Arc Flash

Q: Is it acceptable to use alternative personal protective protection when applying ‘the table method’ to protect employees from arc flash hazards?

A: Unless you can prove through arc flash analysis data that the PPE will provide sufficient protection, it is not recommended.

Arc Flash

Q: Where can I find reference material for arc flash?

A: The two best sources are the NFPA 70E (available for a fee at www.NFPA.org) and OSHA 1910 Subpart S standard (available for no cost at www.osha.gov).

Recordkeeping

Q: An employee was injured in 2011 and will be away from work for >180 days.  Do I have to put this on my 2012 log in addition to 2011?

A: The injury should only be counted in the year that the injury occurred.  All 180 days should be counted in 2011.

Fall Protection at Loading Docks

Q:  We would like to know if you have the OSHA requirements necessary for our loading dock area for a rail or barrier. We are in the midst of having our chains replaced with a more secure barrier. Our loading dock is about 5’ off the ground. Any information would be great.

A:  You’ll want to make sure the new barriers that you install meet the following criteria:

• Top rail at 42 inches in height and capable of withstanding 200 lbs of outward and downward force.  
• Midrail at 21 inches in height.

I’ve seen some facilities use 2x4 boards for these barriers.  They install brackets on the inside of the door that hold the boards.  They are then able to lift the boards out of brackets with ease in order to use the dock.  This seems to be a sturdy solution for a removable barrier at the dock.  This is just a suggestion as I’m not sure if this would work for your application. 

Battery Charging PPE

Q: We have forklifts and power floor sweepers that operate off of batteries.  We have an eyewash station in the charging/changing area, but what types of PPE should we require?   
A: Goggles, face shields, aprons, and rubber gloves need to be worn while handling the batteries.  Refer to the MSDS of the battery acid to determine the type of rubber gloves/aprons that need to be worn.

Scissor Lift Training

Q:  Does OSHA have specific training requirements for scissor lifts?

A:  Since scissor lifts are covered under OSHA’s scaffolding trainings there are no specific training requirements.  However, under the general duty clause it would be the employer’s responsibility to ensure all operators are competent and authorized to operate the lift.  

Contact us for more information on OSHA training. 

Fixed Ladders

Q: If you have a fixed ladder with a cage or well around it would you also need to have a safe access hatch?

A: This would actually fall under the 1910.23 (Guarding floor and wall openings and holes standard) instead of the 1910.27 (Fixed ladder standard).  If there is a potential that the employee can free fall 4 or more feet the fixed ladder will need a safe access hatch. 

First Aid Kit

Q:  What are your recommendations on the size of  kit, contents required, and maintenance of the first aid kits on monthly or quarterly basis?

A:  OSHA’s regulation states that in the absence of an infirmary, clinic, or hospital near the workplace, a person or persons must be adequately trained to render first aid.  Adequate first aid supplies must be readily available.  Appendix A to 1910.151 (first aid requirement) is a non-mandatory guide for the contents of first aid kits.   OSHA uses ANSI’s Minimal Requirements for Workplace First Aid Kits as an example of the minimum contents for a generic kit. 

OSHA does specify that this is only the minimal requirement, and employers who have unique or changing first-aid needs in their workplace may need to enhance their first aid kits.  Also, if it is reasonably anticipated that employees will be exposed to blood or other potentially infectious materials while using first aid supplies, employers are required to provide appropriate PPE.  Purchasing a bloodborne pathogens kit or emergency first responder kit to go along with your first aid kit is also recommended.

Accident Investigation

Q: How long should accident investigation documents be retained?

A: OSHA does not specify how long to retain these documents.  OSHA 300 logs must be retained for a period of 5 years, so it is a good idea to retain the accident investigation documents for the same period of time.

LOTO Requirements

Q:  We purchased a deluxe lock out/tag out kit.  Does this have to be in a place for everyone to see, or can we keep it in the office and advise everyone where it is?  Maybe post a signs where to locate it.

A: To answer your question it does not have to be in a place where everyone can see it.  However, it does need to be in a place that all of the Authorized Lo/To Personal know where it is, and that they can access it at all times.  For example, you don’t want to keep it in an office that could be locked and the Authorized Personal would not be able to access it.