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.