Fixed Ladders

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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.


For more information on buying the proper ladder, please click here.

Recordkeeping

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

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

A: Yes.

Fall Protection

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

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

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

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

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

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

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

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.