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.

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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.

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