LOTO Requirements

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

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

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

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

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

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

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

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

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

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.