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Emergency Showers

Q:  Are there any OSHA requirements that apply to the placement of where we put our safety showers?

A:  OSHA’s regulation regarding emergency showers and eyewash facilities states the following:  1910.151(c) Where the eyes or body of any person may be exposed to injurious corrosive materials, suitable facilities for quick drenching or flushing of the eyes and body shall be provided within the work area for immediate emergency use.

Even though OSHA currently doesn't have specific requirements for the location of the facilities, OSHA does recognize the guidelines set by sources such as the American Standards Institute (ANSI).  ANSI requires that emergency eyewash facilities to take no longer than 10 seconds to reach.  They also state that where a strong acid or caustic is used, the unit should be immediately adjacent to the hazard.  The MSDS for the chemical will also provide guidelines on how corrosive the chemical is and information on drenching facilities.

If you have specific questions about safety issues at your facility, contact us today!

Welding Curtain Use

Q: If employees are working approximately 25 feet from welding operations, is it required that welding curtains be used?

A: OSHA does not give a definitive working distance, but states that proper welding shields or curtains shall be used to protect other workers in the area. (1910.152(b)(2)(iii)). 

Entering a Dumpster

Q: We sometimes have an employee enter the dumpster on the jobsite to rearrange it. What would be the proper protection for this employee?

A: Proper PPE would need to be worn while performing this task. Cut/puncture resistant gloves, safety glasses, steel toes, etc. would need to be worn. Also, since there could be boards that have nails sticking out of them footwear with puncture resistance/steel reinforced soles would need to be worn. If the dumpster is 6 feet or higher and the worker needs to access it when it’s full proper fall protection would be required as well. To eliminate the need for fall protection, a company policy should be put in place that prohibits the worker from accessing the dumpster if the material is less than 42 inches from the top of the dumpster. Ladders can also be used outside of the dumpster if possible.

OSHA Poster In Spanish

Q: Does OSHA require us to hang the OSHA required poster in Spanish?

A: OSHA regulations do not specify or require employers to display the OSHA poster in a foreign language. However, OSHA encourages employers with Spanish-speaking workers to also display the Spanish version of the poster. 

Find out what OSHA requires at your company.

Fall Protection

Q: Is it acceptable to use a scissors lift from an elevated platform that has perimeter openings of 40 inches around the outside of the floor?

A:  Since the wall openings are 40 inches, it is required for workers working from the floor level to have fall protection.  In this case the horizontal lifeline and fall arrest harnesses are acceptable, as long as they are used in the proper form. 

Any employee using the scissors lift will be required to have their fall arrest harness secured and attached until entering the lift because of the 40 inch openings.  When in the lift, the wall structures and the curtain walls must act as a curbing system; that will not allow the lift to reach the edge of the floor, exposing the employees to the risk of driving the lift off the edge. 

This process must be made as safe as possible to ensure that the lift is incapable of driving over the curtain walls that are acting as the curbing system.  If there are any potential hazards that may occur, they must be addressed.  OSHA may be unclear with the use of equipment use from an elevated platform, but OSHA does state under the General Duty Clause that the employer must ensure a safe workplace for the employees.

Safety challenges can come up at any time, trust the OSH consultants at LSCI to help with your company's safety.

Written Program Storage

Q:  Where do we need to keep our written programs - plant or office?

A:  OSHA requires that the manuals are “accessible” to all employees.  So either in the plant or the office would work as long as the employees have access to them.  You may not want to keep them in the office if the office is ever locked while employees are working.  OSHA wouldn't consider them to be accessible in this case.

Forklift Man Basket

Q:  Can we attach a man basket to the forklift? Also, can it be moved while an employee is in it?

A:  OSHA permits the use of personnel platforms on forklifts as long as the manufacture approves it.  You would need to contact the manufacturer of the forklift to see if they permit it’s use.  The manufacturer would also be able to provide you with the new forklift specifications (center of gravity, weight limit, etc.) when using the platform.  Riding on a forklift is not permitted due to the tipping hazard so the employee would need to exit the platform before it is moved.

Workers Compensation

Q: In the state of Texas; Are you required to turn in all OSHA recordable incidents to your workers compensation insurance?

A: OSHA does not require you to report a claim to your workers compensation provider.  However, that is only because it must be evaluated separately form the OSHA recordkeeping process.  The state of Texas requires employers  who carry workers’ compensation insurance to report all known occupational disease and any work-related injuries that result in more than one day of lost time. Employers that fail to meet these requirements commit an administrative violation and may be subject to administrative penalties.

Excavating below the trench box

Q: Are you permitted to dig 1-2 feet below the shoring box in a 4x5 trench?

A: Yes, according to 1926.652(e)(2)(i), you can excavate no more than 2 feet below the bottom of the support system, only if the support system itself can handle and resist the forces calculated for the full depth of the trench and if there are no signs of a loss of soil from below or behind the support system.

Get all your safety questions answered by our experienced OSH consultants, learn how today at lancastersafety.com 

Aerial Lifts

Q: Is it acceptable to tie off inside a basket (lift) using a retractable safety cable and harness? 

A: It is a requirement to tie off when using an aerial lift in any form other than a properly guarded scissors lift.  OSHA requirements when using the personal fall arrest system state, when stopping a fall:

(iii) be rigged such that an employee can neither free fall more than 6 feet (1.8 m), nor contact any lower level.  [1926.502(d)(16)(iii)]

Forklift and Aerial Lift Certifications

Q: How often do the men need to be certified to operate rough terrain forklifts and aerial lifts?

A:  Forklift operators need to be re-certified every 3 years or more frequently if any of the following conditions occur:

·The operator has been observed to operate the vehicle in an unsafe manner

·The operator has been involved in an accident or near-miss incident

·The operator has received an evaluation that reveals that the operator is not operating the truck safely

·The operator is assigned to drive a different type of truck; or

·A condition in the workplace changes in a manner that could affect safe operation of the truck.

OSHA doesn’t have a specific frequency for aerial lift training.  Training must be completed initially and when/if any of the following conditions occur:

·An accident occurs during aerial lift use,

·Workplace hazards involving an aerial lift are discovered, or

·A different type of aerial lift is use

Contact us today to get re-certified!

Recordkeeping

Q: If a physician removes a splinter, is it recordable?

A: This case would not be recordable if the physician solely performed first aid and did not issue a prescription, recommend days away from work or light duty, or perform medical attention.

Reporting Injuries

Q: Do I need to report injuries/illnesses to OSHA?

A: You do not need to report ordinary injuries/illnesses to OSHA.  In the event of a work-related death or hospitalization of 3 or more employees, you must call OSHA within 8 hours of the incident at 1-800-321-OSHA.

Forklift Man Baskets

Q: Are man baskets allowed by OSHA?

A: Forklift man baskets are allowed by OSHA as long as you use them the correct way the manufacture designed them to be used.  When employees are inside the man basket they need to have a fall arrest harness on and tied off with a lanyard to ensure they cannot be ejected.

Stilts

Q: Does OSHA permit the use of stilts when doing drywall and taping?

A: Stilts are permitted, but make sure the working area is clean and free of tripping hazards. Also, if you are working in an area that has guardrails you will need to add extra protection to ensure the employees on stilts cannot fall over the top of the guardrail. 

Abrasive Blasting

Q:What are the PPE requirements when abrasive blasting?

A: 1910.94(a)(5)(ii) Abrasive-blasting respirators shall be worn by all abrasive-blasting operators:

1910.94(a)(5)(v) Operators shall be equipped with heavy canvas or leather gloves and aprons or equivalent protection to protect them from the impact of abrasives. Safety shoes shall be worn to protect against foot injury where heavy pieces of work are handled.

1910.94(a)(5)(v)(b) Equipment for protection of the eyes and face shall be supplied to the operator when the respirator design does not provide such protection and to any other personnel working in the vicinity of abrasive blasting operations. This equipment shall conform to the requirements of 1910.133.

Also don’t forget hearing protection!

Abrasive Blasting

Q: What are the exit requirements regarding fire and blasting booths?

A: 1910.94(a)(3)(i)(e)(1) Doors shall be flanged and tight when closed.

1910.94(a)(3)(i)(e)(2) Doors on blast-cleaning rooms shall be operable from both inside and outside, except that where there is a small operator access door, the large work access door may be closed or opened from the outside only.

1910.94(c)(3)(ii) Unobstructed walkways shall not be less than 6 1/2 feet high and shall be maintained clear of obstruction from any work location in the booth to a booth exit or open booth front. In booths where the open front is the only exit, such exits shall be not less than 3 feet wide. In booths having multiple exits, such exits shall not be less than 2 feet wide, provided that the maximum distance from the work location to the exit is 25 feet or less. Where booth exits are provided with doors, such doors shall open outward from the booth.

To help paraphrase, you must ensure your doors are flanged and tight when closed.  The doors must open outward from the booth.  These doors need to be installed one every 25 feet or less.  If you have multiple doors the doors only need to be 2 feet wide, but if you only have one door that door needs to be at least three feet wide.

Certification for gloves

Q:  We recently purchased gloves are that are rated to 300 degrees.  They are not certified by a 3^rd party.  Does OSHA require gloves to be approved by ANSI?

A:  OSHA requires eye/face, head, and foot protection to meet certain ANSI standards, but not hand protection.  The certification from the manufacturer stating that the gloves are rated to 300 degrees will be what you need.  We recommend that you request the manufacture includes the type of test they performed to determine this rating on the document they provide to you.

Recordkeeping

Q: Do I need to keep the OSHA 300A – Summary up to date throughout the year?

A: No, there is no need to fill out the 300A – Summary until January of the following year.

Leading Edge Work

Question:  When installing plywood decking on a suspended concrete slab that is 13 feet high; is fall protection required?

Answer: Yes fall protection is required unless you can prove that fall protection is infeasible or creates a greater hazard than the fall protection systems.  Listed below is the OSHA standard that explains this.

·         1926.501(b)(2)(i) Each employee who is constructing a leading edge 6 feet (1.8 m) or more above lower levels shall be protected from falling by guardrail systems, safety net systems, or personal fall arrest systems. Exception: When the employer can demonstrate that it is infeasible or creates a greater hazard to use these systems, the employer shall develop and implement a fall protection plan which meets the requirements of paragraph (k) of 1926.502.

Note: There is a presumption that it is feasible and will not create a greater hazard to implement at least one of the above-listed fall protection systems. Accordingly, the employer has the burden of establishing that it is appropriate to implement a fall protection plan which complies with 1926.502(k) for a particular workplace situation, in lieu of implementing any of those systems.

We recommend using temporary anchorage points!  These are simple to use and can be installed into concrete or wood.  The use of these anchorage points with either a retractable lifeline with a personal fall arrest harness or a horizontal life line and personal fall arrest harness will ensure you’re in compliance with OSHA!

Electrical Cord Repair

Q: If the prong is damaged on an extension cord, is it permissible to replace the prong with an approved one, provided the repair is done by a qualified electrician?

A: Yes, OSHA states “Extension cords used in construction may be repaired, so long as the repair returns the cord to the "approved" state required by 1926.403(a)”

Eyewash Distances

Q: We don’t handle any corrosive chemicals and only have an eyewash station as an emergency precaution when grinding and other tool use. What is the required distance?

A: OSHA only requires the eyewash station to be immediately adjacent when working with corrosive chemicals. In any other case it is recommended to have the eyewash station as close as possible.

Recordkeeping

Q:  When counting days away from work or light duty, do I count work days or calendar days?

A: You want to count all calendar days that the employee is off, up to 180.

Find recordkeeping tools at our website!

Recordkeeping

Q: If we are working 2 weeks on and then 2 weeks off, do we need to record the two weeks off for an injured employee?

A: Yes, the case needs to be recorded for each of the days that he is away from work including the 2 off weeks even though the rest of the company is also not working those days. 

E-stops Testing

Q: Are you required to test e-stops, if so what frequency?

A: There is no direct regulation, however it is a good company practice. It would be recommended for testing to be conducted weekly, monthly, or at most quarterly. 

Flammable Liquid Inside Storage

Q: How many drums of our resin, which is a class III flammable substance, are we allowed to store inside?

A: The quantity of liquid that may be located outside of an inside storage room or storage cabinet in a building or in any one fire area of a building shall not exceed 120 gallons in containers or 660 gallons in a single portable tanks. The direct regulation can be found here, 1910.106(e)(2)(ii)(b). 

Eye Wash Station

Q: Can a portable eye wash station have the solution off to the side to preserve shelf life?

A: It is recommended that in any portable eye wash station that must be filled manually with solution to have it filled with the solution. This is so that if an employee does have something in the eyes they don’t have to first fill the station before using it.

Stair Railings

Q:  Does OSHA require stair railings to be installed when the stairs have 4 risers or 4 steps?

A:  OSHA requires stairs with 4 or more risers to be equipped with a stair railing or handrail.

Make sure you're company is also trained on OSHA's fall protection requirements.

PPE For Changing Forklift Battery

Q: Is there any specific PPE that is required for changing/checking a forklift battery?

A: It is recommended that vinyl-coated, PVC, or gauntlet-type gloves with a rough finish are worn, also chemical splash goggles or face shield, safety shoes and an apron. Though OSHA does not require these items to be worn, they would have you refer to the individual MSDS and commonly the items stated above are the minimal required items.

Drug Testing

Q: We have suspicion that one of our subcontractor's employees is using drugs while working on our jobsite.

A: If the employee is a subcontractor working on your site you can require drug testing such as pre-employment, random, post-accident, etc. 

Fire Extinguisher’s on Forklifts

Q: What would be your recommendation for fire extinguishers on forklift trucks; is this mandatory by OSHA?

A: If the forklift comes from the manufacturer with a fire extinguisher then it must be properly maintained and inspected. If it does not come with one then it falls under OSHA’s fire extinguisher regulation. Whether it is fueled by propane, gas/diesel, or battery then it would be considered a Class B fire hazard and is required to be within 50 feet of a fire extinguisher at all times. If the forklift is operated outside of the 50 foot travel distance then it is recommended that one be mounted on the forklift. Lastly, all modifications and additions to forklifts need to be approved by the manufacturer.

To see if your facility is OSHA compliant, contact LSCI to set up a mock OSHA inspection.

Storing Oxygen and Acetylene

Q: What are the requirements for storing oxygen and acetylene tanks inside a building?

A: Inside of buildings, cylinders shall be stored in a well-protected, well-ventilated, dry location, at least 20 (6.1 m) feet from highly combustible materials such as oil or excelsior. Cylinders should be stored in definitely assigned places away from elevators, stairs, or gangways. Assigned storage spaces shall be located where cylinders will not be knocked over or damaged by passing or falling objects, or subject to tampering by unauthorized persons. Cylinders shall not be kept in non-ventilated enclosures such as lockers and cupboards.  (1910.253(b)(2)(ii))

Stickers on Hardhats

Q: Is there a regulation or standard that states a company may not apply stickers to a hard hat?

A: No there is no regulation or standard stating that but one thing that you want to ensure is that the sticker being applied will not affect the shell of the hardhat. Some stickers contain adhesives that may break down the outer shell and reduce the original protection rating. It is recommended to keep the stickers to a minimum so you can always see the shell and ensure that it is still in good condition.

Forklift Train-the-Trainer Certifications

Q: Do the train-the-trainer certifications received by two of our employees have an expiration date, or a time frame in which they have to get re-certified?

A: No, the train-the-trainer certification does not have an expiration date. However, if the certified employees are also operators, then they would need to be re-certified every three years. You can also do a refresher training as time progresses.

OSHA & Labor Law Posters

Q: Do I need to post a new OSHA poster and Labor Law poster each year?

A: The OSHA poster does not need to be updated annually.  The labor law posters do need to be updated annually.

Common Cleaners

Q: Do I need an MSDS for common cleaners?

A: It is a good idea to have them readily available.  However, an MSDS is not required as long as the cleaners are used in the workplace for the purpose intended by the chemical manufacturer or importer of the product, and the use results in a duration and frequency of exposure which is not greater than the range of exposures that could reasonably be experienced by consumers when used for the purpose intended  (1910.1200(b)(6)(ix))

MSDS

Q: Do I need a separate MSDS for each type of paint that is in their maintenance office.

A: Yes, the MSDS for each paint needs to be readily available.

Audiometric testing

Q: We have conducted yearly audio testing since we were cited by OSHA in 2007, do we need to continue?
 

A: As long as employees are still exposed to noise levels above 85 dBA for an 8-hr time-weighted average then you need to continue the baseline audiograms for new employees and annual audiograms for those employees already in the hearing conservation program.

Confined Space

Q: Are you allowed to have employees working in two separate confined spaces at the same time but with only one full set of rescue equipment?

A: No. Adequate rescue equipment needs to be provided for each confined space during entry. If both spaces needed to be entered at the same time then an additional set of rescue equipment would be required or you could rely on outside sources for rescue.

Working Unsupervised

Q: As a company, are you permitted to have only one employee working in the facility at a time?
A: It is not an OSHA requirement, but it is highly recommended that someone else be present for supervision or if there was an incident.

See how your facility would do during an OSHA inspection.

Evacuation Drawings

Q: Where should we hang our evacuation maps?

A: By all the main exits and fire extinguishers. 

  

Be prepared in the event of an emergency, find out how.

Lanyard Specifications

Q:  What is the fully open length of a 6' lanyard after its activated?  We are quoting a job with 10'6" floor to floor, they are saying we cannot tie to the beams, because the lanyard + activation added length + the body length is more than 10'6".  Do they make a 4' or 5' lanyard ?
A:  You usually add on an additional 3 feet to the length of a lanyard when it is activated.  OSHA and the fall protection manufacturers take 4 different lengths into consideration when they determine the safe fall distance:  the height of the wearer, the length of the lanyard, the 3 feet activation length, and a safety factor of 3 ½ feet. A 6’ tall person wearing a 6’ lanyard would need to be able to attach the lanyard at least 18 ½’ above the lower level. 

If you have safety questions you'd like us to answer, find out more about our services at our website.

Recordkeeping

Q: What do I need to do if we didn’t have any recordable injuries in 2012?

A: Complete the 300 log and the left portion of the 300A with zeros.  Fill the right side (company information) of the 300A completely, have the highest ranking company official sign and date it, and post it in an area where information is usually conveyed to employees.

Post a copy of the annual recordkeeping summary (OSHA’s Form 300A) from February 1-April 30 in an area where company postings are usually kept.