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.