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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.