Recordkeeping

Q: Do we have to send our 300 logs to OSHA every year?

A: No, not unless you receive a letter from OSHA/DOL requesting them.  For more information on recordkeeping requirements please click here or contact us.

OSHA 1910 First Aid Standard

Q:  What is the definition of “near proximity” used in the OSHA first aid standard 1910.151(b)?

A: The term "near proximity" that is contained in the first aid standard, means the facility or jobsite must be 4 minutes away from a first responder or medical facility to treat the injured employee. If the facility or jobsite isn’t within a 3-4 minute time frame of a first responder, or drive time, than you are required to have an employee on-site that is capable of performing first aid duties (must be certified).

If you need to have your employees trained in first aid/CPR/AED, please contact LSCI by clicking this link.

Geronimo Line on a Drilling Rig

Q: Where is the proper location to place a Geronimo Line on a drilling rig?

A: The location varies rig to rig where the line must be located. But there are a few helpful guidelines for the proper set up of a Geronimo line that come from the American Petroleum Institute (API) RP-54 Standard:

The escape line should be kept clear of obstructions.

• The escape line needs to be a wire rope of a minimum diameter of 7/16” in good condition.
• Tension on the line should be periodically checked and adjusted to enhance safe landing of the user.
• Tension should be set up with 6 to 12 feet of sag in the middle, depending upon the length of the cable.
• It is recommended that the ground anchor point of the escape line should be located a minimum lateral distance from the derrick or mast equal to two times the height of the work platform.

Welding

Q: Employees were welding on Hastelloy (Nickel based) and it’s moving more towards a production level. Do they need to be wearing respirators?

A: Yes, employees do have the potential for exposure to Hex Chrom, and you should conduct air monitoring. Please click here for more information.

Welding in a Confined Space

Q: We have a weld joint that needs to be “fused” after machining.  The welder reaches into a 16” opening about 18” deep and welds this circumferential weld.  His feet never leave the floor; but his head is in the opening.  Based on OSHA’s definition of “entry” do we need to be concerned about this being considered a confined space?

A: Per 1910.146(b) "Entry" means the action by which a person passes through an opening into a permit-required confined space. Entry includes ensuing work activities in that space and is considered to have occurred as soon as any part of the entrant's body breaks the plane of an opening into the space.

Needle Stick Injury

Q: Do needle sticks need to be recorded on the OSHA 300 log if the source was negative or if the source was positive and the employee did not develop disease?

A: Yes, all work-related needle stick injuries and cuts from sharp objects that are contaminated with another person’s blood or other potentially infectious material must be recorded as an injury.  29 CFR  1904.08 

Forklift License

Q: Does an employee need a valid drivers license to operate a forklift?

A:  The employee is required to be trained and certified to operate the forklift in the workplace.  Training and certification shall be documented.  An operators performance shall be evaluated every 3 years.