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.