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.

Age of Forklift Driver

Q: How old do you have to be to operate a forklift?

A: The operator must be 18 years of age or older.

The forklift operator must also be trained and certified. If you need forklift training please contact us at 888.403.6026.

Mechanical Equipment on a Low Sloped Roof

Q:  Are there restrictions or requirements regarding the use of gas powered 4 wheel carts on a roof?  The carts would be driven.  The brakes are normally cable drum brakes.  The specific job we are referring to would have 2’ high parapet walls.  Please advise to the perimeter safety requirements.

A:  Since the parapet wall is only 24” high OSHA wouldn’t consider this adequate fall protection.  In order for the parapet wall to meet OSHA’s guardrail requirement of 42” (plus or minus 3”) it would need to be 39-45” high.  If you extend the height of the parapet wall to meet OSHA’s guardrail requirements, you can operate the cart freely on the roof.  That’s assuming the parapet wall fully encompasses the roof and your employees wouldn’t be exposed to an area where the guardrail height wouldn’t be below 39”.

If it’s not feasible to extend the height of the parapet wall, you are allowed to use the cart without fall protection if you are using a warning line and the following provisions are met:

·         1926.502(f)(1)(ii): When mechanical equipment is being used, the warning line shall be erected not less than 6 feet (1.8 m) from the roof edge which is parallel to the direction of mechanical equipment operation, and not less than 10 feet (3.1 m) from the roof edge which is perpendicular to the direction of mechanical equipment operation.

·         1926.502(f)(4): Mechanical equipment on roofs shall be used or stored only in areas where employees are protected by a warning line system, guardrail system, or personal fall arrest system.

·         1926.502(h)(2): Mechanical equipment shall not be used or stored in areas where safety monitoring systems are being used to monitor employees engaged in roofing operations on low sloped roofs.

See the OSHA standard interpretation that explains the use mechanical equipment.

If your company would like experienced OSH consultants answering your safety questions, please contact us today for more information.

Fire Extinguishers in Company Cars

Q: Are fire extinguishers required for employee company cars?

A: Although recommended to be available along with proper training, fire extinguishers are not required for company cars unless the vehicle falls under 1926.601 construction requirements.