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.

Sling Tags

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

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

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.