeve shirts, long pants, street shoes, and normal work boots; or

-1910.132(h)(4)(iii) Ordinary clothing, skin creams, or other items, used solely for protection from weather, such as winter coats, jackets, gloves, parkas, rubber boots, hats, raincoats, ordinary sunglasses, and sunscreen.

o 1910.132(h)(5) The employer must pay for replacement PPE, except when the employee has lost or intentionally damaged the PPE.

o 1910.132(h)(6) Where an employee provides adequate protective equipment he or she owns pursuant to paragraph (b) of this section, the employer may allow the employee to use it and is not required to reimburse the employee for that equipment. The employer shall not require an employee to provide or pay for his or her own PPE, unless the PPE is excepted by paragraphs (h)(2) through (h)(5) of this section.

o 1910.132(h)(7) This paragraph (h) shall become effective on February 13, 2008. Employers must implement the PPE payment requirements no later than May 15, 2008.

Note to § 1910.132(h): When the provisions of another OSHA standard specify whether or not the employer must pay for specific equipment, the payment provisions of that standard shall prevail. [39 FR 23502, June 27, 1974, as amended at 59 FR 16334, April 6, 1994; 59 FR 33910, July 1, 1994; 59 FR 34580, July 6, 1994; 72 FR 64428, Nov. 15, 2007]

Forklift Mounted Man Basket

2011-07-07T16:01:00.002-04:00

Q: Is there an actual OSHA requirement relating to a forklift mounted man basket? If not, what other “rules” apply to this type of equipment?

A: There is not an actual general industry standard concerning mounted man baskets on forklifts. However companies must abide by The American National Standards Institute (ANSI). ANSI’s standard regarding mounted man baskets on forklifts is B56.6. In this standard it covers the design, training, and machine requirements. Listed below are a few examples as to what it covers.

Requires both the forklift operator and the employee in the man basket to be properly trained on the use of the work platform.
Requires the employees to be trained on the use of seat belts, lanyards, and the use of hard hats.
Requires the forklift operator to have training on inspecting the man basket, attaching the man basket, as well as how to properly operate the man basket when employees are inside.
Requires that both sides of the man basket lock into place on the forklift so the basket will not slide.
The use of the man basket is to be the last option.
Requires safety belt attachment points.
Ladders are not allowed inside of the man basket to reach high.
A first aid kit and fire extinguisher must be inside the man basket.
The forklift operator can only move the platform up and down when employees are inside of the basket.
The basket is required to have the following – two boards, handrails, a gate locked in place, and a load capacity.

Requirements for Eye Wash and Emergency Shower Signage

2011-07-06T15:13:00.001-04:00

Q. What color do our eye wash and emergency shower signs have to be?

A. OSHA does not require a specific color or set up of an eye wash station. Most signs available are green with white lettering.

Water Requirements on a Jobsite

2011-07-05T16:55:00.002-04:00

Q: Do employers have to provide water on a jobsite?

A: OSHA requires that the employer provides water at a jobsite: Heat Stress Prevention

1910.141(b)(1)(i) Potable water shall be provided in all places of employment, for drinking, washing of the person, cooking, washing of foods, washing of cooking or eating utensils, washing of food preparation or processing premises, and personal service rooms.

Hearing Conservation - Standard Threshold Shift

2011-06-30T15:44:00.003-04:00

Q. What is a hearing shift and does this apply to workers?

A. The hearing shift, or standard threshold shift, is in reference to an employee’s loss of hearing. Once it’s determined that an employee or employees are exposed to noise levels above OSHA’s action level of 85 dBA the employer needs to take certain actions. OSHA’s action level is the level of noise exposure where the employer must enlist a hearing conservation program. One of the elements of the hearing conservation program is audiometric testing. This is where the employees get their hearing tested by a licensed or certified audiologist, otolaryngologist, or other physician, or by a technician who is certified by the Council of Accreditation in Occupational Hearing Conservation. The first or original audiometric test is considered the baseline audiogram. The baseline needs to be determined within 6 months of an employee’s first exposure at or above the action level. The baseline audiogram will be then compared against all subsequent audiograms.

After the baseline audiogram has been determined, new audiograms for each employee exposed at or above the action level must be obtained at least annually. These audiograms will then be compared to the baseline to see if there has been any changes in the employees hearing. The standard threshold shift comes into play when there’s a change in the hearing threshold relative to the baseline audiogram of an average of 10 dB or more at 2000, 3000, and 4000 Hz in either ear. If it has been determined that an employee experienced a standard threshold shift controls need to be implemented to reduce the employees exposure to 85 dBA or lower.

Fall Protection Question

2011-06-30T14:31:00.001-04:00

Q. Do you have to have fall protection on while working from a portable ladder?

A. No: See OSHA's Standard Interpretation

OSHA’s Multi-employer Citation Policy

2011-06-30T11:28:00.000-04:00

Q. We are working on a roofing project and wanted to know who is responsible to make sure the contractor is in compliance?

A. They are both responsible. Click here for more information

If you are looking for help with your company's safety program, please visit our website: lancastersafety.com

Ladders

2011-06-30T11:06:00.003-04:00

Q. I have a ladder 103" platform to platform. Does OSHA require this ladder to be caged? What is the required distance between the platform and the bottom of a ladder cage?

A. The answer to your fist question is OSHA’s standard 29 CFR 1910.27(d)(1)(ii) states that cages or wells (except as provided in subparagraph (5) of this paragraph) conforming to the dimensions shown in figures D-7, D-8, and D-9 shall be provided on ladders of more than 20 feet to a maximum unbroken length of 30 feet. If you click on this link it will take you to an interpretation that deals with this requirement: click here

The answer to your second question is 29 CFR 1910.27(d)(1)(iv) states that cages shall extend down the ladder to a point not less than 7 feet nor more than 8 feet above the base of the ladder, with bottom flared not less than 4 inches, or portion of cage opposite ladder shall be carried to the base.

Storing Oxygen Cylinders

2011-06-30T11:03:00.001-04:00

Q. Can empty and full oxygen tanks be stored together without fire wall?

A. Empty and full cylinders of oxygen can be stored together as long as they are either separated from all fuel-gas cylinders by either 20 feet or a noncombustible barrier (fire wall).

Chemical Storage

2011-06-30T10:59:00.002-04:00

Q. Can acetylene be stored by propane without the fire wall between them?

A. Propane and acetylene are both considered to be a fuel-gas by OSHA and can be stored together.

Fall Protection Question

2011-06-30T10:25:00.000-04:00

A piece of siding has been damaged and is hanging off the building. They can fix it by accessing a low roof they can walk on but they would need fall protection to work from the roof's edge to repair it. The problem is there is no anchorage/tie off point.

Q. Could we use another employee as a tie off point?

A. No. You would need an anchorage point, a ladder, or lift.