Safety Vest

Q:  Should we require employees to wear safety shirts in the manufacturing shop?

A:  Safety shirts are only required in traffic areas, such as on site in the field.

Forklift

Q: Can you attach a man basket on a forklift that is manufactured by a different company?

A: You must have the manufactures approval when using any attachment on the forklift.  It will vary forklift to forklift, so you will need to contact the forklift manufacture for an answer.

Authorized Personnel

Q: I have a silo with a wraparound fixed staircase.  The staircase has proper railings.  The question is, if I have a locking gate on the entrance to the staircase and signage posted so only authorized personnel can enter, is this compliant?

A: OSHA does not have a specific standard on this.  This is more of a liability issue, but with the locking gate and signage it shows you are taking the proper measures to keep unauthorized people out.

Forklifts

Q: Do the fork extensions have to reach to the other side of the load?

A: OSHA states in “1910.178(o)(5) A load engaging means shall be placed under the load AS FAR AS POSSIBLE; the mast shall be carefully tilted backward to stabilize the load.” 

Also keep in mind that you do not exceed the forklifts manufactures load capacity.

Online First Aid/CPR Training

Q:  Is online First Aid and CPR training accepted by OSHA?

A:  Generally, online CPR and/or First Aid training is not recommended. However, as long as the students are able to demonstrate that they understand the training and know how to properly perform CPR and First Aid, it should be considered acceptable.

Recordkeeping

Q:  An employee rolled his truck on his way to a job this morning.  He appears to be OK, but was sent to the hospital for X-rays.  Is this recordable?

A:  If there is medical attention beyond first aid or lost/restricted work days, it needs to be added to their logs. The X-rays are not considered recordable since they are a diagnostic procedure. OSHA does not consider diagnostic procedures a form of medical treatment.

Recordkeeping - Returning To Work

Q:  How do I handle a case when a physician or other licensed health care professional recommends that the worker return to work but the employee stays at home anyway? 

A:  1904.7(b)(3)(iii) - In this situation, you end the count of days away from work on the date the physician or other licensed health care professional recommends that the employee return to work.

Recordkeeping

Q:  If the physician issues a prescription, but it is not filled, is this recordable? 

A:  Yes, OSHA considers that medical treatment is provided once a prescription is issued.

Flame Resistant Clothing

Q: Can you wear Tyvek suits over FRCs? 

A: They are not made to be flame resistant.  They do make chemical resistance FRCs, that would be a better choice of PPE.

Flame Resistant Clothing

Q: If Fire Resistant clothing is required to be used along with other PPE such as gloves a fall arrest harness, etc., does the additional PPE also have to be flame resistant?

A: This link will take you to a memo that was released by OSHA to clarify OSHA’s policy for issuing citations for flame resistant clothing (FRC).  Since fall arrest harnesses are not specifically mentioned in the memo, OSHA would have a hard time issuing a citation for it.  Even though they are not currently required, flame resistant fall arrest harnesses are available for purchase online.

PPE Needed For Refueling Equipment

Q: What PPE does OSHA require when refueling equipment that runs on gasoline, diesel or kerosene?

A: OSHA relies on the employer to determine the PPE needs based on the hazard that the employees are exposed to. In this case, the Material Safety Data Sheets for the fuels need to be reviewed to determine the needed PPE.

Working Near Power Lines

Q: How close can you get equipment for drilling to a live power line?

A: Under OSHA 1910.333 standard for voltages to ground 50kV or below you can get within 10 feet.  For voltages to ground over 50kV you would need to be 10 feet away plus 4 inches for every 10kV over 50kV.

Respiratory Protection

Q. What are the requirements for voluntary use of respirators?  

A. The following is necessary (1) medical clearance; (2) provide employees with information in Appendix D of the OSHA respiratory standard; (3) ensure that respirators are cleaned, stored, & maintained so that they do not present health hazards to users.  

To learn more about OSHA compliance look to the experienced consultants at Lancaster Safety Consulting, Inc.

Alarm Pull Stations

Q. Are alarm pull stations required to be located at every door?  

A. The location & number of pull stations were not specifically covered by OSHA, but by building/fire codes administered by each state’s Department of Labor & Industry.   Location & number of pull stations would be determined by sprinkler coverage & building class.  See OSHA’s alarm standard (29 CFR 1910.165). 

Damaged Cord

Q: Is it acceptable to cut the end off of a damaged cord and replace it with a new plug?

A: OSHA will allow this type of repair as long as the plug is replaced with an “approved” plug (i.e., by a testing laboratory such as factory mutual, underwriters laboratories, etc.). 

Using Tape To Designate Floor Areas

Q: We would like to use colored tape or paint on our floors to designate areas that are to be kept clear.  Is there a specific color that we need to use?

A: OSHA specifies that permanent aisles and passageways shall be appropriately marked; however it does not specify a color for floor markings.  While the standard does not specifically mandate colors to be used on accident prevention tags, the following color scheme is recommended by OSHA for meeting the requirements of this section:

• "DANGER" - Red, or predominantly red, with lettering or symbols in a contrasting color.
• "CAUTION" - Yellow, or predominantly yellow, with lettering or symbols in a contrasting color.
• "WARNING" - Orange, or predominantly orange, with lettering or symbols in a contrasting color.
• "BIOLOGICAL HAZARD" - Fluorescent orange or orange-red, or predominantly so, with lettering or symbols in a contrasting color.

Recordkeeping

Q: An employee developed a blister on his foot, and after time this blister got infected.  The employee went to the doctors to get the checked out.  The doctor then issued a prescription to the employee.  Is this a recordable incident?

A: Yes, this is a recordable incident because a prescription is considered more than first aid.

Learn more about OSHA compliance.